Defra outlines a refreshed bovine TB control badger strategy.

Defra has today (30th August 2024) announced plans for a refreshed bovine TB control badger strategy. Whilst it is good to see a clearly stated intention to stop culling badgers, that this will not happen before the end of the current parliament (2029) is completely unacceptable. These plans propose five more years of badger culling, all without sound scientific basis, and would result in the total number of culled badgers exceeding 300,000, all with no measurable disease benefit.

It is equally disappointing to see proposals for mass badger vaccination to be employed as a tool against bovine TB in cattle. This is an unwelcome, and scientifically unjustified continuation of the badger blame game. The scientific evidence just does not support the continued focus on badgers as a significant source of bovine TB in cattle, despite ill-informed media reports in recent weeks. It is a complete waste of resources when the real need is to retrain vets on the science of bovine TB and wildlife, over which they have been misled for many years, and to change cattle testing policy.

While we welcome the statement that “The full strategy will be co-designed with farmers, vets, scientists and conservationists”, we are somewhat sceptical about how inclusive this will be. There has been no engagement with scientists involved in important peer-reviewed science (here and here), despite frequent requests for meetings or at least dialogue. Will there be continued resistance to accept published science that challenges the views of those civil servants at Defra who have been pushing un-evidenced, expensive and unethical policy for so long?  An uncomfortable history of bad decision making by those who need to stand aside to allow genuine progress.  

Not mentioned in the statement, is the 22nd August consultation on licensing of a new badger cull  in the Low Risk Area (LRA). It looks likely that Labour are not just re-authorising existing licences, they are planning to start new licences in new areas, this one in Cumbria in the Eden valley north and east of Penrith. This will have a 100% cull objective, repeating the failed epi-cull of the immediately adjoining area, the subject of a report last year (see here).  There are rumours that two further LRA culls may be licenced this autumn or next, possibly in Lincolnshire and Hertfordshire / Bucks and who knows where else?  

Here is the Defra announcement in full:

 

Government to end badger cull with new TB eradication strategy  

  • First Bovine TB strategy in a decade to end badger cull and drive down TB rates to protect farmers livelihoods
  • New holistic approach will ramp up cattle control measures, wildlife monitoring and badger vaccinations
  • Proposals co-designed alongside farmers, vets, scientists, and conservationists to beat TB that devastates livestock farmers and wildlife

Work on a comprehensive new TB eradication strategy has been launched today (30 August) to end the badger cull and drive down Bovine Tuberculosis (TB) rates to save cattle and farmers’ livelihoods.   

Over the past decade, TB has had a devastating impact on threatened British livestock and wildlife. Over 278,000 cattle have been compulsorily slaughtered and over 230,000 badgers have been killed in efforts to control the disease, costing taxpayers more than £100 million every year. 

For the first time in over a decade, the Government will introduce a new bovine TB eradication strategy working with farmers, vets, scientists and conservationists to rapidly strengthen and deploy a range of disease control measures.   

The new strategy will mark a significant step-change in approach to tackle this devastating disease, driving down TB rates and saving farmer livelihoods and businesses. It will use a data-led and scientific approach to end the badger cull by the end of this parliament.   

The work to end the badger cull starts immediately and includes:     

  • First badger population survey in over a decade: The last major badger survey was carried out between 2011-13, leaving policy makers with no clear idea of the impact culling techniques have on our badger populations. The Government will work at pace to launch a new survey this winter to estimate badger abundance and population recovery to illustrate the impact of widespread culling over the past decade.  
  • New national wildlife surveillance programme: After a decade of culling, the prevalence of TB in remaining badger populations is largely unknown. The development of a new national wildlife surveillance programme will provide an up-to-date understanding of disease in badgers and other wildlife such as deer. Together with updated estimates of badger abundance, this will unlock a data-driven approach to inform how and where TB vaccines and other eradication measures are rapidly deployed to drive down TB rates and protect farmers’ livelihoods.   
  • Establish a new Badger Vaccinator Field Force: Badger vaccinations create progressively healthier badger populations that are less susceptible to catching and transmitting TB. A new Badger Vaccinator Field Force will increase badger vaccination at pace to drive down TB rates and protect badgers.   
  • Badger vaccination study: To supplement the Field Force, the Government will rapidly analyse the effect of badger vaccination on the incidence of TB in cattle to encourage farmers to take part and provide greater confidence that doing so will have a positive effect on their cattle.  

