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environmental assessment is not sufficient. Also, NEPA 
2 . 
requires that alternatives be considered. Well, 
o . 
Dr. Whelan this morning stated that the different 
4 national guidelines have strikingly different containment 
5 requirements for the same organisms. This has not been 
6 explored at all, and no justification has been given for 
7 choosing the particular containment standards set out in 
8 the guidelines. 
9 Also, there has been very little mention from 
10 an environmental standpoint about the activities of the 
11 Department of Agriculture and their great interest in 
13 recombinant DNA techniques. Now, here I see more clearly 
13 environmental impacts coming out, because you are talking 
14 about agricultural products and a desire to release these 
15 new organisms into the environment. I think these direc- 
16 tions should be explored in an Impact Statement. This is 
17 where NIH is a lead agency. The Department of Agriculture 
18 should provide input into the NEPA process in developing 
19 a full, thorough Impact Statement. 
20 My second point concerns the Environmental Im- 
21 pact Statement [Assessment] . This is just a pro forma docu- 
22 ment. It is full of conclusory, self-serving assertions, 
23 and contains essentially no analysis. The prime example 
24 of the lack of analysis is on page 33110, where the basis 
25 for exemptions is given. I will read from the document: 
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