National Guidelines for State Nuisance Wildlife Control Operator Programs

Preface: 

An effective NWCO program must be able to balance a number of competing concerns. We believe that all concerns must be addressed from a biological standpoint with public opinion taken as an important but secondary consideration. We believe that if there is good reasoning behind a policy, which is explainable, it will be accepted by the public. There will always be extreme groups with concerns that will never be fully satisfied. We suggest that the agency’s time should be spent on issues that solve problems and benefit the program. It must be kept in mind that the Wildlife agency’s main responsibility is managing the resource and not managing business.  With these thoughts in mind we make the following recommendations 

An effective oversight program should: 

1.   Derive valuable wildlife data from participants in the program.

2.   Require reasonable standards of competency before damage control permits are issued.

3.   Require operators to balance concerns for animal welfare, effectiveness, cost efficiency and public safety. 

Issuing of permits: 

Knowledge Tests are the easiest and most effective way of assuring the State has reviewed applicants’ minimum knowledge level.  The test should include and test for knowledge in Safe Capture, Natural History of Common Problem Animals, Health Considerations, Local and Federal Laws, Handling and Disposition of Animals.

Testing should be available throughout the year on a quarterly basis as a minimum.  It is recommended that it be administered on an as needed basis by local offices within the Department, i.e. District Biologist Office.  The number of applicants will be few after the initial testing.  Testing would not be repeated annually as a condition for a permit.  A four-year period is recommended with Continuing Education Credits encouraged to replace subsequent testing.

The Agency could provide training classes or award credits for attending outside agency programs sponsored by groups or individuals pertaining to wildlife, i.e. require 8 CE credits per four year period.  Trade association training, College classes or Agency meetings could be awarded credits based on class outline and state would allow using attendance to these classes for credit, i.e. Trappers Education could be worth 3 credits and WCT Training Seminar be worth 4 credits and a class by Safe Capture Inc be worth 2 credits, if an operator attended these he could met the requirement of 8 CE credits and not be required to retest after 4 years.  Training accreditation is a service offered by NWCOA and the State agency would only have to make the requirement that training be accredited by NWCOA and not have to be involved in evaluating classes for training values.

Types of Permits 

Individuals or groups that require regulation fall into four categories, and different permit rules could be required for each.  These groups are identified with considerations as follows:

Property Owner:  An individual or business with an animal damage compliant on their property or property they manage.  They need a means to resolve damage causing situations immediately, i.e. Predators killing livestock or Raccoons in a dwelling.  Laws or Rules should be established to allow the taking of an animal causing or about to cause damage, without delay by a property owner or tenant.    A reporting requirement can be applied that requires the person or persons to report the compliant and resolution within 24 hrs after the initial compliant.

Property Owner Assistant.  Someone who might assist a property owner on a one time non commercial basis, i.e. Raccoons in the corn crib, Fox killing chickens, Raccoons in the attic and a Property Owner ask a fur trapping friend for help.  A temporary permit could be issued with specific location, time and disposition instructions.  A simple application form could be approved at the same office that administers testing.  A person could be limited on the number of permits, i.e. two within a twelve-month period.   If a person chooses to assist more property owners or on a more routine basis then a commercial permit would be required.

Commercial Permit.  Any individual or group that provides services on a regular basis with or without fee would require a commercial permit.  These groups would include Businesses, Animal Shelters and Government Agencies other than issuing agency.   This group of permit holders should be held to higher standards and meet minimum qualifications such as, requiring a formal permit application be submitted and knowledge verification through testing, documentation of activities and access for review by department through out the permit period, and submitting a summary report at least annually.  Permits should be issued to an individual and this individual be held responsible for all activities conducted by authority of their permit.  Each individual that will perform activities under a permit will be listed on the permit.  The listing process should be simple and easy to update or change, i.e. permit holder counter sign permit carried by helper and notify the department of names added or deleted from permit.  The permit should list any animal that is not to be controlled or taken by this permit.  Do not list an animal unless there are overwhelming reasons that an operator should not be involved with the damage management of the animal.  If an animal is listed the special permits discussed below should address it.

