Victory!
We are thrilled to announce a significant victory for wildlife rehabilitation in Florida! Thanks to the overwhelming support from our community and the diligent efforts of everyone who signed our Change.org petition, the Florida Fish and Wildlife Conservation Commission (FWC) has removed the 72-hour veterinary requirement from their rule changes. This is a monumental win for not just the North Florida Wildlife Rehabilitation Center (NFWRC), but for wildlife rehabilitation centers across the state.
The removal of this requirement means that we can continue to provide immediate, specialized care to animals in need without the logistical and financial burdens that a mandatory 72-hour vet visit would have imposed. It allows us to focus on what truly matters: the well-being and successful rehabilitation of Florida's incredible wildlife.
We want to extend our heartfelt gratitude to each and every one of you who supported us. Your signatures, shares, and words of encouragement played an instrumental role in achieving this result. Together, we have shown that community action can bring about meaningful change. Thank you for standing with us and for helping to ensure a brighter future for Florida's wildlife.
NFWRC has pressing concerns about the recent rule changes proposed by the Florida Fish and Wildlife Conservation Commission (FWC). While some changes offer improvements, critical issues include unrealistic age restrictions for animals, vague enforcement criteria, constitutional questions surrounding post-permit inspections, and notably impractical veterinary visit requirements. These rules were made public with insufficient time for public feedback, just days before the only public meetings scheduled. I strongly recommend postponing the adoption of these rules until they have been thoroughly evaluated by both the public and experts in the field.
Support by Signing our Petition
Our Petition
Purpose
New FWC rules could shut down most small wildlife rehab centers in Florida—here's why we need your voice now.
Wildlife Rehabilitator's are concerned about the recent changes to rule 68A-9.006 governing Wildlife Rehabilitation by the FWC. These proposed changes were disclosed mere days before the only public meetings scheduled for September 25th to 28th. This limited window hinders thorough public and expert evaluation. While some changes are beneficial, others are problematic or even unconstitutional. These rules are set for enforcement in 2024 or sooner and urgently require comprehensive review to ensure they are valid and enforceable.
Urgency
These changes are set for enforcement in 2024 or sooner. Time is of the essence.
Specific Concerns
Mandatory Vet Visits
Section (10)(3)(g) imposes a 72-hour window for most animals to have an exam by a veterinarian. This requirement is not only logistically challenging but also financially burdensome. The mandate becomes even more problematic when considered alongside section (10)(a), which obliges us to accept all native wildlife. It's worth noting that the FWC often directs us to take in animals they've captured or confiscated. The narrow 72-hour window is unrealistic given the limited availability of general practice veterinarians and those specialized in wildlife. The situation becomes particularly unmanageable when animals arrive on a Friday and the following Monday is a holiday. Most veterinary offices require at least a week to schedule routine visits and the 72 hour requirement is not reasonable. This places permit holders at risk of being in violation through no fault of their own because of scheduling conflicts beyond their control.
Age Restriction
Section (7)(o) states that off-site facilities cannot house animals older than 12 weeks. This restriction could severely limit our ability to provide extended care for certain species.
Subjective Enforcement
The rule specified in section (7)(f)(1,5) regarding "natural behavior and movement" is ambiguous and could be misused by FWC personnel to apply their subjective judgment rather than rely on experience-based knowledge.
Post-Permit Inspections
Section (9)(c) raises constitutional questions, allowing unscheduled inspections up to 12 months after a permit is no longer active.
Notification Requirements
Sections (10)(3)(b) & (10)(3)(c) require 24-hour notice to FWC for accepting Class I or II animals or threatened/endangered species. The lack of clear procedures for these notifications could result in wasted resources for FWC and permit holders.
Positive Changes
While I acknowledge that some of the proposed changes offer improvements to current practices, such as the apprentice process, the document requires a more comprehensive review.
Solutions
- Postpone implementation until subject matter experts, rather than political appointees, have thoroughly reviewed the changes.
- Extend the period for public comment more than a week!
- Conduct formal public hearings with speakers to allow for in-depth input, rather than limiting feedback to paper and online forms.
Attend the Next Commission Meeting
If you cannot attend one of the meetings but would still like to submit comments, you may do so using the form online at https://myfwc.com/license/captive-wildlife/public-comments/.
October 4th and 5th, 2023 starting at 8:30 AM
Hutchinson Shores Resort
3793 NE Ocean Boulevard
Jensen Beach, Florida, 34957
This meeting is open to the public
Questions You can Ask
- Did the commission (FWC) contact the Florida Wildlife Rehabilitator's Association or the Florida Veterinary Medical Association before drafting these new rules?
- Did the International Wildlife Rehabilitation Council influence or lobby for the requirement of their certification and continuing education courses?
- How did the commission (FWC) arrive at the number of hours between intake and the required veterinary visit?
- If the commission calls and asks a rehabilitator to accept captured or confiscated wildlife, will the commission (FWC) offer any type of remuneration or compensation for the costs associated with that animal to see a vet within the 72 hour requirement?
- Is it the intent of the commission (FWC) to reduce the number of home based rehabilitation?
- What specific research or case studies support the new age and grouping restrictions for animals in rehabilitation?
- How does FWC intend to implement the vague clause about "impeding natural behavior and movement," and what safeguards are in place against subjective enforcement?
- Can FWC elaborate on the constitutional basis for permitting ongoing inspections for 12 months after a license has been revoked or expired?
- What mechanisms will be established to facilitate the 24-hour notice requirement for receiving Class I or II or threatened/endangered species?
- How does FWC propose Wildlife Rehabilitators' manage the impractical 72-hour veterinary visit rule, particularly during weekends and holidays?
Resources
Printable Flyers
Download the Rule Change "Draft" as a PDF
