State Laws Related to Wildlife Control

SECTION TWO: STATE LAWS RELATED TO WILDLIFE CONTROL

Learning objectives for section two:

  1. Name three “rabies vector species” in New York, and the agency with the authority to decide what happens to a nuisance animal that’s a rabies vector species.
  2. List two legal control techniques that may be used on a federally protected bird without obtaining special depredation permits.
  3. Explain two options for dealing with a problem involving a game species.
  4. Identify the laws that regulate the management of dogs and feral cats in New York.
  5. In addition to your NWCO license, what other paper- work do you need to do your job?

Environmental Conservation Law (ECL)

Regulatory agency: DEC

Applicable to: all New Yorkers. The sections that are most relevant to NWCOs are 11-0103, 11-0524, 11-0521, 11-0523, 11-0511, 11-0513, 11-0525, 11-0505, 11-0507, 11-0917, 11-1105 and 11-1101

License required: The NWCO license is required for certain activities (such as transporting wildlife) and to handle protected species.

Read the law: Online- http://www.dec.ny.gov/regulations/40195.html

Note: The Environmental Conservation Law is reprinted at the end of this chapter.

Read the appropriate sections of Article 11, Titles 5, 9, 11 print—6 NYCRR Part 175 Article 11 Titles 5, 9, 11 To check the legal status of a wildlife species in New York.

The Environmental Conservation Law (ECL) is the primary state law that regulates the activities of NWCOs. (For your reference, the full text of the appropriate sections of the ECL are included at the end of this chapter.) On July 30, 2002 Governor Pataki signed a new law about nuisance wildlife control, ECL 11-0524, which gave the DEC the authority to set new regulations and license conditions.

Getting and keeping a nuisance wildlife control license: the overview

To get a NWCO license, you must complete the application, pass the exam, and pay the license fee. The New York State nuisance wildlife control license authorizes you to act as an agent for a property owner or lessee. (You must have a signed contract or written permission from that person stating that you have been hired to act as their agent to take nuisance wildlife on their property). You are allowed to take, temporarily possess, and transport any wildlife, except for those species detailed below, when that animal damages public or private property, or under conditions detailed in a permit issued by the DEC.

NWCOs in New York State shall NOT take, possess, or transport:

  • any species listed federally or in New York State as endangered or threatened, except bats found in occupied homes may be killed if necessary for health department ordered rabies testing;
  • any migratory birds (such as songbirds, waterfowl, birds of prey) without valid federal and state permits—with the few exceptions explained in the Migratory Bird Treaty Act section above;
  • any protected species unless it has caused damage or under conditions described in a DEC permit. Protected bats found in occupied homes may be killed if necessary for health department ordered rabies testing ;
  • any white-tailed deer, black bear, beaver, otter, muskrat, fisher, bobcat, mink, marten, and wild turkey, without a valid state permit.

You may take wildlife only by lawful means, and only in a lawful manner. NWCOs must also exercise due care to safeguard the public from any animal they capture, possess, or move to another location.

After you’ve captured the nuisance animal, you can then: 1) release it to the wild; 2) humanely kill it, then bury or cremate it; or 3) if the animal is distressed or injured, transfer it to a licensed wildlife rehabilitator. When appropriate, healthy wild animals may be released on site, or they may be relocated, if you have permission from the owner of the property on which you’d like to release that animal. This is true whether the preferred release site is public or private land. You may not release an animal into another county without prior approval from that county’s DEC Regional Wildlife Manager. Wildlife taken outside of New York State may not be brought into the state under this license.

If the animal appears to be diseased, it must be humanely killed and buried or cremated, or otherwise disposed of as directed by the DEC Regional Wildlife Manager or the local county health department.

NWCOs must follow the directives of their DEC permits and the local county health department concerning the handling and disposal of bats, raccoons, and skunks (rabies vector species), and any other directives about rabies.

Animals that are distressed or injured but are good candidates for rehabilitation, such as young that have been orphaned, may be transferred to a licensed wildlife rehabilitator. Bats, raccoons, and skunks may only be transferred to rehabbers who have special facilities and approval to accept these rabies vector species, unless the NWCO receives other guidance from the DEC or the Department of Health.

While you’re working as a NWCO, you are required to carry a copy of your license (showing all of the license conditions) with you, on your person. You must present this license on request. You must also keep track of all of your NWCO jobs each day, using the log supplied by the DEC. These records, and any animals in your possession, must be available for inspection by a DEC Environmental Conservation Officer at any reasonable time.

