Badger Crowd can today reveal a letter from Natural England, stating that despite the sickening killing of over 230,000 badgers since 2013, the Natural England Board intends to continue with the failed and ineffective badger culls across England over the next two years. This despite the change to a Labour Government. In its years in opposition, Labour pledged to end the badger culls. But instead, around 100 adult and young badgers on average will be shot every day between now and January 2025 under the direction of the NE Board who control the plans.
Steve Reed, new Environment Secretary for Labour has inherited the disastrous badger culling legacy
This was revealed in a letter repeating much of the material provided in a freedom of information release in May showing how Defra want to keep culling to appease the livestock industry and because they think badger culling ‘works’. This is despite the complete lack of supporting evidence, and with strong evidence to the contrary. Indeed, the new government called the badger culling policy ‘ineffective’ in its manifesto.
This is almost as ludicrous as the claim in 2013 that helped to start badger culling in the first place, i.e. that half of cattle-to-cattle breakdowns originate from badger infections – one of the great mysteriously uncontested travesties of modern veterinary epidemiology. It is based on flawed opinion and flawed analysis, promoted by government scientists and contractors to support government policy. The result has been to support the vested interests that have dominated for two decades. But there was a clear-out at the political level on Thursday night in the 2024 General election.
While dozens of pro-blood sport MPs have lost their positions, entrenched civil servants are no doubt striving to bolster positions they have defended against public interest as a result of tribal behaviour (see here and here), by using the fear-factor that has characterised bovine TB policy.
Notably, Natural England speculate in their letter on how long it might take Defra to gear up for badger vaccination – another cattle disease reduction folly – and talk about a supposed gap between hypothetical benefit effects that have not been shown to exist. Tainted science, based on poor advice.
These plans to continue culling are now under legal scrutiny. Badger Crowd calls on the new government to stand up and be counted on its promises, and not duped by the range of bad advice, information and opinions floating around from those with a conflict of interest and confused stakeholders. It’s time for the badger culls to stop
This week yet more legal action is underway, seeking to end the failed badger culls. A Judicial Review Pre-Action Protocol Letter was sent to Natural England by the Badger Trust and Wild Justice, challenging the issue and authorisation of 26 supplementary badger culling licences in mid-May of this year. This follows the shocking content of Freedom of Information releases obtained in May showing communications between DEFRA and Natural England since April of this year.
This action adds to two other ongoing judicial challenge applications, one of which was lodged today in the High Court, in relation to the recent consultation on the future of ‘badger control policy’ by Defra. This challenge claims that the Defra Consultation to introduce 100% badger culls (of a kind trialled in Cumbria since 2018), under control of the Defra Chief Vet, was unfair when it misrepresented scientific fact about badger culling efficacy to consultees. Other flaws are also highlighted in the challenge.
So how will things play out in the days and weeks to come?
Opinion polls now suggest a Labour government may be in place on Friday 5th July with a substantial majority of MPs in Parliament. Those following the history of badger culling could have expected that a swift and decisive end to the cull would be implemented with an incoming Labour government. A number of Labour MP’s and Shadow Ministers have stated that this is Labour’s intention in recent years. The Labour Manifesto launched last month stated that the badger culls have been “ineffective”, something that makes culling unlawful under the Protection of Badgers Act 1992, confirming that position.
However, last week Shadow Environment Minister Stephen Reed, who has recently been in meetings with the National Farmers Union, threw a surprise question mark over this on BBC Farming Today by saying there would be no ’hard stop’ to badger culling. The implication is that culling could continue for a further two years under existing licenses for Intensive, Supplementary and Low Risk Area culling in England. A terrible prospect for killing protected wildlife with its known inefficiency. How could that be possible?
Dynamics for new Government making the right decisions next week?
There are currently three legal actions underway.
Challenge 1. from Stephen Akrill. Seeking permission for Judicial Review at the Court of Appeal.
