Proposal for exemption

March 2022

ACT Cat Plan 2021-2031 and Domestic Animals Legislation Amendment Bill 2022

Canberra Street Cat Alliance ABN 80 327 087 602 csca.org.au

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Contents Purpose ................................................................................................................................................. 3 Background .......................................................................................................................................... 3 Cat Management Methodologies .................................................................................................... 6 Killing ................................................................................................................................................. 6 Destroy on site ................................................................................................................................ 6 Trap & kill ...................................................................................................................................... 7 Desexing ........................................................................................................................................... 9 Adoption ......................................................................................................................................... 12 Summary of cat management methodologies. ....................................................................... 13 Community Consultation Report - Draft ACT Cat Plan 2019 – 2029........................................ 14 Concerns regarding the ACT Cat Plan 2021 – 2031 ................................................................... 15 Unintended Consequences of the ACT Cat Plan 2021 – 2031.................................................... 16 Recommendations ............................................................................................................................ 18 Five year containment exemption for unowned cats in industrial and commercially zoned areas .................................................................................................................................... 18 Research projects on wildlife predation and community cat desexing .............................. 20 Correct use of terminology.......................................................................................................... 20

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Purpose The ACT government has developed a cat management strategy, the ACT Cat Plan 2021 – 2031, proposed for implementation on 1 July 2022. Legislative amendments required to implement the ACT Cat Plan 2021 – 2031 (Domestic Animals Legislation Amendment Bill 2022) are currently under discussion by the ACT Members of the Legislative Assembly.

The purpose of this submission is to highlight the consequences for the ACT region and community should the proposed Domestic Animals Legislation Amendment Bill 2022 be implemented in its current format.

Background In 2001, ACT became the first jurisdiction in Australia to make the desexing of dogs and cats compulsory by six months of age1 . As early as 1993, before compulsory desexing became the law, most pet cats were desexed. In 1993, 88% of female pet cats in the ACT were desexed.2 More recent data from national surveys suggests that across Australia, 9094% of owned cats are desexed34.

However, twenty years later, there is still a significant population of semi-owned and unowned cats living in the ACT. The number of unowned or semi-owned cats in Canberra is unknown, although Sarah Legge of the Threatened Species Recovery Hub estimates there to be a minimum of 3,0005. The vast majority, 68%, of cats entering the RSPCA ACT are unowned strays6.

Despite unowned cats making up most intakes to the RSPCA, to date there has been no concerted effort or management plan by the ACT Government to deal with semi-owned and unowned cats. While there are various legislations regarding the keeping of cats, including compulsory desexing and microchipping, and cat containment in certain suburbs, these by definition do not apply to unowned cats. These cats have no owner to desex them or keep them contained.

These cats primarily reside in industrial areas including Fyshwick, Mitchell and Hume as well as around commercially zoned areas of various suburbs. As defined by the RSPCA and the ACT Cat Plan, cats found in urban areas of Canberra are, by definition, domestic and not feral due to their dependence on humans.

1

Centre for Companion Animals in the Community. (2007). Mandatory Desexing in the ACT—Has It Worked?.

2

Paxton, D. W. (1994). Dog and cat keeping in the Australian Capital Territory, 1993. Australian veterinary journal, 71(1), 27-28.

3 Johnston, L., Szczepanski, J., & McDonagh, P. (2017). Demographics, lifestyle and veterinary care of cats in Australia and New Zealand. Journal of feline medicine and surgery, 19(12), 1199-1205.

4 Hall, C. M., Adams, N. A., Bradley, J. S., Bryant, K. A., Davis, A. A., Dickman, C. R., ... & Calver, M. C. (2016). Community attitudes and practices of urban residents regarding predation by pet cats on wildlife: an international comparison. PloS one, 11(4), e0151962.

5 https://the-riotact.com/canberras-feral-cats-taking-catastrophic-toll-on-native-animal-population-researchsays/312491 6 https://the-riotact.com/stats-on-cat-attacks-leads-to-containment-in-all-canberra-suburbs/465305

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Source: ACT Cat Plan 2021-2031, page 5.

While there is a link between owned cats not being desexed and turning into unowned cats, most unowned cats in Canberra are born to generations of unowned cats and reside in industrial areas. As such policies targeting owners requiring performing specific behaviours such as desexing and containment have no effect on these cats.

It is for this reason that Canberra Street Cat Alliance (CSCA) was founded in 2014, to fill this gap. CSCA is a registered not-for-profit, 100% volunteer based, self-funded organisation. CSCA is reducing the community cat population of Canberra through humane and effective evidence-based practice. This is achieved through four programs which are primarily focused on desexing and rehoming: 1) Community Cat desexing program Unowned and semi-owned cats are humanely trapped, desexed, microchipped and vaccinated before being returned to their location. Once returned, the cats are fed daily and provided ongoing veterinary treatment as required.

