Demanding (a) Better Service

U.S. Fish and Wildlife Service under fire for proposed roundups of free-roaming cats in the Florida Keys, an out-of-control burn on National Key Deer Refuge land, and participation in anti-TNR workshop.

Many U.S. Fish and Wildlife Service personnel are, I suspect, looking forward to October—or at least putting September behind them. For those involved with USFWS’s “war on cats,” this month’s been a tough one: too much of the wrong kind of attention.

Camera (en)Trap(ment) Project
September got off to a rocky start with readers (myself included) responding to news of camera traps being used in Florida’s National Key Deer Refuge “to document the number of cats stalking prey in the refuge.”

According to Key West Citizen reporter Timothy O’Hara, cats appeared on 5 percent of the “nearly 7,000 [photos] snapped so far,” whereas the endangered Lower Keys Marsh Rabbit appeared on just 3 percent. (Deer and raccoons topped the list, though specific percentages weren’t mentioned.)

Future plans include “a more in-depth study to get a better handle on the number of cats,” which, says USFWS biologist Chad Anderson, who was interviewed for the story, “will give us better insight into the predator management plan [of which I’ve been highly critical]. We want it to be as effective and efficient as possible.”

Five days later, Big Pine Key resident Jerry Dykhuisen took USFWS to task in a letter to the editor calling O’Hara’s article “our quarterly puff piece about how great it’s all going to be when feral cats are trapped and removed from Big Pine Key.” Dykhuisen, vice president of Forgotten Felines, pointed out the incredible expense associated with the proposed roundup (a “government boondoggle that is nothing more than a waste of our tax dollars and job security for U.S. Fish and Wildlife”) and the risk of skyrocketing rodent populations if eradication efforts were actually “successful,” and challenges the “‘best available science’ of which they are so proud” (which “is not really very good science at all, being decades old, using statistical methods that are highly suspect, and not even being conducted on Big Pine.”).

Tax dollars are at a premium in this economy,” wrote Dykhuisen, “and the idea of spending more than $10,000 per cat on a project that has no chance of success is mindless government at its worst.”

The following week, a letter to the editor from Forgotten Felines volunteer Valerie Eikenberg called the camera trap project a lame-brain experiment,” criticizing Refuge personnel for baiting the cameras with cat food. “Why spend thousands of taxpayer dollars to figure out a question that any second-grader could answer,” she asked.

Refuge Manager Anne Morkill disputes Eikenberg’s claim: “extremely small amounts of bait were used at only two camera trap sites located at unauthorized cat feeding stations, where the cats were already lured by food. The purpose was to get the animals to stop and pause for a clear photo for identification purposes.” (I received a similar explanation by e-mail from Anderson.)

Note: I’ve tried to contact O’Hara, who badly misrepresented the science in his story (for example: “Research indicates that cat predation accounts for 50 percent to 77 percent of the deaths of Lower Keys marsh rabbits and Key Largo woodrats.”), but he’s not responded to my e-mail requests.

(Mis)prescribed Burn
Just two weeks later, Refuge personnel once again found themselves defending their actions, this time for a prescribed burn that grew quickly out of control, scorching about 100 acres—five times what was originally planned.

For some, at least, this was the last straw. “Morkill has to go!” read one particularly harsh comment to a Key West Citizen story about the fire.

“Not tomorrow, not next week, not at the end of the fiscal year, NOW!! She is completely over her head and needs to transfer somewhere else. From the complete mishandling of the feral cat situation [to] the out of controlled prescribed burn that threatened both residents AND sensitive wildlife… Ms. Morkill is a complete and total failure at her position. What a travesty. Go back to wherever you came from Anne, you’re a failed experiment in the Keys.”

Earlier this week, USFWS officials met with residents to explain the results of an internal investigation into the fire.

According to USFWS Fire Ecologist Vince Carver, “The review team came up with three findings: One, it was too dry to burn. Two, the [fire] crew that did it, the majority of them did not have enough experience for this type of burn. And three, after they did screw up, they did a fantastic job.” [1]

Refuge fire management specialist Dana Cohen “repeatedly apologized to residents, saying, ‘We made a bad call’ in deciding to burn, but most appeared unmoved.” [1] The “unhappy audience,” as Citizen reporter Adam Linhardt describes them, were short on patience, “speaking out and lambasting” USFWS officials. “One person described the burn as a ‘fiasco’ and called for Cohen’s firing.” [1]

National Feral Cat Policy
A day after the blaze on Big Pine Key, USFWS was trying to tamp down another fire of its own making. This one, too, had gotten out of hand—but on a national scale.

In a post on its Open Spaces blog, USFWS responded to “many expressions of interest and concern regarding participation by U.S. Fish and Wildlife Service employees at an upcoming Wildlife Society conference.” This, of course, is a reference to Informing Local Scale Feral Cat Trap-Neuter-Release Decisions, the day-long workshop being presented by Tom Will, Mike Green (both of USFWS), and Christopher Lepczyk (University of Hawaii).

As part of that conference, two Service biologists are presenting a workshop designed to help wildlife biologists and other conservationists effectively communicate the best available science on the effects on wildlife from free-ranging domestic cats. The Service has no national policy concerning trap-neuter-release programs or feral cats.

If there’s no official policy, it’s not for lack of effort.

In his 2010 presentation to the Bird Conservation Alliance, What Can Federal Agencies Do? Policy Options to Address Cat Impacts to Birds and Their Habitats, Will is pushing for a “Firm policy statement—clear, definitive, easily available—as a tool for partners.” In fact, it looks like he’s suggesting that such a policy already exists, citing, for example, a 2007 “response to inquiry” from the USFWS Charleston Field Office:

Is it still FWS policy to promote legislation banning feeding of wildlife? Yes. The U.S. Fish and Wildlife Service (Service) stands firmly behind its recommendations promoting legislation banning the feeding of wildlife, especially nuisance species such as feral cats. Local governments are better equipped than are Federal and State agencies to regulate feral and free-ranging cats since most local governments have ordinances in place to address domestic animal issues as well as animal control services and personnel to implement those ordinances.

