HomeMy WebLinkAboutDocumentation_Workshop_Tab 02_04/01/2013 �� � � BestFriends
AN I MAL SOCI ETY
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July 24, 2011
The Honorable Ken Salazar
Secretary
U.S. Department of the Interior
1849 C Street, N.W.
Washington, D.C. 20240
Sent via certified mail and e-maiL• Kensalazar(a�ios.doi.gov
Re: American Bird Conservancy's recent requests regarding a feral cat management policy
Dear Secretary Salazar:
The American Bird Conservancy (ABC) recently sent you a letter on behalf of itself and other
groups it recruited, requesting that the Department of the Interior (DOI) develop a Department-
wide policy regarding feral cat management. ABC suggests using, as models for such a policy, a
2009 letter from a U.S. Fish and Wildlife Service (USFWS) New Jersey field office to the New
Jersey Department of Environmental Protection (NJDEP), and the proposed Florida Keys
Integrated Predator Management Plan, both of which call for eradication, either directly or
indirectly, by lethal means. This request by ABC and The Wildlife Society (TWS), the primary
signatories of the letter, is not unexpected given their vociferous opposition to non-lethal feral
cat control methods being used effectively by some states and many local municipalities and
endorsed by professional organizations such as the National Animal Control Association
(NACA).
As animal protection groups, scientists, wildlife protection organizations, veterinarians,
academics, animal control professionals, and attorneys, we request that if you (or a representative
from your office) meet to discuss this matter with ABC, you also meet with representatives of
our coalition. Unlike ABC and TWS, our coalition is made up of entities and individuals with
extensive background in, and experience with, feral cat management. In addition, we respectfully
request that DOI:
1. Refrain from issuing a Department-wide policy calling for the wholesale eradication of feral
cats from DOI land and/or opposing the Trap-Neuter-Return (TNR) method of feral cat
management. Such a blanket policy would defy scientific recommendations as well as the
agency's responsibilities under the Endangered Species Act (ESA). To comply with the ESA,
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a predator control plan must be site-specific, and attempting to eradicate feral cats in some
settings would lead to greater endangerment of protected species through the mesopredator
release effect.
2. Refrain from using the USFWS/NJDEP letter as a model for any feral cat management
policy, and instead, officially retract this letter as it misstates the law, misrepresents the
science, and also greatly oversteps USFWS' authority by asking a state agency to exceed its
legal jurisdiction in matters unrelated to federally—protected wildlife.
3. Refrain from using the Florida Keys predator control plan as a model for any feral cat
management policy as this proposed plan misrepresents both the science and the legal
arguments concerning the impacts of cats on wildlife.
4. Support model collaborations between wildlife experts, animal control experts, and animal
protection organizations to design non-lethal feral cat management programs with built-in
protections for wildlife, such as the protocols created by the New Jersey Feral Cat and
Wildlife Coalition.
Each request and its rationale are explained in detail below.
I. Agency-wide Policy
Pursuant to the National Environmental Policy Act (NEPA), any federal project or policy that
could significantly impact the environment must go through the Environmental Impact Statement
process. Under the ESA, federal projects are subject to comprehensive, site-specific reviews to
assess their potential impact on endangered and threatened species in the area. A Deparhnent-
wide policy calling for elimination of feral cats from all agency lands would violate the mandates
of these two policies, as the best available science clearly indicates that predator control policies
must be site-specific and based on a full analysis of the complex interactions among predators
and prey.
With regard to cats, analysis of such interactions must include not only the cats and any prey
species of concern in a particular location, but also the role of local "mesopredators" (e.g., black
rats, Norway rats, etc.) which may pose a greater threat to native wildlife. Inappropriate removal
of feral cats can lead to an explosion of inesopredator populations and a"trophic cascade"
resulting in large-scale devastation. This is not just a hypothetical matter; fragile ecosystems,
including a World Heritage island, have actually been destroyed by removal of feral cats. While
ABC and TWS are apparently not familiar with the extensive body of research on this matter,
scientists have repeatedly warned against jumping to remove feral cats from sensitive ecosystems
before fully understanding their role in the particular location (see Appendix A for studies on the
mesopredator release effect and feral cat management). As the authors of one study note, "such
strategies are not universally applicable. In some cases, it may cause a disastrous impact to
managed or natural ecosystems" (Fan, Kuang, & Feng, 2005).
Numerous studies on the mesopredator release effect indicate that any proposed actions to
remove feral cats from agency land (or adjacent parcels) be subject to careful, site-specific
analysis including, for example, population estimates (of both cats and suspected prey species)
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and dietary studies. It would be highly inappropriate—and, indeed, a possible violation of the
ESA—for the agency to impose a blanket, agency-wide policy that fails to take into account the
interactions of local species.
DOI lands are situated within different states and localities, each with its own laws, animal
control procedures, and public and cultural attitudes towards feral cat management. Rather than
imposing a top-down, one-size-fits-all approach to feral cat management, as requested by ABC,
the Department should recognize that feral cat control has always been—and should remain—a
problem best resolved in the context of local conditions, needs, resources, and priorities. Wildlife
veterinarians Michael Stoskopf and Felicia Nutter emphasize this point in the title of their 2004
article published in the Journal of the American Veterinary Medical Association: "Analyzing
approaches to feral cat management—one size does not fit all."
II. USFWS/NJDEP Letter
In November 2009, the New Jersey field office of USFWS sent a letter to NJDEP supporting a
New Jersey Fish and Game Council (FGC) resolution against free-roaming cats and municipal
TNR programs. Citing ABC "estimates," authors of the letter claim that feral cats kill hundreds
of millions of birds (in a circular fashion, ABC is now pointing to this document as evidence of
the need for an agency-wide policy!). The letter also claims that TNR programs do not work,
completely ignoring the many studies demonstrating its effectiveness (some of which are
described in Appendix B).
Moreover, the letter states that feral cats could kill endangered or migratory birds and that
NJDEP may be vicariously liable under the ESA and the Migratory Bird Treaty Act (MBTA) if it
does not take recommended actions, such as requiring universal licensing of pet cats and
outlawing municipal TNR programs throughout New Jersey. It is important to note that the FGC
member responsible for the resolution owns an impoundment facility for cats, and—shortly after
USFWS threw its support behind his initiative—was forced to recuse himself, and ultimately
resigned from the Council, based on his financial conflict of interest.
The letter (attached), and its claims and suggestions, are absurd and an abuse of federal authority
for a number of reasons.
Legal Authority/Jurisdiction
First, even if the factual claims in the letter were true, neither USFWS nor NJDEP has
jurisdiction to require statewide changes in domestic animal control practices. Neither agency
has the legal authority to control how municipalities handle the control of feral cats living, for
example, behind dumpsters in industrial parks and apartment complexes, or in residential and
nual areas where there are no cat-vulnerable species protected by federal or state law. Domestic
animal control in New Jersey is, by statute, in the hands of the New Jersey Department of Health
and Senior Services (DHSS) and—at a local level—municipal councils and boards of health. The
only jurisdiction that NJDEP could possibly claim over domestic cats is some choice of control
strategies on its own lands (though this would still be subject to state and local law), and
authority to require mitigation if a control method utilized in a particular situation were harmful
to a protected species actually present.
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The overbroad language that the New Jersey Field office used in its letter is equivalent to saying:
Development has the potential to harm endangered species; therefore, NJDEP may be in
violation of the ESA if it fails to prohibit development throughout New Jersey. This would, of
course, be absurd; whether or not development has the potential to harm a protected species
depends on whether it is in a location where such species exist, and whether it is handled in a
manner that will adversely affect the species.
Clearly, failure to prohibit development across the state does not violate the ESA or any other
federal laws; NJDEP, therefore, has no legal authority to issue such a prohibition. Likewise,
failure to require eradication of all outdoor cats across New Jersey (or any other state), prohibit
particular methods of animal control, or require cat licensing or leash laws does not violate the
ESA or any other federal law. To suggest that it does is a gross misstatement of law and misuse
of federal authority. DOI should not permit its field offices to take such liberties with state
agencies. Although NJDEP is undoubtedly aware of the absurdity of the New Jersey field
office's demands, it is our understanding that the field office continues to press them.
