Is thermal use of groundwater a pollution?

Thermal use of the shallow subsurface and its aquifers (< 400 m) is steadily increasing. Currently, more than 2800 aquifer thermal energy storage (ATES) systems are operating worldwide alongside more than 1.2 million ground source heat pump (GSHP) systems in Europe alone. These rising numbers of shallow geothermal energy (SGE) systems will put additional pressure on typically vulnerable groundwater systems. Hitherto, suitable criteria to control the thermal use of groundwater in national and international legislations are often still at a preliminary state or even non-existing. While the European Union (EU) Water Framework Directive (WFD) defined the release of heat into the groundwater as pollution in the year 2000, the cooling of groundwater for heating purposes is not explicitly mentioned yet. In contrast, some national legislations have stricter guidelines. For example, in Germany, detrimental changes in physical, chemical and biological characteristics have to be avoided. In the Swiss water ordinance, it is even recommended that the groundwater biocenosis should be kept in natural state. However, exact definitions of 'detrimental changes' and 'natural state' are still missing. Hence, the current study provides an overview on natural and affected thermal groundwater conditions and international and national legislations of the thermal use of groundwater. Also, it presents recent studies on groundwater ecosystems and proposes a sustainable policy framework for the thermal use of groundwater. In addition to geothermal heat sources, other anthropogenic heat sources such as climate change, underground car parks, heated basements, district heating systems, land fills, wastewater treatment plants and mining are considered, although no legislation on these anthropogenic heat sources and their impact on groundwater is currently in place. Finally, we intend to answer the above question and provide recommendations for the further discussions on the joint use of shallow groundwater systems for drinking water production and thermal use.