September 10, David E. Williams State Director USDA APHIS Wildlife Services 6135 NE 80th Ave., Ste. A-8 Portland, OR 97218

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1 September 10, 2012 David E. Williams State Director USDA APHIS Wildlife Services 6135 NE 80th Ave., Ste. A-8 Portland, OR Dear Director Williams: Thank you for the opportunity to comment on the Pre-decision Environmental Assessment (EA) for Wildlife Services Gray Wolf Damage Management in Oregon dated July Defenders of Wildlife (Defenders) is a national non-profit conservation organization with more than one million members and supporters nationwide, of which 8600 reside in Oregon. Defenders is a science-based advocacy organization focused on conserving and restoring native species and the habitat upon which they depend. We have been involved in such efforts since our establishment in Over the last three decades, Defenders has played a leading role in the recovery of wolves in the Northern Rockies, including the administration of The Wolf Compensation Trust from 1987 through 2011, which reimbursed more than $1,400,000 to ranchers in the region including Oregon for livestock losses due to wolves. In 2010, the federal government assumed responsibility for paying compensation for livestock losses due to wolf predation, making continuation of our Trust no longer necessary. Today, Defenders administers The Wolf Coexistence Partnership, which assists Oregon family ranchers and farmers in the use of nonlethal, preventative methods that help reduce or prevent livestock losses to wolves. These methods include sharing the cost of range riders, livestock guarding dogs, predator deterrent fencing, alternative grazing, and more. Across the region, we operate these projects in partnership with county, state, tribal and federal agencies, including the USDA National Wildlife Research Center in Ft. Collins, Colorado. Defenders helped develop Oregon s 2005 wolf management plan and provides assistance to landowners for proactive efforts to protect livestock from wolves. In 2011, the State of Oregon passed HB 3560, The Livestock Compensation and Wolf Co-Existence Act, which is considered an historic agreement between livestock growers, rural communities, and wildlife conservationists including the Oregon Cattlemen s Association, Oregon Farm Bureau, Defenders of Wildlife, Hells Canyon Preservation Council, state and local agencies, and the Legislature. As Governor Kitzhaber notes, The Livestock Compensation and Wolf Co-Existence Act is the first of its kind in the United States. It establishes precedents that go beyond what other states have done related to livestock compensation by authorizing local, county-led programs to address compensation for and deterrence of livestock losses, guaranteeing funding for nonlethal techniques to deter wolves from killing livestock, and conditioning compensation in areas of known wolf activity on attempts to use wolf deterrence techniques. The Act also intentionally brings together the Oregon Department of Agriculture (ODA), which handles agricultural matters, such as livestock, together with the Oregon Department of Fish and Wildlife (ODFW), which has jurisdiction over wildlife management. ODA

