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Bovine TB: consultation on proposals to introduce licensed badger control to prevent the spread of bovine tuberculosis in the Low Risk Area (England)

Somerset Badger Group is a not for profit organisation run by volunteers since 1989 raising funding through public donations to continue its work in conserving, protecting and promoting badgers along with other native wildlife, by education to, and support for, the wider public throughout Somerset including the Avon area.

We run a 24/7 helpline and email advice service dealing with thousands of contacts from the general public with concerns on a huge range of issues including illegally killed badgers, sett persecution and increasingly, concerns about the cull. We have been contacted by farmers and landowners and members of the public who have genuine concerns about the cull and how it will affect them.

Since 2012 the Somerset Badger Group with the help of public funding, has also been supporting farmers in Somerset, Devon, Gloucestershire and Wiltshire by vaccinating the badgers on their land for a minimal cost. We have also responded to the numerous consultations relating to the badger culls in order to raise our significant concerns about the badger control policy.

Comments required on:

a) The principle of controlling the risk from badgers with TB in the LRA. Somerset Badger Group is totally against the principle of controlling the risk from badgers with TB in the Low Risk Area (LRA) through badger culling for a number of key reasons:

 The risk of badger to cattle transmission in the High Risk Areas (HRAs) is known to be low with less than 6% of herds that have contracted bTB being attributable to badgers1. It is therefore likely to be significantly lower in the LRAs. Your own consultation document states at paragraph 1.1 ‘in the rare event that disease is present in badgers’2; at 2.1 ‘the presence of infected badgers in the LRA may be a rare occurrence’2 and at 2.6 ‘While the risk of disease spread between badgers and cattle is lower in the LRA’2 which suggests you recognise this fact. However the risk of cattle to cattle and cattle to badger transmission is significantly greater3 and we cannot therefore understand why you are focussing efforts on culling badgers in order to control badger to cattle transmission.

 In addition Results from the Welsh ‘badger found dead survey’ between September 2014 to the end of October 2016 confirmed that out of 648 badgers tested only 6.6% cultured positive for M.Bovis4.

 There is no empirical evidence that the culling of badgers is reducing the prevalence of bTB in cattle in the HRAs and there is certainly no empirical evidence to support culling badgers in localised areas. In two areas where badgers have been culled for the last 5 years there is however evidence to suggest that the number of new breakdowns in West Somerset has slightly increased and in West Gloucestershire has remained the same.

 Evidence from the Welsh IAA where more than 5,500 badgers were vaccinated demonstrates that badger vaccination when used in conjunction with improved TB surveillance and cattle testing, has contributed to a significant reduction in the prevalence of bTB5.

 As a group we strongly support badger vaccination which we believe would be a much more effective method of controlling infection of the badger population from infected cattle6 without the potential harmful effects of perturbation which has been proved to occur as a result of localised badger culling. In addition, unlike badger culling, badger vaccination is much more acceptable to the public and is also much cheaper.

 At 2.8 in the consultation document it states ‘Sporadic cases of bovine TB do occur in the LRA, mostly due to movements of TB infected cattle that escape detection through routine and pre-movement testing’2. Concerningly, the enhanced cattle TB surveillance and breakdown controls as stated in Annex A of your consultation document2, are not in our opinion, sufficiently robust. In order to adequately reduce cattle to cattle transmission we believe that:

i. imports of cattle from HRAs including from the Republic of Ireland and Northern Ireland should not be allowed;

ii. risk-based trading of cattle should be compulsory;

iii. the use of Interferon gamma (IFNγ) blood test should be increased and the phage blood test introduced as soon as possible to provide a more accurate test than the tuberculin skin test alone;

b) The principle of a government-led badger control operation where required. As we have already stated in our response we do not support any badger control operation which involves the culling of badgers whether it is industry-led or government-led. We are also extremely concerned that your consultation document suggests that a government-led badger control operation does not need to be licenced under the Badger Protection Act which requires evidence that the action taken is ‘preventing the spread of disease’. As we do not consider that culling badgers in the LRA will prevent the spread of disease this suggests that the Government want to be able to act outside this important piece of legislation because it does not believe that this badger control operation would comply with the Act. Instead it is happy to inappropriately kill what is a protected species. We are concerned that the Government is considering using powers under the Animal Health Act 1981 Section 21 ‘Destruction of wild life on infection other than rabies’ which allow

‘methods of destruction that would otherwise be unlawful’.7 This is something that we and the majority of the British public would be extremely concerned and unhappy about.

c) The principle of taking a precautionary case-by-case approach, dependent on the local conditions and situation, including as regards the number of years in which culling is carried out. We strongly disagree that this proposed approach is a precautionary approach. As we have already stated in our response, there is absolutely no empirical evidence that badger culling of any kind is reducing the prevalence of bTB in cattle. We have already confirmed that we support the use of badger vaccination and we believe that this would be a much more precautionary approach which is much more likely to have significant benefits6, is humane and much less costly for the taxpaying public. In addition, your consultation documents gives little or no specific information on any evidenced based criteria that would be applied for this approach in order for it to achieve a beneficial result in reducing bTB rather than a hugely detrimental one.

