South Dakota Dept. of Game, Fish and Parks Commission

Mr. Jeff Olson, Chairman

South Dakota Dept. of Game, Fish and Parks Commission

523 E. Capital Ave.

Pierre, S.D. 57501

Re: Mountain Lion Hunting Season (Amend. ARSD 41:06:61)

Submitted Electronically:

October 3, 2012

Dear Chairman Olson,

On behalf of the more than 2,000 nation-wide members of The Cougar Fund, we want to thank you for this opportunity to comment on the 2012-2013 South Dakota Mountain Lion Hunting season proposal now before you. We strongly urge the Commission NOT to increase the quotas as proposed and to give serious consideration to lowering the existing quota and instituting a scientifically defensible female sub-quota.

COMMENTS RELATING TO MOUNTAIN LION QUOTAS

The Cougar Fund assumes the motivation for the proposed increase in the 2013 hunt quota is to achieve the population objective expressed in the South Dakota Mountain Lion Management Plan 2010-2015 (Plan). Page V of the Plan sets out five objectives. The first is “To reach a sustainable and socially acceptable mountain lion population that is in balance with available habitat and other game animal populations in the Black Hills of South Dakota at 175 +/- 25 individuals”.This population objective of 175 lions represents a 24 percent decrease from the current population estimate of 230 lions. A measure of a “socially acceptable” mountain lion population appears on page 15 and Table 9 (p. 51) of the Plan which reports the results from a recent public survey. In part, the report concludes that over 46 percent of Black Hills residents (home of the core mountain lion population) surveyed preferred that mountain lion populations remain at “Current Levels” with an additional 10 percent of the respondents wanting to see the lion population increase. In contrast, only 43.5 percent of the respondents wanted to see the lion population decrease. Clearly, 56.4 percent of public favors mountain lion populations to remain at or increase from current levels which in 2010 (assumed period when the survey was taken), was estimated to be 223 (+/- 25) (p. 18. Plan). The planned reduction of the mountain lion population by 24 percent goes against what is documented as “socially acceptable” by the majority of the public and should not be authorized.

Another portion of the Plan’s number one objective is to reach- “…[a] balance with available habitat and other game animal populations…” An analysis of recent deer hunting trends in South Dakota (the dominant lion prey species in the Black Hills) indicates that hunter success has remained higher in the Black Hills region (57%) – where the core of the mountain lion population resides, than in either the East River (52%) or West River (52%) deer hunting units (2011 East River Firearm Deer and 2011 West River Firearm Deer summary reports) where there is no documented resident lion population (p. 16. Plan). The Statewide Combined Deer Harvest Report (p. 1. 2011) describes a decline in statewide deer hunter success over the past three years and goes on to say that – “Reductions in harvest for the East River Dear, Archery Deer, Muzzleloader Deer, and West River Deer accounted for most of the decrease…”. Clearly, the recent decline in deer harvest numbers is a statewide phenomenon, and not one solely attributable to mountain lions.Based upon this information, the South Dakota mountain lion population does not appear to be out of balance with the “available habitat” or “other game animal populations”. As such, the significant increase proposed in the 2013 mountain lion hunting quota is scientifically unjustified and should not be authorized.

Page 18 of the Plan lists several “expected benefits from achieving this (175) population objective”. The first being “An estimated 50% reduction in the occurrence of problem lions and removals by the Department.” There is no scientific evidence that reducing lion populations through increased sport hunting will reduce “problem lion” situations. In fact, evidence is mounting that just the opposite is true. With aggressive killing of lions more younger animals will be moving into vacated habitats and it this young segment of the lion population that is involved in most “problem lion” complaints. Because evidence is growing that increased mountain lion harvest will cause MORE “lion problems”, we urge the Commission not to authorize the proposed increase in the 2013 lion hunt quota.

A second expressed “expected benefit” of reducing the mountain lion population by nearly 24 percent is- “An estimated 40% reduction in the number of mountain lion mortalities caused by vehicle collision.” We fail to see the logic of this statement. Thus far in 2012, 4 of the 95 known lion mortalities were caused by vehicle collisions. (A 40% reduction in vehicle-caused lion mortalities would result in ‘saving” 1.6 lions.) If the goal is to keep lions from being killed by vehicles and the chosen method to achieve this goal it to allow hunters to kill more lions, we see no benefit to the lion population. The logic escapes us. If instead the goal is to protect motorists from having dangerous collisions with mountain lions, we suggest the Commission apply that same “kill more wildlife” approach to the state’s deer population to reduce deer/vehicle collisions. In 2011, State Farm Mutual Automobile Insurance Company reported that South Dakota ranked third highest in the nation based on the “Likelihood of Collision with Deer” (7,420 collisions with 602,165 licensed drivers). For a state agency to even propose this action is beyond logic.

Another of the “Expected benefits” of reducing the mountain lion population is – “An estimated reduction in the mortality of 1,650 big game species by mountain lions in the Black Hills.” There is no credible evidence presented to substantiate this number nor is there any way to determine if these mortalities- however real- would be compensatory or additive. This figure and implied argument in no way justify a 24 percent decrease in the state’s mountain lion population and as such, the proposal should not be approved.

In addition, The Cougar Fund urges the Commission to adopt a female quota along with the overall quota. In the state’s seven lion-hunting seasons thus far carried out, 61% of the hunter-killed lions were females. We doubt that this high female kill percentage is sustainable at the population level. Regardless, killing from 20 to 45 females a year obviously includes a number of pregnant individuals and even more lions with dependent kittens. The scientific literature reports a 95 percent death rate for orphaned kittens under the age of 6 months. Clearly, with each female lion killed, there is a significant amount of collateral mortality, whether in the womb or in the field.The Cougar Fund implores the Commission to work with its staff biologists and identify and institute a limited, statewide female quota as soon as possible.

In conclusion, The Cougar Fund must ask: What is the motivation to increase the mountain lion hunt quotas when the majority of the public wants to see current population levels maintained or increased; when deer hunt data indicates that hunter success in the core lion country is greater or at worst equal to that in the majority of the state with “no confirmed “ breeding lion population? How can the proposed increased kill be justified when anticipated benefits make no sense at all? We can only conclude that this proposal is simply driven by a deep-seated and conscious predator prejudice. This proposal reflects neither good game management, sound science, or actions morally acceptable in the 21st century.

We ask the Commission and the Department of Game, Fish and Parks to accept mountain lions as an equal and integral part of the native fauna of the great state of South Dakota and manage the population with respect for its role in the ecological dynamics of your state’s rich habitat. We truly believe it is what the majority of South Dakota citizens want and expect from the agency solely responsible for stewarding its wildlife resources.

Thank you,

Lisa Rullman

Managing Director

The Cougar Fund