The regulation organises around three operational themes: conversion, transfer, and abandonment. Each is anchored to specified documentary and technical standards.

Conversion: The conversion concept is the statutory process turning a "relevant GHG well" into a "water supply bore". Notices of intention (s 5) and completion (s 7) bookend the activity. The regulation defines the minimum content and evidence that must accompany those notices: well schematics located by GDA2020, and a licensed water bore driller’s written approval of suitability (s 5). After completion, the conversion certificate and conversion report (s 8) supply exhaustive pre‑ and post‑conversion technical particulars , spatial coordinates, well completion dates, depths, perforation depths, surveys, casing/equipment diagrams, cementing volumes and losses, plug locations and intervals, and a full inventory of retained/preserved equipment identified as "prescribed equipment" (s 8).

Transfer: The transfer concept governs how the converted water supply bore is conveyed to a landowner under the parent Act’s transfer provisions (s 9). The notice of transfer must be written, state bore identification, position by GDA2020, landowner contact details and intended water use, confirm compliance with conversion requirements in s 467(1)(a)-(f) of the Act, and be accompanied by a signed statement from the landowner consenting to the transfer (s 9).

Plugging and abandonment: The regulation prescribes two routes to abandon a relevant GHG well: the "standard way" being the construction and abandonment code for petroleum wells, or an alternative "proposed way" subject to approval by the chief inspector (s 12). Before any plugging and abandonment works, CTSCo must undertake a systematic safety assessment and prepare a safety report that records, for each identified risk, an "acceptable level" of risk and measures to control the risk (s 13). A plugging and abandonment plan (s 14) must accompany that safety report, demonstrate consideration of code matters, state whether the proposed way deviates from the standard way and, if so, explain the deviation and describe technical measures for risk controls. The chief inspector may approve the alternative method only where satisfied that the acceptable level for each risk is reasonable relative to the standard way and that CTSCo will control the risk to that acceptable level (s 15).

Interlocking references and definitions: The instrument repeatedly invokes external standards and instruments: the GAB Water Plan (s 6), water bore construction codes (s 6, s 14), the construction and abandonment code and petroleum well standards (ss 10, 12, 14), and the P&G Act for definitions (s 8, s 10). It also relies on spatial datum GDA2020 for coordinate specification (ss 5, 7, 9, 8). The regulation refers to "former EPQ10" and CTSCo in the conversion report template (s 8), indicating it is tailored to a specific property set or program, but the full definition of these terms appears in the schedule and in the parent Act (sec 4 notes the dictionary in schedule 1).

Transitional timing and scope: The instrument is expressly transitional (s 3) and temporary, operating between commencement and expiry on 18 June 2029. It also contains "as soon as practicable" catch‑up obligations for works already begun prior to commencement (ss 13(2), 14(2)), which means some actions are retrospective in effect but only to the extent practicable.

Risk and safety framing: The technical requirements emphasise preventing cross‑aquifer flow (internal cement plugs, casing/cement life equivalent to new bores , s 6), and documenting any retained equipment that might create hazards to underground mining (s 8). In the plugging context, the safety assessment requires explicit articulation of acceptable levels of risk having regard to likelihood, severity, and avoidability, and requires control measures targeted at avoiding, eliminating, or minimising risks (s 13).

Decision nodes and evidentiary requirements: The regulation creates several decision points where documentary certification is necessary: the licensed water bore driller’s report for conversion suitability (s 5), the conversion certificate and conversion report (s 7-8), the signed landowner consent for transfer (s 9), the safety assessment report and plugging plan for abandonment (ss 13-14), and the chief inspector’s approval of any deviation from the standard abandonment way (s 15). Those documents form the evidentiary basis for regulatory acceptance of the actions prescribed.

The instrument allocates duties primarily to CTSCo (the regulated operator identified repeatedly in the provisions) and creates secondary obligations or participation requirements for licensed water bore drillers, landowners, and the chief inspector. The broader regulatory network of officials and standards bodies is implicated because the regulation dovetails with the chief executive (well completion reports), the construction and abandonment code, water bore construction codes, the GAB Water Plan and the P&G Act.

