Memorandum submitted by the Badger Trust
(BTB 27)
CONTROLLING BOVINE TUBERCULOSIS
A. INTRODUCTION
1. The Badger Trust welcomes this inquiry
by the Environment, Food and Rural Affairs Select Committee. The
Government's proposals to cull badgers in order to control bovine
tuberculosis (bTB) in cattle are extremely alarming. We believe
that the proposals are not based on sound science, would lead
to the extermination of tens of thousands of perfectly healthy
badgers and will worsen the bTB problem in cattle.
2. In addition, we contend that the undue
haste with which the proposals have been rushed out betrays a
deeper malaise in the Department for Environment, Food and Rural
Affairs (Defra). We argue that, when it comes to making decisions
about disease control, Defra retains many of the flaws that plagued
its immediate predecssor, the Ministry of Agriculture, Fisheries
and Food (MAFF).
3. The Badger Trust welcomes your decision
to: "focus on the key questions that Ministers must address
in reaching conclusions on the issues set out in the consultation
paper".
4. The Badger Trust notes the submission
to the EFRA Committee from Wildlife and Countryside Link. That
submission, to which we are signatory, details a range of questions
currently in urgent need of answers. The Badger Trust also notes
the detailed submission to the Committee from the Mammal Society.
That learned body has dissected the Government's consultation
document, identifying a wide range of flawed assumptions and further
unanswered questions.
5. In making this submission to the EFRA
Select Committee, the Badger Trust asks whether the Government's
proposals conform to the recommendations of the Lessons to
be Learned Inquiry[7]
into the foot and mouth disease (FMD) outbreak of 2001. Whilst
bTB does not spread with the speed of FMD, many valid comparisons
can be drawn in assessing the Government's management of the two
diseases. We contend that Defra has failed to learn many important
lessons from FMD.
6. We draw the Committee's attention to:
(i) A lack of creative initiative;
(ii) A failure to develop comprehensive contingency
plans;
(iii) A failure to communicate in a transparent
and open way;
(iv) A failure to apply risk assessment and
cost benefit analysis;
(v) A failure to use data in support of intelligence
gathering and decision making;
(vi) A failure to base policy decisions on
the best available science and to use clearly understood and trusted
processes for making use of scientific advice.
7. As a result, Government produced a national
strategy for bTB too slowly. It has been even slower in implementing
it because, we contend, officials are reluctant—contrary
to the Lessons to be Learned Inquiry's advice—to
reduce livestock vulnerability by reforming industry practice
and to minimise the impact of bTB.
8. Badgers have effectively been scapegoated
for industry inertia and used as a stick with which to beat the
Government. The scientific data gathered by the Randomised Badger
Culling Trial (RBCT) and its associated research should have provided
Government with an effective, evidence-based shield against such
attacks. Instead, it appears that officials within Defra, whose
professional reputations have been built on the advocation of
culling, have hampered or suppressed key research, leaving Ministers
with no alternative strategies to fall back on.
B. A LACK OF
CREATIVE INITIATIVE
9. "Within MAFF, and now DEFRA,
I detected a culture predisposed to decision taking by committee
with an associated fear of personal risk taking. Such a climate
does not encourage creative initiative. It inhibits adaptive behaviour,
and organisational learning which, over time, lowers the quality
of decisions taken. It seems to me that a reappraisal of prevailing
attitudes and behaviours within the Department would be beneficial."
[8]
10. The Badger Trust observes that, following
the discovery of a badger with bTB in 1971, the overwhelming focus
of Government attention has been on badgers. Defra has failed
to show creative initiative in dealing with bTB in alternative,
more constructive ways.
11. The lack of creative initiative is evident
in the history of bTB inquiries. Each inquiry by Lord Zuckerman,
George Dunnett and latterly Professor Krebs[9],
stuck closely to the narrow terms of reference set by Government
officials. In each case, the authors were asked to look only at
the role of badgers in bovine tuberculosis.
12. In the case of the Krebs report, which
led to the RBCT, no consideration was given to the potential role
of cattle to cattle transmission. We regard this as an extraordinary
and lamentable omission, not least because Professor Krebs was
the author of a Royal Society report on science's role in risk
assessment.
