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Board of Health

January 25, 2000

To: Board of Health

From: City Clerk

Subject: Wildlife Strategy for the City of Toronto and Response to Raccoon Rabies - Recommendations from Animal Services Advisory Subcommittee meeting, January 17, 2000

Recommendations:

The Board of Health Animal Services Advisory Subcommittee recommends:

(1) endorsement of the recommendations contained in the report (November 5, 1999) from the Medical Officer of Health outlining the Wildlife Strategy for the City of Toronto and Response to Raccoon Rabies;

(2) that the City consider implementing an education programme for City of Toronto residents to discourage pet owners from allowing their cats to wander at large;

(3) that the Medical Officer of Health and Commissioner of Urban Development Services, in consultation with the City Solicitor, be requested to report back on co-developing a licensing program to certify and enlist private industry's wildlife control services, and as a condition of licensing, to ensure those private industries seeking licensing abide by the City of Toronto's wildlife control policy;

(4) that the Medical Officer of Health consult with the Ministry of Natural Resources to determine the feasibility of inoculating feral and stray cat populations;

(5) that the City Solicitor be requested to pursue special legislation from the Province of Ontario to ban the use of snares, leg-holds and conibear traps;

(6) that the Medical Officer of Health and Toronto Academy of Veterinary Medicine be requested to establish a co-operative program to promote the rabies vaccination of companion animals;

(7) that the Medical Officer of Health be requested to explore all options of service delivery for telephone services to answer raccoon rabies and wildlife questions;

(8) that the Medical Officer of Health be requested to make some attempt to determine whether there are other methods to control an outbreak of raccoon rabies other than adopting the Ministry of Natural Resources point control program;

(9) that the Medical Officer of Health be requested:

(i) to report on a strategy on how to effectively safeguard the community from domestic animals in a point control area from raccoon rabies; and

(ii) to investigate other options to the use of metal ear tags for raccoons; and

(10) that the Medical Officer of Health be requested to consider hosting a meeting with private wildlife and pest control companies and associated industry representatives to promote and share information about the City's wildlife policies, in co-operation with the Ministry of Natural Resources' Rabies Unit.

Background:

The Board of Health Animal Services Advisory Subcommittee at its meeting on January 17, 2000 had before it a communication (November 15, 1999) from the City Clerk advising that the Board of Health at its meeting on November 15, 1999, adopted the report (November 5, 1999) from the Medical Officer of Health respecting Toronto Public Health's Wildlife Strategy and the recommended response to the prevention and control of Raccoon Rabies, subject to amending Recommendation No. (6) to provide that this matter be forwarded to the Policy and Finance Committee for consideration during the 2000 operating budget process following submission of recommendations by the Animal Services Advisory Subcommittee in January 2000.

The Board also noted that Recommendation No. (4) was revised to read as follows:

"(4) request the Ontario Minister of Health to add the City of Toronto to Table 1 of the Province of Ontario Regulation 567 (Rabies Immunization), thereby making the vaccination of dogs and cats mandatory across the entire City;"

The aforementioned report, as amended, was therefore referred to the Animal Services Advisory Subcommittee to hear public deputations and make recommendations back to the Board of Health for its January 2000 meeting.

The following persons appeared before the Subcommittee in connection with the foregoing matter:

- Mr. Barry Kent MacKay, International Program Director, Animal Protection Institute;

- Mr. Brad Gates, AAA Wildlife Control, and filed a written submission;

- Dr. Heather Reid, DVM, Toronto Wildlife Centre;

- Ms. Cindy Pyves, Toronto Wildlife Centre; and

- Ms. Kate Harrison, Toronto Wildlife Centre.

City Clerk

D. Ting

Item No. 2

c. Medical Officer of Health

Commissioner of Urban Development Services

City Solicitor

attachments

November 15, 1999

To: Animal Services Advisory Subcommittee

From: City Clerk

Subject: Toronto Public Health's Wildlife Strategy and

Recommended Response to the Prevention and

Control of Raccoon Rabies

The Board of Health at its meeting on November 15, 1999, adopted the report (November 5, 1999) from the Medical Officer of Health respecting Toronto Public Health's Wildlife Strategy and the recommended response to the prevention and control of Raccoon Rabies, subject to amending Recommendation No. (6) to provide that this matter be forwarded to the Policy and Finance Committee for consideration during the 2000 operating budget process following submission of recommendations by the Animal Services Advisory Subcommittee in January 2000.

The Board also noted that Recommendation No. (4) was revised to read as follows:

"(4) request the Ontario Minister of Health to add the City of Toronto to Table 1 of the Province of Ontario Regulation 567 (Rabies Immunization), thereby making the vaccination of dogs and cats mandatory across the entire City;"

The aforementioned report, as amended, is therefore referred to the Animal Services Advisory Subcommittee to hear public deputations and make recommendations back to the Board of Health for its January 2000 meeting.

City Clerk

Trudy Perrin/lm.5

c. Medical Officer of Health

STAFF REPORT

November 5, 1999

To: Board of Health

From: Dr. Sheela V. Basrur, Medical Officer of Health

Subject: Wildlife Strategy for the City of Toronto and Response to Raccoon Rabies

Purpose:

To present Toronto Public Health's Wildlife Strategy and the recommended response to the prevention and control of raccoon rabies.

Financial Implications and Impact Statement:

In its October 15, 1999 report on the Public Health 2000 Operating Budget, the Division requested $250,000 in additional funding to implement a Raccoon Rabies contingency plan. Upon further study, these amounts have been revised downwards to $126,000 in annualized funds for ongoing operating expenses, plus $80,000 as a one-time expenditure. The overall impact in the year 2000 from one-time expenses and six months implementation would be $146,000. Animal Services are not eligible for Ministry of Health cost-shared funding, although rabies control activities are cost-shared and some outbreak-related expenses may be covered by the Ontario Ministry of Natural Resources.

