The Welsh 2010 Consultation
Pembrokeshire against the Cull

PAC, PO Box 65, Cardigan SA43 9AD



The Welsh 2010 Consultation

The Consultation is now closed.

You can view the debate to annul the Badger Control Order here

Elin Jones announces new badger cull

We are extremely disappointed to report that The Minister of Rural Affairs Elin Jones has again ignored the science, sound economics, human rights issues and the views of the overwhelming majority of the public and has decided to proceed with a Badger Cull in North Pembrokeshire and parts of Carmarthenshire and Ceredigion. Her cynical timing of this announcement, just after the referendum, to bring the Order into force on 31st March, the final day of this Assembly, denies the public the opportunity to seek better Assembly representation of their views on this issue at the ballot box on May 5th.

Full press releases:

9/03/2011 : Minister makes same badger cull mistake again

10/03/2011 : Welsh Badger Cull plan: The fight continues

We expect a debate and a vote before the end of March, when the Order would otherwise come into force, so we would urge everyone to contact their Assembly Members and ask them to vote against this Order. For more information, see our lobbying page.

The evidence used by the Minister to support this decision can be found here.

Some responses to the consultation that have been published:

Pembrokeshire against the cull

The Badger Trust

Peter Black, AM

Background Information

Elin Jones, Minister for Rural Affairs, is consulting on a new Badger Control Order 2010. Like the 2009 Order, which was ruled unlawful earlier this year, if passed this will allow the Welsh Assembly Government (WAG) to kill badgers in north Pembrokeshire and adjacent parts of Ceredigion and Carmarthenshire - known as the IAA (Intensive Action Area). Their proposed action is, to enforce access to all land within the area, and to cull around 1400 badgers, just in the first year, by cage trapping and shooting, or free-shooting. The cull would take place annually in spring, summer and autumn for at least 5 years. WAG have ruled out the use of vaccination as part of the current TB Eradication Programme, although an injectable badger vaccine is available now and is an option in England. (Oral badger vaccine is also being trialled and cattle vaccination is on the horizon.) They have not addressed the issue that culling will make the future use of vaccination more difficult because it increases the prevalence of TB in the badger population. Nor have they considered the many other detrimental impacts of culling, such as the negative effects on communities, tourism and other industries, and the reputations of farming and Wales itself. See the Science pages for further information on why we believe culling badgers is not an effective solution to controlling bovine TB.


From the Welsh Assembly:

You can also request a paper copy of the consultation document by telephoning WAG on 0845 010 3300 or by emailing The consultation document is probably the most important one to read.

From PAC

From The Wildlife Trust

The Wildlife Trust of South and West Wales have a very good site on the badger consultation here

Who can respond?

Anyone can respond - even if you don't live in Wales. WAG may choose to ignore responses from outside Wales, as they did last year, but we will not. On the other hand if you do have a Welsh address you can use, that might make your response count more.

Equally, rather than send one response from an entire household, it would be most effective if each individual submitted their own response.

How to respond

WAG would prefer you to respond using their Online form. This has the advantage that it automates the format of the response - such as stating which question you are referring to (see below.) It has the disadvantage that you don't automatically retain a copy of your submission, and you can't opt to send a copy to PAC for our records. You may wish to write your response in your usual word processor, then copy and paste your answers into the web form.

Alternatively you can email a response to - but to ensure that your email is treated as a consultation response and not just normal correspondence do please take note of the guidance given below or in the downloadable Guidance notes above.

Finally you can mail a paper copy of your response to the following address:

TB Team
Office of the Chief Veterinary Officer
Department of Rural Affairs
Welsh Assembly Government
Cathays Park
CF10 3NQ

Advice on responding

General points

If you feel you have been disadvantaged by the way that the consultation is being conducted, or that the consultation is biased in any way, say so in your response. For example, you may note that every question requires those who disagree with the Minister to explain why, whereas those who agree with her need only tick a box saying 'yes' or 'no' - arguably setting a higher barrier to dissenting voices. Also many residents, landowners or business owners within the declared cull area have not been informed of the consultation, whereas bodies such as the Farmers Unions have been - if you are in this situation, say so in your response.

