The following comments on the Oregon Wolf Conservation Plan have been submitted to Oregon Department of Fish and Wildlife by the Oregon Cattleman’s Wolf Committee, Rod Childers, Committee Chair:

A List:

  1. That provides the tools and the latitude to aggressively mitigate livestock-wolf conflict.
  2. ODFW to remove problem wolves by whatever means necessary to eliminate any future conflicts with the same wolf (wolves).
  3. Need to eliminate the requirement that wolf kills must be on adjacent land to be counted toward the lethal control of the wolves.
  4. Change of the language that makes “preventative” and “non-lethal” different.
  5. Once a rancher begins dealing with wolves in a given situation his actions should be “counted” toward him having done non-lethal actions to move toward killing these wolves if they persist as a problem.
  6. Livestock producers must have the right to protect their livestock, which says “Not withstanding any provision of the wildlife laws a person may take a gray wolf at any time without a permit if the gray wolf is attacking, biting, chasing, or harassing a person, livestock working or sporting dogs, herding or guarding animals or family pets.”
  7. Communication with landowners needs improved in the plan.
  8. Delisting rules– Change the definition of where four breeding pairs must exist treats the state as a whole for purposes of delisting.
  9. That prevents the transplantation and relocation of wolves.
  10. Pets should be protected from predation the same as livestock. Most campers and or hikers have a pet with them; they should have the right to protect their animals also.
  11. Protection of your private property, family and pets near your home, including the area within 500 feet radius. Home occupant should be allowed to kill wolves entering this area.
  12. Develop rules that requires database and web site be kept current.
  13. All wolves captured or killed must be tested for Diseases (hydatid, neosporosis).
  14. All phases of economics of wolf management, including costs of management by the state should be reported once a year to the commission.
  15. The plan states that Wildlife Services will be the lead agency in livestock depredations. We believe this includes confirming livestock kills, W.S. has the expertise in this field and ODFW should make any changes in Rules that they wrote to recognize W.S. in this capacity. ODFW should be using their funds for management such as identifying, tracking and collaring wolves.

B List:

  1. That does fully and fairly compensates for depredation of livestock as defined in the draft paper written by Sharon Beck

C List:

  1. That declares that “significant suitable habitat exists by identifying through prior analysis how it meets the “suitable habitat” label when measured against the Conservation Plan’s guiding principles and identifying exactly where such habitat exists.
  2. That requires that if minimum numbers are used to fulfill the requirements for delisting (a “conserved” number) an accompanying maximum number will be adopted beyond which wolves will not be able to grow.
  3. Requires the plan to identify “no wolf zones” and “highly desirable wolf zones”.

Below are the recommended changes for the Oregon Wolf Plan submitted by the OCA Wolf Committee. The bullet points from the “A List” are highlighted in red. Following the “Bullet Points from A list” area are the pertinent parts of the Rule and or The Oregon Plan associated with those points. The excerpts from the Oregon Wolf Conservation and Management Plan and the Oregon Administrative Rules are italicized. The parts of the Plan/Rules that we would like to see changed are highlighted. Below the italicized part is our Comments about what we would like the rules to say and our justification for it.

Bullet Points from A List

  • 4. Change of the language that makes “preventative” and “non-lethal” different.
  • 5. Once a rancher begins dealing with wolves in a given situation his actions should be “counted” toward him having done non-lethal actions to move toward killing these wolves if they persist as a problem.

Rule 635-110-0010 Harassment and Take of Wolves during Phase I (Conservation)

(2) Non-injurious harassment.

(a) Subject to the conditions specified in paragraph (c), the following persons may use non-injurious harassment against wolves without a permit:

(A) landowners (or their agents) on their own land; or

(B) grazing permittees legally using public land under valid livestock grazing allotments.

(b) Non-injurious harassment means scaring off a wolf (or wolves) without doing bodily harm, and includes (but is not limited to) firing shots in the air, making loud noises or otherwise confronting the wolf (or wolves).

(3) Non-lethal injurious harassment.

