Michael Johnston.
0407 852 355
Attention: Alastair Smith
Animal Welfare Victoria
RE: Follow-up comments from POCTA Stakeholders Welfare Workshop – Feral Pests (7 March, 2019)
Thank you for the opportunity to attend and contribute to the discussion at the above Workshop. Following from this, and your invitation to provide feedback on the discussion specifically, I have prepared the following notes describing my perceptions and/or experience about the impact of the current regulatory environment relevant to management of feral cats, including POCTA but also relevant to the Victorian Government response to the threat that feral cats present to wildlife species. In respect of these notes, I have provided hyperlinks to supporting/background information.
Firstly, I declare that through my currently undertaking subcontract work from Scientec Research Pty Ltd, I have a direct interest in the field of invasive species control. I particular, I am currently the recipient of a financial reward from provision of expert advice and field services for works associated with cat (feral and domestic) management on French Island. In addition, I have previously been associated with a number of programs entailing feral cat control activities through work for the Victorian, Federal, and West Australian Governments.
In respect of the Workshop per se, it was apparent that the audience of the day was largely composed of commercial pest animal contractors and that each supplier favour use of tools and skillsets that aligned with their own commercial interests, i.e. what they offer to the market. As such, the process of attempting to rank the ‘hot topics’ appeared to result in the discussion failing to recognize that effective pest animal control often entails the necessity of using ‘all of the available tools’ in combination.
It is my belief that there are a number of important changes that need to occur rapidly to provide the best protection for Victorian wildlife.
My personal bias, other than the declaration noted above, is that I would like to see that populations of feral cats (as defined) can be managed using efficient, humane and logical tools and/or techniques to protect native wildlife species that are currently at risk from predation, disease transmission and resource competition from the invasive species.
The current regulatory environment continues to actively prevent this.
The recommendations of the ‘Inquiry into the control of invasive animals on Crown land’ by the Environment, Natural Resources and Regional Development Committee (ENRRDC) were released in June 2017. Included in this report is the recommendation that “the Government declare feral or wild cats to be ‘established pest animals’ under the Catchment and Land Protection Act 1994, mirroring the way wild dogs are classified” (Recommendation 9). The Victorian State Government subsequently accepted this recommendation and made the declaration in July 2018, albeit adding limitations around the geographic extent to which the declarations apply. The declaration was initially framed to just apply to Crown land managed by the Department of Environment, Land, Water and Planning but this was revised to also include other key wildlife habitats, nominally the lands managed by the alpine resorts and Phillip Island Nature Park. The declaration does not recognise that feral cats (as defined) exist and have impacts on wildlife species on other Crown estate as well as private land. I was advised by a senior DELWP officer that the Trust for Nature, as an example of conservation land managers on private land, did not want to see the declaration apply to their properties. A potential reason for this is that requirements of CaLP create a requirement for the land manager to undertake controls and that TfN did not wish to see this imposed on their membership.
Given that the State undertakes limited compliance activity on land managers, including itself, for not adhering to the requirements of CaLP Act, I consider that this is a disadvantageous decision for private land conservation. I cannot see how that a feral cat trapping exercise on their largest property 30000 ha Neds Corner Station could hope to achieve anything meaningful given the regulatory position which requires that all cats are required to be transferred to the local shire shelter over 80 km distant in Mildura. However, this was apparently their decision.
The ENRRDC Committee went on to note that “the current Victorian legislation prevents any effective control of feral cats” (Finding 40) and further that the “current legislation, which restricts the methods that can be used to control feral cats has compounded their impacts in Victoria” (S2.3.2).
My understanding of the current regulatory position is that the only change that the CaLP Declaration of feral cats has made is that firstly, a definition has been adopted and secondly, that cats (cage) trapped may now be shot at the trap site rather than having to be transferred to the shire shelter. These are both useful improvements and act to improve the welfare aspects associated with trapping programs by removing the requirement for longer holding periods and transport of highly stressed wild animals. However, this is all the declaration has achieved to date.
