Great horned owls prefer large stick nests in fairly open situations over smaller, enclosed leaf nests.
Observations in the Ithaca region suggest that when there are several satisfactory nests in a territory the great horned owl will choose a larger nest preferably in a fairly open situation. It is obvious that a nest completely enclosed by interlacing branches would not allow such bulky birds to approach or depart quickly in time of emergency and most nests are at least moderately exposed. In general stick nests seem to be preferred to leaf nests. This is probably due to the fact that they are larger and offer firmer foundations.
However, at times, horned owls display little care in their selection of tree nests, adopting structures so dilapidated and flimsy that they fall apart and dump the young out onto the ground. The nest may be so small that the bird is quite conspicuous or even ridiculous when covering eggs or young.
Few data are available on preference regarding other types of nests, but it appears that the same requirements hold-a spot fairly open yet concealed, which is large enough for the needs of the young until they are able to move about freely. Nests located on ledges or in niches or caves are generally sheltered from the wind, rain, and sun, although the situation permits the young to bask in the sunshine at the entrance.