Have peregrine
falcons and bald eagles recovered in Ontario to the point that the Province of Ontario should be down
listing them?
Our provincial
government believes that both should be down-listed.
What do you
think?
You have been given the opportunity to comment on the Ministry of Natural Resources’ proposal to down-list both the
peregrine falcon and bald eagle here in Ontario!
While the official deadline for responding to the MNR's proposal has past, we believe that it is our elected officials' duty to continue to listen to their constituents, and we encourage you to continue to send your comments and thoughts along to them.
Take a look at some of the facts, and ask a few questions to help you
all better understand the situation!
Some History:
After more than three decades of
recovery efforts devoted to the peregrine falcon here in Canada by both the federal
and provincial governments, and a host of private groups and
organizations, the news does look
promising for the peregrine falcons here in Ontario, but many unanswered
questions have been raised with regards to the Ontario government’s proposal to
remove the peregrine from the endangered species list since it was issued by
the Ministry of Natural Resources in an announced made on June 28th, 2005.
The Ministry of Natural Resources
in
As part of the same announcement,
the MNR wants to change the status of the bald eagle in
Despite the fact that the number of
the peregrine falcon pairs indicated on the official press announcement differs
somewhat from the number that was officially filed in their EBR Registry file -
# RB05E6803, we will, for the sake of argument, and for the benefit of those
that don’t understand the discrepancies with the numbers, use the facts that
have been outlined on the MNR’s official proposal.
Within the same proposal, it is
also proposed that the bald eagle be down-listed (or improved in its status)
and be changed to a species of “Special Concern” in the northern regions - (due
in part to its increased population and a lesser risk of environmental
contaminants (at least while the bald eagles stay in this particular area *). It proposes that the Bald eagle stay listed as
an “endangered species”, but only in the Southern parts of
*Yet another matter of contention,
as many of the young juvenile/non-adult bald eagles have quite an interesting
dispersal range! Bald eagles do not
reach maturity/ breeding age until they are between four and five years of
age. Like many of the young juvenile
peregrines, they can wander quite extensively throughout the province, and
south into the
In an effort to help us all
understand the logic, due in part, that both of these species are migratory (with
the peregrine being one of our great migratory pro’s), and the fact that a good
part of its fate depends on it having “success and good fortune” while it is
outside of our borders, and away from our country’s protection, let us take a
closer look at the peregrine falcon population, and some of the things that you
have been told. We can discuss a little
later the things that you have not been told about the situation and the species.
Some brief
peregrine History:
Let us very quickly take a look at
some of the reasons that the peregrine falcon and the bald eagle were
identified and listed as an endangered species in the first place. You all know the story by now.
The problem was identified as environmental
contamination due to extensive pesticides use (in particular, DDT).
We sprayed and applied DDT on our
agricultural areas (on our crops) here in
We were told that this one single
contaminant played a major role in nearly wiping out many of the peregrine
populations here in North America and drastically reduced both the peregrine falcon
and bald eagle populations here in Ontario in the 1960's and early 1970's. The term “extirpated” has been used to
describe the peregrine’s status as a breeding / producing population both here
in
With
peregrine and bald eagle populations around the continent in serious decline,
the alarms went off and the race was on to find out why!
Thanks to the hard-working efforts
of many people, the federal and provincial governments, some good biology and sound
environmental toxicology investigation, the problem was finally identified, and
this resulted in the banning of DDT in both
In addition to this story, we have
also learned that DDT is a known cancer-causing agent (and thank goodness for
the peregrine falcon for helping bring some of this story to our attention). It is worth noting that while DDT has been
banned in Canada and the in the USA., sadly, DDT and other far more dangerous
chemicals and pesticides are still being used extensively on this continent in Mexico and in Central and
South America as we speak today!
That being
said (and despite what we might all think we know, contrary to those facts that
are stated in the provincial authority’s proposal to down-list the peregrine
and bald eagle as it has been filed), we must, for the sake of some clarity and
argument, use only the facts presented by the government in its proposal, as
submitted to the EBR Public Registry, to down-list these two species.
