Beaver Decision Document - Licence Application 283801

Purpose of this document

This decision document:

• Explains how the application has been assessed;
• Provides a record of the decision-making process;
• Details how all material considerations as outlined in the Scottish Code for Conservation Translocation have been considered;
• Details the specific conditions added to the licence, in addition to our generic licence conditions.

Key factors of the assessment

1. Application summary

An application was received by NatureScot on 30 January 2025 for the release of Eurasian beaver (Castor fiber) to agreed sites within Glen Affric National Nature Reserve as part of the Glen Affric Beaver Reintroduction Project. The project aims to release beavers in suitable habitat in Glen Affric with the expectation that beavers will occupy these waterbodies and colonise and disperse into the wider Beauly catchment over time. The application from Forestry and Land Scotland is for the translocation of up to four beaver families from conflict sites within Scotland to agreed sites within Glen Affric NNR at and near to Loch Beinn a’ Mheadhoin. Releasing beavers to Glen Affric, alongside existing wild beaver presence in the River Beauly catchment and the proposed release of beavers to Abriachan Forest, will increase the current range of beavers in Scotland as set out as a priority in the Scottish Beaver Strategy 2022 – 2045.

Beavers would be trapped following best practice under a separate licence (Beaver Trust licence 271106) and health screened before being transported for release.  All beavers would be obtained from locations already covered by a NatureScot licence for removal associated with human-beaver conflict. This beaver reintroduction project is proposed as an alternative to translocation to sites in England or Wales or to lethal control at sites where mitigation measures are not feasible or have not been successful in resolving the human-beaver conflict. It is proposed such action will bring environmental benefits and conservation benefit from the continued restoration of beavers in Scotland.

Forestry and Land Scotland have proposed beaver translocation to the National Nature Reserve to provide numerous biodiversity and environmental benefits and to help meet wider habitat restoration goals. This includes improved ecological functionality through wetland creation and expansion. FLS also consider there will be benefits to local communities and to wider audiences in Scotland, increasing awareness of the role that beavers play in restoring ecological function, demonstrating approaches to living with beavers and benefiting from beaver presence for example by providing ecotourism opportunities.

2. Our decision

NatureScot Licensing Officers have undertaken a full assessment of the proposal to relocate beavers to sites within Glen Affric National Nature Reserve. 

This assessment has been reviewed by the Licensing Manager who made recommendation to the Head of Wildlife Management for the decision as detailed below:

• Following thorough assessment of Forestry and Land Scotland’s application and giving careful consideration to the concerns raised by local communities and stakeholders, the licence application to reintroduce beavers to agreed sites within Glen Affric National Nature Reserve has been approved
• The licence permits the release of up to four beaver families at the agreed sites within the licence term

3. How we reached our decision

3.1. Assessment of proposal against legislative requirements

Release of a non-native species

Under section 14 of the Wildlife and Countryside Act 1981 (as amended) it is illegal to release, allow to escape from captivity or cause to be at a place outside the control of any person any animal species outside its native range (as defined in the Act) without a licence.  ‘Former native’ species are considered to be ‘non-native species’ for the purposes of the Act.  Beavers are considered a ‘former native’ species in Scotland.  Therefore, any release of beaver into the wild in Scotland requires a non-native species licence under Section 16(4)(c) of the Act.

Requirement to possess, control and transport beavers for release

Forestry and Land Scotland has applied for permission to possess (for the purpose of health screening only), control, transport and release beavers at agreed sites within Glen Affric National Nature Reserve.

The beavers will be trapped, health screened and PIT tagged (Passive Integrated Transponders) under Beaver Trust Licence 271106 and will then be transported(following best practice) and released at the agreed release sites within Glen Affric National Nature Reserve.

The activity is proposed for the principle purpose of conserving wild animals, with a view to reintroduce beavers and preserve genetic diversity within the national population. 

European Protected Species licensing of these activities requires that they meet the 3 licensing tests as follows:

Test 1 – There must be a licensable purpose:

The possession and transport of beavers is permitted under The Conservation (Natural Habitats, &c.) Regulations 1994 (as amended) (hereafter the Habitats Regulations 1994) for the following licensable purposes:

• Conserving wild animals (primary purpose).

The conservation translocation is expected to have a positive effect on the conservation status of Eurasian beaver within Scotland by expanding their range and retaining individuals which would otherwise be lost to the Scottish population. As such the conservation of wild animals is the appropriate licensable purpose in this case.

There is a licensable purpose for this proposal and test 1 is passed.

