DNA technology actually is more precise and predictable in its 
outcome. Thus, the level of concern about problems from 
recombinant DNA techniques should be no more than the level of concern 
associated with release of organisms developed using conventional 
techniques 
"The NIH should not prepare a Programmatic Environmental -Impact 
Statement unless there is a scientifically sound reason why 
application of recombinant DNA technology will inadvertantly 
create a serious environmental problem. The fact that a Program- 
matic Environmental Impact Statement has never been deemed necessary 
for traditional practices such as breeding and mutation, strongly 
suggests that a Programmatic Environmental Impact Statement would not 
be useful for recombinant DNA work. Arguments must be made by 
proponents of a Programmatic Environmental Impact Statement to 
demonstrate that a recombinant' organism indeed has a greater chance 
to create environmental damage than a genetically altered organism 
derived through traditional practices." 
III-B-l-c. Association of American Medical Colleges 
The letter from Dr. Sherman states: 
"The Association strongly supports the argument. . .that a programmatic 
EIS is neither necessary nor appropriate for future research proposal s 
involving field trials of genetically engineered microorganisms. A 
single a priori programmatic EIS cannot be made in regard to such 
experiments. They are not part of a deliberate NIH research program 
but rather unsolicited and as yet unknown proposed future experiments. 
Each experiment will be a unique instance which must be evaluated 
for environmental impact on a case-by-case basis. The Environmental 
Assessment (EA) statement admirably serves this purpose by providing 
a full evaluation of the environmental impact of a given proposed 
experiment involving field testing of a genetically engineered 
organism." 
III-B-l-d. Zoecon Corporation 
The letter from Dr. Brown states: 
"With respect to the need for a Programmatic Environmental Impact 
Statement, Zoecon believes that in view of the increasing 
responsibilities of other Federal agencies notably the Environmental 
Protection Agency, such programmatic EIS should not be required 
of N.I.H." 
III-B-l-e. Genencor, Inc. 
The letter from Ms. Jameson states: 
