Comment on FR Doc # 2011-28376

03 October 3, 2011 Dear Sir/Madam I am writing to submit comments on proposed changes to Migratory Bird Permit, Abatement Regulations, Docket Number FWS-R9-MB-2009-0045; 91200-1231-9BPP]RIN 1018-AW75. Your solicitation for comments includes eleven topics of concern. I have responded to eight of the eleven below. (1) Qualifications and experience necessary to qualify for a Federal abatement permit. No additional qualifications or experience should be required. A Master falconer has already demonstrated adequate ability and knowledge by satisfying the requirements of his/her falconry permit. (2) Limits on the species that should be authorized for use in abatement activities. Bird Abatement with trained raptors has many facets and differing requirements. Raptor species needed to perform landfill abatement projects, for example, will differ greatly from species needed on a vineyard or a blueberry farm. Limits on species that should be authorized, would unneccesarily diminish the falconer’s ability to taylor or create an abatement program to address the needs of the client. (3) Limits on the numbers of raptors that should be authorized for use in abatement activities. There should be no limits placed on the numbers of raptors authorized for use in abatement activities. Bird abatement professionals may be employed by a falconry-based company, or be an individual contractor, so quantities of raptors employed in the work may vary. Also, the type of abatement projects performed may prescribe differing needs in quantities of raptors. No limits are placed upon holders of raptor breeding permits for similar reasons. (4) Qualifications and experience of subpermittees (both those authorized to fly the permit holder's raptors and those allowed to care for birds). In my opinion, an individual holding a novice permit, is fully capable of caring for the birds as well as flying the birds in abatement applications as a subperm