Tab C - Page 36 
Declaration of Stephen Richard Gliessman 
Stephen Richard Gliessman declares: 
1. I am Stephen Richard Gliessman. I reside at Molino Creek Farm at the end of 
the Cement Plant Road Extension near Davenport, California with a mailing address 
of Post Office Box 69, Davenport, California, 95017. 
2. I am an agroecologist. 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 Lindow and Nickolas Pano- 
poulos of the University of California, at Berkeley, to field test ice-nucleation- 
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. It seems that all discussion of potential environmental hazards associated 
with the release of the altered bacteria depends on the minimization of risk and 
low probability of unexpected problems. The fact that this infers that potential 
problems are not wholly eliminated is reason for concern and greater caution in 
the possible release of the ice-nucleating negative organisms that have been 
altered with recombinant DNA techniques. 
5. The assessment does not seem to deal with the question of what possible tests 
need to be designed or could be designed to ensure greater reduction or elimina- 
tion of risk of adverse effects from release of the altered organism. Since this 
case could form a landmark decision for future tests of altered organisms, it is 
even more important that this first case serve as a model for the future. 
6. Those consulted in the preparation of this assessment did not include an 
ecologist or evolutionary biologist. I feel that a broader range of expertise 
would be very important, especially since many of the aspects involved deal with 
ecological and evolutionary processes in the environment. 
7. In the section of the assessment dealing with worst case considerations, the 
assumption again is made that potential problems are at a low probability, due 
to the presence already of ice nucleation negative bacteria in the environment.. 
Before release takes place, it seems to me that it is necessary to gain further 
understanding of how a balance is maintained in nature between negative and 
positive bacteria. How do they shift? What factors promote one over the other? 
How can such information be used to ensure zero probability of problems once the 
altered bacteria are released? Have sufficient tests been performed to demon- 
strate that altered ice nucleation negative bacteria are exactly the same as 
naturally-occurring negative strains? It seems to me that a battery of tests of 
this type should be performed before release takes place. 
I declare under penalty of perjury that the foregoing is true and correct. 
Date: March 11, 1985 
Davenport, California 
[ 301 ] 
