STOP PRESS

 

In March Rishi Sunak seemed intent on killing all the badgers by give sweeping powers and a very free hand to the Chief Veterinary Officer to cull up to 100% of badgers in areas she deemed appropriate. Now he has now called a General Election for July 4th , which means that Parliament will be prorogued tomorrow, 24 May, and dissolved on 30th May. The public will vote 25 working days later. Government actions are limited during the election campaign ‘pre-election period’  that was previously known as ‘purdah’. The shut-down helps to ensure that public money is not used to support campaigning by the political  party in power, and to maintain the impartiality of the civil service.

This could be good news for bovine TB control  and badgers if the outcome is that the government  does not let the National Farmers Union dominate and dictate its actions, as it has for so long.

30th May is also the date by which DEFRA must respond the Pre-Action Protocol (PAP) letter issued on 16th May that was supported and funded by The Badger Crowd.  We should soon learn what Defra intends to do in response. What are their options? And what will the government that takes over in six weeks’ time be likely to do?

Defra could accept that the consultation was botched and shut it down by doing nothing. The PAP letter gives them the option to withdraw the proposals or to reconsult, which would now be after the election. This is likely to mean that it  would now receive a new political steer.  The PAP letter also asks that no future proposals are decided before a legal challenge is  disposed  of – i.e. dismissed or heard in a court trial.

Defra could accept that the consultation  was rushed out too hastily without proper consideration, just in case of an early general election and so needs a total rethink. Alternatively, they could try to rush a formal response through next week, so that the principle of  ‘targeted culling’  is established before a change of government. They could either keep Natural England licensing or continue to re-badge the NE Bristol licensing office as one of  Defra’s own. However, this now looks like a very tall order in the limited time available.

What will the Lib Dems do? Like Labour they will be looking to take back and win over seats in the southwest, in areas where livestock farming dominates the landscape. Not making badger culling a big election issue looks likely to remain important to both political parties, and both are likely to remain tight-lipped. Labour has previously pledged to scrap badger culling, and are the party most likely to hold power next.

Whoever wins the election will be responsible for the bigger challenge of putting in place the appropriate cattle-based measures that will drive down the disease that is embedded in chronic cattle herds. This will have to involve tough restrictions that will cause the beef and dairy to contract. This is something the NFU have resisted and put off, while at the same time holding out a hand for compensation. It’s no easy choice for whoever wins the election. Scrapping badger culling should be easy decision, but what will really count is making the necessary changes to  testing using the expertise pioneered by  Dick Sibley in Devon. That might mean scrapping the ineffective BTB Partnership and setting up something that understands the science of the problem, and how to address the problems without reverting to the lay-beliefs of many rural cattle  vets, based upon dogma and misinformation from government.

The winning government might also instigate a rapid review of bovine TB control needs early on. Whatever happens next, the actions of Badger Crowd have again been highly effective. Legal letters sent to Defra on 19th and 28th March demanded an extra 3 weeks of consultation time, which gave the legal team time to submit the PAP challenging the legality of the consultation. All of the three legal challenges supported by Badger Crowd since 2017 have been accepted for trial by the High Court, and it would be great if a fourth substantive hearing is now not needed. This would allow time and resources to be better spent, redeployed  protecting badgers and dealing with bovine disease in meaningful ways.

Yet again we can dare to  find optimism for the future. Let’s hope that it won’t be dashed as it has been so often over the last ten years. The science is clear that badger culling does not work and plays no role in reducing infections in cattle herds. It has to stop. It must stop.

Tom Langton who has figure headed the legal challenges since 2017 said:

“This looks very much more than the beginning of the end. We have fought hard for seven years to highlight the legal and scientific case against badger culling, with breakthroughs more recently, and exposure of actions that are not in the public interest. Of great concern has been the ‘tribal’ behaviour of civil servants and wilful blindness that shows hallmarks of both the blood transfusion and post office scandals. Yet ‘badger blame’ has been ongoing for 50 years now. Thanks to better understanding of the issues involved, we can now start to see the mistakes and misjudgements of the past. The new government will need to focus on how to lower the rates of transmission of bovine TB, much as was done with Covid-19 in humans. This will bring tough times for the beef and dairy  industry, but it has to be done to interrupt the dependency on public subsidy, stop the wide range of collateral damage to rural life and the environment that it has caused in recent decades, and finally see progress in eliminating this horrible infection”.

Thanks, and good wishes to all who have supported the Badger Crowd fight against badger culling.

WE ARE THE BADGER CROWD. WE STAND UP FOR BADGERS.

GOVERNMENT BADGER CULL CONSULTATION – NEW LEGAL ACTION UNDERWAY

A pre-action protocol letter regarding proposals to evolve the badger control policy was sent to Defra on Thursday 16th May following closure of their extended consultation period on plans to continue badger culling using a so-called ‘targeted’ approach.

Badger Crowd has had sight of the letter sent by lawyers to Defra that challenges aspects of the consultation that ran 14th March – 13 May 2024, as unfair.  A large number of problems are identified including:

  • Misleading and inadequate information regarding badger culling efficacy
  • Failure to provide information on ecological impacts of the policy
  • No meaningful information on economic impacts of the policy

The action is being taken by conservation ecologist Tom Langton who since 2017 has been given permission for and completed three previous judicial reviews (JR’s) supported by Badger Trusts and Groups, wildlife charities and caring individuals. These JR’s have exposed details of the badger culls that have been vital for public understanding of the rationale behind and operational decisions surrounding badger culling, although only preventing culling in a few nature reserve areas to-date. As a professional scientist and with others, he has published since 2019, details of badger culling efficacy and bovine TB trends in England. One of these publications in particular, Langton, Jones and McGill, March 2022 in Veterinary Record, is directly refuted by two government scientists in the recent consultation, but yet again without any supporting evidence. The Government agency APHA have published a paper in front of the new consultation that is weak; it lacks any comparison between culled and unculled areas and states that there is no way to tell whether badger culling is having an effect on measured levels of disease. Despite this, wording in the abstract of the same paper, both as a preprint and as published, has led the Secretary of State and the Defra Minister to make unsubstantiated claims before (since 2022) and within the consultation, saying that APHA data shows badger culling works. This is a very basic misreading of the available published and peer-reviewed science.

Tom Langton said:

“It is with deep disappointment that Defra forces us back towards the courts to seek redress on the ‘badger control policy’, because the current consultation has created a confusion that surrounds safe and informed consideration of the best course of action for bovine TB control in cattle. Defra has not learnt from mistakes of the past and wants to u-turn the 2020 policy that aimed to phase-out badger culling. It wants to award sweeping powers to the Chief Vet to decide when and where to cull, and how many more dead badgers to add to the 230,000 mostly healthy adults and cubs already killed since 2013. This they achieve by simple misinterpretation of science and by implementing further countrywide operations that are veiled in secrecy.

Much of the confusion and misinformation in the consultation obscured public consideration of critically important matters such as rationale, ecological impacts, economic benefit and animal welfare considerations, to a point where it was simply not fit for purpose. Many of the consultations 19 questions and comment opportunities were likewise cloaked in ambiguity, to the point where response was dependent on assumptions and interpretations, so wide as to make collective and comparative analysis of them meaningless. The consultation options were narrow and miscast, appearing to be aimed at quickly pushing though a single, pre-planned approach to keep on killing badgers. This was a construction by a Ministry desperate to use public funds to support a demand that Defra has itself fostered, by blaming badgers as a key part of bovine TB epidemiology for decades, but based on flimsy evidence. The muddled thinking and bad policy needs to stop right now.

On behalf of badgers, cows and farmers I implore Defra to recognise that this consultation was flawed and should be set aside in favour of more detailed and coherent review of current needs, with new planning towards approaches that can be successful.”

The challenge asks Defra to withdraw its proposals or to reconsult in an adequate way. Meanwhile the request to Defra is that they confirm no decision will be made on consultation responses before the challenge and complaints are fully heard and concluded.

The Defra Badger Cull consultation on the ‘targeted badger intervention’ policy – where are the swerves?

The Defra consultation on more badger culling ends on Monday 13th May 2024, at midnight. Since it was launched on 14th March there has been increasing incredulity over how sketchy and confused it is. It is a classic example of how not to consult with the public over an extremely important decision on how to tackle a complex disease epidemic.

The problems are largely of Defra’s own making, with the scientific aspects of the issue particularly poorly handled. Questionable management of the bTB policy is exemplified by the ‘BTB Partnership’. This was was set up under the 2020 ‘Next Steps’ policy, after the Derbyshire badger cull licence was put on hold for a year in 2019 by Boris Johnson who fought off the NFU and announced a  move to phase out badger culling.

