!  Please forward this open letter to the Government of Ontario

A message from Paul and Deborah Harris: 

On July 11, we sent the message that follows to all members of the Ontario Legislature (with the exception of Andrea Howarth, MPP, who does not have an email address listed at the Queen's Park website). We also copied it to a few friends and associates and several have now asked that we provide them the opportunity to indicate to the government that they are in support of our message.

Accordingly, we are sending this to a wider distribution list. If you have received this message and would like to let the government know that you agree with the issues we raised, we would ask that you do so by forwarding them a copy of this email. This is the democratic way to let our elected representatives know what is on our minds so that they may take any actions they feel are warranted. We should tell you that two MPPs have already indicated an interest in these issues.

To do this, you will have to do the following:

1. Select the text of the letter below and copy it into your email program.
    
2. Send the letter to the full list of MPPs below.  Click here for MPP addresses and copy into the "To:" box.
    
3. Add your name and location to the top of the message and briefly state your support. We also invite you to tell them if you do NOT agree with us.

Thank you.

July 11, 2004

An Open Letter to the Government of Ontario:

Your Wildlife Management Practices and Policies Endanger the Health of all Ontarians

First, let us get some housekeeping issues out of the way. We are members of three organizations who are concerned with the care and management of wildlife. One of those organizations is Ontario-based while the other two are international in scope and domiciled in the United States. Although we know that most members of all three organizations will be supportive of the position that follows, this letter should not be construed as anything other than our opinion.

At present the management of wildlife in Ontario is the responsibility of the Ontario Ministry of Natural Resources (MNR). One of the ministry's main goals is to produce revenue and manage the funds that are generated from wildlife. The primary revenue comes from the sale of licenses and permits for hunting, fishing and trapping. Because hunters, anglers and trappers generate revenue for the province, those who support the humane care of wildlife have little success in bending the ear of the government.

MNR has the authority to develop policies regarding wildlife. It has been painfully slow to develop coherent and approved policies but the concern we are raising here is that current practices of the ministry - and some of the proposed policies - may result in situations that put at risk the health and well-being of Ontarians

Background

MNR grants authorization to interested and qualified persons who meet a set of criteria for the care of orphaned and injured wildlife. The role of the person, the 'Authorized Wildlife Custodian' (AWC), is to eventually release the animal back to the wild, or humanely euthanize any animal whose chance of survival is adversely compromised. The MNR has established rules which govern the actions of the AWCs although experience has shown that these rules are ad hoc from region to region, are inconsistently applied, and are frequently at odds with accepted wildlife rehabilitation principles. As authorized custodians ourselves, we are aware of a level of discussion and debate among AWCs, their organizations, and the MNR about the need for and efficacy of several of practices and proposed standards. To date, no resolution to the differences in views has been found, so far as we are aware.

The two American organizations noted above - International Wildlife Rehabilitation Council (IWRC) and National Wildlife Rehabilitators Association (NWRA) - have jointly produced a lengthy and comprehensive set of minimum standards for the maintenance of wildlife. The standards pertaining to the issues addressed in this letter are internationally accepted as fair, balanced, reasonable and practical to implement. Indeed, MNR frequently acknowledges IWRC-NWRA as the authorities of record with regard to wildlife issues - except where an IWRC-NWRA standard is in conflict with the private project of an MNR official.

However, there is major conflict between the rehabilitation community in Ontario and the MNR with regard to one particular species, which is the raccoon, and that conflict may very well lead to compromising the health of Ontarians.

The issue has been the potential spread of raccoon rabies in Ontario. The disease slowly made its way north from the United States and was first detected in eastern Ontario in 1999. This was despite the ministry's vaunted declaration in 1997 that they had a solid plan to prevent rabies entering the province. But even after that plan proved faulty, and rabies did enter the province, MNR's response was to swat a fly with a tree trunk. In the last quarter of 2003, there were no reported cases of raccoon rabies in eastern Ontario so MNR declared that their massive, but unnecessary, slaughter of raccoons did have a positive result. But other responsible jurisdictions across North America have achieved similar results without the need to kill off massive numbers of animals.

For many years, the MNR has sponsored research under the Rabies Research and Development Unit (RRDU). This unit, who failed despite publicly proclaimed plans to the contrary to prevent rabies from entering Ontario, has become the mouthpiece for the MNR's standards and rules for wildlife custodians.
Continuing to follow the lead of RRDU will, if not unchecked, ultimately imperil the health of Ontarians.

The Harsh Rules

There are three rules in particular that reveal a fundamental lack of understanding by MNR officials of the most basic principles of wildlife rehabilitation.

'One kilometre rule' for rabies vector species:

MNR requires that rehabilitated wildlife be returned to a release site within one kilometre of where the animal was originally found and permission from the owner of the property must be obtained. If this is not reasonable or cannot be done (using a dumpster in downtown Toronto as an example), then the animal(s) must be euthanized. Relocating the animal to a forested or countryside area, even to Crown land or conservation areas, is not an acceptable solution for MNR. This rule seems to exist to support and promote the fear-mongering approach to rabies. This appears, at least in part, to be the casus belli for providing a significant budgetary allowance for RRDU as it continues to use taxpayers' money to replicate studies already successfully completed in other jurisdictions.

Interestingly, the IWRC-NWRA standard is 10 miles, whenever possible.
Unlike the MNR focus, the authority of record supports a responsible release to a safe location with suitable denning sites and nearby food and water.

[While there is no doubt that rabies is a serious disease, the government would do well to consider the cost of RRDU as compared to the cost of rabies as a health hazard. A study conducted in the state of New York concluded that the state's funding of rabies-control programs on a per-victim basis would be the equivalent of the state providing annual funding of $3.9 billion dollars for tuberculosis, $800 million for influenza, and $1.3 trillion for cancer. As you can appreciate, it does none of those. (1999. Rabies: Economics vs. Public Safety. Tuttle, Merlin D. BATS. Vol 17, No 2:3-7.)]

