The proposal to issue supplementary licences in the absence of any evidence that culls conducted over four years have resulted in any benefit is completely at odds with Government commitments to evidence-based policy making.
Submissions to Defra's latest public consultation on badger culling closed on February 10th.
This time they were seeking opinions on their plans for 'supplementary badger disease control'.
What they mean by that is that any badger cull which has completed its allotted four years could be licensed to simply go on killing badgers.
How many consultations have been held over this thorny issue? Three or four? Or more? I've lost count. What is clear is that not once have environment or farming ministers listened to (or perhaps even read) the responses, whether from ordinary members of the public or, importantly, from scientists, vets, ecologists and wildlife organisations.
In The Fate of the Badger author Dr Richard Meyer, a member of the Consultative Panel (CP) when the government was planning to cull badgers in the 1980s, quoted from a 2009 paper Intractable Policy Failure which said that one minister asserted that the CP: "plays a major role in allowing us to demonstrate that all shades of opinion on badgers have been taken into account before we kill them."
Consultations are there as fig leaves. Opinions contrary to the government's desired policies have never been taken into account.
Concerned organisations responded with science
With each consultation the barrage of science against badger culling gets stronger, as yet more studies are published (some of them government-led as in Northern Ireland) demonstrating that it is not badgers that are to blame for bovine TB in cattle, but poor testing, even poorer biosecurity and cattle management.
As before, Defra's Consultation document is full of cherry-picked poor science, science that has been proven wrong by later (or even previous) studies and proposed actions based on fanciful assumptions presented as facts.
Defra still maintains, despite ongoing research to the contrary, that disease spread from badgers to cattle is an important cause of herd breakdowns. The Zoological Society of London (ZSL) is politely scathing about the way 'evidence' is presented:
"Such documents should equip the reader to provide informed comment on the government's proposals ... it misrepresents the level of certainty associated with the action proposed... there is thus far no evidence of any disease control benefits from industry-led culling and no evidence as to whether continued culling would prolong such anticipated benefits."
Lack of evidence of any reduction in cattle Tb is an issue raised by several organisations. Using Defra's own figures they point to the drop in new incidents before culling started, caused by the implementation of tougher testing and cattle movement controls.
Defra then added something else, the use of another bTB test (IFNy) which gave more accurate results and identified more infected cattle. This would lead to fewer new incidents of bTB. But the drop is being claimed as proof that the badger culling is working.
"Unfortunately, Defra has undermined its own ability to use this measure, by deciding to use the IFNy test on cattle only in areas where badger culling has been undertaken. Hence, ongoing attempts to estimate the impact of badger culling on cattle TB will be confounded by improvements in cattle testing in cull (but not comparison) areas." ZSL
This is Defra's justification for continuous culling, but both the 'evidence' and the 'success' have been queried. Defra claims that the first two culls, in Somerset and Gloucester, "have now completed successfully their fourth and final year." What do they mean by 'success'?
"Even after four years of culling in Gloucestershire and Somerset, there is no evidence, or indeed any suggestion of any beneficial effect on TB in cattle." HIS UK
The Badger Trust goes further and asks whether badger culling is actually legal:
"More specifically there is a fundamental omission from the licencing process that has existed from the beginning of the 2013 'pilot' culls, namely that there is no requirement for licencees to produce any evidence of bTB infection in badgers or to establish any credible risk to known populations of cattle.
"That is to say there are no safeguards within the process to ensure that 10,2(a) of the Protection of Badgers Act, 1992 (... for the purpose of preventing the spread of disease ...) is being met and thereby ensuring that any culling is actually legal under the Act."
And they point out that "All criteria mentioned with regard to the 'success' (or failure) of culling, or the conditions needed to be met before renewing 'supplementary licences' refer only to numbers of badgers killed."
The International Fund for Animal Welfare (IFAW) commented: "It appears the only criteria being applied to define success of the prior culls is number of badgers killed, not a visible reduction of bTB within cattle herds."
