As Northern Ireland’s Department of Agriculture, Environment and Rural Affairs (DAERA) considers the fallout from the recent court judgement quashing their plan to shoot badgers in Northern Ireland, what does the future now hold for their bovine TB strategy?
DAERA’s current policy carried forward the main elements of the strategy proposed in 2016 by the government-appointed TB Strategy Partnership Group (TBSPG). The TBSPG was a government-industry partnership which included senior industry figures and former civil servants. Notably, no member of the group had any expertise or background in badgers or wildlife.
Soon after its appointment, the TBSPG met with stakeholders to ‘seek their views’. Even at that early stage, the TBSPG made it clear that they thought a badger cull was necessary. There was a clear impression that they had already decided on a badger cull before any evidence-gathering or engagement, meaningful or otherwise, had taken place.
The TBSPG was succeeded in 2018 by another industry-led group, the TB Eradication Partnership (TBEP), under the same TBSPG Chairman. Similarly, the TBEP exhibited equal enthusiasm for a badger cull, with apparent little regard for the views of the badger/wildlife side. You can read about the TBEP membership in this Protect the Wild blog.
Following the recent successful Judicial Review taken by Wild Justice and the Northern Ireland Badger Group, any further attempt by DAERA to progress a badger intervention will require a new public consultation. Given the shambolic nature of the last consultation, any new proposal will require root and branch revision to have any chance of succeeding.
Meanwhile, two major pieces of significant and highly relevant new research have emerged.
Firstly, a comprehensive analysis of bovine TB data by Langton et al. failed to identify a meaningful effect of badger culling on bovine TB in English cattle herds. Instead, reductions in cattle TB incidence and prevalence showed a strong correlation with the introduction of cattle-based disease control measures.
Secondly, a study carried out by scientists at the Northern Ireland Agri-Food and Biosciences Institute (AFBI) found that cattle-to-cattle transmission was by far the most common form of disease spread. Cattle-to-badger transmission was considerably more common than badger-to-cattle transmission, and no badger-to-badger transmission was detected.
The science makes it increasingly clear that ineffective herd testing and the two million cattle movements annually are driving the persistence and spread of bovine TB in Northern Ireland, not badgers. As the body of evidence exonerating badgers builds, DAERA will surely struggle to justify any new badger removal proposal.
As it turned out, DAERA’s (now defeated) decision to implement an indiscriminate and cruellest possible badger cull was a spectacular own goal and a decisive setback to their bovine TB strategy. The responsibility for this debacle lies squarely with the architects of the strategy and those in the industry who supported and enabled it.
Perhaps predictably, the decision to inflict unacceptable suffering on large numbers of healthy badgers served to galvanise the conservation and animal protection sectors in opposition to the plan.
For its part, the badger side has seen its good faith and willingness to engage thrown back in its face. Confidence and trust in the process have been seriously undermined. The government has squandered yet another opportunity to make meaningful progress.
This is a watershed moment for DAERA and the industry. They can choose to embrace the science and tackle the reservoir of undetected infection in cattle, or they can continue to scapegoat badgers and face further legal challenges and delays.
A new analysis of Bovine TB data by the Animal and Plant Health Agency
“Difference in Differences analysis evaluates the effects of the Badger Control Policy on Bovine Tuberculosis in England”, by Colin P.D. Birch, Mayur Bakrania, Alison Prosser, Dan Brown, Susan M. Withenshaw, and Sara H. Downs.
This new analysis was posted as a pre-print on 6th September, on the ‘bioRXive server. You can view it here, although there is no access to the data to check it.
With the current programme of intensive badger culling winding down and coming to an end in 2025, up to a quarter of a million largely healthy badgers have now been killed. A new consultation on Defra’s intentions going forward under the 2020 “Next Steps policy is expected on or after 16th November. This new scientific paper has therefore been constructed at an important moment for the future direction of new bovine TB policy.
Both Therese Coffey (Secretary of State for Environment Food and Rural Affairs) and Lord Richard Benyon (Minister of State for Biosecurity, Marine and Rural Affairs) have said in public and in correspondence that badger culling should continue. Mark Spencer, (Minister of State for Food, Farming and Fisheries), has been using the Birch et al pre-print in parliament to claim large disease reductions from badger culling.
But how certain is the science behind these claims of disease reductions, and the stated intentions to carry on culling badgers?
In a 30 minute presentation available to view on YouTube here, Tom Langton talks through recent scientific pre-prints and publications that have analysed bovine TB in cattle herds and badger culling. Inevitably it is a technical presentation as the issues and the statistics involved are complex. But at this critical moment, as bTB policy is further revised, the controversy and uncertainty surrounding the science of bovine TB control needs even closer scrutiny.
In March 2022, a peer-reviewed analysis of badger culling data was published in a top veterinary journal. It used all publicly available data. It showed no detectable difference in bovine TB breakdown between badger culled areas and unculled areas since 2013 (1). Now, after a government information black-out following their look at the data up to 2017, the Defra’s Animal and Plant Health Agency (APHA) have at long last posted a pre-print of their own creation looking at their secretly held data up to 2021.
It is not clear why it has taken so long to release this new analysis, a draft of which was presented at a conference in August 2022 (2).
Cynics might say there has been a search for obscure statistical methods to get the results needed to try to show a badger culling has not been a 100% failure. And of course, it supported the pro-cull rationale to hold data secret and keep quiet about any weakness in policy. This served to enable the 2022 and 2023 killings of over 50,000 mostly healthy badgers, planned and executed by the willing and obedient hands of Natural England (3).
The new pre-print, posted 6th September in ‘bioarchive’ (bioRxiv), is by six members of APHA staff. It tries to use an obscure technique: “Difference in Differences analysis evaluates the effects of the Badger Control Policy on Bovine Tuberculosis in England” to look at Bovine TB breakdown incidence (Withdrawn herds: OTFW) between 2009 and 2020 (4). There are many aspects of this new analysis which are problematic, but here are a few of the more obvious.
A new statistical method of analysis – ‘Difference in differences’ (DID)
This is the first time the DID approach has been used in badger cull analyses and it is simply inappropriate. DID compares the changes in outcomes over time between a population that is enrolled in a programme (a group subject to an intervention) and a population that is not (the control group).
The attempt here is to use the same areas in a ‘before and after’ way. There is no clearly defined control group, it is just the fragmented cull areas before they are licensed to cull. The 52 cull areas are surrounded by and influencing each other during a wide range of tightening testing interventions. They are, therefore, not adequately discrete in space and time, breaking a fundamental DID requirement. So not only is this (DID) an unorthodox approach, but it does not follow the basic rules of the unorthodox approach. It is looking a bit desperate already.
