DLNR Proposed Wildlife Rule — Take Action Now

PUBLIC HEARING AUG. 13  |  WRITTEN TESTIMONY DUE AUG. 26
DLNR is proposing major wildlife-rule changes that go far beyond community cats.
See below for example testimony.
Comment: dlnr.hawaii.gov/dofaw/comment

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NEW: Why This Is Bigger Than Cats [read now]
Read the HAA Truth Sheet explaining the potential expansion of wildlife law and why it may affect ordinary Hawaiʻi residents.

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Community Cat Action & Testimony Guide [read now]
Detailed guidance on how the proposal could affect community cats, TNR, feeding, trapping, veterinary care and humane population management — plus sample testimony and sources.

Example Written Testimony

RE: Proposed Amendments to HAR Chapter 13-124

Aloha DLNR,

I support protecting Hawaiʻi’s indigenous, threatened, and endangered wildlife. I also support humane and effective management of Hawaiʻi’s community cats.

I am concerned that the proposed amendments to HAR Chapter 13-124 may go beyond implementing existing state law and may unintentionally interfere with effective community-cat population management.

DLNR cites HRS §195D-3 as authority for extending wildlife “take” protections to indigenous wildlife. At the same time, HRS §195D-2 expressly defines “take” in relation to endangered and threatened species. I respectfully ask DLNR to explain whether §195D-3 authorizes this broader expansion through administrative rulemaking.

I am especially concerned that feeding or managing a community cat could potentially be characterized as indirectly harming wildlife without sufficient evidence connecting the caretaker’s conduct to an actual wildlife injury or death.

Feeding a cat is not itself bird predation.

A theoretical chain such as:  feeding → cat → possible hunting → possible wildlife injury  should not automatically become the equivalent of proven wildlife take.

Causation and evidence matter.  Actual injury, foreseeability, proximate cause, and the applicable mental-state requirement matter as well. 

I am also concerned about what happens to existing cats if feeding is prohibited.

Stopping food does not make cats disappear.  Without sterilization, monitoring, adoption, abandonment prevention, and a humane transition plan, cats may simply roam farther, migrate into surrounding neighborhoods, become harder to trap, and become increasingly unmanaged.

I also ask DLNR to consider the Legislature’s previous consideration of aggressive statewide cat-removal legislation in 2022. That proposal did not become law.

DLNR should therefore clearly explain whether the current rules could be used to facilitate removal or lethal control of free-roaming cats and identify the specific statutory authority for any such program.

I respectfully request that DLNR revise the proposal to:

  • protect trapping, sterilization, veterinary treatment, and approved community-cat management;

  • distinguish managed cats from unmanaged populations;

  • provide humane transition plans for existing cats;

  • clearly define the evidence and causation required for wildlife harm or take;

  • and ensure that administrative rules remain within the authority granted by the Hawaiʻi Legislature.

We can protect Hawaiʻi’s wildlife while also using humane, science-based animal population management.

Mahalo for considering my testimony.

Example Two-Minute Oral Testimony

Aloha, and mahalo for the opportunity to testify.

I support strong protection for Hawaiʻi’s indigenous and endangered wildlife. But I am concerned about whether the Legislature actually authorized this particular expansion of “take,” “harm,” and “harass.”

I am especially concerned about community cats.

Feeding a cat is not itself a wildlife take.

There is a major difference between proving that someone injured or killed protected wildlife and assuming that because someone feeds a cat, that cat may someday hunt and therefore the person has harmed wildlife.

Causation and evidence matter.  The public should know what DLNR must prove before indirect conduct becomes wildlife “harm” or “take.” 

I am also concerned about what happens when feeding is prohibited at an existing colony.

Stopping food does not make cats disappear.

Effective population reduction requires sterilization, abandonment prevention, adoption, monitoring, and managed transition. Without those tools, cats may simply disperse and become even harder to manage.

The Legislature has also previously considered aggressive statewide cat-removal legislation and did not enact it. DLNR should tell the public plainly whether these rules are intended to facilitate removal or lethal control of community cats and identify the statutory authority for doing so.

I ask DLNR to revise these rules to protect legitimate wildlife interests while preserving humane, science-based community-cat management and staying clearly within the authority granted by the Legislature.

Mahalo.

Important To Make Your Testimony Personal

Please do not simply copy the example testimony word-for-word.

Your own experience matters.

Consider adding one or two sentences such as:

  • “I have cared for community cats for ___ years.”

  • “The cats at our location are sterilized and monitored.”

  • “I have personally helped trap and sterilize cats in my community.”

  • “I have seen what happens when cats are abandoned.”

  • “I care deeply about both native wildlife and animal welfare.”

  • “I support reducing free-roaming cat populations through humane, effective management.”

  • “I believe Hawaiʻi can protect wildlife without abandoning humane treatment of animals.”

  • “I am concerned about rules that make it difficult for ordinary people to know where legal responsibility begins and ends.”

Individual testimony carries more weight when it reflects your own experience and concerns.

 

Speak Up Now!

For the broader implications of the proposed expansion — including impacts involving dogs, driving, property use and ordinary daily activities — see HAA’s companion DLNR Wildlife Rule Truth Sheet: Why This Is Bigger Than Cats. 

Please know these rules could have long-term consequences for community cats, caretakers, humane animal-management programs, and the interpretation of wildlife law across Hawaiʻi.

This is not simply about feeding cats.

It is about:

Humane population management, wildlife protection, evidence, legal authority, and what kind of animal policy Hawaiʻi chooses to follow.

Cat and animal supporters should review the proposal, submit written testimony, and participate in the public hearing.

Public Hearing: August 13, 2026
Written testimony deadline: August 26, 2026