Rural Development Sub-Committee

Inquiry into Bovine Tuberculosis

Response from Countryside Council for Wales

Cadeirydd/Chairman: John Lloyd Jones OBE, Prif Weithredwr/Chief Executive: Roger Thomas
Anfonwch Eich Ateb At/Please Reply To: Dr David Parker - Cyfeiriad Isod/Address Below
Llinell Union/Direct Line: 01248 385620 Ffacs/Fax: 01248 385427 Ebost/Email: an.jones@ccw.gov.uk

Alun Davies, AM
Chair, Rural Development Sub-Committee
National Assembly for Wales
Assembly Parliamentary Service
Assembly Offices
Cardiff Bay
CF99 1NA
9^th September 2007

Dear Mr Davies

Rural Development Sub-Committee Inquiry into TB in Wales

Thank you for inviting the Countryside Council for Wales to submit evidence to the Assembly’s Rural Development Sub-Committee inquiry into bovine TB (bTB) in Wales. CCW’s interest in bTB is primarily in relation to our remit to provide advice on its general relevance to nature conservation as well as the specific impact of possible control measures on a protected species, the badger and/or other wildlife. CCW is a member of the Wales TB Action Group.

The final report of the ISG

CCW welcomes the publication of the final report of the Independent Steering Group (ISG) 'Bovine TB: The Scientific Evidence. A science base for a sustainable policy to control TB in cattle’. The Randomised Badger Culling Trial (RBCT), overseen by the ISG, is the first scientific analysis of the contribution that two different badger culling strategies (reactive and proactive culling) can make to the control of bTB in cattle. The report provides evidence that perturbation to badger social groups following culling, both within and adjacent to the culled areas, resulted in greater transmission of the disease between badgers and cattle. As a result an increase in disease incidence was seen within the reactive culling areas and adjacent to proactive culling areas.

The results of this trial have provided strong evidence that badger culling is not effective at reducing bTB in cattle except over very large scales and at great cost. As such, badger culling is not considered to present a long-term sustainable disease control option. CCW supports the conclusions and recommendations reached by the ISG.

Difficulties with the trapping methodology and lack of access to some land within the trial areas have been considered in the report. Whilst improvements could have been made to the culling programme, the ISG consider that this would not have substantially changed the results of the trial. Further, it would not be possible to permanently remove all badgers from an area due to immigration and the fact that there will always be those who are unwilling for culling to take place on their land.

Implementation of the EPC Committee’s recommendations

The EPC Committee paper 'EPC(2) 02-07 (p1) Annex 2’ provides details of progress with implementation up until February 2007. However, we wish to make the following points.

As highlighted in the ISG report, the identification and removal of infected cattle at the earliest opportunity is crucial to controlling the spread of the disease. The Welsh Assembly Government has implemented some additional disease identification controls, namely pre-movement testing for 1 and 2 yearly parishes and the use of the gamma interferon test in certain prescribed circumstances. However, the EPC Committee’s recommendations to increase cattle testing in clean parishes from every four years to every two years, and the introduction of gamma interferon testing for all herd breakdowns have not been implemented.

In July 2007 the Wales TB Action Group recommended to the then Minister for Environment, Planning and Countryside, that: "an Intensive Treatment Area (ITA) is established in an area of high incidence of bovine tuberculosis (bTB) within which the g-IFN test is used in parallel with the skin test for specific Government funded testing of cattle”. However, this recommendation was not implemented and the Minister opted instead to follow the GB strategy of a more limited, albeit Wales-wide, use of the test. CCW consider that a more rigorous testing regime should still be developed and that the Gamma Interferon ITA proposal be revived.

In considering the recommendations of the EPC Committee’s report regarding the establishment of an Intensive Treatment Area, the Wales TB Action Group agreed that this could best be implemented by applying the three main 'treatments’ in separate areas. The proposal for a Gamma Interferon ITA has already been referred to above.

The Biosecurity ITA is currently being implemented in an area within Pembrokeshire. CCW wholeheartedly supports this project and the approach that has been developed by the Welsh Assembly Government. Examples of best practice from this project should be used to actively encourage other farmers to adopt improved biosecurity measures. Successful extension of best practice in biosecurity will also have benefits for wider animal health and disease issues.

Steps towards a Wildlife ITA were initiated with a survey of found dead badgers and a regional badger population survey. However, in our response to the publication of the EPC Committee’s report (CCW letter dated 14 October 2004, see Annex), we raised a number of serious concerns regarding the proposed approach for the removal of wildlife found to carry and transmit TB (EPC report recommendation 2, point 4). These concerns have yet to be addressed and there is now strong evidence from the RBCT that this approach is unlikely to be effective and could in fact be detrimental (as was found in the reactive trial areas).

Recommendation 4 of the EPC Committee’s report was to establish the Wales TB Action Group. CCW has been a member of the Action Group and it has served as an effective forum for the discussion of disease control policy options and liaison between stakeholders and Government. CCW supports the continuation of the Action Group.

CCW recognises the considerable burden that is placed on the farming community in dealing with bTB. However, the RBCT has shown that badger culling will not be an effective method to control the disease. Successful management of bTB will require a long-term sustainable strategy that ensures the disease does not spread from established hotspots whilst also containing and reducing the disease on affected farms. Biosecurity measures which improve herd management and reduce contact between cattle and cattle and badgers should be adopted in all high-risk areas. Further support may be required to enable farmers to eradicate the disease from their herds and to implement effective preventative measures.