Is it still FWS policy opposing free ranging cats and establishment of feral cat colonies? Yes. The Service continues to oppose the establishment of feral cat colonies as well as the perpetuation and continued operation of feral cat colonies. As an agency responsible for administering the regulatory provisions of the Endangered Species Act (ESA) and the Migratory Bird Treaty Act (MBTA), the Service’s position is that those practicing Trap-Neuter-Release (TNR) could be subject to prosecution under those laws.

Is it still FWS policy opposing TNR programs? Yes… the Service’s New Jersey Field Office correctly states that “a municipality that carries out, authorizes, or encourages others to engage in an activity that is likely to result in take of federally protected species, such as the establishment or maintenance of a managed TNR cat colony, may be held responsible for violations of Section 9 of the ESA.”

Will goes on to cite several more passages from the letter quoted above, sent in November 2009 from the New Jersey Field Office to the New Jersey Department of Environmental Protection Division of Fish and Wildlife “in support of the New Jersey Fish and Game Council’s Resolution on Trap-Neuter-Release (TNR) and free-ranging domestic cats, passed June 19, 2007.”

The Service strongly opposes domestic or feral cats (Felis catus) being allowed to roam freely within the U.S. due to the adverse impacts of these non-native predators on federally listed threatened and endangered (T&E) species, migratory birds, and other vulnerable native wildlife. Therefore, the Service opposes TNR programs that allow return of domestic or feral cats to free-ranging conditions.

Migratory birds are Federal trust resources and are afforded protection under the MBTA, which prohibits the take of a migratory bird’s parts, nest, or eggs. Many species of migratory birds, wading birds, and songbirds nest or migrate throughout New Jersey. Migratory birds could be subject to predation from State municipality, or land manager-authorized cat colonies and free-ranging feral or pet cats. Predation on migratory birds by cats is likely to cause destruction of nests or eggs, or death or injury to migratory birds or their young, thereby resulting in a violation of the MBTA.

All of which looks a lot like a “national policy concerning trap-neuter-release programs or feral cats.” Which might explain why the American Bird Conservancy has the NJ Field Office letter posted on its website (PDF). (ABC and TWS were among the signatories to a letter sent earlier this year to Department of Interior Secretary Ken Salazar, “urg[ing] the development of a Department-wide policy opposing Trap-Neuter-Release and the outdoor feeding of cats as a feral cat management option, coupled with a plan of action to address existing infestations affecting lands managed by the Department of the Interior.”)

To hear USFWS tell it, Will and Green don’t even speak for USFWS.

In order to protect the independence and integrity of their work and the quality of the scientific information generated, the Service does not review or edit their work based on its potential policy implications. Any findings or conclusions presented at this workshop, as well as other scientific papers and presentations by Service employees, are those of the organizers and do not necessarily represent those of the Fish and Wildlife Service.

How exactly does that work? Are taxpayers (who are, like it or not, supporting TWS’s conference: “the Service is a sponsor of the conference as a whole”) expected to believe that Informing Local Scale Feral Cat Trap-Neuter-Release Decisions wasn’t put together “on company time,” using agency resources? Like me, commenter “Mrs. McKenna” isn’t buying it:

“I find it very strange that there would be not be an edit or review of the presentations done by employees/consultants (personnel on your payroll.) Quite frankly, I know of no organization that would allow taxpayer paid employees to present at a conference of this magnitude without a screening of materials to be presented. In fact, one could deem this type of policy quite irresponsible… If there were no interest in presenting a specific viewpoint supported by U.S. Fish & Wildlife for current or upcoming policies, one can be quite certain no such presentation would be sponsored.”

Mrs. McKenna and I are, it turns out, not the only skeptics. At last check, there were 50 comments on the USFWS post (not all of them critical of the Service, of course), a record for the Open Space blog (which, since its inception in late April, has attracted just 140 comments across 97 posts—including the August 2 post about “a recent incident where the Service inadvertently issued a citation in Fredericksburg, Virginia,” which attracted 46 comments).

Although USFWS is, according to its Office of External Affairs, “committed to using sound science in its decision-making and to providing the American public with information of the highest quality possible,” recent events suggest otherwise.

Actually, past events tell a similar story.

In its Migratory Bird Mortality fact sheet (PDF), published in January 2002, USFWS offers this prediction: “Many citizens would be surprised to learn that domestic and feral cats may kill hundreds of millions of songbirds and other avian species each year.”

“A recent study in Wisconsin estimated that in that state alone, domestic rural cats kill roughly 39 million birds annually. Add the deaths caused by feral cats, or domestic cats in urban and suburban areas, and this mortality figure would be much higher.” [2]

In this case, the Service’s “best available science” can be traced to the infamous Wisconsin Study, [3] and—eventually—to “a single free-ranging Siamese cat” that frequented a rural residential property in New Kent County, Virginia. [4])

Nearly 10 later, Migratory Bird Mortality is still available from the USFWS website. So much for “using sound science in its decision-making and to providing the American public with information of the highest quality possible.”

USFWS is right about one thing, though: many citizens are surprised—just not in the way the Service imagined. The public, to whom USFWS is ostensibly accountable, is surprised at the way their tax dollars are being used to fund a witch-hunt. And, judging by the overwhelming response to the USFWS/TWS workshop (see, for example, Best Friends Animal Society’s Action Alert, blog posts from Alley Cat Rescue and BFAS co-founder Francis Battista, and the Care2 petition), the public has had enough.

