Memorandum submitted by League Against
Cruel Sports (BTB 25)
EXECUTIVE SUMMARY
The League Against Cruel Sports considers that
the scientific evidence shows overwhelmingly that badger culling
should not be used as a strategy for the control of bovine Tuberculosis.
Indeed, it is clear from the studies discussed in this document
that culling can in fact serve to make a bad situation worse.
The League is particularly concerned about the suggested use of
snares as a culling technique, due to their cruel and indiscriminate
nature. We urge the Government to focus its efforts on decreasing
cattle to cattle transmission of bovine TB, and to steer well
clear of an uneconomic and harmful badger culling strategy.
INTRODUCTION
1. The League Against Cruel Sports is a
campaigning organisation dedicated to ending suffering and killing
of animals in the name of "sport". Throughout our 80
year history we have also been committed to the protection of
British wildlife from cruelty, and are particularly active in
regard to the plight of badgers. The League played a key role
in campaigning successfully for badger protection legislation
in the 1980s and 90s. Today, we campaign for a total ban on the
use of snares, to which badgers often fall victim, and have closely
followed the debate on badgers and bovine Tuberculosis. Our in
depth knowledge of the subject area gives us the expertise to
comment on the principles addressed in the consultation, as well
as to discuss whether snares should be used in the event of a
cull.
THE PRINCIPLE
2. In March 2005, the Government committed
to "ensuring its policies on bTB are recognised as being
soundly based on scientific evidence".[5]
In May 2005, scientists at Oxford University published evidence
to show that Cattle movements "substantially and consistently
outweigh" all other factors (including badgers) in predicting
outbreaks of bTB. [6]In
December 2005 the Independent Scientific Group, commissioned by
DEFRA to investigate the influence of proactive culling on the
number of TB breakdowns in cattle, published interim analyses
which showed that not only did intense proactive culling only
manage to reduce TB incidence within the culling area by 19% but
it actually increased it by 29% in a 2km ring around the zone.
[7]Culling
badgers made the situation worse. The reasons for this were made
clear in a study published at the same time, which reported that
culling disrupts badger territories making survivors roam more
widely than usual. [8]
3. Of further concern is the fact that it
takes badger social structures almost a decade to stablise after
disturbance, [9]meaning
that negative effects to both badger welfare and the control of
TB are likely to continue for years after culling.
ECONOMY
4. Evidence cited in the consultation document
supports the idea that badgers make a contribution to cattle infection,
but openly recognises the contribution they make is not known.
Nevertheless, the Partial Regulatory Impact Assesment published
alongside the consultation document assumes that "about half
of all confirmed TB incidents arise from badger-to-cattle transmission
and that these can be reduced in proportion to the reduction in
badger population" (annex B, paragraph 48). What is made
less clear is how vulnerable the RIA is to changes in this assumption.
If, as suggested by evidence from the Randomised Badger Culling
Trials, the actual figure was lower than 50%, it is hard to see
how any badger culling strategy could ever be cost effective.
This concern has been voiced by ISG economist Professor John McInerney,
who said "There are much more economically effective activities
you can try before you take this automatic jump into badger culling".[10]
INTERNATIONAL EVIDENCE
5. Are the international examples referred
to in the consultation transferable? While the consultation document
cites a literature review of international evidence as demonstrating
that "some form of intervention in the wildlife domain is
necessary if bovine TB in cattle is to be controlled", it
neglects to mention that this study concludes that there is evidence
"for transmission from herd to herd not involving badgers,
both locally and over long distances. This, together with experiences
from other countries, emphasises the need for effective and comprehensive
control measures within the cattle population". The report
goes on to recommend research into strategies other than badger
culling.
SNARING
6. In paragraphs 8 and 9 of the executive
summary of the consultation document, the need for any culling
policy to be "humane" is clearly recognised. The League
Against Cruel Sports considers it impossible to cull "humanely"
through the use of snares. Additionally, snaring involves a threat
to other animals due to its indiscriminate nature.
7. The consultation document states that
body snares would be used to capture and hold badgers. We are
particularly concerned that a badger caught around the body will
be able to reach its head around to chew at the snare wire, which
can cause horrific mouth injuries. Regardless of whether the snare
catches around the neck or body, there remain significant problems
with snaring.
8. A badger caught in a snare will naturally
struggle to free itself. Badgers are powerful animals, and these
attempts can tangle the snare, sometimes causing it to lock tightly
around the animal. According to the report of the independent
working group on snares, animals caught in snares can suffer:
(a) stress of restraint including frustration,
anxiety and rage;
(b) fear of predation or capture;
(c) thirst, hunger and exposure;
(d) stress of capture and handling before
despatch[11];
9. The longer a badger is caught in a snare,
the more potential there is for serious injury. Badgers caught
in snares have been known to literally "fall in half"
after sustaining wounds and pressure necrosis damage from snares.
[12]Short
snare inspection intervals may reduce the length of time for the
suffering described above, but to make the restraint "humane",
snares would have to be constantly monitored, which would have
a major impact on the cost benefit analysis—making snaring
even less economic than it is already.
