Our Response

It is our pleasure to respond to the currently Proposed MANAGEMENT AND BIOLOGY OF THE PEREGRINE FALCON IN PENNSYLVANIA TEN YEAR PLAN 2013-2022 put forward by the Bureau of Wildlife Management, Pennsylvania Game Commission.

In this response, we will present a history of federal, regional and Pennsylvanian progress and actions on the listing, recovery and delisting of the Peregrine Falcon (Falco peregrinus) and subspecies F. p. anatum (American Peregrine) and F. p. tundrius (Tundra Peregrine). We also discuss the mixed subspecies Peregrine that nests in Pennsylvania and specifics on the Tundra Peregrine, a commonly encountered autumnal migrant through Pennsylvania. The purpose of this written response is to:

  • Summarize the Peregrine Club of Philadelphia’s position on the peregrine
  • Present data and other information on the Peregrine Falcon
  • Summarize and discuss the conditions upon which species are listed, down listed (changed from endangered to threatened) or delisted as Threatened in Pennsylvania in order to demonstrate that the Peregrine Falcon no longer deserves to be classified as an Endangered or Threatened Species as it has met the recovery goals established by USFWS.
  • Discuss some concerns previously raised by various stakeholders in Pennsylvania over the Peregrine.
  • Reaffirm our urgings that the Peregrine Falcon be removed from the Pennsylvania List of Endangered and Threatened Species during the present list revision.
  • Express our gratitude to the many organizations and individuals responsible for the full successful recovery of the Peregrine Falcon.

Summary Statement

The Peregrine Falcon was originally listed as Endangered in Pennsylvania for only one reason, Falco peregrinus anatum (American Peregrine), a species extirpated in Pennsylvania, and F. p. tundrius (Tundra Peregrine), which was never documented as a nesting species in Pennsylvania, were “classified as endangered under the Federal Endangered Species Protection Act of 1973, P.L. 93-205.” Otherwise, the Peregrine (F. p. anatum) was not “in danger of extinction in the wild in Pennsylvania.”) It was already extirpated. For such reasons, Falconers across the country together withThe Peregrine Fund Inc. began the concept of Peregrine reintroduction of this federally endangered species into the eastern United States. They used three reintroduction locations in Pennsylvania during the 1970s and 1980s, aided by the Pennsylvania Game Commission released birds at four locations in the state during the 1990s. By 2003, the eastern population had grown to approximately 336 nesting pairs, and by 2012 at least 32 nests were occupied by nesting pairs known in Pennsylvania the same number as was known in 2011. Nesting success for the year was at 69% with 22 successful nests and 62 young fledged, while productivity remained high, 1.94 fledglings per pair.


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.



A similar increase in Peregrine numbers is supported by migration counts across the country, especially along the east coast along the Atlantic Flyway.

Between 2008 and 2012, the number of Peregrines counted at Hawk Mountain averaged 61.6 per year. A second classification of large “unknown” falcons were observed with an average of 10.8 per year for a five year average total of 72.4 falcons per year just from the one observation point. Approximately 95% of the Peregrines migrating autumnally through Pennsylvania are F. p. tundrius, and the vast majority of approximately 82% pass through between mid-September and mid-October. Table A shows all observation sights across the Commonwealth of Pennsylvania, average migrants per year and number of years of data for each observation sight.

As a follow-up to delisting, USFWS published a Final Environmental Assessment (FEA) in 2004 to allow a harvest of nestling Peregrines in western states and an FEA for migrant Peregrines across the U.S. in 2008. The 2008 FEA essentially replaced the 2004 FEA, and allows a conservative annual harvest of up to 1% (36 individual birds collectively in all states east of the 100th meridian) of a conservatively estimated population of Peregrines with a harvest goal of up to 5% in the near future in conformance with general sustainable harvest levels for other raptor species implements a harvest strategy to ensure the 1% allowance will not be exceeded, and harvest of Peregrine subpopulations will be minimal. It also encourages states to work with the Flyway Councils to distribute the harvest allotment in an equitable way. The strategy includes limiting harvest to the time slot September 20 through October 20, when migrants are predominated by Tundra Peregrines. An added protection layer has been included in new federal Regulations, modified concurrently with the 2008 FEA, wherein it is required that previously banded raptors, including Peregrines, must be released upon capture.

