Badgerland are a completely independent organisation who are concerned with the provision of factually-accurate information about badgers across the UK. We generally support the efforts of many animal welfare organisations - including the RSPCA, the SSPCA, the Badger Trust, their many badger groups and Secret World. We support badgers in their right to live in the wild and we clearly support the various forms of legislation designed to protect badgers and other wildlife against persecution. We support the actions of the Police and similar authorities in finding evidence which can result in the prosecution of people involved in wildlife crimes - including the crimes of badger baiting, digging, illegal hunting and sett damage. However, we do not support the view that the life of every single badger must be protected in every possible situation. If an individual badger is suffering from a condition which means it no longer has any reasonable chance of continuing with any quality of life in the wild, we may reluctantly come to the view that the best option for that individual sick animal may be for it to be put to sleep in the most humane way possible. Importantly, we do take the view that every badger has a right to live a life in the wild, and for that badger to be fully protected against persecution and extermination. We can never countenance the view that a healthy badger could be killed because other badgers might be sick or that badgers might be the recipient of an infection from another badger or another species. In our view, healthy badgers should live their natural lives in the wild, free from persecution and destruction.

For many years now, Badgerland have held the view that the primary cause of bovine TB in cattle is from other cattle.

Of course the skin test in cattle is well known to provide "false negatives" and "false positives" to bovine TB. It has been incorrectly assumed that the skin test will result in a "correct" result after a number of repeat tests - specifically in the case of cattle which have inconclusive tests. Badgerland think this assumption is a very dangerous one to make when the health of the cattle population is concerned. Certain types of cattle (mainly it seems, those which have recently calved) have an immune response which does not match conventional expectations; and these cattle can continually show up as negative in the skin test; but actually have a TB infection which they can pass on in their milk to other animals, as well as in their sputum, urine and faeces. The assumption (by many farmers, vets and Defra staff) that this effect (called anergy) is not important is incorrect; and it is a KEY reason why animals and herds which have had a number of clear tests suddenly find that they have a mysterious reactor in their midst. Because people do not understand the anergy effect; they incorrectly come to the view that the source of the TB infection must be an external source (such as a badger); whereas the true reason is that a cow which has been TB positive all along has suddenly been identified as such. What then happens these inconclusive reactors are frequently left to live with the rest of the herd to see if they react more obviously next time - and for the next few weeks they remain continuing to spread the infection around the confines of the cattle sheds and fields - providing a great risk of infecting other animals, such as cattle, badgers, cats, rats and badgers.

TB in other species (such as deer, badgers, cats, rats and now, it seems, llamas) is essentially a spillover problem from cattle. There have been countless examples of this, for example, where farm cats have been infected with bovine TB caught from milk from infected cattle on their farm, where farm workers have caught TB from the animals they work with, and deer have caught the same strain of TB from local cattle which were recently bought from an area of the country where that strain of TB was endemic in cattle. The overwhelming majority of badgers live and die and spend the whole of their lives within a 5 mile radius of where they were born; so their is no possibility that badger transmit bovine TB across hundreds of miles of the countryside. The animal that does move round these distances is the cow; and detailed analysis of the specific strains of TB types clearly shows how the infection travels with cattle movements.

It is worth studying the mechanism by which cattle and badgers feed. Cattle eat mainly from feed troughs in barns or grass in fields; and in all cases studiously avoid going near dung - this can be seen most obviously with a ring of fresh green grass around cowpats. Defra experiments have shown that cattle are extremely averse to eating food contaminated with animal dung or urine. Badgers on the other hand eat a combination of earthworms and insect pests - very many of which are found in, under and around cowpats. Badgers therefore have every opportunity to breath in the TB infection from infected cattle dung; as well as consume infected soil within the earthworms which live in huge numbers on pastureland. In other words, any-one who understands the feeding patterns of cattle and badgers will clearly see that badgers are very much more likely to get TB from cattle than vice versa.

