Anne Maree Greenaway Bec. LLB. GradDipLP review of... · Dear Mr Halse Re submission on Pest Animal...

Address: PO Box 1472. Queanbeyan NSW :: Mobile :: ABN 53 198 185 323 Liability limited by a scheme under Professional Standards Legislation

Principal Anne Maree Greenaway Bec. LLB. GradDipLP __________________________________________________________________________________ 31 May 2016 Sean Halse Program Director Natural Resources Commission GPO Box 5341 Sydney NSW 2001 Dear Mr Halse

Re submission on Pest Animal Management Review

While I appreciate that this Review of Pest Animal Management relates to a number of animals this submission relates specifically to cats.

The first concern I have relates to the words “feral cat or feral cats”. I will expand on this point shortly but firstly it is important to highlight the advantages of the domestic cat. Domestic cats share the life and enrich the life of many people. Having a cat as a pet provides the following advantages:

• provides companionship • teaches children empathy • reduces stress and blood pressure • reduces anxiety in autistic children

Domestic cats are much-loved family members. In Australia, Europe and the USA cats are a popular pet. It is likely that our modern busy lifestyles have played a part in that transition. Cats are lower maintenance pets than dogs. They are, for the most part, not noisy, clean and are adaptable to where they live. This Pest Animal Management Review at page 9, Recommendation 17 states as follows. The NSW Government should v. Align the Draft NSW Invasive Species Plan 2015-2022 with the Federal Feral Cat Threat Abatement Plan. However the national Feral Cat Threat Abatement Plan aims for reduced stray and feral cat abundances in areas around human habitation.


The real problem with including cats in this definition is that there is no way to distinguish between owned cats, unowned cats, stray cats, abandoned cats and feral cats. What is the difference between feral cats and stray cats?

Stray cats are usually cats which have at some stage been domestic pets but for some reason have had to fend for themselves, whether they have become lost or been abandoned. These cats can often be rehabilitated into being pets.

Semi wild cats are cats which have possibly once been pet cats or may be offspring of pet cats that have not had socialization with humans. These cats will often domicile around rubbish dumps, industrial areas or where ever there is a food source. Often they are less inclined to hunt, but are opportunistic when it comes to food.

Feral cats are cats which have never been domesticated and are truly wild animals. These cats will have nothing to do with humans and have no reliance on humans, living wild, killing wildlife and scavenging. A true feral cat does not rely on humans at all, obtaining its food and shelter from the natural environment. These categories of cats all are from the same species. So given that there is no scientific way to distinguish between these categories of cats, there has to be other methods to identify the type of cat before any action is taken against the cat. My submission is that is it in many cases impossible to identify a cat as feral as we do not know the background of the cat and it’s “feralness” can not be determined by its behaviour in a cage, or by the observation of a member of the public from a distance using the Feralscan Pest mapping Resource. Threatened Species Commissioner – Misinformation and False Claims Adding to this confusion is a great deal of hysteria and misinformation being presented by the Threatened Species Commissioner about cats. He often uses biased, emotive language on his Facebook page and deletes comments that challenge him or question the scientific basis for his actions, beliefs or more details about how the killing of the cats will assist native animals. His inflammatory posts are a magnet to cat haters. I have seen comments on TSC Facebook page by people advocating the drowning of cats, killing them by bow hunting, hanging cats on metal hooks as well as advocating the use of steel jaw traps. An article in July 2014 in New Matilda states as follows A senior bureaucrat who was forced to apologise for misleading a federal Senate inquiry into petrol sniffing in Aboriginal communities and who appeared on an ABC current affairs program under a false identity has been appointed the nation’s first ‘Threatened Species Commissioner’.

