"Zoecon agrees with NIH's Comprehensive Environmental Assessment 
and finding of no significant impact with respect to the testing 
proposed by Drs. lindow and Panopoulos. The facts that: (a) the 
INA- deletion mutant of the Pseudomonas syringae pv. syringae is 
isogenic with the naturally occurring F\ syringae INA-*- and contains 
no foreign DMA; and (b) that non isogenic INA- mutants produced 
through undirected mutagensls have been previously tested without 
adverse environmental effects; argue convincingly that the risk 
associated with the proposed field use is negligible. Also there 
Is a finite probability that such Isogenic deletion mutants have 
occured naturally in the past without notable effect and that the 
persistance and competitiveness of INA- mutants in general is 
insufficient to allow them to displace the wild type whose INA+ 
character probably confers a distinct competitive advantage for 
epiphytic colonization." 
III-A-l-f. Genencor, Inc. 
A May 10 letter from Genencor, Inc., was signed by Alice K. Jameson, 
Manager of Regulatory Affairs, Genencor, Inc. The letter discusses the 
January 21, 1985, EA-FONSI, but erroneously refers to it as an Environ- 
mental Impact Statement (EIS), which it is not, rather than an 
Environmental Assessment (EA), which it is. The letter states: 
"We . . . find it to be thorough and well done and we agree with the 
finding by NIH of no significant impact." 
III-A-l-g. Dr. C, Elizabeth Castro 
A May 9 letter was received from C. Elizabeth Castro, Ph.D., Southwest 
Foundation for Biomedical Research. The letter states: 
"It appears that the National Institutes of Health in initially 
reviewing the application of Drs. Steven Lindow and Nickolas 
Panopoulos of the University of California, Berkeley, to field test 
Ice-nucleation-minus bacteria prepared by recombinant DNA 
technigues and in issuing an Environmental Assessment and a Finding 
of No Significant Impact has fulfilled its mission." 
III-A-l-h. Dr. Anne K. Vidaver 
A May 13 letter was received from Anne K. Vidaver, Ph.D., Professor 
and Head, Department of Plant Pathology, University of Nebraska. The 
letter states: 
"Relative to the Environmental Assessment for the proposal to field 
test ice-nucleation-minus bacteria, I find the document to 
be appropriate and comprehensive." 
In addition the letter includes a number of specific comments on the EA 
which are cited and discussed below in Section III-A-3 of this memorandum. 
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