The Badger Trust welcomes challenge to the Government’s Chief Veterinary Officer from vets with bTB expertise
The Badger Trust has welcomed a challenge to the Government’s Chief Veterinary Officer, Christine Middlemiss, on the presentation of facts relating to the perceived role of badgers in the transmission of bovine TB (bTB) to cattle, the basis of fact on which decisions are being made, and the indicated future direction of the Government’s strategy for controlling the spread of bTB.
A group of seven vets with extensive knowledge and experience in the field have written to the CVO following a series of concerning statements and factual presentations, asking for a response on several related points. The group includes Dr Iain McGill, a former government scientist who blew the whistle on the BSE cover-up in the 1990s, as well as Professor Ranald Munro, Chairman of Independent Expert Panel on the Pilot Badger Culls, and vets from leading animal welfare groups and/or with specialisms in the subject.
The letter concluded:
‘We are sure you would agree that the badger cull is an unprecedented assault on a protected wild mammal species that should not be undertaken lightly, and certainly not without due regard for the very latest scientific data, in addition to animal welfare and ethical concerns… We would welcome the opportunity to discuss these issues with you as a matter of urgency, in order to give you an opportunity to clarify the apparent inconsistencies in your statements and advice to government.’
Jo Bates-Keegan, Chair of Badger Trust, commented: ‘We welcome this challenge from experts within the veterinary field, as it supports our ongoing concerns. In particular on the ‘risk pathways’ as repeatedly stated by the Government, a key rationale stated as a basis for culling badgers. These in our view are entirely subjective and non-scientific, tick-box exercises in determining the potential cause of a herd breakdown.’
‘Essentially if no clear cause for bTB in the relevant cattle herd is found, it is put down to ‘badgers’ if badgers are present at a farm. This approach is at odds with the recently released ‘Badgers Found Dead Study’ which showed very low levels of the disease in badgers. This report, despite being completed two years ago at the cost of almost half a million GBP, was quietly released on a slow news day. The Government are all over the place, not just on their continued rationale for the cull, but the conflicting statements, facts and continued unashamed roll-out of it.’
Background:
In September 2020, DEFRA announced the continuation and expansion of the badger cull across England. 11 new cull zones were confirmed, in addition to the existing 43 areas covered by a four-year licence. Over 62,000 badgers are scheduled for death in 2020 alone, meaning between 2013 and 2020 the total number of badgers killed as a result of the cull could reach over 164,000.
Whilst Badger Trust believes culling has now finished for 2020 in the areas licensed for four years, the supplementary areas are believed to be continuing until January. Actual figures for badgers killed during the 2020 cull will not be released until early 2021. By the end of 2020 we estimate the cost of the cull policy will reach £70 million, with every taxpayer in the UK having no choice but to fund this budget, even at a time of crisis for the economic outlook for the country, given the ongoing pandemic situation.
Further information:
Read the full letter below:
At the time of writing the letter had been acknowledged but not officially responded to.
Dr Iain McGill, part of the vets group involved in the letter, can be reached for comment via Badger Trust. Please contact us at staff@badgertrust.org.uk for more information.
This is the full letter from the vets to Christine Middlemiss, Chief Verterinary Officer.
Professor Christine Middlemiss MRCVS
Chief Veterinary Officer
Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR 3rd November 2020
Dear Professor Middlemiss
Badger culling policy in England
We are writing to express our concerns relating to statements you made on the BBC’s Farming
Today programme on Radio 4 on 9th September 2020, in defence of the issuing of 11 new badger
control licences in England. We are also concerned by the differing statements you made to the
High Court earlier in 2020. We would welcome your professional opinion on the Disease Report
Forms used as risk pathway questionnaires – data from which are being presented as fact in
bTB epidemiology reports.
The “phasing out” of badger culling
You stated in the Farming Today interview that:
“We are planning and working on moving away from supplementary badger culling once intensive
cull areas are completed, to vaccination.”
The Government response1 to the Godfray review did not indicate that badger vaccination
would only be considered as an alternative to supplementary badger culling. It is also in direct
contrast with the actuality of continuing to license supplementary culling in all seven cull zones
which had completed four years of culling under their original licences in 2019 (areas 4-10
inclusive). Perhaps you would be kind enough to explain this apparent fluidity of policy?
