Analysis of Stockton’s proposed plan for animal services

Last week, Stockton PD released the findings of its investigation into Animal Services and found, not surprisingly given the massive amount of evidence, that Animal Services has been (still is) violating the law. The changes outlined in the police department press release do little to address the unlawful operation of an agency of the police department, but the city is taking this opportunity to resurrect an old proposal for change–and one that would only continue the current high-kill practices, especially since it seems the intention is to keep the obstinately unlawful director Pat Claerbout. The risen-from-the-dead proposal is based on a study produced by Animal Protection League (APL) consultants Tammie Murrell and Sue Marks Gibbs, neither of whom has any expertise or credentials to produce an authoritative study (but hey, they’ve worked in Stockton a long time and they know people, ya know?).

The centerpiece of the proposal is a Joint Powers Authority or JPA. Instead of San Joaquin County contracting with the city of Stockton for animal control and sheltering (unlawful as the sheltering part is), the two would form one JPA to oversee the function. Originally, the intent was for all animal services agencies in the county to participate, but the others declined. The main source of revenue for this JPA is “aggressive license enforcement,” which is a bad idea in every way. The numbers offered in support of this proposal, a projected $1 million a year in revenue, are even more wildly speculative than the 1990s/2000s projection that Stockton would become a bedroom community of Silicon Valley and the Bay Area. And look where that led.

So here is an old but still relevant analysis of APL’s study and recommendations. It’s pretty academic (but so am I), but if you care about this issue, please slog through it, educate yourself, and educate your elected officials. Use it to ask them hard questions, and demand answers. Don’t let Stockton keep killing pets.

Flaws in APL Animal Services Study

Eileen McFall

December 19, 2011


I’m writing this document in response to a request to give details about my critique of the San Joaquin County Animal Services Study produced by Animal Protection League Director Tammi Murrell and member Sue Marks Gibbs. My goal in outlining problems with the study is to re-direct attention to efforts that will dramatically improve lifesaving and conditions for companion animals in Stockton and San Joaquin County within the constraints of government finances. There are evidence-based alternatives to the recommendations that I’ve identified as problematic. Those alternatives can be found by looking to the programs and practices of animal services organizations with the highest rate of lifesaving. Ultimately, all programs and practices should work together to achieve a single mission: improving conditions and saving lives without additional public funding and without compromising public safety.


1. The study does not address the question that makes Animal Services an ongoing problem: How can we bring about the greatest improvements in lifesaving within our financial constraints?


The study is centered on the wrong question. A JPA is a means of funding and establishing jurisdiction. Saving lives is a function of the types of programs that an animal services organization employs, regardless of how it is organized or funded. The question implicit in statements like this one in the study, “Shelter intake numbers and animal-related calls for service continue to increase, forcing euthanasia rates and costs up,” is: How can we bring about the greatest improvements in lifesaving within our financial constraints? The study does not attempt to answer that question, and the recommendations are not consistent in their implications for lifesaving or costs/revenues (see item 3, licensing enforcement). This is important because correctly identifying the problem is crucial to actually solving that problem.


2. In the introduction, the authors say they were contracted to study the feasibility of a Joint Powers Authority, but the study begs the question by assuming a JPA is desirable rather than outlining criteria and actually assessing feasibility using those criteria.


The study never answers the main question it does pose. In the first sentence of the introduction, the authors say they were contracted to study the feasibility of a regional approach to animal control services; however, the study does not address the feasibility of such an approach. Instead, it surveys current practices, assumes a regional approach would be better and explains how such a regional approach works in other areas. This is why it was only after completion of the study that the Board learned that while many cities are interested in adoption, spay/neuter and veterinary services, specific programs and services, none of the cities in San Joaquin County except Stockton were interested in a JPA.


3. Presumed cost savings, efficiencies, and improvements are based on numbers that lack validity, as seen in the example of projected revenue from licensing enforcement.


Since the Board directed the consultants to continue to work on a JPA between the city and county, it is important to note that the cost savings and efficiencies to be realized through a JPA cannot be expected to materialize when the JPA includes only Stockton and the county instead of all the cities. New numbers for a JPA that includes only the city and county are suspect. Licensing enforcement, the main strategy for generating revenue, is likely to significantly increase the number of animals impounded and the rate of killing (see Southeast Area Animal Control Authority and Stanislaus County statistics, attached) and projections for $1 million in revenue are very optimistic given the economic conditions in Stockton and San Joaquin County.


The APL study, even with new numbers intended to project costs and revenues for a JPA limited to Stockton and San Joaquin County, projects $1 million in revenues with enforcement staff of 6 FTE. While the study notes that in other jurisdictions license enforcement can include a voucher for reduced-cost (NOT low cost) spay/neuter and thus the ability to license an animal at the reduced rate for altered pets, the recommendations from APL include no such provision. The implication is that license enforcement staff canvass neighborhoods looking for unlicensed pets; when unlicensed and unaltered pets are discovered, the owner is then faced with licensing costs well over $100. The No Kill Advocacy Center offers an analysis of the effects of mandatory licensing (akin but not exactly the same as the APL proposal).1 In Stockton and San Joaquin, it seems likely two scenarios will play out repeatedly, depending on the pet owner’s ability to absorb the cost of licensing altered or unaltered pets.


