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During a fight I had with Bane with him using his Zeus character, he utilized the summon flock of birds power in a very peculiar way. He utilized the currently vague semantics of the power to summon 10 eagles to attack my character. I think it's high time that we clarified the limits of this power and specified it.
In my opinion, summoning 10 eagles for combat purposes is taking this power way beyond the realm of logic or fairness. I always thought this power was restricted to summoning birds that actually fly in flocks, though the vagueness of the wording certainly allows for more imaginative uses. I would strongly suggest specifying the power so that either only birds that actually fly in flocks can be summoned using this power or that birds of preys are permitted to be summoned but only 1 or 2 at the most as opposed to 10 of them as used by Bane. I also understand that it's easy to believe Eagles a logical choice as they are symbols of Zeus but for the purposes of combat something needs to be done.
Specificity here is absolutely necessary. Even two eagles, being very large, powerful, and yet relatively mobile birds, are capable of doing significant damage along with the actions of an opposing character. Some characters and their limited offensive/defensive powers might actually find themselves wholly overwhelmed. Wind goes into pretty good detail above, so I won't repeat what he said, but I'd personally advocate a serious stamina penalty for summoning more than one large or predatory bird; with these birds being permitted to stand in for a flock of smaller ones. Given that birds divide pretty easily into large and small sizes, with the possible exception of Ravens and a few others, this shouldn't be too hard to misinterpret.
We could word it something like The amount of birds varies depending on the size and nature of the bird type. Small birds, such as pigeons, up to a dozen or more, however large predatory birds, such as eagles, only a couple at a time.