Ontario Wildlife Coalition
221 Broadview Avenue, Suite 101
Toronto, ON M4M 2G3
416-462-9541 (p) 416-462-9647 (f)
January 21, 2005
Dear Mr Cumby,
I am writing to you as the spokesperson of the Ontario Wildlife Coalition and on behalf of the Ottawa-Carleton Wildlife Centre (OCWC) and the Volunteer Wildlife Custodians (VWC).
We want to thank you so much for inviting us to attend your meeting on February 3, 2005.
As you know from my conversation with both you and Tamara, members of the Coalition are deeply concerned with the proposed rules and regulations that will govern the wildlife rehabilitation community in Ontario. OCWC and VWC spokespersons have expressed the same concerns and have agreed that I will write this letter on behalf of all of us.
In brief summary, we have five major concerns with the EBR regulations.
1) Our primary concern is that the 1km and 5km release restrictions for orphaned wildlife prevent responsible and humane wildlife rehabilitation. Such restrictive release criteria do not meet proven international standards and practices that prevail throughout North America, and by the Ministry’s own admission, there is no science to justify such stringent requirements.
2) The 1km and 5km release restrictions will prevent the critical final phase of wildlife rehabilitation, since many species require a soft release with transitional care provided at the release site.
3) The regulations prevent foster care families from raising orphans in their homes – thus eliminating an integral component of most wildlife rehabilitation programmes in Ontario.
4) The proposed 50 kilometre intake radius is also very problematic. Wildlife rehabilitation is a volunteer effort and Ontario is not so fortunate as to have wildlife care facilities in every city let alone spaced every 50 kilometres across the landscape. For example, a family on the way home from the cottage finds a dead mother raccoon by the side of the highway with orphaned babies. The family rescues the infants, drives home and delivers them to the nearest rehabilitation centre. The rehabilitation centre would be disallowed from admitting the orphans and forced to inform the rescuers that euthanasia is their only option. As well, orphaned and injured wildlife could not be sent to those rehabilitators who specialize in specific species.
5) The April implementation date is not acceptable or reasonable. Rehabilitators need to know the ground rules in January and February to plan for the spring, summer and fall rehabilitation season. By April, as you are well aware, most rehabilitators will already have accepted animals into their care.
Additional to the above five major issues we have additional concerns. They include: The Ministry’s inconsistent application of existing regulations among Ontario’s rehabilitators; and its unfair and punitive targeting of the wildlife rehabilitation community while allowing the commercial wildlife control companies to operate without the same kind of control, despite the fact that these companies relocate thousands of adult untreated, unvetted animals every year.
We would be delighted to attend a meeting regarding the above issues, to discuss how to implement a progressive, humane and effective rehabilitation programme in Ontario. We do not believe such a programme can be achieved under the current restrictions and therefore suggest the Ministry set a different agenda for the February 3 meeting. The agenda should include the following items:
1) The withdrawal of the EBR posting and the one kilometre release restrictions now in force.
2) An agreement to go back to the drawing board to develop a progressive, effective and humane rehabilitation programme, including criteria that will support the following internationally recognized care and release standard: “Orphaned wildlife should be raised with others of their own species, to learn proper conspecific behaviours, and the group should then be released together in appropriate natural areas, with transitional care for those species that require it, generally within the city or county of origin.”
Finally, any regulatory change affecting the rehabilitation community must first be discussed with all rehabilitators in Ontario. We are concerned that a small, unrepresentative group of people will be making decisions that will affect all rehabilitators in Ontario and as a consequence the humane societies and veterinary practices that they work with, the broad public that they serve and the politicians who receive the calls.
We look forward to meeting with everyone in the near future.
Sincerely,
Liz White, Spokesperson
Ontario Wildlife Coalition
c.c. Premier Dalton McGuinty
Honourable David Ramsay
Mr. Kevin Wilson
Mr. John Baird
Mr. Michael Prue
Ms. Elizabeth Witmer
All MPPs
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