Midrash for Chullin 278:55

א"ר אשי אמר לי [ר'] חנינא

applies both to clean and unclean birds, but as for the term 'zippor', we find clean birds referred to as zippor but not unclean birds.

(Devarim 22:6) "If there chance before you a bird's nest": to exclude what is normally found there.

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