The Bill introduces a defined set of concepts that govern the transitional regime. Key defined terms are in s 464: "CTSCo" (Carbon Transport and Storage Corporation Pty Ltd), "relevant GHG well" (a GHG well that, immediately before former EPQ10 ended, was in the former EPQ10 area), "decommissioning day" (the last day before which decommissioning must occur under section 267(1)(b) as modified), "conversion certificate", "conversion plan", "licensed water bore driller" (class 3 under the Water Act), "water bore construction codes" (two specified documents published on a Queensland Government website), "landowner" (owner of the land where the well or bore sits), "water supply bore" (artesian or subartesian bore primarily used to supply water), "former EPQ10" (the permit ended under section 454), "GAB Water Plan" (the specified Water Plan 2017), and "Water Act regulator" (chief executive administering Water Act chapter 2).

The concept of an alternative to decommissioning is central. Section 465 states the purpose of the transitional part: to permit CTSCo to convert relevant GHG wells into water supply bores and transfer them to landowners, as an alternative to decommissioning under section 267, and to make provision for how a relevant GHG well is to be plugged and abandoned for s 267(3)(a).

The Bill differentiates between a "decommissioned GHG well" (one already decommissioned before commencement) and other relevant GHG wells. If CTSCo complies with a set of procedural, technical and timing requirements before the decommissioning day, section 267(1) (the statutory decommissioning obligation) does not apply to that well (s 467(1)). If the conversion pathway is not completed, the Bill reimposes modified plugging and abandonment duties and requires plugging and abandonment be done "in the way prescribed by transitional regulation" (s 467(2)). The Bill therefore relies on subordinate instrument detail to define technical standards and notice contents (see multiple uses of "prescribed by transitional regulation" in ss 467, 474, 477 and elsewhere).

The Bill ties the conversion pathway into other regimes. Conversion works are declared water bore drilling activities under the Water Act (s 470), are treated as accepted development for planning purposes (s 471), and interact with the GAB Water Plan and Water Act licensing mechanisms (s 479). The statutory mechanics of ownership and regulatory responsibility change on transfer: on transfer to the landowner, ownership of infrastructure passes to the landowner and the bore ceases to be a GHG well for the Act (s 475(1)(a)-(b)), but the transfer does not itself authorise taking water (s 475(3)). The Bill also modifies post‑decommissioning responsibility by applying section 269(3) and (4) despite section 269(1) where relevant wells are decommissioned on or after the decommissioning day (s 468).

Two further concepts bear emphasis. First, the Bill insulates the State from compensation claims in relation to the transitional part (s 481). Second, it creates a time-limited regulation power (s 483) allowing detailed procedural and technical matters to be prescribed and, notably, may be exercised retrospectively to commencement, with the transitional provisions and regulations expiring on 18 June 2029.

The Bill distributes obligations, choices and rights across a small set of public and private actors. Primary affected parties are:

• CTSCo (Carbon Transport and Storage Corporation Pty Ltd). The company is the designated actor able to elect the conversion pathway and bears most of the administrative and operational duties: giving notices to the Minister (s 467(1)(a), (e)), arranging conversion works and certificates by a licensed water bore driller (s 467(1)(c)-(d)), transferring the bore to the landowner within 40 business days (s 467(1)(f) and Div 5), preparing conversion reports (s 477(1)), and in some circumstances plugging and abandoning wells in a way prescribed by transitional regulation if conversion is not completed (s 467(2)). CTSCo also retains certain rehabilitation obligations after decommissioning and transfer to the State (s 482).

• Landowners. Defined in s 464 as the owner of the land hosting the relevant GHG well or water supply bore, landowners must sign and give CTSCo a statement consenting to conversion, stating intended water-use purpose, and agreeing to accept ownership and responsibility for the bore after conversion (s 467(1)(b)). Once transferred, landowners assume ownership of infrastructure and regulatory responsibilities under other Acts (s 475(1)(a), (c)), but the transfer does not itself authorise taking water (s 475(3)).

