i

J.R. Simplot Company Petition (13-022-01p) for 

Determination of Non-Regulated Status for InnateTM 

Potatoes with Low Acrylamide Potential and Reduced 

Black Spot Bruise: Events E12 and E24 (Russet 

Burbank); F10 and F37 (Ranger Russet); J3, J55, and 

J78 (Atlantic); G11 (G); H37 and H50 (H)

OECD Unique Identifiers: SPS-00F10-7; SPS-00F37-7; 

SPS-0E12-8; SPS-00E24-2; SPS-000J3-4; SPS-00J55-2;

SPS-00J78-7; SPS-00G11-9; SPS-00H37-9; SPS-00H50-4

Draft Environmental Assessment 

March 2014

Agency Contact 

Cindy Eck

Biotechnology Regulatory Services

4700 River Road 

USDA, APHIS 

Riverdale, MD 20737 

Fax: (301) 734-8669

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of 

race, color, national origin, sex, religion, age, disability, political beliefs, sexual orientation, or marital or family status. 

(Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for 

communication of program information (Braille, large print, audiotape, etc.) should contact USDA’S TARGET Center 

at (202) 720–2600 (voice and TDD). 

To file a complaint of discrimination, write USDA, Director, Office of Civil Rights, Room 326–W, Whitten Building, 1400 

Independence Avenue, SW, Washington, DC 20250–9410 or call (202) 720–5964 (voice and TDD). USDA is an equal 

opportunity provider and employer. 

Mention of companies or commercial products in this report does not imply recommendation or endorsement by the 

U.S. Department of Agriculture over others not mentioned. USDA neither guarantees nor warrants the standard of any 

product mentioned. Product names are mentioned solely to report factually on available data and to provide specific 

information. 

This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State 

and/or Federal agencies before they can be recommended. 
TABLE OF CONTENTS PAGE

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TABLE OF CONTENTS

1 PURPOSE AND NEED.............................................................................................. 1

1.1 Background .......................................................................................................... 1

1.1 The APHIS Regulatory Authority........................................................................ 1

1.1.1 Purpose of this Product ................................................................................. 2

1.2 Coordinated Regulatory Framework for Genetically-Engineered Organisms..... 3

1.2.1 USDA-APHIS.................................................................................................... 3

1.2.1 Environmental Protection Agency................................................................ 3

1.2.2 Food and Drug Administration ..................................................................... 4

1.3 Purpose and Need for This APHIS Action........................................................... 5

1.3.1 Public Involvement ............................................................................................ 5

1.3.2 Public Involvement Approach for This EA ....................................................... 7

1.4 Issues Considered..................................................................................................... 7

2 AFFECTED ENVIRONMENT.................................................................................. 9

2.1 Agricultural Production and Agronomic Practices of Potato............................... 9

2.2.1 Land Use ............................................................................................................ 9

2.2.2 General Agronomic Practices .......................................................................... 12

2.3 Physical Environment............................................................................................. 20

2.3.1 Water Resources .............................................................................................. 20

2.3.2 Soil Quality ...................................................................................................... 22

2.3.3 Air Quality ....................................................................................................... 23

2.3.4 Climate Change................................................................................................ 24

2.4 Biological Resources.............................................................................................. 25

2.4.1 Animal Communities....................................................................................... 25

2.4.2 Plant Communities........................................................................................... 26

2.4.3 Gene Flow and Weediness............................................................................... 26

2.4.4 Microorganisms ............................................................................................... 28

2.1.1 2.2.5 Biodiversity........................................................................................ 30

2.2 30

2.2.1 2.2.6 Human Health .................................................................................... 30

2.2.7 Animal Feed..................................................................................................... 34

2.3 Socioeconomics...................................................................................................... 35

2.3.1 Domestic Economic Environment ................................................................... 36

2.3.2 Trade Economic Environment ......................................................................... 39

2.3.3 Organically Certified Economic Environment ................................................ 39

3. ALTERNATIVES......................................................................................................... 41

3.1 No Action Alternative: Continuation as a Regulated Article................................ 41
TABLE OF CONTENTS PAGE

(Continued)

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3.2 Preferred Alternative: Determination That Simplot InnateTM Potato Is No Longer a 

Regulated Article ............................................................................................... 42

3.3 Alternatives Considered But Rejected from Further Consideration ...................... 42

3.3.1 Prohibit Any Simplot InnateTM Potato from Being Released .......................... 42

3.3.2 Approve the Petition in Part............................................................................. 43

3.3.3 Isolation Distance between Simplot InnateTM Potato and Non-GE Potato 

Production and Geographical Restrictions................................................. 43

3.3.4 Requirement of Testing for Simplot InnateTM Potato ...................................... 44

3.4 Comparison of Alternatives................................................................................ 44

4 ENVIRONMENTAL CONSEQUENCES .................................................................... 50

4.1 Environmental Consequences ................................................................................ 50

4.2 Scope of Analysis................................................................................................... 50

4.3 Agricultural Production of Potato .......................................................................... 50

4.3.1 Acreage and Area of Potato Production........................................................... 50

4.2.2 Agronomic Practices........................................................................................ 51

4.2.3 Potato Seed Production .................................................................................... 52

4.2.4 Organic Potato Production............................................................................... 52

4.3 Physical Environment............................................................................................. 54

4.3.1 Water Resources .............................................................................................. 54

4.3.2 Soil Quality ...................................................................................................... 54

4.3.3 Air Quality ....................................................................................................... 55

4.3.4 Climate Change................................................................................................ 56

4.4. Biological Resources............................................................................................. 56

4.4.1 Animal Communities....................................................................................... 56

4.4.2 Plant Communities........................................................................................... 59

4.4.3 Gene Flow and Weediness............................................................................... 60

4.4.4 Microorganisms ............................................................................................... 60

4.4.5 Biodiversity...................................................................................................... 61

4.4.6 Human Health .................................................................................................. 61

4.4. 7 Animal Feed.................................................................................................... 63

4.5 Socioeconomic Impacts.......................................................................................... 64

4.5.1 Domestic Economic Environment ................................................................... 64

4.5.2 Trade Economic Environment ......................................................................... 65

5 CUMULATIVE IMPACTS...................................................................................... 66

5.1 Assumptions Used for Cumulative Impacts Analysis............................................ 66

5.2 Past and Present and Reasonably Foreseeable Actions.......................................... 67

6 THREATENED AND ENDANGERED SPECIES ................................................. 70

Potential Effects of Simplot InnateTM Potato on TES and Critical Habitat ............. 73

7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES 

RELATING TO ENVIRONMENTAL IMPACTS................................................. 77
TABLE OF CONTENTS PAGE

(Continued)

iii

7.1 Executive Orders with Domestic Implications....................................................... 77

7.3 Compliance with Clean Water Act and Clean Air Act .......................................... 81

7.4 Impacts on Unique Characteristics of Geographic Areas ...................................... 81

7.5 National Historic Preservation Act (NHPA) of 1966 as Amended........................ 82

8 REFERENCES ......................................................................................................... 83
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LIST OF FIGURES

Figure 1. Potato Growing Regions of the U.S. (USDA-NASS, 2007)......................................... 10

LIST OF TABLES

Table 1. Major Potato Production States...................................................................................... 11

Table 2.U.S. 2012 Potato Harvest by State.................................................................................. 12

Table 3. Major Insect Pests of Potato .......................................................................................... 15

Table 4. Major Diseases of Potato ............................................................................................... 16

Table 5. Major Weeds of Potato .................................................................................................. 18

Table 6. U.S. Per Capita Potato Consumption in 2012................................................................ 31

Table 7. U.S. 2012 Potato Utilization.......................................................................................... 34

Table 8. A Sample of U.S. Potato Varieties and their Uses......................................................... 36

Table 9. Summary of Issues of Potential Impacts and Consequences of Alternatives................ 45
v

ACRONYMS AND ABBREVIATIONS

AMS Agricultural Marketing Service (within USDA)

AOSCA American Organization of Seed Certifying Agencies

APHIS Animal and Plant Health Inspection Service (within USDA AMS)

BRS Biotechnology Regulatory Services (within USDA–APHIS)

CAA Clean Air Act

CBD Convention on Biological Diversity

CEQ Council on Environmental Quality

CFR Code of Federal Regulations (United States)

CH4 Methane

CO carbon monoxide

CO2 carbon dioxide

DNA deoxyribonucleic acid

EA environmental assessment

EIS environmental impact statement

EO Executive Order

EPA U.S. Environmental Protection Agency

ESA Endangered Species Act of 1973

FDA U.S. Food and Drug Administration 

FFDCA Federal Food, Drug, and Cosmetic Act

FFP food, feed, or processing

FIFRA

FONSI

FQPA

Federal Insecticide, Fungicide, and Rodenticide Act

Finding of No Significant Impact

Food Quality Protection Act

FR

FWS

Federal Register

Fish and Wildlife Service (of the U.S)

GE genetically engineered

GHG greenhouse gas
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ACRONYMS AND ABBREVIATIONS

IPPC International Plant Protection Convention

ISPM International Standard for Phytosanitary Measures

LMO

M

NGO

living modified organism

Million

non-government organization

NO2 nitrogen dioxide

N2O nitrous oxide

NAAQS National Ambient Air Quality Standards

NABI North American Biotechnology Initiative

NAPPO North American Plant Protection Organization

NEPA National Environmental Policy Act (of 1969 and subsequent amendments)

NHPA

NMFS

NOP

NPS

NRC

PIP

PM

PPA

PPM

PPRA

RNA

SSA

TES

U.S.

USDA

USDA-ERS

USDA-FAS

USDA-NASS

National Historic Preservation Act

National Marine Fisheries Service

National Organic Program (of USDA AMS)

non-point source

National Research Council

Plant-incorporated protectants

Particulate matter

Plant Protection Act

parts per million

Plant Pest Risk Assessment

ribonucleic acid

sole source aquifer

threatened and endangered species

United States

U.S. Department of Agriculture

U.S. Department of Agriculture-Economic Research Service

U.S. Department of Agriculture-Foreign Agricultural Service

U.S. Department of Agriculture-National Agricultural Statistics Service
vii

ACRONYMS AND ABBREVIATIONS

USDA-NOP

WPS

U.S. Department of Agriculture-National Organic Program

Worker Protection Standard (for agricultural pesticides)
1

1 PURPOSE AND NEED

1.1 Background 

J.R. Simplot of Boise, Idaho, submitted petition 13-022-01p to the United States Department of 

Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) in March 2013,

seeking a determination of nonregulated status for Simplot InnateTM Potato with low acrylamide 

potential and reduced black spot bruise (events E12 and E24 (Russet Burbank); F10 and F37 

(Ranger Russet); J3, J55, and J78 (Atlantic); G11 (G); and H37 and H50 (H)). The petition was 

deemed complete by APHIS on March 22, 2013. Simplot InnateTM Potato is currently regulated 

under 7 CFR part 340. Interstate movements and field trials of Simplot InnateTM Potato have 

been conducted under permits issued or notifications acknowledged by APHIS since 2009. 

These field trials were conducted in Florida, Indiana, Idaho, Michigan, Nebraska, North Dakota, 

Washington, and Wisconsin. Data resulting from these field trials are described in Simplot’s 

InnateTM Potato petition (Simplot, 2013a) and analyzed for plant pest risk in the APHIS Plant 

Pest Risk Assessment (PPRA) (USDA-APHIS, 2013a).

The petition stated that APHIS should not regulate Simplot InnateTM Potato because it does not 

present a plant pest risk. In the event of a determination of nonregulated status, the nonregulated 

status would include Simplot InnateTM Potato, any progeny derived from crosses between 

Simplot InnateTM Potato, and conventional potato, and crosses of Simplot InnateTM Potato with 

other biotechnology-derived potatoes that are no longer subject to the regulatory requirements of 

7 CFR part 340 or the plant pest provisions of the Plant Protection Act. 

1.1 The APHIS Regulatory Authority

As noted in 1.1.1, the PPA authorizes and mandates APHIS to regulate, manage and control 

plant pests. This directive includes regulatory authority over the introduction (i.e., importation, 

interstate movement, or release into the environment) of certain GE organisms and products. A 

GE organism is no longer subject to the plant pest provisions of the PPA or to the regulatory

requirements of 7 CFR part 340, when APHIS determines that it is unlikely to pose a plant pest 

risk. A GE organism is considered a regulated article if the donor organism, recipient organism, 

vector, or vector agent used in engineering the organism belongs to one of the taxa listed in the 

regulation (7 CFR 340.2) and is also considered a plant pest. A GE organism is also regulated 

under 7 CFR 340, when APHIS has reason to believe that the GE organism may be a plant pest, 

or APHIS does not have information to determine if the GE organism is unlikely to pose a plant 

pest risk.

A person may petition the agency for a determination that a particular regulated article is 

unlikely to pose a plant pest risk, and therefore, is no longer regulated under the plant pest 

provisions of the PPA or the regulations at 7 CFR 340. Under § 340.6(c)(4), the petitioner must 

provide information related to plant pest risk that the agency can use to determine whether the 

regulated article is unlikely to present a greater plant pest risk than the unmodified organism. A 

GE organism is no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

pest provisions of the PPA when APHIS determines that it is unlikely to pose a plant pest risk.
2

1.1.1 Purpose of this Product

Simplot InnateTM Potato is genetically engineered to silence genes that lead to acrylamide 

formation in cooked potatoes, and genes that cause browning in damaged potatoes. Acrylamide 

is a human neurotoxicant and potential carcinogen that may form in potatoes and other starchy 

foods under high-temperature cooking conditions. Black spot bruise is a post-harvest 

physiological disorder primarily resulting from the handling of potato tubers during harvest, 

transport and processing, and refers to the black or grayish color which may form in the interior 

of damaged potatoes. 

The 10 Simplot InnateTM Potato events were produced by using Agrobacterium-mediated 

transformation of potato internode explants of 5 different varieties: Ranger Russet, Russet 

Burbank, Atlantic, variety G and variety H (Simplot, 2013a). The binary plasmid vector 

pSIM1278 (Simplot, 2013a), consisting of the vector backbone (Simplot, 2013a) and the DNA 

insert (Simplot, 2013a) was used to create all 10 events; only the DNA insert portion was 

intended to be transferred to the recipient plants. The DNA insert in plasmid pS2IM1278 is 

designed to silence four different genes in the potato: asparagine synthetase-1 (Asn1), polyphenol 

oxidase-5 (Ppo5), potato phosphorylase L (PhL) and the starch-associated R1 gene (R1). The 

suppression of Asn1 should result in potatoes with reduced free asparagine, and the suppression 

of PhL and R1 should result in potatoes with a lower content of reducing sugars. Collectively, 

the silencing of these 3 genes should result in potato tubers with a reduced acrylamide potential. 

The suppression of Ppo5 confers the Simplot InnateTM potatoes with a non-browning phenotype 

resulting in tubers with reduced black spot bruising. Black spot bruise can lead to economic 

losses as high as 20 %(Partington et al., 1999); the potato industry therefore has a vested interest 

in minimizing these losses. Bachem et al 1994 (Bachem et al., 1994)demonstrated that black 

spot bruise can be reduced by silencing Ppo genes in potatoes, and Simplot has further developed 

this concept in the design of Simplot InnateTM potatoes (Simplot, 2013a).

The intended purpose of the 10 Simplot InnateTM potato lines is to provide the potato processing 

industry with new varieties with low acrylamide potential and reduced black spot bruise. Both of 

these changes are intended to benefit potato consumers, producers, and processors. The low 

acrylamide potential is intended to benefit consumers because of concerns about the health 

effects of ingesting acrylamide (FDA, 2013b). Simplot InnateTM potatoes offer an efficient 

method to reduce acrylamide in the diet. The reduced black spot bruise trait is intended to 

benefit consumers by providing a higher quality product, to benefit producers by reducing culls 

at delivery, and to benefit processors by reducing wastage.

Simplot InnateTM potato tubers are nutritionally and compositionally similar to their respective 

parental varieties and/or other commercial potato varieties, with the exception of the intentional 

changes conferred by the introduced genes. These intentional changes fall into three broad 

categories: (1) reduction of PPO enzyme levels in tubers; (2) alteration of the levels of 

asparagine and glutamine in the pool of free amino acids in tubers; and (3) reduction in the levels 

of the reducing sugars glucose and fructose in tubers (USDA-APHIS, 2013a).
3

1.2 Coordinated Regulatory Framework for Genetically-Engineered Organisms

The U.S. government has regulated genetically engineered (GE) organisms since 1986 under 

Federal regulations published in the Federal Register (51 FR 23302; 57 FR 22984) entitled “The 

Coordinated Framework for the Regulation of Biotechnology” (henceforth referred to here as the 

Coordinated Framework). The Coordinated Framework, published by the Office of Science and 

Technology Policy, describes the comprehensive Federal regulatory policy for ensuring the 

safety of biotechnology research and products. It also explains how Federal agencies will use 

existing Federal statutes to ensure public health and environmental safety while maintaining 

regulatory flexibility to avoid impeding the growth of the biotechnology industry. The 

Coordinated Framework is based on several important guiding principles: (1) agencies should 

define those transgenic organisms subject to review to the extent permitted by their respective 

statutory authorities; (2) agencies are required to focus on the characteristics and risks of the 

biotechnology product, not the process by which it was created; (3) agencies are mandated to 

exercise oversight of GE organisms only when there is evidence of “unreasonable” risk.

The Coordinated Framework explains the regulatory roles and authorities for the three major 

agencies involved in regulating GE organisms: USDA APHIS, the Environmental Protection 

Agency (EPA), and the Food and Drug Administration (FDA). A summary of each role follows.

1.2.1 USDA-APHIS

APHIS regulations at 7 Code of Federal Regulations (CFR) part 340, which were promulgated 

pursuant to authority granted by the Plant Protection Act (PPA), as amended (7 United States 

Code (U.S.C.) 7701–7772), regulate the introduction (importation, interstate movement, or 

release into the environment) of certain GE organisms and products. A GE organism is no 

longer subject to the plant pest provisions of the PPA or to the regulatory requirements of 7 CFR 

part 340 when APHIS determines that it is unlikely to pose a plant pest risk. A GE organism is 

considered a regulated article if the donor organism, recipient organism, vector, or vector agent 

used in engineering the organism belongs to one of the taxa listed in the regulation (7 CFR 

340.2) and is also considered a plant pest. A GE organism is also regulated under Part 340 when 

APHIS has reason to believe that the GE organism may be a plant pest or APHIS does not have 

information to determine if the GE organism is unlikely to pose a plant pest risk. 

A person may petition the agency for a determination that a particular regulated article is 

unlikely to pose a plant pest risk, and, therefore, is no longer regulated under the plant pest 

provisions of the PPA or the regulations at 7 CFR 340. Under § 340.6(c)(4), the petitioner must 

provide information related to plant pest risk that the agency may use to determine whether the 

regulated article is unlikely to present a greater plant pest risk than the unmodified organism. A 

GE organism is no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

pest provisions of the PPA when APHIS determines that it is unlikely to pose a plant pest risk.

1.2.1 Environmental Protection Agency

The EPA is responsible for regulating the sale, distribution, and use of pesticides, including those 

that are expressed by an organism modified using techniques of modern biotechnology. Such 

pesticides are regulated by EPA as plant-incorporated protectants (PIPs) under the Federal 
4

Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.). EPA also regulates 

certain biological control organisms under the Toxic Substances Control Act (15 U.S.C. 53 et 

seq.). Before planting a crop containing a PIP, a company must seek an experimental use permit 

from EPA. Commercial production of crops containing PIPs for purposes of seed increase and 

sale requires a FIFRA Section 3 registration with EPA. 

Under FIFRA (7 U.S.C. 136 et seq.), EPA requires registration of all pesticide products for all

specific uses prior to distribution for sale. Before granting a registration, EPA evaluates the 

toxicity of the ingredients of pesticide product; the particular site or crop on which it is to be 

used; the amount, frequency, and timing of its use; storage and disposal requirements. Prior to 

registration for a new use for a new or previously registered pesticide, EPA must determine 

through testing that the pesticide does not cause unreasonable adverse effects on humans, the 

environment, and non-target species, when used in accordance with label instructions. EPA must 

also approve the language used on the pesticide label in accordance with 40 CFR part 158. Once 

registered, a pesticide may only be legally used in accordance with directions and restrictions on 

its label. The purpose of the label is to provide clear directions for effective product 

performance, while minimizing risks to human health and the environment. The Food Quality

Protection Act (FQPA) of 1996 amended FIFRA, enabling EPA to implement periodic 

registration review of pesticides to ensure they are meeting current scientific and regulatory

standards of safety and continue to have no unreasonable adverse effects (US-EPA, 2011d). 

EPA also sets tolerances (maximum residue levels) or establishes an exemption from the 

requirement for a tolerance, under the Federal Food, Drug, and Cosmetic Act (FFDCA). A 

tolerance is the amount of pesticide residue that can remain on or in food for human consumption 

or animal feed. Before establishing a pesticide tolerance, EPA is required to reach a safety 

determination based on a finding of reasonable certainty of no harm under the FFDCA, as 

amended by the FQPA. FDA enforces the pesticide tolerances set by EPA. 

The ten Simplot InnateTM Potato events are not engineered to express substances to protect the 

potatoes against plant pests, and are therefore not subject to EPA review.

1.2.2 Food and Drug Administration

FDA regulates GE organisms under the authority of the FFDCA (21 U.S.C. 301 et seq.). The 

FDA published its policy statement concerning regulation of products derived from new plant 

varieties, including those derived from genetic engineering, on May 29, 1992 (57 FR 22984). 

Under this policy, FDA implements a voluntary consultation process to ensure that human food 

and animal feed safety issues or other regulatory issues, such as labeling, are resolved before 

commercial distribution of food derived from GE products. This voluntary consultation process 

provides a way for developers to receive assistance from FDA in complying with their 

obligations under Federal food safety laws prior to marketing.

In June 2006, FDA published recommendations in “Guidance for Industry: Recommendations 

for the Early Food Safety Evaluation of New Non-Pesticidal Proteins Produced by New Plant 

Varieties Intended for Food Use” (US-FDA, 2006). This establishes voluntary food safety 

evaluations for new non-pesticidal proteins produced by new plant varieties intended to be used 

as food, including GE plants. Early food safety evaluations help make sure that potential food 
5

safety issues related to a new protein in a new plant variety are addressed early in development. 

These evaluations are not intended as a replacement for a biotechnology consultation with FDA, 

but the information may be used later in the biotechnology consultation.

1.3 Purpose and Need for This APHIS Action

APHIS must respond to petitioners that request a determination of the regulated status of GE 

organisms (7 CFR 340.6), including GE plants such as Simplot InnateTM Potato. When a petition 

for nonregulated status is submitted, APHIS must determine if the GE organism is unlikely to 

pose a plant pest risk. Under § 340.6(c)(4), the petitioner is required to provide information

related to plant pest risk that the agency may use to determine whether the regulated article is 

unlikely to be a greater plant pest risk than the unmodified organism. A GE organism is no 

longer subject to the regulatory requirements of 7 CFR part 340 or the plant pest provisions of 

the PPA when APHIS determines that it is unlikely to pose a plant pest risk.

APHIS must respond to this petition from Simplot requesting a determination of nonregulated 

status for Simplot InnateTM Potato. APHIS has prepared this EA to consider the potential 

environmental effects of an agency determination of nonregulated status of Simplot InnateTM 

Potato. This action is consistent with regulations for the National Environmental Policy Act 

(NEPA) established by the Council of Environmental Quality (CEQ), and those of the USDA 

APHIS NEPA-implementing regulations and procedures (40 CFR parts 1500-1508, 7 CFR part 

1b, and 7 CFR part 372). This EA has been prepared in order to specifically evaluate the effects 

on the quality of the human environment that may result from a determination of nonregulated 

status for Simplot InnateTM Potato.

