The plan rests on a small set of recurring statutory concepts that drive allocation, assessment and conditions.

• Environmental flow objectives and allocation security objective. Section 17 requires chief executive decisions about allocation and management of water to be "consistent with" the environmental flow objectives in s 14 and the water allocation security objective in s 16. Those objectives are the normative targets against which practical decisions are judged. The plan ties decision-making to measurable simulation outputs rather than pure policy discretion by specifying an assessment mechanism in s 18.

• IQQM computer program and approved alternatives. Section 18 makes the IQQM simulation the default assessment tool for consistency with the objectives and allows the chief executive to approve an alternative method only if satisfied it will assess consistency "at least as accurately as the IQQM computer program". The statute therefore elevates a specific hydrological modelling approach to the primary evidentiary standard for administrative compliance with objectives.

• Categorisation of unallocated water. Unallocated water is a finite resource and s 19 categorises it into three legally distinct pools: strategic water infrastructure reserve, strategic reserve and general reserve. Each category has an admitted policy function and permitted grant purposes under s 20: the strategic water infrastructure reserve is single-purpose (Awoonga Dam raising), the strategic reserve is reserved for State purposes, and the general reserve is the residual pool available for any authorised purpose.

• Numeric reserve caps and subcatchment-specific limits. Section 21 fixes numerical ceilings for certain allocations: 19,000 ML for water tied to Awoonga Dam raising; 500 ML for strategic reserve allocations in subcatchment B; 338 ML for general-reserve allocations in subcatchment A; and 1,000 ML for general-reserve allocations in subcatchment B. These volumes are binding maxima on the "total of the nominal entitlements" granted from those reserves.

• Lifecycle grants for State-purpose projects. Section 22 makes clear that water granted from the strategic reserve for a coordinated project or a project of regional significance is a time-limited grant for the life of the project, reverting on project conclusion. Section 23 supplies the statutory factors the chief executive must have regard to in classifying a project as regionally significant, including the chapter 3 outcomes, economic and social impact, public interest and any other relevant consideration.

• Pass flow condition. The plan operationalises environmental flow protection for licences taken from watercourses in subcatchment B by requiring licences from the strategic or general reserve to include a pass flow condition (s 25). The plan defines pass flow condition as a downstream flow rate that must be passing immediately downstream of the take while water is being taken under the licence.

• Limits on interference and purposes allowed. Part 4 (ss 28-33) limits the grantability of water licences to impound flow to listed purposes or to interferences in existence before 14 December 2000 (s 29). Where interference is allowed, the plan imposes "no greater than necessary" limitations on storage capacity (s 30, s 33) and specific operational caps for pumping pools upstream and downstream of Awoonga Dam (s 31). Town-supply related interferences require demonstrated water supply strategies and need (s 32).

• Licence content and amendment rules. Section 35 prescribes the core elements a licence must state (purpose, daily volumetric limit, nominal entitlement, conditions). Division 2 governs criteria for amending licences: s 36 defines "amended water licence"; s 37 sets out how the daily volumetric limit is derived from development permit pump sizes (via schedule 2) or, where not directly matched, the chief executive's discretion informed by measurement or estimation of current or capable take rates, and other contextual factors; s 38 requires the chief executive to consider pre-existing licence conditions when setting new conditions on an amended licence.

These concepts allocate technical authority to the chief executive, set quantitative ceilings for certain reserve releases, anchor assessment to a named modelling tool or approved equivalent and make clear that environmental flow protection is implemented through licence flow conditions and limits on storage and take volumes.

Identify who pays, who decides and who must change behaviour under the plan as written in ss 17-38 and related provisions.

• Chief executive. The chief executive is the central decision-maker. The instrument repeatedly gives the chief executive functions of approval and determination: approving an alternative assessment method only if it is at least as accurate as IQQM (s 18); considering whether a project is of regional significance using specified factors (s 23); determining volumes for water licences when development permits list pump sizes not in schedule 2 or when no related permit exists (s 37); and deciding conditions on amended licences, subject to the need to consider the existing licence conditions (s 38). The chief executive therefore bears implementation and discretionary authority.