2) Adoption program Cats and kittens are taken into our ‘Streets to Sheets’ foster care program and placed with foster carers in residential homes. They are socialised and adopted to indoor only homes. All cats placed into the program are desexed, microchipped and vaccinated prior to adoption. The socialisation process will vary from cat to cat with the duration dependent on the age and temperament of the cat. This process has been known to extend beyond 12 months for particularly scared cats but alternatively as short as 4 weeks for more confident cats.

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3) Barn cat program Street cats who cannot be safely returned to their home location are sent (usually in pairs) to farms. After a 4 – 6 week period of acclimatisation at the new location, typically a stable or shed, they are then allowed free roam to act as mousers. The property owners continue to feed the cats daily and provide any future veterinary treatment the cat requires.

4) Last litter program.

This program is for members of the community who have a mother cat with a litter of kittens. The kittens are surrendered to CSCA and placed into our ‘Streets to Sheets’ foster care program. CSCA arranges for the mother cat to be desexed, microchipped and vaccinated at no cost to the owner, preventing further litters of kittens being born.

Last year, CSCA took in 469 cats compared to 350 for 2020 and 219 for 2019. Of the 2021 intakes, 58 community cats were returned to their home location, a small but crucial component to CSCA’s operations and objectives.

Table 1 Intake numbers and outcomes for Canberra Street Cat Alliance, by calendar year

Adopted TNR Barn homes Euthanised Total intakes

2019

2020

2021

130 60 2 14 219

232 87 6 9 350

226 59 14 23 469

2022 (projected) 450 65 16 20 600

The majority of intakes, 97%, are directly trapped from the streets. However, on occasion, CSCA will take cats from vet clinics and shelters such as the RSPCA ACT and Queanbeyan pound when capacity allows.

The number of requests CSCA receives from the ACT community and other animal management organisations continues to increase. As of 28th March, CSCA has taken in 125 cats for the 2022 year, with the projected number of intakes estimated to be around 600 cats. This may be a conservative estimate due to the closure of a reputable Canberra based cat rescue expected to directly impact intakes for CSCA. The Domestic Animals Legislation Amendment Bill 2022, will require all cats born after July 2022 to be contained in their owners property. For unowned or semi-owned cats, they have no property to be contained to. As a result, Canberra Street Cat Alliance, and other rescues currently working on desexing street cats, will not be able to desex and take ownership of cats born after July 2022. As desexing and adoption go hand in hand, taking cats off the streets for adoption will also cease. All assistance requests made by ACT residents to Canberra Street Cat Alliance will subsequently be referred to Domestic Animal Services and the RSPCA.

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Cat Management Methodologies Current methods for controlling the community cat populations in urban areas include: • • • •

Kill (trap & kill, or destroy on site) Community cat desexing programs (trap, neuter, and return) Adopt Do nothing Figure 1 Options for managing unowned cat populations in urban areas unowned/semiowned cats

Kill

Destroy on site

Desex

Adopt

No action

Trap & Kill Trapping by public Trapping by rangers

The type of method used will depend on the resources available as well as on the acceptability of methods as viewed by the public. Historically, the ACT Government has chosen the ‘no action’ approach. Canberra Street Cat Alliance, and other rescues, have chosen desex and adopt. The ACT Cat Plan and relevant legislation will remove the option of desexing and instead has identified adoption as the primary way to deal with unowned and semi-owned cats, in line with its vision that “all cats in the ACT will be owned, wanted and cared for by responsible owners.” Unfortunately, adoption without desexing is not a feasible method for reducing the population of street cats. Each method will be discussed below.

Killing Destroy on site Destroy on site includes shooting or poisoning cats at their location. Such methods are not frequently utilised as a cat management strategy in urban areas largely due to community safety and attitude toward these lethal strategies.

As defined by the RSPCA in the ACT Cat Plan 2021 – 2031, semi-owned and unowned cats are either directly or indirectly dependent on humans and often located in urban environments. This means that shooting or poisoning on site poses great risk of injury or death to the local community. Destroy on site methods are unlikely to be deemed

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acceptable by the community as highlighted by the public outcry over the shooting of cats at the Port of Newcastle in 20207.

Trap & kill A trap and kill methodology has been widely adopted by Australian local government organisations as a cat management strategy for decades. Trap and kill involves unowned or semi-owned cats being trapped and taken to a shelter facility or veterinarian where they are killed. The trapping can be done by rangers or members of the community. Many councils in Australia, particularly in Victoria and Queensland, provide traps for the public to hire, either for a deposit or for free.

The resulting euthanasia numbers are high. The average euthanasia rate for cats in Victoria is 48% and councils frequently suspend their trap-lending programs when intakes become too high8 . In the ACT, the RSPCA used to do lend out traps for members of the public, however it has stopped this practice in recent years in an effort to limit cat intake numbers.