The BTB Partnership was set up as a group of largely cherry-picked farmers and vets, most of them it would seem wedded to badger culling, and ‘hired and fired’ by Defra who also control the agenda, with secrecy over its work, reporting and outputs. There is a blog about the shambolic Partnership here. Not surprisingly, it recommends more badger culling and tries to row back on actions that might inconvenience the beef and dairy industries, thus preventing the industry contraction that must inevitably come, but that could have been so much smaller, if done earlier.

The main problem with the consultation is that it blurts out its intention without actually consulting. It’s a bit like asking what colour your new car should be, and do you need a sunroof? But the bigger questions have already been fixed; make, model, engine size, fuel type, all decided for you. You are being asked questions about the trimmings.

So, the consultation is not at an early stage, not at a stage where the various options are reviewed and described, with a sound build up to a presentation of the top range of possible alternatives and asking you about which path to take. Instead, Bang!, this is what you get. And it is being handled in a  similar way to previous bTB consultations  only this time it is much, much worse. It looks sloppily written and rushed. Rumour has it the NFU wanted to get it in place before the general election, although it is not actually needed in 2024. The problem for Defra is that views, or perhaps expectations on the government consultation process have been changing, and this kind of approach is no longer acceptable. Witness last October the judgement in Northern Ireland that found the badger culling proposals unacceptable. Why wasn’t the lesson heeded you have to ask?

Looking specifically at factual issues, the ‘elephant in the room’ is the discovery over the last ten years that all but a few of  (SICCT) test reactors are infected. With few false positives this makes any narrative that the herd status OTFW (officially bTB Free Withdrawn) is the yardstick for eradication (or better expressed, elimination), very old thinking.

This has some unfortunate consequences, not least for the now challenged RBCT (Randomised Badger Culling Trial) which actually found no effect of badger culling when all reactors (OTFS (Officially bTB Free Suspended) and OTFW are taken into account. This should have led to Defra reviewing their approach, but ‘stick to plan’ is the order from somewhere – the farming industry? It doesn’t make sense. And it isn’t mentioned at all in the consultation. Neither is the increased frustration and louder and louder complaints by vets and test developers that the current policy is unviable and useless. Not fit for purpode. It follows the failed trend of the Republic of Ireland who have culled badgers for over 20 years. The consultation seeks endorsement without adequately, or in many cases at all, explaining its rationale and alternatives.

Further, the consultation is not adequate in explaining the progress and new development of badger vaccination and cattle vaccination. With badger vaccination, DEFRA now pull back, saying its efficacy is unknown, much as the Godfray Review did in 2018. There is no enthusiasm for it from the farmers either. They have been told since 2022 that badger culling works and a new generation of advocates for culling have developed, bringing sentiments of badger hatred to new highs on social media.

How has this happened? Well by a series of announcements, interviews and parliamentary statements by Secretaries of State and Ministers since 2022, based upon a combination of staff at Defra and its agencies telling people that badger culling works. This continued until just before the start of the consultation on the back of unpublished data, uncheckable analyses and inference trying to transmute association to causation. Same old.

The new Secretary of State in Defra’s revolving doors of sackings and appointments is Steve Barclay. No one in cabinet wants to do the Defra job. You have to deal with climate change, flooding, sewage and farm waste in rivers and on beaches and wangle ways around protecting nature as a flurry of screamingly bad diseases flourish with industrial farming.  So Barclay sets out the consultation, claiming a figure of 56% decline in herd breakdowns after four years of culling, based on the ‘before and after’ APHA paper (Birch et al published Feb 28 this year), with absolutely none of the controls of a scientific study checking causation. There is no comparison of culled areas with unculled areas. There is a blog about the problems of Birch et al. preprint here.

Using words from a rather flaky abstract, designed to please, Barclay mis-quotes and misrepresents what the paper actually says, no doubt incorrectly briefed by the hapless APHA who are desperate to find a way out of the 2020 policy car-crash and not to call the last decade out as one huge mistake. Barclay follows other politicians, Eustice, Coffey, Spencer, Douglas Miller who have groomed the farming industry to believe what they want to hear i.e. that but for the badgers the cows would be clear of bovine TB. What is irrefutable is that the influence of badger culling on bovine TB in cattle herds is unclear.

Defra seem to have gone out of their way to bias consultee’s opinion in front of their consultation. Some observers thought it had been put on hold, with the hope of a new Parliament sorting out the mess in a years’ time. The consultation fails to distinguish between the scientific opinions of a handful of Defra staff who have spent the last decade blaming badgers, and what the published science actually says and means. Not to do so is not just worrying, it is unfair and unlawful.

Why did they drop a weak bit of analysis (Birch et al. 2024 ) just in front of the consultation and weaponise it to try to force a return to mass culling? Results from Cumbria, south of Penrith, showed that cluster culling was a sham in Area 32, and cattle measures had resolved bTB in all but chronic herds before the first of the 1115 mostly healthy badgers were shot, from 2018.The independent report “A Bovine Tuberculosis Policy Conundrum in 2023” demonstrates this clearly, and the follow-up addendum produced in April 2024 confirms it.

The failure of their ‘epi-cull’ or ‘cluster-cull’ trial is too uncomfortable for them and doesn’t fit with their ‘keep to plan’ strategy, so they pretend it hasn’t happened? Then they delay the economic evaluation until later because it looks like everything done to date has been done at a financial loss, but can be fudged in four years’ time?

The confusion and lack of technical reporting on cattle vaccination, and the need for enhanced testing according to the learning from Gatcombe farm in Devon has not been mentioned at all – no options provided. Airbrushed out.

The consultation normalises the least humane option for shooting badgers without going through the difficult considerations behind that decision. This is extraordinary, given the shift to free shooting over cage shooting for cull companies that have had praise heaped upon them with offers to make their killing easier..

The executive powers that would be passed to the Chief Vet and the appointed BTB Partnership for day-to-day decisions looks like an unrepresentative, unaccountable closed shop. Methods for identifying where badgers would be culled are unformed and justified using the unsuccessful Low Risk Area model (see here and here) and the unproven intensive culling results (see here, here and here). Why was the consultation not held back until these problems had been addressed? Answer, because the trials have failed. Why does this consultation even exist if this key point is not absolutely clear for all to consider? As APHA said in 2023, there are now more questions than answers.

This consultation is an abomination. Following the failed DEARA consultation in 2023 it is unprofessional and embarrassing. We should know who is responsible for it. It is so far away from the interests of the public and industry that it must be stopped.  

Responses to consultation questions: some thoughts:

Q7. Should there be an annual cap on the number of clusters that can be licensed to undertake badger culling? 

If you answer Yes, you may be accepting that the policy is fine as long as it is limited to x number of culls per year. Don’t be misled by this trick question. It does not offer the alternative of knowing that no targeted culling should be done.

Q8. What other factors should be taken into consideration in defining a cluster under the targeted badger intervention policy?

If you suggest new factors, this may imply that you agree with the other factors suggested. 

Q10. & Q11. To what extent do you agree or disagree there should be a separation of Natural England’s statutory conservation advice from licensing decisions?

These are tricky. At face value it might suggest that you are being asked if NE need no longer fulfil its statutory nature conservation role. But that is very unlikely to happen without a change in law. What it might be asking is whether you think NE should stop licensing culls in order to distance its  advice on badger culling ecological impacts from the authorisation of killing badgers, which would be a very good thing. However the question is very general and vague. Perhaps the question supposes culling should continue (which it should not), so does agreeing to it endorse the act of culling? NE should never have taken on the role of licensing culling, it was the worst decision in its history and has seen rampant killings of around 230,000 badgers since 2013. The next question, 11, deals with whether cull licensing should go to Defra, (to join with vaccination permissions), to which the answer should be no because culling should stop.  So Natural England  who are just told to get on with it without question should stop and it shouldn’t go to Defra? It would seem sensible not answer these ones on the grounds of confusion.  Defra would love to keep licensing with NE as it gives culling the respectability of endorsement by a conservation body. Be careful how you answer this one because the question isn’t clear. It could trick people into supporting keeping badger culling responsibility with NE. It is not clear if you can use question 12 to explain your views if you have not answered questions 10 and 11 however. What a muddle.

Q12. Please give reasons for your answers to this section (optional)

Here you could make the point that Question 10 is faulty. The question does not reflect the text of the consultation adequately.  Natural England, in preparing impact assessments free of charge for cull companies and being instructed by Defra to issue licences, has lost its supposed  independent role. NE has taken direction from and rubber-stamped Defra and the CVO’s instructions to issue licences, and for the NE Chief Scientist to describe culls as successful whether or not minimum cull targets are met.  And on an uncorroborated assumption that Defra’s badger culling policy has an disease benefit, which it has consistently failed to show.

Q13. Do you have any comments on the Information for Applicants at Annex B for carrying out the culling part of a targeted badger intervention policy? (optional)

This information is inappropriate given the unfair nature of the consultation.

