Bovine tuberculosis

We agree that Government needs to take a fresh approach to tackling this disease. In the 1970s and 1980s the then Ministry of Agriculture seemed to be on course to eliminate TB entirely from British cattle. But since then things have been allowed to get worse - mainly because of uncertainty about the need to control TB in badgers. It is clear to us now that TB must be controlled in badgers too. However there remains uncertainty about whether culling or vaccinating badgers is the best approach. Culling has been tested much more fully than vaccination.

We do not think the Government should postpone action while further research is done on vaccination and it should push ahead with licensing restricted badger culls along the lines proposed.

Defra should continue to finance field trials of badger vaccination to see whether or not it can significantly reduce the incidence of TB in cattle as well as in badgers.

Question 1
Comments are invited on the options, cost and assumptions made in the Impact Assessment

1. We have no cause to doubt the costs and benefits as set out in the Impact Assessment. We note that the overall costs of culling are much lower for the farmer-led options than for the Government-led options. This seems reasonable.
2. We agree that the taxpayer benefits more where culling is led and paid for by farmers.

Question 2 
Do you agree with the preferred option?

Yes. Option 6 has signifcant advantages over the alternatives. It will also allow for a change in emphasis between vaccination and culling should that be needed in the future.

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?

Yes. This will allow for a strategy that mixes culling and vaccination to be adapted to different local situations.

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

The criteria that are outlined are onerous and while we support most we think some issues should be reconsidered:

1. Use of snares
   While cage trapping may catch the majority of badgers some will be trap-shy. It will not always be possible to “free-shoot” these. Snares are a very good way of capturing these trap-shy animals. While there are understandable concerns about the humaneness of badly made and poorly used snares, when properly designed and properly set they usually capture animals without wounding them. Badger research workers have routinely used snares to capture and release badgers unharmed for radio tracking studies.
2. Not causing local extinction
   This a dubious requirement. It will be difficult to measure and is likely to lead to argument between those culling badgers (farmer led) and those monitoring them (government led). It is also unecessary. Badgers are very common and should a local extinction occur it need only be temporary because numbers will recover through immigration.
3. A closed season
   The most efficient way to reduce an animal population is to cull when it is at its minimum – usually just prior to or during the early breeding season. By imposing a close season during this period one will most certainly reduce the efficiency of the cull. It seems odd to protect badger cubs but then capture and kill them a few months later.

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

Quite often the most humane methods are the least effective. One needs to ensure effectiveness is paramount before trying to do it as humanely as possible. As noted above, Defra should reconsider the use of snares in some circumstances.

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

1. We think vaccination should remain an option in the strategy. We think it could be useful at particular localities where there may be a high public interest in a local sett, say in a country park or nature reserve, and where a cull would hurt local community feelings.
2. We are doubtful about the usefulness of vaccination to reduce the effects of perturbation. We don’t see how this would help given that many badgers in this pertubation zone will already be infected with TB and for them vaccination would make no difference.

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

No.

Question 8 
Do you agree with the proposed monitoring?  Monitoring should focus on:

1. Cattle surveillance to ensure farmers adhere to best practise to keep cattle to cattle and badger to cattle TB transmission rates low.
2. Adherence to licence criteria.
3. Any disruption to culling that might be caused by groups intent on illegally disrupting the cull.

SSSI monitoring is not relevant to this exercise. We are not aware of any SSSIs that have been designated because of the presence of badgers.