Dr. D. Fredrickson, Director 
April 16, 1976 
cumulatively significant impact on the environment," and "actions, the 
environmental impact of which is likely to be highly controversial" (38 
Federal Register 20550, August 1, 1973, Section 1500.5). Similar and 
more detailed guidelines have been established by the Department of 
Health, Education, and Welfare (general Administration Manual, Chapters 
30-10, 30-11, 30-12, 30-15). •* 
The issuance of guidelines or regulations for recombinant DNA 
research appears to fall clearly within both of the categories quoted 
above, and thus within the requirement that a detailed statement be pre- 
pared and circulated prior to their adoption. The direct impacts of 
such regulations would include at least the risk of inadvertent release 
of new and potentially dangerous forms of life into the environment; the 
indirect and cumulative effects could include a wide range of significant 
ecological changes, particularly if the dreams of some advocates of this 
research are realized in widespread industrial applications. 
However, I am not aware of any statements of your intention to 
prepare such a statement, nor of any efforts yet made to do so, despite 
language in the CEQ guidelines that these activities should be undertaken 
"as early as possible and in all cases prior to agency decision concerning 
recommendations or favorable reports on proposals" (38 Fed . Reg . 20550, 
Section 1500. 2) . 
I should appreciate, therefore, the following information: 
(1) Notification as to whether any Environmental 
Assessment, Marginal Impact Statement, or Environmental Impact 
Statement has been prepared for this proposed action, or as to 
whether you intend to prepare such a document (and if so, which); 
and 
(2) A copy of any Environmental Assessment, Marginal 
Impact Statement, or Environmental Impact Statement when it is 
prepared, for review and an opportunity to comment on it. 
I would hope that such a document would give particular attention 
not only to the various impacts that might result, both locally around a 
research facility and generally as a consequence of pursuing research in 
these areas, and to the major areas of continuing uncertainty that exist; 
but also to careful discussion of major alternatives to these proposed 
guidelines. These alternatives include at least the alternative of 
(a) banning certain forms of this research; (b) delaying the pursuit 
of them until further research and testing of safety measures can be 
carried out; (c) limiting research to a few strictly controlled 
facilities; and (d) establishing broader guidelines or legislation to 
control such research by industry, the military, and other potential 
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