Ecosystems and biodiversity in the Lower Limestone Coast, including threatened species and ecological communities, are dependent on groundwater. Wetlands in the Lower Limestone Coast are biodiversity strongholds, unique and highly valued. The Plan has a critical role in protecting ecosystems and biodiversity from the impacts of groundwater extraction and recharge interception. Ongoing groundwater level declines are impacting our wetlands, particularly shallow wetlands.

At the broadest scale setting a sustainable limit for each management area, nominally 10% of average annual vertical recharge for the environment, was the most important environmental provision within the Plan. The sustainable limits have been demonstrated to not be enough as environmental provisions.

The protections in the Plan are focussed on priority, high and very high conservation value groundwater dependent wetlands. There are no specific protections provided to other dependent ecosystems with only the assumption that managing groundwater level would effectively provide for them.

The setback principles only apply to new risks posed by irrigation or commercial forestry (e.g. new wells or new commercial forestry plantations). Existing impacts of irrigation and commercial forestry are exempt, as is stock and domestic bores and farm forestry. If existing extraction and/or forestry was directly impacting a groundwater dependent wetland, for which there is evidence that this is occurring, there is no mechanism in the Plan to manage this.

The thresholds set by the Plan lack ecological relevance for some groundwater dependent ecosystems. They actually allow ongoing declines that negatively impact ecosystems and biodiversity. The Plan was insufficient in its recognition of the negative impact of groundwater declines on the condition of groundwater dependent ecosystems and as a result it could not do what it intended.