I've been a bit quiet on here recently due to a bout of illness, Christmas and a lot of badgery business to deal with. A very happy new year to all you good people. We've lots to accomplish together in 2023!
My new year motto is "keep swinging until you connect" and I'm flailing hard. Some of you may remember me taking on the Bovine TB "Engage" team at Defra last November and it finally chose to engage last Friday. My response is copied below and gives, I hope, a reasonably digestible synopsis of the situation in Hampshire. Badgers are being slaughtered here on the back of some guesswork and a farming bloodlust with virtually no scientific justification from any quarter. If anyone has any questions, comments or thoughts about what else we can be doing to expose, frustrate and end the cull then please share them!
Badger Trust is monitoring what we're doing in terms of the Hampshire cull with a lot of interest and January has already seen us connect with Hampshire & Isle of Wight Wildlife Trust's Director of Campaigns and Advocacy to try and enlist more support and publicity to push back against it. In the meantime, we've got other less aggravating work to do. More of that soon!
To:
SM-Defra-BTBengage (FFG)
Cc:
correspondence.section@defra.gov.uk;
email@ranil.uk
Tue 17/01/2023
Dear Defra TB Programme
Thank you for your email of 13th January in reply to mine dated 24th November 2022.
With regard to the ongoing APHA Southern Edge badger bTB project I'm sure that you've noted the results for Hampshire as at the end of December 2022 still reveal only 1 badger carcass submitted from the county border with Wiltshire has tested positive for bTB out of 79 tested from across the county and that the December 2022 bulletin now includes the words "recent further analysis of samples that were initially shown as potentially positive for TB indicate that several were in fact not the bacteria that causes bovine TB but other closely related mycobacteria". The project continues to highlight the lack of evidence of bTB reservoirs in Hampshire badger populations, and elsewhere, and it's a pity the eventual study findings will come too late to contribute towards the 2025 cessation of the badger cull already indicated by Defra, if that intention is to be believed.
Minimum/Maximum badger cull targets for Hampshire
Thank you for the link to the government advice to Natural England on the methodology for setting the minimum and maximum numbers of badgers to be slaughtered under license which I had already read. My question to you was about how the 2022 target cull numbers for Hampshire were determined and you haven't answered it.
The Defra advice to Natural England on the subject is clear that the minimum cull target number is intended to achieve a 70% reduction of the population relative to the initial starting population. The Hampshire cull target for 2021 (Area 56) was a minimum of 543 and a maximum of 737 animals and in total 578 badgers were slaughtered under license that year. The minimum target set of 543 suggests you believe the initial population of badgers in Area 56 at the start of the cull was some 775 and yet a maximum target of 737 was set which, if achieved, would have reduced the population by 95% rather than the 70% you say you were targeting. Please explain the logic of this and why you believe the initial population figure in Area 56 was 775. If you're not able to do so, please put me in touch with the individual at Natural England who can.
The Hampshire cull target for 2022 included Area 56 and a new location referred to as Area 67. The Area 56 target in 2022 was a minimum of 651 badgers and a maximum of 1,026. It's clear that based on 578 badgers being slaughtered in Area 56 in 2021, and at least 651 killed in 2022 (the 2022 actual cull numbers not yet having been made available) that at least 1,229 Area 56 badgers have been slaughtered, and potentially as many as 1,604, out of a total population initially believed by Defra to number only 775. This simply doesn't make any sense and suggests the Area 56 target cull numbers are being determined arbitrarily.
The 2022 cull target numbers for the new Area 67 site were for a minimum of 413 badgers to be killed and a maximum of 560. Again, using your own methodology, this suggests Defra and its agencies believe the total badger population in Area 67 to initially have been 590 and that you are comfortable with the possibility that 95% of this population may have been slaughtered in 2022. Please confirm or, again, refer me to the person at Natural England who can.
You have not explained how the 2022 cull target numbers for Hampshire were determined, by whom and on what basis. Badgers are a protected species and the approach to their culling in this county appears, at best, to be haphazard and, at worst, to be legally questionable.
Licensing
I have not raised any questions regarding the licensing of culling operations but note that any questions that arise in future should be addressed to Natural England. We are, as a group, already aware of the addresses from which cull operations in the county are being directed. They include a location owned by the Minister at Defra responsible for the bTB and badger cull policy area and I have already written to him regarding this clear conflict of interest.
Epidemiology - "Downs" report
Thank you for the link to the May 2021 "Detection of a local Mycobacterium bovis reservoir using cattle surveillance data" report dated May 19th 2021 (the "Downs" report). I note the 2021 badger cull targets for Hampshire were determined prior to this report being published.
