Page 1 Title: Bovine TB control in Badgers consultation Date: Ref: Contact:

NFU Consultation
15th September 2010 NFUTBP/TR/CONSULT Tom Rabbetts John Royle 0247 685 8500

Circulation:

Tel: Fax: Deadline: 08/12/2010 Email:

tom.rabbetts@nfu.org.uk

Bovine Tuberculosis: The Governments approach to tackling the disease and consultation on controlling the disease in badgers
INTRODUCTION The coalition government have released a consultation document which outlines their plans for controlling Bovine Tuberculosis (TB). The consultation summarises the current disease situation in England and the ways in which it is currently tackled, it also seeks views on how bovine TB can be controlled within the badger population. The consultation document provides a range of policy options which would permit individuals (under licence) to control badgers in areas of England with high and persistent levels of TB in cattle. The NFU will be providing a response to this consultation which will be open for comment for 3 months and we will be seeking the views of members during this period. The consultation is in line with the NFUs position on TB and how it should be tackled using a multifaceted holistic approach which includes a controlled cull of badgers within infected areas. This NFU document gives a consolidated outline of the details provided in the full consultation which is available to view at NFUonline. It does not provide a view on the contents of the document. BACKGROUND Bovine TB is one of the biggest challenges facing the cattle industry. We have seen the incidence rising steadily for the past 25 years resulting in over 25,000 cattle slaughtered in 2009 as a direct result of the strict cattle control measures currently in place. Government recognise that the annual cost to the taxpayer of approximately 63 million is not sustainable in the current economic climate, and if the current policy continues the costs to both the industry and the taxpayer will increase further. Figure 1 outlines the changing picture of disease in southern England and Wales.

Figure 1: Geographical distribution of confirmed new breakdowns of bovine TB in 1998 and 2009 (source VLA).

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Page 2 MEASURES AVAILABLE TO TACKLE BOVINE TB

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There is currently pressure upon the government to control the disease in England in order to mitigate the economic impact of the disease to farmers and taxpayers, as well as to meet European Union legal requirements for trade. The consultation lays out the governments framework for tackling TB. The approach taken aims to halt the worsening disease situation and reduce the prevalence in affected areas to ultimately enable eradication. This has led the government to commit to putting in place a package of measures to tackle the disease using all the available tools. It is clear from scientific evidence that in areas with high incidence of TB in cattle, that it will not be possible to eliminate the disease without addressing the transmission of disease in badgers. This wildlife reservoir must be challenged if progress is to be made in tackling the disease and these measures will be implemented alongside current controls. As these measures are introduced government will continue to monitor all disease controls to ensure that they are effective. OPTIONS FOR CONTROLLING BOVINE TB IN BADGERS There are only a few effective ways to control transmission of bovine TB from badgers to cattle. The introduction of some targeted biosecurity measures can help to prevent badgers coming into contact with cattle and feed stuffs, as will vaccination and culling. Badger culling has been used in the past under various policies in order to control TB, though little scientific evidence was recorded. The main scientific evidence base used to gain an understanding of the effects of badger culling on the incidence of TB is the Randomised Badger Culling Trial (RBCT). This concluded that a certain percentage of cattle TB cases occur due to infection from badgers. Analysis of the RBCT provides evidence that there is a 28.3% reduction in confirmed cattle herd incidence within a 100km2 culled area during a period from the first cull taking place, to 5 years after the cull (the length of cull varied depending on the area and ranged from 4-7 years). However this does not include those areas outside of the culling area where so called perturbation occurred. Perturbation is the disruption of badger social groups which is believed to cause the remaining badgers within the group to travel further than they normally would. This results in increased contact with other animals, both badgers and cattle, and may result in more opportunities to transmit the disease. It is believed that this perturbation effect can lead to increased incidence of TB in areas at the edge of a culled area as was evidenced in the RBCT, where areas up to 2km outside the culling area showed a 9% increase in TB incidence. These results have recently been updated to show that to be 97.5% (at 95% confidence interval) confident that culling will be beneficial the minimum area should be at least 141km2. The scientific evidence from the RBCT suggests that proactive culling done on a sufficient geographical scale in a widespread, coordinated and efficient way, and over a sustained period of time of at least four years, is likely to reduce the incidence of bovine TB in cattle in high incidence areas. The consultation considers options for a selective cull of infected badgers. However this would require a sensitive diagnostic test to distinguish infected animals or setts. There is currently no field test available which is able to perform this, although Defra will continue to monitor developments in PCR technology. There are also a number of other variables that have an effect upon the effectiveness of culling, for example farming systems and land use, badger density and barriers to badger movement. These factors as well as others have been drawn upon by government to form the basis of the proposed license criteria proposed in the consultation. Badger culling would have to be employed in a manner which is compliant with current legislation and also in a way that is consistent with the UKs obligations under the Bern Convention. Although not an endangered species in the UK badgers are protected by UK legislation, both the Protection of Badgers Act 1992 and the Wildlife and Countryside Act 1981 afford protection to badgers and their setts. There

