This is a summary response complementary to and in support of the more detailed submission from the National Federation of Badger Groups. The BROCK Badger Group has maintained a rationale and scientific opposition to the various MAFF's badger culling programmes. We formed in the mid-eighties, and have produced several reports etc, including written and oral evidence to the Dunnet enquiry in 1984-85.

  Design and likely effectiveness of the culling experiment. The trial design tries to impose laboratory conditions on the wider countryside. In reality, its unworkable and not scientifically robust. It does not take into account variable field circumstances: in particular badger ecology relative to different field conditions (habitat variability, ease of access, non-agricultural land—dense or impenetrable scrub etc). For political reasons it began prematurely, and external auditing of results has not been planned even though their desirability is acknowledged.

  Badger populations are merely "guestimates". Capture rates, acknowledged to be imperfect, will scientifically invalidate results. Non-compliance and human opposition from various groups and individuals will create "noise" and devalue any conclusions. Farmers are angry and confused; they have been primed to be "anti badger" and many cannot be expected to leave "their" badgers alone if they happen to be in a Reactive or No cull (control) triplet zone.

  In addition, there are many confounding variables, in particular the role of other wildlife and feral species, which will confute any results or at best damage their authority.

  Husbandry methods. Significantly more attention should be paid to the role of trace-elements (particularly copper and selenium) in intensive agricultural systems particularly their severely reduced status in annual ryegrass leys and the impairment this causes to animals' immune systems. Exclusive attention on the badger merely confirms its "guilt" in the eyes of non-specialist farmers, even so we support any reasonable measures farmers might take to keep cattle and badgers apart. However, society must recognise that it cannot have interesting wildlife on its doorstep without granting that such wildlife requires supportive rural habitat—this might well come as some cost to society.

  Implementation of the Krebs strategy. You expressly exclude comment on "historical and scientific background", which makes it difficult to comment helpfully on changes, since we believe the precept of the Krebs review was fundamentally flawed. Essentially, over-emphasis on the badger's role in the epidemiology of bovine TB, due to MAFF's political commitment to a badger campaign, has resulted in other factors being overlooked with disastrous consequences. Very briefly what is required is an holistic approach whch does not focus entirely on the badger.

  Other isssues (and recommendations). Funding currently spent on killing badgers should be diverted into (a) full compensation for affected farmers (including consequential loss), (b) non-invasive research into the background role, prevalence and ecological significance of environmental mycobateria, their ecological role and significance, (c) fast-track research towards an effective cattle vaccine, and (d) non badger factors in the epidemiology of the disease in cattle.

5 January 1999