Response to the LRA consultation

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

Since 2014, Devon Badger Group has been helping to protect badgers in Devon with a small but very committed and active membership which is steadily growing. We have a 24/7 helpline and receive calls and emails from people all over Devon with concerns on a wide range of issues such as sett disturbance, injured badgers, development concerns and the badger cull.

We have spoken to a number of farmers and landowners since the culls began in Devon and have come to realise that many do not believe culling badgers is the answer. We have also been involved in badger vaccination projects providing support for and working alongside Somerset Badger Group.

We know, through our many public information stalls and talks, that there are real concerns among the wider public of the effect prolonged culling will have on the future of one of Devon’s most iconic native mammals.

Comment 6a: The principle of controlling the risk from badgers with TB in the LRA. Devon Badger Group opposes the principle of controlling the risk from badgers with TB in the LRA through badger culling for a number of reasons:

Your own consultation document admits that the risk from badgers with TB in the LRA is low: paragraph 1.1 ‘in the rare event that disease is present in badgers’[1]; 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 . It is therefore, unjustifiable to focus efforts on this when the greatest risk of transmission is from cattle to cattle.[2]
The Welsh ‘badger found dead survey,’ carried out between September 2014 and the end of October 2016 backs this up by confirming that out of 648 badgers tested only 6.6% cultured positive for M.Bovis[3].
To date no evidence has been produced to show that badger culling is reducing the prevalence of bTB in cattle in the HRA’s, there is also no evidence to support culling badgers in localised areas. In fact, the government’s own figures show that where badgers have been culled for the last 5 years the number of new breakdowns in West Somerset has slightly increased and in West Gloucestershire has remained the same.
There is, however, strong evidence to show that badger vaccination in conjunction with improved TB surveillance and cattle testing can result in a significant reduction in the prevalence of bTB in both cattle and badgers[4], as shown by the Welsh IAA where more than 5,500 badgers were vaccinated.
Devon Badger Group supports badger vaccination and believes it would be a far better method of controlling the spread of infection to the badger population from infected cattle[5] and would also reduce the risk of perturbation. Badger vaccination is also much more widely accepted by the public and is a significantly cheaper option.

The risk of infection being brought into a LRA from infected cattle is not being addressed despite it being cited as a significant contributing factor in TB outbreaks as stated in 2.8 of the consultation document: ‘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. The limitations of the measures set out in Annex A of your document2 show that there will continue to be a serious risk if more stringent measures are not introduced to restrict cattle movements from HRA such as Northern Ireland and Republic of Ireland. Failure to control these risk factors shows a lack of commitment and understanding of the strict cattle-based methods needed to reduce TB in cattle which were so effective in Wales, such as risk based trading and more widespread use of Interferon gamma (IFNγ) blood test which would provide a more accurate test than the tuberculin skin test alone.
The principle of a government-led badger control operation where required. The Devon Badger Group is opposed to badger culling by any method and is very concerned at the possibility of a government-led badger cull which, according to your consultation, would be able to act outside of the Badger Protection Act and would not need to prove that culling badgers prevented the spread of disease, which, surely is the sole purpose of the badger culls. This, we believe, shows that the government is not solely concerned with preventing the spread of disease and wish to continue culling badgers even if there is no evidence to show it is working. The Badger Protection Act was introduced to protect a much maligned and persecuted native species and even with the act, we are seeing an increase in illegal badger persecution, particularly since the badger culls began. We are extremely concerned that the Government are considering using powers under the Animal Health Act 1981 which allow ‘methods of destruction that would otherwise be unlawful’,[6] which we and the majority of the British public would be extremely worried and unhappy about, making badger culling even more unpopular than it currently is.
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. The speed at which the badger culls have been rolled out to other areas without sound, scientific evidence that they are significantly reducing TB in cattle shows that this is not a precautionary case-by-case approach. There is also little or no specific information on the criteria that would be applied to show this to be precautionary. The Devon Badger Group believes that badger vaccination, cattle movement restrictions and a better testing regime would be a much more precautionary approach and one which is more likely to produce significant benefits6.
The principle of using culling or vaccination or a combination of the two to control risks from badgers with TB in the LRA. No scientific evidence has been produced to show that culling in conjunction with vaccination or test, vaccinate and remove (TVR) is effective. In contrast, research has been carried which shows that, due to the risk of perturbation, it could have a detrimental effect.[7] The Devon Badger Group has already stated its support for badger vaccination as an alternative to culling and to cull vaccinated badgers removes any disease protection benefits that would be gained by local populations. The consultation document shows a lack of understanding of perturbation and appears to contradict itself. This is worrying as it shows the policy could be based on misunderstood and inaccurate assumptions. 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 However, 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
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. As there is no evidence to show that reducing the badger population reduces the risk of TB in cattle there is no justification in implementing a cull. Badgers are a protected species and, as such, any proposed population control needs to be backed up by rigorous supporting evidence and a lack of non-lethal alternatives.
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 stated above, there is no evidence that localised badger culling reduces the prevalence of bTB in cattle, however studies have shown and continue to show that it can have the opposite effect. We therefore, do not support the proposed revisions to the guidance to Natural England. We believe that badger culling should be suspended until an in-depth review of the scientific evidence has concluded and the results published. To continue with badger culling with further widespread rollout to extensive areas with no understanding of the effects is reckless, unjustifiable and risks local badger population extinctions.
Any additional comments or approaches which you feel are relevant but not captured by the questions above. The Devon Badger Group believes that the government have demonstrated a fundamental lack of understanding of the role badgers play in the transmission of TB in cattle and without a clear evaluation of all of the risk factors the measures laid out in this document are unlikely to realise any disease reducing benefits. In fact the level of disease in cattle could increase at the expense of thousands of badgers. To issue a consultation document on fundamentally flawed proposals shows a cynical and misleading view of this public consultation.

Response to the LRA consultation

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