1.3.1 Public Involvement

APHIS routinely seeks public comment on EAs prepared in response to petitions seeking a 

determination of nonregulated status of a regulated GE organism. APHIS does this through a 

notice published in the Federal Register. Through a March 6, 2012, notice published1in the 

Federal Register, APHIS implemented changes to the way it solicits public comment when 

considering petitions for determinations of nonregulated status for GE organisms. The purpose 

of this change was to allow early public involvement in the process. As identified in this notice, 

APHIS publishes two separate notices in the Federal Register for petitions for which APHIS 

prepares an EA. The first notice announces the availability of the petition; the second announces

the availability of the APHIS decision-making documents. The new process allows for public 

involvement by establishing a comment period after each of the two notices published in the 

Federal Register.

First Opportunity for Public Involvement:

Once APHIS judges a petition complete, a 60-day comment period is established for the public 

to submit comments to assist the Agency in the development of it EA and PPRA. The

availability of the petition for public comment is announced in a Federal Register notice.

 

1This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf
6

Second Opportunity for Public Involvement

If an EA is determined to be sufficient, the PPRA and EA are developed, and a notice of their 

availability is published in a second Federal Register notice. This second notice follows one of 

two approaches for public participation based on whether or not APHIS determines the petition 

for nonregulated status for a GE organism involves substantive new issues: 

Approach 1. For GE organisms that do not involve substantive new issues.

This is used when APHIS determines, based on a review of the petition and its evaluation and 

analysis of public submissions received during the 60-day comment period for the petition, that 

the GE organism does not involve new biological, cultural, or ecological issues. Agency criteria 

for this decision include a determination that the nature of the modification is not novel or that 

the Agency has a high degree of familiarity with the organism through previous regulatory

actions, or both. After this determination is made, APHIS conducts the necessary analysis and 

prepares its PPRA, EA, and finding of no significant impact (FONSI). Once completed, APHIS 

publishes a notice in the Federal Register announcing its preliminary regulatory determination 

and the availability of the EA, FONSI, and PPRA for a 30-day public review and comment 

period.

Unless information received in public comments warrants substantially changing the PPRA or 

EA analysis and determination, the Agency’s preliminary regulatory determination becomes

effective. No further Federal Register notices are published announcing the final regulatory

determination. The Agency posts this public notification in an announcement on the APHIS 

website. 

Approach 2. For GE organisms involving substantive new issues not previously analyzed. This 

protocol is used when a petition is for nonregulated status for a novel GE organism. A novel 

organism is one that is not identical with or sufficiently similar to organisms determined 

previously by APHIS to have nonregulated status. Examples include organisms with new gene 

modifications that could have substantial biological, cultural, or ecological effects not previously

analyzed. For this process, APHIS prepares drafts of a PPRA and an EA, and then solicits 

further comments during a 30-day period that is announced in a Federal Register notice. APHIS 

reviews and evaluates comments and other relevant information, then revises the PPRA as 

necessary and prepares a final EA. Following preparation of these documents, APHIS approves

or denies the petition, then announces its decision in the Federal Register, and provides notice of 

the availability of the final EA, PPRA, NEPA decision document, and regulatory determination.

More details about this expansion of opportunities for stakeholder review and comment are 

available in the Federal Register notice2published on March 6, 2012.

 

2This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf
7

1.3.2 Public Involvement Approach for This EA

APHIS has determined that the protocol for preparation of this EA will follow Approach 2. The 

issues considered in this EA were developed by reviewing the public concerns, including public 

comments received in response to the Federal Register notice on May 3, 2013 (78FR 25942-

25943) announcing the availability of the petition (i.e., the first opportunity for public 

involvement previously described in this document). The Agency also considered public 

comments submitted for other EAs of GE organisms, and concerns described in lawsuits or 

expressed by various stakeholders. These issues, including those regarding the agricultural 

production of Simplot InnateTM Potato using various production methods and the environmental 

and food/feed safety of GE plants, were addressed to analyze the potential environmental 

impacts of Simplot InnateTM Potato.

The public comment period for the review of this petition for nonregulatory status of Simplot 

InnateTM Potato closed on July 2, 2013. At its closing, the docket file contained a total of 308 

public comments. These were screened and sorted into categories according to the subject 

matter addressed (e.g., air, water, soil impacts), and classified as either non-substantive or 

substantive. Most of the comments that expressed a general dislike of the use of GE organisms 

were non-substantive. One comment from a non-governmental organization (NGO) had 41,475 

signatures appended to it.

Eighty-five of the comments supported the petition, citing potential improved health benefits to 

consumers and decreased wastage of potato as economically beneficial to the potato industry.

The majority of the negative comments expressed a general dislike of the use of GE organisms. 

This issue is outside the scope of this EA. 

The issues that were raised in the public comments which were related to the Simplot InnateTM 

Potato petition included: 

 Contamination of conventional potato production.

 Concerns that more research should be done prior to approval of the petition.

 Concerns that plant fitness will be negatively affected.

 Impact that petition approval may have on export markets.

APHIS has analyzed and evaluated the issues described in these comments, and has included a 

discussion of these issues in this EA with citations where appropriate.

1.4 Issues Considered

The list of resource areas considered in this EA were developed by APHIS through experience in 

considering public concerns and issues identified from public comments submitted for this 

petition and other EAs of GE organisms. The resource areas considered also address concerns 

raised in previous and unrelated lawsuits, as well as issues that have been raised by various 

stakeholders for this petition and in the past. The resource areas considered in this EA can be 

categorized as follows: 
8

Agricultural Production Considerations:

 Land Use of Potato Production

 Agronomic/Cropping Practices

 Potato Seed Production 

 Organic Potato Production 

Environmental Considerations:

 Water Resources

 Soil

 Air Quality

 Climate Change

 Animals

 Plants

 Gene Flow

 Microorganisms

 Biological Diversity

Human Health Considerations:

 Public Health

 Worker Safety

Livestock Health Considerations:

 Livestock Health/Animal Feed

Socioeconomic Considerations:

 Domestic Economic Environment 

 Trade Economic Environment

APHIS evaluated these raised issues and the submitted documentation. APHIS has also included 

a discussion of these issues in this EA.
9

2 AFFECTED ENVIRONMENT

This section includes a review of the prevailing conditions of the human environment that might

be impacted by Simplot InnateTM Potato production. Relevant environmental components 

include agricultural production area of Simplot InnateTM Potato, the physical environmental, 

biological resources, human health, animal feed, and socioeconomic resources.

2.1 Agricultural Production and Agronomic Practices of Potato

Potato is the fourth most important crop in the world in terms of human consumption, following 

rice, wheat, and maize (corn) (Arvanitoyannis et al., 2008) (Llorente et al., 2011). Potato is 

grown in over 100 countries, with world potato production exceeding 300 million metric tons 

(Center, 2010).

2.2.1 Land Use

Potatoes are grown across most of the continental U.S., with seven States (Colorado, Idaho, 

Minnesota, North Dakota, Oregon, Washington and Wisconsin) accounting for approximately 

77% of annual production (USDA-APHIS, 2013a) (Figure 1). Within recent years, land devoted 

to potato production has shifted from the East and Midwest to the Pacific Northwest. This shift 

has resulted from a number of factors, including improvements in the U.S. transportation system, 

the relative decline in consumption of fresh potatoes coupled with advantages associated with 

processing potatoes in the Northwest such as lower taxes, and lower power and labor costs, more 

favorable weather, and available land for acreage. The largest potato-growing region by far in 

the U.S. is the Snake River Plain of southern Idaho, a major agricultural area where water is 

available for irrigation, where nearly all the Idaho crop is grown (Bechinski et al., 2001), 

(USDA-NASS, 2012c). The second-largest growing region is the Columbia Basin in 

Washington and Oregon, where approximately 137,000 acres were harvested in 2010 (USDANASS, 2012c). Other important areas (with 2010 harvested acreage in parentheses) are the Red 

River Valley, which lies between the northern borders of North Dakota and Minnesota (63,000); 

San Luis Valley in south central Colorado (55,200), Aroostook County in Maine (50,400), and 

the Central Sands region of Wisconsin (36,700) (USDA-NASS, 2012c). Simplot InnateTM Potato 

events may be grown in any of the U.S. potato-growing regions.
10

Figure 1. Potato Growing Regions of the U.S. (USDA-NASS, 2007)

Potato acres harvested in the U.S. have ranged between 1.0 and 1.5 million acres since 1951, 

with highs of 1.5 million in 1953, 1966 and 1967, and lows of 1.0 million in 2008, 2009 and 

2010 (USDA-NASS, 2012c). In most years from 1900 to 1937, more than 3 million acres were 

harvested, with a high of 3.9 million in 1922 (USDA-NASS, 2012c). While acreage has 

declined over the years, total production has increased (Guenther, 2010a). For example, in the 

1930s, from about 3.5 million acres of potatoes were harvested, whereas by 1985, production had 

nearly doubled on less than half the acreage of the 1930s, and by 2005, acreage had declined to 

about 1 million acres, less than 1/3 the 1930s acreage (Guenther, 2010a). Total annual U.S. 

production has been over 400 million CWT (one CWT = 100 pounds) every year since 1990, 

with a peak of 513,544,000 CWT in 2000 (USDA-NASS, 2012c). Per-acre yields, which 

averaged approximately 336 CWT per acre in 2012, have increased seven-fold since the early

1900s and have doubled since the early 1960s. For example, in 1901 approximately 2.95 million 

acres of potatoes were harvested, producing roughly 125 million CWT, or 46.6 CWT per acre 

(USDA-NASS, 2012c; 2013). 

The top ten potato producing states shown in Table 1 account for almost 83% of the United 

States potato crop (USDA-NASS, 2013

). Highest yields are in regions where daytime temperatures exceed 100° F during the hottest 

part of growing season, and where nights are cool (about 65° F), such as in Washington’s 

Columbia Basin, eastern Oregon, California, and Nevada (Rosen, 2010d).
11

Table 1. Major Potato Production States 

State Production (1,000 

CWT)

Percent of Total 

U.S. Production

Idaho 141,820 30.6

Washington 95,940 20.7

Wisconsin 29,440 6.4

North Dakota 25,200 5.4

Colorado 23,365 4.8

Minnesota 18,800 4.1

Michigan 15,925 3.4

Maine 15,675 3.4

California 15,501 3.3

Oregon 2,236 0.4

Source: (USDA-NASS, 2013)

Most potatoes are harvested in July through October. Fall crops have increased because of 

demand for processing (Guenther, 2010a). Harvested potatoes are either used for food (~93%), 

feed (<1%), industrial purposes (<1%) or as “seed” for planting (5%) (NPC, 2012b; USDANASS, 2013). Usage is partially dependent on a variety of characteristics related to tuber quality.

Only about one quarter of U.S. potatoes are consumed fresh (USDA-NASS, 2013), while 

approximately 60% of annual output is processed into frozen products (such as frozen fries and 

wedges), chips, dehydrated potato and starch (11%), canned potatoes (0.4%), and 6% is 

replanted as seed potato. Americans eat, on average, approximately 112 lb (51 kg) of potatoes 

per person per year (NPC, 2012b). 

Raw potato waste products (peels, out of specification raw potatoes, or other non-processed raw 

potato products) and processed discards (French fries, hash brown, etc.) are routinely

incorporated into feed rations at livestock feedlot operations (Simplot, 2013a).

U.S. 2012 potato harvests by state are summarized in Table 2 (in acres). 
12

Table 2.U.S. 2012 Potato Harvest by State 

State Acres Of Potato Harvested

Idaho 344,000

Washington 164,000

North Dakota 84,000

Wisconsin 64,000

Colorado 59,300

Maine 57,000

Minnesota 47,000

Michigan 45,500

Oregon 41,700

California 37,300

Florida 36,600

Nebraska 23,300

Texas 20,100

New York 16,500

North Carolina 16,000

Montana 11,700

Missouri 8,900

Pennsylvania 8,700

Illinois 7,400

Kansas 5,200

Virginia 4,800

Massachusetts 3,900

Arizona 3,700

Total 1,134,550

Source: (USDA-NASS, 2013)

2.2.2 General Agronomic Practices 

USDA classifies potato production by season, according to the period when the largest supplies 

are harvested. Winter, spring and summer potatoes are harvested while the vines are still green 

and the tubers comparatively immature. These potatoes go directly from the field to fresh 

markets or into processing. 

Fall potatoes are usually harvested when the vines and tubers are mature. Mature potatoes are 

usually higher in dry matter, which makes them better for most processing, and also have 

tougher skins, which makes them easier to handle (Johnson, 2010). A large percentage of the 

fall crop is stored for processing and fresh market through the winter, spring and summer 
13

months. Many modern storage facilities are equipped with temperature, humidity, and forced-air 

ventilation control. Capacity can range from 500 tons to over 20,000 tons (Olsen, 2010).

Proper water management is integral to obtaining optimum quality and yield since potatoes are 

more sensitive to water stress than some other crops. Potatoes have a relatively shallow rootzone depth, and are frequently grown on soils with only fair water-holding capacities (King and 

Stark, No Date).

The easternmost regions of the U.S. generally receive enough rainfall in order to produce good 

quality and yield of potatoes, whereas the western part of the country typically relies on some 

form of irrigation. Specific guidelines for irrigation depend on geographic region and factors 

typical of that region such as temperature, relative humidity, and daylength. Water requirements 

also vary to some degree with cultivar. Most potato-growing regions require between 18 and 36 

in. of water to produce an optimum crop. Enough moisture to keep plant stomata open during the 

hottest part of the day is critical (Shock, 2010).

In regions where rainfall is the primary source of water, growers may increase water use 

efficiency by avoiding steeply sloping fields for planting, and by preparing the soil so that 

infiltration of water is increased, and by also making ridges in the furrows to mitigate the amount 

of water running off the field (Shock, 2010).

Timing of water application and amount of water delivered are important to potato production. 

Some physical defects, such as growth cracks, hollow heart, black spot, and knobby tubers, are 

directly related to amount and distribution of water during the growing season. Excessive water 

may result in yield reduction and diseases such as Rhizoctonia stem canker, scab, and tuber late 

blight (DEFRA, 2006; Shock, 2010; King and Stark, No Date). Too little water at the time of 

tuber initiation can lead to a reduced number of tubers (DEFRA, 2006). Daily water needs 

increase from emergence of plants to approximately two weeks after row closure, but then 

decline rapidly after onset of vine maturation (DEFRA, 2006; Shock, 2010). Potatoes need more 

water during tuber initiation and early tuber development. At harvest, soil water content is also 

important to reduce mechanical damage to tubers which are frequently associated with 

dehydration such as blackspot bruise, and excess water such as shatter bruise and thumbnail 

cracking (DEFRA, 2006; King and Stark, No Date).

Potato Breeding

The tetraploid nature of commercial potato varieties is a significant impediment to potato 

breeding, as well as biological factors such as inbreeding depression, and cytoplasmic and 

nuclear sterility (Hoopes and Plaisted, 1987; Arvanitoyannis et al., 2008). Due to complex 

chromosome segregation ratios, polyploid crops are inherently more difficult to breed. 

Furthermore, vegetatively propagated crops like potato are often poor seed producers due to 

partial or full sterility. For seed propagated crops, like corn or soybean, trait developers often 

create a single elite event and then backcross that elite event into a wide range of elite 

germplasm. This is not possible in potato. Each parent variety must be independently 

transformed to achieve the desired phenotype in that variety (USDA-APHIS, 2013a). If a single 
14

variety was transformed, it could take decades to move these new traits into the other 

commercial varieties by conventional breeding, and even then, it would be difficult to 

reconstitute the desirable characteristics of the original variety (Llorente et al., 2011; USDAAPHIS, 2013a).

Because maintenance of a vegetatively propagated, disease- and insect-free genetic stock is 

difficult, much of the genetic base is kept as true seed populations (Spooner, 2010).

Cultivation 

Potatoes typically require high levels of soil cultivation (Hopkins et al., 2004), which helps with 

weed control, aeration, shaping beds, maintaining proper seed depth and establishing irrigation 

furrows (Bechinski et al., 2001; Sieczka, 2010). Potato production is generally not conducive to 

maintaining healthy soil conditions, because of intensive tillage, minimal crop residues left on 

the field, heavy field traffic and long periods of soil being left bare (Hopkins, 2010). In the 

Northwest, potato fields are typically tilled both before and after the season (Hopkins et al., 

2004). In the Red River Valley, between North Dakota and Minnesota, a common practice just 

before planting is to plow once in the fall, till two or more times during the winter, and disc the 

field in the spring (USDA, 2000). 

Cover Crops

In potato production, a fall cover crop is frequently planted in order to reduce erosion from fields 

(Sexton, 2010). Subsequent to mowing the cover crop, the residues may be left on the field to

minimize wind erosion (Rosen, 2010b). Another method of reducing erosion as well as 

mitigated disease pressure is to till green manure crops into the soil prior to planting (Hopkins et 

al., 2004). Growers in Florida use Sudan grass as a cover crop to provide nitrogen prior to 

potato planting (Mossler and Hutchinson, 2011).

Growing cover crops can also increase yield of the subsequent cash crop (University, 2013).

Crop Rotation

One of the challenges that growers face is the high short-term economic demand for potatoes to 

be grown continuously, partly because of the investment that is put into the specialized 

equipment used in potato growing, and because potatoes represent the highest potential gross 

return per acre (Hopkins et al., 2004). Continuous cropping, and short rotations of this crop 

along with others, causes potato crops to become more susceptible to complications and 

increases the risk of insect, disease, and nematode pressure, decrease in soil nutrient levels, and 

an increase in erosion potential(Hopkins et al., 2004) (Delahaut, 2000; Hall et al., 2000) (Bennett 

and O'Rourke, 2002; Larkin, 2003). Lower microbial biomass occurs in fields where continuous 

cropping is practiced, compared to fields where crops are rotated (Larkin, 2003). Therefore, 

frequent rotation of other crops with potatoes is recommended (Hopkins, 2010) (University, 

2013) in order to increase yield and to reduce insect and disease pressure, as well as to reduce the 

population density of weeds. Farmers are also advised to avoid planting potatoes near fields 

where potatoes were planted the previous year. Rotation crops vary with geographical region: 
15

for example, in Idaho, potatoes are rotated with small grains, sugar beets, alfalfa, dry beans and 

corn (Hopkins et al., 2004); with grains in the Red River Valley in North Dakota and Minnesota 

(USDA, 2000); with malting barley in the San Luis Valley in Colorado (McDonald et al., 2003); 

and corn, small grains, legumes and green manure crops in Wisconsin (Delahaut, 2000). 

Insect Control

The potato crop is intensively managed with integrated pest management (IPM) to control a 

variety of insect and disease (Johnson, 2007b). More than 150 species of insects may damage 

potatoes, most of which cause only minor economic injury. However, several species cause 

economic injury through feeding on foliage, tubers, or roots, or by transmitting disease 

pathogens to the plant. While major insect pests vary within production regions, the most 

serious overall is the Colorado potato beetle. In the eastern U.S., leafhoppers can also cause 

yield loss to plants before plants present any visual symptoms of feeding damage; several 

leafhopper species are serious problems because they vector phytoplasmas (Radcliffe, 2010). 

Aphid-transmitted diseases cause greater economic losses than all other insect damage combined 

together. At least 9 potato viruses are transmitted via aphids, the most important of which is 

potato leaf roll virus (PLRV), vectored primarily by green peach aphid, and potato Y virus 

(PVY), vectored by potato aphid, pea aphid, melon aphid, buckthorn-potato aphid, soybean 

aphid, and bird cherry-oat aphid (Radcliffe, 2010; Rondon, 2012). Occasional pests include 

armyworm, loopers, cutworms and spider mites(Rondon, 2012).

Some soil insects can cause a decrease in quality of tubers, but generally cause little decrease in 

yield. The most important of these are wireworms, the larval stage of elaterid beetles (Bechinski

et al., 2001), particularly if fields are laden with sod sometime before planting (Roberts and 

Cartwright, No Date-a).

Growers may also mitigate insect pressure by avoiding planting on fields nearby cornfields since 

European corn borer may also infest potato (University, 2013).

Insect pests in stored corn include potato tuber moth, Phthorimaea operculella, and seed corn 

maggot, Delia platura (Rondon, 2012).

Table 3. Major Insect Pests of Potato 

Common Name Scientific Name

Colorado potato beetle Leptinotarsa decemlineata

Green peach aphid Myzus persicae

Wireworms 

Limonius californicus, L. canu, 

Ctenicera pruinera

Potato leafhopper Emposasca fabae

Pea aphid Acyrthosiphon pisum

Soybean aphid Aphis glycine

Thrips Franklinella spp., Thrips spp.

Flea beetle Epitrix spp.

European cornborer Ostrinia nubilalis
16

Potato psyllid Bactericera (Paratrioza) cockerelli

Potato Tuberworm or Tuber 

Moth Phthorimaea operculella

Sources: (Radcliffe, 2010; Rondon, 2012; Roberts and Cartwright, No Date-a)

Disease Control

Potato diseases can be caused by viruses, viroids, phytoplasmas, and most importantly, by

bacteria and fungi. Infection can occur when cutting potatoes into seed pieces prior to planting, 

in which a disease organism present in the seed potato is transmitted to the resulting potato plant. 

The cut surfaces of the seed pieces, until they are suberized, are open wounds that provide a 

route of entry for pathogens (Davidson, 2010).

Potatoes can become infected with a number of viruses (e.g. potato leafroll virus, and potato 

viruses A, M, X and Y); however, IPM options for virus pests are limited to insecticidal control 

of their insect vectors and planting of resistant varieties, including some GE varieties(Arif et al., 

2012; Arif et al., 2012

; USDA-APHIS, 2013a).

There are several factors to consider in controlling potato diseases, including part of the plant 

being attacked, pathogen transmission mechanism, and environmental conditions. Table 4 lists 

the major diseases of potato. Some of these are more common while plants are in the field, while 

others only emerge during storage (Bechinski et al., 2001). Growers may plant disease-resistant 

cultivars, use certified seed, spray fungicides, and rotate potato with other crops in order to 

mitigate disease pressure (Johnson et al., 2010) (Hollingsworth, No Date). 

Table 4. Major Diseases of Potato

Common Name Scientific Name

Bacteria

Aster Yellows MLO Member of Acholeplasmataceae

Bacterial ringrot Corynebactium sepedonicum

Bacterial brown rot Ralstonia solanacearum

Bacterial soft rot Pectobacterium carotovorum

Blackleg Erwinia carotovora

Golden nematodes Globodera rostochiensis

Potato tuber rot Ditylenchus destructor

Root knot Meloidogyne spp.

Columbia root knot Meloidogyne chitwoodi

Root lesion Pratylenchus penetrans

Viruses

Potato Leafroll Virus Luteovirus
17

Potato Spindle Tuber Viroid Member of Pospiviridae

Potato Virus A,M, X, Y Members of Potyviridae, Carlavirus, 

Tobacco Rattle Virus Tobravirus

Fungi

Late blight Phytophora infestans

Pink rot Phytophthora erythroseptica

Early dying Verticillium spp.

Sclerotinia stalk rot or white 

mold Sclerotinia sclerotiorum

Canker or black scurf Rhizoctonia solani

Scab Streptomyces scabies

Dry rot Fusarium spp.

Fusarium wilt Fusarium solani var eumartii, 

Fusarium oxysporum

Water or shell rot Pythium ultimum

Early blight Alternaria solani

Gray mold Botrytis cinerea

Black dot Colletotrichum coccodes

Ring rot Clavibacter michiganensis subsp.