Gregory Andrews's history is an interesting one and particularly confusing as to what his specific qualifications are to lead such an important field of work. I expect he ticked the one box they were looking for - "cat hating extraordinaire with experience in misleading others.” While a main cause of animals becoming threatened or endangered is habitat destruction through clearing for urban development Mr Andrews has shamelessly whipped up hysteria about cats on his Threatened Species Commissioner Facebook page. Cats, it appears, are a much easier scapegoat and target than seriously addressing other major causes of threatened native animal extinction or that threaten the ongoing survival of native animals. While his Threatened Species Commissioner appears to enjoy discussing various ways of killing cats, he appears to be doing absolutely nothing with regards to the uncontrolled breeding of cats in urban areas. A question and answer on his Facebook page is reproduced below


Ryan Tate Hi Gregory are there any plans or processes being developed to control the breeding and selling of cats? · 1 · May 1 at 9:29am

Threatened Species Commissioner Hi Ryan. At the Meeting of Environment Minister last year, Minister Hunt secured agreement from all state and territory Ministers for feral cats to be treated as pests. This is a great start and in some cases will include policy and legislative changes that will address confusion between feral and domestic pet cats. Responsible pet ownership is a state and local government responsibility so the Australian Government doesn't have any formal plans on this issue. I have seen nothing on the Threatened Species Commissioner’s Facebook page which addresses the uncontrolled breeding of domestic cats. The issue of uncontrolled breeding has been raised time and time again by cat lovers, cat advocates and not for profit cat rescue groups. An extremely serious problem is the selling and giving away of cats and kittens on websites such as Gumtree as well as on the Buy Swap and Sell pages on Facebook. Every single day people are giving away or selling cats and kittens. If you speak with any cat rescue group you will find they are overwhelmed with requests from people whose cat has had kittens. They are simply unable to keep up with the relentless request from people to rehome their unwanted cats and kittens. Feralscan Pest mapping Resource There is an App called Feralscan Pest mapping Resource that purports to allow users to report Feral Cats. Unfortunately this App appears to be mainly used in urban areas and has resulted in owned and colony cats being targeted which are already being managed by kind, caring and responsible individuals who engage in Trap Neuter and Return. I assume that you are familiar with this concept. My understanding is that the cats in these colonies are not feral but simply strays. There may also be some owned wandering cats which form part of these colonies – which are being managed. Most of these cats have been desexed and are being fed by humans. Often they are less inclined to hunt, but are opportunistic when it comes to food. They are often around industrial areas, hospitals or universities and pose little or no risk to native animals yet it is these easy targets (managed colony cats) which the FeralScan App is targeting. The Threatened Species Commissioner has referred to this FeralScan App in a most inappropriate tweet. His tweet which blames Feral Cats for a number of feathers he stumbles across is typical of the type of rubbish that he posts on his Facebook page. Unlike Facebook where TSC can delete comments, this is not possible via Twitter. The responses are referred to below


Mr Andrews in his previous role is reported to have mislead a federal Senate inquiry into petrol sniffing in Aboriginal communities. Now he appears to have reverted to his previous behaviour in misleading the public with respect to cats in his new role as Threatened Species Commissioner. Existing laws not being enforced. Nuisance cats - While the table on page 80 of the Draft Report states that there is no laws prohibiting cats from roaming this not entirely correct. If a cat is indeed causing a nuisance in any way, an affected person can complain to council and council have the powers to declare the cat to be a nuisance cat. Through the course of my work I have not spoken to a single ranger or council employee who has declared a cat a nuisance cat and therefore imposed legal requirements that it stop roaming. This is an option under the Companion Animals Act for a cat to be declared nuisance and hence stop it roaming.


Breeding and selling of cats - In NSW there are existing laws in place stating that cats and kittens must be micro-chipped and 8 weeks old. These laws are routinely broken every single day as evidenced by posts on Facebook and Gumtree. I have made complaints to the relevant authorities but no action has been taken with regards to these back yard breeders. The posts are open for all to see on Gumtree and Facebook. The RSPCA (NSW) and local councils are aware of the problem but the breeding of cats (intentional or otherwise) goes on unabated without any prosecutions being commenced. How is the random killing of 2 million cats by 2020 going to address the ongoing breeding which is going on unabated? Breaches of Companion Animals Act with regards to stray cats. Under the Companion Animals Act, the correct procedure for dealing with stray cats is to take them to the pound where there are proper procedures in place to locate owners, find new homes or euthanase the cats. The Threatened Species Commissioner appears to be encouraging the by-passing of the Companion animals Act laws by dishonestly not distinguishing between different categories of cats and often referring to all cats as feral cats. ABC Fact Check – inaccurate statistics. Not only has the Threatened Species Commissioner repeatedly misled people on his Facebook page, but there have been unscientific claims about the number of native animals killed by feral cats bandied around for some time. I complained about the claims made about Feral Cats to the ABC and requested a Fact Check. Here is the link and here are the results of the Fact Check. http://mobile.abc.net.au/news/2014-11-13/greg-hunt-feral-cat-native-animals-fact-check/5858282 "There are up to 20 million feral cats taking up to four native Australian animals a night. That is over 20 billion Australian native species being destroyed a year," Mr Hunt said on ABC's Landline on November 2.

