Consultation outcome

Summary of responses and government response

Updated 7 September 2020

Overview

Introduction

This document provides a summary of responses to Defra’s consultation exercise on a proposal to manage the delivery of both badger vaccination and culling in Edge counties. The consultation ran from 15 May 2020 to 26 June 2020. The aim of this document is to provide a summary of the responses received. This document also sets out the government’s response to the consultation.

Background

Bovine TB is one of the most significant problems affecting animal health and sustainable livestock farming in England. The government is committed to delivering the 25-year strategy for achieving Officially Bovine Tuberculosis Free status for England. Controlling the disease in badgers where TB is widespread is an important part of that strategy. The TB Strategy is an adaptive, evidence-based, long-term approach to disease control, including badger control in areas where the disease is widespread in cattle and in badgers to complement other measures.

We want to eradicate this disease in England by 2038 and while badger culling is a necessary part of this, no one wants to see it continue indefinitely. That is why our response to the Godfray Review, published in March 2020 set out the need to identify an exit strategy from the intensive culling of badgers by deploying vaccination to the remaining badger population with the cull phase of the strategy winding down by the late 2020s. We also plan to accelerate other elements of our strategy, including improved diagnostics and cattle vaccination.

This move from widespread badger culling to wider deployment of vaccination, with epidemiology-driven culling only taking place where surveillance in badgers and cattle indicates re-emerging or persistent infection, will necessitate badger culling taking place alongside badger vaccination. Recognising that this could impede deployment of vaccination, the government wants to manage this situation, whilst not making it impossible for farmers to come together and undertake licensed badger culls where warranted.

This consultation set out a proposal to manage the delivery of both vaccination and culling of badgers in the Edge Area of England, particularly where they take place on adjacent sites. Our proposal aims to reduce the risk of culling vaccinated badgers balanced with ensuring that culling can proceed where applications meet the licensing requirements to ensure that progress is made towards disease eradication. In the consultation, it was proposed that badgers within active vaccination sites in the Edge Area are protected from adjacent culling through the use of no-cull zones surrounding the vaccination sites. We invited views on the following topics:

• Question 5: The principle of protecting vaccinated badgers from culling to some degree, to manage delivery of adjacent vaccination and culling
• Question 6: An opportunity to provide comments on the degree and circumstances in which the principle of protection is applied
• Question 7: An opportunity to comment on proposed revisions to the Guidance to Natural England (NE)
• Question 8: An opportunity to provide any additional comments

We consulted on specific proposed revisions to the previously published Guidance to Natural England (NE), setting out the licensing criteria that NE, as the delegated licensing authority, must have regard to when considering such licence applications.

Methodology

Defra emailed over 300 interested parties about the launch of the consultation. These included organisations and individuals from the cattle sector (farming, health and welfare), wildlife and conservation groups and those registered on Defra’s stakeholder lists.

The consultation closed on 26 June 2020.

All written responses were considered. This document summarises the main points raised and the themes that arose. The consultation was not designed to be a representative survey and so the results cannot be statistically generalised to the wider population. This summary is not intended to be an exhaustive record of all the points made and the absence of a particular issue does not indicate that it has been ignored or that it is of lesser importance.

Summary of statistics

In response to the consultation, Defra received contributions from 1,994 respondents. These responses were received online via the consultation website and via email.

Respondents who chose to respond online were asked their organisation name. Some respondents who sent their response in an email also declared their organisation; others did not.

In summary, 96% of responses were from individuals and the remaining 4% were from organisations including wildlife, farming and veterinary organisations.

Many members of the public who responded expressed a strong interest in wildlife, badger welfare or conservation, for personal or professional reasons. Some stated that they had previously participated in badger vaccination programmes.

A fifth of responses submitted appear to have been submitted in response to several campaigns or posts initiated by organisations such as wildlife or farming organisations.

