DO SOMETHING! Make a submission!

Currently, the South Australian government is seeking submissions on companion animal welfare (specifically dogs and cats).  That is, they want to know what legislation could be introduced to improve animal welfare and reduce euthanasia in shelters.

You need to act before the 16th of January 2013.

You can find more details on the submission process on the Parliament of SA website.

Below, I am providing both a summary of my submission, and the body of my submission, too. Though I welcome individuals to write a submission and use mine for inspiration, I hope that you add your own personal touches to the submission, and don’t just take mine ‘word for word’. (Though I personally don’t have a problem if you do – it’s just less powerful if you do!)

If you’d like to download the submission, you easily can: download selectcommittee.pdf

Update as of 16th January: This is the submission I actually made: In Response to the Terms of Reference

Otherwise, below is the document practically copied and pasted into this blog entry:

Firstly, here is a summary of my submission.


In Response to the Terms of Reference

a) options for the regulation of welfare standards for breeding companion dogs and cats,

Key points:

  • More strict enforcement of current legislation – i.e. the Animal Welfare Act – which requires food, water and shelter.  Perhaps the enforcement of this act needs to go to individuals beyond the RSPCA – like extending powers to council rangers or police (with training).
  • Mandatory socialisation of puppies and kittens from 3 weeks and up.

b) the adequacy of regulation of the source of companion dogs and cats for sale,

No comment.
c) the feasibility of a mandatory cooling off period between registering intent to purchase a companion dog or cat and taking possession of the animal,

Key points:

  • Requiring a cooling off period may negatively impact upon rescue organisations, who may in turn have to make space-based euthanasia.
  • Puppies are rarely relinquished to shelters, suggesting that puppies are rarely unwanted. Furthermore, surveys from those surrendering dogs rarely checked ‘unwanted pup’ as a surrender reason.

d) the adequacy of the regulation of non-retail-shop trade in companion dogs and cats,

Key points:

  • As many cats and dogs surrendered to shelters are acquired from ‘friends’, this illustrates a call for action in this area.
  • Non-retail shop trade must account for the majority or animals being sold annually.
  • Free roaming cats are a major source of cat-breeding.
e) how the registration, micro chipping and desexing of companion animals may address these goals,Key points:

  • Dog registration
    • Effective in revenue raising though it needs to be more effectively enforced.
    • Should be expanded to provide discounts for puppy classes.
    • Should be more substantial differences between desexed and entire dogs.
    • Subsidies for the registration of rescue dogs in foster care.
  • Cat registration may cause an increase in relinquishments due to increased expense
  • Micro chipping should become compulsory before sale.
    • It should be a government-based database.
    • There needs to be legislation regarding procedures for scanning animals for chips, and then procedures for making contact with owners, to ensure optimum owner returns.
    • Should be a means to nominate breeders, to identify any problematic breeders or trends in surrendered animals.
    • Education on changing microchip details.
  • Desexing is a medical procedure that should be determined on a case-by-case basis (i.e. should not become mandatory).
    • Early age desexing, especially for cats, should be promoted.
    • Desexing of semi-owned cats should be a target.

f) any other relevant matters.

Key points:

  • Legislation should be implemented that reduces euthanasia in shelters;
    • Mandatory strategies for increasing reclaims, and;
    • “Oreo’s Law”: That no animal can be euthanised where an individual or rescue group is prepared to take the animal into are, and;
    • Mandated time for adoption.
  • Requirement for landlords to accept pets in residential tenancies.
  • Temporary boarding at minimal or no cost in times of owner difficulty.
  • Trap Neuter Release needs to be utilised.
    • Benefits of TNR
    • Response to Arguments against TNR
  • Education of pet owners, including future-pet-owners in schools.
    • Dog bites
    • Breeding
    • Reclaims
  • The establishment of an independent regulatory body on all matters of companion animal welfare.
  • Improved record keeping by council and shelter facilities.


And here is the whole body of my submission. (Please excuse any minor typographical areas that are below. I am still in the process of writing this submission, but wanted to provide enough time for you to get your submission in!)

