May 2020 consultation

Last Updated on 22 June 2020 by Badger

In May 2020, the government launched a public consultation on proposals to manage the delivery of both badger vaccination and culling in counties in the Edge Areas (EA).

This page is designed to help you to respond to the consultation by showing Somerset Against The Badger Cull’s response.

You may also wish to check out guidance given by Somerset Badger Group.  Other useful responses have been put together by Rosie Woodroffe, a biologist working at the interface of wildlife conservation and epidemiology and Derbyshire Against the Cull.

Respond to the consultation


Question 5 – Should vaccinated badgers be protected from culling to some degree, to manage delivery of adjoining vaccination and culling?

Yes. Vaccinated badgers should be protected from culling.  Completely. We do not agree with the use of the words ‘to some degree’.  What does ‘some degree’ mean? Either the social group is protected or not. If a social group and its neighbours are not protected, there will be many vaccinated badgers culled in the years to come.

There is no scientific or rational and moral evidence to justify the culling of any vaccinated badgers.

Question 6 – If so, to what degree, in what circumstances and subject to what conditions?

In particular –

(i) Should any such protection only be provided to badgers vaccinated in the Edge Area?

No.  Protection shouldn’t only be provided to badgers vaccinated in the Edge Area.

Vaccinated badgers in High Risk Areas should be given similar protection as those in the Edge Areas. Without this, the Government risks undermining its own commitment “to support badger vaccination in areas where there is a reservoir of infection in badgers but farmers have decided not to cull or have been unable to organised sufficiently to do so”.

With reference to the quote above, we question the use of ‘farmers’ rather than landowners. It is important to remind the Government that not all landowners are farmers.  Conservation groups hold significant areas of land (eg National Trust, Wildlife Trusts, RSPB, Woodland Trust, Butterfly Conservation,). There is land owned by local councils, small and large woodland owners, and re-wilding projects with a remit to conserve native species including badgers.  They may chose to vaccinate their badgers and some may use funds raised by the public to do so – so there is no reason why these badgers should not be fully protected.

(ii) Should protection be achieved by means of a no-cull zone?

In theory, no-cull zones are important to protect vaccinated badgers.  And would go some way to help mitigate the local eradication of the badger population. As experience shows, local populations of badgers have been eradicated in many key areas.  The combination of no-cull zones would help to ensure similar local eradications are not widespread throughout the southern half of the country – and any other hot spots where the evidence from Cumbria and West Susses show the lack of stringent trading measures in the cattle industry have caused local breakdowns in a few cattle herds.

However, putting the theory of no-cull zones into effective practice is a minefield (see response to 6 (iii) below)

(iii) If so, how should the size of the no-cull zone area be determined?

The size of the no-cull zone should be guided by science combined with ecology (ie the behaviour of badgers).  Setts are founded dotted around land holdings and are often on the edge of a holding rather than in the middle. So to protect vaccinated badgers, the size of no cull zones should be determined by sett location rather than the centre of a land holding.  Scientific evidence shows badger behaviour does not change when they are vaccinated. The opposite is true when badgers are culled (killed). In cull zones, their behaviour changes radically and they roam further – up to 39% on average, every night.

A recent study showed that “In the months of August-October, when most culling occurs, GPS-collared badgers stayed within 200m of their setts on just 1.9% of nights” so the area that would enclose badger ranging on 95% of nights during these months would cover land up to 1,081m from the sett.

This shows that the protection to vaccination badgers offered by the current Government proposal of a 200 metre buffer zone measured from the centre of a land holding would be negligible.

Evidence from the large badger vaccination site in the original West Somerset zone showed that cull operatives deliberately ignored the buffer zone on several occasions in order to target the vaccinated badgers. A much larger buffer zone would go a little way to ensure such transgressions by cull operatives are minimised.

Finally, ratification of the no-cull zones legally would enable police action to deter or stop criminal trespass by armed operatives  – otherwise the theory of no cull zones and protection of vaccinated badgers will never be put into practice.

(iv) Should eligibility for a no-cull zone be subject to meeting certain minimum criteria?

The Government’s proposal to use the criterion of ‘number (of badgers) vaccinated’ as eligibility for a no-cull zone is flawed.  There may be many land holdings that are too small to support multiple social groups of badgers yet, taken together, a series of well-established vaccination sites on small properties with large setts is likely to contribute to TB control over a much larger area than that covered by its licences.

