Draft Tasmanian Cat Management Plan

The Draft Tasmanian Cat Management Plan will be referred to as the Draft Plan.

GENERAL COMMENTS AND RECOMMENDATIONS
The strongest aspects of the Draft Plan are:
- the actions aimed at promoting best practice techniques: section 4.2;
- a number of actions that aim to improve knowledge about feral cats;
including section 4.4; and
- the recommended changes to the Cat Management Act; section 4.6.
The weakest aspects of Draft Plan are:
- the lack of commitment to actual control or eradication of feral cats:
section 4.5;
- an inadequate understanding of the most effective approaches to
community education and behavioural change; sections 4.1 and 4.3;
- that the clarification of the roles and responsibilities of state government
land management authorities and local councils is yet to be done and
may not be included in the final plan: section 4.7.

Due to the numerous flaws and gaps in the Draft Plan, in particular in sections
4.1, 4.3 and 4.5, the TCT strongly recommends that the Draft Plan be revised
and reissued for further public comment. As recommended through this
submission, we also recommend that the Cat Management Reference Group
be reconvened to provide advice on the revised draft plan prior to public
release.


SPECIFIC COMMENTS
Our specific comments relate to section 4 as this contains most of the
substance of the Draft Plan.
4.1. Objective 1: Encouraging responsible ownership of pet cats
Objective
The wording does not constitute an objective as ‘encouraging’ is an action
and not an objective. The objective is the aim or expected outcome. The
objective should be reworded as “Tasmanian pet cat owners manage their
cats responsibly”.
Desired outcome
The desired outcome should be that, over a defined time period, such as five
years, that a significant increase in responsible ownership is achieved.
Responsible cat ownership could be measured in terms of:
- proportion of owned cats that are managed responsibly;
- the number of responsible behaviours that are attained (responsibility
score);
- whether the behaviour is lasting (de-sexing), consistent or irregular.
Performance indicators
Performance indicators for responsible cat ownership should relate to all
behaviour that the cat-owner can control, including:
- stopping roaming (which stops a cat from hunting, spreading diseases,
causing a nuisance and fighting or having accidents);
- desexing and microchipping;
- not to abandon cats;
- not to entice a feral cat to become a pet.

A responsibility score might be developed based on these indicators.
Actions
There is substantial overlap between actions 4.1.1 and 4.1.2 and section 4.3
‘Increasing community awareness and involvement’. Perhaps the two sections
can be rationalised.
As with comments made in response to action 4.3.1, action 4.1.1 should be
reworded to identify a range of approaches, not just provision of ‘information
materials’. See comments on action 4.3.1 for further information.
Action 4.1.2 should identify a range of strategies, not just to ‘encourage owners’
and ‘enforcement of legislation’. Additional strategies could include the
implementation of well planned education programs, the provision of
assistance and incentives for the construction of enclosures and subsidised
desexing and microchipping for pensioners and other under privileged people.
The Draft Plan should propose that a strategy be developed regarding
effective enforcement in relation to responsible cat ownership,
Action 4.1.3 should be reworded to ‘provide Councils with encouragement,
assistance and coordination in regard to development of by-laws’. The state government, including the Office of Local Government and the Local

Government Association of Tasmania, can assist Councils with:
- advice regarding how by-laws are produced and the implication of
them;
- by sharing information and experiences from councils that have or are
proposing to develop cat by-laws; and
- by helping councils, in particular adjacent councils, to work together to
develop by-laws.

Objective 2. Promoting best practice techniques to guide the planning,
management and control of stray and feral cats
The introductory text in section 4.2 does not explain what ‘best-practice
decision making is’ and this should be corrected in the final plan.
Desired outcome
The TCT supports the desired outcome.
Performance criteria
Some actions do not have performance criteria. The TCT recommends that
performance criteria be included for all actions.

Actions
Most of the stated actions only relate to the ‘development’ of a code,
guideline, monitoring method, criteria, management advice etc, and the TCT
recommends that they should be reworded to require that the proposed
documents are ‘developed, maintained, updated and revised over time as
necessary’.