A legal challenge against badger culling in England was made in a personal capacity by Stephen Akrill from Derbyshire, against the Secretary of State (S/S) for Defra Steven Barclay. With a Judicial Review claim lodged on 14th November 2023, Barclay’s second day in office, Akrill is challenging the historic decision of SSEFRA from 2012 to issue licences to kill badgers under section 10(2) (a) of the Protection of Badgers Act 1992. The claim is that the S/S has acted upon flawed scientific advice that badger culling could influence the spread of disease. Akrill is seeking a quashing order to revoke all licences for badger culls issued by the Secretary of State. With a request to stay extant licences issued by the Secretary of State to kill badgers in 2024, pending the outcome of his application for Judicial Review.
This was the latest JR concerning badger culling since the judgement in Northern Ireland earlier this year where DAERA were ruled to have consulted unlawfully on a plan to mass-shoot badgers, and where detailed justifications were wrongly withheld. In short, this new JR claim contends that there is inadequate evidence to indicate that culling badgers can influence the spread of bovine tuberculosis in cattle. The RBCT experiment was done under Crown immunity despite the Protection of Badgers Act 1992. This, argues Akrill, did not make any subsequent act of killing badgers lawful. While the 2006 RBCT paper was called the established science, Akrill’s argument also is that scientific protocol dictates that science only becomes ‘established science’ once it is shown to be reproducible, not simply because it has been published. This is the science reproducibility argument.
At the Court of Appeal in London in mid-May, Akrill argued that culling badgers by industry without clear reason, and effectively as an experiment, was potentially a criminal offence. Akrill gave two recent examples where evidence suggested non-reproducibility of the RBCT experiment and suggested that the industry led culls had been unlawful from the start of in 2012. Thus, he claims the rolling offence was an error on the part of the decision maker each time culling had occurred, as decided by the S/S, and so remains unlawful.
A related argument was that scientific opinion does not constitute science – specifically it does not overrule the basic premise that science should be reproducible to be safe. On that basis, the Defra CSA and CVO opinion on recent evidence is not sufficient for the S/S to base decisions on. The case continues, and now due to the snap election, will apply to the incoming Government.
Challenge 2. from Tom Langton supported by Badger Crowd and Protect the Wild. Challenge to the March 14th consultation on targeted culling.
A PAP response was received from Defra in mid-June and the case application was lodged at the High Court today, 3rd July. It challenges the fairness of the consultation on three Grounds:
1) that it made misleading claims preventing intelligent consideration 2) that it omitted key information on ecological impacts and 3) it omitted information on the likely economic benefits of the proposed policy.
The government’s position has shifted from saying badger culling caused the disease benefit in cattle, to one where they think it helped, but the detail is fuzzy and not backed by evidence. This is not a good position for the government who needed to come up with some evidence that killing 230,000 badgers (and counting) was worthwhile. They have failed to do this due to weak analysis and are now called out for exaggerating to the public.
Challenge 3. from Badger Trust and Wild Justice. Challenge to the authorisation and reauthorisation of Supplementary Badger Cull (SBC) licences.
The pre-action letter challenges the SBC licences that aim to shoot thousands more badgers from 1st June 2024 and in the next six months of the new Parliament. Also next year between June 2025 and January 2026. This is more and more ineffective culling of tens of thousands of mainly completely healthy badgers for no good purpose.
Based on the information obtained by Tom Langton from Natural England this May, Badger Trust and Wild Justice have together sent a pre-action protocol letter to Natural England and the Secretary of State for Defra to stop the supplementary badger culls continuing. This year, as usual, the supplementary culls started on 1 June. The challenge aims to stop the cull immediately because the advice of Natural England’s own Director of Science (not to cull badgers) was wrongly overruled. The action could lead to the two organisations applying for a full Judicial Review. Natural England has been given until 15 July 2024 to respond and to halt the 26 supplementary culls.
The view is that Natural England, led by Tony Juniper and the Natural England Board, were wrong to overrule Director of Science at NE Peter Brotherton, who felt SBC could no longer be justified. Release of crucial information showed how a Defra official had pressurised NE with advice from Animal And Plant Agency’s Christine Middlemiss (the Chief Veterinary Officer), to carry on culling in order to meet cull company and livestock industry expectations, and to sustain the so-called benefits that Defra have failed to show exist. The fundamental reasoning behind the decision was inadequate and unlawful.