The NWCO license is good for one year. (It expires on the date listed on the front of the license). It’s issued to you, not to a company, so it cannot be transferred. The license may be renewed by sending a written request, your previous year’s log, and the renewal fee to the DEC’s Special Licenses Unit, 625 Broadway, Albany, NY 12233-4752, a month before your license expires (you can send the request any time during that month).

You must successfully complete any training program required by the DEC. For example, if you use firearms, you must pass the DEC hunter safety course. If you use any foothold trap or a body-gripping trap that has a jaw spread of 5” or larger, then you must pass the DEC trapper training course. Foothold and body-gripping traps must meet the requirements of ECL 11-1101 sub. 6.

All traps set for the taking of wildlife must be marked with the name and address of the NWCO or of that person’s business. Traps must be checked each calendar day, by the NWCO or the property owner or lessee who hired the NWCO. Animals must be removed from traps on the same calendar day when they were discovered in the trap, or within 12 hours of capture. After you’ve captured the nuisance animal, you can then: 1) release it to the wild; 2) humanely kill it, then bury or cremate it; or 3) if the animal is distressed or injured, transfer it to a licensed wildlife rehabilitator.

Whew! That’s a lot of information. Now, we’ll go over some of the points again, adding some details.

Which species can you handle?

In New York State, all wild animal species have legal classifications that are described in the Environmental Conservation Law. Their legal status determines several aspects of control efforts. Most commonly, the question is, can a NWCO “take” this species in this situation?

Legally, “take” applies to the pursuit, capture, or killing of wildlife. This covers shooting, trapping, netting, “and all lesser acts such as disturbing, harrying, or worrying.” It refers to any device commonly used to capture or kill that species. The taking must be by lawful means, and in a lawful manner. (See the definitions in ECL 11-0103 on page 3-28).

There are many wildlife species that a NWCO can legally handle in New York State, so it’s actually easier to focus on the ones you cannot handle or must obtain special permits to handle legally.

It’s not your job, definitely.

In New York State, you may not, handle endangered or threatened species. That includes species that are endangered or threatened only within New York State, and those that are in trouble on a national basis, too. The only exception is endangered or threatened bats that are found in homes may be removed using non-lethal methods.

The federal government maintains a list of federally threatened and endangered species. Each state tracks those species that are rare only within its borders. This means there are two lists you have to keep track of: the federal list, and the New York State list. Contact the NYS DEC to find out if there have been any updates to the lists. The DEC keeps current lists of NYS endangered and threatened species and fact sheets about many of these species on its website at: http://www.dec.ny.gov/animals/7494.html

Perhaps—just perhaps—in one of those rare situations that are about as likely to happen as winning it big in the lottery, you might receive a special DEC permit that would allow specific nonlethal controls for a state threatened or endangered species. Your chances of securing a permit for a species on the federal list are even slimmer. Again, the only exception is endangered or threatened bats that are found in homes may be removed using non-lethal methods without a permit.

Another no-no for NWCOs in New York: you cannot capture or kill a pigeon if it’s wearing a leg band.

It’s not your job, but….

Domestic animals, such as dogs and cats, are not covered by the Environmental Conservation Law because they’re not wildlife species. They’re regulated under NYS Agriculture and Markets regulations, Articles 26 and 7. Even if they’re feral and behave like wild animals, they are still considered domestic species. Although every town is legally required to have a dog control officer the same isn’t true for cats. In some areas, there may be inadequate services and customers may turn to you for help with feral cats, but there are thorny liability issues that make this a complicated and risky business. Some of these issues are addressed in Appendix C.

It is your job, but say hello to a new boss – the health department

Special care is given to the handling of mammals that are most likely to be carrying rabies. Known as “rabies vector species,” in New York State the ones to watch are bats, raccoons, and skunks.  Foxes and coyotes may also be rabid in some areas.

Before you respond to a call about these animals, call the local health authority. That’s either the county health department or the district office of the state health department.

You are required by law to follow the health department’s directions concerning the disposal of raccoons, skunks, and bats, no matter what the landowner requests. Of course, you still have to follow DEC regulations, too. You are also legally required to follow any of the health department’s other directions related to the control of rabies. If anyone disputes this, just show your NWCO license. It’s right there on the front page.

The New York State Sanitary Code, which is enforced by the state health department, explains how to handle these situations in detail (see section 3 in this chapter).

