Defra Badger Cull Consultation

What does it say and mean?

On 14th March, Defra launched a new consultation:

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

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

SUMMARY

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

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

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

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

We feel this consultation is unlawful and should be withdrawn and as such cannot recommend anyone responding until further advice has been received.

Consultation Foreword by Steve Barclay Secretary of State for Defra.

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

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

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

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

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

PART A – BACKGROUND

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

PART B – PROPOSAL 1

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

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

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

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

What are the future badger killing consultation proposals in general?

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

How will cluster/cull areas be chosen?

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

Badger vaccination – the new bolt-on

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

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

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

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

Other changes:

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

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

Nothing changes:

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

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

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

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

Strange?

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

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

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

PROPOSALS 3 and 4

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

Annex A: Wildlife disease control – Progress since 2020

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

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

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



Veterinary Record exposes yet more government bovine TB failings

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

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

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

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

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

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

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

The DEFRA Bovine TB Partnership: Shambles or Scandal?

Dick Sibley removed from the Governments BTB Partnership

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Dick Sibley goes on to cite an interesting case study:

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

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

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

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

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

Sibley’s thread finishes with:

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

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

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

The Partnership has a number of responsibilities:

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

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

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

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

3. Co-design potential new policies and communications

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

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

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

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

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

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

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

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

Does it do this? Apparently not at all.

Chairman James Cross, a farmer, might be asked:

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

References

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

Defra’s consultation on the 2020 ‘Next Steps’ badger culling policy

In recent years Defra have made no secret of the fact that they aim to continue badger culling after the current intensive culls finish at the end of January 2026. The 2020 bovine TB policy outlined the intention to continue badger culling in ‘exceptional’ circumstances. APHA have been piloting a new ‘reactive’ style culling policy that aims to kill 100% of badgers, otherwise known as epidemiological culling or ‘epi-culling’ in Cumbria and Lincolnshire. 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 persistent infection in a handful of farms.

‘Epi-culling’ has been licensed by Natural England since 2018 despite its ongoing failure. Badger Trust was told by Lord Richard Benyon (Minister of State at Defra) in written correspondence, and by Eleanor Brown (now deputy Chief Veterinary Officer) at a meeting, that a consultation on this new epi-culling policy would be launched this year. This now seems not to be the case. In this recent article in VET Times, a Defra spokesperson was asked whether the anticipated consultation would begin before Christmas. The reply was “we are working to provide further detail at the earliest opportunity.”

Initially it was thought that the consultation would be in winter 2022 or Spring 2023. This was delayed to Summer, then Autumn, and then the middle of November. It may yet appear, perhaps this winter, but indications are that Defra are rethinking.

The National TB Conference in Worcester on 29th November might have been an opportunity to set out Defra’s intentions going forward. The programme for the event listed senior speakers/participants including Lord Benyon (Defra Minister), Christine Middlemiss (CVO) and James Wood (Head of Department of Veterinary Medicine at Cambridge), long-time supporter of badger culling. But Lord Benyon did not even turn up, & it was left to a few of the pro-cull vets to make statements on their personal ‘views’ about the success of badger culling. Perhaps they had hoped that APHA’s pre-print on the effects of badger culling might have been published by now. But there are serious issues with this analysis, see here and here.

So why has the consultation on epi-culling been delayed? Are Defra beginning to realise that badgers are not a significant player in bovine tuberculosis after all?

Three possibilities………

  1. The epidemiology of bovine tuberculosis science does not support their position on epi-culling, (see this independent report). APHA’s latest epidemiology report has changed its method of assessing attribution of disease, (see here).
  2. The science behind culling is uncertain & becoming frailer. A peer-reviewed paper in 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 (see Langton et al 2022). Following on from this analysis, a pre-print looking at the original RBCT analysis found that alternative & more appropriate analyses of the data found no effect of badger culling (Torgerson et al).
  3. There will probably be a General Election next year. Pushing out a consultation on a scientifically fragile badger cull policy, that is also cruel, potentially ecologically damaging and economically unsound is not a vote-winner for a political party. A majority of the public remain opposed to badger culling.

Meanwhile, in the House of Lords on December 12th, Conservative peer Lord Colrain, asked “What progress they have made towards identifying a vaccine for eradicating bovine tuberculosis?” Labour peer Lord Granchester took the opportunity to quote a reduction of 51% in herds under restriction in Cheshire, appearing to claim this as a win for badger culling, and suggest  that it would make sense “to allow all areas of England to undertake a cull to control disease in cattle, disease in badgers and stress in rural communities before introducing vaccination?” He failed to mention that Cheshire has actually had more gamma testing than any other county in the country as shown in the bar chart below. It is the increased use of gamma testing that is most likely responsible for the observed decline in herd breakdowns. 

