1. Call an immediate halt to the badger cull. Bovine tuberculosis (bTB) is a contagious bacterial disease of cattle, but which also affects a large number of mammals in the UK, including badgers, deer, dogs, sheep or, as DEFRA puts it, “​nearly all warm-blooded animals”.9 bTB outbreaks in England have been rising since the 1980s,​10 posing a serious problem to the farming industry as they are difficult to control, cost the taxpayers over £100m every year, and cause pain and distress to the infected cattle. Since badgers are known to be implicated in the transmission of the disease, the Government in England decided to first trial and then implement a badger culling policy since Since then, ​34,103 badgers have been killed​3 and an estimated £50 million have been spent, while the science behind the effectiveness of the cull remains unconvincing and non-conclusive. In fact, ​the largest independent study on bTB, commissioned by Defra and known as the Randomised Badger Cull Trials (RBCT), took 10 years to run and ​concluded that “badger culling can make no meaningful contribution to cattle TB control in Britain”.​11 Both the Independent Study Group from the RBCT and former members from the group also concluded in a number of other publications that “​badger culling is unlikely to contribute effectively to the control of cattle TB in Britain”.​11,12,13 This is especially true when the economics of the cull are considered. A later analysis noted that although “extensive badger culling could reduce rates in cattle, overall an economic loss would be more likely than a benefit.”​14 This is the case because, although proactive culling reduced TB incidence in the specific areas where the cull took place, it increased the incidence in the neighbouring areas, possibly due to induced changes in badgers’ behaviour ​caused by a breakdown of the their territorial system, therefore increasing their movements and contact rates​.​15,16,17 Finally, although badgers can carry and spread bTB to cattle, later analysis of the RBCT data showed that once cattle-to-cattle transmission was excluded, ​only 5.7% of transmissions were badger-to-cow.​18,19 Nonetheless, cull licenses are being granted each year, with 2017 hitting the highest record to date (19,274 badgers culled) and 2018 setting out to more than double that number.​3,4

2. Launch a publicly funded national badger vaccination programme to reduce the level of TB in badgers. Badger vaccination against TB became available in 2010 and has been proven to reduce the risk of TB infection.​20 Six badger vaccination trials were planned to go ahead in 2010, but five out of the six were cancelled by the government, as it wasn’t deemed to be a good use of public expenditure.​21 The Badger Edge Vaccination Scheme (BEVS) was eventually launched in 2014 and, after a period of global shortage of the vaccine, it resumed in Spring 2018.​22 BEVS has recently been ​renewed​, however, with just £700,000 set aside to compensate only 50% of the cost of privately led vaccination projects over the course of four years, the scheme is clearly underfunded. For comparison, in 2016 alone, £5.4 million were spent on culling badgers.​3 Why is so much funding going towards a cull, when vaccination is both more humane and more effective at eradicating disease, as the history of human epidemiology has shown? Not least importantly, vaccination is also the most economically viable route, as the average cost of killing a single badger was calculated at £496.51 in 2016,​3 compared to that of vaccinating one at ​£82​. In some instances, this difference can be even greater, as the 2016 Welsh trial sho​wed, where each badger killed (and subsequently found healthy in post-mortem tests) cost the taxpayer £76,622​,​23 an extortionate sum of money which could have vaccinated thousands of individuals.

3. Bovine TB in cattle to be reduced through a combination of improved TB testing, tighter movement and bio security controls, risk based cattle trading and a TB cattle vaccination programme. Existing diagnostic tests for bTB are limited and unreliable,​24 with too many cases going regularly undiagnosed,​25 or resulting in false positives.​23 New tests are currently being designed and ​trialled​, and the government should be placing the research and development of these at the top of its priorities. It is of no use to be culling badgers and slaughtering sick cattle if some of the infected cows aren’t detected by the current tests and remain in the herd as “hidden reservoirs” of bTB on the farm. As well as having poor diagnostic tools, we also still have much to understand about the disease itself and how it spreads. Until recently it was thought that infected animals had to come into close contact for the transfer to happen. However, research has shown that badger-to-cattle and cattle-to-cattle transmission is more likely to happen through the environment or, in other words, through the slurry or manure deposited on the pasture the cattle are grazing.​26 This has huge implications for the management of bTB, as it would imply that simply isolating and slaughtering the infected cattle isn’t enough if the environment left behind isn’t also treated. Furthermore, alongside better diagnostic tools and bio security controls, there should be a much tighter regulation in the trade of cattle across the country, as this has been responsible for a number of outbreaks. For example, of the 31 outbreaks recorded in the North-East of England between 2002 and 2004, 30 have been traced to the purchase and trade of animals from high risk areas such as Cheshire, Wales and Ireland.​27 Furthermore, urgent work is also needed to establish the risks involved with other mammalian carriers of the disease. Alarmingly, hunting hounds have been found to carry bTB and when 164 hounds from the Kimblewick Hunt’s pack were tested, 97 were found to be infected.​28,29 This requires immediate attention as the hounds, by the very character of the hunts, are able and  encouraged to move freely across the country, potentially spreading the disease. Finally, just as a TB vaccination programme for badgers should be made available, a TB vaccine for cattle would also help contain the spread of disease. Overall, bTB eradication in England can only be achieved with the implementation of a complete programme that aims to achieve better and more regular tests, strict biosecurity for farms and slaughterhouses, mass vaccination of cattle and badgers and movement/trade restrictions.

