B. THE MAJOR FEDERAL ACTION 
The DEIS begins (p. 2) and maintains throughout that 
the major federal action being considered by N.I.H. is the 
issuance of guidelines for the conduct of federally funded 
recombinamt DNA research. We disagree. The action taken by 
N.I.H. which may significantly affect the environment is the 
funding of recombinant research. The guidelines, important 
as they are, are auneliorative measures to reduce the effect 
of the action of funding. The distinction is more than semantic; 
it affects the very objectivity of the DEIS. 
First, considering the major action to be the issuance 
of guidelines closes the transcendent question of whether this 
research should be funded at all. This question is generally 
ignored in the DEIS. Moreover, the entire discussion is 
inevitcdsly slauited towards a favorable decision on the guidelines 
since widespread recombinant research is assumed as a given. 
In this light the "action" is invariably seen as improvement 
over the status quo and as a prudent and cautious step. As an 
example of such bias, one need only turn to the "Alternatives" 
section. The first alternative of "No Action" is stated as 
N.I.H. funding of recombinant research with no grant restrictions 
on the conditions under which the research would progress. Of 
course, given the potential biohazards, no action will be seen 
-3- 
Appendix K — 83 