Recommendations:

Subject to final decisions of the Board of Health and City Council regarding the Animal Services Review, it is recommended that the Board of Health:

(1) Endorse the Wildlife Strategy, with a principal focus on rabies prevention, as outlined in this report;

(2) Recommend additional funding to the Public Health operating budget of:

(i) $60,000 for the year 2000 ($120,000 annualized) to implement the educational components of the Wildlife Strategy;

(ii) $30,000 one-time in 2000 to investigate the most effective ways of vaccinating raccoons and to conduct surveillance for the detection and prevention of rabies within Toronto's raccoon population;

(iii) $50,000 one-time in 2000 for research and development into appropriate policies and procedures to prevent human rabies that may result from Raccoon Rabies exposures; and

(iv) $6,000 annually for the purchase of traps to implement a point control program;

(5) Endorse the establishment of:

(i) an active surveillance program for Raccoon Rabies within Toronto, focusing on high-risk areas and bordering green spaces, and that this program be initiated by the Medical Officer of Health at the appropriate time, in consultation with the Ontario Ministry of Natural Resources;

(ii) a raccoon rabies vaccination program within Toronto using the most effective methods available, and that this program be initiated by the Medical Officer of Health at the appropriate time, in consultation with the Ontario Ministry of Natural Resources;

(iii) a Raccoon Rabies committee involving bordering health units, the Ministry of Health and the Ministry of Natural Resources, to ensure that Toronto Public Health is well informed about Raccoon Rabies in Ontario;

(4) Request the Ontario Minister of Health to add the City of Toronto to Table 1 of the Province of Ontario Regulation 567 (Rabies Immunization), thereby making the vaccination of dogs and cats mandatory across the entire City;

(5) Request the Medical Officer of Health to report back to the Board of Health on the recommended policies and financial implications of a revised City response to potential rabies exposures once the necessary research is completed;

(6) Refer this report to the Budget Advisory Committee for consideration during the 2000 operating budget process; and

(7) Refer this report to the Animal Services Advisory Committee to hear public deputations and make recommendations back to the Board of Health for its January 2000 meeting.

Background:

At its meeting of July 22, 1999, the Board of Health requested the Medical Officer of Health to report back on the City's policy concerning raccoons and to develop an action plan to prevent or minimize the potential spread of raccoon rabies to the City. The initial request regarding the City's raccoon policy was from a local resident; this request has since been withdrawn. However, in light of the recent introduction of the raccoon strain of rabies to Ontario and related concerns as to how wildlife is dealt with in the city, this report has been prepared in order to address both issues.

Also, at its meeting of March 27, 1998, the Board of Health adopted the March 12, 1998 report from the Chief Administrative Officer and Medical Officer of Health, entitled "Interim Arrangements for the Provision of Animal Services in 1998." One of the adopted recommendations authorized the Chief Administrative Officer, with resources provided from Finance, Audit and the Amalgamation Office, to conduct a comprehensive review of options for the delivery of animal services across the City.

The external review of Animal Services has been completed, and the final report will be considered, at the November 15, 1999 Board of Health meeting. The findings of the Review are consistent with the approach outlined in this report.

Comments:

(1) Toronto's Wildlife Strategy

Wildlife forms an integral part of a quality urban environment, representing an important part of the ecosystem within our parks and green spaces. Over the years, wildlife has been displaced from its natural habitat due to urban development and as a result, a number of the remaining species have adapted well to living closer to people in order to survive. This, combined with the increased naturalizaton of much of our parkland, has greatly increased the potential for human and/or pet to wildlife contact and conflict.

Wildlife in Toronto is comprised of many species, including a well established population of raccoons. With the recent introduction of Raccoon Rabies to Ontario, an effective wildlife strategy with a focus on rabies will improve Public Health's chances to control the introduction and spread of Raccoon Rabies. The wildlife strategy deals with responses to nuisance wildlife concerns, public health and safety threats, and sick/distressed or injured wildlife. The strategies to deal with these concerns include educational efforts, on-site visits, and emergency fieldwork. The development of this strategy included consideration of the province's position regarding wildlife.

(a) Provincial Action Plan

In 1993, the Ministry of Natural Resources (MNR) released an action plan entitled, "Looking Ahead: A Wildlife Strategy for Ontario." This document considered various ways of resolving human/wildlife conflicts in urban Ontario. It concluded that to best resolve, minimize or eliminate human/wildlife conflict, urban animal control services should emphasize effective public education and programs focused on changing the urban environment to prevent human/ wildlife interactions and to promote ways in which people and wildlife can better co-exist.

The MNR also concluded that, while live trapping and removal of wildlife may appear to be temporarily successful in solving complaints, it does not provide a long term solution to the problem due to the following observations:

(i) The attractant(s) (usually a potential den site or food source) that initiated the human/wildlife interaction likely still exists after removal of the animal(s). Other animals quickly take advantage of the remaining attractant(s) and re-initiate human/wildlife conflict.

(ii) Removal of an animal from one area results in greater litter size the following year from the remaining wildlife in that area. The population density naturally increases to the level sustainable within that environment.

(iii) New animals moving into a depopulated area may bring disease with them, exposing the existing population to a new problem. The MNR has spent the last ten (10) years immunizing foxes against the Arctic Fox strain of rabies by distributing oral bait impregnated with rabies vaccine. Removal of these animals when they become a "nuisance" would detract from the program's effectiveness.

(iv) Extensive park systems support healthy populations of wildlife, including substantial numbers of raccoons that are available to re-populate any area where nuisance animals have been removed.

The MNR has reinforced its position on wildlife management with the passage of Bill 139, an act to promote the conservation of fish and wildlife through the revision of the Game and Fish Act. This new legislation prohibits the transportation of wildlife from one jurisdiction to another.

(b) Response to Nuisance Wildlife Concerns

All of the former municipalities within Toronto had similar strategies to deal with nuisance wildlife complaints. Nuisance wildlife is simply defined as any wildlife that is causing damage or is about to cause damage to a person's home and/or property. This does not include mice and rats, which are considered vermin. Nor does this definition of nuisance wildlife include feral animals, which are considered as strays within the by-law respecting animals.

The emphasis when dealing with nuisance wildlife is on informing and educating the public in an effort to create an environment where both can co-exist free from conflict. Education is provided to help residents eliminate wildlife attractants, such as potential sources of food or shelter. The one instance where harmonization of the strategy is required, is when the resident is unable to resolve the conflict with the information provided. In these cases, all of the former cities except North York offered an on-site Wildlife Control Property Evaluation. The evaluation requires that an Animal Service Officer attend the property to assist in determining why the conflict still exists and to provide appropriate recommendations on how to remedy the problem. This on-site evaluation is done as a last step as it is staff-intensive. Where the property owner has complied with all preventative measures and the problem still persists, the owner has the option of hiring a wildlife removal company or using a humane trap to capture the animal. Relocation of the trapped animal is restricted by the new Conservation of Fish and Wildlife Act, requiring release of the animal in close proximity to where it was captured.