4. The use of dogs below ground by hunts which leads to the death of foxes and badgers to be prohibited under the Hunting Act. The use of dogs for hunting was banned in Scotland in 2002 and England and Wales in 2004. However, the Hunting Act includes a number of exemptions to this rule. One of them is the use of a maximum of two dogs below ground, known as terrier work, where dogs may be used to flush out a fox to be shot for the purpose of protecting game birds reared for shooting. This obviously opens a dangerous loophole which can be exploited by huntsmen. In the year 2000 the ​Burns Inquiry into hunting with dogs concluded that the inability to escape dogs underground causes the fox ‘extreme fear’ and is a ‘serious compromise of its welfare.’ Foxes forced to face terriers underground can also suffer injuries to the face, head, and neck, as, of course, can the terriers, who are often left with untreated injuries and will be shot when they are no longer of use.

5. A ‘reckless provision’ clause to be inserted in the Hunting Act to stop hunters using the false alibi of trail hunting. The hunting of mammals like foxes, hares and deer using dogs has been illegal in the UK since the 2004 Hunting Act came into force. Trail hunting was invented after the ban, and it consists of getting the hounds to follow an animal-based scent trail which has been previously laid, often in areas where foxes or hares are likely to be. The dogs are supposed to follow the laid-trail, but this can often get mixed up with an actual animal trail, which leads to countless hunting accidents ending up with animal deaths. The hunt can then claim that it was an accident, thus avoiding any charges and getting away with it. Whether some hunts may be genuinely just using trails or whether this may be a complete cover for illegal hunting, this practice opens up too many ways of  circumventing the Hunting Act, and should therefore be banned. The only way to do this is to introduce a “reckless provision” in the Act, which would enable people to be prosecuted when it can be proved that they were reckless by not preventing their dogs from chasing and hunting a wild animal.

6. The ‘Observation and Research’ exemption which has been abused by stag hunts to be immediately removed from the Act. The Hunting Act contains “exemptions” built into its Schedule, which were designed to prevent the ban affecting activities which Parliament did not intend to prohibit. Unfortunately, hunts often use these exemptions as an excuse if they are caught hunting. For example, staghunts use the 'Research and Observation' exemption that was designed for researchers and not hunters, and some fox hunts carry birds of prey in order to claim that they use the 'falconry' exemption, which was designed for falconers.

7. The indiscriminate and ruthless slaughter of Scotland’s mountain hares to stop immediately. Mountain hares, native to the Highlands, are being culled each year by gamekeepers as part of tick control measures to reduce the spread of “louping-ill” flavivirus (LIV) to the grouse population. In 2003 a study predicted that by reducing hare numbers, a decline in ticks would follow, which would in turn reduce grouse mortality and therefore increase their numbers.​30 A response to that study was quickly published, the following year, highlighting the lack of evidence to connect the culling of hares with an increase in grouse numbers,​31 and advising that the conclusion was premature. Since then, no other scientific evidence has been brought forward supporting the culling of hares, but nonetheless hares have remained a huntable species even though they are now classed as “near threatened” in the UK. Furthermore, their large-scale cull is not monitored and is completely unregulated during the open season, raising welfare concerns as well as ecological ones. In 2014 alone, 37,681 hares were killed,​32 a shocking and unjustifiable number, especially when placed in the context of the vertiginous collapse this species is experiencing, now -99% of what it used to be in 1954.​33

8. Management of mountain hare numbers to be more tightly controlled by Scottish Natural Heritage to safeguard populations. The Scottish government to cease the issuing of any further licences for the culling of seals.

