NEWS RELEASE about Environment posted on April 5, 2011 by Roslyn Cassells

UVic plans to shoot campus rabbit during study break - Easter brings death and suffering to UVic rabbits

Advocates demand Kelowna-like solution - trap, neuter, relocate!

by Roslyn Cassells

Rabbit decapitated by trappers, UVic 2010, photo courtesy of Heather Clebo

Young rabbit poisoned by bromadiolone by UVic, photo courtesy of Heather Clebo

Please email these UVic administrators to demand they use non-lethal wildlife management methods to deal with the remaining rabbits on campus.  Shooting rabbits or trapping and killing rabbits is unacceptable to the community.  Kelowna adopted an ongoing trap-neuter-relocate program for any rabbits that were missed in the initial round-up.  UVic should do the same. (for more info see press release below)

emails:
"Bruce Kilpatrick Head UVic External Communications" <abk@uvic.ca>, "UVic Facilities Manager Tom Smith" <tomfmgt@uvic.ca>, "UVic President David Turpin" <pres@uvic.ca>

press release:

UVic plans to shoot campus rabbits on upcoming study break despite community opposition

Advocates call for Kelowna-like trap-neuter-relocate solution.

This Easter UVic administration plans to bring death and suffering to the UVic rabbits once again.  Instead of reaching for a practical non-lethal solution, the spin doctors have been hard at work reworking the UVic rabbit story in an attempt to derail their detractors.  Smoke and mirrors aside, their attempts to manufacture consent for the ongoing killing of the remaining campus rabbits, their spring babies, and any recent imports does not sit well with the community.  At a time when surrounding municipalities are coming on board with progressive rabbit bylaws and on the heels of the largest rabbit rescue in Canadian history, the institution has reverted to type.  UVic has returned to their old brutish ways of dealing with abandonned domestic rabbits...shoot to kill, and ongoing bromadiolone poisoning (a practice outlawed federally in 2006). 

Just last week the District of Saanich enacted bylaw amendments prohibiting the sale of unspayed or unneutered rabbits, as well as prohibited rabbit abandonment, among other progressive changes (see attached press release "District of Saanich leader in best practices...")  As local municipalities climb on board, UVic can no longer say they are alone in the attempt to deal with rabbit abandonment on Vancouver Island.

There has been little public confidence in the statements and pronouncements that UVic has made about the rabbits.  No one believes, for example, that there are no rabbits on campus, nor that any rabbits who now appear were all "dumped".  Reports from campus regulars confirm that there are indeed a number of rabbits still on campus, particularly in areas close to UVic's borders.  These rabbits will have babies of course.  Their existence is all UVic feels is necessary to justify their killing. 

There is little public confidence in UVic's statements about rabbits. A poor track record in truth-telling could be the reason.  For example, in early April of 2010 UVic stated to the press that "no cull was planned", and in late April Tom Smith of UVic's facilities management was saying to the Times Colonist reporter "there are no poison boxes, no secret cull".  These comments were made while he planned and executed the trapping and killng of rabbits at Continuing Education at UVic and on the sports fields. Poison boxes and dying and decapitated rabbits were in full view across campus.  In late April exterminators were discovered one evening trapping tame rabbits at Continuing Education. In early May 2010, UVic killed over 100 rabbits on the sports fields...during which time UVic continued their public denials of the killing. 

Finally, on May 15, Tom Smith admitted in a Times Colonist interview with Judith Lavoie to killing 94 rabbits so far, and "reserving the right" to kill more.  To say that UVic lied to the public, and misrepresented their plans, is a given.  The Long Term Rabbit Management Plan had not even been released at that point.  Members of UVic and the surrounding community had not been consulted. 

Little has changed in the callous corporate attitude towards rabbits and the community taken by UVic bureaucrats who now pronounce the campus rabbit-free and say they will kill any "new" rabbits.  The members of UVic, the public, and interested animal welfare groups were not consulted on this new strategy, just as they were ignored in the past.  What many want, however, is an ongoing trapping and removal to sanctuary program, similar to that of Kelowna.

Despite statements by Tom Smith from Facilities Management that UVic's campus is now "rabbit free", local residents say there are still some rabbits on campus, particularly in areas in the periphery where all it takes for a rabbit to get into the firing line is to cross the road dividing UVic from its neighbours.  UVic plans to shoot any rabbits which stray onto UVic property and shoot any remaining rabbits who evaded the trappers.  Some are babies who were born in the last month of trapping and are only now showing their noses above ground.

