Memorandum submitted by National Beef
Association (BTB 05)
EXECUTIVE SUMMARY
1. An effective badger cull in core TB affected
areas is at least 10 years overdue. Defra has at last recognized
this but there are elements in its Bovine TB and badger culling
consultation that are naive and alarming.
2. The National Beef Association (NBA) is
firmly of the view that properly organised intensive culling must
be conducted over a suitably wide area and over an extended period—although
it would also prefer an initial blitz with as much concentrated
culling activity as possible being undertaken in all designated
areas for at least the first two weeks of the approved culling
period so that the culling policy has the earliest possible impact.
3. However a number of fundamental concerns
relating to the depth of Defra's commitment to a demanding culling
process have already emerged.
4. This is demonstrated by its apparent
unhappiness in helping to prepare the industry to properly tackle
the expensive and difficult problem of culling out sufficient
badgers over a sufficiently wide area to prevent further spread
of TB through population disturbances (perturbation) in which
unsettled badgers, which have TB, wander into new areas and infect
new cattle and new badgers—or by playing a full and proper
part in the planning and execution of pre-established strategies
after culling has begun.
5. One example of the former is its lack
of urgency in approving the use of carbon monoxide gassing before
the cull—which is expected to begin in June. The NBA is
seriously of the view that without using this gas, which is available
to large numbers of farmers through petrol engines and catches
entire badger groups while they are underground during the day,
it will be extremely difficult to conduct a satisfactory cull
on the scale necessary to put bovine TB on the retreat and then
eliminate it.
6. In the meantime Defra has said it will
be impossible to approve carbon monoxide for culling in 2006 and
perhaps thereafter too. In short it is saying carbon monoxide
may never be a culling tool while the NBA is saying that without
it a worthwhile cull over large areas of land will be much more
difficult than it otherwise would be—even if large numbers
of farms can be persuaded to use rifles or snares across large
areas of ground for at least five years if not longer.
7. Another is its apparent wish to commit
itself only minimally to the conduct of the cull. The NBA has
spoken to Defra at length over the last six weeks and has formed
the view that the Department is not at all enthusiastic about
taking a lead position in helping to organise, co-ordinate or
part fund the cull—while it is also clear that without substantial
help from Defra farmers will not, on their own, be able to sustain
the organisation or momentum to cull out the huge numbers of badgers
over the vast tracts of countryside over a number of years that
would be necessary to achieve a satisfactory result.
8. Our impression is that Defra, which is
persistently under-budgeted and under funded, would for internal
resource reasons prefer the cull to be conducted almost entirely
by farmer volunteers, or their paid assistants, and the co-ordination
of their activity to be conducted by organisations of relatively
slim means, like the National Farmers Union (NFU), working with
the help of groups like ourselves.
9. The NBA, NFU and others may be enthusiastic
about, at last, being able to tackle a badger cull but they are
not government and there are severe limitations on the resource
they can offer and the likely effectiveness of activity they are
able to co-ordinate.
10. The NBA's very clear view is that the
culling of badgers must be organised with a similar thoroughness
and resolve as other difficult anti-disease tasks such as the
elimination of FMD—although of course an anti-TB campaign
would be conducted on a smaller overall scale.
11. We see a specially designated operations
rooms being set up in each county in which culling will take place.
Cornwall, Devon, Somerset, Gloucestershire, Herefordshire, Worcestershire,
Derbyshire and Staffordshire are among those that would be included.
12. These rooms would be permanently manned
and staff would have telephones and computers, contact lists,
maps and clear strategy targets. Strategies would be coordinated
with the help of staff from Defra's own Wildlife Unit (more on
this later), farmers and landowners, members of National Gamekepers
Organisation (NGO) representatives from the local fox hunt and
the National Wildlife Trust—each of whom would be able to
help in identifying setts. At least one full time member of staff
would be familiar with officials in Defra's TB department in Page
Street.
13. A county stakeholder group made up of
representatives of these organisations would meet regularly fix
and monitor its overall strategy and then discuss whether current
culling targets have been achieved and re-arrange the programme
if culling in some locations has fallen behind.
14. This would require direct Defra input
at both local and national level. Other participants would offer
their services without charge, as they did during FMD, but Defra
would also have to meet the cost of the room, the staff, and the
management. If necessary logistics and planning specialists from
other areas of government, perhaps the army, could be called in
to help. Such activity may be necessary for 10 years.
15. Unfortunately Defra currently gives
the impression that it is reluctant to accept these arguments
and appears more concerned about saving what it can of its £7
million annual expenditure on its Wildlife Unit by dispensing
with the services of men it employed during the Random Badger
Culling Trials (RBCT or Krebs) to trap badgers, and who know exactly
where the setts are, than recognising that if TB costs compound
at 20% a year they will double every four years.
