2 
Cir. 1976); District I-Marine Engineers v. Coleman, Civil Action 
No. 75-1208 (D.D.C. 1975); East Tennessee Energy Group, Inc. , v. 
Seamans, 7 ERC 2144 (D.D.C. 1975). As we will demonstrate in 
our opposition to plaintiff's motion for a preliminary injunction, 
the environmental impact statement submitted to the Court in this 
case falls within the ambit of the above cases. A broad program 
statement with respect to recombinant DNA research satisfies 
the requirements of NEPA, and individual impact statements with 
respect to each and every recombinant DNA experiment are unnecessary. 
Thus, it is apparent that there is no point whatsoever in 
continuing the stay of proceedings here. An environmental impact 
statement has been finalized and submitted to the Court. That 
environmental impact statement complies fully with NEPA, and we 
shall so demonstrate to the Court in our opposition to plaintiff's 
motion for a preliminary injunction. Moreover, plaintiff will have 
a full opportunity to attempt to show the Court why the environmental 
impact statement is not sufficient with respect to the particular 
experiment which is the subject of his action. In these circumstances, 
the stay of proceedings should be lifted so that the Court can 
consider the merits of the complaint. 
Respectfully submitted, 
EARL J. S INSERT 3 
United States Attorney 
Co /U / P 
' T RTT/RKRT ^ 
ROBERT N. FORD /*■ 
Assistant United States Attorney 
[Appendix C — 104] 
