LETTERS TO GOVERNMENT
Office of the Auditor General of Canada – Environmental Petition
May 28, 2020
An environmental impact statement assessing the ecological effects of wide-scale wolf reduction programs underway is necessary and overdue.
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: As part of their provincial caribou recovery efforts Alberta has killed approximately 2,500 wolves since 2005 and BC has killed more than 1,000 wolves since 2015. The Section 11 partnership agreements for caribou recovery between the federal government and the provinces of Alberta and British Columbia (BC) recommend killing wolves indefinitely in caribou recovery units. Specifically, the 2019 draft Agreement for the conservation and recovery of Woodland Caribou in Alberta1 recommends wolf population management for all [Woodland Caribou] ranges in whole or in part on provincial land to be carried out on an ongoing basis with 5-year reports. Similarly, BC’s 2020 Section 11 Agreement for Southern Mountain Caribou 2 indicates that predator management programs will be conducted annually throughout each Land Planning Unit (LPU) until British Columbia, Canada, and the West Moberly and Saulteau First Nations agree that Southern Mountain Caribou habitat conditions no longer require it. Given that that wolves are recognized for having major roles in maintaining diversity and important ecological processes, why has no environmental impact statement assessed the ecological impacts of wolf killing in these ecosystems?
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: Given that the costs for wolf and ecosystem restoration in Yellowstone National Park exceeded US $30 million3 following the intentional extirpation of wolves, at what point will the financial, ethical and ecological costs of killing wolves outweigh the potential benefit of maintaining caribou (or other species) in situ? Has this parameter been defined?
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: Why is the government willing to functionally extirpate wolves when scientific evidence suggests that this will result in negative ecological repercussions?
According to the Canadian Council on Animal Care (CCAC 2003), a killing method is humane if it causes rapid (immediate) unconsciousness and subsequent death without pain or distress. Death by strychnine ingestion is inhumane, as it causes frequent periods of tetanic seizures, occasional cessation of breathing, hyperthermia, extreme suffering, and death from exhaustion or asphyxiation, which typically occurs within 1–2 hours of the onset of clinical signs (Khan 2010). However, death can take up to 24 hours or longer if the dose is low (Eason & Wickstrom 2001).
The use of strychnine is in contravention of Canadian Council on Animal Care guidelines (CCAC 2003), the American Veterinary Medical Association (AVMA 2013), the Canadian Veterinary Medical Association (CVMA 2014), and the American Society of Mammalogists (Sikes et al. 2011). [Source: Proulx et al. 2015]). In addition, the International Union for Conservation of Nature has denounced the use of poison, incentive programs, and hunting with mechanised vehicles (e.g. aerial shooting) in wolf management programmes (IUCN 2000), all of which are in practice in Alberta’s caribou recovery program. On top of inhumanely killing wolves, the indiscriminate nature of Strychnine has already killed a federally listed species (grizzly bear) in addition to 12 other non-target species in a program aimed at killing wolves, several of which are listed as sensitive under Alberta’s Wildlife Act.
Also, the practice of aerial gunning fails to meet criteria set in CCAC guidelines (2010) on euthanasia of animals used in science which includes the following: “Euthanasia should result in rapid loss of consciousness, followed by respiratory and cardiac arrest and ultimate loss of all brain function.”
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE and HEALTH MINISTER: Why is the federal government supporting wildlife management techniques that use strychnine and aerial gunning when these practices are not supported and are in fact condemned by Canadian and international expert bodies?
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: Please will you provide information about the size/area, location and date of implementation for habitat protection measures in caribou ranges, in addition to the land already outlined in the Section 11 Agreements, where wolf reduction programs are underway?
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: How much of the newly protected land in question 5 has not undergone anthropogenic manipulation for resource extraction and is in effective caribou habitat? In other words, what amount of caribou-friendly climax habitat has been additionally protected where predator and primary prey kill programs are underway?
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE: Why is Canada not including caribou shepherding programs as a non-lethal approach to support caribou recovery whereas these programs have successfully helped stabilize caribou numbers in other parts of the world?
