American Bird Conservancy 2017 Position on TNR

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June 2, 2017
The Honorable Jeffrey D. Klein
Legislative Office Building
Room 913
Albany, NY 12247
Dear Senator Klein:
On behalf of American Bird Conservancy (ABC) and our members throughout New York, I am
writing to urge your withdrawal of S6182, an Act to amend the agriculture and markets law, in
relation to authorizing the trapping, neutering or spaying, and releasing of feral cats.
Cat management and control is a pressing topic, and I commend your willingness to tackle this
important issue. Nevertheless, in the pursuit of remedies to alleviate the crisis of feral cats, it is
critical that our solutions neither encourage the conditions that led to the crisis nor perpetuate the
harms inflicted on communities. The authority and endorsement provided in S6182 for the
practice known as trap, neuter, release (TNR) fails on both of these counts.
An abundance of scientific evidence and professional organizations have determined that TNR
programs are ineffective in reducing feral cat numbers, contribute to unsustainable predation on
sensitive wildlife, and undermine public health and safety. Please consider the following:
 TNR Fails to Reduce Cat Populations. The results of an evaluation of two long-term
TNR programs in California and Florida led a team of researchers to conclude that “no
plausible combination of [conditions] would likely allow for TNR to succeed in reducing
population size.”i
Other studies have even concluded that TNR may lead to increased cat
abandonment and be worse than doing nothing at all.ii,iii
 Feral Cats are Invasive Predators. Feral cats are among the world’s most harmful
invasive species and have contributed to the extinction of 63 species.iv,v
Each year in the
United States cats kill 2.4 billion birds, making them the top source of direct, human-
caused mortality.vi,vii
 Feral Cat Colonies are a Rabies Risk. Cats are the number one carrier of rabies among
domestic animals, having accounted for 76% of all confirmed cases in New York from
2001-2014, and pose a “disproportionate risk for potential human exposure.”viii
Public
health organizations such as the National Association of State Public Health
Veterinarians advise that all stray cats be removed from the community.ix
 TNR Amplifies the Risk of Toxoplasmosis. Cats are the definitive host for the parasite
(Toxoplasma gondii) that causes toxoplasmosis, which is the reason why doctors advise
pregnant women to avoid changing cat litter. A single cat may excrete hundreds of

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millions of tiny eggs (oocysts) that can infect any warm-blooded animal. Infection in
humans can result in miscarriages, blindness, memory loss, organ failure, and death. x,xi
There are also links with behavioral changes and mental disorders. By keeping cats on
the landscape, TNR perpetuates the transmission of this parasite and its environmental
contamination and reproduces the conditions that have led to epidemics in North
America.xii
 TNR is a Legal Liability. Purposely maintaining feral cats on the landscape introduces
unnecessary legal risks. Who will be responsible should one of these cats scratch or bite a
person? Furthermore, not only are the wildlife species that cats attack public trust
resources, many are also protected by a variety of laws including the Migratory Bird
Treaty Act and the Endangered Species Act, and a federal lawsuit is currently in progress
because of the maintenance of feral cats near Piping Plovers at Jones Beach State Park.
Although ABC and a strong coalition of humane organizations, sportsmen’s groups, and
conservation professionals oppose TNR, we would be happy to discuss more appropriate
methods of cat control. Initiatives such as licensing, microchipping, and keeping cats contained
are all proven methods that can benefit cats, wildlife, and people.
Based on the overwhelming evidence that invariably indicates the failure of TNR, I urge you to
withdraw S6182. Rather than sponsoring a program that will maintain roaming hordes of feral
cats outdoors, the State would be better served by treating cats like dogs and to actively and
effectively contain these animals.
Thank you for your consideration,
Grant Sizemore, M.S., AWB®
Director of Invasive Species Programs
American Bird Conservancy
i
Foley P., J.E. Foley, J.K. Levy, and T. Paik. 2005. Analysis of the impact of trap-neuter-return programs on
populations of feral cats. Journal of the American Veterinary Medical Association 227: 1775-1781.
ii
Castillo D. and A. L. Clarke. 2003. Trap/Neuter/Release methods ineffective in controlling domestic cat “colonies”
on public lands. Natural Areas Journal 23: 247-253.
iii
McCarthy R. J., S. H. Levine, and J. M. Reed. 2013. Estimation of effectiveness of three methods of feral cat
population control by use of a simulation model. Journal of the American Veterinary Medical Association 243: 502-
511.

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iv
Lowe S., M. Browne, S. Boudjelas, and M. De Poorter. 2000. 100 of the World’s Worst Invasive Alien Species: A
Selection from the Global Invasive Species Database. The Invasive Species Specialist Group, International Union for
the Conservation of Nature.
v
Doherty T.S., A.S. Glen, D.G. Nimmo, E.G. Ritchie, and C.R. Dickman. 2016. Invasive predators and global
biodiversity loss. Proceedings of the National Academy of Sciences 113: 11261-11265
vi
Loss S.R., T. Will, and P.P. Marra. 2013. The impact of free-ranging domestic cats on wildlife of the United States.
Nature Communications 4:1396.
vii
North American Bird Conservation Initiative, U.S. Committee. 2014. The State of the Birds 2014 Report. U.S.
Department of Interior, Washington, D.C. 16 pages.
viii
Roebling A. D., D. Johnson, J. D. Blanton, M. Levin, D. Slate, G. Fenwick, and C. E. Rupprecht. 2013. Rabies
prevention and management of cats in the context of Trap-Neuter-Vaccinate-Release programmes. Zoonoses and
Public Health doi: 10.1111/zph.12070.
ix
Centers for Disease Control and Prevention. Compendium of Animal Rabies Prevention and Control, 2011. 2011.
Morbidity and Mortality Weekly Report 60: 1-17.
x
Torrey E.F. and R.H. Yolken. 2013. Toxoplasma oocysts as a public health problem. Trends in Parasitology 29: 380-
384.
xi
Gajewski P.D., M. Falkenstein, J.G. Hengstler, and K. Golka. 2014. Toxoplasma gondii impairs memory in infected
seniors. Brain, Behavior, and Immunity 36: 193-199.
xii
Boyer K., D. Hill, E. Mui, K. Wroblewski, T. Karrison, J.P. Dubey, M. Sautter, A.G. Noble, S. Withers, C. Swisher, P.
Heydemann, T. Hosten, J. Babiarz, D. Lee, P. Meier, and R. McLeod. 2011. Unrecognized ingestion of Toxoplasma
gondii oocysts leads to congenital toxoplasmosis and causes epidemics in North America. Clinical Infectious
Diseases 53: 1081-1089.