Beaver SEA Consultation ER Post Adoption Statement - Addendum, Loch Lomond and Forth
1. Introduction
This is the post-adoption report for the Environmental Report (ER) produced in October 2022 as an Addendum to the ER that was produced by SNH in 2017 accompanying the decision to allow beavers to remain in the wild in Scotland. Further to this we produced the first of a series of ERs on the likely effects of beaver releases into specific new catchments. This first report assessed the likely environmental effects in the River Forth and River Leven (Loch Lomond) catchments. Both reports were subject to public comment from 10th October to 18th November 2022.
The Environmental Assessment (Scotland) Act 2005 sets out the requirements for SEAs post-adoption of plans. These can be summarised and combined into four topics that are the focus of this post adoption report.
1. Taking account of the environmental assessment: how the environmental considerations and findings of the assessment presented in the Environmental Report have been taken into account in the plan or programme (in this case the consideration of beaver releases into new catchments in Scotland).
2. Taking account of consultation responses: how the opinions and results of relevant consultations have been taken into account (in this case, the responses to the consultations on the Beavers in Scotland ER Addendum and the ER for the Rivers Forth and River Leven (Loch Lomond) catchments).
3. Consideration of alternatives: the reasons for choosing the plan or programme as adopted, in the light of the other reasonable alternatives considered.
4. Monitoring of environmental effects: the measures that are to be taken to monitor the significant environmental effects of the implementation of the plan or programme.
2. Taking account of the environmental assessment
The 2022 Addendum to the 2017 ER was intended to provide an update on the policy context, what we know about beavers, their impacts and management and mitigation since the previous Strategic Environmental Assessment (SEA) report. The report provides a national assessment of environmental effects arising from beaver presence and beaver translocations.
In the ERs we have outlined that we will take account of the ER and Habitats Regulations Appraisals at a catchment scale when considering applications for licences to release beavers in new catchments. The policy to promote beaver restoration in Scotland and associated actions in Scotland’s Beaver Strategy are unchanged as a result of these assessments, but how the policy is implemented can be guided by these assessments. We can assess the likely importance of interactions at a catchment level and use these to guide where beaver translocation would have greater or fewer benefits, current habitat suitability and where there may be greater or less need for management and mitigation.
The ER for the two catchments assessed supports that they are highly suitable for beavers; noting they already have a presence in both catchments. The policy in support of beaver restoration comes partly from commitments to restore former native species (Habitats Regulations), but also from the desire to harness the benefits that beavers bring as ecosystem engineers to deliver a wider range of benefits for biodiversity and climate change mitigation. The 2022 ER sought not to replicate the Beavers in Scotland Report and 2017 ER which was comprehensive regarding the potential positive effects of beavers. Hence the 2022 Addendum largely focused on the potential negative effects which may need to be considered in new catchments. The scale of anticipated negative impacts and the experience of management and mitigation from Tayside support that negative impacts that do arise can largely be mitigated. This does not negate that some negative impacts many arise and the same people that experience negative impacts are not necessarily those in receipt of benefits. Beaver restoration in Scotland will take some adjustment as recognised in Scotland’s Beaver Strategy. NatureScot and Scottish Government are committed to supporting this process, whilst recognising the wider benefits.
3. Taking account of consultation responses
The consultations provided a series of questions and a webform to help respondents comment on the reports. Hard copies were made available in two locations and an address supplied, although no responses were received in writing. Unfortunately the webform did not include a field for respondents to include their personal contact details. This omission was not intentional (and will be rectified in future consultations), however, many respondents did include their details in their responses or sent their response directly to the consultation email address. Fifty five responses were received, although a number of these were duplicates where the respondent submitted a response via the webform and also submitted a response by email. However, the content of all responses has been considered in the same way.
It is apparent from the responses that many respondents were keen to voice their views on the desirability of beaver translocations (particularly to specific catchments) rather than necessarily commenting on the likely environmental effects. There are also some comments which could be considered out of scope of an SEA; focusing on socio-economic impacts. Nevertheless we have listed and responded to the issues raised in Appendix 1. Many of the comments were generalised in nature and not specific to the Addendum or the ERs for the Rivers Leven (Loch Lomond) or River Forth catchments, however, we have presented them in Appendix 1 by report where it was possible to do so.