If the Government licences culling between such sites, without buffers (if fewer than six badgers had been captured per site the previous year) this could undermine this existing control effort.

It is relevant to note here that if the purpose of these criteria is to encourage vaccination of larger areas, that purpose would be better addressed through the licensing of vaccination areas, rather than the associated no-cull buffers.

In addition, there is an inaccurate statement on p 7 #4.9.   According to Best Practice Guidelines, vaccinators only have two nights to trap badgers at their licences sites not as stated here “vaccination groups have several months in which to capture 70% of the badger population”.

(v) Should any such eligibility criteria include a condition as to the minimum size of a vaccination site?


As the evidence shows and as mentioned above, a series of well-established vaccination sites on small properties with large setts is likely to contribute to TB control over a much larger area than that covered by its licences.

One would expect that notes provided by Government to a public consultation would avoid any indications of confirmation bias.  However, at #4.10 p 7, there is a statement that includes the adjective ‘perverse’ that throws into question the theoretical neutrality of the notes.

In addition, there is no justification for the statement “no-cull zones that might provide a PERVERSE incentive for many small vaccination sites to be licensed purely to PREVENT or DISRUPT future culls’. Offending words that indicate confirmation bias are put in capitals. It is a sentence we would associate with a National Farmers Union (NFU) press release.

Question 7 – Do you have any comments on the proposed revisions to the Guidance (Annex A)? The new section header and other proposed revisions to the Guidance have been highlighted in yellow for ease of reference.

#4.1 and #4.2 would become irrelevant if buffers were delineated around setts rather than properties. This suggestion would also make the Government’s stated commitment to “move from widespread badger culling to wider deployment of vaccination” more practical and effective. Without this, the whole exercise undertaken here seems to be more of a tick-box exercise to ensure progress of a policy that depends on political expediency than science.

#4.3:  Our experience in Somerset and elsewhere in the country shows that unremitting and undue pressure is put on landowners that are either non-participants in the cull or, during the recruitment phase, hoping to be non-participants. If these landowners chose to vaccinate, it is completely unrealistic to expect them to negotiate a no-cull zone with their pro-cull neighbours. The policy has been shown to be divisive amongst families, communities and the larger neighbourhood.

We know of very few non-participating landowners particularly one that has chosen vaccination as a humane, scientific and moral alternative to culling that would be comfortable exposing themselves to a cull company. Maybe this unrealistic expectation imposed by the Government is a way to ensure the theory of no cull zones remains just that. A theoretical exercise that is never put into practice.

On p 8 #4.16 the Government claims that “The location of cull areas is not revealed on security grounds, and we consider there is no reason to change this position”. Yet, in court, this statement has been tested and the ruling made that Natural England had not produced enough evidence to justify its position.  Apart from wilfully misrepresenting the position in these notes, how can the Government expect a non-participating landowner to negotiate with his neighbour without the knowledge of whether the neighbour has signed up to cull or not?

Question 8 – Do you have any other comments?

The tone and misleading content of some of the notes accompanying the consultation document and the draft revised guidance imply a confirmation bias and affinity towards culling at the expense of vaccination.

To pick out a few key examples:

Consultation on badger vaccination/culling:

p 1 # 1.2 Bovine TB is recognised as “causing devastation and distress for hard-working farmers and rural communities” but despite record-breaking petitions, letters to MPs, and the alliance against badger culling from conservation and animal rights groups, the Government consistently refuses to recognise that badger culling also causes devastation and distress for hard-working members of the public and rural communises

p 1 #1.3 The document states that the Government is working towards “enhancing the environment and biodiversity” but the badger cull is an eradication of a native species on a scale not seen since the Victorian age.  In no way is it enhancing biodiversity.

p 3 #2.5 “The disease spreading from badgers to cattle is an important cause of herd breakdowns in high-incidence areas”. However, modelling data shows over 94% new breakdowns are the result of cattle-cattle transmission.  And Lord Krebs pointed out that the focus on badger-cattle transmission is crazy yet the Government focus, as this consultation shows, is still focused on badger-cattle transmission. The badger cull consistently is motived by political expediency to satisfy a few core voters rather than following a course that is backed up by considerable independent scientific principles

p 3 #2.6  “…. intensive culls are reducing the incidence of bTB in cattle’.  We understand that this ‘incidence rate’ is calculated by examining the number of new cases of TB in cattle herds. However, this approach, using “complex and sometimes obscure calculations” is wrong. Instead, the focus should be on the percentage of cattle herds in badger culling zones that have the disease at a specific point in time.

