2 
is exposed to the dangers of this new research the requirements 
of the National Environmental Protection Act and other laws of 
the land be complied with. 
2. This area of scientific research has perhaps the 
most far reaching potential for harm to the inhabitants of the 
earth that has yet been encountered. Only the uncertainties 
that existed at the detonation of the first nuclear and thermonu- 
clear devices, comes close to the scientific controversy which 
surrounds the issue of recombinant DNA "research. Highly trained, 
well motivated and concerned citizens, even Nobel prize winners, 
are arrayed on both sides of the controversy. The scientific 
details are fully set forth in the annexed exhibits, and the 
affidavits in support of this Motion. In simple terms, what 
confronts the Court is this. 
3. Historically, when science has wanted to alter or 
refine creations of nature to suit human needs and desires, 
it has been required to do so by imitating nature. Just as 
the artic fox, by the process of natural selection, developed 
a white coat for protection in his environment, so science has 
been able to cultivate fatter cattle, and better corn, and more 
beautiful flowers by selectively breeding to obtain the desired 
traits. Such processes, of course, have taken long periods of 
time, requiring birth of the species involved, growth to maturity, 
and selective reproduction. By the same token, science has had 
no success in crossing reproduction barriers laid down by nature 
which prevented the creation of life across certain prohibited 
[Appendix C — 46] 
