How about if they are maiar?
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Originally Posted by Letter #200
They [valar and maiar] were self-incarnated, if they wished; but their incarnate forms were more analogous to our clothes than to our bodies, except that they were more than are clothes the expression of their desires, moods, wills and functions. Knowledge of the Story as it was when composed, before realization, gave them their measure of fore-knowledge; the amount varied very much, from the fairly complete knowledge of the mind of the Creator in this matter possessed by Manwe, the 'Elder King', to that of lesser spirits who might have been interested only in some subsidiary matter (such as trees or birds).
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these lesser spirits taking care of trees and birds could very well be the same spirits taking care of kelvar and olvar. It can be argued: if they are maiar, why did the elves had to teach them a language - but it is worth noting that even the istari (the "wisest of the maia", Olorin, included) have to re-learn a lot of what they knew, once they are embodied.
The eagles are another interesting matter: in Annals of Aman, Tolkien notes that
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Manwe however sent Maia spirits in Eagle form to dwell near Thangorodrim and keep watch on all that Melkor did and assist the Noldor in extreme cases
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Yet on the other hand, in Myths Transformed, he goes the other way around:
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But true 'rational' creatures, 'speaking peoples', are all of human / 'humanoid' form. Only the Valar and Maiar are intelligences that can assume forms of Arda at will. Huan and Sorontar could be Maiar - emissaries of Manwe. But unfortu¬nately in The Lord of the Rings Gwaehir and Landroval are said to be descendants of Sorontar
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In summary: I think it must be assumed that 'talking' is not necessarily the sign of the possession of a 'rational soul' or fea. The Orcs were beasts of humanized shape (to mock Men and Elves) deliberately perverted / converted into a more close resemblance to Men. Their 'talking' was really reeling off 'records' set in them by Melkor. Even their rebellious critical words — he knew about them. Melkor taught them speech and as they bred they inherited this; and they had just as much independence as have, say, dogs or horses of their human masters. This talking was largely echoic (cf. parrots), in The Lord of the Rings Sauron is said to have devised a language for them.
The same sort of thing may be said of Húan and the Eagles: they were taught language by the Valar, and raised to a higher level - but they still had no fear.
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[It is worth noting also that Myths transformed presents an almost complete change of Tolkien's designs: the coming of the Men is shifted thousands of years back, the Sun and Moon apparently predate the Trees, orcs are in "irremediable allegiance to evil" (while in letter #153 he refutes that idea). All in all, Christopher concludes that this new design is "a fearful weapon against his own creation", so I will go with the "eagles as maiar" idea onwards.]