Comments on Petition of Pacific Legal Foundation, et al., for Rule-making under the Administrative Procedure Act
On June 6, 2018, the Clinic submitted comments to the U.S. Fish & Wildlife Service and National Marine Fisheries Service opposing a petition from the Pacific Legal Foundation to establish regulatory definitions for the terms “species” and “subspecies” under the Endangered Species Act. The Clinic’s comments, on behalf of several eminent biologists, explain that the proposal is inconsistent with the use of those terms in the scientific community.