Appeal under s. 38 of the Provincial Animal Welfare Services Act, 2019, S.O. 2019, c. 13.
Between:
Cassandra Keuhl
Appellant
and
Chief Animal Welfare Inspector
Respondent
DECISION AND ORDER
ADJUDICATOR: Susan Clarke, Vice-Chair
For the Appellant: Soumya Sanyal, Counsel
Cassandra Keuhl, Appellant
For the Respondent: Adrien Iafrate, Counsel
Scott Brown, Regional Supervisor, Animal Welfare Services
Heard by Videoconference: January 21, 2026
OVERVIEW
1Cassandra Keuhl (Appellant) appeals to the Animal Care Review Board (Board) a Statement of Account (SOA) issued by the Chief Animal Welfare Inspector (CAWI, Respondent) for the boarding and related care expenses of her 29 domestic and exotic animals following their removal from her property in November 2025.
2The SOA is in the amount of $34,926.76, and was issued on December 12, 2025, pursuant to s. 35 of the Provincial Animal Welfare Services Act, 2019, S.O. 2019, c. 13 (PAWS Act).
3Pursuant to s. 9.1(1)(c) of the SPPA, this hearing was held immediately after the hearing of two other appeals and an application involving similar matters and the same parties (17986, 17988, and 18119/ACRB). In addition to the evidence filed in this hearing, the parties agreed that I could rely on the evidence filed in the hearing of the other appeals and application for this appeal, over which I presided.
4The Appellant asks for the SOA to be varied or revoked. She argues that the costs are excessive and that they reflect items that were not necessary and not provided at a reasonable cost.
5The Respondent seeks to have the SOA confirmed and argues that it reflects actual and reasonable costs incurred in the care of the animals and that the costs are recoverable under s. 35 of the PAWS Act. The only exception is a duplicate charge of $60.20, which it asks the Board to deduct from the total.
ISSUE IN DISPUTE
6The issue in dispute is whether the SOA should be confirmed, revoked or varied.
RESULT
7For the reasons that follow, I vary the SOA to $31,435.99. I find that the expenses related to costs of providing care to the animals that were removed were, for the most part, reasonable in the circumstances. However, I exercise my discretion pursuant to s. 38(9)3.1 of the PAWS Act to vary the amount based on some minor expenses which are either excessive or do not relate to recoverable costs described in s. 35(2) of the PAWS Act. The varied amount also reflects the duplicative charge identified by the Respondent.
ANALYSIS
8Section 35(1) of the PAWS Act states that the CAWI may, from time to time, serve on the owner/custodian of an animal a statement of account respecting any costs incurred in relation to an animal if the costs were incurred in relation to any of the following:
An inspector has taken steps to relieve the animal’s distress, by providing it with necessaries;
An inspector has removed the animal under s.31(1) or (2); or
The CAWI has kept the animal in its care or taken the animal into its care.
9Section 35(2) of the PAWS Act identifies the costs that may be included in a SOA, which include:
Costs incurred to relieve the animal’s distress;
Costs incurred in removing the animal or taking it into care;
Costs of providing care for an animal that has been removed;
Costs of providing care for an animal that the CAWI has kept or taken into care;
Costs of taking any prescribed action in relation to the animal.
10While the burden of proof on this appeal is on the Appellant to show that the SOA should be revoked or varied, the Respondent has an initial evidentiary burden to prove, on a balance of probabilities, that the SOA reflects the actual costs of necessaries and that these costs are reasonable.
11To that end, Inspector Pryer and Dr. Delnatte testified for the Respondent. Based on the parties’ consent to rely on the evidence filed in the hearing of 17986, 17988, and 18119/ACRB, I considered the evidence submitted in that hearing, which included the events that led to AWS’ removal of the Appellant’s animals, how the need for boarding care arose, and the medical distress of the animals.
12The animals were removed from the Appellant’s residence on November 5, 2025, because they were found to be in distress. The CAWI issued a Decision to Keep the Animals in Care (DTK) on December 18, 2025, because some of the animals were still being medically treated for distress, and because the CAWI believed that to return the animals to the Appellant would place them in distress because the environmental conditions identified in the Notice of Removal had not been addressed. The SOA reflects charges for services provided to the animals for the period before the DTK was issued.
