The Abstract of a paper on the potential harmful impacts of badger culling on other species and habitats in the Journal of Zoology (1) this year has been amended to better reflect the contents of the paper.
The original Abstract of the paper, whose authors include two Natural England employees working alongside researchers from the British Trust for Ornithology on licensing the culling of badgers, contained a sentence saying that badger removal ‘..has not affected bird populations..’. However, the important main conclusion from the work, and one better supported by the findings of the analyses, was rather different – that ‘A landscape scale, quasi-experimental approach is strongly recommended to provide stronger inference about the complex potential ecological effects of culling predators such as the badger.’
The changes reflect and highlight the paucity of effort that government has taken to investigate ecological impacts since mass badger culling began in 2013. Defra and Natural England escaped full judicial scrutiny earlier this year by a ‘smoke and mirrors’ approach to remaking an impugned decision to disregard side-effects on wildlife outside designated sites. Behind the backs of the claimant, and of the court (see here) they made just enough of a procedural correction to satisfy the judiciary. They kept their ’do nothing’ approach alive, at least until new powers arrive under the new Environment Act once that is enacted.
In recent weeks, Natural England have been approached via lawyers to address the issue of the ‘strong recommendation’ in the August 2022 paper. They have been asked how they have responded to the published finding that a different, larger scale approach is needed before the potential damage from badger culling can be properly assessed, when granting licences to mass-kill badgers over the wider countryside. Government’s entrenched position in 2021 was that ecological studies were too expensive, and it was ‘too late’ for meaningful research as badger culling is being phased out by 2025.
Such impacts are important when considering the fate of European Protected Species and those priority species and habitats afforded protection under the 2006 NERC Act. There are legal duties to fulfil.
Dominic Woodfield has provided expert advice and witness statements relating to challenges to Natural England’s defective approach to protecting nature in England when organising badger culling over the last five years, including High Court rulings where judges found that NE had been in breach of its statutory duty by neglecting nature conservation protection. He said:
“The abstract of a paper is the most public-facing element and often the only bit that gets read by busy people looking to gain a rapid insight into current science and issues. It is therefore very important that it is an accurate summary of the conclusions reached.
We don’t know whether the original authors or the Journal editors were responsible for the error of representation in the abstract in this case, but it is evident that the publisher now accepts and agrees that it was misleading and that it did not reflect the actual results and conclusions of the study. Perhaps incidentally, or perhaps not, it had the further effect of masking the inadequacy of the effort made by Natural England to investigate insidious but potentially significant side-effects on sensitive bird species arising from the Government’s badger culling policy – side-effects that remain a mystery after an unknown amount of money wasted on meaningless desk-top analyses.
The study actually, and inevitably, concludes with a statement that vindicates mine and others’ view that the approach being reported on is a waste of public money and tantamount to kicking the can down the road for fear of getting an unwanted answer. As a body no longer even semi-autonomous from Government, one might expect Natural England to want to ‘spin’ the presentation of the results, but if that is indeed what happened here, it would be a matter of much more concern that the BTO would seem to have been complicit in such actions.“
The correction to the abstract of the paper is shown below.
Abstract Since 2013, the Department for Environment, Food and Rural Affairs (Defra) has licenced culling of European badger (Meles meles) populations in several English regions. In the first 7 years, more than 100 000 badgers have been removed. It is critical to evaluate the ecological impact of severely depressing the population of a widespread predator from large areas of the country, such as effects on breeding bird populations. Citizen science survey data on the abundance of breeding birds supports the estimation of population trends, i.e. whether species are exhibiting population growth or declines, and the effects of potential environmental influences, such as badger removal, on these trends. Here, these survey data are used together with data on the presence and amount of culling in an area to explore whether removing badgers has an effect on breeding bird populations both inside and outside culling zones from 2013–2019. This is not equivalent to a controlled trial, but collects critical, landscape-scale evidence in real-world conditions. In analyses evaluating the effect of culling presence, 18 of 55 bird species showed significant or near-significant growth rate changes. Of these, four species had higher growth rates and 14 exhibited lower growth rates in cull areas, compared to areas outside of the culling zones. When using culling intensity data to assess the impact on growth rates, 10 of 55 species showed significant or near-significant results, with only one species exhibiting a higher population growth rate in the presence of more intensive culling. Predicted sensitivity to badger effects based on species’ ecologies did not predict whether the measured relationships were significant, or their directions, suggesting that other factors underlie the patterns seen. Hence, there was little evidence to indicate consistent, community-level effects of badger removal on bird populations. Reasons why this predator removal has not affected bird populations are discussed. A landscape scale, quasi-experimental approach is strongly recommended to provide stronger inference about the complex potential ecological effects of culling predators such as the badger.