Scientific Claims
Beyond the legal absurdities of the letter, the claims made by the New Jersey field office are also
inaccurate scientifically, reflecting insufficient knowledge of feral cat population dynamics,
human dimensions, and the realities of municipal animal control resources and practices. The
letter also ignores entirely the extensive body of literature on the mesopredator release effect
(MRE) demonstrating that feral cats can actually be beneficial to native wildlife by controlling
invasive rodents—which often pose a greater threat to protected prey species than do cats (see
Appendix A for case studies). Moreover, the predation estimates cited in the letter are little more
than guesses and gross extrapolations (e.g., from very small samples of house cats to large
populations of feral cats, from one habitat or region to another, etc.).
While trying to convince NJDEP to take action against the many state municipalities that are
controlling feral cat populations through T'NR, the New Jersey field office egregiously overlooks
or ignores numerous scientific studies demonstrating the benefits of TNR (several of which are
described in Appendix B) as well as the real life success that the municipalities have had with
reducing feral cat populations through TNR Contrary to what has been suggested by ABC, TNR
has proven effective at reducing feral cat populations—and, in some cases, eliminating
colonies—over time.
The Realities of Municipal Animal Control
The New Jersey field office's position also ignores the realities of municipal animal control. As
Mark Kumpf, past president of the National Animal Control Association has stated, "there's no
department that I'm aware of that has enough money in their budget to simply practice the old
capture-and-euthanize policy; nature just keeps having more kittens." Traditional control
methods, argues Kumpf, are akin to "bailing the ocean with a thimble" (Hettinger, 2008).
Limited resources prevent a municipality from removing all free roaming cats; thus, any
remaining unsterilized cats continue to reproduce. Trapping efforts are further compromised
because citizens often refuse to report a cat's presence once they realize the animals will be
killed.
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More and more municipalities are realizing that lethal control is an inefficient use of resources,
and that the only way to effectively reduce the population of feral cats is to engage teams of
volunteers and private donations to trap more cats, remove kittens and friendly abandoned cats
for adoption, and minimize reproduction of the remaining cats. In New Jersey, such TNR
programs have been very successful: Englewood's health officer reports a 72 percent reduction
of feral cat numbers in 3 years; Morristown reports a 74 percent reduction in 5 years; and
Atlantic City and Cape May report 75-80 percent reductions over a decade. No municipality has
been able to accomplish such reductions without TNR. The New Jersey field office of USFWS,
in urging NJDEP to interfere with this effective practice, is working against its own stated goals
of reducing free-roaming cats for the benefit of wildlife, and severely overstepping its authority
and charge.
For these reasons, rather than considering the New Jersey field office's 2009 letter as a model for
an agency-wide policy, DOI should officially retract the letter and instruct the New Jersey field
office to stop pressuring NJDEP to take actions that are both beyond its jurisdiction and beyond
USFWS authority to require.
III. Keys Predator Management Plan
Like the USFWS/NJDEP letter, the Florida Keys Integrated Predator Management Plan—
released earlier this year in draft format—misrepresents the science and misstates the law
pertaining to feral cats and feral cat management. Most notably, the Plan overlooks the risk of
triggering the mesopredator release effect (Appendix A) by attempting to remove all feral cats
from its lands in the Keys, and dismisses TNR as an alternative option that could dampen such
effects, ignoring the numerous studies demonstrating its effectiveness in gradually reducing feral
cat populations (Appendix B). And the Plan—like the USFWS/NJDEP letter—overlooks the
potential impact of a large-scale removal/euthanasia effort on already-scarce resources.
Trapping feral cats is resource-intensive and its prioritization as a use for limited funds and
manpower is necessarily dependent on the issues specific to a particular site. Examples of
eradication efforts on islands are illustrative. On Marion Island (115 square miles in total area,
barren, and uninhabited), located in the South Indian Ocean, it took 19 years to eradicate
approximately 2,200 cats, using disease (feline distemper), poisoning, intensive hunting and
trapping, and dogs (Bloomer & Bester, 1992) and (Bester et al., 2002). We have been unable to
find any published figures regarding the cost of the project. On Ascension Island, eradication
efforts (�635 cats killed over 27 months) totaled GBP 650,000 (approximately $1.1M today)
(Ratcliffe et al., 2010).
The Florida Keys Integrated Predator Management Plan is also flawed in its lack of substance
supporting USFWS's position to trap and remove predator species. No predator density data has
been collected; nar has scat analysis been conducted to determine predator propensities. In fact,
the Plan provides no information whatsoever regarding the abundance and distribution of free-
roaming cats�learly the target of the proposed effort—on Refuge land. In addition, the Plan
lacks sufficient detail with regard to the extent of damage predator species are causing to the
ecosystem as a whole and, to endangered and/or native species in particular. The Plan, contrary
to what's been suggested by ABC and others, offers no scientific evidence to support a proposal
far predator removal.
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The Plan also lacks the necessary information, valid documentation, andlor evidence to show
that employing a lethal predator management program will be any more successful than previous
attempts. In 2003, when the USFWS office in the Florida Keys first tried to eliminate feral cats,
they spent $50,000 to trap 13 cats and they also inadvertently trapped hundreds of native wildlife
in the process. It is likely that in many areas, local FWS offices will—quite reasonably—
determine that such roundups are not the best use of funds allocated for the management and
protection of wildlife on the land they manage.
Contrary to what has been suggested by ABC, the Florida Keys Integrated Predator Management
Plan should not be used as a model for DOI policy regarding feral cat management.
N. Collaborations
In New Jersey, there is a momentous collaboration between the NJDEP, New Jersey Audubon
Society, New Jersey DHSS (which oversees animal control throughout the state), the Humane
Society of the United States, Animal Protection League of New Jersey, and Neighborhood Cats
(an advocacy organization based in New York City).
Over the past several years, the New Jersey Feral Cat and Wildlife Coalition developed a set of
model protocols and ordinances� designed to help municipal TNR programs in ensuring the
protection of any vulnerable native wildlife. The coalition then successfully tested the protocols
in Burlington County, NJ, developing a data set demonstrating its success. The protocols center
on the use of digital mapping and global positioning systems to determine where feral cat
colonies overlap territory with cat-vulnerable endangered or threatened species, consultations
with NJDEP when overlap occurs, and a menu of mitigation options that can be employed,
including TNR with increased monitoring, fencing, andlor removal or relocation.
This kind of collaboration is necessary, and represents the only hope for controlling and reducing
feral cat populations, as animal control expertise and the human and financial resources of
animal protection organizations are integral to the endeavor. USFWS should be supporting this
kind of collaboration and holding it up as a model for other states.
Instead of supporting this collaboration, however, the New Jersey field office of USFWS has
inexplicably been opposing it and pressuring NJDEP to end it. DOI should reverse this course of
action, and require the New Jersey field office to support the New Jersey Feral Cat and Wildlife
Coalition's efforts. Indeed, DOI should encourage such collaborations across the country.
. .
We thank you for your attention and consideration, and hope that you will meet with
representatives of our coalition before taking any Department-wide action on feral cat
1 New Jersey Feral Cat and Wildlife Coalirion (2007). Pilot Pmgram: Ordinance and Protocol,c for the Mana�ement of Feral Cat
Colonie.r in Wildl'fe-Sen.ritave Area.r in Burlington County, New Jerrey.
(http://urwu'.nei�hborhoodcats.or�r/uploads/File/Resc�urces/Urdinances/N�'���201�eralC;at&Wildlite%�2UOrdinance&Pr
otc�cols I'ilc�t 7 U7 duc).
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management issues. Please contact Laura Nirenberg, Legislative Analyst for Best Friends
Animal Society, if you are interested in meeting, or with any questions or requests for additional
information.
Sincerely,
Laura M. Nirenberg, Esq.
