by GM Watch 
Cornell University has applied  for a permit to execute the world’s first open-air trial of a genetically engineered diamondback moth (GDM). The purpose of this new GM insect is to reduce pest populations of diamondback moths through engineering a new female lethality trait (female larvae die, and males go on to reproduce until the population is destroyed) into male GDM.
Those pushing this new technology have not completed any worldwide assessments of health and environmental safety, and only the most cursory of environmental reviews has been conducted by the USDA’s Animal Plant Health Inspection Service (APHIS).
Unless and until all environmental and health impacts have been reviewed, it is reckless to release hundreds of thousands of novel organisms around the citizens and farms of New York State.
The USDA’s Animal and Plant Health Inspection Service (APHIS) is holding a public consultation on the proposal to release the GM diamondback moths.
Please object to the proposal. You can use the bullet points given below (in “Points for your comments to the USDA/APHIS”).
Please submit your comments here BEFORE May 19, 2017:
by clicking on the box, “Comment Now!”
For more information, see the complete USDA/APHIS permit
The environmental assessment
and GeneWatch UK’s briefing
Points for your comments to the USDA/APHIS
Please use your own words insofar as is possible and make the objection your own by explaining how this GMO insect trial affects or concerns you, your family, and/or your community.
1. IMPACT ON HUMAN AND ENVIRONMENTAL HEALTH
* The human and animal health and environmental impacts of GDM on target and non-target species are unknown.
* In particular, the impacts on non-target species that might eat the GDM larvae are not known. These include:
– Farmworkers who may breathe or ingest large amounts of dead larvae debris or live adults
– Vegetable consumers who may eat dead GDM larvae remaining on the vegetable
– Other birds and animals that may eat the plant, larvae, or debris
– Non-target species in the soil that might eat or come in contact with dead GDM larvae that drop to the ground
* The use of a tetracycline antibiotic to breed the GDM could mean that antibiotic resistant bacteria can develop in their guts and spread into the environment and food chain.
2. IMPACT ON BRASSICA FARMING IN NEW YORK STATE
This trial could create a problem that doesn’t exist today, with negative consequences to the vital brassica farming business and farm economy in NYS.
* Diamondback moths are not a serious agronomic threat in New York, yet this trial could create a bigger problem. The permit allows that non-GM moths may be released if there aren’t enough naturally. GDM need to be repeatedly released at many times greater-than-natural numbers in order to overcome the wild population. Ratios of 10 to 1 and 40 to 1 GDM to wild moths have been used in caged experiments to date, taking repeated releases over six weeks to begin to suppress the wild moth population. The resulting damage to crops could be considerable.
* In real world use, large releases of GDM could make it economically and agronomically challenging to grow brassicas in NYS for both conventional and organic farmers.
* Farmers may need to use additional amounts of pesticide to protect the crop against the infestation. This could create a cycle of release/spray that will require ever greater releases and more spraying.
* Organic farms and methods of control could be overwhelmed in the face of the infestation created, making organic brassicas a thing of the past in NYS.
* If the release results in reductions in diamondback moth populations, other pests, including potentially more destructive ones, could move into the ecological niche created, resulting in serious ecological and agronomic problems.
* Since GDM female larvae die (presumably on the plant), farmers (conventional or organic) could experience large amounts of dead larvae on the plants, possibly resulting in market rejection of NY-grown brassicas and threatening export markets.
3. POTENTIAL FOR CONTAMINATION AND OTHER UNINTENDED CONSEQUENCES
There are no appropriate bio-security measures in place that can protect those who do not wish to expose themselves to GDM. Windblown moths can be dispersed hundreds/thousands of miles from where they emerge.
* When male GDM spread outside the trial site, breeding and release of large numbers could lead to a resistance to the female lethality trait. The GDM might encounter sufficient tetracycline in the environment to allow them to survive and breed.
* The developers have not investigated how the insects might mutate and evolve as releases continue.
* Organic and other farmers who do not wish to have GDM on their crops will not be protected from spread of GDM to their fields. No measures have been put in place to establish liability and responsibility for contamination by GDM.
Background to the plan
The GM diamondback moth was developed by the British GMO insect developer firm Oxitec Ltd to reduce the population of this species, which is a pest to Brassica family plants. In 2014 Oxitec received a permit from USDA APHIS to allow the first world-wide efficacy trials of this moth in New York State by Dr Anthony Shelton, Cornell University.
The world’s first GDM trials began in 2015 under netted cages at Cornell University’s Geneva Experiment Station.
The permit granted by USDA/APHIS allows for 3 years of open (non-netted) trials, releasing up to 1.44 million male GDM per year.
Diamondback moths are a serious pest to the Brassica family of plants in the southern US, UK, parts of Europe, South and Southeast Asia, Australia, New Zealand and Africa, although not particularly in New York State.
The purpose of this new GM insect is to reduce pest populations of diamondback moths through engineering a new female lethality trait (female larvae die, and males go on to reproduce until the population is destroyed) into male GDM.
Concerns include the contamination of crops with female GM larvae, which die while feeding on the crop, and impacts of this single-species approach on other pests which could cause increases in their numbers.
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 to adulthood by feeding them on this antibiotic. Multiple thousands of male GDM are repeatedly released into the field and mate with wild females who produce eggs which are laid on the brassica. Larvae develop and the GDM female larvae die. The GDM males pupate to continue the cycle and surviving GDM males, along with repeated additional releases of GDM males, suppress the numbers of wild diamondback moths. This takes six weeks or more in laboratory experiments.
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 months. There may also be a release of non-GE moths if there are not enough naturally existing. The release of male GDM must be in numbers an order of magnitude greater than wild moths in order for the GDM to overtake the wild ones. The release rate is unknown at this time, but numbers from 4X to 50X have been used in trials of other GM insects.
With thanks to NOFA-NY (Northeast Organic Farming Association of New York) for their information sheets:
General fact sheet https://www.nofany.org/files/GDM_FACT_SHEET_v._1-10-16.pdf 
Farmers’ fact sheet https://www.nofany.org/files/FARMERS_GDM_Info_SheetREVISED.pdf 
Read the full article at GM Watch