• Licensed water bore drillers. Only a licensed water bore driller (class 3 under the Water Act) may perform the conversion and must sign a conversion certificate that conversion has been completed in accordance with the conversion plan and prescribed requirements (s 467(1)(c)-(d)). The conversion plan must be approved and signed by such a driller (s 467(4)).

• The Minister and chief executive. The Minister receives CTSCo’s notice of intention and completion notices (s 467(1)(a), (e)), may fix days relevant to decommissioning timing (relevant day in s 466(3)(b)), and is the administrative point for the end of tenure report (s 466). The chief executive receives notices of transfer and conversion reports and must forward copies to the Water Act regulator within prescribed days (ss 474-477).

• Water Act regulator. Defined as the chief executive administering the Water Act chapter 2, this regulator receives copies of transfer notices and conversion reports (ss 476, 477), and must grant, within 60 business days, a water licence to the landowner to take water for stock purposes where the regulator considers the landowner will take water for stock (s 479). The regulator administers Water Act licensing consequences of the transfer and conversion.

• Other regulatory regimes. The Planning Act 2016 and the GAB Water Plan are engaged: conversions are treated as accepted development under the Planning Act (s 471), thereby affecting planning assessment responsibilities, and the GAB Water Plan provisions are modified for the purposes of granting stock licences and deemed drilling dates (s 479).

Indirectly affected parties include future buyers of the land (s 478 limits transfers of converted bores by CTSCo), users of regional groundwater (via new bores entering the GAB regime), and insurers or financiers with interests in CTSCo infrastructure or liabilities. The Bill also affects the State by clarifying no compensation is payable for enactment or operation of the transitional part (s 481), and it changes potential State ownership and responsibility where s 269(3) and (4) are applied (s 468).

The Bill creates a structured set of duties and conditional rights tied to the conversion alternative.

Duties on CTSCo

• Notice of intention: CTSCo must give the Minister a notice of intention to convert a relevant GHG well, complying with requirements prescribed by transitional regulation, and the notice must be accompanied by a conversion plan (s 467(1)(a)).
• Landowner consent: CTSCo must obtain from the landowner a signed statement consenting to conversion, stating intended water use, and agreeing to assume ownership and responsibility post-conversion (s 467(1)(b)).
• Conversion works: CTSCo must cause conversion works to be carried out by a licensed water bore driller in accordance with requirements prescribed by transitional regulation and water bore construction codes (s 467(1)(c); definition of water bore construction codes in s 467(4)).
• Conversion certificate: CTSCo must secure a conversion certificate signed by a licensed water bore driller, certifying that conversion has been completed in accordance with the conversion plan and prescribed requirements (s 467(1)(d)).
• Notices and timing: Within 10 business days after the conversion certificate is signed, CTSCo must give the Minister a notice of completion in the form prescribed by transitional regulation; within 40 business days after signing the conversion certificate CTSCo must transfer the water supply bore to the landowner under Division 5 (s 467(1)(e)-(f); ss 474-475).
• Conversion report: Within 60 business days after signing the conversion certificate, CTSCo must give the chief executive a conversion report complying with transitional regulation requirements; failure attracts a maximum penalty of 100 penalty units (s 477(1)).
• Continued obligations where conversion not completed: If conversion is not completed, CTSCo remains subject to section 267 as modified and may be required to plug and abandon the well in the manner prescribed by transitional regulation (s 467(2), s 472).

Duties on the Minister and chief executive

• Receipt and record-keeping: The Minister and chief executive are recipients of notices and reports; the chief executive must provide copies to the Water Act regulator within set timeframes (ss 476-477).
• Administrative timeframes: The chief executive must, within 30 business days of receiving a notice of transfer, give a copy to the Water Act regulator (s 476(1)); the chief executive must forward CTSCo’s conversion report to the Water Act regulator within 30 business days (s 477(2)).