With access to both information and “broadcast” technology more accessible than ever, it’s becoming increasingly difficult for USFWS to continue with business as usual. The people the Service is supposed to—well, serve—are demanding better science, more transparency, and greater accountability. People are paying attention like never before.

Think of it as “the new normal.”

Literature Cited
1. Linhardt, A. (2011, September 29). Residents rage about rogue fire—Fed officials apologize: ‘We made a bad call’. The Key West Citizen, p. 1A,

2. n.a., Migratory Bird Mortality. 2002, U.S. Fish and Wildlife Service: Arlington, VA.

3. Coleman, J.S., Temple, S.A., and Craven, S.R., “Cats and Wildlife: A Conservation Dilemma.” 1997.

4. Mitchell, J.C. and Beck, R.A., “Free-Ranging Domestic Cat Predation on Native Vertebrates in Rural and Urban Virginia.” Virginia Journal of Science. 1992. 43(1B): p. 197–207.

Operation Sisyphus

The draft environmental assessment (EA) for the Florida Keys National Wildlife Refuges Complex Integrated Predator Management Plan (download PDF), released last week by the U.S. Fish and Wildlife Service (FWS), aims to eliminate free-roaming cats in the Keys. Not that this is anything new—FWS (along with USDA, and some state agencies) has been trying to do this for years now.

Plans include the trapping/removal of free-roaming cats—owned and unowned alike—from refuge lands and other public lands nearby, as well as from other land (including private property) where cats may be considered a threat to vulnerable native species. TNR has been dismissed as an option, and FWS proposes to prohibit the feeding of feral cats wherever possible.

Unfortunately, the proposed plan is unlikely to be any more successful than previous efforts. There’s plenty to dislike about the FWS plan—including the risk that it may set a dangerous precedent nationwide. The deadline for public comments (see Plan for details) is February 3.

Justification or Rationalization?
In a section of the document called Justification for Management Action, FWS lays out their numerous grievances against “non-native species and human-subsidized populations of native predators.” [1] As a review of the relevant literature, the sub-section on domestic cats leaves much to be desired is a train wreck.

In fact, if this were a college-level term paper, it would likely receive a failing grade—followed, perhaps, by disciplinary action. (And, if it were allowed under the law, maybe a drug test, too.)

Among the references cited here (about three-quarters of which I’m familiar; the rest I’m still chasing down) is, admittedly, some rather damning evidence. For example:

  • The near-extirpation of rock iguanas from Pine Cay in the Caicos Islands during the 1970s. “The decline, from an estimated adult lizard population of nearly 5,500, was due primarily to predation by domestic dogs and cats introduced to the island simultaneously with hotel construction.” [2] (Strangely, FWS cites Iverson’s paper not as an example of a near-miss, but of a global extinction. This, however, pales in comparison to the “strangeness” of many of their other citations.)
  • On Little Barrier Island, off the coast of New Zealand, cats “were considered to have been the sole cause of the local eradication of North Island saddleback and to have contributed to the extinction of the Little Barrier snipe, and to threaten, by their continued presence, grey-faced, black, and Cook’s petrels. Cats probably also contributed to the decline of tuatara and the 12 lizard species known to be present on Little Barrier Island.” [3]

On the other hand, much of the FWS’s evidence is, at best, circumstantial. Among the studies cited to support their claim that “free-roaming cats have been shown to be a major cause of 33 native species extinction [sic] globally,” is a 1987 paper by Cruz and Cruz, in which the authors, studying Galápagos Petrels, found that cats were hardly the only culprits:

“They are threatened by introduced rats, which attack eggs and young chicks… dogs and pigs which prey on eggs, nestlings and adults. Introduced goats, burros and cattle destroy nesting habitat and trample nests. A different combination of these pests and predators exists at each of the petrel nesting sites, while three of the islands are plagued by all of them.” [4]

And, as with the rock iguanas, the FWS would have the public believe the Galápagos Petrel is among those 33 extinctions. In fact, the birds are still there, though they are listed as Critically Endangered.

The story is similar for the 1986 paper by Kirkpatrick and Rauzon, another purported link between free-roaming cats and species extinctions. Kirkpatrick and Rauzon found that more than 90 percent of the diet of free-roaming cats on Jarvis Island and Howland Island was made up of Sooty Terns, Wedge-tailed Shearwaters, and Brown Noddies—each of which is listed as a species of Least Concern.

Another of the papers cited by FWS has nothing to do with extinctions at all. As the authors themselves describe it, their study was an evaluation of “whether a collar-worn pounce protector, the CatBib, reduces the number of vertebrates caught by pet cats and whether its effectiveness was influenced by colour or adding a bell.” [5]

FWS argues that “many of the species impacted by free-roaming cats are federally listed threatened or endangered species and federally protected migratory birds.” While probably true, this statement is also largely meaningless. According to the 2009 State of the Birds report, published by the Department of the Interior (which oversees FWS):

“The United States is home to a tremendous diversity of native birds, with more than 800 species inhabiting terrestrial, coastal, and ocean habitats, including Hawaii. Among these species, 67 are federally listed as endangered or threatened. An additional 184 are species of conservation concern because of their small distribution, high threats, or declining populations.” [6]

That translates to approximately 31 percent of all birds in this country being species of concern. FWS makes it sounds as if perhaps the cats are targeting these birds; in fact, they could just as easily have claimed that many of the species impacted by all forms of mortality are federally listed threatened or endangered species and federally protected migratory birds of these birds.

Hang in there, though—it gets better. I mean worse.