Sepedonicus

Powdery scab Spongospora subterranea

Silver scurf Helminthosporium solani

Wart Synchytrium endobioticum

Nematodes

Golden nematodes Globodera rostochiensis

Potato tuber rot Ditylenchus destructor

Root knot Meloidogyne spp.

Columbia root knot Meloidogyne chitwoodi

Root lesion Pratylenchus penetrans

Sources: (Johnson et al., 2010; Roberts and Cartwright, No Date-a)

Weed Management

Weeds pose a management issue for growers, potentially causing a significant loss in yield by

outcompeting potatoes for nutrients, water and sunlight. Tillage and herbicide usage can help 

control weeds (Delahaut, 2000); (Hutchinson, 2010), although tillage can also damage potato 

plants and reduce yields. Common weeds in potato fields fall into three main classes: annual 

broadleaf plants, which are the easiest to control, with the exception of nightshade; annual 

grasses, which may germinate later than most broadleaf annuals; and perennials, which are the 

most difficult to control (Hutchinson, 2010; University, 2013). Major weed species in potato 
18

fields are noted in Table 5. In addition to competition with potato plants for resources, weeds are 

detrimental to the crop due to potential penetration of potato tubers by weed roots, causing a 

severe reduction in crop quality (Hutchinson, 2010).

Table 5. Major Weeds of Potato 

Broadleaf Annuals Annual Grasses Perennials

Hairy nightshade (Solanum 

sarrachoides)

Common lambsquarters 

(Chenopodium album)

Redroot pigweed (Amaranthus 

retroflexus)

Ragweed (Ambrosia artemisiifolia)

Kochia (Kochia scoparia)

Pennsylvania smartweed 

(Polygonum pennsylvanicum)

Barnyardgrass (Echinochloa crusgalli)

Foxtail (Setaria spp.)

Wild oat (Avena fatua)

Fall panicum (Panicum 

dichotomiflorum)

Nutsedges (Cyperus spp.)

Quackgrass (Elytrigia repens)

Canada thistle (Cirsium arvense)

Source: (Hutchinson, 2010)

In order to mitigate weed problems, growers should avoid planting potatoes on fields with heavy 

infestations of weeds. Most growers also scout their fields to assess the need for herbicides, and 

choose rotational crops that compete successfully with weeds (Bechinski et al., 2001). 

Commonly used herbicides are metribuzin, EPTC, and metolochlor (Bechinski et al., 2001), 

(USDA, 2000) (McDonald et al., 2003). Growers may also rotate herbicide use according to 

chemical class in order to avoid or delay the development of weed resistance (Bechinski et al., 

2001).

Volunteer Potatoes

Volunteer potatoes are tubers that are left in fields after a harvest, which compete with rotational 

crops for sunlight, water, and essential nutrients, and then compete with a subsequent potato 

crop. In addition to becoming weeds, volunteer potatoes can also be hosts for disease such as late 

blight, potato leaf roll, and virus Y(Eberlein et al., 1998; Boydston and Williams, 2005). Several 

herbicides can be used for the control of volunteer potato plants ((Boydston and Williams, 2005); 

(Everman and Long, 2010). Other control measures may include post-harvest grazing and 

rotation to crops competitive with the volunteers (Eberlein et al., 1998). 

In general, potato is a poor colonizer in wild ecosystems. Outside agricultural fields, volunteer 

potato seedlings cannot compete well with other plants, and, therefore, are unlikely to establish 

themselves. During transportation and processing, there is a possibility of tubers being released, 

but again, there is little probability of successful establishment (OECD, 1997b). 

Organic Potatoes

To bear a certified organic label, farms grossing more than $5,000/year in revenues must be 

certified by a USDA National Organic Program (NOP) accredited certifying agency. . 
19

Certifying agencies also have specific cultural requirements with regard to field selection (e.g., 

fields cannot have been treated with prohibited chemicals for 3 years before harvest of a certified 

organic crop, and there must be sufficient buffer zones between certified organic crops and 

conventionally grown crops in order to reduce potential contamination between the two such as 

via pollination) (University, 2013). There are other requirements and recommended practices for 

organic potato production see, e.g., (Moore and Olsen, No Date) for organic potato production in 

Idaho, and (Hollingsworth, No Date) for organic potato production in California.

In terms of US organic potato production, measured in cwt/year, the leading states are 

Washington (>600,000), Colorado (>500,000), California (>400,000), Oregon (>300,000), Idaho

(>200,000), and much lesser amounts from Maine (>25,000), Wisconsin (>23,000), Ohio 

(>17,000), and Vermont (>7,000) (reference from Omar). In terms of sales/year, the leading 

states are California (>$10 million), Colorado (>$6 million), Washington (>$4 million), Oregon 

(>$3 million), and Idaho and Maine (each state, >$1 million) (USDA-NASS, 2008). As 

discussed in Section 2.3.1, Domestic Economic Environment, organic potatoes command a 

premium price compared to conventionally grown potatoes.

Potato Seed Production

Potatoes are vegetatively propagated by planting tubers or seed pieces (Davidson, 2010) (NSF, 

2011). In 2012, approximately 6 percent of the 2012 annual potato crop was used as seed (NPC, 

2012a) in the form of seed potatoes. Certified seed potatoes are produced to ensure genetic 

purity and to reduce disease introduction (NPC, 2012a). Most seed that is sold is labeled certified 

seed (USDA, 2000), which means that certification agency requirements must be met. These 

requirements include inspections of fields, storage facilities, and shipping points in order to 

evaluate whether disease incidence exceeds established thresholds (Moore and Olsen, No Date).

There are 16 potato seed certification agencies in the U.S., including one in each major 

production state (NPC, 2012a). Typically, seed potatoes are grown in the same areas where 

potatoes for commercial production are grown, although the areas of maximum seed production 

sometimes differ from the areas of maximum tuber production. Major seed production states in 

2012 in order of decreasing production were Idaho (>35,000 acres harvested), North Dakota, 

Colorado, Maine, Wisconsin and Minnesota (>7,000 acres harvested)(USDA-NASS, 2013). 

The use of good quality seed potatoes is important to successful potato culture. It is 

recommended that seed size be ideally about two to four ounces, about the size of a golf ball

(Hollingsworth, No Date).

Potato Processing and Storage

About 60% of potatoes are processed into frozen commodities such as French fries and 

shoestring potatoes and dehydrated. Typically, frozen and dehydration industries are 

concentrated in the Northeast, upper Midwest, and Pacific Northwest. Potato chip processers 

tend to be more evenly distributed throughout the country because chips are fragile, and longdistance shipping is expensive. Therefore, chipping plants tend to be located near heavily 

populated areas (Guenther, 2010b).
20

Long-term storage is needed for processing operations. Capacities of storage facilities typically 

range from 500 to >20,000 tons. Most of the tubers are kept in bulk piles, but some facilities use 

box storage. In northern production areas, a large percentage of the potato crop is stored for 

processing and fresh market uses during the winter, spring, and summer months. Storage 

facilities are frequently equipped with ventilation systems and systems to monitor temperature, 

relative humidity and carbon dioxide levels. Some storage facilities are refrigerated to cool 

stored potatoes during warmer spring and summer months(Olsen, 2010). Potatoes kept stored for 

> 130 days have a tendency to sprout, and are therefore chemically treated to prevent sprout 

formation (Kleinkopf, 2010). Prolonged storage can also lead to lowered tuber quality from

moisture loss, which can cause tuber surface wrinkling (Arvanitoyannis et al., 2008).

2.3 Physical Environment

2.3.1 Water Resources

The principal law governing pollution of the nation’s water resources is the Federal Water 

Pollution Control Act of 1972, better known as the Clean Water Act (CWA). The Act utilizes 

water quality standards, permitting requirements, and monitoring to protect water quality. The 

EPA sets the standards for water pollution abatement for all waters of the U.S. under the 

programs contained in the CWA, but, in most cases, gives qualified states the authority to issue 

and enforce permits. Drinking water is protected under the Safe Drinking Water Act of 1974 

(Public Law 93-523, 42 U.S.C. 300 et seq.). 

Surface water in rivers, streams, creeks, lakes, and reservoirs supports everyday life through the 

provision of water for drinking and other public uses, irrigation, and industry. Surface runoff 

from rain, snowmelt, or irrigation water can affect surface water quality by depositing sediment, 

minerals, or contaminants into surface water bodies. Surface runoff is influenced by 

meteorological factors such as rainfall intensity and duration, and physical factors such as 

vegetation, soil type, and topography. Agricultural production, including potatoes, can adversely 

impact surface water quality, primarily through sedimentation from erosion and nutrient loading 

from fertilizers ((US-EPA, 2005b) (US-EPA, 2009a). Nitrogen loss in the form of ammonium 

and nitrates to surface water can occur as a result of direct runoff, or by infiltration through the 

root zone, and discharge to surface water by drainage or seepage (Zebarth et al., 1999).

Groundwater is the water that flows underground and is stored in natural geologic formations 

called aquifers. It sustains ecosystems by releasing a constant supply of water into wetlands and 

contributes a sizeable amount of flow to permanent streams and rivers. Based on 2005 data, the 

largest use of groundwater in the U.S. is irrigation, representing approximately 67.2% of all the 

groundwater pumped each day (McCray, 2009a; McCray, 2009b). In the U.S., approximately

47% of the population depends on groundwater for its drinking water supply. The EPA defines a 

sole source aquifer (SSA) as an aquifer that supplies at least 50% of the drinking water 

consumed in the area overlying the aquifer. An SSA designation is one tool to protect drinking 

water supplies in areas where there are few or no alternative sources to the groundwater resource. 

There are 77 designated SSAs in the U.S. and its territories (US-EPA, 2011e). Crop production 

has the potential to impact groundwater in areas with shallow (less than approximately 15 feet 

deep) water tables through leaching of the nitrates from fertilizers (Nolan et al., 2002; DEFRA, 
21

2006). Agricultural production leads to nitrate contamination of groundwater through leaching 

associated with high applications of manure or fertilizers or excessive irrigation (Zebarth et al., 

1999) (DEFRA, 2006)

Unlike a point source which is a “discernible, confined and discrete conveyance”, nonpoint 

source (NPS) pollution comes from many diffuse sources. Rainfall or snowmelt moving over the 

ground, also known as runoff, picks up and carries away natural and human-made pollutants, 

creating NPS. The pollutants may eventually be transported by runoff into lakes, rivers, 

wetlands, coastal waters and ground waters. Agricultural NPS pollution includes animal wastes, 

fertilizers, and pesticides. Surface water may be contaminated by agricultural sediments 

transported by erosion that may also include pesticides, fertilizers, and sometimes fuel and 

pathogens. Agricultural practices that introduce contaminants into the groundwater include 

fertilizer and pesticide application, spilled oil and gasoline from farm equipment, nitrates, and 

pathogens from animal manure.

NPS pollution is the leading source of water quality impacts on rivers and lakes, the second 

largest source of impairments to wetlands, and a major contributor to groundwater contamination 

(US-EPA, 2005a; 2005b). Management practices that contribute to NPS pollution include the 

type of crop cultivated, plowing and tillage, and the application of pesticides, herbicides, and 

fertilizers. The primary cause of NPS pollution is increased sedimentation in surface waters 

following soil erosion (US-EPA, 2005a; 2005b). The major contribution to groundwater 

contamination derives from agricultural areas (nitrogen inputs from fertilizer and manure

drainage and leaching from root-zone areas due to over-irrigation; and salts in the form of 

carbonates, sulfates, and chlorides, from drainage) and is influenced by regional environmental 

factors such as precipitation and soil characteristics (Skaggs et al., 1993; US-EPA, 2003; King 

and Stark, No Date). Nutrients applied in excess of recommended application rates are listed as 

the second cause of impairment in lakes, reservoirs, and ponds, with agriculture listed as the third 

most probable source of the impairment (US-EPA, 2012b).

Agricultural pollutants released by soil erosion include sediments, fertilizers, and pesticides that 

are introduced to area lakes and streams when they are carried off of fields by rain or irrigation 

waters (US-EPA, 2005a; 2005b). Increase in sediment loads to surface waters can directly affect 

fish, aquatic invertebrates, and other wildlife maintenance and survival. It also reduces the 

amount of light penetration in water which directly affects aquatic plants. Indirectly, soil erosionmediated sedimentation can increase fertilizer runoff, thereby increasing nutrient loading and 

facilitating higher water turbidity, algal blooms, and oxygen depletion (Skaggs et al., 1993; USEPA, 2005a; 2005b). Over-fertilization should be avoided to prevent nutrient leaching into 

groundwater, risk of ground water pollution with nitrates, and risk of estuary pollution from 

nitrates and phosphates (Carroll and Robinson, 2006). Preservation and conservation of water 

and soil resources must be maximized and non-point-source pollution must be minimized 

(Carroll and Robinson, 2006).
22

Most of the potatoes produced in the U.S. are grown under irrigation, including potatoes grown 

in Idaho, Washington, Oregon, California, and Wisconsin, whereas rainfall provides adequate 

moisture for potato crops in the eastern U.S. (Shock, 2010) (King and Stark, No Date). Potato 

yield can be reduced by both under- and over-irrigating (King and Stark, No Date). Potato 

processing can contribute to eutrophication of water (DEFRA, 2006). 

2.3.2 Soil Quality

Soil consists of solids (minerals and organic matter), liquids, and gases. This body of inorganic 

and organic matter is home to a wide variety of fungi, bacteria, and arthropods, as well as the 

growth medium for terrestrial plant life (USDA-NRCS, 2004a; 2004b). Soil is characterized by

its layers that can be distinguished from the initial parent material due to additions, losses, 

transfers, and transformations of energy and matter (USDA-NRCS, 1999b; 1999a). It is further 

distinguished by its ability to support rooted plants in a natural environment. Soil plays a key

role in determining the capacity of a site for biomass vigor and production in terms of physical 

support, air, water, temperature moderation, protection from toxins, and nutrient availability. 

Soils also determine a site’s susceptibility to erosion by wind and water, and flood attenuation 

capacity.

Soil properties change over time; temperature, pH, soluble salts, amount of organic matter, the 

carbon-nitrogen ratio, numbers of microorganisms and soil fauna all vary seasonally, as well as 

over extended periods of time (USDA-NRCS, 1999b; 1999a). Soil texture and organic matter 

levels directly influence its shear strength, nutrient holding capacity, and permeability. Soil 

taxonomy was established to classify soils according to the relationship between soils and the 

factors responsible for their character (USDA-NRCS, 1999b; 1999a). Soils are organized into 

four levels of classification, the highest being the soil order. Soils are differentiated based on 

characteristics such as particle size, texture, and color, and classified taxonomically into soil 

orders based on observable properties such as organic matter content and degree of soil profile 

development (USDA-NRCS, 2010). The Natural Resources Conservation Service (NRCS) 

maintains soil maps on a county level for the entire U.S. and its territories.

There are a multitude of organisms associated with soils, ranging from microorganisms to larger 

organisms, such as worms and insects. The microbial populations of the soil encompass an 

enormous diversity of bacteria, algae, fungi, protozoa, viruses, and actinomycetes (filamentous 

bacteria) (Doran et al., 1996a; Doran et al., 1996b).The extent of the diversity of microorganisms 

in soil is seen to be critical to the maintenance of soil health and quality. Microorganisms in soil 

are critical to the maintenance of soil function in both natural and managed agricultural soils 

because of their involvement in such key processes as soil structure formation; decomposition of 

organic matter; toxin removal; and the cycling of carbon, nitrogen, phosphorus, and sulfur

(Bruinsma et al., 2003). In addition, certain microbial organisms may contribute to the 

protection of the root system against soil pathogens (Garbeva et al., 2004a; Garbeva et al., 

2004b).

Potatoes grow well in a wide range of soils. Optimum soils are deep, loose, and drain well 

(Rosen, 2010c). Poorly drained soils tend to yield poorly shaped tubers and tubers which are 
23

susceptible to diseases like tuber rot (Johnson and Sideman, 2006) (Plissey and Erhardt, 2000). 

Sandy soils can also produce high-quality potatoes, but these soils are more susceptible to wind 

erosion (Rosen, 2010b). The ability of soils to retain water is important because the drier soil 

becomes, the more difficult it is for the crop to pull water from it, and is dependent on soil 

texture and structure (DEFRA, 2006). Maintaining organic matter in soil is advisable because it 

keeps the soil loose and well-aerated, which in turn, leads to better penetration of root structures, 

and development of tubers, but is a problem in almost all regions where potatoes are grown 

except for those areas where soils contain muck and peat (Rosen, 2010a). The recommended pH 

for soils is slightly acidic, which helps reduce incidence of diseases such as scab (Plissey and 

Erhardt, 2000) (Johnson and Sideman, 2006).

Maintaining adequate soil conditions in potato fields may be difficult due to crop tillage, low 

crop residues on soil surfaces, and foot traffic from agricultural workers, which can lead to 

higher erosion rates. Erosion mitigation strategies include growing a cover crop and utilizing the 

subsequent crop plant residues (Hopkins et al., 2004). Where potatoes are grown in fields with 

stones such as in Maine, removal of stones may ease movement of mechanical harvesters, but 

may also negatively affect tuber yield (Saini and Grant, 1980). Soil compaction can occur with 

excessive tillage (Roberts and Cartwright, No Date-b), continuous cropping, and the use of large 

agricultural machines and increased pesticide spraying operations. As the number of machinery

passes through the fields increases, soil compaction increases, and oxygen diffusion rate to roots 

decreases, which in turn may lead to a reduction in tuber size and increased soil erosion(Saini 

and Grant, 1980). Compacted soil also reduces the ability of roots to find water in soil (DEFRA, 

2006).

2.3.3 Air Quality

The Clean Air Act (CAA) requires the maintenance of National Ambient Air Quality Standards 

(NAAQS). The NAAQS, developed by the EPA to protect public health, establish limits for six 

criteria pollutants: ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide 

(SO2), lead (Pb), and inhalable particulates (coarse particulate matter [PM] greater than 2.5 

micrometers and less than 10 micrometers in diameter [PM10] and fine particles less than 2.5 

micrometers in diameter [PM2.5]). The CAA requires states to achieve and maintain the NAAQS 

within their jurisdiction. Each state may adopt requirements stricter than those of the national 

standard and each is also required by EPA to prepare a State Implementation Plan (SIP) 

containing strategies to achieve and maintain the national standard of air quality within the state. 

Areas that violate air quality standards are designated as non-attainment areas for the criteria 

pollutant(s), whereas areas that comply with air quality standards are designated as attainment 

areas. Non-attainment areas are typically associated with large metropolitan areas with many 

mobile (e.g., vehicle) and stationary (e.g., power plants and factories) sources. Other than 

emissions from mobile sources, crop farming emission sources are not specifically regulated 

nationwide under the CAA. The degree to which emissions from farming practices (such as 

prescribed burning) are allowed are location-specific within each State Implementation Plan 

(US-EPA, 2011f). Regulation of agricultural sources within a State Implementation Plan does 

not appear to be typical. For example, based on a review of the available plans in Idaho, 
24

achievement of air quality standards is focused on managing residential wood burning, vehicle 

emissions, and facilities such as factories and processing plants (US-EPA, 2011a). 

Agricultural production may produce air emissions such as fugitive dust from the disturbance of 

bare soil from farming activities or wind, vehicle emissions, and emissions associated with 

fertilizer and pesticide applications. In some agricultural areas, prescribed burning is practiced 

and results in higher air emissions levels (US-EPA, 2011f). Ammonia may be lost to the 

atmosphere via inorganic nitrogenous fertilizers, but occurs mostly from livestock production 

processes such as manure storage and application. Atmospheric ammonia can then contribute to 

the eutrophication of surface water and acidification of soil and water (Zebarth et al., 1999)

The US EPA regulates mobile source emissions by reformulated gasoline and automobile 

pollution control devices (US-EPA, 2011f). Stricter requirements, such as vapor recovery

nozzles on gas pumps, may apply in non-attainment areas.

2.3.4 Climate Change

Climate change represents a statistical change in global climate conditions, including shifts in the 

frequency of extreme weather. Agriculture is recognized as a direct (e.g., exhaust from 

equipment) and indirect (e.g., agricultural-related soil disturbance) source of greenhouse gas 

(GHG) emissions. The EPA has identified carbon dioxide (CO2), methane (CH4), and nitrous 

oxide (N2O) as the most important GHGs contributing to climate change. While each of these 

gases occurs naturally in the atmosphere, human activity has significantly increased the 

concentration of these gases since the beginning of the industrial revolution. The level of human 

produced gases accelerated even more so after the end of the Second World War, when industrial 

and consumer consumption expanded greatly. With the advent of the industrial age, there has 

been a 36% increase in the concentration of CO2, 148 % in CH4, and 18 % in N2O (US-EPA, 

2012a)

Greenhouse gases vary in their global warming potential (GWP), and the US EPA converts all 

gases to carbon dioxide (CO2) equivalents. For the three greenhouse gases most associated with 

agriculture, GWPs are as follows: CO2 = 1, methane (CH4) = 21, and nitrous oxide (N2O) = 310 

(US-EPA, 2012a). The US EPA classifies different sources by sector, with the energy sector 

being the largest contributor of greenhouse gas emissions (US-EPA, 2012a). The agriculture 

sector, as defined by US EPA, represented 6.3 percent of total greenhouse gas emissions for the 

U.S. in 2010(US-EPA, 2012a). However, this does not include CO2 emissions and removals 

from agricultural-related land use activities such as liming of agricultural soils (which are 

included in the land use sector) and it does not include emissions of CO2 and N2O from diesel or 

gasoline-powered agricultural equipment (which are included in the energy sector). The primary

greenhouse gases contributed by the agriculture sector as defined by US EPA are N2O and CH4. 

The relative percent contribution to total CO2 equivalent emissions of the various agricultural 

sources in 2010 was as follows: agricultural soil management (fertilizer application and other 

cropping practices that contribute N2O), 49 percent; enteric fermentation (primarily methane 

emissions from cattle), 33 percent; manure management, 16 percent; and rice cultivation, two 

percent. Most of the climate change potential from potato production is derived from 

transportation, packing and processing of potatoes. Emissions from field burning of agricultural 

residues, the remaining category, were less than 0.1 percent of the total (DEFRA, 2006; USEPA, 2012a).
25

2.4 Biological Resources

This section provides a summary of the biological environment and includes an overview of 

animals, plants, microorganisms, and biodiversity associated with potato production. This 

summary provides the foundation to assess the potential impact to plant and animal communities.

2.4.1 Animal Communities

Animal communities in this discussion include wildlife species and their habitats. Wildlife refers 

to both native and introduced species of mammals, birds, amphibians, reptiles, invertebrates, and 

fish or shellfish. Agriculture dominates human uses of land (Robertson and Swinton, 2005). In 

2011, 917 million acres (approximately 47%) of the contiguous 48 states were devoted to 

farming, including crop production, pasture, rangeland, and Conservation Reserve Program areas

(USDA-NASS, 2012b). How these lands are maintained influences the function and integrity of 

ecosystems and the wildlife populations that they support.

A wide array of wildlife species occur within the major potato-producing U.S. states and could 

possibly be found in potato fields at least intermittently. There are reports of wildlife feeding on 

foliage of potato, but reports of damage resulting in economic loss are uncommon. This is not 

surprising considering that the foliage and stems of potato contain toxic glycoalkaloids known to 

cause illness when consumed (Sinden, 1987a). In 1992, APHIS Wildlife Services conducted 

formal appraisals of wildlife damage on 490 acres of potatoes in Wisconsin and did not report 

any damage or economic loss(USDA-APHIS, 2013d). However, white tailed deer have been 

reported to damage potatoes in some areas (Marinette County, 2014) and it is well known that 

wild boar and voles will feed on tubers (O'Brien, 2005; Taylor, 2014) (Taylor, 2014). USDAAPHIS Wildlife Services has also received complaints for damage caused by sandhill cranes

(USDA-APHIS, 2013d). 