16. This means that if TB spread is not
checked taxpayers will face a £2 billion TB bill over the
next 10 years (Defra accepts this figure). The NBA finds it hard
to believe that in view of this Defra, and others in government,
are not prepared to invest substantial forward sums so they can
save as much as possible of this huge cost burden
17. Our question to decision makers in Defra,
and therefore government is—how much are you prepared to
invest in effective badger culling to avoid inflicting tax payers
with an avoidable £2 billion bill in 2016? A supplementary
question would be—does Defra not think it will be impossible
to save taxpayers £2 billion if carbon monoxide is not approved
for culling badgers from June 2006 and culling has to be conducted
by rifle or snare alone?
THE NEED
TO CULL
OVER LARGE
AREAS
18. The NBA is aware of the arguments against
small scale, pocketbook, culling. These are commonly cited by
the Independent Scientific Group (ISG) which at one stage abandoned
a section of the Random Badger Culling Trials (RBCT) because it
was convinced that the disturbance (perturbation) culling created
added to TB spread because more infected badgers were being pushed
beyond their territorial boundaries and coming into contact with
cattle which up until then had not been exposed to the disease.
19. The ISG repeated these arguments in
the interim report which informed the consultation paper Defra
issued on 15 December. After studying the ISG report the NBA found
it impossible not to conclude that a badger cull, should one be
adopted, would have to be conducted on a scale not previously
envisaged if it was to be successful.
20. That being said the NBA also noted that
culling (conducted by trapping) within the RCBT areas was far
from efficient and concluded that if the culling there had been
more well-organised fewer surviving badgers would have been disturbed
by incomplete culling activity, because their family unit structures
had been broken up, and a smaller number of infected badgers would
have been able to move beyond the cull boundaries and raise the
level of TB in cattle in those areas.
21. Inevitably this persuades us that all
culling, including that in large areas, must be efficient with
as many badgers as possible removed.
22. We note the contents of the ISG letter
of 20 January in which it says that only intensive culling over
a large area over an extended period will be effective. Significantly
it suggests that culling in target areas of only 100 sq kms or
so must be avoided while anything over 300 sq kms would help to
curb TB spread and reduce TB infection rates, and costs, in cattle—as
long as it is done properly.
23. This observation fits in with our own
view that culling must be conducted over the widest possible area
and we consider that when measuring out 300 sq km sections in
the worst affected TB regions there will be many occasions when
these overlap to form much larger regions perhaps accounting for
a significant proportion of an entire county—if not entire
counties in the case of Cornwall, Devon and Herefordshire.
24. It is also important when conducting
a cull to establish a boundary so that the number of badgers culled
is kept to the lowest possible levels. Such boundaries will be
where badgers without TB exist so it makes sense if culling embraces
all areas where TB in badgers is endemic but does not move into
areas where badgers can be proved, by polymerase chain reactor
(PCR) analysis if necessary, to be free from TB.
THE CULLING
TOOL BOX
25. All culling will require cullers to
be adequately equipped and the need for this will be even greater
in the biggest culling areas.
26. Unfortunately Defra appears to think
that huge numbers of badgers over vast tracts of countryside can
be removed using body snares and guns.
27. The NBA is not persuaded. Each of these
is a method that could be used effectively in small, specific,
areas but neither could adequately cover the wide areas we envisage
because each is time hungry. One requires the regular re-visiting
of snares in daytime the other the work of at least two people
(the lamper and the shooter) at night.
28. On the other hand carbon monoxide gas
is a tool which lends itself to general widespread use. Gas pumped
in from portable petrol engines or petrol driven quad bikes could
be put through many badger setts relatively easily by a single
person—and also has the advantage of targeting several badgers,
indeed entire groups, at the same time. It is easily the most
efficient method and vital it is confirmed as permanent tool in
the culler's kit.
29. Unfortunately Defra says it will not
be able to satisfy anti-cull lobbyists that carbon monoxide (exhaust
gas) is humane by the time culling is expected to start in June.
Its main objection appears to be that some badgers, perhaps unweaned
cubs, lying in elevated areas of the underground tunnel system
will survive the gas.
30. The NBA has read the information on
this provided by Defra on its website and has concluded that on
the rare occasions that a badger survives monoxide poisoning it
does so with no permanent ill effects—except perhaps for
a headache that soon disappears.
31. We cannot stress how important carbon
monoxide is to the conduct of an effective cull or how slender
the arguments against using it appear to be. We would like Defra
Ministers to overrule officials on this extremely important issue.
Gassing with carbon monoxide in day time backed with rifle and
spotlight (lamping) action at night have a real chance of being
effective while each activity on its own would be significantly
less useful.