Why a ‘hard stop’ to badger culling is actually warranted now
The time is right to bring an end to all badger culling. As things stand, Natural England may also maintain its plans to continue to ‘cull by stealth’ this year (as it has done for several years) using ‘cull extensions’ to kill more and more badgers over hundreds of square kms, by secretly expanding the edges of existing cull areas. Further, in mid-August 2024, just six weeks away from now, over 20 further areas of 4-year culls could be re-authorised by Natural England for the autumn bloodbath to continue.
Scientific analysis has shown these intensive culls to be ineffective. There is no better time for a full-stop, and a new policy to be formed with a change of approach.
What about industry objection to culling ending?
Back in 2019, the government took a decision to stop the first Derbyshire badger cull before it started due to inadequate preparation on the distance standoff between badger culling and badger vaccination areas, that had not been properly thought through. NE paid compensation to the cull company involved for late notification of that decision. However, when NFU took High Court legal action against the government over the decision, the judge indicated that the government had a political prerogative to take such a decision.
A decision to cancel the culls in 2024 would surely follow the same outlook. And in any case, compensation paid to farmers for loss of set-up costs would be less than the cost of government spending on managing ineffective culls. It would ultimately be a logical, cost-saving decision preventing waste and cruelty.
While the new government might be wary of not doing what some pro-cull rural voters want before an election, there are many more voters (rural and non-rural) who oppose culling, and who will support bringing it to an end. It is true that badger culling retains heavy support amongst niche livestock sectors, fuelled by government misinformation as to its value. The new NFU President has re-iterated his views on the need for badger culling to continue. But this support is misplaced, a result of a relentless campaign of poor information aimed at blaming for badgers for a significant role in the spread of bovine TB, based on weak and misquoted science. The position of Labour on the science of badgers and bTB is likely to consolidate with investigations into maladministration since 2010, and that is what should follow the decision to end badger culling for good very soon. In which case these costly legal actions need not proceed.
On 18th June, the BBC ran a story about Rishi Sunak on the election trail at an event In North Devon, where he was asked a question about his intentions concerning badger culling, should he remain Prime Minister.
Badger culling was not mentioned in the Conservative manifesto, but he laid his cards on the table, answering “culls have to be part of the solution”. The BBC wrote, “Mr Sunak said bTB outbreaks are at their lowest in 20 years and “part of that is because of the success of the badger culls.” The statement was confirmed by a video tape released by Farmers Guardian on the same day.
Sunak went on to say that “badger culls have brought down TB by just over 50%. That shows that the culls are working.” This despite the ink being hardly dry on a legal letter from Defra admitting that decline in TB cannot be attributed to badger culling and that not too much should be read into the Secretary of State saying so in the foreword of the recent consultation! This is a key point in the legal challenge that will move forwards shortly.
The current Government badger culling is based on the APHA’s publication Birch et al. (2024), published February this year. However, Mr Sunak is wrong to attribute reduction of disease incidence to badger culling. The new publication does not do this. Authors of Birch acknowledge (on careful reading) that the overall result cannot be attributed to badger culling: all disease measures implemented, including extensive testing, were analysed together. Crucially the expected comparison of culled and unculled areas was missing making the study of low or arguably no inference, given there was also some key missing information and over-simplifications. It is more likely that the cattle measures are causing reduction in disease than badger culling, because decline began well before culling was rolled out and in response to the introduction of annual SICCT testing in 2010. Other cattle-based measures were also introduced alongside culling.
Likewise, the BBC which has extensive ‘previous’ with mis-reporting of the badger culls, was wrong to state (again presumably from Birch et al) that badger culling cut bTB breakdowns by 56% after four years. A 56% reduction cannot be attributed to badger culling, as explained above, because that study was not designed to and was incapable of asking that question.
Mr Sunak said the Conservatives were “the only party at this election” committed to maintaining the cull. If this is the case, his seems to be the only party prepared to consistently misinterpret the science and misinform others about it.
Today the I News has mentioned what Labour might do, claiming culling might not be ended this year and also misquoting the Birch paper – you can see what a good job the government have done on fooling the media – good evidence for the legal challenge to the Consultation.
