The Welsh Government is seeking responses on its latest important consultation for the agricultural community. They have called the document “A Refreshed TB Eradication Programme”. A misnomer if ever there was one.
If you start by accepting that the Welsh Government has no intention of taking the steps necessary to eradicate TB, it makes reading and responding to the document somewhat easier. The evidence base provided at the start of the consultation document is poor and selective. Likewise, many of the proposals are not supported by evidenced reasoning as to why they will improve the situation.
It is naturally hugely disappointing to our industry that the emotional and financial toll of TB is not being properly addressed, but it remains important to make our voice heard. Naturally, the farming Unions are preparing their responses but it is important for the Government to hear as many personal experiences as possible, so if you can, please take the time to respond to the Consultation.
There are many proposals to consider in the Consultation, many of which increase the testing burden on farmers – usually at their cost. There are proposals to increase pre and post movement testing, depending upon the risk areas the cattle are moving to and from. The differences between the low and intermediate areas are also reduced, with increased testing proposed in the low risk areas. The proposal not to allow the second clear test to be used as the pre-movement test will cause significant additional stress to farming businesses and families which cross everything the week of that test in the hope that the strain can be lifted. An additional period of increased stress and cost is now proposed, requiring yet another test after a further 60 days as passed. For a Government which finds it necessary on its webpages to signpost the industry to charities which can assist the sector with mental health and financial issues, it seems they are unwilling to consider that their policies and further proposals are the root cause of many of these problems.
There are proposals to introduce measures which are intended to provide information to buyers of stock on the TB status of the cattle for sale. If there were measures proposed to deal with every source of infection and genuinely eradicate the disease, one could understand the move to risk-based trading. As it stands, what is proposed is a blunt instrument which does not provide the full picture. It also risks significantly reducing the value of stock based in high risk areas and, combined with the lack of genuine attempt to get rid of the disease, leaves those farms high and dry. It is important that these measures – if they are introduced – tell the whole picture and do not place even more financial burden on businesses in the high risk areas. There is also the intention to add further information onto publicly available TB Maps. Care is needed with the protection of this data and there is no reason for people other than farmers and vets to regularly access this data. Placing families at risk in their own home should be avoided at all costs and should be the primary consideration when the use of such information is considered.
The types of tests to be used are also under review, including a proposal to use the gamma test more regularly as opposed to where there is a known breakdown. Although the skin test is well known to have its own problems, the gamma test’s issues are different. It carries a higher rate of false positives, owing to lower specificity than the skin test. When used in a targeted fashion in a breakdown, this failing seems to be the cost of removing the disease entirely, from cattle at least. However, applying the test to a situation where there is no breakdown is far more likely to lead to false positives, followed by the restrictions and damaging and costly cycles of testing which will follow.
Finally, there are proposals to make significant changes to the compensation paid to farmers for the TB affected cattle. To date, calls to follow England to a tabular value have been resisted and the value of affected cattle has been based on an actual valuation. There are several options proposed which get rid of this system and replace it with either a table or average system or appoint a board to deal with the valuation, but importantly, have no say on policy. The move to a tabular valuation (or a tabular valuation with an uplift for health scheme membership) is set to save the Government between £4 and £5million. A somewhat strange outcome, perhaps, for a system which is meant to simply average the true value of stock.
As that last point suggests, the main thrust of the consultation is to increase the burden and cost of the disease for farmers while saving a substantial amount of money in terms of the compensation offered. Given the pattern of Welsh Government consultations it seems likely that several of these measures will come into force eventually. However, while it is entirely understandable why you and I may be cynical at this stage, it remains important to respond as fully as possible, explaining how these changes will impact your businesses and lives. There is still an opportunity to minimise the negative impacts at this stage. Your responses may also contribute to the evidence available in any future legal challenge to the regulations. A number of years have passed since there was a major decision in relation to TB regulation which would obviously open the door to challenge the Welsh Government’s policy on TB and its implementation. The regulations which will follow this consultation will provide a clear decision which will allow those within the sector to consider whether it wishes to challenge the Government’s stance.
The Welsh Government has succeeded in making a wholly political problem out of a scientific one where TB is concerned. Even if you no longer believe that persuasion through the consultation process will work, please consider contributing to the body of evidence which may be useful in due course.
Rhodri Jones, Director Rural Advisor
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