1.  We welcome the opportunity to submit evidence to the Committee for its inquiry into badgers and bovine TB. We have been concerned about this issue for many years—in light of the devastating implications for farm businesses of TB breakdowns and the animal welfare implications of bovine TB for both badgers and—too often forgotten—for cattle. We submitted evidence to the Krebs Committee and, in February 1998, commented on the Krebs report and the Government response. The latter submission, which raises many issues that have still not been effectively resolved by the Government in taking work forward in this area, is attached. We invite the Committee to consider the points raised.

  2.  We are pleased that the Government has decided to act on the Krebs report and that a programme of trials is now being put in place following the report of the Group chaired by Professor Bourne. We strongly support the trials and are encouraging individual farmers and landowners to do likewise. However, we remain concerned over various aspects of this issue. We should particularly like to draw the Committee's attention to the following:

(a)  Various groups have sought to argue that there is no link between TB in badgers and cattle. The authoritative view is set out in the Krebs report: "The sum of evidence strongly supports the view that, in Britain, badgers are a significant source of infection in cattle. Most of this evidence is indirect, consisting of correlations rather than demonstrations of cause and effect; but in total the available evidence, including the effects of completely removing badgers from certain areas, is compelling."

(b)  It has also been argued that because the culling of badgers under the interim strategy appears not to have tackled the problem effectively, any culling is pointless. The Krebs report states that "the indication is that more severe culling policies involving complete, or near complete, removal of badgers from an area, are more effective at reducing the herd breakdown rate than is less complete removal." This finding suggests that it is the type of culling of policy adopted which matters. It can be argued that culling under the inerim strategy has exacerbated the problem by encouraging dispersal ("perturbation") of the remaining badgers and high levels of stress in badger social groups (leading to a flare up of infectious TB).

(c)  We are concerned at the narrow scope of the trials. They are to be implemented in stages over three years, rather than at once, and do not cover enough of the "hotspots" where farm businesses are severely affected by TB herd breakdowns. The total number of trial areas should at least be doubled. This would demonstrate to farmers in all the affected areas that the Government takes the threat of bovine TB seriously. Trials covering a larger area would also be expected to yield meaningful conclusions sooner than the current trials. This would minimise the delay before a new national TB control strategy, based on the results, is put in place.

(d)  We see particular advantages in selecting "hotspots" in the Midlands for the trails. There has been a significant increase in herd breakdowns in this area in recent years. Moreover, badger populations are relatively undisturbed by reactive culling activities in this area, given the recent nature of the breakdowns. This area should be a priority for establishing trials, alongside areas where there is a long history of bovine TB.

(e)  Lack of resources appears to be a reason for the limited scope of the current trials. We are concerned that inadequate resources are being made available to ensure that the trials proceed effectively. Once again, as in the past, the Government risks doing too little. The Krebs Committee proposed a conclusive experiment that would deliver, once and for all, clear answers to the many questions surrounding the control of TB in badgers and cattle. It would be very regrettable if the value of this experiment was reduced simply by a failure to fund it properly.

(f)  We are particularly concerned that the staff resources available to run the trials are inadequate. Trained staff are needed to undertake the detailed survey work on which the trials are based, annual testing for TB of cattle within the trial areas, and effective badger removal operations where required. The Government should ensure that all the trained, qualified staff needed are in place as soon as possible. This concern is exacerbated by the news that work to establish the second triplet of trial areas has apparently been delayed because of a lack of trained staff.

(g)  We also consider that compensation should be provided for the "consequential losses" of farmers where restrictions are placed on their herds following a TB breakdown. Compensation at a rate of 100 per cent. for infected cattle is welcome, but inadequate by itself to reflect the full impact of breakdowns on farm businesses. Compensation should be made available throughout the country, to alleviate the losses faced by farmers—for example when they are prevented from selling cattle and have to buy-in extra feed to keep them until they can be moved off the holding.

15 January 1999

  A1.  The CLA has serious concerns about the problem of tuberculosis in cattle and badgers—particularly as regards its economic and social implications—and about the effectiveness of the current control policy. Action cannot come too quickly for those farmers and landowners affected by tuberculosis breakdowns where badgers have been implicated.

