Rare Breeds International welcomes the proposal to extend the time limits for the final implementation of the NSP programmes. Three items in particular affect the progress of implementation:

1.       The FMD outbreak in 2001 caused delay and disruption to the programme, and it was appropriate that DEFRA recognised the need to allow for this in a revised timeframe.

2.       It is also prudent not to take precipitate action in view of the development of tests which distinguish between BSE and scrapie in sheep. The utilisation of these tests may enable the NSP to be modified to prevent unnecessary damage to individual breeds and to biodiversity in the national sheep flock.

3.       Questions raised regarding the validity of results also justify a slower application of the programme in order that apparent inaccuracies can be resolved.

B. Rare Breeds International welcomes the categorisation of breeds (3A, 3B, 3C and 3D) to recognise the greater vulnerability of some breeds to the application of NSP. Categories 3B and 3D relate to only one breed each, and the critical distinction is between categories 3A and 3C. There are some inaccuracies:

1.       Some breeds are missing from the lists. In particular we noted the absence of Castlemilk Moorit, Icelandic and North Ronaldsay - all breeds which, by coincidence, have a nil frequency of ARR.

2.       Some breeds (e.g. Ryeland, Teeswater) appear in both lists (3A and 3C).

3.       British Milksheep is only two words (not Milk Sheep).

C. No change is proposed for category 3C. Most (or all) of these breeds have a frequency of >50% for the ARR allele, and we have no further comment to make on this category except to repeat our warning of the danger of creating homozygosity (ARR) in the national sheep flock. Homozygosity renders the national flock uniformly vulnerable to any challenge which ARR is unable to resist. That may be another strain of scrapie, or an entirely different challenge. Similarly, the elimination of ARQ (the ancestral allele), AHQ, VRQ and ARH will cause genetic erosion (extinction) of characteristics which may have special value.

D. We retain severe reservations regarding the proposal for category 3A. The breeds listed in this category coincide closely with our data for low ARR frequency, and the breeds which are most at risk fall mainly into three groups (Northern Short-tailed, Marsh and Mountain). These groups contain breeds with special performance qualities and with characteristics which assist environmental (ecological) objectives. The new proposed deadline for the sale of rams (2006) allows only one further generation of breeding from the present with normal breeding practices. Even accelerated breeding practices would allow little latitude for sensible selection and maintenance of genetic variability. Less than 10% of the population of most (or all) of the breeds in this category possess the ARR/ARR genotype. Some have a much lower frequency, and in some cases this genotype is absent. The proposed timescale would cause irrevocable change and damage to these breeds. The items mentioned above in A1, A2 and A3 merit further elaboration.

E. FMD: The intended volume of testing was reduced severely by the FMD outbreak in 2001. Awareness of the importance of biosecurity inhibited many owners from proceeding with testing as intended. In this context, an extension of the deadline by one year to 2008 is not realistic. Rare Breeds International has been pressing for a deadline of 2010, and we continue to believe that this is a more appropriate date than 2008. Clause 4 of the letter of 12 September refers to a delay of 2 years from FMD, and this should be the minimum period for extension of the scheme.

F. Tests: It is incumbent on DEFRA to take account of the imminent validation of tests to distinguish between BSE and scrapie. We have been assured previously that the cause for concern is BSE in sheep. Scrapie has been present in the national sheep flock for 300 years without any adverse effect on human health. It is our understanding that such tests may be available within 2-3 years. It would be unacceptable to permit the loss of significant genetic material in susceptible breeds by the rapid application of NSP when tests
to distinguish between BSE and scrapie will be available in the near future. In this context, we urge that no deadline is fixed for susceptible breeds, and that the situation is reviewed in the light of progress with the tests. It is our opinion that scrapie-monitoring could be used for susceptible breeds as an alternative to NSP.

G. Accuracy: We have information which indicates that results supplied to owners may not be accurate. This information has come from several sources, but we have been authorised to quote the following examples:

1.       Norfolk Horn (flock ref. 8000253): animal N5016 (ARR/ARQ) is the progeny of N2796 (ARR/ARR) and N4180 (ARR/ARR).

2.       Southdown (flock ref. 8000256): animal T2 (ARQ/ARQ) is the progeny of ST4 (ARR/ARR) and P6 (ARR/ARR).

Such discrepancies further delay the implementation of effective breeding programmes, and risk the loss of valuable genetic material.

H. It is important to establish a balance between the original objectives of NSP, and the need to accommodate the security of individual breeds and the importance of biodiversity. Breeds which have a low or nil frequency of ARR have other qualities which are important in the British sheep industry.

We make the following recommendations:

1.       That the deadlines of 2006 and 2008 are removed for breeds in group 3C. If it is not possible to remove deadlines, they should be extended to at least 2014 and 2018 to permit three normal generations of breeding. This would not help breeds with a negligible frequency of ARR, but breeds with a frequency of circa 10% ARR/ARR would have some opportunity to avoid significant genetic erosion.

2.       That the deadlines are replaced by a programme of scrapie-monitoring for breeds in group 3C, and that animals from these breeds should be permitted to enter the food chain on the basis of scrapie-monitoring results.

3.       That the development of tests to identify the presence of scrapie, and to distinguish between BSE and scrapie, should be developed as rapidly as possible and that substantial Government aid should be given to research in this field.

4.       That re-testing free of charge should be provided for animals where results indicate probable inaccuracies. The full implementation of the programme should proceed only on the basis of reliable results.


G.L.H. Alderson

24 September 2002