In addition, we will accelerate work on the development of a cattle vaccine, whichis at the forefront of innovative solutions to help eradicate this disease. The next stage of field trials will commence in the coming months. Our aim is to deliver an effective cattle TB vaccination strategy within the next few years to accelerate progress towards achieving officially TB free (OTF) status for England.   

The full strategy will be co-designed with farmers, vets, scientists and conservationists. It will consider a range of further measures including boosting cattle testing, reducing the spread of disease through cattle movements, and deploying badger vaccination on a wider, landscape scale. This will build on Professor Sir Charles Godfray’s 2018 independent strategy review.  

Minister for Food Security and Rural Affairs, Daniel Zeichner said:   

“Bovine tuberculosis has devastated British farmers and wildlife for far too long.  

“It has placed dreadful hardship and stress on farmers who continue to suffer the loss of valued herds and has taken a terrible toll on our badger populations.   

“No more. Our comprehensive TB eradication package will allow us to end the badger cull by the end of this parliament and stop the spread of this horrific disease.”   

Chief Veterinary Officer Christine Middlemiss said:   

“Bovine tuberculosis is one of the most difficult and prolonged animal disease challenges we face, causing devastation for farming communities.   

“There is no single way to combat it, and a refreshed strategy will continue to be led by the very best scientific and epidemiological evidence. With the disease on a downward trajectory, we are at a crucial point. Working in collaboration with government and stakeholders will be the only way we achieve our target to eradicate bovine tuberculosis in England by 2038.”  

John Cross, chair of the bTB Partnership said:   

“As chair of the bTB Partnership for England, I am delighted to hear Minister Zeichner’s intention to refresh the current bTB strategy. Ten years after its launch, the time is right to look again at the tools we use to tackle this persistent disease.  

“Bovine TB is the common enemy, not farmers or wildlife groups. Only by working together, will we reach our goal.”   

 The government will also publish additional information about animal and herd-level bTB risk – for example, the date and type of the most recent TB test completed in the herd of origin of that animal and how long the animal has been in the herd.  

This greater level of detail will be made available on ibTB – a free to access interactive map set up to help cattle farmers and their vets understand the level of bovine TB in their area and manage the risks when purchasing cattle.  

Today’s announcement ensures the government meets its manifesto commitment and represents a new direction in defeating this disease that will both protect the farming community and preserve wildlife.    

Notes to editors:  

Existing cull processes will be honoured to ensure clarity for farmers involved in these culls whilst new measures can be rolled out and take effect.    

The Bovine TB Partnership is a stakeholder-government collaboration established as a driving force for further progress towards disease eradication.  It is made up of experts from government (Defra, APHA and Natural England), as well as farmers, veterinarians, scientists, academics, and ecologists/conservationists, including representatives from the National Farmers Union, British Veterinary Association, British Cattle Veterinary Association, and the National Trust.

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More or less? Truth, life and 56%

August 2024

In life generally people crave the truth, learn from the truth and act on the truth. Truth is the universal source for learning, where trust develops, and where solutions to tackle the myriad of challenges that life throws at us are fostered.

Yet, we all know that absolute truth is a fickle thing. As time passes, new insights evolve, things change. Gradually we may find that what we thought we knew is conditional on certain things, right only some of the time, or even wrong for a clever reason.

So care is needed, especially with the big decisions where large amounts of money, time and effort are employed to address a particular issue or problem.

Take for example the culling of badgers. A Government expert [1] concluded 20 odd years ago that a very small trial study [2] suggested badgers might spread bTB to cattle, especially if frightened away from the setts where they live, and shooting them would help.

Sounds ridiculous? The entire livestock industry eradication policy in GB and Ireland has been based around ‘badger blame’ for the spread of Bovine tuberculosis among cattle herds for two decades. There has been over £2 Billion of subsequent spending and hundreds of thousands of badgers have been culled around a truth that is now uncomfortable to lose, because so many people have enthusiastically believed and embraced it. They own it, and accepting it is wrong messes badly with what they have said and done over the last 20 years.

The matter came into sharp focus in March of 2024, just weeks before the general election was called, with a Government Agency staff academic paper on badger culling effort [3] in England since 2013. This, followed shortly by a DEFRA Public Consultation [4] aimed at extending badger culling for a decade or more, over further huge areas, but with even fewer constraints on when, where and how.

To the general public this is all a mystery. Surveys show that the public largely think that badger culling ended in 2020 when Government said it was ‘phasing it out’, and the new government’s election manifesto view [5] that it has been ‘ineffective’ means it will stop for good. But actually, in the cold night air, from Cornwall to Cumbria, guns with silencers are steadily slaughtering tens of thousands of badgers each autumn. As harvest 2024 is concluding, the culling is now ramping up yet again.