2 will manage the distribution of funds to counties while ODFW will determine whether a livestock kill was caused by wolves or other factors. We appreciate the opportunity to comment on the pre-decision EA (DEA). In summary, our concerns are: 1) WS has not been actively involved in nonlethal measures to reduce livestock losses in Oregon. We support this DEA proposed action for Oregon WS to become more engaged in nonlethal wolf management efforts. However, our support is based on the understanding that WS will need to provide more training, different resources, and possibly more experienced personnel to accomplish this goal; 2) Lethal control measures alone are ineffective over the long term and should only be used as a last resort to temporarily address livestock and wolf conflicts; 3) The Oregon WS program has significant and ongoing problems with misidentifying unrelated causes of death or injury as wolf predation (see examples below). This inaccuracy in determining actual cause of death has led to a substantial lack of confidence in the Oregon WS program and immediate actions should be taken to rectify this serious problem; 4) Until the significant problems with WS investigation procedures are fully addressed, we are supporting Alternative Two, which restricts the agency to implementation of only nonlethal control methods. Purpose and Need for Action The United States Department of Agriculture (USDA), Animal and Plant Health Inspection Service (APHIS), Oregon Wildlife Services (WS) program has released an environmental assessment (EA), which evaluates a proposed action and alternatives to assist the State of Oregon, Department of Fish and Wildlife (ODFW) and Native American tribal governments with management of gray wolf (Canis lupus) conflicts throughout the state. WS claims that the basis of the EA s proposed actions is to protect livestock in portions of the state where the gray wolf population is managed by ODFW and by the Confederated Tribes of the Umatilla Indian Reservation (CTUIR). The EA lists the need for action based on confirmed and chronic livestock depredation, and although less likely, the potential for wolves to threaten human safety. As an initial matter, the purpose and need statement does not adequately explain or justify WS involvement. ODFW appears capable of implementing the Oregon Wolf Plan without the assistance of WS, and WS and not adequately explained in this EA how WS involvement would further that plan or the conservation of wolves in Oregon. Moreover, the proposed need for action does not even include the need to conserve and promote wolf restoration in Oregon in the Need for Action and, at a minimum, we feel that objective should be included. We appreciate that WS has determined that Any actions undertaken on behalf of ODFW must conform with ODFW s conservation and management objectives and goals as defined in detail in OAR (Appendix A) and OWCMP (ODFW 2010a, Section II). We are also very pleased to see that Oregon WS is open and willing to assist ODFW in providing advice, information, and 2

3 direct assistance to livestock producers with nonlethal methods that can be used to aid in wolf conflict prevention Managing wolf-livestock conflicts in a way that minimizes livestock losses can reduce livestock conflict and sustain the state s wolf population. Some of the most effective methods include: assisted removal of dead or dying livestock, increased human supervision of livestock when possible, using livestock guarding dogs during certain times of the year, installing different types of fencing and lighting and using a variety of scare devices. The effectiveness of these deterrents is highly dependent on a number of factors, including type, number, and age of livestock, grazing and pasture conditions, and season (Stone et al. 2009). These different factors underscore the need for agency involvement in the training and implementations of these methods. We encourage WS to provide information and training, and when appropriate, to also hire wolf specialists whose duties would include providing technical assistance to livestock operators to implement the methods and to supply or loan equipment like fladry, turbofladry, lighting sensors, alarm systems, monitoring devices, and other practical tools to ranchers, prioritizing those in high priority wolf conservation areas. These specialists should also work with other wolf managers and researchers to determine which methods are most effective in reducing livestock losses to wolves as this information is vitally important for national and international wolf conservation programs. For more information regarding these methods, please see: Additionally, Defenders staff are available to assist WS with these efforts. We have found that nonlethal measures are most effective in reducing livestock and wolf losses to minimal levels when there is good cooperation and communication among agency partners, adequate tools and deterrents to address specific situations, a willingness to try alternative methods, and good planning to avoid exposing wolves too frequently to any one deterrent so often that wolves become habituated to it. WS has an excellent resource in the National Wildlife Research Center and their science team who are exploring and developing new nonlethal tools and methods to effectively reduce livestock losses to native predators. However, while we would welcome Oregon WS s interest in assisting livestock owners with nonlethal measures, we have not found evidence that the program has yet assisted ODFW in the past with nonlethal deterrents. That leads to our concern that WS may not be serious about promoting these nonlethal aspects of wolf management and would fall back to the traditional and nearly exclusive pursuit of lethal control once the EA is approved. We hope very much that this is not the case. Lethal Control Issues Under the preferred alternative identified in the DEA, Oregon WS is seeking to regain authority to kill wolves in relation to livestock conflicts. Lethal control methods are expensive (e.g. requiring significant resources including helicopters, airplanes, vehicles, and other resources), they can be dangerous for personnel, and they are only a temporary solution to the loss of livestock. Unless preventative strategies are addressed, new wolves moving into the now vacant habitat are likely to prey on livestock in less than a year after the former pack was killed (Bradley and Pletscher 2005). While wolves account for less than 1% of livestock losses in areas where wolves and livestock share the land (Bangs, et al. 2009), the controversy over these losses is often played out in the political arenas and media outlets. 3

