Our Response - Page 8


We propose the following

I. Science Based Management in line with the standards used by USFWS.

The scientific community (Federal, States, Academic) as it relates to raptor management and specifically to the peregrine falcon is very clear and consistent in its acceptance of standards for measuring healthy populations and productivity rates. Rates of productivity typical of expanding or stable populations average between 1.0 and 2.0 young per occupied territory (refs. in White et al. 2002), and most historical and recent productivity estimates fall within that range (Hickey 1942, Mesta 1999).

We respectfully request that the Pennsylvania Commission follow the same scientific standards for peregrine management. The tables below demonstrate that nesting peregrines on man-made structures have the same or a higher ratio of success than do those on natural sites. We believe that it is both arbitrary and capricious to discriminate against peregrines nesting on man-made sights by not recognizing them as successfully nesting peregrines just as one would any other successfully nesting peregrine regardless of where it is nesting. In other words, we recommend and urge the Commission to give full weight to all nesting pairs rather than the proposed ratio of 0.25% for those birds nesting on man-made structures. The scientific standard of acceptability would indicate that the Pennsylvania Commission does not currently utilize a scientifically reliable standard of measure as it relates to its management of the peregrine.

II. The Human Factor

The USFWS in its FEA has implemented standards of safety for nesting peregrines east of the 100th meridian where no young shall be taken from a nest.

Secondly, they have included a restriction on take of banded peregrines. These two safeguards singlehandedly protect all Pennsylvania nesting peregrines from disruptions as they produce their young and as the PGC carries out its task of banding young nestlings. Those two steps insure that nesting peregrines east of the 100th meridian will not be intruded upon.

Third, the USFWS has also provided a third safeguard that limits trapping of first year immature peregrines by licensed falconers from mid-September to mid-October when more than 80% of the migrating peregrines are F. p. tundrius which have never been known to nest in Pennsylvania.

Fourth, the Atlantic Flyway Council allocates permits to each state within the flyway with the largest allocations going to those coastal states where migrants are most numerous. This means that Pennsylvania could theoretically be allocated a very small number of permits each year that they could make available to licensed falconers to trap migrating immature peregrines within the mid-September to mid-October time limit and within all the other restrictions virtually eliminates any chance of a local nesting peregrine from being trapped, and in the unlikely event that a local bird were to be trapped, it would immediately be identified by its band and released.

Finally, In the unlikely event that a non-targeted species is taken there would be no significant impact on the species within the meaning of Section 102 (2) (C) of the National Environmental Policy. (See attached letter below)


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