CTSCo: The principal actor mandated to take action is CTSCo. The regulation requires CTSCo to give notices of intention to convert (s 5) and notices of completion (s 7); to obtain and rely on a licensed water bore driller’s report (s 5); to prepare and submit an extensive conversion report (s 8); to give a notice of transfer with landowner consent (s 9); to carry out safety assessments and prepare safety reports before plugging and abandonment (s 13); and to give plugging and abandonment plans to the chief inspector (s 14). When CTSCo proposes a deviation from the standard plugging and abandonment method, it must secure the chief inspector’s approval, and the chief inspector may request amendments (s 15).

Licensed water bore drillers: Conversion activities are certificated or approved by a licensed water bore driller, who must sign a report stating the well is suitable to be converted (s 5) and whose licence number and name must appear in the notice of completion and conversion report (ss 7, 8). The driller's professional assessment is a precondition for conversion notices and for populating the conversion report.

Landowners: Landowners for the well/water supply bore are named in conversion reports (s 8) and their consent is required for transfer of the converted bore (s 9). The notice of transfer must state the purpose for which the landowner will use water from the bore (s 9). The landowner thereby becomes the recipient of the bore and a signatory to the transfer documentation, and their contact details must be provided in notices (ss 5, 7, 9).

Chief inspector and chief executive: The chief inspector is the decision maker for approving alternative plugging and abandonment methods (s 15) and may request amendments to plugging plans. The chief inspector’s satisfaction is expressly required regarding the reasonableness of acceptable risk levels and the adequacy of control measures (s 15(3)). The chief executive is a recipient of prior well completion reports (s 5 definition of well schematics refers to modifications after the well completion report was given to the chief executive; s 8 requires the date the well completion report was given to the chief executive).

Standards and codes bodies: The GAB Water Plan and water bore construction codes shape minimum technical standards for conversion (s 6). The construction and abandonment code and matters required under it set the baseline "standard way" for abandonment (ss 10, 12, 14). Entities maintaining or updating those codes and plans influence compliance through technical standards and criteria.

Other potentially affected parties: Underground mining operations are indirectly implicated because the conversion report must describe any "prescribed equipment" that may create a hazard to underground mining operations (s 8). Mining operators and regulators will rely on the conversion report to assess risks. Similarly, surveyors, geophysicists and cementing contractors are implicated through the detailed reporting requirements (s 8).

Temporal impact groups: The regulation applies to works started after commencement, but includes "as soon as practicable" catch‑ups if works started earlier (ss 13(2), 14(2)). Therefore projects in mid‑stream at commencement face transitional compliance burdens.

Geographic and datum specificity: The regulation requires position references by GDA2020 (ss 5, 7, 8, 9), so affected parties must have the capability to provide coordinates to that datum. This affects surveyors and any operator compiling the technical documentation.

Who bears costs and obligations: The instrument imposes documentary, technical and procedural obligations primarily on CTSCo, which will bear the direct costs of commissioning licensed drillers, producing detailed engineering reports and diagrams, undertaking safety assessments, and submitting plugging and abandonment plans. Landowners must sign consent for transfer and may have responsibilities arising from ownership of a converted bore. The chief inspector and the chief executive bear administrative burdens in reviewing submissions and making approval decisions, though the text does not allocate additional resources.

This section summarises the principal actionable duties created by the regulation and the decision rights that key public officials hold under the instrument.

Duties imposed on CTSCo:

• Give a written notice of intention to convert a relevant GHG well that includes specific content and attachments: well name, statement of intent to convert into a water supply bore under chapter 8 part 8 of the Act, landowner contact details, estimated completion date, well schematics located by GDA2020, and a licensed water bore driller’s report approving suitability (s 5). Well schematics must include the original construction, position by GDA2020 and all modifications made after the well completion report was given to the chief executive (s 5).
• Ensure conversions meet specified technical construction requirements: control under the GAB Water Plan s 29(1); casing and cement with functional life equivalent to a newly constructed bore; internal cement plugs preventing extraction from non‑targeted aquifers; and otherwise comply with water bore construction codes (s 6).
• Give a notice of completion in writing with specific elements: pre‑conversion well name, position by GDA2020, that conversion under chapter 8 part 8 has been completed, completion date, new bore name, licensed driller’s name and licence number, and attach a copy of the conversion certificate (s 7).
• Prepare and give a written conversion report that must contain extensive details: particulars of former EPQ10 (example of licence/tenure context), driller details, author and submitter details, landowner name; detailed pre‑conversion data (location, well completion report date, total depth, positions and thicknesses of intersected strata, perforation depths, surveys/interpretations); post‑conversion data (casing/equipment diagrams, full equipment inventory including "prescribed equipment", surveyed locations of prescribed equipment, cementing operation details including volumes and losses, and compliance statements for each applicable water bore construction code requirement, and an assessment of impacts relevant to underground mining) (s 8).
• For plugging and abandonment: carry out a systematic safety assessment of plugging/abandonment risks, prepare a written safety report setting an "acceptable level" for each risk with regard to likelihood, probable severity and avoidability, and set out means to control risks to the acceptable level (s 13). Prepare a plugging and abandonment plan and give it to the chief inspector before starting works, showing how the well will be plugged and abandoned, whether the proposed way deviates from the standard way and, if so, how, include the safety report and describe measures to control each risk to the acceptable level (s 14).