Duties on the Water Act regulator

• Grant of water licence: If the Water Act regulator receives the copy of the notice of transfer and considers the landowner will use the bore for stock, the regulator must grant a water licence within 60 business days, with or without conditions; but the licence must not allow taking water unless a watertight delivery system exists (s 479(1)-(3)).
• Planning and Water Act integration: For the GAB Water Plan, the bore is treated as drilled after the commencement of the Plan in relation to certain provisions, and certain plan divisions do not apply to the licence grant (s 479(4)-(6)).

Rights and effects on landowner

• Consent and ownership: The landowner’s signed statement is a precondition; upon transfer under s 474, ownership of all infrastructure and equipment transfers to the landowner and the bore ceases to be a GHG well for the Act (s 475(1)(a)-(b)).
• Regulatory obligations: The landowner assumes responsibility for the bore under any other applicable Acts or laws (s 475(1)(c)), but the transfer itself does not authorise water-taking until appropriate Water Act processes are concluded (s 475(3)).

Other rights and constraints

• Right of entry: Section 459, as modified by s 469, gives CTSCo a right of entry to facilitate conversion or plugging and abandonment. Section 482 creates a limited post‑transfer right of entry for CTSCo to comply with specific rehabilitation conditions even after the well is decommissioned and transferred to the State under s 269(3).
• Transfer restrictions: CTSCo cannot transfer a converted bore to anyone other than the landowner (s 478).
• No compensation: Section 481 declares no compensation payable by the State for the enactment or operation of the transitional part.

Many procedural and substantive particulars are deferred to transitional regulation; multiple duties referenced in the Bill are required to comply with matters "prescribed by transitional regulation" (see ss 467, 474, 477). The delegated regulation power thereby becomes material to the precise content of duties and rights.

The Bill contains a limited set of explicit penalties and a number of enforcement mechanisms or constraints that affect how compliance is compelled and what occurs on non‑compliance.

Express penalty

• Conversion report: Section 477(1) imposes a maximum penalty of 100 penalty units where CTSCo fails to give the chief executive a conversion report within 60 business days after the conversion certificate is signed. This is the only penal sanction expressly contained in the inserted Part 8.

Administrative enforcement and consequences

• Continuation of decommissioning obligations: If CTSCo does not fully satisfy the conversion pathway requirements before the decommissioning day (s 467(1)(b)-(f)), section 267, as modified by sections 456 and 467(2), continues to apply (s 472(2)). That means statutory decommissioning and related obligations remain enforceable; the Bill expressly keeps the statutory plugging, abandonment and decommissioning regime alive where conversion is incomplete.
• Plugging and abandonment prescribed by regulation: Where section 267(1) applies to a relevant well that is not decommissioned, the Bill requires plugging and abandonment to be carried out as prescribed by transitional regulation (s 467(2)(a)). Enforcement of that requirement will depend on the enforcement mechanisms in the principal Act and any details in the transitional regulations.
• Rights of entry: Sections 469 and the reference to section 459 extend or modify statutory rights of entry so that authorities can enter land to facilitate conversion or plugging and abandonment. Section 482 provides CTSCo with a limited right of entry after decommissioning and transfer to the State to comply with specified rehabilitation conditions. These entry rights are enforcement‑oriented tools that enable regulators or CTSCo (in limited circumstances) to access land to ensure compliance with environmental and rehabilitation conditions.
• Transfer does not invalidate regulatory action: Section 476(2) and section 477(3) both state that failures to comply with the chief executive’s duty to forward notices do not invalidate or otherwise affect the underlying transfer. This preserves the legal effect of transfers despite administrative lapses, reducing the scope for challenge based on procedural forwarding delays.

Restrictions and prohibitions

• Limitation on transfers: Section 478 renders any purported transfer of a converted water supply bore by CTSCo other than the statutory transfer to the landowner of no effect. That is a strict statutory prohibition on alienating converted bores to third parties.
• No compensation clause: Section 481 removes the State’s liability to pay compensation to any person in connection with the enactment or operation of Part 8 or anything done to implement it, and declares the provision applies notwithstanding any other Act or law. That clause curtails compensation-based legal remedies against the State for impacts arising from the transitional regime.

