Badger Trust's Full Submission Letter to the Godfray Review

Dear Professor Godfray,

Subject: Bovine TB Strategy Review 2025 Update

I am writing on behalf of Badger Trust to submit evidence for your 2025 Bovine TB strategy review update. In doing so, we recognise that although you are leading the review, its terms of reference and publication of any of your conclusions may not be within your control. We would be grateful for clarification on both points.

We have avoided offering any policy advocacy, following the guidance on the TB Hub website, and below set out why we are offering the evidence enclosed, and listed.

Badger Trust expects that any measures introduced by the Government to tackle bovine TB in cattle are legal, have a clearly attributable and material effect, are sustainable, humane, based on solid scientific evidence, and are publicly acceptable.

We oppose the badger cull policy because it fails to meet these criteria, even on the Government's own internal assessments, if not its press office communications.

Aside from the RBCT, none of the studies of which we are aware have studied badger culling in isolation from the raft of cattle measures (e.g. more frequent testing with much more sensitive tests, intelligent movement controls, ‘social distancing’ of animals from different herds and those bought in, etc.). All of these studies are open about the inability of their analyses to differentiate the effects of cattle measures from concurrent badger culling on any observed changes to bTB rates in cattle.

None of the studies of which we are aware themselves claim to show that badger culling causes a fall in bTB rates in cattle. Yet farmers and the public can be forgiven for thinking otherwise because press announcements, Ministerial statements, and industry commentary informed by DEFRA reportage seem to claim that badger culling ‘works’ despite the evidence.

We therefore welcome this Government's commitment to end culling, albeit after over 230,000 badgers have been legally shot (figures to the end of January 2024).

British wildlife has been failed by the ‘all the tools in the box’ approach which rather misses the point: it’s the use of the right tools, those proven to be most effective, which reliably solve problems. We hope that your 2025 review brings us to that position.

When any Government claims any policy has ‘worked’ it’s always worth asking what criteria that success is based on, and how it’s measured.

It has long been a frustration of Badger Trust that reductions in bTB in cattle have never been a criterion by which the badger cull was to be judged a ‘success’.

Lots of other measures get cited annually - sufficient land available for culling, sufficient time spent shooting, no one getting injured, and cull contractors meeting their kill targets (despite kill targets increasingly and repeatedly being failed). But not reductions in bTB in cattle. An FOI (enclosed) querying the basis on which a former Secretary of State had claimed the cull to be a success was responded to by these answers. It is unknown whether the SOfS concerned was aware of the very narrow nature of the definition, or that it had nothing to do with bTB rates in cattle.

In around 2011/2012, cutting the annual cost of cattle compensation was cited by DEFRA as a criterion. Yet that measure has remained remarkably stable along with the proportion of English cattle prematurely slaughtered as a result of bTB barely moving in all these years. When compensation costs as a result of slaughter rates did increase to a peak over three years, a query from the National Audit Office to DEFRA found it was the result of DEFRA temporarily employing the more sensitive cattle bTB test Interferon Gamma Release Assay (IGRA) (as used widely in Wales) which revealed more cases of bTB. DEFRA stressed that these were not additional cases of disease, merely that it was diagnosing more of the existing reservoir. We enclose the evidence from DEFRA and the correspondence with the National Audit Office in our submission. DEFRA reverted to using SICCT without supplementary Interferon Gamma Release Assay (IGFA) testing at the same levels subsequently.

The first rule of any Government policy should be that it should have clearly articulated objectives and that those objectives should be met. Ideally, there should be oversight that those objectives are being met. It appears to us that significant Government effort has been invested in making it look as though badger culling has had the effect of slashing bTB in cattle, without the evidence to substantiate the case. Trust in Government policy - and democracy - depends on honesty.

This ought to be where evidence is central to policy making and transparency in policy making and its evaluation. We look forward to learning that your latest review has been able to play its full part in this.

The new national bTB strategy must take a holistic approach grounded in rigorous scientific evidence for a swift, successful, and permanent shift away from culling.

Lethal control of wildlife for a disease that is almost always transmitted between livestock can never be the answer. Whether that’s avian flu or bTB.

There are two studies each of which evidence the vast majority of bTB cases arise as a result of cattle-to-cattle infection.

The most recent Microbiology Society from 2023, Genomic Epidemiology of Mycobacterium bovis infection in sympatric badger and cattle populations in Northern Ireland Assel uses evidence from whole genome sequencing at 95% its findings are remarkably consistent with that from Donnelly et al ten years earlier which established that 94% of bTB cases arise from cattle to cattle infection.

Killing Britain's dwindling native wildlife rather than controlling infection among the affected livestock is barbaric, outdated, and crucially, ineffective. We are therefore pleased that this still new Government has commissioned an independent expert assessment of recent evidence and the totality of evidence to date.

Your review is the first opportunity to review the sum of the evidence as well as examine vital new evidence. In particular, we hope that seven years on from your last review, you will make use of the evidence highlighting the existence and possible or likely extent of residual hidden bTB in cattle arising from poor testing policy over many years. Leaving bTB hidden in the herd - hidden from farmers, leaving them helpless - only stokes future infection and disease outbreaks, condemning farmers to recurrent breakdowns and increasing despair. bTB needs no help getting into cattle herds when it’s knowingly left behind by cattle testing policy in England.

