Phil is sending the following letter to Spelman and Paice. He makes some very relevant points. Of particular interest are the areas the decision makers have chosen to ignore to date. Let's hope they read what he is saying carefully and we await their response with interest.
 
' I started my career in agriculture in the early 1970’s, and progressed to a managerial position. For twenty years of that time I have been responsible for animal protection and crop protection on 400 ha of intensive livestock and mixed arable. My qualifications and experience have provided me with a particular set of skills that enable me to accurately identify and define clearly the boundary that exists between agriculture and the environment. Although not unique to me, these skills are vital for success in my job and are well used, daily throughout my career.
 
There are many of us in agriculture who, for many years and under Common Agricultural Policy, have been taking very purposeful, progressive and successful steps away from the idea that poisoning, polluting and infecting the environment are acceptable just so long as we are getting our needs met, whether those needs are material, emotional or otherwise.
 
Environmental damage shouldn’t be used as a tool to prevent or suppress leakage of any nature from agriculture, whether that leakage is into other agriculture or more widely into the environment. That’s a fundamental principle that enables our progressive steps and is the principle behind why, for instance, we no longer consider that if we have silage effluent that is getting into a ditch we correct it by filling in the ditch, those days are long gone. It’s the same principle behind the reason why we no longer use chemicals such as organo-phosphates and DDT and why we have buffer zones next to watercourses and work to reduce spray drift. We know that what we do impacts on the environment.
 
If we know that TB spreads through non agricultural hosts and wild animals, we know that leakage can happen.
 
Environmental damage and long term disease prevention and control in agriculture are not compatible bedfellows, and they are not compatible because environmental damage is antagonistic to successful long term disease control. It only ever has short term effects that may show positive results but that also always mask the true nature of things, thereby preventing success.
 
Localised badger culls, as in the “Krebs trials”, don’t work to stop TB, if they did then we wouldn’t be having these conversations.
To suggest that killing badgers, at any level, should be used in the prevention and/or eradication of bovine TB, is to suggest that we should now apply opposing and conflicting principles simultaneously to achieve the same end in the same process under Common Agricultural Policy, and to regress.
 
If, in your proposal to kill badgers, that is not what you will be doing, then can you please explain how it is not what you will be doing, so that I may continue to progress?
 
Repeated attempts over the years and, now again, your proposal to kill badgers, are examples of “filling in the ditch”! It is to deliberately disregard the very clearly definable boundary and to step across it with an attempt to obscure it. I would say that that is precisely why TB is in the cattle population as it is now.
 
Decoupling subsidy payments to farmers from production introducing the Single Farm Payment Scheme is possibly the biggest single act of reformation in Agricultural Policy in over 40yrs. For all that time we have paid farmers their subsidies in accordance with what they produce and how much of it they produce, and following EU Ministers agreement in 2003 all that changed. It is the purpose of this CAP reform to inspire, initiate, encourage and enable change in the behaviour of farmers, and it succeeded. Some of those changes would be small and we probably wouldn’t notice them, but equally some of the changes would be large and obvious. An example of large and obvious changes in cattle behaviour since SFPS in 2005 is the increase in numbers of what we have come to describe as “Mega-dairies”. Either way, those changes would occur, by definition that’s the purpose of reform. We know this.
We also know that bTB is always present in the national herd; we know this because Defra is always testing there. We also know that they’re not always testing badgers.
 
We also know that bTB spreads by following behaviour patterns and changes in behaviour patterns of farmers and their livestock. We also know that badger behaviour tends to not change, especially if we don’t disturb them.
 
We also know that in order for all farmers to receive Single Farm Payment, (and in Wales 75% of farmers received their first payment on the first day!), then they would have to have received scrutiny and then qualification from Defra.
 
So we also know that Defra knew all the changes were coming and they knew when those changes might occur.
 
So we also know that all that knowledge was prior knowledge and that it was so in 2005.
 
So I have a question: Given the predicted risk and predictable increase in risk, following, and in response to, EU Ministers agreement in 2003 and in the 2 yrs of the run up to the Single Farm Payment take-up in 2005, given that all that is prior knowledge, what steps did Defra take to prevent this bovine TB outbreak from ever happening and following the course that it has, thereby costing taxpayers the money that they have paid out in compensation to farmers?
 