Summary of responses

Overview of responses

The responses to each question posed in the consultation are summarised below. Although we were only consulting on the proposal to manage the delivery of both vaccination and culling of badgers in the Edge Area of England, many individual respondents and organisations provided general comments, notably on the government’s overall approach to controlling bovine TB in wildlife. Natural England provided a formal consultation response as the licensing authority for badger control in England.

The majority of respondents from the farming and veterinary community wanted the policy focus to be on disease eradication and stressed their view of the importance of culling badgers in eradicating TB in cattle. They expressed the view that there is limited evidence that the vaccination of badgers leads to a decrease in the incidence of TB in cattle. They made comments outside of the scope of the consultation that farmers should have the ability to cull where the epidemiological picture shows that there is a recognised reservoir in badgers as culling is a proven method in tackling the disease.

The majority of respondents from wildlife organisations and those not associated with any particular community wanted complete protection of vaccinated badgers from culling with a large proportion stating that they were against culling in any part of England which were also outside of the scope of the consultation.

Some wildlife groups and the Royal Society for the Protection of Animals (RSPCA) questioned the epidemiological evidence for badgers being a source of cattle herd breakdowns in any of the Edge Area, and suggested that the government should declare the whole Edge Area a vaccination area with associated governmental investment.

The wildlife trusts, Badger Trust, National Trust, and Zoological Society of London (ZSL) all highlighted their concern that the consultation proposal was encouraging farmers to withdraw from participation in vaccination due to a fear of preventing their neighbours from undertaking a cull in the future. They proposed that the impact of these actions would be vaccination land coverage shrinking, and schemes becoming unviable.

Some respondents requested that government defines where the recognised reservoir of infection in badgers occurs and therefore where culling is an option.

There was concern from several organisations that the proposal may lead to further conflict between vaccination and culling groups, rather than reducing tensions. For example, the National Trust argued the proposal set out in the consultation would ‘create increased animosity between vaccination projects and neighbouring land [with] the potential to significantly reducing [sic] the willingness of farmers to engage with badger vaccination projects in the future.’

Some respondents were concerned about the enforcement of no-cull zones and there were a number of responses expressing concern over the disclosure of the location of vaccination sites. Respondents felt this could lead to both the intimidation of landowners and the targeting of badger setts by cull participants.

Some respondents, including those who disagreed with culling policy, acknowledged the impact that dealing with bovine TB has on farmers, and their businesses.

Responses to question 5 – Should vaccinated badgers be protected from culling to some degree, to manage delivery of adjacent vaccination and culling?

We asked for views on the principle of protecting vaccinated badgers from culling to some degree, to manage the delivery of adjacent vaccination and culling in the Edge Area.

We received 1,994 responses to this question; with 1,016 respondents expressing support for the principle of protecting vaccinated badgers from culling to some degree in the Edge Area whilst 840 respondents were not supportive of this principle. The remaining 138 respondents did not clearly provide a response either in support or against this principle.

Of the 1,016 respondents expressing support, very few agreed with the entire proposal of protecting vaccinated badgers to some degree to manage the delivery of adjacent vaccination and culling in the Edge Area. The majority of those in favour expressed a desire for total protection of vaccinated badgers from culling everywhere or that protection should extend to all badgers, not just those that have been vaccinated.

840 respondents were not supportive of the proposal. One of the most common reasons respondents were not supportive was that they felt vaccination in the Edge Area would prevent culling from taking place in these counties. No reasoning or evidence to support this view was provided. Another common concern was that there was insufficient evidence for vaccination as a method of disease control for TB in cattle. Some respondents who were not supportive of the proposal were willing to consider vaccination but only in a reduced badger population following an intensive cull.

Organisations such as the wildlife trusts, Badger Trust, RSPCA, ZSL and Animal Aid were broadly in favour of the general protection of vaccinated badgers but opposed the proposal as outlined in the consultation as they felt it would not offer enough protection to vaccinated badgers and still allows for culling within the Edge Area. These responses in general did not consider how a successful cull could be carried out adjacent to vaccination sites. The Badger Trust stated that ‘..protection (of badger vaccination schemes and vaccinated badgers) should be achieved by vaccination, replacing intensive culling in the Low Risk and Edge Areas and all supplementary culling in both Edge and High Risk areas.’