In addition to non-target deaths, serious concerns exist regarding the inhumaneness of strychnine. Health Canada has acknowledged the growing concern among Canadians about the use of pest control products to control vertebrate pests and initiated a public Consultation on Humane Vertebrate Pest Control in December 2018 in order to consult with Canadians on how the humaneness of pesticides to control predators could be considered during their approval and use (RVD2020-06). As noted above, strychnine is a component of a wolf kill program underway in Alberta since 2005 ostensibly for caribou recovery.
PMRA's directive for 15-yr re-evaluations for all pesticides registered in Canada prior to 1994 (DIR2001-03) states the following:
The PCPA provides the Minister of Health broad discretionary authority to determine information requirements, principles, policies and standards to be applied in the evaluation and re-evaluation of pest control products.
HEALTH MINISTER: please outline your intentions, with a timeline, to incorporate humane standards policy in the evaluation and re-evaluation of pest control products.
Emerging prion pathogens such as Bovine Tuberculosis [BT]and Chronic Wasting Disease [CWD] are serious biological threats facing North America which warrant immediate evidence-based wildlife management decisions. CWD has not yet arrived in British Columbia but it is spreading among wild deer and elk populations in Alberta and Quebec as well as Saskatchewan, which experienced a record number of cases of CWD in 20194. CWD was first detected in the United States of America where it continues to spread and has been detected just south of British Columbia’s border in multiple regions of Montana. There are at least two wildlife populations known to be infected with BT in Canada: the wood bison of northern Alberta and the adjacent Northwest Territories in and around Wood Buffalo National Park and the elk and deer of southwestern Manitoba in and around Riding Mountain National Park (GOC 2015). BT has also been detected in domestic cattle in BC and AB.
Scientists suggest that healthy wolf populations can contribute to reducing and limiting the spread of these diseases (Hobbs 2006, Stronen et al. 2007, Wild et al. 2011).
MINISTER OF ENVIRONMENT AND CLIMATE CHANGE and HEALTH MINISTER: how do you reconcile removing wolves over vast portions of a province or territory ostensibly for caribou recovery in a measure that is counterproductive to management efforts seeking to minimize disease transmission and which could have grave impacts on both wild and domestic animals?
Yellowstone National Park recently celebrated 25 years of wolf restoration and rewilding, spending approximately US $30 million in recovery efforts5,6. Meanwhile, the intentional extirpation of wolves is swelling across BC, Alberta and Northwest Territories (NWT)as tax dollars and private corporate funds pay for the removal of wolves in and around caribou ranges. Since 2005 Alberta has killed more than 2500 wolves as part of caribou recovery efforts. BC began a program in 2015 which has killed more than 1000 wolves. NWT is the third province or territory in Canada to aerial gun wolves, beginning in March 2020.
Wildlife management policies based on reducing carnivore numbers have caused severe harm to many other organisms, as evidenced when wolves were eradicated from Banff National Park (Hebblewhite et al. 2005) and Yellowstone National Park in the USA (Ripple and Beschta 2004). The ecological benefits wolves and other apex consumers provide is becoming increasingly understood and scientifically documented (Estes et al. 2011, Ripple et al. 2014) and includes critical, invaluable, and irreplaceable functions such as control of disease spread, limiting invasive species, and maintaining plant and animal species diversity.
Wolves are now recognized for their important role in maintaining biological diversity and resilience (Hebblewhite et al. 2005, Estes et al. 2011, Beschta and Ripple 2009, Ripple et al. 2014), and yet no environmental impact assessment has ever been conducted to measure the major ecological effects of wolf reduction programs underway as part of any species recovery program. Such an assessment would likely show widespread destabilizing damage to ecosystem processes and functions. Stability in ecosystems is something on which we and other species depend.
The ecological consequences of this action are resulting in ecological debt which is being immorally placed on future generations. As Yellowstone has shown, the damage will be expensive to restore. Restoration of caribou-friendly climax habitat may not be possible giventhe interaction between changing climate, increasing pollution, and ongoing extraction of natural resources.
