PUBLIC AND SCIENTIFIC AFFAIRS BOARD 
AMERICAN SOCIETY FOR MICROBIOLOGY 
Tab C - Page 1 
1913 I Stmtt, N.W. 
W^jwnoton, D.C. 20006 
T&xtsone: (202) 822-9229 
April 24, 1985 
Dr. William Gartlaad 
NIH Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Dear Dr. Gartland: 
The Public and Scientific Affairs Board (PSAB) of the American Society 
for Microbiology (ASM) is pleased to respond to the FEDERAL REGISTER notice 
of April 15, 1985 (50 FR: 14794-14796) concerning the "Environmental Assessment 
and Finding of No Significant Impact" (EA-FONSI) for the application to the 
National Institutes of Health (NIH) under the NIH Guidelines for Research 
Involving Recombinant DNA Molecules, of Drs. Steven Lindov and Nickolas 
Panopoulos of the University of California, Berkeley, to field test ice- 
nucleation-minus bacteria prepared by recombinant DNA techniques for purposes of 
biological control of frost damage to plants. The ASM is the largest single 
biological life sciences organization in the world with an active membership of 
over 31,000. The PSAB wishes to comment on the EA-FONSI for the Berkeley 
experiment and the need for a programmatic Environmental Impact Statement (EIS) 
in connection with NIH approval of proposals to release into the environment 
organisms containing recombinant DNA molecules. 
The Environmental Assessment 
The Environmental Assessment (EA) prepared by the NIH in relation to the experi- 
ments proposed by the Berkeley scientists is exhaustive in its coverage and per- 
suasive in its arguments. It describes all proposed actions in detail and 
thoughtfully identifies and then considers the environmental effects of risks 
posed by those actions. We can think of no points to consider that are not 
addressed by the document. The agricultural history of the site is summarized. 
Climatological data is presented, and the animal and the human populations 
surrounding the experimental site have been surveyed. Reasonable consideration 
also was given to the probability of escape from the test site, to transport, 
and to survival of the organism after escape. Finally, although not required, 
the EA concludes with worst case considerations that describe what is remotely 
or infinitesimally possible, but highly unlikely. 
We concur in the opinion expressed in the EA that the proposed studies by the 
Berkeley scientists will have no significant impact oa the environment for the 
following reasons: 1) No functional gene has been added to the bacterium. 
Rather, a single bit of chromosomal information has been biochemically deleted 
from the bacteria that will be applied to the test site; 2) Mutation of the same 
[266] 
