survival of the organism after escape. Finally, although not 
required, the EA concludes with worst case considerations that 
describe what is remotely or infintesimal ly possible, but highly 
uni ikely. 
"We concur in the opinion expressed in the EA that the proposed 
studies by the Berkeley scientists will have no significant Impact 
on the environment for the following reasons: 1) No functional 
gene has been added to the bacterium. Rather, a single bit of 
chromosomal information has been biochemically deleted from the 
bacteria that will be applied to the test site; 2) Mutation of 
the same organism has been accomplished previously using techniques 
other than recombinant DNA, and deletion mutants have been 
demonstrated to occur naturally. Therefore, the organism produced 
by recombinant DNA deletion cannot be considered unique; and 3) 
Since the test organism does not contain a foreign gene and is not 
unique, it poses little or no added risk than that experienced 
under what are considered natural conditions. 
"The EA makes a convincing case for the need for the proposed field 
test. We are certainly persuaded that the benefit of using ice-nuc- 
leation-minus bacteria will justify any risk that may be Involved. 
Alternative procedures for protecting plants against frost damage 
require large amounts of energy and water or consume large quantities 
of fossil fuels, and they can create health hazards and adversely 
affect environmental quality. The Berkeley case offers certain 
benefits and limited risk, if any risk at all." 
III-A-l-b. Dr. Donald Gustafson 
A May 3 letter was received from Donald P. Gustafson, DVM, Ph.D., 
Professor of Virology, Department of Veterinary Microbiology 
Pathology and Public Health, Purdue University School of Veterinary 
Medicine. The letter states: 
"This is to support and commend the statement made by the Public and 
Scientific Affairs Board of the American Society for Microbiology 
regarding the 64 page EA-FONSI related to the NIH approval of the 
application of Drs. Lindow and Panopoulous to field test ice- 
nucleation-minus bacteria prepared by recombinant DNA techniques 
(48FR24549). The statement is intelligent, concerned and powerful. 
It is from responsible, well informed scientists." 
III-A-l-c. Dr. Winston Brill 
An April 24 letter was received from Winston J. Brill, Ph.D., Vice 
President, Research and Development, Agracetus. The letter states: 
"This document appears to be a thorough, balanced and accurate 
assessment of the environmental effects of conducting the proposed 
field test of ice-nucleation-minus bacteria produced through 
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