Bellow are two letters explaining the very serious concerns created by the allowance of illegal deer farming in New Brunswick. We could really use the support of our environmental friends to make sure New Brunswick’s indigenous white-tailed deer are not continued to be exploited at the expense of environmental health and safety. Please write our Minister of Natural Resources, Bruce Northrup at and let him know that you want these farms shut down now!

June 7, 2012

Dear Minister Northrup,

It was reported on Monday that your department has decided to halt the closing of illegal deer farms in this province. I hope you will understand how surprising and frustrating this is to many of us who work in fields related to wildlife.

As you are aware, we established the Atlantic Wildlife Institute in New Brunswick in 1995, at a time when the province was in the early stages of reviewing and adjusting many of its policies and protocols for handling wildlife. At the time there was a concerted effort by the wildlife staff of the then Department of Natural Resources and Energy to bring the province into harmony with other North American jurisdictions. A series of incidents, both within and outside the province, motivated the department to take action.

Primary concerns focused on:

the mixing of indigenous wildlife with captive exotic populations;
the lack of a standardized methodology for handling nuisance wildlife;
the lack of a regulated system for the handling of distressed wildlife; and
the illegal raising of native species in farming environments.

At the same time, a series of incidents across North America involving the epizootic movement of new diseases such as West Nile Virus, Lyme Disease, Rabies and Chronic Wasting Disease, instilled concern about regional wildlife and general public health and safety.

The end results of this review were:

closure of provincial zoos and nature parks and/or adoption of new standards of operations which included not taking in animals from indigenous wildlife populations;
establishment of privatized, fee-for-service, wildlife control agents to handle nuisance wildlife concerns;
establishment of AWI under appropriate rehabilitation standards, to deal with injured, sick or orphaned wildlife; and
elimination of wildlife farms that were operating illegally and without provincial regulatory guidelines.

All these actions were taken with the supposed intent of minimizing human/wildlife conflict and protecting both human and animal welfare.

As years passed and administrations changed, decision makers in government seem to have lost their focus on these important initiatives and forgotten the lessons learned from the years past.

Over the last five years, your department has imposed a policy restriction on the Atlantic Wildlife Institute that has prohibited us from rehabilitating deer and moose in New Brunswick. It specifically states that,
"Due to federal regulations restricting the movement of ungulates as a means to minimize the spread of disease, New Brunswick will not allow wildlife rehabilitators to rehabilitate moose and white-tailed deer in the province." Ever since it was imposed, AWI has adhered scrupulously to this restriction, despite the urgings of dozens of New Brunswickers, including officers of the RCMP and of your own department, who have implored us to ignore the ban. Sadly, when confronted with injured and orphaned deer and moose in their communities these people have been left to fend for themselves, with no humane option to turn to.

Federal and provincial regulators justify this policy because of concerns over the spread of Chronic Wasting Disease and Tuberculosis from captive animals to wild ones and vice-versa. It is interesting to note that the origins of this policy do not reflect a local concern, but rather are linked directly to the practice of commercial deer farming in Western Canada and the United States.

Surely you see the disconnect here. Why does your department, on the one hand, prohibit AWI from acting as the sole safe buffer against members of our communities interacting with these wild species while, on the other hand, turning a blind eye to the very activity - namely deer farming - that is considered one of the primary vectors for bringing new diseases into regional wildlife populations?

We implore you and your department to act swiftly in enforcing the existing law to keep these farms illegal. At the same time we urge you to reconsider the restriction on our wildlife rehabilitation permit so we may once again offer a safe and effective alternative to reckless public interactions with our wild deer and moose population.

Barry Rothfuss
Executive Director
Atlantic Wildlife Institute

9 June 2012

Hon. Bruce Northrup
Natural Resources & Energy
PO Box 6000
Fredericton, NB
E3B 5H1

Dear Minister Northrup:

I was dismayed to learn that you "flip-flopped" on your previously
wise decision to close down the 15+ illegal white-tail deer pens in New Brunswick. My "gut" reaction was that you are indeed supportive of closing these operations, but have been pressured to reverse this decision by your Caucus and/or colleagues. This is an unfortunate "turn of events" for wildlife management in this Province.

Mr. Northrup, as a representative of the Crown and Minister of Natural Resources, you took an oath to uphold the laws of New Brunswick. No citizen [or legislator] can "cherry-pick" the laws that he or she wishes to follow or uphold. If you and your colleagues feel that private ownership of native wildlife is an acceptable and desirable practice and should be permitted then you should announce publicly of your government's intent and begin the process of drafting amendments to the Fish & Wildlife Act and Regulations. If this is your chosen course of action then you should include a consultative process for public comment and discussion as part of the process and decision. If you are not prepared to change the legislation then you should immediately instruct your Conservation Officers to seize the 200+ white-tailed deer illegally held in private ownership and arrange either euthanization or export/sale to a jurisdiction that permits this practice.

