Nature Conservation

Environment, Planning and Sustainable Development Directorate

epsddcomm@act.gov.au

28 June 2019

Dear Sir/Madam

Re: Draft ACT Cat Plan 2019-29 (the draft plan)

We welcome the opportunity to comment on the development of a cat plan for the ACT.

This submission is jointly prepared by:

• Best Friends Pet Rescue
• Canberra Lost Pet Database
• Canberra Pet Rescue
• Canberra Street Cat Alliance
• Hear No Evil Deaf Dog Rescue
• Sydney Fox and Dingo Rescue

We are locally based not-for-profit organisations dedicated to the rescue, rehabilitation and rehoming of cats in need in the ACT. Between us, we help and rehome approximately 800-1000 cats annually, and have over 70 years of experience collectively in doing so. We have extensive experience working with the local community to educate and promote the welfare and best practices of cats. We take in surrendered, stray, and unowned cats and kittens at our own expense, with no surrender fees, and have the trust of our community in ensuring their wellbeing and care. We do not euthanise cats for being in care too long or being unable to find a permanent home within a certain period of time. We work with local councils, pounds, and rescue groups across Australia and engage on an international level as well.

We think it’s an opportune time to consider the management of cats in the ACT. We feel that the vision “All cats in the ACT will be owned, wanted and cared for by responsible owners” is too ambitious and sets the wrong direction in identifying and solving the correct set of issues. We would propose that something more suitable would be “All cats in the ACT are cared for by responsible owners or the community, and humanely managed”.

The plan outlines 8 strategies which may go some way towards effectively managing cats, but we are of the view that a number of strategies will be ineffective, have negative and counterproductive results, and some are based on erroneous conclusions and lack detail.

Our submission is divided into two parts. The first outlines our key priorities that we feel are not adequately addressed by the cat plan and should be incorporated to ensure the appropriate management of cats in the ACT. The second part provides our brief comments against each of your proposed strategies and actions.

 

 

PART ONE

Our key strategies

Below are our key priorities that we feel are not adequately addressed by the cat plan and should be incorporated to ensure the appropriate management of cats in the ACT.

1. Creating an animal welfare and rescue ecosystem that fosters collaboration between local Government, Domestic Animal Services, the RSPCA and rescue groups.

We consider that there would be merit in the ACT Government establishing a network that would foster ongoing collaboration and coordination between relevant government agencies and non-government organisations on operational and policy matters relating to the management of cats in the ACT. Such collaboration and coordination is vital to ensuring the successful implementation of any of the identified strategies and actions from the cat plan. This would enable greater coordination and collaboration in helping and fostering animals in need as well as assistance on enforcement matters, and clearer more effective channels of communication between these stakeholders. This cohesive group would have a united and consistent voice working with the community with shared goals.

2. Reducing the number of unowned or semi-owned cats in the ACT

While we share the dream of one day having no more unowned or semi-owned cats (we refer to both of these groups as “community cats” or “street cats”) in Canberra, and acknowledge that management of semi and unowned cats is a highly complex issue, we feel that the action items set out in the draft plan are based on a flawed understanding of the realities of street cats in the ACT, and the individuals they have contact with.

The typical community cat in Canberra is not a solitary cat living in a residential or suburban area. Most community cats have started from an undesexed pet cat in a suburb or dumped in an industrial area, who has bred to large numbers and are fed by employees of surrounding businesses who have varying degrees of attachment to these cats. The options currently available (and proposed) to manage these cats are in our experience not suitable for community caretakers nor appetising to community members more generally. Adoption of these often timid cats that are not of nuisance, is usually not viable as they are not suitable cuddly pets but caretakers have an emotional attachment to them, and do not feel it is morally right to take the cat to an animal shelter where they are likely to be euthanised.