This correction was added to the Journal paper on 4th November 2022.
Another chance to read an important guest article entiled; ‘Breeding Bird Survey (BBS) data, badger culls, Natural England and the British Trust for Ornithology: New paper, same old.’ by Dominic Woodfield that first appeared on Mark Avery’s blog on 23rd September
Dominic Woodfield is a highly experienced practitioner in Environmental Impact Assessment and Habitats Regulations Assessment. Most of his work is for the development sector, but he has also undertaken commissions for Natural England, the RSPB, Wildlife Trusts and campaign groups. He once mounted a succesful independent legal challenge in defence of an important site for butterflies in Bicester, Oxfordshire.
Most readers would, I imagine, concur that an increase in fox populations in places where there are vulnerable ground nesting waders and waterfowl might be a matter worthy of conservation concern and attention. Especially where such increases are substantial (as much as a doubling of numbers), and arise as a consequence of a specific controllable human intervention, such as culling up to 95% of badgers across large swathes of English countryside.
Natural England (NE), which issues the licences to cull badgers, is obliged by statute to assess the potential side effects of badger culling on other species. When it comes to designated sites – SACs, SPAs, Ramsar Sites and SSSIs – NE do (now) acknowledge that a ‘predator release’ effect (where foxes and other mammalian predators increase in number via backfilling the ecological niche vacated by culled badgers) is an impact risk. Under pressure from legal challenges since 2017, NE has developed detailed guidelines for such assessments, amended their assessment procedures and added restrictions onto licences to better take this risk into account and/or mitigate potential effects on such sites. But outside these sites and across the larger part of the countryside in cull zones, the same birds, as far as NE are concerned, are on their own. There are no procedures for assessment or protection.
The small group within NE that processes and issues cull licences describes the ecological risks associated with ‘predator release effect’ as a consequence of badger culling as “theoretical”. This is despite their being flagged as a risk worthy of further investigation in the wake of the Randomised Badger Culling Trial (RBCT) in 2007 (Defra 2007) and again in 2011 (Fera 2011). This loose end did not trouble the masterminds behind the current badger cull, which commenced in 2013, nor those responsible for cull licensing within NE. At least it didn’t until relatively recently. Ultimately, it took the pressure of tribunals and legal challenge and the scrutiny of the courts in 2018, five years after the cull had started and with tens of thousands of badgers already removed, to force the agency charged with protecting our wildlife to finally promise a High Court judge they’d look more closely at this issue.
It’s conceivable that NE then asked the Government, through Defra, to fund a proper study and the Government refused. We don’t know. But in any event the outcome was that instead of a properly designed and controlled investigation, NE elected to go ‘cheap and cheerful’. Behind a wall of secrecy, they commissioned the British Trust for Ornithology (BTO) to conduct a simple desk study, extracting subsets of volunteer data from the Breeding Birds Survey (BBS) for cull and non-cull areas, and comparing them to see if there were any patterns to be found that might be attributable to badger removal. When, in 2018, the BTO unsurprisingly reported to NE that nothing conclusive could be gotten from such a coarse approach (Kettel and Siriwardena 2018), NE chose to interpret that as indicative that there was no issue to be concerned about, and advised Ministers and the Courts the same.
This is all old news of course, especially for readers of my previous guest blog, kindly published by Mark on 18th June (see here). In it I criticised the methodology and utility of these desk-top analyses of BBS data, the secrecy around them, and how NE’s chosen ‘absence of evidence is evidence of absence’ interpretation was used to inform badger culling policy decisions at Government level, without the benefit of such ‘science’ being through independent peer review or subject to any public scrutiny.
One of the BTO scientists involved was piqued into responding (his remarks can be found in the comments section under the blog, again (here). Amongst a somewhat prickly defence of the study’s approach and methodology, he conceded two of the central premises underpinning mine and others’ concerns. One: that the study did little to answer questions about the wider ecological side effects of removing as much as 95% of the population of an apex predator across large areas of English countryside. And two: that ecological side-effects from removing badgers from the ecosystem were, to use his word, “certain”. Notwithstanding what those two concessions, when read together, say about the worth of this form of study, he said that he stood by it and furthermore that the BTO had been commissioned to repeat it in 2022.
