Northern Ireland Badger Cull Consultation

TAKE ACTION: Northern Ireland Badger Cull Consultation

DAERA is consulting on plans to start culling badgers in Northern Ireland. This is your chance to speak up. The consultation closes on Friday 9 October.

We’ve made it quick and easy to respond. Using the form below, you can send your personal response directly to DAERA in under 30 seconds.

PLEASE NOTE: If you’re having trouble using our email tool (for example if it’s not loading properly, removing the line breaks, or recipients aren’t displaying), simply copy and paste the message below (and add your full name), and send it directly from your email to: TB.Consultation@daera-ni.gov.uk

You may want to alter the response to question 5 to suit your own circumstances.

First Name

Surname

Your Email

Subject

Message

3. Are you responding on behalf of an organisation in an official capacity?

No.

4. Please state which of the following best describes your interest in bovine tuberculosis.

Member of the public

5. Are there any comments on equality or disability issues you wish to raise?

6. Are there any comments on the social and economic needs of persons in rural areas that you wish to raise?

Yes.

"Rural needs" are frequently oversimplified as relating solely to the farming sector and agricultural economics. However, the economic needs of rural areas extend far beyond large-scale livestock farming. Decision-makers must recognise that "rural needs" include the protection of local biodiversity and the mental well-being of rural residents who advocate for coexistence with wildlife.

7. Are there any comments that you wish to raise regarding the HRA Report?

Yes.

The HRA Report does not provide sufficient assurance that the potential impacts of the proposed wildlife intervention on European sites have been adequately assessed.

8. Are there any comments that you wish to raise regarding the SEA Report?

Yes.

The SEA Report clearly demonstrates that any culling strategy directly conflicts with Northern Ireland’s environmental and biodiversity objectives.

- Negative Impacts on Biodiversity: Table 0-3 in the report explicitly marks all Non-Selective Culling methods as having a negative (-) impact on the Strategic Environmental Objective (SEO) for Biodiversity, Flora, and Fauna (BFF). The department should not progress policies that its own environmental assessment defines as ecologically damaging.

- Wounding and Welfare Risks: Section 2.7.2.4.1 references historical data from Independent Expert Panel (IEP) reports, highlighting that between 7.4% and 22.8% of badgers were estimated to remain alive for more than five minutes after being shot, causing severe wounding and unnecessary suffering. The report admits that controlled shooting presents "notable humaneness challenges," which represents an unacceptable animal welfare risk.

- Support for Vaccination Only: The SEA notes a distinct exception for the Vaccination Only strategy, stating it has the potential for positive effects by improving overall badger health and addressing bTB infection "without a requirement for a large population reduction within intervention areas".

9. Do you agree with the Department that a wildlife intervention is necessary in Northern Ireland?

No.

The bovine TB crisis is a consequence of the failure of government and industry to effectively address the reservoir of infection within the cattle population and to mitigate cattle-to-cattle transmission. Wildlife interventions distract from addressing the root issues in intensive farming practices, farm fragmentation, and livestock movement.

10. Based on the scientific evidence that has been provided in Annexes V to VII is there any additional scientific evidence the Department should also consider?

Yes.

The Department must consider the peer-reviewed study by Langton, Jones, and McGill (2022) published in the Veterinary Record, which analysed 11 years of government data and concluded that mass badger culling has no statistical effect on reducing bTB in cattle.

Furthermore, the Department should evaluate Tom Langton's published criticisms regarding the diagnostic inaccuracies of the Dual Path Platform (DPP) test utilised in TVR models, which risks killing healthy wildlife.

True eradication requires acting on Langton’s 2024 findings in his Veterinary Record paper, "Bovine TB in cattle: true burden of disease untouched?": focusing resources away from wildlife culling and entirely toward advanced, highly sensitive cattle testing (such as phage-based blood cultures) and addressing the biosecurity risks of farm fragmentation.

11. Do you agree with the rating and scoring applied in the options analysis set out at annex VIII?

No.

The evidence presented is not sufficiently reliable to be confident that any of the intervention options can deliver the predicted benefits and savings. Predicted benefits and savings do not reflect the uncertainty of the methodology and evidence, and are too simplistic to be credible.

12. Do you agree that any wildlife intervention option selected should be delivered by the private sector, with the Department’s role limited to oversight, regulation and monitoring?

No.

Any wildlife policy must remain under direct public control, and outsourcing wildlife management to the private sector must be entirely rejected.

Leaving intervention delivery to private sector operators eliminates crucial public accountability, compromises animal welfare standards, and introduces a dangerous profit-driven or biased incentive structure into wildlife handling.

13. Do you agree that any wildlife intervention option selected should be funded by the private sector, with the Department funding oversight, regulation and monitoring?

No.

Wildlife intervention should be free of any industry influence to avoid conflict of interest and to maintain public confidence.

14. Considering all the relevant factors outlined would you support the controlled shooting of free-roaming badgers as a potential Wildlife Intervention approach?

Strongly oppose.

