Clinic Submits Comments Opposing ESA Petition from Property Rights Group

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 including Professor James Mallet, Professor of Organismic and Evolutionary Biology in Residence in the Department of Organismic and Evolutionary Biology at Harvard University, explain that the proposal is inconsistent with the use of those terms in the scientific community.  If the Services were to grant the petition, they would be violating their statutory duties to list species based on the best available science and would be artificially restricting their ability to identify species and subspecies in need of protection.  Clinic student Shirley Chan (JD ’18) and Deputy Director Shaun Goho drafted the comments.

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