'Bundling':

It is very common for an AWC to be presented with single orphaned animals.
For most species it is critical for the animal to be raised with others for socialization and to promote healthy development of behaviours and skills specific to the species. The current MNR rules forbid the bundling of single orphans, using rabies as the catalyst behind this decision. Yet wildlife rehabilitators the world over recognize this as one of the most important features of wildlife care.

Let us be clear: this rule is frequently vocalized by MNR officials although we have been unable to discover verification in any guidelines or legislation that this is indeed the applicable rule.

Again, organizations like IWRC-NWRA support and encourage bundling for the healthy development and eventual successful release of the animal.

'Rabies Vector Species and Point Infection Control (PIC) program for designated high risk areas':

Restrictions are in place regarding the rehabilitation of so-called 'rabies vector species' (RVS) which includes raccoons, skunks, foxes. The rules state that in the so-called 'high risk' area of eastern Ontario, "it is illegal to relocate raccoons, foxes and skunks. As well, raccoons, foxes and skunks captured in the high-risk area must be released immediately at the point of capture, or humanely euthanized as soon as possible and within 24 hours" (Point Infection Control program, RRDU Website).

What is particularly interesting is the Ministry's definition and determination of 'high risks' areas. The most recent article on the RRDU Website pertaining to rabies control in 2004 states that "Ontario's success . is attributable to the introduction of high-risk areas in eastern Ontario" and "that efforts will continue since several cases of raccoon rabies were confirmed within 10 km of the City of Ottawa boundary in 2000 and several raccoon rabies cases last year were near to the city's boundary."

How long will the MNR continue to fear-monger on the strength of a finding from four years ago? The website fails to mention that of the almost 9,700 animals killed in the Ottawa area since 1999 under the PIC program, almost 99.8% were healthy.

The website lauds the success of the Rabies Control Program but notes MNR will still refuse to remove the 'high risk' designation from Ottawa even though, according to the Rabies Reporter (Rabies in the Fourth Quarter and a Review of Rabies in 2003, Beverly Stevenson, RRDU, Peterborough): "For the second consecutive quarter the were no confirmed cases of raccoon strain rabies in Ontario." In other words, the area appears to be designated 'high-risk' because of a disease which was present in the area four years ago.

It should also be noted that estimates show approximately 2% of all bats carry rabies and these are found throughout Ontario. Where is the intensive campaign to protect the public from bats?

It appears to us that MNR continues to mislead the public that rabies is widely prevalent in Ontario. Perhaps this is in order to justify the budget of the RRDU and its continued replication of studies already done elsewhere.

RRDU's actions in attempting to 'control' rabies have also caused a great deal of concern in the rehabilitation community where we all have access to the published results of a program in Ohio which achieved eradication without the euthanization of a large population of healthy animals.

The Danger for the Public

Persons who are presently AWCs are increasingly under pressure from MNR to comply with unworkable standards. Although MNR proclaims that it looks to custodians as the 'experts' in wildlife issues, it persists in attempting to insert its own emphasis in wildlife management and in contradiction to internationally acknowledged standards.

There is a well established network of custodians across Ontario who communicate with each other for help, guidance, and support. A very small but dedicated number of custodians and rehabilitators belong to the Ontario-based organization mentioned in our opening paragraph. But, increasingly, we are seeing evidence of custodians surrendering their authorizations or having them stripped by over-zealous or misinformed MNR officials. In the eyes of the custodians, the AWCs are most often being punished for insisting on proper and appropriate wildlife care in the face of unsupportable ministry practices.

It must be understood that people who become wildlife custodians are generally passionate about the humane care of wildlife. Surrendering or being stripped of ministry authorization to provide that service (a service, by the way, funded entirely from the custodians' own resources and without taxpayer support) may well result in peril to the general public.

Where the peril arises is that the general public, who has been able to rely on authorized custodians, will no longer be able to locate custodians and may undertake the task of rehabilitation themselves. They will almost certainly not have sufficient knowledge to protect themselves, their families, their pets, and the wildlife from harm. The spread of a readily controllable animal disease, such as rabies, may follow.

In 20 out of 21 American states with many years of experience in dealing with raccoon rabies, rehabilitation of RVS by authorized or licensed rehabilitators is permitted as being vastly preferable to leaving the uneducated public to do it. Ontario's policies and practices are creating a readily avoided health hazard.

What is Needed

These are the steps we believe are necessary in order to properly care for Ontario's wildlife and to ensure that neither danger nor health hazard for the citizens of this province:

• An immediate adherence to the internationally accepted IWRC-NWRA rehabilitation standards pertaining to bundling and release for both RVS and non-RVS animals
   
• A re-evaluation of what constitutes 'high risk' areas and how geographical boundaries are determined
   
• A more cost effective and humane approach to rabies control
   
• Public education on the needs of injured/ill or orphaned wildlife with advertising by the government of a clear and easy path to the rehabilitators
   
• Removal of wildlife rehabilitation from the control of MNR. This Ministry has as its concern the financial value of marketing wildlife; its only interest in maintaining a rehabilitation program is so that the animals can grow up to be killed by someone to whom MNR has sold a license. The care of wildlife more properly belongs within the purview of the Ministry of the Environment.
   

We are urging all members of the government, and all members of the legislature, to petition the Premier's office with a view to asking the Premier to bring about these changes. It is our understanding that prior to his election as Premier, Mr. McGuinty expressed support for the wildlife rehabilitation community. It is time for him to translate that support into action.

Yours with respect,

 

Deborah and Paul Harris

Denfield, Ontario

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