Responses from Natural England and the British Veterinary Association/British Veterinary Zoological Society weighed up the competing needs of culling and vaccination in the Edge Area and made suggestions as to how this could be managed in relation to the proposed criteria.

Organisations such as the National Farmers Union, British Cattle Veterinary Association and Vet Partners were against the implementation of the proposal based on concerns that culling must remain the primary means of controlling bTB transmission where there is endemic disease and that the effectiveness of badger vaccination on controlling bTB in cattle is unknown. The National Farmers Union stated that ‘…culling must remain the principal means of controlling the spread of bTB infection from badgers in areas of high or rising infection, as it is proven to be effective. To date there is no evidence that vaccination will eliminate the transmission risk in badgers or cattle in areas where the disease is prevalent.’

Responses to question 6 - If so, to what degree, in what circumstances and subject to what conditions? In particular – 6 (i) should any such protection only be provided to badgers vaccinated in the Edge Area?

We asked for views on whether protection should only be provided to badgers vaccinated in the Edge Area.

We received 1,596 responses to this question; 1,525 respondents directly answered the question or made relevant contributions, and 71 responses were categorised as not relevant to badger vaccination.

Of the 1,525 responses that made relevant contributions to this question: 1083 expressed the opinion that protection of vaccinated badgers should not just be restricted to the Edge Area; 61 agreed that any protection should only apply to the Edge Area. 381 expressed the opinion that vaccinated badgers should not be protected in response to this question.

The wildlife trusts, Badger Trust, ZSL and RSPCA supported protection of all vaccinated badgers. They proposed that the Edge Area was of higher importance than the Low Risk Area (LRA) and High Risk Area (HRA).

Of those who expressed broad opposition about two thirds expressed concern that introducing no-cull zones would leave pockets of infection and delay progress towards TB eradication.

Responses to question 6 (ii) – should protection be achieved by means of a no-cull zone?

We asked for views on whether protection should be achieved by means of a no-cull zone.

We received 1,328 responses to this question; 1,018 respondents agreed with no-cull zones as a means of protecting badgers (and of these 546 wanted this protection expanding to the HRA), 302 respondents opposed the proposal, and 8 responses were unclear.

The wildlife and vaccination community were widely supportive of no-cull zones to protect badgers and offered no alternative approaches.

There was limited support for the option of marking badgers and allowing culling by cage trapping within a no-cull zone. Significant concerns were raised over how the cage trap proposal or indeed no-cull zones would be policed. Suggestions were made that vaccination licence holders could act as monitors but in order to do this would need to be informed of where no-cull zones were implemented.

The farming community were in general not supportive of no-cull zones and did not offer an alternative suggestion for managing situations where culling and vaccination adjoin.

Responses to question 6 (iii) – how should the size of the no-cull zone area be determined?

We asked for views on how the size of the no-cull zone should be determined.

We received 1,139 responses to this question; 526 respondents directly answered the question, 587 provided responses that did not directly respond to the question but made relevant contributions to the consultation subject and 26 responses were categorised as not relevant.

Of those that answered the question, just over half suggested that the size should be determined using evidence from studies on badger movements i.e. a scientific basis, and a third thought the no-cull zone should be bigger than in the proposal. The responses from the wildlife trusts and the Badger Trust quoted evidence from a number of studies on badger ranging distances emphasising the maximum ranges recorded for badger movements to argue that the proposed no-cull zones were not large enough to effectively protect vaccinated badgers.

ZSL gave the most detailed response to this issue and provided data from a study on radio-collared badgers (this study has been published as Ham et al. 2019 ¹) showing the maximum nightly distance a badger roams from its main sett. Although not supportive of the proposal in general, they did suggest that no-cull zones of a minimum 700m in width and centred on main setts would be a better approach than around the boundaries of the vaccination site. The Badger Trust, RSPCA and NE also suggested focusing the no-cull zone around main setts. They proposed that this would better reduce the risk of badgers being culled where setts were located close to the edge of a site.

