C . The Draft EIS Does Not Adequately Describe The 
Proposed Action (Section V, Draft EIS) 
The description of the federal action which is the 
subject of this draft impact statement is incomplete. Although 
section V describes the purpose and specific provisions of the 
Guidelines in detail, it does not describe the extent and nature 
of recombinant research being conducted now or planned for the 
near future. NIH should not limit the scope of the impact 
statement by defining its action narrowly. NIH's action on 
recombinant DNA activities includes awarding grants which promote 
the development of this new technology and the decision not to 
regulate non-NIH-supported research. 
The award of grants for recombinant DNA research is 
clearly major federal action which must be discussed in an 
impact statement. The Guidelines have little meaning or impact 
by themselves. Their significance comes from the fact that 
they permit NIH-supported recombinant research to proceed if the 
Guidelines are followed. The description of the federal action 
must therefore describe the recombinant research now being 
conducted with NIH funds and research for which grant applica- 
tions are now pending. 
When NIH promulgated the Guidelines with the approval 
of the Secretary of Health, Education and Welfare, it decided not 
to regulate non-NIH-supported research, transportation or 
8 
Appendix K — 134 
