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Deadline to Submit Written Comments to SDGFP Commission for their September mee

August 31 @ 11:50 pm - 11:59 pm

On Sept 4th the Commission voted to approve the proposed season, as recommended by staff.

Deadline to Submit Written Comments to SDGFP Commission for their September meeting was  just before midnight  MT on Sunday August 31st,  Late comments are given to the Commissioners  next month.

Opponents to the Season got the most comments in – we achieved 69% of the comments. See report – https://phas-wsd.org/wp-content/uploads/Report-on-Comments.SDGFP_.CougarsSept25.pdf

Here is a link to the “short” comments sent to GFP

https://phas-wsd.org/wp-content/uploads/Short.public-comments.-September_Commission_Book-2.pdf

The file for the “long” comments – the formal letters is too large to put in the library but here are links for two of them- those of  Prairie Hills Audubon Society and Humane World for Animals (HSUS)

https://phas-wsd.org/wp-content/uploads/August-mt-Lion-comments.pdf

https://phas-wsd.org/wp-content/uploads/Humane-World-Mountain-Lion-Proposal-Comments-Aug-2025.pdf

Later I will attempt to divide the too large file and post all public comments here. You can find them in the Commission Book for September at the end.  You can find the Commission book on the “Current meeting page” Go to our calendar date for the Hearing Sept 4-5th for such details.

SCROLL DOWN THIS PAAGE FOR DISCUSSION OF ISSUES and Talking points.

HOW tO COMMENT

SDGFP has a public commenting web page https://gfp.sd.gov/forms/positions/

You go to this page &  type in required address info and indicate you oppose the “Mountain Lion Season” rule on the “Position Comment” drop down section . That is enough- call up a friend and get them to check “oppose” also. Getting lots of comments in opposition helps us to win.   It  is best if you  also type in some comments or attach a formal letter.

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A. Commenters can comment on the entire mountain lion hunting season rule – in its’ entirety.

B. Or commenters can just oppose the new changes to the  season  for the next two years – they proposed an  increase in areas  folks can hunt mt. lions with hounds in the Black Hills.  


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LONG TERM PHAS OBJECTIONS TO SD MT. LION HUNTING RULE, Over many years:

We have always opposed “recreational” hound hunting of mt. lions anywhere in SD – this  amendment just increases the area covered by hound hunting and likely the number of lions taken via  hound hunting. Now hound hunting is allowed in Custer State Park (CSP) and the prairie unit. If they institute proposed changes it will be allowed in an expanded subset of the Black Hills Fire Protection District (beyond CSP)

We have always opposed the 375 day unlimited hunting (no harvest caps) ,  on the prairie – both on private and public land.  We want the prairie area broken into subset units with harvest caps and season time limits. We want SDGFP to cooperate with tribes, when there is mixed jurisdictions in areas of confirmed cougar breeding or residency.

We have always opposed the current  Black Hills Fire Protection District (BHFPD) harvest caps  as too high (60 either sex/40 females). Hunters in recent years have not meet harvest caps before the time limit closes the season.  Overly aggressive hunting results in “conflict lions” as the hunting  replaces older experienced males with younger inexperienced males. Mt lions remove ungulates with chronic wasting disease – they don’t catch it themselves and they remove most of the prions (don’t defecate most of the prions back out).

The mt. lion is a keystone species, we want SD cougars managed for the benefits to  biodiversity they provide. We want all locations with suitable habitat to be managed for viable breeding populations and hopefully as source populations from which cougars emigrate to areas they have been extirpated from.

SD GFP should not manage for one type of wildlife related recreation over another – non-game, non-consumptive users (wildlife watchers) should be equal to consumptive users (hunters/trappers). We don’t want SD to manage our cougar population for a goal of maximizing the opportunities of hound or boot hunters, as is required  in SDGFP’s current  Mt Lion Action Plan.

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Problems with NEW AMENDMENTS
This alert now focuses on PROBLEMS WITH PROPOSED NEW CHANGES

SDGFP is proposing a rule change to allow hound hunting of mt. lions in  southern and southeastern areas of the Black Hills Fire Protection District (BHFPD).

The Commission proposed to increase the unit size, where hunting with dogs is allowed in the Black Hills Fire Protection District (BHFPD), to grow beyond Custer State Park (SEE MAP ABOVE). The Commission proposed to expand the season dates for hunting intervals, that allow the use of dogs in BHFPD.

Hunting mountain lions in the designated area with the use of hounds will be allowed for a total of fifteen individuals with
access permits, provided the harvest limit has not been met. Three access permits will be issued in each of five 21-day intervals, starting December 26, provided the harvest limit has not been met. The proposal would eliminate the requirement for access permits to hunt mountain lions in Custer State Park without the use of dogs.

Hyperlink to the  proposed rule change (hunting season that will be voted on on 9/4/25 –   https://phas-wsd.org/wp-content/uploads/Mtlion-proposal.-July_Commission_Book-2.pdf

Go to Sept 4th post about the meeting for details or post about July 10-11th SDGFP Commission meeting.

