NOFA-NY Call to Action: USDA’s Environmental Assessment Did Not Complete Comprehensive, Health and Environmental Review
Farmington, NY — In December, 2016, the USDA’s Animal and Plant Health Inspection Service (APHIS) released an Environmental Assessment (EA) of Dr. Anthony Shelton’s Cornell University application for a permit to carry out the world’s first open-air trial of a genetically engineered diamondback moth (GDM) in Geneva, New York. The diamondback moth is a pest to brassica plants worldwide.
The Northeast Organic Farming Association of NY (NOFA-NY) considers this Assessment to be significantly lacking in comprehensive health and environmental review of the first-in-the-world open air release of the GDM — a novel organism. “We consider this to be a major activity with potentially significant and heretofore unknown health and environmental effects,” said NOFA-NY Policy Advisor Liana Hoodes.
If approved, the proposed experiments would likely be the first to utilize a female-killing trait for GE diamondback moths. NOFA-NY is concerned that the owner of this technology (originally, Oxitec UK – now Intrexon) never completed comprehensive, independent health, safety, and environmental review required by international protocols prior to bringing this organism to the United States.
Hoodes goes on to say that “most of the EA confines its review to the general impacts of the new technology, yet neglects to adequately assess the potential impacts of the trials themselves on farms and residences near the New York State Agricultural Experiment Station (NYSAES) in Geneva, NY and across the state.”
NOFA-NY has detailed its concerns in public comments on the following points:
Lack of transparency. The permit application is not publicly available as part of the Environmental Assessment, so citizens cannot fully evaluate such a major proposal.
No specific details and analysis of the 2015 Caged Trials. In 2015, Cornell’s Dr. Anthony Shelton performed caged trials of the GDM at the NYSAES, but there has been no comprehensive documentation in peer-reviewed journals, and no substantive response to NOFA-NY’s request for data.
Lack of evaluation and mapping of land use surrounding the NYSAES site, including farms, residences, and schools.
Lack of evaluation and modeling of regional climate and wind trends throughout the season, as diamondback moths are known to travel distances on the wind.
Lack of specific mapping and analysis of known agronomic or livestock antibiotic use on the site. Because the GDM technology includes the use of an antibiotic switch, the existence of background levels of antibiotics in the environment is of significant concern.
Lack of comprehensive food safety assessment, despite the likelihood that dead GE larvae on brassica plants may be ingested by various non-target organisms, including humans.
No documentation of potential economic and social effects of the trials and the proposed technology, especially its effect on organic farmers who have considerably less pest control tools available, and whose federal organic certification and livelihood may be compromised or at risk
Lack of full analysis of cumulative impacts and the trials’ effect on the local and statewide environment
Without adequate review, NOFA-NY believes that the proposed experiments may pose unnecessary risks to public health and the environment, and requests that the application be denied. NOFA-NY also points to the work of the following organizations whose comments support a denial of the permit and the request for a comprehensive Environmental Impact Statement: GeneWatch UK, Food & Water Watch, Center for Food Safety, Friends of the Earth, and Consumers Union.” -NOFA-NY
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