Like many relatives, vegetables within the cabbage family share a similar trait: they’re prone to invasion from pests. Cornell University is at work to address the problem, but if its current “solution” is any indication, it scientists definitely need to go back to the drawing board. The USDA has made available for comment, the environmental assessment of the field trial of the genetically engineered diamondback moth, cooked up in a lab to supposedly protect cauliflower, Brussels sprouts and their kin from pesky invaders.

Cornell will host the three-year field trial and open-air release of up to 14 million Oxitec-patented insects. You might remember Oxitec from its pending application for a field trial of genetically engineered mosquitoes in the Florida Keys. Genetically engineering any form of life is a bad idea, particularly those that can fly. It’s also bad news coming from the USDA, which has had trouble keeping tabs on accidental releases and unintended presence of plants, which do not have wings. Cornell is certainly doing its part for team GMO with recent news that it is has created the Cornell Alliance for Science with the goal of “depolarizing” the “charged debate” around GMOs.

Oxitec’s GMO diamondback moth contains the company’s patented technique for controlling survival of the insect offspring. Cornell claims that this moth will reduce the population of wild moth larvae, resulting in less damage to vegetables. Although the GE moths do reproduce, they pass on a lethal gene that theoretically causes their offspring to die before reaching adulthood. However, Oxitec’s data shows a 3 to 4 percent survival rate of mosquito offspring, with unknown impacts on the environment. And, in the presence of tetracycline, an antibiotic commonly used in agriculture, the lethal gene could not activate at all, allowing the moths to live long enough to wreak havoc in cabbage or broccoli fields.

Because the genetically engineered insects in question are considered a “plant pest,” the USDA is the regulatory agency with authority to approve the field trial and ultimately, the full commercialization of these bugs. Since the moths are under USDA’s authority alone, the EPA and the FDA are not involved in the review process, which means that environmental and human health impacts are not being adequately assessed.

Some additional issues with the USDA’s environmental assessment include:

• The environmental assessment did not look at the impacts of animal and human consumption of these GMO diamondback moths, except for one Oxitec–provided study on two insect species.Ingestion of these insects and their manipulated DNA could have unexpected health effects, which the FDA must address
• USDA did not consider the potential for long-distance dispersal of GMO moths, which means that areas outside the bounds of the trial are not assessed and will not be monitored. This could be a huge problem for nearby organic and non-GMO growers who are not permitted to use GMO organisms in their production.
• There is no indication that Cornell has a plan to ensure that crops exposed to these experimental moths will be kept out of the supply chain, or even a contingency plan to destroy all released GMO moths in the case of an emergency.
• All New Yorkers in surrounding neighborhoods, whether or not they’re farmers, must be informed about this field test and have the opportunity to voice their concerns and give consent.

There are many unanswered questions surrounding GMO diamondback moths. The USDA should exert extreme caution by performing an environmental impact assessment to answer them. In the meantime, farmers looking to protect their broccoli crops can use alternatives to insecticides that have historically proven effective, like row covers, or introducing into fields, traditional moth predators.

Take action today and tell the USDA to conduct a more thorough assessment of these genetically engineered moths to adequately examine all of their potential risks.