! Call for an inquiry into MNR's mismanagement of wildlife rehabilitation in Ontario
Ontario Liberal candidates join leader in calling for
an inquiry into government's closure of
Ottawa-Carleton Wildlife Centre.
An open letter to the Premier
of Ontario for an inquiry into the treatment of
wildlife seized by the OMNR.
We believe the two key issues, from a political perspective, are the need for an Inquiry and the need for Change. The former stems from the Tory-created fiasco that involves deception and breach of public trust, abuse of power and misuse of public funds with respect to wildlife issues in eastern Ontario. The latter represents the Liberal recognition of the problem and the commitment to modernize wildlife and environmental services so that they reflect community values and public opinion in Ontario.
While an inquiry is essential to restoring any level of public trust or confidence, this is an excellent opportunity to not just identify yet one more government problem but to rectify it and to move forward in a positive new direction.
Letter to Premier of Ontario
An open letter to the Premier of Ontario makes a formal request for an
inquiry into the treatment of wildlife seized by the Ontario Ministry of
Natural Resources in a controversial raid on the Ottawa-Carleton
Wildlife Centre in September 2002.
Read letter to Premier Eves.
I. An Inquiry – The Animals that were Seized:
There was no justification for taking the animals that were confiscated by the MNR from the OCWC. They came from Ottawa where there has never been a case of raccoon rabies, they were fully vaccinated against rabies with a vaccine provided by the MNR, they had already been in quarantine for beyond any scientifically-proven incubation period and, as is the standard practice, would have been over-wintered at the OCWC
Instead, the animals were taken to an MNR research facility where they were separated and kept in
small cages in violation of basic humane practices as well as
international standards for wildlife
rehabilitation care – standards the MNR itself imposes on wildlife rehabilitators in Ontario!
- They were kept in these unacceptable conditions for over seven months, three times longer than the longest-known incubation period for raccoon rabies
- Requests made to inspect the animals and the facility by the OCWC and its veterinarians, the media and even a representative from the Canadian Council on Animal Care were turned down
- Judge recommended rehabilitation before
A justice of the peace, after hearing testimony from MNR and OCWC witnesses, indicated he felt it would be in the “best interest of the animals” to be returned to the OCWC for a brief period of rehabilitation before release given their compromised care. He indicated his regret that a legal technicality prevented him from ordering the animals be returned.
- Premier Ernie Eves, made a commitment on an Ottawa radio show on April 28 to look into the matter immediately given the strong public concern about the MNR decision to release these animals without any rehabilitation or an independent assessment
Healthy animals released in rabies hot zone:
In spite of this, the animals, nevertheless, were “released” a few days later to meet a May 1st deadline to which the MNR seemed obsessively committed but many saw was a “rush to get rid of the evidence”
- It was later learned through a Kanata Kourier-Standard investigative report that these animals were released at “ground zero” in Edwardsburg-Cardinal Township where there are current cases of raccoon rabies and where animals are consequently being trapped and killed as part of MNR “depopulation” activities
- Why would animals taken from Ottawa where there has never been a case of raccoon rabies be released into an area in another county where there are current cases of rabies? These animals were seized at great public expense and kept in the most inhumane manner for many months only to be released a hundred or more kilometers away from where they came and in violation of the Ministry’s own one-kilometer release restriction
- The answer, we believe, is now clear. These animals were taken and used for research purposes. The MNR is a partner in a major grant from the Natural Sciences and Engineering Research Council of Canada that identifies as part of the research activity schedule “the development of real time rt-pcr for rabies virus detection – this will involve using control samples that have been seeded with known amounts of viral RNA to assess limits of detection of this approach compared with the standard antibody approach. It will be then compared with the current rt-pcr approach”.
The anticipated starting date was May 1, 2003.
II. An Inquiry – Connected Issues:
- The expansion of the raccoon rabies high-risk zone in July 2002 was unjustified, it was based on misrepresented facts, it has been totally discredited and is viewed by many as a serious breach of public trust.
- Given that no human has ever died of raccoon rabies, the outlandish and unsupportable fear-mongering used by the MNR to promote its raccoon rabies program is an insult to the public’s intelligence and brings further discredit to the MNR and the government of Ontario
- The killing of over 8,500 healthy wild mammals in eastern Ontario as part of the MNR “depopulation” activities is scientifically-unproven, costly and ineffective compared to states like Ohio which has become the “model” for raccoon rabies control.
- The major Natural Sciences and Engineering Research Council of Canada grant to the MNR creates pressure to continue to “find” new cases of raccoon rabies and to rely on “depopulation”, increasing the focus on what has become an unprecedented slaughter in North America. One that will become more controversial and embarrassing to Ontario until it is stopped.