Using this approach, the former six municipalities experienced a decrease in the numbers of animals that were trapped and unnecessarily relocated or euthanized. The public, in most cases, was happier with the long-term solutions suggested and preferred to do what was better for the animals. The residents who did not wish to follow the deterrent recommendations still had the option of hiring a wildlife removal company or renting a humane trap and removing the animal themselves. However, as previously indicated, release of captured animals must occur in the manner set out by the Province. The arrival of Raccoon Rabies in Ontario will require intensification of this strategy to support the goal of preventing the arrival of Raccoon Rabies in Toronto and reducing the risk for further spread of the disease through wildlife relocation.

(c) Response to Wildlife Threats to Public Health and Safety

All six former municipalities responded to instances where wildlife presented a real threat to public health and safety, a practice that has continued since amalgamation. Police assistance is requested in situations where an animal is an immediate threat to the public safety and cannot be readily captured by Animal Services. Where the animal is perceived by the public to be a health and safety threat but there is no proof of such, Animal Services provides the public with educational information to help alleviate any concerns or misperceptions. Staff have also worked with other agencies (such as MNR and Toronto Wildlife Centre) for assistance and support to help resolve the concerns and to consider other potential responses within the community.

Where a wild animal has scratched or bitten a person, or where the person has come into contact with the blood, saliva or other body fluids of the animal, efforts are made to capture the animal and have it tested for rabies. In these instances, appropriate information is collected and provided to Public Health staff for follow-up regarding post-exposure rabies vaccination of the exposed person.

An expeditious response to public health and safety threats is an important component of public health practice and should form part of Toronto's wildlife strategy.

(d) Response to Sick, Distressed or Injured Wildlife

Toronto Animal Services receives over 2,000 sick, distressed or injured wild animals per year. The former and current practice of the six animal service regions is to respond to calls regarding such animals or to direct the concerned citizen to the agency that can best be of assistance. In all of the former regions except Toronto, Animal Services responds to these calls during regular hours of operation. After hours, Animal Services provides response in all areas except the former regions of Toronto and East York. The Toronto Humane Society responds to these wildlife calls at all times in the former Toronto region and after hours in the former East York region. The Toronto Wildlife Centre and the Toronto Humane Society receive wildlife for rehabilitation and assist other agencies in dealing with wild animals. The wild animals received by Toronto Animal Services, upon assessment, may be released to an authorized wildlife rehabilitator, released back into the environment, or euthanized, in accordance with provincial legislation.

It is recommended that Toronto Animal Services continue to operate in this manner within the Wildlife Strategy until final decisions are made regarding the delivery of service as they relate to wildlife.

(e) Wildlife Education, Program Expansion

Currently, Animal Services provides information to members of the public on specific wildlife and on exclusion and detraction steps via telephone, written material, and the City's web site. With the future likelihood of Raccoon Rabies advancing closer to our city, it is recommended that increased public communication and education initiatives primarily focused on Raccoon Rabies be implemented starting in the year 2000. The Raccoon Rabies prevention strategy will be discussed in Part 2 of this report. However, the foundation this strategy will be public education to increase awareness of how Raccoon Rabies can be transmitted and to stimulate changes in the environment to separate wild animals from humans and pets as much as possible. The allocation of increased resources to the current educational efforts will be required to expand the wildlife response. This increase will include two FTE's to respond to telephone inquiries, set up educational displays, visit schools, and develop educational information. The additional funding will also cover the implementation of a telephone information line and production of educational materials for public distribution. The cost to implement the expansion is $120,000 per year.

The main elements of the wildlife education program encompass environmental changes, wildlife avoidance, responsible pet ownership, and mandatory rabies vaccination of dogs and cats, as detailed below.

(i) Environmental Changes

One of the important education initiatives to decrease contact and conflict with wildlife is to inform people about the changes they can make in their environment to reduce wildlife attractants. Raccoons and other wild animals live close to human development because many property owners provide readily available inducements such as food and shelter. Raccoons have become very adept at getting into trash that has not been properly stored and using it as a food source. Information on proper exclusionary composting efforts is another important step in reducing food potentials. Poorly maintained properties, decks, and other structures such as open garages provide accessible wildlife shelter. Educating residents on the proper ways to store trash, and on altering and maintaining the structures on their property to reduce their use as shelter are important components of the wildlife strategy that will also help prevent future contact with RR.

(ii) Staying Away from Wildlife

Increasing the public's awareness of the unpredictable nature of wildlife and the importance of maintaining a safe distance from all wildlife will help reduce injuries and the potential for rabies exposure. For example, people tend to avoid foxes and treat them with caution, as an animal with a long history of carrying rabies in Ontario. Raccoons are often viewed as cute or as a nuisance, rather than as a potential danger to people or their pets. A principal goal of the proposed education campaign will be to change this perception of raccoons to one closer to that of the fox, in order to reduce the frequency of human/raccoon and pet/raccoon contact. Raccoons, when sick with rabies, often become more vicious and lose their natural fear of humans, thereby increasing the possibility of human/raccoon and pet/raccoon contact. Even before the arrival of Raccoon Rabies, this education campaign will reduce the potential for transmission of other strains of rabies by decreasing the number of contacts between humans, animals, and sick raccoons.

(iii) Responsible Pet Ownership and Proper Pet Supervision

There are many potential problems caused by pets allowed to roam freely in the City. Pets may harass and harm wild animals, while wild animals may directly harm domestic pets by physically attacking them or by transmitting diseases. This becomes a human health concern if the disease transmitted to the pet can infect people.

Rabies is one such disease and is deadly to both people and animals. Rabies is a viral infection of the central nervous system of humans and other mammals. People may get rabies from the bite of a rabid animal. Any wild mammal, like a raccoon, skunk, fox, coyote, or bat, can have rabies and transmit it to people. It is also possible, but quite rare, for people to acquire rabies if infectious material from a rabid animal, such as saliva, gets directly into their eyes, nose, mouth, or open wound. Symptoms in humans include headache, fever, behavioural changes and paralysis leading to death. Human cases of rabies still occur, though very rarely nowadays due to the effectiveness of post-exposure rabies vaccination in preventing clinical illness. The last case in Ontario was in the early 1980's.

