Wildwood Trust’s response to the consultation on approach to beaver reintroduction and management in England

Questions 1 to 5 are individual information that each person responding to the consultation needs to complete for themselves or their organisation. Wildwood Trust’s answers to Questions 6 to 11 are set out below and may be copied or adapted.

N.B. The Text in Blue is extracted from the wording from DEFRAs Consultation Proposals and is not part of Wildwood Trust’s response – that wording is for information and context only.

(Q6) 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.

Consultation Proposals

• A project proposal must provide evidence that the project has funding to cover all aspects of the reintroduction, including provision of advice and management of impacts. This funding must be in place for at least five to ten years.
• A project proposal must provide evidence of substantial stakeholder engagement at all stages of project development.
• A project proposal must demonstrate significant benefits and that the risk of conflict is low, including consideration, and mitigation of potential conflicts.
• A project proposal must include a Project Plan including funding streams, roles, responsibilities and planning and feasibility study for all aspects of the reintroduction. These Plans will run for a minimum of 5-10 years.
• A project proposal must include details of a Project Steering Group to support the project and must consist of a range of stakeholders with strong local ownership.
• The proposed project must appoint a Local Beaver Officer to act as a local contact point, and support to stakeholders, including risk management authorities and others operating in.

The Wildwood Trust agrees that there should be a review of Beaver reintroductions and that a new system must be created. However, we disagree with the approach set out in the consultation.

The COP26 agreement states:

“Recognizing the interlinked global crises of climate change and biodiversity loss, and the critical role of protecting, conserving and restoring nature and ecosystems in delivering benefits for climate adaptation and mitigation, while ensuring social and environmental safeguards.”
and

“Emphasizes the importance of protecting, conserving and restoring nature and ecosystems, including forests and other terrestrial and marine ecosystems, to achieve the long-term global goal of the Convention by acting as sinks and reservoirs of greenhouse gases and protecting biodiversity, while ensuring social and environmental safeguards.”

Beavers are a native keystone species that have established a number of wild populations in the UK over the past 20 years, 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.

The restoration of beaver populations is an essential part of protecting, conserving and restoring nature and ecosystems. They play an essential part in delivering benefits for climate adaptation and mitigation, whilst ensuring social and environmental safeguards. Failure to facilitate the effective reintroduction of beavers in the UK would be a failure to implement the COP26 agreement. The current proposals will not enable an effective programme of beaver reintroductions as it has a disproportionate emphasis on perceived risks and costs and the licencing system is overly and unnecessarily burdensome. Specifically: –

• A requirement for any project to have full funding and local beaver officers for a minimum of at least 5 years is unreasonable and unnecessary. It will be challenging and prohibitive to otherwise highly feasible wild release projects.
• Mitigation should be reflective of site specific requirements as such a Local Beaver Officer should not be a condition for a licence. Beaver Officers or similar roles should be responsible for a catchment, multiple catchments or a designated area where they can be employed as required. These roles should sit within appropriate NGOs and should be funded directly by the government at a national level rather than by those applying for a local licence. These Beaver Officers should be employed by an appropriate third sector organisation with the experience of managing reintroductions and human wildlife coexistence.
• There is a significant risk that if the conditions for a licence permitting the release of beavers into the wild isn’t achievable or affordable, landowners interested in beaver reintroduction will continue to look at enclosures for beavers, or even unlicensed releases. This conflicts with the overall objective of properly and lawfully re-establishing beavers as wild animals in England.
• Management of beaver impacts should not be required to be funded as a condition for a licence permitting release of beavers into the wild. Advice and support will need to be provided to land owners and managers affected by beavers permanently, not just for the project life cycle of 5 to 10 years. Instead, beaver management should be funded directly by the government at a national level, in keeping with the objective of accepting beavers back as a native wild animal. It is Government policy that it is the responsibility of landowners to cover the cost of managing wild animals on their land.
• By restoring England’s beaver population, the government would save money from the ecosystem services beavers provide (Thompson et al, 2021). Even after providing central funding to cover the costs of management at a national level, this would ultimately still be a saving and would also demonstrate climate leadership and compliance with the COP26 agreement. This is also supported by Natural England’s own findings. In reviewing ‘The feasibility and acceptability of reintroducing the European beaver to England’ in 2009 Natural England concluded “The evidence gathered in this report clearly shows that it is feasible to reintroduce beavers into England and that many benefits are likely to accrue, not least the potential for beavers to assist with river and floodplain restoration.”
• We welcome the requirement for a Steering Group that will support a project and its stakeholders. This is effectively a Beaver Management Group (BMG), similar to those that have been fruitfully established around existing wild beaver populations such as on the River Otter in Devon and the River Stour in Kent.
• A national approach accepting beavers as a native wild animal, with delegation to regional beaver management groups, requires national government support and funding, not 5-10 year project funding. National funding would make submitting an application for a licence permitting the release of beavers into the wild more achievable for landowners and communities who are interested in beaver reintroduction.
• Detailed definitions need to be provided for areas of the proposed approach, such as a clear definition of what ‘substantial stakeholder engagement’ entails.
• Further stakeholder agreement should then be sought at a nationally representative English beaver forum once definitions are set, before the framework becomes binding.
• It is important that the licensing arrangements recognise that beavers already exist in the wild and will, over time, disperse from reintroductions into neighbouring 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.

