"The Consultation Paper on Culling Badgers in Response to Bovine TB"
....The New Forest Badger Group reply

Compiled by Adrian Butterworth, Martin Noble, Manuel Hinge and Simon Daniels
 

Question 1
In the light of the evidence presented as part of this consultation, on balance, do you think a policy to cull badgers should be part of the approach to help control the disease in cattle in high incidence areas?

Response 1
The historically stable and Iow level of bTB in England was a result of routine testing and consequent removal of bTB reactor cattle and was achieved without the need to cull badgers. Since the decision was taken to restrict testing largely as a result of BSE and Foot and Mouth Disease, coupled with a massive increase in cattle movements (14 million in Britain every year), the evidence reveals an increase in the spread of bTB. The conclusions to be drawn indicate a considerable spread of bTB in some parts of the UK but the vector for that spread has yet to be identified.

To quote from Krebs....
“it is not however possible to state quantitively what contribution badgers make to cattle infection”.

The veterinary advice contained on page 27 of the-consultation paper reads....
“The uncertainty about the specific contribution badgers make to bTB in cattle means that it is difficult to estimate with certainty the full impact culling will have (and this is likely to vary between different parts of England)".

The consultation paper provides no compelling evidence of cross-infection of bTB between domestic cattle and badgers and furthermore, research has shown that almost 90% of Badgers are free of bTB. The solution of reducing the prevalence of bTB in cattle appears therefore to lie with the cattle husbandry rather than with the badgers and the proposed pre-movement testing although limited in its scope is to be applauded as a positive step in bringing the bTB situation under control. It is clear from the research so far carried out that cattle to cattle transmission of bTB is by far the biggest cause of its spread.

While it is accepted that badgers (and many other animals, including humans) may be carriers of bTB, we believe it is essential that the potential of all other sources of disease spread should be eliminated as far as possible before resorting to a widespread cull of badgers. Furthermore the expert opinion of the Independent Scientific Group (ISG) draws clear conclusions, stated in their letter dated January 20th 2006. Those views are that specific alternatives, namely to cull within localised areas, would be more likely to exacerbate the spread of disease rather than reduce it.

The alternative of blanket culling over a very large area, possibly over two or more counties, may well constitute a breach of the Bern Convention, which the UK ratified in 1982 and implemented in domestic law under the Wildlife and Countryside Act of 1981, i.e. going beyond what is permitted for regulated management of a protected species. Such a widespread cull would be likely to exacerbate the spread of disease or disrupt the family groups of these social animals. It is our opinion that badgers should only be killed when to do so would be an act of mercy to prevent further suffering to a severely diseased or injured animal.
 
In conclusion, the principles embraced by the consultation paper are based on insufficient evidence and the proposals are fundamentally flawed. The paper should be withdrawn. We oppose any form of culling for the reasons stated.

Question 2
Comments are invited on the options considered and the costs and assumptions made in the Partial Regulatory Impact Assessment.

Response 2
Defra’s own figures indicate that while culling of badgers may reduce the incidence of bTB in the immediate area of the cull, it causes a commensurate increase in the area outside this. The implications of this are that unless the area of cull is both huge (at least several contiguous counties) and perhaps more importantly, carried out intensively by all landowners within the area it will not work. Additionally a cull on this scale would be totally unacceptable to the general public (who through their taxes are likely to be part funding it) and to the conservation organisations, most of which believe that there are better alternatives.

Question 3
Under what circumstances should the Government grant licences to cull badgers for the purpose of preventing the spread of bTB under the Protection of Badgers Act 1992?

Response 3
The criteria for culling badgers should be based on the welfare of the badgers themselves. Badgers should only be killed when to do so would be an act of mercy to prevent further suffering to a severely diseased or injured animal.

To grant farmers individual licences to kill badgers might give the farmers some satisfaction in that they may feel that they are doing something to help the situation. However as indicated above, at the same time they would be likely to spread the problem onto adjoining land as the culling disturbance causes the badgers to move away.

Question 4
What qualifying geographic criteria would be appropriate, achievable and reasonably likely to be an effective disease control measure?

