I was dismayed to read Friday’s letter to you on GMO mosquitoes which was so full personal attacks and so scant on scientific information. I’m not sure where the writer got his facts, but on behalf of the over 50,000 concerned citizens who view our Facebook page, Never Again, each week, I’d like to set the record straight on a number of issues that the GMO mosquito salesmen have left out.

If Zika is “knocking on our door,” it’s the door of an airplane. All three of the Zika cases reported in Monroe County are from travelers. No one has gotten Zika from a mosquito here, and the cases currently under investigation are hardly a secret. They’re published daily on the Florida Health Department’s website. If we are going to allocate billions of dollars to stopping Zika in this country, we should start with health questionnaires or tests for airport travelers. Every scientific paper which has examined mosquitoes as a route of disease transmission admits that the most effective ways of stopping them are “boots on the ground.” That’s literally knocking on doors, emptying standing water containers, educating the public, and conducting small-scale pesticide spraying in hard to reach areas like storm drains.

The thousands of citizens who share and comment on our educational social media posts are not “protecting mosquitoes” nor rallying against a British invasion. They’re lending their support to legitimate concerns, not only about poor scientific methods, but also about backroom money deals between local elected officials and a for-profit corporation which go against the very foundations of our democratic process. We are people from every social class, race, religion, profession, and political party on this island. There is no coordinated effort of real estate moguls trying to stop GMO mosquitoes. The coordinated effort is from a $4B bio engineering company which makes its money by selling artificial animals created in laboratories. Perhaps we should ask Oxitec what it cost to hire one of the world’s most powerful PR companies, Hill+Knowlton, to represent them in their crusade against the people of Key West. What does their door-to-door electioneering and robocalling cost? The people of the Keys are against being test subjects. We have no budget and no agenda beyond protecting the place we live and the people we love.

So what makes GMO mosquitoes such a risk? You may remember the scene in Jurassic Park where the visitors watch a cartoon that explains how the dinosaurs were grown. One snippet of DNA was taken from a frog, another from a flower, and several random pieces were used to “fill in the missing bits.” In the movie, the scientists promised that GMO dinosaurs couldn’t reproduce or escape into the wild. Michael Crichton’s novel was written as a warning against exactly this kind of arrogant genetic engineering. Unbelievably, Oxitec has taken its “science” (bio engineering, really) right out of the Jurassic Park script.

The company created its GMO mosquito by combining artificial protein sequences from 6 different species, including fruit flies, cabbage moths, a sea coral, E. Coli bacteria, and Herpes simplex virus. The patented strand also contains a long sequence which is labeled “uncoded” in the FDA report. It’s those “missing bits” from cross-breeding the artificial life form numerous times in order to get their DNA shredding process to work out even once. This mosquito is not so much genetically modified as it is genetically engineered, grown from the ground-up out of other animals, bacteria, and a virus.

Oxitec wants to release clones of the original patented animal, but these clones will mate with wild mosquitoes and produce offspring with DNA that no one can predict. It is this “leaky” DNA that poses the greatest risk factor. The DNA manipulation is achieved by shredding gene fragments, moving them around, and reattaching them in different places. It’s not 100% successful, and when it fails (about 5% of the time), unknown combinations of DNA exist in the failed clones. These will also be released into the environment, creating another source of DNA contamination of the food chain and of human beings.

“But wait,” you say, “how can there be offspring when only males are released?” This is the biggest lie of the entire Oxitec campaign. On page 39, the FDA report states that an average of 62 females will be released per person around homes in Key Haven during the test if it is allowed to go forward. Each of these females will live long enough to take two blood meals from human beings before laying eggs. One doesn’t have to a be scientist to see that there’s no way to predict what the offspring of these GMO females and wild males will be like. Are they better carriers of disease than the wild mosquitoes that came before them? Are they more competitive and harder to kill with pesticides? Are they dangerous when they bite human beings? No one can answer these questions and no one has tried. Oxitec has simply said these are “low risk” problems.The people of Key West do not want to the be the test subjects for this human medical experiment, regardless of how Oxitec portrays these risks.

Just look at any two people before they have kids and try to predict what their children will look like — or what strengths and weaknesses they might have. You can take a guess, but no spreadsheet can hold all those variables and no scientist can tell us what anyone’s offspring will be like. The 5% of male mosquitoes who make it through with a broken “lethal” sequence (the part that’s based on Herpex simplex virus) will also reproduce with wild females and carry unknown genetic mutations forward for generations to come. There is no way to recall any of this DNA once the animals are released and begin mating.

It is an outright falsehood to claim that the FDA approved Oxitec’s product. What the FDA approved is a proposal for an investigational release. What the FDA approved is paperwork from Oxitec describing a test. The FDA did not approve the mosquitoes. The FDA never handled these mosquitoes, tested these mosquitoes, or asked anyone other than Oxitec (and us!) to test them. All of the studies submitted to the FDA are from Oxitec. Bringing up the EPA is woefully misleading when Oxitec has refused to even submit an Environmental Impact Statement to the agency, saying they “don’t need it.” The EPA has not approved these mosquitoes, either, and nor has the USDA. Offering a rubber stamp list of agency names as a form of blanket approval is a disservice to the people of Key West who deserve transparency in any public health or environmental process.

