risks were properly evaluated with the finding of no foreseeable 
impact from this limited field experiment. Much energy and effort 
was expended to restate the consensus of the NIH-RAC decision." 
III-A-2. Comments Criticizing the EA-FONSI 
One letter was received criticizing the EA-FONSI. It was a May 14 letter 
from Mr. Edward Lee Rogers. Mr. Rogers Is the lawyer for the plaintiffs 
in the suit. Foundation on Economic Trends et al . v. Heckler et al. 
(Civil Action No. 83-2714 in the U.S. District Court for the District 
of Columbia.) This case is mentioned both in the January 21, 1985, 
EA-FONSI and in the April 15, 1985, Federal Register notice. Mr. 
Rogers writes that the comments in his May 14 letter, "are submitted 
on behalf of the Foundation on Economic Trends, Inc., and the other 
plaintiffs in Foundation on Economic Trends v. Heckler ." Attached 
to Mr. Rogers' May 14 letter are two declarations : one dated March 14, 2985, 
from Dr. David Pimentel, Professor of Insect Ecology and Agricultural Sciences, 
Cornell University; and one dated March 11, 1985, from Dr. Stephen Richard 
Gliessman, Associate Professor, Environmental Studies, University of 
California, Santa Cruz. The comments of Mr. Rogers, Dr. Pimentel and 
Dr. Gliessman are cited and discussed below in Section III-A-3 of this 
memorandum. 
III-A-3. Additional Comments and Response to Comments on EA-FONSI 
III-A-3-a. Dr. Anne K. Vidaver and Dr. Trevor Suslow 
III -A-3-a-( 1 ) . In her May 13 letter, Dr. Vidaver makes some specific 
suggestions concerning, and proposes some specific alternative language for, 
the January 21, 1985, EA-FONSI, as follows: 
"Page 22. 5.2. 1. A. 1. Nomenclature & taxonomy. Pseudomonas syringae 
is not an 'abbreviated taxonomic designation of Pseudomonas syringae 
pathovar ( pv . ) syringae 1 (see e.g. Bergey's Manual of Systematic 
Bacteriology, Vol . 1. 1984, p. 168). Rather, P. syringae is a taxon 
with nomenclatural status according to the International Code of 
Nomenclature of Bacteria (1976); infrasubspecific taxa, such as pathovars, 
do not have such a status and are not part of the taxonomic hierarchy. 
The term pathovar is used to refer to a strain or set of strains with 
the same or similar characteristics, differentiated at the 
infrasubspecific level from other strains of the same species or 
subspecies on the basis of distinctive pathogenicity to one or more 
plant hosts (Dye et al. 1980; Rev. PI. Pathology 59:153-168). That is, 
it makes no sense and is confusing to create pathovar names for sub- 
populations of species where there is no evidence that they have any 
pathogenic character. Thus, the epithet P^ syringae is correct, since 
the strains being worked with are not and never have been shown to be 
pathogenic. An example of such correct usage is found in Gross, 
D. et al., 1983, Appl. Evn. Microbiol. 46:1370-1379. Those strains 
[ 172 ] 
