Proponent’s Proposal and Assessment
1. Proponent’s Proposal: Removal of domesticated European ferret (Mustela putorius furo) from the list of restricted animals under California Fish and Game Code §671
2. Lead agency name and address: California Fish and Game Commission and California Department of Fish and Game,1416 Ninth StreetSacramento, CA95814owls
3. Proponent’s contact person and phone number: Pat Wright, (619) 741-4439
4. Project location: Statewide
5. Project proponent’s name and address: Pat Wright, P.O. Box 3395, San Diego, CA92163
6. General plan designation: N/A
7. Zoning: N/A
8. Description of proposal: The project proponent is requesting that the California Fish and Game Commission (Commission) remove the domesticated European ferret from the list of restricted animals under California Fish and Game Code §671, or any other such list in state regulations.
9.Surrounding land uses and setting: Statewide.
10.Other public agencies whose approval is required (e.g., permits, financing approval, or participation agreement.): None.
Proponent’s Proposal to Remove the Domesticated Ferret
from the List of Restricted Mammals Under Section 671
of the California Fish and Game Code
Background and Purpose
The California Fish and Game Commission and the California Department of Fish and Game (CDFG) are the principal entities with responsibility to manage and conserve the biological resources of the state, including fish, wildlife, and plants. The mission of CDFG is to manage California's diverse fish, wildlife, and plant resources and the habitats upon which they depend, for their ecological values and for their use and enjoyment by the public. Part of that responsibility is to protect wildlife resources from the unwanted introduction of invasive, non-native species. This is reflected in the Commission’s 2005 policy statement titled Miscellaneous Policies, Introduction of Non-Native Species, which states:
“Proposals to introduce exotic species shall be submitted to the Commission for approval. The Department willreview and evaluate proposals to insure that the potential effects of such introductions will not haveunacceptable negative impacts on native species, agriculture interests, and public health and safety.In considering proposed introductions, the Commission and Department will be guided by the following:
“Introduction of exotic species will be authorized only after potential impacts have been carefully evaluatedand it has been demonstrated that such impacts will be negligible or positive. Such an evaluation will considerthe species' ability to disperse outside the introduction area.
“Initial experimental introduction of an approved exotic species will be made under conditions that will permitthe action to be reversed, such as introduction into a confined area or introduction of sterile individuals.
“Benefits of the action will be described, including why the need cannot be satisfied through improvedmanagement to enhance native species or previously established non-native species.
“Introduction of previously established non-native species into areas of the state where they have not beenestablished will be permitted only after it has been determined by the Department that they will have nosignificant negative impacts.”
This Proponent’s Proposal is a formal request to the Commission and CDFG, per its 2005 PolicyState above,to allow importation, ownership and transportation of the domesticated ferret.This document also provides the Commission and CDFG with information concerning potential environmental, economic, and human health impacts of legal domesticated ferret ownership in California.
This document could be useful as input for a Statement of Reasons for Regulatory Action by the Fish and Game Commission, for example,as part of an action to amend Section 671 and related code to allow import, transportation and ownership of the domesticated ferret in California. The Commission recently proposed amendments to §671, §671.1 and §671.7 to allow import of live Barramundi for aquaculture purposes. The project proponent would welcome a similar administrative process to allow import of the domesticated ferret to licensed facilities that would ensure all retail sales or rescue placements are limited to sterile and inoculated animals.
In support of its proposal, the proponent commissioned a major research effort into the health, environmental and economic effects of legalized ferret ownership. The results of that effort are summarized below. The proponent welcomes any opportunity to work with the Commission and DFG to clarify and augment this information during the administrative process.
Introduction
The domesticated European ferret (Mustela putorius furo)is a distant descendant of the wild polecat, having been bred for thousands of years to become domesticated animals for use as hunting companions, pets, or for rodent control. They are now almost exclusively maintained as pets, and their numbers have risen significantly in recent yearsas ownership has become more popular following favorable portrayals of pet ferrets in several popular films and television shows. Estimates of the total population in North America vary widely, butan averaging of all estimates indicates that several million domesticated ferrets likely reside in North America.[1]
Neither the ferret nor the polecat is considered by the scientific community to be an established wild mammal in North America.[2] The domesticated ferret is incapable of surviving more than a few days in the wild. Ferrets raised in captivity do not recognize insects or birds as food, and if they escape they are subject to predation by a wide variety of animals, including fox, coyote, mountain lion, bobcat, domestic and feral dogs, and several raptor species, including owls, hawks and osprey. They are incapable of sustaining themselves long enough in the wild to establish wild feral ferret populations anywhere in North America.[3]For this reason, it is not surprising that that no sightings of feral ferret colonies have ever been confirmed in North America.