The TCT supports, with some amendments or caveats, all of the actions
recommended in section 4.2. However, there will be a considerable amount of
work involved to develop, maintain and make available the:
- code of practice for cat management facilities;
- cost effective methods for monitoring cat management actions;
- model codes of practice for humane control of stray and feral cats
- criteria for cat management projects;
- advice on alternative methods for control of cats;
- advice on coordinated, cross land-tenure frameworks for cat control;
- training and education regarding cat control.
While the state government is acknowledged as being involved in
implementing all of the actions, DPIPWE needs to acknowledge and take
responsibility for coordinating and administering the process. The TCT
recommends that the final plan should include an additional action stating that
DPIPWE will take a lead role in coordinating and administering a program to
support best practice techniques to guide the planning, management and
control of stray and feral cats. To assist with this work, DPIPWE may consider
establishing and maintaining an advisory committee.
Action 4.2.1: The TCT supports the development of a code of practice for cat
management facilities. However, the Draft Plan does not explain the reason for
creating a code or why the Cat Management Act needs to be changed to
create and operate one (as per Objective 4.6). The TCT recommends that the
final plan include a brief justification for creating a code of practice for cat management facilities and an explanation for why the act needs to be amended.

Action 4.2.2: The TCT supports the development of ‘cost effective methods for
monitoring’ cat management actions but there needs to be
acknowledgement that historically landholders and community groups have
been reluctant or unable to do monitoring and that this is a problem that needs
to be addressed.

As well as developing ‘cost effective methods’ we recommend the
development of strategies for convincing landholders and community groups
of the benefits of monitoring. While we do not have any magic solutions, it is not
sufficient to develop a monitoring system and offer it to landholders who may
not be convinced of its importance.
Monitoring programs should be developed in collaboration with landholders
and community groups and they should be provided with an adequate level of
support in running them. Depending on the priority of a cat control project a
high level of government support may be justified.

Action 4.2.3: The TCT supports the ‘Adoption of model codes of practice for
humane control of stray and feral cats’ but recommends that the action clarify
whether the Sharp and Saunders code (that is listed in the footnote) is the code
being adopted. We support the immediate adoption and use of the Sharp and
Saunders code. If any tweaking is required for Tasmanian use it should not delay
the adoption of the code. We also ask that the final plan make it clear whether
the Sharp and Saunders document relates only to ‘humane’ best practice or
also provides guidance on effective and efficient cat control generally?

Action 4.2.4: The introductory text in section 4.2 outlines some key principles,
that the TCT strongly supports, and that should be incorporated in the ‘criteria
that are proposed in action 4.2.4. Criteria outlined include:
- ‘that control programs:
o consider all options and have a good understanding of the extent
and nature of the impacts being caused;
o the likely outcomes of any given program and
o the most effective and efficient methods to employ’.

The TCT recommends that a set of criteria be developed by DPIPWE, reviewed
by the Cat Management Reference Group and included in the final plan.
The TCT supports action 4.2.5 but we recommend that it should relate to
community groups as well as landholders. The introductory text should explain
what is meant by promoting alternative methods where ‘appropriate’.

This action would require DPIPWE or some other agency to provide sufficient
resources to be able to assess new and developing control methods and
whether they are appropriate for use in Tasmania by community groups and
landholders.

Action 4.2.6 seems to be the same as 4.2.2 except that it relates to research as
well as management and control. Perhaps the actions can be rationalised into
a single action. 

TCT supports action 4.2.7 but it is not clear from the introductory text in this
section or the wording of the action what the problem is that is being
addressed, what ‘a coordinated, cross land-tenure framework’ is and how a
community group or a groups of landholders are expected to find this
information. It may be explained in the Sharp and Saunders code but this is not
stated in the Draft Plan.

TCT supports action 4.2.8 but we do not know if there are existing guidelines that
could assist. We note that the TCT has produced a training video on the
effective use of cat traps and this is freely available on request

4.3 Objective 3: Increasing community awareness and involvement
Objective

Objective 4.3 relates only to ‘increasing community awareness and
involvement’. It should be reworded to be ‘Increasing community awareness,
understanding, commitment and involvement in cat management’.

