Comment on FR Doc # E7-24347

Dear USFWS, Please find attached information from BirdLife International which we hope will be useful in your consideration of the proposal to add six Pterodroma species to the US Endangered Species Act. The attached documents are the draft 2008 BirdLife Fact Sheets for these species. These represent an update from the 2004 fact sheets that are currently available on the BirdLife and IUCN websites. These 2008 fact sheets will not be published on the BirdLife website until May 2008, but we wanted to make them available to USFWS for your consideration. Our main comments are as follows: There is a statement in the petition that all seabird species are threatened by bycatch in fisheries, citing BirdLife International as the source (see first paragraph Page 5 on Chatham Petrel, and then repeated in the sections for the other 5 species). This is an incorrect representation, please could you correct it? The correct statement is that bycatch in fisheries is known to be a major threat to some seabird species. Better citations for this would be Gales 1993 and BirdLife International 2004 (Gales, R. 2003. Cooperative Mechamisms for the Conservation of Albatross. Division of Parks and Wildlife, Tasmania, Tasmanian Govt. Printer. 132 pp.; BirdLife International (2004) State of the world?s birds 2004: indicators for our changing world. Cambridge, UK: BirdLife International). Please could you remove the reference to Mike Rands and BirdLife International News 2003. These six species under consideration by USFWS are of high conservation concern (Chatham, Fiji, Galapagos and Magenta are listed as Critically Endangered on the IUCN Red List; Magenta Petrel is Endangered; Heinroth?s Shearwater is Vulnerable). However, you will see that neither bycatch or fisheries are mentioned in 5 of the 6 attached fact sheets. BirdLife does not list bycatch in fisheries as a threat to these 5 five species. The ?Threats? section in each fact sheet summarises what BirdLife International (and the experts which it has consulted for each species) considers to be the threats to each species. Predation by introduced predators and risk at breeding colony are the primary threats in most cases. For Galapagos Petrel, bycatch in longline fisheries in the East Pacific is listed as a threat in addition to predation, disturbance and habitat destruction at the nest site, and collisions with fences and power lines at the nest site. There are few data on the extent of the impact of fisheries on this species, and BirdLife does not have evidence to suggest that fisheries are a primary threat. The section on ?Conservation measures proposed? includes an action to quantify the impact of fisheries on this species. We appreciate the opportunity to provide input into this process, and please contact me if you would like any further information. Best wishes Cleo Small