A citizen or group concerned about the
impacts of feral cats, that could establish standing as a substantially affected party, might successfully challenge the FWCC in at
least two ways: (1) seek an administrative determination of the invalidity of the FWCC's rule prohibiting the release in the state of non-native
wildlife — defined as non-domestic animals, and thus not including cats —
on the ground that the rule is an invalid exercise of delegated legislative authority because it modifies or contravenes the specific provisions of the law implemented; or (2) seek an administrative determination that FWCC's statement that the agency does not regulate cats because they are a domestic species is an agency statement defined as a rule, in violation of § 120.54 (1)(a).