In Response to the Terms of Reference
a) options for the regulation of welfare standards for breeding companion dogs and cats,

Re: More strict enforcement of current legislation

There are too many stories of the RSPCA failing to act in light of information on Animal Welfare Act violations.  The government needs to reassess whether the RSPCA is the most suitable use of their funding, and instead consider training police or council workers in animal welfare and enlisting them to enact welfare regulations.


Re: Mandatory Socialisation of Puppies and Kittens

Socialisation has two benefits: It makes animals more ‘liveable’ and so less likely to be surrendered, and also reduces the risk of euthanasia if they do enter a shelter.

Many researchers have found that a large proportion of animals are surrendered for behavioural issues.  Salman et al. (1998), in the USA, found that 28.8% of dogs were surrendered for behavioural issues, and 21.1% of cats.

Furthermore, being socialised is a risk factor for euthanasia when admitted to shelters.  Marston et al. (2006), when studying cats admitting to Melbourne shelters, found that sociability by far had the greatest effect on their outcome – i.e. whether they were euthanised or adopted.

Research by Pluijmakers et al. (2010) and Scott & Fuller (1965) show that experiences from 3 weeks of age, in puppies, can change their behaviour.  For this reason, it is important that individuals rearing puppies are commencing socialisation as soon as possible.  Though interaction with people would be most desirable, substitutes like televisions (played within visual and audio range), toys in pens, and exposure to different surfaces are potential habituation approaches that could modify the behaviour of the puppy, for the better, long term.
c) the feasibility of a mandatory cooling off period between registering intent to purchase a companion dog or cat and taking possession of the animal,

Re: Impacts on shelters

Currently, the large Adelaide based shelters claim that there is a pet overpopulation problem that results in large euthanasia rates.  That is, the population of pets they receive exceeds their holding capacity.  One means to reduce the number of pets in their care is to adopt them, but a mandatory ‘cooling off’ period may mean that animals are required to spend longer periods of time in a shelter environment.  Not only is this stressful for the animals held for longer periods (increasing risk of them becoming ‘kennel crazy’, as in Coleman et al. 2011), but it may also put further stress on shelters already straining on the number of animal impounds.  That is, a mandatory cooling off period may require shelters to increase euthanasia as a result of lack of space.


Re: Puppies aren’t unwanted

Very few puppies are surrendered to shelters, and very few puppies are described as unwanted when surrendered, according to Marston et al. (2005) in research conducted in Melbourne shelters.  Only 10.2% of dogs entering the shelters were puppies.  Furthermore, only 6.47% of dogs surrendered to the shelter were surrendered for the reason of “unwanted pup”.  In this way, it seems unlikely that a cooling off period would alter the desirability of puppies.
d) the adequacy of the regulation of non-retail-shop trade in companion dogs and cats,

Re: Shelter intakes from ‘friends’

In New et al. (2000)’s research, both cats and dogs that were acquired from a ‘friend’ were more likely to be surrendered to a shelter.  This indicates that the non-retail-shop trade has a significant relationship to shelter surrender and euthanasia.


Re: Backyard breeders produce many pets

Approximately 450,000 dogs are sold in Australia each year (ABC News).  However, pet shop puppy sales are less than 70,000 pups per year (ABC News).  Furthermore, the Australian National Kennel Club (the purebred dog register), had on average 63,465 puppies registered per year from 2009-2011 (ANKC website).  This leaves over 300,000 dogs being sold from largely unregulated sources, such as ‘backyard breeders’. For this reason, it is clear that regulation in this area is highly desirable, considering the volume of animals produced.


Re: Free roaming cats are breeding

Any regulation on non-retail-shop trade needs to adequacy address the breeding of free roaming cats.  This will be further considered in section (f) of the terms of reference, looking at trap-neuter-release (TNR) strategies and their effectiveness.