Test 2 – There must be no satisfactory alternative:

NatureScot have considered the alternatives to granting a licence for the stated primary purpose (Regulation 44(3)(a) of The Habitats Regulations 1994). This included, not granting a licence, consideration of alternative locations and the timing; including whether allowing a natural process of colonisation would be a satisfactory alternative. 

The trapping element of the project is covered by an existing licence to trap and translocate beavers to approved sites in Scotland.  This licence to trap beavers at sites where they have been assessed in accordance with legislation to meet the licensing tests for beaver removal due to an active conflict between beavers and other land management uses. Hence the consequences of trapping or not trapping these animals is not considered further in the consideration of alternatives.

Do Nothing - Not granting a licence in this case would mean that beavers from conflict sites that could have been moved to the release sites within Glen Affric NNR would instead be moved to projects in England and Wales or killed under a lethal control licence.  In both these scenarios the animals will be lost to the Scottish wild beaver population. 

Alternative locations - There are currently a very limited number of sites in Scotland that are licenced for beaver release that have not already carried out beaver translocations. Therefore, the alternatives to consider in this case are whether or not to grant a licence for the possession, control, transport and release of beavers at the proposed release sites.  The release of beavers to new catchments is part of the vision of Scotland’s Beaver Strategy and the Beauly catchment has been identified as one of the most suitable catchments in Scotland for beaver restoration due the availability of suitable habitat. The risks and benefits of beaver release to Glen Affric in the Beauly catchment of a social, economic and environmental nature are considered further under section 3.2.

There are currently a small number of beavers living wild in the Beauly catchment arising from unauthorised releases. The number of animals that have escaped or have been released is unknown, but there are likely to be a small number of founding individuals and hence the population is likely to be vulnerable to inbreeding depression and stochastic events. An assessment of the likelihood of further beavers naturally colonising the proposed release area has demonstrated that, given current population numbers and distribution, it is highly unlikely without assistance via proactive translocations. Licensing the release of four beaver families to Glen Affric, will provide greater viability to the beavers present in the catchment from a population and genetic perspective. However, we would note that approval of beavers in the Beauly catchment is only being granted here on the basis of the formal application and process of engagement that has taken place and unauthorised releases remain to be ill-advised and an offence under the Wildlife & Countryside Act (1981 as amended).

NatureScot considers Scotland’s beaver population will be enhanced by establishing a viable population within the Beauly catchment. The proposed release sites have been assessed and are considered favourable for beavers to establish. The application seeks to take proactive actions to facilitate the restoration of this species and conserve well-adapted, healthy individuals in order to promote the genetic diversity of the Scottish beaver population. It is recognised that beavers are a valuable key stone species and will bring positive biodiversity and ecosystem beavers to the catchment.

Timings – Beavers are protected year-round, so a licence will always be required to possess, control, transport and release. To ensure minimal welfare impacts; beaver trapping, transportation and release will take place out with the kit dependency period (1^st April to 16^th August). 

We have concluded that not granting a licence in this case would mean that beavers from existing conflict sites that could have been released within Glen Affric NNR would as a result be released at other sites in England and Wales or killed via lethal control licence and therefore lost to the Scottish wild beaver population; and that for the purpose of conserving wild beavers in Scotland there is no satisfactory alternative to granting a licence in this case.

Test 2 is passed, there is no satisfactory alternative.

Test 3 – Actions will not be detrimental to Favourable Conservation Status

The translocation of beaver to Glen Affric NNR will contribute to improving the overall status of the beaver population within Scotland, in terms of both numbers and maintaining genetic diversity. The Scottish Government has stated its strong determination to see more beavers translocated within Scotland to directly reduce the number of beavers killed via lethal control at conflict sites. The use of lethal control is of significant public concern and alternative solutions, such as translocations, should be applied to ensure healthy beaver populations.

The proposed action will not be detrimental to the maintenance (or restoration) of the population of beavers at a favourable conservation status in their natural range (regulation 44(3)(b) of The Habitats Regulations 1994.

On the genetic status of the population we refer to:

Campbell-Palmer, R., Senn, H., Girling, S., Pizzi, R., Elliott, M., Gaywood, M. & Rosell, F. (2020). Beaver genetic surveillance in Britain. Global Ecology and Conservation, 24, e01275.

Licensing test 3 is passed.

3.2 Assessment of proposal against Scottish Code for Conservation Translocations

NatureScot have assessed the benefits and risks of the proposal in line with the Scottish Code for Conservation Translocations. We have also considered the practical aspects of the project feasibility and desirability. 

