Rabbit Advocacy Animal Matters

 

No clear status on rabbits 

Comment: We have spoken to staff at the Fish and Wildlife Division of the Environment Ministry as well as written to the Environment and Community Ministries regarding the designation of the European Rabbit as wildlife as soon as they are abandoned and turned loose to the outdoors.  These same rabbits are sold in pet stores as companion animals, just like dogs and cats.  We’ve asked that municipalities regulate or prohibit the breeding or sale of intact rabbits, as a proactive measure, but so far there is no legislation specific to their sale.  We’ve also asked store owners to voluntarily stop selling baby rabbits.  The cycle of breeding to abandonment is acknowledged by decision makers as one that needs to be addressed.  While we wait and wait, countless more rabbits are bred, and later dumped by heartless individuals who have grown tired of them.  Following is some written correspondence on the matter.      

July 11, 2007 

To: Honourable Pat Bell
Cc: Honourable Barry Penner 

Topic: Domestic rabbits turned loose 

When I first became involved in rabbit rescue/advocacy in the early 1990's there weren't the same numbers of rabbits being dumped outdoors as there are today.  With their increasing popularity and exploitation as a companion animal the instances of abandonment have also increased.  Baby bunnies are most often purchased on impulse and once the novelty has worn off the "pet" becomes disposable. 

Most end up in our communities and throughout our province there are many established colonies. 

Richmond, Surrey, Victoria, Vernon, and Kelowna have all attracted media attention with their exploding rabbit populations.  What we need is a collaborative effort of updated municipal bylaws and provincial regulations pertaining to the unregulated breeding and selling of these animals. 

Commercial and "backyard" breeders are contributing to the homeless population. There is an over-abundance of perfectly health rabbits at rescue groups and shelters everywhere.  The BC SPCA admits to taking in nearly 1,700 each year at its branches and if they can't find homes for them they are put down.  I've been told by many people that they'd rather let their rabbit loose than take it to the SPCA because of their poor track record in "speaking" for the animals. 

However, introducing a domestic rabbit into the wild is an illegal act and can create an imbalance in native ecology as well as encourage other wildlife to the area. The GVRD has flyers posted asking that people not release their pet rabbit in Colony Farm Regional Park as vegetable crops are being devoured and burrows are creating potential hazards for visitors.  Farmers and other homeowners who consider them a nuisance are taking matters into their own hands, employing measures such as "shotgun euthanasia" or trap and kill, in efforts to eradicate them.  Not only is this dangerous it may also cause suffering and a slow, lingering death.  Lethal methods simply don't work, and address symptoms and/or consequences only, not the causes. 

Hiring "conservation" officers or hunters, who have vested interests, does not meet with public approval nor is it cost-effective.  Funding this type of nonsense is a complete waste of taxpayers' money.  After much public input and researching the issue, the Town of Canmore has decided to let the rabbits be, and instead give residents tips on how best keep them away from their gardens.  This is similar to our more humane "Bear Aware" program which focuses on preventing conflicts. 

We need to eliminate the sale of live "product" in all retail outlets, regulate and reduce the lucrative breeding industry, raise awareness and educate the public as to responsible pet guardianship, implement spay/neuter

programs as part of any sale or adoption procedure, and make it affordable to those on low incomes.  At this time California is debating a pet-sterilization law aimed at reducing the numbers of pets needlessly put to death solely because they don't have a place to call home.   

Common sense proactive measures, combined with legislation, is what works, and it is our obligation to implement actions that respect and value other living beings.  We can’t continue to be reactive and wipe out whatever we find inconvenient.

For further information on rabbit matters and animal welfare please view the following: 

http://www.petsinneedsociety.ca/  

http://www.petsinneedsociety.ca/news.htm  

Sincerely,  

Carmina Gooch, Director
Pacific Animal Foundation
Pets In Need Society
Rabbit Advocacy Group of BC
http://rabbitadvocacy.com

August 3, 2007 (header removed)

Dear Ms. Gooch:

Thank you for your e-mail dated July 11, 2007 addressed to the Honourable Pat Bell, Minister of Agriculture and Lands, expressing concern regarding the keeping of rabbits as companion animals.  I am responding on behalf of Minister Bell.

Rabbits are “wildlife” and as such come within the mandate of the Ministry of Environment.  The Ministry is currently conducting a public consultation process regarding changes to the Wildlife Act.  I would encourage you to submit your views on this topic through the public comment forum that the Ministry of Environment has set up.  You can access that forum through the Ministry’s website at www.env.gov.bc.ca/fw/wildlifeactreview .

Local governments have authority under local governance legislation to regulate the keeping of animals.  Many local governments already regulate or prohibit the keeping of animals which have potential to create public or private nuisance, such as rabbits.  Decisions relating to the keeping of animals for companionship purposes are matters that I believe are best determined by local citizens through their local representatives.  You may wish to share your views on this topic with the Minister of Community Services, the Honourable Ida Chong.  I am providing Minister Chong with a copy of my response for her information.

Thank you for taking the time to share your views.

