View Full Version : Submit your comments to the USFWS

06-18-2016, 07:50 PM
From NAFA president Scott McNeff:

The U.S. Fish Wildlife Service (USFWS) is finalizing an Environmental Impact Statement and some new regulations regarding golden eagles. Eagle falconers need our help and are requesting that we submit comments to USFWS before July 5th.

If you would like more information on the issue, including this Draft EIS, the proposed regulations and much more, go to the following website; http://www.fws.gov/birds/ management/managed-species/ eagle-management.php

NAFA General Counsel James Maynard and I, with help from NAFA's Eagle Committee Chairman, Carter Wilford, and his team have drafted an extremely thorough response for this comment period, as a follow-up to the comments that we submitted in September of 2014 We are really happy with what we've put together. These comment periods are valuable opportunities, and we've found that our comments actually do have an impact and can affect change, so please take some time to draft your own letter, or encourage your state falconry organization to submit comments.
Comments should be submitted electronically to:
https://www.regulations.gov/#! documentDetail;D=FWS-R9-MB- 2011-0094-1052

To ensure consideration of written comments, they must be submitted on or before July 5th.

Letters do not need to be lengthy to have an impact. A few polite and professional paragraphs will do the trick. I urge you to address the Service with respect. An aggressive, accusatory, or condescending tone will only serve to damage our standing with the Service on this issue.
Here are some key points for your consideration:
We appreciate the opportunity to offer comments on USFWS's proposed regulations for Eagle Take Permits which allow incidental or non-purposeful take of eagles by wind farms and others.
Access to Golden Eagles for falconry purposes should be “allowed without limitations beyond those necessary for the sustainable use of wildlife as determined by biological science.”

USFWS recently transferred regulatory oversight of falconry to the States and should accordingly defer to individual states to work with USDA Wildlife Services to manage the trapping of Golden Eagles in depredation areas, as allowed for in the Bald and Golden Eagle Protection Act (16 U.S.C. 668a) amended by Congress in 1972.

We request USFWS to collaborate with key eagle falconry stakeholders such as State Wildlife Agency managers, USDA-Wildlife Services, ranching industry representatives, and NAFA to find a long term solution that will allow eagle falconers to trap immature Golden eagles.
Peer reviewed publications by USFWS scientists have documented that falconry take of Golden Eagles has had, and should continue to have no measurable influence on the overall Golden Eagle population, (a population which has been robust and stable for over 50 years, according to studies recently published by the Service)

Falconers are at the forefront of raptor conservation. The well-documented participation of our cultural heritage community in raptor conservation speaks for itself.

Falconers should be viewed as a responsible and conservation-oriented community of trusted partners in ensuring the proper management and sustainability of the raptor resource. Falconers have voluntarily mitigated our non-lethal take of eagles for many years via raptor rehabilitation efforts, public education programs, habitat conservation work, etc..

Falconers are well positioned to participate in Compensatory Mitigation or Species Survival Plan (“SSP”) projects. Falconers are capable of activities involving the propagation and release of Golden Eagles to the wild. USFWS should develop regulations to allow captive breeding of Golden Eagles.

USFWS has adopted a policy forbidding the transfer of rehab eagles to a falconer's license. Many falconers are heavily involved in raptor rehabilitation. USFWS should allow falconers to obtain Golden Eagles from rehabilitators.

The skills which the cultural heritage of falconry has honed and practiced for over 4000 years of human-raptor relationship are valuable assets to the assured survival of the Golden Eagle. As displayed historically with the Peregrine Falcon, falconers are a valuable resource and possess the ability to respond quickly to any raptor population crisis.

UNESCO determined that falconry is an Intangible Cultural Heritage of Mankind. Golden Eagles have been a part of that cultural heritage for thousands of years.

The falconry cultural heritage community has extensive knowledge of golden eagles, and we stand ready to work with energy companies to reduce impact on eagles.

If you want to see what other folks are saying, go to this link;
https://www.regulations.gov/#! docketBrowser;rpp=25;so=DESC; sb=postedDate;po=0;np=90;D= FWS-R9-MB-2011-0094

Don't wait to submit your comments. Please take a few minutes out of your day, and put a letter together. If you're part of a state falconry or raptor related organization, please encourage the leaders of that organization to submit comments on your behalf.

If you have any questions, don't hesitate to contact me or one of the Members of NAFA's Eagle Committee.

Scott McNeff
NAFA President

06-21-2016, 06:58 PM

two of your links are broken. Here are the fixed ones.

Comments should be submitted electronically to:

If you want to see what other folks are saying, go to this link:

That second one is some entertaining reading. The kooks have come out!

06-21-2016, 07:27 PM
Thanks Geoff!

06-27-2016, 03:37 PM
From NAFA president Scott McNeff:

Letters do not need to be lengthy to have an impact. A few polite and professional paragraphs will do the trick. I urge you to address the Service with respect. An aggressive, accusatory, or condescending tone will only serve to damage our standing with the Service on this issue.

I agree, it's important to be polite when writing your comments, but people also don't need to be afraid or intimidated for wanting to tell the truth. Sometimes you just have to call a spade a spade.

On page 107 of the Draft Programmatic Environmental Impact Statement (DPEIS), under §22.24 Eagle Falconry, the FWS writes (in part):

"the Service's Mountain-Prairie Regional Office (Region 6) has adopted a policy of requiring all golden eagles trapped for depredation to be released".

Well, that about excludes any more passage eagles to be taken out of the wild ever again by falconers, since falconers can only get eagles from the wild because of depredation.

And this is in a draft EIS! And that language was in the falconry section of the draft EIS! How many times has language like this ever been written in a Draft EIS where the specific falconry wild take of a non endangered , non threatened raptor was specifically crossed off the list?

I'm sorry, but sometimes you just have to call a spade a spade, even though it may appear to be aggressive and accusatory! We had eagle trapping open in depredation areas for over a decade. It took years to get eagle trapping opened the first time. I'm just lobbying to keep wild take of passage eagles open.

We are stakeholders, whether the FWS likes it or not. Congress said so. We are one of only two groups specifically mentioned by name in the Eagle Act allowing us to acquire eagles from the wild to practice our legal sport!

All my best,