Quote Originally Posted by 460shooter View Post
That's the problem. Every region says something different. Fed's say one thing in one area, then something else in another.

....why doesn't this surprise me???

Kinda like having 10 different IRS agents do your taxes. I'd bet some serious money that you'd get 10 different answers as to what you owe, or what your refund would be.
You are right, they are shooting from the hip. But the law they all operate from is crystal clear:

http://www.ecfr.gov/cgi-bin/text-idx...1_129&rgn=div8
50 CFR 21.29 (b) (ii):
(2) Reporting. (i) The State, tribe, or territory must work with us to ensure that the electronic 3-186A reporting system (http://permits.fws.gov/186A) for reporting take, transfers, and loss of falconry birds is fully operational for residents of that jurisdiction.


(ii)[This should be subsection (i), they messed up the numbering] If you are required to submit a report or other information under this section, you must either enter the required information in the electronic database at http://permits.fws.gov/186A, or at http://www.wildlife.ca.gov/FalconryReporting if you are a resident of California, or submit a paper form 3-186A to your State, tribal, or territorial agency that governs falconry.
The trouble here is that none of them are really bothering to read it unless it comes time to persecute someone for going astray.

There really is nothing wrong with sending in a piece of paper to the federal regional offices, and NAFA's party line recommendation that we all do this is at worst a bit of overkill. However, the feds and the state cannot REQUIRE this. The law is simply laid out. If you reside in california, use that web site mentioned in the regs. For all the rest of us, while the federal reporting system is down send the info to the State. Its is then the state's job to pass it along to the feds.

If I was asked by a regional fed to send it to them, my response would be to politely point to the rules I just quoted and tell them that it is not my job. Its not that I am being confrontational, or obstructive. Its just that I have plenty of other things to worry about which are my responsibility and enough drains on my finances already.

I am sure the state agencies can apply a lot more pressure to get this resolved than we can.