Our Response: Government's beaver consultation

The consultation contains 15 questions in total. Questions 1 – 5 are personal questions. Questions 6 – 15 relate to the proposed approach to beaver reintroduction and management. Here are our own responses below.

6. Do you agree or disagree with the proposed approach to beaver reintroductions? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

We welcome this hugely significant and long awaited announcement to licence the release of beavers into the wild in England. We agree in part with the proposed approach, but we are very concerned about the disproportionate emphasis on perceived risks and costs and the overly burdensome nature of the licencing criteria being proposed.

Beavers are a native keystone species and their reintroduction has an unrivalled capacity to provide a wealth of benefits for people and wildlife. Consistent and overwhelming evidence from the River Otter Beaver Trial (ROBT) and elsewhere in Europe demonstrates clearly that the benefits of beavers hugely outweigh the costs. It is therefore important that a presumption in favour of beaver releases should be the unequivocal theme of the licencing procedures.

As it stands, the overly onerous licensing conditions proposed in this consultation will thus need significant modification. The key areas which need addressing are as follows:

• It will be vital for any Beaver Management Groups (BMGs) or nominated regional beaver management officer to have access to relevant funding streams such as the Environmental Land Management scheme (ELM) to support landowners who are willing to allow beavers to provide "public goods" such as reduced flood risk and improved water quality on their land. This needs to be made absolutely clear in the licencing arrangements.
• The five-ten-year funding commitment requirement is prohibitively long and wholly unreasonable. It is completely unrealistic to expect licence applicants to commit to this timescale. Government agencies such as Defra itself rarely to commit to more than one-three years (four years in the exceptional case of flood risk funding). The majority of applicants will be seeking external ‘blended’ income streams and 5 years is the maximum timescale for most grant funding bodies, with three years maximum being the norm. The best solution would be for an approved body – eg an environmental NGO or a willing individual landowner – to commit to play a hosting role for the Beaver Management Group officer with the length of the project term being dependent on the timeframe for core financial commitment from Defra.
• The following wording: “The reintroduction partnership is responsible for managing financial impacts of beaver activity” needs to be amended. It is not reasonable for the applicant to be liable for reparations for third party losses which arise from beaver activity – especially given that through beaver reintroduction they will be delivering exactly the kind of societal benefits that are encouraged through ELM. This unreasonably onerous requirement does not apply to other legal reintroductions and would set a dangerous precedent.
• The requirements for cost-benefit analysis are unreasonably onerous and unrealistic. Costs and benefits are very difficult and potentially prohibitively expensive to quantify accurately in advance of reintroduction. Until the beavers start to have an impact in particular parts of catchments, it will be difficult to predict where and when the costs and benefits will arise – and to what extent.
• It is unrealistic and unnecessary for every project to appoint its own Local Beaver Officer. This role can be fulfilled at a regional or sub-regional scale via Beaver Management Groups or by dedicated officers with support from core government funding.
• It is important that the licensing arrangements recognise that beavers will, over time, disperse into neighbouring catchments and should not be restricted from doing so (unless these are very specific "zero tolerance" areas). It must not be beholden on projects to prevent beavers dispersing into adjacent catchments. Funding for BMGs must therefore recognise that management advice and support from the BMG should extend to adjacent catchments prior to colonisation to ensure that they are ‘beaver ready’. These principles are not dealt with adequately in the consultation and need to be made absolutely clear in the licensing arrangements
  

7. What criteria, in addition to those listed above, do you think projects should meet to be granted a licence for wild release? Please state your reasons and supporting evidence.

None. The conditions are already far too onerous as they stand. Any further criteria will only make matters worse.

8. Do you agree or disagree with the proposed approach to existing wild-living beaver populations? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

We strongly welcome the proposal to permit all existing wild beaver populations in England to remain. With regard to the management of all of these existing populations, we strongly recommend the adoption of the Beaver Management Group approach taken by the River Otter Beaver Trial. The ROBT is a world-class species management initiative which has been hugely successful at managing conflicts whilst allowing beavers to thrive and thus deliver flood risk and water quality benefits as well as tangible improvements for a wide range of other wildlife. There is no need to reinvent the wheel here. This project and the management strategy produced by it, is the model to follow.

