INTRODUCTION

  1.  The RSPCA welcomes the decision of the Agriculture Committee to hold an inquiry into this subject and is grateful for the opportunity to submit it's views.

  2.  In it's opening remarks to the Government consultation, on implementation of the recommendations of the Krebs Report, the Society expressed the view that there were some major practical difficulties in implementing the proposed culling trial. We believed that unless these could be satisfactorily overcome the trial would not be able to operate in the way the Krebs Review Team envisaged and that if this was the case then undertaking the trial should be reconsidered.

  3.  In coming to their decision over the culling experiment, the Government did take some account of the concerns expressed. However, subsequent events have served to illustrate the extent of the practical problems and the RSPCA remains concerned that as a result no clear conclusion may emerge from the experiment. In the light of these practical problems, questions regarding the trial are pertinent and we hope the Committee will raise them with MAFF and the independent Expert Group overseeing the experiment.

  4.  The RSPCA welcomed many aspects of the approach to the problem of bovine turberculosis in cattle and badgers adopted by both the Krebs Review Team and the Expert Group and did not oppose the proposed culling. Although it was regrettable that badgers were to be killed we considered the culling trial an attempt, albeit belated, to answer some of the many thorny questions which have long surrounded this issue. However, following the Government decision to proceed with the trial there was some criticism that it was: "unlikely to work", "impractical" and "unlikely that there would be any clear results despite the culling of large numbers of badgers". The Expert Group presumably took a different view but the RSPCA is pleased that the Committee will be considering such points in their inquiry in reviewing the action taken so far in relation to the experiement.

PARTICIPATION IN THE TRIAL

  5.  There is no compulsion on land owners/occupiers to participate in the trial. The Expert Group stated that all feasible steps would be taken to ensure that a certain amount of non-cooperation would not nullify the trial but that non-compliance on a large scale would have serious consequences for the interpretation of the trial data. The question therefore arises, in the light of the experience since August, whether the actual level of non-cooperation is such as to affect interpretation?

  6.  Non-compliance could relate not only to denying MAFF staff access to kill badgers but also refusing permission for staff to enter land and survey for badgers. Both might serve to obscure the results of any comparison between experimental treatments. Failure to permit MAFF staff to undertake badger surveys could render assessment of the extent of any illegal culling of badgers difficult. The possibility of farmers/landowners taking unilateral action against badgers, thus rendering the results of the trial worthless was, and remains, a major concern of the Society. We recommended an increase in the compensation paid to farmers in the event of a herd breakdown and we were pleased that the Government have done this. We hope this will go some way to reducing any temptation some farmers may have to take unilateral action against badgers. However, since compensation does not cover the consequential costs such a risk remains.

  7.  We are not convinced that the arrangements for surveying—whether initial or subsequent—will be adequate to measure the extent and impact of any illegal culling. If the survey, or re-survey, depends on the voluntary compliance of the landowner/occupier then denying access could be a way of seeking to conceal any action taken against badgers or their setts. If, as the Expert Group suggest, a re-survey is confined to a sample area within each treatment area then selection of that area would be critical.

AUDITING

  8.  The Expert Group made the welcome recommendation that an external audit be put in place to check on the efficiency of the culling operation. Advertisements appeared, early in October, seeking invitations to tender for the contract of undertaking the independent evaluation of the field operations carried out under the badger culling trial and the view was expressed that the successful applicant would commence in November. Although we understand negotiations have taken place no announcement had been made before the Christmas recess.

SELECTION OF AREAS

  9.  The recommendation was that a minimum of 30 "hot spot" areas would be required in order for the experiment to have sufficient statistical power. The Expert Group considered that these should be grouped into "triplets" with each triplet comprising three areas in the same locality with the treatment randomly allocated. On 17 August the Food Safety Minister announced the location of the first two triplets. In a Parliamentary Answer on 18 November 1998 (column 687) it was stated that the next two triplets would be identified within the next few months but no announcement had been made before the recess. The time taken to select areas considered suitable for the study introduces a delay which is likely to affect the duration of the study.

INITIAL SURVEYING OF AREAS

  10.  Surveying began in the first two triplets on 28 August. However, by mid-October it had apparently become clear that progress in both was slower than had been hoped. The terrain was "unfavourable" for conducting the badger survey in the Gloucestershire/Herefordshire triplet and in order to have a chance of completing culling in the proactive area of Devon/Cornwall MAFF switched resources to that area in order to complete the survey and enable culling to begin. Heavy rain hampered the survey work but pre-baiting started in Putford in the middle of November with trapping commencing early in December.

