A series of stages have been developed to guide proponents and operators of proposed MAR schemes through concept design and implementation, and assist with understanding the regulatory requirements of each stage.
These stages are based on the risk management framework outlined in the Australian Guidelines for MAR. Further information about how this works in the context of South Australian regulation is available via:
MAR Stages and Regulatory Approvals Flowchart
MAR Recharge Stages and Regulatory Approvals Explanatory notes
This process ensures the MAR scheme operator will:
Identify risks associated with catchment, hydrogeology, construction, and operations.
Include within MAR RMMPs (for example if risk identified as potentially requiring mitigation):
- Injection pressure management
- continuous online and/or grab samples
- same aquifer monitoring wells and/or unconfined aquifer monitoring wells
- surface water monitoring points and parameters
- whether pressure transducers/data loggers will be installed
- establishment of trigger levels for monitored parameters
- injection criteria
- exceedances register and actions
- provisions for regular meter readings and volumes per well and from the surface water extraction point/s (extraction and injection operations must be metered without interference and metering requirements can be ascertained from DEW).
For the EPA and DEW, appropriate monitoring is crucial to ensure the MAR operator can conduct compliance reporting as required. Considerations of this reporting include:
- Use of MAR Annual Reporting Template (MAR ART) - MAR AR will keep track of changes to schemes over time, provides a consistent approach across schemes, makes data collection and interpretation easier.
- Exceedances and findings from reporting to feedback into potential changes to the risk management plan or monitoring requirements.
- Meter data assists determine DEW licence allocations for the following period for take and any rollovers of allocations if available.
Monitoring and management plans and risk management activities ensure that operation of the MAR scheme will not cause unreasonable impacts on existing users, including the environment. Most MAR schemes across South Australia go in and out of research and development phases. This ensures adaptive monitoring, management and improvements as schemes utilise innovative thinking and technology to optimise the whole of their schemes operations. If a scheme is expanding their water capture, storage and distribution operations, a hydrological review of the scheme may be appropriate and could include revisiting the groundwater/surface water models developed for the scheme during the earlier conceptualisation stage, further validation of the models and model update (if deemed appropriate). Data collected as part of compliance reporting is deemed crucial for this evaluation to occur.
Stage One: Desktop study
For all schemes, other than domestic, a Stage One (desktop study) must be undertaken to determine if the scheme fits the criteria of a small or large scheme, if further information is required, any necessary investigations, and an indication of the scheme’s viability.
Stage Two: Investigation and assessment
Proponents of schemes other than low risk schemes identified in Stage One are required to proceed to a Stage Two risk assessment and gather further information to support their scheme. In most cases the information gaps and uncertainty will be detailed as a result of Stage One.
The likely steps include:
- gathering outstanding data and information
- undertaking a maximal risk assessment to determine hazards and evaluate risk
- identifying and confirming performance of appropriate preventative measures
- determining if the scheme can be operated at a low risk
- preparing a draft risk management plan and lodging an application for assessment, either through a development application or Environment Protection Authority (EPA) works approval.
Proponents will be asked to provide documented evidence of the risk assessment process as part of an application for an EPA works approval or development approval, or departmental permit, depending on the amount and source of water to be recharged to the aquifer.
Agencies including the EPA, DEW and the Department of Health may be called on to provide input into the assessment process. Successful completion of the risk assessment process will determine if the MAR scheme is worthy of a licence or permit, and is able to proceed to the next stage.
Note: Proponents and consultants are reminded that under Section 83A of the Environment Protection Act 1993, they must notify the EPA in writing as soon as reasonably practicable after becoming aware of any existence of site contamination at the site or in the vicinity of the site.
Stage Three: Construction, commissioning and validation
If the scheme is deemed low risk after assessment, the proponent can now proceed to Stage Three where construction, commissioning and validation are carried out.
- finalising the risk management plan and operational management plan
- validating preventative measures
- finalising the regulatory process for the EPA licence to operate.
During Stage Three, developers must ensure that associated environmental issues - such as stormwater runoff, sediment, dust, noise and drilling spoils - are controlled so no adverse impacts are caused.
Stage Four: Operation and verification
If the preventative measures are validated to be effective and the scheme is confirmed to be able to operate at a low risk, the operator proceeds to Stage Four for operation and verification of the scheme. This includes:
- finalisation of the MAR risk monitoring and management plan
- operational management of the scheme to maintain low risk
- compliance with the regulatory approvals including monitoring and reporting
- response to monitoring, emergency incidents and remedial action if necessary.
MAR scheme approvals will be managed jointly by the EPA (discharge to aquifer licence) and DEW (including water licence and allocation to extract recharged water), including joint annual reporting utilising the MAR Annual Reporting Template. Appropriate compliance actions will be taken by each agency if necessary.
Stage Five: Decommissioning
Decommissioning will be required when a scheme has reached the end of its useful life, which will include:
- testing the aquifer condition
- remediating if necessary
- decommissioning wells and removing infrastructure.
The EPA will oversee any site contamination issues.
A well construction permit is required to plug, drill, backfill or seal a well.