Notably, in the period 2016- 2020, pre-cull and cull areas closely juxta position. Pre-cull and cull cattle testing interventions of course influence changes in adjacent pre-cull and cull areas in an irregular and unpredictable manner, via the constant movement of cattle with different testing and control histories. It’s a mess, and surprising that this has been presented as an appropriate statistical method, considering the subject and the epidemiology involved.
Analysis does not distinguish between different causes of disease decline.
Does the analysis decisively link badger culling to decline in bovine TB in cattle? Not at all. Any possible effect of badger culling is confounded with the continuous multi-faceted and complex tightening of cattle testing that took place in an uneven manner over different and irregular time periods. Some of the very important bTB testing controls used, and the timing of their introduction, are incorrectly described and some of the most important ones are not even mentioned.
The Badger Culling Policy invention
There are places in the manuscript where a claim is made for a link to badger culling, ‘The effect of badger culling…’, but then later this is adjusted to ‘However, this data analysis cannot explicitly distinguish…….’ APHA have stated more than once in their recent epidemiology reports that the cattle breakdown data alone are insufficient to show an effect of culling.
Frankly there is no such thing as the ‘Badger Culling Policy’ (BCP) as framed by this report, beyond just killing badgers. It is an invention trying to characterize extensive cattle testing and movement control measures as just a part of the badger culling bolt-on, rolled out six years after testing control measures had been continuously tightened year on year. To pretend the extensive suite of testing and movement control measures is somehow a part of a whole is just a repeat of the ‘all tools in a box’ nonsense and it deceives. True, some of the more essential measures were increased from the first year of badger culling, but most of them were independent of it and ramped up gradually. So trying to pull them apart in a post-facto try-on will not impress the independent scientist, even if an obliging journal prints it, and industry and Defra promote it with their coterie of academic cheerleaders. Badger culling has just been a pointless distraction to cattle surveillance and control measures to address rampant cattle-to-cattle transmission.
So again, no, the analysis is not able to show causation by badger culling of any change in disease, and Defra and APHA’s judgement could be seen ill-judged by trying to convince anyone that this is credible. It is as clumsy as the Chief Vet’s apologies and efforts on Radio 4’s Farming Today in 2022. Defra boss Richard Benyon has been claiming big figures for badger cull benefits for years, but this does not provide any evidence for them.
What is the ‘true burden of disease’?
The new analysis has a surprising and unconventional interpretation of the ‘true burden of the disease’ or disease ‘prevalence’ in a population. It suggests that ‘incidence’ is the better indicator of true burden, which they must surely understand flies against first principles. It is ‘old thinking’ based on the out-dated views of farm vets who claimed that only visibly lesioned cows are infectious. Yes, incidence has been one unit of disease measurement, and it was the unit used by the RBCT to claim a benefit for badger culling. But science has moved on, and this is a strange attempt to live in the past.
The interpretation contrasts with APHA’s reports and understanding of disease controls if you look closely. It contrasts with the conclusions drawn from better comprehension of the SICCT (skin) test sensitivity and specificity, which has been clarified in recent years. Gamma IFyN testing has revealed a very significant reservoir of undetected reactors (diseased animals) in bTB infected herds, pointing towards undisclosed infection in undetected herds too. This ‘hidden’ reservoir in cattle that remains is what really matters for disease understanding and control. The true burden is bigger than the known breakdowns and identified reactors, why else would the disease persist? Both here and in Republic of Ireland where badgers have been relentlessly persecuted and SICCT and Gamma testing has failed for decades.
So why exactly did APHA attempt this clumsy redefinition of the ‘true burden of disease’. Perhaps because it needs to try to defend the original RBCT analysis which by controversial statistical modelling (5), managed to suggest a relationship between incidence and badger culling, having failed to find a relationship with disease prevalence. The effort applied to carry on killing badgers is deeply disturbing.
But wasn’t bovine TB already reducing before badger culling began?
Levels of Bovine TB were falling in many areas soon after annual SICCT testing was introduced in 2010. And well before culling started in most areas. However, the new APHA analysis reduces the analysis of pre-cull data to one data point. This conveniently helps to conceal the significant pre-cull decline and masks the true disease trajectory and results. A logarithmic scale is also used to distort visual effect. Not unlike methods used in the earlier Brunton and Downs reports.
Recent Edge Area data added into the analysis for what purposes?
The new analysis mixes data from 46 High Risk Area study areas with 6 from the Edge Area. These have very different epidemiological and disease control history profiles and the reason for mixing them is not explained. It looks like a deliberate attempt to manipulate the data. Pre-cull gamma testing was intense in the Edge Area. While the manuscript mentions additional gamma testing from 2017, gamma testing was erratic between areas and over time. There were considerable numbers of gamma reactors in many of the cull areas in cull years 1 and 2 of culling with similar disclosures levels to years 3 and 4, but pre-cull use in the HRA was generally low. Mixing them may give you a result you like, but it can be seen through for what it is.
In both HRA and Edge areas, bTB incidence was declining when many of the additional disease control rules were intensified, and badger culling introduced. The addition of this extra data makes it even more impossible to distinguish effects of badger culling and disease control measures that are known to drive down bTB.
Attempt to dismiss peer-reviewed 2022 study published without mentioning it
A comment in the text of the new pre-print says that it is not possible to match badger culled and control areas. This is not only incorrect but unevidenced, with unsubstantiated claims. The 2022 published and peer reviewed study that used this methodology effectively has not been cited. There is no mention of the even more obvious alternative to their complex DID approach, which would be to simply match a series of individual farms in culled and unculled areas. This approach is only available to APHA, which holds all individual farm records confidentially. Such simple monitoring could and should have been an expected outcome of a High Court ruling that required the government to ‘adapt and learn’ from badger culling. Why has it not been done? Perhaps it has been done but gave the wrong results?
Distinct lack of clarity
There is a definite need for clarity in the analysis presented, including the Appendix. This does not seem to be the output from the constrained DID analysis, but something else that is not fully described in the methodology. Analysis uses the lesser known system called STATA (nearly all analysts use R-code). The data is not supplied, and the Stata code is not supplied, so no one can replicate what has been done here. An author, when contacted, said these would be available following publication of the paper. Too late for others to comment on?
Does this draft show that badger culling has reduced bovine TB In cattle?