Contrasting assertions regarding Whole Genome Sequencing (WGS)
When asked about the rationale of licencing two new cull zones in the LRA, you stated to
Farming Today:
“…because we had conclusive evidence that badgers are involved in the spread of infection in those
areas. Through whole genome sequencing which is a fantastic tool we can look at the gene
sequence of the bacteria both in cattle and badgers and see that there is infection spread between
the two. We know there is infection in the badgers there and we want to be able to control it.”
We are unconvinced by this statement. For example, out of 313 badgers killed in Cumbria (LRA)
in 2019, only 3 were positive for the bTB spoligotype responsible for the outbreak in cattle
(17:z)2, which resulted from importing infected but ineffectively screened cattle from Northern
Ireland. In relation to whole genome sequencing (WGS), a Government report published in
September 2020 states that in Cumbria2 “The presence of shared sequences across the two species
provides more evidence that possible cattle-badger and/or badger-cattle transmission has
occurred in the area. However, direction of transmission cannot currently be inferred from this
data.”
We would request sight of the ‘conclusive evidence’ you cited, demonstrating that badgers are
involved in the spread of infection in the LRA.
Conflicting statements to the High Court regarding the Derbyshire cull zone
According to High Court documents published in May 2020 (High Court Judgement
13/05/20 Case No: CO/4817/2019), in late August 2019 you ‘positively endorsed proactive
badger culling in the Lunar area in Derbyshire as “the best available option” ’. Soon afterwards,
this advice was reversed, ostensibly at the Prime Minister’s behest. In your evidence you stated
that shortly after your initial advice to allow culling to proceed, you then suggested that culling
should only be licensed in the High Risk Area, and not in Edge areas such as Derbyshire. You
acknowledged that this represented a departure from the views you had expressed
previously. As of September 2020 your advice appears to have changed yet again, such that
culling in Derbyshire has been given your approval.
Two studies on found-dead badgers completed in 2018 have only just been published3. In the
Southern Edge area the overall prevalence of MTB complex infection in badgers was under 1%3.
In the Northern Edge area there was not only a low prevalence of MTB complex infection found,
but of these 92% were latent and therefore unlikely to be infectious. Malcolm Bennett,
responsible for the northern Edge survey is on record4 as stating that “…there is no evident
support of badgers driving the cattle epidemic in Derbyshire or Nottinghamshire in the period
when we were doing the testing”.
Were you not aware of Professor Bennett’s findings and conclusions in this regard? If you were
aware of this, we can understand why you might have withdrawn your support for culling in
Derbyshire in 2019, but why did you then go on to authorise culling in 2020?
Given the above inconsistencies, we are extremely concerned that your statements may have
misled the public, the farming industry and members of the veterinary profession and threaten
to undermine confidence in the independence of the Chief Veterinary Officer’s advice to
government.
Furthermore, we note the use of pie charts in APHA’s epidemiology reports based on risk
pathway questionnaires (Disease Risk Forms) completed by the attending vet. These ascribe an
astoundingly high percentage of breakdowns as being due to badgers – a great deal more than
any of the published epidemiological studies would indicate. These DRF pie charts are being
quoted as if they represented fact by multiple authors to incriminate badgers as the source of
the overwhelming majority of herd breakdowns. Given that the Government response to Godray
describes these forms as being in need of replacement (and thus not fit for purpose), are you
happy that the current robustness of this analysis is sufficient to warrant inclusion of these pie
charts in epidemiology reports as factual evidence?
We are sure you would agree that the badger cull is an unprecedented assault on a protected
wild mammal species that should not be undertaken lightly, and certainly not without due
regard for the very latest scientific data, in addition to animal welfare and ethical concerns.
We would welcome the opportunity to discuss these issues with you as a matter of urgency, in
order to give you an opportunity to clarify the apparent inconsistencies in your statements and
advice to government.
