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Bovine TB: Culling Badgers

March 2006

Introduction

Some Important General Points

1. The National Gamekeepers’ Organisation does not have any particular expertise to comment on what level of badger cull would reduce bovine TB, nor does the NGO regard itself as an appropriate body to make strong representations on that point. The NGO does, however, recognise the link between TB infection in badger social groups and bovine TB in cattle which graze over areas that TB infected badgers forage. Increasing outbreaks of TB in various wild deer species are also circumstantially linked with contamination of the environment by TB infected badgers.
2. Gamekeepers have a wealth of knowledge about wildlife management and some of the culling techniques being suggested, so our comments below concentrate especially on that area of the consultation.
3. It remains our firm belief that badger numbers in many parts of England and Wales are excessively high, causing many problems for wildlife unrelated to TB. We have repeatedly called on Ministers[i], on MPs[ii] and on Defra[iii] to address this issue in a wider context and we make no apology for repeating those calls now. 
4. It should never be forgotten that the Badgers Act was based on a false premise that there were only some 25,000 to 35,000 badgers left in Britain, yet within a year of its becoming law, another survey by the then Nature Conservancy Council estimated the population at around 250,000. In some areas badgers have now reached saturation levels and are having a serious impact on free range agriculture of various types, as well as crop-growing and - perhaps most seriously - wildlife.
5. The NGO is far from certain that there would be enough voluntary participation in regional badger culls to achieve the near eradication over a period of several years that the Government thinks will be necessary in order to control TB in high incidence areas. This is because:  Culling would need to be efficiently carried out over a long-term period;   Not all farms would benefit from a reduction in TB (eg those without livestock).: The culling would be time consuming and onerous, whatever methods are used; People would justifiably fear interference from animal rights campaigners.
6. Some gamekeepers would no doubt be willing to take part in a TB-related cull, although to be frank their motivation for doing so is far more likely to be connected with game and wildlife protection than it is with any desire to control TB.  
7. Nearly all gamekeepers are equipped with firearms, and their knowledge of wildlife, snaring, trapping and safe shooting makes them potentially ideal candidates to become involved. However: The decision is ultimately for their employer, not the gamekeeper;   The employer may well not want to get involved in a cull for the reasons given above;  Gamekeepers themselves may not wish to get involved for fear of unwelcome attention, reprisals and the effect these might have on their normal trapping and game management activities; Gamekeepers are extremely busy with other duties;  Their least busy period would coincides with the most likely period for a close season on badger culling.
8. In the NGO’s experience a range of techniques is invaluable when dealing with a wildlife control situation. Different techniques suit different terrain, different times of year and individuals’ abilities.
9. We believe a far simpler and cheaper route to reducing badger populations overall would be to relax their protection nationwide, leaving individuals free to select from a range of approved methods and times for control, irrespective of their motivation for doing so. This would lead to management in much the same way as foxes or mink are currently controlled. It would of course need to be monitored and adjusted or reversed if necessary (not least to meet the UK’s obligations under the Berne Convention). The approach would benefit wildlife and farming generally, and whilst it would be unlikely to lead to the local eradication said to be necessary for TB control, it would surely help. A national approach would avoid all the problems of victimization referred to above, because control would be widespread and not identifiable to specific areas.     