Duties on licensed water bore drillers:

• Produce and sign the report stating suitability for conversion, and have name and licence number recorded in notices of completion and conversion reports (ss 5, 7, 8).

Duties on landowners:

• Provide a signed statement consenting to transfer when CTSCo gives a notice of transfer (s 9). The notice of transfer must state intended water use by the landowner (s 9).

Decision rights held by officials:

• Chief inspector: may approve a proposed deviation from the standard plugging and abandonment way, or require CTSCo to amend and resubmit the plugging plan (s 15). Approval is discretionary but conditioned: the chief inspector must be satisfied that for each risk the acceptable level is reasonable relative to the standard way’s risks and that CTSCo will control the risk to that level (s 15(3)).
• Chief executive: holds a continuing role in recording well completion reports (s 5 definition of well schematics) which feed into modification history; the conversion report requires the date the well completion report was given to the chief executive (s 8).

Compliance timing obligations:

• If plugging and abandonment works started before commencement, CTSCo must carry out safety assessments and give plugging plans "as soon as practicable" after commencement (ss 13(2), 14(2)). The same "as soon as practicable" rule applies to giving the plugging and abandonment plan if works started before commencement (s 14(2)).

Information and evidentiary duties:

• Many duties are documentary: notices, reports, certificates, diagrams, and signed statements. The detailed conversion report (s 8) is particularly evidentiary in nature , it supplies both historical well construction data and contemporary engineering details and cementing records that are material to future safety assessments (s 8).

Rights or entitlements:

• The regulation does not create express property rights or compensation entitlements within its text. It primarily prescribes procedural and technical obligations. Rights relevant to decision processes are limited to the chief inspector’s statutory discretion to approve or require amendments and the landowner’s right to withhold consent for transfer (s 9).

Interface with codes and plans:

• Duties require acting in accord with, or at least addressing, external instruments: the GAB Water Plan, water bore construction codes and the construction and abandonment code. These external documents confer technical standards that CTSCo must either meet (conversion) or demonstrate consideration of and compliance with in plans (s 6, s 14).

Transitional and retroactive compliance:

• The "as soon as practicable" requirement for pre‑commencement works creates a duty to retrospectively produce documents and plans, but only to the extent practicable (ss 13(2), 14(2)). The regulation thus imposes compliance duties that may crystallise after the start of physical works.

The regulation itself prescribes documentary, technical and planning obligations, but it does not set out express sanctions, monetary penalties or administrative fine schedules within its text. Enforcement mechanisms and penalties therefore derive from the parent Act and from other statutory instruments referenced by the regulation rather than from the regulation’s text. The regulation repeatedly frames provisions as being "for" particular sections of the Act (for example, ss 5, 6, 7, 8 and 9 are given "for" sections 467, 477 and 474 of the Act), which indicates that the Act supplies the enforcement architecture that applies to breaches of the duties prescribed here.

What the regulation provides that bears on enforcement and administrative control:

• Decision oversight by the chief inspector: The chief inspector has an explicit power to approve the proposed plugging and abandonment way or to request amendment and resubmission of the plugging plan (s 15). That power creates an administrative gate: proceeding without approval where approval is required will likely engage contraventions under the Act, even though the regulation itself does not restate statutory penalties.
• Prescriptive documentary obligations: The many mandatory disclosure and certification requirements for conversion and abandonment create clear compliance markers (ss 5-9, 13-14). Failure to provide the specified documents, or to meet the technical standards referenced (s 6), will typically engage obligations and potential enforcement under the parent Act.
• Interaction with external codes and plans: The regulation imports compliance obligations or at least requires consideration of technical standards in external codes (GAB Water Plan, water bore construction codes, construction and abandonment code). Non‑compliance with the external codes may attract enforcement under the Act or the regimes that govern those codes.