Yours sincerely
Dr Mark Jones, Veterinary Surgeon, BVSc MSc (Stir) MSc (UL) MRCVS
Head of Policy, Born Free Foundation
Dr Iain McGill, Veterinary Surgeon, BSc (Hons) BVetMed MRCVS
Director, Prion Group
Professor Ranald Munro, BVMS MSc DVM MRCVS
Chairman of the Independent Expert Panel on the Pilot Badger Culls
Professor Andrew Knight, MANZCVS, DipECAWBM (AWSEL), DipACAW, PhD, FRCVS,
PFHEA, University of Winchester, European & RCVS Veterinary Specialist in Animal Welfare
Science, Ethics and Law
Richard Saunders BSc (Hons) BVSc FRSB CBiol DZooMed (Mammalian) DipECZM(ZHM)
MRCVS, RCVS Specialist in Zoo and Wildlife Medicine
(Mammalian), European Specialist in Zoological Medicine (ZHM)
Dr Andre Menache, BSc(Hons) BVSc Dip ECAWBM (AWSEL) MRCVS
European Veterinary Specialist in Animal Welfare Science, Ethics and Law
Professor Alastair MacMillan, BVSc MSc PhD FRCPath MRCVS
Veterinary Advisor, Humane Society International/UK
References
1. https://www.gov.uk/government/publications/a-strategy-for-achieving-bovinetuberculosis-
free-status-for-england-2018-review-government-response
2. Defra (2020) TB surveillance in badgers during year 2 badger control operations in eastern
Cumbria, Low Risk Area.
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_da
ta/file/914655/tb-surveillance-in-wildlife-sept2020.pdf
3.http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None
&ProjectID=19579&FromSearch=Y&Publisher=1&SearchText=se3054&SortString=ProjectCode
&SortOrder=Asc&Paging=10#Description
4. https://www.youtube.com/watch?v=BfXkrSI9lE0&t=3414s
Department for Environment, Food and Rural Affairs
Nobel House
17 Smith Square
London SW1P 3JR 3rd November 2020
Dear Professor Middlemiss
Badger culling policy in England
We are writing to express our concerns relating to statements you made on the BBC’s Farming
Today programme on Radio 4 on 9th September 2020, in defence of the issuing of 11 new badger
control licences in England. We are also concerned by the differing statements you made to the
High Court earlier in 2020. We would welcome your professional opinion on the Disease Report
Forms used as risk pathway questionnaires – data from which are being presented as fact in
bTB epidemiology reports.
The “phasing out” of badger culling
You stated in the Farming Today interview that:
“We are planning and working on moving away from supplementary badger culling once intensive
cull areas are completed, to vaccination.”
The Government response1 to the Godfray review did not indicate that badger vaccination
would only be considered as an alternative to supplementary badger culling. It is also in direct
contrast with the actuality of continuing to license supplementary culling in all seven cull zones
which had completed four years of culling under their original licences in 2019 (areas 4-10
inclusive). Perhaps you would be kind enough to explain this apparent fluidity of policy?
Contrasting assertions regarding Whole Genome Sequencing (WGS)
When asked about the rationale of licencing two new cull zones in the LRA, you stated to
Farming Today:
“…because we had conclusive evidence that badgers are involved in the spread of infection in those
areas. Through whole genome sequencing which is a fantastic tool we can look at the gene
sequence of the bacteria both in cattle and badgers and see that there is infection spread between
the two. We know there is infection in the badgers there and we want to be able to control it.”
We are unconvinced by this statement. For example, out of 313 badgers killed in Cumbria (LRA)
in 2019, only 3 were positive for the bTB spoligotype responsible for the outbreak in cattle
(17:z)2, which resulted from importing infected but ineffectively screened cattle from Northern
Ireland. In relation to whole genome sequencing (WGS), a Government report published in
September 2020 states that in Cumbria2 “The presence of shared sequences across the two species
provides more evidence that possible cattle-badger and/or badger-cattle transmission has
occurred in the area. However, direction of transmission cannot currently be inferred from this
data.”
We would request sight of the ‘conclusive evidence’ you cited, demonstrating that badgers are
involved in the spread of infection in the LRA.
Conflicting statements to the High Court regarding the Derbyshire cull zone
According to High Court documents published in May 2020 (High Court Judgement
13/05/20 Case No: CO/4817/2019), in late August 2019 you ‘positively endorsed proactive
badger culling in the Lunar area in Derbyshire as “the best available option” ’. Soon afterwards,
this advice was reversed, ostensibly at the Prime Minister’s behest. In your evidence you stated
that shortly after your initial advice to allow culling to proceed, you then suggested that culling
should only be licensed in the High Risk Area, and not in Edge areas such as Derbyshire. You
acknowledged that this represented a departure from the views you had expressed
previously. As of September 2020 your advice appears to have changed yet again, such that
culling in Derbyshire has been given your approval.
