X. RELIEF REQUESTED 
WHEREFORE, plaintiff prays for judgment 
A. Declaring that the actions of the defendants in 
connection v/ith the recombinant DMA research program, including 
the actions and determinations 
(1) to implement the recombinant DMA research 
program; 
(2) to conduct recombinant DMA research; 
(3) to make grants to individuals and institutions 
for the purpose of conducting recombinant DMA 
research; 
(A) to let contracts for the construction and/or 
renovation of facilities for the conduct of 
recombinant DMA research; 
(5) to construct and/or renovate HIM facilities for 
the purpose cf conducting recombinant DilA research; 
(6) to promulgate Guidelines for the regulation of 
the recombinant DMA research; 
(7) to propose legislation regulating recombinant DMA 
activities; 
have been and are contrary to applicable lav/. 
B. Declaring that the defendants are required by §102(2) (C) 
of NEPA to prepare and circulate for comment a detailed final 
environmental impact statement with respect to each of the actions 
and determinations stated above. 
C. Declaring 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 v/ith respect to the promulgation of guidelines for the 
regulation of recombinant DMA research, and that the procedures 
followed by the defendants in promulgating the Recombinant DMA 
Research Guidelines are contrary to these requirements and 
defective and insufficient as a matter of law. 
D. Declaring that the promulgation of the Recombinant DMA 
Guidelines by the defendants was and is arbitrary, capricious, 
an abuse of discretion, contrary to the provisions of the APA 
37 
[B-39] 
