The Countryside Council for Wales is the statutory adviser to Government on sustaining natural beauty, wildlife and the opportunity for outdoor enjoyment throughout Wales and its inshore waters. With English Nature and Scottish Natural Heritage, CCW delivers its statutory responsibilities for Great Britain as a whole, and internationally, through the Joint Nature Conservation Committee.

  The badger is a protected animal in Britain and is the only species with its own act, The Badgers Act (1992). Wales has a sizeable population of badgers across the Principality. There has been a high incidence of new TB outbreaks in cattle recently in Dyfed and Gwent and CCW is sensitive both to the needs of conserving badger populations and to reducing or eliminating TB outbreaks in cattle.

  CCW Council will be discussing this issue on 10 March 1999. If it determines anything which is different from the contents of this submission, we will of course inform you immediately.

  The Agriculture Committee requested views on four areas:

  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  The Country Conservation Agencies for England, Wales and Scotland, produced a joint response (February 1998) which welcomed the Krebs report as a positive step in resolving an issue which has been insufficiently and unsystematically addressed for many years.

  1.2  CCW recognises the need for rigorous scientific data to resolve any role that badgers play in the transmission of bovine TB to cattle. However, we believe that the trial has commenced prematurely before all methodologies and areas of concern expressed by Government Agencies and NGOs have been sufficiently addressed to ensure the maximum amount of information is collected from a minimum amount of culling, consistent with good experimental design.

  1.3  Whilst CCW recognises that the culling trial as proposed will not alter the national status of the badger in Britain and recognises that a literature review has been undertaken, we are extremely concerned that there has been no Environmental Impact Assessment (EIA) undertaken of the likely ecological effects of removing badgers from areas as large as 100 km2. Because this trial concerns a protected species, we would have thought that such an assessment was a pre-requisite. Although a field project is proposed (and we have been consulted on its methodology), there has been no action undertaken on the ground despite the culling trial commencing in the Autumn of 1998. CCW is of the view that such an assessment should have been undertaken well before the trial began.

  1.4  With regard to the EIA, whilst CCW is aware of the difficulty in monitoring the effects of badger removal from the reactive sites as well as the proactive sites, we believe that it is essential that a thorough examination of both treatments, compared to the control is undertaken if these treatments are to be properly assessed as a potential future strategy for TB management.

  1.5  Methodologies such as assessing badger densities have not yet been resolved despite being integral to the trial protocol.

  1.6  External auditors recommended to oversee the trial are not in place.

  1.7  Whilst CCW accepts that the trial may be robust enough statistically to withstand certain levels of interference, we remain concerned that outside influences could reduce the ability of MAFF to carry out a taxing programme of fieldwork to a high standard and tight timetable. It is essential that the trial should reach a statistically robust conclusion if thousands of badgers are to be culled and public money spent and clear conclusions reached. CCW does not believe that the addition of further culling areas should be considered if interference to the culling programme becomes a significant problem.

  1.8  MAFF staff have no powers of access to land for the purpose of carrying out badger control operations. If access is denied to large areas of land this would reduce the power of the trial and in addition may allow "sanctuaries" for badgers which would continue to forage in the experimental area.

  1.9  In conclusion, CCW believes that the experimental design of the culling trial has been compromised by starting the trial before all of the methodologies and issues surrounding the trial have been resolved. In particular, CCW believes that it is unacceptable to commence such a trial involving culling of a protected species before an Environmental Impact Assessment has been undertaken and that it sets an unfortunate precedent.

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

  2.1  Evidence from previous studies suggests that changes to animal husbandry practices could reduce the outbreaks of TB in cattle. In addition, TB outbreaks occur in geographically restricted areas mainly in the south-west of Britain which suggests that environmental factors play a significant part in disease prevalence and transmission. CCW therefore welcomes research into these aspects and urges that sufficient emphasis and funding is in place for this work. We have not seen any significant information to convince us that it is.

  2.2  Whilst the Expert Group and MAFF are considering methodologies to reduce herd breakdowns in cattle, CCW would urge that the wider implications on nature conservation should be taken into account. For instance, removal of hedges would be contrary to CCW's policy, for example through the delivery of Tir Gofal (the new all-Wales agri-environment scheme) to reduce agricultural intensification for the benefit of wildlife and landscapes.

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

  3.1  CCW welcomes the more open and balanced approach to the problem of TB in cattle which has resulted from the Krebs report. It urges that sufficient research is funded on all aspects surrounding transmission and prevention of the disease and we look to MAFF to develop a more extensive partnership with the research community to ensure that all the relevant experts are involved.

  3.2  Whilst there has been a great deal of work in recent months on the culling trial, CCW would like to see a shift in emphasis towards the development of animal husbandry techniques and the development of a TB vaccine for cattle.

  3.3  CCW considers that the development of a vaccine for cattle may represent the best long-term prospect for the control of TB in cattle. In written information supplied to us, MAFF consider that it will be 10 to 15 years before a suitable vaccine may be available. Professor Bourne, chair of the Expert Group does not consider that increased funding would speed up the development of a suitable vaccine. However, information from Glyn Hewinson, Head of TB Research at the Central Veterinary Laboratories suggested that it is "more likely" that with more resources, vaccine development could be shortened by a couple of years. According to the Minister of State at MAFF (Mr Rooker) in a House of Commons debate on bovine TB on 22 February, MAFF intends to devote "a lot more money" to its development. CCW urges that sufficient funds are directed to this area of research to ensure that vaccine development is undertaken with all speed and that more clarity is provided on the rate of development of such a vaccine.

4.   Other issues relating to the question of badgers and bovine tuberculosis

  4.1  We are not at all clear regarding the future strategy for TB control if badgers are found to be significant vectors of bovine TB. We would not support widespread culling and we understand, there is no consideration by MAFF for such a step. Consequently, we believe that clarity throughout this process is required. CCW believes that any future strategy for TB control must take into account the costs and benefits to nature conservation of any changes to disease control practices.

3 March 1999