Also listed among the evidence of island extinctions were Coleman and Temple’s 1993 survey of rural Wisconsin residents about their outdoor cats [7], and Churcher and Lawton’s “English Village” study [8]. (While England is an island, it’s quite a stretch to suggest that Felmersham’s House sparrows are at risk of extinction.)

When it comes to the disruption caused by cats to “the abundance, diversity, and integrity of native ecosystems,” FWS turns to, among others, studies by Hawkins [9] and Jessup. [10]

As I’ve discussed previously, Hawkins’ dissertation work was plagued with problems that raise serious doubts about his rather triumphant conclusions—“the preference of ground feeding birds for the no-cat treatment was striking,” [9] for example. A closer look reveals that five of the nine ground-feeding birds showed no preference for either area of the study site. One could, based on Hawkins’ findings, just as easily conclude that more than half of the ground-feeding species studied were indifferent to the presence of cats.

Jessup cites some well-known predation studies, but his concern is the condemnation of “trap, neuter, and reabandon,” [10] as he calls it (“Abandonment of animals cannot be morally justified and is illegal under state humane laws… If it is illegal to abandon a cat once, how can it be legal to do it a second time? How can veterinarians justify being party to abandonment, an illegal act of animal cruelty?” [10])

FWS suggests that “free-roaming cats kill at least one billion birds every year in the U.S., representing one of the largest single sources of human-influenced mortality for small native wildlife,” [1] supporting their assertion with just three sources, one of which is Rich Stallcup’s 1991 article from the Observer, a publication of the Point Reyes Bird Observatory. But “A Reversible Catastrophe” is very light on science—and Stallcup gets most of that wrong. Mostly, the article is Stallcup’s manifesto regarding neighborhood cats:

“If you have a garden, why not proclaim it a wildlife sanctuary and protect it from non-native predators? If roaming cats come into your sanctuary to poach the wildlife under your stewardship, you have the right and perhaps even the duty to discourage them in a serious way.” [11]

Discourage them? Among Stallcup’s suggestions: “…try a B-B or pellet gun. There is no need to kill or shoot toward the head, but a good sting on the rump seems memorable for most felines, and they seldom return for a third experience.” [11]

No feral cat witch hunt would be complete without some public health threat fear-mongering, and FWS’s plan is no different:

“According to the Centers for Disease Control (CDC), free-roaming cats not only threaten wildlife through direct predation but also serve as vectors for a number of diseases including rabies, cat scratch fever, hookworms, roundworms and toxoplasmosis. Some of these diseases can be transmitted to other domestic animals, native wildlife, and in some cases, humans.” [1]

But the CDC site makes no mention of cats being a threat to wildlife. And humans? “Although cats can carry diseases and pass them to people, you are not likely to get sick from touching or owning a cat.” And, notes the CDC, “People are probably more likely to get toxoplasmosis from gardening or eating raw meat than from having a pet cat.”

There’s even a link to another page on the CDC’s site, called “Health Benefits of Pets.”

And finally, there’s the paper by Sax and Gaines. If the previous examples miss their mark, this one’s a full-blown non-sequitur. Though the authors do mention “the extinction of many native animal species on islands” [12] briefly in their introduction, the purpose of the paper is, as the authors state plainly enough, to “show that the number of naturalized plant species has increased linearly over time on many individual islands.” [12, emphasis mine]

•     •     •

FWS intends to eliminate free-roaming cats from the Florida Keys, and this is the best they can do? If so, well, perhaps they ought to be doing something else. If this is their “justification for action,” then any subsequent action can, I think, rightfully be considered unjustified.

Predator Management
Among the animals to be monitored throughout and/or removed from the four refuges that make up the Florida Keys National Wildlife Refuges Complex (National Key Deer Refuge, Key West National Wildlife Refuge, Great White Heron National Wildlife Refuge, and Crocodile Lake National Wildlife Refuge) are non-native reptiles and rodents, native raccoons, and, of course, the cats.

“Presence of exotic non-native iguanas, lizards, and large-bodied snakes will be detected through reports, incidental sightings, and the community-based interagency ‘Python Patrol’ network. Exotic reptiles will be immediately dispatched in accordance with AVMA guidelines for humane euthanasia.” [1]

“Any non-native opossum, armadillo, or rat caught incidentally in the live traps targeted for cats on Refuge lands will be immediately dispatched in accordance with the American Veterinary Medical Association (AVMA) guidelines for humane euthanasia. All native species will be immediately set free.” [1, emphasis mine]

“Raccoons trapped incidentally in live traps targeted for cats or other non-native predators will be released alive at the trap location… Raccoons that exhibit severe disease or other serious health issues will receive appropriate evaluation, which may include care by a state-certified wildlife rehabilitator or euthanasia as recommended by a qualified veterinarian or animal control services provider… If field studies and monitoring indicate that raccoon populations are having a negative impact on endangered species, the USFWS will reevaluate the need to implement more direct control by removal of raccoons from sensitive habitats. Removal could include, but not be limited to, transfer to a wildlife park or zoo, a state-certified wildlife rehabilitator, or euthanasia. Any decision by the Service to use lethal control measures on raccoons will trigger additional public notification and an amendment to this EA.” [1]

Free-roaming Cats
But, as I say, the cats are the real focus here: “The USFWS will remove all free-roaming cats found on Refuge lands through live trapping,” at which point, the cats will become of the responsibility of any one of three (currently, two; a third contractor is currently being sought) Monroe County animal control providers.

“The Monroe County animal control service provider will have the authority to determine the final disposition of the trapped cats according to county ordinances and standards, which may include returning to owner, adopting out, relocating to a long-term cat care facility on the mainland, or euthanizing.” [1]

Of course, it’s no secret what happens to the vast majority of feral cats brought into shelters. As Nathan Winograd writes in his book Redemption: The Myth of Pet Overpopulation and the No Kill Revolution in America, “there is no other animal entering a shelter whose prospects are so grim and outcome so certain.”