No, it doesn’t. Because the methods are inappropriate, the results are flawed, and so the conclusions are wrong. There is no way to distinguish between different interventions and change in herd breakdowns since 2013 with the approach taken. Might these results be misleading and deceive if published? Yes. Why has such a flawed analysis been produced now? Is it a try-on to justify Natural England’s new autumn badger blood-fest? Will Defra contractors, grant recipients and a friendly journal whisk it through peer review with recommended friendly reviewers? Probably.
A consultation on culling all badgers over wide areas is being cooked up despite previous policy promises. One could speculate that APHA have been told both by bosses and lawyers that they need to produce evidence that the culling policy has not been a complete waste of life, public funds, and other resources including masses of police time. They are desperate to do this, and get it out right in front of the move to ‘carry on culling’. This preprint aims to be the new truth about badger culling, but it’s all smoke and mirrors.
A quick look at the BBC farming media and sociology, touching on ‘tribalism’, the BTB Partnership and ‘avoiding the facts’. The result: a perfect storm to confuse bovine tuberculosis control.
In 2022 DEFRA took steps, but failed, to try to stop published peer-reviewed science being published in the Veterinary Record (here, here,here and here), disgracefully interfering in the scientific process. Fourteen months later, DEFRA are still unable to produce data or analyses to substantiate their claim that badger culling has resulted in any disease benefit, or indeed has not failed completely. The Minister Therese Coffey now talks about badger culling continuing ‘if the science is good‘ (see here). Last year, the Chief Veterinary Officer Christine Middlemiss on Radio 4s Farming Today, blamed others in DEFRA for the withholding of data on badger culling (listen here). If such data were released, it would quickly allow the use of a wide variety of analyses to check for the efficacy of badger culling. Surely the BBC’s influential Radio 4 flagship farming programme Farming Today, with its one million listeners, would wish to be first to get to the bottom of what is really happening in the badger cull, which is after all, such an important subject. But recent events suggest that they are perhaps, more than hesitant, and might even prefer confusion over clarity?
This month, following enquiries to Farming Today about a misleading story on badger culling by David Gregory Kumar (a BBC reporter from the West Midlands), a follow-up piece was promised by the BBC’s Dimitri Houtart, their ‘Environment, Food, Rural Affairs & Natural History Executive Editor & BBC Rural Affairs Champion’. He said: ‘I have asked my Farming Today team to ensure we mention your complaint and highlight your main points’ On the offending programme on 4th July, Gregory Kumar had played a clip where James Griffiths, a livestock farmer from the Gloucestershire Pilot 1 badger cull area had said ’badger culling has undoubtably made a difference, no one can deny it.’ With Gregory-Kumar then adding, ‘the latest data seems to support this.’ Which it does not. The latest data shows bTB falling generally as it has since around 2015, but the role of badger culling, unseparated from the increased use of better disease tests, is not known. The only published science, checked by a large raft of independent experts, suggests that it has not worked (read here).
Oddly, Gregory Kumar had mentioned the apparent inability of Defra to show badger culling works in an online article that day (see here), reporting a Defra line that analysis of the cull data was not possible due to a lack of comparison sites. This is misinformation because there are many ways to compare Defra’s secret data inside and outside cull areas each year since 2016 to give valid comparison analyses. Is it that Defra don’t get the results they want, or is it that for some reason they are incapable of doing the statistics in question? At least the Secretary of State is referring to ‘if’ the science is good. But the apparent delay in producing good scientific evidence of the benefits of culling is curious. Meanwhile, the government tries once again to bundle a further raft of badger killings through in August to perpetuate the miserable fiasco. Thousands and thousands of completely healthy adult and cub badgers will be killed for no good reason while farmers and the public are misinformed.
Sadly, in this recent episode of media confusion, history was repeating itself, with Gregory Kumar grossly overstating the case for the badger cull working and providing misleading information in the same way on a BBC outlet. Back in 2014 the BBC Editorial Complaints Unit (ECU) partly upheld a complaint against an article that Gregory Kumar wrote on BBC NEWS online, as follows: here is a part of the ruling on Gregory Kumars work:
The committee began by looking at what data there was to support the belief that a badger cull had led to a reduction in TB in cattle.
Given that both the statistics and scientific studies about the link between badger culling and bovine TB levels were inconclusive, the Committee examined whether the article had used clear and precise language to make this apparent to the audience. In doing so, it observed that the badger cull had become a highly divisive issue with those for and against the cull using the findings of different trials to bolster their respective causes and so it was essential that the BBC provided the greatest clarity possible on the subject.
In this context, the Committee believed that the language used in the article had not been sufficiently precise as it suggested that the badger cull might be a factor in helping control the disease when this was scientifically unproven. It considered that, while the data did show a decline in the number of cattle infected with TB in Ireland, there was no conclusive evidence to show that the badger cull had been categorically responsible for any of this decline and so it was inaccurate to say that, along with other measures, it can help control the disease.
On July 4th 2023, misleading information was again given out suggesting that badger culling had worked in Gloucestershire and England, with bTB policy in Wales (without culling) not working so well. However, the epidemiology reports (here) show an influx of diseased cattle into north Wales from Shropshire and Cheshire, providing a simple explanation for this. Local trading is still around 50% of cattle movements in Wales.
Here is the data from Gloucestershire where James Griffiths farms:
There has been an increase from 22 incidents in 2013 when badger culling began to 28 incidents in 2022. It is not hard to spot that badger culling shows no sign of working.
So, Defra persist in withholding data that could tell us if badger culling is working, and continue to allow exaggerated claims for efficacy to be made. And what did Farming Today do to clarify the situation? They got in touch with DEFRA, and on 17 July played bits of an interview with a member of its secretive BTB partnership, Professor Gareth Enticott of the Human Geography Department at Cardiff University.
The bTB Partnership Group was set up in 2021, with the aim ‘to encourage shared ownership, coordination, and decision-making surrounding England’s 25-year bovine TB eradication programme’. In 2022, its chairman John Cross (who has just been given an OBE) when asked its view on a new scientific analysis, said that the group does not have the capacity to consider scientific evidence. This was a surprise as it counts a professor of epidemiology amongst its membership. Other members of the group are largely farmers and vets who believe that badgers should be culled. Wildlife and nature conservation experts are not well represented.
Disappointingly, rather than addressing the point of contention in the previous Farming Today, i.e. whether or not the latest bTB data support the thesis that badger culling is reducing disease in cattle, Prof Enticott introduced the concept of ’post-normal science’. This did not really feel like an appropriate response to a factual and statistical matter concerning real data and the withholding of it for simple analyses. Enticott contended that Farmers may not be keen to wait for data to show that badger culling is effective – was that deemed acceptable? He said words to the effect:
“ …science is never definitive on anything, and that’s how science progresses, that there’s always debate about what works and what doesn’t work. In terms of the badger cull and TB policy as a whole, what you’ve got really is a debate about values which are in contest with each other, so the evidence which has been collected around badger culling reflects a set of different values about what constitutes appropriate evidence, and those values represent or are reflective of the times in which the evidence was collected.
