Help us protect the future of wildlife rehabilitation in Wisconsin!
Want to make a real difference for the future of wildlife rehabilitation in Wisconsin? Please take a few minutes tonight to send your comments to the DNR regarding proposed changes to the rules covering wildlife rehab.
We really need your help in sending a strong message to the DNR! This post lists the rule changes that we have deemed most significant and potentially damaging and the Wisconsin WildCare position on them in italics below each.
Please send your comments by midnight, September 1st to Scott Loomins Scott.firstname.lastname@example.org
Thank you for your support!
NR 19.70 Purpose. This subchapter is adopted to establish consistent standards for the rehabilitation of wildlife in Wisconsin. The intent is to ensure all persons engaged in wildlife rehabilitation are qualified and provide humane care and housing for wildlife being rehabilitated.
NR 19.73 Licenses (e) 1. The licensee has submitted to the department a caging report as required under s. NR 19.76 (2m), pictures of pens/enclosures, and documentation indicating the licensee’s rehabilitation experience or knowledge with the new species. Experience or knowledge with the new species shall include at least 100 hours of hands-on experience gained within the previous two years and 25 of those hours may be fulfilled by participation in seminars or courses relating to the new species. The department may require that licensees demonstrate specific experience or knowledge of species that it determines to be sensitive or difficult to rehabilitate.
Since 2005, Wisconsin’s licensed wildlife rehabilitators are limited to rehabilitate only those species for which they have been specifically licensed. Before this time, a license holder was allowed to rehabilitate any wild species in need, with the exception of skunks, endangered animals and migratory birds (unless a special permit issued by the U.S. Fish & Wildlife was obtained). Since 2005, rehabilitators who wish to add a species, must pass an additional facility inspection and submit a care protocol for that species.
Several seasoned rehabilitators have years of experience working with a variety of species, but have not yet been licensed specifically for those species. This rule change would require these rehabilitators to seek out additional hands-on experience elsewhere, despite their current level of expertise in handling these species.
Additionally, any current license holder wishing to add a species would need to secure some type of experience gaining opportunity, such as volunteering at an area wildlife center. This rule change would effectively restrict the majority of licensees from adding any new species, whether or not they have knowledge of and experience with rehabilitation of the species. Here’s how:
- It would be extremely difficult to add a less common species, such as badger or weasel, even if the licensee happened to live nearby a wildlife center and had enough spare time and resources to volunteer her time at said center. The hands-on requirement would allow only for time spent directly caring for a species. Thus, a volunteer at a center could only count the 10-15 minutes per shift caring for a given species, and then, only if the species were currently in care at the center.
- The number of hours required (100 in a two-year period) is arbitrary and is not based on scientific evidence that 100 hours doing any related care task for a species would instill the necessary knowledge to effectively rehabilitate that species independently. This is akin to stating that the volunteers at the local humane society would be qualified to raise orphaned and/or injured puppies after 100 hours of dog walking.
- This requirement would apply to all species and to all levels of licensee experience, disregarding any past experience that was not documented. A seasoned rehabilitator with years of experience rehabilitating all varieties of squirrels, would need to acquire 100 hours of hands-on experience to become licensed to work with deer mice.
- Of the approximately 100 rehabilitation licenses in Wisconsin, only 12 of these are held by wildlife centers. That means that 90% of rehabilitators in the state are home-based. These individuals donate their time, living space, and remarkable amounts of their own money caring for orphaned and injured wildlife.
Rehabilitation is an independent activity, in no way supported financially by the state taxpayers. Asking a home-based rehabilitator who is interested in expanding the scope of their care to new species to volunteer an additional 100 hours is not only unreasonable, but impossible for most. Many, if not most, home-based rehabilitators hold regular paying jobs in addition to their donated time rehabilitating wildlife. In most cases, they would not have the time to volunteer additional time elsewhere to meet the 100 hour requirement.
What’s more, access to these opportunities is extremely limited unless a rehabilitator happens to live a convenient distance from a wildlife center or another rehabilitator licensed for that species who is willing to offer training. That, unfortunately, is not the case for a large segment of the rehabilitators in Wisconsin. Some centers restrict hands-on care to interns, only allowing even licensed volunteers cage-cleaning and food prep duties.
- There are several species which are either rarely taken into rehabilitation or very with which few rehabilitators are permitted to work. Using white tail fawns as an example, a co-director of Wisconsin WildCare has extensive fawn rehabilitation experience, having worked with that species exclusively for the first three years she was licensed. Under this rule, if her organization wanted to add fawns as a species, this experience would count for nothing. The co-director would have to take the time off work and travel to the nearest facility – 80 miles away in Lake Geneva – to gain hands on experience, and only if that center was open to this arrangement. Meanwhile, area wardens and wildlife biologists have mentioned to Wisconsin WildCare how helpful it would be to have a rehab facility in the region that handles fawns. There is a need for fawn rehabilitation in the region, but filling it would be impossible under this new rule.