One potential way to target free-roaming cats is through ‘last litter funds’.  Marston et al. (2006) argued for this to be investigated when examining cat intakes into Melbourne shelters.  Kitten season often sees two intake ‘spikes’, suggesting that many queens are producing two litters during breeding season.  When individuals enter shelters to surrender a litter of kittens, that individual may act as an access point for desexing the mother cat.  Kitten-only surrenders should lead to queens being targeted for desexing, instead of allowing for a second litter to be produced in the breeding season.
e) how the registration, micro chipping and desexing of companion animals may address these goals,

Dog Registration

Re: Dog registration

Dog registration has been an effective way to raise revenue for council’s animal management.  The Dog and Cat Management Act, who legislates the use of these funds, is a successful way to ensuring these funds are appropriately used.  However, Councils and the Board are ‘missing out’ on funds as a result of individuals failing to register their pets.  There needs to be stricter enforcement of this existing legislation to ensure that all dogs are registered, as per the Dog and Cat Management Act, to guarantee that optimum dog funds reach important animal management projects.


Re: Discounts for dog registration through puppy classes

There is no doubt that puppy classes are effective in terms of puppy and owner education (Seksel 2008).  Furthermore, Duxbury et al. (2003) reported that puppies who attended puppy socialisation classes were more likely to be retained by their owners in adulthood.

According to Hugh Wirth, from the RSPCA Victoria, dogs are surrendered to shelters for behavioural problems such as destructiveness, barking, digging, fence jumping, escaping, anxiety, fear, dislike of people, inappropriate toileting, and attacks on other animals (Wirth n.d.).  A study by Seksel et al. (1999) demonstrated that puppy class can be highly successful for training dogs basic commands.  Lack of socialisation is associated with aggression and avoidance of people (Appleby et al. 2002), and so puppy classes seek to counteract this.  Additionally, puppy classes provide a venue for new owners to be schooled on means of preventing all these potential problem behaviours.

These type of behavioural problems are often the result of dogs being surrendered in shelters.  In New et al.’s (2000) study, dogs surrendered to shelters were more bitey, less toilet broken, more likely to damage things in and out of the house, more hyperactive, and more noisey than other households studied.  Again, all problems that could potentially be prevented through puppy school education.


Re: Discounts for desexing

Discount registrations for dogs that have been desexed is an excellent method to encourage desexing.  It may be necessary to make these desexing discounts mandatory, and perhaps increase the difference between entire and desexed animal registrations, to provide more of an incentive for people to desex their dogs.


Re: Rescues and dog registration

Currently, all dogs over 12 weeks old and residing at a premises for 2 weeks or more are required to be registered.  For small private rescues who use foster care networks to rehome dogs, this is a significant burden on their often limited finances.  Furthermore, these small private shelters are assisting to reduce resource drain on the large shelters and deserve some recognition for these efforts.  There should be some investigation on voiding or reducing registration rates for dogs that are in foster homes on a temporary basis.


Cat Registration

Cat registration is not currently effective in South Australia, and seems to have little benefit.  Though the government may benefit from revenue from cat registration fees, there are issues in compliance.  Additionally, it becomes difficult to ascertain ownership of cats that spend some time outdoors.  Another complication of cat registration is that individuals may choose to relinquish their pets to a shelter in lieu of paying registration fees, and so compound the shelter euthanasia problem (Williamson 2009).  Even when states where registration is compulsory, very few cats wear their registration tags and so they are little help in reclaims (see Marston et al. 2006 that showed that 0.04% of cats admitted to Melbourne shelters studied wore a registration tag on intake).  Additionally, in Melbourne shelters, 36.37% of owners, when surrendering a cat, stated that “too many cats” was the reason, with a further 5.78% stating “cannot get council permit”.  Marlston et al. (2006) suggest that these reasons may be interconnected, and that council restrictions on cat numbers may have an influence on the relinquishment of cats to the shelters.


Micro chipping before sale

Laws that require dogs and cats to be micro-chipped before sale would be a means of helping more pets return home.  Additionally, micro-chipping allows a means to identify animals that may be involved in ownership disputes, or even identifying dangerous dogs and seeking legal action.

