Beaver SEA Consultation ER Post Adoption Statement - River Beauly Catchment
1. Introduction
This is the post-adoption report for the Environmental Report (ER) produced in June 2023 to assess the likely environmental effects of beaver translocation to the River Beauly and River Beauly Coastal catchments (which have been considered together as if they were one catchment). The report was subject to public comment from 9th June to 28th July 2023.
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 licensing beaver releases in the Beauly catchments).
2. Taking account of consultation responses: how the opinions and results of relevant consultations have been taken into account (in this case, setting out how the responses to the consultations for the Beauly catchments have been taken into account).
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 and the 2017 Beaver in Scotland SEA provide a national assessment of environmental effects arising from beaver presence and beaver translocations.
Beavers in Scotland - Environmental Report Addendum 2022 | NatureScot
Scotland’s Beaver Strategy sets out a vision to promote beaver restoration in Scotland. However, how the policy is implemented can be guided by such ER assessments for individual catchments. 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 and where there may be greater or less need for management and mitigation. NatureScot have set out 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 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 2023 ER for the River Beauly catchments sought not to replicate the Beavers in Scotland Report (2015) or previous SEA assessments, which included a comprehensive review of the generic potential positive effects of beavers. Hence, the River Beauly ER largely focused on the potential negative effects in this catchment.
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. More detailed assessments and site visits would be needed to examine the potential for specific local effects.
The ER for the Beauly catchments supports that these catchments are highly suitable for beaver; noting beaver already have a presence in the catchment. Whilst not able to quantify the scale of benefits for climate and nature, the ER recognises the range of potential effects and that beavers could make a significant positive contribution in these catchments. The catchments are also considered to present low risks in terms of the likelihood and scale of negative impacts that may arise from beaver release. If negative impacts do occur, there are existing mechanisms available through the Beaver Management Framework to deal with them.
Hence, on balance beavers were considered likely to bring greater benefits and fewer conflicts in these catchments. This does not negate that some negative impacts may arise bringing costs to some. The socio-economic impacts are not the focus of the ER, but these are considered likely to be of a smaller scale in these catchments than in catchments with a higher proportion of land that is used for arable production or with more infrastructure. There is also the prospect that land managers will be supported for delivering a range of public benefits in future agri-environment schemes, which might include the types of ecosystem benefits being delivered by beaver.
We will consider this assessment along with other information arising from public engagement, when assessing applications for the release of beavers to this catchment.
3. Taking account of consultation responses
The consultation provided a series of questions and a word document with protected fields for respondents to complete. Respondents were asked to indicate if they were responding as an individual or on behalf of a named organisation; otherwise responses were anonymised and stored in compliance with GDPR. A hard copy was made available in in NatureScot head office, Great Glen House, Inverness. The content of all responses has been considered in the same way. We have listed all the issues raised and propose a response to each in Appendix 1. Some of the issues raised are also broader than beaver translocation specifically to the Beauly catchment and will be the subject of wider actions in support of Scotland’s Beaver Strategy.
A total of 12 responses were received, half from individuals/local groups and half from organisations. It is apparent from the responses that many local respondents were keen to voice their views on the desirability of beaver translocation to the Beauly catchments rather than necessarily commenting on the assessment of environmental effects. There was a notable split, with the responses from organisations tending to be positive or pragmatic in seeking to work with beaver translocation. The views of local individuals and groups, whilst not unanimous, reflected greater opposition to the idea of beaver translocation. The socio-cultural perceptions of beaver translocation in this catchment have been subject to social science studies carried out by the University of Highlands and Islands in conjunction with the engagement that has been led by Trees for Life. The findings of this study have recently been published and offer further insight to local perceptions of beaver - NatureScot Research Report 1318 - Nature’s contribution to people and community engagement: socio-cultural and economic perceptions of beaver presence in the environment
Many of the responses refer to potential beaver impacts on agriculture, primarily in a negative way, but not exclusively with one response noting the potential for the containment of agricultural run-off. Many of the negative comments relate to the socio-economic impacts; the time and costs associated with monitoring beaver activity, resourcing mitigation, meeting the cost of damage or the impact of beaver activity on land classifications or values. Whilst socio-economic factors are not the focus of an SEA, there is recognition that living alongside beavers whilst expected to bring net environmental benefits, may bring additional time requirements and costs to some land and fishery managers, to the managers of assets and public agencies. Hence, while there is the expectation of wider benefits to society (including socio-economic) arising from these environmental benefits (such as through flood mitigation, improvements in water quality and eco-tourism) it is recognised that those bearing the costs are not necessarily the same people that are experiencing the benefits. Responses relating to fisheries also noted concern about the costs associated with monitoring and mitigation. Scotland’s Beaver Strategy has actions that relate to looking at the support available to land and fisheries manager for living alongside beavers and reducing negative impacts.
