Please accept my comments against the proposed beaver trapping rules>>> Aug. 2017 (submitting comments to: becky.orff@maine.gov )
Date: September 5, 2017
Re: IF&W Rulemaking Proposals
Chapter Number and Title: Chapter 4.01 (G. 1a, 1b) – Upland Game and Furbearing Animals
Proposed open and closed areas for beaver trapping
From: Richard A. Hesslein Jr. / http://www.beaverbros-ecohumanesystems.com
68 Peary Mountian Rd., Brownfield, Maine 04010
Tel. (207) 875-2005 / (207) 935-3938
I have been involved with beaver related issues for 15 years or so, working with State and Federal biologists and others, to advocate for, and to mitigate conflicts from, beaver activity in Maine and New Hampshire. I am involved with a beaver monitoring project for the White Mountain National Forest.
I have worked with the region’s foremost experts on beaver activity and the ways to successfully mitigate beaver conflict sites while keeping beaver and important habitat considerations in place.
I believe significant reduction modifications to the proposed beaver trapping rules for 2017 should be made. Beaver mortality levels are too high. I have found many beaver habitats are empty and the ecological diversity and all the related benefits as described below are being negatively impacted all across the State due, perhaps, to in ingrained prejudice in the general public, and inappropriate, heavy-handed lethal conflict resolutions.
The recent change to the rules allowing reduced setbacks for trapping on beaver dams and lodges in the more remote regions of the State seem to demonstrate a dramatic insensitivity to beaver welfare and ecology concerns. These feed and promote a continued bias against beavers.
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No beaver monitoring or research
I am concerned that there is no monitoring of beaver populations nor research being done to inform decisions about the areas that should be closed or restricted for trapping. The proposed rule states that: ”Townships or portions thereof are opened or closed … in response to the amount of habitat, past harvests, and complaints of beaver damage to public property.”
I find that little to none of this analysis has been done (except for required attention to complaints!). Virtually all areas of the state are open to unlimited trapping. This is done without regard to habitat needs, ecology concerns, or beaver welfare.
Habitat needs and beaver welfare need to become greater considerations in beaver management
The current blanket approach, aimed primarily at reducing conflict complaints, results in the degradation of not only beaver, but all the connected ecologies, habitats and species of both plants and animals that depend upon their keystone activity.
Statewide, unlimited trapping seasons for beaver, along with relaxed restrictions on trapping setbacks from dams and lodges, sends the inaccurate message that beaver are primarily pests and destructive nuisance animals.
I question the position taken by MDIF&W last year that beaver are at or beyond the “carrying capacity” for the state, based on a very loosely estimated population (in 1985?), and the counting of corpses. It seems that unless beaver remain nearly invisible, then they must be overpopulating. Based on my own extensive observations across many regions of Maine, North, South, East, and West, I do not agree that most quality beaver habitat is already occupied, and that any further expansion of the beaver population is likely to be into potential conflicted sites. Again, I have witnessed many prime habitat sites to be vacant!
The Department’s current assumptions will lead to further, unsustainable encroachment by humans into wetland and transitional wetland habitats; habitats that are crucial to the restoration and sustenance of healthy hydrology and animal, plant, and even our own human ecologies. Beaver work also has been cited for significant value in mitigating the effects from climate change which should not be ignored! **
*http://www.beaversww.org/assets/PDFs/Freshwater-Species-at-Risk.pdf
*https://www.wildlifeadaptationstrategy.gov/pdf/nov-13-2014-climate-beaver-team-report.pdf
High quality flow devices should be first choice for blocked culverts
Conflict sites where roads and culverts are threatened can most often be solved by the installation of cost effective, long lasting, low maintenance, modern water-level control structures and/or properly designed protective fencing. Conflicts arising from landowners who are simply intolerant of any beaver presence, or who may be unaware of the values from beaver for ecosystem health, should be met with education and a robust regard for the important public resources at stake. Can’t we do better? *******
*…………………http://www.gwrlt.org/images/stories/NewsletterArchives/2016_fall.pdf >> (must scroll down through newsletter for beaver deceiver article)
**** http://www.BeaversWW.org, http://www.beaversolutions.com, http://www.beaverdeceivers.com, http://www.martinezbeavers.org
*http://www.beaversww.org/beavers-and-wetlands/articles/beaver-flow-device-studies/
*https://www.fws.gov/oregonfwo/Documents/BeaverHabitatMgTools.pdf
Poorly-placed trails and unimproved roads guarantee conflict
Another concern is logging and other “unimproved” roads also snowmobile and other trails which penetrate even some of the most remote areas of our State that are inappropriately located or inadequately designed/engineered to accommodate transitional wetlands. These virtually guarantee further beaver conflicts. These human encroachments will inevitably lead to the usual lethal removal of beaver and further suppression and degradation of these critically valuable cyclic wetland systems.