In my opinion, there are further necessary changes that are required if Victoria is to improve protection of native wildlife from impact by feral cats. Further detail is provided for each point below the summary list;
1. Conservation reserves, such as national and state parks are gazetted for preservation of wildlife. Domestic animals are not permitted. It is therefore the responsibility of pet owners to prevent their pets from roaming into the conservation reserve. 2. Permitting the setting of modern leghold traps for feral cats. 3. Facilitating the conduct of aerial baiting programs using Curiosity® bait subject to wildlife risk assessments and other established procedures. 4. Trap Alerts – included as follow-up to the workshop discussion. 5. Permitting the capture and use of feral cats in AEC-supervised captive animal studies, inclusive of studies that have death as an endpoint. 6. Scientific studies using radio-collared feral cats 7. Having a regulatory mechanism that allows for trial use of new technology that may improve efficacy and/or humaneness of the management of invasive species. 8. Provision of clarity on the powers of seizure and subsequent actions required of cats in Unincorporated Localities, such as French Island. 9. Provision of timely guidance documents, such as Codes of Practice.
1. Land managers of conservation estate are responsible for the protection of the wildlife that inhabits the land that they manage (Wildlife Act 1975 and National Parks Act 1975). This responsibility may often include management of invasive species that inhabit the reserved estate. Domestic pets are not permitted in these reserves. I’d like to see that land managers are supported in their responsibilities to protect wildlife species from impact of roaming pets. There can be little doubt about the interpretation of the sign shown in Figure 1. Proposals to revise regulation relating to the management of feral and owned cats should reflect that domestic animals are not permitted in conservation reserves.
Figure 1. No dogs or cats permitted in Warrandyte State Park.
2. The current regulatory environment provides for capture of rabbits, foxes and wild dogs using leghold traps in various scenarios. It is illogical that this known-effective tool is not permitted to be used for capture of feral cats. There was obvious broad interest indicated at the Workshop for this to be revised situation to be revised allowing the setting of modern leghold traps for capture of feral cats (as defined). I would like to add some background information for your consideration. I have been involved with the research and management, including island eradication, programs in several states around Australia. These programs have used both cage traps as well as modern rubber-padded leghold traps (size 1.5 and 3) for capture of feral cats. All of this work was supervised by one or more Animal Ethics Committees (AEC). The various capture devices used have respective benefits / disadvantages with respect to apparent causation of injury, target-specificity and survival beyond release. My experience suggests that all traps, regardless of design (cage, leghold, other) cause injury and sometimes death of captured animals as well as have impacts on non-target species. Some captured animals can be released confidently while others sustain injuries that compromise their ability to survive and should not be released. I don’t have any experience with the use of laminated traps discussed at the Workshop and as such cannot comment on their relative ‘humaneness’ compared to rubber-padded designs. I don’t see that laminated traps can offer any improvement in efficacy given that they operate in the same conditions as rubber-padded leghold traps. However, I have contributed to several studies that used padded leghold traps to capture feral cats that were subsequently released after being fitted with GPS dataloggers. The data below (Figures 2 – 4) suggests that the cats did not suffer debilitating injury that impacted on their ability to survive.
Karajini National Park – Western Australia.
Source: Johnston, M., O’Donoghue, M., Holdsworth, M., Robinson, S., Herrod, A., Eklom, K., Gigliotti, F., Bould, L. and Little, N. (2013) Field assessment of the Curiosity® bait for managing feral cats in the Pilbara. Arthur Rylah Institute for Environmental Research Technical Report Series No. 245. Department of Sustainability and Environment, Heidelberg, Victoria.
Figure 2. Activity of feral cats trapped with rubber padded leghold traps at Karijini National Park. Figure 3. Activity of feral cats trapped with rubber padded leghold traps on Dirk Hartog Island.
Figure 4. Activity of feral cats trapped with rubber padded leghold traps at Roxby Downs.
I would also argue that these programs would not have been possible if a requirement existed to solely use cage traps, both on a logistical basis and also in terms of capture success. From a logistics perspective, cage traps are bulky and relatively susceptible to damage when compared to leghold trap sets. This acts to limit the ability of land managers to undertake trapping programs given the physical size of traps. Collapsible cage traps are a waste of time. The requirement to physically transport cage traps does impact on the efficacy of pest control operations with respect to occupational health and safety. Contrast this, with a box of 20 pairs of rubber padded leghold traps fit into a single Nelly crate.
Figures 5. Logistic limitations of vehicles used for cat trapping, i) 16 traps on a buggy, ii) 6 traps on an ATV.