• Landowners and water users holding or applying for licences. Owners of land may take water for stock or domestic purposes from watercourses, lakes or springs in the plan area under s 26. Licence applicants seeking unallocated water from the strategic water infrastructure reserve, strategic reserve, or general reserve must follow the processes set out in the resource operations plan or the Water Regulation 2016, as applicable (s 24). Applicants for interference licences to impound flow must demonstrate that their proposal is for an authorised purpose under Part 4 or pre-dates 14 December 2000 (s 29), and where the purpose is stock or domestic supply, must show that storage capacity is no greater than necessary and provide evidence of existing supplies (s 30). Licence holders seeking amendments will be subject to new daily volumetric limits and conditions as determined under ss 37-38.

• Local government and town water authorities. Section 32 imposes conditions on interference to improve security for town water supply. Applicants must satisfy the chief executive that the town has appropriate water supply security strategies, such as demand and drought management strategies, and that there is demonstrated need for increased reliability. This places an evidentiary and planning obligation on local supply authorities or the entities proposing interference works intended to enhance town supply.

• Proponents of coordinated projects and projects of regional significance. Section 22 and s 23 affect proponents by making grants of strategic-reserve water for these State purposes time-limited for the project life, and by making regional significance a discretionary finding by the chief executive based on chapter 3 outcomes, economic or social impact, public interest and other relevant considerations. Proponents seeking water for such projects must prepare material addressing those statutory factors.

• Applicants for unallocated water and potential market participants. Because unallocated water is split into three reserves with particular purposes and numeric caps (s 19-21), potential applicants are affected by the limited availability: 19,000 ML is ring-fenced for the Awoonga Dam raising; small aggregate volumes remain available from the strategic and general reserves in specified subcatchments. Market entrants or existing entitlement holders considering trade or augmentation will confront these quantitative constraints.

• Environmental and downstream users. The statutory requirement to include pass flow conditions for water licences taking from watercourses in subcatchment B that are granted from strategic or general reserves (s 25), the requirement that interference must not be greater than necessary (s 30, s 33), and the primacy of environmental flow objectives in s 17 all affect downstream environmental values and rights. Those with an interest in environmental flows are affected not as primary decision-makers, but through the licence conditions the chief executive must impose to secure consistency with the objectives.

• Regulatory agencies and technical consultants. The statutory elevation of IQQM as the default assessment tool (s 18) directly affects modelling consultants and regulators: those parties will either need to work in the IQQM framework or secure chief executive approval for alternative methods by demonstrating equal accuracy.

In short, the chief executive and licence applicants are the main decision-makers and payers of compliance costs, while local authorities, project proponents, licence holders, and environmental stakeholders are affected by the allocation, condition and assessment regimes set out in ss 17-38.

This part imposes statutory duties on the chief executive and on licence applicants or holders and confers limited rights on landowners and project proponents. The text provisions and duties are these.

Duties of the chief executive

• Consistency duty: Decisions about allocation or management of water (except certain water-permit decisions) must be consistent with the environmental flow objectives in s 14 and the water allocation security objective in s 16 (s 17). The chief executive must therefore ensure administrative decisions align with those objectives.

• Assessment duty: The chief executive must use the IQQM simulation for the simulation period to assess consistency with the objectives (s 18(1)). If IQQM is not practicable, the chief executive may approve another method only if satisfied it will be at least as accurate as IQQM (s 18(2)-(3)). This imposes a gatekeeping duty to judge methodological comparability.

• Approval and classification duties: The chief executive may classify a project as of regional significance only after considering the statutory factors in s 23. For State-purpose water grants, the chief executive must ensure such grants are time-limited to the life of the project (s 22).

• Decision-making on volumetric limits and conditions: When a water licence is amended under s 217 of the Act, the chief executive must set the daily volumetric limit according to the hierarchy in s 37, and consider existing licence conditions when deciding new conditions under s 38. Where pump sizes do not match schedule 2, the chief executive exercises discretion, guided by specified evidence.

Duties of applicants and licence holders

• Process compliance: Applicants for unallocated water must follow the grant processes specified in the resource operations plan for the strategic water infrastructure reserve, or the Water Regulation 2016 part and subdivision for strategic or general reserve water (s 24). Compliance with those processes is a precondition to allocation.

• Evidence burden for amendments and custom limits: Licence holders seeking to challenge the default daily volumetric limit tied to a schedule 2 pump size must satisfy the chief executive that the pump's water-taking capacity is different, and provide supporting material as required by s 37(2), including evidence of pump capacity, system function over the prior 10 years, and efficiency.