So what about the truth? Well Steve Barclay MP, the old Defra Minister, one of the few seniors to keep his seat during the Labour landslide, had claimed in an ebullient foreword to the March consultation, that a 56% benefit has been gained after four years of culling badgers down to under 30% of their numbers.

So let’s unpack the truth in that. Firstly, the key time marker in all this is 2016 when the first of ten large cull areas were all up and running and followed by around 60 more at a starting rate of around ten a year. Unfortunately for unpicking science and truth, this was also the time that more intensive cattle testing began ramping up. So telling between the effect of culling and testing is not possible, despite what Barclay claimed.

‘Ah’, say the boffins at the Government Agency for badger culling. ‘But without killing badgers, the cattle tests wouldn’t work so well.’

At this point most people switch off….’ I dunno…suppose it’s possible…I’m not that interested  actually….’ It’s one of those speculation moments that is only so interesting given that the facts and alternatives are beyond the non-specialist’s reach and require weeks of fact-checking. This is indeed a complex issue, even for interested parties to consider.

So where did Barclay’s view come from? Well, back in 2012 the coalition government encouraged an academic paper in 2013 [6] that was timed to support badger culling, and that printed its truth, as a part of the justification for mass badger  culling. The paper said a few things that we now know were right and wrong thanks to good old Captain Hindsight.

Right, was that the old small study had been rendered meaningless by a horrendous Foot and Mouth disease outbreak in 2001 [7] that mucked up the experiment’s need for ‘stable countryside’ to be able to monitor change in three of the ten areas – enough to spoil the results. The hapless NFU encouraged rapid restocking with untested TB infected cattle, firing up the bTB epidemic.

Wrong were the calculations that rested upon a belief that cattle do not give bTB to badgers. It was thought to be TB moving all one-way, from badger to cattle, that Defra believed in those days, something that was always suspicious and that modern studies now show is wrong [8-11].

And questionable too was a theory, to try to make the numbers add up in a way no one has ever explained and that looks implausible. That theoretical infections going from badger to cattle are somehow passed on more rapidly than those originating from cattle. Baffling?

Lost already? Well to make the old small study work, the boffins believed that while around 94% of disease was the result of cattle-cattle infection, around 6% was down to badgers. Unfortunately, wildlife groups have believed and utilized these figures, despite warnings, not realising it is part of a dubious study that blames badgers and the king pin in justifying the badger culls since 2013. The so called ‘onward transfer’ of infection from badger to cattle is akin to a biblical myth with no scientific legs, yet it became the truth that key people in Government believed. It was held up as the science to believe in, forming and promoting the badger cull policy. Most cull objectors had realised this by 2016.

Back to Barclay’s 56% and the boffins new paper in March 2024. Despite elaborate graphics, this was a pretty rough-and-ready analysis, looking at before and after culling and substantial cattle testing improvements in the first few years of application, and attributing the decline in herd TB breakdowns to a combination of badger culling and herd testing. It stated (twice) that it is not possible to say which factor caused the change. Yet in a discussion of the results it also said the results were consistent with effects of badger culling seen during the small study, and studies using the small studies assumptions, and this speculation found itself in the paper summary (abstract) at the front.  This now gives an opportunity for apparent disease benefit to masquerade as fact or truth. Hence Barclay and the National Farmers Union ramped up the rhetoric on ‘Badger Culling Works’, and quoted the 56% benefit as a function of badger culling. Not bTB control – the better description of the mix of things being tried. Without evidence. Sunak picked up the mantle and did the same in a shed with farmers shortly before he lost office at the general election.

But the truth, as pointed out by other senior academics observing, is that these public statements were untruthful. Change might or might not have been assisted by badger culling – the very question the small RBCT study 20 odd years ago was supposed to resolve when it came up with a split answer – it possibly does and it possibly doesn’t. Flip a coin. And the real truth is that badger culling could be having some effect or it might all be down to tougher testing and movement control. Saying badger culling helped from 2013 or was pivotal or a catalyst is a bit like any of the innumerable causation arguments that created problems in science before they were recognized for what they were during the 1960’s [12].  Association is not the same as causation. Would anyone propose that Donald Trump being elected as President in 2016 caused bovine TB to start to fall? Well it happened at the same time, and bTB has come down since………..Or was the fall in TB the result of a general switch to tougher testing?

