Oregon Cougar Action Team

MOUNTAIN LION FOUNDATION
Saving America s Lion ™
July 23, 2010

Mountain Lion Management Plan Comments
South Dakota Department of Game, Fish and Parks
523 E Capitol Avenue
Pierre, SD 57501
Via Overnight Courier and email (chad.switzer@state.sd.us)
Re: Draft 2010 - 2015 South Dakota Mountain Lion Management Plan
To the South Dakota Department of Game, Fish and Parks Commission:

On behalf of the Mountain Lion Foundation (MLF) and our members and
supporters in South Dakota and throughout the United States, I present these
comments on the South Dakota Department of Game, Fish and Parks'
(SDGF&P) Draft 2010 - 2015 Mountain Lion Management Plan. The Mountain
Lion foundation is dedicated to protecting and conserving mountain lions
throughout the United States and in promoting peaceful coexistence between
mountain lions and humans.

The Mountain Lion Foundation's review of South Dakota's Draft 2010-
2015 Mountain Lion Management Plan found the document full of conflicting
numbers, flawed mathematical equations, bad scientific practices, faulty
assumptions, and a complete disregard of the basic biological and behavioral
qualities of the species. The following are our most vehement objections to
this Plan.

First, the South Dakota Department of Game, Fish and Parks have turned
the issue of managing the State's mountain lion population into a much
narrower focus of managing mountain lions in the Black Hills.
The state of South Dakota encompasses 75,896 square miles of land. Of
this, the Black Hills region is less than seven percent ofthe state's land area.
SDGF&P's mountain lion management plan presents the Black Hills as the
"only" viable mountain lion habitat in South Dakota because this is where
resident territories and breeding populations are currently found.
What is not presented to the public is the fact that, until the species was
extirpated from the state sometime around 1906, mountain lions could be
found throughout the entire state. Because of this human induced extinction,
South Dakota's mountain lion population is undergoing the slow process of
recolonization. A process which has slowed even further in consequence of the
disproportionate number of trophy-hunting related lion mortalities throughout the region
(South Dakota, Wyoming, and Montana) which have vacated previously held resident
territories.

Studies show that mountain lions are a highly adaptable species which can live in almost all
types of environments ranging from high mountain forests to harsh desert canyons. A key
determining factor for suitable lion habitat is the availability of their primary prey species--deer.
The National GAP Analysis Program's listing of suitable habitat, and prey species probability
virtually guarantees that mountain lions could exist almost anywhere within South Dakota.
Mountain lions as a species are biologically designed to disperse. Maturing juveniles have been
known to travel hundreds of miles to establish home range territories. By not allowing the
species to roam, inbreeding will inevitably occur (as is seen with the approximately 100
panthers left in Florida) and the genetic health of the population will decline.
The bottom line is that mountain lions should be managed on a larger, regional scale and
not confined within the Black Hills. Until the recolonization process is complete, with a
mountain lion population appropriately scattered throughout the state, any discussion about
overpopulation and habitat limits is premature.

Second, the relatively small size of South Dakota's mountain lion population, makes the
accurate estimate of population numbers critical in making any reasonable management
decisions, and dramatically increases the margin of error risks. An analysis of SDGF&P's
mountain lion population estimate raises several questions as to the validity of their population
growth mode" and identifies major errors in their mathematical calculations.

For example, SDGF&P's rate-of-growth calculation is based on the maximum growth rate,
found in one study (Logan and Sweanor 2000L which took place in an environment totally
dissimilar to that found in South Dakota. In actuality, mountain lion growth rate values can and
do change annually in anyone area, and are highly dependent on unique geographic factors. By
not looking beyond a single aspect of a single study, SDGF&P researchers are violating sound
analytical practices and have risked developing a population estimation formula which is likely
to be misleading and far from reality.

After creating this potentially faulty population growth model, SDGF&P attempted to justify
their conclusions by using their 2007-2009 mountain lion harvest data. But according to them,
"No harvest occurred in 2008 due to movement of the harvest season to January 2009. Harvest
data for 2009 provided a similar estimate of population size to that of 2007." The three years of
harvest data supposedly used for the population estimate is actually just 2007's mortality
numbers, which means they are relying on only one year's data to assume population trends.
SDGF&P rationalize this choice by saying 2009 was "similar" to 2007 and thus they only needed
to use results from one of the years. Their harvest data is noted below.

Even if you overlook the fact that they are only using one year's data to support a trend
analysis, and selecting their favorite year to build upon, they still screwed up their calculations.
SDGF&P noted that in 2007, estimates of population size were generated for the female
segment of the population . ... " This decision was made... due to total harvest of one radio
collared male." At the time, South Dakota's collection of radio-collared lions totaled 35 (15
males, 20 females- page 29). When calculating the female segment of the population by harvest
data from 2007, the harvest rate should therefore be calculated as 5/20 collared females, NOT
5/35 total (male + female) collared lions. This error in their mathematical calculations for
population estimates on page 5 leads to a drastically different estimate of South Dakota's
mountain lion population.

