AGRI 
GENETICS 
CORPORATION 
14142 DENVER WEST PARKWAY 
DENVER. COLORADO 80401 
303-277-0300 
Comment Re: Agenda Item (V): Proposed Field Testing of Genetically 
Engineered PI ants 
Agenda Item (VII): Amendment Sec. III. A. 2 and III. B. 4(c) to 
Permit Local IBC Review of Proposed Field~Tests 
Recent developments in the sciences of plant genetics demonstrate that 
transfer of genetic material to plants using recombinant DNA techniques is 
now entirely feasible. These methods are under development in a number of 
academic and industrial laboratories in this country and abroad. The 
potential for the development of crop varieties and soil inocula with 
enhanced agronomic properties is of far-reaching significance for improving 
the economy, quality, and yield of food, fiber, and oilseed crops. It is 
apparent that several groups engaged in research and development will in 
due course seek field tests of "genetically engineered" plant materials. 
The mere existence of field trial requests, however, should not raise 
false expectations of early commercial success or of reduction to practice. 
At least one previous request was made to this committee, but actual 
testing was never carried out. Nevertheless, field tests are an indispen- 
sable phase in the development of economically significant plant varieties 
utilizing recombinant DNA methodol ogies . 
With respect to items V and VII, Agrigenetics suggests that item VII be 
decided prior to acting upon the specific request of item V. Permitting 
routine local IBC review would make it unnecessary to undertake national - 
level reviews of applications such as the one presented in item V. Such a 
decision would ensure that the present and subsequent applicants are 
treated similarly, from a procedural standpoint. A decision to permit 
local IBC review should also tend somewhat to discourage applications made 
for publicity or for political purposes. (Agrigenetics does not wish to 
imply that the present application under item V is made for other than a 
bona fide purpose) . 
Criteria to be considered when applications for field testing are 
reviewed should include: 
1) Whether the object of the testing is such that greenhouse or 
growth chamber trials are inappropriate or impractical; 
2) Whether a definable commercial or scientific purpose can be 
perceived; the committees should not be asked to pass on "test cases;" 
3) Whether the genetic modification is sufficiently well- 
characterized, a review of which would include investigating the 
structure and function of the inserted sequences, and the stability of 
their mode of integration. 
Lorance L. 
Vice President 
Agri genetics Corporation 
Greenlee, Ph.D., J.D. 
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