8 
2. all agencies of the Federal 
Govemement shall . . . 
/comply with the eight 
action-forcing provisions/ 
(Emphasis added.) 
10. The requirement of compliance "to the fullest 
extent possible" has been applied with special vigor to the 
provisions of 1 102(2) after the forceful interpretation given to 
the phrase in Calvert Cliffs* Coordinating Committee v. Atomic 
Energy Commission, 449 Fed. 2d. 1109 (D.C. Circuit 1971), Cert, 
denied, 404 U.S. 942 (1972)." 
11. It might be argued that this initial step of 
experimentation at Ft. Detrick is a relatively minor action 
and, consequently, not of sufficient magnitude to justify 
requirement that an environmental impact statement be prepared. 
Such an argument overlooks the broader aspect of what is involved 
namely that this experiment is admittedly but the first stepping 
stone towards greater utilization of Ft. Detrick, for recombinant 
DNA research; it is, as the Court stated, in United States v. 
247.37 Acres of Land /"but a small cog in anoverall big plan," 
' 
having major environmental consequences. Fed. Supp. 
, (Southern District Ohio 1971, Fed. Supp. 
(S. D. Ohio 1972). 
12. The admissions of the defendants, their actions 
acknowledging the serious potential environmental effect, 
consequent to the research to be conducted, the affidavits of 
three highly qualified scientists and the controversary reflected 
in the exhibits filed with this Memorandum clearly demonstrate 
[Appendix C — 52] 
