RE: Environmental Registry…

RE: Environmental Registry of Ontario Proposal 019-9441

The Ontario Hawking Club (OHC) was formed in 1984 to promote the recognition of falconry and enhance the standards of practice. The OHC is the largest falconry club in Canada, with approximately 100 members. As such, we have a vested interest in the administration of the rules and regulations surrounding the sport, including the mechanics of the issuance of falconry permits.
In principle, we support the modernization of the licensing process and offer the following feedback:

1. Digital access to purchase and display licence products would be very convenient.

2. No mention is made of commercial falconry licences. There is a complete lack of information as to how the proposed changes would affect a commercial falconry licence.

3. The OHC does not support that "eligibility requirements for a general falconry licence would change 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)." The are several reasons for our concern, including: potential changes to laws and fading skills over an extended absence from active practice. Also, after an extended absence equipment will have to be re-acquired and facilities rebuilt. Requiring an applicant to find a sponsor and re-apprentice after an extended absence from falconry 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 early 20’s to re-acquire a license, 40 years later, in their 60’s 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 issuing a license. However, we do agree that the current limitation of 5 years is unnecessarily restrictive. We would support increasing this time limit to allow issuing a general or commercial falconry licence to a person that has held that license in Ontario at any time in the past 10 years.

4. Re: "The general and apprentice falconry licences would be listed as line items on a client’s licence summary rather than separate licence documents.” Our only concern with this is that is that falconers who transport their birds out of province and/or into the USA for hunting need to have clear licence documentation to meet interprovincial and international requirements. Any new system must show printable licences clearly and with great specificity.

5. Re: General and apprentice falconry licence holders would be required to submit their annual report online through the licensing system by December 31st of the year in which the raptors were kept (instead of the current requirement of January 31 the year following). The OHC sees this as problematic. December 31 is the middle of the hawking season for most Ontario falconers. If the permits expire on Dec 31, there is no grace period to complete paperwork and we risk hunting without a permit. We suggest that the expiry date for permits be established as March 31, the end of the hunting season, and a 30 days grace period is permitted (to April 30) during which paperwork can be submitted. In this manner, falconers begin and end the hunting season with proper documentation.