(2) to make grants to individuals and institutions 
for the purpose of conducting recombinant DNA 
research ; 
(3) to let contracts for the construction and renovation 
of facilities for the conduct of recombinant DNA 
research ; 
(4) to promulgate Guidelines for the regulation of 
the recombinant DNA research program; 
(3) to propose legislation regulating recombinant DNA 
activities ; 
have been and are contrary to the requirements of law: 
B. That the defendants are required by §102(2) (C) of NEPA 
to prepare and circulate for comment a detailed final environment- 
al impact statement with respect to and prior to the taking of 
each of the actions and determinations stated above, and that the 
defendants have failed to prepare and circulate for comment a 
• final environmental impact statement on all of the actions and 
determinations stated above in contravention of the law: 
C. That the defendants are required by §553 of the APA to 
give notice of a public rulemaking proceeding, provide an 
opportunity for public comment, and hold public hearings with 
respect to the promulgation of guidelines for the regulation of 
recombinant DMA' research, and that the procedure followed by the 
defendants in promulgating the Recombinant DNA Research Guidelines 
are contrary to these requirements and defective and insufficient 
as a matter of lav/: 
D. That the defendants are required by §5 of the Federal 
Advisory Committee Act (FACA), P.L. 92-463, £6 Stat. 770, 5 U.S.C. 
App. I, October 6, 1972, to have balanced and independent 
advisory committees, and that the Recombinant DNA Molecule 
Program Advisory Committee established by the defendants is not 
balanced and independent, and its membership is contrary to these 
requirements and defective as a matter of law. 
I. JURISDICTION 
2. A. This action arises under: 
2 
[B-4] 