  11.  Badger activity is considerably reduced in winter, particularly between mid-November and mid-January, with December being the month of least activity. Thus, the start of MAFF's badger trapping in Putford coincided with the time that badgers are least active and trapping efficiency at its lowest. It was therefore somewhat surprising that MAFF reported they had completed trapping in the area on 13 December having caught 238 badgers. Estimates based on the assumption used in the Krebs report of five badgers/km2 suggested that the Putford area contained around 500 badgers. Thus, either the general figure for badger density was not applicable for the situation in the Putford area or MAFF staff have failed to capture a lot of badgers. Resolution of such questions is important not only for the validity of the trial but for public relations aspects since the outcome is being portrayed, in local media, as serving to illustrate that the experiment is flawed because MAFF didn't catch many of the badgers in the area. Unfortunately, as we have already remarked, the arrangements for external auditing of such operations have not yet been established.

  12.  The Expert Group recognised "the severe logistical challenges" of putting the remaining triplets in place by the end of 1999. With the experiences this Autumn it is questionable whether this is practical and it is therefore an aspect we hope the Committee will explore with the Expert Group.

STAFFING RESOURCES

  13.  During mid December MAFF advertisements for 60 fieldpersons appeared in various journals eg Shooting Times and Country Magazine, (10 December), Farmers Weekly (11 December). The duties related to implementation of the badger control trial and staff were to be based at either Aston Down in Gloucestershire or Polwhele in Cornwall. Applications had to be submitted by the end of December. Bearing in mind the difficulties MAFF staff were already experiencing with the field work and the switching of resources that was necessary to enable the trial to commence in even one area had there been a delay in recruiting staff (and, if so, why) or had the staff resources needed for the trial been seriously underestimated?

LACTATING SOWS

  14.  The RSPCA was very concerned at the original proposal that lactating sows be killed and that many cubs would be left to starve to death as a result. We welcomed the fact that the Government decision to have a closed season, from February to May, reduced such risks. On average, in south west England cubs start to emerge from the sett in April and weaning begins in the first half of May although dependency can last for six to eight weeks after weaning. Therefore when trapping resumes there will still be a risk that removal of the females will result in cubs starving to death. Therefore the potential welfare benefits of having such a closed season will only be realised if the cubs are caught in the trapping operations when they resume. This is an aspect we believe should be closely monitored. Apart from the welfare benefits of avoiding leaving such cubs to starve to death, assessing the disease status of such cubs alongside that of the female would provide information about aspects such as maternal transmission of the disease.

CAPTURE METHODS

  15.  On welfare grounds the RSPCA welcomed the Government decision to rely on the use of cage traps and not to use snares to catch badgers. However, we are concerned about the separate, but related, decision to trial the use of a leg cuff on badgers. We believe that such a device is likely to pose similar welfare problems to those caused by snares. The first phase of this trial is being conducted in a specially designed observation pen with the badgers under constant video surveillance. If badgers are harmed the Government have said that the trial will be abandoned but if no problems occur a field trial will be conducted. The RSPCA believes that the onus of proof regarding this method rests with the Government and that progress on this trial might also be a matter for consideration in the Committee's inquiry.

ROAD TRAFFIC ACCIDENT SURVEY

  16.  The Krebs report considered that the testing of road traffic accident badgers offered an important source of data on the underlying disease prevalence and recommended a limited reintroduction of the survey. The Expert Group recommended that a new formal programme be instigated to coincide with the launch of the trial. However, no mention of such a scheme was made on 17 August. In a Parliamentary Answer on 18 November it was stated that "The Government expects this survey to start in the early part of 1999". The undertaking of such a survey obviously has some implications for MAFF staff and laboratory facilities. However, given that MAFF had been collecting some carcasses from certain areas it is difficult to understand the reason for the delay in setting up a more formal scheme in the seven counties recommended by the Expert Group and appears to be another example of timetable slippage.

CONCLUSION

  17.  The Krebs Report considered that the experiment should be implemented immediately and cover a large enough area to provide significant results within an acceptable timescale. Even so a period of five years was likely to be necessary before full quantitative assessments could be made, with acceptable confidence limits, which might serve as a basis for future policy considerations. Evidence to date indicates that even the more phased introduction of the experiment is experiencing considerable operational difficulties. This does not engender confidence for the future operation of the trial, the timescale in which significant results might be obtained or even whether such results might be produced.