Absence of express penalties in the regulation:

• The instrument does not, within its text, create new offences or prescribe fine amounts, time limits for enforcement, or infringement notice schemes. Consequently, enforcement follows the Act’s existing enforcement framework and any regulatory regimes governing referenced codes. Practitioners must therefore consult the parent Act and the P&G Act (for definitions and roles such as chief inspector) to identify the specific offences, penalties and enforcement processes applicable to non‑compliance with the duties set out in this regulation.

Administrative remedies and oversight:

• The chief inspector’s capacity to require resubmission of plugging plans (s 15) gives regulators an administrative compliance lever before physical works proceed. This does two things procedurally: (1) gives the regulator an opportunity to insist on amendments without immediate criminalisation, and (2) conditions approval on the inspector’s satisfaction about "reasonable" acceptable risk levels and controls (s 15(3)), thereby delegating substantive judgment about risk tolerability to the regulator.

Practical considerations for enforcement risk:

• Because the regulation is transitional and expires on 18 June 2029 (s 3), enforcement actions will largely concern activities and reports in the 2026-2029 window. The "as soon as practicable" clauses for works begun before commencement (ss 13(2), 14(2)) may complicate enforcement timetables, as compliance obligations apply retrospectively subject to practicability.
• The heavy documentary footprint (detailed conversion reports, cementing volumes, surveys, and so on) means enforcement will be document‑driven; regulators can assess compliance by inspection of submissions and certificates rather than by extensive field testing in many cases.

Recommended follow‑ups to identify enforcement specifics:

• Consult the parent Act (the Act provisions repeatedly referenced such as ss 467, 474, 477 and s 483) and the P&G Act for the schedule 2 definition of chief inspector and for the enforcement and penalty provisions that apply when duties in the Act or delegated regulations are not met. Also, confirm whether the construction and abandonment code or the water bore construction codes carry separate enforcement regimes or obligations that generate their own sanctions for non‑compliance.

The regulation is highly interlinked with the statutory framework and external technical instruments. It functions as a procedural and technical elaboration of obligations in the parent Act and cross‑references multiple other legal documents and codes. Practitioners must treat the regulation as constituent part of a network of law, rather than as a stand‑alone instrument.

Direct references to the parent Act:

• The regulation is expressed to be "for" specific sections of the Act. For example, the notice of intention provision is "for section 467(1)(a)(i) of the Act" (s 5), the conversion requirements are "for section 467(1)(c) of the Act" (s 6), the notice of completion is "for section 467(1)(e) of the Act" (s 7), the conversion report is "for section 477(1) of the Act" (s 8), and the notice of transfer is "for section 474 of the Act" (s 9). This signals that enforcement, offence definitions, and some procedural matters are governed by the Act and its enforcement provisions. The regulation therefore supplements and operationalises the Act’s provisions.

P&G Act and chief inspector/definitions:

• The regulation imports statutory definitions and roles from the Petroleum and Gas Act (P&G Act). Section 8 refers to "natural underground reservoir" as defined in the P&G Act s 13, and section 10 identifies the chief inspector by reference to the P&G Act schedule 2. That means the P&G Act’s definitions and regulatory architecture (including the chief inspector’s statutory powers and duties) are relevant to understanding obligations and enforcement.

Water management law:

• Conversion requirements are tied to the Great Artesian Basin (GAB) Water Plan, specifically the notion of being "controlled within the meaning of the GAB Water Plan, section 29(1)" (s 6). Compliance with the GAB Water Plan will therefore be a material legal requirement. Practitioners must check the GAB Water Plan’s provisions, including any permitting, licence or reporting obligations under water law, to assess whether the converted water supply bore can lawfully be used and what regulatory permissions are needed.

Water bore construction codes and construction and abandonment code:

• The regulation requires that conversions "otherwise be constructed in accordance with the requirements for water bores stated in the water bore construction codes" (s 6) and that the standard way for plugging and abandonment is to follow the construction and abandonment code (s 12). These codes may be statutory instruments, industry standards incorporated by reference, or administrative documents. Their technical standards create de facto legal obligations that must be met or addressed substantively in plans.

Spatial datum and surveying law:

• The requirement to reference positions by GDA2020 (ss 5, 7, 8, 9) imposes a coordinate datum standard; compliance will involve licensed surveyors and accurate placement of spatial information consistent with land and resource mapping laws.

