I am sending you a copy of a letter which I sent to the Minister of Agriculture on 28 September 1998, and I would like the contents of this letter to be submitted as written evidence to the agriculture committee who are looking into the practical implications of the governments proposal for implementing the recommendations of the Krebs report.

  This letter was subsequently published in the Veterinary Times and in its preparation I did draw on the expertise of a number of veterinarians who have practical experience of this matter.

  Incidentally I would add that I have not received either a reply or even an acknowledgement from the Minister of Agriculture since sending him this letter over six weeks ago.

17 November 1998

  Congratulations on your new appointment. One of the unresolved problems that will remain on your desk is how to control the increase of Tuberculosis in Cattle and Badgers.

  Following the recent publication of the Bourne Report, the Food and Safety Minister, Jeff Rooker, has announced details of the new MAFF strategy, but that will not satisfy everyone.

  I read that you have no agricultural background, so it will be possible for you to look at this issue afresh with a clear analytical mind. I hope that by setting out the basic facts and opinions this letter may be of some help to you in reaching rational and logical decisions.

  I have read 191 pages of the full Krebs report and the Bourne report, but like you, I have no expert knowledge in this field. As a vet in farm practice, I tested thousands of cattle to help try and eradicate TB in the UK. I have a small farm in badger country and am a member of the NFU and FWAG. I am also involved in a number of wildlife conservation projects—so I feel that I have a foot in each camp.

FACTS

(1)  The number of cases of TB in cattle is rising each year at an alarming rate

  Earlier this year the Government placed a moratorium on new badger culling operations in all affected areas and the problem of TB in cattle continues to escalate. There are now as many breakdown herds in 1998 as there were in 1948. The difference is that in 1948 the infected animals were old cows—now it is young cows and the problem is getting worse.

  In the West Midlands the number of herd restrictions increased by almost 30 per cent from January to May 1998 (145) compared to the same period in 1997 (116). The number of confirmed breakdowns in the south west region of England inceased by 45 per cent from January to May 1998 (204) compared to the same period last year (141).

  Serious outbreaks are occurring in Gwent and West Wales. Two years ago Staffordshire, Shropshire and Derbyshire were free of bovine TB, there are now 67 herds under restriction. Last year Cheshire had its first herd breakdown and it currently has eight herds under restriction. This year Nottinghamshire and Oxfordshire both had their first herd restrictions.

  I appreciate that the figures for herds under restrictions are not the same as herds where positive infection has been diagnosed but the figures I have used raise real concerns for all those involved with the cattle industry.

  Official statistics for the South West Region for total herd breakdowns over the last four years are:

Final January-December figures Final January-December figures Final January-December figures January-July

1995 1996 1997 1998

316 329 413 311 (7 months)

  The 1998 figures are for seven months only and normally the last three months of the year show increased TB incidents when cattle testing occurs following summer grazing.

(2)  Current MAFF policy to control the TB outbreak in cattle has failed

  The "clean ring strategy" which culled all badgers in the area around an outbreak was effective, but abandoned by the Ministry in 1988. This was replaced by the "interim policy" of only removing badgers when they enter the "reactor area" of the infected farm. This has been a failure because the badgers that live off the farm are not removed, the lactating badgers remain a foci of infection and the re-colonisation of setts is rapid. The incidence of new breakdowns has increased significantly during this period of "interim policy".

  The "live test" trial introduced in 1994 to detect infection in live badgers was suspended in 1996 after two years because of poor performance—it only detected 41 per cent of truly affected badgers.

(3)  It is generally accepted that badgers play a major role in the transmission of TB to cattle

  The Zuckerman report (1980), the Dunnet report (1986) and the latest report to the Minister of Agriculture by Professor Krebs (1997) all concur that badgers are acting as a reservoir of infection for cattle.

  The Krebs report stated that "The sum of the evidence strongly supports the view that in Britain, badgers are a significant source of infection to cattle. Most of this evidence is indirect, consisting of correlations rather than demonstrations of cause and effect; but in total, the available evidence, including the effects of completely removing badgers from certain areas, is compelling".

  The route of transmission is considered to be ingestion of pasture contaminants of M.bovis bacteria mainly by urine or sputum but possibly also by faeces and pus from suppurating abscesses. Other wildlife, such as deer, may contract infection but to a much lesser degree and are not believed to be a significant reservoir of infection.