• Storage and interference limits: Applicants proposing to interfere with water for stock and domestic storage must show that the storage capacity is not greater than necessary and must disclose existing water supplies on the property (s 30). Applicants proposing pumping pools must ensure storage capacity is no greater than required for pump operation upstream of Awoonga Dam or for access to fresh water downstream (s 31). Town-supply related interference applicants must demonstrate security strategies and need (s 32).

Rights conferred

• Stock and domestic take: Section 26 grants landowners the right to take water from a watercourse, lake or spring in any way for stock or domestic purposes for the purposes of s 20A(5) of the Act. This is an express statutory right that operates in the plan area.

• Time-limited access for State projects: Proponents of coordinated projects or projects of regional significance have a right to water from the strategic reserve for the life of the project, subject to the chief executive's grant and the project being classed as regionally significant where applicable (s 22, s 23).

• Procedural and evidentiary opportunity: Licence holders have an opportunity to provide evidence about pump capacity, irrigation systems and efficiency to influence the chief executive’s determination of the daily volumetric limit (s 37(2)). This is an identifiable procedural right to influence the administrative decision.

The statutory architecture therefore establishes duties on the chief executive to apply objective modelling and statutory factors, places evidentiary and procedural duties on applicants, and secures limited rights for landowners and project proponents. The chief executive has significant gatekeeping and evaluative duties, while licence holders and applicants have duties to produce technical evidence to avoid default limits.

The source text supplied (secs 17-38 and related headings) contains provisions that shape licence content, assessment methods and grant processes but does not itself specify penalty structures or enforcement mechanisms in those sections. The Act and Water Regulation cross-references indicate enforcement and penalty regimes reside in other provisions of the Act or in the Water Regulation 2016 referenced in s 24. What the provided provisions do show about enforcement is the following.

• Licence conditions as compliance instruments. The plan prescribes mandatory elements of water licences (s 35) and mandatory inclusion of pass flow conditions for certain licences (s 25). Enforcement of a licence requirement would typically be by compliance and enforcement powers available under the parent Act. The plan uses licence conditions and quantified daily volumetric limits as the primary levers for operational compliance.

• Administrative discretion enabling enforcement actions. The chief executive’s responsibility to assess consistency with objectives using IQQM or approved alternatives (s 18) and to set daily volumetric limits and conditions on amended licences (ss 37-38) means non-compliance may be detected and remedied via administrative decision-making: by refusing an application, imposing conditions, or modifying existing licences under the Act. The presence of statutory caps (s 21) provides a measurable threshold against which enforcement action can be taken.

• Cross-reference to regulatory processes and other enforcement provisions. Section 24 directs the process for release of unallocated water to the resource operations plan or to the Water Regulation 2016 part and subdivision. Those instruments commonly contain procedural requirements and may also cross-refer to penalty provisions for contraventions. The supplied sections do not reproduce those enforcement clauses.

• Implication for disputes and remedies. Because the plan sets out decision standards, objective assessment mechanisms and precise quantitative ceilings, disputes about compliance are likely to centre on technical questions (IQQM outputs, alternative method comparability, measurement of pump capacities, whether storage is "no greater than necessary"). Remedies for breaches or disagreements are not contained in the text provided; the Act's enforcement chapter and the Water Regulation would need to be consulted to identify available penalties, compliance notices, or civil and criminal enforcement mechanisms.

• No express sanctions in these sections. The supplied sections do not create or specify fines, offence provisions, infringement notices, or orders to rectify. Consequently, enforcement of the substantive rules described here depends on the licensing regime and enforcement provisions located elsewhere in the Act and subordinate instruments referred to in s 24.

Practitioners should therefore treat this plan as prescribing substantive requirements and administrative decision standards, while enforcement mechanisms and penalties are to be located in the broader Act and the Water Regulation 2016. To determine coercive measures, applicable fines, and the procedures for issuing compliance notices, one must consult the enforcement parts of the Act and the Water Regulation referenced in s 24.

The plan is explicitly cross-referential. It embeds interaction points with the parent Act, the resource operations plan, the Water Regulation 2016 and other statutory instruments. The key interactions set out in the text are these.

• Interaction with the Act. Numerous provisions in the supplied text are expressly framed as applications or qualifications of provisions of the parent Act. For example, part 4 applies to applications made under s 206 of the Act for licences to interfere with flow by impounding (s 28). Sections 26 and 27 apply for the purposes of particular Act provisions (s 26 applies for s 20A(5) of the Act; s 27 applies for s 20(2) of the Act). Division 2 references amendment powers in s 217 of the Act (s 36). The plan therefore operates as a subordinate instrument imposing constraints and processes authorised by the Act and must be read in conjunction with those statutory provisions.

