Friends of the Earth 72 Jane Street • New York, New York 100M • (212) 67S-5911 
September 21, 1979 
Dr. Donald S. Fredrickson 
Director 
National Institutes of Health 
Bethesda, Maryland 20014 
Dear Dr. Fredrickson: 
We are writing to request that an environmental impact 
statement be prepared for the proposed exemptions from the 
recombinant DNA guidelines which were considered at the 
September 5-6 meeting of the Recombinant Advisory Committee. 
The proposed exemptions are of such breadth and importance 
as to require full compliance with the National Environmental 
Policy Act (NEPA). The proposed exemptions are certainly 
controversial, as evidenced by the 10 to 4 vote, with one 
abstention, by the Recombinant Advisory Committee. Further- 
more, recently obtained risk assessment data is subject to 
differing interpretations, leading us to believe that 
further assessment is necessary before such action is taken. 
The proposed exemptions plainly constitute a major federal 
action which may significantly affect the environment. 
As you know, we have been dissatisfied with previous 
actions in the recombinant DNA program, both with respect 
to NEPA compliance and the rational consideration of risks 
in the conduct of recombinant research. The question of 
appropriate safeguards should not be decided as a result 
of pressure from the scientific communitv, because of letters 
signed by x hundred scientists, or because of paperwork 
involved; but rather on the basis of substantive considerations- 
the possibility of adverse environmental impacts and a careful 
exploration of alternatives. 
Our concern is two-fold: that hazards be properly taken 
into account in pursuing recombinant DNA research, and that 
the law be obeyed in conducting this federal program. NEPA 
applies to all federal agencies, and the NEPA regulations 
promulgated by the Council on Environmental Quality are 
mandatory for all federal agencies. As a matter of law an 
environmental impact statement should have been prepared 
prior to consideration of the proposed exemptions by the 
Recombinant Advisory Committee. 
As part of our request for an environmental impact 
statement, we are asking that the Recombinant Advisory 
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