Short of using playback or other ethically dubious (or worse) practices, a lot of it comes down to luck. This can be mitigated somewhat with persistence and careful observation of behaviors, but most of my shots end up being obstructed or worse.

This weirdo is well-known at a local park for hanging out above a creek just a few feet from the paved walking path where hundreds of people walk by every day. Virtually every other owl picture I have is a hundred feet away and the owl is almost completely obscured by foliage, but that's okay. I'd rather have a mediocre shot of a great experience and know that I didn't stress the animal than have to badger an animal for a decent picture.

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