Legislative Analyst
Lauran@be stfriends. org
(219) 379-4401
And on behalf of:
Margaret R. Slater, DVM, Ph.D
Senior Director of Veterinary Epidemiology
Shelter Research and Development
Northampton, MA
Priscilla Feral
President
Friends of Animals
Darien, CT
Susan Richmond
Executive Director
Neighborhood Cats
New York, NY
Louise Holton
President
Alley Cat Rescue
Mt. Rainier, MD
Richard Alampi
Executive Director
American Association of Feline Practitioners
Hillsborough, NJ
Steve Hindi
President/Founder
Showing Animals Respect and Kindness
Geneva, IL
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Sydney Ross Singer
Medical Anthropologist, Author
Director, Good Shepherd Foundation
Pahoa, HI
Mark Kumpf, CAWA
Director
Animal Resource Center
Dayton, OH
Jack Murphy
Vice-President, Colorado Wildlife Control Operatars Association
President/Executive Director, Urban Wildlife Rescue, Inc.
Director, National Urban Wildlife Coalition
Denver, CO
Katherine McGill
Founder/Advisory Director
National Urban Wildlife Coalition
West Palm, FL
Patricia Knight
President
Songbirds of Northern Indiana, Inc.
Plymouth, IN
Anne Muller
President
Wildlife Watch, Inc.
New Palitz, NY
Susan J. Davis
Executive Director
WildCare Inc.
Bloomington, IN
Linda Brink
President
Sunnyskies Bird & Animal Sanctuary
Warwick, NY
Joe Miele
President
Committee to Abolish Sport Hunting
Las Cruces, NM
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Deborah L. Ackerman, MS, Ph.D
Dean of Research, Oregon College of Oriental Medicine
Portland, OR
Adjunct Associate Professor, UCLA School of Public Health
Los Angeles, CA
Verne R. Smith, Assistant Dean for Business and Administration
Widener University School of Law, Animal Law Professor
Chair, Animal Law Committee, Pennsylvania Bar Association
Adam W. Stern DVM, CMI-N, CFC
Clinical Assistant Professor
Section Head (Receiving)
Veterinary Diagnostic Laboratory
College of Veterinary Medicine
University of Illinois
Springfield, IL
Julie Levy, DVM, Ph.D, DACVIM
Professor
College of Veterinary Medicine, University of Florida
Gainsville, FL
Bernard E. Rollin, Ph.D.
University Distinguished Professor
Professor of Philosophy/Animal Sciences/Biomedical Sciences/LTniversity Bioethicist
Colorado State University
Fort Collins, CO
Priscilla Cohn, Ph.D
Professor Emeritus
Associate Director: Ferrater Mora Oxford Centre for Animal Ethics, Oxford, England
Founder/Director
PNC, Inc.
Editor: JAE (Journal of Animal Ethics)/Palgrave MacMillan Animal Ethics Series
Villanova, PA
Peter J. Wolf
Independent Researcher/Analyst
VoxFelina.com
Phoenix, AZ
Morgan E. Stewart, Ph.D
UCLA (epidemiology and biostatistics)
San Diego, CA
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Kim Pohle, MS RLATG
Animal Facility Supervisor - Purdue Ossabaw Facility
Purdue Comparative Medicine Center and Department of Cellular & Integrative Physiology
Indiana University School of Medicine
Dr. Millie P. Schafer
Public Health Molecular Microbiologist
Neighborhood Cat Helpers
Cincinnati, OH
Laurie Garrison
Executive Director
Monmouth County SPCA
Eatontown, NJ
Sy J Goldberg
President
Burlington County SPCA
New Jersey
Peter Muller
President
League of Humane Voters
New Palitz, NY
Richard Yocum
President
New Jersey Society for the Prevention of Cruelty to Animals
Donna Bainter
Director/Behavior and Animal Care
SPCA
Tampa Bay, FL
Susette Kamell
President
Pet Rescue
Larchmont, NY
Vanessa Wensing, DVM
Pleasanton, California.
Maureen Fehrs, DVM, MS
Michigan City, IN
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Kathy Hessler, J.D., LL.M.
Portland, OR
Jennifer Scarlett, DVM
Co-President
The San Francisco SPCA
San Francisco, CA
Laurie Crawford Stone, J.D.
Co-founder and past executive director
Animal Advocates of Iowa
Cedar Rapids, IA
Dana Gleason, DVM
President
Peninsula Fix Our Ferals
Shelter Veterinarian
San Jose Animal Care Center, San Jose, CA
Lee Roberts, DVM
FACE Low-Cost Spay/Neuter Clinic
Indianapolis, IN
Marilyn Weaver
Executive Director
League of Humane Voters-FL
Director, Feral Cat Coalition of Tampa Bay
Tampa Bay, FL
Nikki DesChamps
State Chairman
Indiana League of Humane Voters
Logansport, IN
Mark Dodge, Attorney
President
FixNation, Inc.
Woodland Hills, CA
Lisa Tudor
Founding Director
Indy Feral
Indianapolis, IN
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Connie Szawara
President
Independent Cat Society
Westville, IN
Sherry L. Silk
Executive Director
Humane Society of Tampa Bay
Tampa, FL
Dona Cosgrove Baker
President/Founder
Feral Cat Caretakers' Coalition
Los Angeles, CA
Deborah Weinrauch, Attorney
Directar
Friends of Culver Ciry Animals
Culver City, CA
Anne Gard, D.V.M.
The Cat Guardian Clinic
Oxford Junction, IA
Richard Speck, DVM
Board Member
Spay/Neuter Veterinarian
Animal Protective League of Springfield and Sangamon County, IL
Anja Heister,
M.S. Biology, Ph.D. Student Wildlife Conservation, Ethics & Policy
Missoula, MT
Lora O'Connor
Director
Humane Society of Western Montana
Missoula, MT
Marti Kheel, Ph.D,
Feminists for Animal Rights
El Cerrito, CA
Michelle Lemer, Attorney
Animal Protection League of New Jersey
Englishtown, NJ
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Susan Oakey
Treasurer
Animal Connection of Texas
Dallas, TX
Lynn M. Garfinkle
President
Animal Rights Alliance/Project Save-A-Cat
Cos Cob, CT
Devon Smith
Executive Director
Michiana Feral Cat Initiative
South Bend, IN
Frank Hamilton, Ph.D.
President
Animal Coalition of Tampa, Inc.
Tampa, Florida
Rick DuCharme
Founder/Director
First Coast No More Homeless Pets, Inc.
Jacksonville, FL
Nancy Allen
Executive Director
TriCountyTNR
West Lafayette, IN
Richard Warner, Attorney
Director
Responsible Pethood, Inc.
Marathon, FL
Morgana Washington
Founder/Director of Animal Care
Welcome Home Sanctuary, Inc.
Mid-Hudson Valley, NY
Bonney Brown
Executive Director
Nevada Humane Society
Reno, NV
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Stacy LeBaron
President
Merrimack River Feline Rescue Society
Salisbury, MA
Chris Bralick
President
Elkhart County Feral Cat Coalition, Inc.
Elkhart,IN
Elizabeth Ellis
President
The Feline Rescue Association
Baltimore, MD
Dona Cosgrove Baker
President and Founder
Feral Cat Caretakers' Coalition
Los Angeles, CA
Edwin R. Wilkinson
Vice President
Cats-R-Us Rescue
Annapolis, MD
Rebecca Poling
President
Companions For Life
Dallas, TX
Jerry Dykhuisen
Vice President
Forgotten Felines of the Florida Keys
Marathon, FL
Julie Royal
Founder
Royal Pet Rescue
Sarasota, FL
Diana Hensley
Founder and President
The O'Malley Alley Cat Organization
Nacogdoches, TX
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Eric T. and Julia C. Smith
Founders
The Alliance for Responsible Pet Ownership (ARPO); The Indiana Companion Animal Network
(I-CAN); and Indy Pets ALNE! Coalition
Indianapolis, IN
Rachael J. Jones, DVM -- (Veterinarian/Licensed Wildlife Rehabilitator)
Christopher J. Keeley, DVM
Southlane Veterinary Hospital
Valparaiso, IN
Gordon Stull, DVM
Founder/Director
Burlington County Cat Initiative
Burlington County, NJ
Laura Moretti
Founder/Editar & President
The Animals Voice
Chico, CA
Elena Mavros
Director
Pets In Distress, Inc.
