effect upon existing epiphytic populations." (Page 39 of EA-FONSI.) 
"If, however, the modified bacteria were to escape the monitoring 
network and were to become established in neighboring fields, it is 
conceivable that the modified bacteria, together with INA- bacteria 
of the same or different species could alter whatever balance may 
exist in the particular field between INA+ and INA- bacteria. 
The scientific literature, however, does not Indicate that there 
is any stable balance in the environment or In a field between 
INA+ and INA- bacteria. Large seasonal fluctuations and widely varying 
proportions of INA+ and INA- bacteria in a given field appear to be 
characteristic in nature, as bacterial populations change in response 
to environmental variables such as temperature and humidity. Among 
P. £. syrinqae , the INA+ phenotype may be dominant in one field 
at a given time, while the INA- phenotype is dominant in other fields 
in the vicinity, and the pattern may change over time with no perceptible 
environmental consequences, other than greater frost injury in INA+ fields. 
Existing agricultural practices add a further variable that drastically 
affects natural bacterial populations without any known adverse 
environmental consequences." (Page 47 of EA-FONSI.) 
"Even if there were some fixed INA+/INA- balance in nature that had 
some environmental significance, it is unlikely that the slight 
alteration of that balance that could conceivably result if modified 
bacteria from this field test become established in adjacent fields 
would have any environmental consequences. The numbers to be applied 
are many orders of magnitude lower than the number of naturally-occurring 
bacteria, both INA+ and INA-, against which they would have to compete 
for space and nutrients for survival, growth and reproduction. Nothing 
in this proposed field test will enhance the reproductive potential or 
competitive fitness of the modified INA- bacteria. In all respects. It 
will be identical to its wild counterparts, except that it will be unable 
to ice nucleate. It will therefore be subject to the same environmental 
factors and the same population control mechanisms as the much more 
numerous wild bacteria. To the extent that the INA+ characteristic plays 
a role in growth, survival or reproduction, the modified bacteria will be 
more vulnerable to environmental and other stresses than its wild 
counterparts. Therefore, any escape of modified bacteria from the test 
site would not cause any significant environmental impacts." (Page 47-48 
of EA-FONSI.) 
"Large INA- populations of both P^_ s^ syrinqae and E^ herbicola 
already occur naturally. Depending on the nost plant from which the 
bacteria are isolated, such bacteria can represent, for example, 
up to 80 percent for P. ;s. pv. syrinqae and up to 100 percent for E. 
herbicola of the totaT number of epiphytes present. Such large ratios 
of INA- bacteria in the environment suggests that some equilibrium 
already exists between INA+ and INA- strains and. other bacteria. 
The populations proposed for field tests would be trivial introductions 
into the environment, and would not significantly affect that balance. 
Even if an imbalance in favor of the INA- bacteria did occur on a 
local field, a situation that already exists in nature, the result 
would be protection of the plants from frost damage or no effect." 
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