FOUNDATION ON ECONOMIC TRENDS 
1130 17th Street, NW, Suite 630, Washington, DC 20036 (202) 466-2823 
17 October, 1986 
James Wyngaarden 
Di rector 
National Institutes of Health 
Room 124, 9000 Rockville Pike 
Bethesda, MD 20892 
Dear Dr. Wyngaarden: 
In regards to comments on your proposed actions to remove 
gene-deleted or rearranged organisms from NIH review, described 
in 51 Fed. Reg. 29423 (August 15, 1986), the Foundation on 
Economic Trends, Inc. ("Foundation") wishes to describe the 
actions and comments it has made on this issue, actions and 
comments which have already been addressed to, inter alia, the 
NIH. 
On July 15, 1986, the Foundation, Jeremy Rlfkin and Michael 
Fox filed suit against several federal agencies, Including NIH, 
alledging their failure to comply with the Administrative 
Procedure Act ("APA") and the National Environmental Policy Act 
("NEPA") in the promulgation of the Coordinated Framework of 
Biotechnology as described in 51 Fed. Reg. 23303-23393 (June 26, 
1986). See Foundation on Economic Trends, Inc, et al., v. 
Richard G. Johnson et al ., Civ. No. 86-1956 (D.C.D.C.). 
In this Complaint, specifically in Paragraphs 6, 27-36, 45, 
57. Plaintiffs describe their opposition to, and the potential 
harm caused by, the exclusion of intrageneric genetically engin- 
eered organisms from federal review. 
The Foundation has also commented on the gene-deletion 
exemption provisions of the Coordinated Framework, 51 Fed. Reg. 
23306-9, to the Domestic Policy Council Working Group on Biotech 
nology, of which NIH is a member agency, through the Office of 
Science and Technology Policy. These comments, including 
statements on this issue by Dr. Liebe Cavalier! , citing his own 
view and those of other scientists, indicate that the gene- 
deletion exemption is based on insufficient and inadequate 
scientific data and based on no established predictive ecology 
principles. (See attached copy.) 
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