It is still a bit unclear what Labour will do with bovine TB policy if they are elected to government in due course, with their messaging inconsistent at present. Shadow Defra Minister Steve Reed recently told journalists at the Countryside Land and Business Association conference that there is enough reason to believe that badger culling is a way of preventing transmission, so “in the short term we have to continue with that”. Sue Hayman (former Shadow Environment Minister) meanwhile said at the launch of a Wildlife Link report recently, that badger culling would be brought to an immediate end. Current Shadow Environment Secretary Daniel Zeichner was quoted in The Guardian (here) in October saying “I’ve spent a long time looking at this…….We’re going to make England bovine TB free by 2038, but with a range of measures that do not include culling.”

None of this is satisfactory. Secrecy cloaks every move, and stakeholders remain outside what should be an open and careful discussion of the various technological and economic options. It is in no one’s interest to let factional lobbying and secret deals continue with the wasteful and cruel outcomes seen over the last ten years.

We have now reached the point where a handful of pro-cull lobbyists are promoting their ‘views’  on the success of badger culling and making statements that are simply not borne out by the facts. Dick Sibley (a vet who has worked on alternative bTB testing approaches), in a recent letter to Vet Record, comments on “the unfortunate paucity of scientific evidence” that currently underpins current advice, and concludes that “the effect of the mass killing of hundreds of thousands of badgers has been disappointing, to say the least”.

The latest government epidemiology summary shows that half of breakdowns are now herds with embedded disease, herds breaking down for a second, third or more times. Why? Because infection is not being caught by conventional testing. It is not that hard to work out why public money has been frittered over the last ten years on a policy with no end point. It has been deemed just too tough to grasp the nettle and get on with the difficult and expensive job of better testing and some herd depopulation, with farms left fallow for several years. This reality cannot be put off any longer and the economics of a new campaign need to be clear for all to consider, with relevant measures to achieve prompt bTB control, not decades more of subsidised nonsense.

Has APHA finally seen the TB light?

A shift of emphasis

Was it the damning April report on the failed Cumbria badger culls that has led to the clear change in the way that APHA’s is now attributing source of bTB infection in cattle? Have the crazy proposals for the so-called ‘epidemiological culling’ policy been recognised for the epidemiological nonsense that they are?

Or is it simply that the raft of Whole Genome Sequencing (WGS) results clearly indicate cattle movements as the main distributor of bovine TB? Either way, the new epidemiology report for England published this November shows a dramatic shift of emphasis in the attribution of source of infection.

While previous APHA reports have laboured to claim that around half of cattle bTB infections are attributed to badgers, the analysis for 2022 of the results of ‘bovine tuberculosis epidemiology and surveillance in England and Great Britain‘, published earlier this week (20th November) (read here) tells a different story.

Outrageous attribution

It looks like the death knell for the perpetually dodgy and unscientific ‘Risk Pathways’ approach that was so heavily slated in the April report by independent scientists earlier this year. Risk Pathways was introduced in 2017, as evidence to cull badgers across the whole of west England and more. Every APHA ‘epi’ annual report since 2017 has contained a table with the consequence of condemning badgers to more culling.

Now, with the speculative nature of the approach well exposed, APHA have no choice but to do what they should have done before badger culling began – shift emphasis to the necessary cattle testing and herd management. These are the only measures that will actually move bovine tuberculosis in cattle towards elimination using the right cattle tests from the cattle testing toolbox.  

See below in the 2021 analysis: the first column claims outrageously high attribution of source of infection to badgers, at over 50%.

In this years table for 2022 (see below), the column has gone, and the switch to uncertainty is complete.

Compare the pies

Compare also, the pie chart of disease sources from 2021 (below) with that for 2022 (below that). Where once badgers were getting 52% of the blame, 56% is now shown ‘blank’ – effectively showing as uncertain.

What is concluded from this welcome, but far too late in the day revision? The ridiculous blaming of badgers was just too unevidenced, too ridiculous. APHA can no longer deny that evidence now points to the source of bTB infection being all but totally from livestock and livestock infected pastures. And it can only be addressed by livestock measures.

APHA’s hopeless Disease Report Form (DRF) to coax vets into naming badgers as a cause of new cattle infections was heavily criticised by a Derbyshire Wildlife Trust veterinary report in 2019. In their supplementary file, also recently released, APHA now say:

 “A new Disease Report Form (DRF), for recording cattle TB incident investigations, is under development. This aims to enhance data capture and review the methodology around how we assess source attribution to improve understanding of TB transmission pathways and the evidence base for biosecurity advice.”

