The Beaver Tenancy Association. An innovative alternative to the government’s beaver consultation proposals.

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The UK Government is consulting on its plans to reintroduce beavers into the wild in England. Beavers are ecosystem engineers and were hunted to extinction across most of the European range for their fur, meat and castoreum. Back in the 1980s, countries across Europe began to restore beaver populations. We in the UK are late to the game and, as a result, our government is proposing a cautious and controlled approach that is out of sync with public demand for a more confident and ambitious approach to nature recovery.

During the 1990s, Silvo Funtowicz and Jerome Raventz proposed a ‘post-normal science’ approach for use in situations where facts are uncertain, values are in dispute, and where risk-averse, or other, ways of thinking are locked in. The approach offered up robust sets of insights to enable action.

In this spirit we offer up a ‘post-normal conservation’ approach to the Beaver Tenancy Association (BTA) approach to UK beaver reintroductions. This was developed by the Ecosulis innovation team during the summer of 2019 in the context of thinking through blockchain applications in conservation (although the approach is not dependent on this).

The idea of ‘post-normal conservation’ is to put out radically different, but well thought through, ideas as an ‘other’ to conventional proposals. The presence of intriguing alternatives helps democratise conservation by introducing the possibility to compare and discuss approaches. This also introduces an accountability dynamic because it presents established conservation bodies with a choice; to ignore the post-normal proposal, adopt it, justify their proposal, or discuss it and allow the opportunity to allow for something different to emerge.

Rewilding is all about restoring the dynamic interactions in ecosystems that give rise to biodiversity and abundance. We can think about conservation policy in the same way. Our BTA concept is an initiative to restore dynamic interactions between government and big NGO policy makers, with communities of SMEs and scientists developing innovative new approaches to nature recovery.

Our Beaver Tenancy Association whitepaper presents an overview of our proposed approach to beaver reintroductions and the saline points are covered in our responses below to the government’s consultation which ends on 17th November 21.

We look forward to hearing your reactions!

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The 12-week public consultation, which closes on 17th November 2021, sets out the criteria for The Department for Environment, Food and Rural Affairs (Defra) presenting the government’s framework for introducing beavers to the wild. The consultation contains 15 questions in total. Questions 1 – 5 are personal questions. Questions 6 – 15 relate to specific aspects of the proposed approach to beaver reintroduction and management. Below are our responses which offer an alternative to the proposed approach.

5. What is your interest

Ecosulis is the first UK SME with accelerating rewilding as its primary purpose. We are acknowledged as leading experts in the science, policy, and practice of the rewilding approach to nature recovery. The restoration of species that play a functional role in ecosystems and contribute to ‘uplifts’ in ecosystem integrity and resilience is central to the rewilding approach. The beaver is an exceptional ecosystem engineer and policy has enabled its recovery in most west European countries. We are keen that the UK learns from European experience and, rather than simply catching up with others, applies our reputation for creativity to design new policy approaches that express and support the growing social movement identity of rewilding.

6. Do you agree or disagree with the proposed approach to beaver reintroductions? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

The licensing-based approach proposed sounds overly bureaucratic and risk-averse. We offer an alternative ‘Beaver Tenancy Association’ (BTA) approach

This conceives beavers as new countryside residents in need of land to settle, cultivate and raise their families. Agricultural tenancies and use rights (e.g. angling) structure the rural land economy. Beavers, just like people, need tenancies and licences to ‘go about their business’ and contribute to rural life, economies and heritage. The BTA imagines a special purpose vehicle that secures, negotiates and manages tenancy agreements with landowners on behalf of beavers. The BTA would commission beaver ‘suitability’ models (potential territories) for catchments, generate fair rent models and invite landowners to offer fixed-term tenancies. The contracts would place responsibilities on the landowner and BTA (‘beaver tenant’ support) and transfer rights to the value of ecosystem services to the BTA. The BTA business model – i.e., its ability to pay rent on behalf of beavers, would be a blend of public (ELMS) and private payments for ecosystem services and impact philanthropy. For example, this would give new meaning to the popular ‘adopt an animal’ fundraising approach by giving citizens a direct stake in beaver recovery.

The current proposal prompted a reread of Prof W.A. Adams’ excellent 1997 paper “Rationalization and conservation: ecology and the management of nature in the United Kingdom”. His analysis highlights how ideas of equilibrium and stability and the control and management of nature have been institutionalised in the UK and associated with the rise of risk avoidance and standardisation in administrative culture. The beaver symbolises advances in ecological science and conservation practice that recognise and embrace ecological dynamics, systems thinking and uncertainty (sometimes referred to as a ‘messy chaos’).

The proposal presented appears out of sync with advances in ecological and integrated conservation science and the clearly articulated political ambition to ‘move from a defensive focus on nature protection to a proactive focus on nature recovery’. Achieving this will require new policy mechanisms and instruments and the design of this would benefit from an examination of the processes of institutional reductionism (e.g., simplifying ecosystems to ‘standardised’ habitats and species) that co-produced the protective, defensive and, to some extent, agnostic protective nature regime.