What are we being told in the MNR’s
proposal to down list the two species in
-
both the peregrine falcon and bald eagle populations in Ontario have
recovered significantly since DDT and other harmful pesticides have been
banned, and as a result of both natural and artificial breeding program
successes of the species, they no longer need the protection of the endangered
species act here in Ontario.
With
regards to the peregrine falcon:
You are being told (in part) that
-
the Ontario Peregrine population
is now currently at 56 pairs (or 126 birds).
- the majority of the 56 pairs of peregrine
falcons in
- twelve of the current 56 Ontario peregrine
pairs (or approx. 20% of Ontario’s entire population) can be found nesting on
city buildings and other structures in/on and around urban locations in the
southern parts of Ontario.
- the Anatum sub-species of the peregrine falcon,
which breeds in
- the peregrine falcon will no longer be
protected by the endangered species acts, but would in turn continue to be
protected as a Specially Protected Raptor under Schedule 7 in the Fish and
Wildlife Conservation Act (FWCA) (which protects them from being hunted or
trapped), and that the nests, eggs, and habitats of the species would receive
similar consideration with regards to their protection.
With
regards to the bald eagle:
You are being told (in part), that
- the
- the population level is highest
in the North-western Ontario and is increasing in southern
- the bald eagle populations are
both safe and sound in their northern strongholds, but still at risk in the
southern regions.
For the most part of this happy
little story for both species (at least as it is presented), everything sounds
rather good, doesn’t it? As you know, packaging and presentation,
is of course everything.
So then, what is not being said, and what are
you not being told?
First, let us ask some simple questions that really need
to be answered by the
- After more than 30 plus years of
recovery efforts for the peregrine falcon here in
- What are the targets and goals set
out and outlined in the provincial peregrine recovery strategy plan?
- and how does it differ from those
set out from the National peregrine recovery strategy plans?
- Where have these numbers and
statistics come from?
- What formulas were used to arrive
at these conclusions?
- What does
- How old is this historical data?
- Who collected and who assembled
this historical data?
- Was this data ever verified
during its collection?
- Was this data ever verified?
- Who verified this data?
- How accurate is this historical
data?
- How reliable is this historical
data?
- Excluding the twelve “urban
territories” in the south (referenced in the MNR’s proposal to down-list the
peregrine falcon that the Ministry had considered “artificial or surplus” due
to the fact that these territories are on man made, privately owned buildings
that cannot be prevented from demolition at the stroke of the building owners
pen), how many of the historical peregrine territories in the province are in
fact occupied?.
- How many of the existing twelve urban
territories in southern Ontario will be drastically changed, modified or demolished,
making them either non-existent or unsuitable for peregrines?.
- How many of the 44 northern peregrine
territories surveyed are historical nesting territories and how many of them
are currently occupied with “producing pairs”?
- With well documented evidence of
peregrine mortality being upwards of 80%, what are some of the factors accredited to and responsible
for this high mortality rate?
- Does this high peregrine
mortality rate apply only to peregrines in “other states, provinces and countries”, or does it also apply to our
provincial population of peregrines right here in
- How does the adult peregrine
mortality rate differ from that of the juvenile mortality rate?
Given that
the population has been broken down and described to us as “Northern Ontario”
and “Southern Ontario - Urban” territories, let us also direct and focus some
of our questions to the “non-urban” - Northern Ontario territories.
Keep in mind
that almost 80% of the entire provincial population of
- Of the occupied territories
surveyed in the north (those other than the
- Of the surveyed peregrine
territories, how many are occupied by juveniles (non-breeding age peregrines), how
many of them are occupied by sub adult peregrines and how many of them are
occupied by adult breeding age peregrines?
- Given what is known about the
environmental toxicology challenges for the peregrine falcon, and its effects
on the species (particularly with regards to the effects of these toxins both
on the peregrine’s egg production and hatch success), how many eggs were
actually produced by these individual breeding pairs at these surveyed territories?
- How many of these same
territories were actually occupied by breeding pairs of peregrines and how many
young were actually produced?
