August 22, 1980 
Dr. Donald S. Frederickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20205 
Reference : Request for an 
exception to prohibition 
I-D-4 in order to field 
test corn genes put into corn 
with an E. coli or £. cerevisiae 
vector. 45 Federal Register 
28907 (item 10) , April 30, 1980. 
Dear Dr. Frederickson: 
The Environmental Defense Fund (EDF) hereby re- 
quests the National Institutes of Health (NIH) to prepare 
an environmental impact statement (EIS) on the above re- 
ferenced proposal to field test corn plants (Zea mays ) 
into which corn recombinant DNA has been added using an E. 
coli or S^. cerevisiae vector. 
On April 30, 1980 NIH noticed in the Federal Re- 
gister the proposed experiment by Dr. Ronald Davis of Stanford 
University Medical Center to obtain an exception to the pro- 
hibition of deliberate release into the environment of any 
organisms containing recombinant DNA. 
A final decision on this proposal was deferred, 
pending receipt of additional information (45 Federal Register 
50524, July 29, 1980). The preparation of an EIS could sub- 
stantially aid NIH in obtaining as much additional information 
as a prjeect of this significance should have. 
We wish to emphasize that we do not object either 
to the experiment per se or to the desirable goal of increas- 
ing protein in corn. As George Beadle. :wrote in the Smithsonian 
Magazine recently, "Corn is the most efficient of all cereals 
m converting solar energy, carbon dioxide, water and mineral 
nutrients into foodstuff. It is now the world's .third most 
important food crop. . ." 
For American agriculture, the story of hybrid corn 
is well known as "one of the great contributions of science 
Environmental Defense Fund, 1525 18th Street NW, Washington, DC 20036 (202) 833-1484 
OFFICES IN: NEW YORK, NY (NATIONAL HEADQUARTERS); WASHINGTON, DC; BERKELEY, CA; DENVER CO 
