Monday, March 30, 2009

Letter from Wild Raptor Take Conservancy on Florida Peregrine Delisting

Peregrine Falcon Management Plan Comments
Florida Fish & Wildlife Conservation Commission, Northeast Region
1239 SW 10th St.
Ocala, FL 34471-0323 March 24, 2009

To whom it may concern:

WRTC would like to congratulate FWC for its support in protecting peregrine
populations when it was in need of protection, and the current effort in de-listing this bird – an
excellent example of the success of the Endangered Species Act. The peregrine populations are
now substantially above the de-listing mark established by the Fish & Wildlife Service. It is
through the joint efforts of public and private forces that real change can be accomplished.
We would like to point out that many people are not aware of the fact that falconers
were the first to recognize the problem and took an active role in establishing the listing of the
anatum peregrine as endangered. In addition, many people are not aware of the fact that it
was falconers who discovered the means to breed peregrines in captivity and who released
them back into the wild with the monetary support of State wildlife agencies and donations
from citizens and falconry clubs.
An important point to be aware of: Throughout the 1930s, 40s and 50s when wildlife
managers and the birding community saw nothing wrong in shooting or pole trapping
raptors, falconers were speaking out against their destruction (it was the falconer Jim Rice who
first went to Hawk Mountain – before Mrs. Edge bought the property and turned it into a
sanctuary in 1934 – with Boy Scouts to stare down those who were shooting hawks, making
them so uncomfortable that the shooters would leave: Source, Robert Berry of the Peregrine
Fund and Brian McDonald, zoologist). Wildlife managers saw raptors as competitors to
hunters in their pursuit of upland game and waterfowl and therefore shot raptors – including
peregrines – on a regular basis; and many birders saw raptors as predators taking their song
birds. As a group, falconers were the only ones advocating the protection of raptors. It wasn’t
until the late 1960s that wildlife managers and the birding community came out in full force
advocating the protection of raptors, and, when this finally came to pass, falconers were elated
to receive this long overdue support to protect all raptors.
Whenever a species is de-listed and consequently opened for regulated harvest, it
demonstrates the success of the Federal and State endangered species acts as workable
management programs that all interest groups can join forces in implementing and managing,
in spite of fundamental philosophical differences of opinion regarding the use of natural
resources (one can certainly assert that no recovery plan implemented under the ESA is
complete until managed take is incorporated at the time of de-listing). In order to continue this
united front, all interest groups must benefit from it: falconers must have access once again to
this classic falconry bird, which they historically referred to as the “noble” peregrine, unique
of all falcons used in the sport; and the birding community must have access to sighting their
“iconic” peregrines wherever they might be found. If any stakeholder group is marginalized
or punished due to some powerful majority interest, endangered species acts around the
country are weakened substantially by such anti-democratic use of power. The opinions and
personal preferences held by a majority must never be allowed to harm the values and
personal beliefs of a minority group. Subjective moral value systems must not be allowed to
spill over into the larger State or national population. It must be contained within the interest
group that maintains the tenets of their faith. They have every right to demand that their
members abide by a set of established subjective rules, but they don’t have the right to
demand that individuals outside their ranks abide by the same set of subjective rules. This
would provide for arbitrary and capricious powers to be asserted against all American citizens
from every sector of society.
It is ironic, now that the peregrine has been saved by an unrecognized interest group
– a group that expended more time and effort than all other interest groups combined – there
are those who would attempt to deny access to that bird; a bird which provided the very
motivation, the impetus, necessary to start and finish a project a few decades in duration in
order to save this bird so that someday falconers might once again be able to take wild
peregrines for use in falconry. The peregrine is the falcon that provides the most classical style
of falconry in the Western hunting tradition.
Given the fact that most of the peregrines used in the various peregrine release
projects came from falconers, it is unreasonable to deny falconers access to wild populations. If
not for access to wild populations, there would have been no peregrines in the hands of
falconers to donate to the release projects. Even more fundamentally: If falconers did not have
access to wild populations, we would never have discovered how to breed them in captivity
and therefore, release projects would have been impossible.
At the January 28th, 2009 Florida Peregrine Falcon Stakeholder’s Meeting, there were
objections raised and points made that are deserving of comment:

• Falconry has no impact on wild raptor populations, including the peregrine; therefore there
would be no justification in prohibiting take. There is no sound scientific or legal justification
in such a prohibition; only subjective opinions by those who have a unique perspective on the
interaction between mankind and wildlife.
• There was comment on social concerns for wildlife values that peregrines should remain in
the wild. This argument is asserted by all those protectionists who believe mankind should not
touch wildlife. Fish & game departments would no longer be needed if States were to
eliminate take of wildlife. In addition, there is the issue of citizens’ rights to access and use of
natural resources.
• It was suggested that because anatums are still listed in a couple of provinces in Canada,
Florida should not allow for a take of peregrines. Yet in Canada peregrines are presently being
taken for falconry. Is it acceptable that Canadian falconers are allowed to take peregrines, but
U.S. falconers are not?
• Protecting habitat and minimizing mortality is the greatest good the State of Florida, as
well as the nation, can do for peregrines.
• There was comment on economic cost of issuing permits for falconry and LE related
permits – i.e. cost-benefit analysis of permit fee. It must be remembered that the primary
purpose for any fish & game agency’s existence is to provide access to our natural resources
for citizens’ use in perpetuity. It is not necessary that each endeavor bear the cost of that
particular activity. Permit fees in general must support all management activities so that one
group is not disenfranchised due merely to its size, lack of money, and lack of representation.
• Questions of funding a monitoring plan were raised. Since the peregrine does not breed in
Florida and all three subspecies have healthy and rapidly increasing populations, the primary
effort that can be put forth is hawk-counts and banding. This is presently done by private
individuals who are associated with falconry groups or raptor related organizations. As
occurred with falconers’ breeding and releasing peregrines, perhaps the birding community
can contribute their part to the continued management of peregrines by participating in
counting and banding of peregrines and reporting their findings to FWC. This would
demonstrate their true commitment to their beliefs as asserted in their comments. Those who
feel they have a say in this matter, should be willing to contribute their resources to the cause
they believe in.

Falconers continue to do their part in monitoring the peregrine on well known
migratory routes such as, but not limited to, Lake Michigan, Padre Island and Assateague
Island. Falconers have a vested interest in monitoring peregrine populations throughout
North America given the amount of resources they invested into them. One group of falconers
established a study whereby a few peregrines were radio-tagged in the Canadian arctic and
were monitored throughout their migration to South America. An Illinois falconer, Rob Sulski,
who is banding peregrines along Lake Michigan is extracting a breast feather from each
captured peregrine and will have these feathers stable-isotope analyzed to determine the
origins of these birds – again, from private funding by falconers. In addition Bob Anderson,
another falconer/peregrine breeder, monitors breeding peregrines along the Mississippi River
bluffs in the Iowa-Wisconsin-Minnesota breeding range. What other group of private
individuals is willing to invest their resources into such endeavors? In addition, what other
group of private individuals has the knowledge necessary to pursue such projects? Even the
USFWS is not pursuing such studies!
Another important point to consider: It was falconers that set up the falconry
permitting system with USFWS. The limits placed on falconry were self-imposed. Falconers
established the rule that only first year immature birds could be taken for the sport so that
mature birds were not removed from the breeding population; and that master falconers could
possess only three wild birds and could take only two birds from the wild per year even
though raptor populations could sustain far greater take than this. This was not forced upon
the sport; this was a conscious decision due to the love falconers have for raptors. No other
group has such affection and attachment to raptors as do falconers. To suggest falconers be
punished because it is not popular in certain protectionist circles is to encroach upon that
sector of society that offers raptors the greatest representation in conservation efforts.
Under these circumstances, total population data and other information gathered by
falconers observing, trapping, banding and monitoring peregrines can make a significant
contribution to the continuing management of the peregrine at no cost to the rest of society.
The value of the information contributed by falconers will far outweigh the minor costs
incurred in administering a limited harvest program. Forty plus years ago, it was the unpaid
and voluntary efforts of falconers that alerted the world to the peregrines plight. The
information provided by falconers will continue to be of equal value in properly monitoring
and managing this falcon. Approving a legal falconry harvest of migrant peregrines will
enhance and ensure the future health of all peregrine populations in North America.


James M. Ingram III MD
President, WRTC
17909 N. Reflection Circle, Bennington, NE 68007