3.2.1 Release location suitability

A summary of the characteristics of the Beauly catchment and its suitability for beavers is provided in the Environmental Report (section 2) produced to consider the effect of beaver releases in this catchment. The ER concluded that ‘these catchments are highly suitable for beavers in terms of habitat availability and suitability. Based on the availability of suitable habitat and potential for ecosystem benefits, the Beauly catchment is considered to be one of the most suitable catchments for beavers in Scotland (ranked 9th in SEA Addendum 2022).

An assessment of the suitability of Glen Affric for beaver has been provided by the Beaver Trust and has been assessed by our own beaver specialist. These assessments support that there is suitable habitat for 4 beaver families in Glen Affric and the surrounding area. We note that the released beavers may move beyond the release site into the wider catchment and we have taken this into account in our assessment of potential effects and mitigation. NatureScot can clarify that should beavers be released, all beavers present within the Beauly catchment will be regarded as wild animals and are already afforded European Protected Species status.

We have assessed there is the potential for beavers to significantly contribute to the nature and climate challenges currently faced in this catchment. The catchment is also considered to present low risk in terms of the likelihood and scale of negative impacts that may arise from beaver release. If negative impacts do occur, we considered there are existing mechanisms available through the Beaver Management Framework to deal with them. It is also planned that a Beaver Monitoring and Mitigation Group be established to co-ordinate and oversee beaver activity and impacts in the wider catchment.

3.2.2 Assessment of potential impacts on designated sites

Impacts on the designated sites in the wider catchment have been assessed with respect to agreed release sites within Glen Affric NNR via appropriate assessment in relation to Regulation 48 of the Conservation (Natural Habitats, &c.) Regulations 1994 as amended (Habitats Regulations Appraisal). 

The Habitats Regulations Appraisal concludes: 

“With the appropriate mitigation in place beaver translocations to the River Beauly catchment will not adversely affect the integrity of a European site. This mitigation will need to be considered and secured as part of the consenting process for any applications to translocate beavers to the River Beauly catchment.”

The agreed release locations fall within the Strathglass complex Special Area of Conservation (SAC) and this is the only European Designated Site affected by the release. Before a licence can be issued NatureScot require to have assurance that a Monitoring and Mitigation plan can be delivered for the SAC/SPA interests. To this end we have assigned responsibility within the Monitoring and Mitigation plan, to FLS and to NatureScot Operational Teams. Some aspects will require working with others, but NatureScot will take responsibility for putting agreements in place to ensure these arrangements. Further details of the Beaver Monitoring and Mitigation Plan will be refined following the formation of a local stakeholder group to oversee and shape plan delivery. The public agencies will put this group in place to work with land managers and other stakeholders in planning for and mitigating beaver impacts in the wider catchment.

3.2.3 Other potential environmental effects

The Environmental Report systematically assessed the likelihood and significance of beaver effects in the Beauly catchment. This includes to biodiversity, to water resources, to population and human health, to cultural heritage, to material assets (including agriculture, forestry, fisheries) and to infrasture. The potential for negative impacts are recognised particularly to riverbank erosion, riparian woodlands and to migratory fish which are addressed below.

Beavers dig canals and create burrows in the riverbank. The effect of such burrowing is context specific depending on the substrate, the nature of vegetation and trees holding the bank together, and the existing river processes; whether erosional, balanced or depositional.

Further to the Environmental Report and concerns raised by the land management and fisheries interests regarding potential impacts on riverbanks, we sought advice from SEPA on the risk of beaver- induced erosion on the River Glass and River Beauly. A senior SEPA hydro morphologist carried out an assessment of coarse sediment dynamics on the River Glass and Beauly based on a comparison of bar and channel areas in aerial imagery (between 2013 and 2024). This assessment established that erosion is more dominant in the river reaches in the steep higher energy headwaters above Loch Affric. SEPA consider it is reasonable to assume that beavers could add to erosion in such reaches (noting riparian woodland is sparse above Loch Affric which is likely to limit beaver spread in this direction), but the beaver effects may be small here compared to existing erosion processes.  Below the power station at Fasnakye, the rivers have a gentler gradient and are classified as balanced or depositional. SEPA advise suggests beaver influence is unlikely to change the overall balance in depositional reaches but reaches that are ‘in balance’ may be more vulnerable to being ‘tipped’ towards beaver induced erosion. This data is now on NatureScot’s GIS system to inform monitoring of these reaches. SEPA also highlighted the benefit of riparian woodland restoration in such reaches in stabilising the banks.

