Rachel's Precaution Reporter #39
Wednesday, May 24, 2006
From: ETC Group ..........................................[This story printer-friendly]
May 19, 2006
GLOBAL COALITION SOUNDS THE ALARM ON SYNTHETIC BIOLOGY
[Rachel's introduction: In October 2004, an editorial in the British scientific journal Nature warned, "If biologists are indeed on the threshold of synthesizing new life forms, the scope for abuse or inadvertent disaster could be huge." Now, less than two years later, there is no doubt that biologists have crossed that threshold. The race is on to invent and commercialize new forms of life never before seen on Earth.]
A coalition of thirty-five international organizations has called for inclusive public debate, regulation and oversight of the rapidly advancing field of synthetic biology -- the construction of unique and novel artificial life forms to perform specific tasks. The coalition raising the alarm about synthetic bilogy includes scientists, environmentalists, trade unionists, biowarfare experts and social justice advocates.
Synthetic biologists are meeting this weekend [May 20-22] in Berkeley, California where they plan to announce a voluntary code of self- regulation for their work. The organizations signing the Open Letter are calling on synthetic biologists to abandon their proposals for self-governance and to engage in an inclusive process of global societal debate on the implications of their work (see Open Letter, appended below).
"The researchers meeting in Berkeley acknowledge the dangers of synthetic biology in the hands of 'evildoers," but they naively overlook the possibility -- or probability -- that members of their own community won't be able to control or predict the behavior of synthetic biology or its societal consequences," said Jim Thomas of ETC Group.
"Scientists creating new life forms cannot be allowed to act as judge and jury," explains Dr. Sue Mayer, Director of GeneWatch UK. "The possible social, environmental and bio-weapons implications are all too serious to be left to well-meaning but self-interested scientists. Proper public debate, regulation and policing is needed."
In the last few years, synthetic biologists, by re-writing the genetic code of DNA, have demonstrated the ability to build new viruses and are now developing artificial life forms. In October last year, synthetic biologists at the US Center for Disease Control re-created the 1918 Spanish flu virus that killed between 50-100 million people[1] and last month scientists at the University of Wisconsin- Madison created a new version of E. coli bacteria.[2] Meanwhile, genomics mogul Craig Venter, whose former company, Celera, led the commercial race to sequence the human genome, now heads a new company, Synthetic Genomics, that aims to commercialize artificial microbes for use in energy, agriculture and climate change remediation. It is one of around 40 synthetic biology companies undertaking gene synthesis and/or building artificial DNA.
"Biotech has already ignited worldwide protests, but synthetic biology is like genetic engineering on steroids," says Dr. Doreen Stabinsky of Greenpeace International. "Tinkering with living organisms that could be released in the environment poses a grave biosafety threat to people and the planet," adds Stabinsky.
In October 2004, an editorial in the journal Nature warned, "If biologists are indeed on the threshold of synthesizing new life forms, the scope for abuse or inadvertent disaster could be huge." The editorial suggested that there may be a need for an "Asilomar-type" conference on synthetic biology -- a reference to an historic meeting in 1975 where scientists met to discuss biosafety risks associated with genetic engineering and opted for self-governance which ultimately pre-empted and avoided government regulation. Following the Asilomar model the "Synthetic Biology Community" intends to use their second conference (Synthetic Biology 2.0, 20-22 May 2006) to adopt a code of self-governance for handling the biosafety risks.
According to the Open Letter, the effect of the Asilomar declaration was to delay the development of appropriate government regulation and to forestall discussion on how to address the wider socio-economic impacts. Asilomar proved to be the wrong approach then, and Synthetic Biology 2.0 is the wrong approach now.
"We scientists must come to terms with the fact that science can no longer claim to be living in an abstract realm disconnected from the rest of society," said Alexis Vlandas of International Engineers and Scientists for Global Responsibility (INES).
The signatories to the Open Letter urge the synthetic biologists meeting in Berkeley to withdraw their declaration of self-governance and join in seeking a wider, inclusive dialogue.
A background note for press is available from the ETC Group at www.etcgroup.org and at www.etcblog.org
[Afterword: The synthetic biology conference in Berkeley produced an interim statement on self-regulation, which is still being discussed via the internet before final approval by synthetic biologists.]
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[1] Tumpey, TM et al (2005) Characterization of the Reconstructed 1918 Spanish Influenza Pandemic Virus. Science 310: 77-80.