INCIDENCE OF BREAKDOWNS

  A2.  We recognise that the incidence of breakdowns is low in absolute terms—but their seriousness is perhaps better reflected by noting that "0.4 per cent" means 1 in 250 herds, and "1 per cent" means 1 in 100. For those farmers who are affected, the rate of breakdowns is, of course, 100 per cent: it is that figure which must be the focus of attention.

ECONOMIC AND SOCIAL IMPLICATIONS

  A3.  The economic and social implications of breakdowns should not be under-estimated—especially for small farms. The restrictions on sales can be catastrophic. We understand that the NFU is surveying the economic impact of breakdowns. We hope that the Government will fully heed the results of that survey. It is also important to recognise that if the UK were to lose its "TB-free" status, this would have substantial trade implications, which again would impact on the sector.

HEALTH RISKS

  A4.  We endorse the Committee's conclusions on health risks to the public. It should also be recognised that the system of meat inspections provides a further safeguard against infection for consumers of meat. We consider that the health risks to stockmen, farmers and their families of exposure to bovine TB through direct contact with infected cattle should be closely monitored. There is always the potential for the disease to be present and infectious before it is detected, and during this time those coming into contact with cattle could be at risk.

EXPERIENCE FROM ABROAD

  A5.  We note the point that cattle in other countries in Europe and elsewhere also have infections of M. bovis. It is important that experience in other countries is taken into account in developing and implementing UK policy.

LINKS BETWEEN TB IN BADGERS AND CATTLE

  A6.  We note that paragraph 9 of the Government response refers to "substantial" evidence for an association between TB in badgers and cattle. We feel that this downplays the findings of the Committee—which states that such evidence is "compelling". Further work is needed to establish the link between TB in badgers and cattle. It should be possible to do so, beyond doubt, through the molecular typing of the infective agent. We accordingly fully support the study to test these techniques proposed in paragraph 7.6.2 of the report.

TB IN OTHER WILDLIFE

  A7.  We agree that it is important to continue to study TB in other wildlife species, to establish to what extent these, as well as badgers, are linked to TB in cattle.

PAST FAILINGS

  A8.  The report demonstrates clearly the problems which arise when Governments fail to grip problems firmly enough. In this case we consider that there has, for too long, been too little science and too much political judgement in this policy area. Sound science needs now to be the guiding force. A conclusive experiment is essential.

DIFFERENT CULLING STRATEGIES

  A9.  This finding that "more severe culling polices involving complete, or near complete, removal of badgers from an area, are more effective at reducing the herd breakdown rate than is less complete removal" accords with our own perceptions of the effectiveness of different policies over many years. While recognising the value of the experiment now proposed, it could be argued that this conclusion on its own is enough to justify introducing a more effective strategy now, rather than the policy of "no culling combined with husbandry measures" which is to be applied outside the proposed experimental areas.

THE PRINCIPLE OF THE PROPOSED EXPERIMENT

  A10.  We support the proposed experiment involving three treatments: proactive culling of badgers, reactive culling following the identification of TB in cattle, and no culling. Farmers may be able to play a useful role in monitoring the recolonisation of setts. However, we do not consider that it is advisable to involve farmers more fully in the day-to-day operation of the experiment. Any such involvement could be misconstrued by extremist groups, placing farmers at risk of threats and other intimidation.

  A11.  We note the comments made in paragraph 15(c) of the Government response regarding the recommendation to remove lactating sows in the experiment. We consider that the removal of lactating sows is essential if the experiment is to succeed, and note that this conclusion is supported by the Committee's report.

ROLE OF THE EXPERT GROUP

  A12.  We consider that it is very important that the Expert Group is composed of scientists. It must be credible and not subject to political influence—or vulnerable to any suggestions that it is. However, we are concerned at the suggestion that it should be MAFF which carries out the cost-benefit analysis. We suggest that this should be part of the remit of the Expert Group—to avoid any suggestion that the analysis is influenced by public expenditure or other concerns. The analysis should be a straightforward economic analysis.

