Evidence from English Nature, the statutory body responsible for advising both central and local Government on nature conservation issues and for promoting the wildlife and natural features of England. In fulfilling its duties, English Nature:

—  advises Ministers on the development and implementation of policies for nature conservation;

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—  identifies, notifies and safeguards Sites of Special Scientific Interest (SSSIs);

—  establishes, maintains and manages National Nature Reserves;

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  The Committee requested views on four topics:

1.   The design and likely effectiveness of the culling experiment proposed by the Krebs report and any significant issues which will have to be considered by the independent Expert Group overseeing the experiment.

  1.1  In a joint statement, the Conservation Agencies welcomed the publication of the Krebs report as a positive step towards resolving an issue which has persisted for many years. However, given the history of previous badger control strategies, we raised a number of concerns about the design and operation of the proposed culling experiment.

  1.2  Whilst recognising that the culling trial, at the scale proposed, will not permanently alter the national conservation status of the badger (although this will not be true at the local level), we believe it is important that badger culling is planned in a way which provides the maximum amount of information possible from the minimum amount of culling, consistent with the objectives of the work. In addition, we have expressed the view that no culling should begin until the Expert Group has assured itself that the likelihood of successfully completing the trial is high.

  1.3  We retain a concern that, because of factors outside the control of Ministry staff, it may not be possible to carry out the required fieldwork to the high standard required, posing a real danger that many thousands of badgers will be killed without the trial reaching a statistically-robust conclusion. This would be disastrous. Inevitably, there would then be pressure to extend the trial by culling more and more badgers in an attempt to reach a statistically-valid conclusion. We believe that such temptation should be resisted, as the culling intensity necessary to reach a statistically-valid conclusion has been carefully set by the Expert Group during the experimental design phase of the work. Similarly, an important part of Krebs proposal was that the trial should be completed in a pre-determined timescale. If this is allowed to slip significantly the statistical power of the experiment could be weakened.

  1.4  Whilst recognising the desire of the Government to try and resolve this long-running problem, some elements of the experimental protocol cause us particular concern. These include:

(a)   The ecological effects of badger removal. The ecological "knock-on" effects of large-scale badger removals are unknown, and we believe that the Ministry has a responsibility to undertake a programme to monitor the wider ecological effects of this trial. We urge them to adopt the recommendations of the report by Dr Robertson, commissioned by the Expert Group, which concluded that such monitoring should be undertaken. Monitoring any wider effects must be a particular priority around Natura 2000 sites (there are some in the first triplet to be chosen), but should be carried out in all proactive removal areas.

(b)   Shape and configuration of the experimental triplets. The adoption by the Expert Group of a much more flexible shape, following natural boundaries where possible, is to be welcomed. However, we foresee considerable difficulties in delineating the boundaries of such an area where it needs to follow the boundary of badger social groups. This weakness can be overcome, to some extent, by the use of buffer zones, but we anticipate some practical problems here, particularly where badger density is low.

(c)   Access to land within the trial areas. The Ministry has no powers of entry to land for the purpose of carrying out badger control operations. If staff are denied entry to significant parts of the trial areas, the experimental design would be seriously compromised. We recognise that the Expert Group can, where such areas are known, take this into account when the areas are chosen, but there remains a concern that large "no-go" areas within the triplets could seriously weaken the power of the experiment. Such areas could provide "sanctuaries" for badgers, which could continue to forage within the experimental area.

(d)   The proportion of badgers that can be removed. Experience indicates that some badgers can be extremely difficult to trap and, hence, that removal of all the badgers from the proactive removal area is unlikely. The views of the Expert Group should be sought on the extent to which this can be tolerated in the experimental design. In any event, it will be essential to include a realistic estimate of the number of badgers remaining within the proactive removal areas when the data are analysed.

(e)   Interference with fieldwork and illegal badger killing. Both these factors could weaken the power of the experiment by reducing any differences between the proactive, reactive and no-cull areas, perhaps to the point where the experiment becomes worthless. We do not have any factual information about the extent of illegal badger killing, but recommend that the Expert Group gathers what information it can about the scale of this problem. Interference with MAFF field operations will only become apparent once work is under way, but this needs to be kept under review as work progresses. The Expert Group has suggested that interference with field work may result in extra triplets being added to the experimental design, but we suspect this may be impractical for logistical reasons (staff, budget and availability of suitable areas).

  1.5  In conclusion, we believe that the experiment has the potential to shed considerable light on the relationship between TB in cattle and badgers, but that the practical difficulties of implementing the experimental design need to be carefully assessed and kept under review. To assist with this, the Expert Group may wish to seek greater involvement from those with experience of badger field studies.

2.   Issues to be considered in the implementation of the experimental comparison of different husbandry methods proposed by the Krebs report.

  2.1  The limited geographic distribution of persistent foci of TB infection in cattle suggests strongly that local factors, which may include husbandry methods as well as environmental factors, play a significant part in the probability of herd breakdowns. We welcome, therefore, the proposals for further studies of these factors, which could contribute to highly cost-effective ways of reducing the rate of herd breakdowns. Indeed, there may be benefits to expanding some of these studies, since it is important that the husbandry issues are examined closely.

  2.2  In assessing the extent to which changes in husbandry practices could contribute towards a reduction in herd breakdowns, we believe it is important that the impact on nature conservation of any proposed changes to husbandry methods is taken into account. For example, measures to reduce the number of hedgerows would act counter to policies to reduce agricultural intensification, and could have a negative impact on efforts to enhance biodiversity.

3.   The Government's implementation of the changes in the bovine TB research strategy proposed by Krebs

  3.1  In our response to the Krebs report, we recommended that the balance between research funding and TB control measures be carefully examined. We welcome a greater emphasis on research as we believe that a long-term solution to the problem can only emerge through a greater understanding of the origins of herd breakdown. In addition, we believe it is important that research work is commissioned from those best placed to carry it out successfully, and look to MAFF to develop more extensive patnerships with the research community.

4.   Other issues

  4.1  Although there is wide agreement that the development of a cattle vaccine is a highly desirable goal, this is some way off and there remains considerable uncertainty as to whether a suitable vaccine can be developed and utilised. A strategy which relied completely on the development of a cattle vaccine would thus carry significant risk of failure and so we recognise the desirability of an approach which explores a number of different routes, including badger management and cattle husbandry practices.

  4.2  Nevertheless, we believe it is essential that any future strategy also takes into account the costs and benefits, both financial and to nature conservation, of any changes to disease control practices. In particular, we would not see the permanent removal of badgers from large areas of the south-west as either desirable or achievable. Such an approach would simply not be sustainable in the long-term and would not provide the hoped-for solution to the problem of herd breakdowns.

15 February 1999