Whole Genome sequencing can now be used to better understand transmission routes. There is no excuse for anything but bringing all badger culling to an immediate and permanent stop.

Setting out the truth about badgers in black and white

The Northern Ireland Badger Group together with the USPCA has published a new factsheet on dispelling the myths on the role badgers play in the spread of Bovine TB (bTB).  This follows a recent court outcome which has stopped a proposed badger cull in Northern Ireland.

Last month, both organisations welcomed the ruling from a judge that a badger cull proposed by the Department of Agriculture, Environment and Rural Affairs (DAERA) as part of its drive to tackle bovine TB, would now not proceed.

This new factsheet provides dispels the myths on the role badgers play in the spread of Bovine TB.  It adds to a growing evidence base that culling badgers is not the answer to bTB.

Nora Smith, Chief Executive of the USPCA said:

“Last month, we welcomed the court’s decision as a positive step in protecting Northern Ireland’s diverse wildlife and badger population. The unnecessary killing of helpless badgers by free shooting will do nothing to address the problem we have faced for years with bovine TB.

“We have full sympathy for our farming community who have been devastated by the impact of bovine TB on their herds and who have been led to believe a cull of badgers will play a leading role in solving the problem. It will not.

“The latest evidence reaffirms the highest rate of transmission is cow to cow. There must be a new conversation around how we eradicate bovine TB and the focus must be on cattle movements, testing and biosecurity. In Wales, which has a more robust strategy to protecting both cattle and badgers, they have seen a marked reduction in bTB, while their badger population remains intact. 

Mike Rendle, Northern Ireland Badger Group commented:

“The recent court ruling has forestalled the pointless killing of large numbers of badgers in Northern Ireland. It is now beyond any doubt that cattle to cattle infection is driving bovine TB in herds. There is no credible evidence that badgers play a significant role in disease spread.

“The problem lies with the reservoir of undetected infection in cattle. The current skin test, which may detect as few as half of the infected animals in a herd, is not fit for purpose. Farmers and cattle deserve better.

“I hope that by dispelling misconceptions about badgers and instead following the latest scientific evidence, we can all work together to develop an effective evidence-led policy to deal with the disease while protecting farmers’ livelihoods as well as our badgers.”

Read the new factsheet here.

What next for Northern Ireland’s bovine TB strategy?

As Northern Ireland’s Department of Agriculture, Environment and Rural Affairs (DAERA) considers the fallout from the recent court judgement quashing their plan to shoot badgers in Northern Ireland, what does the future now hold for their bovine TB strategy?

DAERA’s current policy carried forward the main elements of the strategy proposed in 2016 by the government-appointed TB Strategy Partnership Group (TBSPG). The TBSPG was a government-industry partnership which included senior industry figures and former civil servants. Notably, no member of the group had any expertise or background in badgers or wildlife.

Soon after its appointment, the TBSPG met with stakeholders to ‘seek their views’. Even at that early stage, the TBSPG made it clear that they thought a badger cull was necessary. There was a clear impression that they had already decided on a badger cull before any evidence-gathering or engagement, meaningful or otherwise, had taken place.

The TBSPG was succeeded in 2018 by another industry-led group, the TB Eradication Partnership (TBEP), under the same TBSPG Chairman. Similarly, the TBEP exhibited equal enthusiasm for a badger cull, with apparent little regard for the views of the badger/wildlife side. You can read about the TBEP membership in this Protect the Wild blog.

Following the recent successful Judicial Review taken by Wild Justice and the Northern Ireland Badger Group, any further attempt by DAERA to progress a badger intervention will require a new public consultation. Given the shambolic nature of the last consultation, any new proposal will require root and branch revision to have any chance of succeeding.

Meanwhile, two major pieces of significant and highly relevant new research have emerged.

Firstly, a comprehensive analysis of bovine TB data by Langton et al. failed to identify a meaningful effect of badger culling on bovine TB in English cattle herds. Instead, reductions in cattle TB incidence and prevalence showed a strong correlation with the introduction of cattle-based disease control measures.

Secondly, a study carried out by scientists at the Northern Ireland Agri-Food and Biosciences Institute (AFBI) found that cattle-to-cattle transmission was by far the most common form of disease spread. Cattle-to-badger transmission was considerably more common than badger-to-cattle transmission, and no badger-to-badger transmission was detected.

The science makes it increasingly clear that ineffective herd testing and the two million cattle movements annually are driving the persistence and spread of bovine TB in Northern Ireland, not badgers. As the body of evidence exonerating badgers builds, DAERA will surely struggle to justify any new badger removal proposal.

