皇家华人

This consultation has now closed.

皇家华人has submitted its response. You can read a summary of our response below.

NFU members can also log in to read our response in full at: NFU response to proposals to evolve badger control policy and introduce additional cattle measures.

Targeted badger intervention policy

皇家华人supports the principles of TBI and agrees with the need for an ongoing policy which permits culling led by science and evidence in areas where there remains a disease problem.

It is vital therefore that we continue to contain and control the disease through culling of badgers in areas where they are thought to be part of the problem.

While the proposal states that badger vaccination will be supported by Defra, it is unclear as to what this means. 皇家华人cannot support asking its members to pay for vaccination at this time.

We therefore believe that support in this instance should include full funding for any badger vaccination activities.

We would also strongly recommend that any savings made by government through licensing changes are invested in successful delivery of culling as a proven disease control measure.

In order to retain the benefits that have been achieved through culling of badgers to date, it will be important to implement this policy as soon as practicable.

Clusters of cattle infection

皇家华人agrees with the principles for identifying localised disease issues within cattle, but farmers must be provided with confidence that analysis will be undertaken regularly.

The strong rural networks that have developed have been a vital part of successful wildlife control to date and these must be maintained in order to deliver effective culls in eligible clusters.

Whilst we accept there is evidence that badger vaccination reduces bovine TB prevalence within the badger population, there is currently no evidence to show how these benefits will present in cattle.

Consideration should therefore be given as to whether there is a need or cost benefit in implementing immediate widespread badger vaccination, but focussing the most cost-effective measures in the right areas and retaining an agile application of each intervention.

We suggest a risk-based approach is implemented, which prioritises application of badger vaccination within post-cull clusters to specific locations in which it will be of the most benefit.

Annual cap

There should not be any form of cap imposed on the number of clusters eligible to cull in any given year.

If the situation demonstrates that badgers are part of the problem, it is imperative that actions can be taken to control the risk as soon as possible; delays due to a cap on areas will simply prolong the issue on farm and increase the cost of dealing with the disease in cattle herds.

Defining a cluster under TBI

Local stakeholder feedback and non-bovine disease information should be taking into account when defining a cluster.

We support the CVO鈥檚 (Chief Veterinary Officer) decision making to be in collaboration with expert advisers as suggested in the consultation, however there must be mechanisms in place to allow farmers and vets in and around clusters to feed into this process.

It is important that those individuals on the ground with first-hand knowledge of how and where the disease is of concern can provide representation, rather than relying wholly upon data trends and modelling.

It will also be important that the local disease situation considers information that is available from non-bovines in assessing the disease picture.

Whilst cattle are the main beneficiary of culling, reducing the risk from badgers will also have impact upon other species. Therefore, utilising information available from these species, for example, both wild and farmed deer, pigs, or camelids, will assist in offering information on the extent of local disease spread and must not be excluded.

Licensing

皇家华人is calling for licensing to be streamlined and simplified to ensure that culling in eligible clusters can be delivered without delay, while remaining thorough.聽

We therefore support moving to a licensing mechanism which enables organisational licences to be granted.

Overall, relieving Natural England from its current role of licensing culling operations would appear to streamline decision-making, and is therefore supported.

All licensing decisions must be underpinned by science, evidence and ensure that the eradication strategy is not influenced by political sensitivity.

皇家华人has welcomed the Defra consultation which details proposals for future TB policy. The suggested introduction of a TBI (targeted badger intervention) policy and simplified licensing procedure offers sound principles for disease control, which we hope can be implemented to continue building on the great benefits industry have achieved in reducing bTB.

皇家华人is aligned with the overarching aim of the cattle measures set out in the consultation.

The proposals to enhance accessible information on ibTB follow recommendations made by the TB Partnership.

How would TBI be delivered?

The guidance to applicants included within the consultation document is similar to the guidance for current SBC (supplementary badger control) areas. Operationally we would therefore expect methods, operating procedures, and licence conditions to remain broadly the same as that policy.

Badger vaccination delivery

There is no defined expectation within the consultation regarding who will be the badger vaccination delivery body.

Similarly, we don鈥檛 know at this stage what the requirements will be to demonstrate the ability to vaccinate after culling when applying for a licence. The consultation suggests this could be a field force of individuals to undertake training, or via securing the services of an existing supplier.

Change of licensing organisation

Natural England currently work closely with cull companies, creating detailed reports which are submitted to the Chief Veterinary Officer and Secretary of State. We anticipate that the proposed change of licensing organisation would therefore be similar to the current structure which offers the Secretary of State powers for decision making under the Protection of Badgers Act, regardless of the licensing body.

Defining clusters and eligibility for culling

We support the proposal for Chief Veterinary Officer鈥檚 decision making to be in collaboration with expert advisers, but also believe that there should be mechanisms in place to allow farmers and vets in and around clusters to feed into this process.