(4)  The Krebs Report has proposed that five-year experimental trials should be underaken to assess the effectiveness of control measures. In the meantime no culling should be carried out outside the hotspot areas but instead simple husbandry measures should be adopted.

  The experiments proposed by Krebs will be overseen by an expert independent scientific group, chaired by Professor John Bourne, MRCVS, will last for five years and then be followed by a further period of evaluation of the results. Your recent announcement that these trials will start in the next few weeks but be phased in over two years will even further extend the time needed for the experimental trials and evaluation.

  There is clear evidence from work which has already been undertaken to show that badgers act as a reservoir of infection for cattle. As part of the badger clearance programme and to study the effect of badger removals, MAFF in co-operation with the then Nature Conservancy Council, embarked on an extensive badger removal exercise in a "TB hotspot" area of Thornbury, South Gloucester in 1976.

  The Thornbury exercise area of 104 sq km comprised approximately 100 farms with total cattle numbering approximately 12,000. Starting in 1976 all badgers were removed, the area being virtually cleared during 1977. During the 10 years prior to the start of this exercise the reactor herd incidence averaged 5.6 per cent but in 1978 it fell to 1.4 per cent and by 1979 to zero where it remained until 1990 when partial re-colonisation by badgers was allowed and since which time outbreaks in cattle have restarted.

  A similar smaller scale exercise to this was carried out in South Dorset in an area of 12 sq km yielding very similar results and a large scale clearance is currently being undertaken in County Offaly, Republic of Ireland in an area of 600 sq km. This last exercise started in 1989 and interim results have shown a 52 per cent reduction in the number of reactors during 1991 compared to an increase of 33 per cent in the control area where badgers have not been removed.

(5)  The number of badgers in the countryside is showing a rapid increase

  Badgers are a protected species, but not endangered. A national survey in the 1980's estimated the overall population of badgers in the UK at 250,000. Last year a survey by the People's Trust for Endangered Species found that the number of badgers has increased by 76 per cent in the past 10 years. It has been estimated that 50,000 badgers are killed on the roads each year.

(6)  The best prospect for the control of Bovine TB is to develop a vaccine for Cattle

  Krebs estimated that the development of a vaccine for cattle would take fifteen years and success cannot be guaranteed. Your own MAFF staff predict effective vaccination programmes are 15-20 years away.

(7)  Compensation to Farmers for reactor cows has been paid at 75 per cent of their market value

  The market value is a variable amount with a current maximum of £555 and based on average sales from a number of sample cattle auction markets. No compensation is paid for consequential loss.

(8)  The public, conservationist and animal welfare groups are concerned about the methods used for widespread culling of badgers.

  It has been accepted that gassing with Hydrogen Cyanide is an inhumane and unacceptable method of culling of badgers. Gassing has now been replaced by live trapping.

  Animal welfare groups such as the RSPCA and National Federation Badger Groups (NFBG) are strongly opposed to the use of snares or the killing of lactating sows. The Wildlife and Countryside Act 1981 prohibits self-locking snares for the killing or taking of any wild animal.

OPINIONS

(1)  Europe & Bovine TB

  There is now a danger that the incidence of Bovine TB in some areas threatens their health status.

  It is anticipated that with the reduction of BSE the beef export ban will soon be lifted. However, some veterinarians believe that there is a possibility that this ban could be re-imposed on meat and milk products on account of the incidence of Bovine TB in the UK. Many herds will become unable to export cattle because the herd is under movement restrictions because of local TB breakdowns.

(2)  Krebs Experiments

  The badger and welfare groups have reservations about the practicality of the proposed experiments. The NFBG oppose the culling aspects of the experiment on the grounds that "it is practically unworkable and ethically unacceptable and recommend that it should be replaced by a trial to investigate husbandry practices on farms".

  Professor Stephen Harris from the University of Bristol argues "that the experiments designed by Krebs serves no useful purpose, that the logic behind the five-year experiment is flawed, it is not practical and that the results are predictable. Illegal killing of badgers in the `no control squares' will nullify the results. He is in favour of a `one-off control operation' by the proactive culling of badgers where there are pockets of infection. The badgers left in the surrounding will be predominately healthy and can be allowed to re-colonise the cleared areas".