There are numerous insects found in and around potato fields. Some insects and other 

invertebrates can be beneficial to potato production, providing services such as nutrient cycling 

and preying on plant pests. As discussed in Section 2.2.6, Insect Control, many insects and 

invertebrates are detrimental to potato crops, including: Colorado potato beetle (Leptinotarsa 

decemlineata), various aphid species including the green peach aphid (Myzus persicae), 

wireworms (Limonius californicus, L. canus, Ctenicera pruinina), flea beetles (Epitrix sp.), 

European corn borer (Ostrinia nubilalis), potato psyllid (Bactericera (Paratrioza) cockerelli), 

tuberworm (Phthorimaea operculella), and the potato leafhopper (Emposasca fabae) (Johnson, 

2007a; Simplot, 2013a). Nematodes can also be found in potatoes such as the root knot 

nematodes (Meloidogyne spp. ), and cyst nematodes (Globodera pallida) and (G. rostochiensis) 

(Hardy, 1996). The potato crop is intensively managed with integrated pest management (IPM)

practices to control these insects, nematodes, and several disease pathogens that include fungi, 

bacteria and viruses(Johnson, 2007b) and to enhance potato yield. As a result, pesticides, 

including insecticides, nematicides, and fungicides, are generally part of an IPM strategy to keep 

losses below economic threshholds (US-EPA, 2000), (Senseman, 2007). Conventional broadspectrum insecticides are potentially toxic to invertebrates and vertebrates. The US-EPA 

requires application control measures for certain Restricted Use insecticides to limit human and 

environmental exposure. These impacts can affect animal communities, with those communities 
26

within and in close proximity to potato fields experiencing the greatest impact (US-EPA, 

2000),(US-EPA, 2009b). 

2.4.2 Plant Communities

The landscape surrounding a potato field may be bordered by other potato fields, other crops, or 

may be surrounded by forest, grassland, bodies of water, or built-up areas. As discussed in 

Section 2.2, most commercial potatoes are grown in large agricultural areas, such as the Snake 

River Valley in Idaho. Thus, other crops would most frequently make up the surrounding 

vegetation, although some fields would be bordered by non-crop vegetation. Growers may

provide buffer zones to reduce or prevent impact to adjacent vegetation. Because potatoes are 

grown throughout much of the U.S., a wide variety of plants may be found adjacent to the 

agricultural fields. These plants have the potential to be impacted by agricultural practices, 

including the use of pesticides, which are regulated by US EPA. Aquatic plant communities near 

agricultural fields may be affected by sedimentation resulting from erosion, or by nutrients 

leached from fertilizers. 

Plants which compete with potato in crop fields are generally regarded as weeds, and are 

discussed in Section 2.2.8, Weed Management. Native or wild plant species related to cultivated 

potatoes are of interest because of the potential for interbreeding through gene flow. By

definition, interbreeding between species that result in viable offspring is not common, otherwise 

the two plants would not be classified as different species. Interbreeding can occur to a limited 

extent between some species under some circumstances. Among the many factors that must be 

present for hybridization to occur between two species are: 1) the species must occur in the same 

area and habitat, 2) the flowering periods of the species involved must overlap, and 3) 

appropriate pollinators must be present (OECD, 1997b). Section 2.4.3, Gene Flow and 

Weediness discusses this subject.

Threatened and Endangered Species

There are currently three plants in the genus Solanum on the U.S. Fish and Wildlife Service (US 

FWS) list of threatened or endangered plant species: Erubia (S. drymophilum), found only in 

Puerto Rico; and popolo ku mai (S. incompletum) and Aiakeakua popolo (S. sandwicense), both 

found only in Hawaii (FWS, 2011) p. 47). Based on the evaluation of wild potatoes presented 

above, these species would not interbreed with cultivated potatoes; additionally, potatoes are not 

commercially grown in these areas. 

2.4.3 Gene Flow and Weediness

Gene flow is a biological process that facilitates the production of hybrid plants, introgression of 

novel alleles (i.e., versions of a gene) into a population, and evolution of new plant genotypes. 

Gene flow to and from an agro-ecosystem can occur on both spatial and temporal scales. In 

general, plant pollen tends to represent the major reproductive method for transmission across 

geographic areas, while both seed and vegetative propagation tend to promote the movement of 

genes temporally and spatially. 
27

The rate and success of gene flow is dependent on numerous external factors in addition to the 

donor/recipient plant. General external factors related to pollen-mediated gene flow include the 

presence/abundance/distance of sexually-compatible plant species; overlap of flowering 

phenology between populations; the method of pollination; the biology and amount of pollen 

produced; weather conditions, including temperature, wind, and humidity (Zapiola et al., 2008). 

Seed-mediated gene flow also depends on many factors, including the 

absence/presence/magnitude of seed dormancy; contribution and participation in various 

dispersal pathways; environmental conditions and events.

Volunteer potatoes arise from overwintered tubers, and can be a weed problem in the following 

crop. Potatoes have a fairly low frost tolerance, and tubers planted too shallowly are subject to 

loss by frost. In temperate climates up to 20% of tubers left in the soil show no dormancy and 

will sprout the next season (Andersson and de Vicente, 2010). However, volunteer potatoes can 

be easily controlled with cultivation and herbicides and do not persist as weeds for more than one 

or a few years (Andersson and de Vicente, 2010). In general, potato has a low propensity for 

weediness or persistence and is incapable of survival outside of agricultural production (OECD, 

1997b) (Holm and Pancho, 1979) (Muenscher, 1980a) (Love, 1994b). 

Gene flow by hybridization is not possible for some potato cultivars such as the Russet Burbank, 

the most commonly grown potato, because they are sterile(NSF, 2011), (PAA, 2009a) (Simplot, 

2013a). Pollination of potato is mostly by insects such as such as bumblebees (Bombus

impatiens) (OECD, 1997b), which have a relatively short flight range, and, therefore, pollen 

dispersal is limited. Because potato flowers have little nectar, the honey bee (Apis mellifera) is 

not attracted to them, and wind plays an insignificant role in pollination (OECD, 1997b). 

Empirical field testing of outcrossing distances in potato show that separations of 20 meters or 

more are sufficient to prevent outcrossing (Conner and Dale, 1996). 

Of the fertile varieties, which include Ranger Russet, Atlantic and “G”, about 80 to 100 percent 

of true seed produced is derived from self-pollination (Hoopes and Plaisted, 1987). A potential 

source of volunteers is true potato seed (TPS). TPS is seed produced via pollination, which 

develops inside small fruiting bodies formed on the potato vine. Its major disadvantage is that it 

segregates for numerous traits because potato is highly heterozygous, and plants arising from 

TPS typically take longer to establish and set tubers, resulting in lower yield than from seed 

potatoes (Simplot, 2013a) (Pallais, 1987). Of the five parent varieties used to develop the 10 

Simplot InnateTM Potato events, Russet Burbank and “H” are fully sterile, precluding any

possibility of TPS production. However, the Simplot InnateTM Potato events derived from 

Ranger Russet, Atlantic and “G” are fertile and may produce TPS. But plants produced from 

TPS are no weedier than volunteer plants produced from over-wintered tubers and are relatively 

easy to control in rotational crops.

Potato (Solanum tuberosum) belongs to the Solanaceae plant family, along with other cultivated 

crop plants such as tomato (Solanum lycopersicon), eggplant (Solanum melogena), tobacco 

(Nicotiana tabacum), and pepper (Capsicum annuum) (OECD, 1997b). S. tuberosum is divided 

into two subspecies: tuberosum and andigena. The subspecies Solanum andigena is also a 

cultivated species, but its cultivation is restricted to Central and South America (OECD, 1997b). 

While there appears to be minimal, if any, overlap geographically between cultivated and wild 

potatoes in the U.S., there is a possibility that a few wild potato plants may be growing near 
28

potato fields (Love, 1994b). However, the potential for hybridization between wild and 

domesticated potatoes is extremely unlikely. Approximately 200 species of wild potatoes have 

been identified (Hijmans and spooner, 2001), but only two species grow within US borders, the 

tetraploid species Solanum fendleri (recently reclassified as Solanum stoloniferum) and the 

diploid species Solanum jamesii (Bamberg et al., 2003); (Bamberg and del Rio, 2011). In 

addition to geographic separation (US-EPA, 2011c), there are several biological barriers to gene 

transfer such as multiple ploidy levels and endosperm imbalances (Love, 1994b). Hybridization 

between native and cultivated potatoes has never been reported in the US, although gene transfer 

has been accomplished using special laboratory techniques (Love, 1994b) (US-EPA, 2011c). 

2.4.4 Microorganisms

Soil microorganisms play a critical role in soil structure formation, decomposition of organic 

matter, toxin removal, nutrient cycling, most biochemical soil processes (Garbeva et al., 2004a)

and maintenance of soil structure and composition (Rosen, 2010b). Compared to soil supporting 

crops, fallow soil has the lowest microbial mass and diversity (Larkin, 2003). Microorganisms 

suppress soil-borne plant diseases and promote plant growth (Doran et al., 1996a) (Inceoglu et 

al., 2013). The main factors affecting microbial population size and diversity include soil type 

(texture, structure, organic matter, aggregate stability, pH, and nutrient content), plant type 

(providers of specific carbon and energy sources into the soil), and agricultural management 

practices (crop rotation, tillage, irrigation and herbicide and fertilizer application) (Garbeva et 

al., 2004a; Garbeva et al., 2004b) (Rosen, 2010b). Crop type also may play an important role in 

the type of soil microorganisms in soils (Larkin, 2003).Plant roots, including those of potato, 

release a variety of compounds into the soil creating a unique environment for microorganisms in 

the rhizosphere, whereby microorganisms may be attracted to and stimulated by the roots 

(Inceoglu et al., 2013). Microbial diversity in the rhizosphere may be extensive and differs from 

the microbial community in the bulk soil (Garbeva et al., 2004a).

Larkin (Larkin and Honeycutt, 2006) investigated the effect of potato production on soil 

microbial communities over a period of three years. A two-year rotation period appears to 

control soilborne disease. Potato soil microbial populations were lower than for several other 

crops, including canola, barley, and corn. Use of rotations also appeared to reduce the incidence 

and severity of black scurf, as well as reduced the number of misshapen tubers. Larkin (Larkin 

and Honeycutt, 2006) suggested that activity and diversity of microbial populations were 

negatively correlated with the percentage of misshapen tubers.

In a study examining the abundance and structure of bacterial communities in a potato-barleypotato rotation, it was determined that the roots of all potato cultivars had positive effects on 

bacterial numbers in the soil, diversity and community structure of bacterial communities varied 

with time and season, and the composition of bacterial communities is linked to the specific 

requirements of different cultivars. Bacterial composition was potentially related to tuber starch 

content, as well as specific fertilizers (Inceoglu et al., 2013).
29

Pathogenic microorganisms which are associated with diseases of potatoes, is discussed in 

section 2.2.7, General Agronomic Practices, Disease Control.
30

2.1.1 2.2.5 Biodiversity

Biodiversity refers to all plants, animals, and microorganisms interacting in an ecosystem. 

Biodiversity provides valuable genetic resources for crop improvement (Wilson, 1988a; Wilson, 

1988b); (Harlan, 1975b; Harlan, 1975a), and also provides other functions beyond food, fiber, 

fuel, and income. These include pollination, genetic introgression, biological control, nutrient 

recycling, competition against natural enemies, soil structure, soil and water conservation, 

disease suppression, control of local microclimate, control of local hydrological processes, and 

detoxification of noxious chemicals (Altieri, 1999). The loss of biodiversity results in a need for 

costly management practices in order to provide these functions to the crop (Altieri, 1999). 

The degree of biodiversity in an agroecosystem depends on four primary characteristics: 1) 

diversity of vegetation within and around the agroecosystem; 2) permanence of various crops 

within the system; 3) intensity of management; 4) extent of isolation of the agroecosystem from 

natural vegetation (Southwood and Way, 1970).

Agricultural land subject to intensive farming practices, such as that used in crop production, 

generally has low levels of biodiversity compared with adjacent natural areas (Altieri, 1999). 

Tillage, seed bed preparation, planting of a monoculture crop, pesticide use, fertilizer use, and 

harvesting limits the diversity of plants and animals (Lovett et al., 2003).

Biodiversity can be maintained or reintroduced into agroecosystems through the use of woodlots, 

fencerows, hedgerows, and wetlands. Agronomic practices include intercropping (the planting 

of two or more crops simultaneously to occupy the same field), agroforestry, crop rotations, 

cover crops, no-tillage, composting, green manuring (growing a crop specifically for the purpose 

of incorporating it into the soil in order to provide nutrients and organic matter), addition of 

organic matter (e.g., compost, green manure, animal manure), hedgerows and windbreaks

(Altieri, 1999).

Because potatoes are grown throughout regions of the U.S., there is a large diversity of plants 

and animals that inhabit the areas surrounding the potato fields. These include the weeds 

discussed in Section 2.2, Agronomic Practices, Weed Control, and animals in Section 2.4.2, 

Animal Communities.

2.2

2.2.1 2.2.6 Human Health

Humans interact with potatoes either as consumers of potato and products derived from it, as 

workers who produce potato crops. Under the FFDCA, it is the responsibility of food and feed 

manufacturers to ensure that the products they market are safe and properly labeled. Food and 

feed derived from GE potato must be in compliance with all applicable legal and regulatory

requirements. GE organisms for food and feed may undergo a voluntary consultation process 

with the FDA prior to release onto the market. Although a voluntary process, thus far all 

applicants who wish to commercialize a GE variety that will be included in the food supply have 

completed a consultation with the FDA. In a consultation, a developer who intends to 

commercialize a bioengineered food meets with the agency to identify and discuss relevant 

safety, nutritional, or other regulatory issues regarding the bioengineered food and then submits 

to FDA a summary of its scientific and regulatory assessment of the food (insert reference to 
31

FDA letter). FDA evaluates the submission and responds to the developer by letter. Simplot 

submitted a letter of consultation on February 12, 2013, which FDA is still reviewing (BNF No. 

141). 

As noted by the National Research Council (NRC), unexpected and unintended compositional 

changes arise with all forms of genetic modification, including both conventional hybridizing 

and genetic engineering (NRC, 2004). The NRC also noted that at the time, no adverse health 

effects attributed to genetic engineering had been documented in the human population. 

Reviews on the nutritional quality of GE foods have generally concluded that there are no 

significant nutritional differences in conventional versus GE plants for food or animal feed

(Faust, 2002; Flachowsky et al., 2005).

Consumer Health

The potato is the world’s number one non-grain food commodity (FAO, 2008). Potatoes are 

high in nutrients and at least twelve essential vitamins, especially vitamins B and C, and minerals 

such as iron, potassium, and zinc (Arvanitoyannis et al., 2008) (Bushway, 2010) (FAO, 2008). 

They have the highest protein content (around 2.1 percent on a fresh weight basis) in the family

of root and tuber crops. As a low-fat source of carbohydrates, potatoes can be instrumental in 

providing a solution to long-term problems of world hunger (Bushway, 2010).

Because of their high sugar and starch content and resulting high glycemic index, consumption 

of potatoes by persons with diabetes or similar conditions may need to eat potatoes sparingly. 

U.S. per capita potato consumption is summarized in Table 6 (NPC, 2012b). 

Table 6. U.S. Per Capita Potato Consumption in 2012 

Fresh 

Market

Processing All 

Canned Frozen Chips Dehydrated Potatoes Total 

Processing

35 1 50 15 12 78 112

Source: (NPC, 2012b); totals may not add due to rounding.

Toxins and Allergens in Potato

Potatoes contain two classes of toxins and/or allergens: glycoalkaloids and patatins. Acrylamide 

is a toxic compound formed in cooking potatoes at high temperatures, such as roasting or baking 

and frying.

Glycoalkaloids are well-known naturally-occurring compounds that are present in all potatoes, 

which likely serve a defense mechanism against predator attack. These compounds are 

concentrated in foliage, flowers and sprouts, although glycoalkaloids are present in lower 

concentrations in other parts of the plant, including tubers. For food safety purposes, an upper 

limit for glycoalkaloid content of 20 milligrams per 100 grams of potato is generally accepted.
32

Concentrations exceeding this are potentially poisonous to humans and livestock. Light 

exposure to harvested tubers can increase glycoalkaloid content in potatoes, and may result in 

green areas of coloration on potato skins (Sinden, 1987a) (Center, 2010). 

Patatins are a family of proteins that makes up 30 to 40 percent of the soluble protein in potatoes

(Mignery et al., 1988). Allergic reactions to cooked potatoes are considered to be very

uncommon and have been reported for children only (De Swert et al., 2002), with patatin 

identified as the major allergen involved in this reaction (De Swert et al., 2007). Because potato 

protein naturally contains a relatively large proportion of patatin, those who are allergic to 

patatin would need to avoid eating potatoes.

Of greatest significance to human health is the toxic compound acrylamide, which is a known 

carcinogen of rodents and a probable human carcinogen (WHO-IARC, 1994) (NTP, 2011)

(Chawla et al., 2012) (Halford et al., 2012a). In particular, risk of endometrial and ovarian 

cancer appears to increase with increased acrylamide intake (Pedreschi, 2009). Acrylamide is 

also regarded as a mammalian cell mutagen, wherein very low dosages of the compound can 

damage chromosomes (Chawla et al., 2012). Acrylamide has also been reported to be a 

cumulative neurotoxin (Friedman, 2003).

Acrylamide is formed in potatoes which are cooked at high temperatures, such as baking or 

frying. In 2002, Swedish researchers demonstrated that acrylamide forms when starchy foods, 

such as potatoes and breads, are heated at high temperatures, such as in baking, roasting, and 

frying, but not in unheated or boiled foods (Tareke et al., 2002; Halford et al., 2012a). Therefore, 

even though dietary exposure to acrylamide is measurable, it is not a natural compositional 

component of unheated foods derived from plants. Acrylamide forms during the Maillard 

reaction (Martins et al., 2000) which is a reaction at high temperatures (such as frying French 

fries) between certain sugars such as glucose and fructose (reducing sugars) and asparagine (an 

amino acid) that are naturally present in the food (FDA, 2009). In addition, prolonged heating 

time increases acrylamide content, whereas higher moisture content reduces acrylamide content 

(Kotsiou et al., 2013). Maillard reaction products, which affect the flavor and texture of the 

cooked food, are formed by a chemical reaction between an amino acid and a reducing sugar

(Halford et al., 2012b). Oxidation of the free amino acid asparagine, a major amino acid in 

potatoes and cereals (Mottram et al., 2002; Chawla et al., 2012), is the main source of 

acrylamide when starchy foods are baked or fried (Stadler et al., 2002; Friedman, 2003; Halford

et al., 2012a; Kotsiou et al., 2013). Color of cooked potato products such as potato chips has 

been found to correlate well with acrylamide formation: the darker the color, the higher the 

greater the acrylamide concentration (Halford et al., 2012a) (Kotsiou et al., 2013) (Pedreschi, 

2009) (Arvanitoyannis et al., 2008).

Important variables leading to acrylamide formation and affecting acrylamide concentration in 

cooked potatoes include reducing sugar content, processing/cooking temperature and method, 

cooking/processing time, moisture content, and additives (Kotsiou et al., 2013) (Halford et al., 

2012a). In turn, concentrations of sugars and amino acids are influenced by cultivar, fertilizers, 

climate, and storage conditions (Pedreschi, 2009). 
33

It is estimated that potato chips and fried potato products such as French fries are responsible for 

about 1/3 of the human dietary exposure to acrylamide (Chawla et al., 2012). Acrylamide is also 

present in other foods such as coffee, some breads, biscuits, gingerbread, and processed onion 

mix and dip mixes. Smoking may contribute to human exposure to acrylamide (Chawla et al., 

2012) (Kotsiou et al., 2013) (Friedman, 2003). 

For all of these reasons, the discovery of acrylamide in cooked potato products has raised 

concerns throughout the potato processing industry, as well as among consumers. The 

FAO/WHO Expert Committee on Food Additives has recommended that dietary exposure to 

acrylamide should be reduced (FAO/WHO, 2011). Perhaps because children consume more 

acrylamide-laden products such as French fries and potato chips, their exposure to the chemical 

is greater than for adults(Friedman, 2003) (Halford et al., 2012b). The State of California listed 

acrylamide as a potential carcinogen under Proposition 65 in 1990 and established a No 

Significant Risk Level (NSRL) of 0.2 μg/day (CEPA-OEHHA, 2005). Subsequent to the 

discovery of acrylamide in cooked foods, this NSRL was revised to 1.0 μg/day (CEPA-OEHHA, 

2005). FDA has recently released draft guidance for the food industry to reduce acrylamide in 

foods(FDA, 2013a).

Proposition 65 requires that food manufacturers warn consumers about the dangers of acrylamide 

in their products. In 2005, the State of California sued Frito-Lay, Kettle Foods and Lance, Inc. 

for failing to provide such warnings. In the settlement, the potato chip manufacturers agreed to 

reduce the acrylamide in their products to 275 ppb, low enough to avoid the Proposition 65 

warning. These three companies also agreed to pay close to $2M in penalties and court costs. 

The potato processing industry now has a strong financial incentive to reduce the levels of 

acrylamide in their retail products.

Worker Health

Worker hazards in farming are common to all types of agricultural production, and include 

hazards from equipment and plant materials. Pesticide application represents the primary

exposure route to pesticides for farm workers. Workers engaged in potato production may

encounter insecticides, herbicides, fungicides or fertilizers that may pose a worker health or 

safety risk, unless used in accordance with the US-EPA -established agriculture-specific 

requirements in the Worker Protection Standard (WPS) (40 CFR Part 170) that protect workers 

from the hazards of chemical exposure. The WPS offers protections to more than two and a half 

million agricultural workers who work with pesticides at more than 560,000 workplaces on 

farms, forests, nurseries, and greenhouses. The WPS contains requirements for pesticide safety 

training, notification of pesticide applications, use of personal protective equipment, restricted 

entry intervals following pesticide application, decontamination supplies, and emergency

medical assistance. The Occupational Safety and Health Administration requires all employers to 

protect their employees from hazards associated with agricultural chemicals. The EPA pesticide 

registration process, however, involves the design of use restrictions that if followed have been 

determined to be protective of worker health.

A potato field is a highly managed environment which incorporates the use of agricultural 

chemicals, including herbicides and insecticides. Pesticides are used on most potato acreage in 
34

the U.S., and changes in acreage, crops, or farming practices can affect the amounts and types of 

pesticides used and thus the risks to workers. Worker safety precautions and use restrictions are 

noted clearly on pesticide registration labels. Growers are required to use pesticides consistent 

with the application instructions provided on the EPA-approved pesticide labels. These 

restrictions provide instructions as to the appropriate levels of personal protection required for 

agricultural workers. These may include instructions on personal protective equipment, specific 

handling requirements, and field reentry procedures (see, e.g. (Carroll and Robinson, 2006)

(Carroll and Robinson, 2006).

