As a wildlife biologist with…

As a wildlife biologist with over 30 years of professional birding experience, I do not find that your proposal is justified or scientifically defensible. An 8-fold increase in the number of raptors taken from the wild is not necessary or prudent based on the information presented. The proposal states that the populations of species currently allowed are abundant and secure without providing any scientific evidence for this assertion. Recent observations indicate that most raptor species are experiencing steady declines in numbers. The third Ontario Breeding Bird Atlas, which will begin in just 3 months, will provide data to determine if additional wild raptors can be taken without jeopardizing populations or regional occupancy. Any decision on increasing the number of birds should not be made without those data.

The proposal seeks to add Northern Goshawk to the permitted species on the basis that populations are stable, again without providing any data on breeding pairs or habitat occupancy. The first two Ontario Breeding Bird Atlases documented population declines for this species. These data support increased protection for Northern Goshawks, not removal for falconry. As above, adding this species to the list should be postponed until the results of the third Ontario Breeding Bird Atlas indicate that the population is stable.