Respond to the bTB consultation

Bovine tuberculosis, or bTB, has a serious emotional and financial impact on farmers, farming families and rural communities. There is no single solution to this complex disease, and effective action must proportionately address all the ways it spreads, particularly through stronger cattle testing, movement controls and farm biosecurity. 

Since the mid-1980s, the incidence of bovine TB in cattle has increased substantially, creating a significant economic burden on both farmers and the taxpayer, as cattle must be regularly tested, with infected cattle being culled and compensation paid by the government to the affected herd keeper. 

The spread of bovine TB is primarily through cattle-to-cattle transmission. And the science is contested on the risk of infection to cattle from badgers, but we recognise that badgers can be carriers of Bovine TB, which they can contract from cattle or other badgers. However, we don’t believe the killing of healthy, non-infected badgers is acceptable or proportionate in addressing the lower level of transmission risk of the disease by badgers, which are a protected, native species.  

Our clear preference is for a non-lethal approach, with stronger action to prevent and control bTB in cattle alongside badger vaccination. 

We: 

• strongly oppose all forms of non-selective badger culling;
• strongly support badger vaccination as the preferred wildlife intervention option in the consultation;
• strongly support the introduction of trained, licensed lay vaccinators, working under veterinary oversight, to increase the scale and affordability of badger vaccination;
• while we do not actively support TVR (where badgers are first tested and then only bTB-positive badgers are culled; negative ones are vaccinated and released), we could accept TVR using baited cages only, as the outermost limit of our position, in limited and well-justified circumstances, after cattle measures have been substantially strengthened;
• strongly oppose the use of stopped restraints (a special type of wire snare used to capture live badgers) including for TVR or vaccination;
• believe cattle testing, movement controls, farm biosecurity and preparation for future cattle vaccination must remain at the centre of the strategy; and
• believe DAERA must retain clear public responsibility for the governance, scientific oversight, animal welfare and evaluation of any wildlife intervention. 

1. Oppose non-selective badger culling 

Tell DAERA that you oppose culling badgers without knowing whether they have bTB. 

Non-selective culling would remove infected and healthy badgers alike. It also risks disrupting badger social groups and changing their movement patterns, which could undermine the intended disease-control benefits. Ulster Wildlife strongly opposes controlled shooting and all other forms of non-selective badger culling.   

2. Support badger vaccination  

Badger vaccination is the strongly preferred approach to managing bTB in badgers. 

Vaccination offers a non-lethal way to reduce disease risk while maintaining stable badger populations. Vaccination must be accompanied by long-term funding, proper training, veterinary oversight, independent monitoring and transparent reporting.   

3. Oppose the use of stopped restraints 

Tell DAERA that stopped restraints should not be used to capture badgers. 

Although careful operation may reduce some risks, stopped restraints continue to raise animal welfare and non-target capture concerns. Ulster Wildlife does not believe that a sufficient case has been made for their use when baited cage trapping is available as an alternative.   

4. Support trained and licensed lay vaccinators 

Support proposals to allow properly trained and licensed people, working under veterinary oversight, to vaccinate badgers. A lay-vaccinator programme could build local skills, increase the number of people able to deliver vaccination and make vaccination more affordable and practical across Northern Ireland.  

5. Badger vaccination should be prioritised over TVR. 

If you believe TVR should remain an available option, you could say that it must be limited to exceptional, evidence-led circumstances and use baited cages rather than stopped restraints. It should be independently monitored, publicly reported and introduced only after substantially strengthened cattle controls. You could also ask DAERA to set clear review and stopping points so that TVR does not become an indefinite programme or lead to non-selective culling. 

6. Put stronger cattle measures first 

Ask DAERA to prioritise action to prevent and control bTB in cattle, including: 

• improved testing and surveillance;
• stronger farm biosecurity;
• better management of cattle movements and trading risks;
• measures to reduce contact between cattle and badgers;
• preparation for future cattle vaccination. 

Wildlife intervention should not be treated as a substitute for effective cattle measures. Ulster Wildlife believes the strategy should test a strengthened cattle-led and non-lethal approach before concluding that lethal intervention is necessary.   

7. Require independent oversight and public accountability 

Any action affecting protected wildlife must be led by evidence and subject to strong public safeguards. Ask DAERA to retain responsibility for programme design, scientific oversight, animal welfare, monitoring and evaluation. Results should be reported publicly, and there should be clear criteria for reviewing, changing or stopping an intervention. Private funding or delivery must not be allowed to determine which method is chosen. 

5. Badger vaccination should be prioritised over TVR. 

If you believe TVR should remain an available option, you could say that it must be limited to exceptional, evidence-led circumstances and use baited cages rather than stopped restraints. It should be independently monitored, publicly reported and introduced only after substantially strengthened cattle controls. You could also ask DAERA to set clear review and stopping points so that TVR does not become an indefinite programme or lead to non-selective culling. 

To whom it may concern

I recognise the serious impact of bovine TB on farmers, farming families and rural communities, and I support urgent, effective action to tackle the disease. However, I strongly oppose the non-selective culling of badgers. Healthy badgers should not be culled without knowing whether they are infected. 

I want DAERA to prioritise stronger cattle testing, movement controls, farm biosecurity and preparation for cattle vaccination. Badger vaccination using baited cages should be the preferred wildlife approach. 

If TVR is to be considered, it should be used only in limited, evidence-led circumstances, after cattle measures have been strengthened. It must use baited cages, be veterinary-led and time-limited, and include independent monitoring, public reporting and a clear pathway towards vaccination-only. It must not become a route to non-selective culling of badgers. 

I oppose the use of stopped restraints. Cost should not take priority over animal welfare, biodiversity, scientific evidence or public confidence. 

Regards
[Insert your name and address]