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.
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.