So if we go back 20 – 25 years, you know there was a real hope that the randomized badger culling trial, very scientific approach – that form of evidence seemed to be the kind of the highest level of scientific evidence would provide the answer, and would also convert people into believing that badger culling would work. Now it turns out that that wasn’t actually the case and it wasn’t the case because they’re always these kinds of uncertainties around badger culling. But you can look at that in a number of different ways and always challenge it. So there’s never really going to be a definitive answer.”
This is simply misleading. The RBCT, as a scientific exercise, was aimed at finding out it culling could provide any disease benefit, rather than trying to ‘convert people into believing that badger culling would work’. The recent learning curve from better understanding of testing efficacy is that the ‘all-reactor’ set of results should be used in the analyses; these show no relationship between badger culling and herd breakdown. These comments reduce the conversation to confusion with a jaded view of the science process. Enticott went on:
“The answer really is what kind of science do you want to have. So, in other another environmental controversies people talk about the need for what’s called kind of post-normal science. You often have an issue where the facts are uncertain, values are disputed, the stakes are high, but people need to make a decision quite quickly. Waiting for the evidence of the randomized control trial or whatever, is not going to be appropriate.”
Firstly, the facts are not uncertain (although the interpretation certainly is), and the normal science process is open for business, it is just Defra don’t want to let go of data, talk about analytical procedure or publish results because they just want to carry on killing badgers. There never was any hurry, everyone knew that bTB was spread long distance in lorries and the skin test was not clearing herds properly. The reality was a conscious policy choice to carry on ‘trading dirty’ rather than lock down, while blaming the badgers. Enticott continued:
“You need to develop different ways of collecting information and doing science, and people refer to that as post-normal science. Now one of the ways in which you might do that is by kind of accepting that you know different forms of evidence are limited and there are problems with them.”
Well, anyone interested in post-normal science is welcome to Google it. It looks like a bit of a neo-liberal mandate to make it up as you go along. Promoted by an ‘International Society for Ecological Economics’…… While it can be appreciated as a kick-back on the current trend to twist data with dubious modelling, it looks like the kind of rationale that could be used to help reduce the planet to dust. You must wonder if Farming Today’s million listeners were given a clear insight into the concept and its application to bovine TB control.
This must be an example of the BBC at its worst and you have to wonder what Gregory-Kumar and Dimitri Houtart are up to. Do they know what they are doing or are they just two more of John Krebs sticky people (see here)?
Gareth Enticott articulated that farmers hold their own views on the effects of badgers on biodiversity and would be keen to take control of badger numbers for that reason, which is very revealing but not very helpful. Any move towards farmer-led/informed manipulation of the ecosystem remains illegal because of the barbaric treatment of wild and domestic animals by a range of sadistic people. The legal protection of badgers was a move that reflected the wishes of the public in the 1970’s who had witnessed decades of sickening abuse. Animal welfare, like science, progresses by careful process. It marks out some measure of human progress and humility. The role of badgers in the ecosystem would be much better understood if Natural England and DEFRA had done what they promised a High Court Judge they would do in 2018 and monitor the ecological consequences of removing hundreds of thousands of them. But that has been strongly resisted, and substituted with feeble ‘rule of thumb‘ assumptions.
The effectiveness of badger culling as a disease control measure remains unproven, and this is what needs to be communicated to the farming community effectively. Then they can stop wasting their own, as well as public money on a badger culling policy that is expensive, and ultimately has not had, and never will have, any measurable or actual impact on bTB in cattle.
Back in 2012, ‘Bourne’s carrot’ was the phrase developed from the rumoured whisper in a Westminster corridor, to John Bourne, who ran the RBCT. The metaphorical carrot offered killing badgers to help incentivise farmers to test and remove infected cows. We have had a long era of Fake News and ‘winner takes all’ mentality. Can the truth prevail? Not with post-normal science one suspects.
Since 2011, there have been books exposing government incompetence in livestock disease management (1) and the jumping to conclusions by social analysts on the advice of vested interests (2). There has been the cautioning by an exiting Chief Scientist on ‘tribalism’ and its drug-like ability to bring civil servants into conformity (here). The farming and veterinary sectors, alongside vested academia still struggle to come to terms with the reality that badgers are not implicated in any significant spread of Bovine TB in cattle herds. Which players will be the first to accept the wickedness (here) of the situation, and will the media finally spot what is ultimately in the best interest of farmers, cows and badgers? Has post-normal science been hiding in plain site since 2011 – it looks decidedly possible. Will BBC Farming Today and other farming media be able to cope? Probably not on current form – we will see.
A full transcript of the Farming Today piece from 17th July is availablehere.
(1) Why were you Wicked to Badgers?, May 2022. Book Review: A History of Uncertainty – Bovine Tuberculosis in Britain 1850 to the Present, Peter J Atkins, 2016, Winchester University Press (2) Book Review: Vermin, Victims and Disease. April 2020. British Debates over Bovine Tuberculosis and Badgers, by Angela Cassidy
Some observers may have noticed bovine TB breakdowns figures for Wales have levelled-off in recent years. For the first time in a long while they are showing a divergence away from the progress of herd breakdown trends that until recently was largely parallel with England. See the data here.
Since 2021, north Wales has experienced an uptick of bovine TB breakdowns in two areas in north Wales, which is causing a levelling of national decline. Looking at the genomic (spoligotype) data indicates that this upsurgence of disease originates from cattle movements from the English border counties of Shropshire and Cheshire, dating back to 2017. Radiating local movement of disease (local trading) within the ‘Low’ and ‘Intermediate’ TB Areas North, in Wales, has pulled down the overall progress compared with England. Wales introduced enhanced measures and increased testing sensitivity several years before England, resulting in its downward trend. But this has now been held back and it has nothing to do with badger culling.
While bTB control has been compromised in two areas of Wales, in 2022 England saw a welcome steeper decline in 0TF-W breakdowns as the use of 6-monthly SICCT testing and gamma interferon to better identify infected cattle began to take effect. Gamma testing raises herd testing sensitivity from around 80% (of the SICCT test) to perhaps 90% or more, halving the numbers the tuberculin test misses but has around 4% false positives. This is one reason why 6-monthly SICCT testing has been preferred as it also detects more than a single annual SICCT test. The additional 6-monthly SICCT tests were introduced in Shropshire and Staffordshire from March 2021 and in the rest of the HRA from January 2022. Defra have had issues updating their data recently, but it now appears that in the HRA cattle tests increased from around 4.61 million 2021 to 5,44 million in 2022 an increase of approaching 20%.