Tom Smith, who has lied to the public in the past about his intentions towards the rabbits, now says that any rabbits which appear on UVic's campus will be trapped, and given to a licensed trapper to "humane" destruction.  Given that it is standard practice for licensed trappers to bludgeon, decapitate, or stomp rabbits to death, it can hardly be called a humane death, even if the rabbits were to be given to a trapper.  However Smith, true to form, is actually planning to have the rabbits shot, not trapped. 

As the LGL Environmental Consultants report to UVic says "Trapping may be more appealing from the viewpoint of public perception...Trapping may, however, be a necessary precursor to a shooting program in order to improve the defensibility of shooting as an appropriate means of population control."  In other words, trapping has been used as a method of manufacturing public consent for a shooting program.  UVic has done some trapping to appease the public, and will now do some shooting.  Well now, just hold your horses UVic!

If previous rabbit shoots are anything to go by, this will result in many injured and dying rabbits escaping into the woods to die painful, lingering deaths far away in the brush, or deep in their burrows.  Injured rabbits are easy prey for off-leash dogs and other animals. When mother rabbits are killed, an average of 6 little baby rabbits will starve to death in their burrows.  As rabbits breed year round, this can happen at any time.

Other jurisdictions have employed sporadic live-trapping in spots where rabbits appear.  Kelowna, like UVic, managed a large-scale trap-neuter-rehome/relocate program but The Responsible Animal Care Society (TRACS) is still on-hand for periodic trapping for maintenance of rabbit control.  A similar approach must be taken at UVic.

The BC Society for the Prevention of Cruelty to Animals must also take a stand and do what they can to stop rabbit dumping and other abuses of this sensitive and gentle species.  Although the BCSPCA has the power to charge those who abandon rabbits at UVic or elsewhere, to date there has not been one person charged with this offence anywhere in BC.  The British Columbia Society for the Prevention of Cruelty to Animals should be advocating for the lives and welfare of rabbits and other suffering animals in this province.  Instead, the largest and best funded animal welfare organization has turned it's back on one of the most vulnerable species around. 

In addition to their initial and current support of the University of Victoria's plan to kill the homeless former pet rabbits on campus, the society even recommends how to kill them using cruel and regressive methods such as decapitation, gassing, blow to the head and strangling/wringing of their necks.  BCSPCA's "Feral Rabbit Position Statement" says: "If euthanasia is to be performed by agencies other than the BC SPCA, it must be conducted humanely using a method approved by the American Veterinary Medical Association’s Guidelines on Euthanasia".  The rabbit-killing methods suggested by the AVMA are most certainly not humane, as described below and in the attached report "This is how the rabbits die".

The Ministry of Environment also has provisions under the Wildlife Act to charge persons who abandon rabbits.  To date, not one person has been charged under the Wildlife Act either.  There has been no attempt to remove domestic rabbits from "wildlife" designation under the Wildlife Act, despite the lobbying for many years by rabbit advocacy groups.

There is clearly a complete and utter lack of political will on behalf of the BCSPCA, the Ministry of Environment, and UVic to deal humanely and in a non-lethal fashion with homeless domestic rabbits.  There is so much they could do, that they have the power to do...if only they did their duty towards this species.

These large regressive, archaic institutions have clearly learned little from the tremendous public response on behalf of the UVic rabbits during the past few years.  The community cared then what happened to the rabbits, and they still care.  To revert to the old ways at a time when best practices would have them adopt a non-lethal approach to wildlife management would be not only unwise, but also a display of their blatant disregard for the community who have without any assistance from the responsible bodies seen that the rabbits were rescued, and continue to lobby for improved laws, education, and enforcement.

Roslyn Cassells
Action for UVic Rabbits
former Vancouver Park Board Commissioner

attached and inline report: HERE'S HOW THE RABBITS DIE

The BCSPCA's Cruel Attitude Towards Homeless Rabbits and the American Veterinary Medical Association's Euthanasia guidelines

Preface: The British Columbia Society for the Prevention of Cruelty to Animals should be advocating for the lives and welfare of rabbits and other suffering animals in this province.  Instead, the largest and best funded animal welfare organization has turned it's back on one of the most vulnerable species around. 
In addition to their initial and current support of the University of Victoria's plan to kill the homeless former pet rabbits on campus, the society even recommends how to kill them using cruel and regressive methods such as decapitation, gassing, blow to the head and strangling/wringing of their necks. BCSPCA's "Feral Rabbit Position Statement" says: "If euthanasia is to be performed by agencies other than the BC SPCA, it must be conducted humanely using a method approved by the American Veterinary Medical Association’s Guidelines on Euthanasia"

It must be said that it absolutely inappropriate for the BCSPCA to refer to killing healthy animals as "euthanasia".  Euthanasia refers to mercy killing when an individual is suffering terribly and there is no possible further treatment or pain control available.  Killing animals in any other circumstance is simply convenience killing.