Desired outcome
The desired outcome is supported.
Performance indicators
Performance indicator number 1 should be changed to relate to ‘increased
community awareness, understanding and commitment to action in regard to
the impacts of feral and stray cats’.
Performance indicator number 2 needs to be changed to relate to ‘increased
community awareness, understanding and commitment to implementation of
the management plan more broadly.
Some actions do not have performance indicators. Performance indicators
should be included in relation to:
- increased commitment to implementing humane practices for
controlling feral and stray cats, as proposed in action 4.3.1 (dot point
four)
- provision and take up of training opportunities, as proposed in action
4.3.2; and
- completion of the proposed communication plan, as proposed in action
4.3.3.
Actions
Action 4.3.1 only recommends that ‘information materials be developed and
distributed’ to address the lack of awareness and understanding in the
community of key matters relating to cat control.
The TCT accepts that there is a serious, but as yet unmeasured, problem
regarding the community’s understanding of the:
- ‘role that cat owners can play to reduce problems associated with stray
and feral cats’;
- ‘the threat to biodiversity and the agricultural sector posed by stray and
feral cats’; and
- ‘humane practices’.
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It is also highly likely that the ‘actions proposed under this plan are also poorly
recognised and understood.
However, the Draft Plan fails to properly explain the problem that this lack of
awareness, knowledge and understanding creates and does not recognise the
need for research and strategic planning to address them.
As with comments made in response to section 4.2, the problem is more
complex and requires a more sophisticated response than provision of
‘information materials’. Many people involved in cat control are not committed
to humane control or do not understand what it involves and this undoubtedly
is linked to a very strong hatred of cats and/or a perception that there is a cat
crisis that they must address and that cruelty in justified or unavoidable.
In the community there are serious misunderstandings regarding the type and
extent of the impacts of cats and this may relate to a lack of fundamental
biological knowledge, media misinformation and a mistrust of government.
Many cat owners refuse to acknowledge the need for them to take greater
responsibility toward their cat, especially in regard to containment, and this is
probably due to a mixture of factors, including that some people live in areas
where their cat probably does not have impacts, ideological or political beliefs
regarding their rights and a lack of care for the impacts their cat has.
It is probably the case that insufficient research has been done in Tasmania to
be certain of the most effective strategies for changing cat owner’s behaviour.
Research from outside Tasmania and anecdotal information from elsewhere
suggests that cat owners may be more likely to change how they manage their
cats based upon what is good for their cat and who delivers the information i.e.
other cat owners and friends and relatives are more likely to be effective. See
‘Responsible cat ownership- what it will take to own your pet?’, Tasmanian
Conservationist number 336, www.tct.org.au.
Clearly, these problems are related to much more than a lack of appropriate
information and could require complex and long-term educational programs
to address.
In addition to developing information materials, the TCT recommends that
action 4.3.1 commit to targeted social research and careful strategic planning
to determine what behaviour, beliefs and attitudes that need to be addressed
and how these can most effectively be changed. The development of
behavioural change strategies would benefit from ongoing research,
recommended elsewhere in the Draft Plan, to better understand the impact
that stray pet and feral cats have.
Key messages and supporting information should be developed in relation to all
aspects of responsible cat ownership i.e.:
- stopping roaming (which stops a cat from hunting, spreading diseases,
causing a nuisance and fighting or having accidents);
- desexing and microchipping;
- not abandoning cats;
- not enticing a feral cat to become a pet.
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Having said this, the TCT also recommends that there are areas of behavioural
change that are well understood and action that can more confidentially be
taken without waiting for further research and strategies to be developed. That
is, a lack of complete knowledge should not prevent some immediate action
being taken.
The TCT supports action 4.3.2 but suggests that it commit to actually delivering
as well as investigating ‘training to community and volunteer groups involved in
managing stray and unwanted cats’ and that this training also be offered to
groups managing ‘feral cats’ and ‘industry’ groups.
It is unclear what action 4.3.3 means. In particular, what ‘public sensitivities’ exist
regarding cat control and why are these important enough to warrant a standalone
action.
4.4. Objective 4: improving the knowledge about feral cats to better inform
