Submission on Draft Royal Park Master Plan

Submission on Draft Royal Park Master Plan (Master Plan)

From Entomological Society of Victoria

The Entomological Society of Victoria has a membership of more than 300 entomology enthusiasts, professional and amateur. One of our objectives is “the protection and preservation of the insects of Australia”. 

In furtherance of that objective, we make this submission about the Master Plan.

The Royal Park Master Plan Biodiversity and Ecology Report (Ecology Report), commissioned to inform the development of the Master Plan states:

“Royal Park has significant existing biodiversity values and many opportunities to further increase and improve habitat to increase flora and fauna diversity.”

We draw attention also to the following pertinent statements in the Ecology Report:

“Consequently, it is a park with high ecological and landscape value. These qualities are valued by visitors and local residents, many of whom have a strong environmental ethos, and are highly educated and politically connected. “

“Now, in addition to sport, the park is increasingly used for nature-based recreational activities, such as walking and bird watching, as well community-based ecological restoration activities (i.e. by friends groups). Its improving ecological values are increasingly being recognized by the City and the public and therefore also need to be balanced against other, potentially detrimental uses.”

“Increasing biodiversity, through species reintroductions, would contribute to the restoration of ecosystems severely affected by the European settlement of Melbourne.”

“Continuously working to improve biodiversity in Royal Park and undertaking innovative urban ecology projects will reinforce the City of Melbourne’s global reputation and leadership in this area.”

In our view, the Master Plan is deficient in that it does not sufficiently align with these sentiments enunciated in the Ecology Report.

Many of the changes to Royal Park proposed by the Master Plan will adversely impact the ecosystems and biodiversity of Royal Park, of which the native invertebrates are a key element.

The loss of habitat which will result from the implementation of the Master Plan will accelerate the decline in insect populations and put at risk their diverse contributions to the functioning of Royal Park ecosystems.

Royal Park provides uniquely valuable and irreplaceable habitat for many species of invertebrate. Just ask Roch Desmier de Chenon, member of our Society, renowned entomologist, native bee expert, Parkville resident and longtime observer and researcher of natural history in Royal Park. He has a mass of high-quality observations and data on the insects of Royal Park.

He has, for example, significant data about the approximately 90 species of native bees which he has observed in Royal Park.

In 2013, he made a submission in relation to the impact on Royal Park of the proposed East West Link, in which he stated: “The number of different species of insects in the Park is estimated to be more than one thousand. Most of them are limited in number, each species linked to a special food plant and living larvae conditions, often very specific. Many are very dependent on particular plant species. Disturbance of the ecosystems in the Park could be fatal for some of them.”

He listed as examples some species which he considered as “iconic due to their beauty, rarity or the influence which they have in maintaining a special natural biocontrol balance, avoiding pest outbreaks. Many are also essential for the pollination of the plants inside the Park.”

Sadly, in the decade or so since he commenced his observations, he has witnessed a marked decline in Royal Park in the number of insect species and their individual abundance.

One example of a species which was a spectacular “icon” a decade ago and which was then present in summer in large numbers, but which has since then virtually disappeared from Royal Park, is Scutiphora pedicellata (Kirby), Heteroptera Scutelleridae   Metallic Shield Bug,

A recent study[1] by prominent Australian entomologists estimates that, since colonisation in 1788, approximately 9000 species (known and unknown) of non-marine invertebrates have become extinct in Australia and that such extinctions are continuing at an estimated rate of between 40 and 150 species per annum (1 to 3 species per week).

We hear reports, from all around the world, of the apparent significant decline of insect numbers (both of individual species and biomass). This worrying phenomenon has been called the “Insect Apocalypse”[2].

Many reasons have been advanced, which could no doubt be summarised as “disturbance of insects and their habitat”; which makes it vital that we prioritise the avoidance of further “disturbance” where we can.

In our view the Master Plan does not advance that objective.

The Master Plan includes proposals which will in our view unnecessarily continue the “death by a thousand cuts” of the natural habitat of Royal Park and its insects, including:

1 Creating more sporting facilities, ovals, courts, pavilions and infrastructure at the expense of natural parkland.

2 More constructed pathways.

3 More artificial lighting in Royal Park. The adverse impact of light pollution on our insects and other native species is widely recognised. For example, Zoos Victoria Fighting Extinction campaign advocates “Lights off for the Bogong Moths”.