[2] Posfai, G et al (2006) Emergent Properties of Reduced-Genome Escherichia coli. Published online April 27 2006; 10.1126/science.1126439 (Science Express Reports).
Text of Open Letter:
An Open Letter from Social Movements and other Civil Society Organizations to the Synthetic Biology 2.0 Conference May 20-22, 2006 Berkeley, California concerning the "community-wide vote" on Biosecurity and Biosafety resolutions (to be implemented Jan 1, 2007.)
We are writing to express our deep concerns about the rapidly developing field of Synthetic Biology that is attempting to create novel life forms and artificial living systems. We believe that this potentially powerful technology is being developed without proper societal debate concerning socio-economic, security, health, environmental and human rights implications. We are alarmed that synthetic biologists meeting this weekend intend to vote on a scheme of voluntary self-regulation without consulting or involving broader social groups. We urge you to withdraw these self-governance proposals and participate in a process of open and inclusive oversight of this technology.
Asilomar 2.0? In 1975 a group of scientists convened at Asilomar to try to address the safety hazards associated with genetic engineering. The Asilomar meeting promoted self-regulation that had the result of preempting public debate and preventing government action. Synthetic Biology 2.0 follows down the same self-regulation road. The scope of discussion at Asilomar was narrowly limited to questions of safety hazards -- explicitly excluding broader socio-economic and ethical issues. The effect of the Asilomar declaration was to delay the development of appropriate government regulation and to forestall discussion on how to address the wider socio- economic impacts. Asilomar proved to be the wrong approach then, and Synthetic Biology 2.0 is the wrong approach now. We recognize that you are justifiably concerned about certain risks of Synthetic Biology, but society requires strong mandatory measures in accordance with the precautionary principle to curtail these risks. As the chair of the recent Boston 'Town Hall Meeting' speaking about the recent proposals said: "I don't think this will have a significant impact on the misuse of this technology." We agree that these proposals will be ineffectual. Moreover, the social, economic, ethical, environmental and human rights concerns that arise from the field of synthetic biology go far beyond deterring bioterrorists and "evildoers." Issues of ownership (including intellectual property), direction and control of the science, technology, processes and products must also be thoroughly considered.
Society -- especially social movements and marginalized peoples -- must be fully engaged in designing and directing dialogue on the governance of synthetic biology. Because of the potential power and scope of this field, discussions and decisions concerning these technologies must take place in an accessible way (including physically accessible) at local, national and global levels.
In the absence of effective regulation it is understandable that scientists are seeking to establish best practices but the real solution is for them to join with society to demand broad public oversight and governmental action to ensure social wellbeing. Moreover, in the years since Asilomar, science has become more strongly linked to commercial interests, so this can appear as an industry saying that it should only police itself. We urge you therefore to withdraw your declaration of self-governance and join with us in seeking a wider inclusive dialogue.
List of Organizations Signing the Open Letter
Accion Ecologica (Ecuador) -- www.accionecologica.org California for GE Free Agriculture -- www.calgefree.org
Centro Ecologico (Brazil)
Clean Production Action -- www.cleanproduction.org
Corporate Europe Observatory -- www.corporateeurope.org
Corporate Watch (UK) -- www.corporatewatch.org
Edmonds Institute -- www.edmonds-institute.or/
ETC Group -- www.etcgroup.org
Farmers Link -- www.farmerslink.org.uk
Friends of the Earth International -- www.foe.org
Foundation on Future Farming (Germany) -- www.zs-l.de
Foundation Science Citoyennes (France) -- www.sciencescitoyennes.org
Gaia Foundation -- www.gaiafoundation.org
GeneEthics Network (Australia) -- www.geneethics.org
Genewatch (UK) -www.genewatch.org
GRAIN -- www.grain.org
Greenpeace International -- www.greenpeace.org
Henry Doubleday Research Association (UK) -- www.gardenorganic.org.uk
Indigenous People's Biodiversity Network
International Center for Technology Assessment -- www.icta.org
International Network of Engineers and Scientists for Global responsibility -- www.inesglobal.com
Institute for Social Ecology -- www.social-ecology.org
Institute for Bioethics, Culture and Disability - www.bioethicsanddisability.org
International Union of Food and Agricultural Workers -- www.iuf.org
