THE UNIVERSITY OF CONNECTICUT 
HEALTH CENTER 
School of Medicine 
Farmington, CT 06032-9984 
October 16, 1984 
Dr. William J. Gartland 
Executive Secretary, RAC 
Bldg. 31, Room 3310 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
I am writing to express my strong opposition to the two proposed 
amendments to the NIH Guidelines submitted by Jeremy Rifkin concerning 
gene transfer into germline across mammalian species. His stated 
rationale for these proposals is without scientific basis and is, 
indeed, directly contrary to everything we know about genetics and 
speciation. First, the notion that any species has a fixed genome and 
that change in any single gene threatens the fundamental integrity of 
the species is simple nonsense, given our current understanding of the 
degree of polymorphism and genomic plasticity that is the norm within a 
well-defined species. The implicit corollary, that a species is defined 
by the sequence of any (or every) gene, is therefore a logical 
absurdity: if the cytochrome c’s of human and Macaque monkey differ by a 
single amino acid residue, does a mutation to identity impose a change 
of species on that individual? Secondly, the idea that a species has a 
"telos" is contrary to any evidence provided by biology and belongs 
rather in the realm of mysticism. That mysticism is a poor basis for 
sound public policy is amply confirmed by history. 
I do share the belief that foreign genetic material should not be 
inserted into the human germline without the fullest consideration of 
all the potential implications and the broadest public discussion of 
these. However, there is no reason to undertake such experiments in the 
near future; an enormous amount of additional information will be 
necessary before it is known of such an approach is feasible, much less 
a preferred route to intervention in human genetic disease. In the 
meantime, current NIH guidelines and regulations concerning human 
experimentation clearly provide the requisite safeguards, without the 
necessity of explicit prohibition. This conclusion appears to be 
entirely consonant with the recent report of the President s Commission 
for the study of Ethical Problems in Medicine and Biomedical and 
Biobehavioral Research. 
[529] 
