Guest blog – Licensed Badger Killing; Ethical Considerations by Alick Simmons

Alick Simmons is a veterinarian, naturalist and photographer.  He lives in Somerset. He has written several guest blogs here: The Ethics of Animal Exploitation 1, 2, 3, 4 and UK Guardians of Animal Welfare. His Twitter handle: @alicksimmons

Licensed badger killing is an integral part of the Government’s strategy to eradicate bovine tuberculosis (bTB) from the cattle herd in England (Ref 1): the aim is to achieve Officially Tuberculosis Free status, the European Union standard for disease freedom, by 2038.   According to Defra ‘The strategy sets out a comprehensive and adaptive, risk-based and staged approach informed by the best available evidence and scientific and veterinary advice, and drawing upon demonstrably successful approaches to address bovine TB from around the world.’ Since publication there have several initiatives including dividing the country into zones based on disease risk in cattle, stepping up movement controls and testing in some areas, increasing the deployment of alternative tests for cattle and the introduction of licensed, systematic killing of badgers. However, control efforts began almost 100 years ago and compulsory eradication started in 1950. Hence the objective of the strategy, which is silent on the ethics of the killing of native wildlife, is essentially a restatement of the original objective from 1950. 

The policy draws on evidence from the Randomised Badger Culling Trail (RBCT) which concluded that under certain conditions killing badgers reduces bTB incidents in cattle herds (Ref 2).   Recent analysis shows reduced incidents in cattle in areas subject to badger killing since 2014 (Ref 3).  However, interpretation of these results is controversial and scientific opinion about the value of the badger killing policy is, at best, divided (Ref 4).  Further, the reduction, while statistically significant, is small and considerably smaller than is necessary to achieve the stated aim of eradication by 2038.

Since the first licences were issued in 2014, more areas have been granted licences and, as of late 2019, the area affected covers 21,458 km² (roughly 16% of England and somewhat larger than Kruger National Park, the second-largest national park in Africa)(Ref 5). 

The ethics of killing native wildlife

The killing of native wildlife particularly when it is partially taxpayer-funded and conducted over a wide area is likely to be controversial.  The policy is perhaps the only current Government-sanctioned campaign against a native mammal in the developed world.    The evidence base that supports the killing and the means by which they are killed have separate but linked ethical considerations and hence the robustness of the science and the welfare of the badgers being targeted have come under close scrutiny.

Despite that the licences provide for a sustained reduction in numbers no greater than 70%, killing badgers on this scale causes local and area extirpation. While the badger is unlikely to become endangered numbers are sharply reduced across an increasingly large area.

Objections fall into 5 broad categories:

• Controversy about the aims and objectives of eradication on the grounds it is neither necessary nor practicable.
• Objections to the systematic of killing of badgers on the grounds that badgers are native wildlife and occupy an important place in the UK’s ecosystem.
• Objections to the secrecy that surrounds the programme.
• Objections to the lack of local consultation and information available to residents of licensed killing areas.
• Objections arising from concerns about the welfare of badgers being shot or trapped and shot. 

On the other hand, there are legitimate concerns about the financial impact on farm businesses where bTB is disclosed in cattle as well as concerns about the well-being of the individuals and families whose livelihoods are threatened by the protracted nature of the eradication programme.

Vaccines for both cattle and badgers are advocated by many.  Injectable badger vaccines are being used but on a much smaller scale than killing.  Widespread badger vaccination is likely to need an oral bait to be practicable at the landscape level and is some years away.  Cattle vaccines are some years away from being a practical proposition.   Farmers are generally resistant to both options.

In summary, the programme is controversial and for several reasons.  An ethical approach provides the means to consider both scientific and social aspects.  An example of such an approach was developed by Dubois and others (2017)(Ref 6); the framework advocated by the authors can be applied by answering a series of questions:  

1. Can the problem be mitigated by changing human behaviour?

Yes.   Things can be done.  However, the livestock sector is unlikely to advocate or adopt such changes while the current policy provides no incentives or sanctions.  Alternatives might include the following:

• Manage the risk rather than the hazard: The current policy includes eradication, that is the elimination of the hazard.   However, effective risk management does not always require the hazard elimination.  For example, incidents involving motor vehicles kill or injure several thousand people every year.  Rather than banning the motor vehicle, because of its utility, we have employed innovation and education to reduce the risk.   However, while there are motor vehicles, it is unlikely that the risk of human injury will ever be eliminated.   Society accepts some risk.  Such an approach could be considered for bTB.  Indeed, the original reason for intervening, starting in the 1920s, was to protect public health.   It remains the primary risk but it has been effectively controlled since the 1960s. See Annex 1.
• Make changes to farming practice to reduce the risks of transmission: These include:
  • Adopting cattle husbandry practices that rely on fewer movements of cattle on and off the farm.
  • Stop sourcing cattle from known affected areas.
  • Manage the risk from off-grazing or stop altogether.
  • Make changes that reduce the risk of transmission between badgers and cattle and vice versa:  There are numerous, simple ways that can reduce direct and indirect contact between cattle.  Government has been providing advice on this for many years.   There is little evidence that it is taken up.
• Make changes that make the farm environment less favourable for badgers.   As well as legal protection, other factors influence badger numbers:  Livestock husbandry, particularly on dairy farms, has changed dramatically since the 1960s: herd size, the distribution of livestock, the nature of pasture and its management, the feeding, grazing, breeding and housing of cattle have all changed.  Farmers, as well as providing optimal conditions for cattle, may be providing optimal conditions for badgers.  A better understanding of these factors is required to develop more sustainable farming practices which take account of the presence of wildlife.

2. Are the harms serious enough to warrant wildlife control?

This is a contentious point with opinion divided on philosophical positions. Many veterinarians and farmers believe that leaving a focus of infection in wildlife is anathema.  But the gains in disease control from badger killing are marginal, difficult to sustain, unlikely to lead to eradication and offer a poor cost-benefit. 

Ceasing licensed badger killing, in the absence of any other intervention, would leave an infected population at least in the short term; it will be argued that leaving a reservoir of a zoonotic infection in wildlife is irresponsible since it represents a hazard to public health.  However, there are many reservoirs of zoonotic infection in wildlife.  For example, European Bat Lyssavirus (present in several British bat species), Lyme Disease (deer), Tick-borne encephalitis (mice and voles), etc.  In mainland Europe, zoonotic diseases such as West Nile Fever (various species of wild bird), rabies (fox) and Crimean-Congo haemorrhagic fever (various species of mammals) are present.  In none of these cases is the wildlife reservoir targeted for destruction.  The risks are variously managed by taking into account the means of transmission and the risk to public health. 

The primary means of transmission of bTB organism to humans is the ingestion of raw, infected cows’ milk.  The direct risk from badgers is very low.    A strategy which manages the risks is likely to be sustainable, cost effective and avoid the need to kill native wildlife.  See Annex 1.

3.  Is the desired outcome clear and achievable, and will it be monitored?

It is very unlikely that the strategy will succeed.  This is because:

• The Government continues to apply a disease control regime better suited to a shrinking epidemic. A sustainable approach accepts that disease in endemic and adopts a strategy which manages the risks while protecting better those areas free of disease.
• The Government is relying, primarily, on a testing regime which is failing to detect and remove all infected cattle.  Setting the cut-off point for the interpretation of the test at a point that maximises specificity to the detriment of sensitivity exacerbates this effect (although there has been some tightening of this recently).
• The Government’s policy of licensing the killing of badgers fails to recognise that, under the current state of knowledge, only the complete elimination of the badger (or the organism from the badger) will be sufficient to eliminate the risk of cattle becoming infected.  Although, the RBCT determined that declines of 70% from carrying capacity reduces bTB in cattle, leaving a substantial proportion of badgers behind will mean that the infection will not be eliminated. 
• The Government has failed to research the factors that influence badger populations including changes to land use and livestock husbandry, and climate change.

The strategy includes no interim targets and no exit strategy making it impossible to monitor success or otherwise.

4.  Does the proposed method carry the least animal welfare cost and to the fewest animals?   

Probably not. The 2014 pilot trials were planned with careful consideration given to killing methodology and monitoring.  On behalf of Government, an independent expert group (IEG) was charged with overseeing the pilots and their published report, drawing on data collected across the two pilot areas is detailed and clear[vii]. The IEG concluded that ‘We have very high confidence that robust monitoring protocols were put in place to monitor the effectiveness and humaneness’ and ‘We have very high confidence in the data collection and analysis performed by [the Government]….’   However, the IEG expressed concerns about the welfare of so-called ‘controlled shooting’:  ‘Evidence suggests that between 7.4% and 22.8% of badgers that were shot at were still alive after 5 min and therefore were at risk of experiencing marked pain and that ’if culling is continued …… standards of effectiveness and humaneness must be improved. Continuation of monitoring, of both effectiveness and humaneness, is necessary to demonstrate that improvements have been achieved.’

