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OOC Working to Increase YOUR Hunting Opportunities!

Oregon Outdoor Council

March 30, 2014 – Stan Steele, Chairmen of the Board

OOC Working to Increase YOUR Hunting Opportunities!

U.S. Fish and Wildlife Service
Willamette Valley National Wildlife Refuge Complex
26208 Finley Refuge Road
Corvallis, Oregon 97333

March 27, 2014

Elk Management Plan Draft Environmental Assessment Comments,
On behalf of the Oregon Outdoor Council (OOC)), our supporting businesses and partner
conservation organizations we thank you for this opportunity to comment on the Unites States
Fish and Wildlife Service (USFWS) Willamette Valley National Wildlife Refuge Complex
(WVNWRC) draft Elk Management Plan (Plan) Environmental Assessment (EA). OOC’s
mission is “To promote and protect outdoor pursuits in Oregon including hunting, fishing,
trapping, habitat and species management, public access to outdoor recreation and gun
ownership.” We work through advocacy, education and collaboration to conserve fish and
wildlife, promote responsible outdoor pursuits and protect Oregonians’ rights to enjoy all that
our beautiful outdoors have to offer.

The Oregon Outdoor Council supports the Plan and applauds the USFWS for applying the
guidelines contained in the National Wildlife Refuge System Improvement Act of 1997
regarding the recreational use and conservation of the WVNWRC’s resident Roosevelt elk
population.

The National Wildlife Refuge System Improvement Act identified six wildlife-dependent
recreational uses for the Willamette Valley’s, William L. Finley, Basket Slough and Ankeny
National Wildlife Refuges. Hunting, fishing, wildlife viewing and photography, environmental
education and interpretation are referred to as the “Big Six” activities that receive special
consideration when designing management plans for the National Wildlife Refuge System. The
Service is directed to make extra efforts to facilitate these priority wildlife-dependent public use
opportunities.

The Oregon Outdoor Council believes the management actions considered in the EA, Section 2.2
Alternative B: Preferred Action – Implement Elk Management Plan, Appendix B. WVNWRC
Elk Hunting Plan, best demonstrate the spirit of the National Refuge System Improvement Act
regarding the principles of multiple use and conservation of our nation’s wildlife resources.
The wildlife species that inhabit the WVNWRC today do not exist by accident. They are a
rich and vital living example of what more than 100 years of dedicated work by hundreds of
organizations and millions of hunter – conservationists have successfully accomplished. Nearly
two centuries of unchecked habitat devastation and wildlife exploitation prompted George Bird
Grinnell to comment about the “fallacy of the inexhaustible” while advocating for a change in
the way America viewed and utilized its rapidly dwindling natural resources. Famous hunter –
conservationists like Theodore Roosevelt, Gifford Pinchot, Grinnell and countless others had
a vision that laid the cornerstone to the world’s most successful fish and wildlife management
system which is commonly referred to as the North American Model of Wildlife Conservation.
The model has two basic principles: our fish and wildlife resources belong to all citizens and
these resources should be managed in a way that their populations will be forever sustainable.
The proposed WVNWRC Plan adheres to and responsibly applies the successful conservation
guidelines of the Seven Sisters of Conservation which support the principles of the North

American Model of Wildlife Conservation. The Seven Sisters guidelines have been directly
responsible for establishing public ownership and public recreational use of the nation’s 150
million acre National Wildlife Refuge System.

Working collaboratively, the Service and the Oregon Department of Fish and Wildlife (ODFW)
have recognized their public trust responsibilities by scientifically designing an elk management
plan that the OOC believes balances the WVNWRC’s elk herd’s biological requirements with
the associated social and economic desires of the refuge’s neighboring farms and recreational
users.

William L. Finley National Wildlife Refuge was created (1964) to provide wintering habitat for
dusky Canada geese. The refuge utilizes an intensive cooperative farming program that provides
nutritious browse (commercial grass seed crops) for seven subspecies of wintering Canada
geese and nearly 200 head of Roosevelt elk. The elk are year around residents while the geese
start arriving in mid to late October and depart the refuge in April and May. The OOC believes
that the time frame of the proposed elk hunt will not biologically interfere with the Refuge’s
primary purpose and will comply with the “Big Six” guidelines. Managing the on refuge – off
refuge dynamic of the refuge elk herd through a scientifically-designed and monitored elk hunt
will likely increase social tolerance and decrease agricultural and property damage to adjacent
landowners.

The OOC believes the proposed elk hunting program meets the compatibility standards for
refuge approved recreational activities and the provisions contained in the National Wildlife
Refuge System Administration Act of 1966 as amended by the National Wildlife Refuge System
Improvement Act of 1997, (16 U.S.C. 668dd-668ee Refuge Administration Act). This law states
that “The Secretary is authorized, under such regulations as he may prescribe, to — (A) permit
the use of any area within the System for any purpose, including but not limited to hunting,
fishing, public recreation and accommodations, and access whenever he determines that such
uses are compatible” and that “. . . the Secretary shall not initiate or permit a new use of a refuge
or expand, renew, or extend an existing use of a refuge, unless the Secretary has determined that
the use is a compatible use and that the use is not inconsistent with public safety.”

The National Wildlife Refuge System Improvement Act of 1997 (NWRSIA) mandated that
Comprehensive Conservation Plans (CCP) be developed for all refuges in the National Wildlife
Refuge System. The refuges that make up the WVNWRC, William L. Finley Refuge, Ankeny
and Basket Slough complied with the NWRSIA mandate by approving the CPP’s (USFWS
2011). When fully implemented, this will guide refuge fish and wildlife management activities
on the refuges for the next fifteen years.

Preferred Alternative B, Elk Hunting Plan for the Willamette Valley National Wildlife Refuge
Complex is enthusiastically supported by the Oregon Outdoor Council as both an appropriate
and scientifically responsible CCP wildlife and recreation management action.

Stan Steele
Stan Steele Oregon Outdoor  Council

 

 

 

Chairman of the Board
Oregon Outdoor Council