Special jobs require special permits

Federally-protected wildlife

In some circumstances, the landowners may receive permission to capture or otherwise harm a federally protected species. This is handled on a case-by-case basis. The landowners need special depredation permits from both the federal government and the state government. Federally protected wildlife include migratory birds and nationally endangered or threatened species, as described previously.

There are very few situations that justify the issuance of a special permit for an endangered or threatened species. You may not harm them in any way. You can’t harass them or disturb their habitats. Of course, you’re not likely to encounter them while on the job, either. The exception is federally protected bats that are found in human structures may be evicted using non-lethal methods. NWCO’s should use refer to the bat species section for guidance.

Chances are, you’ll only get calls about a few federally-protected species, most likely, Canada geese, woodpeckers, gulls, cormorants, and some birds of prey (usually hawks and owls). Most of them are protected by the Migratory Bird Treaty Act, but not by the Endangered Species Act, so you may have some more options.

Try a combination of nonlethal control methods first. This may solve the problem and will save you the hassle of the paperwork. Because you don’t need permits for most nonlethal control methods, you can probably deal with the situation right away, which may be appealing to your customer. Just remember that you can’t destroy eggs or disturb their young, or disturb a nest if there are eggs or young in it, because those actions are classified as “taking.”

One exception is Canada geese. If you only want to destroy goose nests or treat the eggs with corn oil (or puncturing) to prevent hatching, you only need to visit t the USFWS’s Resident Canada Goose Nest and Egg Registration Site to register online. You do not need any special authorization or permit from the DEC. Go to: http://epermits.fws.gov/eRCGR/

You may be able to persuade the birds to leave by hazing them with dogs or frightening them with devices such as noisemakers and scarecrows. Or alter the conditions that make the site attractive to them, for example, by removing unnatural food sources such as garbage. Exclude them from the site by erecting fences. If that approach doesn’t work, call the DEC regional wildlife office to discuss the situation and seek the proper permits.

One postscript: the management of mute swans has changed once again. DEC can authorize a NWCO to remove mute swans. Hazing of mute swans will not be authorized as it could lead to range expansion. No federal permits are needed.

Game species

State and federal agencies manage game species primarily by controlling hunting and trapping. Some game species, such as muskrat, beaver, white-tailed deer, turkey, and black bear may become a nuisance on private property. What should you do if you’re asked to take care of a problem with one of these species? Tell the landowner to call the regional DEC wildlife office. If appropriate, the DEC will issue a special state permit—to the landowner, not to the NWCO—that will allow certain control efforts. You can be hired to do that work, but the landowner must speak directly to the DEC. (You can explain the process, but they still have to talk to the DEC).

NWCOs may take bears on residential land if they’ve first proven to the DEC that the animal is damaging the property or threatening public health or safety. If persuaded, the DEC may issue a special permit. If the bear is killing or worrying livestock or destroying an apiary on cultivated land, the landowner (or you, as that person’s agent) may take the bear at any time. The landowner is then required to contact the DEC promptly, and to deliver the carcass to the DEC officer for disposal.

If the landowner doesn’t want to get the state permit, you may once again use nonlethal control techniques. If the problem happens during a legal season for that species, you could advise the landowners to invite hunters or trappers onto their land.

What’s left: first, the species any New Yorker can handle, without a permit

The remainder of New York’s wildlife are either classified as “protected species” or “unprotected species.” That distinction won’t tell you which species you can handle and which you can’t, but it’s important to understand because the public has certain rights to take nuisance animals, mostly limited to the taking of unprotected species.

All New York State residents can take a member of an unprotected species, and of a few specified protected species, that’s on their own property when the wildlife becomes destructive to public or private property.

Nuisance animals of unprotected species may be taken at any time of the year and by any means provided that other laws are not violated (such as pesticide regulations, firearm discharge ordinances, or trespassing laws).

There’s one important difference that applies to the public: even without a permit, they may capture nuisance animals of the species listed in sections 11-0523 (see below), but cannot release them. Private citizens must humanely kill a trapped nuisance animal, and bury or cremate it; or release the animal alive on their property (e.g., bat exclusion). Your NWCO license gives you the additional option of transporting and releasing animals, with the permission of the owner of the release site.