The results of this repeat exercise have just been published in the Journal of Zoology. The paper is titled Ward et al. 2022 “Breeding bird population trends during 2013-2019 inside and outside of European badger control areas in England”. The abstract can be accessed here (but the full paper is behind a paywall). I encourage interested minds to read the full thing. Does it represent a robust way of finding out whether localised predator increases as a consequence of removal of badgers are having any impact on local populations of sensitive ground nesting species, such as lapwing, redshank, snipe or curlew?
My own thoughts on this question are below. Ward et al. 2022 essentially repeats the exercise carried out in 2018 and modified in Kettel et al. 2021, albeit with a slightly bigger data input. For me, the biggest difference is a much-improved discussion. Indeed, anyone who read my previous blog will observe that despite neither myself or any of the other more vocal critics of the 2021 paper (and its suppressed 2018 predecessor) being part of the peer review process, the discussion within the new paper rather reads as if we were! It attempts, at least, to respond directly to some of the criticisms of the methodology of analysis, the utility of the results and the inherent problems of bias, that were levelled at both Kettel et al. 2021 and Kettel and Siriwardena 2018.
In consequence, the authors are now more openly cognisant of the fact that studies this coarse-grained, data-limited and with such little statistical power, are never likely to detect impacts anything short of catastrophic for any individual bird species. It now also appears to be recognised by the authors that this sort of high-level approach inherently militates against the prospect of arriving at any conclusive answers to the fundamental question – is badger culling having a collateral ecological effect of relevance in conservation terms on any individual bird species?
All of which means NE have frittered away a further four years and paid the BTO an unknown quantity of public money to conclude, as Ward et al. 2022 does, that it’s not clear whether there is an effect or not and that answering the question would need better, more targeted investigation. The same conclusion reached fifteen years ago following the RBCT, again by Fera in 2011 and further reiterated by the Godfray Review of 2018 (Godfray et al. 2018). That a proper study is necessary and important. Not exactly revelatory – indeed it is no more than critics of NE’s lackadaisical approach to assessing the collateral ecological impacts from badger culling have been urging for years.
Although the authors’ discussion of the results in Ward et al. 2022 is an improvement on previous iterations, the continued application of a flawed methodological approach renders the study only marginally less worthless than its predecessors. The 2022 version remains, in particular, compromised by the decision to lump species at high risk of predation effects together with those at inherently lower risk, and by the inescapable fact that the BBS dataset is too coarse grained to provide a sufficient platform for sensible analysis for precisely the scarcer species – such as ground nesting waders – that should be a focus of concern. Instead, and in common with its 2018 and 2021 predecessors, the study contrives an ecologically nonsensical guild of “ground nesting” species on the basis of a single common parameter – that they construct nests generally within 0.5m of the ground. Thus, ecologically disparate species such as chiffchaff, herring gull and coot are homogenised into a single receptor with a standardised susceptibility to mammalian predation. The continued failure of the authors to properly explain, qualify or acknowledge the deficiencies of this approach is glaring. They either genuinely believe that vulnerable species such as lapwing, nesting on the ground, in open uncluttered environments such as arable fields, are at the same risk of predation from larger mammalian predators as a whitethroat in a bramble thicket, or they are wilfully building a massive source of obfuscation and bias into the methodology. Either way, it muddies the waters and fatally undermines the study.
Sadly, predetermined bias is not just restricted to the methodological design. It also infects the syntax of the discussion and conclusions of the paper. Most glaring perhaps is the abstract – the bit one can read for free – concluding with a wholly unsupported premise – that “this predator removal has not affected bird populations”. That might be the conclusion the authors from Natural England (and Defra) wish casual readers to take from the study, but for those who read the full paper, it’s not actually a conclusion supported by the analyses. I am surprised this statement survived the peer review process and that the BTO authors (at least) would allow such an unevidenced leap of logic. In contrast, the all-important last line of the conclusions calling for a landscape-scale quasi-experimental approach: “to provide stronger inference about the complex potential ecological effects of culling predators such as the badger” didn’t make it into the abstract. Strange that.