THE CULLING
CLOSE-SEASON
32. If carbon monoxide gas is used we see
no reason why there should be a closed season. This is currently
in place to prevent unweaned cubs starving if their dam dies above
ground.
33. Carbon monoxide (exhaust gas) would
kill both dam and cubs underground and so could be used without
a closed season. It does seem strange to us that animals breeding
within a targeted culling area are offered the chance to continue
breeding and add to the task of achieving a full and effective
cull.
34. We would accept that snaring and shooting
be abandoned over the suckling period but urge that carbon monoxide
control should be encouraged in January-February when many livestock
farmers are free of the burdensome seasonal tasks they face in
spring, summer and autumn.
CULLING STRATEGIES
AND CO
-ORDINATION
35. The NBA favours the adoption of a concentrated
culling blitz in the first two weeks of the culling period and
for two weeks each year thereafter.
36. Such action would be especially effective
in areas where snaring and shooting were the dominant culling
methods because badgers wandering off one farm onto another would
be more likely to be caught or killed.
37. Our opinions on how culling should be
organized on an overall basis are contained in the executive summary.
USING POLYMERASE
CHAIN REACTORS
(PCR) TO DEFINE
THE PERTURBATION
LINE
39. The NBA has investigated the use of
PCR machines in identifying the location of diseased and disease
free badger setts and late last month introduced two Defra officials
to the machine.
40. Our view is that even if culling areas
are on occasions as large as individual counties, as seems likely,
there has to be a properly defined point at which the culling
ends so no more badgers are killed than is necessary but TB is
eliminated in the area where it is endemic.
41. We do not propose that a PCR assay,
which can be done on site, by the sett, within 15 minutes, using
badger faeces, is conducted in the centre of the core culling
areas but believe it must be used to define the perimeter of the
culling area and indicate the point beyond which no more culling
is necessary.
42. Amongst ourselves we are calling this
the perturbation line and believe an effort must be made to see
whether such a definitive line can be established using information
on TB outbreaks in cattle to establish exactly where these sentinel
animals are confirming TB among resident badgers—and then
extending outwards from that line, perhaps by 10-12 kilometers,
to determine, by means of PCR assay, exactly where a line can
be drawn that indicates badgers on one side are carrying TB but
those on the other do not. These lines could be monitored on a
regular basis to see if they have moved.
CONCLUSION
43. The NBA is disturbed by the apparent
naivety of Defra's thoughts on badger culling and is also worried
about whether or not the Department is genuinely determined to
maintain its important contribution to a national effort to reduce
TB in GB over the next 10 years.
44. We are not yet sufficiently well informed
to be exactly sure where Defra stands on the culling issue. However
we have the very real impression it has spent so long diverting
farmers' attention away from discussion on badger culling that
now the need to offer constructive thoughts on the conduct of
an effective badger cull has been thrust upon it is shown to be
woefully short of useful ideas.
45. This would certainly explain why it
appears to think an effective cull can, and should be, organized
(and largely paid for) by farmers while we are already certain
that an effective cull requires long term government assistance
with manpower, planning and funding.
46. The NBA is looking for confirmation
from Defra that it recognizes the scale of the task ahead and
the need for its help and commitment. We see more serious examination
of the need to include carbon monoxide in this summer's culling
tool box as proof of its realization that it simply cannot, after
10 years of saying no, simply lob the culling ball at the farming
body and tell it to get on with it.
47. However there may be more sinister reasons
for Defra's lack of interest. It may think that by opening the
way for a few farmers to relieve their TB frustrations to have
a pot shot at a few badgers it will more easily persuade the farming
lobby to accept the cost of cattle pre-movement testing in heavily
infected TB areas.
48. We would certainly hope this is not
the case, especially as the perturbance such disorganised activity
would create would compound the TB problem, and look forward to
being reassured that such thinking is wrong.
49. Nevertheless it is abundantly clear
that Defra does not appear to fully appreciate the responsibility
thrust upon it through bovine TB being a notifiable disease—not
least because it is a zoonosis with the potential to damage human
beings who have contracted it through cattle and milk—or
more likely these days from diseased badgers either directly or
through their contact with household pets.
50. Our understanding is that Defra is required
by law to control and then eliminate bovine TB in GB—which
it has manifestly failed to do—and that it is under genuine
pressure from the European Commission introduce more urgency into
its anti-TB activity now that the disease is doubling in intensity
every four years and therefore posing an even greater risk to
human and animal health.
51. The NBA itself is astonished that Defra
does not yet appear to be ready to invest in reducing the anticipated
cost of further TB spread, estimated at £2 billion over the
next 10 years unless effective action is taken, by working with
industry in establishing the framework for a planned attack on
TB through the organized culling of large numbers of badgers,
across vast tracts of countryside over a considerable period of
time.
January 2006
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