1.  COMMENTS

  1a.  The heading of the Press Notice gives clear indication that the government regards badgers as the problem as the notice is headed "Badgers and Bovine Tuberculosis"

  1b.  We have the bizarre situation that Groups like ours spend time, effort and money to protect badgers with steel mesh and concrete. At the same time, MAFF is killing badgers in the South West.

  1c.  The signals given to badger diggers and terrier men in our area, are that the Government is ambivalent in its belief in the protection of badgers. This cannot be true, but the long struggle to obtain protected status for badgers can appear to be imperilled.

2.  EFFECTIVENESS

  2a.  Some farmers will clear out their own badgers. Some farmers and landowners will not want MAFF operatives on their land. This is an immediate flaw to the experiment.

  2b.  The extent of the trial in terms of hectares of land is almost impossible to supervise. Surveying land to identify badger setts is not an easy skill. Setts will be missed. Outlying setts will become used and become main setts as the ordered habits of the badgers are destroyed. It is an extensive and difficult piece of field work which is required. The interpretation of the signs requires experience.

  2c.  Krebs stated that snares would have to be used in order to obtain maximum number of badgers killed. He suggested that 20 per cent of badgers may be cage shy. The public outcry has forced the Government to abandon neck and body snares. Therefore the object of the proactive strategem cannot be achieved. ON ALL THESE POINTS WE BELIEVE THAT THE EXPERIMENT WILL FAIL.

  2d.  The results of this large scale trial will be questioned by everyone—farmers, landowners and conservationists alike.

  2e.  I have written to the Minister of State Jeff Rooker MP asking about future actions should the killing of badgers show a reduction in the incidence of TB in cattle. In reply to a local MP he states "I CANNOT ANSWER" However, he has stated elsewhere on behalf of the UK Government that government policy is not to eradicate badgers and that widespread killing would not follow. If that is true, there seems to be no point in the experiment.

  2f.  The Government's own body "English Nature" has advised that they believe that circumstances surrounding the experiment such as denial of access, interference with equipment and illegal killing of badgers, may reduce the power of the experiment to the point at which it could become valueless.

3.  THE BERN CONVENTION

  The Standing Committee has agreed unanimously (UK abstained) to open a file in order to investigate the actions of HM Government. The National Federation of Badger Groups successfully presented their case in Strasbourg. Articles 7, 8 and 9 were invoked. Briefly, these concern the protection of an animal specified in Appendix 3, the use of traps and snares on a large scale, and causing the local disappearance of badgers. Article 9 requires that every other possible solution is sought.

  We support the NFBG position regarding the Bern Convention.

4. HUSBANDRY

  4a.  Krebs states that simple husbandry methods to separate badgers from cattle could have a significant role in reducing risk, that current MAFF guidelines are not widely heeded and that husbandry may well play an important role as part of the long term solution. Krebs comments on the disparity of the research budget compared with the control budget. The total TB control budget for 1999-2000 will be increased to £23 million (MAFF) The research budget as a whole is to be increased to £3 million of which £1 million will be related to vaccine research. The remaining £2 million will be for research other than that on vaccines. These figures do not appear to represent a substantial enquiry into various husbandry problems.

4b.   Health of Cattle

  Improvements in Public Health have been achieved as a result of hygiene measures. Clean water supplies, sewage disposal, dry warm housing, and, most importantly, good nutritious food have formed the major contirbutions to our present standards of health. It is reasonable to suppose that this will apply to our animals!

  Cows are now exhausted when reaching 5-6 years old—formerly they would be productive into their teens. Overstocking, excessive milk yields, and poor quality feed takes its toll.

  4c.  The TB status of cattle which are being sold should be known. A positive reactor was brought to our area recently.

  4d.  We believe that husbandry should be considered in the wider context of food safety and biodiversity.

5.  VACCINES

  5a.  The Government has allocated £1 million per year for research into a vaccine for cattle. Krebs believes that a cattle vaccine is the best prospect for control of Bovine TB in cattle. Again there seems to be a great disparity in the allocation of funds.

6.  ANIMAL WELFARE

  6a.  The number of badgers to be killed has been underestimated. Professor Stephen Harris, a co-author of the recent report on "Changes in the Badger Population 1988-1997," researched the number of setts and extrapolated a possible population figure with an average for the whole country. The Ministry's own research centre at Woodchester Park has a high density of 20-25 badgers per social group. As the South West has the highest density of badgers in the country, it is clearly not correct to stick with such a low figure.

  6b.  The close season regarding the killing of lactating sows is three months. English Nature allocates seven months to this protected zone. We believe that, leaving cubs to starve underground or by allowing them to come prematurely to the surface in search of food, is cruel and contravenes the spirit of the Wild Mammals Act.

  6c.  The dislocation of badger families is also cruel. They are social animals and rely on their group for mutual support and education for the young. When part of the family is eradicated, the remainder will be stressed and this may cause the very problem which MAFF is trying to eradicate.

6d.   Training operatives.

  Men will have to return yearly to maintain the absence of badgers in the designated areas. We are concerned about the quality of the staff employed. We understand that they will be "trained". More men will be needed as the reactive and proactive areas become established and we feel that some cruelty is inevitable.

  6e.  The suggested research into the use of leghold traps, which are merely spring snares. The Government is to investigate "the welfare" implications of these snares as used by the fur trade.

SUSTAINABLE POLICY

  Professor Bourne refers to his report as towards a "sustainable" policy. It is hard to believe that killing badgers can be regarded as "sustainable". There are no answers being given to the question about what will happen if the killing of badgers provides a short term solution. A thoughtful strategy would have considered all possible outcomes at the inception of such a programme.

FARMING COMMUNITY

  Farmers have been misled about many aspects of their work in recent years and, as a result, have had bad publicity through no fault of their own. They will suffer the same bad press in connection with the killing of badgers. We believe that the Government is doing the farming community a great disservice by not investigating the other strands of the Krebs Report more vigorously.

PUBLIC HEALTH

  The Government has not clarified to the general public that this is not a public health issue. The pasteurisation of milk removes Mycobacterium Bovis completely. Krebs admits that the risk to human health is negligible. There is some public concern.

INDUSTRY

  Krebs suggests that industry should be involved with research strategy. This has financial attractions, but we believe that "industrial involvement" may compromise the result.

THE "CULL"

  The use of the word "Cull" is a euphemism, as is "welfare" in connection with snares.

  Cull. The dictionary definition is "an unsuitable animal eliminated from a flock or herd" or "to pick out and destroy, as inferior members of a group". This is not MAFF's intention. It is not concerned with the health of the badgers. It is an experiment in the eradication of badgers in certain areas. It is certainly not a Cull.

  We believe that the public is being misled by this word. There is an implication that the badgers will benefit as a result of the killing which is clearly incorrect.

  Kirklees Badger Protection Group supports the National Federation of Badger Groups on these issues. I am sure that they have made these points far more effectively than I have done. However, we are glad of the opportunity to express the views of our members, to the Agriculture Committee and thank them for reading these notes.

12 January 1999