The problem for truth in this case is that Governments need to make decisions, and where there is uncertainty they need to have a plan. But Government scientists presenting their opinions as fact, for politicians and stakeholders to believe and to repeat, is a deception. A dangerous step and something that needs weeding out by journals employing peer-reviewers. And hopefully not by mournful inquiries years later, charged with working out how it all went wrong. The problem here is that there are few people experienced enough to understand and judge boffin science, and so you find your mate reviewing your work, and you review your mates work, and bad habits develop. Bovine TB science is plentiful and this syndrome sees awkward material published quite often; it provides a good exemplar of the issue called the reproducibility crisis [13]. All the Government scientists need to say is we ‘think’ it might be working because…. that is a long way from saying it ‘is’ – think snake oil salesman. It matters, it matters a lot when lots of lives and money are at stake. It matters because lying to the public is undemocratic and wrong.

So if someone asks you about badger culling, you might just say – ‘well its complicated and I don’t know.‘ But if they pick up a gun to shoot a badger, you might just say ‘hang on – I think you might be breaking the law’. Which requires evidence, and sufficient clarity that mass killing badgers to prevent the spread of bovine TB can be justified. And after 20 years there is no truth to suggest it does, only guesswork. However, cattle testing and movement control has worked in England and Wales without badger culling, so using that proven remedy is justified with some confidence and is an honest approach, if truth be told.

References

1. King, D. 2007 Bovine tuberculosis in cattle and badgers. A report by the Chief Scientific Advisor, Sir David King, to the Secretary of State for Defra on 30 July  2007. 

2. Donnelly, C. A. et al. Positive and negative effects of widespread badger culling on tuberculosis in cattle. Nature 439, 843–846 (2006).

3. Birch, C. P. D. et al. Difference in differences analysis evaluates the effects of the badger control policy on bovine tuberculosis in England. Sci Rep 14, 4849. https://doi.org/10.1038/s41598-024-54062-4 (2024).

4. DEFRA 2024 Bovine TB: Consultation on proposals to evolve badger control policy and introduce additional cattle measures. A consultation exercise contributing to the delivery of the government’s strategy for achieving bovine tuberculosis free status in England..

5. Labour Party manifesto https://labour.org.uk/change/        

6. Donnelly, C. A. & Nouvellet, P. The contribution of badgers to confirmed tuberculosis in cattle in high-incidence areas in England. PLoS Curr. 10, 5 (2013).

7. Private Eye 2001 Special Report. Not The Foot And Mouth Report. London

8. Biek R, O’Hare A, Wright D, Mallon T, McCormick C, Orton RJ, McDowell S, Trewby H, Skuce RA, Kao RR. Whole genome sequencing reveals local transmission patterns of Mycobacterium bovis in sympatric cattle and badger populations. PLoS Pathog. 2012;8(11):e1003008. doi: 10.1371/journal.ppat.1003008. Epub 2012 Nov 29. PMID: 23209404; PMCID: PMC3510252.

9. Crispell J, Benton CH, Balaz D, De Maio N, Ahkmetova A, Allen A, et al. Combining genomics and epidemiology to analyse bi-directional transmission of Mycobacterium bovis in a multi-host system. Elife. 2019;8

10. Akhmetova, A; Guerrero, J; McAdam, P; Salvador, LC; Crispell, J; Lavery, J; Presho, E; Kao, RR; Biek, R; Menzies, F et al. 2021. Genomic epidemiology of Mycobacterium bovis infection in sympatric badger and cattle populations in Northern Ireland. bioRxiv 2021.03.12.435101; doi: https://doi. org/10.1101/2021.03.12.435101

11. van Tonder AJ, Thornton MJ, Conlan AJK, Jolley KA, Goolding L, Mitchell AP, Dale J, Palkopoulou E, Hogarth PJ, Hewinson RG, Wood JLN, Parkhill J. Inferring Mycobacterium bovis transmission between cattle and badgers using isolates from the Randomised Badger Culling Trial. PLoS Pathog. 2021 Nov 29;17(11):e1010075. doi: 10.1371/journal.ppat.1010075. PMID: 34843579; PMCID: PMC8659364.

12. Hill, Austin Bradford. “The Environment and Disease: Association or Causation?.” Proceedings of the Royal Society of Medicine 58 (1965): 295.