We support the concerns jointly expressed by the four community groups, all with a deep local interest in Royal Park, namely Parkville Association, Friends of Royal Park, Royal Park Protection Group and Protectors of Public Lands Victoria. They summarise their concerns about the Master Plan as that it proposes an inappropriate “intensification and expansion of active sporting use to the detriment of informal, passive recreational use and the Park’s environmental values and amenity.” We agree entirely.

For these important reasons, the Entomological Society of Victoria requests that there be a reconsideration of the Master Plan.

Yours Sincerely

Gordon Ley

President

dgpiley@hotmail.com

24 January 2025

[1] This is the way the world ends; not with a bang but a whimper: Estimating the number and ongoing rate of extinctions of Australian non-marine invertebrates Cambridge University Press: 09 December 2024 John C.Z. Woinarski, Michael F. Braby, Heloise Gibb, Mark S. Harvey, Sarah M. Legge, Jessica R. Marsh, Melinda L. Moir, Tim R. New, Michael G. Rix, Brett P. Murphy

[2] The insect apocalypse, and why it matters Goulson, Dave, Current Biology, Volume 29, Issue 19

Vale Ian Endersby

The Entomological Society of Victoria is sad to learn of the death, on 19 April 2024, of our esteemed Life Member and former President of the Society, Ian Endersby. We acknowledge his valuable contributions to the Society over many years. We extend our sincere condolences to his family and his friends during this difficult time.

Gordon Ley, President

Warburton Mountain Bike Destination - Project Submission

Warburton Mountain Bike Project

Yarra Ranges Council is seeking approval to build and operate 177 kilometres of mountain bike trials and infrastructure near Warburton, 70 kilometres east of Melbourne. Stage 1 of the Project is to the south of the town through state forest and other private and public land. Stage 2 is to the north of the town on Mount Donna Buang, which is within Yarra Ranges National Park.
The Minister for Planning has appointed an Inquiry and Advisory Committee (IAC) to advise on the Project and the many submissions received. On 15 March, 2022, a five-week hearing began (IAC website: https://engage.vic.gov.au/warburton-iac)
The Entomological Society of Victoria lodged a submission prepared by Gordon Ley (Submission No: 2177) https://engage.vic.gov.au/download/document/23717. He has questioned several of the witnesses for the Proponent and will make a further oral submission on 29 March 2022.
The submission of the Society is that the Warburton Mountain Bike Destination Project must not proceed, unless it is amended so as to exclude Stage 2, so as to avoid any encroachment upon the Yarra Ranges National Park. We believe that the National Park Management Plan makes it clear that neither the construction works nor the “biking” activities of the Project would be compatible with the values of the National Park.
We focused particularly on the fact that the Yarra Ranges National Park is the only known habitat of the critically endangered species Riekoperla darlingtoni — Mount Donna Buang Wingless Stonefly, which would be at significant risk if the Project were to go ahead in the National Park.

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1.       The Entomological Society of Victoria Inc dates back to 1927. Its objects are to encourage the study and preservation of insects. The membership includes scientists and other members of the community with an interest in insects. Members’ meeting are usually held at Melbourne Museum.

2.       The submission of the Society is that the Warburton Mountain Bike Destination Project must not proceed, unless it is amended so as to exclude any encroachment upon the Yarra Ranges National Park (“National Park”).

3.       We believe that the Yarra Ranges National Park Management Plan of 2002 makes it clear that neither the Project construction works nor the “biking” activities would be compatible with the values of the National Park. The following are extracts from the 2002 Management Plan which we believe support our submission:

“  Natural values • Several land systems which are inadequately represented in other conservation reserves. • The occurrence of 14 of the 23 Ecological Vegetation Classes (EVCs) identified in the Central Highlands region. • Sites of National and State botanical significance. • The mainland’s most westerly occurrence of sub-alpine vegetation communities, at Lake Mountain. • Botanically significant representation of old-growth Mountain Ash Wet Forest and Cool Temperate Rainforest. • Twenty rare or threatened flora species. • Large areas of mature forest important for conserving hollow-dependent fauna species. • Twenty-one threatened fauna species

Yarra Ranges National Park is reserved and managed under the provisions of the National Parks Act.