Trap and kill methodologies are resource intensive, with both financial and personnel resources impacted and require sustained work over several years to be effective.

Unfortunately, this methodology has had little success in reducing the cat population. To be effective, trap and kill needs to be done at a high intensity. Research which has modelled cat population dynamics suggests, to achieve attrition, at least 30- 50% of the stray cat population must be killed every 6 months for at least a decade9. For example, if there are 2,000 stray cats, that requires trapping and killing 600 to 1,000 every 6 months.

Trap and kill is currently used in an ad-hoc manner in the ACT. Members of the public source their own traps, for example by purchasing them or renting from Kennards Hire and take the cat into RSPCA. However, there is no systematic government funded trap and kill program in the ACT. The RSPCA 2018 report “Identifying Best Practice Domestic Cat Management” highlights the difficulties of trap and kill programs10: Trap and kill programs in peri-urban and urban areas are very difficult to effectively implement. Ineffective implementation results in failure to reduce cat numbers in the long term and consequently no significant improvement for issues of concern such as wildlife predation. The community is increasingly opposed to lethal cat control programs, particularly in urban areas.

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https://www.abc.net.au/news/2020-12-20/port-of-newcastles-stockton-breakwall-cat-cull-sparks-fury/13001868 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.

9 Miller, P. S., Boone, J. D., Briggs, J. R., Lawler, D. F., Levy, J. K., Nutter, F. B., ... & Zawistowski, S. (2014). Simulating freeroaming cat population management options in open demographic environments. PloS one, 9(11), e113553.

10 https://kb.rspca.org.au/wp-content/uploads/2019/01/Findings-and-Recommendations-Identifying-Best-PracticeDomestic-Cat-Management.pdf 8

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Our own longitudinal analysis of the Domestic Animal Management Programs (DAMPs) which each Victorian council is required to conduct, suggest that most councils have not seen any reduction in the level of stray or unowned cats being taken into shelters every year, despite the high level of support they provide to citizens to undertake their own trapping, and despite restrictions such as cat curfews. For example, in the Greater City of Dandenong, since the last DAMP was put into effect the number of cats impounded has increased rather than decreased. In 2015/16 495 cats were impounded, and 50% were euthanised. In 2020/21 the number of cats impounded was 665 and 56% were euthanised. The 2020/21 figures are lower than average for the last years due to COVID19 and suspension of cat trapping.

The lack of results from the public themselves trapping is outlined in the 2021-2025 DAMP which states:

….the cat over-population problem in Greater Dandenong comes not from owned, domesticated cat over breeding, but rather from the wild and semi-wild cat colonies.

This suggestion is further supported by the rate of de-sexing amongst owned (registered) cats, which sits at 98%.

Council records clearly indicate that there is an overpopulation of cats and that in the main these are un-owned ‘wild’ animals that can never be domesticated. It is Council’s view that current legislation is not designed to deal with this type of problem. It is also Council’s view that there is currently little State government support for addressing this problem.

For example, under current legislation, Council cannot engage in trap, neuter, release programs aimed at reducing the numbers of un-owned cats in the community. In other countries, spay/neuter release programs have proven effective as cats that are unable to breed consume some of the available food and thus reduce the food supply to breeding cats. This in turn reduces the number and the size of the litters.

The current legislative framework does not allow for this practice in Victoria. Research has shown that the size of a feral cat colony will increase relative to the food supply in the area and then remain fairly constant. Food supply is the main determining factor of colony size. The consistency of the number of impounded cats over the last few years would indicate that current practices are having little effect and further research is needed at the State and National levels, to investigate alternative strategies.”

Analysis of Brisbane City Council data also suggests that year on year the number of requests for traps, and complaints about wandering cats is increasing rather than decreasing despite the council conducting their own trapping as well as lending out traps to members of the public11.

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https://www.data.brisbane.qld.gov.au/data/dataset/animal-related-complaints

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Negative consequences for mental health In addition, trap and kill methodology poses negative implications for the mental health of veterinarians who are expected to perform lethal control on otherwise healthy animals.

Numerous studies have illustrated that performing animal euthanasia puts animal shelter workers at a high risk for compassion fatigue, burnout, and even suicide. There is a correlation between the live release rate of shelters and the incidence of secondary traumatic stress and burnout in animal shelter employees12. Veterinarians and shelter staff experience higher traumatic stress when they have the pressure of decision-making regarding which specific animals to euthanise or not. Another study of reactions of shelter staff to performing euthanasia found that sadness (83%), crying (69%), anger (57%), and depression (57%) were the most commonly reported staff reactions13.

Access to cats For trap and kill methodologies to work on a large scale it would require members of the public to trap cats, or for rangers to be informed about the locations of the cats in order to trap them. However, as caretakers of the cats have an emotional bond with them, they will be unlikely to contact government authorities if they are aware the cat will be killed.