Unlike arguments against cat registration, requiring animals to be micro-chipped only before sale does not have the issues associated with animal relinquishment.  It is only when animals are being sold or transferred that they are required to be ‘chipped. There, of course, needs to be a clause to allow animals to transfer animals to rescue groups without penalty.


Legislation on micro-chipping procedures

Microchips are worthless without procedures regarding their implantation, registration, scanning, and access to the database.

Firstly, there should be a limit of one microchip per animal (i.e. an animal should not be implanted with two ‘chips).  This requires implanters to scan animals for a microchip before implantation and, if a chip is found, the database holding the microchip data should be contacted for change of ownership, in lieu of a second microchip being implanted.

Currently in South Australia, microchips records are managed be private companies.  This means that they have their individual policies in regard to registration and change of ownership, some of which are flawed.  A government managed database, such as that seen in NSW, could be an excellent way to produce consistency in micro-chipping. This is also a means of revenue raising.  This database needs to be accessible Australia wide, in case pets travel across state boarders when lost.

Again, there is no legislation governing the scanning of animals that may be lost.  Indeed, the Dog and Cat Management Act does not even mention ‘microchip’ in any capacity.  This desperately needs to be changed in order to improve owner reclaim rates.  In the first instance, an animal management officer, collecting a dog in the field, should scan the dog for a microchip and attempt to return the animal to its owner, without admitting it to a shelter.  Because microchips can migrate, and scanners can be ‘temperamental’, each impound facility should have two scanners that they run over the dog on two separate occasions, by two separate people, before it is determined that the animal is ‘chipped or otherwise.

In the case that animals are microchipped, then all details on their microchip should be used in order to optimise reclaims.  The phone numbers should be called, the postal address should be sent a letter, and the electoral role should be used to attempt to find the owner’s new location.  If animals get to go home, this means they are not at the shelter to suffer the fate of euthanasia.


Nomination of breeders on microchips

Breeders should be responsible for their animals for their lifetimes, not just up until sale. To nominate breeders on microchips would be useful for statistical purposes, at the very least.  Marlston et al. (2006) suggested that locating breeders could be a step in reducing euthanasia rates in shelters.


Education regarding changing details on a microchip

Many people move house and neglect to update their pet’s microchip details.  Education needs to take place regarding this, to make sure that pet microchips stay up to date and ensure optimum reclaims.  This type of education could be distributed in ‘moving house’ packs, like those distributed by Australia Post or electricity providers.  Real Estate agents could also distribute microchip address change forms with new home purchases.  These simple steps could be a great way to reduce pets ending up in shelters that are microchipped, but owners are not contactable.


Desexing is a medical procedure and should not be mandated

While desexing is a common procedure, it is still a medical operation performed under anaesthetic by licensed veterinarians.  There are numerous health effects associated with desexing, and not desexing (Sanborn 2007), and so the choice to spay or neuter a pet should be left to the discretion of vets and owners.

While New et al. (2000) noted that desexed pets were less likely to be surrendered to shelters, Marston et al. (2006) noted that over 90% of pet cats are desexed and so efforts to desex more pet cats is unlikely to reduce cat numbers.


Promotion of early age desexing in cats

Despite desexing being an individual choice, many individuals believe their pet is ‘too young’ to be desexed (18% in a study by Byrd Subacz 2008).  In reality, early age desexing (EAD) may be a viable means to prevent litters in cats before they are 6 months old.  While Marston et al. (2006) is pessimistic about the impact this would have on shelter admissions, it may have effects on free ranging and un-owned cats that do enter shelters.  Regardless, Byrd Subacz (2008) and Marston et al. (2006) identifies that increased education on feline reproduction and fertility in cat owners is needed.


Low cost cat desexing

While the majority of owned cats are desexed, the cost of desexing may be a significant barrier to cat desexing for the 10% whose cats are entire (Byrd Subacz 2008, Marston et al. 2006).  Avenues to subsidise, reduce, or even standardise cat desexing may be a useful way of reducing pricing barriers.


