15 June 2021
Dear Elizabeth Thirsk,
Access to information – Request No RFI 5590
Thank you for your request for the information detailed below which we received on 18 May 2021.
Your request has been considered under the Environmental Information Regulations 2004.
You requested the following information and our response has been provided below:
1. I require OS Maps outlining all cull zones and their boundaries for the 2020 cull
and all new proposed zones for 2021
The information you have requested is being withheld under EIR Regulation 12(5)(a) –
public safety. Please see below for further details.
Regulation 12(5)(a) states:
“…a public authority may refuse to disclose information to the extent that its disclosure would
(a) international relations, defence, national security or public safety;”
Any disclosure made under the Regulations is in effect a disclosure to the world at large, as
any other applicant would be entitled to the same information on request. As such we take
this into consideration when making any decisions as to whether it is in the public interest to
disclose or withhold requested information.
This information is being withheld as it can be used alongside other information already in
the public domain to identify a small group of individuals participating in the Badger Control
Policy. The Policy is a sensitive issue and we believe that the release of this information
would impact adversely upon the protection of private property, public buildings and the
health and safety of individuals. In view of this risk we have decided not to disclose the
In applying this exception, we have had to balance the public interest in withholding the
information against the public interest in disclosure. Whilst Natural England believes in
openness and transparency, as a public body, Natural England also has a responsibility to
protect the safety of individuals. We are satisfied that the release of this information would
allow parties to identify individual participants.
We feel that by releasing this information, participants could be more easily targeted for the
purpose of objection. Animal rights activists object to this policy and target participants.
Releasing this information wil result in a higher risk of unwanted contact or interference from
persons wishing to object to the project and harass/harm the participants involved. It is not in
the public interest that participants are subjected to unnecessary harassment or put at risk.
Whilst it is a public right to object, that right has to be balanced against issues of security
and safety. We believe that these are legitimate concerns sufficient to al ow Natural England
to engage this exception and withhold the information.
2. How many licenses will you be granting for the 2021 cull?
The applications and licences for 2021 are currently ongoing, therefore this information is not
yet available and therefore is being withheld under EIR Regulation 12(4)(d) - in course of
Regulation 12(4)(d) states:
“…a public authority may refuse to disclose information to the extent that-
(d) the request relates to material which is stil in the course of completion, to unfinished
documents or to incomplete data;”.
Whilst Natural England believes in openness and transparency, as a public body, Natural
England has a duty to ensure that the data it releases is scientifically accurate and not
misleading. Applications are stil being processed.
In view of this we have decided not to disclose the requested information at the moment. In
applying this exception, we have had to balance the public interest in withholding the
information against the public interest in disclosure. These are the factors we considered in
deciding where the public interest lay.
We believe that, in this case, the public should have access to the data. However, we feel
that the release of this information early without sufficient quality assurance audit and
approval could mean releasing information that is incomplete and possibly inaccurate and/or
We feel there is little public interest in releasing this information prior to licence issue
determination having taken place. We believe that this is a legitimate reason to allow Natural
England to engage this exception and withhold the information
3. What scientific evidence do you use to justify granting cull licenses?
This information has already been supplied, under reference RFI 5559, emailed to you on 21
4. On what basis do you give out cull licenses?
Please see the response to Q3
5. Do farmers have to prove there is a TB problem before the grant licenses? If so
what proof do you require?
Please see the response to Q3
If you have any queries about this letter, please contact the Specialist Licensing Team by emailing
s you may be aware, under the legislation should
you have any concerns with the service you have received in relation to your request and wish to
make a complaint or request a review of our decision, please contact the Specialist Licensing
Team, at the above postal address or email address. Under Regulation 11(2) this needs to be
done no later than 40 working days after the date of this letter.
If you are not content with the outcome of that complaint or the internal review, you may apply
directly to the Information Commissioner for a decision. Generally, the Commissioner cannot make
a decision unless you have exhausted the internal review procedure provided by Natural England.
The Information Commissioner can be contacted at: Telephone: 0303 123 1113, www.ico.org.uk.