Comment on the Oregon Wolf Conservation and Management Plan

Public comments on the draft revised Wolf Conservation and Management Plan still being accepted

The Oregon Department of Fish and Wildlife (ODFW) is still accepting comments on their draft revised Wolf Conservation and Management Plan. During the May 19th Oregon Department of Fish and Wildlife (ODFW) hearing, the public sent a strong and clear message that Oregonians support strong protections for wolves. We need to keep up the pressure! We remain concerned that the revised wolf plan does not adequately protect wolves. Please submit written comments to the Oregon Fish and Wildlife Commission on behalf of wolves.

See our talking point suggestions below. Please also note that ODFW recently issued a order to kill pack members of the Harl Butte Pack for depredations of livestock on public lands. BMBP is adamantly opposed to killing wolves, especially on public lands. BMBP has documented widespread overgrazing and trampling of sensitive areas such as streams and stream-side riparian areas in the Ochoco, Malheur, Umatilla, and Wallowa-Whitman National Forests. Livestock grazing damages the ecology, wildlife, and water quality. Wolves should not be killed in order to make room for ecologically destructive private ranching on public lands. Protections for wolves need to be significantly increased, and non-lethal deterrents should be required.

Even brief comments are important. If you love wolves, please speak up on their behalf!

Urge ODFW to carry forward the parts of the Wolf Plan that worked to reduce conflict and recover wolves. Non-lethal controls are effective and help to reduce conflict. They should be an integral part of the Wolf Plan, with clearly defined, enforceable, and meaningful requirements. Research shows that killing wolves is not an effective strategy for reducing livestock depredations (1), nor does it increase social acceptance of wolves (2).

The inherent ambiguity and uncertainty regarding “probable” depredations as discussed in the Wolf Plan make them inappropriate to consider as counting against wolves. In addition, Wildlife Services lacks transparency and public accountability, and so this agency should not be involved in investigations. Members of the public should not be deputized to kill wolves, as this increases opportunities for conflict and abuse, and may decrease social acceptance of wolves. Given the complexities of population dynamics, and that wolf populations are much smaller than those of deer and elk and that wolves are more vulnerable to extirpation, it is inappropriate to kill wolves in response to fluctuations in ungulate numbers. Wolf population caps are arbitrary and biologically indefensible, and should not be imposed on wolves.

Stronger protections are needed to ensure wolf recovery. Wolves are still too limited in numbers and in distribution to be considered “recovered”, or to maintain sustained populations. We are concerned that shrinking populations in neighboring states, combined with delisting in Oregon will not ensure sufficient genetic diversity or connectivity. Particularly in light of threats from poaching and other sources of mortality, our small wolf population continues to be in jeopardy of extinction.

Strong protections are needed to ensure public acceptance of wolves. In areas where killing wolves is legally acceptable, public support of wolves may decrease (2). State-sanctioned killing of wolves actually increases controversy and discontent about wolf presence. We are opposed to killing wolves, especially on public lands.

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 (3). In the draft management plan, the inherent ambiguity and uncertainty regarding “probable” depredations make them inappropriate to consider as counting against wolves. Wildlife Services lacks transparency and public accountability, and so should not be involved in investigations. Members of the public should not be deputized to kill wolves, as this increases opportunities for conflict and abuse, and may decrease social acceptance of wolves. Given the complexities of population dynamics, and that wolf populations are much smaller than those of deer and elk and that wolves are more vulnerable to extirpation, it is inappropriate to kill wolves in response to fluctuations in ungulate numbers. Wolf population caps are arbitrary and biologically indefensible, and should not be imposed on wolves.

We urge ODFW to include stronger conservation values in the Wolf Plan. We ask ODFW to place increased value on wolves for their important ecological roles. Wolves should not be killed for the benefit of private interests, especially on public lands. The State is responsible for protecting wolves in the public trust, for all Oregonians. Wolf conservation is important for all citizens, and should not treated as an issue limited to private or local business interests. We also ask the ODFW to refrain from using wolves as political bargaining chips to mediate political and economic conflicts. ODFW went forward with the recent delisting of wolves, despite overwhelming public outcry, and contrary to scientific opinion. We hope that ODFW acts in the listens to the public, and includes stronger protections for wolves in the revised plan.

Oregonians have been clear in their overwhelming support of wolves, and want strong protections in order to ensure wolf recovery. 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 (4, 5, 6). 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.

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 (7). Studies have also shown that the presence of wolves contributes to healthier soils (8), and may buffer the negative effects of climate change on ecosystems (9).

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 non-lethal 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. (10, 11, 12, 13) 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 (14).

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 (15).

The Wolf Plan must prioritize wolf conservation, as promised by ODFW and the commission.

Please speak up for wolves– let ODFW know that you support strong protections for wolves.

You can link to ODFW’s Wolf Management and Conservation Plan by clicking here.

Footnotes/references:

1. Treves, A.; Krofel, M.; McManus, J.; 2016. Predator control should not be a shot in the dark. Frontiers in Ecology and the Environment 14: 380-388.
2. Treves, A. 2009. Hunting for large carnivore conservation. Journal of Applied Ecology 46: 1350-1356.
3. 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
4. Defenders of Wildlife, 2013. Polls show strong support for wolf recovery in the Pacific Northwest. http://www.defenders.org/press-release/poll-shows-strong-support-wolf- recovery-pacific-northwest
5. Tulchin Research, 2013. RE: Polls show strong support for wolf recovery in Western States. http://www.defenders.org/sites/default/files/publications/defenders-of-wildlife- public-memo-new-poll-finds-strong-support-for-wolf-protection-in-western-states.pdf
6. Harris Interactive, 2011. Endangered Species Act summary- Poll for Endangered Species Act public support. http://www.defenders.org/publications/endangered_species_act_poll.pdf
7. Ripple, W.; Beschta, R.; 2011. Trophic Cascades in Yellowstone: the First 15 Years After Wolf Reintroduction. http://www.cof.orst.edu/leopold/papers/RippleBeschtaYellowstone_BioCon serv.pdf
8. 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.
9. Wilmers CC, Getz WM (2005) Gray Wolves as Climate Change Buffers in Yellowstone. PLoS Biol 3(4): e92. doi:10.1371/journal.pbio.0030092.
10. Defenders of Wildlife, 2014. Living with Wildlife: Coexisting with Wolves in Idaho’s Wood River Valley. http://www.defenders.org/living-wildlife/gray- wolves?_ga=1.220162841.1084860869.1412731542
11. Defenders of Wildlife, 2014. Wolves Among the
Sheep. http://www.defendersblog.org/2012/10/wolves-among-the-sheep/
12. City of Ketchum, Idaho. Recommendation To Adopt Resolution 14-022 in Support of Wildlife Co-Existence and Recognizing The Wood River Wolf
Project. http://ketchumidaho.org/DocumentCenter/View/2251
13. KTVB.com, Idaho News and Weather, 2014. Conservationists use non-lethal methods to deal with wolves. http://www.ktvb.com/story/local/2014/10/07/12686175/
14. Wielgus, R. and Peebles, K. 2014. Effects of Wolf Mortality on Livestock Depredations. PLoS ONE 9(12): e113505. doi:10.1371/journal.pone.
15. Treves, A., Naughton-Treves, L. & Shelley, V. 2013. Longitudinal analysis of attitudes toward wolves. Conserv. Biol. 27, 315-323.

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