The aim of the report was to identify badger associated M. bovis reservoirs in the Edge Area, between the High and Low Risk Areas, for cattle TB. The Edge Area includes Hampshire and 10 other counties and the report is not exclusive to Hampshire. The authors are keen to emphasise that "badger TB surveys were sparse" and that consequently "a definition for a local M. bovis reservoir potentially shared by cattle and badgers was developed using cattle TB surveillance data". The report, whilst acknowledging cattle to be a reservoir for M. bovis, provides no clear evidence of M. bovis reservoirs in Hampshire badger populations. It states that "TB confirmed by post-mortem tests has been detected in badgers from the Edge Area" (11 counties of which Hampshire is only one). A more accurate statement would be "TB confirmed by post-mortem tests has been detected in badgers from some counties in the Edge Area". Figure 1 on page 32 of the report ("Badger density in the Edge Area and locations of samples from badgers with TB confirmed by post-mortem tests or no confirmed TB detected in different opportunistic surveys") reveals there were no badgers in Hampshire with confirmed TB when the report was produced. As such it offers no evidence of confirmed M. bovis reservoirs in Hampshire badgers.
Epidemiology - APHA 2021 Bovine TB report (Hampshire)
As you point out the 2021 APHA Year-End Descriptive Epidemiology Report: Bovine TB in the Edge Area of England (Hampshire) was published by Defra on 27th November 2022, three days after I contacted you asking after its whereabouts. It is county specific and I have read it carefully to understand how Defra/Natural England determined it necessary to increase the Hampshire badger cull targets from the (highly questionable) minimum 543/maximum 737 in 2021 to a minimum of 1,064/maximum of 1,586 in 2022.
The report contains no epidemiological justification for the 115% increase in the cull target compared to 2021. It repeats the revelation made in the 2020 report for the county that M. bovis was detected in a domestic cat that year, states that the annual incidence rate of bTB in cattle herds in 2021 was the lowest reported in Hampshire since 2015 and that Hampshire had the lowest incidence rate of TB out of the 11 Edge Area counties in 2021. Indeed, the annual incidence rate was lower than in the "Low Risk Area" counties of Bedfordshire and Lincolnshire.
The APHA 2021 report for Hampshire could not be clearer in stating "Movements of undetected infected cattle remained the biggest driver for new incidents. They provided a weighted contribution of approximately 47% of all weighted risk pathways. The closest livestock market to Hampshire is Salisbury in the HRA, therefore many cattle purchased from this market will have originated from herds in the HRA. All purchased cattle contributing to OTF-W incidents originated from the HRA or Edge Area, despite the mitigating requirement to pre-movement test".
The report goes on to say "The second most common source attribution was residual infection, contributing to 19% of weighted risk pathways. Badgers accounted for 11% of weighted risk pathways".
It is important to recognise that the methodology to determine these weightings is based on known or suspected sources of M. bovis infection with each TB incident having up to 3 potential risk pathways identified. Each risk pathway is given a score that reflects the likelihood of that pathway bringing TB into the herd. The score is recorded as either "definite" (score 8), "most likely" (score 6), "likely" (score 4) or "possible" (score 2) as determined by APHA veterinary investigation to identify the source of the infection.
Cattle movement was identified as the "most likely" source in 7 infection incidents. Residual cattle infection was identified as the "most likely" source in 3 infection incidents. Badgers were identified as the "most likely" source in 0 infection incidents. In fact, badgers were regarded as the "likely" source in only 2 incidents and the "possible" source" in another 7.
There is no confirmed evidence of bTB in Hampshire badger populations in either the Downs report of 2021, the APHA Bovine TB in Hampshire report for 2020 or the same report for 2021. You yourselves have already confirmed the APHA RTA project findings (1/79 Hampshire carcasses testing positive for bTB to date) have not been considered when setting the cull targets for the county.
Please confirm the basis of your/Natural England's understanding of the initial Area 56 and Area 67 badger populations in 2021 and 2022 respectively.
Please advise me who determined that up to 95% of those populations (according to your own methodologies) could be exterminated in 2020/2021 and on what basis.
Please disclose the epidemiological rationale on which the 115% increase in the Hampshire badger cull target from 2021 to 2022 was based.
Please let me know when we can expect to see publication of the actual number of badgers slaughtered under license in 2022 in Hampshire.
There is no compelling justification for the culling of badgers in Hampshire. The epidemiology supporting the cull here is weak and based entirely on supposition. The bTB problem in the county is one of poor herd management and biosecurity practices compounded by an absence of mandatory bTB protocols. It is tragic that in the 12 months to June 2022, 175 cows in Hampshire were slaughtered as a result of bTB infection. It's unacceptable on any level that 578 badgers were shot under license here in the same period and that an even greater number have been culled during the Autumn of 2022. I have copied this email to both Richard Benyon at Defra from whom I am still awaiting replies to the substantive points raised in a letter to Ranil Jayawardena MP last September and to a letter I sent directly to Lord Benyon on 1st December (reference MC2022/18284/JD). I have also included Mr. Jayawardena as a recipient for the sake of completeness. Regards, Nick Cole Chair North East Hampshire Badger Group www.northeasthampshirebadgergroup.com
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