  The NFBG believe that "direct action may be taken by members of the public to sabotage culling operations in hotspot areas". There is concern by veterinarians that such direct action could result in the release of infected badgers to other parts of the country. The BVA and the NFU both argue strongly that 5 years is too long to wait and a more rigorous culling of badgers is needed now in the newly-affected areas.

(3)  Compensation for farmers

  The NFU and some welfare groups will welcome the change in policy in that farmers will now receive 100 per cent compensation for TB reactors but this should also take into account consequential loss.

  In confirmed breakdown herds, restrictions on the movement of cattle onto and off infected premises can remain in force for many months, in some cases they have done so for two and three years. MAFF is, in effect by imposing movement restrictions, enforcing the unlucky owners into severe financial loss by preventing normal trading activity.

(4)  Badger Numbers

  There is concern from badger groups that changes in attitude by farmers and landowners may bring about an increase in illegal interference with badgers and their setts, and that the badger numbers may already be in decline.

(5)  Husbandry methods

  There is considerable scepticism from farmers and vets about the practical aspects and likelihood of success of the "simple husbandry methods" advocated by Krebs which are aimed at reducing the risk of infection by keeping cattle away from badger setts, urination trails and latrines and keeping badgers away from cattle feeding troughs and out of farm buildings.

  These husbandry measures are unproven and now the subject of industry funded research.

(6)  Welfare Aspects

  The use of snares is opposed by animal welfare groups as they can cause horrific injuries and are an unacceptable risk to other wildlife.

  The killing of lactating females is opposed as it is not acceptable to allow cubs to die from starvation or through infanticide from other badgers.

  Professor Harris believes that "culling can be planned to avoid the killing of lactating badgers. Each pocket of infection can be surveyed from January to June, trapping can commence in July and be completed by the end of December, thus avoiding the breeding season".

  Many people will be pleased at your decision that snares are not to be used and that there will be a closed season from 1 February to 30 April each year to protect lactating sows.

  There is a strong possibility that unless more positive action is undertaken then the illegal killing of badgers outside the hotspot areas will increase as farmers become desperate to protect their livelihood.

  TB is an unpleasant disease for both badgers and cattle, its eradication would improve their welfare. We all want to save the badger but they are not an endangered species. If the animal carrying infection to cattle was a rat; would we have the same dilemma over the future control measures of this outbreak?

(7)  The Way Forward

  Professor Harris argues "that proactive culling can be highly successful in reducing TB in cattle and badger and the reduction of herd breakdowns is both dramatic and potentially long lived".

  Krebs refers to four large-scale clearances by culling of badgers which have been carried out at Thornbury, Avon, Steeple Leaze in Dorset, Hartland Peninsular in North Devon and East Offaly in the Irish Republic. In each case clearance was followed by a marked reduction in the incidence of TB in cattle but these were not conducted as a "scientific experiment".

  Can we afford to wait five years for the Krebs experiments to be completed? Are these experiments likely to produce meaningful results? Can we afford to carry out these experiments? Or should the money be spent for better use?

  Resources are limited and yet you are seemingly going ahead with the duplication of earlier working in the UK and currently in progress in Ireland. The more pragmatic might view this as a scientific prevarication. To reprove the already proven will not help control TB in the national herd, which is now virtually out of control and is requiring very significant additional finance to deal with outbreaks and routine testing in high risk areas.

  A major culling campaign focussing on the newly affected areas as well as the hot-spot areas of this trial could bring about the reduction of TB in badgers and at the same time the number of cattle herd breakdowns, although this will increase the number of badgers killed in the short term, it has a better chance of controlling the bovine TB outbreak and will be beneficial to the welfare of both badgers and cattle in the long term. This is the hub of the problem and must be addressed now.

  Professor Krebs recommends work to be carried out in developing a vaccine for cattle, an approach which offers the best long term approach to this problem. Surely this is an area where as much resources as possible should be invested. At the same time work should continue on the development of a badger vaccine as a means of reducing the transmission of the disease in badgers.

  This is a highly complex and emotive issue. You have difficult and unpopular decisions to make and I look forward to your response.

John Gripper BSc MRCVS