13. Had it not been for the genuine independence
of the Independent Scientific Group (ISG), which followed Krebs,
it is doubtful that this trend would ever have been bucked. The
ISG, by looking at bTB holistically, has compelled Defra to re-examine
the role played by cattle in the spread of bTB.
14. In addition, a variety of evidence suggests
that Defra officials continue to demonstrate a fear of personal
risk taking by, for example, failing to draw attention to emerging
bTB issues that needed addressing. This is best evidenced by Defra's
approach to the problem bTB in deer. It was only following our
report on bTB in deer[10]
that the possibility of deer involvement in bTB transmission became
part of the public debate. Yet Defra had clearly known about the
problem for a very long time and suppressed it:
(a) The TB Forum was established to consider
methods for controlling bTB other than badgers. Defra officials
refused to allow the Badger Trust to table its research paper
on bTB in deer to the TB Forum. Officials refused to allow discussion
of the role played by deer in transmitting bTB to cattle. Indeed,
although Defra was working with the British Deer Society on ways
of addressing endemic bTB in at least four populations of wild
deer, members of the TB Forum were never told of this work. It
emerged in a chance remark in a radio interview prompted by the
Badger Trust's own report into bTB in deer. Defra invited the
Badger Trust to attend a discussion about bTB in deer. This, of
course, would have kept the matter offline. We insisted on a written
response to be published online for the benefit of all stakeholders.
(b) When a new bTB outbreak occurred on the
Furness peninsula in Cumbria, Defra announced a study of badger
road traffic accident victims to determine whether they were the
cause of the outbreak. Deer were also to be included in the study,
but only badgers were mentioned in the press release headline.[11].
It required investigations by the Badger Trust to reveal that
a herd of bTB infected red deer were involved in the outbreak.
The red deer had been sold on to Penwith, triggering further bTB
outbreaks amongst local cattle herds that, in turn, led officials
back to the source farm on the peninsula. By September 2004, Defra
had tested 19 badgers for bTB and found no evidence of the disease.
Yet it had failed to assess bTB in wild deer in the area. Although
deer shooting is a widespread practise, only one deer had been
submitted for investigation. [12]To
this day, Defra has failed to advise the media that badgers were
not involved in the disease and that the outbreak is the result
of localised deer management and farming practices (such as nose
to nose contact with stock moved widely across small grazing lots).
Although park fallow deer remained on the source farm and were
a potential source of infection, Defra advised us that it had
no legal authority to deal with the deer.
(c) Research by the Central Science Laboratory
into the presence of bTB in wildlife other than badgers was never
publicised by Defra, even though it had found evidence of the
disease in a very wide range of animals and had identified a particular
problem in fallow deer. [13]Maps
used in the study show that the fallow deer carcasses, with an
infection rate of up to 16%, came from a relatively small area
of Gloucestershire. Yet the Badger Trust is not aware of any action
being taken to address the infection in those deer. Moreover,
although this is a bTB hotspot, there have been no press releases
about the existence of bTB in deer in this or other areas.
15. Similarly, the Badger Trust has observed
a lack of creative initiative in Defra with regard to investigating
ways of minimising badger to cattle transmission of bTB. Almost
all resources have historically been focused on killing badgers.
We further explore the problems that this has created in (4).
C. A FAILURE
TO DEVELOP
COMPREHENSIVE CONTINGENCY
PLANS
16. "Contingency planning should
not be seen in isolation. It is a dynamic process, not a static
document. It must be linked into a wider process of risk analysis
and disease prevention. Risks should be managed so that the country
can better respond to threats at an early stage. This can help
to ensure that future animal disease emergencies are less likely
to become crises, and that crises do not become disasters.
"[14]
17. Over the last ten years, Government
has presided over the steady spread of bTB to new areas. It has
watched the establishment of new bTB hotspots and done nothing.
It is abundantly clear that badgers were not the cause of this
spread. The Badger Trust (then, the National Federation of Badger
Groups) warned on 5 December 2001 that allowing the movement of
untested cattle in the wake of FMD would allow TB to spread[15].
We were ignored.
18. It is now clear that the ISG was also
ignored. The ISG has confirmed in its Fourth Report that:
"Geographic spread was heightened by
the predictable increase in cattle movements, and its associated
disease risk, that followed the lifting of restrictions imposed
during the FMD epidemic. Our concern at the increased potential
for the spread of TB that this represented, particularly into
relatively unaffected areas of the country, as a result of inadequate
biosecurity (movement of infected cattle), was forcibly expressed
at the time to Government representatives and the farming community.