CCW also consider that more research is needed into the contribution that nutrition can make to controlling bTB. Correcting mineral deficiencies has been raised as a legitimate consideration for reducing the susceptibility of cattle (and badgers) to the disease.

In conclusion, CCW supports the position of the previous administration of a science-based approach to the control of bTB. CCW consider that the ISG report on the RBCT has provided clear scientific evidence that badger culling does not represent an economic solution to the control of bTB in cattle. Whilst it may prove more demanding for the farming community in the short term, we believe that a long-term bTB strategy should be developed which focuses on improved testing and ensuring farmers adopt a rigorous approach to cattle herd husbandry.

Yours sincerely

Dr David Parker
Director Science

Annex CCW Response to Publication of EPC Committee Report, October 2004

Dear Ms Barry

CCW Response to EPC(2)-0804 (P3) Report: Wales’ Approach to TB Control

CCW welcomes the report of the EPC as published on 14^th July 2004. We wholeheartedly support recommendations 1, 4 and 5 and consider that the increased attention proposed for biosecurity, testing regimes and methods, and the establishment of a Wales TB action group, will all contribute to the reduction of bTB in Wales.

We also support most of the points raised in Recommendation 2 (Intensive Treatment Areas), but would like to point out some of our concerns with the proposals in point 4:

"If investigations find that the cause of the breakdown is not due to cattle to cattle transfer, an investigation of major species of wildlife known to carry TB should be undertaken within a 2km radius of the breakdown. Wildlife that carry and transmit TB found to show signs of the disease should be removed. A level of prevalence/rate of transmission in wildlife should be agreed upon.”

Wildlife that carries bTB includes deer, badger, polecat, grey squirrel, small rodents and feral cats. The DEFRA report SE3010 (The risk to cattle from wildlife species other than badgers in areas of high herd breakdown, CSG15, April 2004) includes data collected from wild animals in southwest England in bTB hotspots. The final paragraph of their summary suggests that further work is needed before small mammals can be ruled out as bTB vectors and that whilst polecats, stoats and foxes had infection levels ranging from 4.2% to 3.2%, their relative scarcity may rule them out of transmission possibilities. Of course in Wales the polecat is a widespread and in many areas, common animal, that is known to frequent farm buildings. Deer seem to show high levels of infection too (4.4% for fallow) and also levels of pathology that indicate a potential risk to cattle. Deer populations in Wales are increasing and work by the Wales Deer Initiative indicates that both fallow and roe are common in the southwest of Wales where there are bTB hotspots.

This gives quite a wide range of species for which trapping and testing will need to be carried out in Intensive Treatment Areas. We are aware that a live 'sett-side’ bTB test for badgers is under development, but know of no other diagnostic tests that can be carried out on live individuals of other species. How is it intended to carry out these tests? If trapped animals are killed and tested, do you have any indication of the numbers of individuals that would be involved and how they would be killed. We note that the current Randomised Badger Culling Trial has very stringent standards for culling and that this is carried out by trained staff and inspected by an external auditor (see The 3^rd independent audit on the humaneness of dispatch procedures used in the randomised badger culling trial and DEFRA response, July2004). We presume that a similar level of humane treatment would be considered necessary should wider scale trapping and culling be carried out as suggested by Recommendation 3.

We presume that if the testing procedure identifies the agreed level of infection in a particular species, then all possible efforts would be made to remove any member of that species from the surrounding area up to 2km away from the breakdown. The logistics of this are daunting, but we would be concerned to know if you will make any attempt to examine the likely effects on the nature conservation interest of this action, particularly if the target area includes SSSI/NNR or indeed SAC/SPAs. In the case of protected land there may be a requirement to consult CCW and obtain the necessary consents/assents if any of the Operations likely to damage the special interest is affected by animal culling. This is a requirement under Schedule 9 of the Countryside and Rights of Way Act 2000. We understand that some study of the ecological effects of badger removal is included within the current RBCT procedures, but are not aware of any linked work on other bTB carriers.

We presume that the culled area would continue to be trapped for the target species, but wonder if you had any indication of the time span of such operations. Many of the potential target species are quite mobile and likely to move back into the area over time.

We continue to maintain our position that we are unable to provide advice on the effectiveness of the removal of badgers with regard to its effect on bTB incidence in cattle, until the RBCT is completed.

Point 5 of the recommendation states "Potentially infected areas should be cleaned as well as practically possible to reduce the risk of transmission to other wildlife”.

Does this mean that the general countryside will be subjected to a disinfection programme, or that this would be restricted to animal resting places such as setts? Either of these would have the potential to damage other nature conservation interests, including affecting water courses or damaging non-target species that shelter in setts and animal burrows.

Recommendation 3 proposes extending the use of intensive treatment areas across Wales. We would hope that sufficient time for the effects of other action including new testing regimes, methods and biosecurity improvements would be given sufficient trial time before the possible widespread introduction of wildlife culling.

We note that many of these points were raised by Assembly Members at the Plenary Session on 6^th October 2004. We also note that the Ministers intends that the Wales TB Action Group will look at the recommendations of the Report, and look forward to contributing to the discussions on the wildlife issues as part of that Group.

We would of course welcome the opportunity to meet and discuss these matters if you feel it would be helpful.

Whilst we do have some concerns over the possible details of the Intensive Treatment methods, we do wish to re-iterate our agreement with the other recommendations and look forward to the Ministers response to the EPC report.

Yours sincerely

Dr David Parker
Director Science