Two studies on found-dead badgers completed in 2018 have only just been published3. In the
Southern Edge area the overall prevalence of MTB complex infection in badgers was under 1%3.
In the Northern Edge area there was not only a low prevalence of MTB complex infection found,
but of these 92% were latent and therefore unlikely to be infectious. Malcolm Bennett,
responsible for the northern Edge survey is on record4 as stating that “…there is no evident
support of badgers driving the cattle epidemic in Derbyshire or Nottinghamshire in the period
when we were doing the testing”.
Were you not aware of Professor Bennett’s findings and conclusions in this regard? If you were
aware of this, we can understand why you might have withdrawn your support for culling in
Derbyshire in 2019, but why did you then go on to authorise culling in 2020?
Given the above inconsistencies, we are extremely concerned that your statements may have
misled the public, the farming industry and members of the veterinary profession and threaten
to undermine confidence in the independence of the Chief Veterinary Officer’s advice to
government.
Furthermore, we note the use of pie charts in APHA’s epidemiology reports based on risk
pathway questionnaires (Disease Risk Forms) completed by the attending vet. These ascribe an
astoundingly high percentage of breakdowns as being due to badgers – a great deal more than
any of the published epidemiological studies would indicate. These DRF pie charts are being
quoted as if they represented fact by multiple authors to incriminate badgers as the source of
the overwhelming majority of herd breakdowns. Given that the Government response to Godray
describes these forms as being in need of replacement (and thus not fit for purpose), are you
happy that the current robustness of this analysis is sufficient to warrant inclusion of these pie
charts in epidemiology reports as factual evidence?
We are sure you would agree that the badger cull is an unprecedented assault on a protected
wild mammal species that should not be undertaken lightly, and certainly not without due
regard for the very latest scientific data, in addition to animal welfare and ethical concerns.
We would welcome the opportunity to discuss these issues with you as a matter of urgency, in
order to give you an opportunity to clarify the apparent inconsistencies in your statements and
advice to government.
Yours sincerely
Dr Mark Jones, Veterinary Surgeon, BVSc MSc (Stir) MSc (UL) MRCVS
Head of Policy, Born Free Foundation
Dr Iain McGill, Veterinary Surgeon, BSc (Hons) BVetMed MRCVS
Director, Prion Group
Professor Ranald Munro, BVMS MSc DVM MRCVS
Chairman of the Independent Expert Panel on the Pilot Badger Culls
Professor Andrew Knight, MANZCVS, DipECAWBM (AWSEL), DipACAW, PhD, FRCVS,
PFHEA, University of Winchester, European & RCVS Veterinary Specialist in Animal Welfare
Science, Ethics and Law
Richard Saunders BSc (Hons) BVSc FRSB CBiol DZooMed (Mammalian) DipECZM(ZHM)
MRCVS, RCVS Specialist in Zoo and Wildlife Medicine
(Mammalian), European Specialist in Zoological Medicine (ZHM)
Dr Andre Menache, BSc(Hons) BVSc Dip ECAWBM (AWSEL) MRCVS
European Veterinary Specialist in Animal Welfare Science, Ethics and Law
Professor Alastair MacMillan, BVSc MSc PhD FRCPath MRCVS
Veterinary Advisor, Humane Society International/UK
References
1. https://www.gov.uk/government/publications/a-strategy-for-achieving-bovinetuberculosis-
free-status-for-england-2018-review-government-response
2. Defra (2020) TB surveillance in badgers during year 2 badger control operations in eastern
Cumbria, Low Risk Area.
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_da
ta/file/914655/tb-surveillance-in-wildlife-sept2020.pdf
3.http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None
&ProjectID=19579&FromSearch=Y&Publisher=1&SearchText=se3054&SortString=ProjectCode
&SortOrder=Asc&Paging=10#Description
4. https://www.youtube.com/watch?v=BfXkrSI9lE0&t=3414s
