February 17,2012
Alaska Board of Game
Boards Support Section
P.O. Box 115526
Juneau, AK 99811-5526
via fax: (907) 465-6094
Subject: Additional comments on Proposal 40 - Permits for Falconry - Allow Nonresidents to Take Raptors for Falconry
Dear Ladies and Gentlemen of the Board:
The American Falconry Conservancy (AFC) understands that that the Alaska Board of Game tabled Proposal 40 - Nonresident Take of Raptors for Falconry - at their January 2012 meeting and is awaiting further input from the Department of Fish and Game at the March 2012 meetings.
AFC has reviewed the entire Alaska Board of Game record associated with the January 2012 State-wide Proposals 38,39,39(a) and 40 and offers additional comments for the Board's consideration to respond to some of the comments and concerns contained and expressed thus far and to augment the record with additional information relevant to the subjects. AFC again respectfully requests that the Board adopt provisions allowing nonresident falconers to harvest both juvenile free-flying and nestling raptors in Alaska for falconry purposes. All of the concerns expressed by those who commented in this record were considered when AFC worked with a number of Alaska falconers to draft Proposal 40. Many of the same concerns were expressed by other states while in the process of adopting nonresident take. However, in the years following adoption, none of the issues of concern ever arose. In fact, in nearly all cases, non-resident harvest across the U.S. has occurred without incident at harvest levels well below any of the quotas some states chose to adopt.
1) None of those who commented indicated that there is any resource health issue associated with nonresident take of raptors in Alaska. AFC's proposal on numbers and species constitutes a very conservative harvest rate which will have no impact on any raptor species population in Alaska. Dr. Titus and others who commented and participated in the Board's discussions and deliberations agree with AFC's assessment. A number of those who commented suggested greater numbers and additional
species beyond those suggested in Proposal 40 should be allowable, and we agree that even a much less restrictive harvest rate will have no impact on Alaska's wild raptor resource. The Kodiak Advisory Council suggested adding several other species to the Proposal 40 list and raising the nonresident allowance for goshawks up to 10 birds per year, and AFC would concur.
2) Several of those who commented suggested that nonresidents have a history of illegal activities that could tarnish the good reputation of resident falconers. One who commented suggested nonresident take would encourage "black market" activities. However, no examples of such purported illegal activity were provided. In fact, U.S. falconers at-large are a very dedicated group, who individually and collectively have worked very hard to be able to pursue our sport within a framework of what may be the most complex set of regulations among all hunting sports, especially in regards to nonresident, inter-state migratory bird activities, which bring into play even more federal laws and regulations. The clean records of falconers across the U.S. support with very few exceptions, that the U.S. falconry community is an extremely reputable, law-abiding group of sportspersons.
3) A few of those who commented suggest that harvest should be restricted to passagers (juvenile birds capable of flight) and exclude eyasses (nestlings). One of those who commented suggested that passagers are readily available and so there is no need to allow eyasses. For a number of reasons, AFC and several others who commented continue to maintain that there is no biological or other justification for placing restrictions on either passager or nestling harvest. Furthermore, many falconers favor the behavioral disposition of eyasses; birds raised from an early age more easily and swiftly integrate into human social settings, which include family activities, hunting dogs, traffic, etc. than do their passage counterparts. Additionally, in contrast to a commenter's assertion, for a number of reasons passagers of a desired species are much less likely than eyasses to be encountered, let alone captured. Firstly, young birds move out of their nest site areas in late summer and most of them end up residing in or migrating through remote, road-less regions of the state. Secondly, Alaska's geographic features do not concentrate migrating raptors down predictable corridors as is the case elsewhere in the lower 48 states; this is why a number of Alaska falconers have come down to the lower 48 to harvest raptors. Finally, passager movement is associated with unpredictable weather patterns, which makes planning nearly impossible for nonresidents.
4) One commenter testified that large falcon species are known to use the same nest site for many years and insinuated that repeated harvest from a particular nest site would be detrimental. However, the commenter provided no evidence to support that such activity would affect the species population or even the falcon pair's reproductive success. The testimony on this subject was incomplete in several important ways. Firstly, there was no evidence presented that indicates repeated harvest by residents has had such an affect. Secondly, species as a whole and individuals within a population are programmed through evolution to reproduce in order to perpetuate their kind regardless of whether a particular ledge or crevasse continues to exist. Birds, including raptors readily utilize alternate nest sites to complete their nesting cycle when necessary, and there is no indication that nesting habitat is in short supply within the vastness of Alaska. Finally, federal and all other state nesting raptor harvest provisions prohibit the removal of all the nestlings from a particular nesting site, a provision that was authored by falconers in order to allow a pair to complete a full nest cycle and minimize nest site abandonment. Dr. Titus provided information that indicated repeated harvest of juvenile prairie falcons had no effect on the populations.
Finally, as the Board is likely aware, the proposed language in 40 would conflict with the approved compromise version of the Falconry Manual with respect to exporting birds. It appears the Falconry Manual provisions on this subject would need to be modified to allow nonresident take. Should the Board approve nonresident take and the Falconry Manual be reopened, AFC recommends that the present restrictions that prohibit Alaska resident falconers from export birds be loosened up. Here too, there is no biological justification for a no-export provision.
Thank you for this opportunity to provide additional comment and clarification of the record.
Sincerely yours,
Bill Meeker
