RDC(3) BTb3

Rural Development Sub-Committee

Inquiry into Bovine Tuberculosis

Response from Radnorshire Badger Group

From: Bryan Price [bryan_price@talk21.com]
Sent: 12 September 2007 20:16
To: Sustainability.comm
Subject: TB in Wales

Attachments: 1719604474-NAW tb response Feb04.doc

FAO Virginia Hawkins.

Radnorshire Badger Group,
PO Box 8,
Knighton,
Powys,
LD8 2AD.

Response to inquiry into TB in Wales - Rural Development Sub-committee.

The Radnorshire Badger Group (hereafter referred to as RBG) wishes to submit the following views on a) the report of the ISG and b) the implementation of the EPC Committee’s recommendations.

a) The report of the ISG.

The RBG welcomes the ISG report and its

recommendations and would wish to draw particular attention to 10.92 and 10.93 of the report being the overall conclusion "that after careful consideration of all the RBCT and other data presented in this report, including an economic assessment, that badger culling cannot meaningfully contribute to the control of cattle TB in Britain” and "further from the scientific evidence available, that the rigorous application of heightened control measures directly targeting cattle will reverse the year-on-ear increase in the incidence of cattle TB and halt the geographical spread of the disease”.

b) The implementation of the EPC Committee’s recommendations.

Recommendation 1

We welcome the view that "measures should be developed in partnership with all stakeholder groups and based on current scientific knowledge”. We would assume the ISG report forms "current scientific knowledge”. We welcome the adoption of the various measures listed at 3.8 of the EPC Committee’s report.

Recommendation 2

Our comments on the establishment of an 'Intensive Treatment Area’ would centre on the ISG findings of the problems of perturbation effects when badgers are removed from an area (see ISG report 5.47, 48, 49, 50 and 10.45, 45 and 47.) RBG would also like to stress that, to date, there is no reliable live tb test for badgers and question the practicality of cleaning potentially infected areas. RBG believes that a voluntary bio-security audit was conducted by vets in 100 square kilometres centred in Narbeth but we have yet to see any published findings.

Recommendation 3:

As recommendation 2 has not been fully implemented it follows that neither has recommendation 3. RBG has concerns, however, regarding the wording of recommendation 3 and would seek further clarification of "following evaluation, it proves useful”. RBG would wish to have confidence in the evaluators and would question the terminology "useful”as enough of a trigger to roll out any intensive treatment to other areas of Wales. RBG would again stress the ISG findings concerning small treatment areas (see ISG 5.39 and 5.48).

Recommendation 4

RBG notes that a Wales TB Action Group has been set up but must register disappointment as no badger group representative became a stakeholder on the Action Group, badger groups in Wales being represented by the Welsh Wildlife Link member. Because of this we feel unable to usefully comment on the implementation of the remit of the Wales TB Action Group.

Recommendation 5

RBG would hope to see the measures detailed in the ISG report "Options based on cattle controls” 10.57 - 10.88 be taken forward. The ISG conclude (at 10.90) that ”Vaccination of either cattle or badgers can be considered only as a long term option for the control of cattle TB”.

For your information, please find enclosed a copy of our February 2004 response to the EPC’s Committee Inquiry. (Please note that since this response was submitted, the National Federation of Badger Groups (NFBG) has changed its name to Badger Trust).

RBG/12.09.2007.

enc.

Radnorshire Badger Group
PO Box 8
Knighton
Powys ID7 1WN

Response to inquiry into bovine tuberculosis [m. Bovis]

Environment, Planning & Countryside Committee
Welsh Assembly

Introduction

The Radnorshire Badger Group (hereafter referred to as RBG) is a Charity formed by a group of volunteers who have been involved in:-

• carrying out regular badger sett surveys in Radnorshire for the last 10 years using the method approved by the NFBG and the Mammal Society
• contributing to the national database on badger numbers and distribution
• providing advice and practical help to Powys CC, landowners, RSPCA, Dyfed/Powys Policy, Welsh Water and others on issues relating to badgers
• facilitating the rehabilitation of injured or accidentally trapped badgers

Our data suggests that the underlying population level remains broadly constant subject to annual fluctuations resulting from natural influences e.g. weather.  We have seen no evidence of a significant increase in numbers in Radnorshire.
We welcome this review being undertaken by the Committee and hope it will lead to a practical way forward which reflects the scientific evidence.  We would very much welcome a more open and up-to-date system, available to interested parties, of information on testing, regulations, herd breakdowns, and management controls.

Science of M. Bovis

RBG are aware of and fully endorse the views and opinions of the National Federation of Badger Groups in respect of these issues.  We do not wish to add to those comments.
Animal health and welfare, bio-security and animal husbandry
We wish to comment on a number of specific aspects on which the Committee are seeking views.

Role of farmers

Farmers in Mid-Wales are generally conservative and appear to adhere firmly to traditional farming practices [with some notable exceptions, e.g. converting from hay to silage]. Attitudes towards and opinions about the relationship between farming and wildlife are very much a part of this traditionalism and there is a reluctance to accept current scientific information. Under the current CAP regime where subsidies are paid on a production basis, our experience is that most Mid-Wales farmers look to maximising their income by high stocking levels.  Losses/restrictions, either of sheep/lambs or cattle are, inevitably, seen as major problems. Under these circumstances most farmers normally want instant solutions to any animal health problems and changes to their farming methods may not be seen as an acceptable way forward.  