  A13.  It is important that the parameters for the cost-benefit analysis are subject to public consultation. We seek confirmation that the following will all be included in the analysis: the costs of compensation for breakdowns (within the experiment and outside it); loss of earnings by those affected by breakdowns (eg as a result of restrictions on stock movements); the social costs of herd breakdowns; long-term damage to earnings (eg where highly-productive herds have been built up over many years); the impact on land values associated with the blight of a breadown, or the risk that a breakdown might recur (ie impacts on values between farms in the same region, and between farms in different regions); the impact of breakdowns on exports (eg the implications if the UK lost its TB-free status); and the costs of the further surveillance needed if this happened. It is also essential that a full risk assessment is applied to the issue. For example, this should assess the costs if the UK did lose its TB-free status.

  A14.  We suggest that it might be helpful for the Expert Group to meet farmers and their representatives from time to time to exchange views. Such meetings could provide a useful sounding board for the Expert Group and help to keep the farming community in touch with progress—which should in turn help to build confidence among farmers in the operation of the proposed experiment. The consultation meetings held by the Krebs Committee provide a good precedent.

THE PROPOSED EXPERIMENT

  A15.  We consider that the proposed experiment must be extended to take account of "hotspots" which appeared in the 1990s (eg in Staffordshire, Derbyshire and Shropshire, where more than fifty farms are now affected). It is strange that the report does not identify these, despite the continuing concern over them over the last three years or more. Figure 5.2 in the report needs to be up-dated to the present. A particular advantage of including these areas would be that they have been relatively undisturbed by removal operations in the recent past compared with other parts of the country: this could assist the experiment. Inclusion of such areas is especially important in studying the epidemiology of the disease (ie if new spoligotypes are involved in breakdowns in such areas).

  A16.  If further breakdowns occur in new areas, these too should be considered for addition to the experiment. We also consider that the experiment should include all 10-km squares where there have been more than 6-8 breakdowns per square. This would extend the total experimental area to some 6,000 square kilometres. In making this suggestion we note in particular that increasing the sample size would reduce the period before conclusive results would be obtained. This is a very strong argument for extending the experiment. The removal operations within the experimental areas must include the removal of badgers in woodland setts as well as farmland setts, if they are to be effective.

  A17.  We consider that enhanced compensation for breakdowns will be essential to encourage farmers to co-operate with the experimental approach suggested. This should be at least 125 per cent of the market value of the animal slaughtered for the first breakdown, and rise to 150 per cent where there is a second breakdown on the same farm, 175 per cent where there is a third breakdown, and so on. Compensation should be payable from the identification of the trial area up to the time that a new strategy is accepted and implemented by the Government. It should be available throughout the experimental area and outside it.

  A18.  It is essential that such compensation is available: otherwise there is a risk that farmers may take illegal action to cull badgers in parts of the experimental areas, which would render the experiment useless. This is a risk—unless adequate compensation is provided—even though it will be in the interests of farmers as a whole to co-operate with the experiment. The danger is that any one farmer may consider that it is in his best interests as an individual to take illegal action to cull badgers. Consideration also needs to be given to the provision of compensation not only for the loss of livestock but also for consequential losses.

  A19.  The experiment could also be damaged if farmers in those areas where the "no culling" strategy applies were simply to cease farming cattle. This would then automatically reduce the risk of breakdowns, and distort the findings (the "no cull" option would appear to be 100 per cent effective if there were no breakdowns in the areas involved because there were no cattle there to be infected). This means that in these areas, those farming cattle will require an incentive to continue farming in the same way for the period of the experiment. There must, at least, be no reduction in the numbers of cattle or substantial changes in their geographical distribution. An incentive will be required, as well as enhanced compensation for breakdowns. This will only be required within the experimental areas. Outside them if, as a result of a breakdown, a farmer moves out of cattle, this will not affect the experiment and no such incentive payment will be required.