(Q7) 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 proposed approach is already too onerous. Any further criteria will only make matters worse.

(Q8) 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.

Consultation Proposals

• Existing beaver populations in England will be permitted to remain and will be subject to management in the same way as other beaver populations when not covered by a Project Plan (see Management section below).
• We are aware that for some existing wild populations, local stakeholders have started to set up management groups to support the public and offer advice. We encourage such partnerships to form around these populations to enable stakeholders and the public to become used to living alongside beavers.

We Disagree. But we do support the need for the establishment of BMGs, adopting or adapting the approaches being developed in the River Tamar, River Otter and River Stour. Similarly, in Kent, in response to the establishment of a wild beaver population on the River Stour, the East Kent Beaver Advisory Group (EKBAG) was set up in 2018. This partnership between Kent Wildlife Trust, the Environment Agency, Natural England, the River Stour (Kent) Internal Drainage Board, Wildwood Trust and the Kentish Stour Countryside Partnership works together under the neutral banner of the EKBAG to proactively investigate beaver activity, provide consistent and comprehensive advice to landowners and engage with a broad audience around the presence of beavers in east Kent.

In the case of existing wild populations these groups should be voluntary and have no financial obligation to provide mitigation / management interventions. Beavers from these catchments should be permitted to naturally spread into adjacent catchments, and there must be no requirement to capture and return animals which spread in this way.

Acceptance and protection of existing wild-living beaver populations should extend to the populations not referenced in the consultation.

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.

(Q9) 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.

Consultation Proposals

• Conditions of licence permitting the release of beavers into a secure enclosure to be tightened. To gain a licence, a project must add to the knowledge base of beavers i.e. research on a specific impact or management technique.
• A licence will also be given where an enclosure might be used to pilot a reintroduction in a particular area, allowing the project to gather relevant information and build support and engage with the local community.
• Licensing of an enclosure project does not provide any guarantee that a licence will be granted subsequently for a wild release. If a current or future enclosure project wishes to move towards a wild release, they will be expected to demonstrate how they meet the criteria for wild release.
• Once the process for licensed release to the wild has been developed, we anticipate the demand for licences to release to enclosures will reduce.

Wildwood Trust agrees with some of the proposals put forward; we would select DISAGREE in response to question 9 for the reasons laid out below:

• Whilst we support a move from enclosed to wild releases, this is still likely to be a gradual approach, therefore any tightening of enclosed licensing should be a phased approach only after such time as wild releases are regularly occurring and the species is actively being restored in the wild. Otherwise such actions will ultimately slow the restoration and normalisation of beavers in England during the climate and biodiversity crises.
• Enclosures to date have provided and continue to act as a valuable educational tool whereby communities can learn how they can live alongside beavers. They are also vital in increasing understanding and social acceptance of the species’ return. These benefits must be taken into consideration when reviewing an application for a licence permitting the release of beavers into a secure enclosure.
• It is 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 and contribute to compliance with the COP26 agreement.
• It is also essential to consider the need to develop a more diverse genetic base for beaver populations long term in England and to manage animals that will require translocations from existing and future projects. There will need to be populations of beavers in enclosures to enable this and there are currently very limited facilities to do so.

(Q10) What criteria do you think should be taken into consideration when determining whether or not to issue an enclosure licence?

Consultation Proposals

• We intend to make beavers a European Protected Species by listing them in Schedule 2 of the Conservation of Habitats and Species Regulations 2017. Therefore, if an individual wants to undertake management activities which would otherwise be prohibited, they will be required to apply for a licence from Natural England.
• This management framework should proceed stepwise from avoidance or tolerance of impacts, to least to most harmful actions, with interventions such as moving beavers to other areas (translocation) or lethal control considered only as a last resort.
• A management hierarchy for beaver could include the following steps: Avoid or tolerate negative impacts, such as: ◦ allowing space for potential impacts, for example by creating buffer zones along the side of watercourses where valuable crops or trees are not planted. ◦ exploring financial incentives available for landowners to make space for environmental benefits provided by beavers. Use legal management or mitigation methods if negative impacts cannot be avoided, including: ◦ protecting trees of value from felling with tree guards or anti-beaver paint. ◦ fencing to exclude beavers from undesirable areas. ◦ protecting banks from burrowing impacts. If unavoidable and other solutions are not satisfactory, apply for a licence to undertake actions including: ◦ destruction or modification of dams, lodges and burrows, ◦ translocation or ◦ lethal control.
• Translocation of beavers or lethal control must only be considered as a last resort, however in circumstances where this is unavoidable, licences may be obtainable. Management English Beaver Consultation Position Page 10 Text derived from original Defra consultation”.

Wildwood Trust’s position on question 10:

• 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.
• 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.

(Q11) 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.