Killing badgers will do nothing to solve the problem of TB in cattle; as there is no evidence that badgers transmit TB either to other badgers or other species in any significant numbers. The suggested solution (of killing badgers) will do more harm than good to Welsh and British agriculture; and the joint losers will be all those badgers who will be killed for nothing, as well as the farmers who will still have a sick industry; and who will have spent a lot of time and effort on work which will not solve the problem in TB in their own animals. It is worth remembering that badgers are NOT culled in Scotland; where the "TB-free" status is maintained by a proper cattle testing regime. Remember too how TB in cattle really began to ramp up as soon as testing was relaxed (allowing TB-infected stock to be imported from Ireland) and when it was relaxed again after the Foot and Mouth saga. If cattle testing had remained in force at those key periods, TB would NOT have started to increase in the way it now has.

The immediate solution is better TB testing in cattle, to cull out infected cattle IMMEDIATELY they provide either a positive or an inconclusive test result. We absolutely agree that cattle testing should be made mandatory for ALL cattle; and that the skin test should be used in conjunction with they more modern tests. We also take the view that the TB test history and vaccination status of every farm animal should be on the cattle passport.

It is so obvious that it is hardly worth saying, but the ONLY long term solution is vaccination of all animals which can suffer from TB. We take the view that vaccination should be used as a compulsory requirement for any farmer who has had any TB infection in any cattle, deer, llamas or any other farmed animal - either on his farm or on any contiguous premises.

Question 1 – Comments are invited on the options, costs and assumptions made in the Impact Assessment.

Badgerland do not agree that any healthy animal should be culled. We therefore can not support the culling of all badgers in a wide area as the overwhelming majority will not be infected with TB. As we do not accept that badgers cause TB in cattle in any significant numbers, we think killing badgers will make no difference to the level of TB infections in farmed animals. Regarding the specifics of the consultation, we think the majority of the public will not be able to understand the methodology. Likewise, we think the financial assumptions are wholly wrong, being based as they are on an assumption that the problem of TB in cattle can be fixed "on the cheap" by people who will work for peanuts for years at a time killing wildlife. The issue of bovine TB in cattle is one which will require some effort and expense to fix; and it would be far better to spend the money on culling out infected cattle so vaccination can make a difference in the healthy ones which remain.

Question 2 – Do you agree with the preferred option?

If farmers won't follow guidelines on cattle testing and all the other rules and regulations; they won't follow them for badgers. Accordingly, Badgerland do not agree with the preferred option.

Question 3 – Do you agree that this approach, of issuing licences to farmers/landowners, is the most appropriate way to operate a badger control policy?

We do not agree that badger numbers should be "controlled". We can not even begin to see how the guidelines will be followed as many farms are many miles away from the DEFRA head office; and neither the farmers nor the badger killers will have much regard for the rules invented by a civil servant who is not watching over their shoulder.

Question 4 – Do you agree with the proposed licensing criteria for culling and vaccination?

The licensing criteria for providing badger killing AND vaccination IN THE SAME AREA is one of the most stupid government ideas ever to emerge from Whitehall. Given that 30% of badgers remain trap-shy, you will only be able to trap 70% of badgers in an area. What is the point killing a vaccinated animal? What is the point vaccinating an animal which will then be shot later in the week? The mixture of killing and vaccination is pointless in the extreme. It is wasteful of the lives of badgers. It is wasteful of the time and expense in the time spend on vaccinations as well as the time spent killing animals. If it is important for the government not to waste the countries money, the government should not be encouraging other people to waste their money either. Importantly though, vaccinating 70% of badgers (which is achievable) would mean that TB in the badger population would not only die out; the continual infection which is fed into the badger population from cattle would not be able to take hold. More importantly, you should be able to achieve TB vaccination rates of more than 99% amongst cattle; which would solve the TB problem in cattle; and would, in the end, increase livestock values for farmers as their cattle would be more or less certain not to have TB.