• Resource operations plan. Section 24(1) requires the process for granting unallocated water from the strategic water infrastructure reserve be the process stated in the resource operations plan. That means procedural steps, criteria or public notification requirements in the resource operations plan will apply to strategic water infrastructure reserve releases. Practitioners must read the resource operations plan to understand the full grant process and any additional constraints.

• Water Regulation 2016. Section 24(2) states that grants from the strategic reserve or the general reserve follow a process set out in the Water Regulation 2016 part 2 division 2 subdivision 2. This creates a legal dependency: statutory allocation processes, application requirements, assessment criteria and potentially fees or forms may be contained in that regulation. The plan does not duplicate those procedural rules. Compliance therefore requires consultation of the Water Regulation 2016.

• Schedule cross-reference. Section 37 derives default daily volumetric limits from pump sizes in schedule 2, column 1 and the corresponding volumes in schedule 2, column 2. The plan’s operation thus depends on Schedule 2 content, which is not reproduced in this excerpt. Practitioners must refer to schedule 2 to calculate default daily volumetric limits and to understand what pump sizes are listed.

• Spatial and temporal interplay. The plan imposes limits and caps tied to subcatchments (A and B) and to specific infrastructure (Awoonga Dam). Section 21’s caps are subcatchment-specific. Section 31 distinguishes upstream and downstream locations relative to Awoonga Dam for pumping pool storage capacity limits. These spatial references interact with cadastral and hydrological definitions elsewhere in the Act or subordinate instruments that define the plan area and subcatchment boundaries.

• Interaction with chapter 3 outcomes. Section 23 requires the chief executive to consider outcomes stated in chapter 3 when deciding whether a project is of regional significance. Thus the plan ties grantability to the plan’s broader outcome statements, which are likely to codify environmental, economic or social objectives. The text supplied does not reproduce chapter 3, so interpretation requires cross-reading.

• Relation to existing entitlements and historical rights. Section 29 allows a licence to be granted for interference with flow only if the purpose is provided in the part or the interference was in existence immediately before 14 December 2000. This locates the plan within a temporal and rights-protective framework, preserving pre-existing works. The interface with property and vested rights doctrines will be addressed by the Act and judicial interpretation, but the plan itself preserves historical interferences.

Overall, the supplied text is designed to operate within the statutory architecture established by the Act and specified subordinate instruments. Practitioners must read the Act, the resource operations plan and the cited parts of the Water Regulation 2016, and consult schedule 2 and chapter 3, to understand full duties, processes, procedural obligations and any fees or penalties that are not reproduced here.

The supplied text contains internal amendment annotations. These annotations identify particular clauses that have been amended or omitted and the statutory instruments effecting those changes. The explicit amendment notes in the text are:

• Section 24. The text includes the annotation "s 24 amd 2016 SL No. 216 s 146 sch 20" and repeats the content with an "(sec.24-ssec.1)" and "(sec.24-ssec.2)" breakdown. This indicates section 24 was amended by Subordinate Legislation No. 216 of 2016, specifically s 146 of schedule 20 to that instrument. The substance of s 24 now cross-references the resource operations plan for the strategic water infrastructure reserve and the Water Regulation 2016 part 2 division 2 subdivision 2 for strategic or general reserve processes.

• Section 30. The text includes "s 30 amd 2016 SL No. 216 s 146 sch 20" and repeats the section with "(sec.30-ssec...)" subsections. This signals an amendment in 2016 by the same subordinate legislation. The content requires the chief executive to consider existing water supplies on the property, and caps storage capacity to what is necessary for storing water to be taken for stock or domestic purposes.

• Section 34. The note "s 34 om 2014 SL No. 142 s 36" indicates section 34 was omitted by subordinate legislation number 142 of 2014, section 36. The text does not reproduce section 34 content because it was omitted.

• Section 35. The line "s 35 sub 2014 SL No. 142 s 37" indicates s 35 was substituted by Subordinate Legislation No. 142 of 2014, s 37. The current content of s 35 (elements of a water allocation) is therefore the 2014 substituted text.

