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WELSH BADGER CONSULTATION - Advice and TEMPLATE reply

FROM BADGER TRUST
9 December 2010

Subject:
Badger Trust Cymru Advice on "Bovine TB Eradication Programme:
Consultation on Badger Control in the Intensive Action Area" issued by Welsh Assembly Government

Dear Friends,

I am writing on behalf of Dave Williams who is not in the office today. As you know, we are already very grateful to everybody for the help given to Badger Trustin generating responses to the Consultation on Bovine TB issued by Defra on behalf of the Coalition Government.

We have a final favour to ask of you this year. As many of you may already know, the Welsh Assembly Government issued a consultation on 20th September 2010 which closes on 17th December 2010, called "Bovine TB Eradication Programme: Consultation on Badger Control in the Intensive Action Area" (IAA). We have done our best to try to deal with the two consultations but I have to be honest,we are very behind with that for Wales although many other organisations in Wales are already working hard to raise public awareness and generate responses. Sadly, many people believe that because Badger Trust won the Appeal re. the previous Welsh consultation, the badgers in Wales are now safe but that is far from being the case. If you can please give us a little more of your time, you may be able to help us to save them.

The recent bad weather has also created difficulties andas a result, we decided last weeknot to print the Welsh Guidance notes but to distribute them electronically and you will find our Advice notes further down this e-mail. We are aware that this is a very busy time of year for everybody but if you are can, please will the recipients of this e-mail complete the attached Response Template by referring to the Advice notes and e-mail or post it to the address given. If you print the Response Template, you will need to increase the space between the questions to allow room in which to write. Responses must be made in time to arrive by 17th December 2010.

If you live in Wales or have friends there, please do all you can to encourage them to respond and to pass it to their friends and neighbours as it is likely that more weight will be given to replies from within Wales. However, a good response from other parts of the UK is also very important.

Thank you once again, we firmly believe that by working together we have made a positive impact for our badgers as far as England is concerned and we need to do the same for Wales. We all feel  that their continued protection is the best Christmas present we can give to badgers, wherever they live and with your help it can be done.

With best wishes to you and your families for Christmas and the New Year,
Pat Hayden,
Vice Chairman, Badger Trust.

 

DOWNLOAD TEMPLATE DOCUMENT HERE

 

The Advice Notes follow:

BADGER TRUST CYMRU ADVICE ON “BOVINE TB ERADICATION PROGRAMME: CONSULTATION ON BADGER CONTROL IN THE INTENSIVE ACTION AREA” (IAA) (Issued by Welsh Assembly Government (WAG) on 20thSeptember 2010 closes 17th December 2010).

Reasons for the current threat to badgers

· Bovine tuberculosis (bTB) in cattle is a serious problem although recently there has been a decline in incidence since strict and increased cattle measures have been introduced.
· Compensation to farmers cost taxpayers in Wales about £120m during the last 10 years.
· Some people believe badgers are the sole cause of the problem. This is definitely not so although they are affected by the disease. Even in bTB areas only 1 in 7 badgers may have TB. Most badgers are TB free.
· Although badgers are protected by law, the Welsh Assembly Government can issue licences to kill them in certain specified circumstances.

What does the Welsh Assembly Government (WAG) want to do?

· The WAG has issued a consultation document “Bovine TB Eradication Programme: Consultation on Badger Control in the Intensive Action Area” (IAA). The IAA is primarily in North Pembrokeshire with small parts in Ceredigion and Carmarthenshire and contains 321 herds of cattle. The WAG proposes:

· To send their agents to all farms and other properties in the IAA to trap and kill badgers in cages by shooting or lethal injection ;or to shoot free-running badgers.

· To maintain this killing every year for 5 years.

· To make it illegal for any farmer or other landowner to opt out of the cull.

· To make taxpayers pay for the killing of 1,500 to 2,000 badgers, most of them healthy.

Why the WAG’s proposal will not work.

 · The United Kingdom Government spent £50m on a 10-year badger culling trial supervised by the Independent Scientific Group (ISG) which concluded that: “badger culling can make no meaningful contribution to the control of bTB”.

· The Agents will be unable to kill all badgers in the cull area as the animals are wary and some are innately trap shy. Badgers not killed are more likely to move around, perhaps taking bTB with them.