Despite this advice, the proportion of ‘controlled shooting’ monitored by the Government is substantially lower than during the 2014 pilots.  The number of observed shooting of badgers in 2014 is broadly similar to 2018 (the most recent data available) despite the number killed by controlled shooting in 2018 being over 20 times greater (Ref 8).  The killing is co-ordinated over a short period meaning that many shooters have to be deployed. Without a significant increase in monitoring, the effectiveness and humaneness of each shooter cannot be determined.   It is impossible, therefore, to determine whether the method carries the least welfare cost.  In the absence of representative data it is prudent to conclude that it is not.

5.  Have community values been considered alongside scientific, technical, and practical information?  

No. The arguments used to support licensed killing of badgers take no account of the social value of the badger and the environment in which it exists.  Conservation concerns have been brushed aside since, even after systematic killing over a large area, the badger is not considered to be threatened. It is seen entirely as a technical problem and analysis of costs and benefits are solely financial.

Much of the decision making nationally and locally is conducted in secret.  Licences are granted to private companies; the name of the company and those of the company directors and its accounts are secret. When new areas are being considered and the company directors only those occupying a substantial land-owning are consulted (how substantial an area is unclear).  Other residents are neither consulted nor informed.  Unlike other public- or privately-funded activities which make substantial changes to the local environment,  for example, road building, house building, ‘fracking’, mining, nuclear power generation, solar and wind farms, the entire programme is shrouded in secrecy.  The locations of the areas licensed for killing, the dates of the start and end of each killing season and the names of those involved are kept secret. 

The secrecy is considered necessary because of the perceived threat of disruption by those who are opposed to badger killing.  The secrecy and lack of engagement continues despite rulings from the Information Commissioner who believes that the potential for disruption should not override the publication of information about the programme of killing (Ref 9).  

6.  Is the control action part of a systematic, long‐term management programme?

No. Licensed badger killing is part of the Government’s strategy for eradication by 2038 but there are serious flaws in the programme:   

• Disease eradication is very different to disease control.  Experience of animal disease eradication campaigns shows that, with effective intervention, there is a sharp reduction in incidence within one to two incubation periods.  The strategy’s failure to demonstrate this sharp reduction despite 5 years of badger killing indicates that badger killing as currently practiced contributes little to control and even less to the goal of eradication.
• Until consideration is given to more draconian controls such as more robust cattle movement controls, more frequent cattle testing and more severe test interpretation then there will be little substantial change to national prevalence of infection in cattle.  However, each of these interventions, alone or in combination will increase the number of cattle which are compulsorily slaughtered and increase the administrative burden and business disruption on affected farms. 
• It is almost 70 years since compulsory eradication began; the ethics of gradually increasing these controls with the associated commercial and psychological burden on those affected has to be questioned, particularly as it is the impact of these controls rather than the disease itself that causes the greatest disruption to farm businesses.

7.  Are the decisions warranted by the specifics of the situation rather than negative labels applied to the animals?

No.  The badger, while it enjoys comprehensive protection and is regarded in fondly in folklore and by a large proportion of the public, has been characterised largely by farming interests as destructive, dirty, diseased and a threat to ground nesting birds and hedgehogs. 

Conclusion

Badger killing in England does not follow international ethical principles for wildlife control.   The policy is unethical because:

• There is no robust evidence on the contribution that killing numbers of badgers make to the objective of eradication.
• Practical alternatives to managing the public and animal health risks have not been evaluated.
• There is no exit strategy.
• There is insufficient monitoring of killing to ensure that it is being done humanely. 
• The social and environmental value of the badger is not being taken into account,
• The policy is shrouded in secrecy.
• Residents are not consulted and excluded from any decision making. 

An alternative approach is needed.  However, doing nothing is not being advocated.  An ethical review process with proper governance and sufficient resources, similar to that used by animal ethics committees when assessing the acceptability of scientific research, must be used to address legitimate social concerns about the bTB control policy.   This would include better cost-benefit analysis including the social value of our native wildlife and formal risk assessment.  It should also take into account the unsustainable annual  taxpayer expenditure and the financial and business impact that the programme has on farm business.  This offers the prospect of a sustainable policy reflecting the aspirations and values of society as whole rather than solely the interests of a vocal minority.

