The Invasive Species Council (ISC) welcomes the opportunity to comment on the release of the updated Threat Abatement Plan (TAP) for predation by feral cats.
The updated TAP for predation by feral cats presents a significant opportunity to curb the impacts of feral and roaming pet cats on wildlife, but only if it is adequately funded and fully implemented.
The revised threat abatement plan is detailed, comprehensive and underpinned by extensive research and expertise.
While the plan is strong, no specific new funding has been identified to ensure the plan can achieve its goals. Without new and targeted funding, we do not have confidence that this new TAP will be any more successful than the previous three cat TAPs in protecting native wildlife from the impact of feral and roaming pet cats.
The impact of feral cats on wildlife in Australia has been devastating. Feral cats have contributed to the extinction of at least 20 native mammals, and predation by feral cats is listed as an identified threat to over 200 nationally listed threatened native species. As a major driver of mammalian extinctions in Australia, ensuring the TAP for predation by feral cats is adequately resourced and implemented is a necessary step if the Australian Government is to achieve its ambitious target of ‘no new extinctions’ that sits within the Threatened Species Action Plan 2022-32.
The core priority for the Australian Government should be to ensure the TAP is fully funded. No threat abatement plan has been fully funded before, and this would signal a significant improvement to the threat abatement system.
1) Implementing the threat abatement plan
Recommendation 1: Commit at least $88 million from the Federal budget to the implementation of the first four years of the plan. This should include:
- $12 million per year for implementation of the base plan;
- $10 million per year for Indigenous-led management of feral cats;
- $100K per year to chair and operate the National Domestic Cat Management Working Group; and
- $500K (once-off) to revise the humaneness assessment and code of practice for feral cat control tools.
Recommendation 2: Establish a funding pool of A$10 million per year for the duration of the plan to support and enhance Indigenous-led management of cats in Australia (as per recommendation 1 and supplementary to the baseline funding).
Recommendation 3: Under objective 2, request each state and territory to develop and implement a subsidiary cat action/management plan, specifying their intended actions to implement the national TAP.
2) Maintaining national leadership on feral cats
Recommendation 4. Continue to invest in the Feral Cat Taskforce as a long-term mechanism to coordinate feral cat management and re-establish the National Domestic Cat Management Working Group.
3) Ensure terminology supports effective management, is consistent and broadly understood
Recommendation 5: Include an action under Objective 1 to collaborate with state and territory governments and other relevant stakeholders to develop and adopt consistent definitions for categories of cats for management purposes, to provide clarity over responsibilities, expectations and appropriate control tools.
4) Protecting species of cultural significance to Indigenous peoples
Recommendation 6. Expand Objective 6 to specify objectives and actions to protect Culturally Significant Entities (defined as animals, plants, ecological communities with spiritual, cultural or symbolic significance to Indigenous Australians) from the impact of cats. Such entities should be included in the creation of predator-free havens, noting there is likely some overlap with cat-susceptible species.
5) Improving tools to inform decision making on feral cat management
Recommendation 7: Under Objective 2, support the design of an interactive and costed ‘map’ for optimal cat control across Australia, that integrates the conservation values and susceptibilities of local species (and thus the level of cat control required), the feasibility of 6 control options, and the employment opportunities for local people (as previously proposed by the Threatened Species Recovery Hub).
Recommendation 8: Under Objective 2, develop a centralised website on feral cat management in Australia that aims to increase overall engagement in feral cat management by supporting and connecting practitioners, and disseminates information on cat management options, decision-making support tools, humane control and community education packages.
Recommendation 9: Under Objective 3, undertake a body of work to refine the predicted prevalence map for Toxoplasma gondii, as a tool to help inform key areas to focus research on toxoplasmosis impacts in Australia, including impacts of cat-dependent diseases to native wildlife, livestock and people, and options for responses.
6) Ensuring social licence is maintained to support feral cat management
Recommendation 10: Incorporate into the TAP broader aspects of social licence relevant to the lethal control of cats (e.g. cultural concerns of Indigenous Australians, views of society on animal welfare).
Recommendation 11: Specify as part of action 4.3 that field trials and refinements of new tools like the Felixer grooming traps should also focus on developing the use of PAPP as an option.
Recommendation 12: Support the development of an updated humaneness matrix and model code of practice for feral cat control methods in Australia (estimated to cost A$500,000 as a once off-cost at the start of the plan) in addition to action 2.11.
7) Demonstrate federal leadership on domestic cat management
Recommendation 13: Lead a process to develop a national domestic cat management plan that sits under, and is supplementary to, the threat abatement plan for predation by feral cats. This plan should be a core objective under objective 9 and refine the actions under this objective.
Recommendation 14: Amend objective 9 to:
- Acknowledge the role of the animal welfare and rescue sectors in domestic cat management, education and uptake of responsible cat ownership practices (such as desexing and containment) and ensure these groups are reflected in the actions, including as responsible organisations.
- Express that any form of control should occur via legal pathways and illegal cruelty to roaming cats around areas of human habitation and infrastructure is not tolerated.
Recommendation 15: Re-establish, fund and support the National Domestic Cat Working Group to improve cooperation on domestic cat management and address complex issues relating to pet cats in Australia (e.g., national pet overpopulation, cat hoarding, and backyard breeding) (relates to Objective 9).
8) Strengthening Australia’s threat abatement system
Recommendation 16: Consider as part of the upcoming reforms of the EPBC Act how states and territories can be required (for example, as part of funding agreements) to prepare implementation plans for all relevant threat abatement plans.