4 If lethal control measures were effective there would not continually be livestock depredations in the same areas. Simply removing or killing wild predators frequently results in their being replaced by outlying predators and a cycle of lethal control and livestock losses without ever attempting to address or prevent these conflicts in a nonlethal manner. We are not against all lethal control nor are nonlethal methods a replacement for lethal control in absolutely all circumstances. However, nonlethal deterrents have proven to be effective in most situations and lethal control should only be implemented as a last resort especially on public lands such as national forests. Addressing WS Investigation Protocol Problems The DEA notes (page 7) that: ODFW requires a standard of conclusive evidence before wolf-caused livestock depredations are confirmed (ODFW 2010b). In some cases, wolves may have been responsible for the death of a rancher s livestock, but there was insufficient evidence remaining to confirm wolf predation. In other cases, those portions of the livestock carcass that might have contained the evidence of predation may already have been consumed, carried off, or decomposed. Some of these incidents might be classified as probable predation, depending on other evidence that might still remain. But in many cases, there may be little or no conclusive evidence of predation, other than the fact that wolves are known to be in the area and some livestock have seemingly just disappeared. While this is true, livestock have disappeared from the range for known and undetermined causes long before wolves were in the region. For example, ranchers have reported losses of more than 1,000 cattle from rustling over a three year period in Malheur County alone with hundreds more reported in neighboring counties ( Since the return of wolves to the state, the Oregon WS program has been plagued with severe problems that have undermined the agency s credibility in conducting depredation investigations related to wolves. These problems include public disagreements with ODFW findings in livestock losses attributed mistakenly to wolves, defying ODFW requests for conducting joint depredation investigations, and stirring up public sentiment against wolves in Wallowa County. These problems, in part, led to the need for legislation passed in 2011 that ensured ODFW s lead authority in livestock depredation investigations related to wolves. Some of these problems are apparent in the investigation reports of livestock injuries and mortalities. In each disputed case, the WS agent confirms the livestock losses as wolf caused despite a clear lack of evidence as identified by ODFW s co-investigation. Not only does WS s field investigator disagree with the findings of ODFW but his counter opinion becomes part of a public dispute with ODFW through the local Oregon Cattle Association representatives, ranchers and local sheriff. Two of the seven calves found in May, one on the Schaafsmas Tucker Down Road ranch outside of Joseph and one owned by Kirk Makin found on the Zumwalt Prairie, were confirmed wolf kills by USDA Wildlife Services, but not by the Oregon Department of Fish and Wildlife. ( 4

5 In the investigation report dated May 16, 2010, the ODFW report states He [the WS investigator] already had made judgment that the calf had been killed by a wolf. He stated that he based it on bite marks found on the carcass along with tracks and scat collected at the site of the dead calf. From the WS field report signed However, ODFW found that the calf had been dead much longer than the WS field investigator estimate of hours and that there were no bite wounds, no visible trauma, no signs of hemorrhaging nor any signs of struggle to imply predation of any kind contrary to the WS report. ODFW determined that this mortality was unrelated to wolf predation (ODFW May 16, 2010 investigation report). Other Examples May 27, 2011: WS Report This incident involved a 225 calf that WS confirmed as a wolf depredation. The cattle owner brought the head, spine and pelvic of an approximately 225 lb calf into the ODFW office in Enterprise. The WS field investigator noted that the remains showed Typical wolf feeding pattern and trama [sic] on nose bridge and that the area where the calf was found has a history of high wolf activity. Conversely, ODFW s report states that After the examination, ODFW drove to the area to investigate the location where the calf had been found. However, on 5/29 ODFW learned that the area examined was incorrect. On 5/30 ODFW visited the correct area where the dead calf was originally found. The area where the dead calf was found was searched for approximately two hours on 5/30 and only coyote tracks and scat was detected. Very little of the carcass remained -- only the head (with muscle tissues gone), spine, and partial ribs were present. All muscles had been consumed on the remaining skeleton. Clear evidence of feeding by coyotes was observed (tooth marks on ribs). No evidence of pre-mortem trauma or hemorrhage was observed. A slight pink mark was observed on the forehead hide (diffuse non point), but with no corresponding mark on skin tissue. This did not appear to be a bite of any kind. There was some sign of respiratory illness (inflamed nasal passages with mucous) in the calf but it is unknown if the calf was sick or had been severely stressed or run. No bites or feeding could be identified as wolf. ODFW concluded that the calf death could not be confirmed as wolf related. June 12, 2011: WS Report The WS field investigator identifies three adult cattle injuries as confirmed wolf depredations. His report states The bite marks are typicl [sic] wolf bite marks in typical wolf attack sites but provides no greater details. If this report was the only investigation into the incident, wolves would have likely been killed in response. 5

