January 11, 2008

Oregon Fish and Wildlife Commission
3406 Cherry Avenue N.E.
Salem, OR  97303

RE: Bear and Cougar Agent Rulemaking

Dear Oregon Fish and Wildlife Commissioners:

On behalf of Big Wildlife, I write to offer comments about the Bear and Cougar Agent Rulemaking process. We urge the Commission to abandon the state’s plan to deputize hunters to pursue cougars with packs of hounds. Big Wildlife believes the new hounding law, HB2971, passed by the state legislature this summer violates the intent of Measure 18, the 1994 voter-approved ban of hounding of cougars. It also flies in the face of sound science.

We opposed a roll back of Measure 18 for a number of reasons and reiterate those concerns below. We hope you will take them into consideration:

1.)     There is simply no need for deputizing hunters to pursue cougars with hounds.

Proponents of HB2971 argued it was necessary to implement the Oregon Department of Fish and Wildlife’s (ODFW) Cougar Management Plan (CMP). But the hounding law and CMP are based on several faulty assumptions.

First, the Department contends cougar populations are increasing dramatically in Oregon. Yet, the agency has never undertaken a scientifically credible count to determine how many cougars inhabit the state. Rather, the ODFW has relied on notoriously unreliable methods – such as cougar sightings, depredation, and hunting levels – for reaching its conclusions about Oregon’s cougar population. The authors of the 2005 Cougar Management Guidelines, a compilation of peer-reviewed science on cougars, state that “cougar sightings, depredation events and harvest levels are not reliable ways to index cougar populations.” The Guideline authors, including noted biologists, Drs. Paul Beier, Maurice Hornocker, and Ken Logan, concluded that reports of cougar sightings are especially poor indicators of cougar presence “because many sightings are cases where the observers misidentified a bobcat, coyote, domestic dog, domestic cat, raccoon, or deer.” They also noted that increased interactions with cougars are more likely a result of human population expansion, rather than that of cougar population increases or changes in cougar behavior. [1] It makes little sense to launch a plan that calls for expansive killing of cougars when the ODFW’s cougar population data is based on methods that have been discredited.

Second, a study published in The Journal of Wildlife Management in 2006 concludes that cougar populations in the Pacific Northwest are actually declining due in part to increased human intrusion on cougar habitat and a very young age structure of the cougar population caused by heavy hunting. The Journal study also recommended reduced hunting levels, particularly among adult females, throughout the Pacific Northwest.[2]
Third, the Department says its plan is necessary to reduce potential conflicts with humans and domestic animals. But cougars do not present a significant threat to public safety. There has never been a verified cougar attack on humans in Oregon and nothing in this bill, nor the Cougar Management Plan, would prevent an attack. According to the Center for Health Statistics, a child in Oregon has a much greater chance of being killed by a bee, wasp, or spider than a cougar. From 1980-1996 in Oregon, horses were responsible for 41 deaths, bees and wasps for 13, and dogs for 9. I doubt anyone would suggest state authorities launch a lethal control program against dogs and horses.

2.)     Hunting of cougars – including hound hunting as permitted by HB2971 – will not reduce conflicts with cougars.

Contrary to the ODFW claims, leading cougar scientists have found no evidence hunting reduces conflicts. In fact, hunting of cougars may actually increase conflicts with the big cats. Cougar researchers have found:

·         Hunting may be increasing attacks by cougars. Dr. Horrnocker, considered the dean of cougar researchers, said “sport hunting may be exacerbating the likelihood of attacks by removing those cougars that are more wary of people – and thus quicker to climb trees when pursued – thereby skewing the population towards those more aggressive cougars that are also more likely to attack humans.”[3] Dr. Beier found sport hunters tend to seek out larger and older cougars as trophies, which increases the proportion of younger cougars that are more frequently implicated in attacks than adults[4][5]

·         Hunting is not an effective tool for reducing conflicts. According to Dr. Beier, “It is not valid to initiate hunting [of cougars] on the grounds that it will reduce the risk of cougar attacks. Quite simply, sport hunting will not reduce the risk of cougar attacks on humans.”