I asked Connie Christian, Executive Director of the Florida Keys SPCA, about this last week. “Every cat brought to our facility is assessed to determine their disposition,” Christian told me via e-mail. “Every attempt is made to return ‘non-feral’ cats to their owners or place for adoption.”

“Unfortunately,” she continued, “we do not have an outlet for feral cats that are brought to us without a request for return.” Which would likely be the case for cats unlucky enough to be trapped by FWS. (Interestingly, FKSPCA is involved with TNR, which FWS wants to eliminate—more on that in a moment.)

What about that “relocation to long-term facilities on the mainland” option? There was some discussion of this option during stakeholder meetings that took place in 2008. And local papers carried stories suggesting the possibility. [13, 14] Now it looks like FWS is dumping this is the laps of Monroe County animal control providers.

I guess they can say they tried.

Expanding Territory
But FWS isn’t stopping at their property line—and the four refuges included in the plan already make up, according to my calculations, more than 28 percent of the Keys’ total land mass. According to the South Florida Multi-Species Recovery Plan (MSRP), FWS has plans to use land acquisition and conservation easements or agreements to protect the endangered Lower Keys marsh rabbit. [15]

The MSRP, excerpts of which are included in the EA, also spells out FWS’s intention to “remove nuisance feral cats” from land “near rabbit habitat” in the Lower Keys. [1] Additional plans include deed restrictions “to prohibit free-roaming cats” [1] in areas where they might be a threat to the rabbits, the Key Largo Woodrat, or the Key Largo Cotton Mouse. And to “enforce deed restrictions of cat control in Ocean Reef Club and other areas.” [1]

The Ocean Reef Club, of course, is home to ORCAT, perhaps the best known—and certainly one of the most successful—TNR programs in the country. According to their website, ORCAT has reduced the island’s population of cats from approximately 2,000 cats, in the early 1990s, to about 350 today, “about 100 of which reside at the Grayvik Animal Care Center.”

Frankly, I’m not sure what FWS means by “enforce deed restrictions” (one of many follow-up items on my to-do list). Other aspects of their plan, however, are straightforward:

“Feral cat colonies and feeding stations on Refuge lands will be identified and removed. The USFWS will also coordinate with county and state agencies to assist in the identification and removal, where feasible and legal, cat colonies and feeding stations on other public properties that are adjacent to or near Refuge lands. Extensive public outreach will be conducted to encourage people who feed free-roaming cats to cease doing so, and to promote trapping and relocating those animals to long-term facilities on the mainland where they will no longer be a threat to Refuge’s wildlife.” [1]

Something else that’s clear: FWS is going after pet cats, too. The MSRP includes plans to “establish a program to license domestic cats, implement leash laws, eliminate cat-feeding stations, implement spay and neuter program, increase awareness through educational material, test diseases, and remove nuisance feral cats.” [15]

Is this mandatory spay/neuter (which has been shown to fail when implemented in the absence of adequate low- and no-cost services)? Does the FWS plan to test pets for, say FIV and FeLV? Lots of unanswered questions here, obviously.

It’s no surprise, then, given their plan for the removal of feeding stations—and cats—that FWS is staunchly opposed to TNR, which, they argue “does little to reduce cat predation on native wildlife.” [1]

Success Stories
“In addition,” argues FWS, “the TNR method has little valid scientific support for claims that it actually reduces cat colony numbers over time and often has been shown to attract people to release new cats into an area.” [1]

Ironically, some of the greatest TNR success stories are right there in the papers cited by FWS. Natoli, for example, reported a 16–32 percent decrease in population size over a 10-year period across 103 colonies in Rome—despite a 21 percent rate of “cat immigration.” [16]

Castillo and Clarke, though highly critical of TNR documented remarkably little predation in the two Florida parks they used for their study. In fact, over the course of approximately 300 hours of observation (this, in addition to “several months identifying, describing, and photographing each of the cats living in the colonies” [17] prior to beginning their research), Castillo and Clarke “saw cats kill a juvenile common yellowthroat and a blue jay.” [17]

“Cats also caught and ate green anoles, bark anoles, and brown anoles. In addition, we found the carcasses of a gray catbird and a juvenile opossum in the feeding area.” [17]

Any TNR program contends with the unfortunate (and illegal) dumping of cats. Still, it’s difficult to imagine that the presence or absence of a nearby TNR program would affect a person’s decision to abandon his/her pet cat(s). (If any studies had demonstrated such a connection, TNR opponents would surely cite them!) On the other hand, cats dumped near a managed colony are far more likely to be adopted and/or sterilized—thereby mitigating their potential impact on the overall population of unowned cats—as well any impacts to wildlife and the environment.

Moreover, FWS ignores the value of population stabilization. Julie Levy, Maddie’s Professor of Shelter Medicine in the University of Florida’s College of Veterinary Medicine, and one of the country’s foremost experts on feral cats, argues that “wildlife benefits when populations of cats that are trending rapidly upwards are at least stabilized” [18].

Among the more perplexing aspects of FWS’s argument is their claim that “TNR practices are prohibited on National Wildlife Refuges, and violate the Endangered Species Act (ESA) and the Migratory Bird Treaty Act (MBTA) because they may result in the direct harm of protected species.” [1]

This is an argument that’s been thrown around since at least 2003, when Pamela Jo Hatley, then a law student, suggested the possibility. But that’s all it was—and, apparently, is—a possibility.