• Section 37. The section text contains scheduling references to schedule 2 and its columns, and later includes a reference to "s 37-ssec..." formatting consistent with the amendment annotations for other sections. There is no explicit amendment line shown beneath s 37 other than the contextual notes; however the presence of substitution notes for s 35 and omission of s 34 is visible.

These annotations are the only amendment-history information present in the supplied excerpt. They identify that key operational provisions were modified in 2014 and 2016 by subordinate legislation, and that at least one section was removed in 2014. The supplied text does not list earlier amendments or the full chronology beyond the 2014 and 2016 subordinate instruments cited. To construct a complete amendment timeline, one must consult the statutory instruments repository to retrieve the full text of:

• Subordinate Legislation No. 142 of 2014, particularly s 36 and s 37 noted in the supplied text.
• Subordinate Legislation No. 216 of 2016, schedule 20 s 146.

These instruments will show the legislative history, the exact textual changes, commencement dates of those changes and any transitional provisions. The plan’s operational provisions as supplied reflect those amendments. Practitioners preparing compliance advice or transactional documentation should confirm the contemporary consolidated text and review the amendment instruments cited.

The supplied text does not name, summarise, or reference any judicial decisions or proceedings. There are no cases cited within sections 17-38 as reproduced. Consequently, the textual record provided does not contain a litigation history.

That absence of case citations has practical significance:

• No statutory interpretation guidance within the text. Because the supplied instrument does not record judicial interpretations, the statutory phrases in this part, such as "consistent with" (s 17), "at least as accurately as" (s 18), "no greater than is necessary" (ss 30 and 33), and the chief executive's discretionary standards, lack embedded case law in the text. Administrative actors and practitioners therefore cannot rely on the plan excerpt alone for precedent on how courts have read these phrases.

• Potential dispute loci are visible from the statutory language. The provisions most likely to generate litigation or review given their technical and discretionary character include: the chief executive’s approval of alternate assessment methods under s 18, where the "at least as accurately as" test is inherently comparative and technically complex; the derivation of daily volumetric limits under s 37 where factual assessments of pump capacity, system efficiency and historic water taking are central; the chief executive’s classification of regional significance under s 23, which brings evaluative public-interest judgments; and the "no greater than necessary" storage limitation in ss 30 and 33. While the plan sets the legal tests and decision-making criteria, the supplied text does not indicate whether courts have adjudicated their application.

• Administrative review pathways exist in the parent Act. The absence of reported decisions in this text does not mean disputes cannot be litigated. The Act will contain merit and judicial review pathways for applicants and licence holders to challenge administrative decisions. To understand the procedural history and precedents, one must search court and tribunal databases for decisions applying the Act and the plan.

• Advice caution. In practice, because this excerpt provides no litigation guidance, practitioners should prepare evidence and decision files to robustly support decisions and applications on technical grounds: include modelling outputs, calibration reports, pump and system specifications, historical usage records over the prior 10 years where relevant, and justifications linked to chapter 3 outcomes. That mitigates legal risk in adjudicable decisions but does not substitute for searching the case law for instances where these or analogous provisions were challenged.

To conclude, the supplied material contains no litigation history. For a complete picture of how courts have applied these provisions, one must search for decisions under the parent Act that reference the relevant sections and procedural rules cited in this plan.

The plan’s language contains specific operational pitfalls that can trap practitioners if they rely on surface readings or incomplete documentation. Below are concrete "gotchas" grounded in the text.

• IQQM as the default evidentiary standard creates a high technical bar. Section 18 makes IQQM the standardised tool for assessing consistency with environmental flow and allocation security objectives. Alternative methods may be used only with chief executive approval and only if they are "at least as accurately" assessing consistency. That requires applicants or consultants to either deliver IQQM outputs or prepare technical comparability demonstrations capable of satisfying the chief executive. Expect a significant evidentiary burden and modelling-resource cost if seeking to rely on non-IQQM approaches.

• Schedule 2 dependency for daily volumetric limits. Section 37 ties default daily volumetric limits to pump sizes in schedule 2, column 1 with corresponding volumes in schedule 2, column 2. If the related development permit states a pump size not listed in schedule 2, the chief executive must decide a volume by analogy. If there is no related development permit the chief executive uses other measures. Practitioners should not assume an automatic mapping exists; confirm schedule 2 content and the mapping logic before drafting or relying on limits.