13. Baker, Monya, 2016, “1,500 Scientists Lift the Lid on Reproducibility”, Nature, 533(7604): 452–454. doi:10.1038/533452a

 

 

Brian May – The Badgers, the Farmers, and Me

Brian May: The Badgers, the Farmers, and Me’ is a documentary that was aired on BBC2 at 9.00pm on Friday 23 August, and is now available on the BBC iplayer. Filmed over 4 years, the programme charts Brian May’s journey as he explores the ongoing battle against bovine tuberculosis, and the differing views of both farmers and those who oppose badger culling .

The new film covers 12 years of practical research ongoing over the last 12 years. The shocking truth around the monumental failure of Defra to effectively address the problem of bovine TB  is highlighted, and the resulting tragic slaughter of both cows and badgers is revealed with horrible clarity.

Animal campaigner Brian May and Anne Brummer, CEO of May’s Save-Me organization, have spent the years since culling was first mooted by David Cameron’s government uncovering the truth about bovine TB. Rather than fighting the farmers, May and Brummer have looked at the problem from the viewpoint of the farmer and the vet , following a case study which has transformed a chronically infected cattle herd into a healthy herd with TB-free status. This was achieved without killing a single badger. The revolutionary methods used are now known as the Gatcombe strategy.

Meanwhile, over the same period, nearly a quarter of a million badgers have been killed on the basis that they spread bTB to cattle. This new documentary shows that the badger cull policy implemented since 2013 has failed farmers completely. Rates of bTB infection and consequent numbers of cattle slaughtered are in some areas no better, and in others worse than ever, following the cull. The work from the case study farm in the documentary clearly shows with that blaming badgers has been a wildly incorrect reading of the facts.

May and Brummer conclude that the very idea that badgers are part of the bTB re-infection process is unsupportable. Government and NFU policy has been based on the work of a small number of scientists who have persisted in claiming disease benefit  from  statistical models, ignoring the uncertainty around them, and doubling-down when challenged.

This new documentary is the first time that an alternative view about badger culling has been presented in documentary format. Do watch it for a sincere, refreshing and honest take on badger culling. It goes to the heart of the problem, and shows compassion for the farmers, the cattle and badgers. And it provides answers and a way forward. Congratulations to all involved.

 

RBCT uncertainties debate gains momentum

On December 13th 2022, a preprint was put up on the ResearchSquare platform. Entitled ‘Absence of effects of widespread badger culling on tuberculosis in cattle’ [1], it was a reanalysis of the Randomized Badger Culling Trials (RBCT). Following a protracted period of review, with a number of very long silences, and relatively few revisions, it was published in Nature Scientific Reports on July 15th 2024 (Torgerson et al 2024) [2]. Finding a major anomaly, it uses a range of statistical models to re-examine the RBCT data  and concludes that most standard analytical options did not show any evidence to support an effect of badger culling on bovine TB in cattle.

Torgerson et al 2024 [2] noted that the statistical model selected for use in the original study in 2006 [5] was one of the few models that did show an effect from badger culling. However, various model assessment criteria suggest that the original model was not an optimal model compared to other options available. You can read a short blog on the new Torgerson et al paper here, and the full paper is available here. Essentially, the more appropriate models in the latest study strongly suggest that badger culling does not bring about the disease reduction reported.

Following publication, the new analysis [2] was mentioned in an article in Vet Times on July 24th, and in Vet Record in their 3/10 August edition. Neither publication noted its major significance. No other mainstream media reported on it at all. This is perhaps surprising since the government badger cull policy rests all but entirely on the conclusions from the RBCT. It is the science that DEFRA has used in court to defend their decisions to experiment with culling. It is the science that has resulted in 11 (12 including 2024) years of intensive and supplementary badger culling across huge areas of England, and around 230,000 dead badgers. In other words it is the pivotal piece of work for the decision-making around badger culling policy.

The reluctance of the media to report further on Torgerson et al. is a prelude to work by two of the authors of the original 2006 analysis (Christl Donnelly and Rosie Woodroffe) together with a DPhil Statistics student at Oxford University (Cathal Mills), who had, at the time of publication, two rebuttal papers in press with Royal Society Open Science [3,4]. Unusually, the abstracts and supplementary information for these new papers were posted online and available to view before publication without the main text. Enquiries regarding the posted information and the main papers resulted in in press versions being helpfully forwarded. The new analyses from Mills et al. are entitled An extensive re-evaluation of evidence and  analyses of the Randomised Badger Culling Trial (RBCT) I: Within proactive culling areas [3], and  An extensive re-evaluation of evidence and analyses of the Randomised Badger Culling Trial II: In neighbouring areas [4].