So, beyond the authors’ clearer acknowledgement of the fundamental limitations of the exercise, Ward et al. 2022 merely perpetuates the uncertainty that has presided over this question since the end of the Randomised Badger Control Trial, fifteen years ago. In other words, it does nothing to progress Defra’s, the Secretary of State’s, Natural England’s, conservationists or the wider public’s understanding of collateral ecological effects from badger culling any further forward from the position prior to the current cull starting in 2013. At all the junctures in time cited above, independent review has indicated that further investigation into the ecological side effects from badger culling was merited. All NE have actually done in the wake of their promise to a High Court judge in 2018 is commission a spectacularly coarse analysis which was never likely to deliver anything close to a useful answer, suppress the results for three years and now repeat it. A cynic might conclude that this is deliberate – a means to be seen to be doing something in the face of repeated legal challenges that exposed systemic failures by NE to properly assess impacts – whilst actually kicking the can down the road.
There is one paragraph worthy of note in the discussion of the results. Despite the continued determination of the authors to muddy the waters by casting the analytical net to include species of inherent low-vulnerability to predation by ground-based mammalian predators – such as nuthatch and green woodpecker (really, guys?), the authors do for the first time note and discuss separately the negative trends indicated for two of the species which actually ought to be the critical focus – lapwing and curlew. It is worthy of remark, at least, that such trends as there are for these species appear more or less consistently negative across all three iterations of BTO analysis. Finally, this has been remarked upon in Ward et al 2022. The problem of course is that this potential cause for concern should have triggered further targeted investigation – along the lines that the paper now suggests – much, much earlier. Not now, nearly ten years too late.
Repeating a near-pointless study again and again is, in my view, a poorly disguised exercise in obfuscation and delay. An excuse to do nothing more meaningful, just in case that gives you an awkward answer. But don’t listen to my cynicism and take my word for it. Read Ward et al. 2022 and ask yourself whether this is valuable and robust science being commissioned by Natural England and/or a good use of the time and resources of the BTO and of the data that it receives from volunteers. Do you think this type of data analysis exercise has any conceivable prospect of determining whether curlew in Somerset, redshank in Gloucestershire or stone curlew in Wiltshire are experiencing increased predation pressure as a consequence of badger removal? Do you agree with NE that ‘absence of evidence is evidence of absence’? Or alternatively, ‘if you can’t see the wood for the trees, it means there is no wood’.
If you would like to leave a comment about this blog you can do so at the end of the article on Mark Avery’s site here.
Kettel, E.F. and G. M. Siriwardena 2018. Comparisons of breeding bird population and abundance trends within and outside two specified areas located in SW England. Unpublished (confidential) Report to Natural England. British Trust for Ornithology, Thetford, Norfolk, UK. V. Ward, M. Heydon, I. Lakin, A. J. Sullivan, G. M. Siriwardena. (2022) Breeding bird population trends during 2013–2019 inside and outside of European badger control areas in England. Journal of Zoology 108. https://zslpublications.onlinelibrary.wiley.com/doi/10.1111/jzo.13010
Dominic Dyer, chairing the State of the Earth evening session at Birdfair on 15th July this year, asked two of his assembled panel guests about badger culling. The first, Sir Iain Boyd, the former Chief Scientific Advisor (CSA) to Defra commented, beyond his usual emphasis that the problem is more with people than badgers, that he “suspected that the evidence is suggesting it doesn’t work”. And “if badger culling isn’t working it shouldn’t be done, that’s absolutely clear.” Presumably, a reference to the most recent peer reviewed science (here).
The second guest, Tony Juniper, currently chairman of Natural England, freshly reappointed for another 3 years, was asked about the ecological impact of changing ecosystems by removing most of a dominant species. His response was slightly less coherent. Knowing his staff had just issued more supplementary killing licences and were in the final stages of lining up licences for a further 40,000 mostly healthy badgers to be killed this and the following three autumns. He picked words carefully: “we did say that it wouldn’t be a good idea” and “Natural England’s advice was that it probably wouldn’t work and we should try other methods” and (not answering the question) “will it have an effect on protected sites and protected species?.. we are looking at that too.”
Not mentioned by him, Juniper’s hands were tied due to a legal case that would play out a fortnight later in the High Court, that turned into a spectacular environmental travesty (here), remining us just how far government and the judiciary are now leaning towards unsound, politically expedient policies. Briefly, Defra remade its improper decision not to look at impacts from badger culling, supported by Natural England, without telling the court or the claimant. It rubber stamped its do-nothing approach in a way that meant Defra and Natural England could carry on doing little or nothing, escaping justice via the back door. It was ‘too late and too expensive’ now to study and deal with the problem anyway, was their best position, and that was their final decision. Looking at it was all they were doing.