We are awaiting further information from Defra and the APHA on details of clusters, including how they are identified and the regularity of the identification, but we can agree with the broad principles for identifying localised disease issues and reducing disease.

We also need further information on their size and geographical spread which is currently not available to have confidence they will achieve the desired outcomes.

It can be anticipated however that clusters will not align to existing cull areas so there will be a need for ongoing local engagement and industry representation.

The networks that have been developed have been a key part of successful wildlife control to date and these must be maintained in order to deliver effective culls in eligible clusters.

Organisational licence 鈥� what would it look like and who would be responsible?

There may be an opportunity to streamline costs and the administrative burden by centralising tasks under one organisational licence issued annually. This could also permit industry to react faster once a cluster is identified and deemed eligible for culling.

Whoever takes this on will, as stated in the consultation, have a greater level of responsibility for operations on the ground so a strong network of contacts across a cluster will be vital.

We understand the huge amount of work and dedication that has gone into delivering industry-led culling over the last decade, and it is vital the investment is maintained.

皇家华人will continue supporting industry to deliver any future wildlife control policy successfully.

Who will pay for culling and vaccination?

It is proposed that culling will continue to be industry-led and industry funded, however we would expect any badger vaccination to be supported financially by Defra.

Given the lack of evidence on its effectiveness at reducing bTB within cattle there cannot be an expectation for farmers to pay.

We would strongly recommend that any savings made by the government through licensing changes are invested in successful delivery of culling as a proven disease control measure.

NFU position on cattle measures

皇家华人endorses initiatives that empower farmers with disease information, enabling them to make informed individual purchasing decisions tailored to their herds, thus mitigating TB risk and minimising disease transmission.

However, we are mindful that these measures must not impact trading opportunities or result in diminished stock values with the potential of creating a two-tier market.

ibTB data

The ibTB map is currently updated every two weeks; we do not yet have details of whether the information relating to animal data will be real time, however, we believe that it should be to be of use to farmers.

Benefits of publishing additional disease information on ibTB

Cattle movements are a recognised TB risk pathway with the potential to introduce disease into herds. Publishing additional animal and herd level TB information will enable potential buyers to assess the associated TB risk 鈥� especially relevant for breeding stock.

If CPH and tag numbers of potential source cattle are known in advance buyers will be able to cross reference ibTB to access key information to ensure the purchase fits with their business model.

The date and type of an animals鈥� most recent pre-movement TB test provides reassurance that an animal moving to a new herd has a low TB risk of spreading residual infection.

TB testing has limitations and risk factors are variable; information such as the length of time in a herd, number of years that herd has been TB Free, and the date and type of the last TB test are key indicators of the level of disease exposure.

Increasing accessible routine information gives greater transparency and promotes responsible purchasing within the cattle industry.

How will bTB risk information on source stock herd be displayed?

The level of detail is yet to be confirmed but we expect this to be developed once the principle to display it is established. Updates to the ibTB website will be part of a three-year improvement project.

Currently, herds locations are the registered address of the CPH; bTB history for all herds ('the health rating view') for the last 10 years displays as a traffic light system.

Cattle vaccination

The Veterinary Medicines Directorate has not approved the cattle BCG vaccine for use in the UK because it can cross-react with the approved tuberculin skin test used for national bovine TB surveillance.

An effective DIVA test that can tell infected animals apart from vaccinated animals is vital. Defra recently announced a future third phase of the UK cattle vaccine field trials to further assess the specificity of the DIVA test and options to maximise performance.

How will the changes be funded and delivered?

The consultation states that proposals to enhance ibTB will not result in increased costs or burdens to the industry.

Funding for the proposed enhancements to the ibTB website is expected to be through the Government鈥檚 bovine TB control programme and implementation will require resource from the APHA.

It will be imperative that there is no impact upon their existing commitments.

Livestock information service

皇家华人supports the delivery of the livestock information service for cattle which has the potential to deliver additional TB information at the point of sale to support a voluntary risk-based trade approach.

Enhancing ibTB information at the animal level is not comparable to the potential to give cattle keepers information through the livestock information service which we urge Defra to introduce as soon as possible.

Defra has set out new proposals for a 鈥榯argeted badger intervention policy鈥� for inclusion in the next phase of the government鈥檚 TB eradication strategy.

The consultation will run for five weeks and will look at retaining badger culling as an option in targeted parts of the High-Risk area and Edge areas, where there are high levels of infection in cattle, and where evidence suggests badgers are part of the problem in the spread of disease to these herds.

The UK鈥檚 Chief Veterinary Officer will review the disease situation annually to inform decisions on whether badger culling or badger vaccination would be deployed.

The consultation will also consider proposals for publishing additional information about animal and herd level bTB risk, to help those purchasing cattle to factor in such risks when sourcing new stock.

You can read our briefing for more detail on the proposals.

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