June 6, 2020

Kelly Hepler, Secretary
South Dakota Game, Fish and Parks Department
523 E. Capitol Avenue
Pierre, South Dakota 57501

Secretary Hepler:

Re: Friends of the Big Sioux River Comments on the River Otter Management Plan and de-listing the otter from its “threatened” status

Friends of the Big Sioux River is an organization working to improve water quality and clean up the Big Sioux River and other waterways in the Big Sioux watershed. We also work to increase people’s interest in the outdoors. The enhancement of wildlife habitat in the watershed is another objective. Our members and friends have removed barb wire fences, cleaned out trash dumps, planted countless trees, and pulled invasive species from buckthorn to garlic mustard to help improve the flora and fauna of South Dakota’s state parks.

This past weekend we organized a clean-up with the Big Sioux Recreation Area Park Managers, John Dummer and Luke Dreckman, to start the removal of tons of trash from a popular trail system in that recreation area that was damaged by two years of flooding. We are squeezing this clean-up in between the water quality monitoring we are doing in the Split Rock Creek watershed to help identify pollution sources which contaminate the creek as it flows through Palisades State Park. We have been doing water testing for several years at another fifteen sites, including state park access areas such as the Big Sioux Recreation Area and Newton Hills, as well as Lake Alvin and Lake Lakota.

We have tremendous respect for the work done by the South Dakota GF&P. We realize that without the state park system many residents in eastern South Dakota would have few places to enjoy nature. We also know that much of this work is accomplished on thin budgets, and that revenues are shrinking as fewer people are involved in hunting. It is important that GF&P recognizes a shift in people’s uses of the outdoors from harvesting wildlife to simply enjoying the experience of observing wild birds and animals. As our outdoor spaces shrink, and as our human footprint expands, more people are embracing wild animals as creatures that add beauty and fascination to their outdoor experiences. We believe that this is something future generations deserve to enjoy, as well.

There is no greater representation of the fascination and joy in observing wildlife than watching a river otter! The otter is an iconic symbol of river wildlife, and it also represents a species that is playful and communal and fun to watch. Unfortunately, it is difficult to observe them in South Dakota because there aren’t very many of them here. As you know, hunting, trapping and the degradation of waterways and wetlands obliterated our state’s otter population. By 1977, it was postulated that this species might be extinct in our state. Through the next several decades things did not improve, as sighting were extremely rare. Fortunately, the Flandreau Santee Sioux tribe introduced 35 otters on the Big Sioux River in Moody County in 1998 and 1999. Scientists have identified the Big Sioux River as possessing the best potential for otter habitat in the entire state.

We now know that from this group of otters introduced on the Big Sioux River have spread out and are now residing on three waterways in eastern South Dakota: The lower James River, the Vermillion River, and the Big Sioux River. By 2004, otter sightings in the entire state of South Dakota climbed to 22. By 2012, sightings rose to 46. This increase can be traced to the reintroduction efforts by the Flandreau Sioux tribe.

We note that a “sighting” might be simply observing scat or tracks or an otter slide in the snow, in addition to an actual animal sighting or finding an incidental catch by a trapper or an animal killed by a vehicle.

Two years ago, verified reports sightings of river otters in our state totaled 38. Last year that total reached 40. These are small numbers, to be sure. Considering how a “sighting” is defined, does this sound like a species that is comfortably rebounding in our state? Is this the level of population resurgence that warrants a de-listing of this species? We suggest that de-listing is not a reasonable step in the recovery of this species currently.

Your agency is making the claim that otters have reached a harvestable point. A spokesperson for your agency stated that improved conditions on waterways and wetlands make de-listing possible. We would argue the opposite. Wetland destruction continues, and water quality issues in waterways such as the Big Sioux River are worrisome. How successful is the state’s riparian buffer program? Habitat remains problematic. Otters continue to face major challenges caused by human beings. This de-listing adds to their challenges.

Your agency explained that for this species to be de-listed there should be confirmed reports of reproduction in three of the five watersheds within the species recovery area. Another factor, according to your agency, is that you need reports indicating satisfactory distribution. We note that over the past five years average sightings are only about 40 per year. We find this inadequate evidence that this species is prospering and no longer deserves to be protected under “threatened” designation.

Your agency’s new recommended management plan calls for an annual harvest of 15 otters per year. Already, 16 incidental otters are trapped each year. There may an increase in otter numbers in our state, but it is happening at a terribly slow pace.

The research done by your agency does not support a harvest and this move is premature. The question is why have a harvest season at all? Please consider the facts that:

• Otters do not destroy crops or harm any type of livestock.

• Otters do not create burrows. They mostly use other animal dens or burrows or downed
  trees for homes.

• They do not cut down and damage trees nor cause any flooding of property.

• Otters do not eat upland game bird eggs, so they do not hurt pheasant populations.

• There is no real economic reason for trapping otters.

Each year our organization teaches classes at water festivals for school kids, and we also teach classes at local schools. We lead off our presentation with a video of a river otter family frolicking as they live their lives. The children are curious where they can see an otter. Our answer is: “There may be some around the Flandreau area , but despite all the time we spend on the Big Sioux River and other rivers and streams in eastern South Dakota we have never seen one.” We also tell students that we could have more otters in our state if our state agencies would enforce and prioritize the implementation of clean water practices that would help otters thrive. Clean water is critical for otters, and our state has fallen short in monitoring water quality and enforcing water standards. That unfortunate situation has been well documented, with admissions by state leaders that funding to pursue clean water projects is scarce.

Friends of the Big Sioux River renamed its printed newsletter The Otter. We re-designed our logo to include an image of an otter. We did this because otters represent healthy rivers and waterways. We did it because it is an aspirational goal for our organization – we recognize that healthier waterways mean more otters. But only if otters are given a chance to thrive.

Rather than open otters to harvest and reduce protections for this important animal, we suggest your agency take steps to accomplish this following:

1. Restore clean water to our streams and lakes.

2. Require all landowners to implement riparian buffers on all lakes and streams.

3. Develop an otter monitoring program that accurately determines population
   thresholds in various watersheds.

We believe GF&P should recognize the advantage of drawing people to the outdoors by protecting the otter from any harvest. There are far more people and children who admire and appreciate the remarkable otter than there are who want to trap this animal.

We suggest that the general public disapproves your agency permitting the trapping of otters and de-listing them considering current numbers. We advise you to work on behalf of all the people in South Dakota who appreciate wildlife. They far outnumber those who wish to trap.

We believe it is premature to de-list the otter from its threatened status. Forty sightings through the entire state is hardly a reason to celebrate. It is, however, a reason to focus more attention on doing what it takes to restore otters to our landscape. Doing this sort of work is how an agency earns its keep. It’s what you should be doing. We urge you to reverse this decision.

Sincerely,
Travis Entenman
Director
Friends of the Big Sioux River