Please make submission to the draft 'Animal Care and Protection Act', by 25th March. Victoria needs exemption from ‘abandonment' - to save the lives of Community Cats.   Submit to: https://engage.vic.gov.au/new-animal-welfare-act-victoria  (Only submissions to Engage Victoria help - this petition is invalid without addresses.)

There are two parts for submissions - one on the draft text, and one on the Regulations.  Please ask for this Exemption in both: Part 3 Division 2, 21 (1)(d) 'person abandons the animal': Exemption for Trap Neuter Return and Return to Field programs when run by trained/qualified authorised officers, or specialists in cat management.

AJP Guide for submissions: https://assets.nationbuilder.com/animaljusticeparty/pages/2702/attachments/original/1709183925/AJP_Guide_to_Animal_Care_and_Protection_Bill_and_its_supporting_regulations.pdf?1709183925   AJP video: https://www.youtube.com/watch?v=Y3bJX8dWsqA

Upload your document.  Also fill-in the Regulations Survey. Written submissions can only challenge the Act wording.  We can only comment on the Act in the Regulations. In Regulations choose 'Needs significant updates' then make comments.

Please comment in Regulations Survey on the Code of Practice for the Private Keeping of Cats - which was revised in Dec 2023: https://agriculture.vic.gov.au/livestock-and-animals/animal-welfare-victoria/domestic-animals-act/codes-of-practice/code-of-practice-for-the-private-keeping-of-cats  

CoP calls domestic cats ‘wild and feral’ and claims they 'do not make good pets'. Please comment that: Homeless cats, ‘community’ and ‘stray’, are NOT ‘feral’.  

Australian Pet Welfare Foundation: ’Cats should be categorised based on how and where they live.’ APWF recommends that cats should be recognised as feral or domestic, consistent with the RSPCA’s Best Practice Domestic Cat Management (2018). …consistent with the 2015 TAP, which classified cats as feral, stray, or domestic. …stray cats … live in and around where humans live or frequent should not be considered feral cats. …Sociability and adoptability cannot be judged in a highly stressful environment, such as in a trap cage; frightened pet cats may display more aggressive behaviours towards humans than truly feral cats (Slater 2013; Jacobson 2022). …5 days, and up to 14 days or longer, are required for many pet cats to habituate to a new environment and for accurate assessment of sociability.’ (full meaning below)

An animal lawyer notes this new Act recognizes animal sentience, but then gives animal industries’ exemption for cruel acts - meaning that animals have no legal ‘protection’, no ‘care’.   The Act licences animal industries of hunting, killing, racing, and maiming: exemptions - and these actions cannot be challenged in court.   Please ask for Animal Industry exemptions of cruelty offences (wounding, torturing, tormenting, terrifying, starving, killing) to be removed.  

Please add links in your submissions:

Scientific evidence from the Australian Pet Foundation is not being followed - the Act requires ‘best available scientific evidence’:

Community Cat Programs work to save both cats and wildlife, and at much lower cost: https://www.youtube.com/watch?v=PQbK3R36Xjg  https://petwelfare.org.au/2022/08/31/australian-pet-welfare-foundation-position-statement-on-cat-containment/  

24-hr cat curfews fail Victoria, and have failed in Casey and Yarra Ranges: https://petwelfare.org.au/2022/09/02/key-issues-to-consider-related-to-mandated-24-7-cat-containment/  

Way to prevent killing and to lower pound intake: https://theconversation.com/australian-shelters-and-pounds-kill-50-000-mostly-healthy-cats-and-kittens-in-a-year-theres-a-way-to-prevent-this-pointless-killing-201947   Full scientific article: https://www.mdpi.com/2076-2615/13/11/1771 

The Impact of Lethal, Enforcement-Centred Cat Management on Human Wellbeing: Exploring Lived Experiences of Cat Carers Affected by Cat Culling at the Port of Newcastle  https://www.mdpi.com/2076-2615/13/2/271?fbclid=IwAR2GgLTAULJoaBhVuVsrPIG59S5dV54OhoPQexarznCH57fjfzWuojhw3xs 

Please give your feedback on the Code of Practice for the Private Keeping of Cats in the Regulations Survey.