Delegated regulatory enforcement and discretion

• Many material standards and procedural contents are left to "transitional regulation" (s 483) or to requirements "prescribed by transitional regulation" (see ss 467(1)(a), (c), (e), s 474, s 477). The Bill thus centralises specification of technical standards and notification forms in subordinate legislation, which will govern enforceable detail including conversion standards, notice contents and completion validation. The transitional regulation may be retrospective and has an explicit expiry date (s 483(2)-(4)), which raises both operational flexibility and uncertainty about enforcement specifics until the regulations are made.

Overall, the Bill relies on a mix of explicit penalty (limited), statutory continuation of pre‑existing enforcement rights (decommissioning and plugging obligations), rights of entry, and a substantial role for transitional regulations to set out the enforceable technical and procedural standards. The no-compensation clause narrows monetary remedies against the State for the regime’s effects.

The Bill links the Greenhouse Gas Storage Act framework to multiple other statutes and instruments, altering regulatory interactions and procedural pathways.

Water Act

• Conversion works declared water bore drilling activities: Section 470 expressly states that works to convert a relevant GHG well into a water supply bore under Part 8 are water bore drilling activities under the Water Act. That invokes the Water Act’s licensing, technical and occupational regulatory framework for drillers, and requires compliance with water bore construction standards as referenced in s 467(4).
• Water Act regulator and licensing: The chief executive administering the Water Act chapter 2 is defined as the Water Act regulator (s 464). Section 476 requires the chief executive to forward notices of transfer to that regulator within 30 business days. Section 479 obliges the Water Act regulator to grant a water licence for stock purposes within 60 business days where the regulator considers the landowner will take water for stock using the converted bore. The licence must require a watertight delivery system (s 479(3)), and the Bill modifies certain GAB Water Plan processes for these grants (s 479(4)-(6)).

GAB Water Plan

• Section 479 interacts with the GAB Water Plan (2017). It provides that for section 31(2) of the GAB Water Plan the water supply bore is taken to have been drilled after the Plan’s commencement (s 479(4)), and that Part 4 Division 5 of the GAB Water Plan does not apply in relation to granting the water licence (s 479(5)). It also treats the process as being "stated in" the GAB Water Plan for the Water Act section 116(2) purpose (s 479(6)). This produces specific, plan-level exceptions or deeming consequences for converted bores when assessing and granting stock licences.

Planning Act 2016

• Accepted development: Section 471 takes any development involved in conversion that would otherwise be prohibited or assessable development under the Planning Act and treats it as accepted development for the Planning Act 2016. This removes the need for development assessment processes under the Planning Act for those conversion activities that qualify, and thereby shifts planning regulation interaction to an accepted-development pathway.

Primary Act , Greenhouse Gas Storage Act 2009

• Modifications to reporting and decommissioning: Clauses 4 and 5 add notes to sections 455(2) and 456(2) respectively, directing readers to the new transitional provisions (s 466 and s 467). Section 466 modifies the operation of section 256 in relation to CTSCo’s end‑of‑tenure report obligations. Section 467 modifies section 267 so that, where conversion requirements are complied with, section 267(1) does not apply to relevant wells. Section 468 modifies the application of section 269 provisions after decommissioning. Section 469 treats conversion and plugging works as falling within the right-of-entry provision (s 459). The Bill thereby interposes an alternative set of requirements on CTSCo that coexist with, or supplant in certain circumstances, obligations in the principal Act.

Environmental law and environmental authority

• Rehabilitation conditions: Section 482 references "rehabilitation conditions" defined as conditions 58 to 60 of an environmental authority (EA) identified as EPPG00646913 which was ended under the Environmental Protection Act provision referred. The section preserves the application of those rehabilitation conditions to CTSCo despite decommissioning and State transfer, and grants CTSCo a limited right of entry to comply with them. This binds the conversion/decommissioning pathway into prior environmental approval conditions.

