Tay beavers to stay free and living wild
Read the first article:
With over a year gone by since I last wrote about the free-living beavers of Tay, it is time to give an update on what is continuing to be a sorry embarrassment for the Scottish Government and Scottish Natural Heritage (SNH). It was always going to be difficult for SNH to resume their search and trapping of the Tay beavers when they announced in February 2011 a cessation until after the mating season began that Easter (1, 2). SNH were still maintaining that there were only around 20 wild beavers in the region, which it was attempting to capture, after claiming that their release into the wild had been illegal. However, the local people around the Tay, who had disagreed with the original decision to trap the beavers (3) were getting themselves organised.
meeting of the newly formed Scottish Wild Beaver Group (SWBG) was held in
Blairgowrie in January 2011 (1) on the back of the surge in support for
the Facebook group Save the Free Beavers of the Tay, set up shortly
after the trapping began, and bringing in 849 members in very quick time
(2, 4). In February, 22 people turned up at the second meeting of SWBG (5)
and as a result of the controversy surrounding the beavers,
Liam McArthur, MSP for the Orkney
Islands, had tabled a Written Question to the Scottish Executive, asking
“whether the (a) Tayside and (b) Knapdale beavers are legally termed as
(i) res nullius or (ii) private property” (6). The distinction is
between wild animals that nobody owns, like red deer (res nullius)
or domestic livestock like cattle that are private property. It was a
crucial question, because it could have tied the fate of the Tayside
beavers to those of the officially sanctioned reintroduction trial at
Knapdale, as beaver that are wild are considered to be strictly protected under the EU
Habitats Directive (see later).
The answer from Scottish
Environment Minister Roseanna Cunningham was indicative of the legal
Liam McArthur had asked a series of questions, including how many beavers had been captured in Tayside by SNH and where each was kept; what legal basis would permit SNH to capture beavers on land where landowners were not willing to give them access; whether there was an exit strategy for the Knapdale beaver trial should it find that the reintroduction of beavers is not appropriate and, if so, how such a strategy would be implemented; and what assessment was made of the impact on otters and other protected species by the trapping of beavers on Tayside (8). The question about how many beavers had been trapped received the answer of only one, and that it was being kept at Edinburgh Zoo (9). Erica, as she was named by SWBG, became a cause célèbre (10) but she later died in captivity (11, 12).
Perhaps his most important question
though was in asking what the criteria were for beavers to be permitted to
become established in the wild, because here again was a potential link to
the Knapdale Trial, as indeed was revealed by the answer from Cunningham
formed SWBG moved fast, making an impact by announcing - even before
seeing the responses from Cunningham - that the order to trap escaped
beavers in Tayside could be challenged in the courts, drawing a response
from SNH who obviously were unsuspecting of such a challenge. SNH chief
executive Ian Jardine grandstanded a weak argument, considering the legal
contrary, Louise Ramsay of SWBG responded (14):
It was the Group’s belief that the Tay beavers were protected by European law - whether legally introduced into the wild or not - and it had been preparing to take action to "clarify" the legal position. The Group was also concerned about the implications of SNH advice to landowners that the beavers could be legally killed, and said there were "persistent rumours" that two had already been shot near Meigle. SNH confirmed that it had told landowners it was not illegal to shoot the beavers, but said it was not encouraging this action. Rather, they were advising landowners to contact SNH so that they could trap the beavers.
swiftly followed up with a briefing paper on the Tay Beavers for the
Scottish Government that explained that they were a new group in the
process of forming into a company limited by guarantee with charitable
status (5). Its objectives would be:
The briefing also looked at how many beavers there were living wild, where they were, and how long they have been there. They also considered the legal position of the beavers, a key issue that first came up with the intention of SNH to trap them, and which carries on unresolved to this day.