Wolf kill programs fail to consider the immediate and long-term effects this type of "management" has on wolf genetic and social structures, other wildlife, and the sustainability of the entire ecosystem. Aerial gunning, toxicant use, trapping incentives, and any other management practices aimed at wide-scale reduction of carnivore populations should be abandoned until the Environment Minister releases a federal environmental impact statement for any lethal wildlife reduction program in Canada.
References detailed here.
September 22, 2019
Dear Public Input Coordinator, Ministers, BC Premier and Mr. Peel,
RE: Proposal to expand wolf gunning to Tweedsmuir-Entiako, Hart Ranges and Itcha-Ilgachuz caribou herd ranges and paying hunters to kill cougars in Itcha-Ilgachuz range
We urge the BC Government to abandon the proposal to initiate a wolf kill program in the Tweedsmuir-Entiako, Hart Ranges, and Itcha-Ilgachuz caribou herd ranges (August 22nd 4-pg document “Predator Reduction for Caribou Recovery”). We additionally urge FLNRORD to abandon its proposal to pay hunters to kill cougars in the Itcha-Ilgachuz caribou range, or to engage in any form of predator reduction under the guise of caribou recovery. We maintain that we wish to see an end to tax-funded predator-kill programs underway in British Columbia.
Wolf Awareness has engaged directly with the province regarding caribou recovery as part of the Provincial Caribou Recovery Program Stakeholder Engagement process, and consequently we were very disappointed and concerned to learn that this existing proposal was not: i) shared with us directly; ii) publicized on the Caribou Recovery engagement website; nor iii) shared with the general public beyond selected members of the communities (“targeted stakeholders”) where the killing is proposed. We are ALL stakeholders in decisions such as this, yet there was no media release or effort to provide due diligence to all British Columbians regarding this plan. Despite Mr. Peel’s statements during our phone conversation Sept. 19th that this proposal falls under regulations set by the BC Wildlife Act and therefor does not require broad public engagement, this indicates your government’s serious lack of transparency regarding decisions surrounding the future of caribou, as well as wildlife communities including predators and their alternate prey in these areas. Wolves, caribou, and ecosystems are all part of a larger public trust and these management decisions reflect upon the Natural legacy of all Canadians. As such, all British Columbians should be consulted about decisions for wide-scale predator killing that are funded by tax-dollars.
Moreover, earlier this year, several in-person consultations sessions about the bilateral Section 11 Agreements for caribou recovery proved to be catastrophic failures – they incited misinformation, fear-mongering and racism in northern communities, where economics are widely dependent on extractive industry that is damaging caribou habitat and leading to these population declines. When the province abandoned these consultations, it did so promising to do better. The province broke this promise in its proposal to increase the wide-scale killing of wolves and also cougars, as well as suggesting that alternate prey like moose, elk, deer and/or wild horses will also need to be killed yet deliberately preventing fulsome public participation. What is allegedly a consultation for "targeted stakeholders" wrongly bars the public from consultation and engagement regarding the management and conservation of wildlife in this province and willfully ignores and neglects public demands that the province commit to meaningful habitat protection and restoration and puts an end to the killing of an increasing number of species serving as scapegoats.
The proposal makes clear that ongoing destruction and disturbance of critical habitat that caribou rely on is negatively impacting not just caribou, but likely also many other species that are endemic to old-growth ecosystems. Removing at least 80% of local wolf populations is likely to impact not only caribou, but negatively affect the wolf populations themselves (both short and long-term) and have adverse impacts on various species and ecological processes. It is unacceptable that there has never been an environmental impact statement that assesses the impacts that killing hundreds of wolves repeatedly for years has on wolves, non-caribou species, or ecological processes. Conservation goals should not be species-specific, but rather promote and allow for ecological functions and diversity which may enable adaptations during this time of changing climate. Wide-scale killing of predators may increase caribou numbers short term, but this is a tunnel-visioned approach that will wreak havoc and peril for the ecosystem at large, and to the psyche of our society.