And then: If it is your intention to kill badgers, then by definition and by your design, you will be applying the purposes and the consequences of the Common Agricultural Policy and its reforms outside agriculture, into the environment, onto badgers, and onto everyone else too. If, in those actions, that’s not what you will be doing, can you please explain how it is not what you will be doing?
 
Your threat to kill badgers continues to force us all away from the conversations that have to take place in order to change the process from the one that has been with us for fifty years; killing badgers isn’t doing something different, you are just perpetuating the problem!
Vaccines work, that’s why we use them, and vaccination changes the process.
 
Vaccinating badgers protects wildlife and goes a long way to plugging the leak, and vaccinating cattle would seal it. For the Protection of badgers and the environment, for the protection of agriculture and its reputation and credence, and because of the science, do something different; change your mind and vaccinate.'

Here is Phil's interesting and very thought-provoking paper. Let's hope the politicians and civil servants read it!
 
© Philip Allsopp October 2010
On Bovine T.B.
 
I am not a member of any wildlife conservation organisation, nor am I a member of any local action group. I live and work in North Pembrokeshire.
 
When people try to undermine one another, try to manipulate one another and bully one another, as has been happening here in response to this proposed badger cull, it is an indication that they are in a dysfunctional process of some sort. This unsolicited, non-consensual intrusion into our homes and the removal of our ability to say “No”, and have it mean “No”, has given me reason to look at this process in order to determine what it is that generates the dysfunction. My years in agriculture have given me first-hand experience of it making me able to.
 
This is what I have found: It is there in the very first action taken when government vets come onto farms to test cattle. They test the cattle, but that is not the only thing that they do. They also do something else that, by and large, goes unseen by most; it gets spoken about by some farmers, but it has remained unchallenged and therefore unchanged since the 1960’s.
 
When vets come onto farms to test cattle, in that action also, they take the primary healthcare of the cattle away from those people whose job it is to have it, and that’s not a good decision, that’s the opposite. That’s a really bad management decision. Worse still, it’s a really bad decision that is then acted on by everyone, including farmers, as if it was a good one. What this means is that when every decision that follows is compromised in this way, regardless of what good intention may be behind it, and regardless of how good it would normally be under everyday circumstances, every decision becomes a bad decision also.
 
Such decisions are so bad that, for instance, the decision to take a cow to slaughter in response to an adverse test result prevents that cow passing the disease on, but it also breaks every link that there may have been between that animal and every source of infection that there may have been (it’s not possible to have a connection between a disease source and something that doesn’t exist). This means that it is then never possible to properly identify or indeed prove any source of infection, which means that every decision that follows can only ever be made based on guesswork. It may be good guesswork, it may be very educated guesswork, and it may even be accurate guesswork based on years of experience, but it is guesswork all the same because by then there is no alternative, and then some of the gaps are filled in by some of the science retrospectively.
 
So, government, Welsh Assembly, DEFRA, Vets and, of course, farmers, have in place a system of disease management and control that was designed and built in the 1960’s, is based around a series of bad management decisions, the first one of which takes the healthcare of the livestock away from those people whose job it is to have it, those bad decisions are repeated on every farm that is visited, every time it is visited, on and off for over forty years and all the decisions that are being made with regard to disease control and management have their basis in guesswork!
 
It is not the methods that are the problem, it is the process that’s the problem, and it’s completely dysfunctional! That’s not how to stop the spread of T.B., I’d say that’s probably the best way to spread it, because then it would spread out of sight of everyone, and not because it’s being spread by badgers, which are nocturnal and out of sight, but purely and simply because everybody that is involved is acting with what they believe to be the very best of intention and it is that good intention, along with one or two other things, which leads them to hold and maintain within themselves the very poorly held belief that all the decisions that they are making are automatically good ones, when the reality is they are not, they are all very bad ones. And here we are in 2010 having this conversation about the spread of bovine TB, so none of it actually works. This would also account for why the disease is spreading in places where there are no badgers!
 
A measure of that dysfunction is that which is happening in North Pembrokeshire in response to this proposed badger cull.
 