(a) Subject to the conditions specified in paragraph (c), in addition to state or state authorized agents, the following persons may use non-lethal injurious harassment against wolves by permit:

Comment: We would like all of the “non-injurious” methods and definition put in the glossary of the Plan. The reason why is because the landowners were already practicing non-injurious and non-lethal injurious methods according to the plan. Some had went the extra mile to bury or move their bone piles so not to attract the wolves. When a depredation occurred, ODFW would not take any action beyond saying that they were moving to non-lethal actions because landowners were just doing “preventative” measures and the landowners needed to be doing non-injurious actions. When asked what actions were considered “non-injurious” many the actions mentioned were the same as what the landowners had been doing. Since preventative is not in the Plan or the Rules and there is some confusion as to what non-injurious entails, we would like to see it clarified better and some of the other methods, such as moving bone piles, included so it counts toward doing non-injurious actions.

In an area where wolves are located and ODFW has notified producers of the risk and producers are practicing non-lethal and non-lethal injurious measures on a regular basis, if 1 depredation occurs a caught-in-the-act permit, including chasing and harassing, should immediately be issued to the producer to eliminate the problem wolf or wolves.

If this cannot be done by revisions to the wolf management plan and administrative rules without going through a legislative process, then ODFW should move toward lethal take of the wolf and authorize Wildlife Services to remove the wolf or wolves.

Bullet Points from A List

  • 9. That prevents the transplantation and relocation of wolves.

Rule 635-110-0010 Harassment and Take of Wolves during Phase I (Conservation)……

(4) Relocation. ODFW will authorize relocation by state personnel when a wolf (or wolves) becomes inadvertently involved in a situation, or is present in an area, that could result in conflict with humans or harm to the wolf. The relocation will be designed to prevent conflict with humans or reduce the possibility of harm to the wolf. The wolf (or wolves) would be relocated to the nearest wilderness area at the direction of ODFW.

The Oregon Plan
Translocation’s primary intent is to help meet conservation objectives in both halves of the state. It may be used only in areas where dispersing wolves is determined to be essential to achieve conservation objectives. Translocation may be used only following a public process, involving public meetings, public testimony and approval by the Commission. Relocation differs from translocation in that relocation does not require a public process and is not used to facilitate dispersal. (pg 24-25)

Comment: We would like to see the relocation and translocation taken out. In Wallowa County, relocating them to the nearest wilderness area, or other areas, does not move them out of human’s way. In Wallowa and Baker counties, the wolves have been found to be in the wilderness area frequently, but they have been coming back to the private lands and adjacent public lands. So moving them to the nearest wilderness area does not work. Wolves also have their territorial areas and will most likely return to where they were. After packing 8 of the 9 dead calves into the cooler for later inspections, I would not wish these things on anybody. This comment also applies to the same wording under Phase II (Management) and Phase III.

Bullet Points from A List

  • 1. That provides the tools and the latitude to aggressively mitigate livestock-wolf conflict.
  • 2. ODFW to remove problem wolves by whatever means necessary to eliminate any future conflicts with the same wolf (wolves).
  • 6. Livestock producers must have the right to protect their livestock, which says “Not withstanding any provision of the wildlife laws a person may take a gray wolf at any time without a permit if the gray wolf is attacking, biting, chasing, or harassing a person, livestock working or sporting dogs, herding or guarding animals or family pets.”

Rule 635-110-0010 Harassment and Take of Wolves during Phase I (Conservation)……

(5) Lethal take of wolves in the act of attacking livestock.

(a) Subject to the conditions specified in paragraph (c) and with a permit from ODFW, the following persons may use lethal force against wolves in the act of attacking livestock:

(A) landowners (or their agents) on their own land; or

(B) grazing permittees using public land.

(b) A wolf is “in the act of attacking livestock” if it is biting, wounding or killing livestock.

Comment: We would like to add chasing and harassing along with attacking livestock. We would like this added in areas of the Plan and the Rules where it states “in the act of attacking livestock.”

Note: The definition of “livestock” in the Rules and the Plan includes ratites, psittacine, horses, jackasses, cattle, llamas, alpacas, sheep, goats, swine, domesticated fowl, any fur-bearing animal bred and maintained (commercially or otherwise) within pens, cages and hutches, bison and working dogs (herding and guarding).

Bullet Points from A List

  • 10. The definition of livestock does not include domestic dogs that are not working dogs, so a landowner, hiker, recreationist with a domestic dog would not be allowed to take lethal measures to protect his/her pet if attacked by a wolf.
  • 11. We would like to see Protection of your private property, family and pets near our homes, including the area within 500 feet radius. Home occupant should be allowed to kill wolves without a permit within this area.

