Tabe C - Page 5 
8520 University Green 
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"4 Pvtn*rjrtip or C*rm Co^po««y> and Wfl. &»e* A Co' 
April 24, 19S5 
Dr. William J. Gartland, Director 
Office of Recombinant DNA Activities 
Building 31, Room 3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
This letter is in response to the April 15 Federal Register notice inviting 
comment on: 1) the "Environmental Assessment and Finding of No 
Significant Impact" for the application to field test ice-nucleation-minus 
bacteria, 2) the need for a Programmatic Environmental Impact 
Statement. 
Environmental Assessment and Finding of No Significant Impact 
This document appears to be a thorough, balanced and accurate ansessment 
of the environmental effects of conducting the proposed field tes\ of ice- 
nucleation-minus bacteria produced through recombinant DNA 
technology. Clearly a tremendous amount of thought and work has gone 
into its preparation. No documenation approaching this magnitude has 
previously been required for introduction to the environment of any 
microorganism, considered to be safe, that contains a man-made genetic 
alteration. 
Many individuals with diverse experience in areas relevant to the proposed 
project have evaluated potential environmental consequences of this 
experiment and have concluded that the chance of damage is sufficiently 
low that the experiment should no longer be delayed. The Environmental 
Assessment and Finding of No Significant Impact clearly indicates to the 
public that there is no cause for concern. The consultants identified at the 
end of the assessment include scientists who are well-versed with the issues 
and who have nothing personal to gain from the outcome of the 
experiments. These scientists are internationally recognized for their 
scientific judgments. 
Thousands of different mutant microorganisms have been released to the 
environment over a period of half a century. It is important to realize that 
there is no confirmed case of environmental damage caused by release of a 
safe microorganism that has been genetically modified in the laboratory. 
The Environmental Assessment strongly supports the conclusion that this 
experiment will not affect the environment in any substantively different 
way than the thousands of "experiments" involving mutants of safe 
microorganisms that have already proceeded without problems. 
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