I am opposed to the proposal…

I am opposed to the proposal to exponentially expand the capture of wild raptors.

The proposal states:
" The four common species that would be taken by falconers as part of their falconry licence are all abundant with secure populations" yet provides no evidence to support the claim. In fact there is abundant evidence that wild raptor populations are actually experiencing a decline. From the Ontario Federation of Ornithologists - "In fact, current observations from hawkwatch sites indicates that most raptor species are experiencing a steady decline in numbers." The MNRF has not undertaken any scientific study of wild raptor populations while organizations dedicated to such studies have provided factual evidence that runs contrary to the ministry's claims.

The ministry has provided no reason whatsoever for such a huge increase in the take of wild raptors. From the current 25 wild captures per year to eight times that number without providing any justification. Without a legitimate need or scientific reason for the increase the proposal should be withdrawn. In fact greater limits should be placed on falconry. Apart from a very few scenarios, namely the protection of air travelers at specific locations there can be no justification for continuing this antiquated practice.

Likewise the specific proposal to include Northern Goshawk for the firs time states: "The northern goshawk population in Ontario is secure". In fact the last two Breeding Bird Atlas suveys show strong evidence of a population decline for this species. The Minister has failed to provide any evidence to support this claim or sponsored any scientific studies on Ontario's Goshawk populations and the sustainability of expanding the wild capture program.

The proposal does not include any form of monitoring or means of assessing impacts on wild raptor populations. No description of criteria required to obtain a license to capture wild raptors has been provided other than being a "licensed falconer".

Given the obvious lack of scientific rigor in this proposal the Ministry must wait until supporting evidence becomes available. The third Ontario Breeding Bird Atlas survey is due to begin in just a few months. It will, when completed, provide a much clearer understanding of current raptor populations and the dubious sustainability of the proposed expansion of wild raptor captures. A delay in moving forward with this proposal will harm no one while errors made in haste and without scientific credibility may cause lasting or permanent harm to wild raptor populations, Northern Goshawks in particular.

This proposal must be withdrawn.