Appendix 11 – NFUS beaver response

NFUScot­land Rur­al Centre — West Mains, Ing­liston New­bridge, Mid­lothi­an EH28 8LT T 0131 472 4000 F 0131 472 4010 www​.nfus​.org​.uk

Cairngorm Park Spey Catch­ment Beaver Trans­lo­ca­tion Pro­pos­al response from NFU Scotland

20/09/2023

Dear Sirs/​Madam,

NFUS is aware that there are num­ber of bene­fits beavers can provide to the Scot­tish envir­on­ment how­ever pro­pos­als like the CNPA pro­pos­al on trans­lo­ca­tion of the Scot­tish Beaver pop­u­la­tion should con­sider neg­at­ive impact that may occur to those liv­ing and work­ing in the prox­im­ity of the pro­posed trans­lo­ca­tion. Before any pro­pos­al can be agreed pos­sible neg­at­ive impacts must be addressed and strategies agreed to mit­ig­ate or address the neg­at­ive impacts of the pro­pos­al on individuals.

We wel­come the effort which CNPA staff have been going to get out and fully enga­ging with Farm­ers, Crofters and Land man­agers with­in the Spey Catch­ment area. They have made every effort to help our mem­bers under­stand the full facts around the pro­posed releases, any det­ri­ment­al effects these may have on their busi­nesses as well as pro­mot­ing the bene­fits. It is also pos­it­ive that CNPA have ded­ic­ated staff and resource to help with any issues that arise.

NFUS has been approached by sev­er­al of our mem­bers /​land man­agers who are con­cerned about these pro­pos­als and the neg­at­ive effect that they are likely to have on their busi­nesses and their land.

In response to the Cairngorm / Spey Catch­ment trans­lo­ca­tion proposals: -

• NFU Scot­land very much believes that nat­ur­al expan­sion of Beavers will con­tin­ue without the need for trans­lo­ca­tion. We believe that the trans­lo­ca­tion of beavers should not be con­sidered unless a robust mit­ig­a­tion scheme with mit­ig­a­tion meas­ures for all neg­at­ive impacts is estab­lished with guar­an­teed fund­ing in place to allow those neg­at­ively impacted to pro­tect their prop­erty. We are encour­aged by the CNPA’s will­ing­ness to engage with landown­ers and identi­fy how they might help mit­ig­ate any poten­tial dam­age to or loss of pro­duct­ive Agri­cul­tur­al land due to dam­age or flood­ing res­ult­ing from Beaver introductions.
• We and our mem­bers wel­come the oppor­tun­ity identi­fy areas of greatest poten­tial con­flict and urge the CNPA to high­light these areas with­in their Trans­lo­ca­tion applic­a­tion includ­ing the meas­ures of mit­ig­a­tion that CNPA will under­take in these con­flict areas. A form­al frame­work of meas­ures like damn remov­al, trap­ping, relo­ca­tion and where oth­er meth­ods fail, or are inap­pro­pri­ate, leth­al con­trol would provide landown­ers with the reas­sur­ance that pro­duct­ive land would be pro­tec­ted, and these steps will be under taken swiftly where needed.
• Where licenses are required CNPA should com­mit time to land man­agers in the com­ple­tion of such applications.
• The pro­pos­al must also con­sider the impact of the intro­duc­tion for land out­side of the park. We have con­cerns that­down­stream interests will be neg­at­ively affected by the intro­duc­tion of beavers to the Spey bey­ond the park area. We ask will the CNPA afford these interests the same level of pro­tec­tion and assist­ance with mit­ig­a­tion and con­trol meas­ures as those with­in the Park area will receive?

• While the con­sulta­tion pro­cess appears to be very full and wide­spread there will likely be areas affected, as the beaver pop­u­la­tion expands, that were not iden­ti­fied as poten­tial con­flict areas. If these areas include pro­duct­ive land, they will need to be dealt with swiftly before dam­age occurs.

• As it stands NatureScot does not fund all mit­ig­a­tion, land man­agers bear most of cost imple­ment­ing meas­ures to pro­tect their prop­erty. Future sup­port con­tin­ues to be debated, robust meas­ures and long-term government

fin­an­cial sup­port is needed before any con­sid­er­a­tion should be giv­en to fur­ther trans­lo­ca­tion or rein­force­ment projects.

• We were dis­ap­poin­ted that the latest Nature Scot beaver strategy fails to address the costs of dam­age being caused by beavers, costs that are being borne by the farm­ers, crofters and land man­agers suf­fer­ing these losses and dam­age. Until this is fully addressed along with a prop­er suite of fully fun­ded mit­ig­a­tion options no new trans­lo­ca­tions should be tak­ing place.
• If, against what we believe will be bet­ter judge­ment, the trans­lo­ca­tion is approved we would like assur­ances around how quickly mit­ig­a­tion meas­ures would be avail­able to those effected. We can­not see our mem­bers sub­jec­ted to fur­ther dam­age caused by delays in bank repair, dam removals, relo­ca­tion of prob­lem beavers or leth­al con­trol licenses being granted.

We are con­cerned at the poten­tial loss of pro­duct­ive land which is already in very short sup­ply with­in the Cairngorm Park and Spey Catch­ment, This land is hugely import­ant to the viab­il­ity of these farms and loss of graz­ing or worse still land to make import­ant winter feed could chal­lenge the future of these busi­nesses and the depend­ent rur­al com­munit­ies. These areas are rel­at­ively small in terms of area but are hugely import­ant to the viab­il­ity of these farm/​croft busi­nesses. We can­not over­state the con­cerns that our mem­bers in the Cairngorm Park area and fur­ther down the catch­ment have with the pro­posed trans­lo­ca­tion of beavers to the Spey is already untold stress and anxi­ety for amongst those likely to be impacted by this pro­pos­al. Mem­bers also have con­cerns around poten­tial dam­age to much of the ripari­an plant­ing they have done over the last num­ber of years to help with flood man­age­ment and water tem­per­at­ure con­trol with­in the river for example. Much of this plant­ing was done with Scot Gov fund­ing sup­port to improve the envir­on­ment and could be lost if plant­ings failed due to beaver dam­age and landown­ers may be forced to repay the fund­ing they received.

We believe that at this time these pro­pos­als should be with­drawn until the full suite of mit­ig­a­tion meas­ures are avail­able and fully fun­ded to all exper­i­en­cing the neg­at­ive effects of beavers. Full cost recov­ery for any dam­age caused by beavers like increased flood­ing, riverb­ank dam­age (very likely in the soft banks of the River Spey and its trib­u­tar­ies, wood­land dam­age and grazing/​crop losses. We urge Nature Scot and Scot­tish Gov­ern­ment to put a hold on any fur­ther trans­lo­ca­tions until a fully fun­ded mit­ig­a­tion and com­pens­a­tion for loss schemes are in place.

Yours sin­cerely,

lan Wilson NFU Scot­land High­land Region­al Manager