criteria as to the meaning of "into the environment" in 
coordination with other federal agencies. While, as is true of 
many regulatory situations, that criteria may have to be modified 
as experience dictates, it can be made sufficiently flexible to 
include all experiments that must be reviewed and, at the same 
time, provide much needed guidance. 
Turning to the RAC Working Group recommendation developed on 
December 5, 1986, a fundamental problem with proposed Section 
III-A-2 and subsection a thereof (in both parts II and III of the 
Notice) is that the essence of the change from the current 
III-A-2 is the expansion of the exemptions as will be established 
by the evidence to be described in Appendices L, M, N and 0. 
With the exception of existing Appendix L for certain plants, the 
other appendices are not yet developed. Therefore, at this time, 
there is no basis whatsoever for approving their creation or for 
making the other proposed changes in III-A-2 and developing 
subsection a to accomodate them. In short, the proposal is 
premature. 
We request that if and when it is decided to develop the 
appendices, there be full and adequate represention of the wide 
variety of disciplines relevant to that undertaking among the 
voting members of the working group or committee assigned that 
responsibility, including micro-ecologists and other ecologists. 
Our other comments relating to part II are discussed below. 
III. We oppose both options submitted by the Working Group. 
While the Notice states that "[t]he working group were split as 
to whether they preferred dealing with this problem by changing 
the definition of recombinant DNA or by further modification of 
other sections of the Guidelines," the overwhelming majority 
voted against changing the definition (Option 1) by 7 to 2 with 1 
abstention . 
One obvious problem with Option 1 is that it would mean no 
NIH review of deletions and rearrangements within the human 
genome. 
A problem with both options (and with proposed Section 
III-A-2 and subsections a and b under II), is that the mutations 
included within subsections b and c can present serious risks of 
adverse ecological and health effects. Some of these problems 
were described by Dr. Frances Sharpies, a member of the Working 
Group, at the most recent meeting of the RAC. 
The significant and continuing controversy over these (and 
similar) proposed taxonomic definitions as a basis for 
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