Tab A - Page 54 
isolated, such bacteria can represent, for example, up to 80 percent for P_. s_. 
pv. syrinqae and up to 100 percent for _E. herbicola of the total number of 
epiphytes present. Such large ratios of INA bacteria in the environment 
suggests that some equilibrium already exists between INA + and INA" strains and 
other bacteria. The populations proposed for field tests would be trivial 
introductions into the environment, and would not significantly affect that 
balance. Even if an imbalance in favor of the INA" bacteria did occur on a 
local field, a situation that already exists in nature, the result would be 
protection of the plants from frost damage or no effect. Wild-type strains of 
these bacteria have been sprayed experimentally on plants for over 20 years in 
different biological control experiments in field tests. In most cases, it is 
not known whether or not these were INA 1 " or INA"; the probability Is that some 
of both have been used. No adverse effects on applicators, plants, animals or 
the environment have ever been reported. P_. syrinqae pv. syrinqae has never 
been shown to be a pathogen of humans or animals and does not grow at mammalian 
body temperatures . E. herbicola strains of plant origin have never been shown 
to be associated with pathogenicity to humans or animals and the bacteria to be 
used in this experiment have been isolated from plants. (U) Some strains of 
P_. syrinqae pv. syrinqae can cause disease in certain plants some of which are 
grown in the area surrounding the test plot, but the strains to be used in the 
proposed field test have been isolated from healthy plants and screened to 
assure that they do not cause disease to major crops grown in the area. 
Furthermore, there is some evidence that the bacteria are host specific, best 
suited for colonizing or causing disease only in the plant from which the 
bacteria were isolated. The modified IMA" bacteria are no more capable of 
causing plant disease than are their wild counterparts and will not change the 
balance between INA + and INA" bacteria outside of the test plot. Since INA" 
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