A bizarre numbers game was then played out shortly afterwards. It was reported in early April 2011 that an agreement to avoid trapped beavers being killed was struck after experts had estimated there were only about 20 animals running loose in Scotland (15). The expert estimation had, in fact, come from a statement by SNH released on 28 March 2011 (16). Anyway, this story was based on a backtracking on the original agreement that SNH had with the Royal Zoological Society of Scotland (RZSS) which runs Edinburgh Zoo, about the disposition of the trapped beavers. It was revealed in a letter to SNH, dated 25 October 2010, that zoo officials had said that they were prepared to provide temporary accommodation for beavers and would seek new homes for them for three weeks, before culling them if none could be found (15). The charge for culling would be "£100 plus VAT for the cost of drugs for the destruction of each animal, and subsequent disposal of the cadaver"
An RZSS spokeswoman explained that at the time of writing of the letter, there were potentially an unknown number of beavers that the RZSS were going to be asked to hold by SNH. They were willing to accommodate as many captured beaver as resources would allow, but could not accommodate a large number and would thus have to kill them.
about this letter, an SNH spokesman had said (15):
SWBG had been doing their own survey of beaver numbers, and announced
their results in April 2011 showing that there were around 15 family sites
and about a dozen individual beaver sites scattered about the catchment
The Group hoped that news of higher than expected numbers would lead to a decision by SNH not to resume the trapping in the autumn, as the rehoming of such a large number of animals would be difficult for Edinburgh Zoo. This news report made SNH’s assertion of only 20 beavers look silly, but at least it forced them to recognise the value of SWBG’s local knowledge, such that SNH conducted some fieldwork with the Group in June 2011. Based on active lodges and field signs, SNH then released an update where they reported that there were possibly between 35 and 80 beavers in Tayside (18). However, SNH were still not happy about numbers of beaver (see later).
Tay beavers present an alternative study opportunity
It all went
quiet after that until January of this year, when the Scottish Gamekeepers
Association called on the Scottish Government to carry out further
research on the beavers before deciding whether they should be allowed to
remain in the wild (19). Apparently SNH had submitted an advisory paper to
the Scottish Government on the “escaped/illegally released beaver
population in Strathtay”, in which one option put forward was to “let
the rodents continue to roam free” (19, 20). The Association claimed
that the beavers were already causing serious problems on agricultural
land, rendering parts of fields unproductive, and damage to forestry on
river-banks. SGA spokesman Bert Burnett said (19):
prepared a detailed rebuttal of the SGA’s claims, but supported the call
for research (21). Faced with budgetary cuts, SNH was having to consider
scrapping some projects, one of which could have been release of beaver
into a new study site at Insh Marshes in the Cairngorm National Park, once
the current five-year trial at Knapdale in Argyll had completed (22).
However, as an alternative, the Group proposed that SNH should instead run
a less expensive project in Tayside, conducting some light monitoring and
surveys on the free-living Tay beavers to determine the impact of beavers
in various kinds of habitat in Scotland. Louise Ramsay for the Group said
The SWBG offered to collaborate with yet another SNH survey of beaver numbers in the region, before a ministerial decision was made on what would happen with the Tayside beavers. The planned start of the survey was delayed as SNH struggled to agree upon the most appropriate methodology for conducting it, one costly option of which could have been using helicopters for scoping the area (23). It was reported that the results of the survey, when it was finally carried out, were not expected to have an influence on Environment Minister Stewart Stevenson’s decision for the Scottish Government. As it was, the decision pre-empted the survey when it was announced on 16 March 2012 that the Tay beavers would be left in place and monitored until the end of the Knapdale beaver trial in 2015, when a decision would be made about the future re-introduction of beavers to Scotland as a whole (24). The minister also signalled the setting up of a monitoring group, to be chaired by SNH that would gather information and monitor impacts on other wildlife and land use, as well as providing advice and practical help in managing beavers to landowners in the area. The group was to include amongst others, local landowners, the Tay District Salmon Fishery Board, conservation groups including Scottish Wildlife Trust, and the Royal Zoological Society of Scotland. SWBG will have a vital role in that monitoring group, and its credibility will be shot without them.
The clamour for a cull
decision to leave the Tay beavers in place received predictable scorn. An
article in the Daily Telegraph reflected the view of
Land and Estates that farmers would have no option but to cull beavers on
the River Tay themselves (25). The press release from Scottish Land and
Estates was an open call on its members for that cull, irrespective of the
National Farmers Union Scotland director of policy and regions, said the
decision to allow the beavers to remain uncontrolled and continue to
expand was disappointing (27)
Association of Salmon Fishery Boards said the beavers should have been
removed when their presence was first identified, but it would support the
minister’s efforts to monitor them (25, 28). However, Andrew Wallace,
Chairman of the Rivers and Fisheries Trusts of Scotland added to the
pressure to cull the beaver (29):
Times had a long, reflective and informative article about the Knapdale
and Tay beavers, apparently unaware of the minister’s decision. The
article asked the question of whether it was better to accept that a
native species has returned by an unexpected route, and to make the most
of any benefits presented by the Eurasian beaver in Scotland. However, it
could not resist a pitch at providing a means of culling (30):
Even anglers in England got in on the pressure for culling. The Angling Trust expressed anger at the Scottish Government decision, and had written to Richard Benyon, the UK minister for fisheries and the natural environment. Mark Lloyd, chief executive, explained that they had urged him “to apply to the European Commission for an exemption to the beaver’s European Protected Status to allow them to be controlled and their dams to be dismantled, should they cross the Border” (31).
