I 
" 30 - 12-00 introduction 
Actions which arc part of a program (or group of 
activities) that do not have a Statement of 
Inapplicability (Chapter 30-11-20) to the NEPA 
requirements, must be reviewed on an individual 
basis to determine the extent of the effects 
the action would have on the environment. This 
This Chapter discusses the necessary review and 
documentation for individual actions." 
E. FAILURE TO COMPLY WITH THE NATIONAL ENVIRONMENTAL POLICY ACT 
33. The NIH has developed a full program for the purpose 
of pursuing recombinant DIIA research. It has created the 
Recombinant DMA Molecule Program Advisory Committee, established 
the Office of Recombinant DMA Activities, and promulgated 
Guidelines for the conduct of this research. It has funded, 
is funding, and intends to continue funding recombinant DNA 
research into the future. It has let contracts for the con- 
struction and/or renovation of laboratories for recombinant DNA 
research, and is setting up its ovm laboratories for this 
research. 
34. The recombinant DNA research program of the NIH and 
each of the actions described above in Paragraphs 14 through 23 
and 33, has and will have profound short and long term effects 
upon the quality of the human environment and upon the main- 
tenance of a productive and enjoyable harmony between man and 
his environment and will have profound effects on the health and 
welfare of present and future generations over the entire planet 
35. In the conception and development of the recombinant 
DNA research program, including the funding of research projects 
and laboratory construction, and the promulgation of the 
Recombinant DNA Research Guidelines, defendants have violated 
and disregarded the decisionmaking processes required by NEPA, 
Executive Order 11514, the CEQ Guidelines, the DREW GAM, and 
other provisions of law, in that defendants, among other things, 
hnvc : 
15 
[B-17] 