Published on August 21st, the two new papers largely duplicate the analyses in Torgerson et al 2024, but use different model assessment criterion to come to a different conclusion. In fact they double-down on the conclusions of the original 2006 analysis: “…we estimate substantial beneficial effects of proactive culling within culling areas, consistent with separate, existing, peer-reviewed analyses of the RBCT data.”

So in the year and a half since the posting of the Torgerson pre-print [1], Mills, Woodroffe and Donnelly have been working on their rebuttal to it. Torgerson and his team have looked through the in press versions of the Mills et al (2024) publications [3,4] for a few days and multiple problems stand out. In particular:

  1. Incorrect statements regarding disease control outcomes since 2010
  2. Use of a non-peer reviewed publication
  3. Confusion between the offset and overdispersion leading to incorrect calculation of disease exposure
  4. Incorrect and confused statements regarding model comparisons
  5. Exaggerated claims during use of new modelling.
  6. Failure to address the modern interpretation of SICCT test reactors
  7. Failure to recognise the onward effect of the analytical failure on multiple subsequent publications and policy outcomes.

Somewhat unusually, the new Mills et al papers do not refer to or cite the published Torgerson et al paper [2], only the first pre-printed version of Torgerson et al. from 2022 [1]. So in essence, the new Mills et al papers [3,4] are out of date at the time of publication, failing to refer to the updated 2023 preprint or the final version in  Scientific Reports published 15th July 2024 [2]. Following contact with the Royal Society, a response raising concerns with the newly published papers is being written and will be submitted shortly. An interim report has been put together by Torgerson and Langton with brief observations on the new papers (see here).

The Royal Society says it is committed to reproducibility. Reproducibility is the ability of independent investigators to draw the same conclusions from an experiment by following the documentation shared by the original investigators [6]. The issues identified in [2] and “rebutted” in [3,4] illustrate one of the major issues of the reproducibility crisis: poor statistical inference. It is hoped that the conclusions of this exchange will inform future bovine TB intervention policy this autumn.

References

[1] Torgerson P, Hartnack S, Rasmusen P, Lewis F, Langton T. 2022 Absence of effects of widespread badger culling on tuberculosis in cattle. In Review. (doi:10.21203/rs.3.rs-2362912/v1)

[2] Torgerson, P.R., Hartnack, S., Rasmussen, P. et al. Absence of effects of widespread badger culling on tuberculosis in cattle. Sci Rep 14, 16326 (2024). https://doi.org/10.1038/s41598-024-67160 (available: https://www.nature.com/articles/s41598-024-67160-0)

[3] Mills CL, Woodroffe R, Donnelly CA. 2024,  An extensive re-evaluation of evidence and analyses of the Randomised Badger Culling Trial (RBCT) I: Within proactive culling areas. R. Soc. Open Sci. (doi:10.1098/rsos.240385)

[4] Mills CL, Woodroffe R, Donnelly CA. 2024, An extensive re-evaluation of evidence and analyses of the Randomised Badger Culling Trial II: In neighbouring areas. R. Soc. Open Sci. 11:240386.

[5] Donnelly CA, Woodroffe R, Cox DR, Bourne FJ, Cheeseman CL, Clifton-Hadley RS, Wei G, Gettinby G, Gilks P, Jenkins H, Johnston WT. Positive and negative effects of widespread badger culling on tuberculosis in cattle. Nature. 2006 Feb 16;439(7078):843-6.

[6] Gundersen Odd Erik 2021The fundamental principles of reproducibility. Phil. Trans. R. Soc. A. 37920200210

 

 

Why are we waiting?

Things are starting to become slightly clearer as we near the point of discovery over the future of badger culling in England and beyond. Consultees to the online Defra Consultation  questionnaire of 14th March were told this Monday (5th August) that an analysis of Consultation responses will be published in the autumn (Sept-Nov?) giving more time for policy development without badger culling. But there is no reason now to delay clarification on the big 56% lie surrounding the ineffective badger culls.



 

Notably, the NFU appeared fully taken in by the spin from the Animal and Plant Health Agency paper by Colin Birch and Defra, that badger culling ‘is working’. Birch et al. follows on from a paper published in Veterinary Record in 2022 that showed quite neatly how recorded bovine TB levels (recorded OTF-W incidence)  peaked after the introduction of annual tuberculin testing in 2010 and began dropping in the High Risk Area from 2013 in some counties and generally by 2015. And, at a steady rate that did not increase once badger culling started (and that was more widespread from 2018), showing no evidence that badger culling had contributed to a slow decline of around 6% per year. 