Sadly, these warnings went unheeded and we are now seeing the
consequences of this lack of caution. "[16]
19. It is also clear that Defra has possessed
sound scientific evidence that cattle movements are the cause
of new bTB outbreaks since 2003. Long before the results were
published in Nature, Defra's own copy of research report
SE 3034 was online, stating clearly that:
"These analyses have demonstrated unequivocally
that the movement of animals, especially those from cells where
BTB is present, and particularly for locations outside the core
disease areas, is a critical factor in the current exponential
increase in BTB. "[17]
20. The agonisingly slow response of both
MAFF and Defra to the steady spread of bTB contrasts strongly
with Defra's rush to cull badgers in the wake of the publication
of the RBCT's research. As far back as 1998, members of the TB
Forum had approved a tightening of bTB testing regimes to make
Britain compliant with EU regulations. But the changes were not
implemented for more than four years.
21. In 2001, the ISG recommended that the
whole of Britain underwent annual bTB testing. In 2002, the British
Cattle Veterinary Service (BCVS) supported this and recommended
pre-movement testing, too[18].
Yet Defra did not establish a pre-movement testing stakeholder
group until September 2004. It did not report until June 2005
and its recommendations only came into effect on 1 February 2006.
22. Thus, despite the abundant evidence
of the risks posed by the movement of infected livestock, it has
effectively taken Government more than seven years even to begin
to address the problem.
23. Alarmingly, there is no evidence that
Defra has given any consideration as to how pre-movement testing
will be monitored and enforced. Our informal discussions with
Defra suggest that there is no legal obligation on markets to
ensure that cattle must comply with the pre-movement testing requirement
before being sold. There appears to be no provision for robust,
scientific modelling of the benefits of pre-movement testing either.
D. A FAILURE
TO COMMUNICATE
IN AN
OPEN AND
TRANSPARENT WAY
24. The Government's consultation on badger
culling should be comprehensive in its analysis and presentation
of the facts. Yet we note that critical information is missing,
with the result that the consultation is not open and far from
transparent.
25. The consultation conspicuously lacks:
(a) Estimates of the number of badgers that
would be killed;
(b) Estimates of the impacts on the overall
population of badgers in Britain;
(c) An assessment of the wider impacts of
culling strategies on nature conservation;
(d) Any attempt to predict the speed with
which culling would deliver a benefit over cost;
(e) Any attempt to predict how long culling
would continue; and
(f) Any proposed exit strategy from badger
culling.
26. Using the Freedom of Information Act
2000, the Badger Trust has asked Defra to provide GIS datasets
that would allow us to model the impacts on badger populations
ourselves. This would be easy to do: Defra itself quotes studies
that link badger population densities to land cover types and
this data, too, is available in GIS format. Modelling the impacts
of culling on badger populations should be a simple exercise for,
for example, the Central Science Laboratory's Woodchester Park
team.
27. But Defra has refused to provide the
data on the ground that it is Crown Copyright and the location
of infected farms is confidential. Anticipating this, we also
asked Defra what impact on badger populations its culling strategies
would have. We pointed out that Defra would need to know the answer
to this question in order to ensure that the Government was complying
with the Berne Convention. Again, Defra has refused to provide
an answer, stating that:
"There are no accurate figures of the
badger population in England and Wales in terms of location. Defra
have begun a detailed population survey in bTB hotspot areas.
This would provide baseline data for monitoring the impact of
any culling policy, that might be introduced following the current
consultation. "[19]
28. It is extraordinary that Defra has launched
a consultation on the widespread extermination of a protected
species in its European stronghold, with no idea as to the impacts
these policies would have. But such responses also fuel distrust
of Government. Defra's consultation states that "culling
efficiency [in the RBCT] has recently been estimated by Defra
at 20-60%". Defra cannot have estimated culling efficiency
without reliable badger population estimates in the culling areas.
