December 8, 2004

US Fish and Wildlife Service
Oregon Coast NWR Complex
2127 SE Marine Science Drive
Newport, OR 97365

RE: Environmental Assessment: Mammalian Predator Damage Management to Protect Seabird Colonies on Oregon Islands National Wildlife Refuge, Three Arch Rocks National Refuge, and Adjacent Mainland Areas

Thank you for the opportunity to provide comment on this Environmental Assessment regarding predation on coastal seabirds by red foxes, feral and free-ranging domestic cats and raccoons. After careful consideration of your Environmental Assessment (EA), the Feral Cat Coalition of Oregon (FCCO) opposes all four alternatives in the draft report. All four options prescribe the removal and subsequent destruction of feral and free-ranging domestic cats, foxes and raccoons using methods that are anathema to our humane mission.

The Feral Cat Coalition of Oregon, in existence for nine years, is a Trap-Neuter-Return (TNR) program that has successfully spayed or neutered over 21,000 feral cats throughout the state. We have made significant strides in preventing future generations of cats.

While we laud your efforts to protect the 1.2 million coastal seabirds, we are troubled by the proposed lethal and, indeed, some of the non-lethal methods of predator management. We hold long-standing opposition to the use of leg-hold traps and snares that inflict inescapable pain and suffering to the animal captured. This unnecessary pain and suffering has been compounded by the Oregon Department of Fish and Wildlife's (ODFW) recent implementation of inadequate trap check requirements; merely once every 72 hours for leg-hold and body-gripping traps.

While the least onerous and most humane option in the EA is clearly Alternative 1, continuation of the current management program, we were perplexed to read the cursory consideration and subsequent dismissal of TNR programs without sufficient analysis. We strongly believe TNR to be a significant component in any humane animal and wildlife management plan and request that you revisit the issue as a more humane, cost-effective alternative means of controlling feral cat populations. Other salient issues in Option 1 include improved trash and carcass removal that would reduce the number of feral and free-ranging cats attracted to a site.

We emphatically oppose Alternative 2, which employs all removal methods, both lethal and non-lethal. Similarly, we out rightly oppose Alternative 4, albeit seemingly possessive of a scintilla of humaneness. Alternative 4 proposes to employ lethal removal methods only after exhausting all non-lethal methods. Again, both alternatives employ trap and destruction of feral and free-ranging domestic cats.

Alternative 3 is misleading, apparently utilizing a version of TNR for cats by capturing them and taking them to local shelters to be euthanized. This option might be more palatable to the animal welfare community, of which you claim to be a member, if it were expanded to include a partnership with the various cat advocacy groups throughout the state who already implement TNR programs and do not take them to local county shelters to be destroyed. We cautiously advocate your further exploration and revision of Alternatives 1 or 3 to incorporate a TNR program for feral and free-ranging cats, although this encouragement must not be construed as support for either proposal in current form.

We are uncertain whether the problem you seek to resolve is truly destruction of coastal seabird habitat or if the concern is disturbance of the observable seabird habitat provided the general public. By your own admission, larger nests of seabird colonies exist offshore from Coquille Point on, named, ironically, Cat and Kittens Rock. Such a distinction can hardly be a rationale for the indiscriminate, inhumane destruction of red foxes, feral and free-ranging cats and raccoons.

While the observable seabird habitat provides aesthetic value as well as economic benefit to many Oregonians, it is a fact stated in your EA that "knowledge that feral cats may be removed (killed) may be distressing and detract from some individuals' aesthetic enjoyment of the refuge and surrounding areas."

Consequently, "lethal predator damage management," killing feral and free-ranging cats, using leg-hold traps, snares and shooting, "will not be conducted when people are likely to be present." Your plans urge discretion in "placing traps and bait stations out of the view of the public," presumably to protect the taxpaying public from having their aesthetic birdwatching activities disturbed by witnessing a dying animal in a body-gripping trap or taking a "clean" gun shot to the brain.

Despite your stated goal of "avoidance of all unnecessary forms of animal suffering," your proposed plans contradict this assertion. Humane application of snares and leg-hold traps is oxymoronic, counterintuitive and unattainable. If your mission is humane protection of coastal seabird habitat, why not conduct your "activities" in full view of taxpaying seabird enthusiasts? After all, as stated in the EA, "in the long-term, effective efforts to manage predation by mammals may enhance the chances for the public to view seabirds."

Your additional stated goal of avoiding the killing of non-target animals, as a means of minimizing unnecessary suffering is also counterintuitive. Minimizing unnecessary suffering in all animals should be the collective goal, not just for the sake of the errant free-wandering Labrador Retriever.

The overall EA states that the likely fiscal impact of all four options is imperceptible. It may be prudent to calculate possible negative fiscal impacts to the coastal tourism economy should disapproving, enlightened public sentiment ensue subsequent to perceived inhumane removal of feral and free-ranging cats. A more precise cost estimate for trapping and destroying feral and free-ranging cats would be instrumental in proposing alternative plans for humane removal of the cats.

Although the FCCO takes no position regarding the destruction of foxes, raccoons and rats, we are impressed with your confidence that the methods used to destroy these scourge; firearms, traps, snares, zinc phosphides, aluminum phosphides, gas cartridges, and denning, will not effect humans and their pets (nonnative domestic or free-ranging felines, nonnative domestic or free-ranging canines) and nontarget animals and will take extra precautions and measures to dispense diphacinone in tamper-resistant bait stations and will only be deployed by professionally trained USFWS employees. We would, however, feel greater assurance that these lethal weapons and hazardous materials, including agents used to eradicate noxious weeds, will be scrupulously monitored so as not to adversely affect vulnerable wildlife and even the very seabirds that these proposed actions were devised to protect. Such precautions should be elucidated in writing.

We resolutely support truly humane efforts to protect coastal seabird populations. Please do not hesitate to contact us for further information or comments. We look forward to more spirited discussion and the opportunity for a public hearing in the near future.

Thank you again for your consideration of our comments.

Respectfully,

The Feral Cat Coalition of Oregon