The SEPA hydro-morphologist highlighted the embankment data used in NatureScot’s ER had been remotely derived. This data suggests there are relatively few artificial flood banks in the catchment. Some sections of embankment identified on the SEPA data were visited on stakeholder site visits in Strathglass. Some sections of embankment were adjacent to back channels on the river and hence likely to be areas favoured by beavers. We propose that proactive mitigation would include; risk assessment, monitoring and carrying out repairs or river restoration approaches to reduce the impact of beaver activity. There is an offer of support to land managers from the Trees for Life Beaver Project Officer relating to the Glen Affric project. What other support can be offered for manage these risks could be further considered by the Beaver Monitoring and Mitigation Group.

The rivers in the Beauly catchment are important for fish and fisheries. Atlantic salmon, sea trout and eels are found in the catchment, (with a few local records of lamprey). The Beauly District Fishery Board in collaboration with the Beaver Trust, UHI and Trees for Life carried out baseline electrofishing at 39 sites in summer 2022, which provides valuable information on salmon and trout distributions and densities. NatureScot staff met with the Lower Beauly and River Glass fishing Syndicates and some individual proprietors during local community visits. This enhanced our understanding of the areas that are important for salmonid spawning and fishing pools and the concerns that have been expressed about impacts on riverbanks and fishing. 

The Beauly District Fishery Board staff already check key spawning locations for beaver dams as part of their routine patrolling and other burns in the lower catchment are regularly checked for woody debris by the Lower Beauly Syndicate staff. We have shared what we have learned about fisheries interests and locations identified from site visits with fishing interests with the Beauly District Fishery Board. NatureScot have committed to working with the Beauly District Fishery Board to ensure that the essential monitoring is supported in the catchment. Through engagement with the Beaver Monitoring and Mitigation Group it is proposed that this monitoring (surveillance for dams) can be responsive to the beaver distribution as monitored by public reporting of field signs. 

Whilst the woodlands in the catchment provide an extensive network of suitable habitat for beavers, various bodies have highlighted the scope for improvement in riparian woodland. A programme of monitoring of herbivore impacts in existing woodland and opportunities for habitat enhancement should be considered by the Beauly Beaver Monitoring and Mitigation Group.

3.2.4 Stakeholder engagement

The Scottish Code for Conservation Translocation sets out the expectation that those proposing a project will carry out a consultation that is proportionate to the project/ risk and will engage with those most likely to be affected by the proposal.

There has been discussion of proposals to reintroduce beavers to the Beauly catchment through an initial consultation organised by Trees For Life in 2022 (in relation to a larger number of landholdings) and via further engagement hosted by Deciding Matters and commissioned by Forestry and Land Scotland in relation to Glen Affric. The University of the Highlands and Islands also carried out research on the socio-cultural perceptions of beaver presence in the Beauly catchment, which has been published as NatureScot CR1318.  There have also been meetings with representatives of community groups and representation has been made to NatureScot from local groups and individuals. We have collated all the information relating to this application and have considered all the issues raised and have included them in our assessment.

Though we consider the process has been adequate to engage with those likely to be affected and more broadly with an interest in the proposal and to identify the risks and opportunities, we recognise there remain considerable concerns about the proposal among the local community and its representatives.

The main concerns/objections have been raised by those with farming/crofting and fisheries interests – arguably those most likely to be directly affected by the proposal. These concerns relate to socio-economics, but also in relation to creating greater uncertainty and affecting personal wellbeing. The Deciding Matters report suggest there are slightly more members of the local community that support the proposal than are opposed. However, we are aware that not everyone wanted to engage with the process for a number of reasons. Hence it is difficult to accurately gauge the range of views in the community, whilst noting it has been contentious. The upset caused to individuals is regrettable and we appreciate there are strongly held views, both in favour and against the proposal.

The Scottish Code for Conservation Translocations recognises the need for stakeholder engagement to help shape the project, share views, address concerns and identify mutually agreeable mitigation. The Code suggests translocation should not proceed where there is the potential for harm unless acceptable solutions can be developed.  Hence perhaps more important in the decision making than the absolute numbers for and against a proposal, is the development of an appropriate suite of mitigation measures to address concerns and the acceptability of them to stakeholders.