The outlet teased:
“i understands a Labour government will not interfere with existing contracts to carry out culling“
and that a Labour spokesman said:“
“The next Labour Government is committing to ending the badger cull and eradicating TB. We will work with farmers and scientists to introduce a TB eradication package rolling out vaccination, herd management and biosecurity programs to protect farmers’ livelihoods so we can end the killing of badgers.”
Is this a row-back on the earlier statement about the cull being ineffective? Difficult to say without clear evidence. What can be said is that a letter was sent today to Natural England and Defra asking for the the May licences and authorisations to be immediately revoked and for intensive culling to be ended too. After all, if they are ineffective as stated last week, they are unlawful.
DEFRA don’t want to vaccinate badgers, they want to keep killing them, against advice from Natural England.
As the first badgers of summer 2024 are being killed outright by a shot to the heart, or scream and die slowly in pain, a Freedom of Information response released on 31st May has revealed a morass of Government confusion. Communications between Defra and Natural England from April and May of this year show DEFRA contriving to carry on culling. By aligning with the views of its highly controlled ‘BTB Partnership’, and stalling the promised badger vaccination programme, that they have had four years to prepare for.
Dr Peter Brotherton’s (Director of Science at Natural England) advice in April, (see here), a response by Defra in early May (here), and final decision by NE (here) tell the story. NE’s response to the recent policy consultation (here), is also very revealing. Brotherton gives NE’s view on Supplementary Badger Culling (SBC) that are done after 4-years of Intensive culling, is that badger vaccination should be the best option to promote, based upon his view of the available scientific evidence :
“I can find no justification for authorising further supplementary badger culls in 2024 for the purpose of preventing the spread of disease and recommend against doing so.”
However, on 1st May, Sally Randall who is the Director General for Food, Biosecurity and Trade for DEFRA responded saying:
“The experience of the last three years has shown that whatever changes are made to disease control, those most affected by the disease, must have confidence in both the process and the trajectory. Changes need to be carefully timed and communicated, whilst balancing a range of potentially opposing views. Any abrupt changes to policy would seriously undermine our ability to engage constructively with the industry on future disease control interventions.”
The letter included an Annex A. with advice from APHA and the Chief Veterinary Officer, stating that Defra’s view was that SBC should continue until badger vaccination was fully viable, and that would take an unspecified amount of time. DEFRA said it had not gone far enough with preparations and that there was no financial capacity to promote it. They implied that farmers didn’t want it either. Then just two days later on 3rd May, Oliver Harmar, Natural England Chief Operating Officer, responsible for badger cull licensing at Natural England, decided to grant nine new Supplementary Badger Control licences and to authorise seventeen existing SBC licences in 2024, the decision having been passed by Tony Juniper and the NE Board. The licences were issued around mid-May.
But of equal importance, Brotherton made the following remarks:
“As I have said in previous advice, much greater effort is needed to raise awareness ofthe disease reduction benefits of the alternatives to culling among the farmercommunity, in my opinion. In this regard, it is disappointing that the recent publicationby Birch et al. 2024 has been widely reported as providing evidence that badger cullingreduces the incidence of bTB by 56%, when in fact the study shows the overall impactof implementing a range of bTB control measures, not culling alone. Further researchto establish the relative disease reduction contributions of the different controlmeasures is needed.”
This of course is the point made problematic by the crude and misleading ‘Abstract’ at the start of the APHA draft report (here) and following on with the published version (here). The recent Defra consultation on introducing so-called ‘targeted culling’ claimed that badger culling was responsible for herd incidence reduction, although it had no evidence of this. Brotherton is therefore disappointed by Steve Barclay, the Secretary of State for Defra and Defra Minister Douglas Miller and previous Defra Ministers. They have all seriously misled the public with badger cull claims and this is now a matter for legal consideration. Reductions in herd breakdowns could all have been down to tighter cattle testing and the accepted published peer reviewed and uncontested science on changes to herd incidence peaking and falling before badger culling was rolled out – and shown at the County level (2013-2019) suggests that this is most likely the case (see Langton, Jones and McGill 2022).