So that’s alright then! You see so far all of this is perfectly normal. We all, from time to time in our lives, get tangled up in a dysfunctional process of some sort or other; it’s human nature and it’s OK because when we recognise that it is happening we are then able to stop, step out of the process, or change the process. It’s also acceptable that for some people they can remain within the dysfunction for as long as it suits their purpose and, most importantly, so long as nobody is getting hurt.But what is not acceptable is that which is happening here in North Pembrokeshire. There are a lot of people here who, along with their families and their businesses, many of which have no connection with agriculture, are being dragged into this dysfunctional process against their will. They have no means of preventing that from continuing, and no way of stepping out of it or changing it; that is, until the Judicial Review earlier this year stopped the cull and changed things. Some would say “QED”!
 
Now the Welsh Assembly is at it again- disenfranchising farmers, undermining everyone, hitting everyone down, suppressing their voices, oppressing them and intimidating them in their own homes whilst using people wearing full- face balaclavas! That’s not how to stop the spread of bovine T.B., but that is how the Welsh Assembly Government is attempting to do so!
 
Lifting people up, making it so that they can empower themselves and go on to become further enabled; that is how to stop the spread of T.B. Killing badgers is just changing the method. It is not the method that’s the problem; it’s the process that’s the problem. So the answer is to change the process!! This can be done easily by bringing to an end the disenfranchisement that occurs when vets come onto farms to test cattle. This would hand back the healthcare of the cattle to those people whose job it is to have it. These farmers and stockmen are the better qualified and the most experienced, they are in exactly the right place, and they are very dedicated, and when people with those qualities are given the right tools for the job they always go on to succeed very quickly. That’s not what I think, that’s what I know! I live in North Pembrokeshire, and I see it happening in different ways all around me every day.
 
The best tool in any process of disease management and control in the 21st century is a vaccine. We don’t use euthanasia to stop the spread of diseases; we use vaccines, because they work. So vaccinate the cattle! Vaccinate the cattle, and we can all forget about badgers and leave them as nature has intended them, and then under the eyes of those who watch them. Vaccinate the cattle, and then any farmer who has a particular problem with badgers, or wildlife of any sort, can get in touch with an ecologist, which makes good common sense, good business sense, and of course good ethical sense. An ecologist would be the ideal person qualified to help the farmer with their problem, rather than getting in touch with the politician, who just thinks she’s qualified and who is all too ready to continue making really bad decisions about all of our welfare based on guesswork.
 
In amongst all of the propaganda from the Welsh Assembly on this, we are being told that it is EU Legislation that prevents the use of vaccines in cattle, and that authorisation from Europe is needed to change that. So it follows then that if the authorisation is needed, it should be gained. We are told that in Australia they have eradicated the disease but it has taken 27 years; we’ve only been at it in the UK for over 40 years, since around the time that I started my career as a stockman. More recently, my time spent as a member of one of the Welsh Assembly Government Strategy groups has given me some clear insight. There is no question in my mind that this dysfunction, and many like it, is generated systemically within government, at the hands of politicians, bureaucrats and civil servants in an environment that is overpopulated by them and whose ambitious and sometimes bullish approach, coupled with a very obvious need to produce results in accordance with a pre-formed agenda and a little bit of good intention thrown in, undermines and then invalidates functional strategic thinking, rendering it impotent and then pointless. It is always a social construction, rather than an evolutionary process. As a result, we find those in government using such words as, “I believe”, “I am satisfied”,
“most experts agree”, instead of using words such as, “I know”, “all experts agree”, and most importantly, “this proves that that badger passed that disease to that cow”. They don’t say it because the dysfunction prevents them from saying it, so they can’t prove it.
 
An example: On page 5 of a recent edition of the Welsh Assembly Government magazine ‘Gwlad’, Rural Affairs Minister, Elin Jones is quoted as saying, “Based on the available evidence, at the end of a cull and post cull period, through culling alone we expect to have reduced bovine TB in the area by approximately 22%, preventing an estimated 83 confirmed herd
breakdowns that would otherwise have occurred in the absence of culling badgers in the area.”
 
