@report {1140674, title = {Comments on petition of Pacific Legal Foundation, et al., for rule-making under the Administrative Procedure Act (which aimed to promulgate new regulatory definitions of {\textquotedblleft}species{\textquotedblright} and {\textquotedblleft}subspecies{\textquotedblright} under the Endangered Species Act)}, year = {2018}, author = {Mallet, James and Ehrlich, Paul and Gill, Frank B. and McCormack, John and Raven, Peter and Chan, Shirley and Goho, Shaun A.} }