However, APHA data shows how, alongside, gamma testing bit into the main driver of disease – persistent herds, often with large numbers of cows and cow sales each year and infecting many new herds each year through local and auction sales. The big breakthrough came in 2019 with over a quarter of a million gamma tests across the HRA and Edge with a 30% drop in persistent herds across the HRA and Edge.
Further, for 2019, Defra followed the example of the Welsh Government and applied a 50% reduction in compensation for animals moved into a TB breakdown herd that were subsequently removed as TB reactors or direct contacts before the herd regained OTF status. Gamma testing was used in England at considerable levels from 2018-2022 in the HRA, and the disparity became more visible from 2020 as Wales became infected from the English Edge Area.
Peer-reviewed analyses show that in England there is no sign of benefit in the HRA from badger culling. The rate of decline of bovien TB disease prevalence in England’s High Risk Area (HRA) now matches the level of fall of 20% per year seen in the 1960’s, when the disease was quickly brought under control using cattle based measures. Had gamma testing been introduced earlier as in Wales and the Republic of Ireland, the English epidemic would have been well under control by now.
Six-monthly SICCT testing and use of Gamma testing will disclose more infected cows that escape the testing system and bring bovine TB down, but may not finish the job. A more sensitive and specific blood test such as Actiphage will be needed to do that. Cattle vaccination may also play a role too but with a disciplined approach to testing, may be avoided.
The annual bovine TB epidemiology reports (1) for England and Wales, both compiled at APHA Weybridge, have historically had authors in common. More recently however, the reports no longer publish the identity of the authors. Why might this be? What we see now is a definite disparity in approach, presentation and implication.
The emphasis on wildlife andRisk Pathways Analysis (RPA) in the England reports is noticeable, compared to the Welsh versions (Table 1) which barely mention them. So whilst bTB is clearly the same disease in both countries, the attribution to wildlife, cattle movements and residual infection differs very markedly as you cross Offa’s Dyke.
*Wales not yet reported
Table 1. Mentions of the risk pathways approach and badgers and wildlife as a source of bovine TB infection in APHA reports for Wales and England 2016-2021. Note near absence of mention for Wales, while England has a growing obsession over wildlife involvement. Will attempts be made to force Wales to follow England’s scientifically unreferenced pathway?
These differences have occurred due to the use in England of un-evidenced data to support a policy that culls badgers in England, whereas in Wales no such policy exists (2). RPA was introduced in 2015 by APHA on a trial basis by vets using the newly updated Disease Report Form (DRF), and with the stated aim of identifying the source of bTB breakdowns, defined as ‘hazards’. In this trial, the pathway by which disease entered the bTB infected herd was to be decided by the investigating vet. The DRF provided a list of epidemiological hazard options to select; the option of attributing disease to wildlife was the default where attribution to a cattle source was not immediately obvious. The trial was quickly hailed as a success and expanded in 2016 with a few changes. In 2017 it was adopted by APHA as a standard recognised procedure for identifying the source of an infection, training vets to routinely misdiagnose.
Risk Pathways; a process hijacked by pro-badger cull advocates
APHA have not been able to provide scientific citation to validate the use of RPA protocol. Despite claiming since 2019 that they have a supporting paper in preparation for peer review and publication in a scientific journal, over three years later this has not appeared. It could perhaps be argued that RPA has all the hallmarks of being constructed by APHA to facilitate and support widespread badger culling, because that in effect is what it has done.
Since 2017 RPA has become the primary tool to implicate badgers as the source of the majority of incidents in England (2,3). Wales, in contrast, cites cattle movements, residual cattle herd infection and poor cattle purchasing decisions as the primary sources of bTB herd infection.
A trawl through recent APHA English County bTB reports reveals a plethora of statements about badgers which are not supported by qualifying scientific evidence. Many of these are stated as if they are settled science (they are not), or with descriminatory language. Below are a few examples from the Executive Summary of the APHA England 2021 epidemiological report (4) :-
“Eradication of bovine TB requires control of infection in both cattle and the main wildlife reservoir (badgers).”
“In 2021, as in previous years, herds located in the HRA (where there is high infection pressure from cattle and badgers),…….”
“For England, the source of infection with the highest weighted contribution was badgers (49%), followed by ‘Other or Unknown’ sources (17%). The most frequently considered sources of infection in the HRA were badgers (52%) and ‘Other or Unknown’ sources (16%). In the Edge Area, badgers constituted 52% of the considered source, followed by cattle movements (17%).“
“The existence of local reservoirs of M. bovis shared by cattle, badgers and other species; wildlife reservoirs of M. bovis are more common in the HRA and the western and northern parts of the Edge Area.”
Compare this with the extracts from the Executive Summary Wales Bovine Tuberculosis Surveillance Report 2020 (5), where there is not a single ‘wildlife’ reference.
“The risk of a herd becoming infected with TB is associated with factors such as herd density, herd size, production type, TB history and location. These factors contribute to the spatial pattern of TB in cattle herds across Wales. Dairy herds had a significantly higher TB incidence rate compared to beef herds, with this effect remaining after adjusting for herd size and location. Similarly, herds with more than 300 animals have the highest incidence rates, with this effect remaining after adjusting for herd type and TB Area.”
“The increase in recurrent infection (a TB incident occurring within the last two years) in cattle suggests this remains an important driver of infection in Wales.”
“Use of antibody blood tests increased by 85% in 2020 compared to 2019, with 11-13% of tests disclosing reactors in the high TB areas, west and east, intermediate TB area mid Wales.”
From 2017 onwards, the England epidemiological report has a map illustrating the areas of England where badgers are considered by (what is described as) “informed veterinary opinion” to be the source of bTB infection. This is veterinary opinion that has been informed by APHA’s flawed briefing of vets.The map suggests that badger contribution far outweighs that of cattle. Combined with DRFs, from which the map data is derived, it offers no evidence to support this veterinary judgement. There is a clear bias towards blaming badgers. It even references “infected badgers” within the text, with an admission from APHA that no badgers have been clinically tested.
There have already been 10 years of intensive badger culling in England, and there appears to be some intention to continue with so-called ‘epidemiological culling’ into the future, despite a lack of evidence as to efficacy (6). APHA’s epidemiological assessments try to justify this new style epidemiological culling, by ‘finger pointing’ badgers as the source of breakdowns.