We have not amended the text of the ERs as we consider the substance of the report would not be altered by the comments received, but recognise there are valuable contributions made in consultation responses and have outlined how we will seek to incorporate them in decisions regarding beaver release licences.
Report specific summary
Addendum
Appendix 1 sets out a summary of consultation responses and how NatureScot has responded to these comments.
Many of the comments relate to wider ambitions around beavers in Scotland that are already captured in Scotland’s Beaver Strategy (SBS). For example around resourcing for management and mitigation; who bears the costs and proposals for further research. Whilst relevant to the discussion of beaver translocations, these actions will be picked up through the implementation of the Strategy and the Scottish Beaver Advisory Group that has recently been convened to oversee strategy delivery. Some of the responses provide comments and do not require specific action.
Actions relating to the Scotland’s Beaver Strategy
- Want to see beavers and woodland interactions better understood and clearer arrangements around protection measures, grants and herbivore impact assessment tools.
- Support for integration with future rural support for land management delivering environmental benefits and reduced beaver conflicts.
- Support for better understanding of beaver effects on water temperature, carbon sequestration etc.
- Calls for wider benefits to be studied and recognised.
- Call for socioeconomic assessments.
There is also a category of responses that highlight issues that may need to be assessed in more detail at a catchment or proposal specific level. There were some suggestions for further spatial analysis using additional datasets that could be included to identify other suitable/ unsuitable catchments. In addition there are a couple of request for ERs to be completed for other catchments to allow translocations to be considered there.
Summary of catchment specific proposals
- Further engagement with fishery interest to agree a programme of monitoring and processes for management of dams (dam removal criteria).
- A better understanding of where spawning habitats occur and timing of up and down stream movements on river systems to help target surveillance and management programmes.
- Development of local Beaver Management Plans/ for SACs setting out commitments.
- Potential role for local Beaver Management Groups to share information and seek to explore local concerns and opportunities.
- More engagement with new audiences in new catchments regarding the operation of the Beaver Management Framework, Beaver Mitigation Scheme and funding opportunities.
- Calls for more comprehensive guidance (or specific updates) to be made available on mitigation approaches
- Further scoping of lichen interests and heritage trees to identify the need for pro-active protection
- Population modelling of release scenarios to inform monitoring and management.
- Further assessment of specific flood risks and implications for planning.
- Development of proportionate monitoring protocols for a range of interests that allows early detection of negative impacts including;
- salmon, trout and lamprey
- water levels in lochs for bird interests
- monitoring of herbivore impacts in woodlands
- protected sites monitoring
Loch Lomond ER
There were a number of comments to the effect that the scale of assessment is not sufficiently detailed to assess local issues; of flooding and associated impacts on planning considerations; impacts on fish spawning habitat, impacts on specific infrastructure e.g. fish passes and culverts. The assessment was at the whole catchment scale and sought to explore the likelihood and significance of effects of beaver colonisation at this scale. The report also drew on the summary of mitigation approaches from the Addendum and what monitoring and mitigation can be relied on to address potentially negative effects. Hence the scale of assessment is not at the very local scale that would be needed to examine some of these effects. Some local assessment could be beneficial in relation to specific release licence applications. Beavers have already made their way into the River Leven (Loch Lomond) catchment from both the south east and the north of Loch Lomond and hence it is likely it will be further colonised. The decision whether to allow beaver translocations will influence the speed of colonisation and the genetic complement of the population. Given the findings of the ER, the assumption is that more detailed assessments will inform the need for monitoring and mitigation rather than necessarily the decision to translocate beavers into this catchment.
There were no responses that highlighted the need for substantive changes to the Environmental Report for the River Leven (Loch Lomond) catchment and hence it is proposed that it is adopted as is, with the addition of this post adoption report as an Annex (Annex 2 to the report).
