Saturday, June 01, 2019

Comments on Oregon's Draft Wolf Plan

Oregon's plan for managing growing wolf (Canis lupus) populations is in its draft stage.  Consideration for adoption by the Fish & Wildlife Commission is scheduled for June 6th and 7th. US Person wishes to direct the Commissions attenuation to page 31 et seq of the Draft Plan in which the department intends to include limited hunting as a means of controlling wolf populations. The provision should be eliminated as necessary and contrary to the goal of allowing the nearly extirpated wolf to regain its former place in Nature within the boundaries of the state.

There are a lot of cows and sheep in Oregon. The Plan states there are over 1.2 million cattle and over 200,000 sheep in the state. About two thirds of cattle in eastern Oregon spend some time during the year grazing on public lands. The US Forest Service permitted grazing for 91,341 cattle and the BLM permitted 151,877 cattle in 2016. Despite this huge number of livestock dependent on subsidized public grazing, wolves kill relatively few cattle. Predation* on livestock is not ingrained in wolves; it is a learned behavior usually governed by the lack of prey, proximity of human settlement, and husbandry practices. Coyotes kill more cows than wolves do; according to 2011 statistics by the US Agriculture Department 63% of cattle losses were caused by coyotes. Wolf kills in Oregon show an upward trend over the last ten years, (chart p.34) but the crucial fact is that the increase has been less than the increase in minimum wolf counts. For the period 2009-28 there were only 193 confirmed losses of livestock due to wolf predation. Livestock owners who suffer losses due to wolf predation are eligible for state funded compensation. In 2017, a total of 10 participating counties were awarded $252,570 in 23 grant funds.

Given that the problem of wolf predation on livestock is not a "crisis" problem as some livestock owners with a grudge would have wildlife managers think, attention should be directed to managing wolf populations with the least amount of lethal intervention needed for effective population control. The Plan, by including public hunting as a means of wolf control, does not strike the correct balance. The Plan admits that lethal removal of offending wolves does not always solve problem predation. In Oregon, authorized lethal removal has occurred in six situation involving wolves. In two of those, subsequent kills occurred by the same pack after culling. After killing the entire Imnaha pack, predation began again less than four months later by new wolf occupants of the territory. (p.42) Non lethal methods, relatively inexpensive to deploy, such as fladry can be just as effective in deterring livestock predation over short term periods. Trapping, also allowed under the Plan is inhumane and should never be used a management tool.

In the Plan, general season hunts by the public are prohibited. (p.31) A good thing, but the prohibition does not go far enough. In the next subparagraph the Plan says the public may participate in "controlled takes" (culling) to assist ODWF conservation efforts in two circumstances: 1) in the instance of long-term recurring predation of livestock, and 2) the protection of desired human game animals which also happen to be the wolf's natural food source. This provision puts unwanted pressure on the agency to submit wolf predation problems to the public hunting community that views the wolf not as valuable predator species necessary to ecological balance, but as a trophy, or worse a varmint.  It is this illogical and counterproductive culturally bias thinking that needs to be removed from wolf management decisions. Such decisions also must be insulated from any revenue or budget considerations related to tag sales and licensing.

In order to achieve this, the Commission must put emphasis on the required use of non-lethal deterrence by livestock owners. Currently the Plan does not make such use mandatory (p.45). No culling should be allowed unless an agriculturalist has first attempted deployment of non-lethal deterrence before lethal removal is undertaking by ODWF. (pp.49-51) In addition, a livestock owner should not be permitted to take, or ODWF permitted to take a grey wolf until three prey incidents with 9 months are confirmed by authorities to be reasonably considered "chronic" livestock predation.

*The widely used term "depredation" is not used here since it is tainted by an implied moral judgment, as in "depraved" behavior by humans. Wolves hunt and kill to survive, only the human species kills for entertainment.  Predation is a normal biological function, not a immoral activity.