“It is quite obvious that cats can be lethal to birds,” writes Hatley, “and if the death of a migratory bird can be traced to a cat, or a cat colony, which can be further traced to an individual or organization, there may be strict liability for that person under the MBTA.” [19] Hatley’s argument for violations of the Endangered Species Act is similarly speculative: “…persons who release cats into the wild or who maintain feral cat colonies could be found liable for a take under section 9 of the ESA if maintenance of feral cats in the wild is found to kill or injure wildlife by degrading habitat.” [19]

It’s been nearly eight years now—a period during which TNR has undoubtedly increased substantially across the country—so where are all the court cases? If this were as black-and-white as FWS makes it sound, there wouldn’t even be a discussion about TNR (and the Urban Wildlands Group would likely have taken a very different tack in Los Angeles).

Finally—perhaps in a desperate attempt to appear as though their plan has the support of animal welfare organizations—FWS gives PETA a plug.

“Some animal advocates therefore often agree that traditional TNR programs are not the most appropriate choice, especially where cats are released near designated wildlife areas and at-risk wildlife populations (see the People for the Ethical Treatment of Animals’ Animal Rights Uncompromised fact sheets at For these reasons, TNR was considered but dismissed from further evaluation.” [1]

PETA, of course, is also opposed to caged birds, crating dogs, and zoos. When PETA is the only “animal advocate” you can get to endorse your approach, it’s time to rethink it.

Operation Sisyphus
The purpose of FWS’s Plan/EA “is to conserve and restore federally-listed species and protect all native fauna and flora on the [refuges] from population decline and potential extirpation or extinction due to predation by non-native species and human-subsidized populations of native predators.” [1]

Will the plan work? Only time will tell, of course—but there’s plenty of reason for skepticism. If their “literature review” is any indication, FWS either doesn’t have a particularly strong grasp of the issues involved—or they’re not interested in sharing that understanding with the public.

Nitpicking? I don’t think so. In their attempt to focus—however carelessly—on the impacts of cats, FWS overlooks some key factors.

Mesopredator Release
FWS refers to two often-cited papers [20, 21] as evidence of cats disrupting native ecosystems, but fails to acknowledge the larger point made by the authors: the mesopredator release phenomenon. “In the absence of large, dominant predators,” write Soulé et al., “smaller omnivores and predators undergo population explosions, sometimes becoming four to 10 times more abundant than normal.” [20]

In Soulé’s example, coyotes were the dominant predators, while cats were the mesopredators. In other contexts, however, cats have been shown to play the dominant predator role with rats becoming the mesopredators.

Mathematical modeling of the mesopredator release phenomenon illustrates the complexities involved in eradication efforts, even on small islands. As Courchamp et al. explain, “although counter-intuitive, eradication of introduced superpredators, such as feral domestic cats, is not always the best solution to protect endemic prey when introduced mesopredators, such as rats, are also present.” [22] Fan et al. warn of the risks involved with such eradication efforts: “In some cases, it may cause a disastrous impact to managed or natural ecosystems.” [23]

Macquarie Island, located roughly halfway between New Zealand and Antarctica, offers a well-documented example of such a disastrous impact. In 2000, cats were eradicated from this United Nations Educational, Scientific and Cultural Organization World Heritage Site in order to protect its seabird populations. The resulting rebound in rabbit and rodent numbers, however, has had its own disastrous impact. “In response, Federal and State governments in Australia have committed AU$24 million for an integrated rabbit, rat and mouse eradication programme.” [24]

Could something like this happen in the Florida Keys?

According to FWS, non-native rats are already “prevalent in residential and commercial areas.” [1] Should the removal of cats create a spike in their numbers, FWS suggests that they’re prepared to remove the rats, too: “Noticeable population increases based on reports, road kill, or other specific or auxiliary data may initiate targeted control and eradication efforts in addition to incidental capture…” [1]

But controlling these rats is complicated considerably by the need to protect Lower Keys marsh rabbits. The MSRP warns of these rabbits coming into contact with pesticides and “poisons used to control black rats.” [15]

“In a 1993 Biological Opinion, the FWS investigated the effects of vertebrate control agents on endangered and threatened species and determined that several chemicals (e.g., Pival) would jeopardize the continued existence of the Lower Keys marsh rabbit. Chemicals—such as Pival—a rodenticide used to kill rats, are lethal if ingested. The FWS also concluded that if development in the Keys continues to increase, the potential for these animals to come in contact with such chemicals also increases, as does the potential for their extinction. Based on these findings, the FWS believes the continued use of such chemicals will result in the deaths of Lower Keys marsh rabbits. Given that the majority of occupied habitat is adjacent to urbanized areas, and that urbanization continues to expand into their habitat, then it can reasonably be predicted that the use of such chemicals has had a negative impact upon the Lower Keys marsh rabbit that may prevent its recovery.” [15]

Removing Cats
It’s also not clear that FWS will be able to remove the free-roaming cats from the Keys. For one thing, they have no idea how many are there. Only now—after years of struggling with this issue—does FWS propose to “implement monitoring and conduct further research as needed to determine abundance and distribution of free-roaming cats throughout the Refuge, document effectiveness of management actions taken or not taken on cat populations, and determine the impacts on the ecosystems and native species to aid in the adaptive management process.” [1]

Plus, FWS has a rather poor track record when it comes to actually trapping cats.

In 2007, they “received $50,000 to remove cats from federal refuges on Big Pine Key and Key Largo, and to protect endangered marsh rabbits, silver rice rats and other animals and birds that call the refuges home.” [25] Reports (from what I can tell, nothing official has been issued) suggest that fewer than 20 cats were caught—some of which were returned to their owners (kudos to FWS and USDA)—along with 81 raccoons, 53 of which were released alive. [26]

I think it’s safe to say that the Keys’ wildlife reaped little or no benefit from this effort. Had that same money been used for TNR, on the other hand…

So what’s different this time around?