Davie, FL
Elizabeth Johnson
Executive Director
Ohio Alleycat Resource and Spay/Neuter Clinic
Cincinnati, OH
Katherine H. Rich
Co-Founder
Alley Cat Project
Shoreline, WA
Helana A. Cichon
United States Fish & Wildlife (Retired)
Weeki Wachee, FL
Cynthia L. Flowers
Founder
Kitty City Foundation, Inc.
Tampa, FL
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Peg Nemoff, Donna Bernstein, Ruth Canan
Co-founders
Community Cats Maryland (CCMD)
Baltimore, MD
Richard Hall
President
Washington Alliance for Humane Legislation
North Bend, WA
Kevin J. Hyatt
President
Animal Protective League of Springfield and Sangamon County
Springfield, IL
Sue Gorman
President
Forgotten Felines, Inc.
Valhalla, NY
Marnie Miszewski
Executive Director
Helping Paws Animal Sanctuary, Inc.
Saint James City, FL
Jeffery Termini
President
League of Humane Voters of Western New York
Buffalo, New York
Elena Mavros
Director
Pets In Distress, Inc.
Davie, FL
Cathy O'Brien
Board Member
Save the Animals Foundation
Cleveland, OH
Eileen McDonnell
President
Hope for Animals
East Brunswick, NJ
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Jennifer K Doll, DVM
Director
Witty Kitties, Inc
Solon, IA
Dina Raymond
President
Feral Fanciers, Inc.
Lakeland, FL
Irene Mc Coy
President
Compassion for Cats
Shelton, CT
Katrin Hecker
Founder/Director
Animalkind, Inc.
Hudson, NY
Vivan Kiggins
Executive Director
Hi Tor Animal Care Center
Pomona, NY
Connie Henrici
President
Animals In Distress, Inc.
Wilton, CT
Eric Johnson
Executive Director
Animal Adoption Foundation
Hamilton, OH
Katherine Evans
President
Rude Ranch Animal Rescue
Harwood, MD
Robin A. F. Olson
President & Founder
Kitten Associates, Inc.
Newtown, CT
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Pam Brighton
President & CEO
Oasis Animal Sanctuary, Inc.
Williamstown, NJ
James C. Laney, Ph.D (retired)
Clinical Psychologist
Joan Star
Founder/Director
The Rescue House
Encinitas, CA
T. Wolak
President
Bully Baby Rescue, Inc.
Port Chester, NY
Amber Talbot
Director
PAWS and More
Washington, IA
Nadine Bechtel
Director
Animal Rescue Center
Cleveland, OH
Tara Waterlander, J.D.
Healthcare LL.M Candidate (2011)
Chicago, IL
Deborah M. Schmitt, Attorney
Tampa, FL
Kim Boggs
Attorney at Law
Chicago, IL
Raymond A. Nuzzo
Attorney
Law Offices of Raymond A. Nuzzo, LLC
East Haven, CT
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Appendix A: Mesopredator Release Effect Studies
Inappropriate removal of feral cats can trigger the dramatic increase in the populations of smaller
predators that are more damaging to ecosystems, a phenomenon known as mesopredator release
(Soule et al., 1988). Such "trophic cascades" can result in large-scale devastation, as illustrated in
the following examples.
Meta-Analysis
In their review of 61 studies (involving both terrestrial and marine environments), Ritchie et al.
report: "More than 95 percent of studies found evidence consistent with mesopredator release
and/or the suppression of inesopredators by apex predators" (Ritchie & Johnson, 2009). In
addition, the authors reviewed 20 studies that investigated the impact of MRE on the populations
of inesopredator prey, only two of which "showed no such benefit of inesopredator suppression"
(Ritchie & Johnson, 2009).
The authors argue that these examples "highlight that a better understanding of predator
interactions and functional roles within a whole of ecosystem context are crucial before wildlife
management is applied, to avoid unforseen [sic] deleterious effects. Failure to do so may result in
unexpected negative conservation outcomes which may also be extremely costly to fix" (Ritchie
& Johnson, 2009).
Ritchie et al. warn of the challenges involved in assessing specific ecosystems, especially those
associated with identifying top-down and bottom-up processes: "Potentially, habitat structure
and complexity, and food availability, may combine in a number of different ways, which in turn
may influence the outcomes of interactions between predators. At present, these effects are
poorly understood" (Ritchie & Johnson, 2009). The necessary long-term monitoring, however, is
"an obstacle for many conservation initiatives" (Ritchie & Johnson, 2009).
Mathematical Modeling of Mesopredator Release Effect Caused by Feral Cat Removal
In their seminal mathematical modeling work published in 1999, entitled "Cats protecting birds:
modeling the mesopredator release effect," Courchamp et al. conclude: "although counter-
intuitive, eradication of introduced superpredators, such as feral domestic cats, is not always the
best solution to protect endemic prey when introduced mesopredators, such as rats, are also
present" (Courchamp, Langlais, & Sugihara, 1999).
Fan et al. expanded on this work, developing a model that "overcomes several model
construction problems in Courchamp et al., and admits richer, reasonable and realistic dynamics"
(Fan et al., 2005). Results suggest "the existence of two types of inesopredator release
phenomena: severe mesopredator release, where once superpredators are suppressed, a burst of
mesopredators follows which leads their shared prey to extinction; and mild mesopredator
release, where the mesopredator release could assert more negative impact on the endemic prey
but does not lead the endemic prey to extinction" (Fan et al., 2005). Fan et al. acknowledge that
"in some cases, the control of cat [sic] has been proven to be effective in restoring some
endangered ecosystems," but warn that "such strategies are not universally applicable. In some
cases, it may cause a disastrous impact to managed or natural ecosystems" (Fan et al., 2005).
19
Gambino et al. expand the modeling further, incorporating "explicit spatial considerations,"
which, the authors argue, have been shown to "facilitate the persistence of populations in nature"
(Gambino et al., 2007). The authors maintain that the spatial relationships among cats, rats, and
birds are critical "because spatial arrangement affects the interactions between them. In
particular, clustering, when a single species densely populates a convex domain within the
lattice, is an important result of spatial arrangement. For example, when prey are clustered,
predators only have access to the perimeter of the clusters and not the entire prey population"
(Gambino et al., 2007).
"In some particular situations supporting the [Mesopredator Release Hypothesis]," Gambino et
al. write, "the presence of a controlled population of cats might be, at least temporarily, more
beneficial to the endemic existence of the prey, since the cats maintain the population of rats at
low levels. Although the cats also prey on the endangered species, the beneficial effects of
reducing the population of rats are superior relative to the damage done by predation to the
endemic species" (Gambino et al., 2007).
Real-World Examples
A 15 year cat eradication effort on Macquarie Island (49.4 square miles, uninhabited), a United
Nations Educational, Scientific and Cultural Organization World Heritage Site, concluded in
2000 with "unintended consequences [that] have been dire." Despite a simultaneous integrated
rabbit management effort, the rabbit population skyrocketed following removal of the cats,
devastating the island's vegetation and bird habitat. "The efforts towards management action to
control rabbits," observe Bergstrom et aL (2009), "which began in 1968 has been reversed in
only six years. ... Rabbit numbers on Macquarie Island have returned to pre-control levels and
this can be clearly ascribed to the removal of cats." Moreover, the authors estimate "that a pulse
of at least 103,000 mice and 36,600 rats have also entered the ecosystem since cat eradication. ..
The pace and spatial extent of the inadvertent trophic cascade precipitated by what appeared to
be a sensible and much-needed management intervention are remarkable and herald a waming
for other eradication programs" (Bergstrom et al., 2009). The Australian government is now
having to spend AU$24 million to try to eradicate the additional rabbits, rats, and mice.