Special Permits.  Issued for situations that would require department personnel to be involved in resolving damage complaints that might normally be excluded from another permit.  Administered similar to a temporary permit except that it would be used to grant permission to a person to handle or resolve a damage situation involving an animal of special concern, i.e. a state endangered or threatened species, also animals such as Bear, Deer, Elk, Lion that would normally been handled by department personnel.  These animals or cases usually require special training or equipment.  Issued by specific individuals in the department for specific situations.  It is generally better to list the animals that the regular permit does not allow control of than it is to list what is allowed.  It is rarely justified to preclude a commercial operator from managing any animal causing damage but is justifiable to require specialized training or skills for some situations.   Special Permit systems allow you to use wildlife control operators to the fullest potential and protect special concerns.

Alternative to Formal Permits for states without an established permit system:

 As a minimum, permits should be issued for any damage activity if only to monitor trends in wildlife damage complaints.  If your state is one without any form of permit than a non- restrictive registration of persons conducting damage control activities might be the place to start.

Provide a simple form and request information about the operator.  Supply the operator with a data form to record information pertaining to the damage activities.  It should include Location, Species, Number of Animals and Disposition. 

Normally states without a formal permit system have damage complaints caused by animals that have open seasons or no seasons at all.  This allows for the taking of offending animals without the need for any special authority.  It poses problems in requiring permission to conduct activities that are already authorized or allowed by law.  This should not stop you from taking advantage of a great data collection tool.

Logic of rules or laws 

          Generally it is better to avoid restrictive rules relating to methods, equipment or disposition that are not based on wildlife damage management principles.   Objections to less restrictive rules come from the thought that no wildlife should be killed and that non-target animals might be harmed or captured.  Commercial nuisance wildlife control should be regulated to allow flexibility to the operator, hold the operator responsible for their actions and provide an effective control tool for the state agency.  Fur trapping and commercial nuisance wildlife controls are similar but very different activities, which need separate regulation.  The greatest difference lays were fur trapping is the regulated harvest of specific species during a predetermined season to harvest surplus animals and wildlife damage management is year round control of individual animals of both game and non-game species.  The goal of wildlife damage management is to manage wildlife damage and not to regulate harvest.  Wildlife damage management involves a lot more than trapping.  Minor restrictions to Fur trapping methods or equipment might have a minor effect on the overall harvest but have a very harmful effect to conflict resolution and the goals of damage management.   Tools and methods are employed in a restricted environment and mostly on private property.  With property owners involvement there is little reason to restrict or limit any tool or method. 

Included are Policy Statements on Relocation and Euthanasia that can be helpful in drafting rules in these areas.

NWCOA Translocation/Relocation Policy

"It is the opinion of NWCOA that translocation of wildlife should be avoided, especially under the following circumstances:

1-When translocated wildlife may likely cause damage at a new site.

2-When translocated wildlife may spread disease to new wildlife populations, or may carry disease that threatens human populations.

3-When wildlife species are overabundant in the area of translocation.

4-When weather, habitat conditions, or the condition of the animal render translocation inhumane.

In general, alternative methods (harassment, distress tapes, etc.) should be considered first to discourage destructive behavior.  NWCOs should seek continuing education to remain informed about legitimate, proven alternatives to prevent the need for translocation. When animals are causing damage to the point of necessitating capture, they should not be released into new locations unless it is highly probable the animal will not cause "the same problem in a new area."  Captured animals should be:

1- removed from the population humanely, or

2- released on site after modifications have been made to prevent further damage, or

3- used in a legal, humane captive manner (such use might include wildlife rehabilitation training animal, veterinary medicine training animal, or similar legitimate, legal research or educational purposes).

For the purposes of this policy Translocation and or Relocation means any removal from the site of capture and moving to another site for release.”

End of statement

PROGRAM SERVICE ASSISTANCE OFFERED BY NWCOA

1.  Formulate test questions that can be used for random testing.

2.  Program administration.

3.  Training Outlines.

4.  Conduct training in cooperation with local groups, associations, and agencies.

5.  Evaluate and accredit training for continuing education programs.

6.  Complete regulation drafting.

7.  Proctor tests, grade, score and keep records on the same.

8.  Administrate continuing education programs.

All services are on a contractual basis and can be tailored to the individual states needs.  Most programs can be self-supporting financially and or actually reduce the cost to the state or current program administration.

End of Statement