Q15. Should animal level bTB risk information be published on ibTB?   

Yes

Q16. Please give reasons for your answer (optional).

Any information on disease risk should be publicly available.

Q17. To what extent do you agree or disagree it would be helpful to share information on where herd owners source their stock from?

  1. Strongly agree

Q18. Please give reasons for your answer (optional).

Any information on disease risk should be publicly available.

Q19. Do you have any other comments? (optional)

Here is your chance to offer your full view.

This consultation is an utter shambles and should be withdrawn. It is thrown together, unfair and misleads on multiple counts. It avoids providing essential background facts and leads those answering questions into endorsing ill-described proposals. This consultation will be challenged and measures are already in place for that to happen.

WE ARE THE BADGER CROWD

 

 

 

 

 

Cracks appear at DEFRA

Badger Cull Consultation extended by 3 weeks to 13 May

At around 5.00pm yesterday (19th April) Badger Crowd was sent Defra’s ‘stakeholder’ message that the badger cull consultation has been extended by 3 weeks. Due to end on Monday 22nd April, it will now finish on 13th May. One legal letter was sent to Defra on 19th March and then two on the 28th March this year, stating specifically that the 5 week consultation period was too short and that an 8 week period would be appropriate.  Defra consultations are often eight weeks long.

Although a three week time extension has been granted, the three week delay in responding to the letter and agreeing it means this still does not provide an adequate response time. Defra just doesn’t get it. 

One of the letters also pointed out the misinformation and lack of detail on aspects of the consultation document. Two long letters were also received from Defra yesterday (19th) and are now under the legal microscope.

Legal pressure from our friends at Badger Trust and Wild Justice, together with their ‘survey monkey’ poll of respondents, illustrates problems with interpretation of the consultation. Extra time will give Defra more time to reflect on how muddled their consultation truly is.

Other voluntary groups are still considering what advice to provide to individuals wanting to write to Defra about the consultation, and we will report further on this as it is made available.  It is still difficult to advise on the best way to complete the consultation, because of the lack of information provided, its limited scope, the misleading content including wrong use of science and the wording of the questions which does not allow adequately for views to be expressed.

Defra’s consultation is a mess and they know we know it’s a mess. They know it’s a big mess. Thanks again to the 700 of you who have joined the Badger Crowd and are supporting the fight for justice for badgers.

We are the Badger Crowd.  We stand up for Badgers.

*** URGENT *** IMPORTANT ***

Badger Cull Consultation Advice

There is now just a little over a week left to comment on the Defra consultation on what it wants to do next to badgers in the name of bovine TB control in cattle. As you probably know, the consultation is inaccurate and very badly justified.  Consultation responses must be in before the end of Monday 22nd April. You can find the 40 page consultation document  here.

You can respond to the consultation from Defra’s link at the bottom of the consultation page. However, the questions are loaded in favour of a U-turn to allow endless widespread badger culling, contrary to the promises of the Defra policy direction in March 2020. If you do not want to follow this limited survey, you can send your own a personal comments on the consultation to bTBengage@defra.gov.uk

If you do this, be sure to read the consultation carefully and make your views known.

What are other organisations saying?

Protect the Wild as an organization are calling the whole thing a sham and not fit for a response for a range of reasons that you might like to read:

  • See here
  • They have a petition here signed by over 8,000 people in just a few days.          

Legal eagles Wild Justice are doing a poll of views on certain aspects to follow up legal letters to Defra. They are running a questionnaire about the Defra consultation. This needs to be responded to TODAY 15th APRIL. You have to answer a few initial questions, then read the consultation and finish the questionnaire – it takes about 20 minutes.

Legal letters sent to Defra by Badger Crowd and Badger Trust & Wild Justice have not been responded to promptly, and responses are likely to be made one working day before the consultation closes. This is all part of a ploy to railroad one of the biggest decisions in the history of badgers in five weeks only. Based on loaded language and cause-arguing designed to mislead. The way this is being handled is disgraceful and a new low point for Defra. It is hoped that they will withdraw the consultation this week, as common sense dictates. We cannot rely on this however.

Don’t forget to ask any organisations that you support what they are doing about the consultation. A joint statement by the main NGOs is anticipated in the days to come. This is late in  the day, but the complexities of the misinformation and short consultation period  are all part of normalising a cruel, illogical, unscientific and needless shooting of badgers.

Defra Badger Cull Consultation

What does it say and mean?

On 14th March, Defra launched a new consultation:

“Bovine TB: Consultation on proposals to evolve badger control policy and introduce additional cattle measures”

A five week consultation period ends on 22 April, so here is a digest of what is proposed. It’s is a bit long, but important if you care about truth, bovine TB control in cattle, badgers, cruelty and the squandering of public finances.

SUMMARY

This consultation is badly worded in places and the detail is hard to comprehend. It appears unrealistic in terms of scale and implementation. The questions asked in this consultation are minimal and generally loaded towards the respondent agreeing with the described process to keep on killing healthy badgers into the future.

The consultation is founded on the incorrect interpretation of a new study Birch et al. 2024, which itself is in need of revision. The robustness of the new study is open to question, and aspects of it are now being queried with the Minister and the authors.

Defra are back-tracking on the March 2020 ‘Next Steps’ policy in favour of continued forms of supplementary and low risk area culling in existing and new areas, as directed by the Defra Chief Veterinary Officer. The methods for selecting ‘cluster areas’ for badger culling is not prescribed and effectively leaves a free hand for culling at the CVO’s discretion aided by industry advisors.

All previous Defra badger cull consultations have resulted in implementation of the policies as set out in the consultation, whatever the responses have been. Defra have made it clear that they will consider ‘group’ objections differently to personal objections.

We feel this consultation is unlawful and should be withdrawn and as such cannot recommend anyone responding until further advice has been received.

Consultation Foreword by Steve Barclay Secretary of State for Defra.

It is hard to know if the mistakes in new Minister Barclay’s foreword are unintended. It was probably written for him by Defra staff, perhaps the Chief Vet, who as we know struggles with science papers. On the back of the brand new APHA research he says “I want to be clear. A major element of this success has been the industry-led cull of badgers.  The latest evidence from the first 52 cull areas shows that rates of bovine TB breakdowns in cattle are down on average by 56% after four years of culling. This analysis has been published in a scientific journal after rigorous peer review. “

Leaving aside whether the peer review was rigorous and independent or not, Barclay, the Secretary of State for EFRA is attributing the decline in detected cattle herd breakdown incidence to four years of badger culling, as has the Defra Minster Douglas-Miller. This is now being repeated widely in farming circles. But the science Barclay refers to does not support this, even if it implies it in the abstract. There is a bit of speculation about it in the discussion, that is all.

Call this lies or misinterpretation, there really is no such clarity from ‘the latest evidence’. Even Cambridge’s Defra-funded James Wood had to correct the over-simplified abstract of the new APHA paper (Birch et al) for a piece in last weeks  Veterinary Record. The misleading abstract should be a simple retrospective corrective edit for the journal, along the lines of other government funded bTB science. We will see.

On this point Defra boss Douglas Miller had been making  the ‘56% benefit’ claims  for months, based on a preprint that was corrected when published. To be really, really clear, what the peer reviewed published science says is that it is not possible to directly attribute the fall in cattle herd bTB breakdowns to badger culling. It could all be due to cattle testing or other factors. Recent alternative published peer-reviewed analyses strongly suggest that this is the case (Langton et al). The courts could be interested in the misrepresentation of science by the Minister.

Also not mentioned in the consultation is the fact that the statistical code for the Birch paper (instructions on how it was analysed) is not included in the supplementary information published with the paper, so it can’t be checked. Requests to the author for this code and to the Minister have not yet been successful. Defra have received a legal letter asking for it promptly but it had not arrived by the noon deadline on 20th March. There are several things about the analysis that look a bit odd and which deserve further scrutiny, so supply of information to be able to re-run the analysis is critical to an ‘intelligent and informed response’ to the 14th March consultation.

PART A – BACKGROUND

This gives the usual statistics of change in bTB levels around the issue. There are comments about an ‘adaptive policy’, ‘banking the benefits’ and ‘striking a balance’, but none of these claims are scientifically evidenced and are mostly seem to be throw-away blah from Defra staff and the shambolic BTB Partnership.

PART B – PROPOSAL 1

The report text then switches from its assertive attitude in the Ministers statement to be a bit more careful. It says: “5.2. The policy of badger culling, which has been in place since 2013, is highly likely to have contributed to this significant reduction in the disease.” Not sure any more then? Still wrong – should have said ‘could be’. Paragraph 5.3 implies the reduction of bTB breakdown incidence is due to badger culling, which is an incorrect assumption and not borne out by the Birch study, as was also made clear by Oxford’s Prof David McDonald’s analysis earlier this year. A more detailed look at Birch et al.(2023) pre-print is available here and here.