Interaction with underground mining and the P&G Act:

• The conversion report must disclose equipment retained in the bore that may create hazards to underground mining operations and provide information useful to assessing risks to safe and efficient underground mining (s 8). This cross‑links the conversion regime with mining safety regimes, and with the P&G Act’s focus on petroleum and gas safety standards. Mining regulators and operators will rely on these disclosures.

Transitional interplay and time limits:

• As a transitional regulation (s 3), it sits temporarily alongside existing law. Practitioners should check whether the parent Act or other statutes contain time‑limited transitional provisions that affect rights, obligations or enforcement during the period to 18 June 2029.

Reporting line to the chief executive:

• The regulation’s definition of well schematics refers to modifications made after the well completion report was given to the chief executive (s 5). The chief executive’s records therefore are a legal touchstone for what counts as post‑completion modifications. This creates an evidentiary interaction between the operator’s records and the regulator’s file, with potential implications for determining compliance history.

No freestanding civil property effects:

• The regulation does not itself create property transfers or licences; rather, it prescribes the documentation and conditions required for transferring a converted bore to a landowner under the Act (s 9). Legal title questions will be resolved under property law and the parent Act; this regulation supplies the evidentiary and technical requirements for the regulatory transfer process.

Practical implication:

• Compliance requires coordination across legislative and regulatory regimes: the parent Act (for obligations and enforcement), the P&G Act (for technical definitions and inspectorate roles), the GAB Water Plan and water law (for control and use of groundwater), water bore construction codes and the construction and abandonment code (for technical standards), surveying standards (GDA2020) and possibly mining safety and land title processes. The regulation both references and depends on these external instruments to give meaning to its obligations.

The instrument’s own amendment history, as presented in the text, is minimal and clear: it is introduced as the Greenhouse Gas Storage (Transitional) Regulation 2026, it commences on 24 January 2026, is declared to be a transitional regulation (s 3), and it expires on 18 June 2029 (secs 1-3). There are no internal amendment provisions, schedules of prior amendments, or recorded historical changes within the provided text.

What is present:

• Short title records the instrument’s name and year (s 1).
• Commencement date is fixed to 24 January 2026 (s 2).
• A declaratory clause labels the regulation as transitional and records an expiry date of 18 June 2029 (s 3).
• Definitions are left to a dictionary in schedule 1 (s 4), but schedule 1’s contents are not reproduced in the provided text.

What is absent in the text:

• There are no amending notes, historical marginal notes, or prior versions included in the text provided. No repeal or savings provisions are recorded other than the explicit expiry date set out in s 3.
• The text does not include stand‑alone modifications of the parent Act; rather, it provides subordinate rules said to be "for" specified Act sections.

Implications for practitioners:

• The absence of amendment history in the instrument means that, as of the regulation’s commencement, the version provided is the operative text through to its expiry, unless subsequently amended by a later instrument or repealed in advance of expiry. Users must therefore check legislative databases and official notices for any statutory instruments amending this regulation after commencement (post 24 January 2026).
• Because the regulation is temporary, amendments within the window 2026-2029 would be feasible but must be sought and checked by reference to the official register of subordinate legislation. The practitioner should also check whether the parent Act contains transitional or sunset clauses that could interact with this regulation’s expiry.

Records and schedules:

• The regulation relies on schedule 1 for defined terms (s 4). Any interpretive disputes or clarifications about terms like "CTSCo", "relevant GHG well", or "well completion report" will require inspection of schedule 1 and of the parent Act’s definitions. Schedule 1’s contents are therefore part of the instrument’s legal meaning but are not included in the excerpt provided.

Recommendation:

• To establish the complete amendment history and check for any subsequent modifications between commencement and expiry, consult the official Queensland legislation database or other authorised legislative repositories for post‑commencement amending instruments, revocations, or consolidations.

The provided text contains no cases, judicial decisions, or litigation citations. It records no declared judicial interpretation or references to case law. Where the regulation cites other laws (for example, the P&G Act), it also does not include any judicial gloss or declared application derived from court decisions.

Consequences of the absence of litigation data in the source:

• There is no litigation history recorded in the regulation itself. As a result, the instrument’s text does not reflect judicial pronouncements on its interpretation, on the meaning of its requirements, or on the exercise of powers such as the chief inspector’s approval under s 15.
• Practitioners should therefore not assume settled judicial doctrine on points such as the standard of "reasonableness" the chief inspector must apply when assessing acceptable levels of risk, or judicial deference to technical compliance statements in conversion reports and plugging plans. Those interpretive questions will remain open until tested in court or clarified by administrative decisions.