Question 5 – Do you agree that the proposed methods of culling are effective and humane?

Badgerland do not agree that the culling methods are humane. Shooting a free-running badger is not humane - too many will be injured or not killed humanely straight away. How do you recover an injured badger from a sett where it will have taken refuge. Killing free-running badgers could end up being as cruel as badger gassing. Snaring badgers is cruel. Go and look at the photos from badger rescue groups to see the effects of snaring on badgers; and then say no cruelty is involved. Snaring will also capture other protected species and domestic pets; which will turn local people against the cull even more. Cage trapping will not "get" all the badgers; as 30% of badgers remain trap-shy. Also traps will be interfered with in even greater numbers than they were in the Krebs trial.

Question 6 – Do you agree with the proposed use of vaccination, particularly its focus on mitigating the perturbation effects of culling?

Badgerland do not agree with the mixed approach of killing and vaccination. The statistical effects of these two methods will be impossible to tease out in any scientific manner if they are used together. Although the so-called perturbation effect may appear to explain the results found in the Krebs trial; we remain unconvinced that badgers which might be infected with TB suddenly start to roam across much wider areas once their family members have been culled. In other words, we believe the so-called badger perturbation effect is essentially an effect of the discovery of bovine TB infection rates in cattle; and is not due to sudden behavioural changes in some badgers. By all means vaccinate all badgers across a wide area of the countryside as a scientific experiment. However, it would be more use to vaccinate cattle so they can't infect one another with their own infections.

Question 7 – Should anything further be done to encourage the use of vaccination?

Vaccination should be encouraged in all counties where there have been bovine TB infections in farmed or wild animal species. These vaccinations should ALWAYS include cattle; as well as all other species which are not so-called "end hosts" for the bovine TB infection. The government should encourage insurance companies to provide discounts to farmers who insure their stock against TB infections; if those farmers vaccinate their animals and maintain truly closed herds. The government should also provide differential compensation arrangements for farm stock which is culled as a result of a TB test. If the farmers make the choice NOT to vaccinate, he should be penalised by receiving a reduced compensation payment. The logic of this is that vaccination should be regarded as a good thing. Farmers who do NOT vaccinate put their own livelihoods at risk; as well as that of other farmers; and it is not the job of government to pay independent businessmen full compensation when they have neglected to follow best practice.

Regarding the export of animals which have been vaccinated; we do not see this as a big issue, as most cattle are NOT exported. In our view, market values for cattle would INCREASE if those animals were vaccinated; as it would mean other farmers would pay a premium for "risk-free" stock and the ability of farmers to sell premium beef and milk would be heightened if they could be "certified" as TB-free. By all means, have discussions with mainland Europe about vaccines. If mainland Europe will not accept vaccinated animals; then this is one of the risks that a farmer would need to take into account. The consideration would be whether it is better to risk a TB infection by having stock he can sell into Europe; or vaccinating animals are selling only within the UK. At the end of the day, you can not let the minority of farmers who trade their animals abroad dictate policy to the majority of farmers who choose not to truck animals overseas.

Question 8 – Do you agree with the proposed monitoring?

Defra are not likely to have enough staff to be able to monitor the actions of people across hundreds of square miles at night. If Defra can not monitor the situation thoroughly - rules will not be followed and you will not be able to ensure that badgers are killed humanely, that all badgers in a sett are killed and that cubs are not left to starve to death After all, Defra still can't manage to enforce all the thousands of overdue TB tests; and this is a much easier compliance issue than nocturnal badger shooting.

In short, Badgerland are against badger culling as we do not believe that it will make any significant contribution to the reduction of bovine TB in cattle and other farm stock.

Simon Flory

Badger Specialist

The Old Post Office

10 Badger Lane

Blackshawhead

Hebden Bridge

West Yorkshire

HX7 7JX

www.badgerland.co.uk

Phone 01422 846 846

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