Déjà Vu
All the while I’ve been doing the research for this post, I’ve been haunted by two quotes I’ve used rather extensively in the past. Actually, the first is not a quote as such, but the title of Merritt Clifton’s excellent article: Where cats belong—and where they don’t. [27]

The second comes from Gary Patronek, who argues that “the release of cats into an environment where they would impact endangered or threatened species, or even into wildlife preserves or refuges, is inexcusable.” [28] Patronek, the former Director of the Center for Animals and Public Policy at the Cummings School, and one of the founders of the Hoarding of Animals Research Consortium, continues:

I do not believe that this is being advocated by cat protectors who see urban, managed colonies as an imperfect but still preferable alternative to the euthanasia of healthy animals. Abandoned pet cats whose own habitat has been reduced to colonies, and the wild species endangered by clear-cutting or beachfront development, are casualties of the same callous disregard for the lives of animals. I see little justification for shifting the role of cats to that of scapegoat.” [28, emphasis mine]

Well, isn’t this precisely what I’m advocating? I honestly don’t know.

Here’s what I do know:

There is no doubt that the Florida Keys are immensely valuable for their diversity of animal and plant life, some of which can be found nowhere else in the world. Due to a wide range of factors (most of them human-caused), this habitat has become quite fragile, with some animal and plant species on the brink of extinction. And, in such habitats, it’s been shown that free-roaming cats can have a significant negative impact.

I also know that where cats have been eradicated, the process is a horror. In fact, it’s spelled out in some of the papers cited by FWS (though, understandably, they don’t draw attention to that):

  • Nogales et al., describing the “success” of Marion Island, note, “it took about 15 years of intense effort to eradicate the cats, combining several methods such as trapping, hunting, poisoning, and disease introduction… The use of disease agents or targeted poisoning campaigns hold promise for an initial population reduction in eradication programs on large islands—such an approach may save effort, time, and money.” [29]
  • Cruz and Cruz point out that, of all the non-native mammals there, cats were “the most difficult to control or eliminate on Floreana Island.” Although “hunting with dogs was the single most effective method employed and it gave a sure body count,” the authors warn that “the method was costly and with the limited manpower available was only useful over small areas. Both poisoning and trapping were effective and the combination of the three methods is probably the most effective approach, as well as being the best use of time and materials.” [4]
  • Veitch describes efforts on 11-square-mile Little Barrier Island as “a determined [cat] eradication attempt” involving “cage traps, leg-hold traps, dogs and 1080 poison were used, but leg-hold traps and 1080 poison were the only effective methods.” [3] Four cats were also infected with Feline enteritis, but “because of the poor reaction to the virus no other cats were dosed and none were released… Altogether, 151 cats were known to have been killed before the eradication was declared complete. Important lessons learnt can be transferred to other feral cat eradication programmes.” [3] (By way of comparison, the Keys are approximately 137 square miles in total area.)

I know that ecosystems—especially those as fragile as the Keys—are incomprehensibly complex, and that tinkering with them is incredibly risky. And there’s plenty we simply do not know, and cannot—despite our best efforts—predict.

But I know, too, that time is short. And that we’ll never have all the answers we’d like to have before the need for action precludes further inquiry.

Put another way: I’ve given this issue a lot of thought—and, here’s what I’m afraid will happen in the Keys:

FWS will proceed with their plan, rounding up cats—ferals and pets alike—on and “near” public lands. The pet cats will mostly be returned, but some mistakes—the risk of which will likely increase in an atmosphere of mass trapping—will surely be made. Feral cats will be killed.

Progress will move slowly, as these things often do—far too slowly to keep up with reproduction rates. If feeding and TNR are eliminated (to whatever extent possible) throughout the Keys, the cats will simply “go underground.” No more monitoring—and sterilizing—by the “foot soldiers” who currently care for colonies of cats.

Indeed, it’s quite likely that feral cat complaint calls to Monroe County, FWS, and the USDA would taper off considerably, as it becomes clear that such a call is essentially a death sentence. Thus, the cats become that much more difficult to locate—and sterilize. The population, therefore, increases.

Using a population model, Andersen, Martin, and Roemer have suggested that, in the absence of a sterilization program, 50 percent of cats would have to be removed in order for a colony to decrease 10 percent annually. [30] By contrast, the authors suggest that 75 percent of cats would need to be sterilized to achieve the same result.

This model has its flaws, as I’ve explained elsewhere, but the study is one many researchers are familiar with. And, frankly, it’s convenient for my purposes here.

Even if Andersen et al. are off by a factor of two, FWS would need to “remove” 25 percent of the free-roaming, unsterilized (and once they chase away the colony caretakers, it won’t be long before that’s the norm) cats continuously in order to achieve a 10 percent reduction in overall numbers.

Does anybody really think that’s going to happen? Where’s the evidence to suggest that it’s even possible?

FWS has—it seems—taken off the table the unspeakable methods so often employed on small, uninhabited islands.

“While lethal control is allowed by Refuge System policy, it is not a socially acceptable approach and is inconsistent with the points of consensus developed by the stakeholder group. This alternative would likely not be logistically feasible on a FKNWRC-wide basis and would not allow for adaptive management under a strategic habitat conservation approach.” [1]

But they’ve also taken TNR off the table. So, what’s left? We’re back to doing what we’ve been doing for years now—which, of course, is how we got into this mess in the first place.

From what I can tell, the FWS plan is nothing more than a warmed-over version of old-school trap-and-remove, an approach Mark Kumpf, president of the National Animal Control Association President from 2007 to 2008, describes as “bailing the ocean with a thimble.” [31] (There’s a metaphor that ought to resonate with people in the Keys!)

