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SUBMISSION 71
RECEIVED 02/08/2016
The Executive Officer
Environment, Natural Resources and Regional Development Committee
Parliament House
Spring Street
East Melbourne VIC 3002
Dear ENRRDC,
I have prepared the following submission focussing on the issue of feral cat management in
Victoria. I understand that the Terms of Reference #1 and #2 refer to the management of deer
populations but seek to have my views considered under ToR #3 as published on the ENRRDC
webpage.
I have relevant experience with feral cats given that I was employed by the Victorian
Government as a research scientist between 1996 – 2014. During this time, I undertook projects
related to the development of tools and techniques to improve the management of vertebrate pest
species, such as red foxes, feral cats and rabbits. Much of my career has been spent working on the
development of a poison bait for feral cats called ‘Curiosity®’ which was funded by the Australian
Government. A submission seeking registration of the Curiosity® bait as an agricultural chemical is
currently under review by the Australian Pesticides and Veterinary Medicines Authority (APVMA).
This product is intended to be used by land managers of conservation estate, such as Parks Victoria
and private sector agencies such as Bush Heritage Australia, to enable broad scale control of feral cat
populations.
I have become increasingly aware that the legislative framework that applies to invasive animal
control in Victoria is lacking with respect to appropriate strategies for reducing the impacts of the
feral cat. There are several reasons for this and I would be pleased if the Committee would consider
the following information. The Acts that are directly relevant to the management of cats in Victoria,
namely;
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Domestic Animals Act 1994
Catchment and Land Protection Act 1994
Wildlife Act 1975
Flora and Fauna Guarantee Act 1988
The DAA regulates the responsibilities of cat ownership throughout the state and is administered
through local government. It does not provide any definition or differentiation between the various
classes of cats, such as those provided in the Threat Abatement Plan for Predation by Feral Cats, i.e.
domestic, stray or feral. Given this definition, feral cats within Victoria inhabit land managed by the
Crown, Parks Victoria, Dept of Defence as well as freehold tenures. Each class of cat has a different
impact on protected native wildlife which can be reduced by the use of different management tools,
ranging from fostering responsible ownership strategies to lethal control techniques.
The Domestic Animals Act does permit an Authorised Officer to destroy a cat found at large
within conservation zones. The Wildlife Act also enables the seizure, i.e. trapping, of a cat within a
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nature reserve but requires that the animal is then delivered to the relevant local government
shelter. Notably, the Wildlife Act does not allow for the land manager to shoot an animal caught in a
trap but instead only provides for a suitably accredited person to be permitted to shoot a freeranging cat if it “rushes at, attacks, bites, worries or chases wildlife while at large on public land”. It
would be a very rare circumstance for a land manager to observe a feral cat behaving in this manner.
I believe that this requirement should be reviewed as it does not make any sense for a feral cat that
has been trapped in a conservation reserve to be transported some (considerable) distance to a
shelter. This travel will be a major stressor for the animal and is not a pragmatic solution for the
person conducting the trapping program.
To complicate the management of cats under the DAA, it is worth mentioning that there are ~10
areas in Victoria that are termed ‘Unincorporated Areas’ that have no local government. These areas
include French Island and six alpine resorts. It is questionable whether the DAA is applicable at these
sites given that there is no agency responsible for administration of the requirements of this Act. I
would strongly encourage the Committee to investigate how Unincorporated Areas can be brought
into line with other parts of the state as each of them is of high conservation significance and that
cats (including feral cats) are known to inhabit them. Indeed, over 800 cats have been trapped on
French Island since 2010. Similarly, trapping for cats is undertaken at alpine resorts to reduce
predation of species such as Broad-toothed Rat and Mountain Pygmy Possum.
The Flora and Fauna Guarantee Act nominates the Predation of Native Wildlife by the Cat as a
‘Threatening Process’ with the Action Statement providing many goals, of which #11 seeks
declaration of feral cats as pest animals under the Catchment and Land Protection Act. This
document was first published in 1997.