This option is inhumane and indiscriminate. Many healthy badgers will be killed. There remains a distinct lack of robust empirical evidence demonstrating that badgers easily or frequently transmit bTB back to cattle.

As acknowledged in Section 2.7.2.4.1 of DAERA's own SEA Report, controlled shooting presents "notable humaneness challenges." The report references historical data showing that between 7.4% and 22.8% of shot badgers remained alive for more than five minutes, causing prolonged suffering and severe wounding. No civilised wildlife strategy should rely on a method with such high, documented rates of failure.

Shooting free-roaming badgers in the wild disrupts their social group structures. This disruption triggers the perturbation effect, causing surviving, stressed badgers to scatter over wider distances.

Table 0-3 on Page 17 of the SEA Report explicitly states that non-selective culling methods have a negative (-) impact on the Strategic Environmental Objective for Biodiversity, Flora, and Fauna (BFF).

15. Considering all the relevant factors outlined would you support a non-selective cull using baited cages as a potential Wildlife Intervention approach?

Strongly oppose.

This option is inhumane and indiscriminate. Many healthy badgers will be killed. My response to question 14 applies for question 15.

16. Considering all the relevant factors outlined would you support a non-selective cull of badgers using stopped restraints as a potential Wildlife Intervention approach?

Strongly oppose.

This option is inhumane and indiscriminate. Many healthy badgers will be killed. Stopped restraints (snares) are inhumane and should be outlawed.

17. Considering all the relevant factors outlined would you support a Test and Vaccinate or Remove using baited cages as a trapping method as a potential Wildlife Intervention approach?

Strongly oppose.

A 5-year TVR trial in County Down found no significant reduction of TB in cattle, proving the model is a veterinary failure. Sinking public funds into a failed mechanism is completely unjustifiable. Furthermore, TVR relies on inaccurate diagnostic tests that result in the unnecessary slaughter of healthy wildlife. Leaving badgers trapped in cages for hours also inflicts severe stress and welfare risks. DAERA should entirely reject the "Remove" component of this option and pivot strictly to a non-lethal, proactive Vaccination Only approach.

18. Considering all the relevant factors outlined would you support a Test and Vaccinate or Remove using stopped restraints as a trapping method as a potential Wildlife Intervention approach?

Strongly oppose.

The use of stopped restraints (snares) is an outdated, indiscriminate, and inherently inhumane trapping method that poses a severe threat to animal welfare and native wildlife.

19. Considering all the relevant factors outlined would you support Vaccination Only using baited cages as a trapping method as a potential Wildlife Intervention approach?

I do not support the principle that badgers should be subjected to wildlife intervention in response to a disease primarily managed within cattle farming.

However, if DAERA proceeds with a wildlife intervention despite this, Vaccination Only is clearly preferable to any option involving the killing of badgers.

DAERA should entirely reject lethal approaches, including non-selective culling and TVR. If Vaccination Only is pursued as the alternative, it should be delivered to the highest possible welfare standards, remain under direct public oversight, and licensed lay vaccinators should be introduced where this can improve delivery and reduce costs.

My preference for Vaccination Only over lethal alternatives should therefore not be interpreted as endorsement of badger intervention itself, but as opposition to the killing of badgers.

20. Considering all the relevant factors outlined would you support Vaccination Only using stopped restraints as a trapping method as a potential Wildlife Intervention approach?

Strongly oppose.

Stopped restraints (snares) are inhumane and should be outlawed.

21. Do you agree that the Veterinary Surgery (Vaccination of Badgers Against Tuberculosis) Order 2010 should be extended to NI allowing for the lay vaccination of badgers in NI, under licence to support bTB control?

Yes, but only in the context of a non-lethal alternative to culling.

I do not advocate intervention in badger populations as a necessary response to bovine TB. My position is that greater emphasis should be placed on measures addressing disease transmission and control within cattle farming.

However, if DAERA chooses to pursue badger vaccination as an alternative to lethal wildlife intervention, I agree that appropriately trained and licensed lay vaccinators should be permitted to undertake this work under suitable veterinary oversight.

Allowing licensed lay vaccinators could make any vaccination-only programme easier and less costly to deliver. My support for this regulatory change should not be interpreted as support for badger intervention itself, but as a means of ensuring that, where vaccination is used instead of killing, it can be delivered effectively and without creating unnecessary barriers.

22. Are you content that the Blueprint strategy contains all necessary actions to address bTB in NI?

No.

The strategy relies on ecologically damaging culling options. It must explicitly shift to Vaccination Only to avoid the perturbation effect and protect local biodiversity.

It fails to heavily regulate farm fragmentation and intensive livestock movements, which are the drivers of cattle-to-cattle fence contact. The strategy over-relies on standard skin tests that miss infected cattle. DAERA must mandate ultra-sensitive supplementary testing like phage-based blood cultures. There are no robust restrictions on spreading untreated slurry from bTB-restricted farms, which leaves the bacteria active in the environment. DAERA should first demonstrate that all proposed cattle-based measures have been fully implemented, rigorously evaluated, and optimised for effectiveness.

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TAKE ACTION: Northern Ireland Badger Cull Consultation

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