Response 4
The ISG’s conclusions indicate that any such area would need to be very large and at the same time would be at a scale, which would be completely unacceptable to the general public and conservation organisations. More seriously still it is a possible breach of the Bern Convention and other European Environmental Initiatives, which could bring the UK Government into conflict, not only with other signatories to the Convention but also with the European Union, which has consistently advanced funding to the UK for agricultural biodiversity and wildlife enhancement. It would seem politically unwise in the current atmosphere to invite yet more calls for the repayment of monies advanced to HM Treasury by our European partners.

Additionally we have severe doubts as to whether individual farmers would be capable of working collectively on a sufficient scale as to achieve the necessary coverage. We are aware that there are some farmers within bTB areas who are opposed to the principle of badger culling and there would be others who feel it is not their job to have to have to carry out a cull or who may be unequipped to carry out such an activity. Additionally Defra’s own experience during the Randomised Culling Trial showed how difficult it is even with full-time, trained staff, to carry out a complete cull over much smaller areas.

Our belief is that all that would be achieved would be a mass slaughter of badgers to appease some farmers that would enrage the rest of the tax-paying population and still not achieve a significant reduction in the incidence of bTB.

Question 5
How could farmers ensure sufficient coverage to deliver a sustained cull over a large area?

Response 5
We don’t believe that this would be possible. We feel it is unlikely that a sufficiently high number of farmers would be prepared to undertake the additional work required to achieve such a cull as to make it a success. Additionally the whole premise of a cull appears to omit the factor of the resilience of well-established wildlife populations to culling. Compare the attempts currently being made in a similar manner to reduce deer populations in the UK, where high culls in certain areas carried out by dedicated stalkers over a long period of time are merely offset by a compensatory increase in deer numbers in adjoining areas where culling is less intensive or non existent. Overall there is little change in deer density and this with an animal whose meat is edible and can be sold to offset some of the costs of the cull.

Moreover, according to the evidence currently available, the downstream effect of a cull on social behaviour would be to force migration of individuals. As a result, all property owners, not just farmers, would be compelled to undertake a cull on their land, irrespective of the cost to themselves, otherwise a pool or reserve of animals within the controlled area would result. The issues regarding the Bern Convention and the European wildlife and environmental initiatives again are very relevant in this respect.

The single burning issue for many, whose income streams are already disrupted by sector depressions, would be, why should they have to pick up the bill and the political fallout for the Government's dirty work?

Question 6
What qualifying disease history would be appropriate?

Response 6
While we have sympathy for those farmers whose cattle contract bTB, in the context of this consultation we are not qualified to judge what effect the disease may have on cattle. We believe that it would be acceptable to euthanase any individual badgers found to be suffering from bTB but not to cull any which do not exhibit those symptoms. There is evidence from the culling work so far carried out that only a very small proportion of badgers killed were carrying bTB. This suggests that even within family groups, only certain individuals may contract the disease and thus there is absolutely no justification in culling entire groups or meta-populations.

Question 7
What could be included in the criteria to define those farmers eligible for a licence to cull badgers.

Response 7
As stated in response 5, we have grave reservations as to the reliability of farmers with badgers on their property to carry out a cull to any previously stated standards. Culling of verifiably infected badgers should be carried out by trained individuals from within the Defra ranks.

Question 8
Would it be practicable for primary herd owners to recruit neighbours and adjoining landowners to achieves, say, 75% coverage within 1Km of the boundaries of their holding? If not, what might be achievable and reasonable?

Response 8
As stated in responses 5, we do not believe that the responsibility for culling badgers should be placed in the hands of farmers or any landowners and we would doubt their ability to carry out the task to the required degree of efficiency.

Question 9
Over what size of area could self co-ordinated groups of farmers and landowners be expected to manage a cull consistently and efficiently for up to five years, with a high degree of coverage?

Response 9
As stated in response 5, we do not believe that the responsibility for culling badgers should be placed in the hands of farmers. Farmers are often fiercely independent people and their track record of actually working together to achieve a common goal is generally not good.

Question 10
Are there other methods of culling which should be considered?

Response 10
In our view there is only one method of culling which should be considered. That is live cage trapping followed up by the shooting of any affected animals. Any animal not exhibiting visible, external signs of bTB should be released immediately. Culling would only be acceptable in badgers found to be exhibiting external signs of bTB. Any such trapping should only be carried out by trained Defra staff. Testing of animals found freshly dead e.g. road casualties could be carried out at a clinical level.

Question 11
Is gassing appropriate for use under licence by groups of farmers, land owners and their agents?