Natural England had promised the courts in 2018 that they were on the case, with a research programme that was kept secret. Secret, it turns out because the BTO analysis used to justify continued culling had mistakes in it, and so had to be held back for two years while culling continued and Natural England staff worked with BTO to get the work through peer review. More recent events in the sorry saga have been exposed thanks to wildlife stalwart Mark Avery (here) and his guest blogs by the main expert witness for the three Judicial Reviews, Dominic Woodfield (here). Dominic has, in his blogs and comments, unzipped the whole matter from start to finish and dealt with the response from BTO during the sordid passage of the work over its last five years. It is worth taking the time to read the new blog and those that went before, to get a firm understanding of how Natural England have obfuscated their statutory duty and worked hard at minimising effort to examine the problem, while at the same time helping badger cull companies with advice and support to find their cull targets.
Juniper is aware of this of course, and efforts to get funding from Defra to look at the issue may have been turned down. But he has another problem. He has a relationship with and has written a book with Prince Charles. Who is a known lobbiest for badger culling, with his ‘black spider’ letters urging Tony Blair to start culling, a notable royal intervention (here). There followed a concerted effort to neutralise badger culling opposition in mainstream wildlife ngos between 2008 and 2013. Now Prince is King, what will happen? The King faces the reality that the tenuous evidence of badger involvement in bTB in cattle fifteen years ago, then presented as strong evidence, remain tenuous. Critically, recently published research using all of the relevant government data suggests that badger culling since 2013 simply shows no sign at all of working. This is despite Defra’s attempt to use small selective amounts of data with over-elaborate variables to try to show that it does. Defra used their most senior staff CSA Gideon Henderson and Chief Vet Christine Middlemiss to try to rebut the new published research, but this has only made them look foolish. They published, then retracted flawed data (here) that showed huge benefits from badger culling in its first two years, while insisting in their rebuttal of the new analysis that there is little or no benefit to be had in the first 2 years. Leaving professional vets, scientists and commentators completely baffled. Juniper and Charles III now have a big opportunity to help put things right that have gone terribly wrong on their watch.
Most of all, with the BTO paper just published (behind a pay wall), there is a final piece of chicanery. There is no sign of the all-important last line of the conclusions in the papers introductory abstract. The latest BTO magazine simply says that a similar (to the new publication) minimal approach might be repeated. Yet in the BTO paper, the authors call for a landscape-scale quasi-experimental approach: “to provide stronger inference about the complex potential ecological effects of culling predators such as the badger”
More and more journals are making sure that study limitations are placed in scientific papers and their abstracts, partly a response to the science reproducibility crisis. What this all means is that Natural England corner-cut to address important questions about the effects of the ecological impact of culling. It now admits that the minimal approach it employed is inadequate, and points to the kind of study it now agrees should have been done. This, in truth, is confession of guilt when there is little chance of a retrial before thousands more badgers are gunned down.
British Trust for Ornithology (BTO) opens up about its ‘secret’ work for Natural England.
Gavin Siriwardena, a BTO ecologist, has been writing online about his experience of working with Natural England (NE). Please see the third comment below the guest piece by Dominic Woodfield on Mark Avery’s blog here. He writes regarding the prolonged suppression of the release of a BTO scientific report, paid for with public funds, that contained a flawed analysis. He helped prepare this report in 2018, with others, for Natural England. A published version was not released until 2021 when the 2018 version was suddenly labelled as a draft, despite not being cited as such before in official documents used for decision making. This report was a promised outcome of a legal case pointing out lack of attention to ecological protection from the effects of mass-killing badgers on sensitive nature reserves.
Why was the initial 2018 report suppressed? Turns out that yet again, government funded work surrounding bovine TB eradication and badger culling has been cloaked in secrecy and hampered by error. In this case the mistakes were rendered inconsequential, but only because the design of the study was so scant and unconvincing that it made the results ‘low inference’, and the exercise not fit for purpose anyway. Perhaps NE did not want to expose the mistakes, how poor an effort it was, and that they were using it to justify decision making to meet the expectations of a High Court judge. It was, after all, one of their main defences from legal challenge, having promised the court to look carefully at badger cull impacts. However, in exposing these problems the BTO employee has revealed a lot about the situation regarding a further, similar legal case on biodiversity protection that goes to court this month. Here are some of his remarks and some thoughts on those remarks:
“Badgers are a top predator in the UK today and are also ecosystem engineers to some extent. Changes in their numbers are certain to have some effect on some other animals and plants, some of which may be biologically significant. “
Natural England’s previous defence in court was that effects are uncertain, and avoidance or mitigation is in general “ultra-precautionary”. Not the case now it seems.
