TABLE OF CONTENTS 
I. 
II. 
III. 
INTRODUCTION 
THE DRAFT ENVIRONMENTAL IMPACT STATEMENT 
A. Summary of Comment and 
Recommendations on the Draft EIS 
B . NIH Violated NEPA by Not Preparing 
a Final Impact Statement in Time 
to Accompany the Proposed Guidelines 
Through the Decision-Making Process 
C. The Draft EIS Does Not Adequately 
Describe The Proposed Action 
(Section V, Draft EIS ) 
D. The Adverse Environmental Impacts 
of Promulgating The Guidelines Are 
Not Adequately Described (Section 
VII, Draft EIS) 
1. The Impact of Uncontrolled Recombinant 
DNA Activities 
2. Impact of the Guidelines and Experiments 
Conducted Under the Guidelines (Sections 
VII-A and VII-B of the Draft EIS) 
E. The Discussion of Alternatives is Inadequate 
(Section VI, draft EIS) 
F . The Draft EIS Does Not Discuss or Evaluate 
Any of the Long-Range Impacts of Recombinant 
DNA Technology 
COMMENTS ON THE NIH GUIDELINES 
A. Summary of Comments and Recommendatiops 
on The Guidelines 
B. The Guidelines Should Be Designed to 
Prevent Any Release of Organisms Containing 
Re combinant DNA Into the Environment 
Tsection II of the Guidelines) 
i 
1 
3 
3 
4 
8 
10 
10 
13 
15 
17 
19 
19 
Appendix K — 125 
