Nancy Hilding

President
Prairie Hills Audubon Society
P.O. Box 788
Black Hawk, SD 57718
August 28, 2021

To
SD Game, Fish and Parks Commission.
523 E Capitol Ave.
Pierre, SD 57501

Comments on the proposed mountain lion season 2022-2023;

1. Female Harvest Limit in the Black Hills National Forest

Prairie Hills Audubon Society requests a lowering of the Black Hills female harvest limit.
We suggest you lower it to 25 female lions. However any number below 40 is an improvement, so we
ask you to consider any value between 35-25 female lions as an alternate harvest limit.

Andrew Norton showed this powerpoint slide at the July Commission meeting. During the question
and answer session with the Commission, he (or other staff) indicated that if the female harvests ac-
tually reached the female harvest limit (40), the population could be at the lower end of the Manage-
ment Plan’s population goals of 200-300 lions within 2 years. This chart shows that. We think the pink
and blue shaded areas that bracket the line, show the uncertainty with the plotting of the data as the

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line.

The below chart was shown I think by Andy Lindbloom and it shows what the actual harvest of fe-
males was over time.

Wyoming has been managing its’ side of the Black Hills, very aggressively as a lion “sink”. So South
Dakota is growing and exporting lions to Wyoming and then Wyoming is profiting from selling the
death of SD grown lions. They set the lion season every three years and will be doing so in
spring/summer of 2022. Rumors are that the emotions in Wyoming are very anti-predator. If Wyoming
increases their take of the Black Hills lions, it could negatively effect your population goals - decreas-
ing your population faster, than currently.

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The below chart shows population estimates over time using various theories, indicating that you may
have dropped below the 200 lion population goal in 2017, although the goal then was 175 plus or
minus 25 lions. You are planning on the hunters not catching more than 25 or 27 females, as that was
the high point in recent years. But you really can’t rely on that. We suggest that you don’t risk drop-
ping below the population bracket of 200 lions of all ages and you chose a more cautious harvest limit
than 40 female lions.

Custer State Park Hunting

The next chart was also shown during the power point at the Commission meeting. It shows that
hound hunters in the Park have been getting all the lions for the last seven years and the boot
hunters none.

Hound hunting is more efficient than boot hunting. Hunting with dogs was first allowed in
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Custer State Park (CSP) in 2012/13 and in the Prairie Unit in 2015/16. Currently the hound hunters in
CSP have 5 two-week intervals and go first and the boot hunters 4 two-week intervals and go second.
It seems that the hound hunters are out-competing the boot hunters for lions. In Nebraska, the boot
hunters go first and if they don’t reach the harvest limit than the hound hunters go next.

Hound hunters are out-competing the boot hunters in the Park. The boot hunters should have the
first crack at the lions - thus please offer them the first two week hunting period in Custer State Park.

Generic Comments on the Black Hills and Prairie Unit.

We would like the Black Hills Population managed as a stable or source population, not a declining
population.

We object to the 365 day hunting season in the prairie and we object to hound hunting both on the
prairie unit and Custer State Park due to:

1. Animal cruelty issues for hounds and cougars

2. Lack of “fair chase”
3. Threat of trespass
4. Disturbance to non-target wildlife, livestock and other humans
5. The hound hunters out-compete the boot hunters.

In the prairie unit we especially worry about lions being chased where they may have no trees or
rocks on which to escape above the dogs.

We show a map of documented lion mortality below. Blue dots are females, red males. We wish the
prairie unit could be divided in to sub-sets and managed differently in different areas. We believe the
Custer-Gallatin National Forest area that borders Montana and the southern edge of South Dakota
that borders Nebraska, are areas that can grow some breeding lions. These areas should be man-

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aged differently than the rest of the prairie, to allow protected connectivity corridors.

We believe there is certain evidence of breeding on Oglala Sioux Tribe lands, probable evidence of
breeding on Rosebud Sioux Tribe lands and in the past potential evidence of breeding on Yankton
Sioux Tribe’s land. In the mid 1990s, Custer National Forest staff saw a female with kittens on Slim
Buttes.

We object to SDGFP not having any desire to manage for lion populations in the prairie.

Thanks,

Nancy Hilding
President

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