that Mark Lloyd thought the beavers had European Protected Status. Anyway,
a Scottish Government spokeswoman defended the decision to allow the
escaped beavers to remain at large, but there was the issue of culling
As you would
expect, SWBG welcomed the decision, a fitting outcome to the sixteen
months of their campaigning (32):
Group’s approach to management was about solutions, such as volunteering
to help landowners protectively wrap trees, build by-pass pipe and cage
systems or install netting fences to prevent culverts being blocked
(beaver deceivers) rather than culling (33). Increasingly, though, the
continuing rhetoric around culling, led them to fear that landowners may
have been planning a secret cull of the beavers living in the wild on the
Tay, and with the approval of the authorities (34). The Scottish
Government denied the claims, a spokesman saying:
Ramsay, Chair of SWBG had a different story to tell (35):
that the SWBG news release declared that “Stories conflict” and
“It is difficult for us to know what to believe” (36). The Group
understood that there may be some places where beavers are a nuisance and
problems cannot be solved by mitigation. They called on government to
create a licensing framework that allows for relocation in such instances,
and not culling. Later on, when beavers are established in all the
suitable habitats, they would be prepared to discuss the use of
derogations to allow lethal control in the last resort, under license
So how would those derogations fit in with the protection that is given to beaver under the EU Habitats Directive, and what is the extent of that protection anyway?
Beaver and the EU Habitats Directive
In terms of its protection across the EU, beaver is a listed species in Annex II and Annex IV of the EU Habitats Directive (37). The protection is needed because the Eurasian beaver (Castor fiber) was once widespread in Europe, but was drastically reduced both in numbers and range by the beginning of the 20th century through over-hunting for fur, meat and castoreum (a secretion from the scent glands) combined with loss of wetland habitats (38). A few isolated colonies hung on in France, Germany, southern Norway, Belarus and Russia. Conservation measures since then have contributed to the species' recovery in Europe, including reintroductions and translocations, hunting restrictions (beginning with a hunting ban implemented in Norway in 1845) and habitat protection. Free-living populations of beavers are now established or establishing in most regions of their former European range, the main exceptions so far being Portugal, Italy, the south Balkans and, until recently, Great Britain.
A species listed in Annex IV of the Habitats Directive must be given strict protection under Article 12 of the Directive, such that all forms of deliberate capture or killing of these species in their natural range in the wild is prohibited, as is their deliberate disturbance, and destruction of their breeding sites or resting places (37). Some countries in the EU with thriving populations of beavers consider that the strict protection under Annex IV is unnecessary, and sought derogation under the very specific conditions of Article 16 of the Directive. This does not mean that all protection is taken away, since for those countries that have sought an exception - Estonia, Finland Latvia, Lithuania, Poland and Sweden – beaver is instead listed under Annex V of the Directive, which still puts a range of responsibility on those countries for the welfare of their beaver populations, as laid out in Articles 14, 15 and 16 of the Directive.
The listing of beaver in Annex II adds a further requirement for countries to set up and maintain a network of special areas of conservation for the habitats in the natural range of the beaver. The implementation of this requirement operates on a biogeographical basis since it is unlikely that all species at risk would be found in all locations in Europe because of the variations in habitat and climate across such a large continent. There are nine regions identified in the Directive (Article 1 (37): Alpine, Atlantic, Black Sea, Boreal, Continental, Macaronesian, Mediterranean, Pannonian and Steppic. The UK is covered by the Atlantic region, along with the Netherlands, and Ireland. Other countries straddle two or more regions: thus Belgium, Denmark, France, and Germany have parts in the Atlantic as well as the Continental region; whereas Spain and Portugal have parts in the Atlantic and Mediterranean regions.