It's well recognised that feral cats are a major threat to native wildlife, but are there really almost as many cats as people in Australia?

ABC Fact Check takes a look at the numbers.

• The claim: Greg Hunt says up to 20 million feral cats are each killing four native Australian animals a night, destroying over 20 billion animals a year.

• The verdict: The number of feral cats in Australia is impossible to calculate because of density variation, and the way the population fluctuates with prey availability and climate. The number of native Australian animals killed by feral cats each night is also difficult to calculate, due to differences in the size of prey. Mr Hunt's claim is unverifiable.

And yet the ridiculous claims continue unabated and the killing continues. Facebook comment by Threatened Species Commissioner below. Threatened Species Commissioner The Australian Government has ambitious targets approved by Minister Greg Hunt MP to cull 2 million #FeralCats by 2020. I am doing my best to implement these targets. Cheers Gregory The following needs to be established:


1. What tests or checks are in place to ensure that peoples beloved pets are not being killed given that the Feralscan Pest mapping Resource is targeting urban areas – (indeed this seems to be where the majority of “feral cats” are logged in this Resource)?

2. What temperament tests or otherwise are being done to ascertain that these cats are indeed

“feral” and not family pets or strays in a managed colony?

3. Where (location) are the cats being trapped and killed? What records are being kept to log the location of the killed cats?

4. What is the correlation or relationship to killed cats, location and threatened or endangered species. (Surely it defies logic to deem managed, stray colony cats in urban industrial areas with NO threatened or endangered species in the near vicinity as feral just to meet Greg Hunts 2 million cat cull target)?

5. What records are being kept of the killed cats (ie descriptor/photos, numbers of cats and

location)?

6. What investigation of the stomach contents of cats killed is being done to determine what these 2 million cats are actually eating (or is this simply a mass extermination of cats with no examination of stomach contents made)?

7. If there is stomach content analysis what records are being kept of these results? Are these cats being checked for microchips or photos placed up to try and ascertain whether or not these cats have owners given that most of the cats targeted with the FeralScan Pest Mapping App are in urban heavily populated areas. Under the Companion Animals Act, the correct procedure for dealing with stray cats is to take them to the pound where there are proper procedures in place to locate owners, find new homes or euthanase the cats. The Threatened Species Commissioner appears to be encouraging the by-passing of the Companion Animals Act laws by apparent dishonestly due to not distinguishing between different categories of cats and at times referring to cats generally as feral cats. Animal cruelty concerns I have grave concerns, particularly with the behaviour and misinformation and apparent hate campaign against cats waged by the Threatened Species Commissioner that this will result in an increase in cruelty to cats. Whenever an animal is classed as feral there appears to be an associated belief by those who are inclined to be cruel to animals that there is carte blanch permission to do what they please to the animal, no matter how grievous the cruelty. One only has to look on the Internet and see all the pig hunting videos which show the delight that some people get in chasing, torturing and killing feral pigs. I have grave fears that cats will face the same outcome and that once an animal is deemed “feral” there is ‘implied permission” to do what they want to the animal. People will not care if it is a much-loved domestic cat or a stray or abandoned cat. It is “only a feral” is often the justification for extreme and grievous cruelty and of course killing. Such cruelty is often justified on conservation grounds. Desexing of cats I support the desexing of cats but the reality is that not all people can afford to desex their cats.