- The orchestrated campaign by the MNR to close the OCWC and the high-handed treatment of community volunteers has meant the loss of a valued community service
- A further loss is reflected in the significant public-private partnerships that took the OCWC so many years to build in delivering this community service
and that have now been lost due to the actions of the MNR. The Ontario
government allowed this to happen at a time when the federal government has
recently signed an Accord with the Voluntary Sector, acknowledging the key
role that it plays. An example of the partners lost is conveyed in a recent
newsletter from the Alta Vista Animal Hospital. It had provided outstanding
service in training young wildlife interns each year and in donating close to
$150,000 of professional support over the years to the OCWC.
- The closure of the OCWC has also meant that the City of Ottawa is having to face the social, health and financial consequences of the loss of a wildlife response service. The City, along with many community organizations, has been left to pick up the pieces. The MNR has created a crisis where none existed before and, as one City Councillor said, in referring to the MNR claim of wanting to protect human health, “the cure is worse than the disease”.
unworkable wildlife rehabilitation regulations
The McGuinty Liberals promised, prior to their
election in 2003, to “reinstate progressive wildlife
rehabilitation services in Ontario and to develop a new
and improved working relationship between government and
community volunteers in this regard”.
In spite of these promises and thousands of submissions
from wildlife rehabilitators and members of the public
across Ontario, the regulations announced by the
Ministry of Natural Resources in October 2005 will
perpetuate the on-going crisis that has made it
impossible to provide humane and responsible help for
most orphaned and injured wild mammals in Ontario.
In fact, under the McGuinty government, things have been
made much worse for orphaned wildlife and for the public
seeking help on their behalf. Here is why:
1) Unworkable Release Restrictions: The
Ministry’s proposed 15-kilometer release restriction for
rehabilitated orphans is arbitrary and unworkable and is
not based on any proven science.
While it is fully accepted that adult wildlife should be
returned to their familiar home territory, orphaned
wildlife have no established territory as they are still
within the nest or den when rescued. The majority of
these orphans have resulted from the adult mother having
been trapped and relocated, killed on a busy road or
otherwise compromised because of extensive development.
Putting young animals, after months of rehabilitative
care, back into these situations would be irresponsible,
giving them no chance of survival and would be severely
and rightfully criticized by residents because of the
impossible situation faced by the animals and the
predictable human/wildlife conflicts it would also
Wildlife rehabilitators have consistently stated that
the single most important minimal requirement for
responsible rehabilitation is that orphaned animals
be raised with others of their own species to learn
proper conspecific social behaviours and that these
animals be released in appropriate natural areas, with
transitional care for those species who require it,
generally within the city or county-of-origin.
The Ministry well knows that a 15-km. release
restriction for orphans ignores the fact that most large
cities, where the majority of orphaned wildlife is
found, have boundaries that stretch to 90 kilometers or
more. The highly developed and busy inner core of these
areas makes up to 30-40 kms. and has limited natural
habitat that is a suitable distance from human
development and traffic for responsible release.
Furthermore, the 15-km. release restriction eliminates
the vital role played by volunteers with suitable
property who agree to provide the critical transitional
care required by young animals as part of their release.
The 15-km. release restriction also means that single
animals would have to be raised alone, creating
habituated “pets”, dependent on humans, which is the
utter antithesis to responsible and humane wildlife
The Ministry has ignored the previous successful release
practices that have never produced any human health
concern in Ontario. It has ignored the successful
practice in 22 U.S. states where the majority allow for
“flexible release options for rehabilitatated orphans,
whether that is within county-of-origin release or
within suitable habitat”.
The effect of the regulations is to create a climate in
which the Ministry can maintain coercive control over
rehabilitators by forcing them to refuse to take
orphaned wildlife because they cannot rehabilitate them
humanely, to raise and release young wildlife where they
will have little chance of survival or to lie to
Ministry officials about their activities in order to
care for baby wild animals humanely.
2) Inconsistent Application of Standards: The
unfettered authority given to MNR area supervisors,
including the approval, denial or cancellation of
authorizations without any appeal process or recourse
available to the rehabilitator, will eliminate equitable
treatment of wildlife rehabilitators and produce an
inconsistent application of standards across the
province, resulting in a coercive and unfair system.
There are currently gross inconsistencies in the
application of the regulations between the different
Ministry offices. Some districts have been only too
happy to “look the other way” telling select
rehabilitators that they “don’t have the resources to
enforce the regulations” while other districts have
carried out high-handed harassment campaigns against
rehabilitators and required absolute adherence to the
Why, when there is an increasing public demand for
government transparency and accountability at all levels
has such an obviously flawed and potentially corrupt
system been put in place?
It is essential that the Ministry of Natural
Resources reverse this policy and establish a
centralized and transparent custodial authorization
process that ensures equitable treatment of wildlife
rehabilitators and consistent application of the
standards across the province.
3) Lack of Appeal: The discretionary authority
given to area supervisors and the lack of any appeal
mechanism for wildlife rehabilitators to argue
unreasonable decisions or, for that matter, to even be
told what the decision is based on, means that
rehabilitators have been stripped of their most
fundamental rights, an unprecedented and fully
unacceptable situation in any democratic society.
