When the Columbia, MO, city council meets July 5th, they’ll be voting on “Amending Chapter 5 of the City Code relating to animals and fowl.” Many of the proposed amendments are found in Article VI, which addresses issues related to feral cat colonies and the numerous requirements being proposed for their caretakers—including two-year permits and yearly FeLV/FIV testing.

While it’s encouraging to see city officials debating this important issue, Columbia’s proposed ordinance (PDF) is likely to do more harm than good—for the cats, their caretakers, and for the community as a whole.

* * * Readers interested in contacting city officials will find contact information here. * * *

Article VI reads as follows:

Sec. 5-111. Feeding a feral cat colony without a permit.

No person shall provide food, water or other forms of sustenance to a feral cat colony without a feral cat colony caretaker permit.

Sec. 5-112. Feral cat colony caretaker permit.

(a) Any organization or individual over the age of eighteen (18) may submit an application to the department for a feral cat colony caretaker permit. The application shall be on a form provided by the department and shall provide the following information:

1. A detailed description of the cats in the colony;
2. Proof that the feral cats in the colony have been ear tipped and microchipped, neutered or spayed and vaccinated against rabies or are spaying and vaccination against rabies;
3. The address of the private property where the colony will be maintained;
4. Written permission from the private property owner to maintain the colony at such address; and
5. Contact information for the applicant and any other information that may be required by the department.

(b) Feral cat colony caretaker permits shall be issued for a period of two (2) years.
(c) A permit fee of twenty-five dollars ($25.00) shall be paid when the original application is submitted and biannually for permit renewals.
(d) An animal control officer may inspect the private property where the feral cat colony will be maintained.
(e) No feral cat colony caretaker permit shall be issued for a feral cat colony located on public property.

Sec. 5-113. Requirements for care of feral cat colonies.

Every person issued a feral cat colony caretaker permit shall comply with the following requirements:

1. Regularly feed the cat colony, including weekends and holidays.
2. Annually trap each cat over the age of eight (8) weeks in order to comply with requirements (3) through (6).
3. All cats must be spayed or neutered.
4. All cats must be tested annually for feline leukemia and feline immune deficiency virus. Those cats testing positive must be humanely euthanized or isolated indoors.
5. Identify all trapped cats by tipping their ears and insertion of a microchip.
6. Have all cats vaccinated for rabies in addition to any other vaccinations or immunization requirement imposed by the state.
7. Maintain records on the location and size of the colonies as well as the vaccination, microchipping, ear tipping and spay and neuter records of the colony cats.
8. Take all reasonable steps to a) remove kittens from the colony after they have been weaned; b) place the kittens in homes or foster care; and c) capture and spay the mother cat.
9. Obtain medical attention for any colony cat that exhibits illness, signs of rabies or unusual behavior and remove the cat from the colony to prevent disease or injury to other cats in the colony.
10. If possible, report number of cats that died or otherwise ceased to be a part of the colony and the number of cats placed in animal shelters or permanent homes as companion cats.

Sec. 5-114. Revocation of permit.

(a) The director may revoke the feral cat colony caretaker permit of any permit holder for any of the following reasons:

1. Conviction of any violation of this chapter or any other animal statute or ordinance.
2. Failure of the permit holder or property owner to permit an animal control officer to inspect the property at which the feral cat colony is located.
3. Failure or inability of the permit holder to provide care for the feral cat colony as required by Sec. 5-113.
4. The size of the feral cat colony has increased to such numbers that the colony is a health hazard or interferes with the peace or quiet of any Columbia resident.

(b) Within sixty (60) days of the revocation of permit, the former permit holder shall relocate the colony to the care of one or more feral cat colony permit holders.

•     •     •

Nancy Peterson, Cat Programs Manager, Companion Animals, Humane Society of the United States addresses several of the flaws in Columbia’s proposed ordinance in her letter to city officials. I share Peterson’s concerns—the expenses associated with permits and microchipping, for example, which would unnecessarily burden caretakers (and divert precious funding from sterilization efforts).