Desexing of semi-owned cats should be a target

Marston et al. (2006) concluded that most cats entering shelters are likely to be ‘semi-owned’ cats, and efforts should be made to desex these populations.  The study indicated that further research is required into the psychology of community cat feeding, and what incentives could be used to encourage these ‘semi owners’ to desex the cats they are caring for.  Marston et al. (2006) also suggested that a mobile desexing van may be a means to reach cats that are restricted by transport issues.
(f) any other relevant matters.

Animal shelters need to be legislated in ways that reduce euthanasia.

The terms of reference are targeting the source of companion animals, but neglect to note that animal shelters are actually the places where euthanasia takes place.  Animal shelters are not obligated to euthanise animals, and instead implement policies that make the destruction of animals part of the facility’s culture.  Considering consistently high euthanasia rates at the two major metropolitan shelters in South Australia (the RSPCA SA at Lonsdale and the Animal Welfare League (AWL) at Wingfield), these facilities have shown their inability to make proactive changes to improve reclaiming and rehoming.  In this way, implementing legislation that obligates shelters to undertake best practice may be beneficial in reducing euthanasia rates.

Mandatory strategies to increase reclaims

Many pet owners try to find their animals if they become lost or stray, but many pets aren’t reunited with their owner.  Shelters should be mandated to seek the pet’s original owner – if one extra pet goes home this means that one pet is not at the shelter at risk of euthanasia.

There are a number of strategies that could be implemented to encourage pets to go home:

  • All impounded animals should be listed on a central, government-owned database online.  This database would include the animal’s photo, where they are impounded, on what date they were impounded, and anything significant about the pet (e.g. if it was wearing a collar, if it was microchipped, and so forth).  This would allow people who have lost their pets the ability to be able to see recent impounds from the comfort of their home, and remove the inconvenience of these individuals having to physically enter a shelter to locate their pet.  Furthermore, having photographs of pets listed online reduces complications associated with animals being admitted to a shelter as an incorrect breed.
  • As previously stated, microchipping should become compulsory, the details listed on a central, government-owned database, and procedures regarding microchipping should be mandated.  This includes all details listed on the ‘chip to be used to locating the owner and assisting reclaim.
  • Shelters should be required to be open at convenient times to assist reclaims.  For example, the ‘average worker’ works from 9am-5pm, yet the RSPCA SA is open only 10am-5pm and the AWL SA only 10am-4pm.  For working owners, this makes it close to impossible to reclaim their pet during the week.  Facilities that impound lost animals should be required to be open during ‘non-work’ hours (for example, 8am-8pm), to allow animals to be reclaimed.  Not only is this beneficial for the welfare of that individual animal, it also frees up facilities for use by animals entering the facility.
  • Lost pets should be held for longer than 72 hours to, again, allow owners the time to reclaim their pet.  Current, animals impounded can be euthanised in 72 hours with the impound facility not mandated to make any efforts in locating the owner of that pet.

“Oreo’s Law”

Currently, RSPCA SA and AWL SA refuse to work with private rescue groups.  Countless animals could have been spared the fate of euthanasia if these major shelter groups had accepted offers of help from private rescue groups.  It is clear that these large shelters are not prepared to, voluntarily, act in the best interest of their impounded animals.  For this reason, “Oreo’s Law”, which obligates shelters to work with rescue groups when the alternative for that animal is euthanasia.  That is, a shelter could not destroy an animal that had an individual or rescue group prepared to take custody of that animal.  This is one of the recommendations in the Companion Animal Protection Act (CAPA n.d.).  Winograd (2009 & 2012) estimates that over 60,000 animals in the New York Shelter could have been saved by this type of legislation.  It has the possibility of saving pets in South Australia, too.

Mandated time for adoption

Like shelters are currently obligated to hold an animal for reclaim for 72 hours, they should also be obligated to hold an animal for adoption for a set period of time, instead of immediately euthanising animals after their time has lapsed.  CAPA (n.d.) recommends a minimum impound period of 5 days, where 2-3 days are set aside for reclaims, and 2 days set aside for adoption.  Furthermore, shelters should be open for adoption for at least 6 hours, seven days a week (except on public holidays), as recommended in CAPA (n.d).  These types of actions would allow more animals to reach new homes, and so not be destroyed in a shelter environment.