Lok Sanjh Foundation (Pakistan) -- www.loksanjh.org
National Farmers Union (Canada) -- www.nfu.ca
Oakland Institute -- www.oaklandinstitute.org
Polaris Institute -- www.polarisinstitute.org
Pakistan Dehqan Assembly
Practical Action -- www.practicalaction.org
Quechua Ayamara Association for Sustainable Livelihoods, (Peru) - www.andes.org.pe
Research Foundation for Science, Technology and Ecology (India) - www.navdanya.org/
Soil Association -- www.soilassociation.org
Sunshine Project -- www.sunshine-project.org
Third World Network -- www.twnside.org.sg
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For further information:
North America:
Jim Thomas -- ETC Group, email: jim@etcgroup.org, ph: +1 613 2412267
Pat Mooney -- ETC Group, email: mooney@etcgroup.org , cell: +1 613 2610688
Hope Shand -- ETC Group, email: hope@etcgroup.org ph: +1 919 960-5767
Edward Hammond -- Sunshine Project (biological weapons expert) email: Hammond@sunshineproject.org, cell: +1 510 717 7772
Beth Burrows -- Edmonds Institute: email: beb@igc.org, ph: +1 425-775-5383
Europe:
Dr Sue Mayer -- GeneWatch UK, email: sue.mayer@genewatch.org, ph: +44 1298 871898 (office); mobile: + 44 7930 308807
Alexis Vlandas -- International Network of Engineers and Scientists email: alexis.vlandas@materials.ox.ac.uk, ph: +44 7747 036446
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From: Council on Wireless Technology Impacts ..............[This story printer-friendly]
September 14, 2002
THE CATANIA RESOLUTION ON ELECTROMAGNETIC RADIATION
[Rachel's introduction: The human body can be viewed as a machine whose internal parts communicate via chemicals and electricity. Can electromagnetic field (EMF) radiation from cell phones, cordless phones, wireless networks, etc. cause biological effects in humans? "The weight of evidence calls for preventive strategies based on the precautionary principle. At times the precautionary principle may involve prudent avoidance and prudent use."]
The Scientists at the International Conference "State of the Research on Electromagnetic Fields Scientific and Legal Issues", organized by ISPESL*, the University of Vienna and the City of Catania, held in Catania (Italy) on September 13th 14th, 2002, agree to the following:
1. Epidemiological and in vivo and in vitro experimental evidence demonstrates the existence for electromagnetic field (EMF) induced effects, some of which can be adverse to health.
2. We take exception to arguments suggesting that weak (low intensity) EMF cannot interact with tissue.
3. There are plausible mechanistic explanations for EMF-induced effects which occur below present ICNIRP and IEEE guidelines and exposure recommendations by the EU.
4. The weight of evidence calls for preventive strategies based on the precautionary principle. At times the precautionary principle may involve prudent avoidance and prudent use.
5. We are aware that there are gaps in knowledge on biological and physical effects, and health risks related to EMF, which require additional independent research.
6. The undersigned scientists agree to establish an international scientific commission to promote research for the protection of public health from EMF and to develop the scientific basis and strategies for assessment, prevention, management and communication of risk, based on the precautionary principle.
List of signers:
Fiorella Belpoggi, Fondazione Ramazzini, Italy
Carl F. Blackman, President of the Bioelectromagnetic Society (1990-1991), Raleigh, USA
Martin Blank, Department of Physiology, Columbia University, New York, USA
Emilio Del Giudice, INFN Milano, Italy
Livio Giuliani, University Camerino, Italy
Settimio Grimaldi, CNR-INMM, Roma, Italy
Lennart Hardell, Department of Oncology, University Hospital, Oerebro, Sweden
Michael Kundi, Institute of Environmental Health, University of Vienna, Austria
Henry Lai, Department of Bioengineering, University of Washington, USA
Abraham R. Liboff, Department of Physics, Oakland University, USA
Wolfgang Loscher, Department of Pharmacology, Toxicology and Pharmacy, School of Veterinary Medicine, Hannover, Germany
Kjell Hansson Mild, National Institute of Working Life, Umea, Sweden
Wilhelm Mosgoeller, Institute for Cancer Research, University of Vienna, Austria
Elihu D. Richter, Unit of Occupational and Environmental Medicine, Hebrew-University-Hadassah, Jerusalem, Israel
Umberto Scapagnini, Neuropharmacology, University of Catania, Italy, Member of the European Parliament
Stanislaw Szmigielski, Military Institute of Hygiene and Epidemiology, Warsaw, Poland
*Istituto Superiore per la Prevenzione e la Sicurezza del Lavoro, Italy (National Institute for Prevention and Work Safety, Italy)
To order films: "Public Exposure: DNA, Democracy and the Wireless Revolution" and, "Dr. Ted Litovitz's EMR Research Presentation to U.S. Congressional Staff" click here.
