Memorandum submitted by Wildlife and Countryside
Link (BTB 24)
1. Wildlife and Countryside Link (Link)
brings together voluntary organisations concerned with the conservation,
enjoyment and protection of wildlife, countryside and the marine
environment. Our members practice and advocate environmentally
sensitive land management and food production practices and encourage
respect for and enjoyment of natural landscapes and features,
the historic environment and biodiversity. Taken together, our
members have the support of over eight million people in the UK
and manage over 476,000 hectares of land. This statement is supported
by:
(b) Royal Society for Prevention of Cruelty
to Animals
(c) Royal Society for the Protection of Birds
(f) World Society for the Protection of Animals
2. Link welcomes the Environment Food and
Rural Affair's Committee's inquiry into the Government's consultation
on badger culling. In particular, we welcome the Committee's intention
"to focus on the key questions that Ministers must address
in reaching conclusions on the issues set out in the consultation
paper".
3. Link has identified a number of fundamental
issues that it believes need to be addressed.
4. ANY BADGER
CULLING POLICY
NEEDS TO
BE FOUNDED
UPON SOUND
SCIENCE
(a) Link notes the issues raised by the
Independent Scientific Group (ISG) who have expressed their concern
that their advice has not been incorporated and warned that the
consultation document is "inaccurate in important respects",
strongly suggesting that it is not based on sound science.
(b) The independent advice of the Chief
Scientific Advisor's Science Advisory Council (SAC) also appears
not to have been taken into account by Defra in drawing up the
proposals. For example, the SAC have advised that cattle-to-cattle
transmission is the dominant transmission factor regarding bovine
TB in Great Britain and that culling badgers is unlikely to be
an effective control measure unless and until further cattle based
measures have been implemented successfully.
(c) Disease modelling work by the ISG has
indicated that relatively modest improvements either in TB test
performance or TB testing frequency would be sufficient to bring
an epidemic under control. However, there appear to be no proposals
to investigate the policy implications of such an approach.
(d) The impression is therefore of consultation
proposals being put forward despite the initial results and before
completion of the Randomised Badger Culling Trial (RBCT), other
scientific evidence and independent scientific opinion. Link believes
that this raises serious questions over Defra's interpretation
of science when planning policy developments.
(e) Link notes that Defra makes no proposal
for a "Plan B" involving strategies other than culling
badgers, strongly suggesting a lack of strategic thinking or that
a decision to cull has already been made, or both.
5. ANY BADGER
CULLING POLICY
REQUIRES THOROUGH
RISK ASSESSMENT
AND A
ROBUST ASSESSMENT
OF ITS
FEASIBILITY AND
ECONOMIC VIABILITY
(a) Link suggests that the EFRA Committee
request clarification from Defra whether a risk assessment of
the proposed badger culling strategies was made together with
a study of the feasibility of implementation.
(b) Link believes that before proceeding
to full consultation, an updated cost benefit analysis on badger
culling, taking into account the initial results of the RBCT,
should have been received by Defra and made available as part
of the public consultation.
(c) Given that a cost benefit analysis of
badger culling options has been undertaken by Defra, Link believes
that a similar comparative cost benefit analysis of other measures,
including vaccination of cattle and/or badgers, to minimise the
risk of transmission from badgers to cattle should also have been
commissioned.
6. ON IMPLEMENTATION,
ANY POLICY
MEASURE SHOULD
BE MONITORED
AND ASSESSED
THROUGH ROBUST
SCIENTIFIC AND
ECONOMIC STUDIES
(a) Link would welcome further information
on how Defra will distinguish between the costs and benefits of
controls on cattle compared with the control of badgers, if both
policies are implemented simultaneously.
(b) Link has a number of concerns as to
how Defra will monitor whether licences for culling badgers are
fully implemented and whether the licence conditions are adhered
to.
(c) Link has a number of concerns as to
how pre-movement testing will be monitored and enforced by Defra.
7. ANY CONTROL
OF BADGERS
WILL NEED
TO COMPLY
WITH NATIONAL
AND INTERNATIONAL
LEGAL OBLIGATIONS
ON BOTH
ANIMAL WELFARE
AND SPECIES
CONSERVATION
(a) Link is concerned that Defra has proceeded
with a consultation on culling strategies without providing information
on key aspects including: (i) the proportion of Britain's badgers
that the Government is proposing would be culled; (ii) the proposed
number of badgers that would be culled; and (iii) the wider implications
the culling strategies would have for nature conservation.
(b) Link suggests that the EFRA Committee
ascertains as to whether Defra has applied for licences from English
Nature to capture wild badgers to validate, in a controlled scientific
study, the efficacy and welfare implications of different culling
methods.
(c) Link remains unsure as to why Defra
is proposing gassing or the use of body snares when much information
to inform an assessment of such methods is still to be obtained
and suggests that this clarification be requested by the EFRA
Committee.
(d) Link would welcome further evidence
on how Defra will ensure that animal welfare standards are maintained
under the various culling strategies.
(e) Link would also welcome evidence as
to how Defra will enforce animal welfare standards if they are
not met, as we do not believe this is sufficiently addressed in
the current consultation document.
(f) Link would welcome evidence as to how
Defra will ensure the conservation status of the badger is not
threatened by culling, as we do not believe this is sufficiently
addressed in the consultation document.
February 2006
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