the alternatives must be discussed much more specifically. 
The hazards of experiments now being conducted or planned for 
the near future must be described in detail. The hazards 
foreseen by critics of the Guidelines should also be discussed. 
The draft EIS does not discuss the impacts of recombinant DNA 
as a major new technology which is just beginning. There is 
no analysis of the long range consequences of proceedings with 
recombinant research. 
The draft EIS was issued after the final Guidelines 
were promulgated. It therefore does not accomplish the primary 
purposes of the impact statement process which is to assure that 
environmental values and alternatives are fully considered in 
the agency's decision-making. The discussion of alternatives 
is so inadequate it seems clear that the draft EIS is merely 
a post hoc justification of the Guidelines. 
A new draft impact statement should be prepared and, 
when the impact statement process has been completed, the NIH 
Guidelines and alternatives to them should be considered ^ novo . 
B. NIH Violated NEPA by Not Preparing a Final Impact 
Statement in Time to Accompany the Proposed Guidelines 
Through the Decision-Making Process . 
Section 102(2) (C) of the National Environmental Policy 
Act d2 U.S.C. §4332 (2) (O) requires that an environmental impact 
4 
Appendix K — ijO 