- The clause that allows for 25 hours of coursework to replace some of the 100 hours of hands-on experience would not be helpful for even the most common species, but is much less helpful for less common ones. As one 25-year veteran rehabilitator pointed out, there isn’t even 25 hours worth of reading material on the internet about weasel care.
- It is possible, if not likely, that in an attempt to gain the necessary 100 hours of “hands-on” experience, animals may be handled extensively, even to the point of habituation.
- Holders of captive wildlife permits in Wisconsin are not required to have training or hands-on experience for the animals they keep. If you would like to raise fox for fur, for example, you need not know anything about how to care for them, nor do you need to demonstrate any hands-on experience. All that is required is to fill out a one-page form and payment of the $50 annual fee.
Wisconsin WildCare supports the notion of well-trained rehabilitators. Indeed, a major part of our mission is to identify, recruit, train and support well qualified individuals to become licensed rehabilitators. However, we also feel strongly that a fox is a fox, a raccoon a raccoon, and we insist that standards of care for all individuals of any wildlife species held in captivity be brought to the same high level.
- Wisconsin WildCare would like to point out that the DNR staff responsible for regulating wildlife rehabilitation have no such requirements for hands-on experience.
NR 19.74 Application (3) License Renewal. An applicant for renewal of any rehabilitation license shall submit proof of having obtained at least one continuing education credit during the preceding license period. Qualifying continuing education credits are:
(a) National Wildlife Rehabilitators Association, International Wildlife Rehabilitation Council, or Wisconsin Wildlife Rehabilitator’s Association workshops, classes, or conferences.
(b) Participation in a research project, coursework, specialized rehabilitation care, or other activities which have been approved by the department.
Wisconsin WildCare encourages rehabilitators to continue learning, to be aware of the most current scientifically-backed protocols, to engage in research and to network with others in the field so as to increase the collective expertise amongst rehabilitators. However, while wildlife rehabilitators may wish to strive to be as professional as possible, they are not professionals by definition. With the exception of wildlife center staff (a mere 10% of license holders), none are paid for the rehabilitative work they do. To legally require continuing education credits of unpaid volunteers is unreasonable.
Currently, there are very few opportunities for rehabilitators to access related courses. The NWRA and IWRC workshops mentioned above are prohibitively expensive ($150-$300), are typically offered once per year and would require travel and lodging for most. The NWRA conferences, for example, are held throughout the country (in New Jersey for 2015 and Oklahoma for 2016). The WWRA workshops held in the past two years, have been well planned and useful even to experienced rehabilitators. Nevertheless, the workshops are held in Green Bay, a long drive for a good portion of rehabilitators in the state. That fact that the WWRA had not held any workshops in the previous 10 years is worrisome, if this rule were to be adopted.
(3) Advanced license. 8 (e). Subpermittees Subpermittees who operate at a location other than the advanced licensee’s facility are located no more than 60 miles from the main facility of the advanced licensee.
Wisconsin WildCare views the requirement that subpermittees be located within 60 miles of a sponsoring advanced license holder to be arbitrary and unduly restrictive. This rule, if established, would effectively prohibit those residing in areas where the nearest advanced rehabilitator is more than 60 miles from becoming licensed. Wisconsin already has large areas with no licensed rehabilitators. Several of those who currently reside in more remote areas are aging and looking to retire from animal care shortly. This rule only serves to eliminate home-based rehabilitation throughout the state, driving the bulk of rehabilitative care to centers. While wildlife centers have their place, Wisconsin WildCare feels strongly that mammal species are better suited for home-based care. Mammals raised in a center are easily habituated through the constant flow of different caretakers. Part-time center volunteers are less able to detect changes in health than home-based rehabilitators, who work with the same animals day in and day out.
Current technology allows for near constant communication between a mentor and the person she is training. Instant photo and video access allows for assessment of a particular situation at any distance. Furthermore, there is no guarantee that an advanced licensee would be a better mentor if she is located within 60 miles of the basic licensee. As an example, a co-director of Wisconsin WildCare has been in almost daily communication for the past six months with a new basic licensee located 100 miles from her facility, providing advice and support as the new rehabilitator encounters new issues with the animals in her care. In this time, the communication and information sharing between these two has far surpassed that between the co-director and her own mentor in all the 15 years she has been licensed. This despite the fact that the mentor lives only 30 miles away and that they meet several times a year in passing at the local wildlife center.
Wisconsin WildCare recommends that this rule be completely eliminated from the proposed set of rule changes.
NR 19.75 Examination.
(1) A person desiring a basic or an advanced license to rehabilitate wildlife in Wisconsin shall take a written examination, provided and administered by the department, and score 80% or greater.
Since 2005, the department has required all applicants for a basic wildlife rehabilitation license take and pass, with a score of 80% or more, an exam. The exam covers all species, despite the fact that licenses are species specific. Thus, an individual hoping to work exclusively with fox, must correctly answer questions about birds. This rule change proposes to require an exam for those wishing to become an advanced rehabilitator. Wisconsin WildCare requests that if this requirement is to be approved, any exam required would be limited to the specific species the exam taker is licensed to work with at the time of the exam. To require advanced knowledge of all species, while restricting licensees from working with other species, is unreasonable.