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And God said, Let the waters bring forth abundantly the moving creature that hath life, and fowl that may fly above the earth in the open firmament of heaven.

New Defender's Study Bible Notes

1:20 open firmament. Both the “lights” (Genesis 1:15) and the “fowl” are said to be in the “firmament of heaven.” However, the fowl were to be in the “open” (Hebrew pene) firmament of heaven, or better, “the face of the firmament of heaven.” Thus, birds fly only in the lower reaches of the vast spaces of the heavens. Or, it may be that there are two different “firmaments of heaven.”

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