29. So, either Defra could use those population
estimates quickly to extrapolate the impacts of culling policies
and provide us with an answer. Or the quoted estimate of "20-60%"
culling efficiency is not reliable and might even be interpreted
as a blatant attempt to undermine the results of the RBCT. Certainly,
the figure is hotly disputed by the ISG. [20]
30. Either way, this blatant and clumsy
contradiction confirms that far from communicating in an open
and transparent way, Defra is actively suppressing information
that is vital to an informed debate. There can be little doubt
that tens of thousands of badgers would be slaughtered. The Badger
Trust believes that Defra simply does not want to admit it.
31. There is further evidenc that Defra
pro-actively suppresses information that undermines the case against
badgers or does not justify badger culling. For example, under
the Freedom of Information Act 2000, we asked Defra why it failed
to publicise hugely significant and ground-breaking research by
the University of Oxford, which showed that cattle movements substantially
and consistently outweighed all other variables for predicting
bTB outbreaks. In its reply, Defra stated:
"As a retrospective correlation of existing
cattle movement data with outbreaks of TB, and with no badger
data included, it is not likely that a formal press notice would
have been considered appropriate. "[21]
32. In stark contrast, Defra did publicise
an early cost benefit analysis that supported badger culling even
though it was incomplete and based on unverified data. Defra argued
that this was worth publicising because:
"The Government Strategic framework for
the sustainable control of TB in GB specifically refers to the
study to integrate scientific models to establish the overall
costs and benefits of badger culling options . . . Ministers had
referred to the cost-benefit of badger culling options publicly,
including in the House of Commons. In view of this, and of the
anticipation that there would be particular public interest in
the outcome of the work, it was felt it would be helpful to highlight
the key findings. "[22]
33. It is hard to believe that the farming
community would not have had particular interest in the findings
of the cattle movement research, let alone the wider public. The
Badger Trust notes that the Science Advisory Council has since
criticised Defra for "the on-going secrecy around bTB research
which resulted in different groups or individuals only seeing
part of the picture at any time".[23]
E. A FAILURE
TO APPLY
RISK ASSESSMENT
AND COST
BENEFIT ANALYSIS
34. "Apply risk assessment and
cost benefit analysis within an appropriate economic model. "[24]
35. Is Defra using an "appropriate
economic model" to justify killing badgers in its partial
Regulatory Impact Assessment (partial RIA)? We contend that the
answer is: No.
36. In the partial RIA, Defra's rational
for intervention is:
"20. Veterinary advice is that fundamental
principles of infectious disease control need to be employed to
reduce the risk of transmission of disease from badgers to cattle.
At present, the only method known to reduce the number of infectious
badgers is lethal removal. This would permit a balanced approach
to bTB control that deals with the principle transmission risks.
"[25]
37. This odd statement makes an unexplained
jump, from identifying the "risk of transmission" as
the problem to reducing "the number of infectious badgers"
as the solution. It implies that the "fundamental principles
of infectious disease control" are simply "lethal removal".
No mention is made of preventative measures, which are also a
fundamental principle of infectious disease control.
38. Thus, it could also be argued that:
"The risk of transmission of disease from badgers to cattle
should be reduced by the implementation of biosecurity measures."
Defra simply ignores this possibility.
39. Research by the Central Science Laboratory,
scheduled for completion in December 2005, should indicate what
basic husbandry measures might limit badger to cattle transmission.
[26]Some
early work in this area has already been published, although the
small sample sizes involved do not permit assumptions to be made
about the effectiveness of preventing badgers accessing cattle
feed. [27]Studies
of farm level risk factors by the ISG should identify predictors
for bTB outbreak risk that may, in turn, lead to the development
of preventative measures. [28]Furthermore,
the Science Advisory Council has advised that:
"The adoption of potentially effective
precautionary control measures, which involve relatively low costs
and are not controversial, need not await the same standard of
scientific evidence as those which are costly and/or controversial.
However, the effectiveness of such measures should be monitored.
"[29]
40. Unfortunately, over the last ten years
MAFF/Defra officials chose not investigate such measures with
the same enthusiasm as they killed badgers. This disgraceful research
void means that the ISG is unable advise on what might happen
were badgers not killed and attention was instead focused on cattle
controls and biosecurity. [30]This
question must be answered before killing badgers is considered.
41. The RBCT shows that each method of killing
badgers has an inherent risk of making the bTB situation worse.
Smaller scale culling introduces a detrimental perturbation effect.
