Petition to the Wisconsin Department of Natural Resources to Protect Beaver Populations and Update Beaver Management Plans in Wisconsin

Beavers are aquatic mammals essential to the natal hydrology and landscape of Wisconsin. Unique as a keystone species and ecosystem engineer, they create wetland ponds that become complex habitats for biodiversity, and therefore play a key role in flood mitigation, supporting biodiversity, and maintaining these wetlands to support high water quality.

Other aquatic mammals, such as mink, muskrat, and river otters, along with waterfowl, amphibians, reptiles, insects, mammals, and plants thrive in beaver wetlands. Recent science also supports changes to policy that restore river systems to their natal characteristics with beaver wetlands for the higher water quality and habitat value they provide. These wetlands can have a strategic society value for flood reduction as a climate resilience solution. Through canals and damming of beaver ponds, beavers reconnect river complexes while providing green infrastructure of stormwater storage systems. 

With the increasing intensity of storms experienced across Wisconsin due to climate change, beaver wetland complexes will be essential to building Wisconsin’s resilience against these high-intensity storms. Not only do beavers support stormwater storage, but also beaver wetland complexes naturally recharge aquifers and support natural water filtration for clean, safe water.

Beaver management in Wisconsin runs contrary to scientific means and threatens the ecosystems beaver create, endangering threatened species, and increasing flooding risks to communities. The following provides an overview of the current management practices conducted by the Wisconsin Department of Natural Resources (WDNR) and their contracted groups. With the looming threat of climate change, the WDNR must urgently change their management approach to support climate resilience in Wisconsin communities.

Wisconsin’s current approach to the management of beavers is the following:

1. In 2021 alone, the WDNR contracted with the U.S. Wildlife Services to destroy 1,769 beaver dams in Wisconsin. In other words, they destroyed 1,769 potential wetlands which, in turn, destroyed or weakened the wildlife habitat of many endangered and threatened species. 

2. In addition, U.S. Wildlife Services has killed 22,489 beavers in Wisconsin over the past 10 years because of the contract they have with WDNR.

3. The WDNR policy damages fundamental hydrology structures that beaver dams provide to the stability of streams and watersheds. For example, in northern Wisconsin counties where Wildlife Services kill the most beavers, there was disastrous flooding in 2016 that caused billions of dollars in damage. The loss of these beavers to wetlands has significantly increased the flooding experienced in these areas.[1]

4. The WDNR refuses to change or modify game laws to allow for beaver population recovery. Under current law, trappers are granted unlimited take with any method of kill within the 5-month season, and the WDNR does not require any reporting or tagging system. The WDNR does not follow any of the guidelines or practices of acceptable wildlife management science with beaver.

5. Meanwhile, the WDNR has not completed a beaver population estimate since 2013. As a result, the WDNR has little reliable information about the status of the Wisconsin beaver population. 

6. The WDNR and U.S. Wildlife Services have extirpated beavers from over a thousand miles of streams in the Ojibwe-ceded territory, a clear violation of treaty rights. Under the Voigt decision (1983), Tribal nations are granted 50% of the wild resources on the public land in the ceded territory.[2]

7. Killing beavers eliminates important hydrological features of watersheds, such as wetlands, and damages critical wildlife habitat and forage needed by many birds, waterfowl, mammals, amphibians, reptiles, and plants. About 43% of threatened and endangered species use wetlands as habitat. The Wisconsin Wildlife Action Plan states that aquatic and wetland habitats are home to 282 Species of Greatest Conservation Need, with 109 in wetlands alone.[3] The reduction of beaver ponds significantly threatens the existence of these wetlands and the species that depend upon them. This is counterproductive to the goals of the U.S. Endangered Species Act.

8. Killing beavers and destroying their dams is counterproductive to the goals of the U.S. Clean Water Act. Beaver dams support biological integrity, a key component of the Clean Water Act, by maintaining wetland habitat.

9. From 2013-2021, the U.S. Wildlife Services killed 1,191 river otters as a byproduct of its relentless war on beavers. Otters are a species protected under the Convention on International Trade in Endangered Species of Wild Fauna and Flora and are regulated because of their ecological species importance. According to WDNR analysis, for every 21 beavers killed with body-gripping traps, one otter is also killed.

Superior Bio-Conservancy strongly recommends that the WDNR and U.S. Wildlife Services make the following changes: 

 1. The WDNR and U.S. Wildlife Services should turn the Wisconsin Beaver Management Plan (2015-2025) into a living document and update it using the best wildlife population management available, including technology, record keeping (tagging), and baseline data. The same should be done with the U.S. Wildlife Services’ 2013 environmental assessment of its beaver damage management program. These documents must be updated with the assistance of a committee of qualified professionals, including wildlife biologists, hydrologists, and others who have expertise in beaver management and science.

2. The WDNR and U.S. Wildlife Services must primarily use proven, non-lethal beaver management, such tree fencing, beaver deceivers, pond levelers, and culvert-protective fencing, which are more cost-effective than lethal control, while allowing beavers to provide essential ecological services while also reducing risk to other protected species such as river otters. These systems need to be installed by professionals who are trained in non-lethal installation.

3. The WDNR should establish a recovery zone for aquatic mammals for the Milwaukee River Watershed, which comprises 900 square miles and encompasses 1.2% of the state, to allow for the reintroduction and repopulation of beavers who are functionally extinct in that area. This would potentially lower peak flood levels by over 37% on average, provide over $3.346 billion in stormwater storage services, and remove over 500 homes from the floodplain in the Milwaukee area.[4]

4. As there is currently no population tracking system in place for beaver trapping, the WDNR must implement tracking based on up-to-date GIS and recordkeeping technology that would require trappers to record the number and locations of beavers killed, rather than allowing unrecorded, unregulated killing. 

5. The WDNR and U.S. Wildlife Services must acknowledge the Voigt decision (1983) by upholding the usufructuary rights of the Tribal community to maintain ecological resources on ceded territories. They must recognize Tribal rights to protect water quality standards and protect Tribal aquatic resources.

6. The WDNR must support the goals of the U.S. Clean Water Act by managing beavers within each watershed and subbasin to restore the biological integrity of our nation’s waters.

7. The WDNR must uphold its role as a public trustee of Wisconsin’s wildlife and navigable waters, by allowing beavers to support the hydrological functions and restore biological integrity to our waterways.

As custodian of our shared natural resources, the State has the responsibility to engage with up-to- date science as a guide for ecological management and the promotion of ecological services for the betterment of Wisconsin’s future. With an increased threat of climate change, increased flooding, and lost biodiversity across the globe, this is a critical issue that deserves immediate attention. 

Sincerely,

Superior Bio-Conservancy

[1] A 2018 report by the Northwest Regional Planning Commission – “Washed Away: Northwest Wisconsin Copes with the Costs of a Changing Climate. Local Communities Find Themselves Stuck in A Cycle of Rebuilding Infrastructure After Repeated Floods” – about the flood impacts in northwest Wisconsin details fatalities, road closures, and travel disruption experienced in seven counties following the major storm in July 2016. They chronicled the damage and stated with climate change these flooding events will continue.

[2] LAC Courte Oreilles Band of Lake Superior Chippewa Indians v. Voigt, 700 F.2d 341 (7th Cir. 1983).

[3] Available at p.widencdn.net/pd77jr/NH0938.

[4] For reference to the study: beaverinstitute.org/wp-content/uploads/2021/03/Beaver-Hydrology-impact-in-Milwaukee-final-1.pdf