10. The capture of non-target animals is
always a major problem with snaring. The partial regulatory impact
assessment states that snaring would occur "primarily"
at sett entrances (paragraph 35). Clearly it is intended that
some snaring may occur away from sett entrances, therefore meaning
that non badger captures will take place. It is worth noting that
in regard to fox snaring, the independent working group on snares
found that even with best practice it is very difficult to reduce
the overall proportion of non-target animals caught in snares
to below 40% in some environments. [13]Non-target
animals caught in body snares include foxes and small deer, particularly
muntjac. [14]
11. Non target captures may also be an issue
in snares set at badger sett entrances. Foxes commonly make their
homes in badger setts, [15]and
would therefore be at risk from snares set there.
12. The release of incorrectly snared animals
cannot be done safely, as non-target animals which "seem
fine" may in fact have very serious injuries, such as pressure
necrosis wounds, which do not become apparent for up to seven
days after release. Les Stocker MBE HonAssocRCVS, (founder of
the Wildlife Hospital Trust, St Tiggywinkles, Europe's first and
the world's busiest wildlife teaching hospital, and author of
Practical wildlife care (Blackwell Publishing, second edition
2005), the standard reference on treating wildlife casualties)
has expressed similar concerns on this issue.
ALTERNATIVES
13. Paragraph 112 of the regulatory impact
assessment states that if there were a decision not to permit
culling, this would lead to an increased enforcement requirement
for the State Veterinary Service in relation to cattle surveillance
and control measures for bTB, particularly pre movement testing.
This suggests recognition that there is an alternative to culling,
and that involves tighter controls on cattle.
14. At the recent London Zoological scientific
debate on badgers and bovine TB, deputy chair of the ISG and Head
of Statistical Epidemiology at Imperial College London, Professor
Christl Donnelly, spoke on alternatives to culling badgers. [16]She
stated that decreasing the mean rate of cattle movement between
herds would decrease the transmission of bTB, and that if test
sensitivity could be increased, even if only in a modest way,
this could be sufficient to turn the current increase in TB incidents
in cattle into a decrease. Professor Donnelly went on to say that
modelling has shown a similar reversal in trend could be achieved
by increasing testing frequencies from every 12 months to every
10 months.
15. In addition to better, more frequent
testing, there are husbandry interventions that could improve
the current TB situation in this country. These include limiting
wildlife access to feed, and keeping cattle away from badger setts.
Biosecurity measures such as the isolation of newly purchased
cattle, and the avoidance of nose to nose contact between cattle
of different herds could also reduce transmission. The cost of
these measures for farmers could be addressed by Government grants,
as suggested in the 2005 Badger Trust Bovine TB Strategy.
RURAL ECONOMY
16. The Regulatory Impact Assesment places
no economic value on wildlife, biodiversity and public enjoyment
of the countryside, all of which would be compromised by any culling
of badgers, and the associated impact on the biodiversity of the
countryside. The economic assessment of the costs and benefits
takes no account of these wider issues. The potential for impact
on the rural economy caused by changes in visitor patterns (such
as during the Foot and Mouth Disease outbreak[17]),
has not been considered, and neither has the impact of the negative
publicity on farmers and Government departments involved in any
cull.
SUMMARY
17. The scientific evidence on bovine TB
points clearly to a policy that must address cattle movements,
and should on no account involve culling badgers. The extent to
which badgers contribute to cattle infection is not known, and
culling trials have increased the disease in areas around cull
sites. However, the Government continues, through their recent
consultation, to give the impression that the way to solve the
bTB crisis is culling badgers. We hope that the Government will
heed the ISG's recent advice that the consultation is "inaccurate
in important respects",[18]
and abandon it in order to focus on the key issue: cattle to cattle
transmission.
February 2006
5 Government strategic framework for the sustainable
control of bovine TB in Great Britain page 36, March 2005. Back
6
Gilbert et al, 2005 Cattle movements and bovine tuberculosis
in Great Britain, Nature 435, 491-496. Back
7
7 Donnelly, C et al (December 2005) Positive and negative
effects of widespread badger culling on tuberculosis in cattle,
Letters, Nature. Back
8
Woodroffe, R et al (December 2005) Effects of culling
on badger Meles meles spatial organisation: implications
for the control of bovine tuberculosis, Journal of applied
ecology. Back
9
Cheeseman, C L, Mallinson, P J, Ryan, J and Wilesmith, J W (1993)
In Hayden, T J (ed) The Badger, 78-93. Dublin. Royal Irish
Academy. As cited by Bovine TB strategy, Badger Trust,
December 2005. Back
10
Farming Today, BBC Radio 4, 26/1/06. Back
11
Report of the Independent Working Group on Snares, August 2005,
page 50. Back
12
Les Stocker MBE HonAssocRCVS, St Tiggywinkles Wildlife Hospital,
Personal Correspondence. Back
13
Report of the Independent Working Group on Snares, August 2005,
page 55. Back
14
Les Stocker MBE HonAssocRCVS, St Tiggywinkles Wildlife Hospital,
Personal Correspondence. Back
15
Professor Stephen Harris, School of Biological Sciences, Bristol
University-Personal Correspondence. Back
16
London Zoo, 24 January 2006. Back
17
See for example The Report of the Rural Task force: Tackling
the Impact of Foot and Mouth Disease on the Rural Economy
DEFRA October 2001. Back
18
Letter from the ISG to Ben Bradshaw MP, 20 January 2006, as included
in Badger Trust press release "Minister Challenged over Science
Errors", 24 January 2006. Back
| 
