"Further, from our understanding of the programmatic EIS and the 
varied nature of recombinant organisms and environments in which they 
may be released, we feel that the assessment of their 
environmental impact can best be determined on a case-by-case basis... 
rather than a programmatic EIS." 
1 1 1-B-l-f . Dr. C. Elizabeth Castro 
The letter from Dr. Castro states: 
"The preparation of a programmatic Environment Impact Statement 
(EIS) seems unnecessary, particularly as its absence would not appear 
to obstruct environmental review." 
III-B-l-g. Dr. Anne K. Vidaver 
The letter from Dr. Vidaver states: 
"I do not see a need for a programmatic Environmental Impact 
Statement since anticipated proposals and actions by RAC are not 
connected, cumulative or likely to be sufficiently similar, criteria 
which I understand are considered standard for such an EIS." 
III-B-l-h. Industrial Biotechnology Association 
The letter from Mr. Price states: 
"We also concur... that a programmatic environmental impact statement 
would not be appropriate in connection with environmental release 
approvals at this time...." 
III-B-l-i. Lilly Research Laboratories 
The letter from Dr. Johnson states: 
"We certainly question whether an EIS is desirable or necessary 
in this case. 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 these experiments and, it seems to us in all but the most 
unusual circumstances, an EA will serve as well as an EIS to identify 
environmental effects. The EA is more concerned than the EIS with 
the present. 
"To suggest that a programmatic environmental impact statement 
be developed for recombinant DNA technology after two or three 
experiments involving field tests of recombinant DNA organisms 
have been described is at best premature. It is a bit like asking 
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