Other Acts and administrative law

• No compensation and inter‑Act effect: Section 481 declares that no compensation is payable by the State because of enactment or operation of Part 8 "despite any other Act or law". That clause interacts with general compensation regimes or obligations that might otherwise apply under different statutes, effectively overriding them for matters arising from this transitional part.

Delegated legislation

• Transitional regulations: Section 483 grants a broad power to make transitional regulations about any matter required by the transitional Part or necessary to allow or facilitate its implementation. Those regulations may be retrospective to commencement and the division and any transitional regulation expire on 18 June 2029 (s 483(2)-(4)). Many operational details in the Bill are contingent on such regulations (see repeated references to "requirements prescribed by transitional regulation"). Until such regulations are made, and while they are in force, the practical interaction with other laws will depend on the content of the regulations.

In sum, the Bill repurposes GHG wells into water supply bores, and in doing so channels those works into the Water Act and Planning Act frameworks, modifies how the principal GHG Act’s decommissioning and reporting duties apply, maintains environmental authority obligations, creates deeming effects in the GAB Water Plan, and entrusts much of the detailed inter‑regulatory implementation to transitional regulations.

The instrument is presented as a Bill that amends the Greenhouse Gas Storage Act 2009 by inserting a new Part 8 containing transitional provisions and by making two targeted amendments to existing sections.

Textual amendments made by the Bill

• Clause 3 states succinctly that the Bill amends the Greenhouse Gas Storage Act 2009.
• Clause 4 amends section 455 (Reporting and record keeping requirements) by inserting a note after subsection (2). The inserted note directs readers to section 466 for modifications to the operation of section 256 in relation to CTSCo and former EPQ10. Clause 4 does not change the substantive text of section 455(2) beyond inserting an advisory note that cross‑references the new transitional provision.
• Clause 5 amends section 456 (Decommissioning of wells) by inserting a note after subsection (2). The note cross‑refers to section 467 for further modifications to section 267 and to the operation of the decommissioning provisions in relation to a GHG well in the area of EPQ10 immediately before it ended. Again, this is a cross‑reference note rather than a full substantive redrafting of s 456(2).

Insertion of Part 8

• Clause 6 inserts a new Chapter 8, Part 8 , "Transitional provisions for Greenhouse Gas Storage Amendment Act 2025" , comprising Divisions 1 to 8 and sections 464 through 483. The inserted Part covers: preliminary definitions (s 464); statement of purpose (s 465); modification of end-of-tenure reporting obligations (s 466); modification of decommissioning obligations and responsibility post-decommissioning (ss 467-468); matters for conversion (ss 469-472); transfer mechanics for converted bores (ss 473-476); other matters relating to converted bores, including conversion reports, transfer restrictions and water licensing (ss 477-479); continuation of operating plant characterisation and a no-compensation clause (ss 480-481); limited post-transfer right of entry to comply with rehabilitation conditions (s 482); and a transitional regulation-making power with expiry (s 483).

Commencement and duration

• Clause 2 provides that the Act commences on a day fixed by proclamation. The transitional regulation power and any regulations made under it expire on 18 June 2029 (s 483(4)).

Nature of the amendment

• The Bill makes targeted amendments to produce an alternative conversion-and-transfer pathway for wells in the former EPQ10 area, overrides or modifies how certain pre-existing obligations in the principal Act apply to CTSCo and relevant wells, and embeds cross-references and procedural linkages to external regimes (Water Act, Planning Act, GAB Water Plan, Environmental Protection Act). The Bill delegates a substantial amount of implementation detail to transitional regulations (multiple sections require matters "prescribed by transitional regulation"), which makes the subordinate legislation an integral part of the amendment's practical effect.

As the Bill text stands, it is an amending measure that establishes statutory mechanics and roles; important implementation details and standards remain to be specified via transitional regulations, and the Bill expressly contemplates a limited period for that regulatory architecture to operate (expiry mid‑2029).

The Bill text supplied does not include any judicial decisions, court challenges, or references to prior litigation. It is a legislative amendment instrument and the provided text contains no case law, no judicial interpretations, and no references to litigation history arising from the Greenhouse Gas Storage Act or related instruments. There are no cited authorities within the Bill text that would indicate past judicial engagement with the particular conversion-and-transfer framework the Bill creates.

