Document 12 
COLLEGE OF ENGINEERING 
DEPARTMENT OF HUMANITIES 
f 
525 EAST UNIVERSITY 
ANN ARBOR, MICHIGAN 48109 
(313) 764-1420 
October 12, 1976 
Dr. Donald Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
We have read carefully the Guidelines for Recombinant DNA 
Research^ and the Draft Environmental Impact Statement^ written 
as a justification for that action. As you know, we have been 
involved in the issues raised by genetic manipulation experi- 
ments for some time, and have advocated a very conservative 
policy for this area of research and development. The supporting 
papers enclosed give a detailed analysis of the reasons for our 
position. 
Genetic manipulation initiates a new era of synthetic bi- 
ology. Techniques for gene transplantation are not simply novel 
research tools, but instruments for the manufacture of novel 
organisms. Few doubt that these techniques have the potential 
for deliberate misuse to produce highly pathogenic organisms 
capable of disrupting the ecosystem or initiating deadly forms 
of disease. 3 Given our present ignorance of the biological impli- 
cations of novel combinations of genes, it is also possible that 
comparably disastrous effects might result from "peaceful" re- 
search and development . 4 As in the case of other hazardous 
activities, the guiding principle for policy formation must be 
human well-being and security. This must take precedence over all 
other concerns. 
As you have acknowledged, all recombinant DNA experiments 
funded by the government fall within the scope of the National 
Environmental Policy Act of 1969. This act requires that before 
undertaking any "major federal action significantly affecting 
the quality of the human environment," the responsible federal 
official shall prepare and circulate to other agencies and to the 
public a "detailed statement" which describes the environmental 
impacts of the proposed action and alternatives to it.'^^ 
The publication of guidelines prior to the release and con- 
sideration of an environmental impact statement appears to contra- 
vene the provisions of this law. 
Appendix K — 30 