Colony caretakers are the gatekeepers of these cats and would likely sabotage any efforts to have the cats caught for the purpose of euthanizing them. We have witnessed many such sabotage efforts including at one ACT government facility where a pest controller had been called in to get rid of several cats that the staff were feeding. The day before the pest control company came the staff got their own traps and took the cat’s home for the week for safe-keeping before returning them. Another example is one colony caretaker spraying citronella over traps that had been put down by another pest control company to deter the cats from going in. Many of these colonies are at the back of businesses, which have gates locked after hours so there is no way to access and trap the cats without their permission.

Euthanisation of healthy animals is a key trigger for perpetration-induced stress in veterinarians and shelter workers and has been linked to high staff turnover, negative mental health and increased suicide rates (Bennett & Rohlf 2005; Rand et al 2018).

In addition, trying to trap and kill many community cats would leave more resources available and result in more undesexed cats constantly moving in and establishing themselves in the territory, resulting in a larger population through uncontrolled breeding.

A much more effective strategy is working with these caretakers and rescue groups to reduce the number of these cats humanely, through funding ethical trap, neuter, return (TNR) and community feeding and care programs. These initiatives have been shown to be more effective over the long term in reducing the size of the community cat population (Tan, et al. 2017; Swarbrick & Rand 2018) and there is usually a greater willingness from caretakers to support the initiative.

To support an effective TNR program, the ear tipping method should form part of the process for easy identification, and kittens that are rescued from identified colonies would be rehomed through local rescue groups as it is currently already done. Implementing a large scale TNR program would initially result in a larger number of kittens being identified, desexed and rehomed, which would assist in reducing the number of community cats but would also place additional pressure on rescue groups who would need additional support and resources to do this work. Rescue groups such as ours have the trust and support of the community, and experience with socialising community kittens to effectively undertake this work.

3. Addressing the source of unowned or semi-owned cats in the ACT

We feel that the cat plan does not adequately address the main sources of un-owned and semi-owned cats. We continuously hear from members of the community that cats are dumped and/or not desexed for four main reasons;

• Owners cannot afford the cost of desexing and other medical care;
• Owners cannot rehome or surrender their pet due to lack of capacity and waiting list times at a shelter or with a rescue group;
• Owners cannot afford shelter surrender fees; and/or
• Owners are reticent to surrender their cat to a shelter or pound where they feel it may be euthanised.

 

1. Low cost desexing, microchipping and vaccinations

We hear that the most affected group of people in the community who cannot desex their cats (and dogs) are middle income earners who do not qualify for the limited help provided to low income earners, yet live week to week and cannot afford the high cost of vet care in Canberra, compared to other states.

We note that many (if not all) States in Australia have low cost desexing, microchipping and vaccination programs provided by councils to help members of the community. We feel this would be an essential part of helping to curb the number of animals that end up dumped and unwanted litters. We recommend that the ACT adopt a similar approach to other jurisdictions in consultation with key stakeholders such as rescue groups who these groups of people come to for help and advice.

We note that there have been some initiatives from the RSPCA on lower cost desexing and services however these programs were limited to pensioners and health care card holders and did not assist the wider group of people who would benefit greatly. One clinic a year is also not enough to cater for the peak times when people get a kitten (primarily over a nine month duration of the year) so clinics should be regularly offered with more frequently at peak times, or other similar suitable options explored.

1. Preventing unlawful sales of cats

There should be greater engagement by the ACT Government with platforms such as Gumtree to prevent the unlawful sale of cats and kittens in the ACT and stop backyard breeders. This is a key source of where many free or cheap cats come from that are not desexed, vaccinated or microchipped prior to change of owner.

 

4. Changes to Legislation, Codes of Practice and Breeder Registry
5. Desexing before change of ownership

While pet owners have the responsibility of pet ownership, we also believe that there should be a responsibility placed on people and organisations who supply the pets. We consider that ALL cats should be desexed BEFORE they are sold or given away. This should apply to everyone – individuals, breeders, rescue groups, etc. This would avoid the situation where a cat is undesexed and goes to a new owner who cannot afford it or chooses not to desex.