With a NWCO license, you can do:

ECL 11-0523 gives any New York State resident the right to capture:

UNPROTECTED SPECIES, including

Mammals:

woodchuck, porcupine, eastern chipmunk, red squirrel, flying squirrels, moles, voles, shrews, bats (except the Indiana bat, northern long-eared bat,  and the eastern small footed bat), and rats (except the Allegheny woodrat). Note: protected status for the northern long-eared bats is currently proposed and is being considered for little brown bats and tri-colored bats. Check the DEC web site for updates on this rapidly changing situation.

Birds:

house sparrow, European starling, pigeon (without leg band).

And in CERTAIN SITUATIONS, some protected species including:

Mammals:

bears (damaging livestock or apiaries); skunks; raccoons; coyotes; foxes; black, gray, and fox squirrels; opossums; weasels; varying hares, cottontail rabbits, and European hares.

Birds:

red-winged blackbirds, crows, common grackles, and cowbirds (damaging crops in June through October).

BUT THEN WHAT?

This section of law does NOT give a private citizen the right to translocate any of these animals off of their property.  A private citizen must either hire a NWCO for that service, or kill the nuisance animal, and bury or cremate it.  Trapped animals may also be released alive on the landowner’s property.

With a NWCO license, you can do more

You can handle any of the species listed in ECL sections 11-0521 and 11-0523 with your NWCO license (see the following lists).

For a NWCO, the critical parts of the ECL are sections 11-0524 (nuisance wildlife control operators), 1-0103 (definitions), 11-0521 (what you’re allowed to take with the NWCO license), 11-0523 (what you’re allowed to take without the license—this section applies to the public, too), 11-0507 (liberation of wildlife), 11-0511 and 11-0917 (transportation of wildlife), 11-0513 (protection of homing pigeons), 11-0525 (control of rabies in wildlife). These sections are included at the end of this chapter. Important note: Existing laws sometimes change and new laws are adopted, so you should always refer to the most recent version of the conservation law.

To do your work, you also need the landowners’ written permission and must be on their property. If control activities would be more effective on neighboring land, you’d need to secure written permission from that landowner. And if you want to release an animal onto someone else’s land, you must have their permission.

One other “protected” species

As a NWCO, you are also required to act in a reasonable way that will protect the public from attack by the animals you’re handling (under Article 26, section 370 of the NYS Agriculture and Markets Law). And you must not allow any physical contact between venomous snakes and the public. Here’s the actual text of that law, excerpted from the Agriculture and Market regulations, Article 26 (Cruelty to Animals):

  1. Protection of the public from attack by wild animals and reptiles.

Any person owning, possessing or harboring a wild animal or reptile capable of inflicting bodily harm upon a human being, who shall fail to exercise due care in safeguarding the public from attack by such wild animal or reptile, is guilty of a misdemeanor, punishable by imprisonment for not more than one year, or by a fine of not more than five hundred dollars, or by both. “Wild animal” within the meaning of this section, shall not include a dog or cat or other domestic animal. Previous attacks upon a human being by such wild animal or reptile, or knowledge of the vicious propensities of such wild animal or reptile, on the part of the possessor or harborer thereof, shall not be required to be proven by the people upon a prosecution hereunder; and neither the fact that such wild animal or reptile has not previously attacked a human being, nor lack of knowledge of the vicious propensities of such wild animal or reptile on the part of the owner, possessor or harborer thereof shall constitute a defense to a prosecution hereunder.”

Which species can licensed NWCOs handle or take in NY—and when?

CAN DO! (Categories 1–4)

  1. I. Anytime without additional permits

Mammals:

  • bats (except Indiana bat, northern long-eared bat, and the eastern small-footed bat). Protected status for northern long-eared bats, little brown bats, and tri-colored bats is being considered. Check the DEC website for updates.
  • chipmunks
  • flying squirrels and red squirrels
  • mice
  • moles
  • porcupine
  • rats (except Allegheny woodrat)
  • shrews
  • voles
  • woodchuck

Birds:

  • common pigeon (unless it’s banded)
  • house (a.k.a. English) sparrow
  • European starling

2: When the animal has damaged property, can take any animal from category 1, plus—

Mammals:

without any additional permits

  • cottontail rabbit
  • coyote
  • muskrat
  • red and gray foxes
  • snowshoe (a.k.a. varying) hare
  • opossum
  • striped skunk
  • squirrels: black, gray, and fox squirrels
  • weasels

 

with a DEC permit
(obtained by landowner)—

  • beaver
  • black bear
  • bobcat
  • deer
  • Eurasian boar (free roaming)
  • fisher
  • European hare
  • marten (a.k.a. pine marten)
  • otter