Here are the excerpts from the AVMA guidelines on euthanasia which pertain to rabbits:

Acceptable methods for killing rabbits:
"Barbiturates, inhalant anesthetics, CO2, CO, potassium chloride in conjunction with general anesthesia" from Appendix 1 - Agents and Methods of Euthansia by Species

"Conditionally Acceptable" methods for killing rabbits:
"N2, Ar, cervical dislocation (< 1 kg), decapitation, penetrating captive bolt"  from Appendix 1 - Agents and Methods of Euthanasia by Species

under Inhalant anaethetics:
"Nitrogen (N2) and argon (Ar).:  Euthanasia is induced by placing the animal in a closed container that has been prefilled with N2 or Ar or into which the gas is then rapidly introduced. Nitrogen/Ar displaces O2, thus inducing death by hypoxemia."

"Following loss of consciousness, vocalization, gasping, convulsions, and muscular tremors developed in some dogs. At the end of a 5 minute exposure period, all dogs were dead.88 These findings were similar to those for rabbits and mink....rats collapsed in approximately 3 minutes and stopped breathing in 5 to 6 minutes. Regardless of flow rate, signs of panic and distress were evident before the rats collapsed and died.85 Insensitivity to pain under such circumstances is questionable

under Advantages and Disadvantages for N2 (nitrogen):  "Advantages—(1) Nitrogen and Ar are readily available as compressed gases. (2) Hazards to personnel are minimal.
Disadvantages—(1) Loss of consciousness is preceded by hypoxemia and ventilatory stimulation, which may be distressing to the animal."

CO2: "Some burrowing animals, such as rabbits of the species Oryctolagus, also have prolonged survival times when exposed to CO2" and "Carbon dioxide is readily available and can be purchased in compressed gas cylinders. (3) Carbon dioxide is inexpensive"
CO:  "In a study by Ramsey and Eilmann,94 8% CO caused guinea pigs to collapse in 40 seconds to 2 minutes, and death occurred within 6 minutes. Carbon monoxide has been used to euthanatize mink and chinchillas. These animals collapsed in 1 minute, breathing ceased in 2 minutes, and the heart stopped beating in 5 to 7 minutes.
In a study evaluating the physiologic and behavioral characteristics of dogs exposed to 6% CO in air, Chalifoux and Dallaire95 could not determine the precise time of loss of consciousness. Electroencephalographic recordings revealed 20 to 25 seconds of abnormal cortical function prior to loss of consciousness. It was during this period that the dogs became agitated and vocalized."
"In a comparative study, CO from gasoline engine exhaust and 70% CO2 plus 30% O2 were used to euthanatize cats. Euthanasia was divided into 3 phases. Phase I was the time from initial contact to onset of clinical signs (eg, yawning, staggering, or trembling). Phase II extended from the end of phase I until recumbency, and phase III from the end of phase II until death.54 The study revealed that signs of agitation before loss of consciousness were greatest with CO2 plus O2. Convulsions occurred during phases II and III with both methods."
"In people, the most common symptoms of early CO toxicosis are headache, dizziness, and weakness...these signs may be followed by decreased visual acuity, tinnitus, nausea, progressive depression, confusion, and collapse. ..loss of consciousness may be accompanied by convulsions and muscular spasms."
Carbon monoxide must only be used in a chamber built and maintained to specifications.
Barbituates: (NONINHALANT PHARMACEUTICAL AGENTS)

"The use of injectable euthanasia agents is the most rapid and reliable method of performing euthanasia" and "Intracardiac injection (heart-stick) is acceptable only when performed on heavily sedated, anesthetized, or comatose animals."