1. Age to desex cats by

Although current legislation stipulates that all cats must be desexed by the age of 12 weeks, veterinary advice given by most veterinarians in Canberra is to desex a female cat at 16-20 weeks. Many veterinarians will not perform paediatric spays until this age. A feline becomes sexually mature from 20 weeks of age. For these reasons we stand with many veterinarians to support a increase to the age that a cat must be desexed by, to 20 weeks of age.

• Age to adopt cats from

With many behavioural issues created by kittens being adopted out (sold or given away) from their mother and/or litter mates too young, we see it as essential to mandate that kittens must not be sold or given away prior to the age of eight (8) weeks of age. This is in line with veterinarian, feline specialist and cat behaviourist advice.

1. Updates to Codes of Practice

We note that the plan refers to the codes of practice relating the management of cats as being regularly reviewed, however the codes of practice for:

• The Welfare of Cats in the ACT has not been updated in 12 years;
• The Animal Welfare (Handling of Companion Animals in Pounds and Shelters Code of Practice) has not been updated in 19 years; and
• The Animal Welfare (Mandatory Code of Practice) has not been updated in 6 years.

We feel this would be an opportune time to jointly review, update and improve these codes of practice with the collaborative stakeholder group suggested in our first point and the community.

1. Breeder registry

There is a lack of transparency in relation to identifying who holds a current breeders licence in the ACT. This registry should be made available to the public so potential pet owners can easily check to see if they are dealing with a registered breeder. Visibility of this is expected to contribute to public awareness to minimise backyard breeding and unlawful sales. These breeders should be regulated as per legislation and the code of practice that relates.

 

5. Cat Containment

There is a lack of evidence or research to suggest that mandatory cat containment is proven successful in reducing the number of unowned or semi owned (community) cats, nor that cats are the cause of endangerment or extinction of native species in Canberra, and more specifically suburban areas. For the 17 areas of mandatory cat containment currently in Canberra, there has not been any research or evidence to suggest that this has had a positive impact on wildlife, cats or people. We have anecdotal evidence to the contrary where owners have not understood or been able to cater for the mental and physical requirements of cats when containing them, to prevent unwanted behaviour, and as a result have chosen to surrender their cat. This has placed an increased burden on rescue groups to take on more unwanted cats.

1. Impacts – increase in abandoned, dumped or surrendered cats

We have serious concerns about cat containment being expanded in Canberra. Our most serious concern is that many more cats will be abandoned or surrendered as their owners will not be able to provide enough mental stimulation for them in the home leading to behavioural issues. This is particularly the case for cats that are already used to being outdoors.

While our organisations are leaders (and have been for sometime) in Canberra for promoting and educating owners and the community about effectively containing cats to within a property, we acknowledge that there are some cats that have behavioural issues that would benefit from being allowed outdoors in the neighbourhood (without being a nuisance) or are already accustomed to this practise.

1. Concerns related to tenants and enclosure/containment costs

We have also heard MANY concerns from the community that cat containment would also present difficulties for pet owners in rental accommodation who may wish to adapt their properties to provide an outdoor space for their cats for the purposes of mental stimulation and physical activity but are unable to do so due to the conditions of their lease. Many cat owners have also expressed concern over the cost of creating or purchasing cat enclosures or runs.

• Mental stimulation and physical activity for cats

We therefore advocate for NOT mandating cat containment, but instead for supporting rescue groups and the shelter to educate owners on how to provide adequate stimulation and activity for pets that are contained to their property where this is possible and conducive to the health and wellbeing of the pet.

To better support the wellbeing of cats, especially those that are contained to a property or unit, it would be suggested to develop cat parks or safe areas where cats can roam on lead and harness without loud noises, cars, or dogs that may attack and injure or kill a cat.

1. Predator-proof fencing sanctuaries

To minimise any danger to protected native wildlife, we support the ACT Government in considering predator-proof fencing areas where these species live within nature reserves such as Mulligans Flat Woodland Sanctuary. We applaud this approach as it is seeing successful results and prevents any danger posed by any potential predators.