If so, it’s easy to imagine the losers in the deal—the cats, obviously, but also all of the wildlife FWS wants to protect. And the taxpayers, too, of course—not much of a return on investment for all of us, no matter what our position might be on feral cats, wildlife conservation, and the like.

The question is, where are the winners?

Literature Cited
1. n.a., Draft Environmental Assessment: Florida Keys National Wildlife Refuges Complex Integrated Predator Management Plan. 2011, U.S. Fish & Wildlife Service: Big Pine Key, FL.

2. Iverson, J.B., “The impact of feral cats and dogs on populations of the West Indian rock iguana, Cyclura carinata.” Biological Conservation. 1978. 14(1): p. 63–73.

3. Veitch, C.R., “The eradication of feral cats (Felis catus) from Little Barrier Island, New Zealand.” New Zealand Journal of Zoology. 2001. 28: p. 1–12.

4. Cruz, J.B. and Cruz, F., “Conservation of the dark-rumped petrel Pterodroma phaeopygia in the Galápagos Islands, Ecuador.” Biological Conservation. 1987. 42(4): p. 303–311.

5. Calver, M., et al., “Reducing the rate of predation on wildlife by pet cats: The efficacy and practicability of collar-mounted pounce protectors.” Biological Conservation. 2007. 137(3): p. 341-348.

6. n.a., State of the Birds, United States of America, 2009. 2009, U.S. Department of Interior: Washington, DC. p. 36.

7. Coleman, J.S. and Temple, S.A., “Rural Residents’ Free-Ranging Domestic Cats: A Survey.” Wildlife Society Bulletin. 1993. 21(4): p. 381–390.

8. Churcher, P.B. and Lawton, J.H., “Predation by domestic cats in an English village.” Journal of Zoology. 1987. 212(3): p. 439-455.

9. Hawkins, C.C., Impact of a subsidized exotic predator on native biota: Effect of house cats (Felis catus) on California birds and rodents. 1998, Texas A&M University.

10. Jessup, D.A., “The welfare of feral cats and wildlife.” Journal of the American Veterinary Medical Association. 2004. 225(9): p. 1377-1383.

11. Stallcup, R., “A reversible catastrophe.” Observer 91. 1991(Spring/Summer): p. 8–9.

12. Sax, D.F. and Gaines, S.D., Species invasions and extinction: The future of native biodiversity on islands, in In the Light of Evolution II: Biodiversity and Extinction,. 2008: Irvine, CA. p. 11490–11497.

13. n.a. (2007, March 29). Key Deer Refuge wants to control feral cats: A plan to round up feral cats in the National Key Deer Refuge on Big Pine and No Name keys has animal-rights groups and area cat owners upset. The Reporter.

14. Busweiler, R. (2008, December 1). Feds begin drafting rabbit protection plan—BIG PINE KEY. The Key West Citizen.

15.  n.a., Multi-Species Recovery Plan for South Florida: Lower Keys Rabbit. 1999, U.S. Fish and Wildlife Service: Atlanta, GA. p. 151–171.

16. Natoli, E., et al., “Management of feral domestic cats in the urban environment of Rome (Italy).” Preventive Veterinary Medicine. 2006. 77(3-4): p. 180-185.

17. Castillo, D. and Clarke, A.L., “Trap/Neuter/Release Methods Ineffective in Controlling Domestic Cat “Colonies” on Public Lands.” Natural Areas Journal. 2003. 23: p. 247–253.

18. Levy, J.K., Personal communication, 2010.

19. Hatley, P.J., Feral Cat Colonies in Florida: The Fur and the Feathers Are Flying. 2003, University of Florida Conservation Clinic: Gainsville, FL.

20. Soulé, M.E., et al., “Reconstructed Dynamics of Rapid Extinctions of Chaparral-Requiring Birds in Urban Habitat Islands.” Conservation Biology. 1988. 2(1): p. 75-92.

21. Crooks, K.R. and Soulé, M.E., “Mesopredator release and avifaunal extinctions in a fragmented system.” Nature. 1999. 400(6744): p. 563–566.

22. Courchamp, F., Langlais, M., and Sugihara, G., “Cats protecting birds: modelling the mesopredator release effect.” Journal of Animal Ecology. 1999. 68(2): p. 282–292.

23. Fan, M., Kuang, Y., and Feng, Z., “Cats protecting birds revisited.” Bulletin of Mathematical Biology. 2005. 67(5): p. 1081-1106.

24. Bergstrom, D.M., et al., “Indirect effects of invasive species removal devastate World Heritage Island.” Journal of Applied Ecology. 2009. 46(1): p. 73-81.

25. O’Hara, T. (2007, April 3). Fish & Wildlife Service to begin removing cats from Keys refuges. The Key West Citizen.

26. n.a., Lower Florida Keys National Wildlife Refuges Comprehensive Conservation Plan. 2009, U.S. Department of the Interior, Fish and Wildlife Service: Atlanta, GA.

27. Clifton, M. Where cats belong—and where they don’t. Animal People 2003.

28. Patronek, G.J., “Letter to Editor.” Journal of the American Veterinary Medical Association. 1996. 209(10): p. 1686–1687.

29. Nogales, M., et al., “A Review of Feral Cat Eradication on Islands.” Conservation Biology. 2004. 18(2): p. 310-319.

30. Andersen, M.C., Martin, B.J., and Roemer, G.W., “Use of matrix population models to estimate the efficacy of euthanasia versus trap-neuter-return for management of free-roaming cats.” Journal of the American Veterinary Medical Association. 2004. 225(12): p. 1871-1876.

31. Hettinger, J., Taking a Broader View of Cats in the Community, in Animal Sheltering. 2008. p. 8–9.