Dr. Gartland (Reference Y of the January 21, 1985, EA-FONSI) would be as 
follows : 
"In addition to the sixteen rows of plants used in the experiment an 
additional six rows of plants will be used as 'guard' plants to protect 
against severe air movements, dust, and other intrusions into the plot. 
Surrounding the entire plot will be twenty feet of soil which will be 
maintained free of any vegetation by cultivation, and surrounding 
the twenty foot barren area will be a ten foot wide dirt road for 
which little or no vegetation would grow." 
A diagram showing these aspects of the test plot is already in the 
January 21, 1985, EA-FONSI as Appendix C. 
III-A-3-b-(7) . In his March 14 declaration, Dr. Pimentel states: 
"Lindow has not run any tests with beneficial insects like honey 
bees. Bees provide polljination to over $20 billion worth of U.S. 
crops annually. Other beneficial insects play an important role in 
biological control of pests. 
"Lindow should run adequate environmental studies with other crop 
and natural plant species and insects in the laboratory before his 
unique Ps bacterium is applied to test plots in the field. Then 
sound environmental tests must be designed to check for potential 
ecological impacts on fruit and other crops, important natural plants, 
and beneficial insects. As Lindow states the Ps_ organism has potential 
as an 'important pathogen'; thus ample evidence exists that careful 
environmental studies should be run before Lindow's Ps. organism is 
released." 
In his March 11 declaration, Dr. Gliessman states: 
"It seems that all discussion of potential environmental hazards 
associated with the release of the altered bacteria depends on the 
minimization of risk and low probability of unexpected problems. 
The fact that this infers that potential problems are not wholly 
eliminated is reason for concern and greater caution in the possible 
release of the ice-nucleating negative organisms that have been 
altered with recombinant DNA techniques. 
"In the section of the assessment dealing with worst case considerations, 
the assumption again is made that potential problems are at a low 
probability, due to the presence already of ice nucleation negative 
bacteria in the environment. Before release takes place, it seems 
to me that it is necessary to gain further understanding of how a balance 
is maintained in nature between negative and positive bacteria. 
How do they shift? What factors promote one over the other? How can such 
information be used to ensure zero probability of problems once the 
altered bacteria are released? Have sufficient tests been 
performed to demonstrate that altered ice nucleation negative bacteria 
are exactly the same as natural ly-occuring negative strains? It seems 
to me that a battery of tests of this type should be performed before 
release takes place." 
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