“The analyses were limited by scale and context: this was not an experiment and cull areas are likely to have differed systematically in land-use from non-cull areas, added to which sample sizes were small. “
But NE relied on the BTO 2018 report in court. Gavin S acknowledges it is fraught with limitations, yet it remains the only action NE are taking. Disgraceful?
“However, there was a misunderstanding within the project team and a filter for inclusion of species was set at 30 square-year combinations, as opposed to 30 unique squares, and this was reported incorrectly in the report.”
Although NE used this non-peer-reviewed (at the time of use) analysis in their legal case, it contained mistakes that changed conclusions regarding many species.
“I sympathise with the view that policy should not be made on the basis of reports before they have been improved by peer-review, but I also sympathise with policymakers who may not have time to wait for the process to be completed. “
So BTO feels sympathy for policy rested on inconclusive work – not such a good idea to say this really?
“We could only analyse the species for which we had enough data, which inevitable biased the work towards more common species. “
Limitations to the data make the analyses worthless for many of the cohorts of scarcer species for which impacts are most likely to be significant in conservation terms.
“Monitoring therefore remains critical and we will continue to investigate the cull’s effects on birds where we can. “
We are in agreement that a proper monitoring scheme to look specifically at this issue is needed. Despite this, it appears the BTO is planning to repeat their previous dubious exercise with another year’s data, even though it is inherently non-conclusive/low inference by design. Is this just because they are being asked to do so by Natural England and the (taxpayers) money is just too good to refuse?
So, what do we make of all this? A BTO scientist appear to agree with us that there is/was a need to monitor the ecological impacts of badger culling properly. They say they did what they could with low-powered subsets of volunteer data. They admit that they made mistakes in the analyses of these data . Natural England used the error-infected study as evidence in a Judicial Review. A later process of peer review found the mistakes. NE and BTO declined to release the original report to their supporters and interested parties, or to confirm what they were doing with the BTO data. The report was submitted for publication as a peer reviewed paper but rejected on the grounds that the science was weak. They submit the report to BTO’s own journal. It is accepted for publication but conveniently not published until it is too late for it to be subject to legal scrutiny. Pretty stinky?
As others have said, this is not a good look for BTO and is damaging to its reputation for independence, scientific integrity and impartiality. Do NE, on the other hand, care that much? What has been said by a BTO scientist in the Mark Avery online comment is useful. Very useful in showing the world how Defra and Natural England find ways to sidestep the necessary ‘due regard’ of the impacts of Government policy on the natural world. To deliver what their political masters want and to pick up the rewards for doing so.
You can donate towards the legal costs of opposing the flawed policy here:
Who tampered with the data when examining potential ecosystem impacts?
In the last week of July 2022, the Court of Appeal in London will reconsider the 2021 Judicial Review findings of Defra’s alleged failures, under their NERC Act (2006) duty in relation to badger culling. The original claim was that of a failure of government to adequately consider the potential ecological impacts of mass badger removal upon priority species and habitats in badger cull areas under the Act, and to take adequate steps to deal with them.
Now is an appropriate time to report on one important aspect of the case. It relates to a scientific paper published in February 2021 in the journal Bird Study, published by the British Trust for Ornithology, entitled “A comparison of breeding bird populations inside and outside of European Badger (Meles meles) control areas”.
A forerunner of this paper was an unpublished report using BTO volunteer data, that was used in decision making, yet labelled by Defra agency Natural England (NE) as ‘secret’. It had been referred to in NE ecological impacts guidelines, having been cobbled together to try to show the judiciary that Natural England had not completely overlooked the subject after all, and were treating it seriously. NE needed to show something, having been found by a High Court judge as being in breach of duty in respect of SSSI protection.
Why then was this earlier report, prepared in 2018 and cited in government advice, not available publicly until 2021 and despite multiple requests for access to it, as is normal? It is now a story that is worthy of close scrutiny. It is a story that the main expert witness in the case, Dominic Woodfield, a professional in ecological impact assessment, has devoted much time and energy to in support of the legal challenges. He tells clearly and concisely the story of what has happened in his new guest blog for Mark Avery.
We think it sheds more than a little light on the way Natural England, and their handlers Defra, are managing information with the aim of providing the messaging that they are looking for, to facilitate the continuation of badger culling policy. Policy-lead evidence if ever you saw it?
You can find the full story here on Mark Avery’s blog..