As it turned out, DAERA’s (now defeated) decision to implement an indiscriminate and cruellest possible badger cull was a spectacular own goal and a decisive setback to their bovine TB strategy. The responsibility for this debacle lies squarely with the architects of the strategy and those in the industry who supported and enabled it.

Perhaps predictably, the decision to inflict unacceptable suffering on large numbers of healthy badgers served to galvanise the conservation and animal protection sectors in opposition to the plan.

For its part, the badger side has seen its good faith and willingness to engage thrown back in its face. Confidence and trust in the process have been seriously undermined. The government has squandered yet another opportunity to make meaningful progress.

This is a watershed moment for DAERA and the industry. They can choose to embrace the science and tackle the reservoir of undetected infection in cattle, or they can continue to scapegoat badgers and face further legal challenges and delays.

APHA, evidence and distortion – the badger blame game continues

A new analysis of Bovine TB data by the Animal and Plant Health Agency

“Difference in Differences analysis evaluates the effects of the Badger Control Policy on Bovine Tuberculosis in England”, by Colin P.D. Birch, Mayur Bakrania, Alison Prosser, Dan Brown, Susan M. Withenshaw, and Sara H. Downs.

This new analysis was posted as a pre-print on 6th September, on the ‘bioRXive server. You can view it here, although there is no access to the data to check it.

With the current programme of intensive badger culling winding down and coming to an end in 2025, up to a quarter of a million largely healthy badgers have now been killed. A new consultation on Defra’s intentions going forward under the 2020 “Next Steps policy is expected on or after 16th November. This new scientific paper has therefore been constructed at an important moment for the future direction of new bovine TB policy.

Both Therese Coffey (Secretary of State for Environment Food and Rural Affairs) and Lord Richard Benyon (Minister of State for Biosecurity, Marine and Rural Affairs) have said in public and in correspondence that badger culling should continue. Mark Spencer, (Minister of State for Food, Farming and Fisheries), has been using the Birch et al pre-print in parliament to claim large disease reductions from badger culling.

But how certain is the science behind these claims of disease reductions, and the stated intentions to carry on culling badgers?

In a 30 minute presentation available to view on YouTube here, Tom Langton talks through recent scientific pre-prints and publications that have analysed bovine TB in cattle herds and badger culling. Inevitably it is a technical presentation as the issues and the statistics involved are complex. But at this critical moment, as bTB policy is further revised, the controversy and uncertainty surrounding the science of bovine TB control needs even closer scrutiny.

Rescheduled! Friday 24th November Badger Cull Protest – 10 Years On


Originally scheduled for 20th October, the ’10 Years On Badger Cull Protest’ had to be cancelled due to Storm Babet. But we are ready to go again on Friday 24th November.

The early years of the badger cull from 2013 saw over 50 protest demonstrations and walks in towns and cities around England. Badger lovers, nature conservationists and members of the public were incredulous and angry that the government was sanctioning a slaughter of tens of thousands of healthy iconic badgers on the basis of a weak scientific theory that badgers were significantly involved in the spread of bovine tuberculosis in cattle. Many famous names from the world of animal protection and wildlife TV programming turned up to add their voices to the public opinion strongly against the government policy promoted by then Environment Secretary Owen Paterson.

But those in charge of policy ignored the protestors. They were listening to more powerful lobbying voices in the farming industry and to land-owning politicians who spoke out strongly in favour of badger culling and through neglect, the continuing trade in infected livestock.

Ten years on, and despite suggestions that badger culling would be phased out, it has never been more intense. A new consultation on further, more intensive (100%) badger culling is promised before the end of the year. With an election coming up next year it is time to protest again. We need to make sure those who make horrific decisions about our treasured wildlife know that despite all the other critical issues affecting the UK today, we are still shocked and angry about this brutal, unscientific and immoral policy, wasting public funds for vested interest gain – and it will affect how we vote at the next election.

Dominic Dyer will with us on the day, with further speakers to be announced.

IF YOU CARE, PLEASE BE THERE!

Belfast Court Rules Northern Ireland Badger Cull Plans Were Flawed

Mr Justice Scoffield has quashed the NI government attempt to introduce controversial  badger culling to Northern Ireland. Granting a judicial review brought by wildlife NGO’s funded by public donation, he said that  consultees were not told enough – and in sufficiently clear terms – to enable them to make an intelligent response in the consultation exercise. The ruling concludes:

“The court was unimpressed by the respondent’s argument that disclosure of the business case would be too complicated or distracting for would-be consultees,”

“The fact that consultees did their best to respond on the basis of the more limited set of information which had been disclosed to them does not alter the respondent’s obligation to act fairly.”

In September 2022 year Legal Campaigners Wild Justice with Northern Ireland Badger Group (NIBG)  were granted a High Court hearing at the Royal Courts of Justice in  Belfast to challenge a cull of badgers in Northern Ireland HERE and HERE.