Forth ER
There were fewer comments that appeared to relate to the Forth catchment which may reflect that beavers are already well established in this catchment.
Most of the comments listed for Loch Lomond are also relevant to this catchment, but those specifically raised include:
- Want to see beavers and woodland interactions better understood and clearer arrangements around protection measures, grants and herbivore impact assessment tools.
- Support for integration with future rural support for land management delivering environmental benefits and reduced beaver conflicts
- Further engagement with fishery interest to agree a programme of monitoring and processes for management of dams (dam removal criteria).
- A better understanding of where spawning habitats occur and timing of up and down stream movements on river systems would help target surveillance and monitoring programmes.
- Development of local Beaver Management Plans/ for SACs setting out commitments.
- Further scoping of lichen interests and heritage trees to identify the need for pro-active protection; including river jelly lichens on the Teith.
- More engagement with new audiences in new catchments regarding the operation of the Beaver Management Framework, Beaver Mitigation Scheme and funding opportunities.
- Development of proportionate monitoring protocols for a range of interests that allows early detection of negative impacts.
There were no responses that highlighted the need for substantive changes to the River Forth Environmental Report and hence it is proposed that it is adopted as is, with the addition of this post adoption report as an Annex (Annex 2 to the report).
4. Consideration of alternatives
Section 4 of the ER provides a summary of key report findings in terms of summarising the expected benefits and potential risks from beaver translocation to both the River Leven (Loch Lomond) and River Forth catchments. It is acknowledged that beavers will likely colonise the Loch Lomond catchment naturally and are already well established in the Forth. Some opportunities are identified around beaver translocation and potential mitigation of risks outlined. The national policy supports beaver restoration so the do-nothing alternative is not regarded as a feasible option (SEA Addendum 2022).
The 2022 Addendum report considered information at the national scale to inform where the greatest benefits from beaver restoration and least conflicts, are likely to arise. Information from this analysis is presented in the report and Tables in Annex 3. Hence alternative catchments were considered in terms of their suitability for beaver restoration. The River Leven (Loch Lomond) and River Forth catchments both features highly in terms of the extent of suitable habitat with smaller extents of PAL land (Table 12). The consideration in this case is therefore whether or not beaver release licences should be issued in specific catchments. The ER and HRA point to the need for considerable additional monitoring to ensure that there are no adverse effects on Natura interests should a licence for beaver release be granted in either catchment. However, it concludes that the catchments are highly suitable for beavers and there do not appear to be environmental effects that would preclude beaver translocations that cannot be mitigated. The proposal to update the SEA at an appropriate juncture would seem to be sensible given that we are continuing to learn from beaver presence and management and mitigation approaches.
5. Monitoring of environmental effects
The potential for positive and negative environmental effects are recognised in section 4 of the ER. Ideally monitoring would be established to measure many of these effects. Indeed it is an ambition of Scotland’s Beaver Strategy; Goal 8: Assess the biological, environmental, economic and social implications of beaver presence on other species, habitats, physical processes, land use, wider society and wider ecosystem services (including general ‘natural capital’) and use this knowledge to inform decision-making.
There will be a variety of ways such research and monitoring can be progressed such as through academic collaborations and citizen science. However, it is likely that agency resources will need to focus on the monitoring required for regulatory purposes; Article 17 monitoring, monitoring set out in Habitats Regulations Assessments and protected sites monitoring. Such monitoring will need to be proportionate, yet sensitive to provide early detection of potentially negative effects.
Specific mitigations including monitoring are highlighted in Table 7 and 8 of the ER and includes:
- Risk assessment and implementation of dam surveillance programme for the river SACs
- Monitoring of herbivore impacts in SAC woodlands
- Site Condition Monitoring of SSSI woodland features, vascular plants and lowland neutral grassland (As per Annex 1)
- Risk assessment and implementation of monitoring of specific lichen interests and heritage trees.
- Surveillance of known populations of vascular plant species of conservation interests
- Beaver population size and distribution
- Beaver disease screening and health surveillance.