For example, a survey done in the City of Melton in Victoria14, in preparation for its updated Domestic Animal Management Plan found that 73% of respondents would not take a stray to the pound for fear it will be euthanised, and 81% believed others would not take stray cats to the pound for fear they would be euthanised.

Desexing Desexing of street cats, commonly called Trap-Neuter-Return (TNR) can trace its beginnings to England during the 1950s. It then migrated to the United States and took hold in the 1990s. Since then, it has gained momentum worldwide and is increasingly being adopted around the world as a proven evidence-based model for management of unowned cats.

Across the world countries are increasingly enacting laws supporting or making TNR mandatory. In the United States, in 2013 a total of 240 municipal or county governments had enacted ordinances supporting TNR; a ten-fold increase from 200315. A regulation adopted in Chile in 2018 makes it mandatory for municipalities, to implement TrapNeuter-Return16. In Spain the Catalan Animal Protection Law prohibits the killing of healthy companion animals. Since 2007 the Barcelona city-council promotes the humane management of free-roaming cat population through a specific program including a municipal “Cat Neutering Center” (for free-roaming cats only). In France, a 2015 law has established colony management as the first option to control unowned cats population in France. In Toronto, Canada TNR, officially became part of the animal bylaw in 2013.

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Andrukonis, A., & Protopopova, A. (2020). Occupational health of animal shelter employees by live release rate, shelter type, and euthanasia-related decision. Anthrozoös, 33(1), 119-131.

13 Anderson, K. A., Brandt, J. C., Lord, L. K., & Miles, E. A. (2013). Euthanasia in animal shelters: Management's perspective on staff reactions and support programs. Anthrozoös, 26(4), 569-578.

14 Melton City Council (2021). Domestic Animal Management Plan, 2021-2025 https://www.melton.vic.gov.au/Regulations/Animals/Domesticanimal-management-plan 15 16

http://s3.amazonaws.com/tzi/resources/attachments/f48f203fe6ec6ab750c99668edb045904a342aeb.pdf?1386700458 https://www.alleycat.org/chile-makes-tnr-mandatory/

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In Australia, Melton City Council in Victoria17 is “developing an overall strategy for addressing cat and human welfare matters associated with stray/semi-owned cats based on proven and scientifically based trials and strategies”. They are optimising existing opportunities for desexing of cats regardless of animal ownership including with mobile desexing services, free and discounted desexing initiatives, and partnering with community-based initiatives.

Traditionally RSPCA Australia has been against desexing of community cats, however in February 2022 their Knowledgebase website was updated and now favours research to be conducted to evaluate whether, and under what specific circumstances, a program of trap, desex, adopt or return and support (TDARS) is an appropriate tool for urban cat management under Australian conditions.

As indicated by the 2018 RSPCA Report, Identifying Best Practice Domestic Cat Management in Australia, most research indicates that TNR is effective in that it can successfully reduce cat numbers and nuisance and result in the eventual extinction of cat colonies. The evidence also indicates that cats in managed TNR colonies have reasonable welfare if they are managed appropriately.

A selection of research studies conducted on desexing and adoption is shown below in Table 2. In contrast, there is not a single study or example of any program where trap-kill or trap-adoption alone has been effective in reducing the population of unowned cats in urban areas.

Desexing also has the advantage of reducing nuisance behaviour, including agonistic behaviour between males resulting in fighting and vocalisations. This also leads to fewer injuries and reduced transmission of fight-related infectious diseases18.

The RSPCA 2018 report on Identifying Best Practice Management highlights four major concerns in relation to the implementation of TNR programs in Australia: its potential effectiveness, the welfare of cats subject to TNR, the cost of implementation and the impact of cats on wildlife.

As the report notes, “most research indicates that TNR is effective in that it can successfully reduce cat numbers and nuisance and result in the eventual extinction of cat colonies. The evidence also indicates that cats in managed TNR colonies have reasonable welfare if they are managed appropriately. When it comes to cost, although substantial investments of both time and money are required, these costs diminish over time and both TNR and catch and kill programs require significant investment if properly implemented. Where TNR results in the reduction and eventual extinction of cat colonies, then wildlife impacts will also be reduced, but this aspect has not yet been properly assessed”.

Melton City Council (2021). Domestic Animal Management Plan, 2021-2025 https://www.melton.vic.gov.au/Regulations/Animals/Domestic-animal-management-plan 17

Finkler, H., Gunther, I., & Terkel, J. (2011). Behavioral differences between urban feeding groups of neutered and sexually intact free-roaming cats following a trap-neuter-return procedure. Journal of the American Veterinary Medical Association, 238(9), 1141-1149.

