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
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 healthy 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:
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.
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.
August 28th. From the District of North Vancouver
Note: The following is in regards to the Environment and Wildlife Regulation, not the Wildlife Act.
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.
February 2, 2009
I am writing in regard to the current classification of the European rabbit (oryctolagus cuniculus) as an alien invasive species in Section C regulations under B.C.'s Wildlife Act. These are the same rabbits that are bred for the pet industry and commonly found in many households throughout the province. Often bought on impulse, they are frequently abandoned to rescue groups, humane societies, or to the outdoors once they become unwanted.
Currently, a number of municipalities, including Victoria, Richmond, Nanaimo, and Kelowna have seen a substantial increase in the numbers of domestic rabbits and their offspring.
The provincial government has placed the responsibility of managing alien invasive species to municipalities and regional districts. Kelowna recently passed a bylaw prohibiting the sale or adoption of unsterilized pet rabbits, and while Richmond, for example, is considering similar legislation, it has yet to do so. Our group continues to be active in pressing for proactive measures that would protect both rabbit and community from costly human behaviour.
Without a comprehensive and coordinated approach to pet abandonment, I believe we will see a continued growth of colonies throughout British Columbia.
What I would like to know is why the European rabbit is considered wildlife by the Ministry, and on the other hand, a companion animal, exploited and targeted by the pet industry for young children. The SPCA holds the animal control contract for a number of municipalities and while other communities have their own arrangements, stray rabbits are brought to shelters for adoption. It's not a matter for 'conservation' officers. Are revisions planned by the MoE to move the European rabbit into the domestic animal section?
The Responsible Animal Care Society (TRACS) has trapped a number of Kelowna's feral/domestic rabbits, and has had to follow strict reporting and guidelines for keeping these rabbits. Why have they been told that they cannot move or adopt them when other agencies do? Nobody has been overseeing EBB, the contractor hired to exterminate the rabbits. There appears to be a lack of clarity, enforcement, and general inconsistencies in how rabbits are 'managed.'
In previous correspondence with the provincial government I was informed that current legislation is outdated, but nobody was willing to tackle the issue at the time of the Wildlife Act Review. This is an issue that cannot be ignored. The Rabbit Advocacy Group kindly requests that the Ministry collaborate with key stakeholders in ensuring that the European rabbit is protected by all levels of government.
April 2, 2009
Penny Lloyd from the BC Ministry of Environment responded, in part that:
A small number of amendments were made to the Wildlife Act in April 2008. Unfortunately, the scale of the Wildlife Act Review was smaller than originally anticipated and did not include moving the European Rabbit into the domestic section.
Sept - Oct 2009 Carmina Gooch, RAG BC has contacted the MoE regarding rabbit issues. They have been receiving a lot of correspondence about the UVic issue. Part of a response from Penny Lloyd, Fish & Wildlife Branch:
At this time, there is no plan to remove rabbits from Schedule C of the Wildlife Act. In response to your other questions:
1. “How does the Ministry define a stray rabbit as opposed to a feral rabbit?” On the escape from captivity or the release or abandonment of a domestic animal that is not a horse, cow or sheep, the government acquires the ownership of that animal.
2. “Has the Ministry communicated with any local governments with regard to bylaws that would see some sort of harmonized approach in addressing "pet rabbit" issues?” No, the ministry has not communicated with local governments. It will be interesting to see how many local governments enact rabbit bylaws in the coming years and how the Union of BC Municipalities responds to the issue. That may be a good starting point.
September 20, 2012 Richmond to consider new rules to prohibit pet dumping
Carmina Gooch comment posted via FB The BC Wildlife Act classifies feral rabbits to be invasive & a non-native species. However, stray or abandoned rabbits are received by rescue groups, the SPCA, and municipal shelters all the time and are adopted out. The SPCA advises if an injured feral (once domestic) rabbit is found to contact animal control to determine the procedure for domestic rabbits. Animal abandonment is a cruel crime & sadly a reality in municipalities everywhere.
September 20, 2012 Bunnies barring bridge building blessing
Carmina Gooch comment posted via FB: It's the provincial government flexing its muscle. They're ticked off that Delta officials relocated these rabbits instead of going for the only two options given to them by the FLNRO - either kill them or send them to the US. This is leadership? www.rabbitadvocacy.com
January 30, 2013 In our ongoing correspondence with the provincial government, we have yet to receive any information regarding new legislation specific to rabbits. Chronic delay is the norm. The Wildlife Act remains unchanged although we’re being told yet again that certain policies are being reviewed. However, there are no immediate plans to change the Wildlife Act to exclude feral European rabbits (Oryctolagus cuniculus) from the definition of wildlife.
