We are deeply concerned that the Ministry of Agriculture's epidemiological investigations into the hypothetical links between badger and cattle turberculosis infections are deeply flawed, particularly in regard to the case-study questionnnaire to be circulated to farmers.

  At heart, the questionnaire is concered only with the physical (as opposed to physiological) means of TB transmission between badger and bovine—it does not address the fundamental causes of TB within both species. Only when the fundamental causes are correctly and adequately identified, may the means of inter-species transmission become relevant.

  Our major concern is that the questionnnaire fails entirely to consider the role of nutrient depletion within either species (see Annex 1), TB being the result of a depleted immune system caused by inadequate nutritional inputs, particularly (we are convinced) at the micro-nutrient level.

  Experience at an on-farm level suggests that modern farm management practices have severely depressed the micro-nutrient status of soils and grassland. A major body of evidence exists to show that this has had a consequentially profound effect on the immune status of cattle: there is every reason to believe badgers are equally affected. The inter-action between badger and bovine is, we are certain, the direct result of both species being increasingly dependent on micro-nutrient depleted food sources—specifically, a lack of adequate selenium. The role of selenium depletion in the inducement of TB in rabbits was extensively expressed by Professor Max Lurie, formerly Professor of Experimental Pathology, University of Pennsylvania some 30 years ago.

  Close study of the MAFF questionnaire has convinced us that Ministry is steadfastly determined that the badger is the sole cause of bovine TB; and that any future control of the disease within the national cattle herd now depends on the development of on-farm protocols by which contact between badger and bovine is minimised. As we have stated earlier, this is an entirely inadequate approach to a situation which has far-reaching, detrimental implications for the future well-being of livestock farming, animal welfare, the continued (often fragile) standing of farmers within the community and (on a limited scale) public health.

  We therefore urge you to impress upon the Ministry of Agriculture, Fisheries and Food the immediate and urgent need for specific investigation into the micro-nutritional status of badgers and bovines, and the potential impact of this (depleted) status on the susceptibility of both species to TB infection.

  Enclosed, as Annex 2, are some of the vital questions which must be asked of farmers when assessing the susceptibility of their herds to immunilogical breakdown (as evidenced within the herd by the presence of common ill-health/performance indicators) plus supporting evidence for our contentions (Annex 3 [not printed]).

10 January 1999

  The analysis of hair samples taken from apparently healthy badgers has shown that individuals contained up to 10 times less selenium than is required for other mammalian species to adequately sustain their immune systems.

  Hair samples from 36 badgers temporarily held at a Somerset badger sanctuary and from all regions of the UK, were collected by the Surrey-based charity Care for the Wild International. The samples were analysed for their micro-nutrient status by the Natural Resource Management Ltd at Bracknell, Berkshire.

  Selenium levels in the samples ranged from 0.01 to 0.099 ppm with a mean of 0.030 ppm. It is estimated that a hair-sample level of at least 0.15 ppm is required of an animal of similar size and weight to ensure that its Se body reserves are sufficient to maintain its immune system at an optimum level (see Table 1, below). It is suggested that many of the badgers tested would have suffered perilously low immunity levels, particulary to "environmental conditions" such as TB.

  The charity Care for the Wild International has now decided to launch a full-scale farm-based research programme monitored by micro-nutrient specialists Trace Element Services.

  Needed for the programme is a dairy farm of about 200-acres in the West Country with a known badger population and a history of TB in the herd.

  Soil samples from the farm will be analysed for micro-nutrient levels and all the land treated with an appropriate trace element mixture, a practice which has been carried out for more than 20 years on 1,000s of UK farms, to the clear benefit of stock health and performance.

  The TB status of both the cow and badger populations are to be monitored on a regular basis.

  If successful, the trial should provide a far more sophisticated, lasting and publicly acceptable indicator to the badger-TB problem than the proposed Ministry of Agriculture cull programme.

1.  BREED INFORMATION:

  (i) breed(s) of cow used; (ii) breed(s) of bull used.