9. Do you agree or disagree with the proposed approach to licensing of future beaver enclosures? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

We agree – but only in part. Yes, beaver enclosures should be licenced, but far from being tightened, this should be a light-touch licencing process – very different to that for wild releases – accepting of course that an additional more onerous licence would be required if a wild release from an enclosure was subsequently proposed.

It is certainly not realistic to require enclosures to contribute to the knowledge base for beavers - we already know the vast majority of what we need to know about beaver ecology and the pros and cons of the species. Future enclosures for beavers cannot and will not contribute significantly to that knowledge base. However, what they will do, is familiarise local communities with beavers thus helping to secure increased support for future releases into the wild. They will also enhance biodiversity at a local scale, thus contributing significantly to Local Nature Recovery Networks and in some cases they will also enable income from nature-based tourism to help finance further environmental improvements locally – especially as part of a rapidly growing network of rewilding projects.

Another consideration here is the need to develop a more diverse genetic base for beaver populations in England. Having multiple breeding populations in enclosures in the short term can play an important role in this. They can also act as valuable as receiver sites for translocated beavers from Scotland which would otherwise be shot.

10. What criteria do you think should be taken into consideration when determining whether or not to issue an enclosure licence?

• The size of the enclosure and the nature of the habitats therein. The beavers should have access to extensive suitable habitats as a catalyst for biodiversity recovery and ecosystem service delivery.
• Proposals for management of future progeny from the original releases.
  The general suitability of the host catchment for beavers, should the landowner wish to release to the wild in future.
• The potential for the enclosure to be used to support community and stakeholder engagement programmes, thus helping to spread awareness of the true nature of beaver impacts in that specific locality – good and bad.
• The linkage between the enclosure and wider landscape rewilding – ie priority should be given to enclosures which sit within project areas where the landowner(s) are committed to large-scale restoration of natural processes.

11. Does the management hierarchy cover management actions you would expect? Are there additional aspects that you think should be included in the management hierarchy? Please provide further details.

No.

Please provide details of any additional aspects you think should be included in the management hierarchy:

No comments other than to reiterate that the River Otter Beaver Trial has spent considerable time with a wide range of stakeholders developing a comprehensive Beaver Management Strategy Framework. This framework provides chapter and verse on a sensible beaver management hierarchy and there is no need to reinvent the wheel here.

12. Excluding direct payment for management activities, what other support do you think should be available and to whom?

Given that this is, in effect, a National Strategy for Beaver Management in England, it should be supported by core government funding for regional Beaver Management Groups or individual regional beaver management officers – over and above that required by landowners for management activities. The benefits to society as a whole will be very significant in terms of tackling the biodiversity crisis and the climate emergency.

13. Are there any specific areas where guidance is required? Please provide details.

Defra, Natural England and Local Authorities in particular will require improved knowledge and skills with regard to beaver ecology and management. There are plenty of conservation organisations who will be able to assist with suitable training and guidance on this on a commercial basis.

14. How would you prefer to access advice and guidance (e.g. information on website, via email, focal point for enquiries etc)?

Face-to-face advice and support is essential for landowners and those directly impacted by beaver activity.

Web-based information and advice is also essential. This should be made available through regional Beaver Management Groups or designated beaver management officers. This will ensure that up-to-date knowledge and skills is routinely shared between existing and would-be practitioners across the country.

15. Would you (or an organisation you are involved with) consider preparing an application for wild release, if the approach proposed in this consultation became national policy? If yes, please provide the general location where you might consider applying for such a release.

Yes, several of the landowners on our nationwide Rewilding Network are considering applications for wild release of beavers, but we are very concerned that the overly onerous nature of the licencing requirements, as highlighted above, may well put them off.

Beaver Trust is a nature restoration charity run by a small team of environmentalists and supported by a growing network of beaver believers, working to bring beavers back home to Britain and make space for nature in this time of ecological and climate crisis. Read their response on the Beaver Trust website and get help to complete your own.