The ASM letter states: 
"We question whether an EIS is desirable or necessary in the 
specific case of the experiment by Drs. Lindow and Panopoulos 
to test ice-nucleation-minus bacteria prepared by recombinant 
DNA techniques. We also question whether a programmatic EIS 
should be required In any case where an adequate EA Is provided. 
By definition, a programmatic EIS is concerned with broad Issues 
rather than with specific considerations which relate to a 
particular site. In the Berkeley case, and it seems to us In all 
but the most unusual circumstance, an EA will serve as well as an EIS 
to identify environmental effects. The EA is more concerned than 
the EIS with the present. The EIS is more forward-looking than the 
EA, and the availability of an EA without an EIS will not 
necessarily obstruct environmental review. The absence of a 
programmatic EIS does not hinder a continuing concern for 
environmental effects. 
"The thoroughness of preparation of the EA and the fact that the 
organism to be tested by the Berkeley scientists does not contain a 
foreign gene and Is not unique, obviates the need in this case for 
a programmatic EIS. If future EAs are as thoroughly and well 
prepared as the present document, there should be little need in 
general for programmatic EISs. Nevertheless, any experiment which 
proposes to take an organism from the laboratory and apply it in 
the field must undergo careful review, and the need for the review 
must be determined on a case-by-case basis. Given an EA, the decision 
concerning need for a programmatic EIS also should be made on a case- 
by-case basis. Every effort should be made to see that a programmatic 
EIS is not required if all it accomplishes is to duplicate what 
is already presented in an EA. 
"The PSAB applauds the NIH and the NIH Recombinant DNA Advisory 
Committee (RAC) for the way they have managed a difficult assign- 
ment very well. In conclusion, we believe that NIH has effectively 
dealt with this issue and that there is not further need for a 
prograrmiatic Environmental Impact Statement." 
III-8-l-b. Dr. Winston Brill 
The letter from Dr. Brill states: 
"Man has had centuries of experience with plant breeding, a century 
of experience with genetically altering microorganisms, and half 
a century of experience with gene exchanges among microorganisms. 
No special concerns have been raised from release of organisms 
produced through man-made and man-selected genetic alterations. 
We consider these types of projects to be very safe; consequently, 
we have no regulations to govern release of genetically altered 
organisms which are regarded as safe. 
"In comparison to traditional genetic technologies, recombinant 
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