Oregon Department of Fish and Wildlife Commission

Wolf Management Plan Committee

RE: COMMENTS ON THE WOLF MANAGEMENT PLAN

Dear Commissioners,

Thank you for the opportunity to comment on your proposed wolf management plan. I will address several disturbing issues regarding the plan.

ORS.498.012 mandates that ODF&W "..manage to prevent serious depletion of any indigenous species.." The forced experimental introduction of Canadian wolves into Montana, Idaho, and Wyoming has amply demonstrated the serious depletion of moose, elk, deer, antelope, and big horn sheep, as well as domestic ungulates, directly caused in those states by the introduced wolves. No evidence exists that the Canadian Wolf was ever indigenous to Oregon. Only a fool could conclude that similar results will not occur in our state. The implementation of the Commission’s proposed wolf management plan will clearly violate the expressed purpose of ORS 498.012.

State law dictates very specific provisions for how the Commission is to approach management of an endangered or threatened species in Oregon. The proposed wolf management plan significantly departs from that mandate. ORS 496.172(3) and ORS 496.182(8)(a) unambiguously state that when a species is listed as endangered the Commission is required to work with state land owning agencies to determine whether they can take any actions that would conserve the species. Under these statutes the state landowning agencies, not the ODF&W, are required to analyze the needs of the species and to create a conservation plan for the species on their land. They are required by law to balance those needs with the economic impacts of conservation, the statutory use of the agency’s lands, and the role of other people and agencies. This balance must be achieved in the land owning agency’s plan before they implement a plan that can help conserve the species on their land. The agency’s duty to even create a conservation management plan is limited by their decision whether they can help the conservation effort within the statutory mandated balance of use, economics, and effects on other people and agencies. Notwithstanding ORS 496.138(1) and (2) the Commission’s proposed plan appears to usurp this authority and go well beyond what is required, or authorized, in Oregon statute.

ORS 496.192(1) clearly states that private land owners are not required to take actions to protect threatened or endangered species or to restrict the use of their lands to conserve the species. ORS 496.192 (2) speaks to other statutes that may authorize the protection of wildlife species such as ORS 498.012 which requires management to prevent the serious depletion of any indigenous species. The Canadian Wolf was never indigenous to Oregon and its allowed colonization in Oregon will certainly cause serious depletion of indigenous ungulates. The Commission’s proposed wolf management plan appears to directly restrict or require certain acts on private lands that are clearly forbidden in statute. Not least, the adopted plan would criminalize the protection of domestic livestock and pets from these vicious predators thereby severely restricting the use of private lands.

In view of the recent fatal Canadian wolf attack on an adult man in Canada, the Commission must reevaluate how their proposed wolf management plan comports with the protection of the health, safety, and welfare of the human population in Oregon. The 1843 gathering of Oregon Territory settlers in Oregon City was for a single purpose. That purpose was to mitigate the severe health, safety, and welfare effects of the wolf species then indigenous to the Territory. When we compare the human population and concentration per square mile in the Oregon Territory then with the 3.6 million people now residing in Oregon, the insanity of a plan to manage the colonization of this non-indigenous species is highlighted.

Finally, the Commission’s response to public comment should be revaluated. The content of the comments should be closely evaluated and incorporated into the plan where appropriate. The number of the comments is irrelevant to the Commission. The Commission is not exercising a political mandate but rather a utilitarian function. The adopted plan must represent a carefully crafted scientifically and legally sound document rather than a ballot on positive or negative comments.

I strongly urge the Commission not to adopt the wolf management plan as currently written because it is neither legally sound nor scientifically appropriate and because it places the health safety, and welfare of Oregon citizens in harms way.

Respectfully submitted,

Senator Doug Whitsett