I am submitting these…

I am submitting these comments to voice my objection to proposal # 019-1806 which if approved would increase the number of wild birds of prey (red tailed hawk, coopers hawk, sharp shinned hawk and Merlin) that can be captured per year from the 25 to potentially 200+.

The proposal, if approved, would also allow for the capture of 5 Northern Goshawks per year.

I am personally opposed to this proposal for the following reasons;

In preparing my comments, I reviewed the Falconry page maintained on the Ontario Website at https://www.ontario.ca/page/falconry. This document outlines the birds of prey with secure, sustainable populations in Ontario that can currently be captured by licensed falconers (red-tailed hawk, coppers hawk, sharp-shinned hawk and merlin). The document goes on to state that “the list may be revised in the future based on new data and assessment of the status of bird of prey populations in Ontario”.

The current proposal does not provide members of the public with any new data or assessments of the status of birds of prey populations in Ontario which would justify the inclusion of the northern goshawk, even in the small numbers proposed.

I am currently involved in conservation programs focused on the American Kestrel. The American Kestrel was also a common and abundant species in North America but this bird of prey has been in serious decline since the 1960’s and the reasons behind this decline are still not fully understood.

Without detailed population level research into the four species currently allowed for capture as well as for the northern goshawk, it is not possible to tell if any of these species are also suffering long term declines or if, in fact, their populations are stable as stated in the proposal.

The proposal also does not provide justification for increasing the numbers of wild birds of prey that would result by allowing all 200+ licensed and apprentice falconers to capture one bird annually. What is the justification for proposing this increase at this time?

I believe that any rule changes that increases the number of wild birds of prey taken by falconers or adds any new birds of prey to the list of allowable species that can be captured must be fully supported by scientifically sound research available to all interested members of the general public of Ontario.

I do not believe that this proposal accomplishes this and, as such, I cannot support this proposal in its current form.

Thank you.