Steve Barclay, and previous Environment Ministers before him, had made wild claims of a culling benefit of around 50%, based on APHA parroting the claims made since the 1970s that this is the badger contribution to cattle TB. This has always been a poorly evidenced, lame and far-fetched claim, making a mockery of professional epidemiology.

Not to be fooled, Labour are onto the problem and have firmly labelled badger culling as ‘ineffective’ in their manifesto. They have highlighted the need to work with farmers and scientists which is now the helpful – but not very specific – new Defra mantra.

The Birch paper makes it quite clear in two places that the cause of the welcome decline in bTB first identified formally in 2022, cannot be attributed to any particular intervention, be it better testing, different tests and more frequent tests, better biosecurity or badger culling. It is just a crude before-and-after effort with no controls, showing what was already known in a slightly clunky way. This is no help at all, as Professor Macdonald at Oxford pointed out in his November 2023 ‘state of the science’ review. However, the unfortunately misleading abstract for the Birch paper transmutes opinion into ‘fact’, to give the casual  reader a misinformed overview of the findings. How very CVO.

So what are we left with as we approach the time of Labour’s big reveal this month? Firstly, an increased interest in badger vaccination with Defra organising a media spree with its dutiful contractors to suggest a direction of travel that Natural England seem to think is appropriate.

Also, news from Oxford, where a 50,000 signature petition to the School of Biological Science, organised by the Oxfordshire Badger Group calling for increased academic engagement seems to be working. A response to the Torgerson et al. 2024 paper on the choice of models for analysis of the Randomised Badger Culling Trial data, published  recently in Scientific Reports is imminent. The Torgerson paper wallowed rather oddly for 18 months in peer review, emerging little changed, so plenty of time for the RBCT folk to have prepared.

How the 50 something % cull benefit lie has been peddled in recent months and years:

Farmers Weekly: Badger culling policy reduces cattle TB by 56%, study shows 

Farmers Guardian, Farming matters: Lord Robert Douglas-Miller – ‘The science is clear that the tide is turning on bovine TB’ 

Shrewsbury Conservatives, DANIEL KAWCZYNSKI MP MEETS WITH MARK SPENCER, THE MINISTER OF STATE FOR FOOD, FARMING, AND FISHERIES, URGING HIM TO TAKE TOUGHER ACTION TO REDUCE CASES OF BOVINE TUBERCULOSIS:  

Parliamentary Question response from Mark Spencer: To ask the Secretary of State for Environment, Food and Rural Affairs, what assessment her Department has made of the (a) effectiveness of badger culls in tackling bovine TB and (b) reliability of the TB test used to identify cattle for slaughter; and what estimate her Department has made of the (i) annual cost of bovine TB in Shropshire and (ii) level of bovine TB in that county. 

 

Natural England’s rationale for licensing ineffective Supplementary Badger Culling

Peter Brotherton, Director of Science at Natural England, issued his “Advice to Natural England’s Operations Team on Supplementary Badger Culling 2024” in April 2024, see here. It was released under Freedom of Information at the end of May.

So how is supplementary culling being justified?

Brotherton considers that the ‘key insights’ arising from his appraisal are that “disease reduction benefits to cattle achieved through badger culling are sustained in the long term (likely at least 7 years post-cull).” And what is this based on? Brotherton says:

“The most relevant evidence to the current English situation is from Donnelly (2013) who found from the Randomised Badger Control Trial (RBCT) that the disease reduction benefits from four years of intensive culling of badgers are greatest 1-2 years post-cull and are sustained for at least 7 years, albeit at a diminishing level over this period.”

Professor Paul Torgerson, Chair, Veterinary Epidemiology, University of Zurich

The problem for this justification now, is that Donnelly (2013) (an unpublished report) is overturned by the new peer-reviewed paper by Torgerson et al (2024). Published since Brotherton issued his advice, “Absence of effects of widespread badger culling on tuberculosis in cattle” has shown that the original RBCT analysis (Donnelly et al 2006) used an inappropriate calculation of rate, when face value calculation of rates was available. When rates are calculated in the standard way, no effect of culling was found. Many subsequent studies, like Donnelly & Nouvellet (2013) which recycle the approach of that analysis should now be considered unsafe. There are dozens, possibly hundreds of them.

Brotherton also references two small studies, Byrne et al 2014 (4 areas in Ireland) and Clifton-Hadley 1995 (2 areas in south-west England) which he acknowledges may be less relevant to the current English context. They are too small in scale to be able more than anecdotal or provide any certainty. They certainly should not be used as substantive evidence.

