Semiaquatic Mammal Damage Management in Oregon

Dear Wildlife Services Oregon State Director: The Animal Welfare Institute ("AWI"), on behalf of our members in Oregon, submits these comments on the Pre-Decisional Environmental Assessment ("EA") for the U.S. Department of Agriculture, Animal and Plant Health Inspection Service ("APHIS"), Wildlife Services' ("Wildlife Services" and "WS-Oregon") Semiaquatic Mammal Damage Management ("SMDM") in Oregon, which targets beaver, mink, nutria, muskrat, and river otter. AWI is a nonprofit organization founded in 1951 whose mission is to alleviate the suffering caused to animals by people. We seek better treatment of animals everywhere—in the wild, in research, in agriculture, in commerce, and in our communities. We advance our mission through strategically crafted political and legal advocacy, educational programs, litigation, research, and engagement with industry, policymakers, scientists, and other NGOs. The EA contains multiple deficiencies that must be rectified to comply with the National Environmental Policy Act ("NEPA"), 42 U.S.C. § 4321, et seq. First, WS-Oregon provided a flawed set of alternatives within the EA, and improperly dismissed multiple reasonable alternatives. Second, the EA fails to take a sufficiently hard look at the ecological benefits of beavers, the inhumaneness of multiple management methods, and the impact on non-target species, including threatened and endangered species. Lastly, the document fails to adequately consider impacts to special areas containing unique resources and habitats, including Wilderness Areas and Wilderness Study Areas. We request that the legal inadequacies identified in this comment be addressed in the final decision document. For a further discussion of these issues, please see the attached comment. Thank you for considering our concerns. If you have any questions or there is any additional information we can provide, please do not hesitate to contact me. Regards, Johanna Hamburger Director and Senior Attorney Terrestrial Wildlife Program Animal Welfare Institute 900 Pennsylvania Ave, SE Washington, DC 20003