Representation by Badger Trust (Badger Trust)
- Date submitted
- 14 February 2023
- Submitted by
- Members of the public/businesses
Badger Trust exists to promote and enhance the welfare, conservation and protection of badgers, their setts, and their habitats. We are the leading voice for badgers in England and Wales, with a network of around 50 local voluntary badger groups, and supported by thousands of supporters and followers. Badger Trust provides expert advice on all badger issues and works closely with the government, police, and other conservation organisations. We use all lawful means to campaign for the improved protection of badgers and are a member of Partnership for Action Against Wildlife Crime (PAW), Wildlife and Countryside Link and are represented on the UK Badger Persecution Priority Delivery Group of the National Wildlife Crime Unit. "Badgers are protected under the Protection of Badgers Act 1992. The badger is also listed under Schedule 6 of the Wildlife and Countryside Act 1981. Undertaking any activity which could result in damage to a badger sett or disturbance to any occupying badger may constitute an offence. Natural England may issue licences to disturb or close badger setts, but this is a last resort and must be done with great care. Badger Trust has numerous concerns about the proposals submitted, summarised as follows: There is a huge impact on badgers and this must therefore be carefully considered and managed. The badger surveys are all out of date, having been conducted between 2016 and 2020. The sites should be surveyed, and mitigation proposed, no more than 12 months before consideration is given to approving construction. The surveys did not include the entire area which will be affected by this scheme. Some landowners refused access to surveyors and in some locations, dense vegetation prevented a full survey, so the survey data is not complete. The assessment of badger clan territories is not sufficient given the scale of the impact, more work is required on clan boundaries. Bait marking has been insufficient. It has not been established when the outlier, subsidiary and annex setts are used throughout the year. Therefore, the applicant is unable to say that closing any of these setts will not harm badgers. The proposed mitigation for some setts is unworkable. Some proposed relocations are likely to be unviable, and some retained setts will be made unviable by the proposed works. Badgers are nocturnal. No account has been made for disturbance from night-time construction: noise, vibration and bright lights. The exclusion zones need to be reconsidered – they are insufficient in some cases. Habitat connectivity and fragmentation need to be considered and is something we consider vital.