Comment on FR Doc # 2011-16880

As stated falconry and abatement are fundamentally differenent activities. Considering this statement by USFWS, then an abatement premit holder should not be required to hold a Master falconery license. At most the permit holder should have had at one time held a falconry license and or had 2 years experience with raptors. If no federal permit is required to flush or haze deperdating birds with exceptions of endangered or threatened species then there is a 2 nd caes for no master class falconry license requirement. If one can conduct fundamentally the same activity using a Special use permit and that permit does not require a master class falconry permit the same restrictions should apply in both cases. No falconry permit required. As the regulations clearly explain that captive bred species are private property and non native species not covered under use of a 3-186A form can be held by anyone. If the abatement work is being conducted using these types of birds then there is further cause to throw out the federal or state master falconry permit requirement in conjuction with an abatement permit. I believe the abatement sub permitees should also be held to the same rules as the licensee. I believe all housing equipment and transport requirements should stay in place.