First, if pet owners are unable to afford the cost or unwilling to pay it, any effort to collect that revenue is pure cost to the JPA. Animals will be impounded, increasing the cost of housing and perhaps killing them. Intake and costs go up without producing revenue.


Second, if pet owners are able to afford the cost of licensing their animals, as animal lovers they may also be potential volunteers and donors. However, when enforcement staff canvass neighborhoods to generate revenue, they automatically create an adversarial relationship between pet owners and Animal Services. They may generate revenue, but at the cost of goodwill and public relations. Those communities that have achieved high rates of lifesaving have done so with significant community support, but pet owners are unlikely to volunteer or donate to an organization they see as an adversary. Furthermore, by aggressively enforcing compliance with licensing laws, the JPA is likely to discourage animal lovers from feeding and spaying/neutering community cats, or from housing strays and attempting to reunite them with their owners or find them new homes, thus potentially increasing shelter intake and lowering animal welfare in the community as a whole.


Overall, the assumptions about potential revenue from licensing enforcement are overly optimistic, ignore the likely effects on intake and shelter killing, and ignore the effects on public perception of animal services and licensing.


4. The “successful” animal services organizations and “best practices” cited in the study are primarily high-kill organizations, definitions at odds with those of most of the people making decisions as well as the pet owning public.


The agencies discussed throughout the study as models of successful JPAs vary wildly in the rate of lifesaving vs. killing. Southeast Area Animal Control Authority, cited as a model for revenue generation, killed over 72% of the animals it took in last year, or almost 18,000 animals.2 Stanislaus County killed 64% of its animals last year, up from 58% the previous year.3 A save rate of 42% is the best that Stanislaus County has ever achieved.


The Animal Protection League’s definitions of successful animal services organizations are not made explicit in the study, but the numbers show that they are at odds with common definitions of success. A recent survey of pet owners in the U.S. found that 71% believed shelters should only be allowed to euthanize animals when they are too sick to be treated or too aggressive to be adopted.4 Forbes magazine’s “15 Key Insights From 2011 From 15 Key Thinkers And Writers” includes the No Kill Equation and its architect, Nathan Winograd.5 Use of shelters that kill over 60% of animals as models of success and best practice indicates an organization that is out of touch with the public’s goals for animal services.


The study’s use of Santa Cruz County numbers without providing save/kill numbers for the other agencies it called “successful” is misleading. Furthermore, APL did not include information from or about most of the open-admission animal services organizations that actually do save 90% or more of the animals they take in.


5. The study’s proposed staffing plan fails to make use of existing, available community resources and fails to focus taxpayer money on the activities that most need to be performed by animal services staff.


Staffing recommendations do not make good use of existing community resources and are not set up to efficiently produce results. For example, the study recommends, “The joint hiring of a Humane Educator to develop a formal humane education program consisting of regular classroom visits, volunteer and teacher training, adult education opportunities, and a spay/neuter awareness campaign,” and “Establish an aggressive spay/neuter program including a high-volume spay/neuter clinic to be operated by the Joint Powers Authority.” Classroom visits and education regarding responsible pet ownership and spay/neuter are available at little or no cost to taxpayers by partnering with non-profits and using volunteers. There is a private non-profit organization, ACT Clinic, willing and poised to take on the role of high-volume, low-cost spay/neuter provider and to do fundraising associated with expansion of services. A local volunteer is eager to take on Humane Education about responsible pet ownership and has already approached the President of San Joaquin Delta College about partnering in such a venture at no cost to taxpayers. I also see staffing for license enforcement as problematic, as discussed above.


Staffing of Animal Services should prioritize those positions that are both crucial to the core functions of the public agency and that require skills or supervision not available through private partners.


Proposed programs and their likely effects on intake and outcomes at Stockton Animal Services–comparison of APL proposal with the proven lifesaving programs of the No Kill Equation.

Sources of Data

1. No Kill Advocacy Center. The Dark Side of Punitive Legislation. Retrieved December 18, 2011.


2. Southeast Area Animal Control Authority. Asilomar Accords Annual Animal Statistics
for SEAACA. Retrieved December 19, 2011.


3. Stanislaus Animal Services Agency. Fiscal Year Statistics 1987-2008. Retrieved December19, 2011.


4. GfK Roper Public Affairs & Corporate Communications. (2011, October) The Poll Retrieved December 19, 2011.


5. Butterworth, T. (2011, December 13) 15 Key Insights From 2011 From 15 Key Thinkers And Writers. Retrieved December 19, 2011.

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