1. Options to reduce feral cats

Our organisations strongly oppose the use of 1080 bait as it is cruel, inhumane, unethical, ineffective and has unintended consequences on other non-targeted species. We urge the ACT Government to fund more effective and ethical management practices such as sterilisation vaccination programs and proven trap neuter return programs that sustainably reduce numbers of feral cats over the long term.

6. Registration & Licensing
7. Cat Registration

We see ACT Cat Registration as an unnecessary burden that provides no positive impact. Owners will still have to update their cats’ microchip details when they move, and vet clinics will still use the microchip to reunite owners as they do now. There is no evidence to suggest that there is a problem with lost pets not being reunited with owners due to microchip details not being up to date. Further to this a registration, even if free, would be an additional burden (red tape) on rescue groups, pet owners and may not be as effectively run as private microchip registries currently are.

If data is required on pet ownership, then it would be more effective to work with the current private and government owned microchip registries to feed into a federal level registry with the full dataset, particularly as the ACT is small and surrounded by NSW and many owners come to or move from the ACT.

The funding allocated to create and maintain this additional registry would be far better spent on funding the effective services provided by the community trusted “Canberra Lost Pet Database” group. They are the leading organisation individuals go to when a pet is lost or found, and have a great success rate at reuniting owners and pets.

1. Exemptions from licensing and registration requirements

Rescue groups continue to operate in an environment with uncertainty around certain laws in relation to the fostering and rehoming of cats. To support rescue groups in the management of cats in the ACT, exemptions from requirements such as multi-cat licenses should be provided.

 

General comments on the plan

Positive impact of pet ownership

The plan needs to recognise the importance of pet ownership and animal companionship and its related affects on the mental health and wellbeing for members of the ACT community. Given mental health is has an important focus in the community, the new plan should also recognise the positive contribution animal companionship has on our community.

Faulty references and research

The studies referenced in the cat plan have largely been used in the wrong context and are outdated (more than ten years old) and/or do not apply to the Canberra context. To reference studies on feral cats to support strategies to be used on urban/domestic cats does not provide valid support for related proposed actions or strategies.

Lack of relevant research or evidence to show the issue of cats being the cause of the endangerment or extinction of native species within Canberra

No convincing or accurate research was presented in the report that demonstrated that cats within Canberra are the cause of the endangerment or extinction of native species within Canberra. It is therefore misleading to quote this as a reason to mandate cat containment in Canberra, and propose strategies to remove community and feral cats with no research to show the wider negative impacts that may be caused by undertaking this (e.g. vermin populations increase and kill native birds through eating their eggs causing a bigger threat to the endangerment or extinction of protected native species). This was devastatingly seen when Macquarie Island eradicated non-native cats which had the unforeseen impact of rabbits breeding out of control and destroying native plants which severely negatively impacted the whole ecosystem (Svoboda, 2009). In this study it was concluded that “Our findings show that it’s important for scientists to study the whole ecosystem before doing eradication programs”. This was also similarly seen in the 1990s in New Zealand when they eradicated multiple species without proper research into the full ecosystem impacts, which inadvertently endangered native species, and there are many other examples (Svoboda, 2009). Proper research into causes to effectively identify the problems, and trials to test various options to ethically and humanely resolve the issues is required before putting forward many of the strategies listed in the plan.

Other comments on the draft plan                          

List of key stakeholders and roles and responsibilities (p6)

The draft plan currently states that animal care and rescue organisations have a role and responsibility to “humanely euthanase unwanted cats”. Euthanasia is not the responsibility of rescue groups but rather veterinary practitioners. In addition, euthanizing of unwanted cats is not something that we or other rescue group partake in or endorse. Our role is to provide foster care, rehabilitation and rehoming of cats, as well as to promote the benefits of responsible pet ownership to the community.  If this role and responsibility is to be retained in the cat plan, it should be correctly noted as a role and responsibility for veterinary practitioners.