Consultation Proposals

• Government policy is that it is the responsibility of landowners to cover the costs of managing impacts of wild animals on their land. In line with this, Defra will not provide direct payments for management of negative impacts of beaver activity or pay compensation.
• Natural England and Defra will host advice through gov.uk which will cover applications for reintroduction projects as well as management. Natural England will provide further advice and engagement to guide stakeholders and liaise with local projects and management groups.
• Any project applying for a wild-release licence will be required to have a Local Beaver Officer for the duration of the Project Plan. Local Beaver Officers will act as a focal point, providing advice and undertaking management as required, to support local landowners and river users.
• We are working with stakeholders and end users to determine the specific land management actions that will be paid for through the Sustainable Farming Incentive, the Local Nature Recovery scheme and the Landscape Recovery scheme. ‘The Path to Sustainable Farming: An Agricultural Transition Plan 2021 to 2024’ sets out examples of the types of actions that we envisage paying for under the schemes.

Wildwood Trust agrees with some of the proposals put forward but we would select NO in response to question 11 for the reasons laid out below.

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. Further:

• We broadly agree with the management hierarchy set out but we would like to see a management framework adopted paying specific attention to and providing further clarification towards distinguishing between dam function types, shelter function types and when and if to implement translocation and the very limited situations where lethal control could be considered.
• The management hierarchy should begin with education and community engagement to raise awareness, equip and empower stakeholders to co-exist with beavers.
• The licensing system needs to allow for management activities to be carried promptly out by appropriately trained individuals, including class licensed practitioners.
• We need to learn lessons from Scotland where lethal control was made too easily accessible and translocations were limited. This is not consistent with management of other wild species and led to legal action and it deepened conflict between stakeholders which could easily have been avoided.
• Further stakeholder engagement is needed once a detailed management framework has been produced which shows how the framework will practically operate and how licensing ties in before the framework becomes binding. We believe this should be carried out via a dedicated national stakeholder forum.

(Q12) Excluding direct payment for management activities, what other support do you think should be available and to whom?

Consultation Proposals

• Government policy is that it is the responsibility of landowners to cover the costs of managing impacts of wild animals on their land. In line with this, Defra will not provide direct payments for management of negative impacts of beaver activity or pay compensation.
• Natural England and Defra will host advice through gov.uk which will cover applications for reintroduction projects as well as management. Natural England will provide further advice and engagement to guide stakeholders and liaise with local projects and management groups.
• Any project applying for a wild-release licence will be required to have a Local Beaver Officer for the duration of the Project Plan. Local Beaver Officers will act as a focal point, providing advice and undertaking management as required, to support local landowners and river users.
• We are working with stakeholders and end users to determine the specific land management actions that will be paid for through the Sustainable Farming Incentive, the Local Nature Recovery scheme and the Landscape Recovery scheme. ‘The Path to Sustainable Farming: An Agricultural Transition Plan 2021 to 2024’ sets out examples of the types of actions that we envisage paying for under the schemes, including creating, managing and restoring habitats such as wetlands and freshwater habitats.

The benefits to society as a whole will be very significant in terms of tackling the biodiversity crisis and the climate emergency. Management schemes need to be supported to minimise conflict with beavers, create habitat, reduce the risk of flooding downstream and reduce agricultural run-off entering our watercourses.

By restoring England’s beaver population, the government would save money from the ecosystem services beavers provide (Thompson et al, 2021). Even after providing central funding to cover the costs of management at a national level, this would ultimately still be a saving.

Support to landowners is essential and the following should be considered:

• Annual payments for making space for natural processes in riparian zone, including
  o Payment for seasonally inundated and/or permanently inundated land.
  o Riparian zones taken out of conventional agricultural production.
• Capital works options to (for example):
  o Install flow devices to regulate beaver-driven water levels.
  o Protect culverts from blockages, etc.
  There also needs to be support for Beaver Management Groups to ensure the provision of high-quality support to landowners, and to support them in accessing appropriate funding.

Any local mitigation should be reflective of site specific requirements as such a Local Beaver Officer should not be a condition for a licence permitting release of beavers into the wild. Instead Local Beaver Officers or similar roles should be responsible for a catchment, multiple catchments or a designated area which can be employed as required. These roles should be funded directly by the government at a national level rather than by those applying for a licence permitting the release of beavers into the wild.

Detailed information about beavers and their behaviour should be easily accessible on Natural England, as the licencing body, and Defra’s web. An email address and contact telephone number which members of the public can use to speak to someone about beavers at NE or Defra should also be made available for those who want to raise specific queries or can’t access information online.

(Q13) 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 such as the Wildwood Trust who will be able to assist with suitable training and guidance on this on a commercial basis.

(Q14) 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.

(Q15) 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.

At this point in time Wildwood Trust is not considering preparing an application for wild release, but may do so in the future if we are asked to assist a landowner who wishes to do so. However, we are very concerned that the overly costly, risky and onerous nature of the licencing requirements proposed in the consultation will prevent many people from doing so. It is also virtually impossible to bring fresh genetic bloodlines of beavers into the UK as a result of DEFRA’s current policy banning almost all imports of beavers. The current population is at least as closely related as first cousins (Campbell-Palmer et al 2020) and will become more so unless this policy changes.