The Gwent Badger Group was formed in 1974 and has for the past 25 years been involved in many aspects of badger conservation.

  During this period there has been three independent scientific reviews, several different badger culling programmes and an incalculable amount of research carried out, all with the expectation of solving the complex dilemma of bovine tuberculosis. Unfortunately the main concentration of efforts into eliminating and controlling bovine TB has been to cull in excess of 20,000 badgers, of which approximately 80 per cent proved negative for TB, and despite this, incidence of the disease in cattle is increasing.

  It is therefore both frustrating and dismaying that the current recommendation is to cull a further estimated 12,500 badgers. This will not be carried out as part of a control measure but, quite simply, as an experiment which, at best, will only proivde a short term solution to the problem. In addition to this, £27.5 million has been allocated to the culling experiment whilst it was recommended by Professor John Krebs that the farming industry should take the lead in [fund] comparing simple husbandry techniques which he continues" . . . may well play an important role as part of the long-term solution".

  Using a combination of relevant research and current computer technology the opportunity exists to examine a wide range of possibilities. This has the advantage of reducing both public expenditure and time scale involved in identifying workable long-term solutions.

  On behalf of the Gwent BG I would ask that you consider the attached submission and recommend to the Government that the culling experiment be suspended immediately until all other satisfactory solutions have been investigated.

13 January 1999

  This document presents the views of the Gwent Badger Group.

1.   The culling experiment will not produce statistics that will be acceptable to all parties

  The culling experiment will be subject to interference by both animal rights and farming groups. As the experiment is not being carried out under strict scientific conditions, landowners denying access to land, and releasing of badgers from cage-traps and leg-cuffs, the failure to cull all badgers in pro-active areas and the illegal killing of badgers in no cull areas will invalidate the work. The analysis of data adjusted to account for the above will leave the result open to criticism and fail to provide incontrovertible proof of a badger to cattle link.

2.   The culling experiment does not address the problems of reducing the incidence and is unlikely to contribute significantly to the elimination of TB in cattle

  Previous badger removal trials have only reduced the incidence of TB in cattle in the short term. The results of this experiment, were they to show a reduction in the incidence of TB in cattle, would only add to the circumstantial evidence already collected. The purpose of the culling experiment should be to develop a strategy that, when implemented, will bring about a significant reduction in the incidence of TB in cattle. If the results of the experiment suggest, even to the smallest degree, that the removal of large numbers of badgers in high incidence areas will decrease the number of outbreaks, and the government have stated that this is not their intention, then what is the purpose of the experiment? The culling experiment will also fail to identify the possible routes of infection and measures that can be taken to prevent the risk of infection.

3.   The experiment into trapping of badgers by means of leg-cuffs will cause unacceptable levels of suffering

  The use of leg-cuffs, as an alternative to snares, will still inflict injuries such as dislocation and muscle damage. The possibility of badgers self mutilating in an attempt to escape should also be considered and, therefore, such devices should not be viewed as humane. Only cage-traps which have been specially developed to wholly contain badgers until culled should be used in the experiment. However, whilst preventing physical harm cage-traps still cause extreme levels of stress to captive badgers.

4.   The culling experiment will be an indiscriminate slaughter of a large number of healthy badgers

  Current MAFF data (1974-97) confirms that approximately 80 per cent of badgers culled in previous trials and badger removal operations have not been infected with TB. Of the 20 per cent infected only 15 per cent of these are likely to reach the stage whereby they become infectious. Using the above statistics and current government estimates of 12,500 badgers being culled the experiment is unlikely to remove more than 400-500 infectious badgers. The experiment will remove approximately 2,500 badgers that although may have the potential to become infectious also have the potential to develop immunity.

5.   The closed season is inadequate and will lead to the unnecessary suffering and cruel ill-treatment of badger cubs

  The currently proposed closed season, 1 February to 30 April inclusive, is inadequate. The culling of lactating sows will bring about the unnecessary suffering of cubs that are unable to feed independently. The government statutory nature conservation councils recognise that badger cubs can be dependant upon their mothers for a considerable time and impose a closed season of 7 months, 1 December to 30 June inclusive, to ensure that sett closures and disturbance will prevent cruel ill-treatment.

6.   Public expenditure is being directed to killing badgers and sufficient funds are not being provided for other research

  The badger control and research budgets for 1995 were £1.2 million and £1.37 million respectively. The current costs of £3.5 million for the first year and £6 million for each subsequent year of the culling experiment indicate a vast expenditure of public funds being used to contribute further to the results of previous culling trials. The allocation of £1.7 million in 1998-99 rising to £3.1 million in 1999-2000 for other research is inadequate to support investigations into cattle husbandry and farm management practices, trace mineral deficiencies and, most importantly, vaccine development which offers the best prospects of a long term solution.

7.   Investigation of wildlife infected with TB other than badgers

  The recommendations of Professor J Krebs (Bovine Tuberculosis in Cattle and Badgers, 1997) was that all wildlife species should be assessed in areas of high herd breakdown incidence as potential transmission risks to cattle. We understand that there is to be no research carried out acting on this recommendation. Whilst current information indicates that the risk from mammals other than badgers is small, the potential exists and therefore should be investigated as proposed.

8.   Recording of TB testing dates on cattle passports

  The movement of cattle into and out of high risk areas without reference to previous TB tests can contribute to the spread of TB. The recent introduction of cattle passports provides the opportunity for the recording of TB test dates to be included along with other details. Whilst the need for confidentiality precludes information as to the past TB history of cattle or farms being entered the inclusion of TB test dates would enable farmers to be aware of whether or not they were purchasing cattle or making use of hire bulls that have missed regular TB testing.