May 2004

Dear Mayor and Members of Council

Attention: Clerk’s Department

The Ontario Wildlife Coalition was formed out of concern for the Ministry of Natural Resources handling of wildlife issues and the impact of the Ministry’s decisions on communities and local councils.

The Coalition is specifically concerned with the direction the Ministry is taking with its raccoon rabies programme. The concerns include:

• a rabies policy that has resulted in the killing of 9,700 wild animals since 1999, with almost all (99.8%) turning out to be healthy;
   
• the Ministry’s action, declaring the City of Ottawa as a “hot zone” in July 2002, without consultation or justification; and
   
• the few remaining, just 6 cases of raccoons found with rabies, at that time were nowhere near the City. In fact the Ministry’s own documentation shows that the disease was moving even further away from the Ottawa-Carleton region.

The Ministry has chosen this course of action when virtually every other jurisdiction in North America has adopted a much more cost-efficient and humane approach of using oral vaccine delivered by aerial or ground baiting.

The Ministry has used the Ontario Environment Commissioner’s web site to post its intent but seeks no public input. So it is reasonable to be skeptical about a highly controversial scientifically-unproven rabies control programme and to question why the Ministry continues to kill huge numbers of healthy animals.

We urge you to review the attached Background Paper on the experience in eastern Ontario. It questions why we should be anticipating further cases given that Ontario taxpayers have spent millions of dollars over the last ten years on raccoon rabies programmes. Compare this to Ohio where an oral vaccine and baiting programme has pretty much eradicated raccoon rabies in just three years for a fraction of the cost.

In addition to diverting provincial funds that are badly-needed for priority health, education and social objectives in communities with limited resources, the policies surrounding the Ministry’s raccoon rabies programme have other very negative implications for municipalities, particularly those fortunate enough to have wildlife rehabilitation programmes. The impacts include regulations:

• which are unprecedented in North America and which forbid rehabilitators from accepting animals such as raccoons, skunks and foxes in areas it has designated as a “hot zone”;
   
• that require all rehabilitated orphaned wildlife throughout the province to be returned to within one kilometer of where they were rescued, no matter how inappropriate or busy the area;
   
• which have forced many wildlife rehabilitators who have taken years to develop volunteer programmes with community involvement, to close; and
   
• that pressure rehabilitators to comply, forcing some of the few remaining to state that they cannot continue under these conditions.

The situation prompted over 9,000 Ontario residents from 260 municipalities to petition the Ontario Legislative Assembly for changes that will ensure progressive and responsible wildlife rehabilitation services within their communities. Their signatures were presented by Liberal MPP’s and the Liberal government has made a commitment to reviewing the Ministry’s programmes and its policies in this regard.

In the meantime, however, it means that many municipalities face the loss of

• a wildlife rehabilitation service and prevention programme in their communities;
   
• facilities to handle sick, injured and orphaned wildlife, leaving them in the hands of those who want to save, not kill, the animals they have rescued;
   
• prevention programmes that reduce and resolve human wildlife conflicts in the urban setting, and
   
• knowledgeable people to assist municipalities in answering questions about wildlife that reduce the public’s risk and exposure to wildlife diseases such as rabies.

In light of the problems that are now arising out of the Ministry’s raccoon rabies programme, we are asking Councils across Ontario, including yours, to consider the following motions:

1. to request that the MNR discontinue the practice of “depopulation” or the non-selective killing of wildlife, a practice that would be strongly opposed, particularly as it has seen over 9,700 wild animals killed since 1999, with almost all (99.8%) turning out to be healthy;
    
2. to ask the Ministry to adopt a “best practices” raccoon rabies programme that provides an effective, cost-efficient and humane strategy such as the Ohio model, now being used as a nationally coordinated method in the United States;
    
3. to urge the Ministry to bring Ontario in line with the majority of jurisdictions in North America that consider wildlife rehabilitators as a vital part of their rabies control programme and license wildlife rehabilitators to handle rabies vector species while using universally-accepted standards for the care and release of all wildlife;
    
4. to indicate to the Ministry the urgent need to adopt a cooperative approach with municipalities, community organizations and wildlife rehabilitators in providing effective wildlife response based on realistic and progressive public education, not alarmist fear-mongering and the denial of help for people seeking to assist wildlife in distress.

We urge you to put the enclosed report on Council’s agenda for discussion. We ask Council to forward any motions to the Minister of Natural Resources.

If you require further information, please do not hesitate to call.

Sincerely,

Liz White
Animal Alliance of Canada
416-462-9541

Barry MacKay
Animal Protection Institute
905-472-9731

Donna DuBreuil
Ottawa-Carleton Wildlife Centre
613-282-3755
 

Backgrounder

If there is cynicism about the Ontario Ministry of Natural Resources raccoon rabies control programme, it is not without reason. Over the last ten years, this program has cost Ontario taxpayers millions of dollars in contrast to Ohio which has pretty much eradicated raccoon rabies in just three years. Using an oral vaccine delivered through aerial drops, Ohio has become the “best practices” model in North America.

