10 
that no recombinant DNA molecules will escape from the 
carefully controlled laboratory to the environment, a 
separate EIS discussing the environment at Fort Detrick 
or at Frederick, Maryland, would serve no purpose. NIH 
has adopted comprehensive Guidelines concerning all facets 
of recombinant DNA research, and these Guidelines essentially 
eliminate adverse environmental impacts. Under the Guide- 
lines recombinant DNA research will be conducted in such a 
way as to eliminate significant environmental impacts at 
individual locations. Hence, the Guidelines set forth 
detailed physical containment requirements to prevent the 
escape of all organisms together with biological containment 
requirements to ensure that any escaping organisms do not 
survive outside the laboratory. The EIS fully assesses 
the environmental impact of research performed in accordance 
with these requirements of the Guidelines, and there is 
no need whatsoever for NIH to engage in the useless analysis 
of individual factors in each geographic location where an 
experiment is conducted. 
As discussed in Part II below, much of plaintiffs' 
concern is based on an apparent misunderstanding of the 
nature of the materials to be used in the experiment. 
Significantly, the NIH "Guidelines prohibit certain kinds 
of recombinant DNA experiments, which include all the known 
hazards -- for example, those involving known infectious 
agents." Final EIS at 2. Plaintiff has presented no evidence 
to suggest that the experiment poses any threat to the 
environment at all. The use of maximum containment facilities 
[Appendix C — 118] 