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Table 2 Selected studies on desexing and adoption Location San Francisco Bay Area, US

Method Desexing and adoption

San Jose, US

Desexing

Florida, US

Desexing and adoption

Rome, Italy

Desexing

Barcelona, Spain

Desexing

Auckland, New Zealand

Desexing

UNSW campus, Australia

Desexing and adoption

Australia

Desexing and adoption

Result Following desexing and adoption, of the 258 total cats enrolled in the program between 2004 and 2020, only one remained at the end of the program period.

Between 2010 and 2014 a total of 10,080 unowned cats were desexed and returned. Cat impounds decreased by 29%; euthanasia decreased from over 70% of intakes in 2009, to 23% in 2014. Dead cat pick up off the streets declined 20% A- 2year program was implemented to capture and desex at least 50% of the estimated community cats in a single postcode. 2,366 cats were captured. After 2 years, per capita shelter intake was 3.5 times higher and per capita shelter euthanasia was 17.5 higher higher in the non-target area than in the target area.

Between 1991 to 2000 almost 8,000 cats were desexed.

103 cat colonies saw an overall decrease of 22% in cat numbers. In 55 colonies the number of cats decreased, with 20 remaining stable: results showed that the larger colonies and those that had been operating longer tended to decrease in size. In 28 colonies the population increased, because of pet cat abandonment22.

Between 2009-2013, a total of 9,365 cats were neutered within the city council program and all stakeholders consider the program a success in terms of reduction of citizens’ complaints, control of cats’ population and improvement of cat welfare.

348 cats were desexed and returned in one target suburb.

Target suburb experienced statistically significant declines in cat intakes and euthanasia compared to a non-target suburb.

A nine-year desexing and rehoming program on at the UNSW campus reduced a free-living cat population from 69 to 15 cats An anonymous questionnaire was used to gather data on TNR of urban stray cats in Australia. Colony size was reported to have decreased from a median of 11.5 cats to 6.5 cats over 2.2 years, through adoption of a median of three cats or kittens per colony, and desexing a median of 69% of the colony. Cats were fed once or twice daily, and provided with prophylactic health care. Most colonies were in major cities, and at private residences, industrial sites, and streets or alleyways

Authors Sphehar & Peter (2020)19 Johnson & Cicirelli (2014)20

Levy & Scott (2014)21

Natoli, et al. (2006)

Dufau (2013)23

Zito, et al.

(2018)24 Swarbrick & Rand (2018)25

Tan, et al.

(2017)26.

Spehar, D. D., & Wolf, P. J. (2020). The impact of targeted trap–neuter–return efforts in the San Francisco Bay Area. Animals, 10(11), 2089.

Johnson, K. L., & Cicirelli, J. (2014). Study of the effect on shelter cat intakes and euthanasia from a shelter neuter return project of 10,080 cats from March 2010 to June 2014. PeerJ, 2, e646.

21 Levy, J. K., Isaza, N. M., & Scott, K. C. (2014). Effect of high-impact targeted trap-neuter-return and adoption of community cats on cat intake to a shelter. The Veterinary Journal, 201(3), 269-274.

22 In the ACT, cat abandonment at colonies is not an issue. In the last 8 years working across colonies we have not encountered any abandoned pet cats in the colonies.

23 Dufau, A (2013) http://carocat.eu/wp-content/uploads/2014/10/Management-of-urban-cats-in-Barcelona.pdf 24 Zito, S., Aguilar, G., Vigeant, S., & Dale, A. (2018). Assessment of a targeted trap-neuter-return pilot study in Auckland, New Zealand. Animals, 8(5), 73.

25 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.

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

19 20

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Adoption Adoption involves cats being trapped, placed into foster care, receiving mandatory vet treatment including desexing, vaccinating and microchipping, and socialised before eventually being adopted. Desexing and adoption strategies are used in conjunction by rescues. Street cats are humanely trapped, with kittens and suitable cats completing mandatory vet treatment being adopted out while the unsocialised adults are desexed and returned to be cared for outside. If adults are injured, sick or come from an unsafe location they are taken into foster care or relocated through the CSCA Barn Cat program.

Kittens are usually quick to socialise and adopt out. For cats that have gone through foster care with Canberra Street Cat Alliance, the average time to adoption depends heavily on their age at intake. On average cats that came in at 8 weeks or under are adopted within 2 months. Cats that came in at 9-14 weeks stay in care an average of 3 months. Cats that are trapped from the streets at age 6 months or over, stay an average of 9 months.

Unsocialised adult cats require very specific foster homes including: • • • • •

Households with no children No households with frequent visitors or loud environments Foster carers who are confident and willing to work with aggressive cats Foster carers who are willing to put up with the smell of male cats where the strong urine smell can take 3-4 weeks to dissipate after desexing Foster carers who are willing to care for the cat for an unlimited time, up to several years

Even adult cats that have gone through foster care will often remain shy and are therefore difficult to adopt out. The cats who remain timid are often promoted as ‘pet for pets’.