Cage traps are best suited for capture of lazy and inept cats or those that are accustomed to metal surfaces such as fencing. They are not appropriate for capture of all feral cats in a population and are typically unsuitable for recapture of feral cats. To illustrate this, I’d request that you watch this video featuring the removal of feral cats from Tasman Island, Tasmania. Link at https://youtu.be/lv723UVEaiY The feral cats on Tasman Island were remarkable in how ‘trappable’ they were. On several occasions, we were able to open a trap, step back and then watch a feral cat walk in. It was critical for the success of this project that first bad experience that this population of cats had with humans was their last. However, we needed to understand the ranging behaviour of individual cats on the island as well as assess the efficacy of the poison baiting program. Radio-collared were fitted ti animals to inform this work. We were not able to retrap the cats that survived the poison baiting program. The last few Tasman Island cats were recovered using padded leghold traps. This use was authorised under a Ministerial exemption power that exists in the Tasmanian Animal Welfare Act (1993).
The feral cat population on French Island have been subject to the most intensive control operation in the State of Victoria. Over 1100 cats have been removed since 2010 with the bulk of these caught in cage trapping operations. Parks Victoria began the cage trapping program in 2010 that was subsequently joined by French Island Landcare Group in 2012. This program typically involves 13-16 weeks of continuous trapping using up to 100 traps per night. Good quality equipment, a known- effective bait and skilled practitioners are contracted to undertake the program which is supplemented by shooting operations. Some increase in populations of ground-nesting birds, such as purple swamphens, is evident and may be the result of reduced predation impacts as a result of the cat management works.
However, the annual trap catch data suggests that a relatively stable mean of ~85 cats trapped annually each year, (Figure 6). It is evident that there appears to be an annual sustainable harvest of cats on the island.
450 400 350 300 250 200
No. cats of 150 100 50 0 2010 2011 2012 2013 2014 2015 2016 2017 2018 Year
Male Female Unknown
Figure 6. Summary of cats removed from French Island 2010-2018.
This data must be viewed from the perspective that French Island is a closed system. Cats are not able to immigrate into the feral population from adjoining areas without human assistance. Further, despite there being no legal requirement to undertake any pet registration, identification or sterilisation, the French Island community has achieved near complete sterilisation of domestic cats – the exception being a sub-adult that is ‘queued’ for this procedure. Thus there is therefore no feeder population of unwanted kittens that ‘transition’ to become feral. Owned cats are recognised by trappers and returned to their owners. The Australian Government has nominated French Island as one of five islands that are to be targeted for eradication of feral cats under the Threatened Species Strategy. French Island is the most achievable of the sites remaining on this list, noting that Dirk Hartog Island (620 km2) achieved eradication success in 2018. The Feral-Cat Free French Island project was initiated in 2018 and has established an island-wide array of trail cameras to monitor the cat and wildlife populations throughout the life of the project. Photographs from the Spring 2018 data has been curated and tells a condemning story about the efficacy of the cage trap program on French Island. Please view this video (link at https://youtu.be/L0_TvcYzn_Q) and note that the video only includes data from the first ten cameras which are situated along the north of the island, i.e. 1000 pics of 5000. The purple coloured dots on the map image indicate the location of cage traps that were in service during the 2018 trapping program.
Cameras were not placed at cage trap sites given that I did not want the cat’s behaviour to be affected by the camera through noise and light emissions. However, it is evident that the same individual cats are regularly walking in front of cameras and it is not a stretch to argue that these same cats were walking in front of, but not entering, cage traps that were being operated close by. The animals all appear to be at least 12 months old and are in healthy condition. It is arguable that these cats have been walking past cage traps over successive years. I doubt that they will be caught in a cage traps until their health condition deteriorates to a point where they are required to accept the food lure provided in cage traps.
If the proposed Feral Cat Free French Island project is to succeed, then we need to be granted the ability to use known effective capture tools and techniques. One of the obligate rules of island eradication programs is that all breeding age animals are at placed at risk of removal at all population densities. Continued use of a cage trap only approach on French Island will lead to a burgeoning animal harvest and a deterioration in stakeholder goodwill but more importantly, an unnecessary ongoing impact of feral cat predation on French Island wildlife.
There may be opportunities to reduce the capture of wildlife species through use of innovations such as elevated trap stations. I will be assessing the efficacy of these devices for limiting capture of wildlife species for the Bruny Island (Tasmania) feral cat eradication project. Trials of these devices in south-west Western Australia and Christmas Island have demonstrated efficacy at limiting access to traps by terrestrial fauna, such as chudditch (western quoll), birds and land crabs.