Since the artic fox strain of rabies has also been successfully contained in Ontario through the oral baiting method, it leads one to question why the MNR is using the much more costly and controversial point-infection control (PIC) where over 9,700 raccoons, skunks and foxes have been killed in the last few years with almost all (99.8%) turning out to be healthy animals.  Millions more has been spent by the federal government in the unnecessary testing of these animals.

It is for this reason that we felt it important to issue an alert to municipalities on the status and impact of the raccoon rabies program and to ensure, based on what has happened in eastern Ontario, that should new cases of raccoon rabies be “found” in your area, to be skeptical. Here is why:

• In July 2002, in spite of just six remaining cases of raccoon rabies, contained in a very small area and moving much further away from Ottawa, the MNR expanded the high-risk area to include the City. The Ministry’s justification for the expansion, that there were new cases moving closer to Ottawa, was shown to be entirely false and challenged by Liberal opposition members, the media, Ottawa councillors and even a Conservative government Minister at the time.
   
• However, several months later, after the announcement of a major research grant, the disease made a dramatic shift in direction and an equally unusual jump of 50 kilometers. It certainly raises unanswered question about why cases of raccoon rabies had almost tripled in the first two quarters of 2003 over 2002 and were, at that time, moving toward Ottawa.
   
• These questions and concerns prompted environmental and animal welfare organizations to issue a Report to the government of Ontario challenging the ineffective, costly and inhumane MNR raccoon rabies program and its negative impact on municipalities. The Report can be viewed at www.wildlifeontario.ca. A letter was also sent to Ottawa councilors and area MPP’s relaying concern and urging that a thorough investigation be carried out if a case of raccoon rabies was to be found in the City along with the message that there would be strong public opposition to the use of depopulation. The letter was sent in June 2003.  It is interesting to note that the last case of raccoon rabies was reported in eastern Ontario just a few weeks later on June 30th.
   
• The Ministry has failed to provide a clear assessment of the point infection control (PIC) programme but when asked, claim that the programme has been a success.  However, the Ministry appears to be planning for more cases of raccoon rabies as the major research grant referenced above is dependent on significant raccoon samples from depopulation areas.  If the programme is such a success and if raccoon rabies is under control, it begs the question why such an extensive research programme would be necessary.  Could it be that in the face of increased competition from serious human risk diseases like West Nile, SARS and BSE, the MNR has to maintain the public profile on raccoon rabies to ensure the extensive funds allocated to its research.
   
• The unwarranted public funding directed to the MNR raccoon rabies program has diverted badly-needed support for basic health and social programs in our communities. Why is it that growing public funds are directed to the study of a disease that constitutes the lowest public health risk in North America? There has been only one human death from raccoon rabies in the fifty years since the disease was discovered and in spite of thousands of positive-tested animals in densely human populated areas.

Municipal Impacts:

• The Ministry’s raccoon rabies program has been accompanied by regressive regulations that prevent wildlife rehabilitators from accepting raccoons, skunks and foxes, forcing the general public to care for wildlife and greatly increasing the risk to themselves, their children and pets. The public are told to turn these animals over to the Ministry who will kill them.  When faced with such an option people usually refuse to hand the animals over, and in the face of this obvious problem, the Ministry claims that Ontarians will not break the law.  The Ministry has effectively poisoned the relationship with many wildlife rehabilitators in Ontario, destroyed by the Ministry’s heavy handed approach to rehabilitation.  This has resulted in the caring of sick and injured wildlife by inexperienced people.  Under the current situation, the Ministry has no idea how many sick animals are involved, where they came from and how and where they will be released if they survive.  The seizure of raccoons from the Ottawa-Carleton Wildlife Centre has generated concern from members of the public about the safety of turning wildlife over to other wildlife centres still in operation, worried that their animals may be seized as well. In contrast, almost all U.S. states, with many more years of experience in dealing with raccoon rabies, have long acknowledged the important role that experienced wildlife rehabilitators play in the fight against wildlife diseases.
   
• By eliminating progressive help for the public with respect to wildlife, the MNR has effectively downloaded costs to municipal governments, veterinarians and humane societies, forcing them to respond in a purely reactive way and creating a great deal of frustration and anger on the part of the community.
   
• There was no advance consultation with municipalities and/or health departments about the implications of these changes in the regulations. In fact, an MNR document received through public access, identifies that the announcement of these changes would be withheld so as “to prevent any pre-emption in the media from any of the affected stakeholders”.  Ottawa City councilors, for example, received notice on the day the changes went into effect.
   
• The Ministry’s regressive regulations are now impacting communities across the province through the loss of wildlife rehabilitation services. Many wildlife rehabilitators who have taken years to develop volunteer programmes with the community’s involvement, have been forced to close.  While in Opposition, Liberal members presented almost 9,000 signatures to the government from over 260 municipalities in Ontario urging changes to the MNR regulations which have eliminated responsible and humane help for wildlife in Ontario.
   
• The Liberal government has promised a review of the MNR raccoon rabies program. We are urging them to fulfill this commitment as soon as possible by carrying out an independent risk analysis evaluation of the program, something that has obviously not been done since the program commenced more than ten years ago.

In the meantime, we urge you to be vigilant in challenging and investigating any reports of cases of raccoon rabies in your area. The cost for your community, in not doing so, is simply too high.