management
As stated in the introductory text, it is true that ‘The depth of knowledge of the
role cats play in the Tasmanian environment is not strong’ and that this will have
‘significant implications for the efficacy of cat management projects’.
However, we can probably safely assume that cats have some level of impact
in some areas, on agricultural production and the environment, and that there
are interactions between feral cats and other introduced species. The final plan
would benefit from a concise summary (included in the introduction to section
4.4) of what is known about feral cats in Tasmania and the broad information
gaps.
From my personal experience of initiating and helping to coordinate several
cat control programs, the lack of knowledge about the impact of trapping is a
key reason that programs stop.
Desired outcome
The desired outcome is supported.
Performance indicators
Performance indicator number three only relates to identification of research
priorities and knowledge gaps whereas some of the actions relate to doing
research. The TCT recommends that this performance indicator be deleted and
is replaced by specific indicators for each research related action.
Actions
The TCT supports the proposed priority research areas, i.e.:
- action 4.4.1 regarding the interactions between cats and other animal
species
- action 4.4.3 regarding trialing alternative methods for lethal control of
feral and stray cats
- action 4.4.4 regarding the role of feral and stray cats in spread of
diseases to livestock and native species and
- action 4.4.5 regarding valuing the costs to primary industry caused by
feral cats.
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We are unsure whether 4.4.2, which relates to development of monitoring
strategies, should be in a section dealing with research. We assume that
monitoring methods/strategies exist and do not require additional research but
if this is incorrect then the final plan should clearly state why monitoring
strategies are inadequate and that additional research is required to improve
them.
Also, it is not clear whether action 4.4.2 duplicates action 4.2.2 and, if so, the
two actions can be rationalised.
The TCT also supports action 4.4.6 and 4.4.7 regarding publishing and
distributing the results of this research. These actions should refer to informing
other key areas of the final plan, in particular section 4.3 in regard to
increased community awareness, understanding, commitment and
involvement in cat management.
4.5. Objective 5: Minimise impacts of cats in areas of high conservation value
and agricultural assests
Desired outcome
The desired outcome is supported.
Performance indicators
Performance indicator 2 should refer to community and conservation
organisations as well as ‘land owners and land managers’.
There should be an action that relates to performance indicator 3, i.e.
regarding ‘No new establishment of feral cat populations on HCV islands’.
Actions
It is the TCT’s understanding that, at the outset of the process that developed
the Draft Plan, DPIPWE had committed to development of a set of criteria and
a process for ‘identification of high conservation values and where cats are
known to, or likely to have, a significant impact’ for inclusion in the Draft Plan.
This is now only a ‘proposal’ in action 4.5.1.
The TCT recommends that a set of criteria and a process be developed by
DPIPWE, reviewed by the Reference Group and included in the final plan.
In regard to action 4.5.2, there was no commitment as per action 4.5.1 and the
TCT supports the action as it stands.
Action 4.5.3 is the primary action in the entire Draft Plan that relates to
‘landholders and managers’ doing cat control and the provision of assistance
for them to do so effectively.
As such the language used should be more assertive and outcome focused,
including a commitment to working with landholders and managers to
implement cat control projects and provide extension and facilitation services.
The action should relate to community and conservation organisations as well
as ‘landholders and managers’.
The TCT supports action 4.5.4, accepting that it must be ‘practical’ and occur
‘within a integrated pest management framework’. However, we recommend
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that the final plan include a list of Tasmanian islands that contain cats and, if
possible, a prioritisation of the islands for control or eradication.
Action 4.5.5 should relate to community and conservation organisations as well
as ‘Federal agencies, local government and landholders’.
Action 4.5.6 is a duplication of action 4.2.2 and possibly action 4.4.2.
Action 4.5.7 is supported but is seems that it should be included in section 3 or
even as a part of action 4.5.3.
4.6. Objective 6: Undertake legislative amendments to facilitate and support
other objectives
Desired outcome
The desired outcome is supported.
Performance indicators
Performance indicators should be included in the final plan for legislative
amendments.
The TCT supports all of the stated amendments to the Cat Management Act
but we are concerned that some may not have sufficient public and
parliamentary support.
Compulsory desexing of cats