Consequences of absence of litigation material in the source

• No precedential guidance: Because the Bill contains no litigation history or judicial interpretation of the new provisions, parties will need to rely on the statutory text and any transitional regulations to understand enforcement, proof standards and evidentiary expectations. Any disputes about the meaning, scope or procedural requirements (for example, the content of a conversion plan, sufficiency of a conversion certificate, or the content and effect of a notice of completion) will initially be matters of statutory interpretation to be resolved in future litigation or administrative review, if they arise.
• Reliance on subordinate instruments: The Bill delegates substantive procedural and technical detail to transitional regulations and to external documents (the water bore construction codes published on a Queensland Government website). In the absence of litigation, the content of those instruments will be determinative of practical compliance standards. Disagreements about regulatory prescriptions are likely to follow publication of transitional regulations rather than be resolved by reference to existing case law.
• Possible administrative review avenues: Administrative decisions under the Bill , for example, decisions by the Water Act regulator about whether the landowner will take water for stock and the grant of a water licence (s 479), or the Minister’s handling of notices , may be subject to judicial review or merits review processes available under relevant statutes. The Bill itself does not extinguish such review avenues; however, the no‑compensation clause in s 481 removes a form of remedy for impacts attributable to the transitional part.
• Future litigation topics likely: Where litigation does occur, likely themes will include the scope of rights of entry as modified by ss 459 and 469; the effect of the transfer on regulatory liabilities and environmental obligations (particularly interaction with section 269(3)/(4) as applied by s 468); the sufficiency of records, conversion certificates and conversion reports required by ss 467 and 477; the operation and validity of any transitional regulations (including any retrospective operation contemplated by s 483); and the interplay between the transfer and water licence rights and restrictions under s 479.

In short, the Bill contains no litigation history itself. The practical legal contours and likely future judicial issues will depend heavily on the content of the transitional regulations, administrative practice by the Minister, chief executive and Water Act regulator, and any disputes that arise from parties affected by conversion, transfer and licensing decisions.

This Bill has multiple technical features and implementation traps that practitioners should spot. The following items are concrete mechanics-based risks or surprises grounded in the Bill’s text.

1. Many operational details are left to transitional regulation. Sections 467(1)(a), 467(1)(c), 467(1)(e), 474 and 477 require documents or conduct to "comply with the requirements prescribed by transitional regulation". The delegated power in s 483 permits retrospective regulations and expires on 18 June 2029. Practically, this means the precise notice contents, conversion standards, completion validation, transfer forms and conversion report requirements will be defined by subordinate instruments. Until those regulations are made, the statutory pathway lacks granular certainty.

2. Tight statutory timelines. Once a licensed water bore driller signs the conversion certificate, CTSCo must give the Minister a notice of completion within 10 business days (s 467(1)(e)) and must transfer the bore to the landowner within 40 business days (s 467(1)(f) and Div 5). CTSCo must also provide the conversion report within 60 business days after the conversion certificate is signed, and the conversion report carries a penalty of up to 100 penalty units if not provided (s 477(1)). These short clocks create operational urgency and potential exposure if the conversion certificate date is not carefully coordinated with downstream tasks.

3. Transfer does not equal entitlement to take water. Section 475(3) makes clear the statutory transfer of ownership to the landowner does not itself authorise the landowner to take or interfere with water. An additional water licence process under the Water Act is required; the Water Act regulator must grant a stock water licence within 60 business days "if [...] the regulator considers the landowner will take water for stock purposes" after receiving the transfer notice copy (s 479(1)-(2)). Practitioners should not assume that property ownership of the bore is a sufficient operational licence to draw water.

4. Water licence constraints. The water licence the Water Act regulator grants must not permit taking water unless the bore has a watertight delivery system as defined in the GAB Water Plan (s 479(3)). The GAB Water Plan is explicitly engaged and parts of it are modified for these purposes (s 479(4)-(6)). Failure to install the required delivery system defeats the practical utility of the licence.