13The SOA was issued on December 12, 2025, in the amount of $34,926.76, and included six invoices reflecting the costs of removing and boarding, and other related costs for the 29 animals. In finding that the costs of care for transportation, boarding and medical services were actually incurred, I relied on the invoices filed into evidence by the Respondent, as well as on the evidence of Inspector Pryer and Dr. Delnatte. The invoices are summarized in Table 1 (Appendix A).
Transportation Expenses
14I vary the transportation costs for the reasons that follow.
15I find that the transportation costs for removing the animals by Little Rays, to its own facility, including staff costs and mileage, are reasonable.
16I do not find that the transportation costs for transporting some of the animals by Little Rays to Safari Niagara, in the amount of $2,062.93, are reasonable.
17Inspector Pryer testified that Little Rays Nature Center in Ottawa (approximately one hour from the Appellant’s residence) assisted with the removal of all 29 animals and transported them. Some were transported to their Little Rays’ facilities, others to Safari Niagara for boarding.
18Little Rays boarded the 6 Tortoises, 3 Eurasian Eagle Owls, and the Blue Tongue Skink, but could not board the 3 Lynx or 2 Foxes as they are a reptile facility. The 2 Foxes were boarded by Little Rays until November 6, 2025, whereupon AWS transported them for boarding at Riverview Park and Zoo. AWS did not charge for its own transportation costs.
19Little Rays also transported the 3 Eurasian Lynx, 11 Rabbits, 1 Harris Hawk, and 2 Chinchillas to Safari Niagara who was willing to take the animals. The invoice for transporting these animals to Safari Niagara included charges for 20 hours of transportation (round trip) and 645 km mileage (round trip).
20I considered but did not accept the evidence of Inspector Pryer regarding her decision to send the animals to Safari Niagara, when she testified that she was unaware how many other vendors of record AWS has in Ontario or how many of these facilities are qualified to handle exotic animals. She testified that she calls the facilities she knows can accommodate the animals being removed.
21Inspector Pryer provided no evidence that she had reviewed AWS’ vendors of record to determine if there were other facilities closer to the Appellant’s residence. I was not persuaded by the Respondent’s evidence that it was necessary to transport the animals this distance to find suitable boarding. I find this cost excessive because there was no justification that transporting the animals this distance was necessary.
22For this reason, I vary the cost of mileage ($825.60) and staffing ($1,000) from a total of $2,062.93 including HST, to $298.32 (incl. HST). The varied cost reflects the cost of transportation of 2 hours travel time each for 2 staff, and mileage of 100 km total, similar to the transportation costs to Little Rays’ facility.
23In summary, I vary the transportation costs, reducing the total by $1,764.61. I vary these because I am not satisfied the Respondent discharged its initial burden regarding this portion of the transportation costs.
Boarding Expenses
24I find that the daily boarding rates for all of the animals were reasonable, and confirm the costs for all the animals at the three boarding facilities, for the reasons that follow.
25The Appellant submitted that the boarding rates charged were excessive, and that the costs should have reflected a reduced rate for long-term care. She further submitted that the boarding charges, which were the same regardless of species, should have varied depending on the care needed. She provided a copy of her own Fee Schedule to compare the invoiced rates to the rates she charges for boarding, testifying that her rates are similar to neighbouring boarding facilities. She further testified regarding the cost of feeding each species of animal at her boarding facility. She provided no evidence to support her testimony, other than her Fee Schedule.
26I am persuaded by the Respondent that the Appellant’s facilities are not of the same caliber as the three boarding facilities, as hers are not CAZA-certified (Canada’s Accredited Zoos and Aquariums). CAZA-certified facilities are inspected to ensure they meet high standards in animal welfare, conservation, education and ethics. AWS also inspects the facilities to ensure they meet the standards under the PAWS Act. I accept the Respondent’s submission that the Appellant’s boarding care is not optimal, as evidenced by the condition of the animals removed, many of whom were thin, and because they lacked suitable environments for their species, with several of the animals in need of medical care.
27The Appellant did not provide a detailed comparison of the boarding costs from the three boarding facilities to hers, however my review indicates that Safari Niagara, who took 17 of the 29 animals, housed the animals in groups based on species and gender, and charged group fees that were at par with the Appellant’s rates. All three facilities used by the Respondent charged rates of $25 or $30 per animal (or grouping) per day; I accept the Respondent’s evidence that compared to boarding fees indicated in the Ontario Veterinary Medical Association Fee Guides (OVMA Fee Guide), these rates are low.
28In summary, I confirm the boarding expenses related to boarding services provided by all three facilities as they are reasonable and not excessive.
