III. Analysis of Comments 
The fourteen letters at Tab C are analyzed below using the following 
structure. 
Ill -A. Analysis of Comments on January 21, 1985, EA-FONSI 
III-A-1. Comments Praising the EA-FONSI 
III-A-2. Comments Criticizing the EA-FONSI 
III-A-3. Additional Comments and Response to Comments on EA-FONSI 
III-B. Analysis of Comments on Need for Programmatic EIS 
III-B-1. Comments Indicating a Programmatic EIS is Not Required 
III-B-2. Comment Indicating the Need for a Programmatic EIS 
"Is Unlikely to Be Resolved in the Near Future" 
III-B-3. Comment Indicating a Programmatic EIS is Required 
III-B-4. Response to Comments on Requirement for Programmatic EIS 
III-C. Comments and Response to Comments on Adequacy of April 15, 
1985, Federal Register Notice 
III -A . Analysis of Comments on January 21, 1985, EA-FONSI 
Of the fourteen letters at Tab C, thirteen praised the EA-FONSI and one 
criticized the EA-FONSI. 
III-A-1. Comments Praising the EA-FONSI 
III-A-l-a. Public and Scientific Affairs Board, American Society 
for Microbiology 
An April 24 letter from the Public and Scientific Affairs Board of the 
American Society for Microbiology (ASM) was signed by four individuals, 
i.e.,: Harlyn 0. Halvorson, Ph.D., Chairman, Public and Scientific 
Affairs Board, ASM; David Pramer, Ph.D., Chairman, Committee on 
Environmental Microbiology , ASM; Monica Riley, Ph.D., Chairman, 
Committee on Genetic and Molecular Microbiology, ASM; and Kenneth I. 
Berns, M.D., Ph.D., Chairman, Committee on Medical Microbiology and 
Immunology, ASM. 
The letter states: 
"The Environmental Assessment (EA) prepared by the NIH in relation 
to the experiments proposed by the Berkeley scientists is 
exhaustive in its coverage and persuasive in its arguments. It 
describes all proposed actions in detail and thoughtfully 
identifies and then considers the environmental effects of risks 
posed by those actions. We can think of no points to consider that 
are not addressed by the document. The agricultural history of the 
site is summarized. Climatological data is presented, and the animal 
and the human populations surrounding the experimental site have 
been surveyed. Reasonable consideration also was given to the 
probability of escape from the test site, to transport, and to 
2 
[ 166 ] 
