Tab C - Page 29 
parasitism, especially, as regards bacteria. Another 
one is a virologist, and the others are predominantly 
genetic engineers. The assessment would have been 
improved had qualified ecologists in the relevant 
specialities been included as consultants. Issues can 
only be recognized and dealt with adequately if there 
are qualified experts undertaking the evaluation. 
There was inadequate consideration of the nature 
of the modified Pseudomonas syringae ("P_s.") as highly 
competitive specimens chosen for their ability to 
displace their wildlife counterparts. Little or no 
attention was given to the genetic stability of these 
mutant bacteria, a point that Dr. Lindow emphasized 
distinguishes them from mutants created by chemical or 
radiation means. The implications for disruption of 
the natural balance between ice-nuc 1 ea t io n- p 1 u s (INP) 
and ice-nucleation-minus (INM) Ps_. is therefore not 
adequately considered. 
Most of the other inadequacies of the 
environmental assessment are set forth in the 
declarations of Drs. David Pimentel and Stephen Richard 
Gliessman, copies of which are appended hereto and 
incorporated by this reference with the same effect as 
if fully set forth herein. 
The EA fails to justify the conclusion that the 
experiment will have no significant environmental 
impacts because it fails to consider adequately the 
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