Reference Lists exist for each region, and contain the Annex II species considered to be present in their natural range in each country, and for which special areas of conservation have to be designated (39). The Reference Lists derive from the conclusions of bio-geographical seminars and are updated when new scientific information becomes available. Thus Austria, the Czech Republic, France, Germany, Hungary, the Netherlands, Romania, Slovakia and Slovenia are shown in the Reference Lists as having populations of beaver that must have special areas of conservation (SAC) designated for where their natural range occurs, these areas having to be protected so that the habitat that supports the beaver is maintained. The countries that have an exception to strict protection are not required to designate these areas (see above) but Poland appears anyway to have assented to this requirement.
To put this into context for the UK, the otter (Lutra lutra) is an Annex II and Annex IV species in the Directive, with no countries having sought exception. Otter numbers in England and Wales declined dramatically from the mid 1950s to the late 1970s because of persecution and pesticides washing into waterways (40). Hunting otters was banned in Britain in 1978 which, combined with the withdrawal of organo-chlorine chemicals and the cleaning up of waterways, led to their return to many parts of their natural range. Thus the UK, plus 22 other countries in the EU, have otter in the Reference Lists for Annex II species, and have designated SAC. There are over 3,000 SAC designated for otter in amongst those states, and this includes 11 in Scotland where the otter is the primary reason for selection, 32 where the otter is a qualifying feature rather than a primary reason, and 55 where it is noted in the data form for the SAC that they are present.
Interestingly, many of the SAC designated for beaver in the EU are also designated for otter. SNH had come across the concurrence of designation for both otter and beaver, as they had a breakdown of numbers for beaver SAC in Europe, which also had otter, in one of their support papers for the re-application for a beaver license in 2008 (see Table 1 in (41)). Thus of the nine countries that designate for beaver, only the Netherlands has no SAC co-designated with otter, as they are currently reintroducing otter (42). Thus SNH have been aware for some time that it is likely that some of the SACs already designated for otter in Scotland will also be suitable habitat for beaver – i.e. a part of their natural range – and that compliance with Annex II for reinstated beaver could just be a process of adding beaver to the designation of existing SACs. Designations of new SACs for the beaver would not be needed. There is a SAC that is designated for otter in the area of the free-living Tay beavers. The River Tay SAC has salmon as the Annex II species that is a primary reason for selection, and otter are a qualifying feature. The SAC appears to encompass many of the known Tay beaver sites (43). It could be argued now that the Tay beavers are sufficiently re-established in the wild to justify consideration as qualifying features on a SAC (44). They are certainly a better prospect than the Knapdale beavers: of the 34 beavers involved with the trial, only 11 remain in Knapdale (four are kits) leaving 23 that have either died or disappeared (45).
Beaver management in Bavaria
In the world of European beaver conservation, you won’t go far without hearing about the management of beaver in the German state of Bavaria (41, 46). Beaver were reintroduced to Bavaria in the 1960’s and 1970’s, and have grown to an estimated population of 12,000-14,000 animals in 3,500 territories (47). An increasing number of beavers settled in habitats that are also heavily used by humans, and so from 1996 a system of beaver management began to evolve in Bavaria where beavers were trapped and removed if man-beaver conflicts could not be solved by technical means or by compensation for damage (48). A total of 283 beavers were trapped between 1996 and 2000, and were mainly used for reintroductions in other countries, such as Croatia, Hungary and Romania.
Two full-time beaver managers are employed by the Federal Agency for Nature Conservation in Bavaria (49). In about 10% of their casework they have to remove the beavers if mitigation measures such as bypass pipes, cages etc. are not effective. It is said that about 500 beavers per year are removed (about 4% of the total population) most of which are killed, as the opportunities to use them in reintroduction projects have become fewer (41, 46, 50). It is this apparently lawful beaver trapping and killing, in spite of beaver being strictly protected, that attracts those bent on culling the Tay beavers. They should not be so quick to jump on the example of Bavaria as the panacea for their blood lust. This needs some explaining.
area and species legislation in Germany exists at Länder (states) level
as well as national level, both of which incorporate the requirements of
the Habitats Directive. Thus Article 44(1) in the Federal Law on Nature
Protection and Landscape Protection 2009, pretty much follows Article 12
of the Habitats Directive in terms of strict protection for specially
protected fauna and flora species, such that it is prohibited (51):
However, Article 45(7) allows for the legislation of the Länder to have exceptions from the prohibitions of Article 44(1), in individual cases, in order to prevent considerable damage to agriculture, forestry, fisheries, water resources or other considerable economic damage, in the interest of public health, public safety, or for other imperative reasons of overriding public interest, including those of a social or economic nature. An exception may only be granted if no reasonable alternatives exist, and the conservation status of a species' population is not put at risk. This “get out” is sanctioned (and in similar language) to Article 16 in the Habitats Directive.