The NDP government asserts that their wolf kill program results in the “most humane method to thoroughly reduce wolf populations”, yet this is extremely deceptive as AERIAL GUNNING IS NOT CONSIDERED HUMANE by any standards. While it remains of high concern that BC has not adopted Canadian standards set by the Canadian Council on Animal Care, it is important to clarify that the AVMA Guidelines for the Euthanasia of Animals: 2013 Edition that is cited in the Sept. 22 proposal clearly state that a gunshot to the head of a captive animal can be considered humane but when it comes to aerial shooting please review the following:
Pg. 36: A properly placed gunshot can cause immediate insensibility and a humane death…..For wildlife and other freely roaming animals, the preferred target area should be the head. It may, however, not be possible or appropriate to target the head when killing is attempted from large distances (missed shots may result in jaw fractures or other nonfatal injuries)…. The appropriate firearm should be selected for the situation, with the goal being penetration and destruction of brain tissue without emergence from the contralateral side of the head. A gunshot to the heart or neck does not immediately render animals unconscious, but may be required when it is not possible to meet the POE’s definition of euthanasia.
Pg. 38: Ideally, the muzzle of the firearm should be held within 1 to 2 feet of the animal’s forehead and perpendicular to the skull with the intended path of the bullet roughly in the direction of the foramen magnum. This will reduce the potential for ricochet while directing the bullet toward the cerebrum, midbrain, and medulla oblongata, which will assure immediate loss of consciousness and rapid death.
This is not possible when flying in an aircraft over uneven ground in pursuit of a running wolf. Nowhere in the cited American Veterinary Medical Association guidelines for animal euthanasia is helicopter pursuit deemed humane. Even if gunshots do result in quick deaths of these animals, for which there has been no veterinary oversight in the field nor documentation shared with us despite repeated requests, the degree of distress and panic experienced before being killed this way is unacceptable.
If the government is so determined to now assert that the aerial gunning program is humane, despite members of the Provincial Mountain Caribou Recovery Science Team conceding (pg. 6) “There are no humane methods to directly reduce wolf numbers” in a report prepared for the province in 2016 titled Next Steps for Southern Mountain Caribou recovery in planning unit 3A. We formally request that FLNRORD provide independent and expert supervision of all killing (whether it be completed by contractors or ministry staff) including video documentation. We emphasize that it is cause for concern that you have chosen to ignore the most relevant guidelines about animal killing: the Canadian Council on Animal Care and the Canadian Veterinary Medical Association.
Furthermore, we formally request the province publicizes all evidence and evaluations (such as forecast modelling for habitat change and concurrent population viability analyses) that caribou are likely to be self-sustaining at the federally designed habitat disturbance thresholds that would be achieved through habitat protection and restoration efforts. Without this information, this proposal is reduced to one more empty promise that something—herd planning in this case--will be done for caribou later, meanwhile what is being done now is indirect killing of caribou by means of ongoing habitat disturbance and destruction; active denial of the likelihood that climax forests will not sustain future caribou populations due to unpredictable and significant impacts of climate change; and further down-ratcheting ecosystems through the unethical killing of wolves and other apex predators.
While the BC Government is making claims that the science is clear that killing wolves in the South Peace region for the previous 5 years indicates an increase in caribou numbers, it is important to point out that this has happened alongside maternal pens, feeding programs, and herds combining. We believe that the scientific rationale is highly questionable, yet even if the science were clear, we oppose killing one species to potentially help recover another on ethical grounds, especially because the situation is human-caused and the ultimate cause, habitat destruction, is ongoing.
Although caribou decline is certainly a cause for concern, we should not and cannot neglect other current environmental threats that rely on wolves and large carnivores to maintain resiliency in ecosystems, such as chronic wasting disease and climate change.
Wolves and wolf families have intrinsic value, as do all living individuals. Wildlife management and conservation practices should be ecologically and ethically sound. Wolf killing programs are neither and as such should be abandoned. We recommend an immediate end to killing of predators and alternate prey species throughout the province on ethical and ecological grounds. We ask that the Government immediately halt habitat destruction and forbid recreators to disturb caribou while herd planning is underway. This is the only acceptable response given that the proposal cites significant annual declines in caribou populations.