On Christmas Island, (52 square miles, population: �1,400) researchers studying the diet of the
island's feral cats were surprised by their findings. Although cats had been implicated in
declining bird populations —and seabirds in particular—Tidemann et al. reported "no seabirds at
all were found in the guts of cats" (Tidemann, Yorkston, & Russack, 1994). "All of the animal
species that were found in cat guts are common on the island, despite predation by cats since
soon after settlement, and no evidence was found of consumption of species that are declining"
(Tidemann et al., 1994). Tidemann et al. suggested that the removal of cats "would probably lead
to an increase in the numbers of R. rattus, a species that itself can be a serious predator,
particularly of ground-nesting birds, that has caused declines or extinctions on many islands"
(Tidemann et al., 1994). Christmas Island, they concluded, "may well be a case of an oceanic
island where feral cats are beneficial to the management of native species" (Tidemann et al.,
1994).
20
On Raoul Island, a small (11 square miles) uninhabited island, Fitzgerald et. al. investigated
whether a feral cat eradication program would be beneficial or harmful. A study of the cats' diet
revealed that the cats primarily preyed on introduced rats (especially Pacific rats Rattus exulans)
and only rarely on the seabirds that the scientists were seeking to protect. Fitzgerald et al.
suggested, therefore, that removal of the cats posed a threat to the island's birds, especially the
sooty terns. "Unless it is possible to eradicate Norway rats as well as cats from Raoul Island,"
they argued, "the effort and expense involved in a cat eradication programme might be better
spent on other conservation projects that are more assured of a positive outcome" (Fitzgerald,
Karl, & Veitch, 1991).
On New Island (8.8 square miles, sparsely inhabited), part of the Falklands archipelago,
"Analysis of 373 feral cat scats showed cats' most frequent prey were three introduced mammals
(house mice Mus musculus, ship rats Rattus rattus and rabbits Sylvilagus sp.) and the thin-billed
prion" (Matias & Catry, 2008). Matias and Catry suggest it is conceivable that, because the cats
were eating so many of the other introduced predators and only very small numbers of prions,
"on the whole, cats are having a positive impact on the prion population, a scenario predicted by
general theoretical models." As a result, Matias and Catry did "not recommend the
implementation of any eradication programme on New Island that would target cats in isolation"
(Matias & Catry, 2008).
On Ascension Island (37 square miles, population: �880), cats were eradicated in an effort to
protect the island's population of sooty terns. Among the challenges were the island's size
(Ascension is the third largest island from which cats have been eradicated), the fact that the
island is populated, and the presence of pet cats (�70). On the other hand, as Ratcliffe et al. point
out, "The government land ownership of Ascension made obtaining access consent relatively
straightforward. This may be more problematic on islands subdivided into multiple private
ownership" (Ratcliffe et al., 2010). Between 2001 and 2004, approximately 635 cats were killed,
including "a large proportion of the domestic cat population... killed accidentally" (Ratcliffe et
al., 2010). Hughes et al. "have shown that predation by cats on breeding sooty terns ended in
2002 despite the fact that pet cats, some with feral origins, are found less than 5 km from the tern
colony" (Hughes, Martin, & Reynolds, 2008).
21
Appendix B: TNR Studies
1. In one of the very few controlled studies to compare sterilized/managed and
unsterilized/managed colonies of feral cats, researchers observed a 36 percent average
decrease among six sterilized colonies in the first two years, while three unsterilized colonies
experienced an average 47 percent increase (Stoskopf & Nutter, 2004). A four-year follow-
up census revealed that one colony had been reduced from 10 cats to none; at seven years,
another colony originally containing 10 cats had been reduced to one cat. In addition to the
steady population decreases observed among sterilized colonies during these censuses, data
show that sterilization of adults in the control colonies (which were initially left unsterilized)
was beginning to slow, and then reverse, initial population increases (Nutter, 2005).
2. A"no-kill policy" in Italy (dating back to 1991) has prompted the widespread
implementation of TNR in that country. A 2000-2001 survey of caretakers responsible for
103 cat colonies revealed a 22 percent decrease overall in the number of cats despite a 21
percent rate of "cat immigration." Although some colonies experienced initial increases,
numbers began to decrease significantly after three years of TNR: "colonies neutered 3, 4, 5
or 6 years before the survey showed progressive decreases of 16, 29, 28 and 32 percent,
respectively" (Natoli et al., 2006).
3. Between 1996 and 2002, a TNR program on the campus of the University of Florida reduced
cat population from 68 to 23, a reduction of more than 66 percent. The project, launched in
1991, involved the adoption of more than 47 percent of the campus' socialized cats and
kittens. Levy at al. emphasize the importance of adoptions and "an ongoing surveillance and
maintenance program" for "new arrivals" if TNR programs are to be successful (Levy, Gale,
& Gale, 2003).
4. Beginning in 2001, hysterectomy has been used to control the population of feral cats at the
Rio de Janeiro zoo. Between 2001 and 2004, "the estimated population became stable,
showing a trend to decrease" (Flavya Mendes-de-Almeida et al., 2006). Over the next four
years, estimated population numbers dropped 58 percent, from 40 cats in 2004 to 17 cats in
2008 (F. Mendes-de-Almeida et al., 2011). This is in contrast to the failure of prior trap and
kill efforts to eradicate the cats: `Before we started this work in 2001, the population of cats
of the RIOZOO suffered constant interventions but without a pre-established methodology
and only with the simple objective of eliminating the population. Therefore, the population of
cats fluctuated, the animals showed weak social relations and behavioral interactions
reflected by weak individual territorial defense, and this probably opened the way for high
migration rates."
5. Although the campus of the University of KwaZulu-Natal's Howard College (Durban, South
Africa) is recognized as an "urban conservancy" (i.e., "urban areas interspersed with
conservation-sensitive natural bush habitat and a nature reserve on the northern border"
(Tennent & Downs, 2008)), researchers were unambiguous in their recommendation that "a
suitable and ongoing sterilization programme, which is run in conjunction with a feral cat
feeding programme, needs to be implemented" (Tennent, Downs, & Bodasing, 2009) to
control the population of feral cats. Removal, on the other hand, would likely create the
"vacuum effect," thus "encourag[ing] subsequent reinvasion of the area. It may be more
22
costly both financially in the long-term and in terms of effects on the indigenous wildlife
populations if immigration of new, unsterilized cats were to take up residency on the
campus" (Tennent et al., 2009).
6. A 2008 review of the literature on feral cats and feral cat control, including several studies of
TNR, emphasizes the importance of context in effective management: "when considering
feral cats, one solution does not fit all situations because all situations are different"
(Robertson, 2008). Robertson found ample "scientific evidence that TNR under certain
conditions can control the feral cat population, and is a viable, humane alternative to other
methods previously used," and recommends "continued and increased funding (by private
welfare organizations and by municipal and government agencies)... for long-term success"
(Robertson, 2008).
7. A 1999 survey of "101 individuals or couples who cared for 132 colonies of free-roaming
cats in north central Florida" revealed that approximately 70 percent of respondents' colony
cats were sterilized, resulting in a"26 percent decrease in the overall cat population [from
920 to 678] over a median period of 18 months" (Centonze & Levy, 2002).
There have also been many unpublished successes with TNR, including in areas with sensitive
wildlife. In San Francisco's Golden Gate Park, the cat population was reduced from 85 to 2
through TNR. The New Jersey Division of Fish and Wildlife and New Jersey Audubon Society
have collaborated with TNR organizations on a successful pilot project for protecting sensitive
cat-vulnerable wildlife near TNR colonies. The project focuses on the analysis of interactions
between cats and vulnerable species in a given area and options for barrier fencing, limited
removal or relocation, TNR, and patrolling of buffer zones.
�
` New Jersey Feral Cat and Wildlife Coalition (2007). Pilot Program: Ordinance and Protocol.r for the Management of Feral Cat
Colonier in Wildlife-Sen.ritiveArea.r in Burlington County, 1VetvJer.cey.
(http://w hborhoodcats.or�/uplo�ds/File/Res<>urces/C)rdinances/N�°'��3OFcralCat&��'ilcllife"i��2UC)rdinance&Pr
otocols Pilot 7 07 �joc).
