To Whom It May Concern: RE:…

ERO number

019-1806

Comment ID

48858

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Individual

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To Whom It May Concern:
RE: ERO # 019-1806: Proposal to expand the live capture of wild raptors (birds of prey) by licensed falconers

Falconry is an ancient tradition that has existed virtually unchanged for many thousands of years. Its origins lay in ancient civilizations throughout the Old World, and it remains a vital hunting heritage to modern cultures worldwide, across Canada, and in Ontario. The practice of capturing and training a wild bird as a hunting companion is a unique form of hunting, an exception to the way humans and wildlife interact, and is entirely valid and sustainable.
I have been a practicing falconer since 2004, and am a lifelong conservationist. I am a member of the Ontario Federation of Anglers and Hunters, as well as the Ontario Hawking Club. I earned my undergraduate degree in Environmental Studies from the University of Waterloo, and have been employed in the environmental conservation sector since 2002.
I personally fully support the proposal to expand the live capture of wild raptors by licensed Ontario falconers. Until very recently, and as a result of experimental captive breeding of peregrine falcons that was in many respects pioneered by falconers, the only source of raptors for falconry was to capture live birds. Raptors are opportunistic predators that quickly adapt to an easier and regularly abundant food source as a humans’ hunting partner, which is why falconry has continued through millennia. This exemplifies a sustainable relationship with nature.
With respect to Goshawks – it does not make sense to limit the available permits by district.
• Goshawks are a forest hawk, and their presence is likely not equally distributed across MNRF administrative districts.
• Goshawks are not an appropriate bird for a falconry apprenticeship, and they are more difficult to locate and capture, so the fill rate for these permits will be relatively low.
• Falconers who are both skilled and interested in capturing a Goshawk are probably not evenly distributed according to MNRF administrative districts. Limiting the issuance of permits by district will result in inequitable access to falconers in Ontario.
In order to avoid inequity, and unnecessarily restricted access to Goshawks, I suggest not limiting the issued permits by district, and also issuing a higher number of permits in consideration of a low capture rate.
It’s incredibly unlikely that capturing wild raptors for recreational (non-commercial) falconry could ever lead to a valid conservation concern. Falconers in Ontario, on the continent, and around the world, have demonstrated a commitment to conservation through a myriad of dedicated science-based conservation. Having a robust, transparent and equitable process for tracking annually tracking the number of permits issued, how many are filled, how many birds are released, which species and in which districts, would support the assertion that falconry is sustainable, and that the MNRF is managing this activity using the best available information.
Thank you for the opportunity to comment.

Sincerely,
Ontario Falconer