Articles 20 to 24 of Bavaria’s Nature Protection Law 2011 cover protection of SACs (Part 4 Protection of the European ecological network "Natura 2000", the legal protection of habitats (52)). The Bavarian state government has taken advantage of an exception by adopting a Regulation on the granting of exceptions of the protection rules for specially protected animal and plant species, 2008 (53). Article 2 Exceptions for beaver allows for exception from Article 44(1) 1, 2, 3 of the national legislation above so that in order to eliminate serious economic damage, as well as for reasons of public security, beaver can be trapped and killed between 1 September and 15 March, and beaver dams and unoccupied lodges can be removed.
These exceptions are only allowed at treatment plants, water channels in engine power plants and threatened dam and flood protection facilities such as storage dams, dikes and dams. There is also some provision for exception around fish ponds, irrigation and drainage ditches, as well as public roads. Effort must be made to find alternative means to the measures allowed under the exceptions. Persons carrying out the measures have to be knowledgeable and appointed by the Bavarian State Office for Environment. The type of weapon and ammunition is specified, and full information has to be recorded for the State Office on the location and numbers of beaver taken and killed, and of their disposal. The exceptions do not apply in nature reserves, national parks, nor SAC. In addition, the Regulations are time-limited, running out in 2013. It would seem they replaced a prior regulation from 1994, and an ordinance from 2004, and thus require periodic re-application to remain in place.
The exceptions taken by the Bavarian State government do not exempt them from the requirement to designate SACs for beaver, as they are required to do under Annex II of the Habitats Directive. Their effect is directed towards exceptions to the requirements for strict protection under Annex IV, but even then the exceptions have no power in designated protected areas, and particularly in SACs irrespective of whether they are designated for beaver. I do not think it likely that the UK, at the outset of reinstating beaver to its natural range, could ever hope to justify derogation under Article 16 of the Habitats Directive to avoid strict protection, nor could it justify the tightly crafted measures of the limited Bavarian exceptions, which even then do not apply to beaver in protected areas like SACs. Thus in a Scottish situation, those limited exceptions would not allow culling within the River Tay SAC if beaver were a qualifying feature there, and that is where the free-living Tay beaver are. Moreover, the challenges that one hundred beaver present on the Tay at the moment are a bit different to that of 12,000. It would thus be a foolish farmer or land owner who took a shot at one of the beavers when their legal position under the Habitats Directive would still seem to suggest that they are strictly protected, now that the ownership of the original beaver can no longer be traced, such that they are detached from that original ownership (res nullius) and the resulting progeny are free-living and wild.
Mark Fisher 17 May 2012
(1) Beaver battle in east Perthshire, Andrew Harris, Perthshire Advertiser 18 February 2011
(2) Tayside's wild beavers continue to evade capture, Jonathan Watson, The Courier 28 February 2011
(3) The Tayside beavers - living wild and free in Scotland, Self-willed land 10 January 2011
(4) Save the free beavers of the Tay, Facebook Group
(5) The Tay Beavers. Briefing Paper to Scottish Government, Scottish Wild Beaver Group 7 March 2011
(6) Liam McArthur, S3W-39476, Scottish Parliamentary Business 9 February 2011
(7) Answer to Question S3W-39476, Scottish Parliament Written Answers 4 March 2011, TheyWorkForYou.com
(8) Written Questions, Scottish Parliamentary Business 9 February 2011
(9) Answer to Question S3W-39472, Scottish Parliament Written Answers 4 March 2011, TheyWorkForYou.com
(10) Erica 2010 -2011, Scottish Wild Beaver Group
(11) Re-homed 'Tay beaver' dies at Edinburgh Zoo, BBCNews Scotland 1 April 2011
(12) Perthshire beaver Erica was killed by splinter, Sandra Gray, Courier 13 April 2011