In terms of how wide the buffer should be different groups presented the following proposals: Badger Trust: 10km, wildlife trusts: 7km, RSPCA: 2km or alternatively 1km around a sett, British Veterinary Association/British Veterinary Zoological Society: 200m minimum but suggested a maximum of 400m rather than 2km, Natural England: 200m minimum but suggested a maximum of 500m rather than 2km.

Responses to question 6 (iv) – Should eligibility for a no-cull zone be subject to meeting certain minimum criteria?

We asked for views on whether eligibility for a no-cull zone should be subject to meeting certain criteria. The proposed minimum criteria that were consulted on are:

• Only sites where a sufficient number of badgers have been vaccinated in previous years will have no-cull zones.
• The sufficient number is set comparable level to the minimum number that would need to be removed during a licensed culling operation e.g. currently 2.7 badgers per km2. For sites smaller than 2.25 km2 at least six badgers will have needed to have been vaccinated in the previous year.
• NE will set the minimum sufficient number for each site taking into account any extenuating local factors.

We received 1,204 responses to this question; 887 respondents directly answered the question; 317 respondents did not directly respond to the question and were categorised as not relevant.

Over three quarters of respondents who answered the question disagreed that minimum criteria should apply in order for a vaccination site to be eligible for a no-cull zone. These respondents believed all vaccination sites should have protection, regardless of whether they meet certain minimum criteria.

Many respondents proposed that whenever vaccination sites were licensed, i.e. in the season during or after a cull licence had been issued, no-cull zones should be implemented. No suggestions were made on how the operational challenges could be overcome to put this in place.

Some organisations argued that the suggested minimum of 2.7 badgers per km2 was too high for some land class areas based on data from the national sett survey. For the same reasons they felt that there should not be a minimum number of 6 vaccinated badgers on sites smaller than 2.25km2 to qualify for a no-cull zone.

Of those who agreed with the proposal to apply minimum criteria, there was no overwhelming support for any single one suggested alternative to the criteria which were proposed.

Responses to question 6 (v) – Should any such eligibility criteria include a condition as to the minimum size of a vaccination site

We asked for views on whether eligibility criteria should include a condition as to the size of a vaccination site.

We received 1,065 responses to this question; 799 respondents directly answered the question, 4 proposed relevant other proposal, 262 respondents did not directly respond to the question responses and were categorised as not relevant.

Of those who directly responded to this question, the majority were in opposition to eligibility criteria relating to the minimum size of a vaccination site. The most popular alternative suggestion was that the minimum size of a vaccination site should be equivalent to a badger territory.

Of those who disagreed with minimum criteria, approximately 20% did so as they thought it would discourage vaccination on new sites and prevent expansion of existing sites into adjoining areas.

Responses to question 7 – on proposed revisions to the Guidance to Natural England on licensed badger control.

We asked for views on proposed revisions to the Guidance to Natural England on licensed badger control.

We received 803 responses to this question; of these 189 respondents directly provided comments on the draft guidance.

Natural England requested that consideration be given to providing more information on the size of no-cull zones in the Guidance. They requested consideration be given to operational concerns over setting no-cull boundaries, where no physical features were present, for example across the middle of fields. They also advised that where thresholds and criteria are not stated in the Guidance, the Guidance should explicitly state that NE has flexibility to apply its discretion.

Of the other respondents that provided comments on the guidance, the main concerns were regarding the loss of confidentiality of landowners signing up for vaccination and that applicants for culling and applicants for vaccination on adjacent land in the Edge Area would not be able to agree an approach together.

Organisations such as the wildlife trusts, ZSL and Badger Trust expressed concern over the proposal that landowners must request a no-cull zone around a vaccination site, stating that it may increase drop-out rate from current vaccination schemes or deter landowners from requesting no-cull zones for fear of negative reactions from neighbours.