2.2.7 Animal Feed

Potatoes used as livestock feed accounted for approximately 1.2 percent of all potatoes produced 

in the U.S. in 2012 (see Table 7). This quantity includes potatoes sold specifically as livestock 

feed and potatoes used as livestock feed on farms where the crop was grown. It does not include 

the potato waste that was used for livestock feed (USDA-NASS, 2013

). Use of potatoes for livestock feed is generally dependent on quality and price: for example, 

when potatoes are low in both price and quality, more of the crop tends to be used for livestock 

feed. Prices for feed are usually the lowest of all potato usage categories (Guenther, 2010c).

Table 7. U.S. 2012 Potato Utilization 

Utilization Item CWT (1,000) (%) 

Sales – fresh and processing 

Table stock (fresh) 118,535 (25.6%)

Processing

 Chips and shoestrings 56,349 (12.2%)

 Dehydrated (except starch and flour) 50,559 (10.9%)

 Frozen French fries 144,910 (31.3%)

 Other frozen products 20,912 (4.5%)

 Canned products 1,764 (0.4%)

 Other canned products (hash, stews, soup) 695 (0.2%)

 Starch, flour and other 8,031 (1.7%)

 Total processing 282,220 (61.0%)

Other sales

Livestock feed 4,080 (0.9%)

Seed 23,706 (5.1%)

Non-sale

Seed used on farms where grown 3,286 (0.7%)

Household and feed use on farms where grown 1,583 (0.3%)

Shrinkage and loss 28,356 (6.1%)
35

Utilization Item CWT (1,000) (%) 

Total Production 462,766

Source: (USDA-NASS, 2013

)

Potatoes constitute at least part of the diet for several domestic animals, including cattle, horses, 

pigs, and poultry. The recommended rate of feed is approximately 25-40 lb potatoes/1,000 lb 

live weight, but can vary with the type of animal. Potatoes are considered to be a palatable feed, 

and are high in moisture content, but are not as nutritious as grain or corn silage (e.g., it takes 

400-500 lb of potatoes to provide the same nutritive value as 100 lb of grain(Corbett, No Date).

Feed does not include the leafy green foliage of potato plants since flowers, sprouts, and foliage 

has abundant glycoalkaloids, which are potentially poisonous for livestock (Sinden, 1987a).

Similar to the regulatory control for direct human consumption of potato under the FFDCA, it is 

the responsibility of feed manufacturers to ensure that the products they market are safe and 

properly labeled. Feed derived from GE potato must comply with all applicable legal and 

regulatory requirements, which in turn protects human health. To help ensure compliance, GE 

organisms used for feed may undergo a voluntary consultation process with FDA before release 

onto the market, which provides the applicant with any needed direction regarding the need for 

additional data or analysis, and allows for interagency discussions regarding possible issues. 

Although a voluntary process, thus far all applicants who wish to commercialize a GE 

variety that will be included in the food supply have completed a consultation with the FDA. 

In a consultation, a developer who intends to commercialize a bioengineered food meets 

with the agency to identify and discuss relevant safety, nutritional, or other regulatory issues 

regarding the bioengineered food and then submits to FDA a summary of its scientific and 

regulatory assessment of the food. FDA evaluates the submission and responds to the 

developer by letter. Simplot submitted a letter to FDA on February 12, 2013, which FDA is 

currently reviewing (BNF No. 141).

2.3 Socioeconomics

As part of an evaluation of impacts on the human environment, NEPA requires consideration of 

economic and social effects (40 CFR 1508.8), whether direct, indirect, or cumulative. However, 

under CEQ regulations (40 CFR 1508.14), “. . . economic or social effects are not intended by 

themselves to require preparation of an environmental impact statement.”

The following socioeconomic factors are considered in this EA: the interaction of social and 

economic factors that affect agricultural production and products, including farm income and 

employment, crop production expenses, crop value and trade. The main focus of this assessment

is the socioeconomic effect on the crop industry, including production and domestic and 

international trade, and crop producers.
36

2.3.1 Domestic Economic Environment

Potatoes contribute approximately 15 percent of farm sales receipts for vegetables, making 

potatoes the leading vegetable crop in the United States (USDA-ERS, 2012b). The total value of 

U.S. potato production in 2012 was $3.9 billion, the average yield was 409 CWT/acre and the 

average price received was $7.26/CWT (USDA-NASS, 2012c). Unlike true commodity crops 

such as corn and soybeans, most potatoes are grown for a specific market. As shown in Table A, 

the Russet Burbank and Ranger Russet are primarily used for fries, and the Atlantic, “H”, and 

“G” varieties are primarily used for chips. Atlantic is the standard for making potato chips from 

the field or from very short storage (PAA, 2009b). Any of these varieties can also be sold on the 

fresh market. On the fresh market, Russet Burbank and Ranger Russet potatoes are the standard 

for baking (PAA, 2009a); (Pavek et al., 1992). Other varieties are used for canning and are wellsuited for boiling. There are thousands of potato varieties, some intended for very small markets 

(FAO, 2008).

Uses for all potato varieties combined in the United States are summarized in Table 8. Specific 

varieties are not grown for the dehydration market or for livestock feed; rather, food-grade 

potatoes considered unsuitable for their intended fresh or other processing markets are usually 

used for these purposes (Guenther, 2010c). Because potato sales for livestock feed usually

receive the lowest price, potatoes are not sold for livestock feed if other uses are available 

(Guenther, 2010c). 

Table 8. A Sample of U.S. Potato Varieties and their Uses 

Variety1 Use

Russet Burbank Boiling, baking, chipping, French frying

Ranger Russet Baking, French frying

Atlantic Fresh market, chipping

Kennebec Boiling, pan frying, chipping, French frying

Norland Boiling, French frying, chipping

Yukon Gold Fresh market, boiling, baking, French frying

1

http://potatoes.wsu.edu/varieties/vars-all.htm

Fresh market potatoes in North America can be classified broadly as russets, reds, yellows or 

whites based on skin color. Most eastern potato growers also are involved in packing; in the 

west, the businesses are usually separate. Recently, western growers have entered the packing 

business, often in partnerships or cooperatives with other growers (Guenther, 2010a). 

Fresh potatoes may be shipped in refrigerated rail cars or trucks to maintain a high standard of 

quality whereas frozen and dehydration processing typically occurs near potato production areas. 

The fragility of chips and the high cost of shipping low-density products results in most chipping 

plants being located near populated areas. Except for dehydrators, processors typically contract 

for most of their needs and buy the remainder on the open market. Some dehydrators segregate 

potatoes that are suitable for the fresh market, and then sell those on the fresh market, processing 
37

the rest. Others purchase off-grade potatoes from fresh packers for processing (Guenther, 

2010b). 

Revenues and costs of potato production vary widely, depending on geography, growing 

conditions, the local economy, the type of potato, farm size, and other factors. For example, the 

2011 per acre operating cost of growing Russet Burbank potatoes in Southwestern Idaho, 

including on-farm storage and fumigation, was $2,811 (Patterson, 2011). In the same year, the 

gross return per acre averaged $4,107.50, resulting in a net return of $1,297. When that same 

variety was grown in South-Central Idaho, the 2011 per acre operating cost, including on-farm 

storage and fumigation, was $2,560 (Patterson, 2011), and the gross return per acre averaged 

$3681.25, resulting in a net return of $1,121. 

Approximately 90 percent of U.S. potatoes are planted in the spring and harvested in the fall, and 

western states produce two-thirds of the fall potatoes. The storage abilities of potatoes enable 

fall-season potato varieties to be sold in fresh or processing markets throughout the SeptemberAugust marketing year. Less than 10 percent of potatoes are harvested in winter, spring and 

summer; however, these potatoes meet specific market needs (e.g., new potatoes) and tend to 

yield higher prices than fall potatoes (USDA-ERS, 2012b).

Sales value per acre is normally highest for the winter crop and lowest for fall potatoes, but 

varies widely among the producing states. Prices for fresh potatoes are usually higher than 

prices for processing potatoes due to crop-quality standards. Domestic potato prices may vary

not only in response to changes in weather, yield or demand, but also to changes in supply from 

imported potatoes and potato products. If a large quantity of frozen French fries enters the 

country, U.S. potato processors may cut back on contracts for processing potatoes, which would 

be diverted to the fresh market. Fresh market prices would likely fall as a result (USDA-ERS, 

2012b).

Not all potatoes are sold for food. The largest non-sales category is “shrinkage and loss”, which 

accounts for the water weight loss and loss due to respiration during storage. Also in this 

category are potatoes that do not meet market quality standards due to decay, bruising, greening, 

sprouting and disease. Crops that suffer frost damage also are added to this category (Guenther, 

2010c). 

Potato production requires numerous expenditures, including for specialized machinery. The 

largest conventional operating cost items are fertilizer, chemicals and pesticides, storage and 

seed potatoes. Fertilizer and seed accounted for 25 percent of total production costs in eastern 

Idaho in 2007 (Patterson, 2010). Potato production costs for irrigation in the western United 

States ranges between $1,500 and $3,500 per acre (Patterson, 2010). Costs do not stop 

accumulating at harvest unless the potatoes are sold out of the field. Additional costs are 

incurred to store potatoes.

For those producing organic potatoes, an organic production system is required in addition to a 

relatively long crop rotation to minimize pest problems. Profitability margins differ between 

organic farm sizes, but a study conducted in southern Idaho indicated that net returns over 

variable costs for a small farm (30-50 acres) with 100% organic premiums is $1,026/acre and 
38

$1,148/acre for a large farm (100-120 acres) (Painter et al., 2010). Smaller farms have higher 

operating costs as a result of smaller, less efficient machinery, and their machine hours for potato 

production are more than double the hours on a large organic farm. While larger farms reduce 

labor expenses by half with more efficient machinery, they do have an increase in capital costs. 

Organic potato growers face challenges, including growing sufficient fall cover crops to supply 

soils with additional nitrogen, but profit margins for organic potatoes have the potential to 

exceed those for conventional potatoes if these and other challenges are addressed (Painter et al., 

2010).

One of the traits of Simplot InnateTM Potato, reduced black spot bruising, is of major significance 

to economic markets. In general, post-harvest losses are a significant part of the production costs 

of fruits and vegetables, and may reach as high as 50% (Llorente et al., 2011) (Martinez and 

Whitaker, 1995). Browning of fruits and vegetables negatively affects consumer acceptance 

because of altered appearance and perceived nutritional deficit (Llorente et al., 2011). 

Specifically, potato growers can lose up to 20% of income through potato injury at harvest 

(Preston, 2010). The potato industry, therefore, has a vested interest in minimizing these losses. 

Black spot bruise is typically caused by mechanical injury to tubers during harvest, handling, 

storage, or processing such as scuffing and cracking of the skin (Dirks-Hofmeister et al., 2013). 

Injury leads to a bluish-grey to black discoloration of internal tuber tissue (Stremmel et al., 

2010). Bruising symptoms do not appear until 3 hours to 24 hours following mechanical impact, 

and are not visible until the skin is removed from the tuber (Stremmel et al., 2010) (Urbany et 

al., 2011). Because bruising cannot be observed until the potato skin is removed, it is more 

difficult to identify damaged tubers, and makes conventional means of breeding to eliminate this 

trait more problematic (Urbany et al., 2011).

Physical tuber properties, such as tissue stiffness and elasticity, affect transfer of the impact 

energy to the tuber and may affect susceptibility of the tuber to bruising. For example, if potato 

tissue does not crack during injury, the force of the impact is more evenly distributed throughout 

a larger area of the tuber, which results in greater changes to metabolism, and, hence more 

bruising (Stremmel et al., 2010). Therefore, bruising susceptibility varies widely among potato 

cultivars (Stremmel et al., 2010). To a large extent, susceptibility is dependent on multiple 

genetic traits, as well as on maturity of tubers and environmental factors (Urbany et al., 2011).

Potato genotypes with high tuber starch content are more susceptible to bruising (Urbany et al., 

2012).

The chemical basis for black spot bruising lies in the cellular release of phenolic compounds, 

normally compartmentalized in the vacuoles, following injury (Tran et al., 2012). The phenolic 

compounds are converted to o-phenols and o-quinones by the enzyme polyphenol oxidase (PPO)

(Dirks-Hofmeister et al., 2013). These quinoids auto-oxidize, forming melanin, leading to 

blackened tissue which is called enzymatic browning and is undesirable in processed potato 

product (Hunt et al., 1993; Llorente et al., 2011) (Steffens, 1994) (Stremmel et al., 2010; Vitti et 

al., 2011). Oxidative browning reactions generally cause deterioration in food quality by

changing nutritional and organoleptic properties, and can involve changes in texture and flavor 

as well as color (Yoruk and Marshall, 2003). The side chains of essential amino acids in plant 
39

proteins may interact with quinones, leading to a reduction in nutritional quality (Yoruk and 

Marshall, 2003). Degree of discoloration is strongly related to PPO activity (Urbany et al., 

2011). Polyphenol oxidase expression is mediated by a multigene family in potato (Thygesen et 

al., 1995) (Llorente et al., 2011).

Storage temperatures also affect the likelihood of black spot bruise (Preston, 2010)since 

increased temperature heightens PPO activity(Yoruk and Marshall, 2003);(Vitti et al., 2011).

2.3.2 Trade Economic Environment

U.S. and global trade are greatly affected by the growth and stability of world markets, including 

changes in world population, economic growth, and income. Other factors affecting agricultural 

trade are global supplies and prices, changes in exchange rates, government support for 

agriculture, and trade protection policies. 

U.S. farmers and agricultural firms rely heavily on export markets to sustain prices and revenues 

because productivity of U.S. agriculture increases faster than the demand for domestic food and 

fiber. U.S. food imports have increased with the corresponding increase in demand for greater 

diversity in the food supply. U.S. consumers benefit from imports because imports expand food 

variety. This also tends to stabilize year-round supplies of and prices for fresh fruits and 

vegetables.

U.S. exports of potatoes and potato products have grown 133 percent in value and 79 percent in 

volume during the last 10 marketing years (Board, 2013). Frozen potato products comprise 60 

percent of the U.S. potato exports. During the 2012/ 2013 market year (September-August), U.S 

exports of potatoes and potato products totaled $1.6 billion—up from $1.4 billion in the previous 

market year (USDA-ERS, 2013). Exports to target markets were led by an increase in shipments 

to Mexico, South Korea, Malaysia, and Vietnam. During the 2012/ 2013 market year, Canada 

was the largest market for chips while Japan was the largest market for frozen potato products 

and dried, flour, and meal potato products (USDA-ERS, 2013); (Board, 2012). Mexico provides 

the United States with the largest market for exporting potato flakes and granules and is the 

second largest market destination for frozen potatoes (USDA-ERS, 2013); (Board, 2012).

U.S. potato and potato product exports are expected to grow during the upcoming marketing year 

(Board, 2013). Growth rates will depend upon economic growth in the markets and the supply 

and price of competitor products. The United States will facilitate the growth of the export 

market by continuing to gain new market access, as just occurred for fresh table-stock to the 

Philippines (Board, 2013).

2.3.3 Organically Certified Economic Environment

In the U.S., only products produced using specific methods and certified under the USDA AMS 

National Organic Program (NOP) definition of organic farming can be marketed and labeled as 

“organic” (USDA-AMS, 2010). Organic certification is a process-based certification; not a 

certification of the end product. The certification process specifies and audits the methods and 

procedures by which the product is produced.
40

In accordance with NOP, each year an accredited organic certifying agent must review an 

operation. This must include a review of its organic system plan and record-keeping practices, 

and an on-site inspection of the production area(s). Organic growers must maintain records to 

show that production and handling procedures comply with USDA organic standards.

Section 205.105 of the regulations identifies “Allowed and prohibited substances, methods, and 

ingredients in organic production and handling.

“To be sold or labeled as ‘100 percent organic,’ ‘organic,’ or ‘made with organic’ (specified 

ingredients or food group(s)),” the product must be produced and handled without the use of: . . . 

(e) Excluded methods . . . .”

Excluded methods identified at 7 CFR Section 205.2, are defined as follows:

“A variety of methods used to genetically modify organisms or influence their 

growth and development by means that are not possible under natural conditions 

or processes and are not considered compatible with organic production. Such 

methods include cell fusion, microencapsulation and macroencapsulation, and 

recombinant DNA technology (including gene deletion, gene doubling, 

introducing a foreign gene, and changing the positions of genes when achieved 

by recombinant DNA technology). Such methods do not include the use of 

traditional breeding, conjugation, fermentation, hybridization, in vitro 

fertilization, or tissue culture.”

Organic farming operations, as described by the NOP, are required to have distinct, defined 

boundaries and buffer zones to prevent unintended contact with excluded methods from 

adjoining land that is not under organic management. Organic production operations must also 

develop and maintain an organic production system plan approved by their accredited certifying 

agent. This plan enables the production operation to achieve and document compliance with the 

National Organic Standards, including the prohibition on the use of excluded methods (USDAAMS, 2010). 

Common practices organic growers may use to exclude GE products include planting only 

organic seed, planting earlier or later than neighboring farmers who may be using GE crops, so 

that the crops will flower at different times, and employing adequate isolation distances between 

organic and neighboring fields to minimize the chance for pollen exchange between 

fields(NCAT, 2003). Although the national organic standards prohibit the use of excluded 

methods, they do not require testing of inputs or products for the presence of excluded methods. 

The presence of a detectable residue of a product of excluded methods alone does not necessarily 

constitute a violation of the national organic standards (USDA-AMS, 2010). The current NOP 

regulations do not specify an acceptable threshold level for the adventitious presence of GE 

materials in an organic-labeled product. The unintentional presence of the products of excluded 

methods will not affect the status of an organic product or operation if excluded methods were 

used and reasonable practices were implemented to avoid contact with products of excluded 

methods as detailed in their approved organic system plan (Ronald and Fouche, 2006; USDAAMS, 2010). 

Organic market and products
41

The organic sector is rapidly growing both in the United States and the EU. Consumer purchases 

in these two regions made up 95% of estimated world retail sales of organic food products in 

2003(Dimitri and Oberholtzer, 2009). Annual manufacturer survey results (Organic Trade 

Association, 2011), indicated that estimated U.S. organic food sales for 2010 were $26.7 billion. 

This represented a 7.7 % growth rate from the previous year. The market sector experiencing the 

highest growth rate during 2010 was organic fruits and vegetables, which increased 11.8 % 

compared with 2009 sales. The market share for organic fruits and vegetables was 11% of all 

U.S. fruit and vegetable sales (Organic Trade Association, 2011). Organic products represented 

approximately 4% of total 2010 sales in the food and beverage sector (Organic Trade 

Association, 2011). 

Organic Potatoes

In 2008, 2.2 million CWT of organic potatoes were harvested, with a total sales value of almost 

$29 million ($13.24/CWT)(USDA-NASS, 2012a). Prices for organic potatoes are typically

substantially higher than the overall average conventional potato price, and probably reflects 

both the organic premium and the fact that most organic potatoes are sold fresh. Organic 

growers typically receive a significant price premium when they can sell their potatoes as 

organic (Dufour et al., 2009); however, that market is not always available (Esplin, 2009). The 

organic potato market is not highly structured (Dufour et al., 2009). At least one manufacturer 

produces organic potato chips (Foods, 2009)

3. ALTERNATIVES

This document analyzes the potential environmental consequences of a determination of 

nonregulated status of Simplot InnateTM Potato. To respond favorably to a petition for 

nonregulated status, APHIS must determine that Simplot InnateTM Potato is unlikely to pose a 

plant pest risk. Based on its PPRA (USDA-APHIS, 2013a), APHIS has concluded that Simplot 

InnateTM Potato is unlikely to pose a plant pest risk. Therefore APHIS must determine that 

Simplot InnateTM Potato is no longer subject to 7 CFR part 340 or the plant pest provisions of the 

Plant Protection Act. 

Two alternatives are evaluated in this EA: (1) no action and (2) determination of nonregulated 

status of event. APHIS has assessed the potential for environmental impacts for each alternative 

in the Environmental Consequences section.

3.1 No Action Alternative: Continuation as a Regulated Article

Under the No Action Alternative, APHIS would deny the petition. Simplot InnateTM Potato and 

progeny derived from Simplot InnateTM Potato would continue to be regulated articles under the 

regulations at 7 CFR part 340. Permits issued or notifications acknowledged by APHIS would 

still be required for introductions of Simplot InnateTM Potato and measures to ensure physical 

and reproductive confinement would continue to be implemented. APHIS might choose this 

alternative if there were insufficient evidence to demonstrate the lack of plant pest risk from the 

unconfined cultivation of Simplot InnateTM Potato. 
42

This alternative is not the Preferred Alternative because APHIS has concluded through a Plant 

Pest Risk Assessment that Simplot InnateTM Potato is unlikely to pose a plant pest risk (USDAAPHIS, 2013a). Choosing this alternative would not satisfy the purpose and need of making a 

determination of plant pest risk status and responding to the petition for nonregulated status. 

3.2 Preferred Alternative: Determination That Simplot InnateTM Potato Is No Longer a 

Regulated Article

Under this alternative, Simplot InnateTM Potato and progeny derived from them would no longer 

be regulated articles under the regulations at 7 CFR part 340. Simplot InnateTM Potato is 

unlikely to pose a plant pest risk (USDA-APHIS, 2013a). Permits issued or notifications 

acknowledged by APHIS would no longer be required for introductions of Simplot InnateTM

Potato and progeny derived from this event. This alternative best meets the purpose and need to 

respond appropriately to a petition for nonregulated status based on the requirements in 7 CFR 

part 340 and the agency’s authority under the plant pest provisions of the Plant Protection Act. 

Because the agency has concluded that Simplot InnateTM Potato is unlikely to pose a plant pest 

risk, a determination of nonregulated status of Simplot InnateTM Potato is a response that is 

consistent with the plant pest provisions of the PPA, the regulations codified in 7 CFR part 340, 

and the biotechnology regulatory policies in the Coordinated Framework.

Under this alternative, growers may have future access to Simplot InnateTM Potato and progeny 

derived from this event if the developer decides to commercialize Simplot InnateTM Potato.

3.3 Alternatives Considered But Rejected from Further Consideration

APHIS assembled a list of alternatives that might be considered for Simplot InnateTM Potato. 

The agency evaluated these alternatives, in light of the agency's authority under the plant pest 

provisions of the Plant Protection Act, and the regulations at 7 CFR part 340, with respect to 

environmental safety, efficacy, and practicality to identify which alternatives would be further 

considered for Simplot InnateTM Potato. Based on this evaluation, APHIS rejected several 

alternatives. These alternatives are discussed briefly below along with the specific reasons for 

rejecting each.

3.3.1 Prohibit Any Simplot InnateTM Potato from Being Released

In response to public comments that stated a preference that no GE organisms enter the 

marketplace, APHIS considered prohibiting the release of Simplot InnateTM Potato, including 

denying any permits associated with the field testing. APHIS determined that this alternative is 

not appropriate given that APHIS has concluded that Simplot InnateTM Potato is unlikely to pose 

a plant pest risk (USDA-APHIS, 2013a).

In enacting the PPA, Congress included findings in Section 402(4) that: “decisions affecting 

imports, exports, and interstate movement of products regulated under this title [i.e., the PPA]

shall be based on sound science;”

On March 11, 2011, in a Memorandum for the Heads of Executive Departments and Agencies, 

the White House Emerging Technologies Interagency Policy Coordination Committee 
43

established principles consistent with Executive Order 13563 to guide agencies in the 

development and implementation of policies for oversight of emerging technologies such as GE

that included the following guidance:

“Decisions should be based on the best reasonably obtainable scientific, technical, economic, and 

other information, within the boundaries of the authorities and mandates of each agency; . . .” 

Consistent with this guidance and based on the findings and scientific data evaluated for the 

PPRA (USDA-APHIS, 2013a), APHIS concluded that Simplot InnateTM Potato is unlikely to 

pose a plant pest risk. Therefore, there is no basis in science for prohibiting the release of 

Simplot InnateTM Potato.