6 However, ODFW did a much more thorough investigation and disagreed with WS findings. The state notes: There is no physical evidence confirming that a predator caused the injuries to the cows. There are scratches, abrasions, and rashes on cows #1, 2 and 3 that cannot be attributed to bite wounds. There is serious damage to cow #1 s udder. On the lower part of the udder there is a puncture, an abrasion and 2 thin cuts. The puncture is from an unknown cause, there are no other marks on udder to confirm that it is a toothmark There are many small scratches on the cows, particularly on cow #1. The scratches are 1mm across and vary from ½ - 6 inches long. The scratches are on the surface of the skin and do not go through the dermis layer of the skin. None of these scratches have swelling, or subdermal hematomas under them. The scratches go in many directions; some are straight, some are curved. The majority of the scratches are generally lengthwise with the body. None of the scratches match up to be pairs going the same direction a set distance apart such as would canine teeth marks. The scratches are on the top of hip, side of hindquarters, side of neck. Down low on the left side of the udder is a 3x3 inch minor abrasion, within the abrasion are 2 minor narrow cuts by something very sharp (such as a wire barb) that starts shallow and ends deeper. Again the state determined that the injuries are unrelated to wolf predation and appear instead to be common barbed wire injuries that cattle routinely sustain (see photo below). 6

7 June 15, 2011: WS Report Wildlife Services field investigator determined a cow with severely broken back leg had been attacked by a wolf. Here s the excerpt from his report: The cow was alive when found + had to distroyed [sic]. 4 5 yr old cow with calf at side + calf inside... The leg appears to have been broken in the attack or struggle. One wolf scat present at site. Puncture marks on rear legs with trama [sic]. Several tooth scrapes measuring inches in width. Typical wolf attack sites. The area has a high wolf activity and in the wolf travel area. 7

8 However, according to the ODFW report, there was no sign of a struggle in the area and the WS field investigator misidentified coyote scat for wolf scat a basic but important part of the investigation. The ODFW report, which was far more thorough, states: A search of the immediate area around the dead cow revealed no wolf tracks (tracking conditions were fair with several exposed dirt patches). Because the scat in question was identified as wolf by WS, ODFW sent the sample to the University of Idaho lab which reported that both of the scat samples analyzed were identified as coyote. ODFW also noted that The cow carcass was skinned and no bite marks were observed anywhere on the animal. Some marks were observed on a hind leg but it was determined they were not bites and there was no corresponding hemorrhage or trauma associated with the marks. The hind leg break was severe and the associated trauma was visible into the abdomen of the cow. There was also a severe large bruise on the front right shoulder with no point source injury. This appeared to be related to the initial fall and broken leg. A deep hole was found upslope of the cow with a hoof print in it and this may have been the cause of the broken leg. ODFW questions why (if chased by wolves) there were no wolf bites before, and especially after the cow was incapacitated. ODFW disagrees with WS s findings and concludes instead that the calf death could not be confirmed as wolf related. June 15, 2011: WS Report The WS investigator reports signs of struggle at the site. No tracks found due to grassy area + cattle tracking up the site. He notes Teeth marks in both hind legs with trama [sic] underneath. Teeth marks on the skin up the back, nose, + brisket. Typical wolf feeding pattern. The area has a high wolf activity. Jaw was broken. This damage was not caused by coyotes, lions or bears. ODFW s report tells a vastly different story that identifies no relationship to wolf feeding or predation: The calf carcass had been partially consumed but had a significant amount of muscle tissue (with hide) remaining for examination. No wolf bite marks were found on the carcass. There were some small marks and blemishes on hind-end hide, but with no corresponding trauma on muscle or underside of hide. One long scratch (approx 6 long) on hind end with no corresponding 8

