7 
is known to cause cancer in mice. Whether that cancer virus will 
cause cancer in human beings is unknown. The nature of the 
organisms to be created by the research at Ft. Detrick, is such 
that, if released from containment, they may remain dormant in th 
environment for a substantial period of time, and continue to 
possess the potential for infecting the environment. The 
organisms may not cause cancer symptoms for 20 to 30 years , and 
then create illnesses, the treatment of which is not known. 
These organisms are alive, self-perpetuating and reproduce 
rapidly. Conduct of such experiments at Ft. Detrick exposes 
large segments of population to many unpredictable health 
hazards. Even a miniscule quantity of the organisms to be 
created, if released in the environment, due to their ability 
to reproduce rapidly, represents a real threat to life and 
health which is beyond the present knowledge of science to 
cope with. 
e 
16. Despite the requirements of Section 102(2)(C) 
of NEPA, defendants have, in connection with the proposed Ft. 
Detrick experiments, and the renovation of the laboratory there, 
failed to prepare the Environmental Impact Statement required 
by that statute, and have failed to comply with the requirements 
of the guidelines promulgated by the Council on Environmental 
Quality as to statements on proposed Federal actions affecting 
the environment (38 Fed. Reg. 10859, Hay, 1973), and have other- 
wise violated Federal statutes, and regulations. 
17. Unless the actions of defendants are enjoined, 
[Appendix C — 41] 