"Barbiturates depress the central nervous system in descending order, beginning with the cerebral cortex, with loss of consciousness progressing to anesthesia. With an overdose, deep anesthesia progresses to apnea, owing to depression of the respiratory center, which is followed by cardiac arrest...All barbituric acid derivatives used for anesthesia are acceptable for euthanasia when administered intravenously. ..Sodium pentobarbital (Euthanol) best fits these criteria and is most widely used..."

"Disadvantages—(1) Intravenous injection is necessary for best results and requires trained personnel. (2) Each animal must be restrained. (3) Current federal drug regulations require strict accounting for barbiturates and these must be used under the supervision of personnel" (with the relevant governmental agencies' supervision)... also "An aesthetically objectionable terminal gasp may occur in unconscious animals."

There is a serious risk to other animals due to secondary exposure to contaminated carcasses if not properly disposed of  by cremation.  Under Disadvantages: "(5) These drugs tend to persist in the carcass and may cause sedation or even death of animals that consume the body."

"Chloral hydrate depresses the cerebrum slowly; therefore, restraint may be a problem for some animals. Death is caused by hypoxemia resulting from progressive depression of the respiratory center, and may be preceded by gasping, muscle spasms, and vocalization.  Chloral hydrate is not acceptable for dogs, cats, and other small animals because the side effects may be severe..."

Potassium chloride with anaesthetic:  "Although unacceptable and condemned when used in unanaesthetized animals, the use of a supersaturated solution of potassium chloride injected intravenously or intracardially in an animal under general anesthesia is an acceptable method to produce cardiac arrest and death."  Under Disadvantages: "Rippling of muscle tissue and clonic spasms may occur on or shortly after injection."  "Administration of potassium chloride intravenously requires animals to be in a surgical plane of anesthesia characterized by loss of consciousness, loss of reflex muscle response, and loss of response to noxious stimuli"

under PHYSICAL METHODS:

"A penetrating captive bolt is used for euthanasia of ruminants, horses, swine, laboratory rabbits, and dogs." (not for use with wildlife and free roaming animals such as the UVic rabbits)

"Cervical dislocation is a technique that has been used for many years and, when performed by well-trained individuals, appears to be humane. However, there are few scientific studies to confirm this observation. This technique is used to euthanatize poultry, other small birds, mice, and immature rats and rabbits....for immature rabbits, the head is held in one hand and the hind limbs in the other. The animal is stretched and the neck is hyperextended and dorsally twisted to separate the first cervical vertebra from the skull...Data suggest that electrical activity in the brain persists for 13 seconds following cervical dislocation, and unlike decapitation, rapid exsanguination does not contribute to loss of consciousness."

"Disadvantages—...(2) Cervical dislocation requires mastering technical skills to ensure loss of consciousness is rapidly induced. (3) Its use is limited to poultry, other small birds, mice, and immature rats and rabbits." and "Recommendations—Manual cervical dislocation is a humane technique for euthanasia of poultry, other small birds, mice, rats weighing < 200 g, and rabbits weighing < 1 kg when performed by individuals with a demonstrated high degree of technical proficiency. In lieu of demonstrated technical competency, animals must be sedated or anesthetized prior to cervical dislocation. The need for technical competency is greater in heavy rats and rabbits, in which the large muscle mass in the cervical region makes manual cervical dislocation physically more difficult."

 "Decapitation can be used to euthanatize rodents and small rabbits in research settings.
Disadvantages—(1) Handling and restraint required to perform this technique may be distressful to animals.83 (2) The interpretation of the presence of electrical activity in the brain following decapitation has created controversy and its importance may still be open to debate."
"Guillotines that are designed to accomplish decapitation in adult rodents and small rabbits in a uniformly instantaneous manner are commercially available."

from the preface:
"Welfare issues are increasingly being identified in the management of free-ranging wildlife, and the need for humane euthanasia guidelines in this context is great. Collection of animals for scientific investigations, euthanasia of injured or diseased wildlife species, removal of animals causing damage to property or threatening human safety, and euthanasia of animals in excess population are drawing more public attention. These issues are acknowledged in these guidelines and special considerations are described for handling animals under free-ranging conditions, where their needs are far different from those of their domestic counterparts. "  How are their needs "far different", don't all animals deserve equal treatment for pain and suffering?  Why are the social conditions of specific groups of animals used as excuses for their neglect, and their inadequate and cruel treatment at the hands of the veterinary profession and the public?