• The "existing pump" rebuttal requires documentary proof spanning up to 10 years. Section 37(2) allows licence holders to convince the chief executive that the pump’s water-taking capacity differs from the default limit, but the evidentiary matrix includes the irrigation or water distribution system related to the pump during the period of not more than 10 years before plan commencement. If historical records are weak or absent, meeting that burden may be difficult.

• Quantitative caps are small and specific in scope. Section 21 fixes ceilings: 19,000 ML reserved for Awoonga Dam raising; small totals for strategic and general reserves in defined subcatchments. Applicants seeking unallocated water should not assume significant water is available; the statutory caps are firm "totals" for nominal entitlements and will constrain large projects unless the grant is from the strategic water infrastructure reserve for the specified dam raising.

• Pass flow condition mandated only for certain takes and not for impoundments. Section 25 requires pass flow conditions for water licences to take from watercourses in subcatchment B that are granted from strategic or general reserves, but expressly excludes impoundments. Parties may therefore see different environmental constraints depending on whether the take is from a watercourse or an impoundment. If a project proposes impoundment plus diversions, environmental flow protections may attach differently to each licence.

• Interference eligibility limited to listed purposes or pre-2000 works. Section 29 forbids grants for interferences unless the purpose is provided for in the part or the interference was in existence immediately before 14 December 2000. New or novel interference proposals outside the enumerated purposes will be excluded. This is a hard eligibility criterion; applicants must map their purpose to the textual list or demonstrate historical existence.

• Storage caps expressed in "no greater than necessary" language. Sections 30 and 33 require that storage capacity must not be greater than is necessary for the stated purpose and that interference must not be greater than necessary. These are fact-sensitive standards that will draw close scrutiny from the chief executive and likely require engineering, operational and demand analysis to justify proposed capacities.

• Strategic reserve grants to State purposes are temporary. Section 22 grants from the strategic reserve for coordinated or regionally significant projects are only for the life of the project and revert on conclusion. Parties contemplating long-term business models reliant on such allocations must factor the temporal nature into financing and contractual arrangements.

• Multiple procedural instruments govern grant processes. Section 24 delegates process details to the resource operations plan and the Water Regulation 2016. Failure to consult those instruments can be fatal to an application that otherwise complies with the plan’s substantive requirements. Always cross-check both instruments.

• "Demonstrated need" for town supply interventions. Section 32 requires applicants to show that towns have appropriate water supply security strategies and that there is a demonstrated need for increased reliability. Mere project rationale will be insufficient; formal strategies and evidence of need must exist and be presented.

• Omitted and substituted sections. The amendment notes show s 34 was omitted and s 35 substituted in 2014, with other 2016 amendments. Practitioners should confirm the consolidated text, as older documents or earlier versions may contain different obligations. Do not rely on pre-amendment drafts.

Each of these is a concrete implementation trap anchored in a specific section. The mitigation is documentary and technical: obtain IQQM outputs or prepare rigorous comparability, secure historical pump and system records for rebuttal, check schedule 2 and the resource operations plan, build temporary funding and contract plans for time-limited grants, and prepare technical justifications for storage sized "no greater than necessary".

This section explains practical steps, evidence needs and procedural checkpoints for applicants, licence holders and advisers seeking to comply with the plan as written in ss 17-38.

1. Anchor decisions to the objectives and prepare model outputs (s 17-18)

• Requirement: Ensure any allocation or management decision is demonstrably consistent with the environmental flow objectives in s 14 and the water allocation security objective in s 16 (s 17).
• Action: Obtain or produce the IQQM simulation outputs for the simulation period. The statute makes IQQM the default assessment method (s 18(1)). Where IQQM is impracticable, prepare a detailed technical report comparing the alternative method to IQQM and submit it for chief executive approval, addressing why the alternative is at least as accurate as IQQM (s 18(2)-(3)).

2. Match the unallocated water application to the correct reserve and process (ss 19-24)

• Requirement: Identify whether the water sought is to be drawn from the strategic water infrastructure reserve, the strategic reserve or the general reserve (s 19). Each reserve has different permitted purposes (s 20).
• Action: If the purpose relates to raising Awoonga Dam, apply under the process in the resource operations plan (s 24(1)). For State-purpose or general-purpose releases, follow the Water Regulation 2016 part 2 division 2 subdivision 2 process (s 24(2)). Confirm the resource operations plan and the specific Water Regulation subdivision for forms, timelines and consultation requirements.

