only an amalgamat ion of unrelated smaller projects." National 
Wildlife Fed, v. Appalachian Rec. Ccm'n. , 677 F.2d 883, 888 (D.C. 
Cir. 1981). In short, because field testing was contemplated — 
reasonably forseeable — NIH's attempt to disassociate its 
funding actions from the resulting field tests flies in the face 
of the facts and applicable law. 
The NIH is compelled to interpret its Guidelines in accord 
with the foregoing NEPA directives and policies: "The Congress . 
. . directs that, to the fullest extent possible, . . . the 
policies, regulations and public laws of the United States shall 
be interpreted and administered in accordance with the policies 
set forth in [NEPA]." NEPA Section 102(1), 42 U.S.C. S 4332(1). 
In the light of the foregoing analyses, we request that NIH 
reconsider and reverse its interpretation of Section 1-C of the 
Guidelines that led it to conclude that the Argentina experiment 
was not supported in whole or part by NIH funding and that those 
field tests did not violate the NIH Guidelines. 
Your letters of December 9th and 22nd suggest that if we do 
not agree with your interpretation of Section 1-C of the NIH 
Guidelines, a petition to changes its provisions would be 
considered. The Foundation on Economic Trends and Jeremy p.ifkin 
hereby petition the NIH to change Section 1-C as follows: 
Add after the first sentence of the third paragraph the 
following sentences: 
For the purposes of the preceding sentence, the term 
"project" includes any research or development of the 
recombinant organisp or other product or process in 
question, including all such work that is reasonably 
forseeable when the NIH support is received. NIH support 
includes both money grants and any type of in-kind support, 
including research conducted directly by NIH, supplies, 
equipment, the use of facilities, and biological research 
materials. NIH support has been given where the source of 
funds or in-kind support is, directly or indirectly, the 
NIH. 
In our letters to you of November 25, 1986, and December 4, 
1986, we requested your interpretation of the Guidelines on the 
Wistar issue promptly. However, because you chose not to 
disclose your interpretation of Section 1-C until after you had 
made your factual investigation of the matter, we did not receive 
that interpretation until after the closing cate for the agenda 
of the next PAC meeting on February 2, 1987. Accordingly, 
because of the urgency of corrective action on your 
Recombinant DMA Research, Voiume 1 1 
[ 237 ] 