The National Trust expressed concern that there is an imbalance in the draft guidance where ‘cull areas are permitted to know the location of vaccination areas, but those vaccinating are not permitted to know the location of cull areas.’

Responses to question 8 – an opportunity to provide any additional comments on the proposal.

We invited respondents to provide any additional comments which they felt were relevant but had not been captured by questions 5, 6 or 7.

We received 1,443 responses, 713 of these responses were broadly in support of the proposal of protecting vaccinated badgers and 346 were broadly against the proposal of protecting vaccinated badgers. 199 responses related to badger control policy as a whole. The remaining responses were unclear or not relevant to the consultation proposal.

Many respondents expressed opposition to badger culling because they believe that there is little evidence to show that it is having an impact on reducing levels of Bovine TB and some believe that badgers are not the issue.

Environmental or biosecurity concerns were raised by respondents with some commenting that badger culling would likely result in an increase of infection due to perturbation, and some expressed concerns about possibly infected slurry.

Some respondents expressed concern about cattle measures or cattle being the main vector that spreads Bovine TB. Many of these suggest that cattle measures or movement restrictions should be strengthened, in order to combat Bovine TB. However, the responses did not specify what these measures should be. Some felt that cattle testing should be improved and that more research should be carried out because they believe that undiagnosed infection in herds is what is spreading Bovine TB. Others felt that cattle movement should be stopped between the HRA and the Edge.

A smaller number expressed support for cattle vaccination, without specifying where it should happen.

The government’s response to the consultation

Introduction

Defra is grateful to all those who took the time to respond to the consultation. The responses received, as well as the experience from the badger control operations to date and the scientific evidence and veterinary advice available have helped inform the Secretary of State’s decision to implement the proposal.

The Secretary of State has noted the range of responses. The consultation has raised some important considerations for how the delivery of the policy is shaped and managed on the ground.

Policy response

The consultation responses have not provided new or compelling evidence against the need for a policy to manage the delivery of vaccination and culling in the Edge area to optimise the opportunity to eradicate bTB over time. The rationale and evidence for making the proposed policy change are laid out in detail in the consultation paper, and additional information is set out below to address specific points raised by respondents. The government’s view remains that implementing no-cull zones to reduce the risk of vaccinated badgers being culled in the Edge Area will help manage the delivery of vaccination and culling in this area.

Although the consultation did not ask for views on badger culling as a disease control tool, many responses expressed anti-culling sentiments. The consultation only relates to reducing the risk of culling vaccinated badgers balanced with ensuring that culling can proceed where applications meet the licensing requirements to ensure that progress is made towards disease eradication. As highlighted in our response to the Godfray Review, the government is committed to moving to non-lethal control in the future and is continuing to drive this ambition forward.

On the issue raised relating to lack of evidence for vaccination as a method of disease control in badgers: No new scientific evidence has been presented to justify a change in our position that there is clear evidence that vaccination reduces disease in badgers. Although a trial of the effect of badger vaccination on cattle breakdowns has not been carried out in the UK, results of such a study from Ireland ² was recently published and showed that badger vaccination implemented after culling was not inferior to continuation of culling in four of the seven areas where it was implemented, and results were inconclusive in a fifth area. Further investigation in one area where vaccination was inferior to culling found that the presence of a cattle market and number of cattle movements through this market may have had an effect on the result, indicating that bovine TB is a multifaceted disease that needs to be managed with all interventions available.

On the concern that introducing no-cull zones would lead to large areas where neither vaccination nor culling of badgers would take place, it should be noted that within no-cull zones, vaccination can still take place (which would not be subject to an additional no-cull zone), so there is a badger control option available to farmers in that area.

In response to concerns that the proposals restrict the choice of individual farmers for what method of badger control to undertake on their land, we have sought to seek a balance in the proposal. For those fearful that the proposal would prevent future cull areas being licensed, we confirmed in the government’s response to the Godfray Review that epidemiologically-driven culling will still be an option where surveillance in badgers and cattle indicates re-emerging or persistent infection.

