III-A-3-b-(3) . In his May 14 letter, Mr. Rogers states: 
"There was inadequate consideration of the nature of the modified 
Pseudomonas syringae ( "Ps . ) as highly competitive specimens chosen for 
their ability to displace their wildlife counterparts. Little or 
no attention was given to the genetic stability of these mutant bacteria, 
a point that Dr. Lindow emphasized distinguishes them from mutants created 
by chemical or radiation means. The implications for disruption of the 
natural balance between ice-nucleation-plus (INP) and ice-nucleation-minus 
(INM) Ps. is therefore not adequately considered." 
Ill -A-3-b- ( 4 ) . My Response to Comments in Section III-A-3-b-(3) 
I do not agree with Mr. Rogers' statement that inadequate consideration 
was given in the January 21, 1985, EA-FONSI to these issues. The following 
are relevant quotations from the EA-FONSI: 
"The construction of INA- deletion mutants from INA+ isolated 
bacteria does not add new or exotic properties which would make 
the mutant more competitive than its parent bacteria. The mutation only 
deletes functions from the treated bacteria." (Page 28 of EA-FONSI.) 
(Note that contrary to Mr. Rogers' characterization of the modified 
Pseudomonas syringae as "highly competitive specimens," the EA-FONSI 
specif ical ly states that no new or exotic properties are added which would 
make the mutant more competitive than its parent bacteria. See also 
quote from Page 39 of EA-FONSI below.) 
"It is possible that small numbers of the INA- bacteria will be carried 
away from the test plot to surrounding crops or non-commercial plant 
species by wind, birds and insects. The numbers of bacteria involved 
would be very small in comparison to the wild-type bacteria that 
already exist in nature ( P. syringae , for example is ubiquitous). 
It is highly unlikely that a 1 1 of the deletion mutants that leave 
the test plot would be deposited in one place. Even if this did 
occur, there would be a negligible chance that there would be sufficient 
numbers of the deletion mutants to significantly affect the ratio 
between INA+ and INA- wild-type bacteria." (Page 36 of EA-FONSI.) 
"If the field test is successful, the bacteria that have had their 
ice-nucleation genes removed will colonize plants first and prevent 
the natural ly-occuring INA+ from colonizing and becoming established 
on the plants, thereby protecting them from frost damage. The modified 
bacteria will be no more competitive, and probably less so, than 
their natural ly-occuring INA+ counterparts because they are adapted 
only to the target crop for the experiment. It is believed that 
INA+ bacteria are more competitive than INA- bacteria because of 
their ability to induce frost damage and obtain nutrients through 
lesions caused by the frost damage. Because of this comparative lack 
of competitiveness and the small numbers of the modified bacteria 
in relation to the naturally occurring, ubiquitous bacteria, there is no 
significant risk that the modified bacteria will have an adverse 
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