Tab C - Page 24 
ADVANCED GENETIC SCIENCES 
May 1/, 1985 
6701 San Pablo Avenue, Oakland, CA 94608 
(415) 547-2395 
Dr. William J. Gartland 
Director 
Office of Recombinant DNA Activities 
National Institute of Health 
Building 31 
Bethesda, Maryland 20205 
Dear Dr. Gartland: 
I have only a few comments on the Environmental Assessment (EA) 
prepared for the field experiment proposed by Drs. Lindow and 
Panopoulos and on the more general need for programmatic 
Environmental Impact Statement for field experiments with 
genetically engineered microbes. For having received both of 
these items from you, I am very grateful. 
In my opinion the EA is a well prepared document that involves 
the expertise of some excellent research plant pathologists and 
well qualified advisors. I believe' I also understand the basis 
for the requirement to complete such a document and Finding of No 
Significant Impact to satisfy legal ^requirements set for NIH. 
However, in reading the EA I was dismayed to find that such a 
large effort was expended to compile information that in my mind 
gives no greater assurance of safety than was available in the 
proposal of Lindow-Panopoulos that was approved by RAC. Except 
for site-specific information for Tule Lake, no substantially new 
information is brought forward to alleviate fears by 
documentation of experimental results. As no actual data is 
included or cited for many of the broad statements as to 
microbial competition, population dynamics, pathogenicity, etc., 
the statements as to risk or safety have diminished credibility. 
My point is simply that this has been an unnecessary task asked 
of NIH and that the consideration and approval of the proposal by 
RAC, as submitted, was properly conducted with the currently 
available information in this subject area. The environmental 
and health risks were properly evaluated with the finding of no 
foreseeable impact from this limited field experiment. Much 
energy and effort was expended to restate the consensus of the 
NIH-RAC decision. 
My only specific comment on the EA is that I disagree strongly 
with the use of Pseudomonas syr ingae pv syr ingae for epiphytic 
bacteria of this species which have no known pathogenicity to 
standard host plants. Until a host is found these strains could 
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