·         “Short-term, non-selective cougar population reduction [as occurs via hunting] has not been demonstrated to reduce depredation” on domestic animals.[6] In addition, hunting does not select for problem cougars (most cougars are hunted in wild areas far from humans).[7]

·         Hunting of resident cougars that have not preyed on domestic animals opens up habitat for other cougars which may be more likely to prey on domestic animals.[8]

·         Continued emphasis on hunting as a management tool diverts resources away from techniques that are more effective in reducing conflicts between cougars and humans, such as appropriate land-use planning, improved animal husbandry, and comprehensive public education.[9]

·         Cougars are not concentrated in human settlements. “Arguments for decreasing cougar density often focus on scenarios of cougars lurking near human homes and settlements. Because few cougars are more than one home range width from some sort of human settlement, this argument may be nothing more than a rhetorical devise to promote regional hunting. Hunting of cougars near the densest human settlements is difficult because houndsmen are reluctant to hunt these areas (due to risk that dogs will be killed on paved roads), and private landowners or local laws often prohibit hunting. Furthermore, although cougar attacks do occur close to human settlements, they do not seem to be concentrated there.”[10]

3.)     Oregonians oppose the cruel practice of pursuing cougars with a pack of radio-collared dogs, as well as reject the Cougar Management Plan’s expansive use of lethal control measure for “managing” cougars.

When voters approved Measure 18 in 1994 to ban hounding of cougars and bears, they did so not only because they believe the tactic is barbaric but because they support strong protections for Oregon’s wildlife. They had assumed when the initiative was passed that cougars would be afforded adequate safeguards. Unfortunately, since Measure 18 was enacted, the ODFW has bent over backwards to accommodate hunters still disgruntled with the hounding ban. For example, the state agency has reduced cougar tag fees to a meager $11.50, extended the cougar hunting season to ten months and in some areas year-round, and permitted hunters to kill two cougars per year. As a result, more cougars are being killed in Oregon than ever before.

As the Commission drafts rules to implement HB2971, Big Wildlife also urges you to incorporate the following recommendations into your rulemaking:

·         Immediately halt the CMP until a thorough, independent peer review of the plan is completed.

·         Any hunter who has been convicted of violating wildlife laws should be disqualified from the program.

·         All complaints and non-hunt mortality must be verified onsite by trained personnel before use as criteria or threshold for determining the geographic scope of the target area for administrative removal.

·         Produce a more robust, statistically powerful population model to provide a more accurate estimation of cougar population size, density and carrying capacity by incorporating the following additional methods of data collection:  radio telemetry monitoring and application to related demographics and use of non-lethal molecular techniques such as scat and hair analysis.

·         Administrative removal methods must be limited to padded traps (with 24 hour trap check requirement), trained and credentialed handlers, and euthanasia methods that comply with American Veterinary Medicine Association standards.

·         Prohibit removal of females with dependent young.  Training must be provided to all agents and employees with means of identifying reproductive status of females and AVMA euthanasia methods.

·         Direct the ODFW to devote resources to employ non-lethal techniques that are far more effective in reducing conflicts, such as appropriate land-use planning, improved animal husbandry, and public education. Rather than using resources to kill cougars, the Department should be assisting communities with developing strategies for avoiding encounters with cougars. For example, the agency should be educating individuals to take simple steps, like avoiding feeding wildlife, bringing pets in at night, sheltering domestic farm and ranch animals, installing motion lighting around their property, recreating with others while in cougar country, and educating their families about cougars to help prevent conflicts with the big cats.

Thank you for this opportunity to submit testimony to your committee.


Spencer Lennard, Program Director

[1] [1]Cougar Management Guidelines Working Group. 2005. Cougar Management Guidelines. First Edition. WildFutures, Bainbridge, WA.

[2] Lambert, C et al. 2006 Cougar Population Dynamics and Viability in the Pacific Northwest. Journal of Wildlife Management. Vol. 70, Issue 1. Wildlife Society, Lawrence, KS. [3] Hornocker, M. 1992. Learning to live with cougars. National Geographic 182:52-65.

[4] Beier. P. 1991. Cougar attacks on humans in the United States and Canada. Wildlife Society Bulletin 19:403-412. Available online at

[5] Ibid.

[6] Ibid.

[7] Logan, K., and L. Sweanor. 2001. Desert Puma: Evolutionary Ecology and Conservation of an Enduring Carnivore. Island Press, Washington, DC.

[8] Papouchis, C. 2006. Living with Cougars. Cougar Foundation. Sacramento, California. Available online (

[9] Ibid.

[10] Cougar Management Guidelines Working Group. 2005. Cougar Management Guidelines. First Edition. WildFutures, Bainbridge, WA.