This legal claim contested a decision announced in March 2022 by the Minister for Agriculture, Environment and Rural Affairs (DAERA), Edwin Poots, to allow killing of up to 4,000 badgers a year along the lines that DEFRA has been mass killing healthy badgers in England since 2013. The primary target was a decision of 24 March 2022 – set out in a statement made by the Minister that day and in a ‘Bovine Tuberculosis Strategy for Northern Ireland’ published by the Department shortly afterwards.

The claim brought was that consultation on the policy was incorrect and did not reach the requirements of lawful consultation. So, the decision to choose to control the badger population by allowing farmer-led groups to shoot free-roaming badgers was unlawful. The judge agreed.

The claim argued that Mr Poots’ decision is unlawful because he issued the Article 13 (power to destroy wildlife) order under the Diseases of Animals 1981 Order, but that he had not made sure that there was no reasonably practicable alternative way of dealing with bovine TB in Northern Ireland.

Finally, the consultation had proposed shooting badgers as a preferred option, based on a “business case” which was not disclosed as part of the consultation documents. Because of this the consultation was not a fair procedure as those consulted were prevented from having a properly informed response without seeing it. Comparisons with Test Vaccinate Remove (TVR) approaches had not been fairly made and an APHA position that firmly place TVR approaches “on a par with proactive culling with respect to impact on cattle herd breakdowns”  was not properly addressed.

As previously reported, with the help of the Northern Ireland farming industry press, the farming sector was being hoodwinked into thinking that badger culling could somehow help them. DAERA had been busy promoting badger culling with ‘roadshows’ making exaggerated claims, disseminating misinformation and use other propaganda tricks to try to garner cooperation.

All the lessons from England including the question marks over government badger culling science, going back to the 1990s are relevant too.  It was barely possible to believe, after year-on-year failure in England and the Republic of Ireland, that DAERA wished to ignore their inadequate cattle controls and cull badgers over the next 10 years across Northern Ireland.

Also proposed was an element of experimental badger vaccination after the mass slaughter, a policy that government appointed experts in England in 2018 said was an unproven approach to the control of bTB in cattle.

DAERA may decide to appeal the decision or more likely to reconsult with a business plan that they have held secret, and will no doubt need to rewrite. Will they now go down the TVR route or cull and TVR – this too would be a huge mistake? With the present absence of an Executive and sitting Assembly at Stormont, it is unlikely that authorisation could be given in any case, even with a new consulted plan. What DAERA should do is think again. Even more new science has emerged since the claim began, showing why badger culling policy science has gone so badly wrong and culling badgers in any way is unnecessary.

Huge congratulations to Northern Ireland Badger Group and Wild Justice for bringing the case and to all those supporting the case and opposing the flawed consultation process.

Defra’s last stand?

APHA show a little bit of their hand at last

In March 2022, a peer-reviewed analysis of badger culling data was published in a top veterinary journal. It used all publicly available data.  It showed no detectable difference in bovine TB breakdown between badger culled areas and unculled areas since 2013 (1). Now, after a government information black-out following their look at the data up to 2017, the Defra’s Animal and Plant Health Agency (APHA) have at long last posted a pre-print of their own creation looking at their secretly held data up to 2021.

It is not clear why it has taken so long to release this new analysis, a draft of which was presented at a conference in August 2022 (2).

Cynics might say there has been a search for obscure statistical methods to get the results needed to try to show a badger culling has not been a 100% failure. And of course, it supported the pro-cull rationale to hold data secret and keep quiet about any weakness in policy. This served to enable the 2022 and 2023 killings of over 50,000 mostly healthy badgers, planned and executed by the willing and obedient hands of Natural England (3).

The new pre-print, posted 6th September in ‘bioarchive’ (bioRxiv), is by six members of APHA staff. It tries to use an obscure technique: “Difference in Differences analysis evaluates the effects of the Badger Control Policy on Bovine Tuberculosis in England” to look at Bovine TB breakdown incidence (Withdrawn herds: OTFW) between 2009 and 2020 (4). There are many aspects of this new analysis which are problematic, but here are a few of the more obvious.

A new statistical method of analysis – ‘Difference in differences’ (DID)

This is the first time the DID approach has been used in badger cull analyses and it is simply inappropriate. DID compares the changes in outcomes over time between a population that is enrolled in a programme (a group subject to an intervention) and a population that is not (the control group).