The delisting of Peregrines from ESA did not affect their protection under the Migratory Bird Treaty Act (MBTA). The FWS has the legal authority and obligation to regulate take of Peregrines under the MBTA. The Secretary of the Interior is authorized and directed to determine if, and by what means, the take of migratory birds is allowed and to adopt suitable regulations permitting and governing the take (16 U.S.C. § 704). The MBTA and its implementing regulations (50 CFR Parts 20 and 21) prohibit take (see regulations for definition of take). Regulations at 50 CFR 21.28 and 21.30 authorize the issuance of permits to take, possess, transport and engage in commerce with raptors for falconry and for propagation. Other regulations authorize the issuance of permits for scientific collecting (50 CFR 21.23), special purposes such as rehabilitation or education (50 CFR 21.27), and depredation (50 CFR 21.41). Permits are issued if certain criteria are met, including a requirement that the issuance will not threaten a wildlife population (50 CFR 13.21(b)(4)). In addition, issuance of raptor propagation permits requires that we consider whether suitable captive stock is available and whether wild stock is needed to enhance the genetic variability of captive stock. Since delisting, there is renewed interest in taking Peregrines for falconry. Thus, in cooperation with State wildlife agencies, the FWS is analyzing the effects on Peregrine populations of taking wild Peregrines for falconry, and has developed guidelines for falconry take.



The delisting rule (Mesta 1999) discussed existing protections for Peregrines that continue despite delisting under ESA, such as those offered by the Federal Insecticide, Fungicide, and Rodenticide Act (7 U.S.C. 136) for new and existing pesticide registration and use; the National Forest Management Act (16 U.S.C. 1600); and the Federal Land Management and Policy Act (43 U.S.C. 1701). Peregrines are also protected internationally by the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES). This treaty was established to prevent international trade that may be detrimental to the survival of plants and animals. Peregrines were included in Appendix I of CITES on July 1, 1975.

In 2011 and 2012, members of the Peregrine Club of Philadelphia had discussions with Daniel W. Brauning, Wildlife Biologist Bureau of Wildlife Management Pennsylvania Game Commission over a suite of Peregrine management alternatives, nearly identical to those that were subsequently adopted by USFWS in 2008, that would allow harvest of Tundra Peregrines without interfering with the subspecies population of Peregrines nesting in Pennsylvania. The Peregrine Club of Philadelphia (PCP) also offered a workable strategy to the above mentioned biologist which could eventually allow harvest of Tundra Falcons modeled after our neighboring state of New Jersey, again without interfering with the subspecies population of Pennsylvania Peregrines. However, to date, the non-enforcement division of the Pennsylvania Game Commission continues to believe that the Peregrine remains an endangered species fourteen years after the Peregrine was deemed fully recovered by UFWS.

The Peregrine Club of Philadelphia respectfully requests that the commonwealth of Pennsylvania remove the Peregrine Falcon from the Pennsylvania List of Endangered and Threatened Species (“List”) during the present round of review.

The Delisting Monitoring Requirement of ESA

Section 4(g)(1) of the ESA requires that the U.S. Fish and Wildlife Service (FWS),
...implement a system in cooperation with the States to monitor effectively for not less than five years the status of all species which have recovered to the point at which the measures provided pursuant to this Act [the ESA] are no longer necessary...

In keeping with this mandate, the FWS developed this plan in cooperation with State wildlife or natural resource agencies (States), recovery team members, and other cooperators. It has received extensive review by independent experts. A 30-day public comment period was opened with the publication of a Notice of Availability in the Federal Register on July 31, 2001 (66 FR 39523), and again on September 27, 2001 (66 FR 49395). The Federal Register notices and the plan were also posted on the FWS Endangered Species Program’s web page (http://endangered.fws.gov). Meanwhile, the FWS continued to collect and compile data from existing monitoring efforts by States to track continued Peregrine recovery after delisting. Monitoring in association with this plan was initiated in 2002 as a limited, pilot program. A revised draft was distributed within the FWS for comment, to monitoring cooperators, and to the International Association for Fish and Wildlife Agencies on November 22, 2002, for their distribution to States for review. On January 13, 2003, this same version was distributed to individuals and organizations who commented on earlier versions. This version of the plan is based on data collected in 2002, from experience gained while administering a nationwide monitoring program in 2002, and on comments by States and other cooperators on earlier versions of the plan. This version of the plan, and FWS responses to comments on earlier versions, are posted on both the FWS Endangered Species web page