A total of 16 total female lions were killed that year. Five of those killed were radio collared,
thus 5 out of 20 radio-collared female mountain lions were killed (5/20 = 0.25 = 25 percent). So
if those 16 lions represent 25 percent of the female population, then SDGF&P's data shows
there could only be 64 female lions in the state (16 is 25 percent of 64). By dividing instead by
35 lions, the 112 lion result SDGF&P is presenting as females only, is actually a combination of
males and females.

SDGF&P further compounds their error by assuming that their estimated female population
number represents 70 percent of the total lion population in South Dakota.
This 70 percent female estimate appears to be based on data from SDGF&P's own lion
harvest data for 2007 and 2009. During these two years, 31 females and 14 males were killed
(45 total). The 31 females represent about 70 percent of the total harvest, so SDGF&P made a
giant leap in assuming 70 percent of the entire population must also be female, and thereby
able to create a lot of kittens. As justification for this assumption, SDGF&P researchers
incorrectly cited Logan & Sweanor's research from a 2000 lion population study in New Mexico.
Yes, Logan & Sweanor did find that their study population sometimes had slightly more
females than males because males have a higher mortality rate (via killing each other for home
ranges and through competition for breeding females), and a female bias was noted in first time
litters, but in the end, Logan and Sweanor concluded "none of the annual comparisons of
adult sex ratios in either area were significantly different from 1:1." This is clearly a case where
SDGF&P researchers once again only rely on a single source, and then "cherry-picked," data
which would appear to validate their conclusions.

Third, SDGF&P claims that the Black Hills can only support a population of somewhere
between 150 to 200 lions and that recreational hunting quotas must increase to "ensure a
healthy, self-sustaining population of mountain lions in the Black Hills of South Dakota." They
base this conclusion of their assertion that there are currently 251 mountain lions (138 adults,
113 kittens) residing in the region.

MLF has clearly demonstrated the inaccuracy of SDGF&P's mountain lion population
estimate. But even using the Departments own population estimate numbers it is disingenuous
to include "kittens," as if they were adults, just to create a false sense of overcrowding in order
to justify the need for an increase in the annual hunting quota.
In conclusion, the Mountain Lion Foundation finds that the South Dakota's Draft 2010-
2015 Mountain Lion Management Plan is poorly written, contains conflicting numbers (such as
the total number of mortality events), has critical errors in their mathematical equations which
profoundly affect their estimated population figures, and makes assumptions far beyond
anything that can be proven with current research.

The Mountain Lion Foundation formally requests that the South Dakota Game, Fish and
Parks Commission reject this flawed document and authorize a complete audit of the process
as well as a peer review and second opinion on the proposed 2010 - 2015 Mountain Lion
Management Plan from credible outside experts.

Sincerely,
Tim Dunbar
Executive Director
The Mountain Lion Foundation

Our goal is to live fear free with cougars as our Native Nations have done for thousands of years. Historically, America has been a culture that all to frequently killed anyone or animal they feared, did not understand, or believed may take a form of value from them, (Howard Zinn, A People’s History of the United States, 1492 to present”). Too many historic distorted views have shaped our culture in adverse ways towards ecosystems, species, and ultimately humans. It is time to remove the shackle of these fears and beliefs and distortions and sow seeds of peace, respect, compassion, community, and living fear free not only with cougars, but with any issue we do not understand or fear. With today’s growing issues with global warming, it is timely to make changes that protect all life on this planet. Knowledge is power that can remove fear and distorted views. Knowledge empowers people to make better choices and live better lives and develop better communities. 

Oregon Cougar Action Team is honored to announce that they have become members of a National Wildlife coalition, “Celebrating The American Lion.”   We have joined knowledge, experience, science, and humanitarian efforts with other Cougar organizations across the United States in a National effort to help people better understand these great cats and to save them. 

Visit WWW.Americanlion.org to see this great program!  Celebrating The American Lion was started by Mountain Lion Foundation WWW.mountainlion.org and is a fast growing concept helping and supporting all who share the same heart beat and spirit to save this great cat. 

Oregon Cougar Action Team also recognizes Dr. Laurie Marker, WWW.cheetah.org who's African experience saving Cheetahs has given OreCat courage and council. 

OreCat gives a very special thank you to Professor William Ripple who has changed the face of science regarding cougars, wolves and other top predators and how our very existence depends on their survival.  You can read about William at the Smithsonian and Oregon State University websites! 

A big thank you to WWW.Felidaefund.org for their outreach, support and fabulous pictures! OreCat extends a thank you to artists Mark Elbroch and Trish Carney for their wonderful supply of cougar pictures. 

Thank you C.A.S.H., Committee To Abolish Sports Hunting, www.AbolishSportsHunting.com and for all the prayers from all the folks at www.all-creatures.org. We thank you all and are glad to unit with you and many others towards a better planet for generations to come.  Please join us!