Larger scale culling, required over areas of at least 300 sq km,
is impossible to implement effectively. Defra advises that:
"27. In conclusion, the introduction
of effective badger control measures alongside cattle measures,
has the potential to make, over time, a contribution to disease
control objectives in high incidence areas. However, the level
of risk presented by perturbation is unknown and cannot be ignored."
42. It is not true that the level of risk
presented by perturbation is "unknown". The RBCT has
shown that reactive and proactive culling strategies can lead
to perturbation effects of 27% in the culling area and 29% around
the culling area respectively. Defra attempts to sidestep this
inconvenient evidence by arguing that, with no "badger management"
(ie killing):
"53. It would be expected that the current
trends for increase in incidence and spread of the disease in
high incidence areas would continue. The current loss per herd
due to bTB would persist."
43. This disgraceful claim is not based
on any evidence. It simply ignores the possibility that the incidence
and spread of the disease will be significantly reduced with the
introduction of effective controls on cattle.
44. In Northern Ireland, a paper commissioned
by Defra reveals, a reduction of bTB outbreaks of 40% has been
achieved in just one year by "very strict application of
an annual skin testing regime, giving no opportunities to delay
herd tests and testing herds contiguous to breakdown herds".[31].
The authors of this paper add that:
"In GB, where the frequency of herd testing
with the tuberculin skin test is determined by previous information
on presence of bTB, herd testing is not being used optimally as
a bTB surveillance tool, compared, for example, to its use on
an annual basis in RoI and NI."
45. This brings us to the heart of the problem
with Defra's economic model: it is too simplistic. First, it contains
out-of-date information. The underlying cost benefit analysis
hypothecates that badgers cause 80% of bTB outbreaks. Yet Animal
Welfare Minister, Ben Bradshaw, has told the House of Commons
that:
"Eighty per cent of TB cases are spread
from cattle to cattle." [32]
46. Second, and more importantly, the model
costs the killing of badgers in isolation from cattle controls.
There is no effective, integrated economic model that allows Defra
to make combinations of different policy options to come up with
the most beneficial and cost effective solution. Modelling the
costs and benefits of one strategy in isolation from another is
nonsense.
F. A FAILURE
TO USE
DATA IN
SUPPORT OF
INTELLIGENCE GATHERING
AND DECISION
MAKING
47. "We have already identified
the issue of inadequate information flow. Put simply, those at
the top responsible for major decisions were not provided with
timely, accurate and relevant information about what was happening
on the ground. "[33]
48. The Lessons to be Learned Inquiry
noted that one limiting factor in addressing the FMD epidemic
was a lack of robust data on sheep movements, a clear understanding
of livestock movements in general and a good knowledge of trends
in the livestock industry at farm and market level. Addressing
FMD was hampered by a lack of reliable data on progress, such
as how rapidly infected stock were slaughtered.
49. The Badger Trust believes that a similar
problem exists with bTB. Whilst a vast reservoir of data has been
gathered on badgers and their ecology, there is a conspicuous
lack of information about the mechanics of the cattle industry
and the extent to which that might contribute to the spread and
persistence of bTB, both now and into the future.
50. The Krebs Report noted that the number
of breakdowns in England began rising in 1988.[34].
Some individuals have blamed this increase on an alleged "explosion"
in badger numbers. Yet no attempt has been made by Defra to determine
whether the increasing trend in bTB correlates with changing trends
in the cattle industry. This should be a key part of Defra's ongoing,
dynamic risk assessment.
51. For example, England has the largest
herd sizes in Europe and economies of scale mean that: "Average
herd size is expected to increase more rapidly than it has done
in the past".[35]
We now also know that larger herds are more likely to experience
a bTB breakdown. [36]The
period since 1998 has also seen rapid growth in the number of
large holdings, with the largest holdings acquiring an additional
4% of crop and grassland between 1998 and 2003. [37]Many
farms are increasing their production of suckler beef cattle[38]
or increasingly specialising in areas such as the production of
heifers for sale.
52. What effect on bTB might have resulted
from the shift to larger herds and holdings? Is there a herd size
threshold beyond which the bTB current skin test fails to clear
up infection, leading to more repeat breakdowns? What effects
might have resulted from the introduction of milk quotas in 1984
and subsequent industry adjustments? Has greater specialisation
led to an increase in the number of cattle traded between different
specialisms? Is the trend towards larger herds universal or confined
to certain areas?