When Badger Trust submitted an FOI to DEFRA to ask why the (previous) Government had chosen to use a test which according to DEFRA left 20% of infected animals undetected, the Department holding response was to advise more time was needed in which to reply because the answer was “commercially sensitive”. Its final answer was that the decision was made following a public consultation in 2018.

The RSPCA, however, found that a majority of vets and a smaller majority of farmers wanted access to better cattle testing. We are yet to be convinced that leaving bTB hidden and undisclosed in the national herd is wise - commercially or ethically. When it leads to repeated herd outbreaks and calls for wildlife to be killed, it is wholly unacceptable. If DEFRA doubts this, perhaps it could run a further public consultation on the matter, Badger Trust would be happy to assist.

Therefore our interest in transparency is as much for the best interests of farmers and their livelihoods, as it is for the wider public interest and the future of all protected species that might find themselves targeted because of failures in Government policy on livestock health.

The old notion that allowing people to kill wildlife legally reduces illegal killing is now very questionable, particularly in the developed world the Royal Society paper ‘Blood does not buy goodwill’ - “

Now that we do know better, we believe that public (and industry) confidence in future Government policy can and must be underpinned by your review.

We believe your review must take this opportunity to cut through the emerging kill badgers / vaccinate badgers debate and update Ministerial and industry understanding, making clear what the evidence can now tell us about the success of cattle-control measures and the singular importance of cattle-to-cattle transmission.

Badger Trust has been urged to support widespread badger vaccination (our website carries our policy statement) but after much thought, we have declined to do so.

As badger culling hasn’t been shown to have any meaningful effect on bTB rates in cattle, there is no logical reason why badger vaccination should either.

Vaccinating badgers is great for protecting badgers against cattle-borne bTB.

That’s how it is used in Wales, keeping badgers healthy in the face of disease introduced by cattle movements. (Other wildlife and nonbovine livestock remain at risk of bTB from infected cattle, however.) But beyond protecting badgers from cattle disease, and in past years when farmers desperate not to cull their badgers wanted any alternative and our groups were happy to help, Badger Trust doesn’t support widespread badger vaccination.

We now believe that supporting a national badger vaccination scheme would just continue to scapegoat badgers and prolong calls for culling, during and after the term of the present Government.

Lots of people have tried to persuade us otherwise, not least DEFRA.

DEFRA tells us it’s to ‘bank’ the benefits of badger culling yet as part of our evidence submission shows, through his solicitors to our solicitors, the former Secretary of State agreed that Dr Birch in his 2024 study could not distinguish the effects of the many compulsory cattle measures or badger culling on observed changes in bTB in cattle. Dr Birch’s APHA colleague, Dr Downs, in her earlier study, stated clearly that her work could not show an ‘association between culling and TB incidence’ and still earlier the RBCT concluded that badger culling simultaneously made bTB in cattle better and worse. So what benefits from badger culling we are intended to ‘bank’ with badger vaccination still seem hard to pin down once we take the trouble to look hard at causation as opposed to very much weaker associations, correlation, and supposition on which we all once had to rely.

Our partners are sincere in their urging and their reasons include badger vaccination offering a face-saving way for the Government and some in the industry to back away from culling without admitting that culling hasn’t worked as they had sincerely hoped.

At some point, the Government and others would need to accept the reality of cattle-to-cattle infection (even in closed herds) and stop wasting public money on killing wildlife and vaccinating wildlife when it’s livestock that needs all of our attention. We don’t share others' faith that this or a different Government would reach that point while there are still very loud populist calls for killing badgers (and votes to be had by heeding them). Britain is one of the most nature-depleted countries in the world - agreeing to the killing of tens of thousands more per annum of one of our most loved native animals to win transient political support is indefensible in the 21st century.

Others in the wildlife sector have told us that unless we are willing to “go along with the idea that badgers are the cause” some bodies just won’t talk to us. That seems a bizarre reason to support anything and access to others, including Government, is not a good enough reason to uphold a damaging falsehood - at least, not in adult life. We might entertain children who believe in an article of faith, but we don’t regard any of our fellow stakeholders as children to be entertained.

Some have said that if badgers are vaccinated, when bTB in cattle rises [it rises and falls over long periods due to non badger, non wildlife reasons, as shown in the years immediately after Downs period of study in the same areas Downs studied] farmers will accept it’s not badgers at fault - this is an attractive idea on the surface. Its key flaw is that there appears to be a placebo-like effect at work when any group of people have physically, financially invested in a measure which they have been told by trusted sources will be effective, largely regardless of the evidence.

No doubt you can think of your own examples. Swap the favoured measure for one in which there is little or no confidence and it’s very unlikely that the levels of confidence will follow - DEFRA has invested heavily in promoting one single policy lever, badger culling, going as far as referring to its entire package of cattle measures plus badger culling all as the Badger Control Policy (or BCP), leading to predictable (intentional?) misunderstanding that ‘badger culling’ was the measure of choice and best effect. An example of the warning from the last Godfray review on the perils of excessively focusing on wildlife diverting attention from the necessary cattle measures still to be taken.