(http://endangered.fws.gov/recovery/peregrine) and on the Migratory Birds web page (http://migratorybirds.fws.gov). Any revisions and reports are available on the web.




This cooperative plan is primarily designed to detect declines in territory occupancy, nest success, and productivity in six regions across the United States. Regional data for all population measures will be combined to examine trends nationwide. Territory occupancy, nest success, and productivity all are indices of population health. Estimates of all three indices were very low between 1950 and 1980 when Peregrine populations declined severely, but rebounded during population recovery (Cade et al. 1988, Enderson et al. 1995, Mesta 1999, White et al. 2002).

Data will be collected from a randomly selected subset of Peregrine territories for five sampling periods, at three-year intervals, with full implementation to begin in 2003 and end in 2015. The plan is designed to achieve an 80% probability ($= 0.20) of detecting a decline of 12.5 percentage points in territory occupancy and nest success after the first sampling occasion with a Type I error rate of 10% ("= 0.10; i.e., there is a 10% chance that the data will indicate a declining trend in nest success or territory occupancy greater than 12.5 percentage points when, in fact, there is no such decline occurring). Smaller declines will be detectable over subsequent sampling occasions. Productivity will be measured from the same subset of territories. 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). (emphasis added) Thus, data from the first two sampling seasons will be compared to this range; trends will be measurable thereafter. The FWS will also request and synthesize population and territory location data collected by States and other partners and report this information with a regional perspective for years that fall in between the monitoring years suggested by this plan. Finally, we will collect addled eggs and feather samples and archive these for later analysis of contaminant levels in Peregrines nationwide if information indicates that contaminants may be causing a significant population decline.

The Peregrine Club of Philadelphia requests that PGC Biologists use the same metrics for establishing a healthy and expanding population. We recognize USFWS measurement metrics as scientific, repeatable and reliable methods for assessing peregrine populations without prejudice towards those birds that nest on nontraditional sites and the even larger number of peregrines that appear in Pennsylvania each year.

Anatum Peregrines - Eastern Population

It is highly probable that the demise of the Eastern anatum population was due to egg-collectors (oologists), exterminators (such as game managers, pigeon racers, farmers, etc.) plus recreational activity after WWII on and at the eyrie sites (McDonald, 2010), loss of habitat (large scale deforestation of mature trees), and loss of a primary prey species (for the prey species hypothesis see Beebe below and in Hickey, 1969, pp. 399-402), all of which was having catastrophic consequences for the Eastern anatum prior to any possible influence of DDT.


Falconers certainly had no influence on Eastern anatum populations given falconers’ small numbers at the time and the number of peregrines taken (some protectionists did try to include falconers as part of the blame), which McDonald informs us, was no more than 20 to 30 eyasses per year in the late 1930s, and from ’39 onward few if any eyasses were taken due to Bill Turner and Al Nye’s discovery in 1938 of migrating tundra peregrines on Assateague Island.1 McDonald (2010) states “American falconry, had its active beginning in the 1930’s. No discernable activity, for the most part, has been recorded prior to that period; therefore there
1 Bill Turner’s father, Landon, and a Law Enforcement officer, “Roddy” Gascoyne - unsure of the spelling -, for USFWS, would fish at Fox Hill Levels on Assateague and when the fishing for Red Drum was slow due to the outgoing tide, they would shoot sitting peregrines with a .22 Hornet varmint caliber rifle, to pass the time, since this was socially justifiable given the belief that peregrines would take game birds. Landon Turner saved some of the dead peregrines and brought them home for his son to see since Bill was a falconer. It must have been heart-wrenching for Bill to see these dead peregrines, but it provided evidence that migrating tundra peregrines did rest on Assateague before moving on. These tundra peregrines then became the primary subspecies falconers would trap. (McDonald, 2010) was no impact on wild raptor populations.” The population of falconers in the 30’s was simply too small to have any effect. But egg-collecting was different, as a plethora of period literature informs us. Kiff & Zink provide