The attempt here is to use the same areas in a ‘before and after’ way. There is no clearly defined control group, it is just the fragmented cull areas before they are licensed to cull. The 52 cull areas are surrounded by and influencing each other during a wide range of tightening testing interventions. They are, therefore, not adequately discrete in space and time, breaking a fundamental DID requirement. So not only is this (DID) an unorthodox approach, but it does not follow the basic rules of the unorthodox approach. It is looking a bit desperate already.

Notably, in the period 2016- 2020, pre-cull and cull areas closely juxta position. Pre-cull and cull cattle testing interventions of course influence changes in adjacent pre-cull and cull areas in an irregular and unpredictable manner, via the constant movement of cattle with different testing and control histories. It’s a mess, and surprising that this has been presented as an appropriate statistical method, considering the subject and the epidemiology involved.

Analysis does not distinguish between different causes of disease decline.

Does the analysis decisively link badger culling to decline in bovine TB in cattle? Not at all. Any possible effect of badger culling is confounded with the continuous multi-faceted and complex tightening of cattle testing that took place in an uneven manner over different and irregular time periods. Some of the very important bTB testing controls used, and the timing of their introduction, are incorrectly described and some of the most important ones are not even mentioned.


The Badger Culling Policy invention

There are places in the manuscript where a claim is made for a link to badger culling, ‘The effect of badger culling…’, but then later this is adjusted to ‘However, this data analysis cannot explicitly distinguish…….’ APHA have stated more than once in their recent epidemiology reports that the cattle breakdown data alone are insufficient to show an effect of culling.

Frankly there is no such thing as the ‘Badger Culling Policy’ (BCP) as framed by this report, beyond just killing badgers. It is an invention trying to characterize extensive cattle testing and movement control measures as just a part of the badger culling bolt-on, rolled out six years after testing control measures had been continuously tightened year on year. To pretend the extensive suite of testing and movement control measures is somehow a part of a whole is just a repeat of the ‘all tools in a box’ nonsense and it deceives. True, some of the more essential measures were increased from the first year of badger culling, but most of them were independent of it and ramped up gradually. So trying to pull them apart in a post-facto try-on will not impress the independent scientist, even if an obliging journal prints it, and industry and Defra promote it with their coterie of academic cheerleaders. Badger culling has just been a pointless distraction to cattle surveillance and control measures to address rampant cattle-to-cattle transmission.

So again, no, the analysis is not able to show causation by badger culling of any change in disease, and Defra and APHA’s judgement could be seen ill-judged by trying to convince anyone that this is credible. It is as clumsy as the Chief Vet’s apologies and efforts on Radio 4’s Farming Today in 2022. Defra boss Richard Benyon has been claiming big figures for badger cull benefits for years, but this does not provide any evidence for them.

What is the ‘true burden of disease’?

The new analysis has a surprising and unconventional interpretation of the ‘true burden of the disease’ or disease ‘prevalence’ in a population. It suggests that ‘incidence’ is the better indicator of true burden, which they must surely understand flies against first principles. It is ‘old thinking’ based on the out-dated views of farm vets who claimed that only visibly lesioned cows are infectious.  Yes, incidence  has been one unit of disease measurement, and it was the unit used by the RBCT to claim a benefit for badger culling. But science has moved on, and this is a strange attempt to live in the past.

The interpretation contrasts with APHA’s reports and understanding of disease controls if you look closely. It contrasts with the conclusions drawn from better comprehension of the SICCT (skin) test sensitivity and specificity, which has been clarified in recent years. Gamma IFyN testing has revealed a very significant reservoir of undetected reactors (diseased animals) in bTB infected herds, pointing towards undisclosed infection in undetected herds too. This ‘hidden’ reservoir in cattle that remains is what really matters for disease understanding and control. The true burden is bigger than the known breakdowns and identified reactors, why else would the disease persist? Both here and in Republic of Ireland where badgers have been relentlessly persecuted and SICCT and Gamma testing has failed for decades.

So why exactly did APHA attempt this clumsy redefinition of the ‘true burden of disease’. Perhaps because it needs to try to defend the original RBCT analysis which by controversial statistical modelling (5), managed to suggest a relationship between incidence and badger culling, having failed to find a relationship with disease prevalence. The effort applied to carry on killing badgers is deeply disturbing.

But wasn’t bovine TB already reducing before badger culling began?

Levels of Bovine TB were falling in many areas soon after annual SICCT testing was introduced in 2010. And well before culling started in most areas. However, the new APHA analysis reduces the analysis of pre-cull data to one data point. This conveniently helps to conceal the significant pre-cull decline and masks the true disease trajectory and results. A logarithmic scale is also used to distort visual effect. Not unlike methods used in the earlier Brunton and Downs reports.

Recent Edge Area data added into the analysis for what purposes?

