10 
whether "major Federal action" was involved in the licensing 
of a nuclear power station, focused upon the evidence which 
indicated that the environment might be significantly affected. 
15. In looking to other sources of statutory support, 
j 's&D- L? 
plaintiff would point to s5(ir) of the Guidelines of the Council 
on Environmental Quality, which provides: 
"The statutory clause 'major 
Federal actions significantly 
affecting the quality of human 
environment' is to be construed 
by agencies with a view to the 
overall, cumulative impact of the 
proposed action (and of further 
actions contemplated). Such 
actions may be localized in their 
impact, but if there is potential 
that the environment may be 
significantly affected, the 
statement is to be prepared . 
Proposed actions, the environ- 
mental impact of which is likely 
to be highly controversal , should 
be covered in all cases." 
16. Plaintiff seeks the extraordinary remedy of 
injunction authorized by Rule 65, F. R. Civ. P. To be put 
on the scales in balancing the equities of plaintiff and de- 
fendants, is the horrendous potential of harm which may result 
from the experiments if they go forward. Balanced against that, 
is the delay necessary for the preparation by the defendants 
of an environmental impact statement. At the risk of over- 
simplifying the issue, the plaintiff would inquire, whether 
civilization, having survived this far without the tool of 
recombinant DNA research, will suffer substantial harm if it is 
denied science a few more months. 
[Appendix C — 54] 
