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Will New York Become the Location of the First Worldwide Open-air Trials of a Genetically-engineered Diamondback Moth?

Will New York Become the Location of the First Worldwide Open-air Trials of a Genetically-engineered Diamondback Moth?

Thank you to Liana Hoodes, NOFA-NY's Policy and Advocacy consultant for this blog:

In 2014, Dr. Anthony Shelton of Cornell University was granted a USDA/APHIS permit for the world’s first open trials of a Genetically Engineered Diamondback moth (GDM)1 at the Geneva, NY Experiment Station. In 2015 the experiments were done outdoors in netted cages.

We don’t know the results of these trials, but in March 2016, following a request by USDA/APHIS, Cornell withdrew their permit. Within days a new permit application was re-submitted, and it is now working its way through USDA. After this, they will need NYS approval.  While it is unlikely that there will be any trials in 2016, open-air trials are scheduled to take place during the 2017 growing season. It is essential that we all understand the details of these trials – risks or rewards.

And it is essential that New Yorkers get a voice in the process.

During most of the past year, NOFA-NY, Food and Water Watch, Center for Food Safety, Consumers Union, Friends of the Earth, and GeneWatchUK – have been requesting more detailed information from both USDA and Cornell about impacts as well as process. It has been slow in coming and many questions remain.

Whatever the pros and cons of the technology, it is high time for New Yorkers to have all the information in hand before the moths are let out into the environment.

Very little health and environmental review has been completed about this moth. Oxitec2, the developer of the GDM, neglected to complete the Health and Environmental studies required by the EU or the Cartegena Protocol, leaving many health and environmental questions unanswered. When pressed, they claim that this technology is similar to others that were already assessed. That’s just not true – this is the first open trial of the female lethality trait.

Prior to granting the permit, USDA/APHIS produced a cursory Environmental Assessment that failed to assess the impacts on agriculture or on species that might ingest particles of dead GE organisms. In fact USDA/APHIS dismissed most serious impacts because the moths don’t fly very far, won’t leave the trial site, and don’t overwinter. Yet diamondback moths do overwinter in New York, and are known to travel hundreds of miles on the wind. Are we to believe that the moths won’t leave their trial sites?

In addition, there has been no robust analysis of factors that could make the trials go wrong.

These issues must be examined – before this technology is released.

WHAT’S THE PROBLEM THEY’RE TRYING TO SOLVE?

Diamondback moths are a serious pest to Brassica family3 particularly in the southern US, UK, parts of Europe, South and Southeast Asia, Australia, New Zealand and Africa.Broccoli-planting.jpg

The purpose of this new GE insect is to reduce pest populations of Diamondback moths through engineering a female lethality trait into male GDM, in order to overwhelm the natural population.  On Cornell’s trial site of up to 60 acres, they estimate releasing up to 1.44 million male GDM per year. 

HOW IS IT SUPPOSED TO WORK?

Male GDM are produced in the laboratory with fluorescence and ‘female lethality’ traits. The lethality trait is turned off by a tetracycline switch, so the insects can be bred in the lab. Multiple thousands of male GDM are repeatedly released into the field to mate with wild females who produce eggs laid on the brassica. Larvae develop and the GDM female larvae die. The GDM male pupate (eating their way through the brassica) to continue the cycle and aided by repeated releases of additional GDM males, suppress the numbers of wild Diamondback moths. 

In order to significantly affect the moth lifecycle, up to 100,000 male GDM will be released from the lab weekly for up to 4 months4.  Male GDM must be in numbers an order of magnitude greater than wild moths in order for the GDM to overtake the wild ones – estimated at 4X - 50X natural numbers.

 
 

NOFA-NY is specifically concerned about the effect of this proposed research trial on brassica production (both conventional and organic) in New York for agronomic reasons, and the health effects of the ingestion of dead GE larvae on all animals (including humans). Putting aside the viability of commercialization of this technology, NOFA-NY has questions and concerns about the trial itself and its effect on New York farmers and eaters. 

WHAT COULD GO WRONG?

Concerns include the contamination of crops with dead female GE larvae which die, the continued destruction of the crops by high numbers of male survivors, and impacts on other pests of this single-species approach which could cause increases in their numbers.

What about the technology? Do farmers purchase and release hundreds of thousands of moths every week, and watch while they multiply and die in large numbers on their brassica plants so that the population eventually dies off? What happens to their neighbor’s fields? Do they just accept these extra Genetically engineered pests? What happens if hundreds of thousands of GDM are released, in anticipation of dying, but encounter tetracycline in the environment from remnants of agricultural and human use5?  What happens to humans and animals potentially ingesting and interacting with all these moths?

What happens around the Geneva Experiment Station trial sites?  This is New York brassica growing region – and New York is the 3rd largest brassica producing state in the nation. Do hundreds of thousands of moths released just stay on the trial sites, or will they fly to neighboring fields and die in huge numbers on actual production farms?

And while conventional farmers have the option to spray if they see the population increasing, organic farmers will be forced to deal with significant increase in a pest without a quick-fix spray. There are some products available for organic control of diamondback moth, but is dependent on early action. For organic farmers, detailed knowledge of the trial timing and locations will be crucial to their survival. 

WHAT HAPPENS NOW?

It‘s likely that Cornell will receive another USDA/APHIS permit for open air trials in 2017.  They will then need a NYS Department of Environmental Conservation permit for open release. NOFA-NY believes that New York must require full Environmental Review under the State Environmental Quality Review Act, including a full Environmental Impact Statement. That will give New Yorkers detailed information and an opportunity to participate in public comment.

Cornell University must include the public – both farmers and all citizens – in developing their plans for such trials. Given what’s at stake, it is not reasonable to inform after the fact. When novel technologies have the possibility of changing our environment, our health and our ecosystems, it is our right to participate.

Click here for the NOFA-NY Fact Sheet on the GE moth..

NOFA Fact Sheet for farmers:  www.nofany.org/files/FARMERS_GDMoth_Info_SheetREVISED_copy.pdf

 
 

From NOFA-NY 2016 Policy Position on Emerging Technologies and Novel Organisms, adopted Jan. 2016):

Bring democracy and transparency to the process of reviewing, approving, and managing trials and implementation. This includes clear communication to all stakeholders and the community before trials are approved to allow for appropriate public discourse and comment, sharing results and impacts of any trials that occur, as well as any new information that comes forward during implementation.
https://www.nofany.org/files/Policy_Positions_for_Web.pdf

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1(Plutella xylostella)
2(Oxitec UK is the same company that produced the GE mosquito - now owned by Intrexon)
3The Brassica genus includes broccoli, cabbage, cauliflower, and the mustard family
4There may also be a release of non-GE moths if there are not enough naturally existing
5Tetracylcine is the switch that turns the lethality trait on and off - so they can be bred in the lab. 

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