I urge you to reconsider your decision for the following reasons:

1. By allowing private ownership of "native" wildlife you open up a "Pandora's Box" of problems with respect to wildlife management, conservation enforcement, human health, and public safety. I am sure you have not forgotten the unfortunate goring death a few months ago of one of the illegal owners of white-tailed deer. No matter how long they have been confined behind fences, these animals are wild and unpredictable. Since these white-tails are being confined as "so-called pets", what happens next time if a child or visitor gets injured or killed while inside one of the poorly fabricated pens? The origin of these deer are unknown, but supposedly they were imported [illegally?] from Quebec. Who validated the status of their health for inter-provincial movement? Where are the Agriculture-Canada export permits for inter-provincial transport? If they were issued, then who authorized this paperwork?

My sources tell me that some of the deer in confinement came from the wilds of New Brunswick; a number of them donated by Department of Natural Resources staff when they encountered injured/orphaned white-tail fawns during their regular duties. This is a serious situation, but somewhat understandable, since DNR does not have a coherent policy and program for handling injured/orphaned wildlife that are regularly encountered by field staff. If DNR field staff had a "legal" and feasible option [other than euthanization] to provide rehabilitation for these animals, then they wouldn't be tempted to hand them over to illegal deer owners. The largest wildlife rehabilitation centre in the Province, Atlantic Wildlife Institute, in Sackville has been specifically ordered as part of their permitting by your Department to never accept or treat or handle deer or moose because of wildlife disease concerns. This is a hypocritical position by your Department, given that illegal deer owners have no such restrictions or training in handling wildlife.

If you allow white-tailed deer to be kept as pets, what stops a resident from having a raccoon, skunk, crow, wood turtle, garter snake, moose, or bear cub as a pet? Can you imagine the human health and safety issues that this will promote? Wildlife are vectors for parasites and diseases that cause human sickness and death. How will your wildlife and conservation staff be able to monitor these individuals and ensure that these animals are not taken from the wild for private pet ownership? Your staff are hard-pressed enough now to ensure compliance with current [legal] regulations under the Fish & Wildlife Act, let alone attempting to monitor and regulate private pet ownership of wildlife. This would be a disaster!

2, In spite of what the illegal deer owners have stated, you and I both know that these 200+ deer are not being confined behind fences solely as pets. The owners have created markets for trophy shooting within pens, and sale of venison, antlers, antler velvet and urine; all currently illegal activities under the Act and Regulations. Are you planning on amending laws to permit these activities? How is the venison being processed and inspected for human consumption when it is sold? Has the Canadian Food Inspection Agency been consulted to allow sale of venison? The reason why most jurisdictions in North America do not allow personal ownership or farming of native wildlife is because of the significant problems and threats that affect conservation efforts, human health and human safety. New Brunswick would be wise to avoid going down this path.

3. If you investigate the issues and problems surrounding the deer farming industry in North America [or Canada, alone] since the early 1990's, you will find that animal and human health concerns and their impact on domestic animal production have resulted in billions of dollars in compensation having to be paid to deer farmers when disease has been detected and herds quarantined and destroyed. Deer, and other wildlife farming initiatives are
not growing industries, but have resulted in significant threats to our domestic animal production industries. Wild boar farming, in particular, poses significant threats to native wildlife populations and the forest resource industry. You should be concerned that New Brunswick has allowed these operations with limited or no monitoring or regulations. I would like to discuss this with you, once the white-tail deer issue is resolved.

4. Allowing private ownership and creating markets for native wildlife disrupts the key pillars of our North American Model for Wildlife Conservation. Both the Northeast Deer Technical Committee [of which NB is a member] and The Wildlife Society of Canada and the United States do not condone or support private ownership or markets for wildlife. The wildlife resources of New Brunswick are significant to our history and culture, and a sacred trust that you and your Government have been given to manage for the benefit of all New Brunswicker's, not a special interest group of 15+ illegal deer owners. The path you are taking will jeopardize wildlife management and our precious wildlife resources that the naturalists, hunters, and outfitters of this Province enjoy today. Please reconsider and reverse your decision to allow white-tail deer ownership in NB.

I would be happy to further elaborate and discuss with you and your colleagues, the concerns that I have raised in this rather lengthy correspondence.

Please carefully consider the points above and do the right thing: Keep the "wild" in wildlife?

Respectfully yours,

Gerry Redmond
Certified Wildlife Biologist
60 Colwell Drive, Unit 8
Fredericton, NB
E3A 6R3
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