2.  STOCK HEALTH AND PERFORMANCE INDICATORS:

  (i) Per cent herd holding to first service; (ii) Per cent calves dead at birth/die soon after; (iii) Milk cell count; (iv) Clinical mastitis incidence; (v) Milk fever—per cent herd affected per year; (vi) Drinking of urine or slurry; (vii) Per cent retained placentas annually; (viii) Incidence of cystic ovaries annually; (ix) Incidence of abortion/miscarriage annually; (x) Per cent lameness within herd. (xi) Concentrates fed per cow per year (tonnes); (xii) Average yield per cow per year (litres).

3.  NUTRIENT SUPPLEMENTATION:

  (i) Are cows injected with copper, selenium, iodine, vitamin B12 or vitamin E? (ii) Are boluses used? (iii) Are minerals fed? (iv) Is demand for minerals considered excessive? (v) Is mineral supplementation ad lib or restricted?

4.  OTHER FEEDS:

  Are any of the following feeds used in addition to grass/silage and concentrates?

  (i) sugar beet pulp; (ii) brewer's grains; (iii) potatoes; (iv) kale; (v) roots; (vi) citrus waste.

5.  SILAGE MANAGEMENT:

  (i) Please state date of first silage cut; (ii) How long is silage wilted for? (iii) Are additives used?

6.  GRASSLAND:

  (i) What grass types are used for (a) grazing? (b) silage? (ii) How much nitrogen is used annually for (a) grazing? (b) silage? (iii) What form of nitrogen is used for (a) grazing? (b) silage? (iv) How often are pastures re-seeded?

7.  SOILS:

  (i) What are the farm's major soil types? (ii) What is the P, K and Mg status of the soils? (iii) What is the general pH level or pH range; (iv) What is the farm's liming policy? (v) At what rates per hectare is lime applied? (vi) Are any of the following also used: slag, sewage sludge or other organic wastes (eg, chicken or turkey manure)?

EXPLANATORY NOTES TO ANNEX 2:

  (nb many other questions may be asked regarding the health and performance status of a herd, and the general management policies of a farm: only the more obvious have been listed)

  1.  Immunity levels of breeds differ, according to the environment/circumstances under which they have been historically developed. Holsteins, originally developed under very different environmental/management conditions to those found in the UK, have a very low level of disease resistance. Ayrshires and Herefords, in contrast, possess a very robust response to low micro-nutrient status feeds.

  2.  All common health/performance parameters listed above (plus many others less well recognised) are clear indicators of the micro-nutrient status of a herd: in the high-yielding cow, susceptibility to disease and stress is exacerbated by the animal's need to balance her micro-nutrient intakes between physiological maintenance and milk nutrient inputs.

  3.  High levels of mineral/vitamin supplementation pre-suppose an intrinsic micro-nutrient deficiency within the cow's bulk diet, but does not ensure that the cow achieves the essential micro-nutrient input balance necessary to secure the optimum performance/health expected of her.

  4.  Variations in the micro-nutrient levels of any purchased, bulk feed can distort considerably the intrinsic values available through the cow's staple diet of grazed or conserved grass.

  5.  The macro- and micro-nutrient status of grass declines if the crop is allowed to grow beyond its optimal nutritional value. The late cutting of first-crop silage (depending on farm location and local climatic conditions) pre-supposes grass of low nutritional status. If further cuts are taken, these are likely to be of less macro- and micro-nutritional value.

  6.  The micro-nutrient uptake capacity of modern ryegrass varieties is very poor: high levels of nitrogen application and frequent re-seeding (every 2, 3 even 5 years) exacerbate the difficulties the cow experiences in achieving optimum micro-nutrient intakes from grass alone.

  7.  The soil type in which any crop is grown directly and profoundly affects the micro-nutrient values of that crop. Ill-considered use of potassium, phosphorus, manganese and lime can massively and aggressively distort the availability and uptake of those nutrients. This equally applies to the use of industrial wastes as fertilising agents or soil nutrient "enhancers," particularly sewerage from urban areas.