In reality, Key West is the test, not only for Florida but for all of the United States. A “successful” test here will allow Oxitec to sell hundreds of millions of GMO mosquitoes on an ongoing basis to any community in the US. What happens here affects the rest of the world, too, because many countries with less sophisticated public health standards and less transparent government than we enjoy will simply cite the Key West test as “proof” that the mosquitoes are safe.

And what exactly constitutes a successful test? Oxitec and the Mosquito District have declined to say. Here’s the official product claim from the FDA report: “OX513A males mate with local wild-type, non-GE female Aedes aegypti in a population so that the resulting progeny carry a copy of the #OX513 rDNA construct and produce at least a 2-fold increase in mortality of these #OX513 DNA construct-bearing progeny relative to local non-GE progeny before they reach functional adulthood.” This is a very long and wordy way of saying that twice as many of the offspring of GMO and wild mosquitoes should die before adulthood than would normally die without GMO parents.

There are two things to notice in this product claim. First of all, it has nothing to do with Zika or even Dengue. This is because making medical or human health claims would put this product squarely in the range of the FDA’s rules for human drug trials, which are far more stringent than the requirements for an “animal drug,” as Oxitec calls this product. Human drugs require peer-reviewed studies, independent testing with outside doctors and consenting patients, and follow-up studies to assess long term effects. Oxitec has provided none of these and can’t speak to the GMO’s mosquito’s effectiveness in combating disease without running afoul of the FDA.

Oxitec and the Mosquito District have repeatedly refused to answer direct questions about what would constitute a successful Key West (or Key Haven) test. Putting aside disease transmission, the District hasn’t even outlined the number of mosquitoes found in Key Haven now or how many it would expect to find if the test worked. Could it be that this nonsensical solution, continually releasing GMO mosquitoes to compete with wild ones in a never ending battle of genetic survival…. simply doesn’t reduce disease and is therefore useless as well as being risky and expensive?

Make no mistake, this is not a “release once and forget it” kind of product. Returning to the FDA report, we find that Oxitec plans to place artificial breeding containers with sugar water in Key Haven backyards every 70-280 feet and to tend those containers 3 times a week for 22 months while they release at least 10x as many mosquitoes into your yard as it had before. And that’s just for a test! Scaling this product to real-world use is simply impossible. If there aren’t enough employees in the District to directly attend to the places where breeding is happening now (boots on the ground), how will there be enough staff to attending to artificial breeding containers in every backyard three times a week? The Oxitec mosquito solution is no solution at all… just an ongoing competition that starts with releasing far more mosquitoes into the environment than nature created in the hopes of winding up with fewer mosquitoes during a short period in between releases. Does that make sense to you?

The concerns about tetracycline contamination raised by local doctors are certainly valid. Oxitec product manager Derric Nimmo has expressed these concerns himself. In a confidential internal memo titled Eliminating Tetracycline Contamination, Nimmo reveals that the “lethal” gene is deactivated in about 15% of the mosquitoes when they are able to find tetracycline in the wild. How does this happen? In order to rear millions of mosquitoes in the secret Marathon lab, the “lethal” gene must be switched off. This is achieved by adding tetracycline to the rearing water, allowing the GMO mosquitoes to grow to adulthood and mate.

Many common dog and cat foods are contaminated with tetracycline because it’s used in raising cheap meats for animal food. How many pet food dishes are outside in Key West? Nimmo discovered that GMO mosquitoes feeding on cat food can survive and turn off the “lethal” gene. This is the largest hole yet exposed in the leaky DNA problem of Oxitec’s artificial life form. Tetracycline is also found in hospital waste water and in sewage treatment plants, both of which are present in the Keys. The tetracycline family of antibiotics is an important treatment tool for physicians in the Keys and elsewhere.

Recent FDA regulations are requiring the phase-out of tetracycline in animal feeds because of the known risk it presents to antibiotic resistance in human beings. Yet here is Oxitec rearing an animal which is tetracycline dependent and tetracycline seeking. Any middle school student can figure out that the mosquitoes which find tetracycline (and therefore survive) will be favored by nature because they are better competitors. Oxitec’s plan requires creating a species that is dependent on tetracycline to survive — and it’s available everywhere. Mosquitoes transmit bacteria as well as viruses and GMO mosquitoes which are raised in tetracycline will therefore naturally favor and transmit bacteria which are resistant to that drug.

The GMO mosquito test proposed for Key Haven is most definitely an experiment. According to the WHO Guidance Framework for Testing of GM Mosquitoes, its an experiment on human beings. As such, it requires informed consent from volunteers. We, the people of the Florida Keys, have the right to refuse this experiment for any reason that we choose. Some say NO to bad science. Others say NO to crony politics and backroom money deals. Still others say NO, we have better alternatives. Whatever our individual reasons, we the people do not give our consent to the production or release of GMO mosquitoes in the Florida Keys. Please vote NO on the November referendum and urge your friends and neighbors to do the same.

David Bethune

Never Again