Mr. Rogers criticizes the EA-FONSI; however, in contrast to Mr. Rogers' views, 
this memorandum contains, in Sections III-A-l-a to III-A-l-m, numerous 
detailed, cogent statements praising the EA-FONSI. Thus the EA-FONSI is 
referred to as: "exhaustive in its coverage and persuasive in its arguments" 
(American Society for Microbiology); "intelligent, concerned and powerful" 
(Dr. Donald Gustafson); "thorough, balanced and accurate" (Dr. Winston Brill); 
"detailed and thorough" (Association of American Medical Colleges); "thorough 
and well done" (Genencor, Inc.); "appropriate and comprehensive" (Or. Anne 
K. Vidaver); "supported by careful thought and abundant scientific evidence" 
(Industrial Biotechnology Association) ; "well researched and documented... 
balanced, thorough and plausible evaluation. .. .all possible and relevant 
avenues of projected and potential concern were investigated and addressed" 
(National Agricultural Chemicals Association); "a well prepared document" 
(Dr. Trevor Suslow). 
I recommend that you reaffirm the adequacy of the Environmental Assessment 
that you signed on January 21, 1985. Suggestions for changes in the 
January 21, 1985, EA were given above in Sections III -A-3-a- ( 2) , 
III -A-3-b-( 2) and III -A-3-b-( 6 ) of this memorandum. These are minor changes, 
which all provide further clarification of safety of the field test, and in 
no way change the central conclusions of the EA. 
I recommend that you reaffirm the Finding of No Significant Impact that 
you made on January 21, 1985. 
I recotranend you reject Mr. Rogers' suggestions given in Section III -A-3-b- ( 11) 
that the NIH should withdraw the EA-FONSI, and should prepare an EIS on 
the experiment. 
I recommend, based on the EA and Finding of No Significant Impact, that you 
indicate your intention, once the Court lifts the injunction prohibiting NIH 
from reapproving the Lindow-Panopoulos field test, to reapprove the field test 
under the alternative discussed in Section 4.2.3 of the January 21, 1985, 
EA-FONSI. However to be even more conservative, I recommend that you limit 
your approval only to Pseudomonas syringae , and not to include Erwinia 
herbicola. 
III-B. Analysis of Comments on the Need for a Programmatic EIS 
Of the fourteen letters at Tab C, ten indicated that is was not 
necessary for NIH to prepare a programmatic Environmental Impact 
Statement (EIS) in connection with NIH approvals to release into the 
environment organisms containing recombinant DNA molecules. One 
said the need for such a programmatic EIS "is unlikely to be resolved in 
the near future." One indicated that such a programmatic EIS was necessary. 
Two did not deal with the issue. 
III-B-1. Comments Indicating a Programmatic EIS is Not Required 
III-B-l-a. Public and Scientific Affairs Board, American Society for 
Microbiology 
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