that only certain strains of syringae (not being worked with in the 
proposed field test) are pathogenic. 
I recommend that no change is necessary in response to the last proposed 
change given above in Section III -A-3-a-( 1 ) of this memoranum. While I agree 
that "it should not be implied that all naturally-occurring P. syringae have 
arisen due to deletion mutations," I believe the January 21, “1985, EA-FONSI is 
clear on this point when It discusses "naturally occurring mutations, including 
deletions" (page 33, line 2 of EA-FONSI, underlining added.) 
III-A-3-b. Mr. Edward Lee Rogers, Dr. David Pimentel and Dr. Stephen Richard 
G1 iessman 
III -A-3-b-( 1 ) . In his March 14 declaration, Dr. Pimentel states: 
"4. A statement is made that 'neither the original nor the altered 
bacteria are pathogenic to living creatures' yet in Lindow's published 
papers he refers to this bacterium Pseudomonas syringae (Ps ) as an 
'important pathogen' in nature. Lindow also speculates tKat Ps may 
well be pathogenic to insects. Thus, the statement in the assessment 
is incorrect. 
"5. It is stated that Ps 'did not induce frost or other injury to 
plants.' By plants is meant more than potato plants. Only a few tests 
were run with 6 crop species but no other crop plants that are cultured 
in that California region are included. Also no natural vegetation 
types were tested. Thus, insufficient data exist to support the quoted 
statement. 
"6. It is stated that 'certain strains or isolates of Ps have been 
reported to be pathogenic on many woody and herbaceous pTants including 
bean, lima bean, wheat, barley, sorghum, corn, pear, apple, plum, peach, 
cherry, citrus, and others.' This statement contradicts an earlier quoted 
statement (see #4). Also, Lindow has not tested his Ps_ strain for its 
pathogenicity to all of these crop plants and again no natural plant 
species have been included in his environmental study. 
"7. It is stated that their strain of Ps^ 'will have been screened for 
pathogenicity towards oats, wheat, barley, corn, tomato, and three 
cultivars of beans.' When will these tests be completed and how will the 
scientific credibility of the data be validated? It should be noted that 
this list of crop plants makes up only a small portion of the total crop 
plants grown in the test area. In particular no fruit (pear, peach, plum, 
cherry, etc.) are included in the test nor are any natural plant species 
1 ncluded. 
"8. It is stated that 'Analogous to plant frost survival, 
the presence of INA+ bacteria would be detrimental to survival of 
frost-sensitive insects and possible beneficial to frost-tolerant 
insect species.' This also contradicts an earlier statement that 
Ps is not 'pathogenic to living creatures' (see #4)." 
10 
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