Set-up Fees, and Construction of Facilities for the Foxes, and Staff Expenses
29For the reasons that follow, I confirm the setup fees for boarding facilities for the animals. The setup costs do not include the exhibit construction costs for the Foxes, which is a separate entry on the invoices.
30I vary the costs for constructing the exhibit for the Foxes, and for related staff expenses ($1,524.66) to $113 (including HST). I also vary overtime charges to receive the Foxes ($254.25) to zero. My reasons follow.
31I find that the set-up fees at the boarding facilities are reasonable. I agree with the Respondent that the boarding fees are generally much lower than those charged for each of the animals by other boarding facilities, as reflected in the OVMA Fee Guide. While the Respondent did not direct me to any entries in the OVMA Fee Guide for set-up fees, I accept that the higher standard daily rates that are within the Fee Guide are likely to include set-up fees. I accept the Respondent’s evidence that setup is a personalization of an existing area for boarding an animal. The invoices generally reflect a charge of $100 per animal or animal grouping. At $50/hour for staff, this reflects two hours of labour.
32As stated earlier, Little Rays was unable to care for the two red Foxes. They were transported by AWS on November 6, 2025, from Little Rays to Riverview Park and Zoo in Peterborough (some 3.5 hours away). Inspector Pryer testified that the boarding facility had space and appropriate enclosures, and staff were familiar with exotic species. Senior Investigator Collins called Riverview who was able to house the foxes but needed a day to prepare for them. Preparation time included cutting trees down, and purchasing and installing electric fencing, conductors, and wrapping materials to prevent climbing, and roofing. The invoiced cost reflects 16 hours of preparation time ($800) and materials purchased ($549.26).
33I do not find that the charges for exhibit preparation at Riverview Park and Zoo for the Foxes are reasonable. I was not persuaded by Inspector Pryer’s testimony that Riverview was the only facility available to board the two Foxes for the same reasons described above – she was unaware what other pre-approved facilities AWS has, using only those she is familiar with. My conclusion, based on reviewing the costs for exhibit preparation, is that while Riverview was willing to take the foxes, they did not have the facilities to board them.
34While I accept the Respondent’s submission that the Foxes required boarding and care, I find that it is not reasonable to pass on costs of constructing boarding facilities for the foxes to the Appellant. The invoice reflects that it took 16 hours of labour and the purchase of materials to create a suitable boarding facility for the Foxes. This is more than the setup charged at the other boarding facilities, as these are long-term asset improvements that will benefit both the facility and AWS for future removals. Asset improvement is not described in section 35(2) of the PAWS Act as a cost that can be recovered by CAWI and is not directly related to relieving distress. I also do not find the costs justified as the Respondent provided no evidence that Riverview was the only facility able to house the Foxes. For this reason, I vary the costs of $1,524.66 to $113.00 (incl. HST). The varied cost reflects the cost of setup for an area for the Foxes, similar to those charged by Little Rays and Safari Niagara, that could have been charged had Riverview had an existing boarding facility suitable for foxes.
35Inspector Pryer testified that Senior Investigator Collins drove the two Foxes to Riverview, arriving after 4:30 p.m., and because staff there are unionized, overtime was charged because Riverview’s staff had to wait to receive the Foxes. She advised that the Foxes were transported from Little Rays after the veterinarians conducted health assessments on them, which required sedation, and they needed to wake up from the sedation before being transported.
36I do not find that the charge for staff overtime to receive the Foxes at Riverview after 4:30 is reasonable. I accept the Respondent’s submission that the Foxes were sedated for examination at Little Rays and needed to be awake for travel. However, the Respondent offered no explanation of how long this takes and why, knowing that the Foxes were to be transferred, they weren’t examined early in the day or at Riverview, which also had access to a veterinarian. For this reason, I reduced the SOA by $254.25 (incl. HST) for the overtime charges, which reflects 3 staff at 1.5 hours each.
37In summary, I vary the fees for construction of the Fox exhibit and staffing overtime to receive the Foxes after 4:30 p.m. on November 6, 2025, reducing the total by $1,665.91, on the basis that these charges are excessive and not reasonable.
Medical Expenses: Veterinary staff services, procedures and medication
38For the reasons that follow I vary the medical expenses, reducing the total by $60.20.
39I confirm the veterinary charges and charges for tests, procedures and medications. I find that they were reasonable and justified.