Typically, exposure to raccoon rabies does not come through direct human/raccoon contact but rather through contact between pets (mainly cats) and humans after the pet has been infected with rabies through contact with a rabid animal. Many pet owners allow their pets, especially cats, to roam freely off their properties. Even those owners that fence in their pets often leave them unattended for long periods of time. With the high population of raccoons in Toronto, it is not surprising that many of these pets come into contact with raccoons. A rabid raccoon often becomes more vicious and less frightened of other animals, thereby becoming more aggressive and offensive. This presents a perfect opportunity to transmit rabies to the pet, after which the pet can transmit it to its owners. Small children may be particularly at risk because they are likely to come into contact with the saliva of their family pets. Expanded educational efforts would include advising pet owners of why proper pet supervision is important, especially with the possible arrival of Raccoon Rabies.

(iv) Vaccination of Pets

Vaccinating dogs and cats against rabies is one of the best ways to protect both people and their pets. Almost all of the former six municipalities were designated under provincial regulation to require mandatory vaccination of all dogs and cats. It is recommended that the Province be requested to amend Ontario Regulation 567 (Rabies Immunization) under the Health Protection and Promotion Act, R.S.O. 1990 to require mandatory pet vaccination across the entire new City. Public Health and Animal Services staff will ensure that all pet owners are aware of this requirement, particularly at the time of dog licensing or cat registration, to maximize vaccine coverage rates among pets. This protection will substantially decrease the threat posed by Raccoon Rabies by blocking the transmission of rabies from raccoons to pets to humans.

(2) Raccoon Rabies

Raccoons in Toronto:

One species for which a wildlife strategy is particularly important is the raccoon, an animal that is very successful at living in close proximity to humans. This success has enabled the raccoon population to expand as more shelter and food sources have become available. The Ontario Ministry of Natural Resources estimates that there are an average of 16 raccoons per km2 in Toronto and as many as 85 raccoons per km2 in a few areas. Given the City's geographic size of 632 km2, there are likely over 10,000 raccoons living in Toronto.

The raccoon's abundance and its success living close to humans means there is substantial interaction between raccoons and humans and/or pets, mainly cats and dogs. In the past, the response to nuisance raccoons was often their removal by live trapping. More recently, Toronto Animal Services has provided residents with information on ways to manage and prevent conflicts without resorting to trapping and relocation, as described in the wildlife strategy above.

Geographic Distribution of Raccoon Rabies:

In July and September 1999, three confirmed cases of raccoon rabies (RR) were detected in Eastern Ontario. While this marked the first time that RR was detected in Ontario, its appearance here has been predicted for many years. RR originated in Florida in the 1940's and has been travelling northwards ever since, infecting and killing raccoons throughout the northeastern United States. Their otherwise slow progress northward was greatly accelerated in the 1970's and 1980's by local hunters who relocated raccoons from Florida to Virginia, some of which were infected.

RR was first detected in New York State in 1990. It took another 5 to 6 years before it was detected in counties bordering on Canada. The MNR created a buffer of vaccinated raccoons along the Canada-U.S. border (St. Lawrence Seaway and Niagara Peninsula) through a trap, vaccinate, and release (TVR) program, but RR appears to have crossed into Eastern Ontario where the buffer was weakest. Conversely, the TVR program continues and has so far been successful at preventing RR from entering the Regional Municipality of Niagara.

The arrival of RR in Ontario has prompted many local health units to re-examine their rabies control strategies to ensure they are doing everything reasonably possible to lessen the impact of this disease. To date, three cases have been detected in Eastern Ontario, none closer to Toronto than 300 km. The MNR has reacted aggressively to contain the outbreak and will launch an extensive raccoon vaccination program next season, air-dropping over 800,000 RR vaccine-impregnated baits in Eastern Ontario in an effort to prevent the strain from moving towards heavily populated Southwestern Ontario. However, there is no past experience with this control strategy in the raccoon population so its actual effectiveness is still to be determined. More information on MNR's raccoon rabies response programs can be located on their web site at www.mnr.gov.on.ca/MNR/rabies.

It is therefore difficult to predict the speed at which RR will move through Ontario and enter Toronto. It is even unclear whether the three cases represent the permanent establishment of RR in Ontario or whether RR has been contained by the Ministry's control program. Experience from New York State, where RR spread throughout the state in approximately five years, suggests that the strain moves slowly but relentlessly through the raccoon population. However, few if any control strategies were used in New York until RR had spread throughout the State.

Experience in New York State and the characteristics of Toronto's raccoon population suggest that the arrival of RR in Toronto will have a substantial impact on Toronto Public Health. As an example, 84 people in New York State received post-exposure rabies vaccination for suspected exposure to rabies in 1989. Following the arrival of RR in the early 1990's, this number increased to over 2,500 by 1994. During the same year, 2,747 animals tested positive for rabies, up from only 55 positives in 1989. Further, 88% of the 2,747 rabid animals in 1994 were infected with the RR strain of rabies.

(3) Prevention and Control Of Raccoon Rabies

Overview:

Since rabies is a fatal disease, the primary goal of public health agencies is first, to prevent human exposure to rabies by education (pet vaccination, living with wildlife responsibly, etc.) and by vaccinating wildlife through programs such as fox baiting. The second goal is to prevent the disease by anti-rabies treatment if exposure occurs. Approximately 140 people were successfully treated in Toronto in 1997, a typical year, after being bitten by potentially rabid animals. A rabies death usually occurs because a person does not recognize that they have been exposed to a potentially rabid animal and does not seek medical advice.

It is a provincial requirement under the Mandatory Programs and Services Guidelines, 1997 that each board of health develop and maintain a Raccoon Rabies Community Contingency Plan, among other mandatory requirements (Attachment No. 1). Toronto's existing Contingency Plan is being updated in consultation with the Ontario Ministry of Natural Resources and will be completed by the end of 1999.

Irrespective of the speed at which this strain spreads through the Ontario's raccoon population, Toronto Public Health should begin to take steps as soon as possible to prevent the establishment of RR in Toronto.

The wildlife strategy described above should be initiated now to ensure that Toronto residents begin to understand the potential health threats posed by raccoons and come to respect the unpredictable nature of all wildlife behaviour. Early implementation would avoid the intense public concern that would result if implementation begins after RR arrives in Toronto. It will also allow time to develop an appropriate communication plan and ensure that it can be tested and widely disseminated throughout Toronto and to neighbouring jurisdictions.