- How many of these young survived
to fledge age?
- How many of the fledged juveniles
survived to the fall?
- How many of these juveniles
migrated?
- Where did these juveniles migrate
to?
- How many of these juveniles returned
from migration, and where have they return to?
- What is the adult turn over rates
with these pairs at these territories, and what is the adult mortality in these
instances?
- How often is a provincial survey
being conducted in
- When was the last provincial
survey conducted?
- What are the results of this
previous provincial survey?
- What were the results of the
provincial survey before that?
- Understanding that a provincial
survey is conducted only once in every five years, what other peregrine monitoring program exists in between
these five year surveys, and who is responsible for doing this monitoring?
- What types of things are actually
being monitored?
-What are the results of any testing that was
conducted during these monitoring programs?
- How much of the central and
southern
Other
information that you should be aware of:
- Are you aware that the peregrine numbers
being used by the government on the proposal to down-list the peregrine are as
of this date, both out of date and incorrect with regards to the current
numbers of actual occupied territories?
- Are you aware that the 2005
provincial peregrine survey had to be conducted over a two year period, with
only half of the territories having been surveyed last year in 2004, and the
other half being surveyed this year in 2005?
- Are you aware that the many of the
territories in Northern Ontario that were surveyed last year in 2004 were not
surveyed again this year in 2005, and
that the possibility exists that these 2004 territories may no longer be
occupied this year in 2005, let alone with adult producing pairs?
- Are you aware that many of the MNR
biologists in
- Are you aware that there are
three very different distinct sub-species of peregrine falcons in
- Are you aware that many of the
peregrines currently being counted / surveyed here in
- Are you aware that important
research is currently being conducted and investigated by the National
peregrine falcon (Anatum) recovery team, the federal government and Queen’s
University (with Ontario being one of the many collaborators) to better understand
the anatum’s true genetic make-up – research that would better help us
understand if we actually have adequate numbers of the anatum subspecies to
sustain local populations here in Ontario?
- Are you aware of the current
testing of Ontario’s peregrine falcons by the federal government for PBDE’s
(Polybrominated Diphenyl Ethers - better known to us as “fire-retardants”), due
to the concerns of PBDE’s being found in our environment and their effects on
our peregrines?
- Are you aware of published reports
from researchers in the European Union, where PBDE’s have been found in higher
levels in the eggs of peregrines than in any of other eggs of birds tested to
date, and (as published in the same report), PBDE’s have shown up in higher
levels in the peregrine falcons themselves than in any other wildlife tested globally
to date?
- Are you aware of the ongoing
testing by researchers in the State of
- Are you aware of the migratory
habits of our peregrine falcons, in which all of the northern territorial adult
peregrines (and most all of the juvenile peregrines produced each year here in
Ontario) migrate south, where a large percentage of them winter outside of this
country and province and some winter in countries where there is still
widespread use of DDT?
- Are you aware that there are
still many threats, which, especially in regards to environmental toxicology and
contamination issues, still pose potential problems for
- Are you aware that the MNR itself
has no regularly scheduled toxicology and contaminants testing/analysis for our
- Are you aware that our Ontario migrant
peregrines could be at further risk when they fly south, leaving the protection
of our borders, and winter in other countries, where they face a future
possible threat of a legal harvest (or the trapping and take of peregrines)?
- Are you aware that both Central
and South American countries, where our peregrines have been found wintering,
have absolutely no laws at all in place to protect peregrine falcons?
- Are you aware that there is
difference of opinion from within the Ministry of Natural Resources itself,
regarding the proposed down listing of the peregrine species in
- Are you aware that there are questions
being raised regarding the credibility and accuracy of some the old historical
records that are being used (in part) to provide some model numbers for the
purpose of the proposal to down-list the peregrine falcon in Ontario?
- Are you aware of the potential
risks (and the risk assessments) should any of these known threats affect this
rather small provincial population of peregrine falcons?
- Are you aware that the provincial
government has told us that a minimum of five thousand eight hundred human
beings die each year as a result of air pollution and smog in Ontario?