Unscientific perpetuation of wildlife involvement persists
The unscientific claims of wildlife involvement in bTB persist. They are being pedalled via epidemiology reports that lack scientific evidence and backed by vested industry and veterinary interests. The speculative blaming of badgers as a source of bTB infection in cattle, without scientific evidence or justification, seriously undermines the whole bovine TB eradication policy.
APHA pride themselves on being a world class science establishment, supported by such statements as :
“Science continues to be fundamental to everything APHA does and we are committed to high quality science-based evidence for decision making and policy development. We will deliver this strategy over the next five years.”
The new model for epi-culling is not quite the model of scientific rigour APHA aspire to. Is it more a clear case of confirmation bias, remoulding and manipulating information to support a government policy that has tried to normalise removing large numbers of healthy badgers from the English landscape, contrary to high quality science based evidence and to correct handling of uncertainty and precautionary principles.
It has to be asked, has this manipulation been intentional? Is incompetence or even negligence the right perspective? Will public opinion continue to be ignored? Who exactly is pushing biased procedures? What level of pressure is being exerted from vested interests, and who is routinely interfering with government science?
A new article in the May issue of British Wildlife magazine provides an overview of the current state of affairs with badger culling in England, and a welcome update on the science surrounding the issue.
It looks at new work that questions the role that badgers play in bovine TB in cattle, and what the most likely reasons behind the perpetuation of the disease are.
It also looks at the problems that badger culling is likely to be causing to the ecosystem in general, and whether or not this is being adequately monitored or mitigated.
There is a potted history of legal challenges to the badger cull, and a view on the insight and benefits that this difficult work has provided.
It looks at where the current government intends to take the badger culling policy next, and what ‘epidemiological culling’ could mean for our badgers in the future.
You can access a copy of the article here, for a charge of 99p.
The amendment, moved by The Earl of Caithness, was described thus:
47: Clause 17, page 20, line 34, at end insert—“(3) In subsection (1)(b), developments in scientific understanding must be identified based upon regular reviews of the scientific evidence.(4) When undertaking a review of scientific evidence referred to in subsection (3), the relevant national authority must consider the methodological quality of the evidence, in terms of the extent to which all aspects of a study’s design, data collection protocols and statistical analysis can be shown to protect against systematic bias, non-systematic bias, and inferential error.(5) Where regulations under subsection (1) constitute environmental law, the review of scientific evidence must also consider whether the evidence takes a sufficiently wide view of the ecological impacts.”Member’s explanatory statementThis amendment is to ensure that future regulations will be based on a proper assessment of the best science available.
Member’s explanatory statement: This amendment is to ensure that future regulations will be based on a proper assessment of the best science available.
Lord Krebs was at last nights debate and said:
“I support in large part what he said about the importance of rigorous scientific evidence to underpin policy—he referred to the environment, but I would say more broadly. I will add a note of caution from my personal experience. As many noble Lords will know, I was responsible for instigating the randomised badger culling trials, the so-called “Krebs trials”, which were meant definitively to determine whether killing badgers was a good way of controlling bovine tuberculosis. The trial was probably the largest ecological experiment ever done in this country; it did produce results, but it did not settle the arguments or the policy. So science has an important role to play, and I support the noble Earl’s amendment, but we must recognise that political decisions come in as well.”
So Lord Krebs, who set up the Randomised Badger Culling Trials (RBCT), states that the results did not settle the argument as to whether killing badgers was a good way of controlling bTB in cattle.
Further, The Earl of Caithness, speaking in the same debate quoted Lord John Krebs from the recent debate on the Genetic Technology (Precision Breeding) Bill, where he said;
“scientists do not absolutely agree on everything”.
And;
“when there is a centre of gravity of opinion, there are always outliers. Sometimes those outliers turn out to be right and there are transformations”.—[Official Report, 25/1/23; cols. 221-23.]
So in summary: the RBCT did not settle the arguments on the efficacy of badger culling, and the outliers in scientific opinion sometimes turn out to be right and there are transformations.
Will this to be the case with badger cull science; the outliers will turn out to be right, and there will be transformations?
A team of researchers and veterinarians have concluded an urgent need for rapid change to bTB policy for England, warning the present focus on badgers is undermining efforts to combat the disease.
Independent Report Exposes Unsafe Procedures in Bovine TB Control in English Cattle
A new report on the possible future use of so called ‘epidemiological badger culling’ is being released to MPs and Parliament on 11th May 2023. Compiled over the last year by a group of independent experts, it looks closely at one specific element of the government’s bovine TB control policy proposals for English cattle herds; that regarding the role of badgers in bTB disease hotspots as they develop.
Government Policy in 2020 had suggested a move away from intensive mass badger culling, that by 2022 killed over 210,000 mostly healthy badgers in England since 2013. This huge programme of wildlife intervention has produced no demonstrable benefit to disease control in cattle, with the government silent on results since 2017.
Authored by experienced and independent researchers, veterinarians, and epidemiologists, it addresses DEFRA’s handling of the disease crisis, and why the 2020 “Next Steps” policy is likely to fail because of incorrect decision making and exaggerated claims made on the back of equivocal research results.
The report claims that the Animal and Plant Health Agency (APHA) and DEFRA, are failing in their duty to provide proper scientific approaches to vital aspects of the heavily publicly funded, long running bovineTB control crisis in England.
Specifically, it exposes the poor rationale behind aspects of the proposal which aims to implement systematic localized elimination in an area of all (100%) of badgers, an approach termed by DEFRA as ‘epidemiological badger culling’. This back-door approach to systematic removal of badgers from farmland where cattle have bTB, is already being trialed in a small number of counties and appears to be planned in more. But it is founded on evidence and beliefs that are not fit for purpose.
The 55 page report with 2 page summary, provides a catalogue of evidence on issues that the authors say have been consistently misrepresented by APHA and the Chief Veterinary Officer. It calls for an immediate rethink, scientifically robust planning and an end to supporting an ill-conceived policy with uncertain science and procedures.
The report is prepared in advance of an anticipated government consultation over its future policy to phase out badger culling.
Report Citation: Griffiths, L., Griffiths, M., Jones, B., Jones, M., Langton, T.E.S., Rendle, M., Torgerson, P. 2023. A bovine tuberculosis policy conundrum in 2023. On the scientific evidence relating to the Animal and Plant Health Agency/DEFRA policy concept for ‘Epidemiological’ badger culling. An Independent report by researchers and veterinarians to DEFRA and the UK Parliament. APRIL 2023.