Examination of that data demonstrates no reduction in the prevalence of bTB (bovine TB) infected herds in Gloucestershire or Somerset as a result of culling.  The prevalence in cattle is no lower than it was before culling, despite the killing and removal of 1,879 badgers in Gloucestershire and 1,777 in Somerset. A total of 3,656 badgers have been killed with no perceivable disease control benefits.

p 9 #5.2  We would like to remind the Government that in its Value for Money Cost Benefit Analysis, the value of a badger was put at £0.00. Frankly, this is both unbelievable and shocking.

In addition, the calculations provided by the CBA relied on a cull that followed the methodology employed by the Randomised Badger Culling Trial (RBCT). This methodology has not been followed so it may make the CBA invalid.

Value for money will not be achieved by killing vaccinated badgers.

Finally, undermining the CBA is that the recommendations provided by the Independent Scientific Group at the conclusion of the RBCT have not been following. It could be effectively argued that the Government during its pursuit of the badger cull policy has thrown away the £50 million provided by the taxpayer for the RBCT.

This cost should, therefore, be included in any future CBA.

As a result, there is nothing about this Government’s badger cull policy that provides value for money for the taxpayer.

Draft Revised Guidance:

p 6 #11   The document includes the words “In order to ensure humaneness, only two methods of culling are licensed. One of those is ‘free-shooting’.

Yet the Government’s own Independent Expert Panel IIEP) ruled that this was inhumane and the British Veterinary Association withdrew support for free shooting in May 2015. However the Government has ignored this expert advice. Instead unknown numbers of badgers have been free-shot. At the same time, independent monitoring has been reduced to virtually nothing and cull operatives, instead, are expected to self-monitor themselves.  As the Government itself recognises, each time a badger is shot, the circumstances (wind, badger activity, local geography) is different so no shooter is able to guarantee a humane shot every time.  Using the IEP’s calculations, the number will be several thousand. In 2020, this is completely unacceptable and the Government should be clear and transparent about this.

p6 #12 “Defra considers that this approach is sufficient to be confident that culling will not be detrimental to the survival of the relevant population of badgers.”  What is the evidence for this statement?  There have been no recent independent population estimates within the West Somerset cull zone.  And, from our local experience, key populations have been eradicated.  We also know that with the increasing demonisation of badgers, few cull operatives and participating landowners will be concerned if local populations have been eradicated. Repeat this over the county and the present policy will indeed be ‘detrimental to the survival of the relevant population of badgers’. Repeat this policy over the whole country and the future of the national badger population will be undermined.

p 7 #14 d “Reasonable biosecurity measures are being, and for the duration of any licence will continue to be, implemented by participating farmers on their land.”  The evidence contradicts this wide-sweeping statement. In 2012, prior to licences being issued, some 10% of farms were visited in West Somerset & Glos. In 2014 and 2015, this was reduced to 5%. In 2016, 95% of farms were not visited to assess biosecurity measures in 5 out of 7 new cull zones prior to licences to cull badgers were implemented. Once again, lack of clarity and transparency obscures the situation on the ground but it’s suspected that less visits have been made in new cull zones since 2016 and it’s highly doubtful on-going visits to pre-existing cull zones have been made.

Once again, the focus seems to be on culling badgers rather than on ensuring ‘reasonable biosecurity measures’ are implemented.

Our final comment rests on the results published by the Government for year 2 of the cull in Cumbria (2019) , 313 badgers were killed and all were tested for M.bovis.  In March 2020, the Government published the results:

Only 3 badgers tested positive, 306 were negative, and four cultures were pending.

The number of badgers killed in Cumbria that were not carrying M bovis is staggering.

The strain of M bovis in Cumbria originates from Northern Ireland (cattle-cattle transmission) and trade in infected cattle created the problem in Cumbria. Badgers have paid the price, as elsewhere, for a problem created by the farming industry and Government.

To continue the relentless focus on the badger cull shows that this Government is not guided by science but political expediency. It is also morally reprehensible.