Likewise, if you feel a particular question is biased, irrelevant or ambiguous, point that out in responding and clarify what you mean by your response. For example, question 1 asks "Do you object to the culling of any wildlife for the purposes of controlling disease in farm animals?" Would the response 'yes' imply that you object to any cull, or just that there are some you do object to? Why does it matter, as this Order is specifically about culling badgers in the one area?

Making your response count

Last year, during the consultation for the 2009 badger cull Order, 2346 replies were submitted of which 84% were opposed to the cull - and yet more than half these responses were disregarded, e.g. for technical faults in how they were submitted, leaving fewer than 1000 responses of which a small majority still opposed the cull. WAG then selectively quoted just the remaining responses from Wales, allowing them to claim that 80% of responses from Wales supported the cull.

This emphasises how crucial it is to phrase any response to the consultation appropriately, so that your response will be included in any statistics quoted. Wherever you live, don't be put off responding to the Welsh consultation by WAG quoting only the responses from Wales last year - we will be free to quote your response, and the all the responses could be useful in a legal challenge.

suggestions of points to raise gratefully received.

Here's how to make sure your response will be counted...

Comments on the individual questions

Question 1: Do you object to the culling of any wildlife for the purposes of controlling disease in farm animals? If yes, please explain why?

As mentioned above, this question is both ambiguous and arguably irrelevant. If you object to only some culls, either answer 'yes' or 'no' might apply to you. So be careful to clarify your meaning in your response.

Question 2: In view of the fact that a licence for an injectable vaccine for badgers is now available, do you think that vaccination of badgers in bovine TB endemic areas is a viable alternative to culling to prevent disease transmission? If yes, please explain why?

A key question. Refer to our pages on vaccination to see some arguments for vaccination. One key point worth stressing is that vaccination, unlike culling, does not require forcing entry onto the land of its opponents.

Question 3: Do you believe that culling badgers can achieve a reduction in bovine TB incidence in cattle, to justify its use? If no, please explain why?

The relevant phrase here is "to justify its use" - does culling provide enough of a benefit to justify forcing entry onto private land and killing large numbers of a native apex predator species. Also consider how you measure the 'benefit' of culling - is it the benefit of culling over doing nothing, or of culling over vaccinating badgers? Last year WAG's own supporting studies implied the two methods were indistinguishable in their expected outcomes on cattle TB. Also, should we consider only the effect on TB in cattle, or also that on badgers? Culling increases Tb in badgers, where vaccinating reduces it.

Question 4: Do you agree that the Intensive Action Area has a high incidence of bovine TB in cattle which needs to be dealt with? If no, please explain why?

An obvious question. You might want to question whether existing measures are already dealing with the level of TB in the area - official statistics show a marked drop in TB in the area compared to the last two years.

Question 5: Do you believe that access to land for culling badgers should be enforced? If not, why not? Please give reasons for your answer.

On of the most important and relevant questions in the survey. Given the alternative of vaccination, how do you justify the curtailment of civil liberties, damage to the reputation of the area and the farming industry, and the ecological disruption required by culling and mandated by this Order?

Question 6: On balance, do you think the benefits of culling outweigh the harm caused to the badger population in the Intensive Action Area? Please give reasons for your answer. Would you include other factors in the balance of harm and benefits? If so why?

Other factors you might want to suggest would include the damage to the tourist industry, the reputation of the area and the farming industry, and the ecology. We know, for example, that such a cull will increase the fox population with knock-on effects on farming and wildlife.

Again, you may wish to consider whether the 'benefits of culling' should be measured against doing nothing, or against the alternative of vaccination.

Question 7: Do you agree with the prohibitions under the draft Badger (Control Area) (Wales) Order 2010? If not, why not?

The prohibitions in the Order are worded rather broadly. Should people, especially landowners in the area, be criminalised if they in any way "obstruct or interfere" with anything being doen in connection with the cull? Even more worryingly, should they be criminalised if they ina ny way "aid, abet, counsel or procure another person" to do so? Is this document guilty of doing so?