Tab C - Page 12 
Southwest Foundation 
for Biomedical Research 
West Loop 410 a( Miliury Drive 
P.O. Bo* 28147 
San Amonio. Texas 78284 
(512) 674-1410 
May 9, 1985 
NIH Office of Recombinant DNA Activities 
Building 31 
Room 3B10 
National Institutes of Health 
Bethesda, MD 20205 
Re: Comment on the Need for a Programmatic Environmental Impact Statement 
(EIS) 
The following comments are the opinion of the individual scientist whose 
signature is included and may not reflect the opinion of other scientists or 
individuals at the Foundation at which the scientist is employed. 
It appears that the National Institutes of Health in initially reviewing 
the application of Drs. Steven Lindow and Nicholas Panopoulos of the 
University of California, Berkeley, to field test ice-nucleation-minus 
bacteria prepared by recombinant DNA techniques and in issuing an 
Environmental Assessment and a Finding of No Significant Impact has fulfilled 
its mission. The preparation of a programmatic Environment Impact Statement 
(EIS) seems unnecessary, particularly as its absence would not appear to 
obstruct environmental review by other agencies. An EIS prepared by NIH could 
be redundant because of a Proposal for a Coordinated Framework for Regulation 
of Biotechnology proposed by the Office of Science and Technology Policy 
( Federal Register 49 FR 50856) . Should such an inter-agency advisory 
structure be established, it might appropriately review proposals for 
deliberate release of organisms containing recombinant DNA and conceivably 
issue a programmatic EIS for this particular field test experiment. 
d- 
C. Elizabeth Castro, Ph.D. 
[277] 
