I wish the thank the…

I wish the thank the Ministry of Natural Resources and Forestry for the opportunity to comment on proposal 019-1806. I fully support this proposal as it will significantly improve falconry in Ontario, and bring Ontario into much closer alignment with how falconry is managed in other jurisdictions as well as the science surrounding the insignificant impact of falconry on wildlife resources, including birds of prey.

No other jurisdiction in Canada or the United States has a limiting quota or draw for the 4 common species currently allowed to be taken by falconers. These birds have very large populations in the wild in Ontario. Most other states and provinces allow each falconer to catch up to 2 raptors per year, so the proposal by the MNRF, though a big improvement, is still very conservative. I wish to draw your attention to an assessment prepared by the California Department of Fish and Wildlife (attached) on the impacts of falconry in that very populous state: From 2006 to 2010 some 575 licensed falconers, which were legally allowed to capture up to 1150 raptors per year (2 each), in fact took on average 108 per year. About 55% of wild-caught birds were subsequently released, reducing the net impact even further. Based on these numbers the proposal will result in only a modest increase in the number of birds taken, but will result in a big increase in consistency and predictability for falconers. Most importantly it will allow all apprentices to start their apprenticeship with a wild red-tailed hawk which is far more suitable than most of the captive-bred and non-native alternatives.

I am also strongly in favour of making the change part of regulation and eliminating the need for a separate authorization. This will simplify the process for everyone and will also allow for the development of more clear and understandable regulations around the taking, possession and release of wild raptors.

In addition, as someone who has spent a considerable amount of time searching for and finding northern goshawk nests in southern Ontario, I am very pleased to see that the proposal includes provisions for the limited capture of goshawks. Allowing experienced falconers to access this widespread raptor will enable Ontario falconers to fly this iconic traditional species, which is often very difficult to obtain from captive sources. It will also encourage continued efforts by the falconry community to identify nest sites and work with conservation authority and county foresters in the application of provincial forestry guidelines for this species.

My only suggestion would be that since the proposal limits capture to one goshawk per MNRF district, why not allow for more than 5 districts to participate. Every year members of the Ontario Hawking Club locate goshawks nests in the 4 districts immediately surrounding the GTA, but there are 19 more districts further north than undoubtedly have viable goshawk populations as well. Why should the capture of a goshawk in Peterborough district reduce the ability of a falconer to capture one in Kenora district some 1300 kms away? I would suggest allowing up to 10 goshawks to be taken would still be very conservative and would have no impact on sustainability.