9 hemorrhage on underside of hide. This is likely a talon scratch (from scavenging birds). Feeding pattern appears to be from scavenging, primarily from coyotes (which were present as we examined the carcass). Lower jaw bone is broken, but no bite marks on head or neck. One scuff mark on chin is likely related to the broken jaw but it is unknown if the jaw was broken pre or post-mortem. Again, ODFW disagrees with WS findings and concludes instead that the calf death could not be confirmed as wolf related. It appears that during periods of conflict, as many as half of the depredation reports in this area that were co-investigated result in similar disputes to these and that these problems are still ongoing. From August 5, 2012 ODFW field report: The carcass scene had been modified by other investigators prior to ODFW arrival and the carcass of the calf was reported to have been in the water of the pond. The calf was estimated to be dead 1-2 days and was partially consumed. It also had been partially skinned by other investigators prior to ODFW arrival. No evidence of a chase or struggle was observed. All bite marks observed on the bones were consistent with coyote teeth. The only sign of injury observed were two minor hematomas on the lateral side of the left front leg in the area of the knee. One was associated with a small scrape on the hair side of the hide. Other scratches on the same leg were not associated with hematoma on the inner side of hide and were considered to have occurred post-mortem. While it is possible that other injuries occurred on areas consumed, the head, neck, back, and other three lower legs showed no sign of predation. The only tracks found in the area were from coyote, cattle, and humans. Despite this, the WS field investigator confirmed this mortality as a wolf depredation. These ongoing problems with the Oregon WS program have reached the attention of the governor s office and have led to several meetings to attempt to resolve these issues between state and federal agencies. In response, the state has adopted regulations that clearly identify ODFW as the primary authority for wolf depredation investigations. Unfortunately, this does not completely amend the damage that these disputes with WS have created between and among stakeholder groups or in undermining the conservation of wolves in an area of the state that is crucial dispersal habitat for the species. This problem within the Oregon WS program should be addressed quickly and fully before any more damage is done. Other Issues of Concern On page 7, the DEA summarizes the 2003 Oakleaf study as for every calf found and confirmed to have been killed by wolves, there were as many as 8 other calves killed by wolves but not found by the producer. This statement generalizes the findings of this study as if it were applicable across most livestock operations, which is inaccurate. We are familiar with this study because Defenders of Wildlife helped to sponsor it. The study actually portrayed a worst case scenario, as acknowledged by the researcher, in order to determine the highest normal level of undetected loss of livestock. The study was conducted in a remote, heavily wooded national forest where young cattle ranged unprotected for months with a wolf pack that had a known history of chronic livestock predation. Even under these conditions of almost constant predation harassment, the researcher found no evidence of weight loss associated with the livestock and he detected a higher loss of cattle due to pneumonia than to wolf predation, which the rancher had not detected in his herd (Oakleaf et al. 2003). 9

