November 8^th, 2006

Chief, Division of Migratory Bird Management
U.S. Fish & Wildlife Service
4401 North Fairfax Drive
Stop 4107
Arlington Va., 22203
Attn Please: Mr. John Trapp

Ref: D.O.I. USF&W Fed. Register 8-24-06 50 CFR part ten, RIN 1018-AB72
General provisions of the Revised List of Migratory birds, (MTBA) in particular:

1. The Eurasian Siskin (Carduelis spinus)
2. The Common Chaffinch (Fringilla coelebs)

Dear Mr. Trapp

As third term president of the National Finch & Softbill Society (NFSS) I feel obligated to offer my studied comments on the proposal (above) to list birds (a) and (b) within the MBTA.

These species are NOT native to the United States nor do they migrate to or through U.S. territories. I could find no reported sightings of either of these birds in the U.S. We at NFSS are aware that some non-native species were accidentally released in Puerto Rico some years ago when an import or quarantine station had a major release accident. There are no reports the Siskin and Chaffinch were among those escapees, and are breeding, hence, possibly ‘becoming’ native species to U.S. Territories.

As it is, these birds are bred by very few U.S. hobbyists and others interested in captive breeding. For instance, current available information reveals that in 2003 NFSS annual census reported only two out of eight-hundred NFSS members registered working with the Common Chaffinch and the same two members registered working with the Eurasian Siskin. In 2005 the NFSS "Finch and Softbill Save Program" (designed to assist breeders and hobbyists in managing and exchanging bloodlines for purity) did not list any breeders working with or researching the Chaffinch or Siskin. In fact, only one European finch was registered as being worked with, and that was the European Goldfinch (Carduelis carduelis). A recent search of the literature, internet, ornithologist and Audobon listings did not indicate a single qualified sighting of either subject finches. All sightings we found were declared "not accepted, natural occurrence questionable." Another phrase "accidental" (in Maine and Massachusetts) appears to accept that these birds do accidentally venture into Northern U.S. during migration, but do not settle. In view of this data, listing these birds under the act, and following through with the requirements of the act, appears to have no real lasting value.

Very Respectfully

Sally C. Huntington

Life member American Federation of Aviculture
Participating member of Model Aviculture Program
Member – Zoological Association of America
Life member and past president – Finch Society of San Diego County
Contributing author – Hand Rearing Wild and Domestic Birds (Chapter - Hand Rearing Foreign Finches.
Rebecca Duerr DVM/MPVM U.C> David School of Veterinary Medicine & Blackwell Publishing CO. In press for Spring 2007.

Cc: American Federation of Aviculture
Zoological Association of America publication editor
San Diego Zoo and Wild Animal Park
NFSS Journal Editor
Finch Society of San Diego County