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  1. #1
    Join Date
    Apr 2008
    Charlotte, NC

    Default AFC Petition for normalizing peregrine take

    October 28, 2011
    Petition to Normalize Passage Peregrine Take

    AFC is intending to petition Fish & Wildlife Service to expand the harvest of peregrines for falconry purposes. It is our belief, which is supported by science that the peregrine is – and has been for some time – at the point where its harvest can be managed in the same manner as most all other non-listed raptor species.

    In 1999, Brian Millsap and Bruce Taubert spoke at the NAFA Waverly, Iowa Field Meet. They were invited by the Meet Chairman, Bill Murrin, to inform the falconry community of the status of peregrine populations of North America and to explain what post-delisted passage peregrine harvest plans were being contemplated. Millsap and Taubert, along with Jim Enderson, through the International Association of Fish & Wildlife Agencies, were working on behalf of falconers on a peregrine management plan that would include falconry harvest of passagers. They expended a tremendous amount of effort in, among other things, negotiating a harvest plan that would be acceptable to the various States. Their belief was that the most important first step would be to simply break the no harvest barrier, even if the parameters were much more restrictive than science supported and that falconers were hoping for.

    Millsap and Taubert explained how difficult it was. In order to open peregrine take, the States and to some extent the Canadian provinces had to be on board. At the time, many States and provinces had their own issues and agendas concerning the peregrine, and so compromise - and a lot of it - was necessary.

    The Northeastern States and the Canadian provinces did not want "their" peregrines harvested at all. In response, a late September through early October harvest time frame was proposed. Records showed that such a time frame would maximize the chances that only tundra peregrines would be harvested and minimize the likelihood that anatums and city mongrels, which are not hard migrants like the tundra, would be captured.

    Some State and provincial fish & game officials as well as protectionist groups were against any harvest whatsoever. These factions believed falconers would harvest so many peregrines that the peregrine population would decline to a level where it would be necessary to re-petition USFWS to relist. In order to keep the anti-take factions at bay, FWS needed to 1) take an extremely conservative approach to estimating wild peregrine population numbers; 2) propose extremely conservative harvest numbers; and 3) place regional restrictions on where peregrines could be harvested. USFWS was hopeful that such an approach could be defended should a lawsuit be filed, which they fully anticipated at that time. The approach taken was to build a model that consisted of layer upon layer of the most conservative estimates of population size, individual mortality and breeding productivity.

    In the end, the peregrine management plan allowed the annual harvest of 36 passage peregrines east of the 100th, meridian between September 15 and October 15; no lawsuit was ever filed; and passage peregrine harvest was allowed. At the same time, as was the case when the peregrine was delisted, wild peregrine numbers were well above historic levels and continuing to grow.

    We must thank Millsap, Taubert and Enderson for their hard work and successful negotiations with the States and we must also thank FWS (led by Millsap and Allen at the time) for their understanding of the legal/political dynamics of the peregrine - a very high profile poster child of the Endangered Species Act (ESA) - and what it would take to see this through with a minimal chance of failure.

    It was understood at the time that once the no-harvest barrier was broken and we had a few years of peregrine harvest under our belt, it would be much easier to negotiate a more science -less political – based set of harvest parameters in line with what has been applied to most all other raptor species utilized for falconry. It is the American Falconry Conservancy’s belief that we have reached such a stage with the peregrine, and it is time, with the support of all other falconry organizations, to pursue relaxing peregrine harvest management at the federal level.

    We have contacted our legal counsel, Bill Horn, who would be happy to draft a petition to present to FWS to remove the present unique restrictions placed upon peregrine harvest and bring it in line with standard raptor management protocols. Keep in mind that this is not a legal challenge to FWS; it is simply the standard method of working with FWS to make changes to regulations, which they are quite comfortable with and accustomed to.

    AFC has assembled a committee for this effort. It is composed of Rob Sulski, Eric Edwards, Lee Grater and Bill Murrin. If you have comments or information you would like to share with them, you can contact them through the AFC website at: Oscar Ruiz, who is our Treasurer and manages our website, will make sure it is forwarded to them.

    AFC has begun soliciting donations from individuals who helped us fund Bill Horn's previous lobbying efforts with the Department of the Interior/FWS relating to relaxing the falconry regulations and demanding recognition of our property rights in our raptors. Horn’s success in such efforts demonstrates his effectiveness in protecting falconers' interests. We therefore ask our members to contribute donations to our fund "Petition to Normalize Peregrine Take," which can be found at: . Whatever you can afford would be greatly appreciated.

    Whether you have a desire to take a passage peregrine or not, if you love falconry and wish to practice this art and sport with minimal interference, and if you support a science rather than an emotional based approach to managing our wildlife resources, please join in this effort. Every right that is interfered with allows for another to be encroached upon, so stand with each other on every issue so that everyone's rights are protected equally. In addition, whether they are part of AFC or not, please call your friends as well as your State club and ask them to contribute to this cause.

    Something we expect should be understood by all: If the programs that come out of the ESA are to remain viable, they must demonstrate success with a sufficient number of species. Otherwise, we waste taxpayers' money keeping poster children alive, money that should be spent on recovering species that are truly in peril. ESA program success must be measured in terms of returning a species’ population to viable, self-sustaining numbers, and then once this is achieved, maintaining an environment that allows the species to prosper to the point of allowing citizens to access the resource under the same regulatory management framework as most other resources. If this is not understood to be a truism, then the ESA becomes simply a non-scientific weapon used by emotionally charged protectionists against all other American citizens. This cannot be allowed. With this in mind, in support of the intentions of the ESA, it is imperative that the peregrine be managed in the same manner as all other raptor species; and what better animal to show such success than with the peregrine, one of the most high profile ESA poster children.

    Once again, the peregrine should no longer be treated more special or unique in relation to other raptors since its numbers continue to be well above historic highs.

    Bill Meeker
    President, AFC
    Last edited by jhausman; 11-07-2011 at 12:18 AM. Reason: updated to official letter
    Jason Hausman - AFC Moderator
    Tundra Peregrine Falcon, Red-Tailed Hawk & German Shorthaired Pointer

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