Daniel J. Rohlf, OSB 990069

rohlf@lclark.edu

Telephone: (503) 768-6707

Thomas Buchele, OSB 081560

tbuchele@lclark.edu

Telephone (503) 768-6736

Earthrise Law Center

10015 S.W. Terwilliger Blvd.

Portland, OR 97219-7768

Attorneys for Plaintiffs

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

AUDUBON SOCIETY OF PORTLAND, WILDLIFE 

CENTER OF THE NORTH COAST, ANIMAL LEGAL 

DEFENSE FUND, CENTER FOR BIOLOGICAL 

DIVERSITY, FRIENDS OF ANIMALS,

Plaintiffs,

v.

U.S. ARMY CORPS OF ENGINEERS, U.S. FISH AND 

WILDLIFE SERVICE, USDA WILDLIFE SERVICES,

Defendants.

Civil No. 15-665

DECLARATION OF 

NOAH GREENWALD

I, Noah Greenwald, declare as follows:

1. I currently reside in Portland, Oregon, where I have lived for over 12

years.

2. I have a Bachelor of Science degree in Ecology from the Evergreen State 

College and a Master of Science degree in Forest Ecology and Conservation from the 

University of Washington. 

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3. I am currently employed by the Center for Biological Diversity. The 

Center is a nonprofit organization committed to the preservation, protection, and 

restoration of native species and the ecosystems upon which they depend. The Center has 

field offices throughout the United States, including Arizona, New Mexico, California, 

Nevada, Oregon, Washington, Alaska, Minnesota, Vermont, Florida, Washington, and 

Washington, D.C. The Center works through science, law, and creative media to secure a 

future for all species, great or small, hovering on the brink of extinction. The Center has 

more than 50,000 members and over 825,000 online supporters. The Center and its 

members are concerned with the conservation of imperiled species and the effective 

implementation of federal laws protecting wildlife.

4. Before joining the Center in 1997, I worked as a field biologist, surveying 

northern spotted owls and marbled murrelets and banding Hawaiian songbirds. 

5. I have been a member, Conservation Biologist, and now Endangered 

Species Program Director of the Center for Biological Diversity for over 17 years. In 

these capacities, I have been responsible for monitoring the status of numerous species 

and ecosystems. I rely in part upon the Center to represent my interests in protecting 

native wildlife and their habitats.

6. The Center opposes the decision by the Corps and the U.S. Fish and 

Wildlife Service to kill thousands of cormorants breeding on East Sand Island in the 

Columbia River. On March 16, 2015, we sent detailed comments explaining why the 

proposed killings lack justification.

7. The Center will suffer injury in fact to their organizational interests in 

conserving native wildlife if the killing of thousands of cormorants is allowed. 

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8. The Center also has significant organizational interest in ensuring that the 

Service appropriately interprets and applies the statutory and regulatory provisions of the 

Migratory Bird Treaty Act. Any decision in the federal government's favor could set a 

precedent that would weaken the Migratory Bird Treaty Act and make it harder for the 

Center to utilize that federal law to protect birds.

9. I have a moral interest in the conservation of all native wildlife. I believe 

that biodiversity has inherent value. I feel saddened whenever human actions cause the 

decline or loss of native wildlife because I believe that humans have a responsibility to 

preserve biodiversity.

10. With graduate work in forest ecology and conservation and years of 

experience as a field biologist, I have a scientific interest in the conservation of native 

wildlife. The loss or decline of any wildlife species hurts my scientific interest because I 

lose the opportunity to study the species and the ecosystem in which that species lived.

11. I understand that the planned killing of cormorants by the Corps and the 

U.S. Fish and Wildlife Services will occur within a 25 km radius of East Sand Island in 

the Columbia River. That includes areas where I regularly visit and view birds.

12. Just this spring -- and multiple times in the past -- I went to Fort Stevens 

State Park to view birds, including double-crested cormorants on the Columbia River. I 

take joy in viewing these native birds and appreciate the peacefulness of viewing the 

Columbia River when I take hikes in this state park and other open spaces near the River. 

But I am upset when I think that these birds that I've enjoyed viewing could suffer cruel 

and needless deaths at the hands of government agents.

13. I have concrete plans to return to the Columbia River later this spring and 

into the future to look for birds, including double-crested cormorants.

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14. As someone who cares deeply for wildlife and their habitats, I am upset

that the Corps and the Service have decided to kill thousands of double-crested 

cormorants. I fear that when I go outdoors near the Columbia River to enjoy the 

peacefulness of the River and look for birds and other wildlife this spring and in future 

years I could come across federal agents killing cormorants. I might also see dead or 

injured birds that have been shot floating in the river or washed up on shore. This would 

greatly disturb me. 

15. Just knowing that these killings are planned to take place and that I could 

be exposed to those gruesome actions diminishes my enjoyment of recreating in the 

Columbia River basin. It bothers me greatly to know that my tax dollars are being used to 

support the killings.

16. I have a moral in the conservation of all native wildlife. I feel saddened 

whenever human actions cause the decline or loss of native wildlife because I believe that 

humans have a responsibility to preserve biodiversity.

17. I have an aesthetic interest in native wildlife because I find great beauty in

observing nature. The loss or decline of cormorants and other wildlife makes the world a 

less beautiful and wonderful place to live.

18. In sum, I have recreational, aesthetic, professional, and moral interests in 

the preservation of double-crested cormorants. These interests will be irreparably harmed 

by the agencies' decision to kill thousands of cormorants in areas near where I live and 

where I regularly visit. Because of the killings, there will be less cormorants for me to 

view and enjoy. In fact, the goal of the killing program is to reduce the cormorant 

population, and this loss would deprive me of the benefits I currently enjoy from these 

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animals. The killings would also hurt my ability to enjoy my time viewing the Columbia 

River because I fear that I may encounter federal agents killing birds or even see dead 

bodies of birds. A court decision reversing these decisions would ensure that my interests 

in cormorants are preserved and remain free from injury.

I declare under penalty of perjury that the foregoing is true and correct. Executed on 

April 17, 2015, in Multnomah County, Oregon.

________________________

___

Noah Greenwald

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