Since mid-March 2022, Defra has persisted with its claims regarding an independent scientific paper (1) that extensively analysed government data on herd bTB incidence and prevalence in the High Risk Area of England since 2010. The paper compares areas subject to badger culling with those that were not culled in each year of the controversial mass badger culls from 2013-2019.The paper concludes that badger culling has had no measurable benefit in bovine TB disease reduction, and Defra continue to claim that the paper is flawed.
Defra’s and Natural England’s position on this new analysis, including apparently that of the Defra chief scientist (CSA), Gideon Henderson and chief vet (CVO) Christine Middlemiss, seems to be based on their dislike of the statistical approach of the new paper, which differs from Defra’s traditional approach to badger cull evaluation.
Defra/APHA prefer to try to mimic the analytical methods of the Randomised Badger Culling Trial (RBCT). They take cull areas and compare them with different unculled areas, adjusting the data considerably to try to take account of the subtle or sometimes profound differences between compared areas. The new study took a different approach. This study looked at the same (or 97% of) herds over the years of study, so spatial differences were minimized. The analysis used data from herds when they were in unculled areas, and then again when they were in culled areas following their transition from one to the other. This simple approach, dictated by Defra secrecy over cull area locations, brings different strengths and requires less interference with the data. The approach enabled all the data available to be used, not just selected parts of it that might lead to skewed, inaccurate results and conclusions. Just look, for example, at the tangled caveats in the Downs paper from 2019 of just three culled areas and multiple unculled areas.
But Defra are very bold in their criticism : “the analysis was scientifically flawed. It manipulated data in a way that makes it impossible to see the actual effects of badger culling and therefore its conclusions are wrong.” Confident claims, but do they have merit?
Defra’s ‘inappropriate grouping’ claim
Defra’s main objection surrounds the issue of what they call ‘inappropriate grouping’ of data. This is the key point in the letter that they pressed the Veterinary Record journal to publish alongside the shortened printed version of the paper on 18th March. This was reported on in more detail here.
The problem in Defra’s claim goes beyond the calculation mistakes in their 18 March Vet Record graph, that they subsequently (in May) apologised for, retracted & replaced with results more similar to those in the new paper. Defra’s presented data shows the herd bTB incidence reducing dramatically in the first and second years from cull commencement. This is the same data as used in the new paper, so this is no surprise. But the point is, Defra say that you cannot group data from years one and two of culling with that from the third and later years because thelevel of decline in years one and two are too small, and this will remove all signs of effect. However, the Defra graphs do not show that the level of decline in years one and two in cull areas is small, and this is the contradiction that they refuse to talk about.
Similarly, the analysis presented by APHA staffer Colin Birch at the IVSEE16 conference in Nova Scotia, Canada earlier this month, (2) Figure 1, does not show that the level of decline in years one and two is small either. It showed sustained decline over 4 years, with a similar level of decline each year right from the start. Yet it provided no comparison of data from the 25% of the HRA that remains unculled. To the audience’s complaint, here, he quite wrongly tried to attribute these declines to badger culling.
Figure 1. Marginal effects on confirmed bTB incidence rate associated with duration of badger control. Error bars indicate 95% confidence intervals. From Birch abstract ISVEE 2022
So where did the ‘inappropriate grouping’ comment come from? Well, it is likely that Defra have fallen back on RBCT advice and the 2006 and 2007 (3,4) papers that presented the findings of 10 treatment-control area comparisons of small cull areas. These papers showed large variation in the estimated levels of decline in bTB herd incidence in culling areas, so much so that the confidence intervals (CI) on the presented graph figure 2A (Figure 2.) passed through 0 in most years.
Figure 2. Fig 2 (A) from Donnelly et al. 2007
Estimated average declines were 3.5% in year 1 and 12.8 % in year 2, with 39% in year 3. So, you can see that by using the RBCT as a prior reference source (this the point of reference used in Defra/APHA documents), there could be an expectation that there isn’t much disease reduction in years 1 and 2. However, while the drop may not have been projected to show significance until year 3, the decline trend should be present and visible by the end of year 2.
So looking again at Figure 1 (Birch 2022 abstract), government is now turning this on its head and claiming, in contradiction, that bTB incidence among cattle herds reduced by around 15% per year in each of the first two years of badger culling.
Defra’s unsupported point was also made by Cambridge vet James Wood on Radio 4 Farming Today on 19th March 2022, but it simply doesn’t stack up. Even if there was just a modest (say 8% average) annual benefit in years 1 and 2, it would still have shown up in the new paper analysis in comparison with unculled areas when using such a huge amount of data, as is possible using the 2016 onwards rolled-out HRA badger culls.
Ridiculously, Defra have previously claimed substantial benefit in years 1 and 2 from the post-2013 cull data, and used this as a basis for claiming badger culling was working. They did this spectacularly in 2017 with the APHA Brunton et al. paper (5) that suggested benefit 32% in Somerset, and 58% benefit in Gloucestershire in the first two years, and again in 2019 with the notorious and heavily caveated Downs et al. paper using data to-2017 (6), that was undone by the 2018 results (7), also published in the veterinary literature, with slightly more claimed benefit (Table 1 below).
Pilot cull Area 2013-2017
Brunton et al. 2017
Downs et al. 2019
Percent est. in Yrs 1 and 2
Gloucestershire 1
58%
66%
88%
Somerset 1
32%
37%
86%
Table 1. Claimed benefit from badger culling in Brunton et al (5) and Downs et al (6).
The Defra Minister and MP’s were told that badger culling was working based on this claimed year 1 and 2 benefit. They told parliament and the public in no uncertain terms that badger culling was working, so they can’t really go back on it now without losing face. James Wood also told Countryfile views that he thought the data showed badger culling was working based on the first two-years of pilot data. So, who is talking in riddles now?
The problem that Defra have, and it is why they have clammed up to the scientists and media, is that if Defra/the CSA/CVO were to communicate beyond the bold claims made in March in Vet Record and on the Defra media blog, they would lose the argument. Defra have written to the first author saying they are not prepared to discuss the matter. Caught, it seems, between their scientific advisors’ comments, legal undertakings to monitor efficacy and policy-mania to keep on badger culling in the face of failure. Even Natural England have gone as far as saying that the situation is unclear “Because these different control measures are being implemented simultaneously, it is difficult to determine the relative contribution each of them is making to disease reduction.”
Insufficient data points?