Use of leghold traps should be limited to capture of feral cats (as defined) and by, or under supervision of, competent operators. Perhaps Ministerial exemption or AEC review might be a path to investigate as per the case in Tasmania and NSW / Western Australia respectively?
3) The use of the Curiosity® bait for feral cats. This product is still awaiting completion of agricultural registration from the Australian Pesticides and Veterinary Medicines Authority. Once this is complete, there is a regulatory process that is required from the Victorian Government prior to it being available for use.
The Curiosity bait was developed through a collaboration between a private sector biotechnical enterprise, the Victorian and Western Australian State governments with funding from the Australian Government. The bait product has been used at two Victorian sites during the developmental field efficacy studies, namely French Island and Wilsons Promontory. The bait was developed with the objective of managing feral cat populations over broadscale areas in a humane and target-specific manner. The toxicant is presented in a purpose-designed pellet with a tough polymer shell that is consumed by feral cats while consuming a blended kangaroo meat and chicken fat sausage. The pellet is typically avoided or rejected when the meat lure is eaten by small – medium wildlife species. Only animals that consume the pellet are exposed to the para- aminopropiophenone (PAPP) toxicant.
Victorian conservation land managers have experience in conducting baiting programs for canids such as foxes and wild dogs. However, use of a poison bait to manage feral cats will require a revision to the established canid poison baiting practices as feral cats use different foraging behaviours and dietary preferences. Feral cats will typically only take carrion, i.e. a poison bait, if they are food stressed. They will not exhume buried baits – a technique used to reduce consumption of poison baits by native species. Feral cats may not routinely utilise vehicle track networks through forested areas, particularly if canids are present. Thus the current best practice technique for effective poison baiting programs targeting feral cats involves;
- aerial baiting: to apply bait over the landscape rather than along track alignments,
- bait density of 50 baits/km to optimise the opportunity of a feral cat to encounter a bait when hungry,
- undertaken at a period of alternative prey resource is reduced. In SE Australia, this is typically winter.
- Ensure that meat lure component is attractive and palatable. Do not apply baits when wet weather is expected within 10 days of baiting. Feral cats will ignore baits that are unpalatable due to wetting or insect activity.
The procedures for application of poison baits for feral cats have been developed and optimised by colleagues in the Western Australian Department of Biodiversity, Conservation and Attractions. These same procedures were used during the field efficacy studies of the Curiosity bait. Written operational procedures exist describing application of cat baits from rotary and fixed wing aircraft, , no bait buffer distances, risk assessments, staff training, bait transport, efficacy monitoring and neighbour notification (Figure 7). I’m concerned that Victorian Government will spend considerable time developing their own procedures that will inevitably negatively impact on operational efficacy and/or delay the use of the Curiosity® bait product in time for use as part of the Feral Cat Free French Island project.
Similar with the conduct of invasive species management trapping programs in conservation estate, there should be no reason why domestic animals can contact poison baits such as Curiosity®, especially given that adjoining landowners are notified about the poisoning program and an unbaited buffer is created.
Figure 7. Public notifications for feral cat baiting programs used within Western Australia and Christmas Island.
4 – Trap Alerts.
I have had some experience with use of trap alerting systems and assisted in the development and review of these devices – see link https://www.researchgate.net/publication/281373307_Development_of_a_trap_monitoring_syste m_for_wild_dog_traps
It was obvious that the technology at this time was not able to provide the reliability required to suggest that any of the systems should be adopted. There was obvious issues associated with reliability of communications, failure of electronic components such as batteries after snowfall. The doggers themselves were not in favour of use of the devices as they did not facilitate the routine site inspection used looking for fresh sign.
However, the use case for alerting systems in other pest management programs may have more merit. I am following the development of alerting systems in New Zealand, such as Econode and ZIP possum traps which appear to be resolving many of the problems I encountered earlier with respect to power requirement, networking and reporting reliability. Interestingly, conversation with the ZIP developers suggests that they can also remotely disable / enable the traps during periods of poor weather.