BELOW FIND OUR ACTION ALERT ON THIS RULE CHANGE – scroll past other NGO alerts

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Other NGO Alerts:

The Black Hills Mountain Lion Foundation opposes this rule change also. (It is a new corporation, under new leadership – the old BHMLF died about 2003)  You can read their action alert that opposes these changes https://blackhillsmountainlionfoundation.org/Action

South Dakotans Fighting Animal Cruelty Together have an alert on

their Facebook page:

https://www.facebook.com/photo?fbid=1195198405967545&set=a.319919470162114

Humane World for Animals (HSUS’s new name) sent out an alert by e-mail:

https://phas-wsd.org/wp-content/uploads/Take-action-to-protect-South-Dakotas-mountain-lions.pdf

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PHAS ACTION ALERT ON PROPOSED RULE CHANGE:

PHAS opposes the rule change and asks folks to send in comments against such change. Link to PHAS’s talking points against hound hunting –  https://phas-wsd.org/wp-content/uplo change was coninuted ads/Hound-hunting-objecstions.pdf

Some areas of concern are:

  1. Hound  hunting does not allow for “fair chase”, it increases risk of trespass, it results in animal cruelty to dogs and cougars and many members of the public object to it, especially in the Black Hills. It will result in more commercialization of hunting.
  2. This increase in hound hunting will result in more female lions and lions of either sex being killed and will result in a decreasing  lion population and eventually cause SDGFP to lower the cougar harvest cap, because the population will drop below the SDGFP population objective. Mt lions are a keystone species and important to biodiversity – less lions reduces their positive function on the landscape.
  3. Overly aggressive cougar hunting destabilizes cougar populations and thus results in more “conflict lions”.  Older males are less likely to be “conflict lions” than young males: when you kill an  older male you replace him with more younger males, who are not as experienced & more prone to conflict with humans.  See Rob Wielgus’s video at https://mountainlion.org/wp-content/uploads/2021/01/WA-R-Wielgus-2015-PPT-Effects-of-Sport-Hunting-on-Cougar-Population-Community-and-Landscape-Ecology-HSUSconf.pdf
  4. Unfairness – Black Hills Mountain Lion foundation on their web site, says – “Only 3% of lion hunters use hounds, yet they already take 35% of the harvest” – we assume they mean in CSP, the Black Hills or in all SD, but it is not totally clear where this happens and in what time period.  We see SD hound hunters getting 24%, on average, of cougar kills in all SD during the last 5 years (14/58).  Prairie and CSP units  averaged 7 lions/year /each.   — “Boot hunters” and hound hunters compete for the same mt. lions, but lions are elusive and hound hunters are much, much more effective.   The hound hunters persistently petition and ask for more areas that will allow them to hunt mt lions with hounds.  They have been allowed to hunt in Custer State Park (as of about 2012) and unlimited hunting on the prairie unit for 365 days of the year. Recently (April 2025) the restrictions on hound hunting on public land on the Prairie Unit  have been removed. . Increased use of hound hunters will likely lead to more commercialization of hunting, with boot hunters hiring guides with dogs.
  5. PHAS wants the Black Hills Population managed as a source, or at least a stable population, not a sink.  Black Hills lions likely contributed to recovery of mt lions in North Dakota and Nebraska and on tribal lands of Oglala & Rosebud Sioux Tribes  and 3 Affiliated Tribes (ND). Now breeding lions have been confirmed in Oklahoma. They are also recovering in at least one new Canadian Province.  Mountain lions historically  occurred in all  lower 48 states but have been extirpated from most mid-west and  the eastern ones, except Florida. – Let SD Black Hills contribute to recovery of cougars in the midwest and east
  6. This proposal is not consistent with the Mountain Lion Action Plan adopted in  Fall 2024 https://gfp.sd.gov/UserDocs/nav/Lion_Action_Plan_2024.pdf      –  at Objective 2 (b)   Quote from the Action Plan Objective 2(b)  is in italics:       “Modify and adopt hunting season structure as needed to minimize regulation complexity:                                                                                                                                                                                                      In the Black Hills Fire Protection District (BHFPD), excluding Custer State Park (CSP): maximize hunting opportunity for unique hunters allowing unlimited boot hunting with harvest regulated primarily through restricted season lengths and harvest limits.                                                                                                                                                                                                                                                                         *In CSP: maximize hunting opportunity for hunters with dogs with harvest regulated primarily through limited permits and restricted season lengths.                                                                                                                                                  * Outside BHFPD: emphasis to minimize potential human conflicts with mountain lions and maximize hunting opportunity for hunters with dogs allowing unlimited permits and a year-round season. “

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SDGFP has a public commenting web page https://gfp.sd.gov/forms/positions/ –  Go here to submit comments

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You must submit written comments before midnight on Sunday August 31st. As the meeting on Thursday is in Mountain Time Time Zone the deadline should be midnight, but if GFP has not reset the Artificial Intelligence thcy could cut it off, illegally , in violation of the law, at midnight CT.  You should be against the proposed changes – you don’t have to write anything – there is a form to fill out and  you can just check against or oppose, but writing a sentence or more helps, as they then know why you oppose the rule change.  You can also attach files if you want to write a formal letter.

You can testify in person in Rapid City, SD or by Zoom on Sept 4th at 2 pm, if wanting to testify, it is requested that you register with Gail Buus <Gail.Buus@state.sd.us> in advance, but that is not required.  Go to our Sept 4th post for details – https://phas-wsd.org/event/sd-game-fish-and-parks-september-commission-meeting-hybrid-meeting-in-rapid-city-zoom/

Go to our July 10-11th event calendar’s page on July Commission hearing and Sept 4-5th events page on Sept Commission meeting. We have an alert page on mt lions https://phas-wsd.org/cougar-alert/and if you go to that page you can learn of past  (and future) opportunities to comment on cougars in SD, NE, Wyoming and ND.

There is an August 20th deadline  (12 pm MT) for commenting on Nebraska’s 2026 cougar hunting season (see our 8/20/25  https://phas-wsd.org/event/deadline-for-written-comments-to-nebraska-gp-commissions-august-meeting/  , and 8/22/25 calendar pages  https://phas-wsd.org/event/nebraska-game-and-parks-commission-meeting-8-21-8-22/

Details

  • Date: August 31
  • Time:
    11:50 pm - 11:59 pm
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