A'. Refused and failed to prepare final environmental 
impact statements v/hich detail alternatives and other 
matters required by NEPA, the CEQ Guidelines, and the DREW 
GAM, before taking action with respect to 
(i) the recombinant DNA research program 
as a whole; 
(ii) each grant funded by NIH for the purpose 
of conducting recombinant DNA research; 
(iii) each recombinant DNA research project 
conducted within the NIH; 
(iv) each contract let for the construction 
and/or renovation of facilities for the 
conduct of recombinant DNA research; 
(v) the construction and/or renovation of NIH 
facilities for the conduct of recombinant 
DNA research ; 
(vi) the promulgation of the Recombinant DNA 
Research Guidelines; 
each of which constitutes a major Federal action 
significantly affecting the quality of the human environ- 
ment ; 
B. Failed and omitted to study, develop and describe 
appropriate alternatives to the recombinant DNA research 
program and each recombinant DNA research project, including, 
among others, those alternatives set out in Paragraph 12; 
C. Failed, as part of the decisionmaking process, to 
assess the alleged economic and technical benefits against 
the environmental costs ; 
D. Failed to utilize a systematic, interdisciplinary 
approach which will insure the integrated use of the 
natural and social sciences and the environmental design 
arts in planning and decisionmaking which may have an 
impact on man’s environment; 
E. Failed to identify and develop methods and 
procedures, in consultation with the Council on Environ- 
mental Quality, which will insure that presently unquan- 
16 
[B-18] 