Reptiles (with DEC permit obtained by landowner)

  • turtles: except mud, bog, Blanding’s and sea turtles.
  • snakes: except queen snake, timber rattlesnake and massasauga

Birds (with USFWS and DEC permits obtained by landowner)

  • Crow (no permits needed)
  • Turkey (just need DEC permit)
  • Canada goose
  • Cormorants
  • Ducks
  • Great blue herons
  • Snow goose
  • Sparrows (other than house sparrow)
  • Swans (Mute swans with DEC permit)
  • Waterfowl
  • Woodpeckers
  • Migratory birds fall into this category

3: When it’s simply a nuisance—

The DEC may issue a permit, but this is less likely. If you need permit(s) to take an animal when it’s damaged property, you need the same permits to take it if it’s just a nuisance.

Even if they are just a nuisance, you’d need a DEC permit to take:

  • cottontail rabbits
  • coyotes
  • red and gray foxes
  • European and snowshoe (a.k.a. varying) hares
  • muskrats
  • opossums
  • raccoons
  • squirrels: black, gray, and fox squirrels
  • weasels

Exceptions:

  • striped skunks, no permit required
  • crows, if causing nuisance on cultivated land, no permit required

4: Special cases—

Mammals:

  • black bear: if destroying livestock or apiary, no permit needed

Birds:

If they’re destroying crops from June through October, you can also take these three species without permits: cowbirds, grackles, and red-winged blackbirds.

When an animal threatens public health or welfare:

The DEC can issue a permit to anyone to take any wildlife (except federally endangered and threatened species) in this case.

NO WAY, NO HOW:

  • take endangered and threatened species (Perhaps, in a rare situation, you’d secure the USFWS and DEC permits that would allow you to handle—but not take—such species. But during normal working NWCO life? No). The only exception is protected bats found in occupied homes may be killed if necessary for health department ordered rabies testing
  • take Antwerp or homing pigeons that are wearing leg bands (Specified in New York State law, ECL 11-0513).
  • take cats and dogs, whether they’re feral or domestic (There be drag The NWCO license covers wildlife, not domestic animals, such as cats and dogs. They’re covered by NYS Ag. & Market laws. This is risky territory. As a NWCO, steer clear).

Which species can licensed NWCOs handle in NY-and when?

Animal Anytime It’s just a nuisance It damaged property In specific defined circumstances
Mammals that more commonly cause nuisances:
Bats (except Indiana bat, northern long-eared bat and eastern small-footed bat (little brown bat, and tri-colored bat may also be protected soon) Contact DEC Contact DEC Contact DEC N/A
Beaver No Permit A Permit A Permit A
Black Bear No Permit A Permit A If destroying livestock or apiary, no permit needed
Chipmunk Yes Yes Yes N/A
Coyote No Permit A Yes N/A
Deer (white-tailed) No Permit A Permit A Permit A
Eurasian boar (free roaming) No Permit A Permit A N/A
Foxes (red and gray) No Permit A Yes N/A
Mice Yes Yes Yes N/A
Moles Yes Yes Yes N/A
Muskrat No Permit A Yes N/A
Rabbit (cottontail) No Permit A Yes N/A
Raccoon No Permit A Yes N/A
Rats (except Allegheny woodrat) Yes Yes Yes N/A
Shrews Yes Yes Yes N/A
Skunk (striped) No Yes Yes N/A
Squirrels (flying and red) Yes Yes Yes N/A
Squirrels (gray, black, fox) No Permit A Yes N/A
Voles Yes Yes Yes N/A
Woodchuck Yes Yes Yes N/A
Mammals that may cause nuisances N/A
Bobcat No Permit A Permit A N/A
Fisher No Permit A Permit A N/A
European hare No Permit A Permit A N/A
Snowshoe (a.k.a. varying) hare No Permit A Yes N/A
Marten (a.k.a. pine marten) No Permit A Permit A N/A
Mink No Permit A Permit A N/A
Opossum No Permit A Permit A N/A
Otter (river otter) No Permit A Permit A N/A
Porcupine Yes Yes Yes N/A
Weasels No Permit A Yes N/A
“Permit A” means: Unless specifically listed and allowed on your NWCO license, you would need an additional permit from the DEC to handle this species (or group of species) under this situation. “Permit B” means: Only with US FWS and DEC permits