53. As a result of BSE, and later FMD, reliable
data are now available on cattle movements. Oxford University
used this data to confirm that cattle movements substantially
and consistently outweigh all other variables for predicting bTB
outbreaks. [39]The
ISG has since pointed out that 86% of livestock movements originating
in bTB hotspots remain in hotspots. [40]Nevertheless,
there has been no further modelling to assess whether these localised
movements are also good predictors for outbreaks. This matters,
because the National Farmers Union claims that whilst emerging
hotspots are the product of livestock movements, outbreaks in
existing hotspots are the result of badger infection. [41]Modelling
the links between local cattle movements and bTB outbreaks would
clarify this issue.
54. A lack of holistic thinking about bTB
and the potential causes of its spread other than badgers means
that "those at the top" might well be unaware of significant
changes on the ground that pose new and future challenges to bTB
control. The FMD disaster strongly suggests that a better usage
of cattle industry data is needed to inform decision-making about
bTB and its control.
G. A FAILURE
TO BASE
POLICY DECISIONS
ON THE
BEST AVAILABLE
SCIENCE AND
TO USE
CLEARLY UNDERSTOOD
AND TRUSTED
PROCESSES FOR
MAKING USE
OF SCIENTIFIC
ADVICE
55. "The Government felt it had
little choice but to accept the advice it received on these matters
from the Chief Veterinary Officer and the Chief Scientific Adviser.
But the process of determining and responding to that advice should
have been better. It was certainly not in line with the recommendations
on scientific advice made by The BSE Inquiry. "[42]
56. The Badger Trust notes a stark difference
between the following two statements:
"The reactive triplet results were reported
in November 2003 as showing a biologically unexplained 27 % increase
in herd breakdowns compared to the survey-only triplets, at which
point Ministers suspended the reactive treatment. Subsequent spatio-temporal
analyses of the reactive culling data have shown equivocal results.
Further analyses of the data need to be undertaken before conclusions
may be drawn. "
"The Irish Four Areas Trial published
in January 2005 (Griffin et al., 2005) is the latest published
evidence showing that removal of badgers has been effective in
reducing bovine TB in the Republic of Ireland. "
57. Both statements appear successively
in Defra's partial RIA. But whilst the first highlights potential
weaknesses of the RBCT's reactive cull (weaknesses which have
since been addressed by further in-depth analysis of the data),
the second implies that the Irish Four Areas Trial yielded conclusive
results with no weaknesses.
58. Defra fails to mention that analysis
of the Irish data by the ISG, using its own findings in the RBCT,
have revised the Irish "success" downwards from headline-grabbing
reductions in bTB of up to 96% to a mean of 54%. Moreover, the
Irish study's extraordinary failure to include a scientific control
(a fact conveniently ignored by its advocates) has resulted in
the ISG speculating that the Irish study has exaggerated the benefits
of badger culling. [43]
59. The question arises as to whether Defra
is basing its consultation on the "best available science".
We contend that the best available science is that published in
Nature, by the ISG. It is not simply that Nature
is one of the world's most respected journals with the highest
standard of peer review. More importantly, the ISG's work represents
a field study of substantial statistical power and with a proper
scientific control. The Irish Four Areas Study, we suggest, is
not in the same league. Yet Defra's treatment of the two studies
in the consultation is far from even-handed.
60. The Badger Trust believes that the Government's
proposals to slaughter badgers have been rushed out with undue
haste because a decision to slaughter badgers has already been
made. In 2004, civil servants told Professor Charles Godfray that:
" . . . if the [Randomised Badger Culling]
trial yields a benefit from culling and therefore provides the
unambiguous evidence of causation we could very rapidly work up
more effective, easier, cheaper, and undoubtedly more controversial
means of culling badgers." [44]
61. Alarmingly, at the same time, the civil
servants advised that their response might "vary considerably
from experimental methods". It appears that officials were
so sure of their ground that they were determined to kill badgers
using strategies based on little more than guesswork and prejudice.
There is certainly little evidence of any intention to use sound
science.
