University of Illinois at Urbana-Champaign 
INSTITUTE FOR 
ENVIRONMENTAL STUDIES 
Environmental Research Laboratory 
1005 West Western Avenue 
Urbana, Illinois 61801 
217-333-3820 
January 12, 1983 
Dr. William J„ Gartland Jr., Director 
Office of Recombinant DNA Activities 
NIAID 
National Institute of Health 
Bethesda, MD 20205 
Dear Dr. Gartland, 
This letter is in response to the request for comments printed in the Federal 
Register, Vol. 47, No. 235, pp . 55104 and concerns the report entitled "Evaluation 
of Risks Associated with Recombinant DNA Research" published in Vol. 4, No. 4 (Dec. 
1981) of the Recombinant DNA Technical Bulletin . 
The most striking thing about this report is its movement from a small amount 
of specific knowledge to some broad generalizations that in my opinion need to be 
circumscribed more carefully. 
Let me point out an area where I feel knowledge is inadequate or a serious 
signpost of environmental safety. Relating to the basic assumptions that the 
report concludes to be improbable, "that a unique organism, never found in nature, 
might be constructed by recombinant DNA techniques", has anyone considered the 
recombination of DNA from eubacteria and archaebacteria? If Carl Woese is to be 
believed, these organisms are as far apart on the evolutionary scale as E. coli 
and Homosapiens . It is also possible that they do not exchange DNA under normal 
circumstances. Do you know of any work showing the exchange of DNA among archae- 
bacteria, let alone between eubacteria and archaebacteria? The second assumption, 
"that such a unique organism might be able to establish itself in the environment 
outside the laboratory", is a possibility since many archaebacteria reside at low 
densities in habitats where they have few competitors. The assumption that this 
putative, unique recombinant organism might be harmful to plants, animals or man 
is unknown, but it must be remembered that archaebacteria participate in unique 
steps of the global carbon cycle 0 The fact is that we are so ignorant of the 
biochemistry, let alone the molecular biology of the archaebacteria, that any 
assertions of harmfulness or harmlessness of recombinant archaebacteria are really 
statements of faith. It is also only on faith that one can asset, as the report 
does in its conclusions, that "the barriers to expression of foreign genes in most 
organisms, the necessity for new activities to function as an integrated part of 
an existing pathway, and the selective disadvantage given to an organism by recom- 
binant DNA inserts will interfere with such organisms establishing themselves in 
[ 570 ] 
