Tag Archives: badger culling

RBCT uncertainties debate gains momentum

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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?

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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

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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

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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.

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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.

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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

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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

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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?

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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

 

 

 

 

 

Defra Badger Cull Consultation

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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

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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?

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Dick Sibley removed from the Governments BTB Partnership

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

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

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

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

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

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

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

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

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

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

“To get the country OTF by 2038 as pledged by DEFRA, I understand we need to get 99.9% of herds tb free for 6 years. In the 3 counties with current herds, that’s just 8 herds still non OTF by 2032. I don’t think that is possible doing what we are currently doing.”

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

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

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

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

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

“We have tried really hard here in the South West: started culling badgers in 2016 and peaked in 2018: 90% of the area of the 3 counties culling by 2021. More testing, more gamma, more killing, more restrictions and yet 892 herds lost their OTF status last year. Is that success? Of those 892 new herd incidents, most of them weren’t new. They were recurrences of established infections. We used to blame the badgers, but we have now killed most of them. So, as many of us suspected, they are more likely due to undetected residual infections within the herd.”

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

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

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

“We listened, no decisions. Three quarters of the time taken up with presentations, then truncated discussions through lack of time. The rooms got smaller and smaller and tech more dysfunctional. Covid didn’t help. Frustrating”.

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

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

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

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

Dick Sibley goes on to cite an interesting case study:

“A small organic herd of red Devon beef sucklers: set up about 10 years ago. Before stocking the 200 acres of rolling Devon grassland, constructs 7km of badger and deer proof fencing. 2” mesh buried 40cm into the ground and going to 6ft+. Even Steve McQueen couldn’t get out.

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

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

We have got 4 day old calves testing positive for antibody! They didn’t make that themselves, they got it from the colostrum. But mothers tested negative. The offspring of some test negative cows (but designated high risk) have all gone as reactors. We suspect mother – calf”.

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

Sibley’s thread finishes with:

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

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

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

The Partnership has a number of responsibilities:

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

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

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

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

3. Co-design potential new policies and communications

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

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

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

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

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

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

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

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

Does it do this? Apparently not at all.

Chairman James Cross, a farmer, might be asked:

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

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