(13) Answer to Question S3W-39477, Scottish Parliament Written Answers 4 March 2011, TheyWorkForYou.com
(14) Legal challenge over River Tay's wild beavers, BBC News Scotland 2 March 2011
(15) Cull of trapped Tayside beavers avoided BBC News Scotland 7 April 2011
(16) SNH Statement on Tayside beavers – update, SNH News 28 March 2011
(17) Scottish Wild Beaver Group say 80 beavers on the Tay, Andrew Harris, Blairgowrie Advertiser 28 April 2011
(18) Beaver update, SNH News 8 July 2011
(19) Bavarian beavers wrecking fields and forests, Scotsman 14 January 2012
(20) Business Performance Report: Quarter 2 2011/12, SNH/11/11/B95709
(21) Beavers and Gamekeepers, Beaver Concerns, Scottish Wild Beaver Group 14 January 2012
(22) The Scottish Wild Beaver Group offers alternative study site if budget cuts bite nation’s main conservation agency, Andrew Harris, Blairgowrie Advertiser 19 January 2012
(23) Beaver survey has not begun, SNH announce, Andrew Harris, Blairgowrie Advertiser 23 February 2012
(24) Tay beaver watch, Scottish Government News release 16 March 2012
(25) Farmers 'will have to cull feral beavers' on River Tay, Simon Johnson, Daily Telegraph 16 March 2012
(26) Tayside beavers get to stay, Scottish Land & Estates16/03/2012
(27) Beaver monitoring 'regrettable', says NFUS, David Boderke Farmers Guardian 16 March 2012
(28) Tay beavers reprieved for three years, BBC News Scotland 16 March 2012
(29) Wild fishery bodies express deep concern over beaver impasse, Rivers and Fisheries Trusts of Scotland 16 March 2012
(30) Beavers are back, Julian Schmechel, Shooting Times 22 March 2012
(31) The beaver reivers must die, demand English fishermen, Scotsman 31 March 2012
(32) Scottish Wild Beaver Group News & Events 16th March 2012
(33) Solutions, Scottish Wild Beaver Group
(34) Secret Tay beaver cull plan' claim denied, David Miller, BBC News Scotland 4 May 2012
(35) Campaigners for Tayside beavers concerned by rumours of a possible secret cull, Clare Damodaran, Blairgowrie Advertiser 10 May 2012
(36) Possible Secret Culling of Tay Beavers, Scottish Wild Beaver Group 5 May 5, 2012
(37) COUNCIL DIRECTIVE 92/43/EEC of 21 May 1992 on the conservation of natural habitats and of wild fauna and flora (Habitats Directive)
(38) Castor fiber, IUCN Red List of Threatened Species
39) Natura 2000: Habitats Directive Sites according to Biogeographical Regions, Nature & Biodiversity, European Commission
(40) Otters are back – in every county in England, Patrick Barkham and Camila Ruz, The Guardian, 18 August 2011
(41) Beaver reintroduction. Summary update on the European experience. Document 4, Trial reintroduction of European beaver to Knapdale Forest – Advice and Recommendations to the Scottish Government by Scottish Natural Heritage, 8 May 2008
(42) Monitoring reintroduction of the otter, Alterra Green World Research
(43) River Tay SAC Details, JNCC
Artificial habitats and non-native and reintroduced species, Part 1: Background to site selection, The
(44) Habitats Directive: selection of Special Areas of Conservation in the UK, Version 4 September 2009. Joint Nature Conservation Committee
(45) Another of our Beavers is Missing, The Scottish Beaver Blog, 10 March 2012
(46) Reintroducing Beavers into the UK, Briefing Paper, Salmon and Trout Association
(47) Background information on beaver management in Bavaria, Gerhard Schwab December 2009
(48) Schwab, G., & Schmidbauer, M. 2001. The Bavarian Beaver Re-extroductions. Pages 51-53 in: Czech, A. & Schwab, G. (eds): The European Beaver in a new millennium. Proceedings of 2nd European Beaver Symposium, 27-30 Sept.2000, Białowieża, Poland. Carpathian Heritage Society, Kraków
(49) Federal nature conservation beaver advisors, Bavaria
(50) Hölling, D (2011) Beavers – landscapers with potential for conflict, forestknowledge.net
(51) Federal Nature Conservation Act of 29 July 2009 (BNatSchG) Germany
(52) Law on the Protection of Nature, the landscape conservation and recreation in the great outdoors (Bavarian Nature Protection Act - BayNatSchG) from 23 February 2011
(53) Regulation on the granting of exceptions from the protection requirements for specially protected animal and plant species of 3 June 2008, 791-1 UG-11, Bavarian State Government