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BIO submits comments to USDA’s Animal and Plant Health Inspection Service RE: Availability of an Environmental Assessment for the Field Release of Genetically Engineered Diamondback Moths

May 19, 2017

Docket No. APHIS-2014-0056
Regulatory Analysis and Development
Plant Protection Division - APHIS
Station 3A–03.8
4700 River Road Unit 118
Riverdale, MD 20737–1238.
http://www.regulations.gov/#!docketDetail;D=APHIS-2014-0056

Re: Animal and Plant Health Inspection Service Docket No. APHIS–2014–0056; Availability of an Environmental Assessment for the Field Release of Genetically Engineered Diamondback Moths

To Whom It May Concern:

The Biotechnology Innovation Organization (BIO) appreciates this opportunity to provide comments to the United States Department of Agriculture (USDA) Animal Plant Health Inspection Service (APHIS). BIO is the world's largest biotechnology trade association, representing small and large companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of healthcare, agricultural, industrial and environmental biotechnology products. BIO represents its members in a number of matters related to agricultural biotechnology, and in particular, has a strong interest in the sound regulation of animal biotechnology. These comments by BIO address the environmental assessment for the field release of genetically engineered diamondback moths and further support BIO’s advocacy for the sound regulation of animal biotechnology.

APHIS prepared this environmental assessment (EA) in response to Cornell University’s application for a permit1 to conduct an experimental release of the genetically engineered (GE) diamondback moth (Plutella xylostella) strain OX4319L-Pxy. Pursuant to the National Environmental Policy Act of 1969 (NEPA), APHIS thoroughly assessed the potential impacts of its decision to grant or deny a permit on key resource areas: human health, the physical and biotic environments, including threatened and endangered species. BIO concurs with the factual accuracy, scientific validity and thoroughness of APHIS’s review and, therefore agrees with the scope, analysis and conclusions described in the EA...