“Permit C” means: PERHAPS with US FWS and DEC permits (for handling, not taking, of these rare species)

 

Animal Anytime It’s just a nuisance It damaged property In specific defined circumstances
Reptiles:

Snakes (except queen snake, timber rattlesnake, massaasuga)

No Permit A Permit A N/A
Turtles (except mud, bog, Blanding’s, and sea turtles. No Permit A Permit A N/A
Birds:
Canada goose No Permit B Permit B Permit B
Red-winged blackbird No No Special case >>>>>> Yes, when destroying crops from June-October
Cowbird No No Special case >>>>>> Yes, when destroying crops from June-October
Crow No Yes, if on cultivated fields Yes N/A
Ducks No Permit B Permit B Permit B
English sparrow (house sparrow) Yes Yes Yes N/A
Grackle No No Special case >>>>>>>> Yes, when destroying crops from June-October
Pigeon (not wearing leg bands) Yes Yes Yes N/A
Europeans starling Yes Yes Yes N/A
Mute Swan No Permit A Permit A Permit A
Turkey No Permit A Permit A N/A
Migratory birds, in general (such as song birds, birds of prey, waterfowl, and woodpeckers) No Permit B Permit B Permit B
No Way, NO HOW:
Cats and Dogs (feral or domestic) No No No No
Pigeons wearing leg bands No No No No
Endangered or threatened spp. No No No Permit C
Indiana bat, northern long-eared bat and eastern small-footed bat (little brown bat, and tri-colored bat are proposed for protection) No No No Permit C
Allegheny woodrat No No No Permit C
Queen snake, massasauga, timber rattlesnake No No No Permit C
“Permit A” means: Unless specifically listed and allowed on your NWCO license, you would need an additional permit from the DEC to handle this species (or group of species) under this situation. “Permit B” means: Only with US FWS and DEC permits

“Permit C” means: PERHAPS with US FWS and DEC permits (for handling, not taking, of these rare species)

Higher, deeper, further… (activities to explore other perspectives about this topic)

  • Find out how your town manages stray dogs and cats. What are the policies of the nearest animal shelter? How might those policies affect your business?
  • Read the Environmental Conservation Law and the NYS Sanitary Code (included at the end of this chapter).

Summary

Before you answer the review questions, you may wish to think about the learning objectives for this section:

  1. Name three “rabies vector species” in New York, and the agency with the authority to decide what happens to a nuisance animal that’s a rabies vector species.
  2. List two legal control techniques that may be used on a federally-protected bird without obtaining the special depredation permits.
  3. Explain two options for dealing with a problem involving a game species.
  4. Identify the laws that regulate the management of dogs and feral cats in New York.
  5. In addition to your NWCO license, what other paper work do you need to do your job?

Review questions:

  1. 1. Which of the following wildlife are considered “rabies vector species” in New York State? (Check all that apply)

               Bats

               Cats

               Foxes

               Raccoons

               Dogs

               Pigeons

               Skunks

               Rabbits

  1. Deer have destroyed your customer’s newly planted and expensive landscaping and he’s fed up. What advice can you offer over the phone?
  2. Since it’s deer season, he can invite hunters onto his property and that may solve the problem for free
  3. Offer to secure the special permit from the DEC that will allow you to deal with the deer
  4. Tell him to call the regional DEC wildlife office to request a permit; then you can help
  5. More than one answer is correct
  6. The New York State laws that regulate the control of dogs and cats are
  7. Environmental Conservation Law
  8. Agriculture & Markets Regulations, articles 7 and 26
  9. New York State Humane Activities Code
  10. Domestic Animals Act of New York State, article 6
  11. Before you can begin work, you need
  12. the landowner’s written permission
  13. approval from all of the neighbors
  14. to check in with the local animal control officer
  15. coffee, and lots of
  16. Restaurant owners want you to deal with the gulls that are feeding at the dumpster and annoying the customers, but they don’t want to wait. You suggest
  17. Read Johnathan Livingston Seagull, take a yoga class, and chill
  18. Even without the necessary permits, you can try to frighten them away by hazing them with dogs or using noisemakers
  19. Better trash management will make the site less attractive to the gulls. They should empty and clean the dumpster more
  20. You can show up tomorrow to capture the bir Is that OK?
  21. b & c
  22. c & d

Answers:

1—bats, raccoons, skunks, and foxes

2—d (answers “a” and “c” are correct)

3—b

4—a

5—e