23
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Centonze, L. A., & Levy, J. K. (2002). Characteristics of free-roaming cats and their caretakers.
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mesopredator release effect. Journal of Animal Ecology, 68(2), 282-292.
Fan, M., Kuang, Y., & Feng, Z. (2005). Cats protecting birds revisited. Bulletin of Mathematical
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fuscata on Ascension Island, South Atlantic. Ibis, ISO, 122-131.
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on breeding seabirds. Polar Biology, 31(5), 609� 16.
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Management of feral domestic cats in the urban environment of Rome (Italy). Preventive
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Colonies: Population Dynamics, Home Ranges, and Potentially Zoonotic Diseases. North
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biodiversity conservation. Ecology Letters, 12(9), 982-998.
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size does not fit all. Journal of the American Veterinary Medical Association, 225(9), 1361–
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Tennent, J., & Downs, C. T. (2008). Abundance and home ranges of feral cats in an urban
conservancy where there is supplemental feeding: A case study from South Africa. African
Zoology, 2, 218-229.
Tennent, J., Downs, C. T., & Bodasing, M. (2009). Management Recommendations for Feral Cat
(Felis catus) Populations Within an Urban Conservancy in KwaZulu-Natal, South Africa. South
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Christmas Island, Indian Ocean. Wildlife Research, 21(3), 279-286.
25
system of veterinary education, a swine systems class at Colorado tion to occur, close contact with
with equine and companion animal State University. Most of the stu- fecal material is necessary, such as
practice taught in the traditional dents, in describing their ideal start- by direct handling.
way and FAP taught in a consulta- up swine business, included the ln addition, recent surveillance
tive way. As we consider the future latest in confinement technologies, studies have found the prevalence
of veterinary medical education, although there were concessions to oE intestinal parasitism in cats is
we must consider carefully whether animal wellare, such as outside ex- low. A study' of fecal samples from
this is the path we wish to take. ercise pens, in one case. Interesting- 4 northern California shelters
Eugene JanZen, DvM, Mvs ly, of all the presentations, only one found the prevalences of Giardia
Faculty of Ueterinary Medicine showed a paper profi�, and this was spp and Cryptosporidium spp to
University of Calgary by a student who mostly eschewed be 9.8% and 4.7%, respectively. In
Calgary, AB, Canada use of confinement practices for an New York State, a similar studyj
extensive setup. Bill Niman of Ni- also found the prevalences of these
man Ranch has proved that exten- parasites to be low (73% and 3.8%,
Balaneing profit and animal sive humane production of swine respectively).
W@IfBPe I11 SWltl@ pl'OduCt1017 can be profitable. The bottom line And mos[ importantly, recent
l want to comment on the is that �here are things that can be genetic epidemiology studies have
May 1, 20] 0, JAVMA News article done to maximize goals of animal found that subspecies of Giardia
"Protecting pigs, cultivating con- health, wel[are, and profit. and Cryptosporidium are host spe-
sumers."' In that article, Dr. Paul M. Lynne Kesel DVM cific. Dogs and cats are cammonly
R. DuBois' presentation at the 41st Department of Animal Sciences infected with Cryptosporidium canis
Annual Meeting of the American College of Agricultural Sciences and Clyptosporidium felis, whereas
Association of Swine Veterinarians Colorado State University human infections are associated with
was summarized with the follow- Fort Collins, Colo Cryptosporidium parvum and Crypto-
ing: "Food production rules are be- sporidium homini. Similarly, geno-
ing shaped on the basis of emotion 1. Cima G. Protecting pigs cutct�ai- typing data suggest transmission of
he said, citing as examples referen- iag coasun,ers.� Am uet ,�ed nsso� iardiasis ma be anthro onotic.�'
2010;236:932-934. g y p
dums and laws regarding confine- I agree with Dr. Jessup that
ment animal housing. Veterinarians TNVR alone is not the answer.
need to base their arguments on Thoughts on feral cat eontrol However, trapping and removing
science but must also provide a As an epidemiologist, I dispute cats has not been found to be ef-
message with emotional impact, the comment by Dr. David Jessup fective. As long as the environment
Dr. DuBois said. He said they need reported in a recen[ JAVMA News supports a certain population size,
to be ready to phase out practices anicle' regarding the human health sexually intact females will con-
for which they cannot explain the impacts of feral cats. I believe he tinue to breed and other animals
henefits in emocic,nal cerms." overestimates the public health will move in. For example, before
Aren't we more sophisticated risks associated with feral cats. a TNVR program began at a colony
than ascribing emotion to obviously Although trap-neuter-release is the near a hospital in Los Angeles
ethical concerns? Confinement common name for such programs, County, there were as many as 300
housing oE swine involves welfare in truth they are trap-neuter-vao- cats. The hospital would trap and
concerns, and welfare is an ethical cinate-release (TNVR) programs. remove them every 6 months, and
consideration. Is it right or wrong Sick cats are removed from the during each 6-month interval, the
to house adult sows in gestational environment, and the proportion number of cats and kittens doubled
crates most of their adult lives? Does of healthy animals is increased so or tripled. The current number of
it violate their natures? I think few that the risk of disease transmis- cacs is now down to 52.
veterinarians would like to see pet sion is lowered. As long as more pets are born
dogs kept in such a manner, and At the April 15, 2010, joint than can be adopted, there will
swine are considered more intelli- meeting of the California Con- always be abandoned animals,
gent than dogs and, therefore, more Eerence of Local Health OEficers humanitarians who feed them, and
likely to suffer psychologically in Communicable Disease Control and compassionate veterinarians who
such a system. I believe that confine- Environmenta] Health Committees, discount their services. To achieve
ment systems have reduced or elimi- Dr. Ben Sun, state public health the goal of smaller, healthier
nated many endemic swine diseases veterinarian, stated the public colonies that do shrink over time,
and improved survivabiliry, thereby health risk from feral cats is low. a coordinated effort is needed that
supporting profits. But confinement Dr. Sun noted that it is impossible supparts TNVR programs, encour-
systems need to be examined for a to separate out the potential risks ages pet adoptions, promotes spay
halance hetween profit and animal of exposure to the feces of feral cats and neuter laws, and discourages
welfare. I don't think the public will from the risks of exposure to feces animal dumping. Most importantly
accept the production oF cheap pork from pet cats and dogs. In fact, from a public healch perspective,
as the only goal in swine production, Dabritz et aP estimated that pet cats pet owners and the general public
and the public passes the laws. allowed to roam were responsible must be made aware of the need
I recently was a guest during for 72% oE outdoor fecal mass from for proper sanitation and good
the presentation of class projects for cats. Furthermore, for cross-infeo- hygiene.
26 Views: Letters to the Editor JAVMA, Vol 237, No. 1, July 1, 2010
Deborcth L. Acherman MS, PhD pets, wildlife, and water pollu[ion. f Am 5. Hunter PR, Thompson RCA. The
School of Pubiic Health Ve[ Med Assoc 2006;229:74-81. zoonotic [ransmission of Giardia
Untverstty Of CClllf ornia-Los Angeles 3. Mekaru SR, Marks SL, Felley AJ, et al. and Cryptosporidiuum. Int J Parasitot
Los Angeles CQlif �-Omparison of direct immunofluores- 2005;35:1181-1190.
cence, immunoassays, and �ecal [lota- 6. Thompson RCA, Palmer C5, O'Handley
Oregon College o f �YlentCll MedlCirie tion Eor detection of Cryptosporidium
PoYtlQrid, �Ye spp. and Giardia spp. in naturally R. The public health and clinical
exposed cats in 4 Northern CaliFor- significance of Giardia and Crypto-
1. Nolen RS. Economic study estimates nia animal shelters. J Uet [ntern Med sporidium in domestic animals. Uet J
costs of feral cat control. J Am Vet Med 2007;21:959-965. z008;177:18-25.