  A20.  It is essential that MAFF continues to operate the licensing system to deal with disturbance by badgers. We seek an assurance that the system will continue to operate normally throughout the experimental areas. Compensation will need to be paid if farmers within these areas, who would otherwise be able to secure licences to deal with badger damage (eg under-mining) to crops, building or land, are unable to do so for any reason connected with the experiment.

  A21.  A further concern is that it may prove difficult to remove badgers in some cases because of the resistance of some landowners who may wish to protect badgers from any culling. There is a danger that the experiment might be disrupted, or be accused of being invalid, by any failure to effect complete clearances. In these cases the Government should ensure that those involved have effective powers to enter land to remove badgers for the purposes of the experiment.

  A22.  We are concerned that the validity of the experiment could be questioned in general if badger clearances are incomplete or too slow, with the result that infected badgers stray outside the experimental areas or into areas within the experiment where different strategies are being tested. The associated risks are highlighted in paragraph 7.4.4 of the Committee's report. We seek an assurance that the methods used will effect complete and rapid clearances. We suggest that all available humane measures should be used, including, possibly, gassing with carbon monoxide—a humane and potentially effective approach.

  A23.  We reject the suggestion in the report that farmers should bear some of the costs of the experiment. By the breakdowns which they have experienced, and the costs associated with these, farmers have been underwriting for many years the failure of successive Governments—as noted in the report—to tackle the TB problem effectively. The Government should bear the costs involved. The costs should certainly not be borne only by those who suffer breakdowns.

STRATEGY OUTSIDE THE EXPERIMENTAL AREA

  A24.  We suggest that consideration should be given to applying the reactive strategy outside the experimental areas. This would reassure farmers that some action is to be taken to tackle the problem of the re-emergence of TB in such areas after many years without breakdowns. We note that additional costs would be involved. However, we recommend that this option should be considered.

HUSBANDRY MEASURES

  A25.  We suspect that the existing advice has not been widely heeded because it is impractical and substantial costs are involved. For example, rabbit netting is no deterrent to badgers; fencing needs to be maintained; raising troughs is not an option where sheep are grazed; calves are often fed molasses—which it is impossible to keep away from badgers; and minimising contact really means simply keeping cattle indoors—not an option for most farmers.

  A26.  We suggest that the Expert Group—not MAFF—should take the lead in developing a closely-managed experiment to establish the value and cost of different husbandry measures. A thoroughly scientific study is needed, not a half-hearted poorly-controlled initiative where some measures are tried in some places but not others, over different periods, and in different ways. This is essential if farmers are in time to be persuaded of the credibility of husbandry measures.

  A27.  Such an experiment must also be properly funded and resourced. There should be grant-aid for farmers for investment in husbandry measures. We would suggest the preparation of whole-farm investment plans with grant-aid at a high proportion (75 per cent) for the preparation and implementation of measures agreed under those plans over a fixed time-scale. We understand that there is a scheme which pays farmers to protect badgers in the Netherlands. Any relevant experience should be drawn upon in designing a grant scheme here.

  A28.  We also suggest that the Meat and Livestock Commission should prepare a promotional video featuring farmers who have successfully adopted different husbandry measures in different parts of the country. This would help to communicate personal experience of best practice to other, often sceptical, farmers. A video could be much more persuasive than a leaflet alone.

VACCINES

  A29.  We support efforts to develop both cattle and badger vaccines. However, we suggest that priority should be given to a badger vaccine. This need not be difficult to apply in practice—it can be added to bait placed outside active setts. By reducing the level of infection in badgers, a vaccine would further reduce the risk of transmission to cattle. A cattle vaccine would be valuable but regard must be had to the need to develop at the same time a diagnostic test to distinguish between cattle which are infected and cattle which have been vaccinated: this could prove to be a difficult and lengthy exercise.

RESEARCH STRATEGY

  A30.  We agree that MAFF should commission research—under the guidance of the Expert Group. This task should become a formal part of their remit. We suggest that as far as possible the work carried out should be independent of the Ministry. In our submission to the Krebs Committee we listed several priorities for legislation. We commend these suggestions to the Expert Group and to the Government for consideration in developing a new, comprehensive, research programme.