Park management aims The aims for the park, consistent with the Government-accepted LCC regulations and legislation, are as follows: Conservation • Preserve and protect the natural environment. • Allow natural environmental processes to continue with the minimum of interference. • Maintain biodiversity. • Conserve features of archaeological, historical and cultural significance.

The park is one of the key regions in the State for its diversity of mammals and other vertebrates. This diversity results from the diversity of types and ages of ecological communities, which provide a broad range of habitats, and the undisturbed nature of the catchments, which have been largely protected from human activity. The large areas of mature and mixed-age forests are particularly important for the conservation of hollow dependent species such as arboreal mammals, bats, owls and parrots. Twenty-one species are considered threatened, including 10 listed under the Flora and Fauna Guarantee Act.

The Maroondah Unit of the park contains the entire known population of the vulnerable Mt Donna Buang Stonefly (underline added)”

4.       The Mount Donna Buang area of the Yarra Ranges is listed as the Donna Buang Range on the Register of the National Estate for: “regional significance due to: its outstanding visual importance as a component of the beautiful Upper Yarra Valley; the magnificent panoramic views obtainable from many places within the range; its importance as a habitat for native plants and animal species; its role in the provision of nature based recreational activities that are easily accessible to people of Melbourne.”

5.       The National Park is home to diverse and unique ecosystems and species (including endangered species and no doubt some species not yet described). The protection of these ecosystems and species could perhaps have been assumed by the fact that they exist within an area designated as a national park. We submit that this assumption will prove to be misplaced if the inappropriate development and use which constitute the Project are permitted to proceed within the National Park.

6.       It seems from the material presented by the Proponent of the Project that the part of the Project, which proposes construction and use of mountain bike tracks in the National Park, is not an essential part of the Project and that it could proceed in a viable fashion without including any tracks within the National Park

7.       The focus of the Society in relation to the Project is the potential impact on insects and their habitat within the National Park. As to the more general view of the negative impact of the Project on the National Park, we endorse the views expressed by Victorian National Parks Association in its submissions.

8.       Of particular concern to the Society is the existential threat which the Project poses to the species Riekoperla darlingtoni — Mount Donna Buang Wingless Stonefly.

9.        Mount Donna Buang Wingless Stonefly

a.       The only wingless stonefly found in Victoria

b.       To date, found nowhere else in the world except in the National Park within 1 km of the summit of Mt Donna Buang

c.       Requires slow flowing ephemeral springs in forest above 900m

d.       Lives an unusually long life 2.5 to 3 years

e.       Numbers found to be in significant decline (at least 90%) between 2006 and 2016

f.        Likely to be extremely sensitive to any amount of water pollution, sedimentation and any forms of habitat alteration

g.       Subject to high risk from any changes in hydrology and sedimentation of the water in montane trickles

h.       At high risk as a result of soil compaction and erosion during construction and operation of the Project.

i.         At high risk from impacting the ground near to the springs on which the species relies
These above qualities are extracted from the report carried out for the Proponent by Eddie Tsyrlin, entitled: “Survey of the Mount Donna Buang Wingless Stonefly Riekoperla darlingtonia in relation to the proposed Warburton mountain bike trail” and subsequent report dated July 2021. The Society acknowledges the expertise of the author in relation to this species.

j.         Discovered in 1931

k.       Listed as Critically Endangered (Flora and Fauna Guarantee Act 1988 (Victoria): January 2021 list)

l.         Listed as Critically Endangered (Global Status: IUCN Red List of Threatened Species: 2020.2 list)

m.     Listed as Critically Endangered (Advisory List of Threatened Invertebrate Fauna in Victoria: 2009)

n.       Mount Donna Buang itself is listed on the Register of the National Estate in recognition of the presence of the Mt Donna Buang Wingless Stonefly.

o.       Mount Donna Buang Wingless Stonefly Habitat, Donna Buang Rd, Warburton, VIC, Australia is listed on the Register of the National Estate as follows:   “The nominated area supports a rare and endangered invertebrate species, Riekoperla darlingtoni, which is of considerable importance in the study of Australian Pleceptera and evolutionary strategies in invertebrates.”