40The Appellant disputed the necessity of the Veterinarian Technician services (at $200) (who assisted the Veterinarian with the female red Fox), and whether the male rabbit could have been euthanized rather than castrated ($350) to save money. The Appellant did not substantiate these with medical evidence, nor provide evidence of the cost of euthanasia to support her position that this would have saved money.
41I accept the evidence of the Respondent that the medical services were all reasonable and necessary, including Dr. Delnatte’s responses to the Appellant’s disputed items, as well as her evidence regarding the necessity and reasonableness of all the medical expenses, including:
In preparing her expert report, she reviewed all the animals’ veterinary reports, including medical notes, laboratory results, pictures and videos and radiographs from November 6, 2025, to December 9, 2025. She also reviewed her expert report for files 17986 and 17988/ACRB, written on December 11, 2025.
The SOA does not reflect the value of her professional services, and various procedures were not invoiced, resulting in significant savings from what external veterinarians would have charged.
All animals underwent a full initial veterinary assessment between November 6 and November 20, 2025, and follow-ups were scheduled on some, based on their health status.
In her opinion, which included a detailed review of the medical condition of each of the animals, detailed veterinarian examinations were warranted post-removal because of this, and appropriate medical procedures conducted were warranted. This included for example all of the veterinary examinations after intake, as well as radiographs of the juvenile Lynx because of his previous injuries (hind leg fracture and multiple bite wounds), fecal parasitology, and bloodwork (because one wound was found to be infected). Antibiotics and pain medication were necessary for treatment, and anesthesia was necessary to sedate the Lynx for examination. A second set of radiographs was necessary as part of a re-check, because the Lynx’s gait was abnormal, and the initial leg fracture resulted in an angular limb deformity. Another example was the radiographs for the female Fox because of her leg injury, and multiple rechecks. Pain medication and anesthesia were also justified.
No treatments were provided that were not medically necessary. All the animals examined were in poor condition, based on her initial examinations; follow-up care was determined necessary. All vet fees charged were between 10% and 50% cheaper than the Fee Guide, not including the procedures not invoiced.
In her opinion, the veterinary fees are reasonable and consistent with industry practice. She reviewed each individual medical entry and its cost and compared them to the OVMA Fee Guide. In reviewing the fees charged, she referenced the guide for exotic animals/birds and used dogs/cats for foxes because there was no category for them. She also referenced the Fee Guide for cats for the Lynx; again, because there was no category for them.
The male Rabbit required castration because of an injury caused by another of the Rabbits. In situations where it is medically necessary to heal and survive, consent of the owner is not requested.
A staff veterinary technician was needed to assist the Veterinarian for the two examinations conducted on the female red Fox on November 7 and 27, 2025 ($200). The services provided by the technician were not redundant to those of the veterinarian.
42I am persuaded by the Respondent’s evidence that the animals had various medical conditions and that the procedures conducted were necessary. I also find the corresponding charges for those services were reasonable because they were within the ranges in the Fee Guide, if they were charged at all. Furthermore, the Appellant did not contest the charges other than the castration of the male rabbit; I accept Dr. Delnatte’s evidence that this service was medically necessary because the injury had caused it significant pain, and surgery was necessary.
43While the Respondent didn’t address the law regarding euthanasia, I draw attention to s.1(4) of the PAWS Act, which states that euthanasia is the most humane course of action for an animal if immediate veterinary treatment cannot prolong the animal’s life or prolonging it would result in undue suffering. The veterinarian’s actions appear to be consistent with the law.
44I acknowledge the Respondent advised me that the charge of $60.20 for a test was included in an invoice twice, and I reduced the medical charges by that amount accordingly.
45In summary, I confirm the medical charges, with the exception of the duplicate charge of $60.20, which I deduct from the SOA.
ORDER
46Pursuant to the powers of the Board under s.38(9) of the PAWS Act, I vary the SOA and order that the costs of $31,435.99 be paid to the Minister of Finance.
Released: March 2, 2026
Susan Clarke, Vice-Chair
APPENDIX A
Table 1: Summary of Invoices supporting SOA
Service Provider
Invoice Number
Dates of Services
Description of Services
Invoiced Sub-Totals
Little Ray’s Reptile Zoo
6740 issued November 10, 2025
6 Tortoises, 3 Eurasian Eagle Owls, and Blue Tongue Skink
Nov. 5
(assumed)
Staffing for travel – to Little Rays and to Safari Niagara
2 staff @ 6 hrs. each, and 1 add’l staff for 2nd vehicle (2 hrs.), and to drive remaining animals to Safari Niagara (20 hrs.)
