Thank you for the extended opportunity to comment. I have been a falconer for 45 years, but do not generally comment on abatement regulations because I don't engage in this activity with raptors. I'm concerned with the comments of the North American Falconers Association, of which I remain a long time member. My concern it that NAFA is recommending that wild raptors be used specifically for this abatement activity, and that they support unlimited numbers of wild hawks to be taken for that purpose. My concern is not biological, my concern is that allowing wild raptors to be used for abatement purposes is blatant commercialization of wildlife. I do not wish to see raptors become a "backdoor" avenue for commercial use of our wildlife. Additionally, allowing an unlimited number and species of wild raptors to be harvested for abatement would open up yet another avenue for illicit wildlife trafficking. I support raptors' use in abatement, and I realize there isn't a biological reason for not using endemic raptors, but I view wildlife as part of the public trust. Because captive bred raptors are available for abatement purposes, there is not a compelling reason to allow the use of wild raptors (which would violate this wildlife management concept and policy). so please limit abatement raptors to captive bred individuals, and in only numbers required for this activity. Sincerely, Richard W. Musser
Comment on FR Doc # 2011-28376
This is comment on Proposed Rule
Migratory Bird Permits: Abatement Regulations
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