I agree that seems like quite an overreach on the term “captive”. If the animals are free-roaming and not in an enclosure of any kind I don’t know how one could call that captive. Would he consider free-flying California Condors as “captive”? Managed maybe, but not captive. “Managed” itself is also problematic because anything in a Wildlife Management Area…under his apparent definition…would also be captive. Perhaps he has a clearer definition of what he considers as captive and I would be interested to hear it!