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1 to comply with NEPA. First of all, a thorough Impact 
2 Statement is clearly required by the law. The revisions 
3 are both major and significant, and the direction of the 
4 changes will mean an increase in the possibility of 
5 affecting health and the environment. The comprehensive 
g lowering of containment standards, the exemptions, the 
7 possibility of exceptions to prohibited experiments all 
0 contribute to an increased risk to the health and the 
g environment. 
10 The changes will lead to a significant expan- 
H sion of recombinant research in addition to reduced 
12 safeguards, and there are several hundred experiments 
13 in this country now which will be affected. Moreover, 
14 the revisions will have worldwide impact on guidelines 
15 being used in Great Britain, the European continent, 
15 Japan, Israel, Australia, likely even the USSR. Even 
17 a casual perusal of HEW regulations and CEQ guidelines 
18 demonstrates the necessity of a full Impact Statement 
19 for the revisions. 
20 Now, I will just give a couple of examples. 
21 Again, I already made mention of the controversy sur- 
22 rounding the scientific issues with respect to the 
23 guidelines. Now, the CEQ guidelines and supporting 
24 case law say when there is such a substantive contro- 
25 versy, that there must be a full Impact Statement, and 
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