Comment on FR Doc # E9-26154

Dear Sir: On behalf of the Board of Directors of NAFA, I submit our formal comments in the attached PDF file, prepared by NAFA's Conservation Committee, in response to your request for comments to list the British Columbia population of the Queen Charlotte goshawk as threatened, except on the Queen Charlotte Islands where endangered listing is proposed. NAFA is the largest membership falconry organization in the US and the world with approximately 2,000 members, including international members from around the world. We not only promote falconry as a legitimate, legal field sport, but also encourage and support raptor conservation and research on birds of prey. The Northern Goshawk is one of two primary raptor species traditionally used in falconry for centuries, the other being the Peregrine Falcon. The concern that falconers share for the welfare of wild raptor populations was exemplified by the falconry community's response to declining Peregrine Falcon populations decades ago. Recent recovery of peregrine populations has been attributed in large part to the release of thousands of peregrines that was based on captive breeding and release of peregrines using techniques developed by falconers, initiated by falconers, and continued to this day by falconers. We share the concern of many individuals and organizations over the welfare of the Queen Charlotte Goshawks, however we believe there is neither scientific justification for nor conceivable benefit to disallowing take of goshawks from outside the range of A. g. laingi based on similarity of appearance concerns. Furthermore, we believe continued falconry use of wild-taken goshawks from all portions of their range in North America – including Q.C. Goshawks – is biologically sound and likely to continue at such a low level as to be entirely inconsequential to wild populations. Thank you for considering our attached response. Respectfully submitted, Dan Cecchini, President North American Falconers' Assoc.