Rule 635-110-0010 Harassment and Take of Wolves during Phase I (Conservation)……

(c) Lethal force is allowed by permit from ODFW only if:

(A) ODFW confirms that wolves previously have wounded or killed livestock in the area and efforts to resolve the problem have been deemed ineffective;

(B) The wolf is seen in the act of attacking, not testing or scavenging;

(C) There is fresh evidence of the attack (e.g., visible wounds, tracks demonstrating a chase occurred);

(D) The wolf carcass is not removed or disturbed;

(E) the use of lethal force is reported to ODFW or Wildlife Services within 24 hours;

(F) No unreasonable circumstances exist that attract wolf/livestock conflict; and

(G) either ODFW or Wildlife Services confirms that the wound was caused by a wolf (or wolves).

Note: the Oregon Wolf Conservation and Management Plan calls for allowing lethal take of wolves in this situation without a permit on private land. However, the Plan recognizes that because current statute requires a permit, implementing this portion of the Plan depends upon amendment of the statute by the legislature.

Comment: It would be good to be able to lethally take a wolf at this point without a permit but the way this as been explained to me, whether on public or private you still have to have suffered depredation to take a wolf. The permit itself is constrictive in that it goes to the landowner, not the owner of the livestock, and the landowner is liable for himself and whoever is listed as an agent. In many instances the livestock producer is renting the ground the livestock are on. The owner of the livestock should hold the permit and liability since he/she is the one that would incur the loss in a wolf depredation. The written authorization from ODFW is a better way to go, because there could be too many miss-interpretations in a verbal authorization.

Bullet Points from A List

  • 3. Need to eliminate the requirement that wolf kills must be on adjacent land to be counted toward the lethal control of the wolves.

Rule 635-110-0010 Harassment and Take of Wolves during Phase I (Conservation)……

(6) Lethal take to deal with chronic depredation.

(a) ODFW may authorize its personnel, authorized agents, or Wildlife Services, to use lethal force on wolves anywhere at a property owner or permittee’s request if:

(A) ODFW confirms that the property or an adjacent property has had either:

(i) two confirmed depredations by wolves on livestock; or

(ii) one confirmed depredation followed by up to three attempted depredations (testing

or stalking);

Comment: Need to eliminate the word adjacent. Wolves can travel up to 20 to 30 miles in a day which, more often than not, puts them on several different properties. Also a producer may have 2 depredations, but if there is another ownership between the two sites of the incident, then it does not count toward the control of the wolves. In Wallowa County there were 3 confirmed wolf depredations, but they were not on adjacent land and so it did not count toward the legal taking of a wolf by the designated entity. It took more calves to be killed before there were two on adjacent land.

Bullet Points from A List

  • 7. Communication with landowners needs improved in the plan.

Comment: Landowners have not been notified, in a timely manner, about wolves. (Some landowners, where the wolves were known to be, were not contacted. One landowner was not told the depredation he had was confirmed by ODFW. He heard it from another local rancher who read ODFW’s press release.

Bullet Points from A List

  • 8. Delisting rules– Change the definition of where four breeding pairs must exist treats the state as a whole for purposes of delisting.

Comment: The range of these wolves is so much larger than anyone anticipated and with all of the sightings that are on the west side of the state, if these become verified they need to be counted towards the delisting.

Bullet Points from A List

  • 12. Develop rules that requires database and web site be kept current

Comment: All but the press releases on the wolf activity in Wallowa County is outdated on the ODFW website. For example, the last monthly wolf report was November 2009. There should also be a map of the areas the wolves are located.

Bullet Points from A List

  • 13. All wolves captured or killed must be tested for Diseases (hydatid, neosporosis)

Bullet Points from A List

  • 14. All phases of economics of wolf management, including costs of management by the state should be reported once a year to the commission.

Comment: This should also include any federal agencies dollars spent on wolves in Oregon.

Bullet Points from A List

  • 15. Wildlife Services should be the agency responsible for confirming dead livestock.

Comment: The plan states that Wildlife Services will be the lead agency in livestock depredations. We believe this includes confirming livestock kills, W.S. has the expertise in this field and ODFW should make any changes in Rules that they wrote to recognize W.S. in this capacity. ODFW should be using their funds for management such as identifying, tracking and collaring wolves.