10.   The following extracts from material prepared under the Flora and Fauna Guarantee Act 1988 make crystal clear the potential threats to this species from activities which are likely to take place very close to where the species lives; in the course of construction and operation of the Project:

From the Action Statement:
“As the Mount Donna Buang Wingless Stonefly appears closely dependent upon montane rivulets (or their substrates) and adjacent vegetation, it is likely to be sensitive to reductions in water quality (such as from siltation, turbidity, and chemical pollution), possibly even if very minor, or short-term, in effect. Such inputs might result from any of the following factors:

a.       run-off from car-parks, visitor facilities or open spaces (such as picnic and viewing areas, snowplay areas, etc.); 

b.       emissions or spillages of fuel or oil from motor vehicles;

c.       inappropriate application of herbicides;

d.       construction or maintenance of roads and tracks;

e.       degraded walking tracks

Other potential disturbances may include alteration to stream patterns and surface soil structure (such as from earthworks or landscaping), and loss of or damage to vegetation along stream courses, due to trampling, clearing or even fire. In 1993, direct mechanical disturbance (by tractor) was observed along at least one stream line (east of the two lowest car-parks) known to be stonefly habitat (E. Tsyrlin pers. obs.). Such habitat disturbances might be expected to cause at least short-term population reductions. No systematic ecological assessment has been made of the effects on the stonefly of development or visitor activity at Mount Donna Buang, although a brief series of surveys of the known stonefly population was carried out during 1982–83 (Neumann & Morey 1984).”
From the Conservation Objectives:
Determine more precisely the distribution and conservation status of the Mount Donna Buang Wingless Stonefly.

Identify, assess and manage existing and potential threats in order to maintain and enhance known populations of the taxon.

Investigate the ecological requirements of the taxon to assist in identifying and appropriately managing current and potential areas of suitable habitat.

Protect and maintain environmental values, particularly water quality, in areas of known and potential stonefly habitat.

11.   Application was made in 2002 for listing of Mount Donna Buang Wingless Stonefly as a Threatened Species under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999. A decision made in October 2021 that the species is not eligible for listing under the EPBC Act. The decision states in its conclusion: “Despite this restricted distribution, there do not appear to be any direct threats to the species' survival and there is active management addressing development and recreational pressures in the area.” (underline added).
It seems that the Commonwealth decided that as the species in a national park, there would not be any direct threats to its survival. The Project in the form proposed suggests that unfortunately this is not the case.
It is understood that application is to be made to the Commonwealth to reconsider its decision under the EPBC Act in light of the “direct threat” posed by the Project.

12.   Mount Donna Buang Wingless Stonefly has become an iconic species in respect of which considerable government resources have been directed towards identifying and acknowledging its need for protection. As the threat posed to it by the Project becomes more widely known, public interest will quickly grow. It is submitted that it is not credible that the Project could be allowed to proceed in the manner which is proposed, with considerable risk to the continued existence of this species.

13.   Some other noteworthy insect observations in the National Park include the following seen by Eddie Tsyrlin in the course of his fieldwork on Mt Donna Buang, which are listed with his comments:

a.       potentially threatened Thaumatoperla robusta recorded in the vicinity of Mt Donna Buang. Its only other known location is Mt Baw Baw. The National Park is one of the very few places where the genus occurs below 900m above the sea level. Its other species - T.alpina which occurs in very similar habitat, is listed under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999.

b.       Riekoperla zwicki and Riekoperla cornuta are both endemic to Mt Donna Buang.  “The only reason that they have not been listed is the lack of data”.

c.       An unknown nymph from family Notonemouridae at the same (highly specialized) habitat as Riekoperla darligtoni. “Neither myself or other freshwater invertebrate specialists could recognise it.”

d.       White flatworms (Turbellaria), not seen by him anywhere else and katydids which he has not been able to identify.