9. Common and grey seals are protected under Scottish and EU law. Nonetheless, ​on 31 January 2011, Part 6 of the Marine (Scotland) Act 2010 came into force, in which “Scottish Ministers may grant a licence (a “seal licence”) authorising the killing or taking of seals to protect the health and welfare of farmed fish and to prevent serious damage to fisheries or fish farms”.​34 As many as 1,628 seals have been killed since the Scottish licence scheme was introduced in 2011,​53 but many more may have died and gone unreported since licence holders are not monitored by government officials when they are shooting seals. Furthermore, it is impossible to calculate the impact of the shootings given that there is no closed season, which means that pregnant and lactating mothers can also be shot.

10.The Scottish government to introduce a funding programme to help fish farms and wild fisheries meet the costs of non-lethal protection methods to deter seal incursion. Non-lethal protection to deter seal incursions exist, are widely used in other countries, such as Canada and Chile, but are still uncommon in Scotland. Predator nets surrounding the entire cage system, from surface to seabed, are a good management technique, although their effectiveness depends on the intensity of the tidal currents. Net tensioning is also widely cited as being a critical issue in minimising seal depredation. Also, the speedy removal of dead fish, changes in net shape and size and the use of alternative materials are all known methods used by fish farming companies abroad to minimise seal depredation. Fish farms and wild fisheries need to be able to identify and test different techniques to protect their stocks, and this should be funded by the Scottish government. 


9. DEFRA (2010). Bovine TB: TB in other species. [online]. Available at: http://webarchive.nationalarchives.gov.uk/20140305134725/http://archive.defra.gov.uk/foodfarm/farman imal/diseases/atoz/tb/abouttb/otherspecies.htm#cattle(Accessed 9/09/2018)
10. Krebs, J.R., Anderson, R., Clutton-Brock, T., Morrison, I., Young, D., Donnelly, C., Frost, S., Woodroffe, R. (1997). Bovine Tuberculosis in Cattle and Badgers(Her Majesty's Stationery Office,London)
11. Bourne, J., Donnelly, C.A., Cox, D.R., Gettinby, G., McInerney, J.P., Morrison, W.I., Woodroffe, R. (2007). Bovine TB: The Scientific Evidence, a Science Base for a Sustainable Policy to Control TB in Cattle. Final Report of the Independent Scientific Group on Cattle TB Presented to the Secretary of State for Environment, Food and Rural Affairs. Available at:
http://webarchive.nationalarchives.gov.uk/20081108133322/http://www.defra.gov.uk/animalh/tb/isg/pdf/final_report.pdf(Accessed 12/08/2018)
12. Jenkins, H.E., Woodroffe, R., Donnelly, C.A. (2008). The effects of annual widespread badger culls on cattle tuberculosis following the cessation of culling. International Journal of Infectious Disease12: 457–465
13. Jenkins, H.E., Woodroffe, R., Donnelly, C.A. (2010). The duration of the effects of repeated widespread badger culling on cattle tuberculosis following the cessation of culling.
PLoS ONE5(2): e9090
14. Wilkinson, D., Bennett, R., McFarlane, I., Rushton, S., Shirley, M., Smith, G.C. (2009). Cost-benefit analysis model of badger (Meles meles) culling to reduce cattle herd tuberculosis breakdowns, with particular reference to badger perturbation. Journal of Wildlife Diseases45: 1062-1088
15. Woodroffe, R., Donnelly, C.A., Cox, D.R., Bourne, F.J., Cheeseman, C. L., DELAHAY, R.J., Morrison, W.I. (2005). Effects of culling on badger Meles meles spatial organization: implications for the control of bovine tuberculosis. Journal of Applied Ecology43(1), 1–10
16. Woodroffe, R., Donnelly, C.A., Jenkins, H.E., Johnston, W.T., Cox, D.R., Bourne, F.J.,
Morrison, W. I. (2006). Culling and cattle controls influence tuberculosis risk for badgers. Proceedings of the National Academy of Sciences103(40), 14713–14717
17. Carter, S. P., Delahay, R. J., Smith, G. C., Macdonald, D. W., Riordan, P., Etherington, T. R.,
… Cheeseman, C. L. (2007). Culling-induced social perturbation in Eurasian badgers Meles meles and the management of TB in cattle: an analysis of a critical problem in applied ecology.Proceedings of the Royal Society B: Biological Sciences, 274(1626): 2769–2777
18. Brooks-Pollock E, Wood JLN. 2015 Eliminating bovine tuberculosis in cattle and badgers: insight from a dynamic model.
Proc. R. Soc. B282: 20150374
19. Donnelly, C.A., Nouvellet, P. (2013) The Contribution of Badgers to Confirmed Tuberculosis in Cattle in High Incidence Areas in England.
PLOS Currents Outbreaks, 1 