Perhaps ironically, Californiaand New York City are now the only places in all of North America that currently bans ownership of the domesticated ferret by law. Ownership of the domesticated ferret is legal in all other US states in North America, plus all states in Mexico and all provinces of Canada.[4]The domesticated ferret is also the only domesticated animal presently on the list of restricted animals under Section 671 of the Fish and Game Code; all other animals on that list are wild animals.
Despite this ban, which has been in place since 1933, more domesticated ferrets reside in California than in any other USstate. Estimates of the California domestic ferret population vary from as little as 10,000 to as much as 1 million, with an averaging of all estimates producing a figure of about 300,000. What is known is that more than 25 percent of pet ferret food and supplies in the nation are legally purchased in California, providing an estimated $125 million to $250 million in economic benefit annually. Veterinarians in California are legally allowed to treat the domesticated ferret, but ferret owners are often reluctant to seek treatment for sick or injured ferrets out of fear that their pets may be confiscated, often delaying treatment until after the animal presents a health hazard to others. Owners of pet ferrets in Californiaalso often live in fear that malicious ex-spouses or neighbors will inform police or wildlife officials of their pets’ existence, leading to confiscation of their beloved companions.
Though dozens of states have removed previous restrictions on domesticated ferret ownership, California governmental officials, including Governor Arnold Schwarzenegger, have stated that they would favor legalization only if convinced it would not create significant impacts to the environment or to human health and safety.To address this stated need for an assessment of potential impacts,the project proponent has commissioned a detailed, independent study of the issues associated with allowing ownership of the domesticated ferret in California. The full report, entitled “Analysis of the Potential Impacts of Domesticated Ferrets Upon Wildlife, Agriculture, and Human Health in North America, With a Focus Upon California, Based Upon Literature Review and Survey of North American Governmental Agencies,” by Dr. G. O. Graening of Sacramento State University, is attached as reference, and is used as the basis for this Proponent’s Proposal and Assessment.[1]
Based upon the findings of Dr. Graening’s report, the proponent sees no reason why California should continue to stand alone as the continent’s last bastion of illegal pet ferret ownership. As is demonstrated in the report, and summarized below, removing the domesticated ferret from the list of restricted animals under Section 671 of the Fish and Game Code would not create significant impacts to human health or safety, wildlife,or agriculture, either when considered in isolation or especially in comparison to the risks created by dogs or cats.Legalization of pet ferret ownership is likely to create positive economic effects through sales of animals and supplies, however, generating tens or even hundreds of millions of dollarsin economic activity, and creating new jobs in the process. Legalization could also reduce costs for state and local governments by avoiding the enforcement and housing costs associated with the confiscation of thousands of pets annually at agricultural inspection stations and other locations in the state.
Impacts on Wildlife and Agriculture
Much of the previous literature cited as justification for banning the domesticated ferret as a legal pet in Californiaconsists of reports of past invasions of feral ferrets and resultant impacts on wildlife and on agriculture, especially to poultry operations in Europe in the 19th Century. However, the key finding of Dr. Graening’s study is the complete absence of confirmed feral ferret colonies in North America. Given what is now known about the behavior of the domesticated ferret, compared to the folk lore that dominated the debate until recently, the lack of confirmed sightings of established feral ferret colonies in the UnitedState is not surprising.
For a feral ferret population to establish itself in California or anywhere in the continental US, several conditions must be met: a sufficient number of animals escaping into the wild to overcome the loss of predation, disease or other life limiting hazards; a sufficient amount of prey and habitat is available for their survival; and the escaped colony is capable of reproducing itself.Though there has been anecdotal evidence of feral ferret colonies in the US, further investigations into these sightings have proven, without exception, to be based on erroneous or hearsay information, such as misidentifying a domesticated ferret for a Least or Long-tailed Weasel, a now-extinct Black-Footed Ferret,or an Ermine, all of whom are close relatives of the ferret in the genusMustela, or the American Mink, a more distant relative of the ferret in the family Mustelidae.[5]
Unlike domesticated feline and canine species, it is extremely unlikely that a domesticated ferret could survive in the wild for more than a few days, as they do not have the skills nor instinct for survival in the wild. Because of their high metabolism rate, they must eat up to 10 times per day. The food fed to them for the first 6 months of their life is the only food they will recognize their entire lives, meaning they do not recognize insects or birds as food, and therefore depend solely for food upon their masters. They cannot survive long exposures of direct sunlight nor sustained temperatures above 80 degrees F. Following the advice or every ferret organization and all knowledgeable veterinarians, pet ferret owners very seldom allow their pets to roam free outdoors, due to their ability to quickly escape and hide in small spaces, and resultant mortality within a few days. These facts alone effectively ensure that no feral ferret community could survive in the wild in California, and that even escaped ferrets are highly unlikely to inflict significant damage to wildlife before they die or are recaptured, especially when compared to dogs and cats.California also has large populations of animals that prey upon stray ferrets, further decreasing any chance of establishing a feral colony.