Society member and councillor, Martin Lagerwey reports that a rare beetle, Paropsisterna vittata (Chrysomelidae) has been recorded several times on the summit of Mt Donna Buang, probably on Eucalyptus paucifolia (Snow Gum). He notes that only other Victorian record is at Mt Macedon and that it is also recorded in Tasmania.

14.   The observations referred to in the previous paragraph are an indication of the fact that the National Park is a rich environment with insect (and other) species as yet unknown or unstudied, some of which may be threatened by the Project. No doubt this is why the National Park was set apart originally, to protect the environment and all its species and elements from inappropriate development.

15.   There are many reports of recent dramatic decline in insect species all over the world (“insect apocalypse”). Goulson D  2021  “Silent Earth” pub. Jonathon Cape.
There are widely known species which, until recently were present in huge numbers, whose numbers have plummeted alarmingly: Monarch butterfly in North America, our own Bogong Moth (The Guardian 18 December 2021).
Other species are disappearing before they are described (and often no doubt, before their existence is known).

16.   The Society submits that the Project in its present form would bring about inappropriate development, and inappropriate activity, for this National Park, and would represent an unacceptable risk to species, insect and otherwise, known and unknown, which inhabit the National Park.

A Message from ESV’s President

Dear Members,

The past three years have been tough for everyone. We have dealt with natural disasters including bushfires and floods and have navigated an unprecedented pandemic. While dealing with natural disasters has, in many ways, brought us together, our response to the pandemic has disconnected us from the people we love, the communities we value and the places that make us feel whole. For me, the pandemic has been a reminder of how important groups like the Entomological Society of Victoria (ESV) are and how much my mental health is dependent on pursuing my passions.

The last three years has been difficult for groups like the ESV. We have been unable to bring members together for field trips and have not met in person and shared our excitement about insects. That is no recipe for a vibrant society.

The good news is that we have not been idle and have taken the opportunity to fix some problems, complement an amazing group of Council members with some new blood and create a launching pad for the future. Some of the work we have been doing to refresh the society includes.

• Resolving our public liability issues with our insurer allowing us to recommence outdoor excursions. We also have a new Events Officer who is planning our first event in April!

• Appointed a new Outreach Officer who has overhauled our social media platform and allowed us to connect with people in a whole new way.

• We launched our new website and online store, which brings us into the 21st century and allows us to streamline book sales, new membership applications and membership renewals.

• We have continued to hold bi-monthly members meeting using a virtual format, which has allowed the very young and those unable to come into Melbourne to participate. This will allow us to move to a hybrid model of face to face and virtual meetings that will ultimately be more inclusive.

To take advantage of this progress, we need your help!

First and foremost, please stay connected to the society by becoming a member or renewing your membership. Having emerged from the pandemic, we do not want to be disconnected from you. Our membership subscription costs less than a tank of petrol – which is great value for money. We have moved to a new online membership system, that for most will be much simpler, but for some may take a little time to work out. We have developed a step-by-step guide to renewing your membership and are happy to walk you through this. Please email our Secretary, Francesco, if you need help - secretary@entsocvic.org.au.

Second, you are our ambassadors and our champions. Please encourage friends, family and people in your community to become members too. The ESV and its activities are a wonderful way to engage the younger people in your life in nature and science. To encourage more young people to get involved we have made memberships for primary school and secondary school students free.

Third, we need your ideas! The Society exists for you. We want to offer opportunities and activities that excite you. Is your passion photography and using citizen science platforms like iNaturalist or posting on Instagram? Do you want to get better at identifying the different types (Orders) of insects? Would you like to create lists of the different insects found in Victoria? Are you interested in the environment and creating insect friendly gardens?

Finally, be active! Please come to our meetings and our outings and if you are interested in contributing further, consider becoming a member of our Council. We are particularly looking for a Treasurer – so if you have financial experience, I would love to speak with you. The role is not onerous and we are streamlining meetings to reduce the burden further.

I feel very privileged to be President of the society and to have the opportunity to meet and interact with every one of you over the next few weeks, months and years. I can’t wait to see you at our AGM on April 19th and at our first event after Easter.

Best wishes,

Doug Hilton
President, ESV
president@entsocvic.org.au