[W]idespread hobbyist egg collecting did not really take hold in North America until the 1860s…. The study of eggs … was at its zenith on this continent from about 1885 through the 1920s … and had completely faded from the American scene by 1970. Thus, the ‘oological chapter’ of North American natural history lasted about a century.’ … Egg collecting was justified on both scientific and recreational grounds (Grinnell, 1906), and many of the great lights of American ornithology … collected bird eggs in their early years. (Kiff & Zink, 2005)

Next let us consider the environmental forces that have caused the Eastern population of the anatum peregrine subspecies to become extinct and how much of the evidence that was available was ignored. You may ask “I thought the peregrine was saved?” “The American peregrine falcon was listed as endangered on June 2, 1970, under the precursor of the Endangered Species Act (35 FR 16047)”2 However, the “American” peregrine is the anatum subspecies and the Eastern portion of the population (hereafter referred to as the Eastern anatum, which was much larger than its Western brethren3; so much so that it could be classified as distinct) became extinct, as a regional and unique group, sometime in the 1950s (McDonald, 2010), well before the anatum was listed as endangered. The Western portion of the anatum population declined significantly due to natural environmental conditions. Nelson (Hickey, 1969, pp. 65-67) hypothesized that the lack of precipitation and rising average temperatures in the western portion of North America were the primary contributors to the decline of the Western anatum peregrine. He stated “There was practically no pesticide problem when the decline started.” Which he stated began in the 1930’s or earlier. Beebe’s hypothesis of the need for humidity levels being critical to the survival of eyass peregrines (Beebe, 1960, p. 181) supports Nelson’s hypothesis.


Peregrine Falcons introduced into the Commonwealth of Pennsylvania have established self-sustaining populations which continue to grow above earlier forecasts by USFWS and above the minimum number of successful nesting pairs originally proposed by PGC biologists. USFWS delisted the Peregrine in 1999 based on the then existence of more than 40 breeding pairs producing 1.92 young/pair compared to a recovery goal of 22 pairs producing 1.5 young/pair for the Commonwealth of Pennsylvania.

The PGC set a recovery goal based on 50% of the highest historic number of nesting peregrines reported in Pennsylvania of 44 pairs. That recovery goal was reached in 2008 with at least 23 known nesting pairs in PA.

2 http://frwebgate.access.gpo.gov/cgi-bin/getdoc.cgi?dbname=2006_register&docid=fr13oc06-97
3 Beebe attributed the difference in size to its primary prey base which would have been the passenger pigeon – a colonial breeding bird of the region. He hypothesized that the size of raptors is determined by the size of the primary prey base during the breeding season and the tiercel’s (male falcon) ability to catch it in sufficient numbers and carry it back to the eyrie efficiently. If tiercels are unable to do this, there can be no breeding success. The tiercel Eastern anatum was the perfect size to catch and carry passenger pigeons. The Western anatum did not have this evolutionary pressure for similar sized prey. (Frank Beebe, Personal communication, 2005)

and produced 60 fledglings. By 2012, PA is known to have a minimum of 32 active nests producing ever growing numbers of fledglings.



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)



Abundant Resource

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


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.



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.



Given our recommendations, we submit that the Pennsylvania’s recovery objective for a stable, secure population has been met.

Legal delisting requires that several conditions be met for at least 3 consecutive years;

  • (1) 22 or half the highest historic number of nests are occupied calculated as the number of cliff-nesting pairs plus 25% of the pairs on man-made structures; (Currently at 32 occupied nests. It is arbitrary and capricious to change counting methods)
  • (2) at least half of the pairs fledge young, and (Currently 69% fledged)
  • (3) 1.5 or more fledglings are produced per occupied nest. (Total currently 1.94 produced with 2.0 or greater for fledglings on man-made structures, Table 3)

This response is faithfully submitted by the,
Peregrine Club of Philadelphia.






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