Based on our experience from Tayside and the Forth catchment (and internationally) we believe that the likely scale of impacts on agriculture, forestry and fisheries will be small and localised, though undoubtedly of importance to those affected. We also consider there are licensing and mitigation approaches to deal with these scenarios.  The approach as for other areas, will be to utilise the Beaver Management Framework to address any significant negative impacts that arise. Where mitigation is not possible, protected species licensing may be used subject to meeting the three licensing tests (that there is a licensable purpose, that there is no satisfactory alternative and that the actions will not be detrimental to maintaining the species in Favourable Conservation Status). There may be some anticipated need for beaver licensing to prevent serious agricultural impacts, but these would be expected to limited in number and geographically, relating to the topography and types farming and crofting present in much of the catchment. However, the facility of species licensing is there to prevent serious damage and preserve public safety if required. There will inevitably be some additional time demands for land managers in dealing with conflicts where they arise, including taking actions under licence, such as dam removal. Recognising this, the NatureScot mitigation scheme sets out the circumstances where we will provide practical assistance as we learn to live with beavers in the landscape again. However, NatureScot do not provide compensation for damage caused by beaver activity, with a focus on acting early to enable licenced intervention in order to prevent serious damage. Trees for Life have offered that they can provide support for measures that go beyond what is provided by the NatureScot mitigation scheme and they have employed a beaver officer on a initial three-year contract. 

Whilst we recognise there will be some time and cost implications for some land managers of living with beavers, we anticipate these will be small scale and aligned with other aspects of living with wildlife. Although assessed to be of low likelihood, we consider there are two consequences of burrowing impacts which could have more serious consequences; namely burrow collapse impacting on agricultural machinery/people/machinery and burrows impacting of flood bank integrity. We propose that risks could be reduced by monitoring for burrowing activity in at risk locations and carrying out repairs as necessary under licence. This could bring additional time and cost implications to the relatively few land managers likely to be affected. There is however, an offer of support for this monitoring and mitigation from the TFL Beaver Project Officer. We propose this offer of support should be further developed via the Beaver Monitoring and Mitigation Group.

Taking account of all of these issues, our view is that approving the licence and formally recognising wild beavers within this catchment will bring significant environmental benefits beyond beaver presence. Our view remains that whilst beavers may bring some challenges, these are likely to be limited in extent and there are existing frameworks in place or on offer to help manage these conflicts. We recognise there will need to be an ongoing process of engagement and support for local land and fisheries interests to provide assurances of the effectiveness of management measures. We will ensure there are opportunities for further co-development of the approaches to mitigation in the Beauly catchment via the establishment of a Beaver Monitoring and Mitigation Group with appropriate stakeholder representation. We consider there will also be opportunities to develop support for initiatives that will benefit those living with beavers. NatureScot will undertake to ensure that this group is supported by a public body for a minimum period of 10 years post release.

Our view is that the proposals will not lead to unacceptable harm and will provide significant benefits in biodiversity benefits and ecosystem services.

4. Health screening and tagging

Pre-release health screening is carried out for the following purposes: 

• to ensure individuals are suitable for release,
• that their welfare is not compromised, and
• to ensure individuals do not introduce a disease risk to wildlife, livestock or human health following release. 

We have consulted with public health and veterinary experts and have prepared a health screening protocol for all beaver translocation projects. 

5. The Legal Framework

Under regulation 39(3) of The Habitats Regulations 1994 it is an offence to possess or control wild beavers and to transport wild beavers in Scotland.

However, regulation 44 of The Habitats Regulations 1994 allows derogation from the offences contained in regulation 39, provided three tests are met:

1. There must be a licensable purpose as listed in regulation 44(2) of The Habitats Regulations 1994.
2. There must be no satisfactory alternative (regulation 44(3)(a) of The Habitats Regulations 1994).
3. The action authorised will not be detrimental to the maintenance of the population of the species concerned at a favourable conservation status in their natural range (Regulation 44(3)(b) of The Habitats Regulations 1994).

Regulations 44A and 45 of The Habitats Regulations 1994 provides NatureScot with powers as to terms and conditions of any licence it may issue under regulation 44.

The possession, control and transport of beavers for this project is licensed under regulation 44 of The Habitats Regulations 1994.

Under section 14 of the Wildlife and Countryside Act 1981 (as amended) it is an offence to release, allow to escape from captivity or cause to be at a place outside the control of any person any animal species outside its native range (as defined in the Act) without a licence.  ‘Former native’ species are considered to be ‘non-native species’ for the purposes of the Act.  Beavers are considered a ‘former native’ species in Scotland. 

However, section 16(4)(c) of the Wildlife and Countryside Act 1981 (as amended) provides a derogation from the offence contained in section 14 if the introduction of such an animal is in accordance with the terms of a licence granted by NatureScot.

Section 16(5) of the Wildlife and Countryside Act 1981 (as amended) provides NatureScot with general powers as to terms and conditions of any licence it may issue under section 16.