Several consultation comments reflected a desire to present a more balanced summary of beaver activity particularly with greater focus on the beneficial effects highlighted in the scientific literature such as; the greater abundance of juvenile salmonids where beavers are present, the role of beaver dams in reducing nitrates and phosphates and diffuse pollution and beaver wetlands acting as a brake on wildfires/wildfire risk. These potential benefits from beaver activity are recognised in more detailed reviews of beaver effects and it is appreciated that ER as presented may not adequately communicate the range or scale of anticipated positive effects.
Some comments reflected the desire to see monitoring of the positive effects as well as potential negative effects, meanwhile other comments reflected concerns about burden of monitoring on those applying for translocation licences.
It was commented that the impacts of other wild herbivores would need to be compatible with beaver presence and riparian woodland establishment, which is acknowledged in the 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; impacts on fish spawning habitat, impacts on specific infrastructure e.g. field drains. The assessment was at the whole catchment scale and sought to explore the likelihood and significance of effects of beaver colonisation at this scale. It would be possible to look at the site specifics in more detail with the data sources available and via site visits to assess the likelihood of beaver activity impacting on a particular site, but it is not possible to capture this level of detail in an SEA for the whole catchment. Some local assessment could be beneficial in relation to specific licence applications.
The following issues raised in the consultation are noted as considerations that should be taken into account in assessing applications for the wild release of beavers in these catchments.
- Further engagement with fishery interest would be beneficial ahead of a beaver translocation in this catchment, to agree a programme of monitoring and processes for management of dams (dam removal criteria).
- Development of proportionate monitoring and mitigation 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 be made to the assessments of environmental effects in the Environmental Report and hence it is proposed that the ER it is adopted as was published in June 20123, 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 the River Beauly catchments. It is acknowledged that beavers are already established in the River Glass and River Beauly. The decision whether to allow beaver translocations will influence the speed of colonisation and the genetic complement of the population. 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 conflict are likely to arise. Information from this analysis is presented in the report and Tables in Annex 3. Balancing the range of interactions assessed, this analysis highlighted the Beauly catchment as one of the top ranking catchments.
The ER and HRA point to the need for monitoring to ensure that there are no adverse effects on Natura interests should a licence for beaver release be granted in these catchments. However, it concludes that the Beauly catchments are highly suitable for beavers and there do not appear to be environmental effects that would preclude beaver translocations that cannot be mitigated.
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: to ‘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 namely: 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 Tables 4 and 5 of the ER and includes:
- Site checks of clear-water lochs in Strathgass Complex SAC
- Monitoring of herbivore impacts in Strathglass SAC woodlands
- Surveillance for dams impacting on salmon passage in Strathglass SAC woodlands with respect to the notified otter interests.
- Risk based surveillance for dams affecting fish passage more widely in the catchment.
- Site Condition Monitoring of SSSI woodland features and lichen features as highlighted in Annex 1.
- Monitoring and where appropriate mitigation of important stands of aspen and sensitive lichen sites to be considered prior to release.
- Disease screening protocol and additional public health surveillance
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