That no established feral ferret populations have been confirmed in the US, despite that ownership is legal in 48 states and despite that millions of ferrets live in captivity in all states, provides sufficient information to confirm that the domesticated ferret is essentially incapable of surviving in the wild and therefore cannot create significant impacts to wildlife and agriculture in California. The provision that all domesticated ferrets sold in California would be sterile would effectively eliminate the potential to establish a feral ferret population in the state, and therefore would have no potential for creating significant impacts on wildlife or agriculture.[6]
Dr. Graening’s report also confirms that no state or local agency in the US has reported impacts of ferret ownership on agricultural resources in the country for at least the past 20 years. Past folklore of stories of ferrets being particularly vicious carnivores that would kill an entire flock of chickens out of bloodlust have proven to be great exaggerations, or mistaken identity with weasels or other carnivores. In reality, the domesticated ferret is as docile and trainable as any other domesticated animal and, unlike domesticated dogs and cats, very seldom attacks or kills other animals for food.[7]
Impacts on Human Health and Safety
Like all domesticated mammals, the domesticated ferret has potential to bite humans, especially if not trained or handled properly. However, the key question in assessing impacts of legal ownership is whether the delisting of the domesticated ferret from Section 671 would create significant, unmitigated impacts to human health, either in isolation or cumulatively when combined with the impacts created by other pets.
Though attacks on humans are often detailed in the media, and cited as evidence that feral ownership should not be allowed in California, the key factor of perspective has been missing in previous arguments.Dr. Graening’s study shows that even when accounting for the proportion of dogs vs. domesticated ferrets in the US, domesticated ferretsare 200 times less likely to inflict serious injury on humans than domesticated canines. Even if that information was off by a factor of 10 (an order of magnitude), dogs would still be 20 times more likely to attack a human than ferrets. Even if it was off by a factor of 100 (two orders of magnitude), dogs would still be twice as likely to attack humans compared to ferrets.
Further, bites from ferrets result in far fewer hospital visits per incident than bites from cats or dogs. Dogs alone are responsible for more than 2 million bites and 300 deaths per year in the US, mostly of children, whereas only two fatalities from ferret bites have been confirmed in the last 50 years, and those were both of infants left alone with the pets. This is sufficient evidence that legalizing domestic ferret ownership will not create significant impacts to human health and safety. Impacts can be further reduced through effective education stressing that no infant or small child should ever be left alone with any domesticated mammal, including dogs, cats or ferrets.
Similarly, with the condition that all ferrets sold in the state be properly vaccinated against Rabies and canine distemper,[8] the potential for significant health impacts due to infection from ferret bites is less than significant, given the relative infrequent occurrence of bites in comparison to domesticated felines and canines. Even if a non-inoculated domesticated ferret becomes infected with Rabies, it is very rarely capable of transmitting the disease to another animal because the disease generally results in almost immediate death for the infected animal. Infection of ferrets is extremely rare, however. Only five cases of ferrets infected with Rabies have occurred in the US since 1985. For this reason, it is not surprising that no transmittal of Rabies from a domesticated ferret to a human has ever been confirmed in the US. By contrast, bites from rabid dogs cause more than 55,000 deaths per year worldwide and prompt prophylactic treatment in millions of persons.[9]
Economic Cost and Benefits
The economic benefit of pet ferret ownership in California is difficult to calculate, but is estimated to be about $1,000 per animal per year, considering the initial cost of the animal and initial related expenses, such as cages, plus annual expenditures on food, toys, bedding and veterinarian costs. Americans currently spend about $52 billion per year on their pets, and though domestic ferrets make up less than 1 percent of pets in America, total spending on ferrets is estimated to be $500 million to as much as $1 billion annually nationwide.
Californians are reported to purchase 25 percent of the nation’s ferret supplies, though they must obtain the animal out of state or, more often, bring it with them when they relocate to California. That means that Californian pet ferret owners inject $125 million to as much as $250 million into the economy just for supplies and vet visits. Because sales and rescue placements of the pet ferret are illegal in California, however, the state missed out on an equal amount associated with acquiring the animal. This estimate is based upon sales figures alone.