d) The principle of using culling or vaccination or a combination of the two to control risks from badgers with TB in the LRA. As we have already stated we fully support the principle of badger vaccination as an effective method of reducing the risk of bTB from cattle to badgers and therefore badgers to cattle. We do not support the principle of culling nor do we support a combination of both. There is no scientific evidence that the combination of both culling and vaccination or test, vaccinate and remove (TVR) is effective and in fact some research suggests that it is more likely to have a detrimental effect because culling causes perturbation.8 Additionally, there is a significant risk that the benefits of vaccination would be reduced as vaccinated badgers could be subsequently culled as they migrate into a culled area and culling would prevent the potential of protecting other badgers from bTB. The statements within the consultation document relating to perturbation are confusing and opposed to each other. At 2.7 it states ‘Rapid geographical spread of infection is likely to occur when social groups are disrupted or at lower densities. Much of the LRA has a lower density of badgers and rapid geographical spread is likely to be more of a risk.’2 Conversely at 3.3 it states ‘There is no evidence which points to widespread infection in the badger population across the LRA and therefore the risk of the perturbation effect is different from and much lower than that in the HRA and Edge Area’.2 This seems to suggest a complete lack of understanding of badger ecology and of the perturbation effect itself. Badgers are territorial and when a social group is no longer around to defend its territory, then other social groups of badgers will naturally extend their territories over time. The result is that healthy badgers will migrate into culled areas and are therefore at risk of being infected with bTB. It is of real concern to us that you appear to be proposing a strategy based on inaccurate assumptions.

e) In relation to cases where culling is deployed, the principle of lowering the badger population of the affected area sufficiently to reduce the risk of infection of cattle from badgers (whether through direct or indirect contact), and ideally substantially reduce or even eliminate it. There is absolutely no empirical evidence that localised badger culling is effective in reducing the prevalence of bTB in cattle whilst there are many studies that suggest the opposite. We therefore believe there is absolutely no justification for considering the principle of lowering the badger population to reduce the risk of infection of cattle from badgers.

f) On the proposed revisions to the Guidance to Natural England on licensed badger control. Draft revised Guidance can be found at Annex B. See the new section on Low Risk Area Badger Disease Control. The new section header and other revisions to the Guidance have been highlighted in yellow for ease of reference. As we have already stated there is absolutely no empirical evidence that localised badger culling is effective in reducing the prevalence of bTB in cattle whilst there are many studies that suggest the opposite. We believe it is fundamentally wrong to give guidance to Natural England to licence a badger control operation in the LRAs for which there is no scientific justification and which will not deliver the criteria of ‘preventing the spread of disease’ under the Badger Protection Act.

Any additional comments or approaches which you feel are relevant but not captured by the questions above. The economic benefits as stated under section 5 of your consultation document2 are based on the assumption that localised culling will ‘contain and eliminate TB hotspots’ and that culling in the HRAs will provide significant savings when there is no evidence that culling will achieve this. Since the culls began in 2013 the costs to the taxpayer have been estimated at over £50 Million. There is still no publicly available information on the true costs to the taxpayer of five years of culling. We believe that there is a lack of transparency and detail within the consultation document and we believe that it is misleading for individuals who are expected or who wish to comment. We are very concerned that this could be deliberate or at the very least, demonstrate a concerning lack of understanding about the role that both cattle and badgers play and about the efficacy of the proposed policy. We believe that all Government departments have a responsibility to be open and transparent and present the facts clearly.

1 Donnelly, C. A. & Nouvellet, P. The contribution of badgers to confirmed tuberculosis in cattle in high incidence areas in England. PLoS Currents Outbreaks, doi:doi: 10.1371/currents.outbreaks.097a904d3f3619db2fe78d24bc776098. (2013).


3 Woodroffe, R. et al. Culling and cattle controls influence tuberculosis risk for badgers. Proceedings of the National Academy of Sciences of the United States of America 103, 14713-14717 (2006).

4 APHA. APHA report of examination for Mycobacterium bovis in badgers found dead within the Welsh Government Intensive Action Area (IAA) (OG0145/TBOG0146). (, 2016).

5 APHA Report on Differences between bovine TB indicators in the IAA and the Comparison Area: First six years, 1st May 2010 to 30th April 2016.

6 Carter, S. P. et al. BCG vaccination reduces risk of tuberculosis infection in vaccinated badgers and unvaccinated badger cubs. PLOS One 7, e49833, doi:10.1371/journal.pone.0049833 (2012).

7 Animal Health Act 1981 Section 21 Destruction of wild life on infection other than rabies.

8 Bielby, J., Donnelly, C. A., Pope, L. C., Burke, T. & Woodroffe, R. Badger responses to small-scale culling may compromise targeted control of bovine tuberculosis. Proceedings of the National Academy of Sciences of the United States of America 111, 9193-9198, doi:10.1073/pnas.1401503111 (2014).