Defra then repeat their outburst from two years ago, rejecting independent peer reviewed science in a top Vet journal, that suggested badger culling brings no response to bTB control, as follows:

“We acknowledge that this analysis has been challenged by certain groups opposed to culling who analysed the publicly available data from cull areas up to 2020 11. These groups concluded that culling had no effect on bTB in cattle. This peer-reviewed analysis was published in the Veterinary Record journal in March 2022. The Defra Chief Scientific Adviser (CSA) and UK Chief Veterinary Officer (UK CVO) assessed this paper and found the analysis to be flawed. The UK CVO and CSA response (and a later correction) was published in the Veterinary Record12,13 although the authors reject the criticisms of the UK CVO and CSA 14.“

An outburst that APHA have still, after 24 months, failed to demonstrate scientifically – despite holding all the data, in secret. It would be possible for APHA to simply compare farms in culled and unculled areas in multiple ways to test for the efficacy of culling. Why have they not done this? Is it because they do not get the result that they are desperately seeking to support the policy? The signs are that internally, APHA  actually know they are wrong. One senior insider has said privately in response to the consultation “the momentum created by Godfray is being stifled as DEFRA considers that the solution is too difficult and too expensive….. convincing themselves that the cull has worked to avoid the embarrassment of their mistakes.”

What are the future badger killing consultation proposals in general?

  • Construct a narrative that ‘badgers are a part of the local disease problem’ using circumstantial evidence from dead badger surveys.
  • Remove the all-important ‘exceptional use’ requirement of the March 2020 Next Steps policy, so badger culling can expand across the whole of England (HRA/EDGE/LRA), as before.
  • Change the term ‘cull area‘ to ‘cluster area’. Talk about ‘targeted badger intervention’ when all that has happened is cull areas have been renamed.
  • Rename ‘cull company’ as ‘licence holder’ who will appoint gunmen for both cage shooting and cruel free shooting, and it appears, badger vaccinators (Para 5.30).
  • Allow unlimited cluster areas to be licensed for culling each year (Para 5.18). Licenses to last for one year at a time.
  • Keep the 100% culls in the Low Risk Area using the ‘’Hotspot’ approach, which remains more or less the same, and a model for ‘clusters’. Death by APHA terminology.
  • The public will continue to pay for the licensing operation and monitoring, as well as the cost of policing culls, and support with costs incurred by industry when carrying out badger vaccination (Para 5.35).
  • Defra infer that the objective of a targeted badger intervention policy would be to secure disease control benefits by reducing the potential for infectious contacts between badgers and cattle in cluster areas ”before eradicating infection in cattle herds within the affected cluster” (Para 5.7).  This has not previously been suggested, i.e. badger culling is a prerequisite for cattle measures to be able work. This is not borne out by scientific literature and evidence. As such it is speculative and an attempt to mislead consultees regarding disease epidemiology.

How will cluster/cull areas be chosen?

  • APHA say cattle movement data and use of ‘whole genome sequencing’ of dead cattle and badger samples will inform the process. But it is unclear how, and sight of the method is lacking. There is no mention of the detailed independent report from 2023. that found the process failed and unfit for purpose. How cluster areas are chosen  can be changed at any time it seems, a free reign for government.
  • “Breakdowns that could be caused by high-risk cattle movements will then be removed, to increase the accuracy of identifying areas where badgers are a part of the problem in the spread of disease to cattle.“ This does not make sense, why would the source matter if cattle have gone on to infect badgers. This does not even follow the twisted APHA logic.
  • Cull supremo Christine Middlemiss, the UK CVO, will oversee deciding which clusters should be eligible for badgers to die. She might use ‘epidemiologists and veterinary science experts’ from the Bovine Tuberculosis Partnership – the closed cabal of mostly farmers and cull operatives that helped to refine these ideas. That works in secret and seems largely unaccountable.
  • Defra apparently have a magic bullet up their sleeve: “We are developing a surveillance and monitoring system which, when fully implemented, would allow for an assessment of the level of risk that local badgers may pose in a cluster.” We need to see and understand this pipe dream to be able to consider it.
  • The culling season will be relaxed from a fixed duration of around 10 weeks to the free-for-all allowed in Supplementary and Low Risk Area culling, to enable maximum culling of badgers. It seems to faciliate 100% culling if you want it, through to the end of January of the following year.

Badger vaccination – the new bolt-on

  • The failed BTB Partnership has apparently indicated that badgers should not be vaccinated before being culled in the HRA or Edge (Para 5.17) and the LRA (Para 5.21) because it would take too much effort.
  • After culling for two years or more, any surviving/recolonizing badgers may be vaccinated, and this is a condition of culling. Although government may fund vaccination, it appears farmers do not want to vaccinate badgers.

Note, in Cumbria it looks as if badger numbers bounce back within very few years, as they have in Gloucestershire, so the number of badgers needing vaccination is going to be massive. Especially as loads of areas that still have bTB embedded have been coming out of supplementary culling and are now due for badger vaccination according to the APHA vision. Or are government going to wait for badger numbers there to build up and cull large numbers again later? Or launch a military-scale exercise to get them vaccinated? Has anyone really thought this through? Thousands of people, tens of thousands of cages and vaccines. Or will it be a token effort to cover for just more culling?

This consultation, if taken at its word, could be a mandate for massive amounts of badger vaccination starting this year with no culling. But no, the unproven ‘shoot then vaccinate in new areas’ idea is pushed hardest, no doubt to win the anti-badger audience:

  • “The licence holder would also need to demonstrate, that it is able to vaccinate badgers in the year immediately after culling is stopped and for (typically 4) years as advised by the UK CVO (para 5.32). They must establish, with government support, cage trappers and lay vaccinators, organising training or securing a contractor to undertake badger vaccination. “

Other changes:

Defra will take over licensing from Natural England (Paras 5.14 and 5.27), but NE will still be responsible for saying that ecological impacts are barely significant and will be waving culling through without properly monitoring its impacts on designated sites. While claiming that it does. Tony Juniper’s cull-championing charade looks set to continue. Tim Hill who claimed badger culls to be a success each year is leaving this summer though.

Un-culled areas can have farm biosecurity measures and badger vaccination if they wish. APHA think “The available evidence suggests that the factors affecting the transmission of M. bovis between badgers and cattle are highly context-specific and dependent on many interacting factors at a local level.” There is no scientific evidence base or consensus for this claim – unless it is hidden from view..

Nothing changes:

Any decision by the Secretary of State on introducing licensed badger control under a targeted badger intervention licence will be informed by the scientific evidence and veterinary advice available, experience from the licensed badger control operations to date and responses to this consultation.” (Paras 5.24).
How will this be done and made available for scrutiny?

Previous economic assessments of wildlife control policies indicated that badger culling largely represents positive value for money.” (Para 5.22).
This is simply not properly evidenced, with unexplained lumped figures, and the public are almost certainly being misinformed. Defra have no idea about the effect of measures on the true burden of disease in cattle, embedded and undetected.

PROPOSAL 2: Licence and associated conditions for badger culling under a targeted badger intervention policy 

The size of future cluster areas is unclear but may be similar to existing cull areas – over 100 sq km. Within cull areas, Defra “will make decisions on the level of accessible land on a case-by case basis, taking into account such specific circumstances such as topography, land use and badger sett surveys or any other matter that is considered relevant” (Para 5.33).
The CVO has recently claimed (on Farming Today) that cluster culling is not the 100% culling approach of LRA culling (the proposed epi-culling model). But it looks like it. As cluster areas get bigger, the aim will be to kill 100% of badgers over available land which may be more restricted than was the case in the Cumbia and Lincolnshire cull areas. The system is not as well described as the 2018 low risk area culling methodology. It looks fairly similar, but in areas where permission to cull and vaccinate will be harder to obtain. There is no binding agreement for a minimum 6 years cull, and vaccinate it is all on trust. The bad idea is badly planned.

Strange?

Paragraph 5.36 states: “.. if a cluster overlaps with an area that has completed intensive or supplementary badger control within the last three calendar years, there would be no funding requirement.” This presumably means no need of disclosure of available funds to cull. “If the interval is longer than this, the licence holder will need to demonstrate that it has access to funds which are sufficient to carry out culling operations in eligible clusters for at least two years,”  This might imply that there will be an overarching licence holder for more than one cluster. It’s all a bit unclear. Why would a supplementary culling area not go straight to vaccination only, or is the aim just an extension of supplementary culling? Why not go straight to vaccination? The text is hard to unravel and looks ill-prepared.

“Culling in response to bTB outbreaks in the Low-Risk Area of England would continue to be permitted on the same terms as introduced in 2018, on an individual licence basis”. But LRA culling is the model for epi-culling which was not warranted and has failed. Just recently a new breakdown in the area.