'Estimating' badger populations without field surveys
One reason for disputing Defra's idea of 'success' and its plans for the future is the inability to produce any believable badger population figures. ZSL has a lot to say about this. It had taken a lot of hard field work to produce the badger population figures for the first year of culling in Somerset and Gloucester, and even then it was wrong. But now, says ZSL:
"These concerns arise because Defra attempted to estimate badger numbers without conducting any field surveys in the cull zones... Without reliable estimates of initial population size any estimate of population size reduction is likewise unreliable. Unfortunately, now that culls have commenced in these areas the initial badger population size is unknowable."
They conclude: "it is not at all clear how Natural England could be expected to set target numbers of badgers to be killed in follow-up culls ..."
"There is no conclusive evidence that culls carried out to date have resulted in significant disease control benefits, nor that extending them will result in or prolong any such benefits." Born Free Foundation (BFF)
And even Defra admits that there is no evidence on the effects of longer term badger control. The desired benefits are no more than an assumption.
Welfare is left to the killers
Defra wants to continue the use of 'free' or 'controlled' shooting, which was found to be inhumane by the Independent Expert Panel in the very first year of culling. Since then even the British Veterinary Association has condemned free shooting. Just about everyone has called for its ban.
Farmers want shooting for two reasons. Cage-trapping badgers is much more expensive, time consuming and involves physical labour. And - let's be brutally honest here - shooting is much more fun, more macho.
The lack of monitoring, supposedly under the control of Natural England, which is the only way to prove the inhumaneness of shooting, is also called into question. "Wholly inadequate" was BFF's response, based on Natural England's own figures. Only 2% of the badgers shot in last year's cull were observed by monitors, and only one badger was autopsied - out of a total of 8,639 dead badgers.
"Entirely inadequate", echoed Humane Society International UK (HSI UK), adding: "The increased reliance on self-reporting by culling contractors is inappropriate and liable to lead to erroneous data; for example in 2016 contractors reported a level of missed shots one tenth of that observed by NE monitors."
Both the Badger Trust and BFF said that Defra appeared to rely on the Chief Veterinary Officer's belief that "the level of suffering in badgers is comparable with other forms of culling, currently accepted by society". So that's okay then. Hang on - I seem to remember several explosions of public rage over proposals to cull - beavers and buzzards to mention just two.
Defra's 'cost analysis' doesn't add up
"Plans to extend the culls in this way nullify the original cost benefit analysis." IFAW
"Like every other government department, DEFRA and therefore Natural England, have been subject to continuous cuts in budgets and human resources so it is reasonable to assume that much of what is expected of it under the proposed scheme will be beyond its capacity to deliver." Badger Trust.
"The proposal to issue supplementary licences, in the complete absence of any evidence that culls conducted over four years have yet resulted in any benefit and without any evidence from the RBCT or elsewhere that culling beyond four years is warranted is completely at odds with Government commitments to evidence-based policy making." HSI UK.
"The Government claims to have shown that the culling policy will have a positive cost benefit. This is at odds with numerous independent economic analyses and relies on the reduction in TB in cattle shown by the RBCT, which is unlikely, and has not yet been demonstrated." HSI UK
As the Badger Trust points out, TB eradication is being used as an excuse to slaughter badgers, not a reason.
"[I]t is possible for significant portions of the cull zones to be made up of land where no cattle exist and where any risk from badgers (diseased or otherwise) is non-existent. The process allows for landowner / farmer participation in the culling exercise to be based simply on their 'desire' to cull badgers regardless of whether they keep cattle or not."
But will Defra listen?
I said that opinions contrary to the government's desired policies have never been taken into account. So does it surprise you that, just 11 days after the consultation closed and before Defra has had any time to consider the large holes in their science (if indeed they would), Environment Secretary Andrea Leadsom told the NFU conference:
"Last summer we rolled out the cull to seven additional areas - all of which were successful. And this year, I want to extend that even further."
Lesley Docksey is a freelance writer who writes for The Ecologist and other media on the badger cull and other environmental topics, and on political issues for UK and international websites.
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