The new analysis mixes data from 46 High Risk Area study areas with 6 from the Edge Area. These have very different epidemiological and disease control history profiles and the reason for mixing them is not explained. It looks like a deliberate attempt to manipulate the data. Pre-cull gamma testing was intense in the Edge Area. While the manuscript mentions additional gamma testing from 2017, gamma testing was erratic between areas and over time. There were considerable numbers of gamma reactors in many of the cull areas in cull years 1 and 2 of culling with similar disclosures levels to years 3 and 4, but pre-cull use in the HRA was generally low. Mixing them may give you a result you like, but it can be seen through for what it is.

In both HRA and Edge areas, bTB incidence was declining when many of the additional disease control rules were intensified, and badger culling introduced. The addition of this extra data makes it even more impossible to distinguish effects of badger culling and disease control measures that are known to drive down bTB.

Attempt to dismiss peer-reviewed 2022 study published without mentioning it

A comment in the text of the new pre-print says that it is not possible to match badger culled and control areas. This is not only incorrect but unevidenced, with unsubstantiated claims. The 2022 published and peer reviewed study that used this methodology effectively has not been cited. There is no mention of the even more obvious alternative to their complex DID approach, which would be to simply match a series of individual farms in culled and unculled areas. This approach is only available to APHA, which holds all individual farm records confidentially. Such simple monitoring could and should have been an expected outcome of a High Court ruling that required the government to ‘adapt and learn’ from badger culling. Why has it not been done? Perhaps it has been done but gave the wrong results?

Distinct lack of clarity

There is a definite need for clarity in the analysis presented, including the Appendix. This does not seem to be the output from the constrained DID analysis, but something else that is not fully described in the methodology. Analysis uses the lesser known system called STATA (nearly all analysts use R-code).  The data is not supplied, and the Stata code is not supplied, so no one can replicate what has been done here. An author, when contacted, said these would be available following publication of the paper. Too late for others to comment on?

Does this draft show that badger culling has reduced bovine TB In cattle?

No, it doesn’t. Because the methods are inappropriate, the results are flawed, and so the conclusions are wrong. There is no way to distinguish between different interventions and change in herd breakdowns since 2013 with the approach taken. Might these results be misleading and deceive if published? Yes. Why has such a flawed analysis been produced now? Is it a try-on to justify Natural England’s new autumn badger blood-fest? Will Defra contractors, grant recipients and a friendly journal whisk it through peer review with recommended friendly reviewers? Probably.

A consultation on culling all badgers over wide areas is being cooked up despite previous policy promises. One could speculate that APHA have been told both by bosses and lawyers that they need to produce evidence that the culling policy has not been a complete waste of life, public funds, and other resources including masses of police time. They are desperate to do this, and get it out right in front of the move to ‘carry on culling’. This preprint aims to be the new truth about badger culling, but it’s all smoke and mirrors.

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. DEFRA called out over flawed bovine TB claims at international vet conference
  3. Bovine TB and Badgers: a weakened link
  4. PREPRINT: Colin P.D. Birch, Mayur Bakrania, Alison Prosser, Dan Brown, Susan M. Withenshaw, Sara H. Downs Difference in Differences analysis evaluates the effects of the Badger Control Policy on Bovine Tuberculosis in England.  bioRxiv 2023.09.04.556191; doi: https://doi.org/10.1101/2023.09.04.556191
  5. PREPRINT: Paul Torgerson, Sonja Hartnack, Philipp Rasmusen et al. Absence of effects of widespread badger culling on tuberculosis in cattle, 13 December 2022, (Version 2) available at Research Square [https://doi.org/10.21203/rs.3.rs-2362912/v2]

The Failed Badger Culls – a brief history and why the fight is not yet over.

Episodic and patchy badger culling has been taking place in England over the last 50 years in an attempt to influence the bovine TB epidemic in cattle herds. And there have also been several ‘experimental’ badger cull trials over that time, the largest of which was the Randomised Badger Culling Trial (1998-2005). The current ‘proactive’ intensive badger culls, where a guesstimated 70-95% of the badger population is killed, began in 2013. We have now had 10 full years of intensive badger culling across the High Risk Area, with over 210,000 badgers reported killed. There have also been experimental badger culls in TB hotspots in at least two places in the ‘Low Risk Area’, where the aim is to kill 100% of the badgers. Killing is now done largely by free-shooting, which is deemed inhumane by the British Veterinary Association because of the cruelty involved.

How is disease control going?

With variations between areas, the general trend for the bovine TB burden in cattle has been downward. However, this decline in bTB cannot be linked to badger culling as in almost all areas bTB rates levelled off and began falling in response to the move to annual cattle testing in 2010, before badger culling began.

