Papaya posse

The USDA has drawn opposition from "the usual suspects" regarding the University of Florida's request to deregulate genetically engineered papayas in Florida. Here is a sampling from the Center for Food Safety:


The Center for Food Safety (CFS) is a non-profit, membership organization that works to protect human health and the environment by curbing the proliferation of harmful food production technologies and by promoting organic and other forms of sustainable agriculture. CFS represents 67,000 members throughout the country that support organic agriculture and regularly purchase organic products.1 In addition to the comments submitted herein, CFS is concurrently submitting 7,873 comments from CFS Food Network members opposing the deregulation of GE papaya (Docket No. APHIS-2008-0054)

Later....

In general, the University of Florida claims in support of its Petition for Determination of Nonregulated Status for the X17-2 Line of Papaya (hereafter “Petition”) that there has been no reported adverse environmental impacts from the commercial planting of PRSV papaya. However, the history of PRSV papaya tells a very different story. Those who grow non-GE papaya in Hawaii have been devastated by the introduction of GE papaya. While the petitioner claims that PRSV papaya has “revitalized the Hawaiian industry,” (Petition at 1), the petition completely fails to address significant adverse effects to the non-GE papaya industry in Hawaii resulting from wide spread biological contamination and the related adverse economic harm to Hawaiian papaya growers, and how similar adverse effects will likely befall growers in Florida, Puerto Rico, and anywhere else this new GE papaya may be grown.3 APHIS similarly ignores the recent history in Hawaii when it failed to address biological contamination and the interrelated economic consequences. Thus, the following comments illustrate why the proposed deregulation should not be finalized until APHIS prepares an environmental impacts statement (“EIS”) to fully review the significant environmental effects of this possible deregulation. At its core, the National Environmental Policy Act (“NEPA”) directs federal agencies to prepare an EIS for all “major federal actions significantly affecting the quality of the human environment.”4 An EIS must “rigorously explore and objectively evaluate all reasonable alternatives” to the proposed federal action.5 An EIS must also include a full and fair discussion of the proposed action’s effects and their significance.

Relevant effects may be “ecological . . . aesthetic, historic, cultural, economic, social, or health, whether direct, indirect, or cumulative.”7 In the recent federal court decision Geertson Seed Farms v. Johanns, the United States District Court held, and the United States Court of Appeals for the Ninth Circuit affirmed, that where biological contamination of a non-GE crop is made possible by the deregulation of its GE counterpart, APHIS must prepare an EIS to disclose and analyze the contamination as well as the interrelated adverse economic effects. There is ample evidence from the deregulation of PRSV resistant papaya for Hawaii that such adverse impacts are not only possible, but highly likely. Additionally, in its EA APHIS fails to evaluate potential adverse impacts to threatened and endangered species, organic papaya growers and the choice of consumers to eat non-GE papaya, the adverse impacts associated with the pesticidal viral coat protein, and the cumulative impacts of an additional national deregulation of a GE PRSV papaya variety. For the reasons set forth below, the Center for Food Safety respectfully request APHIS to prepare an EIS to evaluate these impacts prior to deregulation.