Methods for the HRA /Edge seem to imply it will not be LRA-style culling (with a buffer area etc) but more like a hybrid with supplementary culling, according to cluster area size. Will cluster areas cull to hard boundaries or not? Thus, the consultation presents a lack of clarity and ambiguity to a degree that makes meaningful response impossible.

PROPOSALS 3 and 4

These relate to cattle purchasing and cattle movement monitoring and are not considered here.

Annex A: Wildlife disease control – Progress since 2020

Defra states (Para 1.10.) “We proposed to pilot the vaccination in areas as part of a phased approach. APHA has recruited two cohorts of full-time vaccinators in 2022 and 2023, who have been undertaking badger vaccination in several areas across the country, including in five former cull areas. These areas vary in size from 15 to over 350 km2, with more than 1,500 badgers vaccinated in England by APHA in total in 2023.”

There is absolutely no chance of vaccinating badgers in more than a very few cluster areas for multiple reasons, so this consultation is misguided not only in its scientific evidence base, but also regarding the feasibility of vaccination ever happening other than at the existing token scale. A phased approach that will fizzle out.

Information on  the pilot exercise in Cumbria is sketchy, and it is not possible for the public to understand exactly what is being done: the recovery rate of badgers, how many vaccinated badgers have been shot and how many vaccinated twice, or how many badgers have bTB of different strains. The consultation is describing an unevidenced process that is more hope than reality, that it cannot afford and will not seek to properly implement, for which there is no evidence that it will have any effect at all, and breaking multiple scientific and ethical veterinary and good practice guidelines. It is representative of a failed policy.



Veterinary Record exposes yet more government bovine TB failings

The respected journal Veterinary Record included two short News and Reports articles on government bovine TB news last Friday 15th March, just a day after their consultation to ‘evolve badger cull policy’ was announced.

The first covered a story we have written about in our blog (here) regarding the downsizing of the government bTB partnership. Member Dick Sibley was effectively sacked from the partnership, and VR comments:

“Sibley said he had been sacked after challenging Defra on the effectiveness of its testing and eradication programme, particularly the south west of England where he is based. He said the downsizing of the partnership would result in a decrease in challenge and debate.”

Another member who was removed from the partnership commented “They don’t want the partnership to come up with its own ideas, they want Defra’s ideas to be rubber-stamped by the partnership.”

The short article ends with the usual Defra quote about what a serious disease bovine TB is and what a difficult and intractable animal health challenge. It concludes “…… we are now able to move on to the next phase, including wider badger vaccination, alongside improved cattle testing, and work towards deployment of a cattle vaccine.”  There is no mention of badger culling in the statement by Defra’s spokesman. This is despite the fact that is was  published a day after the consultation was launched, a consultation in which Defra’s outlines its intention to continue an adapted, unrestricted, and less controlled form of intensive culling. They fail to mention it at all.

The second article “APHA study looks at the effect of badger culling on bTB”, is a short report on the newly published paper by APHA staff member Colin Birch and colleagues. The claims of the paper are reported, but notably, James Wood was quoted as saying “the badger control programme has been associated with increased use of more stringent cattle controls, including the use of gamma interferon assay in infected herds and promotion of biosecurity, which means that the attribution of the full effect to a single intervention is not possible.”

In fact that should be, the attribution of any effect to a single intervention is not possible. The reality is that Birch et al 2024 on which the consultation rests heavily, fails to prove any benefit attribution to badger culling at all. The Defra Minister Lord Douglas-Miller and Secretary of State Steve Barclay have, as a result of APHA’s failings, misled the public. They need to withdraw the consultation immediately.

New badger cull U-turn signals the end of the Badger Protection Act in England

Defra have today announced a 5-week consultation on chilling plans to kill 100% of badgers (also known as epi-culling) in bovine TB affected areas. Rowing back on the pledge for its use only in rare exceptions, this is effectively an increase on the cull limits imposed since culling started in 2013. It is set to be implemented this year in both previously culled and new areas, although not in areas culled in 2024 and 2025 because most of the badgers are already dead there.

The new culling method is based on a ‘model’ trial in Cumbria where over 1100 badgers were shot dead between 2018 and 2022, but where a published report states no demonstrable benefit was achieved in terms of reduced TB breakdowns in cattle herds.

The new policy is partly concealed by a move to encourage the vaccination of recovering badger numbers after culling (for which farm take up is likely to be resisted). The new prolonged killing spree, under what looks like a highly simplified license system, could see the badger tally rise from around 250,000 shot to-date, towards 300,00 by 2030 and half a million by 2038. This would be a cull of largely healthy adult badgers and their cubs, cruelly slaughtered using crude methods opposed by the British Veterinary Association, and for no good reason.

This is a government U-turn on the current policy implemented in 2020 under Boris Johnson. Johnson indicated any future culling of badgers would  be in ‘exceptional’ circumstances only. But the new draft policy has already established ‘cluster groups’ across many central English ‘Edge’ counties where ‘free-for-all’ culls may be allowed locally starting this autumn. Culling will return to previous ‘intensive’ cull areas, where it has currently failed to have an effect.

It is not clear how quickly the new approach will be rolled out or whether a new incoming government would stop it. The Labour party has previously pledged to bring an end to badger culling. Will this change following the NFU’s hope and plea at its conference that the issue will not become an election ‘wedge issue’?

The government claim that badger culling has enabled a drop of 56% since 2013 is repeated in the new consultation, but is based upon a misreading of the recently published Birch et al, who acknowledge that the overall result cannot be attributed either to badger culling or cattle measures; the different measures were analysed together and it is as likely to be cattle measures as badger culling. They then headline that the effect was caused by badger culling alone, something that top Oxford academic David Macdonald has stated in a January 2024 Badger Trust report is absolutely not the case. So why have they lied?

The APHA have stated more than once, that breakdown data by themselves cannot be used to evaluate the effect of badger culling. Christine Middlemiss on Farming Today in 2022 said that it was ‘very difficult’ to  compare culled and unculled area so as to isolate the effect of badger culling on bovine TB. Birch et al (2024) do not claim to have done this and they have not, but their scientific paper has confused wording and this has badly mislead the Defra Minister Douglas-Miller. The only peer-reviewed analysis since 2017 that compared culled and unculled areas found no difference in cattle disease between the two (Langton et al.).

It would seem that DEFRA are unable to interpret the science their own staff have published. They are also refusing to hand over the code that they used to analyse the data.

So what does this all mean? It means the end of the Protection of Badgers Act. There are no restrictions on the number of cull areas and no one will know where they are. Slack controls and confusion will confuse enforcement bodies and the public. This proposed policy is a disaster and must be stopped.

The DEFRA Bovine TB Partnership: Shambles or Scandal?

Dick Sibley removed from the Governments BTB Partnership

According to TB HuB, (1) The Bovine TB Partnership comprises members with extensive experience and expertise in the farming industry, private veterinary profession, non-government organisations, academia, local authorities, and government.” It is managed by Defra and has ‘Member organisations’ including the Animal and Plant Health Agency, National Farmers Union, the British Cattle Veterinary Association, the British Veterinary Association and Natural England.

In recent weeks vet Dick Sibley and others have left the partnership (2), frustrated at lack of progress, and suggesting that anything not central to DEFRA’s agenda is not welcome.

The  terms of reference for the partnership in 2021 (3) suggest that it was established in response to Professor Charles Godfray’s 2018 review of the bTB Strategy: the Government was committed to co-design with industry and other stakeholders ‘a new bTB Partnershipto encourage shared ownership, coordination and decision-making’ and  a driving force for further progress with disease eradication, absorbing the advisory function currently performed by the bTB Eradication Advisory Group for England (TBEAG) to become a senior-level and high impact government and stakeholder group for bTB control.’

Dick Sibley is well known as arguably the foremost English ‘coalface’  veterinary worker on bovine tuberculosis management, in Devon and beyond. He qualified as a vet from Bristol University Veterinary School in 1977 and has been in veterinary practice ever since, and he runs West Ridge Veterinary Practice based in Witheridge, in Mid Devon.

His X/Twitter biography describes him as “Veterinary surgeon working with cattle and other farm animals, hoping to make their lives better & healthier so that they can make our lives better & healthier”.

Dick is dedicated to the care of cattle, with particular expertise in the management of infectious diseases such as BVD, Johne’s and Tuberculosis, as well as delivering whole herd health plans for large dairies to predict and prevent disease and health issues. His credential speak for themselves. He has an Honorary Fellowship, awarded for his work with BSE (bovine spongiform encephalopathy), Foot and Mouth disease and Tuberculosis, he is National Secretary and President of the British Cattle Veterinary Association. He has a range of awards; RABDF Princess Anne Dairy Award, the RASE Bledisloe Cup, Honorary Life Membership BCVA, and Dairy Industry Award 2006 for veterinary services to the cattle industry.