3. Check reserve volume caps before project design (s 21)

• Requirement: Confirm availability against statutory caps: 19,000 ML for the strategic water infrastructure reserve linked to Awoonga, 500 ML strategic reserve in subcatchment B, 338 ML general reserve in subcatchment A and 1,000 ML general reserve in subcatchment B.
• Action: Before committing to capital or contractual obligations, request written confirmation from the department of available unallocated water in the relevant reserve and subcatchment, and secure appropriate reservation or allocation rights per the resource operations plan or the Water Regulation.

4. Prepare specialist evidence for interference and storage proposals (ss 28-33)

• Requirement: Interference licences by impounding are only grantable for purposes provided in Part 4 or for pre-14 December 2000 interferences (s 29). Storage must be no larger than necessary and existing supplies on the property must be documented for stock/domestic storage (s 30). Pumping pools have defined sizing criteria (s 31). Town-supply projects must present supply security strategies and demonstrated need (s 32). Interference associated with taking unallocated water must be proportionate and licences in subcatchment B must include flow conditions (s 33).
• Action: Produce engineering designs, demand projections, existing supply audits, and alternative supply assessments. For town projects, prepare formal demand and drought management strategies. Ensure planning and environmental approvals align with the storage capacity limits and the "no greater than necessary" standard.

5. Ensure licence form and content compliance (s 35)

• Requirement: A water licence for unsupplemented water must state the permitted purpose (either 'agriculture' or 'any'), the daily volumetric limit, the nominal entitlement and any conditions including flow conditions.
• Action: Draft licence applications and instruments to include these elements explicitly. If seeking "any" purpose, ensure the application and supporting material justify the broader use.

6. Anticipate and prepare submissions for volumetric limit determinations (s 37)

• Requirement: When an amended water licence is at issue, the daily volumetric limit is determined by the schedule 2 pump-size mapping if the related development permit states a pump size in schedule 2; if not, the chief executive decides based on analogous pump sizes or other evidence including measurement or estimate of actual or capable take rates (s 37).
• Action: Compile calibrated pump test data, development permits, manufacturing pump curves, irrigation distribution system diagrams, operational regimes and 10-year historical usage records where available. Prepare an evidence bundle that addresses the chief executive’s listed considerations (conditions under which water is taken, the water-taking capacity of the existing pump under normal operating conditions, the irrigation system over the prior 10 years, and efficiency metrics) to support any deviation from default schedule 2 volumes.

7. Prepare to meet pass flow and flow condition requirements (s 25, s 33)

• Requirement: Licences to take water from watercourses in subcatchment B granted from the strategic or general reserves must include pass flow conditions. Licences associated with unallocated water releases in subcatchment B must include flow conditions (s 33).
• Action: Design operations to respect the pass flow rate. Develop monitoring and telemetry plans to measure downstream flows at the specified location and to demonstrate ongoing compliance. Include contingencies in operational plans for low-flow periods.

8. Record-keeping and documentary proof for discretionary assessments

• Requirement: The chief executive exercises qualitative and technical discretion in many places (ss 18, 23, 37). Decisions will be evidence-led.
• Action: Maintain contemporaneous modelling inputs and outputs, calibration records, maintenance logs for pumps, historical usage records, water allocation and trade records, consultation records, and any community or stakeholder engagement documentation relevant to regional significance or public interest considerations.

9. Understand temporal nature of strategic reserve grants (s 22)

• Requirement: Grants from the strategic reserve for coordinated projects or projects of regional significance are for the life of the project only.
• Action: Structure financing and contract terms to reflect the temporariness, including exit strategies and contingency for reversion of water to the strategic reserve. Obtain explicit grant instruments that record the project lifecycle terms.

10. Cross-check external instruments and consolidated text

• Requirement: The plan refers to the resource operations plan, the Water Regulation 2016 and schedule 2. Amendment annotations indicate prior changes (see Amendment history).
• Action: Always work from the consolidated statute and consult the resource operations plan, the Water Regulation 2016 (part 2 division 2 subdivision 2), and schedule 2. Check the legislative instruments cited in the Amendment history to confirm current wording and transitional arrangements.

Following the procedural and evidentiary steps above aligns applications and licence operations with the statutory tests in ss 17-38. The recurring practical imperatives are rigorous hydrological modelling compliant with IQQM or an approved equivalent, thorough historical and technical documentation for pumps and systems, and careful mapping of proposals to the statutory purposes and reserve caps.