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is provision within these Acts however for licences to be granted to kill or trap badgers, or to interfere with their setts for the purpose of preventing the spread of disease. Badger culling would be licensed only for techniques that are considered to be humane and effective for use on badgers, that would ensure co-ordinated delivery, and where culling is done as completely and efficiently as possible. The culling methods available are cage-trapping followed by shooting and the shooting of free ranging badgers. These are the only techniques that are supported by evidence which have the capability to kill badgers humanely and without posing a risk to non target wildlife. Other methods such as gassing, snaring, lethal injection and oral poisons have been ruled out on the grounds of humaneness, effectiveness, costs or risks to wildlife. VACCINATION Badger vaccine (BadgerBCG) has been licensed since March 2010 in an injectable form. Vaccination has been shown experimentally that it can reduce the prevalence and severity of infection in a badger population over time, although there is no scientific evidence to support the disease control benefits of vaccination. Benefits will consequently be incremental, particularly as BadgerBCG is not 100% effective in preventing TB and is not effective for badgers that are already infected. It is therefore concluded that vaccination will not be as effective as culling in quickly lowering the infection in the badger population. However it is thought that vaccination could play a part in helping to reduce the total number of badgers infected with bovine TB. COST AND BENEFITS OF ADDRESSING THE DISEASE IN BADGERS It is estimated that the cost of an average confirmed TB incident in cattle is around 30,000. Of this 20,000 falls to government for compensation, testing and compulsory slaughter of reactor cattle, leaving 10,000 in costs to farmers from losses of animals, farm costs of testing, and disruption to business through movement restrictions. The benefits of addressing the disease in badgers include: Avoiding the cost of cattle TB breakdowns. Savings by avoiding the cost of the cattle TB epidemic spreading across a wider area and into the future. Benefits to members of the public who may value reductions in the level of bovine TB in the cattle population. The main costs of culling consist of: The cost of the culling operation itself (including badger carcase disposal). The cost of the licensing process. The cost of monitoring the impacts of culling to ensure compliance with licence conditions and to safeguard badger welfare and ecosystems. Potential cost of increased bovine TB in neighbouring areas. Cost to members of the public who may value populations and badger welfare. These costs and benefits are described in more detail in the Impact Assessment which concludes that the costs of a government delivered badger control policy would be too high to justify the benefits. If farmers and landowners take responsibility for badger control there is a much stronger economic case. Defra state that the success depends on a commitment and willingness from industry to accept the costs of operating the policy.

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There are 6 options that have been considered for controlling bovine TB in badgers. 1. Continue with the current policy no additional measures Focused primarily on cattle controls with no measures to address the disease reservoir in badgers. This control strategy has failed to stop the spread of disease and incurs costs that are rising year by year and is considered unaffordable. 2. A government led policy of badger culling under the Animal Health Act 1981 A cull of badgers managed and delivered by government, or contractors acting on behalf of government. This approach means that the taxpayer ultimately bears all costs in delivering the operation. This approach also incurs higher costs due to health, safety and security requirements for staff, estate costs, vehicle costs and travel and subsistence expenses. 3. A government led policy of badger vaccination under the Animal Health Act 1981 A policy of vaccinating badgers managed and delivered by government or contractors acting on their behalf. As with option 2, this approach will leave the taxpayer bearing all costs. If government were to deliver a policy of badger control (options 2 and 3), the costs would be too high to justify the benefits. In the current spending reforms and drive for economic recovery, these options are not being taken forward. The following approaches are based upon a partnership between the farming industry and government. 4. Issuing licences under the Protection of Badgers Act 1992 to cull badgers The farming industry delivers culling in line with criteria developed by government in consultation with industry. Natural England would issue licences to those applicants meeting the criteria. 5. Promoting greater use of licences under the Protection of Badgers Act 1992 to vaccinate badgers Encouraging farmers and landowners to make greater use of vaccination to tackle TB using the injectable BadgerBCG vaccine. It is already possible to apply to Natural England for licences to trap and vaccinate badgers. 6. Issuing licences under the Protection of Badgers Act to cull, vaccinate or carry out a combination of culling and vaccination. This would permit groups of farmers/landowners to apply for a licence to tackle TB in badgers through culling, vaccination, or a combination of the two. This approach would be co-ordinated and implemented by the farming industry in line with the criteria set out by government. Natural England would assess and issue licences to those applicants meeting the criteria. The government would ensure compliance with the licence criteria, to monitor the impacts of culling or vaccination and to ensure adequate security. The option preferred by government is option 6 which would enable farmers to use vaccination either on its own or in combination with culling. This should increase participation from a wider range of farmers who will be able to apply the most appropriate control method to use on their land. THE GOVERNMENTS PROPOSAL Farmers and landowners will be able to apply for licences to kill or take badgers for the purpose of preventing the spread of TB in cattle. This will allow them to cull or vaccinate badgers within an area specified by the licence. It is expected that there will be a single licence application for each culling area. This will have to satisfy a series of criteria to ensure a cull is justified and likely to contribute to controlling bovine TB in cattle in the area. Industry will have to cover the direct costs of culling and/or vaccination.