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[1]       Defra (2014) The Strategy for achieving Officially Bovine Tuberculosis Free status for England https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/300447/pb14088-bovine-tb-strategy-140328.pdf

[2]      Bovine TB: The Scientific Evidence  A  Science Base for a Sustainable Policy to Control TB in Cattle: An Epidemiological Investigation into Bovine Tuberculosis. https://webarchive.nationalarchives.gov.uk/20081108133322/http://www.defra.gov.uk/animalh/tb/isg/pdf/final_report.pdf

[3]     Downs, S.H., Prosser, A., Ashton, A. et al. Assessing effects from four years of industry-led badger culling in England on the incidence of bovine tuberculosis in cattle, 2013–2017. Sci Rep 9, 14666 (2019) doi:10.1038/s41598-019-49957-6.

[4]    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

[5]      Data obtained by the author in response to a Freedom of Information request to Natural England.

[6]    Dubois, S., et al. (2017) International consensus principles for ethical wildlife control, Conservation Biology, doi 10.1111/cobi.12896.

[7]  Munro, R , and other (2014) Pilot Badger Culls in Somerset and Gloucestershire. London: Report by the Independent Expert Panel.

[8]   Natural England: Summary of badger control compliance monitoring during 2018 https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/765444/badger-control-monitoring-2018-annexb.pdf

[9]     https://theecologist.org/2016/apr/01/badger-cull-protestors-legal-right-information-upheld

[10]     http://www.eblex.org.uk/wp/wp-content/uploads/2013/06/Cattle-Health-and-Welfare-Report.pdf

[11]    H. Charles J. Godfray, Christl A. Donnelly, Rowland R. Kao, David W. Macdonald, Robbie A. McDonald, Gillian Petrokofsky, James L. N. Wood, Rosie Woodroffe, Douglas B. Young, Angela R. McLean (2013) A restatement of the natural science evidence base relevant to the control of bovine tuberculosis in Great Britain. Proc. R. Soc. B 2013 280 20131634; DOI: 10.1098/rspb.2013.1634.

Annex 1

Risk management of bovine tuberculosis

The risk to public health is, despite the sustained increase in incidence in cattle, well managed.  This is due to the near universal heat treatment of dairy products and the frequent testing and removal of affected cattle.     There is a small residual occupational risk to farmers and others.  

The animal health risk, particularly to cattle, is substantial.   In England, around 30,000 cattle are compulsorily slaughtered annually because of bTB.  However, this should be compared to culling of dairy cattle for other reasons.   Studies suggest that approximately, 240,000 dairy cows per year are culled prematurely because of infertility, mastitis and lameness (Ref10)^. The frequency of testing and removal of reactor cattle at an early stage of infection means that the risk of clinical disease is very low.   In the absence of other effective interventions, a substantial reduction in periodic testing would cause, in the medium term, an increase in clinical disease with associated threats to animal welfare and productivity.    This is not being advocated.

The risk to wildlife health is difficult to estimate.  Estimates of the prevalence of Mycobacterium bovis infection in badgers are difficult but estimates from post-mortem examination and culture in the RBCT vary between 2 and 38%.   M bovis can be transmitted to badger populations from infected cattle but there is insufficient evidence currently available to say definitively whether the disease can persist in British badger populations without on-going transmission from cattle.  Badgers can survive several years infected with M bovis but a small proportion will develop severe infection.  M bovis can infect a range of wild mammals in Great Britain in addition to badgers but are not thought to represent a significant risk to cattle (Ref 11).

An alternative approach that takes account of the above risks should include the following: 

1. Public health protection at least as effective as the current policy.   Heat treatment of dairy products and meat hygiene controls would continue.
2. Animal health controls sufficient to:
   1. Reduce the risk of clinical disease developing in cattle
   2. Protect the Low Risk Area (LRA) from infected cattle. This would be achieved by:  a) In the High Risk Area (HRA) and Edge Area, periodic testing and removal of reactors but no compulsion to achieve OTF status and improved testing, particularly to detect asymptomatic infections; b) In the LRA, periodic testing and maintenance of OTF status (or re-attainment where lost); c) Free movement of cattle between farms in the HRA allowing for re-stocking; d) Prohibition of movement from HRA and Edge Area to LRA (with exceptions for herds with history of freedom and low risk of infection)
3. Wildlife health. 
   1. Research into badger population dynamics with the objective of understanding drivers including land use, livestock husbandry, climate change
   2. Research into farming systems to determine risk factors for transmission between cattle and badgers (and vice versa). 
   3. Pending the outcome on of 3a and 3b, a moratorium on the systematic killing of badgers. 

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