BMBP’s written comments in opposition of proposed wolf delisting

October 29th, 2015

Dear Chair Finley & Commission Members,

Blue Mountains Biodiversity Project wishes to voice our opposition to the premature delisting of wolves.

Our mission is to protect and restore the natural ecosystems of the Blue Mountains and Eastern Oregon Cascades. We work on four national forests, and have been active in Eastern Oregon for 25 years. Our work includes extensive on-the-ground monitoring of public lands projects, and we have field-checked many thousands of acres of national forests with the help of hundreds of volunteers. Wolves are an integral part of ecosystem health in these areas, and we are very supportive of their full recovery so that they can once again fulfill their ecological roles and have sustainable populations.

We urge you not to weaken existing protections for wolves. We are concerned that in light of ongoing threats from poaching and other sources of mortality, Oregon’s small wolf population continues to be in jeopardy of extinction. Wolves are still too limited in numbers and in distribution for sustained populations or ecological recovery to occur. Shrinking wolf populations in neighboring states, combined with weakened protections in Oregon, will not ensure sufficient genetic diversity and connectivity. Approximately 80 wolves is a very small number for any recovering population, especially given wolves’ pack structure and breeding dynamics.

Oregonians have been clear in their overwhelming support of wolves, and want strong protections in order to ensure wolf recovery. We are disappointed that ODFW seems intent on justifying delisting, and on weakening protections for wolves—despite scientific evidence supporting the need for continued listing and in opposition to the values of most Oregonians.

The public favors wolf recovery. Public polls show that over 2/3 of Oregon citizens support wolf recovery. This is also true of public polls in Washington and California, and nationally. In addition, public support of the Endangered Species Act continues to remain strong (1, 2, 3). State and federal agencies are obliged to uphold the law, act in the public trust, and preserve natural resources, including wolves, for current and future generations.

Good-sense economic strategy favors strong ecological protections, and strong protections for wolves. Oregon’s natural landscapes are one of its most valuable economic assets. Oregonians receive tremendous economic gains from clean water, livability, outdoor recreation activities, tourism, and other resources associated with our breathtaking natural heritage. Wolves indirectly and directly contribute to these economic gains.

Strong protections are needed to ensure public acceptance of wolves. In areas where killing wolves is legally acceptable, public support of wolves may decrease (4). State-sanctioned killing of wolves actually increases controversy and discontent about wolf presence. We are opposed to lethal control of wolves, particularly on public lands.

Wolves fill vital roles in ecosystems. Wolves prevent damage to streams and riparian habitats from ungulates, and so play a critical role in the restoration of these areas. This, in turn, helps to support healthy populations of fish, birds, and riparian vegetation. Wolves can release rodent populations from coyote pressure, which in turn sustains healthier populations of certain birds of prey (5). Studies have also shown that the presence of wolves contributes to healthier soils (6), and may buffer the negative effects of climate change on ecosystems (7).

Non-lethal works! The Wood River Project in Idaho, run by Defenders of Wildlife is an example of successful coexistence of livestock and wolves. The Wood River Project has been going strong for eight years, and uses nonlethal management to protect more than 25,000 sheep that graze annually on the Sawtooth National Forest. It has one of the highest concentrations of wolves and livestock sharing the same landscape, yet the project area has the lowest rate of loss due to wolf depredations across the state. The Wood River program has been so successful that Blaine County, where the project is located, unanimously passed a resolution in 2014 requesting that the state use non-lethal tools over lethal tools. (8, 9, 10, 11) On the other hand, where killing wolves in response to depredations has been emphasized, depredations have gone up. These results are consistent with the 2014 Wielgus study showing that killing wolves in response to livestock depredations actually causes more depredations (12).

Killing wolves harms wolf pack structure, which may cause young, inexperienced, or immigrating wolves to be more likely to prey on livestock. In addition, the pack may dissolve, or reproduction can be negatively affected- potentially jeopardizing recovery in a population with very few breeding pairs. (14)

The Wolf Conservation and Management Plan is clear- more than four breeding pairs of wolves triggers a status review of the population. The law requires the Commission to base any delisting decision on scientific criteria related to the species’ biological status in Oregon and to use documented and verifiable scientific information. If the commission moves forward with premature delisting of wolves, we request an independent review. We also would like to point out that under Oregon’s current management Plan, wolf numbers are up while depredations remain low.

We are very disappointed that ODFW seems intent on justifying delisting Wolves rather than seriously considering the wishes of the public or giving an unbiased scientific review. We are also concerned that the decision to delist wolves has been unduly influenced by political concerns rather than facts.

Thank you for considering my testimony.


Paula Hood

Co-Director, Blue Mountains Biodiversity Project


  1. Defenders of Wildlife, 2013. Polls show strong support for wolf recovery in the Pacific Northwest.
  1. Tulchin Research, 2013. RE: Polls show strong support for wolf recovery in Western States.
  1. Harris Interactive, 2011. Endangered Species Act summary- Poll for Endangered Species Act public support.
  1. Treves, A., Naughton-Treves, L. & Shelley, V. 2013. Longitudinal analysis of attitudes toward wolves. Conserv. Biol. 27, 315-323.
  1. Ripple, W.; Beschta, R.; 2011. Trophic Cascades in Yellowstone: the First 15 Years After Wolf Reintroduction.
  1. Bump, J.; Peterson, R.; Vucetich, J., 2009. Wolves modulate soil nutrient heterogeneity and foliar nitrogen by configuring the distribution of ungulate carcasses. Ecology, 90(11), 2009, pp. 3159–3167.
  1. Wilmers CC, Getz WM (2005) Gray Wolves as Climate Change Buffers in Yellowstone. PLoS Biol 3(4): e92. doi:10.1371/journal.pbio.0030092.
  1. Defenders of Wildlife, 2014. Living with Wildlife: Coexisting with Wolves in Idaho’s Wood River Valley.
  1. Defenders of Wildlife, 2014. Wolves Among the Sheep.
  1. City of Ketchum, Idaho. Recommendation To Adopt Resolution 14-022 in Support of Wildlife Co-Existence and Recognizing The Wood River Wolf Project.
  1., Idaho News and Weather, 2014. Conservationists use non-lethal methods to deal with wolves.
  1. Wielgus, R. and Peebles, K. 2014. Effects of Wolf Mortality on Livestock Depredations. PLoS ONE 9(12): e113505. doi:10.1371/journal.pone.
  1. Borg, B.; Brainerd, S.; Meier, T.; Prugh, L.; 2014. Impacts of breeder loss on social structure, reproduction and population growth in a social canid. Journal of Animal Ecology 2014 doi: 10.1111/1365-2656.12256
  1. Treves, A. 2009. Hunting for large carnivore conservation. Journal of Applied Ecology 46: 1350-1356.