In relation to those responses stating that the protection of vaccination sites should not be restricted to the Edge Area, the Chief Veterinary Officer of England maintains the view that currently, in areas where TB is established in badgers, i.e. the HRA, culling is the preferred method for badger control.

In response to requests to increase the width of the no-cull zone, these arguments emphasised the need for a total reduction of the risk of vaccinated badgers being culled. But they did not place any weight on the effect much larger no-cull zones would have on the efficacy of the nearby cull area, often because they did not want culling to take place at all. Similarly, those who argued against no-cull zones did not consider the need to give some level of protection to vaccination sites. We were clear in setting out our proposal that the aim is to strike a balance between these two goals in order to better manage the delivery of adjoining vaccination and culling. No alternative has been put forward that meets this aim better than the approach in our proposal.

There was a suggestion that the maximum width of a no-cull zone should be reduced from 2km to 400-500m. The suggestions were made on the basis of trying to avoid large areas where no badger control might take place where there is a recognised reservoir of infection in badgers and that most vaccinated badgers will stay within this narrower zone width. The larger no-cull zone width was proposed for two complementary reasons. One being to incentivise vaccinators to focus on expanding areas rather than establishing many small new sites and the other based on the distance that scientific studies have shown badgers can roam. Recognising that vaccination schemes have considerable challenges to overcome to expand, such that to date there are no vaccination sites licensed larger than 5 km2 in the Edge Area, we do not believe that reducing the maximum width of a no cull zone would incentivise expansion.

We appreciate the difficulties raised surrounding the compliance with, and enforcement of, no-cull zones in the field, especially in situations where no-cull zone boundaries would cut across the middle of large fields. These issues could be alleviated to a large extent if no-cull zone boundaries were positioned along recognisable physical features. It was also suggested that some topographical features, such as major roads, are expected to significantly reduce badger movements. We have therefore decided to take a different approach to that set out in our proposal in this regard as a result of the consultation comments received. The Guidance has been amended (para 31) to give more clarity to the size of no-cull zones and to give Natural England flexibility to apply its discretion to take account of physical features in determining the boundary of no-cull zones, to reduce the risk of cull participants unintentionally breaching the conditions of a cull licence.

Focusing no-cull zones on main setts rather than vaccination sites is an attractive theoretical proposition in deciding the boundary of no-cull zones if a fixed width of zone was to be implemented. This would focus protection around the area where badgers are most likely to spend the majority of their time i.e. near to the sett. There are significant operational challenges that would need to be overcome before this could be implemented, such as robust criteria developed for identification of main setts, upskilling of surveyors to identify main setts, and mapping of main setts. Our proposals have a variable (rather than fixed) width of no-cull zone between a minimum and maximum depending on the size of the vaccination site and with the addition of the operational challenges to implementation we have decided not to take on board this alternative approach on the centring of no-cull boundaries.

The issues raised on the proposal to allow culling (by cage trapping and shooting) of un-marked badgers within the no-cull zone, related to concerns over compliance and monitoring. Therefore, the government would not want it to be implemented until a robust method to both mark badgers and ensure compliance has been validated. The Guidance has been amended (para 32) to include this proposal that we consulted on. However, we have made it clear that, cage trapping and culling of un-marked badgers within a no-cull zone can only be implemented when Natural England is satisfied that a robust method has been validated.

Concerns that the 2.7 badgers per km2 criterion to qualify for a no-cull zone is too high does not take into account the fact that licensed vaccination sites tend to focus on specific areas where there are badger setts. In contrast, cull areas (which generally achieve removal of 2.7 badgers per km2 in the first year of operations) must cover more diverse terrain and don’t have access to 100% of the land within the cull area. Furthermore, this benchmark is already being met by existing vaccination schemes: Data on vaccination in 2019 shows that average number of badgers vaccinated per km2 in England was 3.9 badgers per km2 and within the Edge Area the average was 3.0 badgers per km2 (see, summary of badger vaccination in 2019. Thus, a figure of 2.7 badgers per km2 is not an unreasonable benchmark, particularly given the fact that Natural England will have discretion to alter this figure if local conditions indicate it is inappropriate, therefore we do not think this criterion is too onerous. The Guidance has been amended (para 30c) to increase clarity regarding sites smaller than 2.25km2.

