Badger Public Consultations
Consultations close in December (8th in England and 17th in Wales) - Act Now!
Please take this opportunity to tell the governments both in England and Wales exactly what you think about their plans to slaughter badgers. To make things easier for you, we have written pre-prepared emails for you to copy and paste – although please do try to personalise (but keep to the question format to help ensure that your comments are recorded!). However, the most important thing is that you object.
Please note: both consultations close in December (England on 8 December and Wales on 17 December). It is vital that you contact them before then. It is most important that you send one to the country where you live – but you can also send both no matter where you live.
When you have objected. Please also consider ordering materials for our National Day of Action for Badgers on November 27 (which include leaflets and postcards to give to friends and family to object to killing badgers). Find out more here.
Important: You must put you name and address with your objection. Failure to do so could result in your objection being voided. You can indicate if you would like to remain anonymous. If you reply by post it is vital that you use the exact address supplied below. Use our template below as guidance:
“I am writing to lodge my objection against plans to kill badgers in England/Wales (delete where appropriate) as a method of TB control in cattle. I wish for my views to be recorded and submitted for the consultation. Please find my answers below.
[full name and address including country]
(Please note: the English consultation is now closed. This is now for information only)
How to respond (to Defra)
Address: TBBC mailbox, Nobel House, 17 Smith Square, London, SW1P 3JR
Q1: Comments are invited on the options, costs and assumptions made in the Impact Assessment.
I am against the killing of badgers because it has not been proven that wildlife is a significant vector in the spread of TB in farmed animals. I am also ethically opposed to killing wildlife – especially when the real cause for the spread of the disease is bad farming practices and agricultural mismanagement. Killing wildlife can never be justified, especially when non-lethal approaches are available – or soon will be.
Q2: Do you agree with the preferred option?
No. I do not believe that guidelines will be properly followed and the preferred option is essentially untenable.
Q3: Do you agree that this approach of issuing licences to farmers/landowners, is the most appropriate way to operate a badger control policy?
No. It will be impossible to monitor the effectiveness (if any) of badger ‘culling’ in such a piecemeal approach. There can also be no monitoring of how badgers are killed – and this could lead to immense suffering.
Also, as farmers themselves are paying for the work – and as shooting will be invariably be cheaper than vaccination – I am extremely concerned that a lethal approach will be taken the majority of the time.
Q4: Do you agree with the proposed licensing criteria for culling and vaccination?
No. ‘Culling’ badgers has been shown not to work as an effective way of controlling the spread of disease. Vaccination of badgers is preferable to killing them. Killing badgers will have no meaningful impact on the spread of the disease (as detailed in the 10 year ISG report), but will cause untold suffering. However, as cattle-to-cattle transmission is the largest cause of infection within herds it is something of a moot point.
Also, the latest evidence shows that TB infections rates in cattle has fallen recent. Also, fewer cattle were killed in 2009 than were in 2008 because of TB infection. This shows that existing cattle controls are working, and therefore badger ‘culling’ is not needed.
Q5: Do you agree that the proposed methods of culling are effective and humane?
No. There can be no way that the proposed methods of killing badgers can be described as humane. Caged badgers will suffer a considerable time in an alien environment before they are shot. Even worse is the proposal to allow the shooting of free-running badgers either by rifle or shotgun. The proposals admit that this is untested. As badgers are nocturnal animals, shooting will invariable happen at night, which in itself presents difficulties. Because of the unique physiology of badgers (their short squat bodies, thick skull, thick skin and thick layer of subcutaneous fat) maiming and injury is highly likely. This method may result in a high number of badgers being shot but not killed outright. Therefore, it cannot in any sense be described as humane.
It will also not be effective. Badger ‘culling’ is not an effective way of controlling TB in cattle. This piecemeal approach – where ‘culling’ may be undertaken on one farm but not its neighbouring farms is liable to spread the disease – and could make rates of infection worse.
Q6: Do you agree with the proposed use of vaccination, particularly its focus on mitigating the perturbation effects of culling?
Vaccination of badgers is preferable to killing them. However, vaccination of badgers will have little meaningful impact on the spread of the disease (but will protect badgers from being infected so on its own could be useful). And, as cattle-to-cattle transmission is the largest cause of infection within herds it is something of a moot point. Vaccination of cattle should take priority (or the investigation into its appliance) – as should an immediate investigation into the intensification of dairy farming and the affect it has had on the susceptibility of dairy herds to disease.
Also, again, such a piecemeal approach to vaccination in surrounding areas (by relying on farmers to pay to vaccinate), may just add to the perturbation effect (badgers moving from infected areas) as outlined in the ISG report as one of the main reasons why badger ‘culling’ can have no meaningful effect on controlling TB in cattle.
Q7: Should anything further be done to encourage the use of vaccination?