And that seems to be pretty much it in terms of published evidence. There is some speculation without evidence. There is a mention of badger vaccination reducing the prevalence of bTB in badgers, but any assumption of this reducing disease in cattle is not based on sound evidence. It should be noted that Natural England keep away from their ‘Uncertainty Standard’ that they previously reported as scrapped, but now seem to want to retain .. its all a bit uncertain at Natural England.

Notably, Brotherton does not refer to the main peer-reviewed and published badger culling  analysis Langton et al (2022) in his ‘rationale’, presumably favouring the Chief Vets unqualified comments. This compared culled and unculled areas after 7 years of industry-led badger culling (2013-2019) and found no measurable benefit.

Also of note is Brotherton’s recollection of the advice of the previous Chief Scientific Advisor Prof. Boyd, who “stressed the limits in the evidence base and the importance of adjusting the policy as new evidence becomes available.“ There is no sign that the evidence of peer-reviewed Langton et al (2022) and Torgerson et al (2024) is being recognized by NE yet.

Badger Crowd understands that Natural England have received a letter requesting that supplementary badger cull licences should be revoked on the basis of new published science. It’s well past time to stop the badger cull immediately on the scientific evidence, and not least the comprehensive peer-reviewed evidence.

Legal pressure grows as end to ineffective badger culls anticipated

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.

This is a legal challenge to the Defra consultation on targeted badger culling proposals that ran from March 14th to 13th May 2024.

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.

PM Sunak contradicts his legal position on badger culling. Further Labour comments reported too.

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.

This General Election, please campaign locally to help STOP the badger culls.



It’s just three weeks until polling day for the General Election. We need badger supporters to step up once again, and  to alert parliamentary candidates to the ongoing outrageous badger culls. There are two things to do:

Firstly contact your constituency candidates and ask them if they will stop the culls, if they are elected. You can find out who they are here. The Green Party have said they will stop badger culling, and Labour say they will “work with farmers and scientists on measures to eradicate Bovine TB, protecting livelihoods, so that we can end the ineffective badger cull”.  Please ask them all what their plans are and make sure they know that all forms of culling should stop from July 5th, with all existing licences revoked.

Secondly, please try to attend hustings. These are the political meetings that are held locally in your constituency, where you can meet your candidates, supply relevant information and ask them questions. Find out  where and when the hustings meetings are and make every effort to attend. Click HERE for access to a leaflet that can help give you guidance with facts about badger culling, carefully prepared by a team of dedicated badgerists from around the UK. You can print it out double-sided on A4, then guillotine in half to make A5 leaflets. (You may have to print on one side of the paper first, then reload it in the paper cassette the other way up & run through the printer again).



Good luck in your constituency. We hope newly elected MPs will be caring and compassionate and understand that on badger culling, much science has been questionable or misrepresented to promote badger culling.

We must stop the Cruel, Expensive culls. They Just Don’t Work.

Defra’s zombie killing machine won’t stop

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 of the disease reduction benefits of the alternatives to culling among the farmer community, in my opinion. In this regard, it is disappointing that the recent publication by Birch et al. 2024 has been widely reported as providing evidence that badger culling reduces the incidence of bTB by 56%, when in fact the study shows the overall impact of implementing a range of bTB control measures, not culling alone. Further research to establish the relative disease reduction contributions of the different control measures 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.

Defra scraps pre-election badger cull ambition

There has been a positive step forward.

Defra have responded this afternoon about how they are handling Tom Langton’s legal challenge to the recent badger culling consultation, that closed just before the General Election was announced last week. A Pre-Action Protocol letter challenged the lawfulness of Defra’s  ‘targeted badger intervention’ policy consultation for several reasons and today Defra were responding about their intentions in the weeks to come.

Defra said they are “continuing to analyse consultation responses with a view to putting proposals for a decision on this policy to the incoming government after the election.”

This is good news at least in the short term. A new policy will not be put in place by the current Conservative government. But it also implies that Defra may seek to defend the claim that the consultation was unfair, which is disappointing.

Defra also say that they want an extra two weeks to consider the PAP letter, but we will learn their position on 14th June. Defra should drop the consultation,  recognise its failings and accept that badger culling has no future at all in bovine tuberculosis control in cattle.

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Responses to consultation questions: some thoughts:

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

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

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

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

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

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

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

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

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

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

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

Yes

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

Any information on disease risk should be publicly available.

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

  1. Strongly agree

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

Any information on disease risk should be publicly available.

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

Here is your chance to offer your full view.

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

WE ARE THE BADGER CROWD