Among the issues I’d like to address in detail are Article VI’s overly broad language, its requirement for FeLV/FIV testing, and its restrictions on feeding feral and stray cats.

Vague Language
Although permit applicants would be required to provide “a detailed description of the cats in the colony,” there’s no mention of which details are to be included. (Presumably, the application will be more specific.)

Similarly, caretakers are required to “maintain records on the location and size of the colonies as well as the vaccination, microchipping, ear tipping and spay and neuter records of the colony cats.” But records from low-cost, high-volume vet clinics—upon which most TNR programs depend—often omit the kinds of detailed information routinely included for pet cats. (I’ve seen paperwork that includes nothing but trap number and sex, for example.)

And when it comes to the location and size of a colony, what sort of records will be sufficient? Considering the potential consequences involved—revocation of a caretaker’s permit—more precise language is in order.

Perhaps the most unsettling language, though, is Article VI’s provision for inspection of “the property at which the feral cat colony is located.”

It’s not clear what circumstances would justify such an inspection, or whether caretakers would be given notice (or, as far as that goes, even allowed to be present). Do animal control officers have such far-reaching authority when it comes to inspection of private property housing pet cats (or dogs)? As Peterson suggests, this provision may very well run up against search and seizure protections and privacy laws.

FeLV, FIV, and Rabies
Article VI requires all cats to “be tested annually for feline leukemia and feline immune deficiency virus. Those cats testing positive must be humanely euthanized or isolated indoors.”

Given the impracticalities involved with isolating a feral cat, of course, a “failed” test is essentially a death sentence.

And, of course, the testing poses significant challenges for caretakers, both logistically and financially (easily $60 or more per cat, a local clinic tells me). Indeed, the only TNR programs likely to satisfy this requirement are those participating in formal research studies—and therefore provided with additional resources.

What’s more, there’s no justification for such a provision in the first place—because there’s no reason to expect infection rates among colony cats to be any different from those of pet cats.

A study of 1,876 colony cats (733 cats from a Raleigh, NC, TNR program and 1,143 cats from a Gainesville, FL, program) revealed a 4.3 percent rate of FeLV prevalence, and a 3.5 percent rate of FIV seroprevalence—“similar to infection rates reported for owned cats.” [1]

So why single out feral cats? If city officials are truly concerned about FeLV and FIV infection among Columbia’s cat population, why aren’t the owners of all cats allowed outdoors required to have their pets tested annually?

In fact, sterilization—required of colony cats but not of pet cats—reduces the spread of FeLV and FIV—both directly (“kittens are much more susceptible to [FeLV] infection than are adult cats”) and indirectly (“aggressive male cats are the most frequently infected [with FIV]”).

Furthermore, Article VI addresses the issue of sick cats directly, requiring caretakers to “obtain medical attention for any colony cat that exhibits illness, signs of rabies or unusual behavior and remove the cat from the colony to prevent disease or injury to other cats in the colony.”

And while Article VI is clear that colony cats must either be “vaccinated against rabies or… actively being trapped” in order to be vaccinated, it’s not clear whether this is a one-time requirement or not.

It’s also not clear whether booster shots are beneficial. July Levy, Maddie’s Professor of Shelter Medicine at the University of Florida’s College of Veterinary Medicine—and one of this country’s foremost experts on feral cats—suggests, “Even a single dose of rabies vaccination provides years of protection against rabies infection.”

Feeding Restrictions
Article VI prohibits residents from providing “food, water or other forms of sustenance to a feral cat colony without a feral cat colony caretaker permit.” Which, it seems to me, is just a step away from an outright feeding ban (which would effectively outlaw TNR altogether).

While I agree with the apparent intent here, the idea that the people feeding feral and stray cats are part of the problem is misguided. Indeed, these same people can be an integral part of the solution.

In a 2007 survey of 703 Ohio households, Linda Lord found that “only 42 of the 184 (22.8 percent) participants who reported feeding free-roaming cats had ever taken any of these cats to a veterinarian for any type of veterinary care.” [2] More intriguing than the figures, though, is the root cause.