Assoc 2010;236:ll62. 4. Spain CV, Scarlett JM, Wade SE, et al. �� Xiao L, Fayer R. Molecular charac-
2. Uabritz HA, Atwill ER, Gardner IA, Prevalence of enteric zoonotic agents in terisation of species and genotypes of
et al. Outdoor fecal deposition by cats less than 1 year old in central New Cryptosporidium and Giardia and as-
free-roaming cats and atti[udes oI cat York 5[ate. J Uet Intern Med 2001;1533— sessment of zoonotic transmission. IntJ
owners and nonowners toward stray 38. Parasitol 2008;38:1239-1255.
JAVMA. Vol 237, No. 1, July 1, 2010 Views: �etters to the Editor 27
Frequently Asked Questions
What is trap/neuter/return?
Trap/neuter/return is a humane, non-lethal alternative to trap and kill ...
Trap/neuter/return (TNR) is a comprehensive management plan in which homeless, free-
roaming (community) cats are humanely trapped, evaluated and sterilized by a licensed
veterinarian, vaccinated against rabies, and then returned to their original habitat.
What is the primary benefit of TNR?
TNR lowers the numbers of cats in the community more effectively than trap and kill
in the long term...
Good Samaritans in neighborhoods all across the country provide food, water, and
shelter for community cats and TNR provides a non-lethal, humane way to effectively manage
these community cat populations. In some programs, friendly cats or young kittens are
customarily pulled from the colony and sent to foster facilities for socialization and, eventually,
placement into forever homes. Stopping the breeding and removing some cats for adoption are
more effective than trap and kill in lowering the numbers of cats in a community long-term.
What are the other benefits of TNR?
The benefits to both cats and communities are numerous ...
There are numerous benefits to TNR. For instance, TNR significantly reduces shelter
admissions and operating costs. These programs also create safer communities and promote
public health by reducing the number of unvaccinated cats. TNR programs also improve the
lives of free-roaming cats: When males are neutered, they are no longer compelled to maintain a
large territory or fight over mates, and females are no longer forced to endure the physical and
mental demands of giving birth and fending for their young. Additionally, fewer community cats
in shelters increases shelter adoption rates as more cage space opens up for adoptable cats.
Furthermore, sterilizing community cats curtails population growth while alleviating nuisances.
Another beneficial component to TNR is the impact these programs have on animal
control officers and shelter workers. Job satisfaction among these workers increases
tremendously when the job does not entail unnecessarily destroying healthy animals for the
purpose of convenience. This increased job satisfaction results in less employee turnover and an
overall improved public image of the shelter itself. The reduction in euthanasia and animal
admissions also provides more time for staff and volunteers to care for resident animals and give
personal attention to potential adopters.
Equally important, TNR programs allow animal control facilities to take advantage of
numerous resources typically unavailable to shelters that employ traditional trap-and-kill
policies. Understandably, people are rarely inclined to volunteer for programs that fail to make
them feel good about themselves. Through the implementation of TNR, volunteers know they
are making a difference in the lives of the animals, and the community is benefiting from their
charitable efforts. Volunteers can help trap cats and also assist animal control in locating other
cats in need of TNR services. Commonly referred to as caregivers, these volunteers also feed and
monitor the health of the individual cats and the colony, when applicable, once the cats are
returned. Frequent monitoring is an invaluable component of successful TNR programs because
caregivers can easily identify new cats who join the colony so they, too, can be sterilized,
vaccinated and ear-tipped. Another component of a well-managed TNR program is the collection
of critical data that can be used to seek grant funding for expansion of current TNR programs.
What happens if you trap an owned pet cat?
All unidentified cats who roam off their property are treated equally ...
TNR volunteers and/or veterinarians will typically examine all incoming cats for owner
identification. In most programs, unidentified animals are treated as if they are part of the TNR
program and are physically evaluated, sterilized, vaccinated, ear-tipped and returned to their
territory, where they can easily be reunited with their owners. Sterilizing owned cats who roam
off their property and frequent community cat colonies is an important component to the success
of any TNR program, since all free-roaming, unsterilized cats contribute to the overpopulation
problem.
Why is TNR preferable to lethal control?
TNR is a practical solution to the failed trap-and-kill policy ...
Lethal control has been used for more than three decades, and given the current problem
of large populations of free-roaming cats, it is obvious that killing as a form of animal control
does not work. Equally important, killing homeless animals as a means of population control is
publicly unpalatable. By contrast, TNR puts an end to this perpetual cycle of death and makes it
possible to maintain a colony at a relatively stable number of sterilized cats, who are unable to
breed and multiply.
Why does the trap-and-kill method fail to curtail free-roaming cat populations?
Populations rebound to previous levels following trap and kill ...
Every habitat has a carrying capacity or, more specifically, a maximum species
population size that can be sustained in that habitat. This carrying capacity is determined by the
availability of food sources, water, shelter, and other environmental necessities. When a portion
of the sustainable population is permanently removed and the availability of resources is
unaltered, the remaining animals respond through increased birthing and higher survivability
rates. Because of this biological certainty, trapping and removing cats from any given area does
little more than ensure that the cat population will rebound to the same level as before,
necessitating additional trapping and killing. While lethal control may arguably rid an area of
cats temporarily, it is not an effective long-term solution because new cats will quickly fill the
vacated area and breed, resulting in a perpetual cycle of killing.
What is the actual cost savings of TNR over the traditional trap-and-kill method of animal
control?
Communities can save tnxpayer money with TNR ...
The city of Jacksonville, Florida, is a fine example of an area that has capitalized on non-
lethal alternatives for controlling free-roaming cats. Over a three-year period (2006-2009),
Jacksonville saved approximately 13,000 lives and $160,000. Equally important, feline nuisance
complaints decreased during this period.
The Feral Fix Program in Salt Lake City, Utah, has also proven to be quite successful.
From 2008 to 2010, Salt Lake City's "save rate" of cats improved 40.4 percent, equaling a total
cost savings of approximately $65,000. Shelter cat intake for the years 2009-2010 decreased 21.8
percent. During this same period, there was no increase in feline nuisance complaints.
Communities can save money with TNR, but the cost savings are undoubtedly location-
specific and involve taking into account numerous variables for an accurate calculation. The
immediate savings many communities experience are a result of tapping into volunteer support
and other resources (e.g., private donations) that come from implementing a humane TNR
program. Cost savings fluctuate based on the type of TNR program implemented, the extent of
animal control involvement, the volunteer base available and the community's support of TNR
programs. The point that needs to be stressed, however, is that over time, through attrition and
sterilization efforts, fewer cats will be breeding and contributing to the population growth. Fewer
live animals to contend with inevitably means a decrease in the demand on ta�cpayer dollars.
Until a TNR program begins, it is difficult to calculate accurately how much money will
be saved. However, other benefits are equally important. A successful TNR program can
improve the public image of a town, which may add to economic development. Employee
satisfaction within the shelter and animal control facilities is also a huge asset and contributes to
a positive image of the community. The hometown pride and enthusiasm generated from
supporting a non-lethal, practical and effective solution to a community problem must be
factored into the equation, even though it doesn't provide precise numbers in terms of cost
savings.
Are there any tools to help keep community cats out of designated areas?
Non-lethal deterrents for cats are effective and easily accessible ...
There are numerous cat deterrents available on the market today. The following YouTube
video discusses each one of these products: I�tt��:%i��������.��outube.cumi�ti�atch?���—�ilnOib��nY�
Why are feeding bans ineffective?
� It's bad public policy to criminalize kindness ...
Feeding bans are notoriously ineffective, primarily because they are impossible to
enforce. Also, human nature rarely allows someone to sit idly by while an animal suffers. When
a starving animal appears, compassion prevails. Consequently, people will not adhere to an
ordinance discouraging the feeding of animals in need, and criminalizing kindness is just bad
public policy.
Hungry cats can continue to reproduce, which further undermines the intent of most
feeding prohibitions. Equally important, feeding bans jeopardize the ongoing sterilization and
vaccination services provided by caregivers who diligently maintain and monitor cat colonies in
the community. It is also important to note that once feeding by humans is prohibited, hungry
cats are forced to physically compete with wildlife over available, natural food sources.
