We consider the draft ICRP report "Environmental Protection: Transfer parameters for Reference Animals and Plants" to be an important document in the general area of environmental protection and more specifically with respect to the matter of tranfer of radionuclides to animals and plants. The document functions well in presenting various concepts such as Reference Plants and Animals and Representative Organisms which have the potential to be somewhat confusing. We feel that the document represents a balanced consideration of the important issues with respect to transfer of radionuclides and serves an important function in highlighting the advantages and disadvantages of various approaches. The document is clear in highlighting deficiencies in current knowledge whilst at the same time adopting extant approaches in such a manner that facilitates further progression of the Commissions activities in the areas of environmental protection.