Although Henry I. Miller is certainly welcome to express his opinions about the risks of biotechnology,1 he should not criticize a detailed report without reading it carefully. Miller indicates that the 2002 National Research Council report2 "invokes a variety of specious arguments." His main example is that the report puts forth "a general assumption that the risks associated with the introduction of genetic novelty are related to the number of genetic changes and the origin of the novel genes." In fact, the report addresses this assumption in detail and concludes that there is no support for it. The executive summary states, "The committee compared empirical evidence of environmental impacts involving small to large amounts of genetic novelty from taxonomically related and unrelated sources and found no support for this assumption."
Concerning Miller's main point about regulation and logical inconsistencies, we would like to clarify the National Research Council's (NRC) positions. ...