People on low incomes and people in rural and regional areas often have vets that charge up to $600 to desex a female cat and also often will NOT desex until 6 months of age. So some people even if they want to get their female cat desexed at 4 months cannot do this due to the vet’s refusal to desex before 6 months of age. There is also a problem with people with no transport options who cannot take their cat to the vet to get desexed. There are also those from non-English speaking backgrounds or from cultural backgrounds that need to be educated about the importance of desexing their cat. Diet of feral cats include mice, rats and rabbits. While much has been said about the damage to the native fauna done by cats, I have seen nothing whatsoever on the Threatened Species commissioner’s Facebook page as to the positive effects of cats in keeping other introduced species such are rabbits, mice and rats in check. For example in times of mice plagues which do damage to the crops of farmers, mice can form up to 100% of the diet of feral cats. Feral cats or indeed any cat do not selectively seek out native animals as food. They will eat what is available, be this native, introduced, killed by another animal or road-kill or provided to them by humans. Killing cats, even two million of them, can inadvertently increase cat numbers by enabling more cats to immigrate into vacant territories. This is particularly so in areas where TNR is carried out. Desexed cats will be removed and replaced with fertile cats which will breed up, increasing the numbers. Conversely, cat eradication can cause population booms of other species (such as rabbits and rats) and result in further harm. Failed war on foxes. The war on cats is ultimately a consequence of the failed war on foxes. Foxes have long been held as Australia’s primary environmental villain. They are also easier to kill, because they more readily scavenge. Meat baits laced with 1080 poison are used extensively in conservation programs. This inhumane poison kills foxes and dingoes in untold numbers, and enables cats to breed up and move with impunity across the landscape. For example, a major poison-baiting campaign did help recover endangered woylies for a time, but eventually the loss of foxes and dingoes caused cats to take over and the newly recovered population collapsed. Consideration of bringing back Dingo as Apex Predator Consideration should be given to bringing back the dingo as an apex predator to keep fox and feral cat numbers under control in isolated rural and outback areas. In one of the great ecological ironies, the loss of predators can disadvantage their prey species. Top predators are ecosystem shapers, exerting control over smaller predators and large herbivores. Eliminate the top of the food chain (eg dingos) and predators lower down (ie cats and foxes) may flourish to the greater detriment of prey species. This is why some ecologists advocate returning the dingo to a pre-eminent place in Australian ecosystems.


Pest Animal Management Review Recommendations I will now address each of the relevant recommendations. My responses are in red. Recommendation 17 Manage feral cats as a pest animal The NSW Government should:

i. Declare feral cats as a pest by including them in the pest animal regulation being prepared for the NSW Biosecurity Act 2015. I do not support this recommendation

ii. Ensure any mandatory measures are consistent with the model code of practice for the humane control of feral cats The killing of any animal should be done in a humane way.

iii. Prioritise within the NSW invasive species plan 2015-20122 management of feral cats in

areas of high biodiversity value I do not support this recommendation

iv. Support continued research into the scale, efficiency, cost effectiveness, sustainability and risk of cat control methods

Given that this review has happened within the climate of the Federal Governments “war on cats” and the spread of misinformation by the Threatened Species Commissioner I have zero confidence that any research will have any genuine positive impact on endangered or threatened species. I believe that the “war on cats” is politically motivated and will result in the senseless death of millions of cats and the wastage of tax-payer’s money on a “war on cats” which will have zero long term positive impact. The behaviour of the Threatened Species Commissioner in banning people from his Facebook page who ask reasonable questions or highlight where he has made errors is a major concern. In my view his behaviour is both grossly unprofessional and dishonest. I can only assume that such conduct is endorsed and sanctioned by Greg Hunt MP.

v. Align the Draft NSW Invasive Species Plan 2015-2022 with the Federal Feral Cat Abatement Plan Recommendation 17 (vi, vii) Manage feral cats as a pest animal The NSW Government should vi amend the NSW Companion Animals Act 1998 to provide for:

a. the compulsory desexing of all cats by the age of four months if not exempted


In principle I support this recommendation but for the problems outlined already it is not practical (eg low income people can’t afford full price desexing, vets in country areas charge high amounts which are a deterrent to pet owners desexing their cats, vets in country areas often will not desex female cats until they are 6 months old etc).

b. requiring all owners of entire cats older than four months to be registered as a breeder

In principle I support this recommendation but many people do not register their cats as it is. And councils largely do nothing to police people who have not registered their cats. If councils seek to enforce these laws people who chose not to register or cannot afford to register will simply dump their cats. My prediction is that if this is introduced there will be very low compliance. In low income country or low income urban areas I suspect that most cats are not registered or microchipped, so requiring back yard breeders to register their cats simply will not work in my opinion and experience.

