Interdisciplinary Doctoral Program in 
Molecular and Cellular Biology 
Irvine Hall 
Athens, Ohio 45701-2979 
614/594-5816 
Ohio 
University 
Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Dear Director: 
Mr. Jeremy Rifkin’s letter, recorded in the September 20, 1984 issue of the 
Federal Register, urging the Recombinant DNA Advisory Committee (RAC) of the NIH 
to ban any research involving gene transfer among mammalian species is cause for 
concern on several points. My concerns are presented below. 
Mr. Rifkin’s claimed basis for the proposed ban is that it would violate 
the right of species to purity of their germlines. This claim is erroneous on 
at least two points founded in biology. First, it is illogical to claim as a 
n right n something that does not now exist in nature. Last year Dr. Barbara 
McClintock was awarded the Nobel Prize for her work demonstrating transposable 
elements in maize. Subsequent to Dr. McClintock's elegant studies in maize, 
other researchers have shown that transposabi lity is a common phenomenon in 
nature. Furthermore, it has been well-established that retroviruses contain 
genetic information and enzymes that allow insertion of DNA copies of their 
genomes into the genomes of mammals and other organisms. Thus, "purity” of the 
germline of species is certainly a non-existent condition. Secondly, from the 
biological perspective, sexual reproduction is a great step forward in promoting 
the adaptability of species and, thereby, the survival of the species. The 
obvious reason for this is that the combination of genetic traits from two 
individuals increases dramatically the variation within the species, increasing 
the likelihood that some individuals within the species will be able to survive 
to reproduce under a wider range of environmental conditions than would be true 
without that variation. This makes clear two important facets of nature: 1) the 
germlines of sexually reproducing plants and animals are not "pure” in any sense 
of the word, and 2) individuals that possess unusual (for their species) genes 
may be, but are not necessarily, extremely valuable for the future of that 
species. Thus, one or a few genes "do not a species make”, but they can be very 
useful to that species if they allow the individual to survive to reproduce. It 
probably need not be stated, but if rare genes are harmful the individual 
bearing them is less likely to survive to reproduce. The point is that species 
are not static genetically; rather, they possess the genetic information to 
survive and compete within the limits of the degree of genetic variation 
existent within the species. 
Man, since the beginning of agriculture, has been practicing genetic 
manipulation of plants and animals. This has occurred as man has attempted to 
select superior plants and animals for agricultural production or for com- 
panions. Thus, domestic swine, cattle, horses, sheep, dogs, cats, and chickens 
(for example) are vastly different from their original wild ancestors, but the 
capacity to interbreed is still complete when domestic animals and wild animals 
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