“Animal care and rescue organisations” and “Not-for-profit animal organisations” are currently listed as key stakeholders. However, we are not clear as to which of our groups would fit into either category. It should also be noted that the two organisations listed are no longer in operation so my not be the best of examples. It would be more beneficial to have the one group called “Animal Care and Rescue Organisations” with roles and responsibilities that may include:

• rescuing, rehabilitating, raising and rehoming stray, orphaned, surrendered and unwanted cats;
• promoting and advocating for the welfare of animals;
• community education and engagement on responsible pet ownership, and
• community services such as reunited lost pets, and providing pet care to people in need (homeless, low income earners, victims of domestic violence)

 

 

PART TWO

Our brief comments against each of the strategies listed in the plan are below.

Strategy 1: Promote responsible cat ownership through community education and engagement campaigns.

• We urge ACT Government to collaborate more widely with us Animal Rescue Groups that have the communities trust and undertake a decent portion of the community engagement and cat rescue work.
• Community members know how to be responsible cat owners, however many report not being able to afford the medical work (desexing, etc) and they have no concern about being caught as it is a highly unregulated sector. We support current staff regulating this more closely and engaging with platforms such as Gumtree to prevent illegal sales or exchange of cats.
• Rescue groups who have the trust of the community, should also be funded to continue to educate the public on how to mentally stimulate and effectively and safely meet physical activity of requirements of cats.

Strategy 2: Improve compliance and enforcement of cat laws; Explore options to improve compliance and enforcement of cat laws including legal obligations for owners to desex, microchip and contain their cat (if they live in a declared cat containment area).

• We do not support the implementation of a Cat Registration system.
• We encourage state government to engage at a federal level to create a national register of pets with far more wide reaching benefits.
• We encourage ACT Government to help fund successful services such as the Canberra Lost Pet Database to continue their vital work in the community
• We support ACT Govt to pursue repeat offenders for offences against the Domestic Animals Act.

Strategy 3: Reduce the number of semi-owned and un-owned cats through community education, increased adoption rates and strengthening laws to minimise breeding, nuisance and wildlife predation.

• We do not support actions 6 and 7.
• We support action 8 but add to it that ethical Trap Neuter Return (TNR) and community cat feeding and care programs be explored and implemented for a proven effective multipronged approach.
• We support action 9 but warn that TNR should NOT fall into this category. Legislative changes may be required to allow for effective TNR programs.

Strategy 4: Adopt best practice animal welfare practices and support training and provision of cat management facilities and shelters in the ACT.

• We support reviewing and updating the relevant Codes of Practice, and would like rescue groups to be included in the process.
• We urge ACT Government to include rescue groups in the strategy and actions around managing cats. Not all cats are suited to a shelter environment and rescue groups should be used to care for ones that do not fit into this category, e.g. orphaned neonatal, sick, timid, etc.
• Rescue groups should form part of the arrangements relating to the management of cats in the ACT, and receive funding from the ACT Government for their vital community service.
• Current capacity of shelter and rescue groups is not adequate for demand, supporting and funding rescue groups would enable more capacity and be a more appetising option than opening a new facility at DAS where staff are not experienced in cat management and a shelter environment which is often not a suitable environment for cats (especially with barking dogs).
• Rescue groups currently take a significant portion of surrendered, stray and unowned cats and vet-work, rehabilitate and rehome cats and kittens and this vital work should be recognised and supported by the ACT Government.
• Rescue groups should also be included in sharing information on best practices etc (action 12).

Strategy 5: Explore options for expanding cat containment in the ACT (both mandatory and voluntary) to reduce the impact of cats on the environment and improve animal welfare and safety.

