As expressed in the aforementioned complaint, such agency 
exemptions, in that they are based, inter alia , on insufficient 
scientific data and are made without the proper environmental 
documentation, are violative of the APA and NEPA. 
We request that you take into consideration our position as 
stated above in evaluating the proposed NIH action of exempting 
gene deleted or rearranged products from review. 
S i ncere 1 y , 
Edward Lee Rogers 
Counsel for Foundation 
on Economic Trends 
Enclosures 
Recombinant DNA Research, Volume 1 1 
[ 227 ] 
