Honorable Sam Hamilton
Director
United States Fish and Wildlife Service
1849 C. Street, NW
Washington, DC  20240
   
Regarding:   Eagle Permits;  
Wild Take Necessary to Protect Interests in Particular Localities

50 CFR Parts 13 and 22
[FWS-R9-MB-2008-0057;
91200-1231-9BPP-L2]
RIN 1018-AV81

Dear Mr. Hamilton,

On September 11, 2009, the U.S. Fish and Wildlife Service (USFWS) published its Final Rule (FR) on the take of Bald and Golden Eagles in the Federal Register. The Final Environmental Assessment (FEA) was published in April of this year. The FR is 45 pages long. The FEA is 210 pages long.  
Golden Eagles have been federally protected under the Bald Eagle Act since 1962; they have never been listed federally as endangered or threatened in any part of their range in the western United States and are currently listed as common.

In 1972 the Bald Eagle Act was amended to allow the USFWS to kill Golden Eagles in designated eagle depredating areas as needed. This amendment also allowed for depredating eagles to be trapped out of the wild for use in falconry.

The American Falconry Conservancy is responding to the FR with the enclosed commentary.  The FR, as published, may have detrimental effects on the legitimate procurement and use of depredating eagles by United Sates falconers.



Respectfully,

James M. Ingram III MD
President, American Falconry Conservancy