3.3.2 Approve the Petition in Part

The regulations at 7 CFR 340.6(d) (3) (i) state that APHIS may "approve the petition in whole or 

in part." For example, a determination of nonregulated status in part may be appropriate if there 

is a plant pest risk associated with some, but not all lines described in a petition. Because APHIS 

has concluded that Simplot InnateTM Potato is unlikely to pose a plant pest risk, there is no 

regulatory basis under the plant pest provisions of the Plant Protection Act for considering 

approval of the petition only in part. 

3.3.3 Isolation Distance between Simplot InnateTM Potato and Non-GE Potato Production 

and Geographical Restrictions

In response to public concerns of gene movement between GE and non-GE plants, APHIS 

considered requiring an isolation distance separating Simplot InnateTM Potato from conventional 

or specialty potato production. However, because APHIS has concluded that Simplot InnateTM 

Potato is unlikely to pose a plant pest risk (USDA-APHIS, 2013a), an alternative based on 

requiring isolation distances would be inconsistent with the statutory authority under the plant 

pest provisions of the Plant Protection Act and regulations in 7 CFR part 340. 

APHIS also considered geographically restricting the production of Simplot InnateTM Potato

based on the location of production of non-GE potato in organic production systems or 

production systems for GE-sensitive markets in response to public concerns regarding possible 

gene movement between GE and non-GE plants. However, as presented in APHIS’ plant pest 

risk assessment for Simplot InnateTM Potato, there are no geographic differences associated with 

any identifiable plant pest risks for Simplot InnateTM Potato (USDA-APHIS, 2013a). This 

alternative was rejected and not analyzed in detail because APHIS has concluded that Simplot 

InnateTM Potato does not pose a plant pest risk, and will not exhibit a greater plant pest risk in 

any geographically restricted area. Therefore, such an alternative would not be consistent with 

APHIS’ statutory authority under the plant pest provisions of the Plant Protection Act and 

regulations in Part 340 and the biotechnology regulatory policies embodied in the Coordinated 

Framework.

Based on the foregoing, the imposition of isolation distances or geographic restrictions would not 

meet APHIS’ purpose and need to respond appropriately to a petition for nonregulated status

based on the requirements in 7 CFR part 340 and the agency’s authority under the plant pest 
44

provisions of the Plant Protection Act. However, individuals might choose on their own to 

geographically isolate their non-GE potato production systems from potato or to use isolation 

distances and other management practices to minimize gene movement between potato fields. 

Information to assist growers in making informed management decisions for Simplot InnateTM

Potato is available from Association of Official Seed Certifying Agencies (AOSCA, 2010).

3.3.4 Requirement of Testing for Simplot InnateTM Potato

During the comment periods for other petitions for nonregulated status, some commenters 

requested USDA to require and provide testing for GE products in non-GE production systems. 

APHIS notes there are no nationally-established regulations involving testing, criteria, or limits 

of GE material in non-GE systems. Such a requirement would be extremely difficult to 

implement and maintain. Additionally, because Simplot InnateTM Potato does not pose a plant 

pest risk (USDA-APHIS, 2013a), the imposition of any type of testing requirements is 

inconsistent with the plant pest provisions of the Plant Protection Act, the regulations at 7 CFR 

part 340 and biotechnology regulatory policies embodied in the Coordinated Framework. 

Therefore, imposing such a requirement for Simplot InnateTM Potato would not meet APHIS’ 

purpose and need to respond appropriately to the petition in accordance with its regulatory 

authorities. 

3.4 Comparison of Alternatives 

Table 9 includes a summary of the potential impacts associated with selection of either of the 

alternatives evaluated in this EA. The impact assessment is presented in Section 4 of this EA.
45

Table 9. Summary of Issues of Potential Impacts and Consequences of 

Alternatives

Attribute/Measure Alternative A: No Action

Alternative B: Determination 

of Nonregulated Status

Meets Purpose and Need 

and Objectives No Yes

Unlikely to pose a plant 

pest risk

Satisfied through use of 

regulated field trials

Satisfied – risk assessment

(USDA-APHIS, 2013a)

Management Practices

Acreage and Areas of 

Potato Production

Total commercial potato 

production has increased 

while land area dedicated to 

potato has decreased. Based 

on potato production trends 

and projections, potatoes will 

continue to be a major crop in 

the U.S. for the foreseeable 

future.

Total acreage dedicated to 

potato is unlikely to change, 

but adoption of Simplot 

InnateTM Potato may reduce 

acreage dedicated to 

conventional potatoes.

Agronomic Practices

Agronomic practices will 

remain the same as used 

currently.

Unchanged from No Action 

Alternative

Pesticide Use Pesticides are currently used to 

control insects, nematodes, 

fungi, and weeds.

Unchanged from No Action 

Alternative

Potato Seed Production Potato seed is primarily 

supplied by seed potatoes.

Unchanged from No 

Action Alternative

Organic Potato Production Organic potato growers use 

practices and standards for 

production, cultivation, and 

product handling and 

processing to ensure that their 

products are not pollinated by 

or commingled with 

conventional or GE crops. 

Unchanged from No Action 

Alternative

Environment
46

Table 9. Summary of Issues of Potential Impacts and Consequences of 

Alternatives

Attribute/Measure Alternative A: No Action

Alternative B: Determination 

of Nonregulated Status

Water Resources

The primary cause of

agricultural non-point source

pollution is increased 

sedimentation from soil erosion, 

which can introduce sediments, 

fertilizers, and pesticides to 

nearby lakes and streams. 

Agronomic practices such as 

crop nutrient management, pest 

management, and conservation 

buffers help protect water

quality from agricultural runoff.

Water usage for irrigation 

would be expected to continue 

to increase.

Unchanged from No Action 

Alternative

Soil Quality

Agronomic practices such as 

crop type, tillage, and pest 

management can affect soil 

quality. Growers will adopt 

management practices to 

address their specific needs in 

producing potatoes. Erosion 

potential may continue to 

increase.

Unchanged from No Action 

Alternative

Air Quality

Agricultural activities such as

burning, tilling, harvesting,

spraying pesticides, and

fertilizing, including the emissions 

from farm equipment, can directly 

affect air quality. Aerial

application of herbicides may

impact air quality from drift,

diffusion, and volatilization of the

chemicals, as well as motor 

vehicle emissions from airplanes

or helicopters.

Unchanged from No Action 

Alternative

Climate Change

Agriculture-related activities are 

recognized as both direct 

sources of greenhouse gases 

(GHGs)(e.g., exhaust from 

motorized equipment) and 

indirect sources (e.g., 

agriculture-related soil 

disturbance, fertilizer

production.

Unchanged from No Action 

Alternative
47

Table 9. Summary of Issues of Potential Impacts and Consequences of 

Alternatives

Attribute/Measure Alternative A: No Action

Alternative B: Determination 

of Nonregulated Status

Animal Communities

Potato fields may be host to 

many animal and insect species. 

Many of these animals are 

typically considered pests and 

may be controlled by the use of 

integrated pest management 

strategies.

Animals consuming Simplot 

InnateTM tubers may be 

exposed to increased levels of 

glutamine, but this is not 

expected to be detrimental.

Plant Communities

Potatoes are a labor intensive, 

highly managed crop. Members 

of the plant community that 

adversely affect potato 

production may be 

characterized as weeds. Weed 

control is an important aspect of 

potato production. Potato 

growers use production 

practices to manage weeds in 

and around potato fields. 

In the unlikely event of 

hybridization of Simplot 

InnateTM Potato with 

conventional varieties, 

resulting progeny may 

contain lowered polyphenol 

oxidase levels. However, this 

is not expected to be 

detrimental. Simplot InnateTM 

Potato is no weedier than 

conventional potatoes.

 

Gene Flow

Since potato is primarily 

vegetatively propagated, gene 

flow between cultivars is low. 

Volunteer potatoes would 

continue to need to be 

controlled, although their 

survival is low.

Simplot InnateTM traits are not 

expected to increase 

weediness in potato.

Soil Microorganisms

Abundance and diversity of soil 

microorganisms in and around 

potato fields is expected to 

remain as it is currently. 

Unchanged from No Action 

Alternative

Biological Diversity

The biological diversity in 

potato fields is lower than in the 

surrounding habitats. 

Unchanged from No Action 

Alternative

Human and Animal Health
48

Table 9. Summary of Issues of Potential Impacts and Consequences of 

Alternatives

Attribute/Measure Alternative A: No Action

Alternative B: Determination 

of Nonregulated Status

Risk to Human Health

Glycoalkaloids and patatins 

would continue to pose a risk to 

human health. In the case of 

humans consuming hightemperature cooked potatoes, 

they would continue to be 

exposed to acrylamide.

Glycoalkaloid and patatin 

exposure would continue. 

For humans consuming hightemperature cooked potatoes, 

acrylamide levels would be 

reduced approximately 60-

70%, which will benefit 

human health.

Risk to Animal Feed

Glycoalkaloids would continue 

to pose a risk to livestock if 

potato stems and foliage are fed 

to them, which is not likely. 

Unchanged from No 

Action Alternative.

Socioeconomic 

Domestic Economic 

Environment

Most potato production is used 

for food. Market utilization 

would likely continue as it is 

currently.

Because of its potential 

human health benefits (lower 

acrylamide) and potential 

reduced wastage (low 

bruising), Simplot InnateTM 

Potato may comprise a larger 

share of the domestic potato 

market, and may result in 

increased revenues.

Trade Economic 

Environment

U.S. potatoes and potato 

products will continue to play a 

role in global potato production, 

and the U.S. will continue to be 

a supplier in the international 

market. 

The foreign trade impacts 

associated with a 

determination of nonregulated 

status of Simplot InnateTM 

potatoes are anticipated to be 

similar to the No Action 

Alternative. However, import 

of each specific trait requires 

separate application and 

approval by the importing 

country. If the Simplot 

InnateTM traits are approved 

by importing countries, it may 

make up a larger percentage 

of potato import markets.

Other Regulatory Approvals

U.S. FDA

FDA is currently reviewing 

Simplot’s voluntary 

consultation submission of 

February 12, 2013.
49

Table 9. Summary of Issues of Potential Impacts and Consequences of 

Alternatives

Attribute/Measure Alternative A: No Action

Alternative B: Determination 

of Nonregulated Status

Other countries Countries importing potatoes 

would continue to do so.

Simplot would need to 

obtain regulatory approvals 

from any nations which 

plan to import Simplot 

InnateTM Potato.

Compliance with Other Laws

CWA, CAA, EOs

Fully compliant Fully compliant 
50

4 ENVIRONMENTAL CONSEQUENCES

4.1 Environmental Consequences

This analysis of potential environmental consequences addresses the potential impact to the 

human environment from the alternatives analyzed in this EA, namely taking no action and a 

determination by the agency that Simplot InnateTM Potato does not pose a plant pest risk. 

Potential environmental impacts from the No Action Alternative and the Preferred Alternative 

for Simplot InnateTM Potato are described in detail throughout this section. A cumulative effects 

analysis is presented for potentially affected environmental concerns. Certain aspects of this 

product and its cultivation would be no different between the alternatives: those instances are 

described below.

4.2 Scope of Analysis

Potential environmental impacts from the No Action Alternative and the Preferred Alternative 

for Simplot InnateTM Potato are described in detail throughout this section. An impact would be 

any change, positive or negative, from the existing (baseline) conditions of the affected 

environment (described for each resource area in Section 2.0). Impacts may be categorized as 

direct, indirect, or cumulative. A direct impact is an effect that results solely from a proposed 

action without intermediate steps or processes. Examples include soil disturbance, air emissions, 

and water use. An indirect impact may be an effect that is related to but removed from a 

proposed action by an intermediate step or process. Examples include surface water quality 

changes resulting from soil erosion due to increased tillage, and worker safety impacts resulting 

from an increase in herbicide use. 

A cumulative effects analysis is also included for each environmental issue. A cumulative impact 

may be an effect on the environment which results from the incremental impact of the proposed 

action when added to other past, present, and reasonably foreseeable future actions. Examples 

include breeding Simplot InnateTM Potato with other deregulated events. If there are no direct or 

indirect impacts identified for a resource area, then there can be no cumulative impacts. 

Cumulative impacts are discussed in Section 5.

Where it is not possible to quantify impacts, APHIS provides a qualitative assessment of 

potential impacts. Certain aspects of this product and its cultivation may be no different 

between the alternatives; those are described below. 

Although the preferred alternative would allow for new plantings of Simplot InnateTM Potato to 

occur anywhere in the U.S., APHIS will limit the environmental analysis to those areas that 

currently support potato production. 

4.3 Agricultural Production of Potato 

4.3.1 Acreage and Area of Potato Production

Acreage of potato production has decreased in recent years, whereas potato yields have increased 

dramatically. Potato acres harvested in the U.S. have ranged between 1.0 and 1.5 million acres 
51

since 1951, with highs of 1.5 million in 1953, 1966 and 1967 and lows of 1.0 million in 2008, 

2009 and 2010 (USDA NASS 2012). Per-acre yields, which averaged 397 CWT per acre in 

2011 and 401 CWT per acre in 2012 have increased eight-fold since the early 1900s and have 

doubled since the early 1960s (USDA-NASS, 2013). 

No Action Alternative: Acreage and Area of Potato Production

USDA projects potato production will increase by 4.6% between 2012 and 2021 (USDA, 2012). 

Based upon historical trends in productivity, this increase in supply is unlikely to result in an 

increase in potato acreage. Therefore, under the No Action alternative, agricultural land used for 

potato production is expected to remain at approximately the same as at present. 

Preferred Alternative: Acreage and Area of Potato Production

If APHIS chooses the Preferred Alternative, some of the Simplot InnateTM Potato events may

become commercially available to the general public. Growers who now purchase conventional 

varieties of Russet Burbank, Ranger Russet and Atlantic potato seed would have the option of 

purchasing the Simplot InnateTM varieties instead of their conventional counterparts. With the 

reduction in black spot bruising and lower levels of reducing sugars, the Ranger Russet may gain 

more market share, partially replacing the Russet Burbank. The lower levels of reducing sugars 

in the Atlantic potato may result in increased market share for that variety, as well.

However, the introduction of these varieties is not expected to have an impact on overall demand 

for potatoes. As described in the petition (Simplot, 2013a), the agronomic characteristics of the 

ten Simplot Innate events are essentially the same as their conventional counterparts, and 

therefore would be grown in the same way as their conventional counterparts. The ten Simplot 

InnateTM Potato events do not possess traits that would allow them to be grown in areas other 

than those where their conventional counterparts are grown. Therefore, under the Preferred 

Alternative, acreage dedicated to potato would remain about the same. 

Simplot’s data demonstrate no differences in morphological characteristics and agronomic 

requirements between Simplot InnateTM Potato and other potato cultivars (Simplot, 2013a) and is 

not likely to change land acreage or any cultivation practices for potato production. It is expected 

that similar agronomic practices commonly utilized in commercially available potato cultivars

would also be used by growers of Simplot Innate TM Potato. 

4.2.2 Agronomic Practices

No Action Alternative: Agronomic Practices

If APHIS chooses the No Action alternative, general production practices are expected to 

continue as they are now. 

Preferred Alternative: Agronomic Practices
52

The agronomic evaluation of the ten Simplot InnateTM Potato events is summarized in Section 7 

of the petition, with details provided in Appendix 6; analysis of disease susceptibility is 

presented in petition Appendix 8 (Simplot, 2013a). Since all ten Simplot InnateTM Potato events 

are intended for fry and chip production, agronomic evaluations were conducted in 

geographically distinct sites that represent most of the main production areas for potatoes 

destined for fry and chip production in the U.S. (Simplot, 2013a). The agronomic practices and 

pest control measures employed were location-specific and typical for potato cultivation. They 

were recommended by both regional potato extension specialists and field agronomists including 

soil preparation, fertilizer application, irrigation, cultivation and pesticide-based control methods. 

Events and untransformed varieties received identical inputs and treatments at each site. The 

following characteristics were evaluated over multi-year trials: time to emergence, vigor, leaf 

size, leaf curl, vine maturity, disease susceptibility, insect damage, yield and specific gravity. 

These trials indicated that no changes to current agronomic practices will be needed to grow the 

potatoes, thus the incorporated traits are not expected to affect agronomic practices. All events 

considered for deregulation were selected to exhibit comparable phenotypic characteristics to the 

control varieties when grown using standard industry practices. There were no differences in 

disease susceptibility that would require additional treatments, nor did the potatoes have different 

nutrient requirements that would alter fertilizer programs. Planting, cultivation, management and 

harvesting processes were not affected by the incorporated traits.

APHIS could not identify any significant changes to agricultural or cultivation practices (e.g. 

pesticide applications, tillage, irrigation, harvesting, etc.) that would result from adoption of the 

GE crop; therefore, no impact on plant diseases or pests or their management is likely to occur 

(USDA-APHIS, 2013a).

Based on these analyses, if APHIS chooses the preferred Alternative, there would be no expected 

differences in general production practices than if the No Action alternative is chosen.

4.2.3 Potato Seed Production

No Action Alternative: Potato Seed Production

If APHIS chooses the No Action Alternative, potato seed production is expected to continue as it 

is currently.

Preferred Alternative: Potato Seed Production

Since APHIS has determined that agronomic practices will be the same if the petition is 

approved (USDA-APHIS, 2013a), selection of the Preferred Alternative is not expected to result 

in any changes in potato seed production.

4.2.4 Organic Potato Production

No Action Alternative: Organic Potato Production
53

In the United States, only products produced using specific methods and certified under the 

USDA’s Agricultural Marketing Service (AMS) National Organic Program (NOP) definition of 

organic farming can be marketed and labeled as “organic” (USDA-AMS, 2010). Organic 

certification is a process-based certification, not a certification of the end product; the 

certification process specifies and audits the methods and procedures by which the product is 

produced.

The organic sector is rapidly growing both in the U.S. and the European Union (EU). Together, 

consumer purchases in these two regions made up 95 percent of estimated world retail sales of 

organic food products in 2003 (Dimitri and Oberholtzer, 2005). In 2009, world retail sales of 

organic products were estimated to be on the order of $54.9 billion (USD), up from $50.9 billion 

in 2008 (Organic Monitor, 2006).

If APHIS chooses the No Action Alternative, organic potato production is expected to continue, 

but trends in production may be affected by unpredictable variables such as demand for both 

fresh and processed organic potatoes, overseas competition and production costs. 

Preferred Alternative: Organic Potato Production Practices

Potato cultivar selection and breeding practices are similar between organic and conventional 

potato production. Risks to organic growers would be most likely to occur with accidental 

mixing of planting material or of potatoes in farming, transportation, or processing channels. 

These risks are the same as those that organic growers already experience when keeping their 

organically grown potatoes separate from potatoes grown with conventional methods. Because 

potatoes are clonally propagated, the risk of affecting seed supplies through cross-pollination is 

negligible. Organic farmers routinely plant organic seed potato material and any incidence of 

cross-pollination in production fields will not affect the harvested potatoes. 

If APHIS chooses the Preferred Alternative, organic growers would not be expected to modify

production practices, and so no impacts to organic potato production would be expected.

Some organic potatoes are grown in the same areas as conventional potatoes and some are grown 

in more isolated regions. Based on USDA data, organic potato acreage from 1997 to 2008 

showed a general increasing trend ranging from a low of 4,335 acres in 1997 to a high of 11,664 

in 2007 (USDA-ERS, 2009). 

It is important to note that the current NOP regulations do not specify an acceptable threshold 

level for the adventitious presence of GE materials in an organic-labeled product. The 

unintentional presence of the products of excluded methods will not affect the status of an 

organic product or operation when the operation has not used excluded methods and has taken 

reasonable steps to avoid contact with the products of excluded methods as detailed in their 

approved organic system plan (Ronald and Fouche, 2006; USDA-AMS, 2010) (USDA-AMS, 

2010). However, certain markets or contracts may have defined thresholds (Non-GMO-Project, 

2010).
54

4.3 Physical Environment

4.3.1 Water Resources

No Action Alternative: Water Resources

The majority of potato production utilizes irrigation as a water source. As discussed in Section 

2.3.1, agricultural production can be detrimental to water quality by adding sediments from 

erosion via surface water, and nutrient loading from fertilizers into groundwater. 

If APHIS chooses the No Action alternative, water usage for irrigation would be expected to 

continue. Supplemental irrigation may increase in some areas where potatoes have traditionally

been grown without irrigation. Potential for water quality impacts will continue. 

Preferred Alternative: Water Resources

No changes to agronomic practices which might affect water resources will be necessary to grow 

Simplot InnateTM potatoes (Simplot, 2013a). Simplot’s studies demonstrate no differences in 

morphological characteristics and agronomic requirements between Simplot InnateTM Potato and 

other potato varieties (Simplot, 2013a). Again, as with the No Action Alternative, supplemental 

irrigation may increase in some areas where potatoes have traditionally been grown without 

irrigation, and potential for water quality impacts will continue. 

A determination of nonregulated status of Simplot InnateTM potatoes is not expected to change the 

management practices currently employed for potato cultivation. Water quality impacts are 

expected to be the same under the Preferred Alternative as under the No Action Alternative.

4.3.2 Soil Quality

No Action Alternative: Soil Quality

Increased erosion potential of soil for potato production may result from fairly high tillage 

requirements, and the small amount of post-crop plant material left in the soil. Cover crops are 

often planted to help mitigate this potential.

Land management practices for potato production can affect soil quality. While practices such 

as tillage, fertilization, the use of pesticides and other management tools can improve soil health, 

they can also cause substantial damage if not properly used. Several concerns relating to 

agricultural practices include increased erosion, soil compaction, degradation of soil structure, 

nutrient loss, increased salinity, change in pH, and reduced biological activity (USDA-NRCS, 

2001). Methods to improve soil quality include careful management of fertilizers and pesticides; 

use of cover crops to increase plant diversity and limit the time soil is exposed to wind and rain; 

and, increased landscape diversity with buffer strips, contour strips, wind breaks, crop rotations, 

and varying tillage practices (USDA-NRCS, 2006). Living cover also protects against erosion, 

provides habitat and substrate for soil organisms, and increases soil organic residue inputs 

(Doran et al., 1996a). 
55

If APHIS chooses the No Action alternative, impacts on soil quality are expected to continue.

Preferred Alternative: Soil Quality

A determination of nonregulation for Simplot InnateTM Potato is not expected to change the 

management practices currently employed for potato production. If APHIS chooses the Preferred 

Alternative, potential impacts on soil quality are expected to be similar to those under the No 

Action Alternative. Bruinsma (Bruinsma et al., 2003)found no differences in soil attributable to a 

GE potato cultivar (not this trait). Simplot’s studies demonstrate that agronomic characteristics 

and cultivation practices required for Simplot InnateTM Potato production are indistinguishable 

from practices used to grow other potato varieties (Simplot, 2013a). Except for the incorporated 

traits, the ten events are substantially equivalent to their conventional counterparts, thus no 

changes in plant/soil interaction are expected. 

If APHIS chooses the preferred alternative, agricultural impacts on soil quality are expected to 

remain the same as they would if the No Action alternative is chosen.

4.3.3 Air Quality

No Action Alternative: Air Quality

If APHIS chooses the No Action alternative, emissions associated with vehicles, fugitive dust 

particles and pesticides are expected to continue. 

Preferred Alternative: Air Quality

As discussed in Section 2.3.3Air Quality, emissions associated with crop production include 

vehicular emissions from the use of farm equipment, fugitive dust particles and releases of 

pesticides. Fugitive dust can arise from fields and unpaved roadways and can be generated by 

disturbance of bare soil through vehicle traffic, harvesting operations or wind. These impacts are 

highly variable across potato growing regions and over time, depending on such factors as 

vehicle type, crop type, utilization of pesticides, method of application, soil type and weather 

conditions. 

