Our Response - Page 2

The current PGC proposed management plan would like to see several conditions met for three consecutive years, (1) 22 or half the historic number of nests are occupied is based on 44 nests, the highest reported number of nests in the history of the Commonwealth by the PGC, not the historic norm. At that time, nest sites were not discriminated on based on location of nest. Changing the way in which you count active nests is akin to changing which citizens are allowed to vote, it benefits the politician not the citizenry as a whole or in this case the peregrine species.  Table1. (2) at least half of the pairs fledge young. Like the last standard, this standard has been met for several years averaging over 70%.  Table 1. (3) 1.5 or more fledglings are produced per occupied nest. Again, this standard has been met with production rates much higher. Table 3.


We support scientific, quantifiable management methods that are supported by the scientific community and adhered to on both federal and state levels. We do not support arbitrary or capricious methods (counting nests differently) and/or the exclusion of a species or subspecies, (table A) (tundrius) to force the data to fit a predetermined outcome. But there is much more to this story.


Pennsylvania’s recovery objective is a stable, secure population. By all acceptable scientific measures this objective has been met. We also point out that there is “a lack of historical records to indicate that the species was [prior to its extirpation] a prominent member of the breeding avifauna of the state” although the Tundra Peregrine was and still is commonly encountered in Pennsylvania during its fall migration. In fact the number of migrating Tundras peregrines in Pennsylvania each year dwarfs the local subspecies peregrines. (Table A.)

The Pennsylvania Peregrine introduction program began by using captive bred Peregrines which were hacked (fed and watched at platforms until young birds fledged and were able to survive on their own) in rural areas of the Commonwealth and then in urban areas after initial efforts all but failed due mostly to predation. Contrary to the low success rates from remote hack sites, success was higher from within urban settings with the greatest success on bridges and buildings. Hacked Peregrines were composed of subspecies hybrids not limited to mixtures of F. p. anatum, F. p. tundrius, F. p. pealei, F. p. peregrinus, F. p. brookei and F. p. casini, and with a few exceptions, whatever breeding stock was in the hands of breeders prior to passage of the Endangered Species Conservation Act of 1969 (Public Law 91–135, 83 Stat. 275). The release program therefore consisted of introducing (imprinting) an artificial bird into an artificial environment. Not withstanding the dramatic decrease in hacking over recent years, a 4-year running average of 27.5 breeding pairs of artificial Peregrines were established and producing a 4-year running average of 2.375 young/pair, 2010 data. It should be pointed out that the current run rates greatly exceed those outlined by the USFWS. The search for breeding pairs outside of selected areas in Pennsylvania has been limited and mostly made up of volunteers and included some agency employees with even fewer efforts in nontraditional nesting areas.

The USFWS down listed the Tundra and the American Peregrine in the 1980s and 1990s. By 1998 the federal recovery plan goals for the Eastern Management zone was met (193 breeding pairs producing an average of 1.5 young/pair compared to a recovery goal of 175 to 200 pairs and 1.5 young/pair) and by 2012 the goal for Pennsylvania was far surpassed (32 breeding pairs producing 2.1 young/pair compared to a recovery goal of 22 pairs producing 1.5 young/pair). By 1999, USFWS considered the Peregrine to be fully recovered well beyond self-sustainable and harvestable levels across the entire U.S., resulting in the Peregrine’s complete removal from the Federal Threatened Species List. By 2011, the ratios of restored nesting birds and productivity achieved in Pennsylvania exceed the federal recovery goals for breeding pairs.


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