The significant financial, legal and liability
responsibilities assigned by the Ministry to wildlife
rehabilitators in caring for wildlife are without
parallel. And, yet, wildlife rehabilitators have been
denied their rights in fulfilling these
Sport and recreational hunters are licensed by the
Ministry with far fewer responsibilities and, yet, they
have access to an appeal and fair hearing process under
the Fish & Wildlife Act. The Ministry is prepared to
uphold democratic rights for those that kill wildlife
but is not prepared to do so for those that care for
wildlife. It is unconscionable that wildlife
rehabilitation volunteers who take on such significant
responsibility and who earn no compensation for serving
wildlife and their community, should have to tolerate
the elimination of their right to fair, equitable and
respectful treatment under the Ministry of Natural
Wildlife Custodial Authorization holders must be
granted the same rights, including the full right of
appeal, as is granted to licence holders under the Fish
and Wildlife Conservation Act and Regulations.
The Hypocrisy of Targeting Wildlife Rehabilitation:
What exposes the very transparent deception in the
Ministry’s professed concern about “protecting public
health and the health of wildlife populations” is that only
wildlife rehabilitation is targeted. The Ministry ignores
or does nothing to enforce restrictions on wildlife removal
companies or homeowners who annually trap and relocate tens
of thousands of adult animals without any regard for the
state of their health. Particularly, when minimal public
education efforts by the Ministry (long recommended by
rehabilitators) such as posting notices in stores selling
traps about the legal restrictions on relocation could make
a huge impact in deterring the practice. It would also
substantially reduce the numbers of orphaned wildlife
needing rehabilitation in the first instance, given that
60-70% of orphaned wildlife are “created” orphans by the
trapping and relocation of the adult.
Compared to the tens of thousands of adult animals
relocated, there is an extremely small number of orphaned
wildlife that are rehabilitated and released in Ontario
each year. In fact, so infinitesimally small that wildlife
rehabilitation serves only as a symbolic gesture that has
little impact on the environment. It does, however, provide
an important outlet and educational benefit for the growing
number of people who recognize it is our substantial impact
on the environment that has caused the need in the first
Furthermore, there are no disease concerns with respect to
rehabilitated orphaned wildlife. As the Ministry well
knows, disease concerns are eliminated by the fact that
orphaned wildlife are cared for under close observation by
experienced rehabilitators, they are regularly tested and
treated for parasites, they are vaccinated against
diseases, they are regularly seen by veterinarians and they
are kept beyond disease incubation periods. This ensures
that the healthy young vaccinated animals that are released
actually provide a disease barrier and contribute to the
health of the general wildlife population.
What this is Really All About: The public is no
longer fooled with respect to the MNR agenda. It is
increasingly clear that the regressive and unwarranted
regulations imposed on wildlife rehabilitation in Ontario
are due to the fact that the Ministry and its partners
cannot attract multi-millions of tax dollars for rabies
research, testing and operations unless they can maintain a
high degree of public fear that raccoon rabies is a
significant disease threat when, in fact, it is the lowest
public health risk in North America, thanks to pet
vaccination. Wildlife rehabilitation and its promotion of
respect and understanding for wildlife represents an
impediment to creating this climate of irrational fear. It
is, therefore, a significant threat to rabies funding
programs, particularly at a time of increased competition
from what are serious government spending priorities.
Abuse of the EBR Process: In July 2002, the MNR
abused the EBR process by posting changes to wildlife
rehabilitation regulations on the basis of intentionally
misrepresented information while fabricating a non-existent
“emergency” to deny public input.
Now, in spite of years of strong public protest during
which time the Ontario Liberals, while in Opposition,
presented petitions from over 9,000 residents in 260
communities in the province demanding changes to those
regulations, the changes put in place in October 2005 by
the McGuinty Liberals, in fact, make matters worse. That is
likely why there has been no consultation with the majority
of wildlife rehabilitators in the province and why there
will continue to be a serious lack of help for people
seeking assistance on behalf of wildlife in distress in
Summary: While Ontario has legislation that provides
for wildlife rehabilitation, the bias against it within the
MNR has created such restrictive regulations and negative
attitudes that it is disallowed. Frankly, the regulations
must either be changed and wildlife rehabilitation housed
within a ministry that can accommodate the public values
that support it, or the legislation should be rescinded. At
least that way, Ontario will stand honestly in one place or
the other – either as a very unprogressive province or it
can join the majority of North American communities that
provide the modern wildlife response demanded by the
Wildlife rehabilitation services cannot survive under the
aegis of the Ministry of Natural Resources. It is a
question of such fundamental differences in mandate,
culture and philosophy that there can be no compatibility.
The mandate of the MNR is that of a regulatory agency
concerned with the harvesting of wildlife, its funding
received from licence revenue from that activity. It holds
solely a population level view of wildlife while wildlife
rehabilitation places value on individual animals that make
up populations. The fact that an increasing number of the
public view wildlife in broader conservation terms than
does the Ministry and in that a majority of the public
support wildlife rehabilitation means that the Ontario
government will soon be forced to address this reality by
reflecting community values and changing public opinion.