· The United Kingdom Government’s badger culling trial showed that there are profound negative impacts from culling. Although a sustained and co-ordinated 4-5 year cull led to modest falls in cattle TB in the core of the cull area, there was an increase in cattle TB on the periphery and culling led to anincreasein the prevalence of TB in the local badger population. This is known as the perturbation effect.

· WAG are not immediately promoting the use of vaccination for badgers.

What about elsewhere?

· In Scotland no badgers have been killed, yet it is officially bTB free.

· In the Republic of Ireland thousands of badgers have been killed but bTB remains a big problem. The intention is to replace culling with badger vaccination and cattle controls.

· In England the coalition Government has issued a consultation document on their proposal to cull badgers in selected areas. The consultation ran from 15th September to 8th December 2010.

What should be done?

The 2007 ISG report recommended that improved cattle controls would greatly reduce incidents of bTB. The TB advisory group and the TB eradication group also recommended increased cattle controls and improved testing.

· Cattle husbandry and biosecurity (disease prevention measures) could still improve. The WAG offer only “advice” to farmers, they do not enforce measures which would lead to a reduction in TB.

· Cattle herds are becoming larger and many farmers keep cattle in close contact in large sheds for long periods increasing the risk of passing TB from cow to cow.

· All cattle controls still need to be rigorously enforced.

EU regulations should be altered so that cattle can be vaccinated against bTB.

Badgers should be vaccinated, not killed. This is the only sustainable long term solution to address TB in badgers. Scientific evidence which fully supports this assertion has been published in 2010 subsequent to the Court of Appeal judgment, which quashed the WAG’s plans on all three grounds.

The Welsh Assembly Government proposal seeks to placate those farmers who support a cull yet it makes all taxpayers bear the cost. It does not deal with the principal factors that perpetuate bTB in cattle, notably:

     · Inaccurate testing for bTB, leaving infected cattle in the herd.

     · Moving cattle with undiagnosed bTB.

Other reasons for the slaughter of cattle

It is estimated that c. 300,000 dairy cattle over 2 years of age were prematurely culled in GB in 2008. The bulk of these died from causes other than bovine TB (eg mastitis, infertility, lameness etc.). (Defra Cattle Book 2008).

PLEASE HELP US TO PERSUADE THE WELSH ASSEMBLY GOVERNMENT NOT TO KILL BADGERS

How you can help

· Read the consultation document at http://wales.gov.uk/docs/drah/consultation/101022bovinetbconsresponseformen.pdf Reply to its 7 questions (see Guidance on Response to Consultation document below). This is the most important of the ways in which you can help.

· Write to:
     ·  Elin Jones, Minister for Rural Affairs, Welsh Assembly Government,
        5th Floor, Ty Hywel, Cardiff Bay, CF99 1NA. Or email:
        bovinetbconsultations@wales.gsi.gov.uk
        · Your Welsh Assembly member at The National Assembly for Wales, Cardiff Bay, Cardiff,
          CF99 1NA. You can find your AM at
        · http://www.assemblywales.org/memhome/member-search.htm
· Write to your local newspaper and raise publicity about the futility of killing badgers as a means of combating bTB.

Guidance on Response to Consultation Document

· There is a separate response template attached.
· The 7 questions are pre-printed on the template.
· You must answer either Yes or No to each question.
· Dependent upon your reply, you are invited to explain your response.
· Obviously, you should and must express whatever views you have on the subject and are not bound to follow our position.
· Wherever a comment is entered it isextremely important to use your own words rather than repeating what is given here.
· There is an additional section at the end in which you can refer to related issues you may have which are not previously covered.
· Please ensure you complete your personal details, sign the form and indicate whether or not your details can be published.

---

Question 1: Do you object to the culling of any wildlife for the purposes of controlling disease in farm animals? If yes, please explain why.

Yes. In the opinion of Badger Trust Cymru, wildlife should not be culled for the purposes of controlling disease in farm animals unless there is no other satisfactory solution or there is an immediate threat to human health. Vaccination of badgers and enforced improvements in cattle husbandry and biosecurity (disease prevention measures) offer a much better alternative solution. Bovine TB in the UK poses a negligible threat to human health. Not only is there no justification for killing badgers, it could well make the cattle TB problem worse through perturbation. It is not cost effective on any level.

Question 2: In view of the fact that a licence for an injectable vaccine for badgers is now available, do you think that vaccination of badgers in bovine TB endemic areas is a viable alternative to cullingto prevent disease transmission?If yes, please explain why?

