The current draft is not mature enough for publication. The choices of reference plants and animals seem somewhat arbitrary and the “Preliminary Dose Consideration Levels” too “preliminary”. Much more field work is needed to support some of the conclusions. It is important to know potential radiosensitivity changes during each living organism life cycle and decide clearly whether we are considering protecting the organisms collectively or individually. To elicit the much needed research world-wide, the ICRP should consider publishing as an independent document the considerable amount of data on radiation effects on flora and fauna and the biological background to the reference animals and plants it has amassed in this draft. Such publication would be very useful as background material for a future document on radiological protection on the environment.