Specific Answers to the Consultation Questions

1. We agree that localised culling might help to control bovine TB although we emphasise that we are not experts in the relevant area of science (see above). 
2. We cannot see any obvious errors in the costs assumptions set out in the Regulatory Impact Assessment. We strongly recommend, however, that the alternative scenario of a national cull outlined in point (9) above is also costed for comparison. 
3. Under the scenario being suggested in the consultation document, the necessary licensing under the Protection of Badgers Act would clearly have to be for individuals who were part of a coordinated cull. Data protection of licensed individuals would be essential to avoid harassment by animal rights extremists. 
4. We are not competent to say what size a cull area should be in order to have an effect on TB. Whatever its size, it would need to be clearly mapped and use prominent features such as roads and rivers as boundaries. It would also be sensible to allow landowners whose properties straddle the boundaries to participate across their whole holding. 
5. We think there is a high probability that voluntary uptake of a licensing regime will be insufficiently contiguous to result in the necessary cull. Few individuals are likely to undertake sustained, effective control of badgers. Para 71 of the consultation document seems to suggest that in recognition of this problem, licences might be granted for cullers to operate on other people’s land. We think this is a non-starter. All other bird and mammal control is based on the principal that only the owner, or someone authorised by the owner, can be involved. There are good reasons for that and the same must apply here. 
6. We have no comment on what qualifying disease history would be appropriate.
7. We have no comment on what criteria should be used to define which farmers are eligible for a licence. There will need to be a set of criteria for the farmer and a different set of criteria for the person(s) actually doing the culling (eg expertise, firearms, training). 
8. We think it unlikely that primary herd owners will be able to recruit neighbours with any certainty for the reasons set out above. 
9. For the same reasons, achieving a consistent and efficient cull over a large area for up to 5 years relying on volunteers seems to us to be unrealistic. 
10. There are no potential culling methods missing from Defra’s list except poisoning. We heard what was said about poisoning at the meeting in Bristol on 22 February but we wonder if it should be dismissed out of hand. It is, after all, one of the intended techniques for dealing with a rabies outbreak and it is currently the method of choice for rodent and squirrel control. With the right compound it could be safe, efficient, cheap and highly effective. 
11. Having heard at the Bristol meeting how technical the process of gassing a sett effectively can be, we do not think gassing is an appropriate method for voluntary licencees. Older gamekeepers and some who assisted with Government co-ordinated gassing programmes in the past know, however, that gassing can be very efficient, so it would need to be part of any strategy. It could particularly have a role in the hands of state employees but the skills and knowledge required are not easily transferable from activities with which farmers and gamekeepers are currently involved. Training would therefore be necessary. Widespread bad gassing would be easy to achieve – everybody has access to a petrol engine and a hosepipe – but getting the job done well using the right gas would be more difficult. 
12. Any training for gassing should be provided by Defra at their expense. 
13. See 12 
14. We believe that shooting of ‘free-running’ badgers is one option for general control but the reference to ‘running’ is unfortunate (no-one should use a rifle to shoot a running target). Both shotguns and rifles could be used and, at appropriate ranges and in suitably safe circumstances, clean kills would be perfectly possible. The necessary skills are widely held and so too are the guns. In the case of firearms, conditions on the certificates might need variation. Shooting could take place during other pest control activity (fox lamping, deer stalking, rabbit shooting). It would therefore be relatively time-efficient. It has the added advantage that no hardware has to be left on the ground, where it would be vulnerable to interference. There is also no complication with non-target fatalities. The downside with shooting is that, as with foxes, it is unlikely on its own to result in a sufficient reduction in the badger population to control bovine TB. 
15. The badger body snare on which Defra has been working might help to supplement shooting and it could be particularly valuable in control near to setts. The design appears to have all the necessary features although no doubt it can be fine-tuned in trials. 
16. An inspection regime of every 4 hours has been suggested for the badger body snare and this causes us concern. In part this is because we think snares are unlikely to catch within an hour or two of being set/visited. We also think once every 4 hours is very onerous and will reduce uptake of an otherwise potentially useful method. In the main, however, our concern is that a precedent could be set for shortening the inspection interval for other types of snare to an unreasonable and indeed unworkable extent. Defra needs to be very careful that in this whole process, precedents and comparisons that could cause problems for other aspects of wildlife management are avoided. This is just one example. To mention another, it was unhelpful to hear all rodenticides being described by a Government employee at the meeting on 22 February as “markedly inhumane”. We have similar concerns about the precedents set by requiring close seasons for badgers and the presumption against any use of poisons.  
17. Subject to satisfactory trial of a reasonably humane body snare and accompanying methodology, we are confident that gamekeepers and other snare users could easily translate their expertise to this new technology for badgers. 
18. Some simple training might be necessary for existing snare users to become familiar with the new device. More substantial training would be essential for newcomers to snaring. 
19. Training should be provided by Government and at their expense. For political reasons the NGO is unlikely to want to be associated with training people in how to snare badgers. Other organisations might well take a similar view. 
20. Badgers culled in areas where TB is a problem should be referred to the nearest VLA laboratory for examination and disposal. Elsewhere, most gamekeepered estates already have a secure dead-hole for the disposal of trapped or shot pest species. 
21. The proposals for monitoring the badger population and other wildlife seem sensible. Access by those doing the monitoring is often an issue for landowners, closely linked to the nature of the individuals concerned, their employment and the code of practice under which they operate. All these would need to be sorted out. We feel certain that badger culling would result in overall wildlife benefits and we note with interest that in the Randomised Badger Culls carried out so far, hedgehogs increased by around 100% in the areas where badgers were culled.
    

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