We believe that if bTB in cattle isn’t sufficiently well controlled because of continued resistance in parts of the industry to the use of cattle measures, badger vaccination will be blamed and badger culling called for and quickly returned to - particularly if there is a single powerful badger vaccination contractor with a contract readily adjusted to other forms of badger or bTB control, a contract which cannot be cancelled without the prospect of legal action.

A darker element in the debate is rarely broached in polite company: in some cases and in the minds of some stakeholders, bTB has been an excuse for killing badgers. We include findings from one small survey on the matter.

Some stakeholder bodies are on the public record as wishing to remove legal protection from badgers so that they can killed without license, and in discussion with these stakeholders once bTB as a reason has been put to bed, they quickly move on to “but badgers do X, Y and Z - so they need to be culled anyway”. In one area where badger vaccination is currently underway, the contractor has reported a sudden and marked lack of badger activity and the police are now involved. Illegal killing of badgers continues despite culling and despite vaccination - it was believed by some very senior staff in DEFRA, FERA (forerunner of APHA) and Natural England to be significant in Somerset prior to the 2013 culling programme, we include an FOI response from a FERA official documenting a Somerset farmer reassuring FERA that they did not need to cull badgers on his land as he had already done it.

The old notion that allowing people to kill wildlife legally reduces illegal killing is now very questionable, particularly in the developed world the Royal Society paper ‘Blood does not buy goodwill’ - “ The researchers found that allowing legal hunting of an endangered species, even as a means of reducing human-wildlife conflict and therefore reducing poaching, appears to actually devalue the life of that species in people’s eyes”. Badger Trust believes the badger cull and its accompanying propaganda (we use the word deliberately) has devalued the life of badgers and their place in our ecosystem.

Taken together with still widespread misunderstanding about the role of meso and small predators in ecology, and about what really constitutes a balanced ecosystem (it isn’t equal or equally distributed numbers of different species or more of a pretty one versus a less pretty one), the demonisation of badgers seems to have become more entrenched in some quarters. Public policy plays a part in the persistence of these misunderstandings and the demonisation of some species.

Badger Trust doesn’t dismiss the value of the lives of cattle prematurely slaughtered due to bTB - albeit thankfully a very tiny proportion (roughly 0.4% of the English herd in 2022).

The industry reality, however, is that in almost all cases, cattle are destined for slaughter. That is simply a business reality. Those slaughtered ahead of schedule as a result of bTB are sold as meat for human consumption once they pass vet inspection in the abattoir (once they are found to be free of advanced disease, evidenced by visible lesions they are perfectly safe for consumption). It isn’t a case of “we have to slaughter our cows so you have to let us slaughter badgers” as has been put to us. Cattle are almost exclusively farmed for meat and milk, ending their lives by slaughter: badgers are free living wild animals and should be expected to live a natural life span.

Previously described as ‘ineffective’ by the Government and described by Professor Sir John Krebs as “not an effective policy and would be a mistake” it makes little obvious sense to continue to spend taxpayers money (and encourage farmers to spend their money) culling badgers at all but especially while this review is underway.e In common with partner organisations, therefore, we strongly urge that the intensive and any supplementary badger culling be suspended while this review is conducted, despite any threat of legal action from culling companies.

We agree with our partners and encourage the 2025 panel to engage with experts beyond those already appointed, particularly in wildlife ecology, animal ethics, and animal welfare. Despite their importance, these factors were neglected by previous Governments in developing and assessing bTB policy and were not sufficiently considered in the commissioning of your last review.

Furthermore, we are disappointed that the opportunity to increase the diversity of the 2025 panel has not been taken.

Finally, we urge the panel to ensure its findings are publicly accessible and fully transparent, allowing all stakeholders and the public to understand the conclusions reached.

For instance, the panel could take note of the work by the Office for Statistics Regulation on ‘intelligent transparency’ and set an example for future work commissioned by DEFRA.

One easy and non-contentious question is that the panel makes clear the material difference between the findings it reviews which show causation, correlation, and association in the evidence presented and what the difference means.

The old adage that ‘everyone who confuses association/correlation with causation will die’ holds true - we all die whether we confuse those terms or not - and usefully illustrates how lightweight association/correlation so often are compared to causation. Sadly, in past Government press communications and consequently in press coverage, where association and correlation are frequently and damagingly misrepresented as though they were causation. This materially misleads members of the public, farmers, and Parliamentarians as we too often see in correspondence sent to us for comment.

We have enclosed several documents for the panel's consideration.

We include

● a summary of key literature that will interest the panel,

● copies of material not in the public domain or not readily available in the public domain,

● the names of academic experts who could benefit the panel to engage with.

We would be pleased to discuss these points further with you if that would be helpful.

Thank you for your consideration.

Yours sincerely,

Nigel Palmer Chief Executive Rosie Wood Chair of Trustees