Simplot’s analyses presented in its petition (Simplot, 2013a) demonstrate that no changes to 

agronomic practices will be required to grow Simplot InnateTM Potato. As discussed in Section 

2.3.3, agronomic practices that could affect air quality, such as soil preparation, cultivation, 

pesticide application and harvesting, were based on practices appropriate for each site, and were 

the same for the events and the controls. The results indicated that no changes from the sitespecific practices used for conventional varieties would be needed for production of the ten 

events. 

Therefore, if APHIS chooses the preferred alternative, impacts to air quality resulting from this 

action are expected to be the same as if the No Action alternative had been chosen.
56

4.3.4 Climate Change

No Action Alternative: Climate Change

If APHIS selects the No Action Alternative, impacts to climate change are expected to continue.

Preferred Alternative: Climate Change

The range and area of U.S. potato production is not likely to change under the Preferred 

Alternative. As described in the Simplot petition (Simplot, 2013a) and APHIS PPRA (USDAAPHIS, 2013a), Simplot InnateTM potatoes use identical management strategies to those for 

conventional potato production. Therefore, no changes are expected in agricultural activities that 

might affect climate change, such as machine usage and fertilizer application. Collectively, 

because the range, area, and agronomic practices of potatoes are unlikely to change following a 

determination of nonregulated status of Simplot InnateTM Potato, the agricultural impacts of 

potato production on climate change are also unlikely to change under the Preferred Alternative.

4.4. Biological Resources

4.4.1 Animal Communities

No Action Alternative: Animal Communities

If APHIS chooses the No Action Alternative, animal communities living both within and outside 

of potato fields are expected to continue to experience impacts similar to the current impacts of 

agriculture. Animals living in or near agricultural fields at the most likely to be affected by crop 

production, including aquatic communities, which may be affected by sedimentation and 

turbidity from erosion, or by pesticide runoff.

Preferred Alternative: Animal Communities

No changes in land use are expected if APHIS chooses the preferred alternative. In addition, the 

evaluation presented in the petition (Simplot, 2013a) demonstrates that changes in agronomic 

practices, including practices related to pesticide use and erosion mitigation, are not required for 

production of Simplot InnateTM Potato. In addition, there are a large number of insects that feed 

on potato leaves and other insects that feed on those pests. Many of these insects, including the 

Colorado potato beetle, potato aphid, European corn borer, potato leafhopper and potato psyllid 

are considered pests. The events have not been modified to exhibit any pesticidal activities and 

do not contain pesticide-expressing genes. No differences were observed for insects or other 

animals interacting within the potato ecosystem during the field trials, leading to the conclusion 

that the Simplot InnateTM potatoes would have the same impact on other organisms as 

conventional potatoes (Simplot, 2013a).

APHIS reviewed Simplot’s data on field trials (USDA-APHIS, 2013a) and impacts by insects, 

and concluded that Simplot InnateTM Potato would suffer no greater insect pressure than 
57

conventional potatoes (USDA-APHIS, 2013a). For example, no increase in aphid infestation or 

damage was reported in the field observations for all ten Simplot InnateTM Potato events 

(Simplot, 2013a). Similarly, although aphids are vectors for viruses such as potato virus 

Y(USDA-APHIS, 2013c), no increase in viral disease was reported in field observations for

seven of the events (Simplot, 2013a). 

In addition, since potatoes are propagated vegetatively from seed potato tuber pieces, pollination 

by bumblebees is not important to potato tuber production. Simplot InnateTM Potato has been 

genetically engineered to silence genes that lead to acrylamide formation and produce PPOs. 

Acrylamide only forms after cooking potatoes at high heat, so this toxic compound is not 

expected to be a concern for herbivores. Consumption of PPOs by animals would still occur.

Phenols occur in wide distribution of plants (Felton et al., 1989), but their biological function of 

remains unclear (Bachem et al., 1994) (Mayer, 2006). The oxidation products of PPO appear to 

play a role in general plant defense mechanisms against pathogens and pests. The relationship 

between PPO and resistance to herbivores has also been studied. PPO activity increases when 

potato leaves are wounded and at higher rates in response to regurgitant from the pest Colorado 

potato beetle (Kruzmane et al., 2002). In other plants, the increase of PPO activity is a direct 

induced defense against insect pests that decreases nutrient availability (Baldwin and Preston, 

1999; Partington et al., 1999). In addition, PPO in glandular trichomes of wild potatoes (and 

other plants) is involved in resistance to insects (Steffens, 1994) (Plaisted, 1980). However, the 

trichomes of cultivated potatoes contain low amounts of PPO which is not thought to be involved 

resistance to pests (Friedman, 1997). Phylogenetic surveys of PPO in land plants shows that the 

gene family has undergone evolutionary expansion in some plant families, but is reduced or 

absent in others, which suggests that PPO function is probably diverse (Tran et al., 2012). PPO 

has also been implicated in other functions such as buffering of plastid oxygen levels, wound 

healing, and chloroplast metabolism (Steffens, 1994).

In potato, PPO is involved in black spot bruise formation, which reduces the quality of harvested 

tubers (Bachem et al., 1994; Corsini et al., 1999; Partington et al., 1999) (Partington et al., 

1999). PPO oxidizes monophenols and o-diphenols to o-quinones, which are then further 

oxidized non-enzymatically to polyphenols. These dark-pigmented polyphenols, also referred to 

as melanins, result in the darkening of potato tissue following mechanical bruising (Thygesen et 

al., 1995).

This suggests that Simplot InnateTM Potato is expected to be unchanged relative to PPO gene 

expression and PPO levels in leaves and therefore unchanged in any potential interactions

between potato foliar PPO and foliar pathogens or pests. No consistent differences were 

observed in foliar pest and pathogens on Simplot potatoes compared to their control varieties

(Simplot, 2013a) (USDA-APHIS, 2013a). Simplot did not assess nematode damage of Simplot 

InnateTM Potato, but Osman et al. (Osman et al., 2012) suggest that PPO might be involved in 

resistance to some plant parasitic nematodes, but do not provide data demonstrating such a role 

or address the species that affect potatoes. Conversely, lower PPO levels might increase the 
58

resistance of Simplot InnateTM Potato to some nematodes. Other researchers found that tubers of 

potato cultivars resistant to the potato cyst nematode, Globodera pallida, have lower levels of 

phenols and discolored less than tubers of susceptible cultivars (Mondy et al., 1985). They

suggest that PPO-mediated tanning of nematode cysts enables eggs to remain viable in soil for a 

longer time. Lyon 1989 (Lyon, 1989) reviewed the biochemical basis for resistance of potato to 

bacterial soft rot caused by Erwinia spp. Because it is the dominant monophenol, chlorogenic 

acid has been a focus in many of these studies. Chlorogenic acid did not inhibit the in vitro

growth of Erwinia spp. or P. infestans (the causal agent of late blight), and there remains no 

proof that phenols are important in the interaction between potato and Erwinia spp. (Lyon, 

1989).

Kroner et al 2012 (Kroner and Marnet, 2012) evaluated the role of specific phenolics in 

quantitative resistance to the elicitors of two pathogens, P. infestans, the causal agent of late 

blight, and Pectobacterium atroseptiucm (synonym: E. carotovora subsp. atroseptica), the causal 

agent of bacterial soft rot. Increasing concentrations of total phenolics tended toward a positive 

correlation with quantity of symptoms due to the late blight pathogen, but were negatively 

correlated with increased tuber rot severity due to the soft rot pathogen. Because chlorogenic 

acid accumulates in response to soft rot elicitors, these authors suggest that chlorogenic acid 

could be used as a marker for resistance to soft rot (Kroner and Marnet, 2012). Since 

chlorogenic acid is a PPO substrate, silencing of PPO would not be expected to reduce the level 

of chlorogenic acid in potato tubers. 

Although animals would not be exposed to acrylamide, Simplot InnateTM Potato tubers contain 

increased levels of glutamine (Simplot, 2013a) because the enzyme asparagine synthetase also 

functions to deaminate glutamine to glutamate (USDA-APHIS, 2013a). In all of the field trials 

tested by Simplot, these differences were within the 99% tolerance intervals generated from nine 

non-GE commercial control potato varieties grown concurrently at the same field sites (USDAAPHIS, 2013a). Souba (Souba, 1991) noted that in mammalian cells, glutamine acts as a 

nitrogen donor for the biosynthesis of important compounds such as nucleotides and amino acid. 

Consumption of increased glutamine has been tested by some researchers. For example, Wang 

et al. (Wang et al., 2008) reported that intestinal dysfunction and atrophy were prevented when 

piglets’ diets were supplemented with glutamine. Similarly, Boukhettala et al. (Boukhettala et 

al., 2010) showed that adding glutamine to rat diets reduced injury to the intestinal mucosa 

following a course of chemotherapy, and Klimberg et al. (Klimberg et al., 1990) demonstrated 

that added glutamine protects rat intestinal mucosa following radiation therapy.

There were no significant differences between any of the ten events and their respective control 

varieties for mean glycoalkaloid toxin content (Simplot, 2013a). 

RNAi-mediated gene suppression generally requires sequence homology of at least 90% between 

the silencing construct and the target sequence to be successful and even higher degrees of 

homology over 21-23 nucleotide stretches (Sharp, 2001). It is not likely that the genetic 

construct components responsible for gene silencing in the Simplot events would contribute to 

silencing of genes in other non-target organisms through direct consumption of pollen by
59

pollinators or through secondary exposure of beneficial predator or parasitic arthropods or other 

potential biological control agents for potato pests (Lacey et al., 2001) since sequences from 

arthropods, bacteria, fungi and viruses are expected to be highly divergent from the sequences 

used to silence genes in the Simplot potatoes. Furthermore, indirect exposure scenarios are 

unlikely to lead to impacts to non-target predators and parasitic arthropods since 1) they may not 

receive effective doses, 2) intracellular amplification of siRNA, the active gene silencing 

component derived from dsRNA, is not widely found in insects, 3) environmental and 

physiological conditions in the gut may destroy the RNA, 4) and they may not have the 

appropriate receptors to allow transmembrane movement of dsRNA or the appropriate enzyme to 

direct RNAi (e.g. Dicer, Argonaute, RdRP, RNA and DNA helicases)(Lundgren and Duan, 

2013). 

The introduced genes did not significantly alter the observed insect pest infestation and disease 

occurrence or resulting damage in Simplot InnateTM Potato relative to the control line under the 

typical recommended pest management conditions. Therefore, APHIS concludes that based on 

the compositional similarity of Simplot potato tubers to the parent varieties, the observed 

interactions of Simplot potatoes with insects and pathogens, and the unlikely impacts of 

nontarget effects due to RNAi, APHIS concludes that the consumption of or indirect exposure to 

Simplot tubers or other plant parts is unlikely to have adverse impacts on animals in or near 

potato fields. 

Consumption of Simplot InnateTM Potato is unlikely to substantially affect non-target organisms, 

such as mammals, birds, or insects. Simplot data demonstrates that the composition of Simplot 

InnateTM Potato does not substantially differ from conventional potato varieties (Simplot, 2013a). 

Simplot indicated that they have submitted a safety and nutritional assessment of food and feed 

derived from Simplot InnateTM Potato to the FDA on February 12, 2013 (Simplot, 2013a). FDA 

is presently evaluating the submission. There is no evidence that animal exposure to Simplot 

InnateTM Potato would have any effect or be any less attractive as food, refuge, cover and nesting 

sites as non GE varieties of potatoes.

4.4.2 Plant Communities

No Action Alternative: Plant Communities

If APHIS selects the No Action Alternative, impacts to plant communities as a result of potato 

production are expected to continue. 

Preferred Alternative: Plant Communities

Simplot has presented the results of field trials which demonstrate that Simplot InnateTM potatoes 

do not require any changes to agronomic inputs when compared with conventional 

potatoes(Simplot, 2013a). There would be no change in herbicide use or patterns. 
60

The silencing of acrylamide potential leads to somewhat heightened levels of asparagine in 

Simplot InnateTM potato, but levels are within acceptable limits (OECD, 1997b). In the very

unlikely event of hybridization of Simplot InnateTM potato, resulting progeny may have increased 

levels of asparagine. Plants use asparagine as a nitrogen source when they are unable to store 

nitrogen in the form of protein, and can accumulate to very high concentrations (Halford et al., 

2012b). 

As discussed in Section 4.4.1, Animal Communities, consumption of Simplot InnateTM Potato is 

not expected to change herbivore-plant interactions. 

Under the Preferred Alternative, potential impacts to plant communities are not anticipated to be 

different compared to the No Action Alternative.

Land use and agricultural production of potatoes under the Preferred Alternative is likely to 

continue as currently practiced. Consequently, any impact to plant communities as a result of 

potato production practices under the Preferred Alternative is the same as the No Action 

Alternative.

4.4.3 Gene Flow and Weediness

No Action Alternative: Gene Flow and Weediness

If APHIS selects the No Action Alternative, there would continue to be little problem with gene 

flow or weediness for potato.

Preferred Alternative: Gene Flow and Weediness

If APHIS selects the Preferred Alternative, no changes in agronomic practices are expected to 

occur (USDA-APHIS, 2013a) which might make potato, including Simplot InnateTM Potato 

more susceptible to gene flow or weediness.

4.4.4 Microorganisms

No Action Alternative: Microorganisms

If APHIS chooses the No Action Alternative, potato crop interactions with microorganisms are 

expected to remain the same. 

Preferred Alternative: Microorganisms

The evaluation presented in the petition (Simplot, 2013a) demonstrates that changes in 

agronomic practices, including practices related to soil preparation (which may impact soil 

organic material and pH) and to pesticide application (which may directly impact 

microorganisms), would not be required for production of the ten Simplot InnateTM Potato

events. In addition, the ten Simplot InnateTM Potato events are substantially similar to their 
61

conventional counterparts. Simplot InnateTM Potato would therefore be expected to have the 

same interactions with soil microorganisms.

A safety assessment of mice fed a diet of GE non-browning potatoes showed no adverse effects 

in mouse gut microbiota (Llorente et al., 2011).

Based on these results, if APHIS chooses the preferred alternative, impacts to microorganisms 

resulting from this action are expected to be the same as if the No Action Alternative is chosen.

4.4.5 Biodiversity

Potato biodiversity can be enhanced by the introduction of new genetic material from the large 

number of existing genetic resources available.

No Action Alternative: Biodiversity

If APHIS chooses the No Action alternative, increases in potato productivity are expected to 

continue to offset increased demand, resulting in a fairly constant acreage devoted to potato 

production in the U.S. This will allow for continued biodiversity outside the borders of 

agricultural fields. Biodiversity is expected to continue to be fairly low within agricultural fields.

Preferred Alternative: Biodiversity

The evaluation presented in the petition (Simplot, 2013a) demonstrates that changes in 

agronomic practices would not be required for production of the ten events. Based on these 

results, if APHIS chooses the Preferred Alternative, any impacts to biodiversity would be 

expected to be the same as if the No Action Alternative is chosen.

In addition, if APHIS chooses the Preferred Alternative, potato diversity will be enhanced by the 

introduction of the new events. 

Under the Preferred Alternative, cultivation, management, and land-use decisions related to 

Simplot InnateTM potatoes are not different from conventional potato cultivars. Agronomic 

practices associated with potato such as cultivation, irrigation, pesticide application, fertilizer 

applications and agriculture equipment would be unchanged. Animal and plant species that 

typically inhabit potato fields will continue to be affected by currently used management plans 

and systems, which include the use of mechanical, cultural, and chemical control methods. The 

consequences of current agronomic practices associated with potato production on the 

biodiversity of plant and animal communities are unlikely to be altered.

Consequently, any impact to biodiversity as a result of potato production practices under the 

Preferred Alternative is likely to be identical to the No Action Alternative.

4.4.6 Human Health 

Potato is primarily grown for human consumption. U.S. per capita potato consumption is 

approximately 112 pounds per year. Of this, approximately 65 pounds is used for frozen fries or 
62

chips. Per capita consumption data are shown in Table 6. As discussed in Section 2.5, potential 

toxins in potatoes are acrylamide, which forms subsequent to high-temperature cooking, and 

glycoalkaloids. Patatin is allergenic to a very small percent of children.

No Action Alternative: Human Health

Under the No Action alternative, consumption of potatoes would be expected to continue at the 

same rate as currently. Consumers will continue to be exposed to similar levels of acrylamide in 

cooked potatoes if other methods are not employed to reduce levels. Glycoalkaloids would be 

expected to remain at sufficiently low levels such that health impacts would not occur. Patatin 

would remain a concern for allergic individuals.

Preferred Alternative: Human Health

If APHIS chooses the Preferred Alternative, and Simplot InnateTM Potato is widely adopted, 

acrylamide content in cooked potatoes should be significantly reduced, leading to health benefits 

for consumers. Compared with conventional potatoes, Simplot InnateTM Potato contains, on 

average, 58 to 72 percent less acrylamide when cooked (NTP, 2011; Simplot, 2013a). As 

discussed in Section 2.2.6, Human Health, the State of California listed acrylamide as a potential 

carcinogen under Proposition 65 in 1990 and established a No Significant Risk Level (NSRL) of 

0.2 μg/day(CEPA-OEHHA, 2005), which was later revised to 1.0 μg/day (CEPA-OEHHA, 

2005). The FDA is considering issuing guidance concerning safety of acrylamide (FDA, 2009), 

and in 2013, published (FDA, 2013b) recommendations that health-conscious consumers may

want to avoid the consumption of fried potato products. Especially since American consumption 

of French fries is high (USDA-NASS, 2012c), these developments regarding acrylamide safety 

may lead to processor preference for Simplot InnateTM Potato in French fries and other frozen 

potato products. 

The data presented in the petition shows that the Simplot InnateTM Potato events are at least as 

safe and nutritious for food as the untransformed controls (Simplot, 2013a). The compositional 

analyses of the ten events are summarized in the petition, with detailed results in Appendix 9 

(Simplot, 2013a). The compositional assessments determined the amounts of 1) moisture, 

protein, total fat, ash, crude fiber, carbohydrate and calories; 2) vitamins B6, B3 and C; 3) 

minerals copper, magnesium and potassium; 4) glycoalkaloids; 5) free amino acids; and 6) total 

amino acids for tubers collected from events grown in 2009, 2010, and 2011 in potato-growing 

areas of the United States. Observed changes in ASN and reducing sugars accomplished through 

transformation of various potato varieties resulted in lower acrylamide levels in French fries and 

potato chips. These modifications did not alter the quality of potato as food because all results

fell within normal ranges for potato. In addition, the research confirmed that glycoalkaloid levels 

were unchanged compared with the control varieties. 

The potato events described in this petition are no different compositionally compared to 

untransformed controls, except for the intended traits. Therefore, issues with allergies would not 

be expected to exist beyond what individuals with potato allergies would normally experience. 

The National Academy of Sciences (NAS) has ranked methods of genetic modification 

according to the relative likelihood of unintended effects, such as the increase in a plant’s 
63

production of certain allergens. The NAS considered methods that involve recombinant DNA 

via Agrobacterium transfer of genes from closely related species (the Simplot InnateTM method 

used to produce these ten events is one such method that does not involve the transfer of genes) 

to be among the methods least likely to have unintended effects – less likely than conventional 

pollen-based crossing of closely related species – and far less likely than methods such as 

ionizing radiation and chemical mutagenesis, which are not subject to regulation and are not 

excluded methods under the NOP (Sciences, 2004). 

Worker Safety 

No Action Alternative: Worker Safety

If APHIS were to choose the No Action alternative, farm workers would continue to be exposed 

to the same kinds of hazards as they are currently. 

Preferred Alternative: Worker Safety

There will be no changes in agronomic practices in order to produce Simplot InnateTM Potato. If 

APHIS chooses the preferred alternative, impacts to worker health resulting from approval of the 

petition are expected to be the same as if the No Action Alternative is chosen. 

Under the Preferred Alternative, cultivation practices and corresponding worker exposures to 

agronomic inputs are unlikely to change. Simplot demonstrates in its petition that the agronomic 

inputs required to cultivate Simplot InnateTM Potato are functionally equivalent to those required 

for conventional potatoes (Simplot, 2013a). Accordingly, the health and safety protocols 

currently employed by farm workers in the production of potatoes do not require changes to 

accommodate the production of Simplot InnateTM potatoes.

Based on these findings, APHIS has determined that approval of a petition for nonregulated 

status of Simplot InnateTM Potato will not impact worker safety. 

4.4. 7 Animal Feed

No Action Alternative: Animal Feed

As discussed in Section 2.6, Animal Feed, a small portion of the potato crop and waste from 

processing are sold as livestock feed. If APHIS selects the No Action Alternative, a small 

percent of the potato crop would continue to be used for livestock feed.

Preferred Alternative: Animal Feed

The compositional analyses of the ten Simplot Innate events are summarized in Section 8 of the 

petition, with detailed results in Appendix 9 (Simplot, 2013a). 

In conclusion, the data presented in the petition shows that potatoes from the events are as safe 

and nutritious for feed as the untransformed controls, and if APHIS were to choose the preferred 
64

alternative, the use of potatoes as livestock feed would be no different than if the No Action 

alternative was chosen.

4.5 Socioeconomic Impacts

4.5.1 Domestic Economic Environment

No Action Alternative: Domestic Economic Environment

The domestic economic environment is discussed in Section 2.7, Socioeconomic: Domestic 

Economic Environment, and potato utilization in the U.S. is summarized in Table 8. Potatoes 

are grown on approximately 1.1 million acres in the U.S., with an annual value of approximately

$3.5 billion. Major products include fresh potatoes, frozen fries and chips. Organic potatoes 

account for less than one percent of the market.

If APHIS chooses the No Action alternative, domestic potato production, including organic 

production, is expected to continue at rates similar to the present. The USDA projects an 

approximate 4.6% increase in production between 2012 and 2021 (USDA, 2012).

Preferred Alternative: Domestic Economic Environment

If APHIS chooses the Preferred Alternative, the ten Simplot InnateTM Potato events will become 

available for commercial production. Because of the reduced black spot bruise of Simplot 

InnateTM Potato, it is expected that wastage will decrease significantly, and therefore, revenues 

will increase. Consumers are likely to be willing to pay a premium for a healthier food product 

(such as reduced acrylamide and black spot bruise) developed by methods of biotechnology 

which use no foreign DNA (Huffman, 2010); (Colson et al., 2011). Overall, if APHIS chooses 

the Preferred Alternative, the introduction of Simplot InnateTM events are likely to have positive 

economic impacts, recognizing that some additional costs could be incurred, and as discussed in 

Section 4.1, no impacts on organic production are expected.

Potatoes with low acrylamide potential and reduced black spot bruise are expected to have higher 

market value for the same inputs, representing potential increased revenue for growers and 

processors, and an overall increase in the value of potato production. The initial crop 

introduction will build up slowly as seed becomes available and will be controlled within 

existing processing channels to ensure that potatoes enter only the intended markets. This will 

provide a period of time to assess consumer acceptance and to address grower and industry

concerns. A limited introduction that is initially in a vertically integrated supply chain will be 

well controlled by grower and processor agreements. In this situation, conventional products 

will be considered “identity preserved” with respect to the well-controlled stewardship of the 

potato event(s) and its products. As adoption of the potato events increases, programs for 

identity preservation will be implemented as needed. It is expected that development and 

implementation of identity preservation systems will add some cost to the supply chain; the total 

costs will depend upon the type and extent of market penetration (Simplot, 2013a). 
65

4.5.2 Trade Economic Environment

As discussed in Section 2.7, Socioeconomic: Trade Economic Environment, the U.S. exports 

more than $1 billion in potato products annually, primarily consisting of frozen fries and other 

processed potatoes. Demand from Canada, Mexico and Asia is driving growth in exports. 