These are cats that may be shy with people but are good with other cats and therefore could be adopted as a companion/pet for an existing cat. For cats which are not good with other cats, and also not good with people the options are more limited. These cats may need to spend several years in care before they can find a home.

If a rescue were to take on 500 unsocialised adult cats every year, they would need at least 550 carers. Foster carers circumstances often change due to experiencing life events such as moving, having children or separation/divorce, making it vital to have an extra 10 percent back up carers for circumstances when a cat needs to be moved.

While adopting out kittens and a small number of unsocialised adult cats is feasible, scaling this up so that adoption becomes the only possible outcome for all unowned cats is not possible. This is due to the lack of foster carers and the poor socialisation prospects of many adult cats. There is no example of any local government that uses adoption alone to reduce the population of cat unowned or semi-owned cats.

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Summary of cat management methodologies.

Table 3 summarises the cat management options in urban areas based on public support, resulting euthanasia numbers, cost to government, feasibility, whether there has been research showing its effectiveness and the expected effect on cat numbers. Each option is based on targeting 50% of the cat population every 6 months.

Importantly public opinion is against lethal methods in urban areas.

In Brisbane, where there is a high rate of trapping and killing of unowned and semiowned cats, after being informed about trap, neuter, and return (TNR) programs for management of urban stray cats, most respondents (79%), chose TNR as their preferred management strategy, while a lesser proportion (18%) expressed a preference to continue the current Brisbane City Council lethal control program (catching and culling ~1,000 cats annually), and 3% selected to leave the cats alone27.

Table 3 Summary of cat management options for urban areas Trap-kill Public support Euthanasia numbers Cost to government Feasibility Research or examples of effectiveness Effect on cat numbers

Desexing

Adopting

No action

Low

Destroy on site Low

High

High

Low

High

High

Low

Low

Low

High

High

Low

Low

Low

Low

Low

High

Low

High

No

No

Yes

No

No

Reduction

Reduction

Reduction

Reduction

Increase

Note: Each option is based on targeting 50% of the cat population every 6 months.

Rand, J., Fisher, G., Lamb, K., & Hayward, A. (2019). Public opinions on strategies for managing stray cats and predictors of opposition to trap-neuter and return in Brisbane, Australia. Frontiers in veterinary science, 290.

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Community Consultation Report - Draft ACT Cat Plan 2019 – 2029 In 2019 the ACT Government released the draft ACT Cat Plan. To gauge community sentiment on cat management, community consultation was undertaken between 6 April to 3 July 2019. Four thousand and eighty seven survey responses were received, of which 3,884 were from ACT residents. One hundred and twenty written submissions from individuals and animal welfare groups were also received during the consultation period.

As published in the Consultation Report, “As the survey adopted an inclusive methodology, rather than a strict random sample, some caution needs to be exercised in extrapolating results to the broader ACT community28” The survey canvassed levels of support for cat management measures including: • • • • •

Cat registration Financial assistance for low-income cat owners Cat containment More domestic animal enforcement officers; and Increase in fines and penalties.

The consultation plan highlighted feedback from the community in relation to support for the management of semi-owned or unowned cats to be “treated humanely and with compassion”.

Support for trap, desex and return methodology was evident within the community responses with the improvement of desexing rates seen as the most crucial strategy to reduce the number of semi-owned and unowned cats.

The consultation report states many submissions supported further research regarding the impacts of cats on wildlife. Further research is encouraged due to the historic data being relied upon is no longer seen as relevant due to environmental differences over the last thirty years.

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ACT Environment, Planning and Sustainable Development Directorate 2019 Cat Management Survey FINAL 2 September 2019

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Concerns regarding the ACT Cat Plan 2021 – 2031 The ACT Cat Plan 2021-2031 lists just two action items to be implemented in relation to unowned and semi-owned cats.

Action 7 Provide information to the community to increase awareness about the environmental and welfare implications of abandonment and feeding wandering cats.

Action 8 Work with animal care and rescue organisations to manage semi-owned and unowned cats in public places, through trap, de-sex and adopt activities.

Action 7 is to be implemented in a 3-5 year time frame and involves community education campaigns incorporating messages regarding semi-owned and unowned cats, such as “what can happen if you abandon your cat” and “don’t feed cats you do not own”. Action 8 is also on a 3-5 year time plan.

While adoption in conjunction with desexing of street cats has been proven to be an effective strategy to reduce semi-owned and unowned cat numbers, adoption alone is not a known method that has been implemented anywhere. It is not possible to foster and adopt out the unsocialised cats at a scale large enough to see a reduction in numbers.

This has repeatedly been highlighted by cat rescues in their consultation with the government.