• As leaders in promoting effective cat containment where appropriate, we acknowledge that there are some cats that have behavioural issues that would benefit from being allowed outdoors in the neighbourhood (without being a nuisance) or are already accustomed to this practise. We therefore do NOT support mandatory cat containment, nor the further implementation of this in more suburbs/areas.
• There has not been any research or evidence to suggest that cat containment has had a positive impact on wildlife, cats or people. We have anecdotal evidence to the contrary where owners have not understood or been able to cater for the mental and physical requirements of cats when containing them, to prevent unwanted behaviour, and as a result have chosen to surrender their cat. This has placed an increased burden on rescue groups to take on more unwanted cats.
• There are concerns related to tenants being able to enclose their yard or balcony.
• There are concerns about the costs of cat enclosure/containment.
• We partially support action 14 to encourage voluntary uptake, however we urge ACT Government to support rescue groups and the shelter to educate owners on how to provide adequate stimulation and activity for cats that are contained to their property where this is possible and conducive to the health and wellbeing of the cat.
• We would advocate looking into the feasibility of cat parks or safe areas where cats can roam on lead and harness without loud noises, cars, or dogs that may attack and injure or kill a cat.
• We support legislative changes to allow cats to be walked in a pet suitable device/pram, and a harness and leash in public areas.

Strategy 6: Raise awareness of how feral cats impact on native wildlife and explore opportunities for monitoring, research and control.

• We do not support action 19 “listing predation by feral cats as a Key Threatening Process under the Nature Conservation Act 2014”. This is not supported by evidence or research to prove this.
• We support further research (action 20) however, strongly oppose the use of 1080 bait. It is inhumane and we agree that better (more humane and effective) options should be made available and used.
• We support the increased use of predator-proof fencing within nature reserves.
• There is strong community concern that lost pet cats could accidentally be targeted by lethal methods used if feral cats are listed as a Key Threatening Process, as there is no validated protocol for distinguishing between a feral cat and a lost pet cat either by the cat’s behaviour or location. A previous 2017 attempt to include cats as a Threatening Process was abandoned due to public fears of the difficulty of distinguishing between “feral” cats and domestic cats. We do not feel anything would have substantially changed in the behaviour of either pet or feral cats, or the methods proposed for killing cats that would alleviate this community concern in 2019.

Strategy 7: Explore options for managing owned, semi-owned, unowned and feral cats in rural areas and undertake information and training campaigns with rural land holders.

• Rural landholders are an opportunity to use desexed, vaccinated and cared for community cats to control issues such as vermin. They are also an opportunity to test TNR programs.
• We do not support cat containment on rural properties either.
• We have not seen any sound research to support agriculture being a source of transmission of parasites and diseases to livestock. We instead see benefits of using them to prevent diseases spread by vermin to humans and animals.

Strategy 8: Raise public awareness about how to reduce risk of infection from cats. Though unlikely, germs from cats may cause a variety of illnesses in people, from minor skin infections to more serious illnesses.

• We do NOT agree with this strategy nor action.
• There is no actual issue identified here, and this is not based on any sound research or evidence of an issue.
• We advocate for the whole strategy/section being removed. This is a cat management plan, not a medical guide with advice from medical professionals (or lack thereof) for people.
• In addition to not supporting the whole strategy and action, we do not agree that cats should only be fed only a commercial diet or well cooked table food.

 

We thank you for this opportunity to provide feedback on this important topic to ensure a sustainable and positive impact on cats, wildlife and people for the future of the ACT. We look forward to working together towards our shared goals in the near future.

 

References

Bennett, P., & Rohlf, V. (2005). Perpetration-induced traumatic stress in persons who euthanize nonhuman animals in surgeries, animal shelters, and laboratories. Society & Animals, 13(3), 201-220.

Rand, J., Lancaster, E., Inwood, G., Cluderay, C., & Marston, L. (2018). Strategies to reduce the euthanasia of impounded dogs and cats used by councils in Victoria, Australia. Animals, 8(7), 100.).

Svoboda, E. (2009). The Unintended Consequences of Changing Nature’s Balance.

https://www.nytimes.com/2009/02/17/science/17isla.html?fbclid=IwAR188GsyvV-drff-FTe1NF-PRxCD_ImiFY0llaOvU7LkcURQcuGIazUTfl4

Swarbrick, H., & Rand, J. (2018). Application of a protocol based on Trap-Neuter-Return (TNR) to manage unowned urban cats on an Australian University Campus. Animals, 8(5), 77.

Tan, K., Rand, J., & Morton, J. (2017). Trap-neuter-return activities in urban stray cat colonies in Australia. Animals, 7(6), 46.