Your tax deductible donation helps continue work on the biological effects of electromagnet fields. Please make your check payable to CWTI and send to us at 936 B Seventh Street, #206, Novato, California. 94945. You can donate online by clicking here.
For more information on CWTI, please contact info@energyfields.org
Copyright 2002-2003 Council on Wireless Technology Impacts (CWTI),
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From: Markham (Canada) Economist & Sun ...............[This story printer-friendly]
May 18, 2006
'DIRTY ELECTRICITY' OUT OF BOUNDS FOR STUDENTS
[Rachel's introduction: Considerable evidence now suggests that electromagnetic fields may cause biological effects in humans, so it makes sense to limit the exposure of children as a precautionary measure.]
By Serena Willoughby, Staff Writer
They're closing hallways, moving the basketball net and putting up fences at St. Monica Catholic School in Markham, all to protect students from a threat federal and provincial health authorities aren't sure exists.
An independent test ordered by the York Catholic District School Board found EMF levels as high as 10 milligauss near a transformer at St. Monica.
Some research links prolonged exposure to "dirty electricity" at levels higher than two to leukemia, as well as chronic fatigue syndrome, fibromyalgia and attention deficit disorder.
But other research on EMFs, which are created wherever electricity is generated such as in cellphones, computers and power lines, indicated the link to health problems is unsubstantiated.
The board fenced off the transformer and closed other areas with high EMF readings at St. Monica, although spokesperson Chris Cable wouldn't speculate on whether similar precautions would be taken at other schools.
"Regardless of whether you believe (the research) or not, we at the board are following a precautionary principle," Ms Cable said.
Dr. Magda Havas, a professor of Environmental Sciences at Trent University, believes EMFs in schools are a major problem because schools use several kinds of equipment that emit EMFs such as older model computers, fluorescent lighting and public address systems.
Children are particularly susceptible to the effects of EMFs, she said.
But Gloria Rachamin, a toxicologist with the public health division of the Ontario Ministry of Health, denied the connection in a report to York public health, the school board and parents.
"Overall, the scientific evidence does not support casual association between EMF exposure and human health risks," she said.
"According to Health Canada.... there is no conclusive evidence of any harm caused by exposures at levels normally found in Canadian living and working environments. It further indicates that, at present, there are no Canadian government guidelines for exposure to EMF at extremely low frequencies since the scientific evidence is not strong enough to conclude that typical exposures cause health problems."
Copyright York Region Newspaper Group
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From: European Commission ................................[This story printer-friendly]
February 2, 2000
EUROPEAN UNION'S COMMUNICATION ON THE PRECAUTIONARY PRINCIPLE
[Rachel's introduction: The European Commission (EC) is the environmental agency of the European Union (EU). In 1992, the EU included the precautionary principle in its founding document, the Treaty on the European Union, also known as the Maastricht Treaty. In early 2000 the EC adopted a "Communication on the use of the precautionary principle," reprinted below, which spelled out how the principle would be applied in environmental decisions.]
The European Commission has today adopted a Communication on the use of the precautionary principle. The objective of the Communication is to inform all interested parties how the Commission intends to apply the principle and to establish guidelines for its application. The aim is also to provide input to the on-going debate on this issue both at EU and international level. The Communication underlines that the precautionary principle forms part of a structured approach to the analysis of risk, as well as being relevant to risk management. It covers cases where scientific evidence is insufficient, inconclusive or uncertain and preliminary scientific evaluation indicates that that there are reasonable grounds for concern that the potentially dangerous effects on the environment, human, animal or plant health may be inconsistent with the high level of protection chosen by the EU. Today's Communication complements the recently adopted White Paper on Food Safety and the agreement reached in Montreal this week-end on the Cartagena Protocol on Bio-safety.