“One reason,” suggests Lord, Associate Dean for Student Affairs at Ohio State University’s College of Veterinary Medicine, “may be the lack of affordable resources, particularly low-cost spay-neuter services, for free-roaming cats.” [2]

“Only 79 (11.2 percent) participants in the present study reported that they were aware of a trap-neuter-return program in their community. Although 296 (42.1 percent) reported they did not know whether such a program existed in their community, it is likely that there is limited access to these types of programs in many parts of Ohio.” [2]

Rather than outlawing “feeding without a permit,” then, Columbia should be developing and promoting community-based services that better connect with residents concerned for the welfare of homeless cats—ultimately increasing sterilization rates.

Caretaker permits, and the bureaucracy that invariably goes with them, are likely to have just the opposite effect, deterring community participation—thus driving down overall sterilization rates.

And finally, the underlying premise here—essentially, that handouts from well-meaning residents increase the population of feral cats—warrants a few comments as well.

A review of 29 studies revealed that, although the population density of cats correlates fairly well with the population density of humans (i.e., a greater density of cats in urban areas), these high densities do not require provisions by “cat lovers.” Indeed, “garbage bins” and “market refuse” proved sufficient to support some of the highest population densities. [3]

Similarly, researchers in Brooklyn found that “supplemental feeding” had no “significant effect on population density,” because available food supplies—again, mostly garbage—already exceeded what the cats required. [4]

All of which confirms a point I made in my previous post: we’re not likely to starve our way out of the “feral cat problem” (Marion Island being a rather dramatic case study [5, 6]).

•     •     •

As I say, I’m pleased to see officials in Columbia tackling this important issue. But the city’s proposed ordinance (years in the making, I’m told) falls well short of what’s necessary to make a significant, positive impact. Indeed, its various provisions—which, taken together, are onerous enough to drive caretakers “underground”—suggest either a lack of input from TNR practitioners, or a lack of good-faith negotiation on the part of those responsible for drafting the proposal. Or both.

Whatever the case, this is not just a missed opportunity; the proposed ordinance actually reads as if it were drafted by people dead-set against TNR but unwilling to make their position known publicly. If Columbia is truly interested in addressing the issue of feral cat management, then, it’s back to the drawing board—with, one hopes, a team that will take the task more seriously.

Literature Cited
1. Lee, I.T., et al., “Prevalence of feline leukemia virus infection and serum antibodies against feline immunodeficiency virus in unowned free-roaming cats.” Journal of the American Veterinary Medical Association. 2002. 220(5): p. 620-622. http://avmajournals.avma.org/doi/abs/10.2460/javma.2002.220.620

2. Lord, L.K., “Attitudes toward and perceptions of free-roaming cats among individuals living in Ohio.” Journal of the American Veterinary Medical Association. 2008. 232(8): p. 1159-1167. http://www.avma.org/avmacollections/feral_cats/javma_232_8_1159.pdf

3. Liberg, O., et al., Density, spatial organisation and reproductive tactics in the domestic cat and other felids, in The Domestic Cat: The biology of its behaviour, D.C. Turner and P.P.G. Bateson, Editors. 2000, Cambridge University Press: Cambridge.

4. Calhoon, R.E. and Haspel, C., “Urban Cat Populations Compared by Season, Subhabitat and Supplemental Feeding.” Journal of Animal Ecology. 1989. 58(1): p. 321–328. http://www.jstor.org/pss/5003

5. Bloomer, J.P. and Bester, M.N., “Control of feral cats on sub-Antarctic Marion Island, Indian Ocean.” Biological Conservation. 1992. 60(3): p. 211-219. http://www.sciencedirect.com/science/article/B6V5X-48XKBM6-T0/2/06492dd3a022e4a4f9e437a943dd1d8b

6. Bester, M.N., et al., “A review of the successful eradication of feral cats from sub-Antarctic Marion Island, Southern Indian Ocean.” South African Journal of Wildlife Research. 2002. 32(1): p. 65–73.

http://www.ceru.up.ac.za/downloads/A_review_successful_eradication_feralcats.pdf