(Page 50-51 of EA-FONSI.) 
I recommend that no change is needed In the EA-FONSI in response to 
Mr. Rogers' comments given in Section III -A-3-b- ( 3 ) . 
1 1 1-A-3-b-( 5) . In his March 14 declaration. Dr. Pimentel states: 
"Any proposed field experiments must be designed to limit dispersal 
of the released Ps organism. At the same time the field experiments 
should detail how dispersal and movement of the released Ps organism 
in air, soil, water, and various organisms like bees, other insects, 
and birds, will be monitored." 
In his March 11 declaration, Dr. Gliessman states: 
"The assessment does not seem to deal with the question of what 
possible tests need to be designed or could be designed to ensure 
greater reduction or elimination of risk of adverse effects from 
release of the altered organism. Since this case could form a 
landmark decision for future tests of altered organisms, it is 
even more important that this first case serve as a model for the 
future." 
Ill -A-3-b- ( 6 ) . My Response to Comments in Section I II-A-3-b-( 5) 
The EA-FONSI does state on page 14-15 that: 
"Survival, lateral dissemination, and population dynamics of INA- 
mutants and INA+ populations in the field and the specificity if any, 
of INA- and INA+ bacterial interactions on leaf surfaces will be studied 
in parallel. To facilitate these studies, the strains will be marked with 
antibiotic resistance mutations not used in clinical medicine so that 
they can be selectively reisolated. Measurements of the applied bacteria 
will be made at 10m, 100m, and 1km in all directions from the site of 
application. Measurements of bacteria carrying the appropriate genetic 
marker will be made before treatment and weekly for the first month 
after treatment. Thereafter, treatment will be at monthly intervals. 
If appropriately marked strains are not detected by standard dilution 
plating procedures these procedures will be repeated following standard 
enrichment procedures." 
The EA-FONSI does state on page 17 that: 
"The test plots occupy approximately one acre on the 100-acre section of 
the field station and will buffered by 20 feet of fallow land and a ten- 
foot road on all sides. In addition, there will be a band of untreated 
plants around the edge of the 0.4 acre plots to protect the treated plants." 
In order to provide more information, I recommend that additional text be added 
to the EA-FONSI to follow immediately the text just quoted. The new text, 
taken verbatim from the September 21, 1984, letter from Dr. Lindow to 
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