University of 
Nebraska 
Lincoln 
Institute of Agriculture and Natural Resources 
Tab C - Page 13 
Department of Plant Pathology 
406 Plant Sciences Hall 
East Campus 
Lincoln. NE 68583-0722 
(402) 472-2858 
May 13, 1985 
Dr. William J. Gartland, Jr. 
National Institutes of Health 
Building 31, Room 3B10 
Bethesda, MD 20205 
Dear Dr. Gartland: 
Relative to the Environmental Assessment for the proposal to 
field test ice-nucleation-minus bacteria, I find the document to 
be appropriate and comprehensive. I do not see a need for a 
programmatic Environmental Impact Statement since anticipated 
proposals and actions by RAC are not connected, cumulative or 
likely to be sufficiently similar, criteria which I understand 
are considered standard for such an EIS. 
I do have comments on the accuracy of the EA document, which 
could affect the interpretation of certain parts. 
Page 22. 5. 2.1. A. 1. Nomenclature & taxonomy. Pseudomonas 
svrlngae is not an 'abbreviated taxonomic designation of 
Pseudomonas svringae pathovar (pv.) svrlngae 'see e.g. Bergey's 
Manual of Systematic Bacteriology, Vol. 1. 1984, p. 168). 
Rather, svrlngae is a taxon with nomenclatural status 
according to the international Code of Nomenclature of Bacteria 
(1976); infrasubspecific taxa, such as pathovars, do not have 
such a status and are not part of the taxonomic hierarchy. The 
term pathovar is used to refer to a strain or set of strains with 
the same or similar characteristics, differentiated at the 
infrasubspecific level from other strains of the same species or 
subspecifies on the basis of distinctive pathogenicity to one or 
more plant hosts (Dye et al. 1980; Rev. Pi. Pathology 
59:153-168). That is, it makes no sense and is confusing to 
create pathovar names for sub-populations of species where there 
is no evidence that they have any pathogenic character. Thus, 
the epithet £_«. svringae is correct, since the strains being 
worked with are not and never have been shown to be pathogenic. 
An example of such correct usage is found in Gross, D. et al., 
1983, Appl . Evn. Microbiol. 46:1370-1379. Those strains of E*. 
svringae that have been shown to be pathogenic may warrant the 
designation of pv. svr ingae or other pathovar epithet. 
Page 23. L.l. svringae and svringae pathovars are common 
plant epiphytes. None of these taxa has ever been shown.... and 
do not grow. . . 
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