Require all landlords and real estate agents to permit pets into residential properties with no penalty.

Individuals who surrender pets to shelters are frequently forced to due to ‘human housing issues’ (Marston et al. 2005, Salman et al. 1998), including tenancy issues.  Currently, landlords are able to discriminate against potential tenants on the basis of their pet ownership status.  Clearly, this is a problematic approach where individuals are forced to surrender animals to shelters in order to find accommodation – or worse, individuals who chose to live homeless instead of surrender their pet.  Undoubtedly, the status quo in residential tenancy is harmful to people and pets.  Landlords and real estate agents should not be able to impose pet bans on properties due to the harmful animal welfare complications this brings.


Temporary Boarding Options

As an extension of the above, another option is for governments to subsidise temporary accommodation for pets when owners are in difficulty.  This could be times where appropriate accommodation cannot be found (e.g. finding a landlord that will accept pets), or where individuals choose to move house to avoid domestic violence situations and need to take their animals with them, or even during natural disasters (Hunt et al. 2012). Currently, these kind of scenarios can lead to animal welfare concerns and potential surrender of animals to shelters, which may result in them being euthanised. RSPCA NSW (n.d.) runs a “Living Ruff” program that provides temporary accommodation to pets when required.  In Marston et al.’s (2006) study of Melbourne animal shelters, she found that all cats that were admitted for “owner support” reasons were reclaimed, which illustrates the success of programs designed to keep pets with their families in difficult circumstances.


Implementation of Trap, Neuter, Release Programs (instead of admitting cats to shelters)

Trap, Neuter, Release (TNR) is free-roaming-cat management method. Because many cats trapped in the community are not sociable enough with people (i.e. ‘feral’) to be adopted, they are instead desexed and returned to the community (Wolf n.d.).

While initially this method seems counter-intuitive to the goals of animal welfare and reducing euthanasia, evidence suggests this is not the case.  Not only has this method proved to be effective in reducing free-roaming cat populations, it has also been illustrated to reduce euthanasia in shelters, increase adoptions in shelters, reducing rodent populations, and for less expenditure than traditional trap-kill models.

Trap-and-kill models have been in place for 30 years or more, to a huge amount of expense. However, it rarely results in eradication (Wolf n.d.).  The few examples where cats have been eliminated from environments have mostly been small islands, where eradication was a costly and long-winded process (Wolf n.d.).

Benefits of TNR

TNR programs have continually lead to a decrease in free-ranging cat populations. For example:

  • In Florida, Levy et al (2003) undertook an 11 year study on free-roaming cats on a university campus.  They found that the population decreased by 66% over 3 years following TNR.
  • In Byrd Subacz (2008)’s own study, Auburn University reduced the population of 150 feral cats to 45 in 2 years as a result of TNR.
  • During a 13 year study, the cat population at Stanford University was reduced from 1,500 cats to just 200 cats as a result of TNR (Byrd Subacz 2008).
  • The University of Central Florida saw a decrease from 155 to just 23 cats following the implementation of TNR (Byrd Subacz 2008, Wolf 2012, Wolf n.d.).
  • In Randolph County, NC the decrease in free-ranging cat population was 36% after TNR (Wolf 2012, Wolf n.d.)
  • Rome, Italy saw a decrease of 22% following a TNR program (Wolf 2012).
  • A study in London Park saw a reduction in the number of cats as a result of TNR (from Neville & Remfry 1984 as cited by Byrd Subacz 2008).