In relation to concerns raised over the loss of confidentiality for vaccination site landowners/occupiers, no-cull zones would not be implemented without their express permission. No-cull zones cannot be implemented without informing cull companies of their location. Sharing the location of no cull zones, without permission of both the vaccination site landowners/occupiers and vaccination licence holder would be a breach of the confidentiality agreement which is put in place when a vaccination licence is issued. The vaccination site licence holder would not need to contact the cull company at any point; Natural England would apply the no-cull zones as part of the cull licence conditions. The Guidance has been amended (para 29) to make it clear that only no-cull zones (rather than vaccination site boundaries) are to be disclosed to cull companies.

In response to the concerns about conflict between neighbours that no-cull zones could cause, both landowners/occupiers of vaccination sites and the vaccination licence holders must agree to the implementation of a no-cull zone. This requirement ensures the landowner/occupiers can vaccinate without a no-cull zone if they so choose.

Operational response

Having consulted Natural England, the Environment Agency and members of the public in accordance with section 15(3) of the Natural Environment and Rural Communities Act 2006, the government has published new Guidance to Natural England on licences to control the risk of bovine tuberculosis from badgers. This Guidance incorporates the proposed changes which were consulted on together with amendments to those proposals which have been made having considered and taken into account responses to the consultation, as explained in this government response.

Natural England must have regard to this Guidance when considering any licence applications, from 17 August 2020, to kill or take badgers for the purpose of preventing the spread of bovine TB under section 10(2)(a) of the Protection of Badgers Act 1992.

Summary of changes to the guidance

Culling policy requirement

Addition of section 10 to state that vaccination sites located wholly or partially in the Edge Area that meet minimum criteria will benefit from no-cull zones around that part of the vaccination site located in the Edge area, proportionate to the size of the vaccination site located in the Edge Area ³. This may have an impact on cull areas (both in the HRA and in the Edge area) near those vaccination sites.

Supplementary badger disease control requirements

Addition of section 16 to also that vaccination sites located wholly or partially in the Edge Area that meet minimum criteria will benefit from no-cull zones around that part of the vaccination site located in the Edge area, proportionate to the size of the vaccination site located in the Edge Area. This may have an impact on cull areas (both in the HRA and in the Edge area) near those vaccination sites.

Vaccination policy requirements

Amendment of section 28d to state 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.

Addition of section 29 stating that where vaccination is taking place on land within Edge Area counties, vaccination licence applicants must determine whether landowners/occupiers of licensed vaccination sites wish to have no-cull zones surrounding those sites and, if they do, to disclosure of no-cull zones around those vaccination site(s) that meet the criteria in paragraph 30 to cull companies applying for adjoining badger control licences.

Addition of section 30 to state that Where vaccination is taking place on land within Edge Area counties and a Badger Disease Control or Supplementary Badger Disease Control licence is applied for in respect of land adjacent to such a vaccination site, any licence subsequently issued will require a no-cull zone to be put in place when the following criteria are met:

a) The vaccination site was licensed at the closure of the previous open season for cage trapping, i.e. 30th November

b) The landowner/occupier and vaccination licence holder have requested a no-cull zone be put in place around the vaccination site and given consent for the location of the no-cull zone to be provided to cull companies

c) The number of badgers vaccinated on the site in the previous year is comparable to the minimum number that would need to be removed during a culling operation. Where the vaccination site is smaller than 2.25km2, the minimum number of badgers which need to have been vaccinated should be equivalent to the number of badgers required to be vaccinated on a site which is 2.25 km2

Addition of section 31 to state that no-cull zones, where implemented, will have a maximum width of 2km and a minimum width of 200m, and be of approximate equivalent size to the vaccination site. The boundaries of no-cull zones should be set where, in Natural England’s judgement, suitable recognisable physical features or hard boundaries occur.