Beyond the components of an effective wildlife program are strategies focusing on rabies prevention and monitoring. Surveillance of both wildlife and pets that for data on rabies prevalence and its distribution in various species will contribute to current knowledge of this disease. As well, a wildlife rabies vaccination program will slow or prevent the establishment of the new strain in the raccoon population.

Agencies with Responsibility for Rabies Control in Ontario:

Specifically, expansion of the current rabies control program will require a number of different players, each of which has responsibility and expertise for different components of rabies control which the RR strategy will build on. These agencies include:

The Ontario Ministry of Natural Resources (MNR)

The Canadian Food Inspection Agency (CFIA)

Toronto Public Health and its Toronto Animal Services

The Ontario Ministry of Health

Local Veterinarians

Wildlife Rehabilitators (e.g. Toronto Wildlife Centre, Toronto Humane Society)

A description of each agency's roles and activities and is provided in Attachment No. 1. All of these agencies will need to work co-operatively to ensure that RR prevention remains a priority and that appropriate steps are initiated when they are necessary. The main elements of Toronto's contingency plan include public education and environmental changes, raccoon vaccination, disease surveillance in high risk locations, and a point control program if and when a rabid raccoon is found in Toronto. These elements are detailed below.

(a) Education

Public education outlined in Toronto Animal Services' wildlife strategy will form an integral part of RR prevention. Toronto Animal Services and Toronto Public Health must provide timely and appropriate information so that property owners are convinced to make the necessary changes that will reduce the interaction between raccoons and humans. Pet owners who do not take responsibility for the proper supervision and vaccination of their pets must begin to do so. By beginning now to educate the public on the link between raccoons and rabies we will build a level of respect for wildlife and its unpredictability. This will ensure that when RR is detected in Toronto, residents will have a better understanding of the health risks and will have already altered their behaviour to minimize contact with raccoons.

Owners and operators of high risk locations such as large truck terminals and truck drivers are an important audience for these increased educational efforts. They should be educated on the importance of the health risks associated with RR and understand the procedures that should be followed should a raccoon be discovered in a truck that has entered Toronto from the U.S. (or potentially, from sout-eastern Ontario).

(b) Vaccination of Raccoons

Another possible step in preventing RR from becoming established in Toronto is widespread vaccination of raccoons against RR. The MNR has advised against a widespread raccoon vaccination program in Toronto at this time, since there is no evidence that the disease is travelling towards Toronto. Since the average lifespan of urban raccoons is only two years, a vaccination program begun prematurely would use scarce resources with no health benefit. Nonetheless, given the unpredictability of the disease's spread, it is strongly recommended that the City begin now to conduct studies on the most appropriate method of raccoon vaccination, so that the most effective procedures can be put in place without delay when the time comes.

There are two methods of conducting raccoon vaccination: trap-vaccinate-release (TVR) and the distribution of vaccine-impregnated bait.

(i) Trap-Vaccinate-Release (TVR) Program

The former City of Toronto had a TVR program aimed at raccoons during the mid-1990's. In TVR program, trained trappers place humane traps in areas frequented by raccoons. The captured wildlife (skunks, raccoons, foxes) are injected with vaccine, ear tagged with a unique number, and released. This establishes a level of immunity in the wildlife population thereby slowing the virus's introduction or spread.

Should a TVR program be initiated in Toronto, trapping would be started in June when the young of the year are old enough to respond to the vaccine. The traps would be moved throughout the City during the trapping season, which extends to the end of October. Property owners would be asked for permission before trapping occurs on their property. Education campaigns would inform residents that trapping was ongoing in their neighbourhood.

Past experience has shown that TVR can result in 60% to 80% rabies immunity based on 10 raccoons per km2. Since, some areas of Toronto have much higher raccoon densities, heavily populated areas may require re-trapping during the same season. TVR programs (as with baiting programs, see below) must be conducted yearly to be successful in order to minimize new litters of young animals and to compensate for movement of wildlife into and out of Toronto.

An explanation of the resources and technical specifications needed to conduct a program of TVR in Toronto are outlined in Attachment No. 2.

There are advantages and challenges to running a TVR program in Toronto. One advantage is that essentially all animals that are captured become immune since the injectable vaccine is very effective. It is also easy to follow the population via the tags placed on immunized raccoons. There is no wasting of vaccine (e.g. from other animals eating a bait or it being washed into a stream) as there would be in oral baiting.

However, pets such as dogs and cats are also captured during the TVR program. It is possible that some pets could be injured if caught. A policy on captured pets will be needed prior to initiation of the TVR program. Traps can also be damaged and stolen during the program, decreasing the program's effectiveness and increasing its cost. TVR programs are also more complex to organize and run due to the specially skilled personnel that are needed.

(ii) Baiting Program

The MNR has successfully reduced the incidence of Arctic Fox rabies through a ten year baiting program. Millions of vaccine impregnated pieces of bait have been air dropped and hand distributed across Ontario leading to a large proportion of the fox population becoming immune to rabies. It is this reduction of the occurrence of rabies in the fox population that has led to the decrease in rabid pets seen in Ontario.

The MNR continues a yearly baiting program in ravines within Toronto using a vaccine comprised of a live attenuated strain of rabies. The bait has a tag on it identifying the product and a telephone number to call for information. Permission is sought if the bait is to be used on private property. This program has been very successful in urban areas with few, if any, incidences of human or pet exposure to the vaccine which should prompt the seeking of medical advice, something that is not required with the V-RG bait to be used for RR.

The technical details needed for a raccoon baiting program and the resources required are outlined in Attachment No. 3.

A baiting program has a number of advantages. Personnel with little training can be used to distribute bait. As with TVR, an education campaign would be important to ensure that the public is aware of this program. Permission will be sought to bait private property. Each bait can be identified with specific wording and a logo to ensure that people understand its purpose. Further proof of a baiting program's safety comes from the long running fox baiting program which the MNR runs every year in Toronto's green spaces.

There are a number of possible challenges with this type of program. The CFIA would require a protocol to permit Toronto Public Health to use the new vaccinia recombinant glycoprotein (VR-G) vaccine that is active against RR. This may not present a problem since the MNR supports the introduction of proactive RR control strategies including the use of VR-G baiting. The MNR could request the use of this product in Toronto and become our partner or assist us with the preparation of the protocol.

There is a small possibility that pets or small children could come into contact with the vaccine, which is in a plastic capsule in the middle of the bait. However, the VR-G vaccine has been tested on many species including cats and dogs and found to be safe. The vaccinia virus has been used extensively in human vaccines and its safety has been well documented. The CFIA has extensive data from the U.S. on the safety of VR-G.

