I study wildlife, including…

ERO number

019-1806

Comment ID

48570

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Individual

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Comment

I study wildlife, including raptors and have found falconers to be great asset to understanding raptor biology and conservation. This is a group of hunters tied to the landscape and spend a great deal of time in the field and are often the first to see sign of problems in our environment and birds they love so much.
I am concerned with the limits in the current policy as they are very restrictive and few applicants for birds get birds. That means less individuals connect with the landscape they love. These regulations are especially problematic for apprentice falconers who do not yet have a bird. Passage (wild-trapped) red-tailed hawks are superior birds for an apprentice for many reasons. Losing out on the draw often means waiting another year.
No other jurisdiction in North America has a hard limit or quota on the 4 species currently allowed. The capture of these species in self-limiting and all recent research indicate that it is sustainable, inconsequential to populations, and requires very little monitoring (Millsap 2006, USFWS 2007; Millsap and Allen 2010). There is no biological reason for a draw for these species. These species should be open for falconry harvest. If wildlife folks are concerned with raptor take, they should use established science to create legitimate limits. The management recommendation established by Millsap and Allen (2010) are well thought out and create a strong framework to build biological meaningful management plans.
I have worked with goshawk nest site locations and density in Montana, Utah, Idaho, and Alaska in the United States. I also have access to data for nest site location and density in parts of the Ontario region. The nest density is at least as great as sites I have studied in the Unites States. Since the northern goshawk is not a species at risk or under review by COSEWIC or COSSARO. It is a widespread species. The population are stable and may be increasing in the Great Lakes region (Farmer et al, 2008). I would professionally suggest that the proposal is very conservative and the take should be adjusted to increase the take number.
In summary, I support the proposal to expand the capture of raptors for falconry. It is environmentally sustainable and provide much greater certainty to falconers, dramatically improve apprenticeship and thus the overall quality of falconry. Equally important, it will strengthen and sustain active conservation by falconers.