Sunday, April 10, 2005

Northeast District Council Letter to UW President Mark Emmert

Northeast District Council
4534 University Way NE
Seattle, WA 98105
(206) 233-3732


Belvedere Terrace Community Council
Greater University Chamber of Commerce
Hawthorne Hills Community Council
Inverness Community Club
Inverness Park Homeowners Association
Laurelhurst Community Club
Montlake Community Club
Portage Bay/Roanoke Park Community Council
Ravenna Bryant Community Association
Ravenna Springs Community Group
Roosevelt Chamber of Commerce
Roosevelt Neighborhood Association
Roosevelt Neighbors’ Alliance
University District Community Council
University Park Community Club
View Ridge Community Council
Wedgwood Community Council
Windermere Corporation
Windermere North Community Association

April 8, 2005

Mark A. Emmert
President, Office of the President
301 Gerberding Hall
Box 351230
University of Washington
Seattle, Washington 98195-1230

RE: Proposal for BioLab on UW Campus

Dear President Emmert,

We are writing on behalf of the Northeast District Council, a group that represents over 20 Seattle neighborhood groups, to offer our comments on the proposed Regional Biocontainment Laboratory now under consideration.

While we strongly support much of the vital research that goes on at the University of Washington, the proposed RBL raises too many concerns for us to support siting this facility on the UW Campus.

Security and Safety. The security of such a facility raises concerns. The proposed location is adjacent to three public streets and is readily accessible to the public. The UW has already experienced eco-terrorist attacks, and this facility would present both a high profile and a high-risk target. In addition, there have been a number of accidents at other laboratories nationwide that highlight the very real risks of human error, most notably the tularemia release at a Boston University lab, the incidence of anthrax samples found outside of a Fort Detrick lab and the cross-country shipment and exposure to live anthrax in Oakland last year. It also bears mentioning that the anthrax used in the 2001 terrorist attacks almost certainly came from a U.S. facility.

Location. In addition, the proposed site is located in a shoreline management zone, within 200 feet of Portage Bay, which raises concerns about the potential effect on local waters and questions about the appropriateness of the facility given land use and design considerations.

Transparency and Public Disclosure. The fact that this facility is part of a national biodefense program that focuses on "select agents" that can be used in a possible bioterror attack creates another set of concerns. The first is the question of transparency – particularly since research on select agents is sometimes classified or proprietary. There will likely be little or no public notification in the event of thefts or accidents. The lack of transparency and the disregard for established procedures in the initial site selection process have been noted elsewhere. Note that over 70 pages of the UW’s application to the NIH were redacted for security reasons, an unusual procedure for an academic institution.

Biodefense research encompasses far more than simply generating vaccines for infectious disease. Select agent research requires the presence of pathogens that are likely to be used in bioterrorism attacks, and research on vaccines for "defense" does in fact have offensive potential. As David Ozonoff, Professor of Environmental Health at Boston University stated in testimony re the proposed NBL at BU, "In other words, no terrorist can use agents that have yet to be created, but the very act of protecting ourselves from these non-existent organisms will likely bring them into existence. That is when the danger moves from theoretical to real."

Control. In addition, the U of W, in the Cooperative Agreement Terms and Conditions of Award specified by the RFA, would effectively cede ultimate control over use of the RBL facility to the National Institutes of Health under the Regional Centers of Excellence biodefense program. The language specifically states that "Awardees agree to participate in projects identified by the NIAID Biodefense Network that include common research interests and address a specific biodefense problem or threat" and "The NIAID Biodefense Network will provide overall scientific coordination of the RBL Program." Even worse, the UW would cede this control over what occurs in the RBL facility for a period of 20 years under the agreement.

Although this is to be an RBL [BSL-3] rather than an NBL [BSL-4] facility, there remain unaddressed concerns that the level of containment required for a given pathogen can be redefined. This has already occurred in the UW project to study the 1918 influenza virus, when the level of containment required was reduced by the UW Institutional Biosafety Committee (IBC) to BSL-3 from the more stringent original standard of BSL-3ag. Which leads to a further concern.

Oversight. There is a potential conflict of interest between the roles researchers have in overseeing their own activities. The analogy is a fox guarding the henhouse, and we would like to propose an alternative to the current practice wherein the UW IBC, made up predominantly of researchers, provides sole local biosafety oversight. UC-Davis announced plans in 2003 to form a community liaison committee, modeled after an independent review committee in Winnipeg, whether or not it proceeded with its NBL proposal. An alternative is the successful model of the Cambridge Biosafety Committee, which oversees biosafety work at Harvard, MIT and private laboratories as part of the Cambridge public health system and has done so for the past three decades.

The existence of thirty BSL-3 labs on campus now and six more at other nearby Seattle institutions came as news to the community. We note that contrary to the impression given initially, the proposed facility is not expected by the Med School to result in the closure of any BSL-2 or BSL-3 labs at UW.

Resources. The general question of the use of federal resources for the biodefense program has been raised at the national level recently. More than 750 scientists, including 17 from the UW, sent a letter in March to the director of NIH stating, "The diversion of research funds from projects of high public-health importance to projects of high biodefense but low public-health importance represents a misdirection of NIH priorities and a crisis for NIH-supported microbiological research."

This particular proposal also impacts local resources. To be eligible for the $25 million federal grant, the UW has already committed $8.3 million in university matching funds, and is seeking an additional $32 million to meet the grant requirements. Allocation of these funds competes with other state and University needs.

In summary, we oppose the siting of this facility on the UW Campus. We urge you to consider the communities surrounding the University of Washington as you make your decision whether and how to proceed. We hope you will decide not to pursue the current proposal to locate an RBL on the campus.


Matthew Fox, Co-Chair
1407 1/2 NE 56th
Seattle, WA 98105

Lynn Ferguson, Co-Chair
6422 NE 60th Street
Seattle, WA 98115

cc: UW Board of Regents, Center for Scientific Review, National Institutes of Health; John Bogdan, Division of Extramural Activities, National Institute of Allergy and Infectious Diseases; Mayor Greg Nickels, Seattle City Council, Senator Patty Murray, Senator Maria Cantwell, Governor Christine Gregoire


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