"These guidelines are intended for use by members of the veterinary profession who carry out or oversee the euthanasia of animals. Although the guidelines may be interpreted and understood by a broad segment of the general population, a veterinarian should be consulted in the application of these recommendations."  This appears to mean that the public, a trapper, a hunter, a grounds maintenance person can use these methods to kill animals.  It is only recommended that a veterinarian be consulted.

from General Considerations: 
"In evaluating methods of euthanasia, the panel used the following criteria:...(12) safety for predators/scavengers should the carcass be consumed."
and "Animals must not be restrained in a painful position before slaughter"
and "Ethical considerations that must be addressed when euthanatizing healthy and unwanted animals reflect professional and societal concerns. These issues are complex and warrant thorough consideration by the profession and all those concerned with the welfare of animals." (BCSPCA, BCVMA, MOE, RCMP, municipal forces and bylaw officers)

"It is the intent of AVMA that euthanasia be performed in accordance with applicable federal, state, and local laws governing drug acquisition and storage, occupational safety, and methods used for euthanasia and disposal of animals." 
What are the applicable provincial, federal, municipal, and regional laws and regulations regarding the killing of rabbits and the disposal of their bodies?" It has been reported for example that the SPCA on Vancouver Island, instead of cremating dead animals (including animals killed with phenobarbital (euthanol) which can cause secondary poisoning and death in scavengers), dumps the bodies in the Hartland Landfill near Esquimalt, a capital regional district landfill. This is where Tom Smith said that the bodies of the 104 rabbits killed in May 2010 were dumped.

under Animal Behavioural Considerations:

"Animals that are wild, feral, injured, or already distressed from disease pose another challenge. Methods of pre-euthanasia handling suitable for domestic animals may not be effective for them. Because handling may stress animals unaccustomed to human contact (eg, wildlife, zoo, and feral species), the degree of restraint required to perform any euthanasia procedure should be considered when evaluating various methods. When handling these animals, calming may be accomplished by minimizing visual, auditory, and tactile stimulation. When struggling during capture or restraint may cause pain, injury, or anxiety to the animal or danger to the operator, the use of tranquilizers, analgesics, and/or anesthetics may be necessary. A route of injection should be chosen that causes the least distress in the animal for which euthanasia must be performed. Various techniques for oral delivery of sedatives to dogs and cats have been described that may be useful under these circumstances."

"Fear can cause immobility or “playing dead” in certain species, particularly rabbits and chickens. This immobility response should not be interpreted as loss of consciousness when the animal is, in fact, conscious. Distress vocalizations, fearful behavior, and release of certain odors or pheromones by a frightened animal may cause anxiety and apprehension in other animals. Therefore, for sensitive species, it is desirable that other animals not be present when individual animal euthanasia is performed."
under Human Behavioural Considerations: "Constant exposure to, or participation in, euthanasia procedures can cause a psychologic state characterized by a strong sense of work dissatisfaction or alienation, which may be expressed by absenteeism, belligerence, or careless and callous handling of animals."                                                                                                                                                                                                                                                                                                                     
"The fourth situation is wildlife control. Wildlife biologists, wildlife managers, and wildlife health professionals are often responsible for euthanatizing animals that are injured, diseased, in excessive number, or that threaten property or human safety. Although relocation of some animals is appropriate and attempted, relocation is often only a temporary solution to a larger problem. People who must deal with these animals, especially under public pressure to save the animals rather than destroy them, can experience extreme distress and anxiety."

under Wildlife:

"Veterinarians providing support to those working with injured or live-trapped, free-ranging animals should take capture, transport, handling distress, and possible carcass consumption into consideration when asked to assist with euthanasia."

under Diseased, Injured, or Live-Captured Wildlife or Feral Species:

"Certain cases of wildlife injury (eg, acute, severe trauma from automobiles) may require immediate action, and pain and suffering in the animal may be best relieved most rapidly by physical methods including gunshot or penetrating captive bolt " (these methods are not used by wildlife rehabilitation centers or veterinarians)

reference:

Appendix 1—Agents and methods of euthanasia by species
Agents and methods of euthanasia by species (refer to Appendix 4 for unacceptable agents and methods.)

 
Species     Acceptable* (refer to Appendix 2 and text for details)     Conditionally acceptable† (refer to Appendix 3 and text for details)      
 
Rabbits     Barbiturates, inhalant anesthetics, CO2, CO, potassium chloride in conjunction with general anesthesia     N2, Ar, cervical dislocation (< 1 kg), decapitation, penetrating captive bolt