The importance of cyclic wetlands needs to be recognized
It might be easy to conclude from driving around, or perhaps especially from flying over Maine, that wetlands are abundant or even over-abundant in Maine. This is NOT indicative of actual ground conditions suitable for, or predictive for numbers of beavers actually present.*
*http://www.martinezbeavers.org/wordpress/wp-content/uploads/2014/11/Ecological-engineering-and-aquatic-connectivity-a-new-perspective-from-beaver-modified-wetlands.pdf
Maine’s wide array of wetland types is usually recognized, and often, but not always, rated for their relative value for various habitats, and often afforded some level of protection, which is a positive step! However, many of these wetlands are of a more static nature and cannot replace the essential effects from sustained beaver managed flowages. While vernal pools have gained some recognition and protections, beaver activity^ has not gained a proportional status! (^ far greater overall biological potential, and would help generate and maintain important vernal pool sites and values as well!)**
*http://www.beaversww.org/assets/PDFs/People-and-Fish.pdf
*https://www.fws.gov/oregonfwo/promo.cfm?id=177175812
The widely acknowledged benefits from beaver activity, include the provision of habitats for many special-concern, threatened and endangered species, along with greatly increased biodiversity. Further, ecological effects from beaver benefit most all other wildlife and plant species, including critical fisheries such as salmon and trout. All of these result from beavers’ CYCLIC work along streams and riparian corridors where the landscape is CHANGED from wetland, bog or stream to PONDED waters.**
*http://www.beaversww.org/assets/PDFs/AtlanticSalmonBeaverDam.pdf, http://www.martinezbeavers.org/wordpress/category/beavers-and-trout/
These cyclic changes do REQUIRE space to expand and contract unimpeded by human interference. The beneficial effects of beavers on biodiversity of plants, animals, and habitats is dependent on their ability to impound water and create highly beneficial openings in the forest canopy that ARE NOT DUPLICATED by human-created forest openings nor static types of wetlands. The resulting benefits to hydrology and biodiversity are essential to forest health and growth. The dynamic wetlands created by beavers retain and store upland waters, buffer drought, and reduce catastrophic or flash flooding damages, as well as helping to guard against and reduce the upsurgence or spread of forest fires!*
*http://www.beaversww.org/assets/PDFs/Moddrainagedesign.2001AIHmeet.pdf
I believe this new activity represents the recovery of beaver from depletion, not over-expansion, and that these admittedly challenging CHANGES are not only critical to our shared, hopefully recovering healthy ecology, but represent merely the beaver’s attempt to resume their natural role in ecology, NOT YET FULFILLED.
As responsible, attentive and visionary managers we must do a better job of educating about and mitigating these changes/developments with wiser planning and technologies to accommodate a recovering resource and recovering ecology that will benefit us all.
It would seem to me that there is a big gap between management justifications that proclaim not to cause endangered, threatened, or special concern species to develop as compared to the Department’s Mission Statement to PROMOTE, ENHANCE AND CONSERVE our wildlife resources and PROTECT habitats! This proposed rule threatens all of the above considerations for restoring the health of our natural systems and the organisms who rely on them.
I look forward to your acknowledgment and response.
Sincerely, Richard A. Hesslein Jr.
http://www.beaverbros-ecohumanesystems.com
ecosystemengineers