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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:
- Select the text of the letter below and copy it into your email program.
- Send the letter to the full list of MPPs below.
for MPP addresses and
copy into the "To:" box.
- 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.
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
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
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
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
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.)]
It is very common for an AWC to be presented with single
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
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
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
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
- 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
- Public education on the needs of injured/ill or orphaned
advertising by the government of a clear and easy path to
- 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
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