20. Carter SP, Chambers MA, Rushton SP, Shirley MDF, Schuchert P, et al. (2012) BCG Vaccination Reduces Risk of Tuberculosis Infection in Vaccinated Badgers and Unvaccinated Badger Cubs.PLoS ONE,7(12): e49833.
21. Government (2010). Changes to badger vaccine deployment project. Press release, availabe at: 
https://www.gov.uk/government/news/changes-to-badger-vaccine-deployment-project(Accessed 29/08/2018)
22. Government (2017).
Badger vaccination scheme relaunched in fight against bovine TB. Press release, available at: https://www.gov.uk/government/news/badger-vaccination-scheme-relaunched-in-fight-against-bovine-tb (Accessed 29/08/2018)
23. Animal and Plant Health Agency (2017). Animal & Plant Health Agency (APHA) report on the delivery of badger trap and test operations on chronic TB breakdown farms in Wales in 2017. Report for project TBOG0235. Available at: https://gov.wales/docs/drah/publications/180712-delivery-of-badger-trap-and-test-operations-2017-report-en.
24. De la Rua-Domenech, R., Goodchild, A.T., Vordermeier, H.M., Hewinson, R.G., Christiansen, K.H., Clifton-Hadley, R.S. (2006). Ante mortem diagnosis of tuberculosis in cattle: A review of the tuberculin tests, γ-interferon assay and other ancillary diagnostic techniques. Research in Veterinary Science, 81(2): 190–210
25. Drewe, J. A. (2015). Bovine tuberculosis: how likely is a skin test reactor to be uninfected?: Veterinary Record, 177(10), 256–257

26. Woodroffe, R., Donnelly, C.A., Ham, C., Jackson, S.Y.B., Moyes, K., Chapman, K., Cartwright, S.J. (2016). Badgers prefer cattle pasture but avoid cattle: implications for bovine tuberculosis control.Ecology Letters, 19(10): 1201–1208
27. Gopal, R., Goodchild, A., Hewinson, G., de la ua Domenech, R., Clifton-Hadley, R. (2006). Introduction of bovine tuberculosis to north-east England by bought-in cattle.
Veterinary record,159: 265 – 271
28. Eastwood, B., Menache, A., Dalzell, F., Puddifoot, J., Elliott, P., Pell, S.,
McGill, I. (2018). Spreading of bovine TB by hunting hounds. Veterinary Record, 183(10): 327–328 https://veterinaryrecord.bmj.com/content/183/10/327
29. O’Halloran, C., Hope, J. C., Dobromylskyj, M., Burr, P., McDonald, K., Rhodes, S., Gunn-Moore, D. A. (2018). An outbreak of tuberculosis due to Mycobacterium bovis infection in a pack of English Foxhounds (2016-2017). Transboundary and Emerging Diseases. ​ https://www.ncbi.nlm.nih.gov/pubmed/30058193
30. Laurenson, M.K., Norman, R.A., gilbert, I., Reid, H.W., Hudson, P.J. (2003).Identifying disease reservoirs in complex systems: mountain hares as reservoirs of ticks and louping-ill virus, pathogens of red grouse. Journal of Animal Ecology 72, p.177–185
31. Cope, D.R., Iason, G. R., Gordon, I. J. (2004). Disease reservoirs in complex systems: a comment on recent work by Laurenson et al.
Journal of Animal Ecology73, p.807–810
32. Scottish Government (2018). Available at: 
33. Watson, A., Wilson, J.D. (2018). Seven decades of mountain hare counts show severe declines where high-yield recreational game bird hunting is practised.J Appl Ecol00: 1–10
34. Marine Scottish Legislation, Act 10, part 6, section 110. Available at: 
https://www.legislation.gov.uk/asp/2010/5/section/110Accessed on August 13th 2018
35. Scottish Government 2017. Seal licensing. Available at: 
https://www.gov.scot/Topics/marine/Licensing/SealLicensing/appgraphAccessed on August 14th 2018
36. Northridge, S., Coram, A., Gordon, J. (2013). Investigations on seal depredation at Scottish fish farms. Edinburgh: Scottish Government.