5. Conversion certificate must be by a class 3 driller and conversion plan must be approved and signed by that driller (s 467(4)). A licensed water bore driller’s professional responsibilities and licensing requirements under the Water Act therefore become gatekeepers to the conversion pathway.

6. Restriction on CTSCo transfers to third parties. Section 478 declares any purported transfer by CTSCo of a converted bore other than to the landowner is of no effect. That prohibits CTSCo from disposing of converted bores commercially to third parties and constrains exit strategies.

7. Partial compliance leaves decommissioning in play. Section 472 provides that if CTSCo has given notice of intention but some conversion requirements have not been complied with by the decommissioning day, section 267 (as modified) continues to apply. Any partial or failed conversion attempt can re‑expose CTSCo to the principal Act’s decommissioning obligations.

8. No compensation from the State. Section 481 declares no compensation is payable by the State because of the enactment or operation of Part 8 and applies "despite any other Act or law". This removes a statutory avenue for monetary redress against State action under the transitional part.

9. Continued rehabilitation obligations and post‑transfer access. Section 482 preserves certain rehabilitation conditions (explicitly conditions 58-60 of a particular ended environmental authority) as obligations on CTSCo even after decommissioning and transfer to the State under s 269(3), and grants CTSCo a limited right of entry to comply. Parties should note that transfer to the State does not necessarily terminate CTSCo’s exposure to rehabilitation duties under that environmental authority.

10. Deeming and planning consequences. Conversion works are taken to be water bore drilling activities (s 470) and conversions that would otherwise be assessable or prohibited development are treated as accepted development under the Planning Act (s 471). That can relieve parties from planning approvals but does not remove Water Act licensing or GAB Plan constraints.

11. Regulatory expiry and retrospective regulations. Transitional regulations may operate retrospectively to the commencement date of the division (s 483(2)). They, and the division itself, expire on 18 June 2029 (s 483(4)). Parties should be alert to retrospective prescriptions that may validate or alter earlier conduct and to the time-limited window for the transitional regulatory framework.

12. Administrative forwarding failures do not invalidate transfers. Sections 476(2) and 477(3) specify that the chief executive’s failure to forward notices to the Water Act regulator does not invalidate transfers, which reduces a potential administrative vulnerability for transfers but may create practical coordination problems.

Overall, these "gotchas" are mechanistic: they create compliance, timing, delegation, and regulatory-risk issues that require active management by CTSCo, landowners, drillers, and regulators. The Bill ties outcomes to delegated regulations and tightly sequenced steps, and several material consequences (licensing, enforcement, liability exposure) flow from both statutory completions and failures.

The Bill establishes a sequence of concrete steps and technical approvals that CTSCo, landowners, licensed drillers and regulators must execute to achieve conversion rather than decommissioning for relevant GHG wells. The following checklist translates the statutory pathway into an operational compliance plan, with references to the controlling sections.

1. Identify applicability and timing

• Confirm the well is a relevant GHG well as defined in s 464 (a well that, immediately before former EPQ10 ended, was in the area of former EPQ10).
• Determine the decommissioning day for the well (s 464 definition) and the "relevant day" for end-of-tenure reporting (s 466(3)) to ensure all notices and reports are delivered before statutory cut-offs.

2. Prepare the conversion notice and conversion plan

• Draft the notice of intention to convert required by s 467(1)(a) to the Minister, ensuring it "complies with the requirements prescribed by transitional regulation for the notice". Because the Bill defers particulars to transitional regulation, consult those regulations as soon as available.
• Prepare a conversion plan and ensure it is approved and signed by a licensed water bore driller, as required by s 467(4). The conversion plan must show how the well will be converted into a water supply bore in accordance with the water bore construction codes (s 467(4)).

3. Obtain landowner signed consent

• Secure the landowner’s signed statement under s 467(1)(b): the statement must (i) consent to conversion, (ii) specify the purpose for which the landowner intends to take water using the bore, and (iii) agree to take ownership and responsibility for the bore after conversion. Retain an executed copy for records.