7. What criteria, in addition to those listed above, do you think projects should meet to be granted a licence for wild release? Please state your reasons and supporting evidence.

An additional criterion we would like to see is specific provision for innovative approaches to nature recovery involving beavers to be funded, trialled and developed.

8. Do you agree or disagree with the proposed approach to existing wild-living beaver populations? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

Yes. The existing beaver populations represent new cultural assets for nature recovery. They are natural heritage in the making.

We support the faster-paced option for beaver reintroduction outlined in the reintroduction advice report (NEER 019) and suggest that our Beaver Tenancy Association approach has the potential to deliver key components of the proposed management framework. We note, however, that in places this report assumes that beavers are an animal in need of management and control. This risk assigns beavers an identity of either an alien species or some form of ‘livestock’ that might generate ecosystem services. We would prefer a policy narrative that frames beavers as productive past residents of our country which we wiped out in times gone by and we now have the desire and foresight to resettle (hence a tenancy approach).

9. Do you agree or disagree with the proposed approach to licensing of future beaver enclosures? Please state your reasons and supporting evidence. If you disagree, please provide any suggested alterations or alternatives and supporting evidence.

The problem with beaver enclosures is that they are costly to install and maintain, very difficult to govern (in terms of efficacy) and communicate a control and caged image of nature recovery. Additionally, the beneficial impact of beavers as ecosystem engineers is predominantly witnessed at landscape and catchment scale. It is at these scales that factors such as improved water attenuation, nitrate sinks and improved biodiversity are witnessed and have the greatest cost benefit. Therefore, an enclosure-led approach fails to maximise the opportunity to offer a nature-based solution to the combined climate and ecological crises.

We recommend that any licensing of beaver releases is undertaken without the need for enclosures. Our concept of tenancy agreements with landowners participating in catchment wide initiatives overcomes the need for enclosures and would maximise the ecosystem benefits offered by catchment scale beaver establishment. Landowners can offer up tenancies. If the beavers move on and settle on other land, then the owner can be offered a fair rent to let them stay. If they decline, then the BTA could capture them and move them to a site where a landowner would like beaver tenants. This is a more dynamic and open approach and based on the assumption that a) most landowners would be happy to rent out boggy and riverside areas of their land, b) would enjoy being part of a collective action and pro-nature story, and c) that, over time, having beaver tenants would become normal. We think these are reasonable assumptions.

10. What criteria do you think should be taken into consideration when determining whether or not to issue an enclosure licence?

We suggest three additional criteria;

1) Whether the costs of fencing etc brings new finance into conservation or diverts existing

2) Whether the effectiveness of the policy instrument can be assessed in a cost-effective way and also the extent to which it can be ‘gamed’

3) How it constructs/influences a future cultural identity for beavers. As suggested above it suggests an animal that needs to be controlled and caged. Like what? What associations would people make in their mind?

11. Does the management hierarchy cover management actions you would expect? Are there additional aspects that you think should be included in the management hierarchy? Please provide further details.

Our main concern with the approach outlined is that the supporting reports do not specifically review learning and experience from other countries in Europe, and in particular the successful 40-year-old holistic Bavarian approach (Home (bibermanagement.de). Our understanding is that this adopts a ‘green, amber, red’ zoning approach with associated beaver governance approaches.

In addition, we caution against assigning beaver legal protection at this stage. Protected species legislation and associated lists were designed to deliver different policy objectives, namely protecting populations of species threatened by human activities. The Beaver represents a new class of functional species, those with the potential to accelerate ecosystem recovery. These include breeds of ‘de-domesticated’ and ‘wilded’ bovids and equids. New categorisations of functional species and associated policy are required to apply the new science and principles of nature recovery. In our view it would make sense to keep the protected status of beavers vague so as to enable the development of next generation conservation policy. Our BTA approach, which gives beavers a contractual right to reside, offers an alternative approach to prescriptive, protective legislation.

12. Excluding direct payment for management activities, what other support do you think should be available and to whom?

Our BTA approach avoids placing the public benefit costs of beavers on landowners. Instead, it offers a practical and entrepreneurial model that is already familiar to many tenant farmers where local authorities, corporations, citizens and activist investors can invest in beaver resettlement and the societal aspiration to leave nature in a better place than we found it. The rise of Environmental and Social Governance (ESG) and the desire to ‘finance green’ is creating material and other forms of value returns from nature positive investments.

13. Are there any specific areas where guidance is required? Please provide details.

Alongside the sustainable land farming incentive, landowners could be offered the opportunity to become a ‘beaver landlord’ and the government could consider making a public finance contributing to a BTA organisation.

14. How would you prefer to access advice and guidance (e.g. information on website, via email, focal point for enquiries etc)?

Via a Beaver Tenancy Association!

15. Would you (or an organisation you are involved with) consider preparing an application for wild release, if the approach proposed in this consultation became national policy? If yes, please provide the general location where you might consider applying for such a release.

Yes, a number of our clients looking to rewild are interested in beavers although we would like policy that supports a more progressive approach.

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