Until recently, he was a member of the government’s ‘Bovine Tuberculosis Partnership’. Towards the end of February 2024 however, it was reported in the farming press that Dick Sibley, and another member had been removed from the partnership, and a third quietly resigned. Although it was originally envisaged in 2021 that the partnership would produce useful summaries of their work and make them publicly available, no insight into the thinking of the group has been forthcoming. It has been a closed shop. For the public and interested parties, there has been no insight at all, a huge disappointment considering its role and potential pivotal importance. In short, the BTB partnership has been a failure. There are even gagging clauses on partnership members speaking publicly without approval.

Shortly after he left the Bovine TB Partnership Dick Sibley started posting on X about his experiences and his posts offer interesting insight both into the problems faced and workings of the so called partnership. By way of introduction to his long social media thread, Sibley pointed out:

The 3 counties of Cornwall, Devon and Dorset have 7,989 cattle herds and generate 33% of new herd incidents of bovine TB in England.  At the end of September 2023. these 3 counties had 652 herds not officially TB free. (Down from 1011 in 2018, but up from 627 in 2021). I repeatedly mentioned this to the partnership. And got sacked. I guess if you dont like the message, shoot the messenger.”

So, does Dick Sibley think that the current bTB policy is working well? He says:

To get the country OTF by 2038 as pledged by DEFRA, I understand we need to get 99.9% of herds tb free for 6 years. In the 3 counties with current herds, thats just 8 herds still non OTF by 2032. I dont think that is possible doing what we are currently doing.”

The answer then, is no, he does not think Defra will achieve OTF (officially tb-free) status by 2038. The reason behind this is that the current testing system largely based on SICCT and gamma testing obviously leaves many infected animals in the herd that could only be found with a wider suite of tests, with local management of each unique farm circumstance needed to finish the job.  For that reason, the current system is doomed to failure as amply demonstrated in painful slow-motion across the Republic of Ireland over decades. Testing needs to be constant and not confined to the current routine. Additional/supporting PCR/qPCR tests in particular.  Use of Actiphage for pre-movement herd testing is the single essential action that would curtail disease spread rapidly, even if triggering a new national herd management strategy for diseased herds.

Why would Defra not want to look too closely at embedded infection? Perhaps too many reactors means too much compensation (too much money) seems the most likely explanation. It appears financially uneconomic, and more politically expedient to sit on?.

Does Sibley think that the bTB partnership of which he has been a member is a helpful and functioning working group, producing & collating useful and relevant science? He says:

.. for the past 3 years I have sat dutifully listening to unrealistic ideas on how we are going to replace badger culling with vaccination, BCG the cows and keep testing and killing. Short, truncated discussions on the pros and cons. Thats not a partnership, its an audience.”

Again, it looks like the answer is no. It sounds as if there was little engagement with the specialist expertise invited to attend. What does Sibley say about whether he believes badgers are an important source of cattle infection? He says:

We have tried really hard here in the South West: started culling badgers in 2016 and peaked in 2018: 90% of the area of the 3 counties culling by 2021. More testing, more gamma, more killing, more restrictions and yet 892 herds lost their OTF status last year. Is that success? Of those 892 new herd incidents, most of them werent new. They were recurrences of established infections. We used to blame the badgers, but we have now killed most of them. So, as many of us suspected, they are more likely due to undetected residual infections within the herd.”

So, Dick Sibley is concluding that repeat infections are most likely due to undetected cattle infections. Sibley has usefully drawn attention to one of the more irrational of Defra’s many rules and restrictions; you can only test cattle for bTB if they are OTF. He says:

Trouble is that the permission to test can only be given to herds that are not OTF! As soon as they go clear with a couple of clear skin tests, we cant use any additional testing. Not even an extra skin test between the six-monthly routines. Endemic infection resurfaces. Nuts.”

There is a more in Sibley threads: how Michael Gove became engaged in the issue, how that led to the Godfray Review (of the bTB policy), how DEFRA’s responded to set up the TB Partnership. But the partnership does not get a good account from Sibley:

We listened, no decisions. Three quarters of the time taken up with presentations, then truncated discussions through lack of time. The rooms got smaller and smaller and tech more dysfunctional. Covid didnt help. Frustrating”.

Frustration seems perhaps to be the overriding outcome of the partnership. Sibley writes frankly:

I asked for targets, objectives, Key Performance Indicators. What was success? Could we have some radical thinking? Ok, maybe I was a bit mouthy. We were told about current policy and plans: phasing out of culling, phasing in of vaccination. But what about the big gap between the two? How could this work?

Task and finish groups did some great work: I co-chaired one on improving testing sensitivity. Brave of them to ask me! Our good group put in hours of constructive discussion and research to produce a detailed report. Radical but realistic. Where is it now? Wasted.

That report even led to a full day workshop held at the APHA site at Weybridge. I really thought that this would do some good and make a difference. A good day of real discussion and proper time spent on difficult issues. Nothing came of it.”

Dick Sibley goes on to cite an interesting case study:

A small organic herd of red Devon beef sucklers: set up about 10 years ago. Before stocking the 200 acres of rolling Devon grassland, constructs 7km of badger and deer proof fencing. 2” mesh buried 40cm into the ground and going to 6ft+. Even Steve McQueen couldnt get out.

The herd went down with Tb in 2019, 3 years after being established in its colditz. I got involved in 2021 and started enhanced testing to see what was going on. We SICCt every 60 days in accordance with rules, and then privately gamma, Idexx and phage 3 or 4 times yearly.

Of the 101 cattle that we have tested in the last 3 years, 42 have left the herd as reactors (either SICCT or gamma) and 40 have been designated high risk due to a positive result on another test type. 7 more were gamma positive last week. There is significant age clustering.

We have got 4 day old calves testing positive for antibody! They didnt make that themselves, they got it from the colostrum. But mothers tested negative. The offspring of some test negative cows (but designated high risk) have all gone as reactors. We suspect mother – calf”.

So despite cattle being reliably isolated from potential wildlife infection, the embedded cattle infection persists.

Sibley’s thread finishes with:

“For those hunting the tb solution, be patient and manage your expectations. There is no simple solution. And for those campaigning for [badger] culling, just take a quick look at iTB map. My patch is the squares with 61 and 59 in. That’s after 5 years of [badger] culling. Disappointing.”

For those with more than an interest, it is worth reading SIbley’s thread in its entirety. If nothing else, it may be the only window into the workings of the bTB partnership that those not actually in it will ever get. DEFRA and APHA’s secret world of policy failure. Not so much a partnership as a captive audience of those who need Defra’s support in many ways and will not contradict them for personal and organisations reasons. Gagged to the outside world. It really stinks.

What does the BTB Partnership actually achieve – let’s take a quick look, according to its published role:

The Partnership has a number of responsibilities:

1. Contribute to setting strategic direction of the bovine TB disease eradication programme, helping to identify priorities, and address specific opportunities, risks and issues, as an integral part of the bovine TB Programme’s governance

Does it do this?  Apparently not very well. It looks slow to investigate advice that does not fit with its past and future plans.

2. Help set standards, monitor progress, and identify where new approaches might be needed

Does it do this? Apparently not very well. DEFRA/APHA seem reluctant to move outside the constraints of its own thinking and to recognise past limitations, oversights, failures and new direction.

3. Co-design potential new policies and communications

Does it do this? Apparently not – most members are there as an audience to offer approval but not to come up with any substantial changes.

4. Identify new evidence sources/requirements and ideas and captures wider views to inform discussion as needed

Does it do this? Absolutely not. Resists new evidence and fails to engage in external communications.

5. Engage widely to advocate agreed bovine TB policy to a range of stakeholders

Does it do this? Not much. Occasional conference for conference goers. NGO’s are outside the tent. There is little or no reporting – the shortfall is huge.

6. Encourage the formation of and work closely with local groups and creates opportunities for stakeholders/local groups to work together. Regularly reviews how to improve local engagement and maximise the value of local groups

Does it do this? No, the reversion to local groups tacking disease locally has been sidelined, despite its obvious potential.

7. Engage with developments in wider domestic agriculture policy (aware of and linked to sector wide initiatives that impact bovine TB control) – helping to build understanding of the potential implications for future disease control and helping to influence the design of future policy to benefit the goals of the bovine TB Strategy

Does it do this? Apparently not at all.

Chairman James Cross, a farmer, might be asked:

  • Where are the results of the specific ‘task and-finish’ groups?
  • Where is the ‘new evidence sources/requirements and ideas and captured wider views to inform discussion’?
  • How have you engaged ‘widely to advocate agreed bTB policy to a range of stakeholders?’
  • How have you worked ‘closely with local groups and created opportunities for stakeholders/local groups to work together’?
  • Where are the ‘Regular reviews on how to improve local engagement and maximise the value of local groups’?