More recently, at the ‘Meeting of Environment Ministers’ held in July 2015, each State and
Territory Environment Minister endorsed the National Declaration: feral cats as pests. Importantly,
this agreement recognises that “feral cats are a nationally significant pest that threaten our native
fauna”. Further, it requires that Ministers review “their jurisdictional arrangements … and remove
any unnecessary legal impediments to land managers undertaking feral cat control and management
within a 12 month timeframe”. I suspect that the State of Victoria has not yet made the requisite
changes. The Australian Government, through the Threatened Species Strategy are directing funds
towards reducing the threat that feral cats present to native wildlife by supporting the removal of
cats from five islands of conservation significance amongst a range of other targets. French Island in
Western Port was been identified as being one of those islands.
The CaLP Act specifies which species are declared as ‘pests’ in Victoria and the level of control
required by land managers to manage that pest. CaLP does not currently list feral cats as a pest
species. It does however specify that a species widely kept in Victoria must not be declared as a pest
species (S59). I suggest that part of the solution for defining or identifying a ‘feral cat’ in Victoria
must include its geographic location in much the same way that differentiates dingoes and wild
dogs.
There are several methods that land managers use to control pests with poison baiting
commonly used for a range of species. The conduct of a poison baiting program for feral cats
requires a different approach to that used for other invasive predators such as foxes or wild dogs. All
meat-based poison baits used in Victoria must be buried. However, as feral cats rarely exhume
buried food items, this requirement will need to be removed such that surface-laid bait can be used.
This practice obviously then increases the potential for bait consumption by non-target wildlife
species. Mitigation of this hazard was one of the key objectives involved with the development of
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the Curiosity® bait. A sophisticated method is employed to selectively target feral cats but minimise
the exposure of other species.
Feral cats have a preference for live prey and generally avoid consumption of carrion unless they
are food-stressed. Baiting will not be successful if baits are applied during at a time when a preferred
prey species is abundant. Optimal baiting efficacy for feral cats also requires that baits are evenly
spread across the landscape such that the cat is more likely to encounter a bait when it is hungry.
Distribution of baits along vehicle tracks, such as occurs with fox baiting programs, generally
provides a poorer coverage of the site with baits and these baits are likely to monopolised by other
species such as canids which regularly use tracks. The activity of canids itself along vehicle tracks is
likely to deter feral cats from also using those tracks – as the cat itself is more exposed to predation.
Instead, I suggest the Victoria adopt the recommended approach to distributing poison baits for
feral cats which was formulated during the development of the Eradicat® bait and has also been
replicated during field efficacy studies of the Curiosity® bait. Operational baiting with Eradicat® is
generally undertaken from aircraft as this ensures that baits are widely spread across the landscape
regardless of the vehicle track network.
To complicate this situation, the Victorian Government declared a moratorium on the conduct of
aerial baiting throughout the state in 1987. This was largely due to concern about the use of 1080
poison to manage impacts of native browsing species on plantation seedlings. Since that time,
limited aerial baiting has occurred. The Minister directed research on impact of aerial baiting to
reduce wild dog populations and secondly, two field trials of the Curiosity® bait for feral cats were
conducted under permit from the APVMA.
The tools available for management of feral cats (as defined by the TAP) in Victoria are limited to
cage trapping, barrier fencing and shooting as well as encouraging responsible pet ownership in
adjoining areas. I urge the Committee to consideration the necessary legislative change required in
order that other tools, such as poison baiting (i.e. Curiosity®) and grooming traps, might be used in
Victoria when they become commercially available.
Similarly, I believe that rubber-padded leghold traps should also be an option for land managers
and their contractors in the same way that applies to wild dogs (i.e. an exemption in the Prevention
of Cruelty to Animals Act for use of traps set for animals listed as a pest under CaLP).
Leghold traps are effective tool for capture of cats and when set by experienced people and
facilitate capture of all age / sex classes of cats throughout all seasons. A cage trap, usually prepared
with a food lure, is biased towards capture of animals accustomed to wire and less skilled at hunting.
A leghold trap, set with blended cat faeces and urine, is attractive to all other cats given their innate
territoriality behaviour, (i.e. who is in ‘my patch’).
To conclude, I would like ENRRDC to consider the above information and determine whether the
Victorian legislation provides the best framework for the management of a highly invasive species
that causes a significant impact on our wildlife species.
Regards,
Michael Johnston
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