Thursday, November 14, 2013

My Comment To The USDA In Support Of Deregulation Of The Arctic Apple

I would like to express my strong support for the deregulation of the non-browning apples developed by Okanagan Specialty Fruits, Inc.  As a consumer I would very much like to have the choice of buying apples which would maintain their appearance, taste and nutrient content longer after being cut.  As a long-term agricultural scientist I completely agree with the USDA's assessment that these apples are not any sort of plant pest. 

Since apples are not grown from seed, but rather propagated by grafting and other clonal means, any minor cross-pollination between blocks of modified and non-modified apples is functionally a non-issue.  Different varieties of apples are routinely planted side-by-side with no concerns about "contamination." 

I know that the issue of organic certification has been raised, but there is no rational reason why that should be a concern.  The precedent for the unintentional presence of unapproved pesticide residues on organic fruit is that even if it occurs it does not effect the certification of the farm in question.  If that is the logic for residues that may be consumed, then the logic should prevail for the presence a few, down-regulated genes in a small number of cells in the germ of a seed.  This is particularly true because the seed is not consumed (apple seeds are cyanogenic so it wouldn't even be a good idea to eat them if someone wanted to).

Consumers should get to decide whether they are interested in this trait.  They will have that choice because it will be marketed explicitly as an improvement via genetic engineering.  This is an optional trait, but it is a key test of whether our regulatory system and commercial channels will stick with a science-based approach or yield to activist political and brand pressure tactics.  There are other traits coming such as resistance to citrus greening which may be critical for the survival of a crop industry, and what happens with the Arctic Apple could effect the chances of that solution becoming available to farmers.

I realize that there has been some opposition to the Arctic Apple from apple industry organizations - not because of any plant pest or consumer safety concerns, but because of "brand risk."  I think the broader apple industry would do well to remember that for a long time they tried to build an "apple brand" based on an intentionally narrow group of varieties - Red Delicious being the primary standard based on color and shape more than on flavor.  When that strategy collapsed in the wake of the "Alar Scare," innovative growers branched out and began offering consumers a wide range of varieties with different appearance and flavor.  It turned out to be an extremely healthy shift that strengthened the "apple brand" among consumers.  Adding non-browning options for consumers to choose is a continuation of that successful marketing strategy.  

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