The TCT supports this change, but the potential effectiveness of this change is
dependent upon having an appropriate age of desexing.
Age to desex
The TCT supports the proposal to consider a lower compulsory age for desexing
of pet cats. The TCT supports the lowest age that veterinarians will sanction as
being humane and that can be performed by most veterinarians. We
understand this is four months but if it is earlier then we support this. The ideal
situation is that all cats be desexed prior to being capable of breeding.
Compulsory microchipping of cats
The TCT supports the proposal to require all cat owners to microchip their cats
and that appropriate penalties should apply. It is our understanding that, unlike
desexing, there is no limit to the age that a kitten can be microchipped and
therefore it should be done as early as possible.
Removal of the care agreement
The TCT supports the proposal.
No compulsory registration of cats
The TCT supports the proposal.
Confining cats to properties
The TCT acknowledges the numerous potential benefits of confining cats but
there is some evidence that most Tasmanian cat owners do not support
confinement being made a legal requirement. For example, the 2013 survey
produced by the TCT and Kingborough Council, ‘Kingborough Community
Attitudes to Responsible Cat Ownership’, found that 44% of non-cat owners and
20% of cat owners supported compulsory cat enclosures.
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Attempting to amend the Cat Management Act to introduce compulsory cat
containment may result in a serious back-lash from cat owners and this may
cause legislators to remove the proposal from draft legislation. A back-lash
against this provision may lead to greater scrutiny and criticism of other
measures related to pet cats. This may cause legislators to make broader
changes to the draft legislation.
Before progressing with legislative changes to require cat confinement, the
state government should seek further advice from the Cat Management
Reference Group as too how best to convince cat owners to accept cat
confinement and what measure may assist people to do so e.g. provision of
assistance for under privileged people.
Also, there may be provisions in the draft legislation that could increase support
of cat owners. Having a phase-in period is mentioned in the background
document. The TCT suggests that consideration should also be given to having
a three strikes provision to ensure that non-compliant owners do not lose their
cat or have to pay a substantial fine out of ignorance of the law. Perhaps the
fines could increase with subsequent offences.
The TCT notes that confinement to a property does not stop cats hunting or
harassing native animals on that property. Some properties are hundreds or
thousands of hectares. Consideration needs to be given to requiring
confinement to a house or adjacent buildings so that cats cannot access
wildlife habitat.
Limiting the number of cats allowed at a property without a permit
Consideration will have to be given to whether the same approach is taken
with cat owners who currently have a high number of cats but who seem to be
able to manage them.
Improved arrangements to support landholders undertaking cat management
actions
The proposals are supported but as has been stated in the reference group,
farmers will want to know that the changes will permit them to humanely
destroy cats by shooting them in the field.
Improvement arrangements for register breeders
The development of a code of practice for cat management facilities is
supported but the final plan should explain why legislation is required to allow a
code to be developed and operated. This will be a question raised by
legislators and the final plan should include an explanation.
Amendments to the act covering administrative components
Proposal 1: The proposed definitions are supported.
Proposal 2: The proposed definitions are supported.
Proposal 3: The proposal is supported but we seek clarification regarding what
implications there may be for cat management facilities. We understand that
cat facilities support commencement of section 24 of the act. 
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Proposal 4: While the TCT supports the intention to simplify minimum holding
time requirements, we recommend that the final plan explain how it is to be
simplified.
Proposal 5: The proposal is supported.
Proposal 6: The TCT supports the proposal on the understanding that it is in
response to a recommendation from managers of existing cat management
facilities. We wish to caution that relying on verbal notice may cause legal
uncertainty if cat owners were to take legal action.
Proposal 7: The proposal is supported.
Proposal 8: The proposal is supported.
Proposal 9: How this measure would be applied and the implications of it are
not clear and these should be better explained before proceeding with
drafting legislation.
4.7. Objective 7: Clarify roles and responsibilities of local government and state
government regarding cat management
Desired outcome
The desired outcome is supported.
Actions
The TCT supports the actions 4.7.1 and 4.7.2 but requests that the outcomes of
these discussions be included in the final plan.