For Recommended Best Practice

Suggestion: Community Cat Programs, Trap Neuter Return, to be run by trained/qualified authorised officers, or specialists in cat management - to reduce homeless domestic cat numbers, and contribute to community wellness in a cost-effective solution.

Authorised Officers require appropriate training, currently they are authorised by a Manager’s letter and photo to the Minister.  Veterinary psychiatrist assessment to be required for impounded cats and dogs.

Correct the false wording of ‘feral’ and ‘wild’ to ‘Domestic’. Community cats are NOT feral and wild cats.  (APWF definition is below)

The CoP 6. Owner responsibilities claims that  '(wild born kittens generally do not make good pets)'   Suggestion: Please delete as this is disproven by cat carers who socialise wildborn/domestic community kittens

For Advice: Councils and Pound Operators are listed but the Australian Pet Welfare Foundation is not.  Suggestion: Please delete defining ‘councils’ as experts, as they are not ‘experts’ and many have high euthanasia rates.  Knox also denies cat owners equal legal rights in not requiring a statement, and representing unknown complainant in court.

10 Breeding: claims undesexed ‘howling’.  Suggestion: Incorrect - as desexed Siamese-mix breeds often vocalise loudly.

12. Housing:  Suggestion: Please remove inaccurate ‘generally sedentary’ and claiming ‘protection’.  Feline Lower Urinary Tract Disease is a disease caused in confined cats, which can be fatal.

Cats are social animals and confined cats can suffer from being denied the same equality and social benefits and being seen and sharing community as canines do.  Here felines, females, are being denied canine equality enjoyed in Victoria’s Dog Parks, off-leash outside walks, and the annual dogs’ party of Pets in the Park - which are paid for by feline registrations.

14. Training and socialisation states: 'Cats should be trained to fit in with the life of their owners (for example, trained to not jump onto tables).'  Suggestion: Remove the judgemental example: a cat is not a dog, and vets advise that cats need jumping to maintain health and fitness.  

17. Trapping stray and feral cats, states feeding bans: Feeding wild or feral cats must not be practised (except if undertaking an appropriate trapping program).  Suggestion: Domestic homeless cats are not ‘feral’, and not ‘wild’ they are Domestic Community Cats.  Compassion and care cannot be banned.  

CoP Statements 17: ‘Trapping… is an effective and humane method to catch and remove cats, particularly for those that are wild and not able to be handled.’  

‘Feeding wild or feral cats must not be practised as it promotes their reproduction and increases the risk of wildlife predation, and injury of pet cats due to fighting.’  Suggestion: correct ‘wild’ to ‘homeless’ or ‘domestic’ or ‘community cats’

Appendix 1: Organisations that can provide further information. Suggestion: Why is the Australian Pet Welfare Foundation not listed?  APFW have the ‘best available scientific evidence’ on cats and dogs.  Agriculture Victoria lists ‘Local Councils’, pound operators and orgs which profit from trapping, caging and killing cats and rising euthanasia of kittens.

Thank you to Jenny Cotterell for the info on the TNR exemption needed, authorised officers, and on dogs: 'Council pounds do not have the capacity to house and care for seized animals with cruelty cases, currently with dogs seized under Section 29 DAA (attack) their health and wellbeing being is compromised waiting for court hearings, some being housed for over a year with limited enrichment.' 

Scientific Testing: Ask Victoria, and the Federal Government, to stop funding of animal experimentation. APWF also suggests: ‘There should be a legal limit on the number of years an individual animal can be used for research and teaching for e.g., 1 year to protect individual animal welfare, ensure animals are able to be rehomed and experience a normal life for a reasonable amount of time, and that any use for research and teaching is minimised over the course of their overall life expectancy.’

In Outro:  We can ask for a Victorian Animal Authority - with jurisdiction over Local Councils and animal industries.  Also can ask to consider fines for Local Councils when decisions are not based on ‘best available scientific evidence’.  And for media which disseminates public misinformation affecting animals’, and carers’, welfare.  

