07
Aug
Action: Oppose Release of Genetically Engineered Moth in New York
(Beyond Pesticides, August 7, 2017) Help stop a dangerous plan hatched in New York to control a caterpillar in cabbage. Under the plan, up to 10,000 genetically engineered (GE) male diamondback moths (DBMs) will be released each week 
during the cabbage planting cycle (which runs about three to four months). According to USDA, “The males are genetically engineered with a lethal gene that they pass on to females when they mate.”
Because of the widespread release, this plan –a first of its kind in food crops– will contaminate organic farms with genetically engineered material. And, this is all being done based on a cursory environmental assessment, without an in-depth environmental impact assessment.
This is an issue that affects all of us –not just New Yorkers–because the moths do not respect state boundaries, and this action would set a precedent for other states.
Inadequate Environmental Review
Following a finding of no significant impact (FONSI) by USDA’s Animal and Plant Health Inspection Service (APHIS) on Cornell University’s proposed release, there is an urgent need to ensure that the state of New York addresses contamination issues that APHIS failed to consider. At the top of the list is possible contamination of organic crops, which could threaten the standing of organic products with consumers and holds the threat of decertification. Other contamination concerns are raised by scientists at the Center for Food Safety, Food and Water Watch, and GeneWatch UK.
The FONSI absolves APHIS from the duty to perform an in-depth environmental impact statement (EIS) under the National Environmental Policy Act (NEPA). The Northeast Organic Farming Association of New York (NOFA-NY) points out that this is the first food use of this particular kind of GE technology –using a genetically engineered male to produce inviable female offspring— and, as such, deserves the full investigation of an EIS, rather than the more cursory evaluation of the environmental assessment that led to the FONSI.
In addition to NEPA, New York state law requires a state agency to conduct a review under the State Environmental Quality Review Act (SEQR) when it uses its “discretionary” authority to approve, fund, or directly undertake an action that may affect the environment. In order to release the insects, Cornell must receive a permit under New York Environmental Conservation Law §11-0507 from the New York Department of Environmental Conservation (DEC), as it did for the release of caged insects in the past. However, DEC has denied responsibility for permitting the action. As a university with a state extension service, Cornell is subject to SEQR. If Cornell or DEC does not perform the required EIS, enforcement is up to citizens. According to the DEC website, “[C]itizens or groups who can demonstrate that they may be harmed by this failure may take legal action. . . . Project approvals may be rescinded by a court and a new review required under SEQR. New York State’s court system has consistently ruled in favor of strong compliance with the provisions of SEQR.” NOFA-NY has made a strong showing that organic growers may be harmed by this release.
Harm to Organic
Organic growers maybe harmed if the moths escape from the research plots. The engineered trait is designed to leave behind dead moth larvae and pupae resulting from the mating of the engineered males with wild females. These residues , if left on organic crops (cabbage, broccoli, and other brassica plants), could threaten the standing of organic products with consumers and the threaten decertification. In addition, there are plausible scenarios that would result in release of viable DBMs, which could increase damage to crops.
In general, the environmental assessment performed by APHIS ignored a number of important issues, including: contamination of crops with GE dead insects; the impacts on the ecological balance of native brassicas; the lack of research on the migration of DBMs from site to site; impacts in the future if engineered DBMs are released in commercial agriculture; other alternatives besides “no action,” such as the systems approach used by organic growers; the lack of adequate monitoring and buffer zones; food safety; impacts on predators; antibiotic resistance as a result from the use of tetracycline in breeding the moths; other ecological effects; and movement of the DBM across international borders.
Voice you Opposition
Voice your opposition to the release of genetically engineered DBMs to Cornell University (which proposes to release the moths), DEC (which is responsible for state permits of releases of wild animals), and Governor Cuomo (who is responsible for ensuring that state agencies meet their responsibilities.)