As such these action items provide no actual plan for how semi-owned and unowned cats are to be dealt with.

A major justification for the containment of cats, including owned and unowned cats is wildlife predation. As mentioned in the Message from the Conservator on page 3, “a Canberra research project1 estimated that free roaming but owned Canberra cats predated on 61,000 native birds, 2000 native mammals, 30,000 native reptiles and 6000 native frogs each year.”

These numbers are from a study that is nearly 30 year old, conducted in 1993-1994 among 138 owned cats in Canberra29. In the last 3 decades since that study was conducted the population, as well as the landscape of Canberra, has changed immeasurably in the last decades, including significant urban development. In the study the number of prey caught by cats, and their categories, were recorded for a 12 month period. From this data the total amount of prey was extrapolated based on multiplying the mean number of animals caught by the estimated owned cat population.

The estimated total number of pet cats used was approximately 50,000 owned free roaming cats back in 1993/94. This appears to be a very high figure. Even nearly 30 years later, based on the fact that at least 27% of households are estimated to own an average of 1.4 cats and assuming that one third of cat owners keep their cats contained at all times, then the figure even today for the ACT would be around 38,000 free roaming pet cats.

The author has a number of important caveats and warns against taking these numbers at face value. In particular, the author warns that the data is highly skewed. The majority of 29

Barratt, D. G. (1998). Predation by house cats, Felis catus (L.), in Canberra, Australia. II. Factors affecting the amount of prey caught and estimates of the impact on wildlife. Wildlife Research, 25(5), 475-487.

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cats caught very few prey, but a small percentage caught a lot. This leads to the mean being skewed. "Estimates of predation by house cats, particularly extrapolated estimates, should be treated with caution. The total number of prey caught by house cats in Canberra estimated using the sample median was approximately half the estimate based on the sample mean."

The author also notes that despite predation there did not seem to be a detrimental effect on the wildlife population. "Predation estimates alone do not prove that prey populations are detrimentally affected, especially in highly disturbed and modified environments such as suburbs. For birds at least, habitat-related factors may be substantially more important in determining community structure in suburbs than predation by house cats…..."

The ACT Cat Plan makes reference to several papers on feral cats, and on owned cats.

However, it contains no studies based on predation of wildlife among semi-owned and unowned cats, whether in managed or unmanaged colonies.

Unintended Consequences of the ACT Cat Plan 2021 – 2031 The ACT Cat Plan 2021-2031 will have major consequences should it be implemented in its current form. Rescues such as Canberra Street Cat Alliance will stop desexing (and adopting) street cats in the ACT resulting in an increase to the population of semi-owned and unowned cats. This will result in an increase in demand to organisations including DAS and RSPCA. This increase in turn will see an increase in kill rates of cats. However, this will not translate to a reduction in the street cat population as the trapping will be done on an ad-hoc basis and not reach the 50% of killing of the population every 6 months that is needed to reduce numbers.

1) Halting of desexing and adoptions of street cats, and subsequent increased population The implementation of the ACT Cat Plan 2021 – 2031 will have grave consequences for the Canberra Street Cat Alliance, a self-funded volunteer-based organisation pro-actively working with community cats.

Rescues such as Canberra Street Cat Alliance working with street cats will stop desexing and adopting out cats in the ACT. Desexing and adopting go hand in hand and it will not be possible for CSCA to continue adoptions without desexing a small percentage of street cats, to remain in their outside environment in the care of people who feed and look after them.

The result will be an increase in cat numbers.

The simulation study below, illustrates the potential effect on the cat population. Between January 2018 and March30 2022, CSCA took in 1,187 cats. Of those 51% were female and 49% were male.

Of the 1,187 cats we excluded 33 cats from the simulation which came from vet clinics, the RSPCA or the pound on the assumption that these cats would otherwise have been

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Up to and including 15th March 2022

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euthanised or rehomed, so whether or not CSCA existed, these cats would not have made a difference as they would not have reproduced regardless. This leaves 1,154 cats.

Cats were modelled from the month and year they were trapped until March 2022 or until they died.

Female cats are assumed to give birth from 9 months of age. Free-roaming cats produced an average of 1.4 litters a year, with a median of 3 kittens/litter (range, 1 to 6)31.

The average mortality rate was 75% by 6 months of age. Based on these figures the average female would have 4.2 kittens a year and only one of those would survive till 6 months of age. Simulation 1 was based on these estimates of reproduction and mortality.

Simulation 1: Each female gives birth to just 1 surviving kitten in February only. The sex of the kitten is randomly assigned to male or female, with a 50-50 chance of being either.

We also modelled if there were two surviving kittens per year.

Simulation 2: Each female gives birth to just 1 surviving kitten in February of each year and 1 surviving kitten in October. The sex of each kitten is randomly assigned to male or female, with a 50-50 chance of being either.

