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Submitted by Isao Kawaguchi, National Institute of Radiological Sciences, National Institutes for Quantum and Radiological Sci
   Commenting on behalf of the organisation
Document Dose Coefficients for Non-human Biota Environmentally Exposed to Radiation
Chapter 4:
Paragraph 23, line 464: The assumption of neglecting contribution from electron to external exposure would not be correct when we consider a very small organisms on the ground with a planar source of electrons (beta rays). We think that electrons can even be a very sever external dose source to a very small organisms that cannot move fast. Since the masses of organisms are now applicable from 1 mg to 103 kg by this revision, it is now necessary to think the effect to small organisms.
Paragraph 32: We would appreciate it if the geometries of the reference grass and tree could have been explained schematically. Comparing with other reference organisms, the geometries of the reference grass and tree are difficult to imagine (e.g. the layers are infinite or not, where is the reference point, etc). In addition, we think the description of bushes and shrub layer is not necessary because this document is not the EC project report but the ICRP report.
Chapter 5:
Paragraph 53, line 796: "s" in equation (9) should be removed.
Paragraph 53, line 807 and Annex A: Explanation about the Allometric model would not be necessary in this document. It has been known that Allometric relationship is observed among the organisms, and examples of the relationship are indeed described in Annex A. On the other hand, the explanation was not clear to us especially how to estimate the internal concentrations in organisms using with the Allometric model.

In Annex B:
The tables should be arranged in atomic number order.