I am opposed to the proposal…

I am opposed to the proposal as currently described to expand the capture of wild raptors for falconry in Ontario. I am not opposed to the practice of falconry or use of raptors as working birds to manage "pest birds" at airports; however this proposal risks harm to wild bird populations without providing sufficient rationale for the necessity of expanding the live capture of wild raptors in Ontario.

I am opposed this proposal for the following reasons.

1. While I am not opposed to the practice of falconry and use of raptors as working birds, there is no justification proposed for the need to increase wild capture to support these activities. Why is
such a large increase – from 25 birds per year to 200+ justified?

2. The proposal states that the population of species allowed for capture: Red-tailed Hawk,
Cooper’s Hawk, Sharp-shinned Hawk and Merlin are abundant and secure populations. There is
no evidence presented for this assertion. In fact, current observations from hawkwatch sites
indicates that most raptor species are experiencing a steady decline in numbers. I
recommends waiting for the results of the third Ontario Breeding Bird Atlas in 2025 to
determine if the increase in taking wild raptors can be accomplished without damaging wild
populations overall and in specific regions.

3. The proposal does not explain how impacts on wild populations are assessed or how the capture will be monitored.

4. The proposal states that Northern Goshawk populations are stable without providing any basis
for this assertion. The first two Ontario Breeding Bird Atlases documented population declines
for this species. I cannot support adding Northern Goshawks to the allowed capture list
unless the results of the third Ontario Breeding Bird Atlas indicate that the population is stable.

5. The social benefit for this proposal is not justified. I support the practice of
falconry, but there is no justification provided for the need to increase the capture of wild birds
or how falconry in Ontario will suffer if the take remains as it is currently at least until
populations can be assessed with information from the third atlas.

I strongly urge the MNRF not to proceed with this proposal.