In previous High Court challenges over the future of badger culling, the ruling has been that decisions on culling can also be political decisions. If the future of badger culling is to be based on the science, then we will be seeing an end to culling very soon. Intensive, Supplementary, Low Risk Area, and Targeted culling are mistakes that should, and will be seen as such, and confined to the past.
While the disease benefit of badger vaccination is (like badger culling) not proven, the benefits of tighter cattle testing are well established. It is cattle measures done properly that will deliver the much needed bovine tuberculosis disease control for Britain and Ireland.
On 5 July the new Government must focus on advanced cattle testing, quarantines and lockdowns and consign badger culling to history, where it belongs.
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:
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.
Kamikaze bovine TB consultation – will it crash and burn?
On Thursday 28th March 2024 two solicitors’ letters were sent to the government. They express grave concerns over aspects of the Defra five-week badger culling consultation that began on 14th March, and attempts to bring about a policy u-turn on the phasing out of badger culling.
As readers may be aware from our recent blog, there is so much wrong with the proposal that it is hard to know where to start. Put simply, the Chief Veterinary Officer, currently Christine Middlemiss who is based at the Animal and Plant Health Agency (APHA) would be given sweeping powers to designate as many new cull areas as she and apparently a group of mostly farmers and cull companies think fit. This would be based upon currently obscure assumptions about how cattle herds have caught bovine TB in any area, yet with the finger wrongly always pointing at badgers.
Future decisions on initiating culls seem to rest around whether badgers share the same countryside areas (mostly they do because of the pasture landscapes) and whether they have the same bTB strain as the cows (mostly they don’t, according to the ‘Badgers Found Dead’ Edge and Low Risk Area surveys). Even if they do, an infected cattle herd may rapidly cause infection of the landscape, including many wild mammal species.
These decisions, to be made behind closed doors, will prevent the promised policy direction to ‘phase out’ badger culling. This phase-out said that the last cull authorizations would be for 2025, other than in ‘exceptional’ circumstances (we continue to oppose these ongoing intensive culls). But the new consultations would permit an unlimited number of ‘cluster’ cull areas across the whole of England. There would be unlimited badger shootings, over an up to seven month period annually, each year decimating healthy badgers in the hope of killing a handful of infectious ones. Totally unacceptable.
‘Cluster’ culling looks very much like the failed Low Risk Area, so-called ‘epidemiological’ culling, which has killed so many badgers in the Cumbria pilot without demonstrable effect (see ‘A bovine tuberculosis policy conundrum in 2023‘, chapter 5.). They are trying not to call cluster culling ‘epi-culling’ because of these failures.
What has become clear is that Defra are keen to muddle the effects of tighter cattle testing and movement control by saying that badger culling has contributed to the well-known reduction in number of herds being withdrawn from trading. But there is no scientific evidence of this, only good evidence that badger culling has shown no effect. Yet Defra and their agency APHA remain in denial. They claim in the consultation that a peer-reviewed published academic study finding no disease benefit is flawed, yet cannot provide the data or any analysis to prove their point. After two years, their public outburst is as useless as it was in March 2022, when their muddled attempts to undermine published science (the first attempt was withdrawn) came out.
Badger Crowd is in touch with Badger Trust and Wild Justice over a range of concerns over the lack of essential information for fair consultation. Responses from government so far have shed no light on questions asked.
Deadlines are coming up and further legal work is necessary, so an initial fundraiser was launched on Monday 1st April on the Crowd Justice website to fund the Badger Crowd legal work. Our fundraising target was reached by April 11th and the fundraiser has now been closed. Thank you very much to all who have supported. If we are advised by our legal team that we have good grounds to seek a Judicial Review, we will need to launch another fundraiser to cover the costs of this. Thank you for your support.
We are the Badger Crowd. We always stand up for Badgers.
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.
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.
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.
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 Partnership’ to 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 don’t 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, that’s just 8 herds still non OTF by 2032. I don’t 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. That’s not a partnership, it’s 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 weren’t 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 can’t 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 didn’t 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 couldn’t 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 didn’t 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’?
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.
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.
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.
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.
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 
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.