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(a) In order to survive and multiply, the genetically engineered 
INA’ bacteria would have to compete successfully against much 
larger numbers of INA* bacteria and naturally occuring INA’ 
bacteria and other bacteria. Established natural populations 
of bacteria on surrounding plants will retard the INA’ bacteria 
from colonizing or becoming established on neighboring plants. 
(b) Even if many of the genetically engineered bacteria survived and 
multiplied, no significant harm would result since INA" bacteria 
already exist in nature with no harmful effects and chemically 
altered INA’ bacteria have previously been released with no 
adverse environmental effects. 
3. The large seasonal fluctuation and widely varying relative abundance 
of INA + bacteria versus IMA’ bacteria in nature, as well as the large 
reductions of INA* bacteria from traditional agricultural practices, 
have all occurred without reported environmental impacts. The 
potential slight, localized and transitory Increase in the number of 
INA’ bacteria resulting from the proposed field test will not result 
in any environmental impact of significance beyond the test plot on 
either a local, regional or global scale. 
2.0 Background: Previous Administrative Action 
Under Section III-A-2 of the Guidelines, (a background statement on 
the Guidelines is attached as Appendix A) an experiment involving release 
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