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Farmers and landowners will be able to collectively or individually apply for licences to vaccinate badgers as part of a co-ordinated approach with culling activity. Vaccination could be used on land surrounding a culling area or on land within the control areas where culling could not take place. The criteria that have been proposed based upon scientific evidence for a culling licence are outlined below. The area has high and persistent levels of TB in cattle. The area is at least 150km2 in size (rounded up from 141km2). There is land access for culling for over 70% of the area. Where possible, the area will have boundaries or buffers to mitigate any possible negative effects in neighbouring areas caused by perturbation of badgers social groups and increased disease transmission. Culling will be carried out effectively and humanely by competent operators. Culling will be permitted by cage-trapping and shooting, and shooting free-ranging badgers only. A commitment to sustain culling effort over the area annually and for a period of at least 4 years. Culling will achieve badger densities low enough to reduce TB transmission, but not lead to local extinction. A closed season to protect dependent cubs will operate during late winter/early spring. Arrangements are in place for carcases to be removed in accordance with legal requirements for animal by-products. Culling will be coordinated locally across the area covered by the licence. The role of vaccination is considered and is coordinated locally with culling activity. Before a cull begins other controls measures should be in place, these include good biosecurity, husbandry and compliance with existing cattle control measures. Alternative criteria must be met in order to obtain a licence to vaccinate badgers. Only cage trapping will be used and vaccination will be carried out effectively and with regard to animal welfare. Vets or trained lay vaccinators will vaccinate using the injectable badger vaccine under prescription. There must be widespread understanding and compliance of existing TB control measures. If vaccination is used alongside culling it is co-ordinated locally. For example enabling immunity to develop in vaccinated animals by starting vaccination ahead of culling programmes and ensuring that vaccination is sustained for a period long enough to cope with badger culling for four years and any subsequent perturbation effect. MONITORING Government will be responsible for monitoring the effectiveness, humaneness and impact of badger control. This will include spot checks of badger carcases, that badger populations are not driven to extinction and that there are effective control operations in place. In addition government will continue to monitor the incidence of bovine TB in cattle through their existing surveillance methods. This policy will be reviewed after 4 years or in the light of new evidence or control tools. CONSULTATION RESPONSE The consultation asks for views on a total of 8 questions. These are: Question 1: Comments are invited on the options, costs and assumptions made in the Impact Assessment Question 2: Do you agree with the preferred option? 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?

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Question 4: Do you agree with the proposed licensing criteria for culling and vaccination? Question 5: Do you agree that the proposed methods of culling are effective and humane? Question 6: Do you agree with the proposed use of vaccination, particularly its focus on mitigating the perturbation effects of culling? Question 7: Whether more should be done to encourage the use of vaccination? Question 8: Is there anything we have missed that may be considered essential to monitor? The NFU will be gathering views from members through a series of member meetings throughout the autumn. These meetings will provide members with an opportunity to give their views on the consultation and how they believe industry could come together to co-ordinate and implement an effective badger control programme. Details of these meetings will be available shortly. If you have any comments on the consultation we would like to hear them through responding to the above contacts. We also encourage individuals to respond to the consultation document to ensure that there is strong support for the proposals set out and to provide a challenge to the large number of negative responses that we expect to be received by Defra. To respond directly: Write to TBBC Mailbox Nobel House 17 Smith Square London SW1P 3JR tbbc@defra.gsi.gov.uk 0207 238 6431

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