The Communication also qualifies the measures that may be taken under the precautionary principle. Where action is deemed necessary, measures should be proportionate to the chosen level of protection, non-discriminatory in their application and consistent with similar measures already taken. They should also be based on an examination of the potential benefits and costs of action or lack of action and subject to review in the light of new scientific data and should thus be maintained as long as the scientific data remain incomplete, imprecise or inconclusive and as long as the risk is considered too high to be imposed on society. Finally, they may assign responsibility -- or the burden of proof -- for producing the scientific evidence necessary for a comprehensive risk assessment. These guidelines guard against unwarranted recourse to the precautionary principle as a disguised form of protectionism.
Today's Communication was presented to the Commission by Mr Erkki Liikanen, Enterprise and the Information Society Commissioner, Mr David Byrne, Health and Consumer Protection Commissioner, and Ms Margot Wallstrom, Environment Commissioner. It is a follow-up to President Romano Prodi's speech to the European Parliament on 5 October 1999.
The Communication recalls that a number of recent events have undermined the confidence of public opinion and consumers because decisions or absence of decisions were not supported by full scientific evidence and the legitimacy of such decisions was questionable.
The Commission has consistently striven to achieve a high level of protection, inter alia in the environmental and human, animal and plant health fields. It is the Commission's policy to take decisions aimed to achieve this high level of protection on a sound and sufficient scientific basis. However, where there are reasonable grounds for concern that potential hazards may affect the environment or human, animal or plant health, and when at the same time the lack of scientific information precludes a detailed scientific evaluation, the precautionary principle has been the politically accepted risk management strategy in several fields. Although the precautionary principle is not explicitly mentioned in the EC Treaty except in the environment field, the Commission considers that this principle has a scope far wider than the environment field and that it also covers the protection of human, animal and plant health.
The Communication makes it clear that the precautionary principle is neither a politicisation of science or the acceptance of zero-risk but that it provides a basis for action when science is unable to give a clear answer. The Communication also makes it clear that determining what is an acceptable level of risk for the EU is a political responsibility. It provides a reasoned and structured framework for action in the face of scientific uncertainty and shows that the precautionary principle is not a justification for ignoring scientific evidence and taking protectionist decisions.
The horizontal guidelines established in this Communication will provide a useful tool in the future for taking political decisions in this regard and will contribute to legitimate decisions taken when science is unable to assess completely the risk rather than decisions based on irrational fears or perceptions. Thus, one of the objectives of the Communication is to clearly describe the situations in which the precautionary principle could be applied and determining the scope of measures taken in this respect. It will therefore help ensuring the proper functioning of the Internal Market as well as a high level of protection and predictability for consumers and economic operators located in the EU and elsewhere.
COMMUNICATION FROM THE COMMISSION ON THE PRECAUTIONARY PRINCIPLE
SUMMARY
1. The issue of when and how to use the precautionary principle, both within the European Union and internationally, is giving rise to much debate, and to mixed, and sometimes contradictory views. Thus, decision-makers are constantly faced with the dilemma of balancing the freedom and rights of individuals, industry and organisations with the need to reduce the risk of adverse effects to the environment, human, animal or plant health. Therefore, finding the correct balance so that the proportionate, non-discriminatory, transparent and coherent actions can be taken, requires a structured decision-making process with detailed scientific and other objective information.
2. The Communication's fourfold aim is to:
** outline the Commission's approach to using the precautionary principle,
** establish Commission guidelines for applying it,
** build a common understanding of how to assess, appraise, manage and communicate risks that science is not yet able to evaluate fully, and
** avoid unwarranted recourse to the precautionary principle, as a disguised form of protectionism.
It also seeks to provide an input to the ongoing debate on this issue, both within the Community and internationally.
3. The precautionary principle is not defined in the Treaty, which prescribes it only once -- to protect the environment. But in practice, its scope is much wider, and specifically where preliminary objective scientific evaluation, indicates that there are reasonable grounds for concern that the potentially dangerous effects on the environment, human, animal or plant health may be inconsistent with the high level of protection chosen for the Community.
The Commission considers that the Community, like other WTO members, has the right to establish the level of protection -- particularly of the environment, human, animal and plant health, -- that it deems appropriate. Applying the precautionary principle is a key tenet of its policy, and the choices it makes to this end will continue to affect the views it defends internationally, on how this principle should be applied.
