Our Response - Page 9
Peregrines are an abundant resource throughout Pennsylvania with a dramatic over abundance available during the fall season when they can be legally harvested elsewhere. The Commonwealth of Pennsylvania was built on the idea of a commonwealth for all of its citizens. Lacking any scientific based reason – none has been presented in the Ten Year Proposed Peregrine Management Plan - it is discriminatory to restrict peregrines from law abiding (permitted) falconers by maintaining them on the endangered and threatened list under false reasons.
It is our opinion that to continue to list the peregrine as endangered or threatened in light of the overwhelming evidence to the contrary creates a lack of credibility in PA’s wildlife management process.
Additional Factors Influencing Productivity
NO FEASIBILITY STUDY
Given the absense of a feasibility study by the PGC on and around the “traditional” nesting sites, there is no way to know whether or not they are suitable as nesting sites for peregrines. History has demonstrated that peregrines are highly adaptable and may move nest sites from year to year for their own protection (Craighead and Craighead, 1939). There are many other factors that address annual productivity that can not be captured in any management plan
Cooper & Beauchesne, (2007, p. 17) state:
Factors influencing annual productivity include: (1) egg and chick mortality from cold, wet, and late spring weather (White and Cade 1971; Court et al. 1988b; Mearns and Newton 1988; Ratcliffe 1993; Bradley et al. 1997); (2) local yearly variation in prey abundance (Court et al. 1988b; Bradley and Oliphant 1991); (3) regional differences in overall prey availability (Ratcliffe 1993); (4) predation/disease: not quantified for any population but can be locally significant (Cade et al. 1989; Tordoff and Redig 1997).
Ratcliffe (Cade et al., 1988, pp. 154-55) reinforces the observations that weather conditions have a profound effect on breeding success. “One feature has become clear during the last ten years. Adverse spring weather can so appreciably reduce breeding performance as to resemble the earlier, pesticidally-induced depressions in output of young. The last decade has been notable for cold, backward springs, sometimes also accompanied by unusually heavy rainfall….” And on page 150 he states “In 1981 an unusually cold and wet spring caused heavy mortality of chicks at hatching and during the early nestling stages.” (Emphasis added) Observations have also been made with a high degree of correlation that peregrine populations decreased in lock step with decreases in passenger pigeons a primary food source throughout Pennsylvania. For these reasons among others, we believe that the current proposed management plan’s inclusion of a multiple year success rate of peregrines in the same nest is inappropriate. It actually ignores that healthy peregrines make changes as they determine their own survival needs. Robert Berry of the Peregrine Fund, Inc. in the Return of the Peregrine (chapter 3) observed that peregrines moved their nest off the “traditional” cliff site near Daulphin narrows and onto the old abandoned pilings in the middle of the river to avoid intruders. As the current proposed management plan is presented, the opposite conclusion would be reached about the population if the bird moved nest sites from year to year.