Ill -A-3-b- ( 2 ) . My Response to Comments in Section III-A-3-b-(l) 
Dr. Pimentel writes that the following statement In the January 21, 1985, 
EA-FONSI Is incorrect: "neither the original nor the altered bacteria are 
pathogenic to living creatures." The full quote (page 2 of EA-FONSI) is: 
"neither the original nor the altered bacteria are pathogenic to living 
creatures (Insects, animals, birds, man)." This Is a true statement. 
Pathogenicity of P^ syringae to insects, animals, birds or man has never 
been shown. As Dr. Pimentel correctly points out, the EA-FONSI (page 23) 
states that certain strains of P. s^ syringae (strains that will not be 
worked with In the proposed fielcl test) "have been reported to be pathogenic 
on many woody and herbaceous plants including bean, lima bean, wheat, barley, 
sorgum, corn, pear, apple, plum, peach, cherry, citrus, and others." However 
Dr. Pimentel is incorrect in saying that the pathogencity of some P. syringae 
strains for some plants , contradicts the statement that the bacteria are not 
pathogenic to "living creatures (insects, animals, birds, man)." (Underlining 
added. ) 
Dr. Pimentel cites the statement that, "Analogous to plant frost survival, 
the presence of INA+ bacteria would be detrimental to survival of frost- 
sensitive insects and possibly beneficial to frost-tolerant insect species." 
(Page 40 of EA-FONSI.) This sentence in the EA-FONSI follows immediately 
a sentence that states that, "ice-nucleatlon-active bacteria may play 
at least a partial role in the limitation of supercooling of leaf-feeding 
insects." (Underlining added.) The key word here is "may." In response 
to Dr. Pimentel's point, I recommend that you change the sentence, 
"Analogous to " to read as follows: "If indeed ice-nucleatlon- 
active bacteria do play a role in the limitation of supercooling of leaf- 
feeding insects, then the presence of INA+ bacteria could be detrimental 
to survival of frost-sensitive Insects and possibly beneficial to frost- 
tolerant insects." 
In his point 7, given above in section III -A-3-b- ( 1 ) , Dr. Pimentel quotes 
the phrase that the strains of P. syringae to be used in the field test 
"will have been screened for pathogenicity towards oats, wheat, barley, 
corn, tomato, and three cultivars of beans." (Page 36 of EA-FONSI.) 
He asks when the tests will be completed. In his points 5, 6 and 7, 
given above, he asks that tests also be done on other crop plants. 
In response to Dr. Pimentel's point, I telephoned Dr. Lindow and he 
indicated that additional tests have been completed. Therefore, 
I recommend that you change the sentence, "The strains to be used in the 
experiment will have been screened..." to read as follows: "The 
syringae strains to be used In the experiment have been screened, 
and have been found to be non-pathogenic, towards potato, oats, wheat, 
alfalfa, barley, cowpea, onion, horseradish, corn, tomato, three cultivars 
of beans (Buck blue lake, pinto and kidney), cherry, almond, pear, 
orange, and lemon." 
As can be seen by comparing the list on page 18 of the EA-FONSI this 
Includes all major crops grown in the area of the field test. In fact 
the EA-FONSI already contains on page 51 the statement that, "the strains 
to be used in the proposed field test have been isolated from healthy 
plants and screened to assure that they do not cause disease to major 
crops grown in the area." 
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