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the environment and thus, ultimately with their potential to cause harm." The 
RAC simply has no factual basis for such a broad assertion. 
I am not claiming that archaebacteria, or other little-studied eubacteria, 
actually have some unique deleterious potential to express foreign DNA and to 
establish themselves in the environment, but no one really knows that they do 
not. Would the promiscuity of inc P-1 plasmids have been predicted on the 
basis of previous experience with plasmids like F? Could the existance of 
Legionella have been predicted? There are still quite a few surprises in nature 
and many of them will be found when molecular biologists focus their attention 
on the little-studied organisms that normally inhabit the environment. 
The bottom line is to better circumscribe the conclusions of the report. 
For instance, before conclusion 1 the phrase, "For typical enteric bacteria, 
accidental..." could be inserted. Following conclusion 2, a third conclusion 
could be added stating that current knowledge of the molecular biology of some 
groups of organisms, like the archaebacteria, is still so primitive that the 
relevance of conclusions 1 and 2 to these organisms is unknown. Presumably, 
this situation will change in the near future as more is learned about these 
organisms . 
I believe that the RAC has so far paid insufficient attention to the 
potential for purely environmental consequences of the release of novel organisms, 
for instance effects on elemental cycles. Their focus has been on eukaryotic DNA 
in prokaryotes and they may have neglected potential combinations of prokaryotic 
genes, especially among bacteria that inhabit physically separate habitats or 
which differ so markedly in structure that they may not exchange DNA. Surely, you 
should amplify your considerations to these areas before making as sweeping a 
generalization as is contained in the conclusions of the current report. 
Assistant Professor 
JBJ/ tw 
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