A Consultation on the Beavers in Scotland Strategic Environmental Assessment Environmental Report

Natural justice requires that the de facto reinstatement of beaver to parts of its former native range in Scotland be given official recognition, and that their presence be legally protected – as is reflected by the assent of Scottish Ministers detailed in the policy
Given the distributive nature of wild animals, the policy is correct in accepting and allowing beaver to expand their range naturally
It is best practice, and will lessen tensions with land users, that this official recognition does not result in unregulated releases of beaver into the wild - as is reflected in the policy

The wording in the policy that beavers should be actively managed to minimise adverse impacts on farmers and other land owners, and that the Scottish Government aims to promote proactive management of beavers to mitigate negative impacts on land use activities, is unfortunate. While an explanation is eventually given that many management actions can be carried out with no adverse effects on animal welfare – ie. through removal or lethal control - the term active/proactive management will always be associated with population control.

The presence of beavers in the Tay River catchment provided opportunities for assessing various practical mitigation activities that will be needed in a predominantly agriculture landscape, and which were not available from the Knapdale beavers. That evidence, coupled with evidence of successful measures for mitigation in continental Europe allowed matching in the Environmental Report of potential impacts with appropriate mitigation. However, there needs to be clarity about what are regarded as the difference between generic management and licencing approaches to practical measures for mitigation, when only physical removal and exclusion are seen to require an SNH licence. I note that there has been development of a fit-for-purpose scheme of licensing appropriate derogations to enable legal management that can reduce or eliminate impacts from beaver activity, and that this will be available when legal protection is enacted. The latter is also the case for when there will be guidance from SNH on information on appropriate techniques to manage for the presence of beavers, or eliminate or reduce unwanted impacts. It would have been better if in the first case, of the licensing scheme, there had been some indication of its outline structure within the documents presented for this consultation. It is important to stress that under the rules for derogation in the Habitats Directive, lethal control is a last resort when all other mitigation methods have been exhausted.

The comparison of benefits and risks of alternative policy scenarios was a valuable exercise, and which benefited from the honesty of its analysis. I would recommend a bold approach to a positive future for beaver in its natural range in Scotland through the choice of Scenario 3, and which is one of the two options that informed the policy agreed by Scottish Ministers.