TNR have often been hailed as more cost effective than traditional ‘trap-and-kill’ models.  For example:

  • In Jacksonville, Florida, TNR was implemented from 2007-2010 and resulted in savings of $160,000 (Best Friends Animal Society 2012).
  • TNR, in Salt Lake City, was launched in 2008 and saw overall costs savings of more than $65,000 (Best Friends Animal Society 2012).
  • In Maricopa County, Arizona, it costs $23 to TNR and $61 to trap, hold, euthanise a cat (Best Friends Animal Society 2012).
  • In Indianapolis, Indiana it costs $20 to TNR and $130 to trap, hold and euthanise a cat (Best Friends Animal Society 2012).
  • Orange County, in Florida, found TNR to be more cost effective than trap-and-kill (in Hughes et al. 2002 as cited by Byrd Subacz 2008).

TNR often sees less cats entering shelters, and subsequently euthanised.  Several studies have shown this:

  • Orange County, in Florida, had less cats impounded in shelters, and less euthanised, as a result of the program (in Hughes et al. 2002 as cited by Byrd Subacz 2008).
  • In Jacksonville, Florida, TNR was associated with a 31% decline of feline shelter admissions, and a higher live-exit rate from the shelters (Best Friends Animal Society 2012).
  • TNR in 2008 in Salt Lake City saw 2009 shelter intakes were reduced by 21.8% (Best Friends Animal Society 2012).
  • San Jose adopted a TNR program in 2010, and saw a 25% drop in cats/kittens entering shelters (Gonzales, A 2013).


Additionally, TNR seems to be associated with increased adoption (in places like Salt Lake City (Best Friends Animal Society 2012), Place County SPCA, and San Jose (Gonzales 2013)). Presumably, because less animals are admitted to a shelter, the ones that are in the shelter have more socialisation and training, and are more likely to find a home (Best Friends Animal Society 2012).

Response to arguments against TNR

However, despite TNR’s demonstrated success in reducing shelter euthanasia and, indeed, the number of free ranging cats overall, a number of arguments are made against TNR.  These are made on both the Homeless Cats SA website (2012) and the “Who’s For Cats” website (2009) run by the Department of Primary Industries in Victoria, as well as the general public.

One argument against TNR is concerns for the welfare of the free-ranging cat population.  All well-managed TNR programs allocate caretakers to feeding colonies, and this caretaker is responsible for monitoring the well being of the cats (Byrd Subacz 2008).  However, many TNRed cats are in good condition, with similar weights and disease status as pet cats (Byrd Subacz 2008).  Indeed, desexing itself increases cat-weights and reduces the spread of disease (Best Friends Animal Society 2012, Byrd Subacz 2008).  Most cats entering Melbourne animal shelters are at optimum weight (Marston et al. 2006), and in a 11 year study in the USA which considered 103, 632 free roaming cats, less than 1% were found to be in such poor health that they needed to be euthanised (Best Friends Animal Society 2012b).  Additionally, free roaming cats live reasonably long lives, with many cats living to six years or older (Best Friends Animal Society 2012).  Furthermore, TNR has been associated with a 17% reduction in cat road kill in San Jose (Gonzales 2013).  It seems, contrary to popular belief, TNR actually has a range of benefits to cat health.

Some express concerns for free roaming cats impacting on native wildlife.  However, cats and native wildlife maintain a complex ecosystem, and it is hard to estimate the effects that cats have on wildlife populations.  Potentially, removing a cat from ecosystems may see other non-native species flourish (Wolf 2010).  This is especially true when we consider cats are known for mostly preying on rodents (Byrd Subacz 2008, Gonzales 2013).  Indeed, in Boston, free-roaming-cats were used as a solution to a 25-year strong rat problem (Shelter Me Inc. n.d.).  Furthermore, well-fed cats are less likely to catch and kill wildlife, and Neville & Remfry (1984, as cited by Byrd Subacz 2008) found that a TNR program in Londan Park “eliminated” cat predation on waterfowl.  While cats are likely to prey on some native wildlife, evidence suggests that they are more likely to prey on rodents.

Cats are also responsible for a range of nuisance behaviours in the community.  However, when TNR is implemented, many of these behaviours are lessened as they are associated with breeding (Best Friends Animal Society 2012, Byrd Subacz 2008).  Furthermore, cats roam less once neutered (Byrd Subacz 2008). Jacksonville, Florida found in 2007-2010 during a TNR program that their nuisance complaints decreased (Best Friends Animal Society 2012).