In both simulations, adult cat mortality is assumed to be 100% from 60 months of age (5 years old). The simulation was run in Stata/SE 16.1.

The results are shown below.

March 2022 March 2023 March 2024 March 2025

Simulation 1

Simulation 2

1 surviving kitten per year 2,137 3,170 4,416 6,144

2 surviving kittens per year 3,224 6,096 11,150 19,572

Even under simulation 1, had CSCA not desexed and rehomed those 1,154 cats in the last few years the population would have grown. By March 2025, even under very conservative parameters those 1,154 cats would have become over 6,000 cats.

2) Increase in ad-hoc trapping and killing, and additional pressure on DAS and RSPCA. Although the ACT Cat Plan has no action plans for implementing a trap and kill program for the ACT, it is likely that in the absence of any other solutions provided to them, members of the public will source traps and take cats to the RSPCA ACT. There is therefore likely to be a small increase in ad-hoc trapping and killing, but not to an extent where there will be any reduction in cat numbers unless a concerted trap and kill program is implemented.

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Nutter, F. B., Levine, J. F., & Stoskopf, M. K. (2004). Reproductive capacity of free-roaming domestic cats and kitten survival rate. Journal of the American Veterinary Medical Association, 225(9), 1399-1402.

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Most businesses in industrial areas, will not contact DAS or the RSPCA for fear of the cats being killed as they have an emotional bond with these cats.

The number of calls for assistance to Domestic Animal Services and the RSPCA will increase, and increased funding will be needed to deal with these assistance requests.

Recommendations 1. Five-year containment exemption Under Section 84AP of the proposed legislation, it is recommended a 5-year exemption be granted to CSCA for the following areas: Commercial – CZ1 – Core Commercial – CZ2 – Business Commercial – CZ3 – Services Commercial – CZ4 – Local Centre Commercial – CZ5 – Mixed Use Commercial – CZ6 – Leisure and Accommodation Industrial – IZ1 – General Industrial Industrial – IZ2 – Industrial Mixed Use

These relevant areas are marked in Figure 2.

This exemption would allow CSCA to continue desexing unowned and semi-owned cats in industrial and commercial areas, without the strict liability offence of ‘owning’ a cat born after July 2022 that is not contained.

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Figure 2 Proposed exemption zones for cat-containment

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2. Research projects on wildlife predation and community cat desexing Protecting wildlife from cat predation is one of the three main stated objectives of the ACT Cat Plan 2021-2031.

Given the main opposition to having unowned cats live outside is their impact on wildlife, it is recommended the ACT Government engage with relevant providers during the 5 year exemption period, to conduct an independent research project in relation to unowned cats.

As outlined in the Community Consultation Report, numerous submissions requested contemporary research given the data used in the ACT Cat Plan is dated and no longer considered relevant. Research based on ‘feral cats’ is not relevant given the unowned and semi-owned cats referred to in the ACT Cat Plan 2021 - 2031 are defined as domestic.

This research could rely on camera footage, stomach content analysis and scat analysis.

• • •

Stomach contents analysis for any cats deceased due to car collisions from industrial areas.

Scat analysis of cats living in managed colonies, and comparisons for cats in unmanaged colonies.

Not all prey is eaten, so also complement with cameras attached to cats

This research would provide an estimate of the number and types of prey being eaten (numerator). However, a survey of wildlife abundance in industrial and commercially zoned areas would also need to be conducted to provide the denominator for any such assessment.

To evaluate the success of desexing of street cats, data could be collated from intakes to the RSPCA as well as local cat rescues based on the location of capture. A successful program would be indicated by a reduction in intakes from commercial and industrial zones, as well as a reduction in number of complaints.

A five-year exemption and research program will provide the necessary information and data to allow the ACT Government to review the effectiveness of the ACT Cat Plan 2021 – 2031 as proposed under the Timeframes for Implementing actions.

3. Correct use of terminology Despite the published RSPCA definitions of cats on page 5, the ACT Cat Plan 2021-2031 uses inconsistent and incorrect terminology e.g. on page 12 referring to cats residing around rubbish tips as ‘feral’.

It is recommended the entire document is reviewed and amended accordingly prior to publication and/or implementation.

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4. Implementation of a subsidised ACT community desexing program As evident within the Community Consultation Report, it is strongly recommended the ACT Government implement a subsidised desexing program for low-income households.

CSCA recommends funding be granted under Strategy 1 – Promote responsible cat ownership - Action 3 Improve cat desexing rates

5. Government engagement with Canberra Street Cat Alliance It is recommended the ACT Government engage with CSCA in relation to provision of their ongoing requirements under Strategy 4 – Continuously improve domestic cat welfare and management practices, 12. Facilitate provision of adequate cat management/shelters to support finding and reclaiming of lost cats; adoption and rehoming; and compliance and enforcement.

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