Commission adopts tighter wildlife-rehabilitation rules after debate, reduces apprenticeship to 600 hours

After extended discussion and public testimony, the Texas Parks and Wildlife Commission on May 28 adopted a revised set of rules governing wildlife rehabilitation in Texas and amended one key element: the proposed 800-hour apprenticeship requirement was reduced to 600 hours before a sub-permittee may qualify to become a primary rehabilitator.

Richard Heilbrun, deputy director of the wildlife division, said staff developed the proposal with input from rehabilitators and the wildlife-rehab council and that the package is intended to raise minimum practical standards for new permittees. "Today a new applicant can become a wildlife rehabilitator by watching a two-hour video on YouTube and taking a ten-question exam," Heilbrun said, arguing the current pathway can produce clinically unprepared permittees and that stronger mentorship and experience requirements will improve outcomes.

Key elements adopted include:

- A supervised apprenticeship pathway for new rehabilitators (commission amended staff’s original 800-hour proposal to 600 hours);
- A more comprehensive examination for permit applicants and a lowered pass-threshold in staff’s testing design (staff framed technical changes to score requirements during the briefing);
- A requirement that permittees document a willing veterinarian who will consult as needed;
- Changes to the sub-permittee/satellite structure (numerical caps tied to permit type, with the largest clinics eligible for expanded capacity), and grandfathering of existing authorizations until permit renewal;
- Reporting frequency changed from quarterly to annual for most permit activities;
- Annual continuing-education expectations increased (staff proposed eight hours annually);
- Clarified restrictions on moving nonreleasable ambassador animals off-site and a restraint requirement for public handling, with an exemption for free-flight bird demonstrations.

Heilbrun said the department received about 1,403 comments on the proposal (a large majority disagreed) and that staff modified elements in response to public feedback — increasing permitted sub/satellite counts for some experienced permit types, clarifying that the apprenticeship can span more than two years, and proposing an implementation date of Sept. 1, 2027 to allow a transition period. Staff also said existing permittees would be grandfathered until their next renewal cycle.

Opponents warned the rule package would make it harder for small centers to form and could reduce statewide rehab capacity. Speaker Jenna Ross, who identified herself as a cofounder of a wildlife rescue, said she is "against the proposal" and warned the new classes of permits and the numerical caps on satellites would prevent small centers from getting started. Several other individual rehabilitators described heavy reliance on satellite operations and expressed concern that the new tiers would be difficult to implement locally.

Supporters, including several large-center leaders and long‑time rehabilitators, urged stronger standards, citing animal health, disease risk and the need for veterinary oversight. Jules Maron, executive director of a large rehabilitation center, said stronger standards would help professionalize the field and improve animal outcomes.

Chairman Paul Foster proposed, and the commission adopted, an amendment reducing the apprenticeship requirement to 600 hours (discussed as roughly one Saturday per week for two-plus years) and then approved the revised package by voice vote. Staff said the rules would take effect Sept. 1, 2027, with existing permit allowances retained until each permit holder’s next renewal.

The commission asked staff to return with clarifying language and additional outreach materials to ensure the rehab community understands the apprenticeship timeline, the distinction between volunteers, sub-permittees and primary permittees, and the transition schedule.