13 
1 the two documents. 
2 When differing interpretations of the same 
3 issue are given in different sections of the Federal 
4 Reg ister package, it is impossible for EDF , any other 
5 commentator or a person conducting recombinant DNA 
6 activity to ascertain what the correct interpretation 
7 is. In addition, it is unrealistic to assume that every 
8 reader will scour all the documents in the Federal 
9 Reg ister . Most importantly, the Environmental Impact 
10 Assessment and the Director's decision document again 
11 do not have the indisputable force of law. 
12 EDF therefore maintains that all information 
13 necessary for compliance must be included in the guide- 
14 lines themselves, and that ambiguities within the guide- 
15 lin®s must be clarified. 
16 The second area of concern I will discuss today 
17 is the failure of the guidelines to specify procedures for 
18 public notification and comment. The guidelines often 
19 indicate that a decision will be made "after appropriate 
20 notice and opportunity for public comment." However, no 
21 further clarification of this notion is ever given. The 
22 procedures for public notification and comment must be 
23 described in detail in the guidelines. Failing this, the 
24 public will have no assurance that opportunity for public 
25 comment indeed will be provided if pressure for a quick 
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