c. requiring all entire cats to be registered annually In principle I support this recommendation but have grave concerns that it will be effective unless more resources are given to local council rangers. As it stands breaches of the laws occur every single day with regards to cats being sold or given away on Facebook and Gumtree and RSPCA NSW and/or councils do nothing to stem the flow of kittens being born or prosecute those selling or giving away cats and kittens, in breach of the relevant existing legal framework.

d. local governments to declare and enforce cat confinement areas

In principle I support this recommendation although would like further information as to how enforcement would take place. On a personal note I am a member of Wildcare and a qualified snake handler and believe native animals should be protected. I simply do not support hysterical “hate campaigns” which mislead and misinform the public and deliver no science based outcomes. Most people I know that have cats as pets do contain their cats within their properties either in the house, in secure runs or have perimeter fencing. I know all ethical cat rescue groups will only rehome cats that are desexed and insist on inside only homes. This inside only homes is a strict criterion for adoption as they deal with the fallout of uncontrolled breeding of cats on a daily (or more like hourly) basis.

vii. partner with the RSPCA and other relevant organisations to deliver a targeted education campaign raising the awareness of the risk posed by stray and feral cats and promoting responsible pet ownership. I don’t feel I can comment on this point as I don’t know what “other relevant organisation” refers to. It would be appropriate to include cat rescue organisations and the Animal Welfare League NSW. Also this draft report refers to the “RSPCA”. Given this Review is NSW based I assume that you mean the NSW RSPCA rather than RSPCA Australia. Also it is disappointing that this recommendation does not address the benefits of cat ownership which have already been covered in this submission. By all means promote responsible pet ownership but how do you think cat owners will feel about this? It is all very negative and there are plenty of responsible cat owners out there. Rescue groups and other groups such as Animal Welfare League also promote responsible pet ownership and realise the positive benefits of cat ownership. Many cats that become stray are due to people abandoning them or a myriad of other reasons. Many


people take in stray cats and those stray cats become much-loved domestic pets. It is offensive that a “targeted education campaign raising the awareness of the risk posed by stray and feral cats” does not include the many positive benefits of cat ownership and acknowledge that cats are much loved family members. The demonisation of cats will not help the problem of native animals being threatened or becoming extinct. Science based strategies with measurable methods, outcomes and results being recorded will have a more desirable effect. As previously mentioned, I am a member of Wildcare and care deeply about native animals and birds. I also own cats. Caring about threatened native animals and owning domestic cats are not mutually exclusive. I have seen absolutely nothing in Greg Hunt’s “war on feral cats” that leads me to believe that such a “war” will have a positive impact on preserving threatened native animals. Indeed, I have grave concerns that given the lack of science based approaches to this problem (and the fact that the same strategy of killing cats for many years has not worked) such methods will prove to be ineffective. The killing of two million cats without any proper scientific research based methodology or recording of outcomes is morally, fiscally and scientifically irresponsible in my opinion. Albert Einstein described insanity as doing the same thing over and over again and expecting different results." OTHER - Bill by Alex Greenwich – Trap Neuter Return I am very disappointed that this Pest Animal Management Review did not include support for The Animal Welfare (Population Control Programs) Bill to manage stray cats as proposed by Alex Greenwich in NSW Parliament. This bill introduced on 12 September 2014 aimed to ensure that sponsored trap-neuter-return and management (TNR) programs are lawful. TNR programs involve desexing animals in a specific group or colony of unowned stray animals and returning them to where they were found where they stop breeding, allowing the population to stabilise. TNR programs are carried out across the world as a humane method of population control and have official approval from the RSPCA UK and the International Society of Feline Medicine I recommend the proposals contained within Bill to Manage Stray cats as proposed by MP Alex Greenwich be considered as a way to manage stray cats in urban areas. Thank you for considering the issues and concerns raised in this submission.

I can be contacted on or [email protected] if you require further information or assistance.

Kind Regards

Anne Greenaway PRINCIPAL

Anne Maree Greenaway Bec. LLB. GradDipLP review of... · Dear Mr Halse Re submission on Pest Animal...

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