Finally, and importantly, we encourage the BC Government to commit to diversifying the northern economy to reduce reliance on extractive industry which continues to bring about the demise of caribou and the biodiversity they represent as indicator species. Certainly, the many millions of dollars that have already and are proposed to be spent on killing programs could be used to restore habitats and support the economic diversification required in caribou ranges.
Sadie Parr - Wolf Awareness Inc. Executive Director
Underwood, W., Anthony, R., Cartner, S., Corey, D., Grandin, T., Greenacre, C.B., Gwaltney-Bran, S., McCrackin, M.A., Meyer, R. and Miller, D., 2013. AVMA guidelines for the euthanasia of animals: 2013 edition. Schaumburg, IL: American Veterinary Medical Association.
Signed by more than 50 leading experts!
An open letter to the Minister of Health and Canada’s Pest Management Regulatory Agency regarding the use of strychnine, sodium monofluoroacetate (Compound 1080), and sodium cyanide to kill wildlife in Canada.
The Hon. Ginette Petitpas Taylor
Minister of Health House of Commons Ottawa, Ontario K1A 0A6
September 27, 2018
Dear Minister Petitpas Taylor and Canada’s Pest Management Regulatory Agency,
We, the undersigned scientists and organizations, oppose the use of strychnine, sodium monofluoroacetate (referred to henceforth in this document by its common name Compound 1080), and sodium cyanide to kill wildlife in Canada and request that the registration of these compounds and products containing them be cancelled under the Pest Control Products Act (2002; hereafter PCPA).
These 3 chemicals are the most toxic poisons currently in use to kill wildlife in Canada. Under the PCPA, the Minister’s primary statutory objective is to prevent unacceptable risks to individuals and the environment, including harm to living organisms and biodiversity. Federal regulations and policy controlling the evaluation, distribution, use, handling, and record-keeping of these pesticides are unable to mitigate public and environmental safety hazards associated with their use.
Evidence suggests that:
I. Strychnine, Compound 1080 and sodium cyanide are inhumane wildlife killing methods, causing undue pain and distress;
II. The environmental risks posed by these products are unacceptable because they pose a threat to non-target species, including species at risk of extinction, and biodiversity;
III. Current conditions for use are not adequately enforced and sometimes impossible to adhere to;
IV. The health risks of these products are unacceptable because they pose a threat to the health and safety of Canadians, as well as pets and livestock;
V. The effectiveness of these products is questionable because indiscriminate killing of wildlife does not often solve the conflicts the poisons are intended to address, results are not scientifically evaluated assessed and/or are poorly documented, and better alternatives exist; and
VI. Wolves, coyotes, and black bears are not “pests” for the purposes of the Pest Control Products Act (2002), as they do not pose risks to human health or the environment, and in fact provide important ecosystem functions.
These arguments are presented in greater detail in the addendum and supplementary material of this letter.
We urge you to cancel the use of strychnine for ground squirrel control, as proposed in PRVD2018-13 and without delay. Furthermore, we hereby request, under PCPA s. 17(4), that you initiate special reviews of all pest control products containing strychnine, Compound 1080, and sodium cyanide. In light of the evidence presented here, we believe that Health Canada should cancel the registration of these active ingredients and end-use products containing them, and ban their use. These pest control products endanger human health, safety and the environment and pose threats that are both serious and irreversible.