Yes. It has been reported that models and field trials prove that vaccination protects badgers from TB without the negative effects of culling. So long term it could reduce the incidence of TB in both badgers and cattle. An injectable vaccine is currently available. Provided there is no cull the WAG could obtain assistance from badger groups to administer this. The development of an oral vaccine should be expedited as this would be easier to distribute. Vaccination offers a sustainable long term option for controlling TB in badgers with none of the negative risks or controversy associated with badger culling. (By analogy, when efforts to combat rabies in foxes through culling proved ineffective, it was vaccination which successfully eradicated rabies from much of Europe.)

Question 3: Do you believe that culling badgers can achieve a reduction in bovine TB incidence in cattle, to justify its use? If no, please explain why?

No. The principal factors that perpetuate bTB in cattle are (1) inaccurate testing that leaves infected cattle in the herd and (2) moving cattle with undiagnosed bTB. Peer-reviewed scientific evidence does not support the claim that the culling of badgers will have a significant impact on the reduction of bTB. In fact, in the short term at least it is likely to make the situation worse and the absence of a control area means that there will be no means of measuring the efficacy of culling.

Question 4: Do you agree that the Intensive Action Area has a high incidence of bovine TB in cattle which needs to be dealt with? If no, please explain why?

Yes. While Badger Trust Cymru would agree that there has previously been a high incidence of bovine TB in the IAA, this is declining without a single badger being killed. The measures already put in place by the WAG have already reduced the number of cattle herd breakdowns. Culling badgers in the manner proposed is likely to worsen matters. The focus should be on the improvement of cattle controls: movement restrictions, regular testing, improvement and monitoring of biosecurity, and vaccination of the badger population with help from local badger groups.

Question 5: Do you believe that access to land for culling badgers should be enforced? If not, why not? Please give reasons for your answer.

No. As bovine TB is not a threat to the health of the human population, it is the opinion of Badger Trust Cymru that the enforcement of access to land against the wishes of the landowners is a disproportionate interference with their human rights to respect for private life and home and peaceful enjoyment of their property. There are many landowners in the IAA who are opposed to culling for a variety of reasons and they should be entitled to refuse access. Enforcement will undoubtedly have an effect on the economy in the area as some landowners find that badgers attract visitors. Tourists expect to enjoy the peace and beauty of the area and will be deterred from visiting and thereby contributing to the economy, if they know that badgers are being slaughtered there.

Question 6: On balance, do you think the benefits of culling outweigh the harm caused to the badger population in the Intensive Action Area? Please give reasons for your answer. Would you include other factors in the balance of harm and benefits? If so, why?

No. Benefits from badger culling are marginal at best and relatively short term. Culling is not economically viable, it will not have a significant impact on the incidence of bovine TB, and the proposed methods are likely to make bTB worse rather than better. If bTB does decline there is no control in place to establish whether it is the culling which has been effective or the concurrent improvements in cattle management. The shooting of free ranging badgers is both dangerous to the human population, other wild animals and pets and it is potentially inhumane. Many badgers are likely to be injured rather than killed outright and will suffer as a result.

Question 7: Do you agree with the prohibitions under the draft Badger (Control Area) (Wales) Order 2010? If not, why not?

No. The Order is based on false assumptions and a highly biased, selective interpretation of the available scientific evidence. We take exception to section 4.1 (a) which is so widely drawn that it appears to rule out any attempt (not just in the proposed cull zone but anywhere in Wales) to treat, help, rescue or rehabilitate any injured, orphaned, or sick badgers. While we cannot and do not condone illegal activity this appears to us to be an infringement of human rights, whether it relates only to the cull area or much more widely.

Final Comment:

It is clear that this decision to include badger culling is politically motivated as there is overwhelming scientific evidence that culling badgers is not the way to combat TB in cattle. This is an ill-conceived initiative for which taxpayers will feel understandably aggrieved at having to foot the bill. Badger Trust Cymru feels very strongly that the WAG should reconsider the position in the context of what is likely to be overwhelming and justifiable opposition to badger culling.

Badger Trust is the only charity solely dedicated to the conservation of badgers throughout the UK.
PO Box 708, EAST GRINSTEAD, RH19 2WN
Tel: 08458 287878 Fax: 02380 233896
E-mail press@badgertrust.org.uk
www.badgertrust.org.uk
Registered charity no.1111440
Company registered in the UK No.5460677

 

 

 

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