Where to look for litigation or administrative decisions:

• Cases or administrative determinations that interpret or apply the regulation would be found in decisions from relevant courts or administrative tribunals, and in published decisions or reasons of the regulator (for example, if the chief inspector issues detailed reasons for approving or refusing a plugging plan). Because the regulation is transitional and time‑limited (to 18 June 2029, s 3), the window for litigation is similarly constrained; however, disputes arising during that window could generate precedent.

Practical approach in absence of litigation:

• In the absence of judicial guidance, practitioners must rely on the plain meaning of the regulation and on the parent Act, the P&G Act, and the referenced technical codes. Where the regulation uses evaluative or comparative standards (for example, "reasonable" acceptable levels of risk compared with the standard way, s 15(3)), practitioners should prepare for administrative interpretation by the chief inspector and retain evidence demonstrating how acceptable levels were determined and how controls will achieve them.
• Documentation, expert evidence (for example from licensed drillers and engineers), and robust safety assessment methodologies will be the primary tools to mitigate litigation risk in the absence of precedent.

Recommendation:

• Monitor administrative decisions by the chief inspector and any published enforcement actions under the parent Act for early signals about how regulators interpret and apply key provisions such as s 15. Also check tribunal and court databases for any disputes involving conversion reports, notices of transfer, or approval/refusal of plugging and abandonment plans during the regulation’s operative window.

This regulation contains many specific, technical and procedural requirements. Missing an element or misframing a report risks regulatory non‑compliance under the Act. Below are concrete pitfalls to watch for, each grounded in the text.

1. Failing to use GDA2020 coordinates:

• Notices of intention, completion, conversion reports and notices of transfer require position data defined by reference to GDA2020 (ss 5, 7, 8, 9). Using another datum or an imprecise coordinate format risks non‑conformity with the prescribed content.

2. Incomplete well schematics:

• Well schematics must show the position by GDA2020, how the well was originally constructed, and all modifications made after the well completion report was given to the chief executive (s 5). Practitioners must check the regulator’s file to identify which modifications post‑date the well completion report; omitting modifications could generate queries.

3. Overlooking the licensed driller’s signed suitability report:

• The notice of intention must be accompanied by a report approved and signed by a licensed water bore driller stating suitability to be converted (s 5). The same driller’s details must appear in the notice of completion and conversion report (ss 7, 8). A conversion without this signed professional certification is not compliant.

4. Technical equivalence requirement for casing and cement:

• Section 6 requires casing and cement to have a "functional life equivalent to the casing and cement of a newly constructed water supply bore." This is a technical standard to be met or demonstrated in the conversion report. Operators must document material specifications, design life calculations and cement composition to justify equivalence.

5. Cementing details and loss records:

• The conversion report requires the volume and type of cement used, volume of cement lost due to voids or permeable strata and methods used to address losses, and the method/material/volume used to cement voids (s 8). These details are granular and retrospective; failing to keep real‑time cementing logs will make compliance difficult.

6. Prescribed equipment hazards:

• The conversion report requires a full description of all equipment, including "prescribed equipment" (metal equipment other than casing or other equipment that may create a hazard to underground mining) and examples given (aluminium, batteries, electronics) (s 8). Retained equipment must be located by survey and described; failure to disclose hazardous debris or equipment may expose downstream mining operations to unknown risks and attract regulator scrutiny.

7. Demonstrating compliance with water bore construction codes:

• For each standard that applied to the conversion under the water bore construction codes, the conversion report must state how the conversion complies (s 8). It is insufficient to state "compliant"; the report must map specific code requirements to as‑built details.

8. Transfer requires landowner consent and intended use stated:

• The notice of transfer must be accompanied by a signed statement in which the landowner consents and must state the purpose for which the landowner will use water from the bore (s 9). A transfer without a signed consent and a clearly stated intended use will not meet the statutory notice requirement.

9. Plugging and abandonment alternatives require chief inspector approval:

• If CTSCo intends a "proposed way" that deviates from the standard way (construction and abandonment code), the chief inspector must approve it in writing, and may require resubmission (s 15). Approval is conditional on the chief inspector’s satisfaction regarding the reasonableness of acceptable risk levels vis‑à‑vis the standard way and the adequacy of controls (s 15(3)). Submitting insufficient risk evidence risks refusal and delay.