References

  1. TB Hub, The home of UK TB information
  2. Defra’s bovine TB partnership loses members, Josh Loeb, Vet Record, March 5 2024.
  3. Bovine TB partnership terms of reference

BTB decline – has cause & effect been shown?

Cattle testing, and not badger culling, is helping control bovine TB in England

Published, peer-reviewed science on the efficacy of badger culling has failed to find an association between intensive badger culling and either the incidence or prevalence of bovine TB in cattle herds (here). In plain English, data on levels of bTB show that badger culling has had no effect on the level of disease in cattle. This is the only published peer-reviewed science on post-2017 data from the ton of bTB statisitics produced by farmers and vets across England over many years. Ask yourself why that is, and also why the government claims it has worked but refuse to discuss it.

The pro-cull response to anyone publicly questioning badger culling efficacy has been (not surprisingly) to follow government rhetoric, and claim that it has caused a 56% reduction of bTB in cattle to-date. Such comments are repeated by those associated with the secretive bTB Partnership of farmers and cattle vets:  ‘just look at this graph showing bTB falling over the period of the culls’. The phoney mantra that accompanies various homemade graphs is often an emphatic and self-confident ’look how well badger culling is working’, or ‘you can’t possibly argue with this huge decline in disease’, and ‘bTB is lower than it’s been for years’.

These summaries of the last 11 years of bTB control are simply unsubstantiated however. They repeatedly overlook the scientific necessity to show the relationship between cause and effect. Something that the Zuckerman, Dunnet and Krebs reviews also failed to establish using basic science principles. Put simply, cause and effect is the relationship between two things, when one thing makes something else happen. Ie. Can it really be claimed that it is badger culling that has brought about the decline in disease?

For the answer to that to be yes, it would be necessary to show that levels of disease were affected only by badger culling and nothing else. Levels of disease are clearly affected by a number of variables other than badger culling. As bTB is primarily a cattle disease, with most (if not all) infection arising from other cattle, the type & frequency of cattle testing will have a huge effect on detectable disease.

So has cattle testing on farms within the badger cull zones changed? Yes it has. Testing has tightened hugely, albeit painfully slowly, as can be seen in the graphic below. It has increased in frequency, and additional testing methods have been introduced too.

In reality, data point to increased and improved cattle testing being the cause of gradual bTB decline in cattle. The graph below illustrates that the decline in bTB across the south west counties of the High Risk Area (HRA) began on average around 2015, 5 years after annual cattle testing began, but before the roll-out of badger culling (coloured arrows indicate point at which badger culling began). It was earlier in other HRA counties. Cattle testing was having an effect well before badger culling could have.

Here (below) is a fresh set of HRA data from abattoir surveillance, detecting disease from previously undetected but infected herds. It also records the response to annual tuberculin testing peaking around 2012.

Published government data for Bovine TB cattle herd breakdown (OTF-W) incidence for the years 2021 and 2022 can now be added to the county-based reference series published in 2022 (1). This shows continued synchronised decline across the High Risk Area counties at similar constant rates, following establishment of annual SICCT testing from 2010 (Figures 1 and 2).

Similar, but slower decline in BTB epidemic in the Republic of Ireland since 1999 (2), has reduced incidence there to 4.4%, but it has been effectively static or rising since 2018 (3). In England, more frequent SICCT testing, with some use of interferon gamma IFN-y and additional tests, have similarly reduced cattle-to-cattle transmission. If levelling off in England is now anticipated, increased and routine use of the more sensitive live bacteria (bacteriophage) blood tests, (as validated for human health checks), for pre-movement cattle testing is needed. There could be need for recourse to cattle vaccination, with bacteriophage, a reliable blood test option for divergence (DIVA infected vs vaccinated) testing too.

Comparison of cattle TB in areas that have undergone culling with those that have not, further suggests cattle measures are by far the most likely cause of disease decline since 2010. In the 2022 paper (1), multiple statistical models checked the data on herd breakdowns over time and failed to find any association between badger culling and either the incidence or prevalence of bovine TB in cattle herds. The models that most accurately fitted the data were those that did not include badger culling as a parameter, suggesting that factors other than culling (cattle testing) were more likely to be the cause of the reduction in disease in cattle.

So it really is not scientifically credible for anyone to claim that the reduction in bovine TB is the result of badger culling. Or to keep up with the tired and fake claims of a need to use ‘all the tools in the box’. The evidence strongly suggests otherwise. The introduction of numerous cattle measures and increased sensitivity of testing has brought about disease benefit as it has done in previous epidemics.

The problem that remains is that notwithstanding the slaughterhouse pattern (above), while OTF-W* incidence is falling, OTF-S* is not. Beyond a few false positives, this suggests that the rate of detection of early infections may not be as fast as that of later infections. If badger culling was working, OTF-W* and OTF-S* should both be falling as new infections are prevented. It is not. As in Republic of Ireland, where badgers have been mass killed for decades, undetected infection is embedded in the herds and being spread by cattle movements within wrongly labelled ‘clear’ herds. As it was from the pockets of bTB remaining in the 1960s and 1970s in England. This is the challenge, and this is what needs addressing. False claims from those who wish to keep blaming badgers are unhelpful and are not ‘following the science’, just trying to manipulate it. Opposing badger culling is not a ‘political position’ as the NFU claim, it is simply following good science.

*Note:
OTF-W = Officially TB-free status Withdrawn
OTF-S = Officially TB-free status Suspended

References

1 Langton TES, Jones MW, McGill I. Analysis of the impact of badger culling on bovine tuberculosis in cattle in the high-risk area of England, 2009–2020. Vet Rec 2022; doi:10.1002/vetr.1384

2 More SJ, Houtsma E, Doyle L, McGrath G, Clegg TA, de la Rua-Domenech R, Duignan A, Blissitt MJ, Dunlop M, Schroeder PG, Pike R, Upton P. Further description of bovine tuberculosis trends in the United Kingdom and the Republic of Ireland, 2003-2015. Vet Rec. 2018 Dec 15;183(23):717. doi: 10.1136/vr.104718. Epub 2018 Nov 28. PMID: 30487295; PMCID: PMC6312888.

3 Gov.ie 2023. National Bovine TB Statistics, Department of Agriculture, Food and the Marine.

U-turn on phase out? Defra to consult on 100% badger culling.

Eleven years of intensive badger culls in England have left over a quarter of a million mostly healthy badgers, dead using cruel methods. This has been justified on the back of a hypothesis that any infected badgers frequently spread bovine TB to cattle. There is very little science to back this up, and no credible evidence that culling badgers has any effect on cattle TB.

Badger culls aimed to reduce infected and uninfected badger numbers by 70% within cull areas, but population numbers are not known, confounding the basic assumption of the theoretical benefit. Badgers may be wiped out or bounce back quickly, but nobody is monitoring with any accuracy and reporting. This current policy of intensive culling is due to finish at the end of  January 2026. But what happens after that? We may see an attempt to set something up very soon to take over, as the ruins of the current pro-cull government crumbles away with a shockingly bad record on nature protection.

Public consultation on the next phase of Defra’s bovine TB eradication policy has been attempted for over a year, rowed back on, and is now thought to be imminent. The 2020 ‘Next Steps’ bovine TB policy suggested that the follow-on policy would aim to phase out intensive (70%) badger culling, but allow 100% culling (as in the failed Cumbria culling effort) but only in ‘exceptional’ circumstances.

What will these ‘exceptional’ circumstances be?

It seems likely that to qualify as exceptional, a farm or defined area will need to have found a dead badger within an unknown distance which has tested positive for bovine TB or have been found with the same strain of bTB present in the local cattle. However, this proves nothing as the directionality of transmission is not known. You could cull badgers anywhere on this basis. It is not rational. We know that once a strain is introduced by cattle it can rapidly pollute the countryside with TB bacteria for considerable distance.

Such culling attempts have been termed epidemiological culling, or ‘epi-culling’, which is a contradiction as it breaks many epidemiological principles and discredits the veterinary profession.  Already the APHA Risk Pathways approach has been discredited following the successful independent report on the subject in 2023. The reasoning behind epi-culling sets a low bar in simplifying the implication of badgers infecting cattle, when presence of disease in badgers does not prove causation of disease in cattle. It never has done. The problem of undetected bTB in cattle is due to poor sensitivity of the tuberculin (SICCT) testing over decades. Poor testing and unwise cattle movements, coupled with residual infection remain by far the most likely cause of all herd breakdowns. The knowledge of the last ten years points directly towards the paucity of testing, while some researchers twist the evidence to bolster government policy.

