Tab C - Page 22 
Dr. William J. Gartland 
May 15, 1985 
Page 2 
no adverse effects on or in the environment. The expert consul- 
tants who were involved are world-renowned for their scientific 
credibility and judgment. As such, the Environmental Assessment 
clearly supports the continuation of the research and the conclu- 
sion that this experiment will not adversely affect the environ- 
ment in any substantive manner. 
The Need for a Programmatic Environmental Impact Statement 
From our point of view, the Environmental Protection Agency and 
the U.S. Department of Agriculture, including APHIS, are taking 
leadership roles in agriculturally oriented research dealing with 
recombinant DNA and genetically engineered plant varieties. With 
the already published EPA interim guidelines dealing with pesti- 
cide research and notification, and the soon-to-be proposed 
rulemaking on the subject, it appears that the role of NIH, as 
oversight, should in the future be directed to only those activi- 
ties of broad national concern involving public health issues. 
The technology of bio/genetic engineering, particularly in 
agriculture, is progressing in a very positive manner. The need 
for detached oversight such as the development of a very compre- 
hensive Environmental Impact Statement by NIH to comply with 
certain interpreted requirements of NEPA seems now to be proce- 
durally redundant unless there is a scientific reason to question 
a basically unknown revelation. 
At this time, there is no reason to believe that genetically 
engineered organisms are any different than organisms that mutate 
during natural selection. Over the years, plant breeding tech- 
niques have used chemically induced mutations to assist in mass 
selection. In genetic engineering, the biological derivation is 
actually more precise and predictable. It would appear that very 
strong arguments would have to be made to justify the need for a 
programmatic Environmental Impact Statement to demonstrate that a 
genetically engineered organism has a greater chance to invoke 
environmental harm than an organism altered by traditional 
practice. 
cc : NACA ad hoc Committee on Biotechnology 
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