Definition of cats

Emeritus Professor Jacquie Rand:  Cats should be categorised based on how and where they live. Accordingly, we recommend that cats should instead be recognised as feral or domestic, consistent with the RSPCA’s Best Practice Domestic Cat Management (2018). We suggest this this approach is also consistent with the 2015 TAP, which classified cats as feral, stray, or domestic. In this regard, stray cats (which may be semi-owned or unowned), which live in and around where humans live or frequent should not be considered feral cats. Further, this approach is based in contemporary evidence and research: Domestic cats have some dependence on people (direct or indirect) and live in the vicinity of where people live or frequent, which includes around farm buildings, mining sites and in indigenous communities, and are subcategorised as owned, semi-owned and unowned. Domestic cats may be:

- owned, live in a domestic household, are usually named, have a form of identification, and depend on humans for their food.

- semi-owned, are directly dependent on humans and are intentionally fed by people who do not consider they own them. These cats are more abundant in disadvantaged areas and where food resources are available. They are sometimes called stray cats. Recent research documented strong emotional bonds of semi-owners with the cats they care for, and almost identical to the bonds reported by cat owners with their pet cats (Scotney 2023; Neal 2023; Ma 2023; Crawford 2023).

- unowned, are indirectly dependent on humans and receive food from people unintentionally, such as via food waste bins. They are more abundant in areas where food resources are available. These cats are of varying sociability and are sometimes called stray cats.

- Feral cats have no relationship with or dependence on humans (neither direct nor indirect), survive by hunting or scavenging for food, and live and reproduce in the wild (e.g., forests, woodlands, grasslands, deserts). Feral cats do not live in the vicinity of where people live, and they do not receive food from humans intentionally (direct feeding) or unintentionally (e.g. via food waste bins, rubbish dumps). Feral cats are not found or trapped in the vicinity of where people live or frequent and are not the subject of nuisance complaints relating to behaviour around humans.

Importantly, behaviour towards humans is an invalid test of whether a cat is feral or domestic.  Sociability and adoptability cannot be judged in a highly stressful environment, such as in a trap cage; frightened pet cats may display more aggressive behaviours towards humans than truly feral cats (Slater 2013; Jacobson 2022). A minimum of 3 to 5 days, and up to 14 days or longer, are required for many pet cats to habituate to a new environment and for accurate assessment of sociability.'  https://petwelfare.org.au/wp-content/uploads/2023/12/APWF-Submission-Summary-to-Draft-TAP.06.SL-5Dec23-website.pdf

The Minister, in May 2022, announced this revised Animal Act as part of ‘a 10-year state-wide cat-management strategy’.  ACT’s Act recognised ‘sentience’ then in 2021, enacted statewide lifetime cat curfew with enforcement fines of $1600 if a cat steps past its property-line - enforcing greater cruelty and inequity upon cats and carers.  Victoria has also announced cat containment grants, re‘education’ of cat-owners, ‘RSPCA key role’ (Victoria’s high contract-killer of cats). 2023’s voluntary, open-worldwide, Pet Census asked questions on only one species of pet - collecting skewed data.  Victoria’s Code of Practice for the Private Keeping of Cats was changed on 6 Dec 2023. The draft Animal Act was then released for public consultation on the 15 of Dec 2023 - a time of year to hide intent and to lessen dissent.

Please make individual submissions in your own name, words, and experience, including the Exemption for Trap Neuter Return. I have written a document submission for Knox AdvoCats.  We need many more in your own names. https://docs.google.com/document/d/1Y3bOE8ceam8OSZfqTyEGvtg4NOTmNeFa8XhESS_xTRQ/edit?usp=sharing  https://www.academia.edu/114881114/Knox_AdvoCats_to_Victorian_Animal_Care_and_Protection_Bill_Act

The government has not been listening, to what scientifically works. Please speak for the voiceless.  Thank you!

Ashlley for Knox AdvoCats   - Save Cats, Save Wildlife