$1,700
Nov. 5
(assumed)
Mileage:
100 km for each of 2 vehicles; 1,290 km to Safari Niagara
Rate: $0.64/km
953.60
No date provided
Lee for vet visit 4.5 hrs. @ $50/hr
225.00
Nov. 5
(assumed)
Staffing for set-up of enclosures
2 hrs. $50/hr
100.00
Nov. 5
(assumed)
Set-up fee for 7 animals @ $100 each
700.00
Nov. 6 – 9, 10 animals, 4 days each
boarding $25/day/animal
1,000.00
Nov. 6 (assumed)
Boarding of 2 foxes @ $25
50.00
HST (13%)
$ 600.37
TOTAL
$5,740.09
Little Ray’s Reptile Zoo
6747 issued November 27, 2025
6 Tortoises, 3 Eurasian Eagle Owls, and Blue Tongue Skink
Nov. 10 – 25, 2025, 16 days each, 10 animals
Boarding @ $25/day/animal
$4,000.00
Nov. 6, 2025
Dr. Cheryl Laite, veterinarian (Invoice 1698)
700.00
HST
$ 611.00
TOTAL
$5,311.00
Little Ray’s Reptile Zoo
6756 issued December 5, 2025
6 Tortoises, 3 Eurasian Eagle Owls, and Blue Tongue Skink
Nov. 26 – Dec. 5, 2025, 19 days
Boarding @ $25/day/animal
$2,500.00
HST
$ 325.00
TOTAL
$2,825.00
Riverview Park and Zoo
20250714
2 Foxes
Nov. 5, 2025
Purchase of materials for exhibit preparation
$549.26
Nov. 5, 2025
Staff prep time (for exhibit), 16 hr $50/hr
800.00
Nov. 6, 2025
Staff overtime to receive animals, 3 staff @ 1.5 hr @ $50/hr
225.00
Nov. 7, 2025
Dr. Sallaway, veterinarian exam & meds for Shadow
$655.40
Nov. 7, and 27, 2025
Technician for vet exam for Shadow
4 hr @ $50/hr
200.00
Nov. 7, 2025
Medication purchase for Shadow
305.78
No date
Radiographs for Shadow, 5 images @ $100/image
500.00
Nov. 7 – 27, 2025, 20 days
Boarding @ $25/day/animal
1,000.00
HST
$ 354.25
TOTAL
$4,589.00
Safari Niagara
33593
2 Adult Lynx 1 Juvenile Lynx
No date
473 lynx
Emergency set up Fee for exhibits; shared for adults
$200.00
Nov 5 – Dec 5[1]; 31 days
Boarding @ $30/day/animal
2,790.00
No date
3 lynx
Vet exams + rabies, 3 Lynx @ $196.90 each
590.70
No date
3 lynx
Sedation/reversal; vet visit – radiograph set up and 5 views each; 4x/5x radiograph view (female and juvenile only)
3,860.30
No date
3 lynx
Vet visit
Fecal test, ear mite test, wellness, blood collection, selavectine, meloxicam, clavaseptin
1,140.98
No date
clean wound - Juvenile
93.50
No date
Vet visit – recheck Juvenile, sedation/reversal, radiograph, selavectine
401.95
TOTAL
$9,077.53
Safari Niagara
33594
11 Rabbits, 1 Harris Hawk, and 2 Chinchillas
No date
Emergency exhibit set up fee @ $100 per exhibit, by group of animals
$ 500.00
Nov. 5 – Dec. 5; 31 days
Boarding @ $30/day/animal grouping - 930
4,650.00
No date
Small/Large exotic vet exam
$138.90/$185.30 each + Selavectine
1,998.73
No date
Male Rabbit
Vet visit
Clean wound, and meds
117.88
No date
Male Rabbit
Vet visit
Surgical procedure (orchidectomy)
350.00
Harris Hawk
Vet visit
Ear/feather mite test
50.60
TOTAL
$7,667.21
1Note that Boarding was invoiced from Nov 5 – 25, and Nov. 26 – Dec. 5 for the Adult Female Lynx, but for the Adult Male Lynx, and the Juvenile Lynx the dates are for Nov 5 – 21, and Nov 26 – Dec 5. As the amounts invoiced are identical, it is assumed that Nov 21 is a typo and should read Nov 25.