A baiting program is quicker to complete but results in a lower immunity rate compared to TVR. Other than biological markers, there is no way of tracking whether raccoons eating the bait become immune to rabies. Research indicates that while 65% of the raccoons may eat the bait only 40% become immune since V-RG is not as effective as the injectable vaccine. It is very difficult with baiting to reach the level of immunity achieved by TVR. Although the cost of baiting is lower, so too is its effectiveness. Table 1 compares the costs (but not the cost effectiveness) of TVR and Baiting. The lowest rates of successful immunization when using baiting must be considered when comparing straight costs.

Table 1: Comparison of Potential Cost Estimates of Baiting (VR-G) and TVR as Mass Vaccination Programs



Component


TVR



Baiting with VR-G
Personnel 20 trappers at $15,000 for half a year salary and benefits = $300,000

Consultant Veterinarian = $5,000

5 students at $6,000 per summer = $30,000
Supplies, transportation Vaccine, syringes, clothing, rabies vaccine (if necessary) = $100,000 (approximately $5,000 per trapper) Bait at $2.10 per bait X 200 bait/km2 X 400 km2 in Toronto = $168,000

Clothing, Transportation etc. = $10,000

Administration $30,000 $20,000
Public Information $60,000 $60,000
Program Total $495,000 $288,000



The limited past experience of running a TVR program in a dense urban area like Toronto with its large population of raccoons makes cost estimation, such as in Table 1, difficult. Therefore, research should be undertaken on the relative merits and costs of these two programs. This will require $30,000 in one-time additional resources. A final decision on the most appropriate way to vaccinate the City's raccoons will be taken in close consultation with the MNR, which has extensive experience in this field.

(c) Surveillance

Surveillance of RR in Ontario is the responsibility of both the MNR and local public health units. Therefore, good communications between these organizations will be necessary to ensure awareness of the location of RR positive animals as they are detected. While there is good communication between Toronto Public Health and surrounding public health units, it may be helpful to establish a RR committee to maintain common elements of a RR prevention strategy. This should include the MNR and other partner agencies.

There are other improvements that could be made to Toronto Public Health's present rabies program to increase our surveillance against RR. Currently, sick animals are not sent for rabies testing unless there is a suspicion of human or pet interaction. This could be changed so that all sick raccoons are captured and sent for rabies testing. Research in New York State has shown that 60% of positive animals would not have been submitted without increased surveillance. While the CFIA (which currently tests potentially rabid animals) has only limited resources and historically has limited testing to animals where there has been a possible human or pet contact, additional testing of suspect animals in the course of an outbreak may be possible.

Once RR moves closer to Toronto, an active surveillance system will be necessary to ensure that RR is detected quickly. Areas where initial detection is likely, such as transportation hubs (truck depots and train marshalling yards), and green spaces that link Toronto to its neighbours should be targeted by trappers on an ongoing basis. Thirteen raccoons have already been captured near truck depots after riding into Toronto from U.S. destinations in the past 6 months and 2 avoided capture. None of the captured raccoons were rabid but this highlights a potential route of introduction for RR.

Currently RR remains far from Toronto (approximately 300 km) and MNR programs may slow its movement westward. As is the case for mass vaccination, MNR experts advise that it is premature to initiate active surveillance in 2000. However, as RR moves closer to Toronto in the coming year(s), this type of surveillance activity will become necessary and work must begin now to put in place the infrastructure for a surveillance system.

(d) Point Control Program

A point control program is an important component of the RR prevention strategy and is the responsibility of the MNR. They have created a program of depopulation and vaccination that they initiate when a case of RR is detected. In urben areas this involves capturing and euthanizing all raccoons within a 5 km radius of the index case and with TVR program for within an additional 5 km radius.

Although lead responsibility falls to MNR, there are ways in which the City can support the program. The large raccoon population in Toronto will increase the number of traps required during a point control program. Also, the MNR may be directing a number of point control programs concurrently, which would stretch their resources. It would be beneficial for Toronto Public Health to purchase some traps on an ongoing basis to be used in a control program. The goal should be to hold approximately half of the number of traps needed to initiate a control program. This represents 500 traps using the density suggested by the MNR. These traps need not be purchased all in one year, but rather 100 should be purchased annually to slowly build our reserve. The MNR will also need access to trappers in Toronto during a control program. As part of the RR Community Contingency Plan, Toronto Public Health should attempt to list a number of agencies or individuals that are available to trap raccoons as part of a control program.

(4) The Potential Costs of Raccoon Rabies

The cost of preventing RR must be considered in relation to the substantial costs of responding to RR once it becomes established in a geographic area. Experience from New York State and Eastern Ontario health units offers the best information on the potential impact of RR on the resources of Toronto Public Health.

There are a number of costs associated with the arrival of RR in a geographic area. They include increased expenditures for traditional rabies control activities, such as pet and wildlife vaccination programs; laboratory testing; animal control activities (including investigation of wildlife/human/pet interaction); public education preventive measures; and human rabies post-exposure vaccination.

(a) Post-Exposure Vaccinations (PEV)

In New York State, the greatest RR-related increase in expenditures was caused by the tremendous increase in potential human rabies exposures requiring post-exposure vaccinations (PEV). In the years prior to the arrival of RR, New York State used approximately 100 series of rabies vaccine a year. In 1994, when RR had spread to almost the entire state, 2,500 series were dispensed.

In Ontario, the Ministry of Health provides the vaccine and local public health units provide the infrastructure for its delivery to the public on a 50:50 cost-shared basis. This includes 24-hour availability of public health inspectors to handle calls regarding possible rabies exposure and the involvement of medical specialists when the appropriateness of administering PEV is uncertain. If a similar increase in PEV use occurs in Toronto, the number of rabies vaccine series issued would increase from 139 (the number issued in 1997) to over 3,400.

Responding to 25 times more calls for PEV would greatly increase the workload for Toronto Public Health inspectors and on-call staff as well as the small number of Public Health Physicians. It would, however, be unrealistic to consider increasing the staff in these areas by the same proportion. Instead, new policies and procedures for investigating possible rabies exposures will have to be designed to meet the greatly increased workload once RR arrives in Toronto. New resources will be needed in the short term to create these new policies and procedures, and in the long term to respond to the increased workload in this area. For 2000, $50,000 in new funding will be needed to investigate new approaches to the response to potential rabies exposure. As more experience dealing with RR in other Ontario health units occurs, Toronto Public Health will be in a better position to predict the increased workload that can be expected once RR moves closer.