I don’t consider that such systems will lead to significant improvement in my work on French Island, but I would be happy to use them if it meant that rubber-padded leghold traps could be used. I’m concerned that a trap alert mechanism should not be considered as something that will lead to an immediate callout for the trapping crew. This would rapidly lead to a 24 hour operation and would also result in the disturbance of (untrapped) cats while they were at the most active. At best, the system would be used to prioritise the daily trap clearing runs as all traps set by the proposed Feral Cat Free French Island project would be checked at least once every day.
5- The use of captive feral cats in AEC supervised studies.
The development of the Curiosity® bait pioneered the use of PAPP as a vertebrate pesticide in Australia in 1995. This required the use of many feral cats to enable the researchers to learn how the compound worked biochemically and compare it against other candidate toxicants. Cats were sourced by departmental officers and contractors from national parks and semi-rural landfills for use in AEC supervised laboratory studies.
Staff from the Victorian Government’s Vertebrate Pest Research Unit went on to be employed by the Arthur Rylah Institute where some of the former VPRU projects were continued. It became apparent that the procedure of sourcing feral cats for AEC supervised trials caused the Bureau of Animal Welfare significant concern despite the ARI AEC granting approval for conduct of the proposed procedures. Work requiring capture and maintenance of feral cats in captivity ceased.
Now that a definition exists for feral cats in Victoria, I would like to see that AEC-supervised research that involves the use of captive feral cats can now be permitted in Victoria. It is remarkable that there is community pressure to continually improve the procedures for management of invasive species but that there is now no ability to undertake such works in Victoria.
Commonly, captive animal trials would require death as the endpoint. I have two points to make about this. Firstly, the acquisition of the death as the endpoint permit adds an additional regulatory burden on top of the AEC review of proposed research studies. I’d like to see that the authorisation for studies that require death as the endpoint be transferred to the AEC as occurs in other states.
Secondly, it is worth mentioning that there is a legitimate need for the conduct of studies that require death as the endpoint. I’m aware that the Invasive Animals CRC had to repeat a series of poison bait efficacy trials as the APVMA did not accept that the data submitted as part of a new agricultural chemical product registration demonstrated sufficient efficacy, i.e. caused death, when the animals were euthanased during the latter stages of the toxicosis.
6. Release of radio-collared feral cats.
Effective invasive species control programs require the behaviours of the target species to be reasonably understood. Similarly, the conduct of research that seeks to understand the efficacy of a control program may benefit from monitoring a proportion of individuals in the population.
Field efficacy studies for the Curiosity® bait used locally trapped feral cats fitted with radio- collars/GPS loggers in AEC-supervised studies to provide critical information on the success of the baiting program. It is necessary to understand how feral cats use the landscape, what habitat and prey resources are relied upon and critically, were the cats within the bait cell when the baits were applied?
It became apparent since the conduct of these Curiosity bait efficacy studies that the practice of capture and subsequent release of feral cats was not permitted in the State of Victoria – apparently due to the regulations related to ‘abandonment’.
I regard this regulation as illogical given that the cats are free-ranging wild animals and encourage Animal Welfare Victoria to remove or modify this regulation to permit the conduct of AEC supervised research studies. Phillip Island Nature Park (PINP) and the Feral Cat Free French Island are proposing to undertake a study that investigates feral cat activity on both islands. This study wishes to collect information about the extent to which feral cats rely on a threatened migratory bird species, short-tailed shearwaters, as a prey resource during the period that the birds are present. The French Island project also seeks to look at feral cat activity within a section of French Island National Park that is the proposed translocation site for a population of eastern-barred bandicoots. Furthermore, it is quite likely that the sustained control feral cat control effort has disrupted normal territorial behaviours on French Island. It is critical to the design of an effective eradication strategy that we understand how the feral cats are using the islands. It is somewhat illogical that we could apply for permits to undertake radio-collaring studies on most other animal species, both native and invasive, in the state other than feral cats.
PINP sent an email on 7th February requesting written clarification of the procedures that can be undertaken with respect to the proposed radio-collaring study. We are still awaiting a written response to this request. Granting approval to conduct the work would provide confidence for us to submit the AEC protocol, invest significant funds in purchase of GPS collars ($~30K) and organise other logistics. Collars are not available as off-the-shelf product and as such our orders progress slowly in the queue of the supplier. This takes some considerable time. If we miss the study window, then we have to wait until next year.
