COMMENTS OF LIEBE F. CAVALIERI ON BEHALF 
OF THE FOUNDATION OH ECONOMIC TRENDS, 
JEREMY RIFKIN AND HIMSELF 
I am Liebe F. Cavalieri, residing at Old Church Lane, Pound 
Ridge, New York 10576. I am a molecular biologist working in DNA 
research. I am including with this comment an abbreviated 
curriculum vitae. 
I have examined the Coordinated Framework for Regulation of 
Biotechnology issued by the Office of Science and Technology 
Policy. On behalf of the Foundation on Economic Trends, and its 
president, Jeremy Rifkin, and myself, I wish to comment on that 
part of the Framework which deals with the promulgation of the 
Biotechnology Science Coordinating Committee's definitions (and 
the exemptions both explicit and implicit in those definitions). 
These definitions state that, 
excluded [from these definitions are organisms that 
have resulted from the addition of intergeneric materials 
that is well-characterized and contains only non-coding 
regulatory regions such as operators, promoters, origins of 
replication, terminators and ribosome binding regions. 
" Well-characterized and contains only non-coding 
regulatory regions" means that the producer of the micro- 
organism can document the following: 
a. The exact nucleotide base sequence of the 
regulatory region and any inserted flanking nucleotides; 
b. The regulatory region and any inserted flanking 
nucleotides do not code independently for a protein, 
peptide of functional RNA molecules; 
c. The regulatory region solely controls the 
activity of other sequences that code for protein or 
peptide molecules or act as recognition sites for the 
initiation of nucleic acid or protein synthesis. 
I have serious difficulty with the definitions quoted above 
for a variety of reasons. 
At the outset, knowing the exact nucleotide base sequence of 
a regulatory element cannot allow one to predict the biological 
role of this element when placed in another organism. This 
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