Addition of section 32 to state that when, in Natural England’s judgement, a validated method to mark vaccinated badgers for a full season has been developed cage trapping followed by shooting of unmarked badgers should be permitted in a no-cull zone.

Addition of section 33 to state that No-cull zones will be re-evaluated each year of the Badger Disease Control or Supplementary Disease Control Licence. Where sufficient badgers are not vaccinated in the relevant vaccination site (using the text in criterion (c) in paragraph 30 above) in the preceding year, the no-cull zone will be removed

Annex A: List of organisations who responded to the consultation

• Animal Aid
• Badger Trust
• Badger Trust Gloucestershire
• Badger Trust West Sussex
• Binfield Badger Group
• Born Free Foundation
• British Cattle Veterinary Association
• British Veterinary Association (BVA)
• British Veterinary Zoological Society (BVZS)
• Buckinghamshire Badger Group
• Calderdale Badger Protection Group
• Central Association of Agricultural land vehicles
• Cheshire Badger Vaccination Programme
• Cornwall Wildlife Trust
• Derbyshire Against The Cull
• Derbyshire Farm Vets Limited
• Derbyshire Wildlife Trust
• Devon Badger Group
• Dorset badger and bovine welfare
• Dyfi Badger Group
• Essex Badger Protection Group
• Greens for Animal Protection
• Hampshire & Isle of Wight Wildlife Trust
• Herts and Middlesex Badger Group
• Humane Society International/UK
• Lancashire Badger Group
• League Against Cruel Sports
• Leeds and District Badger Group
• Leicestershire and Rutland Badger Group
• Leicestershire and Rutland Wildlife Trust
• Lincolnshire Wildlife Trust
• National Beef Association
• National Farmers Union
• National Farmers Union SW Tenants Forum
• National Federation of Young Farmers’ Clubs
• Natural England
• North East Essex Badger Group
• Nottinghamshire Wildlife Trust
• Office of the Police & Crime Commissioner for Derbyshire
• Oxfordshire Badger Group
• Rethinkbtb
• Royal Society for the Prevention of Cruelty to Animals
• Shropshire badger group
• Shropshire Badger Vaccination Project
• Somerset Against the Badger Cull
• Somerset Badger Group
• Somerset Wildlife Trust
• Staffordshire Badger Conservation Group
• Tawny Croft Wildlife Consultants
• Tenant Farmers Association
• The Agricultural Chaplains Association
• The National Trust
• The Wildlife Trusts
• Vet Partners
• West Kent Badger Group
• Westpoint Farm Vets
• Wood Veterinary Group
• Zoological Society of London (ZSL)

Contact us

Any enquiries regarding this publication should be sent to us at:

bTBengage@defra.gov.uk

or

TB Programme, Defra
Area 5D, Nobel House
17 Smith Square
London SW1P 3JR

1. Ham C, Donnelly CA, Astley KL, Jackson SYB, Woodroffe R. Effect of culling on individual badger Meles meles behaviour: Potential implications for bovine tuberculosis transmission. J Appl Ecol. 2019;56:2390–2399. https://doi.org/10.1111/1365-2664.13512 ↩

2. Martin SW, O’Keeffe J, Byrne AW, Rosen LE, White PW, McGrath G. Is moving from targeted culling to BCG-vaccination of badgers (Meles meles) associated with an unacceptable increased incidence of cattle herd tuberculosis in the Republic of Ireland? A practical non-inferiority wildlife intervention study in the Republic of Ireland (2011-2017). Prev Vet Med. 2020;179:105004. https://doi:10.1016/j.prevetmed.2020.105004 ↩

3. Where a vaccination site is located partially in the Edge Area and partially in the HRA, a no-cull zone will only be applied to the Edge Area part of the vaccination site and will be of equal area to that Edge area part. The no-cull zones in these cases extend into the HRA in order that a no-cull zone is provided around the whole of the vaccination site whih is located in the Edge Area. ↩