One argument Government have used to dismiss the validity of the new paper is that it has insufficient data points. While the new study does has few data points, each data point summarises a huge amount of data representing hundreds or thousands of herds, helping to obviate the kind of problems caused by the smaller data sets of APHA studies. The approach is equally or more valid. It did, after all, pass rigorous peer-review (4 reviewers including at least two epidemiological statistical specialists) in a leading veterinary journal.
Basically, Defra lost both arguments, rebutting the paper in short measure, and it is astonishing that CSA Henderson CVO Middlemiss were given this position to hold, let alone to defend. No wonder Middlemiss got muddled on Farming Today over it on 25 May. This problem is now many months old and Defra and Natural England have carried their unsubstantiated criticisms along to justify the licensing of further supplementary culling licences in May and intensive culling licenses from August. This means the killing of tens of thousands more largely healthy badgers over the next four years to add to the roughly 200,000 that have been slaughtered to date. This flies in the face of peer-reviewed science, against which Defra have failed to produce anything credible or comprehensive that is peer-reviewed.
At the Birdfair State of the Earth panel debate on 15th July of this year, the retired badger cull architect Prof Ian Boyd: Chief Scientific Adviser at Defra (2012-2019) commented: “Well, if badger culling isn’t working it shouldn’t be done, that’s absolutely clear. I think there is still an ‘if’ there, but I suspect that the evidence is suggesting it doesn’t work.”
And Prof David Macdonald at Oxford, who chaired the Natural England Scientific Advisory Committee for many years, and who called the Pilot culls an ‘epic fail’ has commented in Chapter 16 of his new Oxford University Press book ‘The Badgers of Wytham Woods’: “ it is hard to see how Middlemiss and Henderson land a knock-out punch on Langton et al’s analysis..”
There is nothing very dramatic or complicated here in Defra’s last stand. Defra has lost the scientific argument. They must surely now face abandoning the failed badger culling policy altogether. They really should talk openly about it.
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. Birch, C. Prosser, A. and Downs S. An analysis of the impact of badger control on bovine tuberculosis in England. Abstract oral presentation to ISVEE16, Halifax, Nova Scotia, Canada. 2022.
3. Donnelly, C. A. et al. Positive and negative effects of widespread badger culling on tuberculosis in cattle. Nature 439, 843–846 (2006).
4. Donnelly CA, Wei G, Johnston WT, Cox DR, Woodroffe R, Bourne FJ, Cheeseman CL, Clifton-Hadley RS, Gettinby G, Gilks P, Jenkins HE, Le Fevre AM, McInerney JP, Morrison WI. Impacts of widespread badger culling on cattle tuberculosis: concluding analyses from a large-scale field trial. Int J Infect Dis. 2007 Jul;11(4):300-8. doi: 10.1016/j.ijid.2007.04.001. Epub 2007 Jun 12. PMID: 17566777.
5. Brunton LA, et al. Assessing the effects of the first 2 years of industry-led badger culling in England on the incidence of bovine tuberculosis in cattle in 2013–2015. Ecol Evol. 2017;7:7213–7230. doi: 10.1002/ece3.3254. – DOI – PMC – PubMed.
6. Downs S H, Prosser A, Ashton A, Ashfield S, Brunton L A, Brouwer A, et al. Assessing effects from four years of industry-led badger culling in England on the incidence of bovine tuberculosis in cattle, 2013–2017. 2019. Sci Rep. 2019; 9:14666. https://doi.org/10.1038/s41598-019-49957-6. Accessed 16 June 2021
Over the last three years, the science base for badger culling has shrivelled away from ‘not very much’, to nothing. It has regressed from speculation that it might enable a modest annual reduction of bTB in cattle, to the reality that after 7 years of study, there is no measurable benefitwhencomparing herd breakdown rates in culled and unculled parts of the High Risk Area. It doesn’t work. This is one reason the government refuses to talk about it. Not only did the 2018 spike in bTB breakdowns in Gloucestershire show how unlikely it is that the killing of badgers is linked to the epidemiology of cattle breakdowns. It showed how cautiously the model-based claims of the Animal Plant and Health Agency (APHA) after 2 and then 4 years of culling should be considered. Subsequent detailed examination of all the government data this year in a peer reviewed paper (Langton et al) showed the badger culls to have failed.
Following a ridiculous three months of trying and failing to block and then rubbish the new scientific paper, Defra stopped communicating with the authors and enquiring journalists, leaving Natural England (NE) with the difficult decision of whether to continue issuing licences. The government response was to re-deploy Andrew Robertson from the government’s TB HUB information service in Exeter to Natural England in May of this year “because of a lack of expertise” inside the NE organisation. The outcome was that Natural England supported Defra’s position and issued yet more badger culling licences. Initially more Supplementary culling licences were approved by NE in May, this despite the fact that there was no benefit after 4 years to maintain for a further 5 years. Then in August, NE were somehow prepared to extend their belief in the killing of badgers and to continue culling badgers based on their own unpublished ‘secret’ science.
Instead of stopping culling as they should have done, NE have taken a nebulous stance on the science. It has refused to provide any written justification for its position, perpetuating its belief in the use of secrecy to prevent public scrutiny of their competence and decision making. The public have a right to see the rationale for their decisions, but this has been withheld. It is clear that NE have worked very very hard this year to facilitate continued issue of licences. They do this for a combination of reasons. They are likely fearful of contradicting Defra and APHA. Perhaps it would be too difficult to admit to failure on such a sensitive area.
Over the summer, NE Chairman Tony Juniper chose not to reply to communications, preferring to talk vaguely on public panels about NE not wanting culling and preferring vaccination. This summer he had a big chance to stop badger culling. He didn’t. He has now been in charge during the culling of most of the approximately 200,000 badgers. He and George Eustice have carried out what some call the near eradication of badgers over large parts of England.
NE eventually responded this week following a legal pre-action letter, sent in early October. They claimed that the death of the Queen and changes in government had prevented the licensing paperwork from being shared with those asking for it. These are embarrassing excuses for the lack of provision of legally required documents, on such a controversial subject of high public interest, and they reflect poorly on those responsible.
Information released late on Friday 28th October, showed 11 new cull areas, and the potential for tens of thousands more badgers to be killed. Over 30,000 or so could have already been shot over the last 8 weeks in a further sickening Natural England licenced ‘bloodfest’ of largely healthy badgers. One thing is certain, this is Natural England’s work. Natural England carry the torch for badger culling even if they say they are only following orders. As they have since 2012, when someone thought it would be a good idea for NE to carry it out and control it. They certainly have. It is the legacy of those involved with NE past and present, as much as anyone.
