Dear Tim Hill, (Natural England Chief Scientist)

We write to you with respect to licence applications for badger culls under the Government's policy on Bovine TB and badger control in England (2011).

As far as we understand, the existing licences for the pilot zones in Gloucestershire and Somerset remain in force, and culling is set to continue in these areas subject to letters of authorisation from Natural England. There is also speculation that an additional licence application may have been lodged for a cull zone in Dorset.

We wish to register our professional opinion that before making any decision the Natural England Scientific Advisory Committee (or equivalent) and thence the Board of NE should re-examine the scientific evidence associated with the control of bovine tuberculosis.

In particular, they should examine the role that badgers play in the epidemiology of the disease, the hard data around the success of badger vaccination and the potential adverse impacts of badger culling on the spread of bovine tuberculosis in cattle.

The NESAC and Board should also very carefully consider the Independent Expert Panel's report (April 2014) on the welfare of badgers in the pilot trials, the withdrawal of British Veterinary Association (BVA) support for the one of the methods of culling proposed and the growing veterinary voice calling for the badger cull to be abandoned.

We are pleased to see the evidence strategy and standards section on Natural England's website, laying out its clear strategy on using evidence to weigh policy proposals (ref NE340).

We hope and trust that in particular your evidence-based work on this issue will be Fit For Purpose, Quality Assured and Transparent.

We would very much appreciate the opportunity to open a line of communication with the Scientific Advisory Council and Board for Natural England, and if possible, would like to meet and discuss the scientific evidence and professional opinion that continues to accrue against the continuation and roll-out of culling.

Our objections to the cull are manifold, but can be briefly summarised thus:

1. The scientific evidence - The majority of wildlife, bTB and veterinary scientists do not support badger culling in any area of England, including the existing cull zones in Gloucestershire and Somerset.

2. The science categorically does not support widening the cull to new areas. Many areas within the government's 'high-risk zone' for bovine TB, including Dorset, have seen substantial falls in the numbers of cattle slaughtered because of bovine tuberculosis over the two years during which culling was being carried out in Gloucestershire and Somerset.

In Dorset, the number of cattle slaughtered has fallen from 1,192 in 2012, to 748 in 2014 (a fall of over a third). Indeed, across the west region as a whole there has been a fall in the number of cattle slaughtered as a result of bovine TB policy, of approximately 16% from 2012-2014.

The falls are even more marked when increased testing intensity is taken into account. These reductions have occurred in the absence of badger culling across the vast majority of the region, and reflect improvements in Wales where badger culling has been rejected in favour of the introduction of stricter cattle measures and the use of badger vaccination in the Intensive Action Area. We therefore argue that there is no scientific reason to introduce culling when current controls are working.

3. Poor results from Gloucestershire and Somerset - The contractors in both Gloucestershire and Somerset failed to achieve the cull targets set as conditions of their licences during the first year of culling. In Gloucestershire, the contractors also failed to meet the considerably reduced targets set for the second year. The failure to achieve cull targets has likely resulted in significant badger perturbation, which is known to increase the risk of spread of bovine tuberculosis between badgers, and by extension from badgers to cattle. (See Bourne and Carter et al)

Such impacts could have been predicted from the results and subsequent analysis of the Randomised Badger Culling Trial (RBCT). These impacts have not been accounted for in the claims made by vet Roger Blowey and others for the efficacy of the pilot culls in terms of their effects on TB incidence in cattle within the cull zones, claims that have been rejected in the veterinary press (eg Torgerson et al 2015) and also in live debate with the former chair of the Independent Scientific Group that oversaw the RBCT, Prof John Bourne (at the Badger Trust AGM 2015).

4. Ethics and humaneness. The IEP report of April 2014 concluded that the pilot culls in year one failed in terms of humaneness (as well as efficacy) in both Somerset and Gloucestershire. The failure to satisfy humaneness criteria raises serious animal welfare concerns relating to the impacts of controlled shooting.

5. Lack of veterinary support. Citing concerns over lack of humaneness, the British Veterinary Association has withdrawn support for the controlled shooting of badgers. In spite of this, the method remains available to the contractors in the two zones.

6. Lack of public support. Recent polls in the cull areas suggest that public opposition to the rolling out of badger culling remains high. ()

7. There is evidence for the efficacy of badger vaccination -In their publication describing the analysis of data from a four year field study, Carter et al (2012) identified a direct beneficial effect of vaccination in individual badgers, and an indirect protective effect in unvaccinated cubs.

Their analysis suggested that intramuscular injection of BCG resulted in vaccinated badgers being 76% less likely to be tested positive by a dual diagnostic system, and 54% less likely using a more sensitive triple system of diagnostics, possibly more closely aligned to true infection status.