10 Again, on page 7, the DEA notes that wolves typically kill one cattle per predation incident but average 14 sheep per predation incident (Muhly and Musiani 2009). It should also note that this is common among sheep losses to all large predators including domestic dogs. In occupied parts of their range, wolves kill far fewer sheep than coyotes, bears or dogs for example though that may be due to the other species occurring at much higher population levels. Much of the public animosity toward wolves appears to be directly connected to statistics such as this being presented out of context of the relevant facts. The public mistakenly assumes that wolves are a much greater risk than other native species when in fact wolves are less of a risk to livestock than most causes of common livestock losses such as disease, bad weather, domestic dog predation and other common factors. We request that WS release and compare losses in the larger, more complete context of overall livestock losses to help avoid causing confusion and resentment of wolves. On page 8, the EA notes that The relative risk of predation on livestock posed by individual wolves was analyzed by WS for Idaho (USDA 2011a). The authors measured the likelihood for depredation to occur from wolves, black bears, cougars and coyotes and showed that individual wolves were more likely to depredate on sheep and cattle than individual coyotes, bears and cougars (Collinge 2008). This citation is a reference to an unpublished presentation made as part of the proceedings of the Vertebrate Pest Conference 23: which was never properly peer reviewed. There is no other body of evidence that has been peer reviewed to support this claim. Studies of depredation data show that protecting livestock from wolves, i.e., prevention, reduces the necessity for killing them (Musiani et al. 2003). Experience has shown that when lethal control is implemented it fails to have long-term effects for controlling livestock depredation (e.g., Musiani et al. 2005). In addition, lethal control can have inadvertent consequences such as disrupting social structure in non-targeted and non-responsible individuals in the meta-population (Knowlton et al. 1999). Moreover, these fractures in social groupings can occur without any reliable impact for reducing canid abundance after the lethal control has been carried out (Wallach et al. 2009). We strongly urge Oregon WS to first consider the many classes of methods and techniques that are widely available for preventing livestock losses to wolves in the first place (e.g., Smallidge et al. 2008). In another example on page 8, the EA states (Cascadia Wildlands, et al. v. Dept. of Fish and Wildlife, et al., No (Or. Ct. App. Nov. 15, 2011) order staying enforcement of rule pending judicial review), a cattle producer which estimated $4,900 in cattle losses to wolf depredation, (not including lost profits), also incurred additional management costs of $19,000. These examples illustrate the severity of indirect economic consequences that wolf depredation and threats can have on individual livestock operations. While we acknowledge there are costs associated with livestock predation management, which could be higher or lower than $19,000, there is no documentation of the estimated costs of this particular incident cited. Were actions taken to mitigate these management efforts necessary, common or effective? We cannot address this because it is an unsubstantiated claim and urge that undocumented claims such as this should be stricken from the final EA. Additionally, we note that the EA considers only lands in the eastern third of Oregon where wolves have been delisted. The U.S. FWS is presently evaluating whether to designate portions of Oregon and neighboring states as a Distinct Population Segment or delist them entirely. Either action could 10

11 result in a need to amend and re-evaluate this analysis and calls into question whether this EA should be finalized prior to final decisions about the status of the grey wolf in the region. If wolves remain listed in this region, WS should consult with the U.S. Fish and Wildlife Service pursuant to Section 7 of the ESA on impacts of its activities in non-listed areas to wolf conservation and recovery in protected areas. The ESA requires consultation where there is reason to believe that an endangered species or a threatened species may be present in the area affected by his project and that implementation of such action will likely affect such species. 16 U.S.C. 1536(a)(3). Wolves are, of course, wide ranging, and wolf recovery in the remainder of the Pacific Northwest region requires the ability of wolves in the Northern Rockies and Canada to migrate into new territory. Overzealous wolf control on the part of Oregon WS or ODFW will hinder broader recovery and conservation of the species, and such impacts of any control actions should be evaluated. The EA may also be legally deficient in that it does not contain a true no-action alternative. In light of the issues and conflicts raised above regarding Oregon WS activities, we believe a more accurate no-action alternative would examine a world without any WS involvement in wolf management in Oregon. The impact of Oregon WS to date on the effectiveness of ODFW s work and the effects of this documented inter-agency conflict on social tolerance is unaddressed in the baseline. Finally, given the extremely controversial nature of lethal control, especially in an environment of documented interagency conflict, and the likelihood of significant impacts to the human environment, we believe WS may need to prepare a full EIS before proceeding. Conclusion Defenders of Wildlife supports and encourages the role of Wildlife Services in promoting and implementing nonlethal methods to reduce avoidable livestock and wolf losses. The nonlethal aspects of wolf and livestock management are well suited with the stated mission of WS to provide Federal leadership and expertise to resolve wildlife conflicts and create a balance that allows people and wildlife to coexist peacefully. The agency s stated vision is to: improve the coexistence of people and wildlife. The program recognizes that the entire field of wildlife damage management is in a period of change, and those involved with this field must consider a wide range of public interests that can conflict with one another. These interests include wildlife conservation, biological diversity, and the welfare of animals, as well as the use of wildlife for purposes of enjoyment, recreation and livelihood. The Wildlife Services program strives to develop and use wildlife damage management strategies that are biologically sound, environmentally safe, and socially acceptable. Wildlife Services also strives to reduce damage caused by wildlife to the lowest possible levels while at the same time reducing wildlife mortality. This approach represents the future towards which Wildlife Services is moving, In charting this course, Wildlife Services must continuously improve and modify wildlife damage management strategies that constrained by current technologies, knowledge, or resources, do not reach this high standard. 11