10. Risk assessment content and acceptable level standard:

• Safety reports must state an "acceptable level" for each risk having regard to likelihood, probable severity and avoidability, and must identify controls that will achieve that level (s 13). The comparative standard in s 15(3) means that CTSCo must prepare evidence establishing why a chosen acceptable level is reasonable relative to the standard way. Generic or conclusory risk statements will not satisfy the inspector.

11. Transitional "as soon as practicable" obligations:

• For works that started before commencement, CTSCo must carry out safety assessments and give plugging plans "as soon as practicable" after commencement (ss 13(2), 14(2)). What is "practicable" is context dependent; operators should document reasons and timelines to substantiate that they attempted to comply promptly.

12. Reliance on external codes and plans:

• The regulation requires conformity with the water bore construction codes and the construction and abandonment code, and control under the GAB Water Plan (s 6, s 12, s 14). Those documents are external and may impose additional technical requirements, approvals or fees not set out in this regulation.

13. Narrow remit of the conversion report examples:

• Section 8 includes examples such as "aluminium, batteries, electronics" and lists "drilling equipment, geophysical logging tools" as examples of prescribed equipment. These examples show the regulator expects attention to non‑casing metals and electronics; practitioners should perform an inventory of all downhole items and treat such examples as indicators of the regulator’s focus.

Operational mitigation steps:

• Keep contemporaneous, properly indexed engineering and cementing logs; engage licensed water bore drillers early; secure survey coordinates in the GDA2020 datum; produce mapping cross‑referencing conversion requirements and water bore construction code clauses; prepare quantitative risk assessments using standard methodologies; document timelines for any pre‑commencement works to justify "as soon as practicable" compliance.

This checklist is a practical, stepwise approach for CTSCo and associated participants to meet the regulation’s obligations. Each step maps to the relevant section(s) of the regulation.

Preliminary: confirm definitions and scope

• Consult schedule 1 (the regulation’s dictionary) and the parent Act to confirm which wells are "relevant GHG wells", understand "former EPQ10" and confirm CTSCo’s defined role (s 4).
• Identify whether any works began before 24 January 2026; where they have, plan to comply "as soon as practicable" with the specific reporting and planning duties (ss 13(2), 14(2)).

Conversion: prepare and give the notice of intention (s 5)

• Prepare a written notice containing: well name, statement that CTSCo intends to convert the well into a water supply bore under chapter 8 part 8 of the Act, landowner contact details, estimated completion date (s 5).
• Commission a licensed water bore driller to inspect and prepare a signed report stating the well is suitable to be converted; record the driller’s name and licence number (s 5).
• Assemble well schematics with position by GDA2020, original construction details, and all modifications made after the well completion report was given to the chief executive (s 5).
• Submit the notice and all attachments to the regulator as required by the parent Act provision to which s 5 relates.

Conversion construction requirements (s 6)

• Ensure converted bore design meets GAB Water Plan control requirements (s 6(a)). Obtain any necessary water approvals under the GAB Water Plan.
• Specify casing and cement so their functional life is demonstrably equivalent to that of newly constructed water supply bore casing and cement. Prepare design documents, materials specifications and life‑cycle calculations to evidence equivalence (s 6(b)).
• Design and install internal cement plugs to prevent water extraction from non‑target aquifers; document plug locations and materials (s 6(c)).
• Ensure all construction complies with the water bore construction codes; map each code provision to the as‑built design and store compliance evidence (s 6(d)).

Post‑conversion: notice of completion and conversion certificate (s 7)

• After works are completed, prepare a written notice of completion that includes the pre‑conversion well name, position by GDA2020, confirmation the conversion under chapter 8 part 8 has been completed, date of completion, the post‑conversion bore name, and the licensed water bore driller’s name and licence number (s 7).
• Attach a copy of the conversion certificate relating to the conversion (s 7).
• Submit the notice to the appropriate recipient(s) as required by the Act.

