Public Input Coordinator…

Public Input Coordinator
MNRF Fish and Wildlife Policy Branch – Wildlife Section
300 Water Street
5th Floor, North Tower
Peterborough, ON
K9J 3C7
Canada

September 14, 2020

Re: ERO # 019-1806: Proposal to expand the live capture of wild raptors (birds of prey) by licensed falconers

Dear Sir or Madam,

On behalf of the 115 members of the Ontario Hawking Club (OHC) I would like to thank the Ministry of Natural Resources and Forestry for the opportunity to comment on this proposal to expand and update access to wild raptors by licenced falconers. Since our founding in 1984 the Ontario Hawking Club has been affiliated with the Ontario Federation of Anglers and Hunters and we work in close partnership with them as strong advocates of responsible falconry regulation and high standards of practice. We fully support the policy outlined in ERO #019-1806.

The MNRF decision in 2011 to allow the capture of wild raptors has had an enormously beneficial and transformative impact on falconry in Ontario. Birds that were previously unavailable have opened up new and exciting forms of this ancient art. The ability to interact with wild raptors has resulted in a much higher level of involvement in and understanding of wildlife resources and also promoted the development of greater skill and proficiency in the handling of birds of all types.

Unfortunately, the limits in the current policy mean that every year less half of applicants are selected in the draw and have an opportunity to share in the policy’s benefits. This is particularly troublesome for apprentice falconers who do not yet have a bird. Passage (wild-trapped) red-tailed hawks are superior birds for an apprentice for many reasons. Losing out on the draw often means waiting another year to start their apprenticeship or accepting an alternative captive-bred bird that is often much less suitable. For general falconers the odds of being selected in the draw are usually less than 50% which makes planning for an upcoming hunting season very difficult. Also, since there is less certainty and applications must be made far in advance, many falconers apply pre-emptively even if they are not sure a bird will be required. This results in more applicants than would otherwise be the case and in part explains why only 60% of permits are typically filled.

No other jurisdiction in North America has a hard limit or quota on the 4 species currently allowed. The capture of these species in self-limiting and all recent environmental assessments indicate that it is sustainable, inconsequential to populations, and requires very little monitoring (Millsap 2006, USFWS 2007). The Ontario Hawking Club strongly supports the elimination of the draw for these species.

In recent years there have been between 55 and 60 applicants for the draw. With the proposed change we anticipate that approximately 45 falconers actually attempt to capture a wild raptor per year as the backlog of unsuccessful applicants is eliminated. The overall result will be only a slight increase in the number of birds taken, but a very large increase in the effectiveness and benefits of the program. All apprentices will be able to gain experience trapping their own bird. In addition, falconers will be able to release their bird back to the wild at the end of the hunting season, if they desire, knowing that they will be able to trap a new bird for the next season. Releasing birds this way has been practiced for thousands of years and is an important part of the sustainable tradition of falconry. In addition, we support including the provisions for capture in regulation as this will provide greater clarity, visibility and enforceability of requirements for the capture and subsequent use of wild raptors.

The size, speed and striking appearance of the northern goshawk have given it a special place in the literature and traditions of falconry. It remains a very important bird to falconers today because of its suitability to the quarry, terrain and climate of Ontario. We are therefore very pleased that the proposal includes a careful and extremely modest provision for the capture of a limited number of goshawks.

The northern goshawk is not a species at risk or under review by COSEWIC or COSSARO. It is a widespread species present in all but the most heavily urban or agricultural areas of Ontario. The population appear to be stable or increasing in the Great Lakes region (Farmer et al, 2008). The Ontario Breeding Bird Atlas showed significant increases in the south and central Ontario (Bush 2007). Furthermore, all other provinces with legal falconry (NS, QC, MB, SK, AB, and BC) allow falconers to capture goshawks. In most of these jurisdictions the goshawk is not given special consideration relative to other raptors. Falconers may also capture goshawks in northern U.S. states.

Since 2012 the Ontario Hawking Club has documented 55 active goshawk nests sites in the MNRF Districts of Guelph, Aurora, Midhurst and Peterborough. We have shared this information with county and conservation authority foresters and cooperated with them in the development or modification of forest stand management plans in keeping with provincial forestry guidelines for active goshawk nests. By allowing a limited capture of goshawks the MNRF will be fostering conservation and encouraging the on-going collection of nesting data and cooperation of this type.

Given that there are 26 MNRF districts, many of which have considerably more suitable habitat for goshawks then the 4 we have explored thus far, we believe that the proposed limit of 5 birds is very conservative. We are therefore pleased to see an explicit recognition in the proposal that the limit may be adjusted as more data becomes available.

In summary, we are very pleased to support the proposal to expand the capture of raptors for falconry. We believe that it is in complete alignment with the MNRF’s strategic goal of “protecting Ontario’s biodiversity while…supporting outdoor recreation opportunities”. It is environmentally sustainable and will result in only a small increase in the number of birds taken while reducing administrative overhead, providing much greater certainty to falconers, dramatically improve apprenticeship and thus the overall quality of falconry. Equally important, it will strengthen and sustain active conservation efforts by falconers.

Sincerely,

Louise Engel
President, Ontario Hawking Club

 
References:

Bush, P.G. 2007a Northern Goshawk pp. 178-179 in Cadman, M.D. 2007, D.A. Sutherland, G.G. Beck, D. Lepage, and A.R. Courturier, eds. Atlas of the Breeding Birds of Ontario, 2001-2005, Bird Studies Canada, Environment Canada, Ontario Field Ornithologists, Ontario Ministry of Natural Resources, and Ontario Nature, Toronto

Farmer, C.J., L.J. Goodrich, E. Ruelas Inzunza, and J.P. Smith. 2008. Conservation status of North America's birds of prey. Pp. 303-419 in K.L. Bildstein, J.P. Smith, E. Ruelas Inzunza, and R.R. Veit (eds.), State of North America's birds of prey. Nuttall Ornithological Club, Cambridge, MA, and American Ornithologists' Union, Washington, D.C.

Millsap, B. A. and G. T. Allen. 2006. Effects of Falconry Harvest on Wild Raptor Populations in the U.S.: Theoretical Considerations and Likely Consequences. Wildlife Society Bulletin 34:1392-1400.

U.S. Fish and Wildlife Service. 2007. Final environmental assessment: Take of raptors from the wild under falconry and the raptor propagation regulations. U.S. Fish and Wildlife Service, Arlington, VA.