Yes, as detailed in question 6, badger vaccination may play a role in keeping the badger population healthy and stop badgers being infected by cattle with TB. The development of an oral vaccine must remain a high priority for badgers.
Vaccination of cattle should also take priority (or the investigation into its appliance) – as should an immediate investigation into the intensification of dairy farming and the effect it has had on the susceptibility of dairy herds to disease.
Q8: Do you agree with the proposed monitoring?
The proposed monitoring is scattershot at best and likely to be highly incompetent and even perhaps fraudulent at worst. Defra has stated that ‘culled’ badgers will not be tested for TB. This means that this proposed ‘cull’ is unscientific and cannot be reliably used to inform future policy effectively. There will be absolutely no way to judge what methods of TB control are effective – and it is worrying that badgers will be blamed should there be a decrease in TB levels in cattle, even though stringent cattle controls will, in reality, be the key.
I can also not see how welfare issues can be monitored. How does the government propose to monitor the killing and judge how humane methods of killing are? It will also be impossible to ensure that there is complete compliance with the licencing conditions.
(closes 17 December 2010)
How to respond
Address: TB Team, Office of the Chief Veterinary Officer, Department of Rural Affairs, Assembly Government, Cathays Park, CF10 3NQ
Q1: Do you object to the culling of any wildlife for the purposes of controlling disease in farm animals? If yes, please explain why?
Yes, because it has not been proven that wildlife is a significant vector in the spread of TB in farmed animals. I am also ethically opposed to killing wildlife – especially when the real cause for the spread of the disease is bad farming practices and agricultural mismanagement. Killing wildlife can never be justified, especially when non-lethal approaches are available – or soon will be.
Q2: 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 culling to prevent disease transmission? If yes, please explain why?
Yes, vaccination of badgers is preferable to killing them. Killing badgers will have no meaningful impact on the spread of the disease (as detailed in the 10 year ISG report), but will cause untold suffering. However, as cattle-to-cattle transmission is the largest cause of infection within herds it is something of a moot point. Vaccination of cattle should take priority (or the investigation into its appliance) – as should an immediate investigation into the intensification of dairy farming and the affect it has had on the susceptibility of dairy herds to disease.
Q3: 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 science does not support the killing of badgers for disease purposes. Indeed, as already mentioned, the ISG report concluded that killing badgers would not prevent the disease spreading – but might make it worse (caused by badgers moving to new land). I understand that the IAA has been chosen because of its hard geographical borders (such as rivers) to somewhat prevent this. However, this is not the case in much of Wales. Therefore this experiment is worthless as it cannot be replicated across Wales – and is therefore scientifically unsound. It will also be scientifically unsound because there will be no way to measure the effectiveness of the ‘cull’ when other measures (such as tighter cattle controls) are to be put in place. A reduction in TB may wrongly be linked to killing badgers, when it is actually other methods that have secured this.
Q4: 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. Any disease in animals should be dealt with. However, a ‘cull’ of badgers will not be the solution for the high incidents of TB in the IAA and in other parts of Wales. The reason for high incidents of TB in the IAA are many, including large cattle numbers (especially dairy herds), a high number of cattle movements and tests for TB in cattle that often fail to spot infection. Also, in general, dairy herds are twice the size they were in the 1970s and dairy cows produce more milk than they ever have done. This takes a toll on them and their ability to fight disease. Strict cattle movement controls, re-evaluation of the intensive nature of the industry and cattle vaccination are practical ways of reducing TB – all without killing badgers.
Q5: Do you believe that access to land for culling badgers should be enforced? If not, why not? Please give reasons for your answer.
No. It goes against the nature of a democratic society. It infringes basic human rights and forcibly overrides an individual’s personal beliefs. This kind of heavy-handed and autocratic policy has no place in a modern, civilised society. People should be given to opportunity to opt out of any ‘culling’ on their land.
Q6: 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. The decimation of the badger population over a large part of Wales – and the ignoring of civil liberties and physical disruption to local communities – is not outweighed by what has already been proven will be a minimal reduction (if any) in TB incidences. Removing a natural predator from this ecosystem will have unknown results – and none of them good. Also, there is no humane way to kill badgers. Caging and shooting them will be violent and traumatic for badgers, and is ultimately pointless.
Q7: Do you agree with the prohibitions under the draft Badger (Control Area) (Wales) Order 2010? If not, why not?
No. This is an excessive use of power and an infringement of civil liberties. It is also likely to be divisive for local communities. The science does not support this approach, and my earlier points show that the planned ‘cull’ in the IAA is both unscientific and ultimately will cause more harm – both to badgers and people – than purely cattle based measures. The economic impact of killing badgers, from loss of earnings in Wales from a tourism boycott, will undoubtedly be very large.