12 We firmly believe that WS has an important but currently unfulfilled role in assisting livestock owners and wildlife managers to identify, adopt and evaluate corrective nonlethal deterrent strategies that will be more cost effective than traditional lethal control measures and far more successful in the long term coexistence of wildlife and livestock interests. While we understand that lethal control may also need to play a continued role in wildlife management, it should only be implemented as a last resort and not a common practice in wildlife management, especially on the public s national forest lands and wildlife refuges. Until the significant problems with WS investigation procedures are fully addressed, Defenders supports Alternative Two, which restricts the agency to implementation of only nonlethal control methods. Thank you again for the opportunity to comment on this DEA. Sincerely, Suzanne Asha Stone Northern Rockies Representative Defenders of Wildlife P.O. Box 773 Boise, Idaho Sstone@defenders.org Cc: Bill Clay, Deputy Administrator, APHIS Wildlife Services Brett Brownscombe, Natural Resources Policy Advisor, Oregon Governor Kitzhaber Ron Anglin, Division Administrator, Oregon Department of Fish and Wildlife Citations: Knowlton, F.F., E.M. Gese, and M.M. Jaeger Coyote depredation control: an interface between biology and management. Journal of Range Management 52: Musiani, M., C. Mamo, Luigi Boitani, C. Callaghan, C. C. Gates, L. Mattei, E. Visalberghi, S. Breck, and G. Volpi Wolf depredation trends and the use of fladry barriers to protect livestock in western North America. Conservation Biology 17: 1,538 1,547. Musiani, M. T. Muhly, C. Cormack Gates, C. Callaghan, M.E. Smith, and E. Tosoni Seasonality and reoccurrence of depredation and wolf control in western North America. Wildlife Society Bulletin 33: Oakleaf, J. K., C. Mack, and D. L. Murray Effects of wolves on livestock calf survival and movements in central Idaho. Journal of Wildlife Management 67:

13 Range Improvement Task Force. Report 78., Cooperative Extension Service/Agricultural Experimental Station, College of Agriculture, Consumer and Environmental Sciences, New Mexico State University. Smallidge, S.T., H. Halbritter, N.K. Ashcroft, and J.C. Boren Review of livestock management practices to minimize livestock depredation by wolves: applicability to the Southwest. Stone, S. A., N Fascione, C. Miller, J. Pissot, G. Schrader, and J. Timberlake Livestock and wolves: a guide to nonlethal tools and methods to reduce conflicts. In house publication, Defenders of Wildlife Wallach, A.D. E.G. Ritchie, J. Read, and A.J. O Neill More than mere numbers: the impact of lethal control on the social stability of a top-order predator. PLoS One 4(9): e