Beaver SEA Consultation ER Post Adoption Statement - River Spey Catchment
1. Introduction
This is the post-adoption report for the Environmental Report (ER) produced in June 2023 which assessed the likely environmental effects of translocating beavers to the River Spey 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 beaver releases in the Spey catchment).
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 Spey catchment 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. 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. 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 Spey sought not to replicate the Beavers in Scotland Report (2015) or the previous SEA assessments which have included comprehensive reviews of the generic potential positive effects of beavers. Hence the River Spey 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 River Spey catchment supports that it is highly suitable for beavers and that beavers are likely to bring positive effects for biodiversity; with safeguards in place for a range of conservation interests. Further benefits are identified for water quality, resources and ecological status. The ER recognises the potential for negative impacts particularly to agriculture, forestry and infrastructure. 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.
Much of the Tay and Spey catchments experienced severe flooding during storm Babet in early October 2023, i.e. subsequent to the production of the Spey ER and the public consultation. Much of the floodplain was under water and there were breaches to floodbanks both on the Spey in the absence of beavers, and in the Tay in areas with beaver activity. It has been recognised since the Tayside Beaver Study Report (2015) that beavers burrowing has the potential to weaken floodbanks (as does burrowing from other animals). Under the Beaver Management Framework, the main tool available to prevent the risk of serious damage from beaver burrowing into flood embankments is to licence beaver removal where there is an identified high risk. Such action may reduce the risk of burrowing (this remains to be demonstrated) but on sections of main rivers, territories may become quickly recolonised. Where beavers are established in the catchment, exclusion from such areas is not considered feasible. Hence this remains an area of potential residual effect which is largely socio-economic with impacts being the loss of crops or forage and the high cost of repairs. We understand that CNPA are conducting a survey of flood embankments to identify their extent, distance from the river, their condition and what assets they are protecting; essentially areas of high risk. The ER provided an estimate of mapped floodbanks (SEPA data) that overlapped with potential core beaver woodland. The full extent of flood embankments in the catchment is greater.
The frequency and intensity of extreme weather events is changing, prompting consideration of the resilience of current land use patterns. It would be possible to re-evaluate the risk and benefits being delivered in areas that are prone to flooding and whether there are options to improve the resilience of farms and crofts to flooding and at the same time reduce conflicts from beaver or to favour natural flood management approaches helping to alleviate downstream flooding. Such discussions are part of a bigger conversation about land use planning, flood mitigation, food security, with wildlife management being a relatively smaller influence in the discussion. There is the prospect that land managers will be supported for delivering a range of public benefits in future agri-environment schemes, which might include support for delivering the types of ecosystem benefits being delivered by beaver.
However on balance beavers were considered likely to bring greater benefits and fewer conflicts in the Spey catchment.
We will take this assessment into account 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 NatureScot head office, Great Glen House, Inverness and at the National Park Offices in Grantown on Spey. Six responses were received. The content of all responses has been considered in the same way.
The majority of responses were from organisations or community groups rather than individuals. The lack of individual responses may reflect that the National Park Authority are leading on the local community engagement which is gathering views on the desirability of the translocation and hence the ER which is focused on assessing the likely environmental effects, elicited less of this type of comment. 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 River Spey catchment.
We have not amended the text of the River Spey Environmental Report as published in June 2023 as we consider the conclusions of the report would not be substantively altered by the comments received, but recognise there are valuable contributions made in consultation responses and we have outlined how we will seek to incorporate them in decisions regarding beaver release licences.
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.
Other comments received addressed the wider management of herbivore impacts and the need for collaborative efforts and support to deliver this particularly in the presence of beaver. Such issues whilst of importance to beaver translocations have a wider context in terms of national policy and regulation and the National Park Plan.
Several comments were made regarding the monitoring required and sought clarity over how this could be delivered and resourced; both in this catchment and others as beaver restoration proceeds in other parts of Scotland. The need for proportionality in the monitoring required of licenced projects was also referenced. It was suggested the dispersal following a release, and hence the need for monitoring would be quite a localised around release sites at least initially. The monitoring protocols agreed as part of licenced translocations will seek to be proportionate to the risks whilst providing the assurances required to protect other biodiversity interest; particularly those of European sites. A monitoring and mitigation plan should be in place prior to a release licence being issued.
The composition of the railway embankment at Insh was queried given that this was flagged as a potential risk in the ER. No further details on the composition have been provided by Network Rail, but we are aware that Network Rail intend to factor in ongoing monitoring of this section of track into their regular programme of track monitoring.
The overall tone of the comments received was supportive of beaver translocation into the catchment with appropriate support in place.
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 Spey catchment. 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. Balancing the range of interactions assessed, this analysis highlighted the Spey catchment as one of the top ranking catchments for beaver translocation.
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. However, it concludes that the catchment is 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: 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 the ER and includes:
- Surveillance for dams principally for Atlantic salmon (and otter and freshwater pearl mussel in the smaller tributaries – HRA also)
- Checking of nest sites and loch/mire outflows for dams for protected bird species
- Herbivore impacts on riparian woodlands
- Site Condition Monitoring of SSSI features as highlighted in Annex 1.
- Notable stands of aspen in the riparian zone
- Rare vascular plants and invertebrates
- Beaver activity close to trees hosting notable lichen species and ancient trees
- Disease screening protocol and additional public health surveillance
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