(b) Responding to the Public

Experience from the Ottawa-Carleton Health Unit suggests that the most disruptive part of RR is the tremendous increase in calls from the public concerned over possible rabies exposure and the investigation by public health and animal services of human/raccoon and animal/raccoon interactions respectively. These costs are the responsibility of the local municipality and have the potential to disrupt the health unit's ability to continue with routine operations.

It is difficult to estimate the increase in the number of reported animal bites and interactions between pets and wildlife that will be reported to public health once RR is detected in or near Toronto. The number of animals tested for rabies is one surrogate that is followed in New York State at their central rabies laboratory. In 1989, they tested 3,202 animals for rabies and found 55 positive (all bats). Four years later in 1994, they tested 11,896 animals and found 2,747 positive for rabies of which 2,369 were raccoons. This represents a 3.7 times increase in testing and an incredible 50-fold increase in rabies positive animals.

The entire State may not be representative of the type of urban environment seen in Toronto. Winchester County, a bedroom community north of New York City, may be a better comparison. It has an area of 1121 km2 and a population of 874,000, with substantial green space. In 1990, they tested 69 animals and found no rabies. In 1998, they tested 793 animals (an 11-fold increase) and found 47 positive for rabies. Prior to RR arrival, one person handled all nuisance animal investigations and rabies investigations. Since its arrival, this workload has had to be split. The County's regional offices now handle all nuisance animal investigations and a new central group of 3 people now handles the investigation of possible rabies exposure.

These two examples reveal the possible implications for workload that can be expected once RR moves closer to Toronto (Ottawa's example is illustrative because no RR was actually detected in this region but their workload increased substantially). It is important to note that no control strategies such as baiting or TVR were in place or have been used in Winchester County. Without a doubt there will be a substantial increase in the number of public inquiries to Toronto Animal Services and Toronto Public Health once RR is detected. Planning for that eventuality should start within the next year to ensure that Toronto Public Health is ready to respond to the arrival of Raccoon Rabies.

(c) Animal Testing

The cost of animal testing is covered by the CFIA. Currently they do not charge for this service. This may change if the number of tests increases in a similar way to that seen in New York State. The cost of handling the animal before it is sent to the CFIA is the responsibility of Toronto Public Health. This includes the collection of the animal and investigation of the circumstances surrounding the exposure. In 1997, 126 animals were sent for testing by Toronto Public Health. Using the increase seen in New York, it would be expected that close to 500 animals will be tested once RR arrives. The Winchester County experience, perhaps more appropriate for comparison to Toronto, suggests that over 1,000 animals may need to be tested.

Table 2: Experience in New York Prior to and After Raccoon Rabies Arrival





Prior to RR Arrival (1989)



After RR Arrival (1994)
Confirmed Rabid Animals 55 2,747
Number of Animals Tested 3,202 11,896
Rabies Vaccine Series 100 2,500
Rabid Raccoons 0 2,369

All of this information reinforces the tremendous increase in workload that the arrival of RR will initiate within Toronto Public Health and its Animal Services. Increased resources will be required to respond to the concerns of the public and to complete investigations in a timely fashion so that the potential for human exposure and health risk can be adequately addressed.

Conclusions:

The wildlife strategy used effectively by the six former municipalities includes responses to nuisance concerns, injured/distressed/sick wildlife and public health and safety threats. Education includes information on environmental changes to reduce conflict, staying a safe distance from wild animals, and vaccination and supervision of family pets. Providing long-term solutions for residents experiencing conflict with wildlife, and information on wildlife to help alleviate fears and misperceptions are also important. A unified wildlife strategy across the new City of Toronto will deliver a consistent level of service and provision of information to the public.

While it is still too early to launch such strongly proactive initiatives as vaccinating Toronto's substantial raccoon population, it is important to use the coming months to prepare the City for the possible arrival of RR. By putting into place a wildlife strategy that emphasizes safe, respectful co-existence with wildlife, one that educates residents on proper pet supervision and requires rabies vaccination of all pets across Toronto, the likelihood of RR becoming established in Toronto can be reduced.

Experience in other jurisdictions has shown that increased resources for Toronto Public Health and its Animal Services division will be necessary both in the short term and in the long term. In the short term, resources are needed to begin planning and implementing the wildlife strategy. Two staff and administration costs will be needed at a cost of $120,000 annually. Increased funding is also needed to begin investigating changes in the dispensing of post-exposure rabies vaccine without a substantial increase in staff. This will require a further $50,000 for one-time expenses. Animal traps should be purchased so they are on hand when a point control program is initiated. One hundred traps will costs approximately $6,000 a year for approximately the next five years. Investigating the merits of various strategies to vaccinate raccoons and other prevention responses is also required, along with a comprehensive plan for implementation. This will require an additional one-time cost of $30,000. The measures taken at this time to prevent the arrival or reduce the spread of Raccoon Rabies appear to be the best first steps in protecting the City from this deadly disease.

Contact:

Dr. Monir Taha

AMOH and Director of Healthy Environments

Toronto Public Health

Phone: 416-392-7407

Fax: 416-392-0713

Eletta Purdy

Manager, Animal Services

Toronto Public Health

Phone: 416-394-8109

Fax: 416-394-8682

Dr. Sheela V. Basrur

Medical Officer of Health

List of Attachments:

Attachment No. 1 - Agencies with Responsibility for Rabies Control in Ontario

Attachment No. 2 - Trap-Vaccinate-Release (TVR) Program in Toronto

Attachment No. 3 - Baiting Program in Toronto

Attachment No. 1

Agencies with Responsibility for Rabies Control in Ontario

(1) The Ontario Ministry of Natural Resources is the lead agency charged with control of rabies in Ontario and:

(a) Conducts rabies research.

(b) Provides information on efficacy of vaccines used against raccoons.

(c) Conducted studies on raccoon densities in Toronto.

(d) Conducts an on-going yearly baiting program in the ravines and green spaces within Toronto using a vaccine effective against the Arctic Fox strain of rabies.

(e) Operates a TVR program in the Regional Municipality of Niagara between the Niagara River and the Welland Canal to prevent RR from moving across the international border.

(f) Dropped 50,000 baits containing vaccinia recombinant glycoprotein (VR-G) vaccine, a new product effective against the RR strain of rabies, in Eastern Ontario after the third case of RR was detected.

