Tab C - Page 31 
DECLARATION OF DAVID PIMENTEL 
David Pimentel declares: 
1. I am David Pimentel. I reside at 147 North Sunset Drive, Ithaca, 
NY. 
2. I am a terrestrial ecologist. My curriculum vitae, appended hereto, 
is Incorporated by this reference with the same effect as though fully stated 
herein. 
3. I have reviewed the environmental assessment and finding of no 
significant impact by the NIH proposed experiment by Drs. Steven Llndow and 
Nickolas Panopoulos of the University of California, at Berkeley, to field 
test ice-nucl eatlon-minus bacteria prepared by recombinant DNA techniques for 
purposes of biological control of frost damaged plants. I have the following 
opinions and conclusions to make regarding that assessment and finding. 
4. A statement is made that "neither the original nor the altered 
bacteria are pathogenic to living creatures" yet In Llndow's published papers 
he refers to this bacterium Pseudomonas syringae (Ps) as an "Important 
pathogen" in nature. Lindow also speculates that £7 may well be pathogenic, 
to insects. Thus, the statement in the assessment is Incorrect. 
5. It is stated that _P^ "did not induce frost or other injury to 
plants." By plants is meant more than potato plants. Only a few tests were 
run with 6 crop species but no other crop plants that are cultured in that 
California region are Included. Also no natural vegetation types were 
tested. Thus, Insufficient data exist to support the quoted statement. 
6. It is stated that "certain strains or isolates of _Ps have been 
reported to be pathogenic on many woody and herbaceous plants including bean, 
lima bean, wheat, barley, sorghum, corn, pear, apple, plum, peach, cherry, 
citrus, and others." This statement contradicts an earlier quoted statement 
(see *4). Also, Llndow has not tested his Ps strain for Its pathogenicity to. 
all of these crop plants and again no naturaT plant species have been 
included in his environmental study. 
7. It is stated that their strain of "will have been screened for 
pathogenicity towards oats, wheat, barley, corn, tomato, and three cultlvars 
of beans." When will these tests be completed and how will the scientific 
credibility of the data be validated? It should be noted that this list of 
crop plants makes up only a small portion of the total crop plants grown in 
the test area. In particular no fruit (pear, peach, plum, cherry, etc.) are 
Included In the test nor are any natural plant species Included. 
8 + It Is stated that " Analogous to plant frost survival, the presence 
of INA bacteria would be detrimental to survival of f rost-sens 1 tl ve Insects 
and possibly beneficial to frost-tolerant insect species." This also 
contradicts an earlier statement that not "pathogenic to living 
creatures" (see #4). Llndow has not run any tests with beneficial Insects 
like honey bees. Bees provide pollination to over S20 billion worth of U.S. 
crops annually. Other beneficial Insects play an Important role In 
biological control of pests. 
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