62. We were appalled to learn that the Government's
proposals were published despite being "inaccurate in important
respects",[45]
strongly suggesting that the Government has not made effective
use of its own Independent Scientific Group.
63. We draw the Committee's attention to
the fact that the advice of the Chief Scientific Advisor is included
in the partial RIA published on 14 December 2005:
"25. . . . After considering the
scientific evidence including a review of the international literature
that he commissioned and advice from the Science Advisory Council,
Defra's Chief Scientific Adviser has concluded that, on balance,
badger culling can contribute to a reduction in herd breakdowns
if intensive removal over a wide area is practised, but it does
not allow any recommendations to any particular approach to culling
or provide any means of predicting the effectiveness in terms
of reduction of herd breakdown. However, data from interim analyses
of the proactive element of the RBCT indicate that, if not conducted
efficiently and over a wide area, there is a possibility that
culling could lead to an increase in the spread of disease due
to perturbation effects; this needs further, careful analysis.
"
64. Yet we now know that the Chief Scientific
Advisor did not receive the views of the SAC on the proactive
culling results until the SAC wrote to him on 20 December 2005,
after the partial RIA was published. [46]
65. In short, there is no evidence that
the Government is using clearly understood and trusted processes
for making use of sound science. All the implications are that
Defra officials decided to kill badgers well over a year ago.
Now that sound science indicates that this is likely to make things
worse or be totally impractical, the Department is simply making
things up as it goes along, clutching at any straw that justifies
a decision that is already made.
66. There are two implications. First, the
consultation exercise itself has no value because it is based
on a highly partial and deeply flawed presentation of the evidence.
The consultation is at best meretricious and at worst deceitful,
and we condemn the Minister for embarking upon it.
67. Second, this sham will inevitably result
in a deep distrust of Defra's claim to make effective use of sound
science. Defra's failure to incorporate the advice of the ISG,
the SAC and the Chief Scientific Advisor into the consultation
in an open and transparent way betrays the reality that officials
continue to bend and manipulate the information to suit a pre-existing
policy position.
H. OPTIONS FOR
THE FUTURE
68. The Badger Trust notes the advice from
the ISG, [47]stating
that the Government's first two options for badger culling (individual
licensing and farm-scale culling) will "seriously worsen"
the bTB situation. We note that the Government's third option—killing
badgers over a wide area—underestimates the scale of culling
required. The ISG advises that killing would need to be delivered
over areas of at least 300 km sq and that Defra's estimate of
100 km sq is "at variance" with the ISG's findings.
69. The Badger Trust believes that the eradication
of bTB is not a realistic option with the tools currently at our
disposal, including killing badgers. The best that can be achieved
is the effective control of bTB in cattle, using improved cattle
controls and bTB testing. In addition, we urge that research into
minimising the risk of transmission from badgers to cattle is
fast-tracked.
70. We predict that, if properly implemented
and enforced, pre-movement testing, more frequent bTB skin testing
and the use of the gamma interferon bTB test in herds with multiple
reactors will rapidly reverse the growth in bTB and significantly
reduce the problem.
71. We argue that it is a far better use
of public funds to invest in measures to minimise the risk of
transmission from badgers to cattle on farms, through effective
grant schemes. We contend that such schemes will address not only
the challenge of bTB but also a range of other farm animal health
and welfare challenges. Richard Sibley from the British Cattle
Veterinary Association has estimated that 250,000 cattle die every
year due to diseases that are preventable, [48]That
is ten times the number of cattle slaughtered for bTB, yet this
figure rarely makes the headlines because the industry knowingly
absorbs the costs.
72. The Lessons to be Learned Inquiry was
quite clear in its recommendations to "reduce livestock vulnerability
by reforms in industry practice" and to "minimise the
impact of any outbreak". It is quite clear that both of these
objectives can be rapidly achieved solely by focusing on cattle.
We believe that further evidence will rapidly emerge to illustrate
how minimising the risk of transmission from badgers to cattle
will be a more cost effective and certainly more palatable solution
than exterminating tens of thousands of one of Britain's most
popular and treasured wild animals.