Furthermore, the study suggested that the risk of unvaccinated badger cubs testing positive to an even more sensitive panel of diagnostic tests decreased significantly as the proportion of vaccinated individuals in their social group increased, with unvaccinated cubs being 79% less likely to test positive when more than one third of the adults in the social group had been vaccinated.

Vaccination has the added advantage of avoiding the perturbation effect on badger social groups that can result from culling; perturbation is thought to increase the risk of infection spreading between badgers and from badgers to cattle.

8. The Chief Veterinary Officer for Wales has reported that "incidents of TB have fallen by 28%" without badger culling but with cattle-based measures and badger vaccination.

9. The badger cull policy has been overwhelmingly defeated twice in Parliament on a free vote.

10. Lack of a thorough Disease Risk Analysis (DRA). The risks of badger shooting include not only perturbation of badgers with concomitant risks of bTB spread to neighbouring areas, but also contamination of woodland with bTB infected blood and body tissues.

We have previously asked for the Disease Risk Analysis for the pilot projects, and for the use of free-shooting of badgers in particular. None has been forthcoming, and we suspect that no thorough DRA was ever conducted for the policy. We have submitted a separate FOI request regarding the missing DRA.

We are also concerned that the wider environmental impacts of badger removal on other threatened species and protected areas, and in particular the possibility of sympatric mesopredator release within the cull zones, have not been sufficiently evaluated or addressed; such evaluations are a requirement of the Habitats and Birds Directives and the Conservation of Habitats and Species Regulations 2010, and of the Convention on the conservation of European wildlife and natural habitats (Bern Convention).

11. Spiralling costs. Each dead badger killed in the pilot culls has cost the public purse over £5,000 including policing. Much of this spiralling cost is due to the unpopularity of the cull, which increases policing and logistics costs.

12. The NESAC Chair called for the cull to be immediately stopped in 2013. I am sure you are only too well aware of the expert opinion given by former NESAC Chair Prof David Macdonald, that the cull should have been stopped back in 2013.

In summary, we strongly request that the NESAC and Board take full account of the science, logistics, ethics and probity of any continued or extended culling of badgers, and examine the policy in the light of its lack of a science base, its ineffectiveness, its lack of humaneness, public opposition and spiralling costs.

It is our view that this policy does not represent an ethically sound, scientifically valid, or fiscally prudent method of controlling bovine tuberculosis. Natural England is the body the public looks to in order to ensure government policy does not harm wildlife and wild spaces.

It is incumbent on Natural England to fully consider the evidence before proceeding to endorse a failing policy which will cause untold suffering to badgers and continuing hardship for dairy farmers by failing to tackle bTB.

This Open Letter was sent to Natural England Chief Scientist Professor Tim Hill, the Natural England Science Advisory Committee, and the Natural England Board on 12th August 2015.

Signatories

Iain McGill BSc(Hons), BVetMed, MRCVS (Correspondent)

Mark Jones BVSc MSc (Stir) MSc (UL) MRCVS, Born Free Foundation

Caroline Allen MA, VetMB, CertSAM, MRCVS

Patricia Barros RVN, MBVNA

Fiona Dalzell BVSc BA(Hons) MRCVS. Department of Philosophy, University of Canterbury, Christchurch, New Zealand

Bronwen Eastwood BSc(Hons), BVetMed, CertGP (SAP), MRCVS

Richard Edwards MSc, MA, VetMB, MRCVS

Phill Elliott BVM&S, MSc, MRCVS

Jo Hinde RVN, MBVNA

Louise Flynn RVN, MBVNA

Sophie Hill MA, VetMB, MRCVS

Hannah Hughes RVN, BVNA

Shailen Jasani MA, VetMB, MRCVS, DACVECC, Emergency & Critical Care (ECC) specialist

Andrew Knight BSc(Vet Biol), BVMS, CertAW, DipECAWBM (AWSEL), PhD, MRCVS, SFHEA. Professor of Animal Welfare and Ethics, University of Winchester

Jo Lewis BSc, BVMS(Hons), MRCVS

Cobie Loubser, BVSc, MRCVS

Derek Moran BVSc, MRCVS

Andre Menache BSc(Hons), BVSc, MRCVS.

Marie O'Connor RVN

Ann Pocknell DVM, MVetSci, DACVP, DipRCPath, MRCVS

Sue Pell, MSc RVN

Judy Puddifoot BSc, MSc, BVetMed, MRCVS

Richard Saunders BSc (Hons) BVSc FSB CBiol DZooMed (Mammalian) MRCVS, RCVS, Specialist in Zoo and Wildlife Medicine

Peter Southgate BVetMed, MSc, MRCVS

Jon Twigg RVN

Liz Wheeler RVN

Jessica Upchurch BSc (Zoology), MRes, BVetMed, MRCVS.

References