or COUNSEL' 
SANORA e. HAMILTON 
BOnniC LOUNSBURT* 
LAW OFFICES 
EDWARD LEE ROGERS 
SUITE T-200 
1710 P STREET, N. W. 
WASHINGTON, D. C. 20036 
(202) 307-1600 
■ULINOlS AND MAIMC ONLY 
September 26, 1986 
BSCC : Docket # BSCC 0001 
Office of Science and Technology Policy 
Executive Office of the President 
NEOB - Room 5005 
Washington, D.C. 20506 
The Foundation on Economic Trends and its president, Jeremy 
Rifkin, having examined the Office of Science and Technology's 
Framework for Regulation of Biotechnology, wish to comment on the 
general provisions of the notice. Specifically, we are 
commenting on the BSCC's definitions contained therein. 
At the outset, by submitting these comments, the Foundation 
and its president do not waive any of their claims set forth in 
the pending litigation, Foundation on Economic Trends, et al. v. 
Johnson , et al . . No. 86-1956 (D. D.C. July 15, 1986). 
As the enclosed comments of Dr. Liebe F. Cavalieri, and the 
cited comments of other scientists demonstrate, there is no 
scientific basis or record substantiating the actions of OSTP and 
other agencies excluding intergeneric biotechnology products 
created through the addition of regulatory elements from 
substantial review. Additionally, the exclusion of intrageneric 
combinations and rearrangements from review is equally 
unscientific and arbitrary. For example, the EPA itself admits 
that "science provides no absolute standards" for the 
intergeneric-intrageneric dichotomy upon which EPA predicates 
much of its regulatory structure. 51 Fed. Reg. 23317. As the 
scientists cited above make abundantly clear, intergeneric 
organisms created through the genetic engineering of regulatory 
elements can be "novel" organisms, with all of the attendant 
risks such organisms may present. Thus, such organisms should be 
subject to full review. Similarly, the instability of 
intrageneric gene-deleted or gene-rearranged organisms can make 
them novel organisms, presenting the same types of risks as 
intergeneric biotechnology products. 
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