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"Sub-optimal".

Asking the UK Chief Veterinary Officer what's "sub-optimal" about ending the slaughter of healthy badgers in a county with the lowest "weighted proportion of source infection" in the cull zones and lower than some in the "low risk area" where no culling has ever taken place.


To: christine.middlemiss@defra.gov.uk

cc: btbengageteam@defra.gov.uk, correspndence.section@defra.gov.uk, email@ranil.uk


14/04/2023


Dear Dr. Middlemiss,


Last week's 2022 badger cull disclosures from Defra informed us that at least 768 badgers were slaughtered in Hampshire's two cull zones during the Autumn of 2022, adding to the 578 that were killed in 2021. I say "at least" because Defra has confirmed that only 122 monitored observations of badger culling took place in England during 2022, despite 33,627 animals being killed last year, and noted that 6.6% of those 122 attempts resulted in the target being "missed but not-retrieved". On a kill number of 33,627, that suggests over a further 2,200 badgers may have died of their wounds across England than the official numbers given, and over 50 in Hampshire.


You'll know the official badger cull figures for Hampshire, or should do, but I'm outlining them here for the sake of anyone else reading this correspondence.


Area 56 (land to the west, north and east of Basingstoke)

2021 badger cull number - 578

2022 badger cull number - 253

Total badgers shot - 831


Area 67 (including part of the New Forest National Park)

2022 badger cull number - 515


Total number of badgers killed under license in Hampshire to date - 1,346


On the 5th of this month, Defra published the following statement attributable to you. I've quoted it verbatim so please let me know if it's in any way inaccurate.


"In May 2021, the government issued a response to the bovine tuberculosis (bTB) consultation. This set out provision for the UK Chief Veterinary Officer (CVO) to recommend early termination for intensive cull licenses issued in 2021 and 2022 after 2 or 3 years.


Cull Areas 55 to 61 inclusive began culling in September 2021, and all of them completed their second cull in late 2022. These areas are therefore eligible for consideration of early termination.


On review of the available data for these 7 areas, my view is that early termination would be sub-optimal for disease control. Therefore, my advice is not to terminate any of those culls this year."


As a Hampshire resident and founder of a badger protection and welfare monitoring group in the county, I've reviewed all of the available data in the public domain for Hampshire and am interested to learn what data you reviewed that led you to the above conclusion in relation to Area 56.


The data contained in both the Animal Plant & Health Agency (APHA) 2020 and 2021 Year-End Descriptive Epidemiology reports for Hampshire contain no evidence of a single badger in the county testing positive for bovine TB (although a domestic cat here was found with the disease in 2020 with the infection source traced back to raw pet food). Furthermore, neither report contains any confirmed evidence of bovine TB reservoirs in Hampshire badger populations or any cases of badgers as a source of cattle herd infections here. According to the 2021 report, the largest "weighted proportion of source infection" derived from Disease Report Forms completed that year was cattle movements and the "weighted proportion" attributable to badgers in Hampshire, just 10.9%, was lower than two of the counties in the Low Risk Area where no culling has ever taken place.


The "APHA Bovine Tuberculosis in England in 2021 - Epidemiological analysis of the 2021 data and historical trends, November 2022" report is even more revealing and shows the Hampshire 10.9% "weighted proportion" attributable to badgers to be the lowest of ALL cull counties in the High Risk or Edge areas and comparable to the 10.3% figure for the overall Low Risk Area. It's also substantially lower than the 52.1% figure for the overall Edge Area and the 52.1% figure for the overall High Risk Area. The same report also reveals that Hampshire is not considered by the APHA to be a homerange for genotypes B3-11, B6-11 or b8-85 of M. bovis.


In addition to the above, the Defra commissioned "Detection of a local Mycobacterium bovis reservoir using cattle surveillance data" report dated 19th May 2021 (the "Downs et al" report) aimed to identify badger associated M. bovis reservoirs in the Edge Area (including Hampshire) yet failed to find a single case of a bovine TB infected badger in the county. Figure 1 on page 32 of that report reveals very clearly that no badgers in Hampshire had ever tested positive for bovine TB prior to it being peer-reviewed and published in 2021. Both Lord Benyon of Englefield, Minister at Defra responsible for the bovine TB and badger cull policy area, and Mark Spencer MP, Minister at Defra are acutely aware of this fact. They have each recently responded to questions submitted in Parliament about the Hampshire badger cull, and the lack of epidemiology justifying it, by pointing to the ongoing "Southern Edge bTB" project being conducted by the APHA. This is, as you know, a two year project running from April 2021 to the end of this month under which roadkill badgers are being submitted for bovine TB testing from the most southern Edge Area counties, including Hampshire.


Presumably, neither Lord Benyon or Mr Spencer are aware of this project's findings to date when it comes to Hampshire. The results so far are telling and re-affirm that there's no justification for culling badgers in Hampshire as a control measure for the spread of bovine TB to cattle. According to the latest "Southern Edge" project bulletin as of the end of March, distributed by the APHA earlier this week, 85 viable badger carcasses have been submitted for testing from Hampshire since April 2021. Only 1 has tested positive for bovine TB although the APHA emphasises that "further analysis of samples that were originally showing as potentially positive for TB were in fact not the bacteria that causes bovine TB but other closely related mycobacterium". The APHA goes on to emphasise "the importance of treating initial results as potentially indicative only, as final confirmation will only be possible at the end of the project". The APHA also helpfully shows the location from which the carcass in question was submitted as being right on the county border with Wiltshire.


In light of all the above, will you please reconsider your decision not to terminate the Area 56 badger cull immediately? If not, please help me understand what data you have reviewed that justifies the continuation of the cull here and why such data is not in the public domain?


I look forward to hearing from you as a matter of urgency.


Yours sincerely,


Nick Cole

Chair

North East Hampshire Badger Group




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