Response 11
Gassing has been shown to be both inefficient in that it is virtually impossible to get lethal doses of gas into all parts of the sett; inhumane in that some badgers will receive a sub-lethal but damaging dose which may cause permanent injury and unselective in that other animals may be killed during the gassing process. As stated earlier, gassing should not be considered as an option for culling badgers.

Question 12
Would there be a need for training of licensees? If so, what form should this take?

Response 12
In the experience of senior Forestry Commission staff with whom we are closely associated, many staff refuse to use lethal gas because of the potential risk to their own health. In addition there is the question of identifying an occupied badger sett. Our experience indicates that holes will be gassed just in case there may be a badger in them and non-target protected species such as polecats, reptiles etc. will be killed unnecessarily and illegally. As stated earlier, gassing should not be considered as an option for culling badgers.

Question 13
How could this training be best provided?

Response 13
Expert evidence clearly indicates that gassing is an inhumane, unselective and inefficient method of culling badgers and should not be considered as an option. There is also a perceived risk to the health of the operatives even when all correct safety procedures are followed

Question 14
Would permitting the shooting of free-running badgers (under licence) be practical and acceptable.

Response 14
Shooting free-running badgers would only be acceptable in the unlikely event that an animal was identified as suffering from visible signs of bTB. As stated earlier the option of cage trapping and then shooting visibly affected animals is most appropriate. Experience with night-shooting of other, larger species such as deer indicates that there would be considerable difficulties with shooting badgers. There is a high risk of causing a non-fatal injury to the animal and any follow-up required would be difficult if not impossible in the dark. The safety aspect to the public cannot be over-emphasized and there have been a number of recent well-publicized cases of fatalities and serious injuries caused to persons in the countryside during the night-shooting of foxes and rabbits.

Question 15
What features should be included in the design and use of the body snare? Are there particular features which should be avoided or included?

Response 15
Snaring of any kind is unselective and inhumane. No civilised country should permit the use of snares on live animals. There are no snares that will humanely hold a badger without the likelihood of it suffering serious pain and injury before it is finally despatched. Given Parliament's clear intention to bestow an unusual level of protection upon badgers as a wildlife species, such inhumane execution of a licence would be most inappropriate.

We are surprised that Defra is even considering such an option in view of the weight of evidence against it. Snaring in any form should not be considered as an option for culling badgers.

Question 16
What inspection intervals for checking snares would meet welfare considerations and be practical?

Response 16
Irrelevant as snaring in any form should not be considered as an option for culling badgers.

Question 17
What skills and competencies for culling are required to ensure that body snares are safely and effectively deployed?

Response 17
Irrelevant as snaring in any form should not be considered as an option for culling badgers.

Question 18
Is there a need for training for farmers or licensees? If so, what form should this take?

Response 18
Irrelevant as snaring in any form should not be considered as an option for culling badgers.

Question 19
How could this training be best provided?

Response 19
Irrelevant as snaring in any form should not be considered as an option for culling badgers.

Question 20
What methods of disposal would be suitable to minimise the risk of disease transmission, assist in monitoring a cull of badgers and be practical?

Response 20
The only safe method of carcase disposal would be incineration. There is already a procedure in place for dealing with the incineration of infected livestock and wildlife and this could be implemented for badgers. There would be some benefit in this being done via the state veterinary service, which in turn would give their staff the opportunity to examine the carcases more closely for any signs of disease.

Question 21
Do the proposals for monitoring the impact on wildlife (para 93-95) look at the right issues? If not, what else do you think should be monitored?

Response 21
Our proposal that only badgers known to be infected with bTB should be culled will have a minimal and probably undetectable effect on badger population levels. However there may be some benefits in monitoring population levels for other reasons. In this case the well-tried method of recording emergence from setts, if carried out properly, is probably the most effective method of counting badgers and potentially the least disturbing for the animals. Such monitoring, however, requires care and skill, both as regards the process of gathering the evidence and its analysis, in default of which scientific conclusions would be rendered unsafe and unusable. The proposal of using nocturnal spotlight surveys is misguided. Such a technique will cause serious disturbance to the badgers’ activity patterns that in turn will disrupt the ability of the operators to assess badger numbers with any degree of accuracy. This has already been tried and abandoned as a means of assessing nocturnal deer numbers by the Forestry Commission in England, in favour of thermal imaging cameras.

New Forest Badger group
6 March 2006