For a start, their proposals don’t involve using culling alone! All of what she says is gathered from statistics and is then put together in a different arrangement in order to justify her words and her actions. She is talking about the future, so it is what she thinks rather than what she knows. In other words, she’s actually guessing again, but because of the way that it’s presented it can be very easily taken as the truth when the reality is that it is nothing more than prevarication, because that is her only option. If they could detail the proof and the truth they would do so because there is no reason not to! Their problems arise because, as is common in this sort of dysfunction, those in it constantly try to amend and change the methods as they go along, but no individual is to blame so it’s not the methods that should be changed, but all are responsible for their part and place in it, which means that it’s the process that should change. However, this good intention, coupled with the ambitious, aggressive, self-righteous and very bullish approach from a politician, may be the accepted way of things behind the closed doors of government, but for this senior Minister to then bring it outside and apply it on all of us in the way that she is doing, is not acceptable and is completely inappropriate behaviour.
 
All this explains why, but it doesn’t explain how. The disease is spreading unseen and all are ‘best guessing’, and of course, pointing at badgers. On the idea that unseen could mean they are looking in the wrong place, I looked elsewhere. Diseases like this spread following behaviour patterns and changes. If I was a cattle farmer and I was to change my farming policy and practice, my behaviour would change. If all those things change then it follows that transactions I have with others change, cattle movements change, cattle behaviour changes, maybe even the number of cattle that I keep changes. So the question is ‘What would influence such changes for me?’ If the criteria on which my subsidy is paid to me was to change, all the above would change. That might even be the point. It would also change for all other farmers at some point.
 
In June 2003, EU Ministers announced Common Agriculture Policy reform. The intention was to de-couple payments to farmers from production, introducing the New Single Farm Payment Scheme. All member states signed up, and by 2005 farmers in Wales were among the first in Europe to engage. By the end of the first day 75% of Welsh farmers had received their first payment! 98% of Welsh farmers had done so within 6 months. So it would follow that over a very short period, all transactions between farmers change, all cattle movements change, cattle behaviour changes, even local
populations change. These changes may be very small and subtle, but equally they may be large and obvious. Either way it follows that they would occur.
 
The purpose of the CAP reform was to change the behaviour of farmers and then to reward the change with payment. It succeeded, and in Wales they all changed things at the same time! When all of that is applied in an area where the farming community is particularly close knit and where unique ergonomics exist, a “hotspot” in behaviour will present. Bovine T.B., always present in the national herd (and we know this because they are always testing there), slips through and breaks out and in response the Welsh Assembly become involved in order to put right what are effectively a farm business management issue and a man-management issue, and they do this by consulting a vet! So the disease spreads and they all carry on wasting taxpayers’ money because they are still trying to blame somebody else; nobody involved is owning the consequences of either their actions or their shortcomings; another indication of the dysfunction.
 
The Common Agricultural Policy, its purposes and its consequences, should never be applied outside agriculture, especially when that application is done forcibly, wilfully and with an intention to do damage to the environment and its contents.
 
Badgers are a protected species, and it is illegal to kill them. We all have a responsibility to protect the environment. My right to have that protection maintained is not diminished because I live in North Pembrokeshire. It is certainly not diminished because I choose to operate my business interests away from intervention schemes and with no need for benefits or subsidies from taxpayers. For a senior Minister to persist so publicly with this humiliation, degradation and diminishment of us all here is sickening to watch, but it is extremely painful to be forced into against our will. For her to then continue in order to satisfy her esteem and personal ambitions is shameful and beyond all common reason.
We, that is every one of us including the environment, are worthy of a more appropriate consideration, a more positive regard and a greater level of respect than has been shown on this by the Welsh Assembly Government, it’s Rural Affairs department, and most significantly by Assembly Minister for Rural Affairs, Elin Jones. The answer isn’t here in Pembrokeshire, it is clearly in Brussels.
 
It is not the method that’s the problem; it is the process that’s the problem. So change the process! Vaccinate the cattle and everybody wins. Nobody wins more than the taxpayer, and they would win all the way to the bank.

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Thank you Phil, we are happy for you to post your analysis providing the information is factual and can be substantiated. We look forward to hearing from you further in due course.