Consultation May 20

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).

Whilst this consultation is primarily about allowing culling adjacent to land where badgers have been vaccinated in these Edge Areas, it will also formulate policy which will also affect Somerset and the rest of the counties in the High Risk Areas (HRA).

This page is designed to help you to respond to the consultation by highlighting some important points.

Where are the Edge Areas?  Click to find out.

These counties fall between the High Risk Area (HRA) of western England and the Midlands and the Low Risk Area (LRA) of eastern and northern England.

This proposal to allow both badger vaccination and badger culling in the same areas poses serious concerns.

The major problem being that badgers vaccinated at taxpayers’ expense, could be at risk of being culled later in the year.  This goes directly against the Government’s stated policy of moving towards non-lethal controls by phasing out culling and supporting badger vaccination.

The government concedes that

“the Guidance to Natural England on licensed badger control does not go into detail on how vaccination and culling should be deployed in a complementary manner, particularly when taking place on adjacent land.

In order to address how deployment of both culling and vaccination in the Edge Area of England should be managed, the Guidance to NE needs to be updated.”

Our badger group together with other badger groups will respond in time to meet the 26 June deadline.

In addition, it would be helpful for as many individuals as possible to submit their views.  You can save your progress you so don’t need to complete your entire response in one sitting.

You can respond in one of three ways:

Online by completing the questionnaire at:
Email to:
Post to: Bovine TB Programme Nobel House 17 Smith Square London SW1P 3JR

The consultation will not consider responses that have been copy/pasted, nor will it consider ‘standard’ responses such as pre-written text for emails or postal responses.

For this reason, Devon Badger Group cannot provide direct responses for you to use, but have listed several bullet points for each question. You should use this for the basis of your own answer, in your own words.

Your answers need to be short and concise, and if you don’t agree with the question, say so.

Read Devon Badger Group’s response.

Read Badger Trust’s response.

Read Rosie Woodroffe’s response.

Read the proposal and consultation document.

Respond to the consultation online.

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

Short answer – yes

Points to consider:

  • Defra recently stated its exit strategy is to move towards non-lethal intervention for both cattle and badgers.
  • Public money has already been invested in vaccination programmes.
  • Hundreds of volunteers have given their time for free to support farmers and landowners wishing to vaccinate rather than cull.
  • Without protection, there is the risk of culling vaccinated badgers.
  • Any scientific evidence gathered on the effect of vaccination would be at risk if vaccinated badgers were shot.
  • This would represent a waste of public money and a downsizing of Defra’s commitment to support badger vaccination going forward.
  • Not offering a degree of protection disadvantages farmers and landowners who wish to vaccinate rather than cull and could act as a disincentive to vaccinate.

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?

Short answer -no

Points to consider:

  • Protection should be given to vaccinated badgers in any area for the same reasons as above.
  • Additionally, the perturbation effect is acknowledged within the proposal.  Culling close to vaccinated areas could cause badgers to change their behaviour and range more widely.  This could potentially dilute the effectiveness of vaccinating.
  • All vaccinated badgers should have a no cull zone to ensure the maximum benefits are achieved for the landowners.

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

Points to consider:

  • Vaccinated badgers must be protected from culling.  Since there is currently no humane, and long-lasting way to identify vaccinated badgers, no-cull zones are the best way of reducing the risk of vaccinated badgers being culled.
  • No cull zones would only be effective if they are of sufficient size, properly monitored and enforced.

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

Points to consider:

  • The document proposes a no-cull zone of 200m around a vaccinated site.  However scientific evidence shows that badgers, particularly through August to October, when culling takes place, usually range much further than 200m from their setts.
  • Since setts will rarely be in the centre of a site, and more often on the boundaries, the risk of vaccinated badgers ranging into cull zones is increased.  Since culling is known to change badger behaviour this is likely to exacerbate the problem.
  • The best protection would be achieved by no-cull zones of at least 700m around setts, rather than proposed minimum of 200m around vaccinated sites.

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

Short answer – no.

Points to consider:

  • All vaccinated sites should be protected from culling.
  • In order to encourage as many landowners as possible to sign up for badger vaccination, no minimum requirements should be imposed.
  • The proposal is suggesting a minimum of 6 badgers will need to have been vaccinated on sites smaller than 2.25 km2 in the previous year to qualify for a no-cull zone.  As many farms and vaccination sites are less than this size and culling will reduce badger populations, this proposed minimum criteria would effectively mean no-cull zones could be withdrawn or not granted making it very difficult to sign up new vaccination sites.
  • Although the consultation documents states ‘vaccination groups have several months in which to capture 70% of the badger population’, best practice guidelines only give vaccination groups no more than four nights to trap on their sites.  Cull operators , on the other hand, are given at least six weeks to meet their targets.
  • On large sites trapping and vaccinating 70% of a population in two nights could prove impossible.
  • If no-cull zones are removed due to failure by vaccinators to reach these high targets, this could further disincentivise landowners to opt for vaccination in the future.

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

Short answer – no.

Points to consider:

  • Creating no-cull zones around setts rather than sites would make the size of a vaccination site irrelevant.
  • The government has set out ‘it’s ambition to move from widespread badger culling to a wider deployment of vaccination’ and therefore it should be made as accessible to as many landowners as possible regardless of the size of the site.

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.

Points to consider:

  • 10 and 16 – Only creating no-cull zones around sites, or parts of sites that fall within the Edge Areas (EAs) continues to expose vaccinated badgers to the risk of being culled.
  • Determining the size of no-cull zones for sites that fall partially in EAs, based on the size of the part that falls within the EA, would become irrelevant if no-cull zones were created around setts rather than sites.
  • 28d – the proposal states that where culling and vaccination are taking place on adjacent land in the HRA, applicants should take reasonable steps to negotiate an agreed approach to badger control operations along the relevant boundary with the landowner/occupier of the land where vaccination is occurring.
  • However vaccination licensees will not know if their site is next to a cull zone since these are kept secret.  Equally cull licensees in HRAs are not informed about vaccination sites.  This means that those required to negotiate an agreed approach will be unable to identify each other.
  • Culling policy requirements state that ‘All participating farmers are complying, and for the duration of any licence continue to comply, with statutory TB controls,’ there is little or no monitoring or independent checking of this by Natural England or other Government agencies.
  • Landowners wishing to apply for a no cull zone must disclose this to their neighbours but not vice versa, this puts them at risk of possible risk of intimidation.
  • Where discussion does take place between both parties, how is this going to be recorded and managed in the event of a dispute?

Question 8 – Do you have any other comments?

Points to consider

  • The government has no idea of the level of disease in badgers on which they are basing their strategy.
  • The comment on p6/7 of Part B, that landowners signing up for badger vaccination might provide a ‘perverse incentive for many small vaccination sites to be licensed purely to prevent or disrupt future cull’ assumes a lack of integrity among landowners and vaccination groups who don’t agree with badger culling.
  • The government should concentrate its efforts on cattle vaccination and until then, badger vaccination should be the way forward in all areas but particularly the HRA. It is cheaper, publicly acceptable, is a scientifically proven alternative to culling does not cause perturbation or tie up police resources.

You may also find reading our initial concerns regarding the proposal and Rosie Woodroffe’s excellent blog will help you with this section.

Read the Godfray Review

Badger Trust believes that these proposals will

  • enable culling across all Edge areas
  • severely limit any new badger vaccination schemes
  • damage the efficacy of current badger vaccination schemes and their ability to expand
  • damage the ability to continue at all for many current badger vaccination schemes