February 2006
7 Anderson, I (2002) Foot and Mouth Disease 2001:
Lessons to be Learned Inquiry. Back
8
Anderson, I. (2002) op. cit. Back
9
Krebs, J (1997) Bovine Tuberculosis in Cattle and Badgers, MAFF,
London. Back
10
Badger Trust (2004), Bovine TB in deer, London. Back
11
DEFRA (31 December 2003) News release /NW/125/03, Survey of badgers
on the Furness peninsula of south west Cumbria following rise
in bovine TB cases, London. Back
12
Moffitt, J (October 2004), TB in South West Cumbria 2002-04,
TB Forum Paper TBF 109, London. Back
13
Central Science Laboratory (2004), The risk to cattle from wildlife
species other than badgers in areas of high herd breakdown risk,
York. Back
14
Anderson, I. (2002), op. cit. Back
15
NFBG (5 December 2001), Farmers at risk from disease triple whammy,
London. Back
16
ISG (2004), An Epidemiological Investigation Into Bovine Tuberculosis,
Fourth Report of the ISG. Back
17
Environmental Research Group Oxford Ltd (2003), Investigation
of cattle movement records in Britain, Defra research project
SE 3034, London. Back
18
Sibley, R (17 November 2002), Countryfile, BBC1, Birmingham. Back
19
Gavigan, G (31 January 2006), response to FoI request, ref RFI
907, Defra, London. Back
20
Woodroffe, R (25 January 2006), personal comment at ISG Open
Meeting, London. Back
21
Tuck, C (1 November 2005), response to FoI request, ref RFI 756,
Defra, London. Back
22
Tuck, C. (1 November 2005), op. cit. Back
23
SAC (13 October 2005), Draft Minutes, 7th meeting of the Science
Advisory Council: 11 October 2005, SAC (05) 25, London. Back
24
Anderson, I (2002), op. cit. Back
25
Defra (2005), Partial Regulatory Impact Assessment, consultation
document. Back
26
xx An investigation of potential badger/cattle interactions and
how cattle husbandry methods may limit these, Defra research contract
SE3029, unpublished. Back
27
Garnett, B T, Delahay, RJ and Roper, T J (2002). Use of cattle
farm resources by badgers (Meles meles) and risk of bovine
tuberculosis (Mycobaterium bovis) transmission to cattle by badgers.
Proceedings of the Royal Society Series B: Biological Sciences
Vol 269, No 1499. Cover Date 22 July 2002. Back
28
Gettinby, G. (25 January 2006), personal comment at ISG Open
Meeting, London. Back
29
SAC (September 2005), Independent review of research on bovine
tuberculosis (bTB), Report and recommendations, SAC-TB (05) 4
Final report. Back
30
Bourne, J (25 January 2006), personal comment as ISG Open Meeting,
London. Back
31
Wilesmore, T and Taylor, N (September 2005), A review of the
international evidence for an interrelationship between cattle
and wildlife in the transmission of bovine tuberculosis, University
of Reading. Back
32
See Hansard online at: www.publications.parliament.uk/pa/cm200506/cmhansrd/cm051117/debtext/51117-02.htm Back
33
Anderson, I (2002), op. cit. Back
34
Krebs, J (1997), op. cit. Back
35
Defra (2005), A study of long-term trends affecting the farming
industry, London. Back
36
Clifton-Hadley, R (25 January 2006), personal comment at a meeting
of the Zoological Society of London. Back
37
Defra (2005), op. cit. Back
38
Upton, M (October 2005), Farmers' adjustments in response to
increased regulatory costs, University of Reading. Back
39
Environmental Research Group Oxford Ltd (2003), op. cit. Back
40
Bourne, J (26 January 2006), op. cit. Back
41
Rowe, J (2005) various media interviews. Back
42
Anderson, I (2002), op. cit. Back
43
Bourne, J (26 January 2006), op. cit. Back
44
Godfray, C (chairman), 4 March 2004, Independent Scientific Review
of the Randomised Badger Culling Trial and Associated Epidemiological
Research, Defra. Back
45
Summerskill, M (20 January 2006) Open letter from the ISG to
TB Stakeholders. The ISG notes that culling would need to cover
areas of at least 300 km sq, but the consultation makes no mention
of this. Back
46
SAC-TB(05)5 Supplementary Report (Final). Back
47
Summerskill, M (20 January 2006), op. cit. Back
48
Sibley, R (2003), Rethink health strategies. Farmers Weekly,
28 February 2003. Back
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