What about liability to the towns or municipalities that implement a TNR program?
There could be liability for towns or municipalities that DON'T implement TNR
programs ...
Many free-roaming cats are unsocialized and tend to avoid people whenever possible.
This lack of human contact minimizes the likelihood of liability or negligence that may result
from human exposure. Also, in a TNR program, community cats are vaccinated against rabies so
the probability of a person being severely injured is quite remote.
Liability should not be an issue for towns or municipalities that implement TNR
programs for the purpose of reducing cat populations, protecting public health through
vaccination efforts, or resolving nuisance complaints. These are all state interests worthy of
government involvement. Also, animal owners are responsible for any alleged damage caused by
their animals' activities or behavior. In the case of community cats, there are no owners, so there
is nowhere for liability to be placed.
The question that often comes up when the issue of liability is raised is this: What
happens if a town fails to adopt a TNR program, and a child gets bitten by an unvaccinated, free-
roaming cat? Is the town then liable because it rejected TNR, since this failure to act may be
deemed negligence? Again, it can be argued that the cat is not owned; however, the obvious
concern in this scenario is that the outcome can potentially be far more tragic.
What are the advantages of adopting a TNR ordinance?
An ordinance grants credibility to any TNR program ...
When crafted properly, a TNR ordinance establishes reasonable standards and defines
duties for those individuals instrumental in implementing a community cat program. This type of
legislation grants credibility to TNR, promotes community involvement and encourages
community cat caregiver cooperation. Equally important, well-crafted legislation will insulate
community cats from licensing requirements, feeding bans, pet limits, or other punitive laws that
often impede the progress of sterilization efforts and public health protection. Grant funding is
available for TNR programs, specifically in those situations where TNR ordinances have been
adopted, as this legal assurance speaks volumes about the level of community support and
involvement.
How serious of a threat are cats to bird populations?
TNR means fewer cats which means fewer threats to birds. Other factors pose more
serious threats to bird populations ...
According to Cornell Lab of Ornithology's webpage entitled "Threats to Native Birds"
(bircl5,l����>>�.11.�cf�����llAt�uut_13r��1�;'c��A���_x�-y�,,tiui�.��i,,�i31�i���,�Ql�rc<Ets), the largest threat to birds is loss
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(or degradation) of habitat, which results from human development and agriculture. Other
significant hazards to bird populations include chemical toxins and direct exploitation from
hunting and capturing birds for pets.
There are no studies that show conclusively that pet cats are responsible for declines in
wildlife populations. In fact, according to Yolanda van Heezik, who wrote "A New Zealand
Perspective" (The Wildlife Professional, Spring 2011), "It's unclear as to what extent declines of
wildlife can be attributed to cats versus other human-related modifications to landscapes."
Although no studies support the misleading claims that cats are destroying songbird populations,
there's no disputing that cats do in fact kill birds. The point that must be highlighted, however, is
that fewer cats mean less bird predation. That being the case, TNR should not be condemned
because of potential wildlife predation, but rather embraced so that free-roaming populations can
be curtailed as efficiently as possible to minimize potential predatory behavior.
Why have TNR programs become so popular?
Trapping and killing homeless animals is ineffective in reducing free-roaming
populations ...
TNR programs are being adopted by towns and municipalities across the nation out of
necessity and good common sense. As evidenced by three decades of trapping and killing, lethal
means for controlling homeless animal populations is not the answer. This paradigm shift is
being seen on many municipal levels as budgets continue to be slashed in the animal control
industry. This evident need for better tools to handle animal control issues has led to a
philosophical shift in the animal control industry itself. In fact, according to Mark Kumpf, 2010
president of the National Animal Control Association, "The cost for picking up and simply
euthanizing and disposing of animals is horrendous, in both the philosophical and the economic
sense." The entire article from which his quote is drawn can be found here:
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Does TNR encourage the abandonment of cats?
Cats will be abandoned with or without TNR ...
Unforlunately, cat abandonment does occur. In fact, cats have been abandoned for as
long as people have had pet cats, which is why TNR is necessary today. These periodic
abandonments, however, will not derail the overall success of a TNR program because cat
colonies can absorb the occasional newcomer yet still show a significant population reduction
when the majority of the animals are sterilized.
It's also important to stress that maintaining a local TNR colony is likely not the
determining factor behind whether someone abandons a pet or not. Surely there are a variety of
other issues that factor into this irresponsible behavior. However, efforts should be made to place
feeding stations in out-of-the-way locations to minimize the likelihood of desperate people
illegally abandoning their pet cats. Other strategies should also be employed to further reduce
potential abandonment like posting abandonment ordinances at high-profile cat colonies.
Do cats pose a risk to public health?
Humans contracting a disease from a cat is quite unlikely ...
According to the Centers for Disease Control and Prevention (CDC) website, people are
not likely "to get sick from touching or owning a cat." As stressed above, free-roaming cats tend
to avoid human contact. This natural avoidance of humans makes the likelihood of disease
transmission quite remote. The CDC also provides simple health tips to minimize potential
exposure, such as washing hands with soap and water after touching feces or after being
scratched or bitten. The agency also recommends that cats be vaccinated against rabies — which
is a key component to most T`NR programs.
Rabies and toxoplasmosis are two diseases often raised during discussions about free-
roaming cats. It's important that both of these serious human health threats be put into proper
perspective. According to the CDC website, rabies in cats is extremely rare
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cats tested in 2009 tested positive. Also, out of the four rabies cases reported to the CDC in 2009,
none of them involved cats. The possibility of humans contracting toxoplasmosis from cats is
also quite minimal. In fact, according to the CDC, "People are probably more likely to get
toxoplasmosis from gardening or eating raw meat."
Do free-roaming cats live short, brutal lives?
Free-roaming cats can live long, healthy lives...
Free-roaming cats often live long, healthy lives. According to a study conducted by Dr.
Julie Levy (Levy, Gale and Gale, 2003) at the University of Central Florida, the majority of cats
(83 percent) in the 11 cat colonies studied were present on the campus for more than six years.
It's quite likely that many of the observed cats far exceeded that life span, since approximately
one-half of the free-roaming cats first observed in the study were already adults so their true ages
were unknown. Furthermore, according to Levy, the body weights of free-roaming cats when
compared with pet cats in previous studies, found "no significant differences" and "commonly,
free-roaming cats were in adequate body condition." Also, similar to owned cats, neutering free-
roaming cats resulted in an increase in body weight and overall body condition.
The findings regarding the health of free-roaming cats were quite similar in other studies.
For instance, during the years 1993 to 2004, seven TNR organizations throughout the nation
collected data on 103,643 free-roaming cats examined in spay/neuter clinics. Less than 1 percent
of these animals needed to be euthanized because of debilitating conditions, trauma or infectious
diseases (Wallace and Levy, 2006). The one program that tested for FeLV and FIV reported an
overall infection rate of 5.2 percent, which is similar to previous studies that reported results for
both pet and feral cats.
Why is the Utah Community Cat Act so significant?
Utah towns and municipalities are now empowered to implement humane and cost-
effective policies to control free-roaming cat populations ...
Utah's Community Cat Act, adopted in 2011, is a significant piece of legislation that
allows towns and municipalities to implement humane and effective policies to control free-
roaming cat populations. The Community Cat Act defines a community cat as "a feral or free-
roaming cat that is without visibly discernable or microchip owner identification of any kind, and
has been sterilized, vaccinated and ear-tipped." This act provides legal protection to caregivers
and sponsors by stipulating that they do not have "custody" of the animals. Consequently,
returning cats to their original habitat following sterilization cannot be construed as
abandonment.
This legislation also exempts community cats from licensing requirements and feeding
bans, providing yet another level of legal protection to the good Samaritans who care for them.
Equally important, cats who are eligible far a community cat program are exempt from the
mandatory five-day hold period, which is a significant cost savings for animal shelters and
taxpayers alike. This provision is also invaluable to the health of free-roaming cats, who
customarily endure a great deal of unnecessary stress while housed in shelter environments.