(g) Will be dropping over 800,000 VR-G baits next spring to the west of the three cases in an attempt to slow the movement of RR towards Toronto.

(h) Will conduct a point control program similar to the one used in Eastern Ontario when RR is first detected in Toronto. The MNR control program is described on their web site at www.mnr.gov.on.ca/MNR/rabies/rabconf.html and www.mnr.gov.on.ca/MNR/rabies/response2.html

(i) The Ministry of Health provides information on the human consequences of exposure to rabies and a clearinghouse of information from local public health units on different approaches to rabies control. They are responsible for drafting the Mandatory Health Programs and Services Guidelines for local public health units, which includes a requirement for health units to conduct rabies control programs within their jurisdiction. They also supply human rabies vaccine used after possible exposure to rabies.

(2) The Canadian Food Inspection Agency (CFIA) is responsible for testing possibly rabid animals. They regulate the use and sale of animal vaccines including those used in baits and conducts its own research on rabies. Should Toronto Public Health initiate a TVR or baiting program on its own or in cooperation with the MNR, CFIA has indicated that it will support our efforts.

(3) Toronto Public Health's activities are guided by the Mandatory Health Programs and Services Guidelines (December 1997) which indicate that Toronto Public Health must have a RR Community Contingency Plan, maintain rabies surveillance within the health unit, and provide rabies information on an ongoing basis. Toronto Public Health also responds to possible human rabies exposure and sends animals for testing. In 1997, 127 potentially rabid animals were sent for testing, all were negative. Toronto Public Health also provided rabies vaccine to 140 individuals who were potentially exposed to rabies. Toronto Animal Services is an integral part of Toronto Public Health. They respond to concerns from the public regarding nuisance animals and wildlife/pet conflicts. They assist property owners with information on ways of resolving wildlife conflicts and are responsible for implementing the wildlife strategy described in the first part of this report. Toronto Animal Services is also a key point of education for pet owners on the proper supervision of their pets.

(4) Local veterinarians, within the health unit are an important partner in rabies control. They are the professionals who have regular, on-going contact with pet owners and their pets. They provide education on the benefits of vaccination against rabies and must stress the importance of this vaccination to pet owners. They can provide promotional material to pet owners to help ensure high compliance with this aspect of pet ownership.

(5) Wildlife agencies that house, rehabilitate and care for animals also are involved in rabies control. This includes Toronto Wildlife Centre, Ontario Society of the Prevention of Cruelty to Animals and Toronto Humane Society. They can help educate people on the proper interaction between humans/pets/wildlife and immunize animals that are detained at their facilities against rabies.

Attachment No. 2

Trap-Vaccinate-Release (TVR) Program in Toronto

Approximately 400 km2 of the city would need to be trapped (assuming the remaining 232 km2 is unsuitable for either raccoon habitat or trapping). To accomplish the task in 20 weeks (June through October) would require 20 trappers working full time (approximately one cell per week). Starting earlier in the year would decrease the number of trappers required but young of the year may not respond to the vaccine. The MNR's past experience with initiating trapping earlier in the year found it much less effective and requires re-trapping to reach the intended vaccine coverage.

The MNR runs a TVR program in the Regional Municipality of Niagara covering 750 km2 with a budget of $180,000 per year. This pays for 7 trappers, supplies and vehicles. However, Niagara and the other areas that have been trapped by the MNR have raccoon densities far lower than seen in Toronto. Fewer trappers are needed and their cost makes up the bulk of the program meaning Toronto's program would require substantially more resources.

In 1993, the old City of Toronto drafted a TVR proposal for its Board of Health. They estimated a raccoon population of 1,000 to 2,000 and the program used a trap density of 50 to 75 per km2 to calculate needed resources. Their cost estimate was $50,000 per year or $486 per km2. However, information from the MNR suggests a higher trap density, 75 to 100 per km2, will be needed to ensure 60% to 70% vaccine coverage. The target raccoon population is also likely closer to 10,000 and the area to be covered has increased substantially. It would be reasonable to expect the cost to be at least $300,000 per year ($486 x 632 km2) plus the cost of education, which was not included in the original estimate.

The vaccine used in raccoons can only be sold to and used by a licensed veterinarian. However, the MNR has a protocol in place that makes the vaccine available to trappers in their Niagara TVR program without the direct supervision of a veterinarian. A veterinarian must still do training and logging of the vaccine, and consulting fees for this professional will have to be added to the cost of the program. Similar arrangements could be made with the cooperation of the Ontario Veterinary College, the CFIA and the MNR.

Attachment No. 3

Baiting Program in Toronto

Unfortunately, the fox rabies vaccine used for many years in Ontario has only limited effectiveness against RR necessitating the development of an entirely new vaccine. Only recently has this vaccine, vaccinia recombinant glycoprotein (VR-G), been widely available. It is an attenuated vaccinia vaccine used previously against small pox in humans (therefore with well known data on its effects in humans) that has been modified to carry one protein from the RR strain. There is no chance of rabies transmission with this product and it has been found to be very safe.

The VR-G bait is licensed in Canada through a special release program by the CFIA. Each use must be accompanied by a written protocol describing the baiting program. The MNR and Santé-Quebec have already used this vaccine in large baiting programs. Next spring the MNR plans to drop over 800,000 VR-G baits in Eastern Ontario to prevent the spread of RR westward. The CFIa has indicated that Toronto could use VR-G after submitting a protocol. The MNR may assist us in completing this protocol.

Toronto has an area of 632 km2. To immunize a proportion of the raccoon population (60% to 80%) comparable to a TVR program would require close to 200 baits/km2. The bait cost approximately $2.10/bait plus any costs associated with its distribution. To bait 400 km2 would require $168,000 of bait plus the cost of distribution. Using students for the summer at $6,000 per student adds $30,000. Additional costs for training and equipment must be added.

Appropriate clothing will be needed for moving through some of the heavily forested areas of Toronto when baiting these areas. Equipment to carry the bait will also be needed. A further $10,000 will be needed for these requirements. As with the program of TVR there will need to be a substantial public awareness campaign and permission will be needed to distribute bait on private property. This will add $60,000 per year.

As with TVR some areas with a high density of raccoons would require a number of passes raising the cost even further. If one quarter of the area required re-baiting at 60 baits/km2 another $15,000 of bait would be needed plus additional costs for distribution.

 

   
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