Thus, it seems that concerns regarding cat welfare, wildlife predation and nuisance behaviours are unsubstantiated and mostly disproven by current evidence.  The benefits associated with TNR have been wildly demonstrated, globally, as a means of improving cat welfare outcomes.



To prevent dog bites

The Dog and Cat Management Board (D&CMB) has proactively funded education to young children aimed at preventing dog bites, through the Delta Dog Safe Program and, more recently, the Responsible Pet Owners Program.  Both of these are worthwhile programs, which may curb the number of dogs surrendered to shelters with bite histories and for euthanasia.  However, child behaviours are only part of the dog bite problem, and investment should be increased in parent education.  Though the D&CMB also provides parent education in the form of the “We Are Family Program”, this program needs to be much more active and far-reaching in order to provide substantial impact.

To prevent animal breeding

Byrd Subacz (2008) and New et al. (2000) explained that many individuals who choose to surrender their animals to a shelter are not knowledgeable on animal reproduction.  This means that pets in their care are at risk of reproduction-based conditions, and may also contribute to the population of pets through ‘accidental’ offspring.   There is a need for increased knowledge on animal reproduction in pet owners.  Knowledge on companion animal reproduction also needs to span into desexing, especially early age desexing, particularly considering that many people consider their pet ‘too young’ to be desexed (Byrd Subacz 2008), which means that they are at risk of producing a litter before desexing takes place.

To increase understanding of reclaims

It is inevitable that, at times, some pets will become lost and owners will need to find them.  However, many owners do not know the most efficient means of searching for a lost pet.  They often will physically look for the pet themselves, and maybe put up posters, but often don’t realise they should contact their local councils and the major animal holding facilities in the state.  In order to ensure that more animals are reclaimed, and less subject to shelter euthanasia, education efforts need to be undertaken to the pet-owning public.


Establishing an independent regulatory body

A recent report from Goodfellow (2012) illustrated the inadequacy in current animal welfare legislation creation.  He says, “The current arrangements for animal welfare regulation do not represent an efficient and effective use of public funds… [and] also fail to serve the public interest in delivering independent and objective animal welfare science, and substantive laws which reflect government policy and community expectations.”  Particularly, individuals concerned with agriculture and primary industries are at the forefront in establishing policy, despite having a clear conflict of interest by being invested in animal productivity.  Goodfellow argues for the establishment of an independent regulatory body, a Commonwealth Office of Animal Welfare, which is not solely composed of individuals with vested commercial interests (such as vets and farmers), and that the current system lacks legitimacy, fairness and equality.  In short, current animal welfare policy is commercialised and lacks input from animal welfare groups.


Improved record keeping by councils

Currently, the Animal Welfare League of SA does not release its euthanasia statistics.  Councils are also not forthcoming surrounding the number of animals they have impounded and the outcome for those animals.  These statistics are vital in determining areas of weakness surrounding animal welfare, and for eliciting public discussion regarding shelter procedures.  At this present time, it’s uncertain what the true animal welfare situation is in South Australia.  Transparency in shelter procedures is one of the recommendations from CAPA (n.d.), which also advocates for shelters to display these statistics publicly and make them known to individuals surrendering pets to facilities.



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You can find examples of submissions (which I don’t necessarily support all components of, but may help you in formulating your own submission):

Deathrow Pets (very similar to this one as Paul (with my blessing) used mine as a base for writing his own)

The Paw Project created a submission (focusses on no-kill processes in section f, not dissimilar to mine)

Animals Australia (many of their suggestions do not have research evidence to support it – for example, mandatory desexing has never been associated with a decline in shelter intakes. Regardless, I have linked their ideas in order to be inclusive.)

Moorok Animal Shelter posted a list of questions that you might like to ask yourself as formulating a response

Please please DO SOMETHING and write your submission this week!

2 thoughts on “DO SOMETHING! Make a submission!

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