4. Engage a licensed water bore driller and carry out conversion works

• Engage a class 3 water bore driller licensed under the Water Act (s 467(4) and note re class definitions).
• Ensure conversion works comply with the water bore construction codes defined in s 467(4) (the two named documents published on a Queensland Government website).
• Document all works, test results, and compliance with the conversion plan and construction codes.

5. Secure a conversion certificate

• Have the licensed water bore driller sign a conversion certificate (s 467(1)(d)) stating conversion is complete and done in accordance with (i) the conversion plan given to the Minister and (ii) the requirements for conversion prescribed by transitional regulation and the water bore construction codes.

6. Timely notifications and transfer

• Within 10 business days after signature of the conversion certificate, CTSCo must give the Minister a notice of completion that complies with the transitional regulation requirements (s 467(1)(e)).
• Within 40 business days after the conversion certificate is signed, CTSCo must effect the transfer of the water supply bore to the landowner under Division 5, by giving the chief executive a notice of transfer that meets transitional regulation requirements (s 467(1)(f); s 474).

7. Conversion report and administrative flows

• Within 60 business days after the conversion certificate is signed, give the chief executive a conversion report complying with transitional regulation requirements (s 477(1)). Failure attracts a maximum of 100 penalty units.
• The chief executive will forward the notice of transfer and conversion report to the Water Act regulator within 30 business days (ss 476(1), 477(2)), but CTSCo should maintain copies and confirm transmission for evidentiary purposes.

8. Water licence process for the landowner

• After the chief executive forwards the notice of transfer to the Water Act regulator, the regulator must consider whether the landowner will take water for stock. If so, the regulator must grant a water licence within 60 business days (s 479(2)). Ensure the landowner understands the licence will not authorise taking water unless the bore has a watertight delivery system as per GAB Water Plan s 29(2) (s 479(3)).
• Coordinate installation, verification, and certification of a watertight delivery system to avoid delays in the licence permitting water-taking.

9. Record-keeping and compliance proof

• Keep contemporaneous records of the conversion plan, conversion certificate, notices of intention and completion, transfer notices, conversion report, and all communications with the Minister, chief executive and Water Act regulator. The Bill cross-references record-keeping requirements and links to s 455 and s 456 via notes (clauses 4-5 and s 466), so preserving documentary proof is essential if questions arise under related reporting or decommissioning provisions.

10. Prepare for contingencies

• If conversion cannot be completed by the decommissioning day or required steps are partially complied with, ensure a plan to satisfy section 267 obligations remains ready, because section 267, as modified, continues to apply (s 472).
• Be prepared to plug and abandon the well in the manner required by any transitional regulation applied under s 467(2) if conversion fails.
• Where decommissioning leads to transfer to the State under section 269(3) as modified (s 468), be aware rehabilitation conditions (s 482) may continue to bind CTSCo and permit limited right of entry to comply.

11. Check transitional regulations and external documents

• Regularly review any transitional regulations made under s 483 and the water bore construction codes (the two named documents on a Queensland Government website). Because the Bill defers key technical and documentary contents to transitional regulations, compliance cannot be assured without consulting those regulations as soon as they are available. Note the regulations may operate retrospectively to commencement and will expire on 18 June 2029 (s 483(2)-(4)).

12. Legal and administrative coordination

• Coordinate with the landowner to secure timely consent and to ensure the landowner understands the transfer does not itself authorise water-taking (s 475(3)).
• Coordinate with the licensed driller to ensure signatures and certificates align with statutory timelines to avoid inadvertent exposure to penalties or to the resumption of decommissioning obligations.

Following the steps and timeframes specified in ss 467, 474, 477 and 479, and ensuring close attention to the contents of transitional regulations and the water bore construction codes, are the core compliance requirements the Bill imposes. Documentation, tight scheduling and inter-agency communication are essential to effect conversion and to avoid reactivation of decommissioning duties or penalties.