No decisions have been made regarding reductions to allocations.

The Limestone Coast Landscape Board has been transparent that reductions to allocations are within scope of the amendment process. Some areas within the Lower Limestone Coast Prescribed Wells Area are over allocated and reductions to allocations is one way to address this. Adaptive management is another way to manage over allocation.

As part of the amendment, the Limestone Coast Landscape Board is considering both ways to address over allocation. Community and stakeholders will be a part of the process to determine the best way forward to bring over allocation back to agreed sustainable limits.

If adaptive management is implemented into the Plan, the framework would have triggers to take action when resource conditions worsen and remove those actions when conditions improve. These would be transparently detailed in the revised Plan.

Management actions could include notifying licence holders of changes to resource condition, temporary suspension of trade and restrictions to allocations but also lifting restrictions to allocations. Triggers will be designed to prevent the resource reaching resource condition limits beyond which the impacts to users and dependent ecosystems are considered unacceptable.

A restriction is not a permanent loss of allocation unless resource condition does not improve. In contrast a reduction to allocation is a permanent loss of allocation.

Industries will have equal opportunity to participate in the process. No one industry will receive special treatment. The Limestone Coast Landscape Board recognises that every industry is different and has business operations that need to be considered to ensure that the revised Plan can support the region. This is consistent with the current Plan which has a range of principles developed in consideration of certain industries.

A key way in which stakeholders can support the process is by sharing knowledge about how they operate and how they could operate under proposed revisions.

The Limestone Coast Landscape Board is reconsidering allocations using an acceptable impact approach. This is different to taking an annual average recharge rate and allocating a percent to the environment. It has been demonstrated that an approach of taking an annual average recharge rate and allocating a percent to the environment is insufficient to protect ecosystems that depend on groundwater. In fact, this approach is largely considered to ignore the dependence of ecosystems on groundwater. It is an approach that allows local areas of water table decline to impact wetlands.

Taking a different approach and not allocating a percent to the environment does not mean that the environment is ignored.

Water allocations plans developed in South Australian since around 2016 have been using the approach of acceptable impact underpinned by resource condition triggers and limits. Through consultation resource condition limits are determined. If resource condition falls below these limits the effects are not impacts we accept. Triggers are designed to prevent resource condition reaching the limit. Key trigger and limit types under consideration are groundwater levels and salinity. But other triggers or limits may be important for wetlands such as discharge rates. Triggers and limits must be ecologically relevant if their intent is to protect wetlands.

Using an acceptable impact approach is a key way to improve how the Plan provides for and protects the environment.

Through 2022-23 the Limestone Coast Landscape Board reviewed the Plan and identified critical areas for improvement. Amendment is important to ensure the plan continues support the region into the future. It is common for water allocation plans to need amendment. This is often the case as data and science improves our understanding of our water resources. Amendment is focusing on new knowledge, sustainable allocation, environmental provisions, legislative and policy alignment, licencing complexity, administrative ease and the water market.

Sustainable allocation and environmental provisions are areas of focus due over allocation and groundwater resource condition decline. Despite the improvements in water policy introduced by the Plan some groundwater declines have continued. Climate is projected to be dryer and hotter which will likely increase demand for water. It is important to undertake revisions now for long term sustainability of the resource.

The Lower Limestone Coast is highly groundwater dependent with few surface water sources such as rivers and lakes. Many uses and values are dependent on groundwater. These uses include viticulture, horticulture, dairy, livestock production, plantation forestry, public water supply and stock and domestic.

Amending the Plan is about supporting all of these uses and values and their dependence on groundwater. Groundwater declines will impact availability and quality of groundwater for industries and environment. The Limestone Coast Landscape Board recognises how hard this process will be and the uncertainty it creates but it is a critical process for water and all we value in the Lower Limestone Coast. It is a process that matters to everyone.

Activation of water now provides no guarantee that you will not be impacted by management actions the arise from the revised Plan. As part of the amendment process the Limestone Coast Landscape Board is reconsidering the current allocations but is not targeting unused water in this process.

Across the Lower Limestone Coast Prescribed Wells Area use of allocation in the confined and unconfined aquifers is approximately 50%. This leaves approximately 50% of allocations unused. But use percentages vary between management areas, from 20% to 90% use of allocation. Use also varies with rainfall.

Allocations are being revised using an acceptable impact approach. Through this process the actions required to address or manage over allocation will be determined. This will likely be different across the prescribed wells area. It will depend on the impacts that we don't accept happening to the environment or uses dependent on the groundwater. Simply removing unused water will not address or manage over allocation.

When considering the impact of use the Limestone Coast Landscape Board will consider the impact of all allocation being used. The Limestone Coast Landscape Board recognises that to date the full allocation for the prescribed wells area has not been used. There are a range of barriers or reasons as to why use varies from allocation. These vary from business to business and between industries. But barriers and reasons for not using water change through time. This can result in the activation of unused water, and this has occurred in places across the prescribed wells area. Use of full allocation must be considered in the revision of the Plan to fully understand the risk and impacts of all allocation being used.

Climate change is one topic of the amendment process. Climate trends change water availability and reliability. They also change the frequency and severity of extreme events like drought. This will impact our water resources. Climate change may also affect the demand for water. We must then consider a changing climate in the management of our water resources. The amendment process with focus on managing water allocations in the most practical way to reduce risks associated with expected declines in rainfall and recharge. This includes considering adaptive management that triggers responses to changes in resource condition.

Climate projections are projections not predictions. They estimate or forecast possible climate futures under different emissions scenarios. They come with assumptions and uncertainty. We will take this into account when applying them to the amendment process.

Under the objects and principles of the Landscape South Australia Act 2019 climate change is a significant factor in our environment. In the management of our natural resources we must consider the need for mitigation and adaptation.