We recognise that under the new CAP rules, payment will be through a  single farm payment [SFP] which will break the link with productivity payments.  When this comes in, it has the potential, if promoted appropriately through ARAD, to develop smaller flock/herd sizes and an increase in the quality of stock.  Under these circumstances it is possible that the traditional farming approaches can be modified to better manage animal husbandry and biosecurity leading to the adoption of the acceptance of better ways of dealing with the bTB issue.  However, in view of the high level of traditionalism, we are certain that it will require a clear and strong lead to be provided by ARAD if this positive change is to be accepted.

Guidance given to farmers on bio-security and husbandry measures to control/manage bovine TB etc.

As indicated above, our view is that a very strong lead needs to be provided by ARAD as a precursor to the publishing of further guidance on bio-security or husbandry.  In our experience the general simplistic view held by our local farming community is that badgers are the cause of bTB in cattle.  As far as we are aware there is no direct evidence in Radnorshire to support this view and from the location of cases in the County, it is clear some of them, at least, are patently as a result of cattle movements.  

Experience locally suggests that the concept of bio-security is either not understood or not considered important enough to properly implement.  Recent examples of this are:

a farmer taking 4 days to remove and/or locate owner of 'foreign’ cow found with his stock, despite both his farm and neighbouring ones being under restriction for a suspected bTB outbreak [proved negative].  

• c.50 dead sheep found piled up in a small woodland near Hundred House
• a deep pit containing dead sheep in East Radnorshire
• and many dead sheep left lying in the countryside.

On farm medium term storage in barns and sheds [not silo’s]  of bulk [blown in] tanker delivered feed stuff for sheep and cattle gives access to this feed to wild and domestic animals, and encourages animals to be around farm yards and buildings.

There is a significant and increasing amount of farm traffic on the lanes and roads, few, if any of which, appear to have been disinfected. In local markets stock vehicle disinfection washing  is allowed 'on-farm' and is farmer regulated.  We suggest that the requirements for disinfection of farm vehicles, including random testing, should be reviewed.  In our view it should be more rigorous in areas where outbreaks occur or have been suspected.   

The majority of cattle in Radnorshire are out-wintered and fed silage; yet those confirmed cases of bTB for which we have a confirmed source, have been linked to imported animals.  We believe that it would seem reasonable that pre-movement testing ought to minimise this risk [see Management Controls: current testing regime].

Reduced farming in areas with high TB prevalence

We assume that this question relates to reducing cattle numbers, rather than reducing all farming activities.  We acknowledge the importance of cattle as part of the mixed farming of Radnorshire and that, in the right habitats, cattle can play an important role in maintaining a wildlife rich area.  We would not wish to see a reduction in the numbers of cattle.  However, we would wish to see a move towards support for native breeds which are more capable of grazing in sympathy with our habitats in the County.  We believe that rather than looking at a reduction in farming, a wide range of bio-security, husbandry and new approaches emerging from the development of vaccines etc,  would minimise the problem and reduce it to a level which is manageable.

Interface of TB testing with other farm and food chain programmes

bTB is generally not considered to be of concern for consumer health , provided milk is pasturised. Thus, we do not see testing as a specific requirement on current evidence in relation to bTB, but we would support it in the wider context of 'traceability'. This may also assist with the restoration of the broken link between farmer [producer] and consumer.

Management Controls

Current testing regime

We would support the principal of increasing the testing frequency of all cattle and would totally support the idea of testing and waiting for results for all cattle before they moved off farm. We note, however, that the National Audit Office reports that 2% [200,000] of annual cattle movements are not reported.  If the NAO figures are correct, then it is imperative that improvements are made in the testing and movement regimes.  We also question whether the reported level of cattle movement is necessary, particularly as it would appear from FMD information that many such movements do not benefit the farmer concerned but for the benefit of 'middle men’.  Further, there is strong evidence that moving stock can precipitate an outbreak of bTB, as the disease is known to be triggered by stress.   We would see little point in increasing the frequency of testing 'hot spots' if these are artefacts of the system, but would support more frequent testing of all animals.

While agriculture continues to be high industrialised and global in scale, and in view of the above, it seems impractical to suggest that water-tight tracking systems can be put in place and therefore thorough and reliable pre-movement testing appears to be a necessity.

Use of lay testers

We do not object to the use of properly trained lay testers.

Use of RTA Surveys

We endorse the NFBG comments on this issue.  See NFBG submission para: 4.15.

Organisational arrangements

We would support better co-operation and integration between relevant organisations in the agricultural industry particularly if this resulted in more open and up-to-date dissemination of information to all interested parties.

Wales specific management controls

We cannot envisage how a Wales-specific management system could be a practical option since there are no border controls between Wales and England, and indeed some farm holdings straddle the border.

RBG/13 February 2004