F. ALTERtlATIVES (DEIS pp. 47~58) 
The analysis of alternative courses of action for 
NIH is seriously deficient and can hardly form the basis of 
important policy planning decisions. As noted before the 
"No Action" alternative is properly that the federal government 
would give no recombinant research grants . This im.pact state- 
ment applies not only to NIH , but to the entire federal 
government for which NIH is acting as the lead agency under 
NEPA. Recombinant research supported by other federal agencies 
must be included in the DEIS as well. 
The DEIS does mention the alternative of no NIH 
finding, but only in a cursory manner. Alternatives should 
be evaluated and weighed, not merely mentioned. V7hat is set 
forth in the DEIS, is in essence a claim that "American leader- 
ship" will be threatened if we do not fund this research. 
This conclusion, without an in-depth discussion, cannot be 
evaluated. If the United States decided not to fund because 
potential health costs outweighed potential benefits, and because 
other research methods could accomplish the same results, other 
nations might be expected to follow suit. The argument of 
competitive disadvantage for taking controversial actions is not 
new. It has occurred in debates over weapons sales to smaller 
nations and is now offered as a reason to sell nuclear technology 
to developing countries . This argument occurs in each debate 
over implementations of new technologies. These are the type of 
important "historical precedents" that should be considered. 
- 22 - 
Appendix K — 102 
