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Lilly Research Laboratories 
A Division of Eli Lilly and Company 
307 East McCarty Stra*t 
inaianapolis. Indiana *6285 
Irving S. Jonnson. Ph.Q 
v<* PrmKMm 
May 14, 1985 
Dr. William J. Cartland, Jr. 
Director, Office of Recombinant 
DNA Activities 
National Institute of Allergy 
and Infectious Diseases, 31/3B10 
National Institutes of Health 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
We are replying to the request for comments on the Environ- 
mental Assessment (EA) prepared by the National Institutes of 
Health (NIH) on the experiments in the "Environmental Assessment 
and Finding of No Significant Impact" (EA-FONSI) for the appli- 
cation to the NIH under the NIH Guidelines for Research Involving 
Recombinant DNA Molecules, of Drs. Steven Lindow and Nickolas 
Panopoulos, 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 
specific question for which comments are requested concerns the need 
for a programmatic Environmental Impact Statement (EIS) relative to 
NIH approvals of such experiments. We offer the following statement 
regarding the rational absence of such a need: 
We certainly question whether an EIS is desirable 
or necessary in this case. We also question whether 
a programmatic EIS should be required in any case where 
an adequate EA Is provided. By definition, a programmatic 
EIS is concerned with broad issues rather than with 
specific considerations which relate to a particular 
site. In these experiments and, it seems to us in all 
but the most unusual circumstances, an EA will serve as 
well as an EIS to identify environmental effects. The 
EA is more concerned than the EIS with the present. 
To suggest that a programmatic environmental Impact 
statement be developed for recombinant DNA technology 
after two or three experiments involving field tests of 
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