Shelley M. Alexander, PhD
Canid Conservation Science Lab, University of Calgary, AB
Hannah Barron, BSc
Director, Wildlife Conservation Campaigns, Earthroots, ON
Marc Bekoff, PhD
Professor emeritus, Ecology and Evolutionary Biology
University of Colorado, Boulder, USA
Executive Director, Humane Society International – Canada
Michael Bloomfield, BSc wildlife biologist, educator
Founder and Executive Director Harmony Foundation of Canada
Heather Bryan, PhD, Postdoctoral Fellow, Applied Conservation Science Lab
University of Victoria, BC
G.A. Bradshaw, PhD Director and Founder, The Kerulos Center, J
acksonville Oregon, USA
Shelley and Casey Black
Founders and Directors, Northern Lights Wildlife Wolf Education Centre, BC
Jodey Castricano, PhD, FOCAE
Associate Professor, Department of Critical Studies, CCS377
University of British Columbia, Okanagan, BC
Marc Cattet, DVM, PhD
RGL Recovery Wildlife Health & Veterinary Services, Saskatoon, SK
Nigel Caulkett PhD, DVM, MVetSc
Department head of Veterinary Clinical and Diagnostic Science, Faculty of Veterinary Medicine
University of Calgary, AB
Chris Darimont, PhD
Scientist Raincoast Conservation Foundation &
Applied Conservation Science Lab, University of Victoria, BC
Rachel Darvill, MSc
Program Biologist - Columbia Wetlands Waterbird Survey & Marsh Bird Monitoring Project
Goldeneye Ecological Services, BC
Conservation and Policy Campaigner, Wilderness Committee, BC
Moira Drosdovech, DVM
Member College Veterinary Medicine of BC, Co-Founder Kelowna Animal Action
Sara Dubois, PhD, RPBio BC
SPCA Chief Scientific Officer, BC
Brooks Fahy, Executive Director, Predator Defence Org.
Eugene Oregon, USA
Executive Director, The Fur-Bearers – Canada
Chapter Contact for Council of Canadians
Campbell River BC chapter
Maureen Harper, DVM, MSc
(retired) Canadian Food Inspection Agency - BSE program officer, Ontario
Stephen Herrero, Phd
Professor Emeritus, Environmental Science, University of Calgary, Alberta
Rick A. Hopkins, PhD
Senior Conservation Biologist, Live Oak Associates, Inc., San Jose California, USA
Executive Director, Wolf Conservation Center, New York, USA
Executive Director, Wildlife Defence League, BC
Susan Kutz, DVM, PhD
Professor, Ecosystem and Public Health, Faculty of Veterinary Medicine
University of Calgary, Alberta
Rob Laidlaw, CBiol, MIBiol
Executive Director, Zoocheck
John W. Laundré, PhD
Large Predator Ecologist, Corvallis Oregon, USA
Misty MacDuffee, BSc
Biologist, Raincoast Conservation Foundation, BC
Barry Kent MacKay
Canadian Representative, Born Free USA
Ken Macquisten, DVM
Wildlife Veterinarian, Abbotsford, BC
Wayne McCrory, BSc, RPBio
McCrory Wildlife Services Ltd., BC
Mike J. McIntosh
Executive Director, Bear With Us Sanctuary and Rehabilitation Centre for Bears, Ontario
Marco Musiani, PhD
Wildlife Ecologist, University of Calgary, Alberta
Peter Neuhaus, PhD
Adjunct Professor, Biological Sciences, University of Calgary, Alberta
Sadie Parr, BSc
Executive Director, Wolf Awareness Inc, Canada
Paul C. Paquet, PhD
Senior Scientist Raincoast Conservation Foundation &
Professor, Department of Geography, University of Victoria BC
Rolf O. Peterson, PhD
Research Professor, Forest Resources & Environmental Science, Michigan Technological University, USA
Director, Valhalla Wilderness Society, BC
Rachel Plotkin, MES
The David Suzuki Foundation
Gilbert Proulx, PhD, CWB
Director of Science, Alpha Wildlife Research & Management Ltd., Alberta
Executive Director, Coyote Watch Canada
Judith Samson-French, DVM, MSc
Banded Peak Veterinary Hospital, Bragg Creek, Alberta
Chair, Jasper Environmental Association, Alberta
Executive Director, Cochrane Ecological Institute, Alberta
Judit Smits, DVM, PhD
Wildlife Toxicology & Ecotoxicology, Faculty of Veterinary Medicine, University of Calgary, Alberta
PhD Centre for Compassionate Conservation, School of Life Sciences, University of Technology
Jonathan Way, PhD
Founder, Eastern Coyote/Coywolf Research, Maine, USA
Executive Director, Animal Alliance of Canada
Robert Wielgus, PhD
Former director of the large carnivore conservation lab at Washington state university (retired)
Pullman. Washington, USA, 99163 - Canadian citizen
Country Director, International Fund for Animal Welfare (IFAW) - Canada