Conversion report: prepare and submit (s 8)

• Produce a comprehensive written conversion report (s 8) including:
  • First page particulars: former EPQ10 particulars, prior well name, licensed driller’s name and licence number, author and submitter details, landowner name (s 8(a)).
  • Pre‑conversion data: spatial location, date well completion report given to the chief executive, total depth, positions and thicknesses of intersected strata (vertical depth and horizontal plane for non‑vertical sections), perforation depths, and surveys/interpretations (s 8(b)).
  • Post‑conversion data: diagrams of casing and equipment showing dimensions and features; full inventory of equipment including "prescribed equipment" and its surveyed location; cementing operation details (plugs, intervals, volumes, losses, remedial actions, materials and volumes used to cement voids); and compliance statements mapping to each applicable water bore construction code requirement. Include an assessment of potential impacts relevant to safe and efficient underground mining (s 8(c)).
• Maintain and archive the raw logs and survey files used to compile the report (cementing logs, TIL reports, geophysical logs, survey files referenced to GDA2020) because the conversion report must present measured values and diagrams (s 8).

Transfer to landowner (s 9)

• Where CTSCo intends to transfer the converted bore, prepare a written notice of transfer stating the bore name, landowner contact details, position by GDA2020, intended purpose of water use by the landowner, and confirmation that s 467(1)(a)-(f) of the Act’s requirements have been met in relation to conversion (s 9).
• Secure a signed statement from the landowner consenting to the transfer and attach it to the notice (s 9).
• File or serve the notice as required by the Act.

Plugging and abandonment: safety assessment (s 13)

• Before plugging and abandonment works start, carry out a systematic safety assessment covering all risks associated with the plugging and abandonment (s 13(1)(a)).
• Prepare a written safety report stating, for each identified risk: the acceptable level of risk, taking into account likelihood, probable severity and avoidability; and the ways to control the risk to that acceptable level, prioritising avoidance, elimination or minimisation, and where not avoidable, measures to reduce likelihood and severity (s 13(1)(b)).
• If plugging and abandonment works began before commencement, prepare the safety assessment and report as soon as practicable (s 13(2)).

Plugging and abandonment plan: prepare and give to chief inspector (s 14)

• Prepare a written plugging and abandonment plan demonstrating consideration of all matters that must be considered under the construction and abandonment code before abandoning a petroleum well (s 14(3)(b)).
• Show the proposed way for plugging and abandoning the relevant GHG well and state whether it deviates from the standard way (s 14(3)(c)-(d)). If deviating, explain how (s 14(3)(e)).
• Include a copy of the safety report and, for each risk identified, include a description of technical and other measures undertaken or to be undertaken to control the risk to the acceptable level (s 14(3)(f)-(g)).
• Give the plugging and abandonment plan to the chief inspector before starting works, or if works already started, as soon as practicable (s 14(1)-(2)).

Seeking chief inspector approval for deviations (s 15)

• If the proposed way deviates from the standard way, submit the plugging and abandonment plan to the chief inspector and be prepared to respond to amendment requests (s 15(1)-(2)).
• Build an evidentiary case that, for each risk, the chosen acceptable level is reasonable compared to the standard way and that CTSCo will control the risk to the acceptable level. Include quantitative risk analyses, comparative assessments, and monitoring and contingency measures (s 15(3)).
• Await written notice from the chief inspector indicating approval or requests for amendment before proceeding if approval is required.

Record keeping and audits

• Retain all notices, conversion certificates, conversion reports, cementing logs, surveying files (GDA2020 coordinates), driller reports and plugging plans in an organised register. These documents form the core compliance record for audit or enforcement and are explicitly required by ss 5-9 and 13-15.

Coordination with external instruments and regulators

• Seek any permits or licences needed under the GAB Water Plan and water law because converted bores must be "controlled" under the GAB Water Plan (s 6(a)). Verify water allocation and use permissions.
• Ensure that work practices and design comply with the water bore construction codes and the construction and abandonment code; where deviations are proposed, explicitly reference the relevant code clauses in the plugging plan and demonstrate equivalence or superior control measures (s 14(3)(b)).

Practical project governance

• Appoint named responsible persons for each submission (driller, author, submitter) and ensure their names and licence numbers are recorded in notices and the conversion report (s 8(a)).
• Provide draft conversion and plugging reports to the chief inspector or regulator for early engagement where feasible, to reduce the risk of resubmission.
• Time submissions to account for the regulation’s transitional nature and the "as soon as practicable" obligations if works are already underway (ss 13(2), 14(2)).

Final note

• Because the regulation is transitional and expires on 18 June 2029 (s 3), plan compliance documentation and approvals on the timeline of the conversion, transfer or abandonment works so that requisite approvals, notices and reports are completed within the instrument’s operative window and in accordance with the parent Act and referenced codes.