Importantly, there has been a further increase in the frequency of cattle testing for bTB over the same period as culling has been taking place, which has begun to remove infected cows slightly more efficiently. Cattle are now tested every 6 months using the tuberculin skin (SICCT) test, and additional testing using Gamma Interferon tests have been introduced to  help remove more of undetected but infected cattle. It is this increase in frequency and efficacy of testing that has been reducing the rate of infection, not badger culling.

Analysis shows no difference in disease decline between culled and unculled areas

The most recent peer-reviewed and pubished analysis of the efficacy of badger culling has shown that there was no detectable difference in disease reduction between culled and unculled areas between 2013 and 2020. All that DEFRA has done is make a crude claim that badger culling works, based on reports  and data that it has  refused to publish or make available for many years and for spurious reasons.

What’s happening now?

Despite the near-complete government news blackout on badger culling, it is still very much government policy. It continues in 60 zones this year, reducing in number by around a third each year until 2025 when the final 23 culls will fizzle out. Natural England have once again authorised badger culling licences for autumn 2023 (announced September 7th). This will mean that up to 26,000 largely completely healthy badgers will be shot dead this year under their watch.

What are Defra’s plans for badger culling in the future?

New report on ‘epidemiological culling’

Despite headlines back in 2020 suggesting that badger culling was to be phased out, the likelihood is that Defra is being cajouled by industry to introduce a new badger culling policy. We understand that a consultation this autumn might seek views on a ‘reactive’, or so-called ‘epidemiological’ culling policy, a method with the core approach banned by government in 2003..

If implemented, this policy would seek to kill 100% of badgers in what are being called bTB ‘cluster’ areas. Although such culls are described in new policy as for ‘exceptional use’ only, it is possible or even likely that they will be implemented wherever bTB is found in cattle and where farmers want to kill badgers. Minette Batters, President of the NFU, has made no secret of her wish to remove badgers from livestock farmland completely, and Defra listen to the wishes of the NFU. The policy does indicate vaccination for any badgers that remain following culling, but this is a policy that clearly continues to attribute significant cattle infection to badgers. This, despite consistently growing scientific evidence for this being extremely unlikely, with weak, equivocal or even manufactured evidence keeping that sentiment alive.

Disease breakdowns continued in Cumbria despite 100% of badgers culled

A trial of this new ‘epi-culling’ approach has been taking place in Cumbria since 2018. Despite eliminating the entire badger population over an area of around 90 sq.km. or more, herd incidents with persistent infections remain unresolved. Bovine TB infection is persistent because it comes from within the herd and from traded stock. There is no credible epidemiological route for infection from badgers. This is useful as a model of why government policy is badly flawed and misguided.

What can we do to stop this?

Years of campaigning by numerous organisations and individuals has so far;

  • Led to legal challenges in the High Court of aspects of the welfare consequences of, scientific justification for, and potential ecological effects of badger culling
  • Challenged the certainty of the science being used to justify badger culling with peer-reviewed analyses
  • Lobbied MP’s repeatedly
  • Organised over 50 rally’s and marches
  • Produced many petitions of up to 300,000 signatories
Protesting outside High Court London

But Defra have not listened or even significantly engaged with those  opposing badger culling. They are listening to the NFU, the big landowners with a powerful voice, and vets who put their own interests and industry before environment, biodiversity & animal welfare. 

The increasing public awareness of climate change impacts and the immediate threat they pose have led to urgent calls to reduce meat and dairy consumption. This in turn should make government take a radical look at the farming industry in the UK, and the policies it is supporting that damage our natural environment. It looks like an impossible task with a government that has no qualms about supporting and subsidising the fossil fuel industry and counts many large land-owners with vested interests amongst its MPs.

Will an election in a little over a years’ time make any difference? Politician’s convictions seem to be increasingly fragile approaching a election, where the importance of green issues to the electorate may be unclear or even antagonize a proportion of it. Whilst polls show that voters rank the environment among the concerns of greatest importance to them, the Uxbridge byelection showed that these issues require careful handling.

Effective caps are needed to block wastefulness and overexploitation of limited resources for trivial activities and inefficient processes.  If candidates want your vote at the next election, the political parties & their candidates need to commit to a comprehensive overhaul of farming and environment policies. It is vital to make it crystal clear to them how important these issues are, or they will not commit to addressing them urgently. We may be stuck with badger culling and policies that continue to deplete our natural resources until it is too late to prevent catastrophic damage. Badger culling is just one more symptom of everything that is wrong in environmental protection in England in recent decades. Strong action is needed right now to change the way government thinks and acts. Everyone has a role to play in ensuring that those in power, and those seeking power, know how important environmental issues are, and how their response to them will affect the way we vote.