It is worth adding that the cats used to assess the efficacy of a poison bait program cannot be trapped with cage traps given that we know that cats that enter cage traps seeking the food lure are more likely to be poor hunters and it is these animals that are also more likely to consume a poison bait. Thus, to avoid a bias that would artificially inflate the measured bait efficacy it is important that the traps used to capture the monitored feral cats do not use a food lure, i.e. leghold traps with a scent lure composed of blended cat scats and urine.
7. Regulatory mechanisms to support research and / or control of invasive species.
I’d like to see that the revisions to POCTA provide a mechanism to allow for the use of ‘new technology’ that is to may be developed or is required to be used for control of new invasive species. A current example is the Felixer device – see link https://youtu.be/AnpJBI_502U. This device is currently being used for control of feral cats under APVMA field trial permit in discrete study sites. This device has some promise to be used as part of an integrated pest control management solution for feral cats, and possibly also foxes, in Victoria.
I have been involved in the development of a device termed ‘Tick-Tock’. This is essentially a delayed-release implant containing sodium fluoracetate (1080) that is implanted subcutaneously in feral cats (or other invasive species) prior to release in discrete studies where it is critical that the ‘marked’ animal dies at the end of the study. Our captive animal studies to date have shown reliable release of the Tick-Tock device at 20 days (+/- 2 days) resulting in the death of the cat. The time delay before release of the 1080 can be varied by adjusting the polymer chemistry.
A possible use-case of ‘Tick-Tocks’ would be a study of feral cat behaviour around a critically threatened wildlife population such as Mountain Pygmy Possum. At the conclusion of the study, the cat would die allowing the GPS collar could be recovered. This would avoid i) potential for the cat to continue to impact on wildlife, and ii) leave the site where it is undetectable and thus has the collar on for the remainder of its life. I’m aware of other new tools, technologies and techniques currently being developed to better improve the protection of wildlife species from feral cat predation. The revised POCTA should have a mechanism to allow this novel invasive species control work to be undertaken.
8. Confirmation of legal powers to seize cats in Unincorporated Localities.
Several years ago, I was advised by a BAW officer that it was uncertain whether the power existed to seize and euthanase cats in Unincorporated Localities. This has obvious implications about the management of invasive species within alpine resorts and French Island.
The position needs to be clarified for the benefit of stakeholder agencies involved with management of cats at these sites. If there is any uncertainty about the legal position, then this needs to be addressed as high priority. Uncertainty does not provide confidence amongst stakeholder agencies nor is it responsible to allow staff to be engaged in animal management programs that has a significant level of operational risk associated with legal actions that might arise.
9. Timely document preparation.
I struggle to understand the time schedules that preparation of operational documents such as Codes of Practice etc. take to be issued. In reality, these documents should be written in a day. Documents describing the same work have all been written previously by other State and National Governments. With respect to the comments above, the procedures for leghold trapping, cage trapping, aerial baiting etc exist elsewhere. There is not any shame associated with a copy/paste for many operational procedures assuming that a logic check with appropriately skilled personnel is undertaken.
Commonly, a consistent approach with respect to documentation may actually assist in removing uncertainty. The Australian Government’s definition of feral cat, first published in 1999, defines feral cats as “Feral cats are those that live and reproduce in the wild, eg. forests, woodlands, grasslands and wetlands, and survive by hunting or scavenging. None of their needs are satisfied intentionally by people.”
While not greatly dissimilar, Victoria’s 2018 declaration provides “Feral cats are unowned and live completely independently of humans with respect to food and shelter and without veterinary care. Feral cats survive and reproduce in self-perpetuating populations in the wild”.
Why was there a need to revise this definition?
Concluding remarks.
In conclusion, it is my view that current regulatory environment that applies to feral cats falls well short of the recommendations provided in the Senate Inquiry. If the Victorian Government is serious about managing the impact of invasive species on wildlife then the appropriate tools and skills need to be provided to conservation land managers.
Feral cats will be killing native wildlife tonight. And tomorrow night. With populations of many native species, such as mountain pygmy possum, affected by changed land use, fire regime and climate, the impact of invasive predators becomes increasingly significant to vulnerable populations. As I drafted this response, I came across a quote attributed to Peter Klinken, (Chief Scientist, Western Australia) from a workshop held 13 March, 2018. The sentiments expressed summarise my position well.
Regards,
Michael Johnston