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Commissioners:
My name is Sharon Beck.
Now that the advisory committee part of the process has ended I believe I have said or written almost everything possible, in every way possible, to help my constituents understand what the plan actually says and to give you the opportunity to see what the plan says from our frame of reference.
There were real differences of opinion among staff and committee. The latter is of no concern now; but the former will, I believe, prove very troublesome for a long time to come unless someone more skilled than I is able to convince the authors of the wolf plan that there are flaws that render the plan impractical, maybe impossible, to implement. I believe that words mean things and their addition or omission are and should be very intentional. I believe they should be specific, clear and used with economy. The authors of the plan do not agree with me.
I came today because even though my minority opinion adequately justifies lack of support for the plan I have yet to comment on the proposed administrative rules.
Since the rules will have the force of law and because their premature adoption would have the effect of making law rather than implementing laws passed by the legislature; because of conflicts and confusion within the plan; because of its bias and verbosity it is our opinion that the document entitled “Oregon Wolf Conservation and Management Plan” should most definitely not be incorporated as administrative rule. (635-110-0000)
Generally the proposed rules overreach the authority of state government to encumber our rights in property and the use of our land.
Specifically, the Commission may authorize harassment of wildlife and if the intent is to make wolves more tolerated and potentially to save individuals, you should do so liberally. Permittees on federal grazing land allotments or their agents should be included in the harassment rule, without a permit, if the wolf is not welcome in the proximity of their livestock. All conditions must be removed including reporting.
(3) Non-lethal injurious harassment (c) remove conditions (A) and (C) because ODFW will find it impossible to confirm all the sites of persistent wolf activity or depredation. Give a permit when it’s requested and request reports. To think that someone trying to get wolves out of their livestock will check for den sites before harassing them is absurd.
(d) State law waives the need for a permit when one is already required by the federal ESA…this fact needs to be reconciled and clarified in the rules.
(4) Relocation should NOT be an option unless and until “secure habit”, is identified through a public process.
(5) In light of the 10j rule changes allowing Montana and Idaho ranchers to kill wolves attacking or threatening to attack their domestic animals without first obtaining a permit it seems clear that ODFW should not lock its rules in to be less permissive than federal rules in order to be able to take advantage of more adaptive approaches should the opportunity arise.
Oregon’s rules should say that lethal take of a wolf in the act of attacking, or threatening to attack a person or a person’s property should be allowed outright any time, anywhere without conditions and in any phase of wolf recovery or conservation.
The necessary changes in the wildlife laws would be to add “wolves” to cougar and bear in ORS 498.166 so that is says “a person may take a cougar, bear or wolf that poses a threat to human safety.
Other wildlife laws would not need amending but rather an acknowledgement that they are not subordinate to endangered species laws.
In the cases of chronic depredation ODFW must be authorized to use any strategy to lethally remove wolves from private property at the owner’s request. No conditions, no documentation, no confirmations, no matter what “phase” of recovery/conservation the plan is in.
We find unacceptable any restrictions on our ability to protect persons or our animals from an impending attack by wolves. Further, any requirements of documentation of past wolf activity or non-lethal means of prevention will be equally unacceptable. Such requirements or restrictions will not prevent ranchers from taking such actions but will discourage reporting them.
I appreciate your tolerance of me as much as my constituents appreciate my persistence in the wolf issue.
Sharon Beck
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