- Are you aware that peregrines
operate at 95% of their peak performance and have very small lung capacities?
- Are you aware of the effects that
air pollution and smog are having on the peregrine falcon, with regards to its
ability to absorb the oxygen that it needs to be able to perform at 95% of its
peak performance (to hunt)?
- Are you aware of the deaths of
peregrines and bald eagles from other poisons, toxins, dieses and viruses that
are only quietly spoken of, such as the those deaths attributed to the West Nile Virus, botulism, Avitrol,
Mercury, and lead, to name just a few?
- Are you aware that several of our urban peregrines
were killed by humans after having been shot in the head by pellets fired from
guns, while another was shot and killed by buck shot believed to have been fired
from a larger caliber gun?
- And lastly, are you aware of the
differences between the Endangered Species Act and the Fish and Wildlife Conservation
Act, with regards to fines and potential jail terms for violating these acts?
The Fish and Wildlife Conservation
Act is far less of a
deterrent than the Endangered Species Act.
A final last comment and question for you to consider:
Being aware that both the peregrine falcon and
the bald eagle are on the top of their food chains, and that fact that they are
dramatically affected by environmental contaminants, and given that both of
these species have proven themselves as superstars as environmental indicators
(one of our more natural first lines of defence alerting us to the presence of
harmful toxins in our environment), the down-listing of these two species could
mean less monitoring, less protection and less public awareness of environmental
issues that affect us all.
There are many more questions than there
are answers!
Taking into account all of the many factors, the many unanswered questions, the small and
still fragile provincial population, and the many potential risks that our
Ontario peregrine population currently still faces, I would suspect that anyone
wanting to protect our peregrine falcons would never propose that the peregrine
falcon of Ontario should be down-listed at this time.
Do you believe that this proposal to down-list the peregrine falcon in
I do!
What do you think?
Sincerely,
Mark Nash
To voice
your opinions, objections and concerns to the Ontario Ministry of Natural
Resources with regards to this proposal to down-list the peregrine falcon in
You can view the proposal at: http://www.ene.gov.on.ca/envregistry/025652er.htm
Proposal to
down list the Peregrine Falcon in
Attention: Chris Risley, Species
at Risk Unit
Biodiversity Section, MNR Fish and Wildlife Branch
300
PHONE: (705) 755-1838 FAX: (705) 755-1788
e-mail - chris.risley@mnr.gov.on.ca
In addition, should you feel that this proposal for
the down-listing of the peregrine falcon in Ontario is pre-mature, you should
write, fax and e-mail both the Ontario Minister of Natural Resources here in
Ontario, Mr David J. Ramsay and the Premier of
Ontario, Mr. Dalton McGuinty,
IN ADDITION, don’t forget to write, call and fax your
local M.P.P.
You should also send duplicate copies of your
comments to:
Ramsay,
Hon. David J
Phone: (416) 314-2301 Fax
- (416) 314-2216
Address:
Hon. David Ramsay
Whitney Block
6th Flr Rm
99 Wellesley St
Toronto
AND/OR
Ramsay,
Hon. David J
Phone: 705-567-4650 Fax: 705-567-4208
dramsay.mpp.kirklandlake@liberal.ola.org
Address:
Hon. David Ramsay
Member, LIB - TIMISKAMING - COCHRANE
29
AND/OR
Ramsay, Hon. David J
Phone: 705-647-5995 Fax: 705-647-1976
dramsay.mpp.newliskeard@liberal.ola.org
Address:
Hon. David Ramsay
Member, LIB - TIMISKAMING - COCHRANE ALTERNATE ADDRESS
99
PO Box 398
New Liskeard, ON P0J 1P0
AND/OR
Ramsay,
Hon. David J
Phone: 705-753-9965
Address:
Hon. David Ramsay
Member, LIB - TIMISKAMING - COCHRANE ALTERNATE ADDRESS
You can also mail, e-mail and fax your
comments to:
Dalton.McGuinty@premier.gov.on.ca.
If you prefer to send your views via regular mail or
fax, please send your comments to:
Queen's Park
Fax: (416) 325-3745