It is almost as if this is a pre-planned effort to enable badger culling to become a free-for-all, and this has  been suspected by some, from the beginning. Removal of badger protection by stealth, not science. The licensing method of future culling is unclear and if it is ‘farmer-led’ as the Godfray Report (2018) suggests, what will that mean in practice? Without cull companies and detailed veterinary supervision, the approach could be even more of a shambles than it has been thus far, particularly in terms of welfare. Details of the new plans are about to be made public shortly it would appear.

What will ‘epi-culling’ look like?

Since 2018 APHA have been experimenting crudely with ‘epi-culling’ in Cumbria and Lincolnshire. This new style culling aims to kill 100% of badgers within designated areas but of unclear size. This pilot has failed to eliminate bovine TB however, (see Chapter 5 of ‘A bovine tuberculosis policy conundrum in 2023′ ) and simply served to highlight recurrent infection in a handful of farms and how concentrated testing effort can remove bTB from a few dozen herds. Clearing of these herds by intensive effort will still leave the Cumbria Area 32 a full failure in terms of demonstrating that badger culling can reduce bTB in cattle. This is no model for the future.

Badger vaccination?

Vaccination of badgers may be offered after epi-culling from year 3 as in Cumbria Area 32. This is a massive operation that the NFU may have agreed to in some kind of deal enabling more culling. The entire Edge Area may potentially be available, with cluster areas already having been prepared. Wildlife Trusts and others may, if not careful, become obligated to support and justify the process of culling with the offer of vaccination follow-on. An unwise route, supporting the pretence that vaccinating badgers will help reduce disease in cattle. This is unproven and effectively a unsubstantiated deception that will be a cover for more badger culling, both licensed and illegal. Badger vaccination is likely to be offered for the HRA with possibly more culling – this is the biggest worry of all. We hope not. Badger Groups need to be aware of the risk of being manipulated to promote vaccination projects to farmers under false pretences, which will in effect facilitate more culling to 2038 and beyond.

Is badger culling scientifically justified & has it worked?

The science behind culling is uncertain & becoming unevidenced. A peer-reviewed paper, Langton, Jones, and McGill (2022) failed to find any association between the industry led badger culling 2013 – 2019, and either the incidence or prevalence of bovine TB in cattle herds.

The paper has two main findings. Firstly, data show the slowing increase, levelling off, peaking and then decrease in bovine TB in cattle in the High Risk Area (HRA) of England during the study period, all well before badger culling was rolled out in 2016. This suggests that the cattle-based measures implemented from 2010, and particularly the introduction of the annual tuberculin skin (SICCT) test are most likely to be responsible for declines in disease.

The second finding came from a look at the amount of cattle bTB in areas that had undergone a badger cull and compared it with the amount of disease in areas that had not had culling. This was done over a six year period 2013-2019, so before and after culling was rolled out. Multiple statistical models checked the data on herd breakdowns over time and failed to find any association between badger culling and either the incidence or prevalence of bovine TB in cattle herds. Models that most accurately fitted the data were those that did not include badger culling as a parameter, suggesting that factors other than culling (time, cattle testing etc) were likely to be the cause of the reduction in disease in cattle.

Defra does not accept the findings of this peer-reviewed study but have not produced a credible peer-reviewed rebuttal to it, and (following the change of DEFRA leadership from Richard Benyon to Robbie Douglas-Miller) they still refuse to engage on the matter. They also refuse to release their ‘secret’ and withheld data, and thus-far have not produced their own published science to show that badger culling is effective in reducing bTB in cattle. A preprint (Birch et al 2023) by APHA staff is discussed here and here.

Following on from Langton et al, a pre-print looking at the original RBCT analysis has found that alternative & more appropriate analyses of the data found no effect of badger culling (Torgerson et al. 2023). This is important, because the RBCT has been used as the basis for all culls since 2013. If badger culling during the RBCT produced no measurable disease benefit, the justification for badger culling has no scientific rationale.

What about the ecological impacts of 100% badger removal?

Under Judicial Review of their decision to licence badger culling, DEFRA undertook in 2018 to monitor the ecological impacts of 70% badger removal. This has not happened, with some vague fox count numbers used as a smoke screen. There was cheating and disgraceful behaviour in court in 2022.

So what will be the ecological impact of trying to remove entire populations of badgers, in patchy ways? What will be the licensing requirements for epi-culling and how will species and habitat impact assessments be provided?  How will Tony Juniper at Natural England continue to support culling? Will he keen to keep saying that there is nothing to see?

Despite the frailty of the science behind badger culling, despite the lack of monitoring of the ecological impacts of culling, despite the financial cost and the cruelty, it looks as if the government is about to proceed with yet another ugly and ill-conceived badger culling consultation for its disastrous bovine TB policy.

 

Key badger scientist reviews recent badger culling science

Professor David MacDonald, founder and Director of the Wildlife Conservation Research Unit at the University of Oxford has reviewed the latest science on badger culling in a new report, ‘A Commentary on Current Policy’ for the Badger Trust charity. 

MacDonald, is one of a group of senior scientists at Oxford who advised on and helped instigate the Randomised Badger Culling Trials (RBCT) from the mid 1990’s, work that has been used to inform government policy on bTB ever since. From 2010, this policy has been to carry out  intensive widespread badger culling in the west of England, and it has resulted in the (often inhumane) death of around an estimated  250,000 badgers starting in 2013.

Macdonald who informed but did not take part in the controversial experiments reflects in his commentary, “…it was ‘interesting’ that exactly the same scientific evidence was used to decide, on the one hand, for a badger cull in England, but, on the other, against a cull in Wales”.

Until now, no senior academic has written publicly about the single large-scale published analyses (Vet Record, March 2022) that looked at badger culling outcomes, or about the new uncertainty over the long-accepted analyses of the RBCT highlighted in a scientific preprint by Torgerson et al. 2023. Usefully, MacDonald does both, and has also had a close look at another pre-print by The Animal and Plant Agency (APHA) (Birch et al. 2023), which considers the efficacy of what it calls the ‘badger culling policy’, which is actually a wide programme of cattle testing and movement control measures, of which badger culling was one, rolled out gradually from 2016.

What are the most important points from this new inciteful commentary? Here are several important views that he has expressed:

Walking his way through the publication of Langton et al (2022) in Vet Record, MacDonald recounts the immediate rejection by Defra & the Chief Veterinary Officer of the conclusions of the paper, the subsequent admission of by Defra of their own errors, and the resulting impasse.

Of the Torgerson et al (2023) preprint, MacDonald writes They found that the conclusions of the 2006 analysis are sensitive to the method of analysis used. Indeed, the analytical approach that Torgerson’s team judge to be the most obvious for the purpose, provides no statistical evidence for a culling effect, whereas a model comparison method aimed at selecting a model with the best out-of-sample predictive power indicates that the best model does not include the treatment effect of killing badgers. According to those statistics, killing badgers during the RBCT made no difference to the herd breakdowns, whether measured by either OFT-W or by OFT-W + OFTS.”

Importantly and from a practical governmental perspective he adds:

“Policy-makers reflecting on the statistical merits of these findings should hold in mind John Bourne’s quote (above) about the practical usefulness of badger culling even when the ISG accepted their statistical robustness.

Of the Birch et al (2023) preprint, MacDonald says that the APHA “… do not claim to have measured the consequences of badger culling, and indeed they have not”, and, “there is still no clearcut answer regarding the impact of this approach to badger culling on controlling bTB in cattle or, more broadly, whether it’s worth it.

David MacDonald’s new commentary is, therefore, a welcome review of the latest developments in badger culling science and well worth a read alongside a much longer general report on badger culling produced by the Badger Trust, ‘Tackling bovine bTB together‘. Both reports are available from the Badger Trust website.

Badger scientists at Oxford University who dominated the badger culling review, planning and experiments between 1995 and 2007 have been reluctant to speak out in a comparable way since the 2016 cull roll outs, some because they moved away, others perhaps because they remained involved. The controversy surrounding badger culling may be the reason some steer away from engaging on various elements of the science and the destructive mass killing of Britain’s favourite sentient animal and its young cubs, most of whom are completely healthy. It would be great to see more of the scientists who were involved in the RBCT engage in a similar open way, acknowledging the uncertainty and new learning that suggests badger culling was always irrelevant and unnecessary.

Looking at the big picture, it is worth noting that Defra still have no simple explanation of their concerns about the published 2022 study that showed that badger culling did not reduce bTB in cattle between 2013-2019, let alone a peer-reviewed rebuttal. Following the change of DEFRA leadership from Richard Benyon to Robbie Douglas-Miller (in November 2023), they have again written (January 2024) refusing to engage on the matter. Perpetual secrecy and lack of engagement that bears similarity to the sub-postmasters scandal. Defra still refuse to release their ‘secret’ and withheld data, and thus-far have not produced their own published science to show that badger culling is effective in reducing bTB in cattle. Meanwhile, government Ministers bandy about unpublished percentages of so-called benefit.