Our Response - Page 10
We can’t help but notice that the non-enforcement division of the PGC defines Territorial Pairs as those that will defend their nests. All active pairs are successful pairs and all successful pairs are active pairs. This may indicate that other nesting pairs are present but not counted because they have been disrupted from their nest sites (failed to defend nest once interrupted). It leads us to believe that there are more breeding pairs that have discontinued nesting once nest sites have been intruded upon. This was also the case prelisting when ooligists raided nests for eggs. The pairs just stopped breeding.
The Peregrine Club of Philadelphia has demonstrated that peregrine populations are fully recovered under the rigorous scientific standards delineated by the USFWS in its most recent FEA. We have also shown that F. p. tundrius peregrines are also plentiful and present in Pennsylvania during the legally available time of year to harvest them for falconry purposes. An average of over 400 migrating peregrines pass through the Commonwealth each fall. We would note that this species is recognized by the Pennsylvania Game Commission in numerous documents including the Management and Biology of The Peregrine Falcon Ten Year Proposed Plan as well as on their website. [“Two peregrine falcon populations occurred historically in Pennsylvania: the arctic subspecies (F.p.tundrius), which migrates through the state in low numbers in spring and fall; and a nesting subspecies (F.p.anatum).”] However, the PGC has chosen to completely discount or ignore them as part of the healthy peregrine population for counting purposes. It also leads us to believe that if they regard over 400 artic F.p. tundrius as a small group, they must realize just how much larger and healthy the species has become. To simply ignore the overwhelming majority of peregrines as part of the abundant resource within Pennsylvania is reckless from a wildlife management perspective. It is also highly questionable, given that the USFWS and a number of other states within the Atlantic Flyway do count them. Florida has delisted the peregrine based solely on migrating numbers of peregrines while New Jersey has written regulations to allow a fall harvest based solely on non-nesting peregrines (migrants). Many of the other states along with the Federal Government have done the same. In fact the final tally for October peregrine sightings from the Florida Keys Hawkwatch was 3,817 on October 31, 2012. We point this out because this is the funneled collection point for peregrines coming down the Atlantic Flyway so observations are more accurate than in remote mountain ranges up north. With precedence from a neighboring state, we recommend that at a minimum, Pennsylvania regulations be rewritten to include a yearly harvest of migrating peregrines. We further recommend that the requirement of nesting peregrines maintaining the same nest site for three consecutive years be eliminated. We do agree with active nest sites producing the objective success metrics, but would not punish a nesting pair for moving a nest site. The Management and Biology of the Peregrine Falcon Ten Year Plan observes that nesting pairs are known to move from the PA side of a bridge to the NJ side yearly depending on how they assess their needs and threats. It would be inconsistent not acknowledge that healthy birds adapt and make changes. The same observations were documented before the species was listed as endangered (Craighead and Craighead, 1939), and later by Robert Berry, Chapter Three of Return of the Peregrine, The Peregrine Fund, Inc.) Next, we recommend that all nesting peregrines be counted equally with full weight regardless of where they nest. We have demonstrated that success rates for both man-made structures and natural sites both exceed USFWS standards and on a four year average also exceeded current PA standards if all nests were counted equally. It is highly inconsistent to place nest boxes on man-made structures and imprint peregrines into urban areas for recovery purposes and then not fully count them to create the perception that the species has not fully recovered. This practice leads one to seriously question the “scientific methods” and credibility of the PGC. Lastly, we recommend that the peregrine be delisted as an endangered or threatened species and be managed in accordance with current USFWS standards.