Sincerely,
Original signed by:
Larry Pedersen
Deputy Minister

pc:     Honourable Barry Penner
Minister of Environment

Honourable Ida Chong
Minister of Community Services

August 20, 2007 

Re: Domestic rabbits turned loose (file & ref. no. removed) 

To: Honourable Ida Chong 

Firstly, I would like to thank Deputy Minister, Larry Pedersen for passing on to you my correspondence regarding domestic rabbits abandoned to the outdoors. 

I had already submitted my views to Barry Penner, Minister of Environment, on this matter as suggested by Mr. Pedersen, but have yet to hear back from anybody in that department. 

What I would like to know is how domestic breed rabbits, such as the Rex, Silver Marten, Dutch, and Lop-Eared, for example, are considered "wildlife" and come within the mandate of the Environment Ministry.  These very rabbits are sold in pet stores as companion animals, so it would seem a bit odd that once they have been abandoned to the outdoors that they would suddenly be construed as "wildlife."  Does this mean that abandoned pet cats also fall under this category? 

Or are these companion animals considered an introduced or invasive species and over what period of time?  

I've been called on many an occasion, including by my local animal shelter where I volunteer, to attend to reports of stray rabbit(s) in the park or in a residential neighbourhood, where they are roaming from yard to yard.  Either I bring them to my home, where I provide lifetime care for them, or they may go to the shelter for adoption, after being sterilized.  This wouldn't be a matter for a conservation officer.  I believe the SPCA's contract with municipalities is essentially that of dog-catcher and know from first-hand experience and from information given to me that they don't spend time trying to round up rabbits.  So, if not for private citizens and rescue groups, who would be doing the work?

As to local government legislating the keeping of rabbits, just how much authority would they have?  A PetSmart is opening soon in the District of North Vancouver and I've asked the Director of Corporate Services and the Chief Administrative Officer to look into the matter of prohibiting sales.  To date the current Pet Shop bylaw regulates but does not prohibit the sale of live animals, and the District's lawyer will be checking whether they have the power to do so.  While rabbits may be considered a nuisance by some, they don't pose a public safety or health risk, like exotic/wild animals in captivity, and haven't been included for consideration in the amendments to the Wildlife Act.  

Rabbits are prolific breeders, with the ability to reproduce every thirty days and once colonies are established it's next to impossible to eradicate them.  However, many have been culled on private farm land, and also on the University of Victoria's property and at Victoria General Hospital in 1999-2000.  Are licensed hunters and trappers hired for the job and what guidelines apply for farmers? Who oversees them to ensure "humane euthanasia?" 

As the welfare of rabbits is of concern to me I would think that proactive, rather than reactive measures be in place, in order to address and reduce the numbers of rabbits being bred and sold throughout our province.  Otherwise, the cycle will repeat, and colonies will continue to thrive or else the BC SPCA will have them put down, simply because there aren't enough homes for them. 

Is there any way of initiating a harmonized province-wide approach to this issue or is it up to each community and its citizens to respond to the situation, if it should so arise?

I look forward to your reply and further discussion regarding this matter. 

Sincerely, 

Carmina Gooch (remainder of close removed) 

September 24, 2007 from Minister's Correspondence (rest of header removed)  

Dear Ms. Gooch: 

Thank you for your email of August 20, 2007, regarding the regulation of rabbits in British Columbia by the Province of British Columbia (Province). 

You have inquired about the possibility of a harmonized Province-wide approach to the regulation of rabbits.  However, the regulation of animals (including rabbits) is the responsibility of local governments.  They are in the strongest position to consider the needs of the community and to make informed decisions for the benefit of its citizens.  Therefore, there would have to be a consensus among all local governments to enact bylaws that take a consistent approach to the regulation of rabbits. 

The local government system depends on the ability of your locally elected representatives to balance their vision for the community with the concerns expressed by the people and organizations that are affected by their decisions.  Therefore, you may want to work with your local government to develop an approach that could become a model for other local governments.

Thank you, again, for writing to me about this matter. 

Sincerely,
Ida Chong, FCGA
Minister of Community Services

August 28th.  From the District of North Vancouver  

Note:  The following is in regards to the Environment and Wildlife Regulation, not the Wildlife Act. 

Hi Carmina.

Under section 8(3)(k) of the Community Charter Council may regulate, prohibit and impose requirements in relation to animals.  But this is a concurrent jurisdiction power - it can only be exercised in accordance with the Environment and Wildlife Regulation.   That regulation only permits a local government to regulate, prohibit and impose requirements under 8(3)(k) in relation to the control and eradication of alien invasive species or the control of wildlife species listed in Schedule B or C of the Designation and Exemption Regulation.  

European rabbits are listed in the Environment and Wildlife Regulation as an "alien invasive species", and therefore the sale of European rabbits may be prohibited.

Dogs and cats are not alien invasive species, and, while it needs to be confirmed under the Designation and Exemption Regulation, I am confident that dogs and cats are not listed as wildlife species in Schedule B or C of that regulation.  As a result, the sale of dogs and cats cannot be regulated or prohibited under section 8(3)(k), and of course the business licencing power cannot be used to prohibit the sale of animals.