Municipalities may have zoning regulations about the keeping of rabbits, but whether they are livestock, pets, or both, is open to debate. 4-H advises that when selecting a rabbit one must consider whether the animals will be “used for meat, fur, wool, breeding or just a pet?” This organization, like other agricultural ones, has not progressed to modern day thought where our use and treatment of animals is being questioned more and more.
June 2013 Revised doc: domestic rabbit abandonment
July 23, 2013 The Richmond Auto Mall rabbits are still in limbo, awaiting transfer to new homes after Rabbitats did not relocate them to Precious Life Animal Sanctuary in Sequim, as per the government permit granted earlier this year. In June, several media outlets reported that there was an offer from the family-run Shearwater Resort & Marina on Denny Island, located on BC’s central coast five km from Bella Bella, to transfer feral rabbits to their nearby privately owned island. This island is remote with no natural source of water, no inhabitants and a climate that is cold and damp for most of the year. Combined with the number of raptors, the exorbitant costs of relocating, setting up and maintaining a sanctuary per se, as well as government regulations prohibiting the transfer of feral rabbits, common sense and sound reasoning would dictate that it is simply not feasible. However, Rabbitats spokesperson, Sorelle Saidman, said the idea was still being “researched.”
Gwen Barlee, policy director for the Wilderness Committee says: "One of the problems is that the island has an ecosystem, and when you put rabbits on that island they are going to eat up every little bit of greenery they could possibly get to," Barlee said. "And what does that mean if you have birds that use the area for nesting?"
Source: Resort owner mulls transfer of Richmond Auto Mall rabbits to remote island, Philip Raphael, Richmond News, June 13, 2013
July 26, 2013 Carmina Gooch, representing The Rabbit Advocacy Group of BC, has been invited to meet with the new Minister of Environment, Mary Polak, appointed on June 10, 2013, to discuss domestic rabbit abandonment. Update: The meeting went well. RA left an information package that included bylaws, classifications of rabbits, and lists of BC breeders. Other key stakeholders and government officials are in receipt of our information as well as the document on rabbit matters sent to the Minister in June.
July 30, 2014 Recap of our meeting with Hon. Mary Polak
September 22, 2015 Rabbit Advocacy continues to be a strong voice for rabbits and all animals. Recently, we joined others yet again in asking the BC government to update the BC wildlife Act. It is hopelessly outdated. Rabbits and other animals listed under Schedule C are left unprotected, its kill policy of top predators and the pay-to-slay hunting regulations are not in keeping with societal values or evolving public sentiment.
Regardless of regulations, policy, or law, caring people will help animals in need, regardless of whether it is sanctioned by government or any other authority. It is our duty to do so. We are facing a federal election next month so now is a perfect opportunity to contact politicians and the media.
August 16, 2013 Concocting fictitious accusations and blaming rabbit advocates, rescue groups, and government agencies for the difficulties with the RAM project is not only counterproductive for the rabbits, but a total waste of time. Rabbitats’ Sorelle Saidman was advised against proceeding in the manner she did, and must now fix the problem. The September deadline for moving the rabbits is imminent, although we expect excuses and delays.
Update: It's the end of the year and the captured rabbits at RAM have not been relocated. Rabbits are still running loose and reproducing. Predictable, yet a letdown all round.
August 26, 2013 We have heard from a representative of the Fish, Wildlife and Habitat Management Branch of FLNRO regarding our recent correspondence which contained a number of requests with respect to dealing with abandoned rabbits. We received some helpful advice and other information. Although Regulating the Sale of Unsterilized Rabbits B123 was endorsed, the Provincial Government is not going to pursue legislation.
September 11, 2014 Further information was finally received over a year later from the Fish & Wildlife Branch, a division of the FLNRO Ministry, regarding issues related to domestic rabbit abandonment raised by rabbit advocacy stakeholders. The Rabbit Advocacy Group of BC continues to be a strong voice for rabbits and was recently in touch with the BC government regarding the lack of protections for farmed animals, including rabbits exploited for meat. While we have heard from several politicians, we have yet to hear from the Premier and the Agriculture Minister.