The North American Falconers…

The North American Falconers Association (NAFA) has been promoting the conservation of raptors and their responsible use in falconry since 1961. NAFA is the world’s largest membership-based falconry organization, and represents falconers across the United States and Canada. On behalf of our Ontario members, we thank you for the opportunity to comment on Ontario’s plans to modernize fishing and hunting licensing.

The administrative procedures in Ontario falconry regulations related to banding, permitting, record-keeping and reporting are amongst the most simple and effective in North America, without compromising conservation objectives. We commend the MNRF for this and, overall, we support the additional improvements contained in the proposal to modernize falconry licensing. We offer the follow specific comments and suggestions:

1. The integration of mobile technology and digital access to licence products will be a very welcome improvement over the current printed licences that falconers must carry. We fully support these improvements.
2. When falconers travel to the United States or other provinces (e,g. Saskatchewan) to hunt with their birds, they are typically required to provide proof that they are licensed falconers in Ontario in order to qualify for the required import/export and non-resident falconry permits. Therefore, we support the listing of the falconry licence on the licence summary provided that the summary is printable or available as a PDF, and is clearly an official government-issued document indicating the falconer’s licensed status.
3. NAFA does not support modifying eligibility requirements for a general falconry licence “to allow issuance to a person if they held a general falconry licence or a commercial falconry licence in Ontario at any time (rather than only in the previous 5 years)." Over an extended period, there can be changes to laws and standards of practise as well as fading skills. Also, after an extended absence equipment will have to be re-acquired, and facilities rebuilt. Requiring such an applicant to find a sponsor and re-apprentice would enable the sponsor to fill any knowledge gaps and perform the important role of inspecting equipment and facilities. The proposed change would eliminate this step, and would effectively allow someone who had practiced briefly in their youth re-acquire a license decades later, without any need to update their skills, have their facilities inspected, or re-connect with the falconry community. Therefore, we do not support completely removing the time limitation on re-issuing a license. However, we do agree that the current limitation of 5 years is unnecessarily restrictive and we would support increasing the time window to 10 years.
4. We are concerned that requiring apprentice and general falconers to submit their annual report concurrent with their licence renewal, before the end of the year, will create a paradoxical situation in which they need to submit an “annual report” before the end of the year the report covers. At this very busy time of year, it is not practical or possible for everyone to complete their annual report and renew their licence on December 31st. If they renew before then, however, there is the possibility that the report submitted with their renewal will no longer be accurate by December 31st. We suggest extended the falconry licence validity and renewal period to January 31st, or providing a method for falconers to amend their annual report after December 31st if necessary.

In addition to the improvements in the proposal, we would also like to suggest an additional simplification to the regulations related to visiting non-resident falconers. We suggest removing the current requirement for visiting falconers to submit a letter of application the MNRF and obtain a de facto permit for the district(s) they will be hunting in (O. Reg. 668/98 Sec 23.1-23.3). Instead, the province would simply recognize the falconer’s licence from their jurisdiction of residence. Most U.S. states operate this way, and only require visiting falconers, including those from Ontario, to purchase a non-resident hunting licence.