4. The precautionary principle should be considered within a structured approach to the analysis of risk which comprises three elements: risk assessment, risk management, risk communication. The precautionary principle is particularly relevant to the management of risk.
The precautionary principle, which is essentially used by decision- makers in the management of risk, should not be confused with the element of caution that scientists apply in their assessment of scientific data.
Recourse to the precautionary principle presupposes that potentially dangerous effects deriving from a phenomenon, product or process have been identified, and that scientific evaluation does not allow the risk to be determined with sufficient certainty.
The implementation of an approach based on the precautionary principle should start with a scientific evaluation, as complete as possible, and where possible, identifying at each stage the degree of scientific uncertainty.
5. Decision-makers need to be aware of the degree of uncertainty attached to the results of the evaluation of the available scientific information. Judging what is an "acceptable" level of risk for society is an eminently political responsibility. Decision-makers faced with an unacceptable risk, scientific uncertainty and public concerns have a duty to find answers. Therefore, all these factors have to be taken into consideration.
In some cases, the right answer may be not to act or at least not to introduce a binding legal measure. A wide range of initiatives is available in the case of action, going from a legally binding measure to a research project or a recommendation.
The decision-making procedure should be transparent and should involve as early as possible and to the extent reasonably possible all interested parties.
6. Where action is deemed necessary, measures based on the precautionary principle should be, inter alia:
** proportional to the chosen level of protection,
** non-discriminatory in their application,
** consistent with similar measures already taken,
** based on an examination of the potential benefits and costs of action or lack of action (including, where appropriate and feasible, an economic cost/benefit analysis),
** subject to review, in the light of new scientific data, and capable of assigning responsibility for producing the scientific evidence necessary for a more comprehensive risk assessment.
Proportionality means tailoring measures to the chosen level of protection. Risk can rarely be reduced to zero, but incomplete risk assessments may greatly reduce the range of options open to risk managers. A total ban may not be a proportional response to a potential risk in all cases. However, in certain cases, it is the sole possible response to a given risk.
Non-discrimination means that comparable situations should not be treated differently, and that different situations should not be treated in the same way, unless there are objective grounds for doing so.
Consistency means that measures should be of comparable scope and nature to those already taken in equivalent areas in which all scientific data are available.
Examining costs and benefits entails comparing the overall cost to the Community of action and lack of action, in both the short and long term. This is not simply an economic cost-benefit analysis: its scope is much broader, and includes non-economic considerations, such as the efficacy of possible options and their acceptability to the public. In the conduct of such an examination, account should be taken of the general principle and the case law of the Court that the protection of health takes precedence over economic considerations.
Subject to review in the light of new scientific data, means measures based on the precautionary principle should be maintained so long as scientific information is incomplete or inconclusive, and the risk is still considered too high to be imposed on society, in view of [the] chosen level of protection. Measures should be periodically reviewed in the light of scientific progress, and amended as necessary.
Assigning responsibility for producing scientific evidence is already a common consequence of these measures. Countries that impose a prior approval (marketing authorisation) requirement on products that they deem dangerous a priori reverse the burden of proving injury, by treating them as dangerous unless and until businesses do the scientific work necessary to demonstrate that they are safe.
Where there is no prior authorisation procedure, it may be up to the user or to public authorities to demonstrate the nature of a danger and the level of risk of a product or process. In such cases, a specific precautionary measure might be taken to place the burden of proof upon the producer, manufacturer or importer, but this cannot be made a general rule.
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Rachel's Precaution Reporter offers news, views and practical examples of the Precautionary Principle, or Foresight Principle, in action. The Precautionary Principle is a modern way of making decisions, to minimize harm. Rachel's Precaution Reporter tries to answer such questions as, Why do we need the precautionary principle? Who is using precaution? Who is opposing precaution?
We often include attacks on the precautionary principle because we believe it is essential for advocates of precaution to know what their adversaries are saying, just as abolitionists in 1830 needed to know the arguments used by slaveholders.
Rachel's Precaution Reporter is published as often as necessary to provide readers with up-to-date coverage of the subject.
As you come across stories that illustrate the precautionary principle -- or the need for the precautionary principle -- please Email them to us at rpr@rachel.org.
Editors:
Peter Montague - peter@rachel.org
Tim Montague - tim@rachel.org
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Environmental Research Foundation
P.O. Box 160
New Brunswick, N.J. 08901
rpr@rachel.org
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