Japan is the largest market for U.S. exports of frozen potatoes, while Canada is the largest U.S. 

export market for chips and fresh potatoes. The U.S. also has substantial imports of potatoes and 

potato products from Canada and Mexico (USDA-ERS, 2012a). 

No Action Alternative: Trade Economic Environment

If APHIS chooses the No Action alternative, U.S. potato exports are expected to continue.

Preferred Alternative: Trade Economic Environment

If APHIS chooses the preferred alternative, U.S. potato exports are expected to continue. 

Approval for the events will be sought in Canada, Japan and Mexico (Simplot, 2013) prior to 

commercial production beginning in the U.S. 

Previous recalls of potato products that were shipped to Japan and then found to contain 

genetically modified material were related to unapproved events; Japan has zero tolerance for 

unapproved events (Reuters, 2001). To assist in the prevention of trade disruptions, as has been

experienced with other potato events, international approvals will be pursued from key trading 

partner countries prior to beginning commercial production in the U.S. Simplot intends to follow 

the recommended stewardship policy statement released by the Biotechnology Industry

Organization in May 2007: 

To help ensure the continued adoption of agricultural biotechnology globally and to 

continue to have products of agricultural biotechnology bring value to the marketplace, 

BIO’s Food and Agriculture Section supports actions that facilitate the flow of goods in 

commerce and minimize trade disruptions. BIO’s Food and Agriculture Section believes 

that henceforth individual member companies should, prior to commercialization meet 

applicable regulatory requirements in key countries identified in a market and trade 

assessment that have functioning regulatory systems and are likely to import the new 

biotechnology-derived plant products.

The voluntary guideline was adopted because, according to BIO “asynchronous authorizations 

combined with importing countries maintaining ‘zero tolerance’ for recombinant-DNA products 

not yet authorized results in the potential for major trade disruptions. The potential occurrences 

of trade disruptions will only increase given the substantial amount of research that will bring 

many new products and combinations of products to market.”

In addition, compared to some biotech crops, the Simplot InnateTM Potato is expected to be 

viewed more favorably by regulatory organizations due to the lack of pesticidal traits and 

marker-free transformation methods, and therefore have fewer implications for export markets. 

In any case, these approvals should ensure continued trade with key export markets. 
66

If APHIS chooses the preferred alternative, as with the domestic economic environment, the 

introduction of these potato events may have positive economic impacts on export markets, 

recognizing that some additional costs could be incurred. Impacts to export markets will be 

mitigated by approvals in key trading countries such as Japan, Canada, and Mexico.

5 CUMULATIVE IMPACTS

A cumulative impact may be an effect on the environment which results from the incremental 

impact of the proposed action when added to other past, present, and reasonably foreseeable 

future actions. For example, the potential effects associated with a determination of 

nonregulated status for a GE crop in combination with the future production of crop seeds with 

multiple deregulated traits (i.e., “stacked” traits), including drought tolerance, herbicide 

tolerance, and pest resistance, would be considered a cumulative impact. 

Regulations promulgated by the Council on Environmental Quality (CEQ) under the National 

Environmental Policy Act (NEPA) define cumulative impact as “the impact on the environment 

which results from the incremental impact of the action when added to other past, present and 

reasonably foreseeable future actions” (40 CFR 1508.7). For example, the potential effects 

associated with a determination of nonregulated status of a GE crop in combination with the 

future production of crop plants with multiple traits that are no longer subject to the regulatory

requirements of 7 CFR Part 340 or the plant pest provisions of the Plant Protection Act, 

including disease tolerance, nitrogen utilization, and herbicide tolerance, would be considered a 

cumulative impact.

5.1 Assumptions Used for Cumulative Impacts Analysis

Cumulative effects have been analyzed for each environmental issue assessed in Section 4, 

Environmental Consequences. The cumulative effects analysis is focused on the incremental 

impacts of the Preferred Alternative taken in consideration with related activities including past, 

present and reasonably foreseeable future actions. In this analysis, if there are no direct or 

indirect impacts identified by a resource area, then APHIS assumes there can be no cumulative 

impacts. APHIS provides a qualitative assessment of potential cumulative impacts.

APHIS considered the potential for Simplot InnateTM Potato to extend the range of potato 

production and affect the conversion of land to agricultural purposes. Simplot’s studies 

demonstrate that agronomic characteristics and cultivation practices required to produce Simplot 

InnateTM Potato are indistinguishable from practices used to grow conventional potatoes 

(Simplot, 2013a; USDA-APHIS, 2013a). This implies that its cultural requirements would 

neither differ from other potatoes nor change the areas where potatoes are currently grown. If 

the petition is approved, Simplot InnateTM Potato could replace other commercially available 

potato cultivars, without requiring production of new, natural lands. As such, land use changes 

associated with approving the petition are not expected to be any different than those associated 

with conventional potato production. APHIS focused the analysis of cumulative impacts on the 

areas in the U.S. that currently produce potatoes.
67

Potential reasonably foreseeable cumulative effects are analyzed under the assumptions that 

growers have used in the past and would continue to use reasonable, commonly accepted best 

management practices (BMPs) for their chosen system and cultivars during potato production. 

APHIS recognizes, however, that not all growers will use such BMPs. Thus, the cumulative 

impact analysis will make the assumption that not all growers would do so.

5.2 Past and Present and Reasonably Foreseeable Actions

The Preferred Alternative is not expected to directly cause a measurable change in agricultural 

acreage or area devoted to potato production in the U.S. Because Simplot InnateTM Potato is 

another potato cultivar that is agronomically and compositionally similar to other commercially

available potato cultivars, it is expected that Simplot InnateTM Potato would replace other similar 

cultivars without expanding the acreage of area devoted to potato production. There are also no 

anticipated changes to the availability of non-GE potato cultivars on the market.

Approving the petition for a determination of nonregulated status for Simplot InnateTM Potato is 

not expected to result in changes to current potato production practices. Studies conducted by 

Simplot demonstrate that agronomic characteristics and cultivation practices required for 

Simplot InnateTM Potato are indistinguishable from practices used to grow other potato cultivars 

(Simplot, 2013a; USDA-APHIS, 2013a). Consequently, no changes to current potato production 

practices associated with the adoption of Simplot InnateTM Potato are expected.

Organic growers use common practices to maintain the organic status of their potatoes including 

employing adequate isolation distances between the organic potato field and the fields of 

neighbors to minimize the chance that pollen will be carried between the fields. Given the 

importance of maintaining varietal traits and consumer recognition and preference for specific 

potato cultivars, the separation of production and processing of potatoes by cultivars have been 

utilized by growers, packers and retailers in the United States market to satisfy consumer 

preference and demand. Availability of another potato cultivar, such as Simplot InnateTM Potato, 

under the Preferred Alternative, is not expected to impact the organic production of potatoes any 

differently than other potato cultivars currently being grown. 

Based on the information described in Section 4.5.1, Domestic Trade Environment, APHIS 

concludes that a determination of nonregulated status of Simplot InnateTM Potato will have no 

foreseeable adverse cumulative effects on domestic commerce. Simplot InnateTM Potato has the 

potential to improve potato processing capabilities and also improve the economics of potato 

processing and consumer nutrition. There may also be a reduction in cost of processing 

associated with a reduction in potato browning and in providing alternatives to conventional 

technologies to prevent browning. Based on these factors, no net negative cumulative impacts on 

domestic economics have been identified associated with the production of Simplot InnateTM 

Potato. 

Approving the petition for a determination of nonregulated status to Simplot InnateTM Potato 

would have the same impacts to water, soil, air quality, and climate change as that of potato 

cultivars currently available. Agronomic practices that have the potential to impact soil, water 

and air quality, and climate change would not change because Simplot InnateTM Potato is 
68

agronomically similar to other potato cultivars. Because of its similarity to other potato cultivars, 

adoption of Simplot InnateTM Potato is expected to replace other similar cultivars without 

changing the acreage or area of potato production that could impact water, soil, air quality, and 

climate change. Cumulative impacts due to climate change would be the same for Simplot 

InnateTM events and conventional potatoes. Potato production in the United States has a fairly 

small production footprint (approximately 1 million acres,(USDA-NASS, 2012b)) when 

compared to row crops like corn (approximately 97 million) and soybeans (approximately 86 

million acres). Considering the production acres, potatoes, including the Simplot InnateTM Potato 

varieties, will have less impact on climate change than the higher acreage crops. 

Cumulative impacts of the Preferred Alternative to microorganisms and biodiversity would not 

be significantly different than that experienced under the No Action Alternative. Simplot

InnateTM Potato is agronomically and compositionally similar to other potato cultivars. 

Cumulative impacts to plant communities resulting from gene flow or weediness potential would 

be the same for Simplot InnateTM Potato events and conventional potatoes. Multiple years of 

field data as well as compositional analysis show that Simplot InnateTM Potato events are 

agronomically equivalent to conventional potatoes. Also, no changes were observed in land use 

or agronomic inputs including pesticides and herbicides. Gene flow from potatoes whether 

biotech or conventional is unlikely due to the cropping practices of rotation and the clonal 

propagation of potato varieties in U.S. agriculture. Thus, it would not require any different 

agronomic practices to produce, and does not represent a safety or increased weediness risk that 

is any different from other currently available potatoes. There are no differences in the potential 

for gene flow and weediness under the Preferred Action Alternative. Outcrossing and weediness 

are addressed in the PPRA (USDA-APHIS, 2013a). Simplot InnateTM Potato is similar to other 

potato cultivars. The risk of gene flow and weediness of Simplot InnateTM Potato is no greater 

than that of other potato cultivars. 

Cumulative impacts to animal communities would be the same for Simplot InnateTM Potato 

events and conventional potatoes. Three years of field data as well as compositional analysis and 

molecular stability show that Simplot InnateTM Potato events are equivalent to conventional 

potatoes. Even in cases where asparagine was lower (for reducing acrylamide), the levels were 

still within the combined literature ranges. In addition, no changes were observed in land use or 

agronomic inputs including pesticides. These data show that there is the same impact (and 

expected cumulative impacts) on non-target animals or animal communities within the potato 

agroecosystem for Simplot InnateTM events as the conventional potatoes (Simplot, 2013a). 

Animals consuming Simplot InnateTM Potato may be exposed to increased levels of glutamine, 

but research on dietary supplementation with glutamine has not had any negative animal health 

effects.

Cumulative effects on human consumer health are expected to be the same for Simplot InnateTM 

Potato events and conventional potatoes, with one exception: the Simplot InnateTM Potato 

contains significantly less acrylamide-forming potential than conventional potatoes. This should 

result in significant human health benefits, particularly for those with a diet high in French fries 

and other baked and/or fried potato products. Compared with the conventional varieties, Simplot 

InnateTM Potato contained on average 58 to 72 percent less acrylamide (Simplot, 2013a). 

Adoption of these potatoes could result in a significant reduction in dietary intake of acrylamide 
69

and decrease exposure to this naturally occurring substance found to cause cancer in laboratory

animals (NTP, 2011).

In addition, glycoalkaloid levels in Simplot InnateTM Potato were unchanged compared with the 

control varieties (Simplot, 2013a).Although patatin was not measured during the studies, total 

protein did not differ between Simplot InnateTM and conventional potatoes and it was concluded 

that any potential allergy to patatin would be the same. 

Cumulative impacts to worker safety would be expected to be the same for Simplot InnateTM 

Potato events and conventional potatoes.

Similarly, Simplot InnateTM Potato is not expected to have any adverse effects on livestock. 

Simplot submitted a safety and nutritional assessment of food and feed derived from Simplot 

InnateTM Potato to the FDA on date February 12, 2013(BNF No. 141). FDA is presently

evaluating the submission. No change in food and feed safety is expected to occur under the 

Preferred Alternative. 

Cumulative impacts on the domestic economic environment would be similar for Simplot 

InnateTM Potato events and conventional potatoes, although some economic impact is expected 

because of the benefits of the new potatoes. These events grow similarly and have similar 

biochemical composition to conventional potatoes, however, the low acrylamide, reducing 

sugars, and black spot bruise traits add value that could increase the price received for these 

potatoes. Potatoes with low acrylamide potential and reduced black spot bruise are expected to 

have higher market value for the same inputs, representing potential increased revenue for 

growers and processors, and an overall increase in the value of potato production. 

Cumulative impacts to the trade economic environment would be similar for Simplot InnateTM 

events and conventional controls, although some economic impact is expected because of the 

benefits of the new potatoes. The U.S. exports more than $1 billion in potato products annually, 

primarily consisting of frozen fries and other processed potatoes (Council, 2013). Japan is the 

largest market for U.S. exports of frozen potatoes, while Canada is the largest U.S. export market 

for chips and fresh potatoes (Council, 2013). 

Introduction of Simplot InnateTM Potato will require channeling of the new potatoes into the 

desired markets. The careful supply chain introduction would be similar to all potato variety 

management systems already in place for product purity. It is expected that development and 

implementation of identity preservation systems will add some cost to the supply chain; the total 

costs will depend upon the type and extent of market penetration (Simplot, 2013a). The Simplot 

InnateTM Potato could have cumulative economic impacts on the domestic potato market and 

procedures will be developed to manage product purity in the supply chain.

Upon introduction, procedures will be implemented to prevent unintended mixing of Simplot 

InnateTM with conventional potatoes as part of the stewardship program. In addition, Simplot is 

seeking international regulatory approvals in areas such as Japan and Mexico for import 

approval. Also, approval in Canada is being sought for import and cultivation. Approval in these 

key trading countries will minimize market disruption should a low level presence of Simplot 
70

InnateTM potatoes be found in the market from accidental mixing. In conclusion, the Simplot 

InnateTM potatoes could have cumulative trade economic impacts on the potato export market 

and procedures will be developed to manage product purity in the supply chain.

In conclusion, Simplot InnateTM Potato may offer protection against black spot bruise, slight 

changes in reducing sugars, and reduced acrylamide potential. During processing, potatoes are 

routinely culled out due to black spot bruise when making French fries or potato chips, however, 

with Simplot InnateTM Potato, fewer potatoes will be lost to black spot bruise, resulting in less 

waste. As a result, there could be increases in yield, with associated positive environmental 

impacts related to land use and agricultural inputs. For the purposes of the cumulative impacts 

discussion, however, it is assumed conservatively that land use and inputs would potentially

decline or remain the same, and are unlikely to increase. Reduced levels of acrylamide in 

cooked potatoes will benefit human health.

6 THREATENED AND ENDANGERED SPECIES

The Endangered Species Act (ESA) of 1973, as amended, is one of the most far-reaching 

wildlife conservation laws ever enacted by any nation. Congress passed the ESA to prevent 

extinctions facing many species of fish, wildlife and plants. The purpose of the ESA is to 

conserve endangered and threatened species and the ecosystems on which they depend as key

components of America’s heritage. To implement the ESA, the U.S. Fish & Wildlife Service 

(USFWS) works in cooperation with the National Marine Fisheries Service (NMFS), other 

Federal, State, and local agencies, Tribes, non-governmental organizations, and private citizens. 

Before a plant or animal species can receive the protection provided by the ESA, it must first be 

added to the Federal list of threatened and endangered wildlife and plants.

A species is added to the list when it is determined by the USFWS/NMFS to be endangered or 

threatened because of any of the following factors:

 The present or threatened destruction, modification, or curtailment of its habitat or 

range;

 Overutilization for commercial, recreational, scientific, or educational purposes;

 Disease or predation;

 The inadequacy of existing regulatory mechanisms; and

 The natural or manmade factors affecting its survival.

Once an animal or plant is added to the list, protective measures apply to the species and its 

habitat. These measures include protection from adverse effects of federal activities. 

Section 7 (a)(2) of the ESA requires that federal agencies, in consultation with USFWS and/or 

the NMFS, ensure that any action they authorize, fund, or carry out is “not likely to jeopardize 

the continued existence of a listed species or result in the destruction or adverse modification of 

designated critical habitat.” It is the responsibility of the federal agency taking the action to 

assess the effects of their action and to consult with the USFWS and NMFS if it is determined 

that the action “may affect” listed species or designated critical habitat. To facilitate their ESA 

consultation requirements, APHIS met with the USFWS from 1999 to 2003 to discuss factors 
71

relevant to APHIS’ regulatory authority and effects analysis for petitions for nonregulated status

and developed a process for conducting an effects determination consistent with the Plant 

Protection Act (PPA) of 2000 (Title IV of Public Law 106-224). APHIS uses this process 

to help fulfill its obligations and responsibilities under Section 7 of the ESA for 

biotechnology regulatory actions. 

APHIS met with USFWS officials on June 15, 2011, to discuss whether APHIS has any 

obligations under the ESA regarding analyzing the effects of herbicide use associated with all 

GE crops on TES. As a result of these joint discussions, USFWS and APHIS have agreed that it 

is not necessary for APHIS to perform an ESA effects analysis on herbicide use associated with 

GE crops currently planted because EPA has both regulatory authority over the labeling of 

pesticides and the necessary technical expertise to assess pesticide effects on the environment 

under FIFRA. APHIS has no statutory authority to authorize or regulate the use of pesticides 

used by potato growers. Under APHIS’ current Part 340 regulations, APHIS only has the 

authority to regulate the InnateTM Potato or any GE organism as long as APHIS believes they

may pose a plant pest risk (7 CFR § 340.1). APHIS has no regulatory jurisdiction over any

other risks associated with GE organisms including risks resulting from the use of herbicides or 

other pesticides on those organisms. 

After completing a plant pest risk analysis, if APHIS determines that seeds, plants, or parts

thereof from Simplot InnateTM Potato do not pose a plant pest risk, then these articles would no 

longer be subject to the plant pest provisions of the PPA or to the regulatory requirements of 7 

CFR Part 340, and therefore, APHIS must reach a determination that these articles are no longer 

regulated. As part of its EA analysis, APHIS is analyzing the potential effects of these potato 

events on the environment including, as required by the ESA, any potential effects to threatened 

and endangered species and critical habitat. As part of this process, APHIS thoroughly reviews 

the GE product information and data related to the organism (generally a plant species, but may

also be other genetically engineered organisms). For each transgene/transgenic plant, APHIS 

considers the following: 

 A review of the biology and taxonomy of the crop plant and its sexually compatible 

relatives;

 Characterization of each transgene with respect to its structure and function and the 

nature of the organism from which it was obtained;

 A determination of where the new transgene and its products (if any) are produced in 

the plant and their quantity;

 A review of the agronomic performance of the plant, including disease and pest 

susceptibilities, weediness potential, and agronomic and environmental impacts;

 Determination of the concentrations of known plant toxicants (if any are known in the 

plant);

 Analysis to determine if the transgenic plant is sexually compatible with any 

threatened or endangered species (TES) of plants or a host of any TES; and

 Any other information that may inform the potential for an organism to pose a plant 

pest risk.

In following this review process, APHIS, as described below, has evaluated the potential effects 

that a determination of nonregulated status of the potato events may have, if any, on federally-
72

listed TES species and species proposed for listing, as well as designated critical habitat and 

habitat proposed for designation.

Based upon the scope of the EA and production areas identified in the Affected Environment 

section of the EA, APHIS reviewed the USFWS list of TES species (listed and proposed) for 

each state where potato is commercially produced from the USFWS Environmental 

Conservation Online System (ECOS; as accessed February 19, 2014 at 

http://ecos.fws.gov/tess_public/pub/stateListingAndOccurrence.jsp) , (USDA-APHIS, 2014c; 

2014a). Prior to this review, APHIS considered the potential for Simplot InnateTM Potato to 

extend the range of potato production and also the potential to extend agricultural production 

into new natural areas. APHIS has determined that agronomic characteristics and cultivation 

practices required for Simplot InnateTM Potato are essentially indistinguishable from practices 

used to grow other potato varieties (USDA-APHIS, 2013b; 2013a),(Simplot, 2013a). Simplot 

InnateTM Potato may be expected to replace other varieties of potato currently cultivated, and 

APHIS does not expect the cultivation of Simplot InnateTM Potato to result in new potato acres 

to be planted in areas that are not already devoted to agriculture. Accordingly, the issues 

discussed herein focus on the potential environmental consequences of the determination of 

nonregulated status of Simplot InnateTM Potato on TES species in the areas of the US where 

potatoes are currently grown.

JR Simplot has used a genetic engineering approach to introduce into the background of 

commercial potato cultivars two traits that are of interest to potato consumers, producers and 

processors: reduced acrylamide potential in certain processed or heated potato products and 

reduced black spot bruise (Simplot, 2013a; Simplot, 2013b). Simplot used the single construct 

pSIM1278 to transform 5 different commercial parent varieties and created the ten events

described in the petition. The objective was to incorporate the same new phenotypes into each 

of these important varieties, while maintaining all of the desirable characteristics originally

selected by potato breeders (Simplot, 2013a). Unlike most GE agricultural products that have 

been commercialized to date, the transformation in this instance does not result in production of 

proteins. The inserted DNA contains silencing cassettes that, when expressed, generate 

variably-sized and unprocessed transcripts. These transcripts trigger the degradation of mRNAs 

that would normally code for an enzyme, like asparagine synthetase. This results in much 

reduced levels of the targeted “silenced” enzymes (Simplot, 2013a). As described in the petition 

and PPRA, the potato lines were transformed to silence four different genes in potato: 

asparagine synthetase-1 (Asn1), polyphenol oxidase-5 (Ppo5), potato phosphorylase L (PhL) 

and the starch-associated R1 gene (R1). The suppression of Asn1 results in potatoes with 

reduced free asparagine, and the suppression of PhL and R1 results in potatoes with a lower 

content of reducing sugars. Collectively, the silencing of these 3 genes should result in potato 

tubers with a reduced acrylamide potential. The suppression of Ppo5 confers the Simplot 

InnateTM Potato with a non-browning phenotype resulting in tubers with reduced black spot 

bruising(Simplot, 2013a), (USDA-APHIS, 2013b). 

For its analysis on TES plants and critical habitat, APHIS focused on the agronomic differences 

between Simplot InnateTM Potato and potato varieties currently grown; the potential for 

increased weediness; and the potential for gene movement to native plants, listed species, and 

species proposed for listing. 
73

For its analysis of effects on TES animals, APHIS focused on the implications of exposure to 

Simplot InnateTM Potato, and the potential for an effect resulting from the gene silencing activity

that sets Simplot InnateTM Potato apart from other potato lines currently in production. 

Potential Effects of Simplot InnateTM Potato on TES and Critical Habitat

Threatened and Endangered Plant Species and Critical Habitat

The agronomic and morphologic characteristics data provided by JR Simplot were used in the 

APHIS analysis of the weediness potential for Simplot InnateTM Potato, and further evaluated for 

the potential to impact TES and critical habitat. Agronomic studies conducted by JR Simplot 

over several years tested the hypothesis that there would be no change in agronomic practices 

used to produce Simplot InnateTM Potato in comparison with conventional potato (Simplot, 

2013a; Simplot, 2013b). Agronomic evaluations were conducted in geographically distinct sites 

selected to represent most of the main production areas for each of the five varieties. 

Characteristics evaluated included time to emergence, vigor, leaf size, leaf curl, vine maturity, 

disease susceptibility, insect damage, yield, specific gravity, and abiotic stressors (frost, hail, 

heat, herbicide, and wind) (Simplot, 2013b). Five events (F37, E12, E24, G11 and H37) had 

statistically significant increased plant vigor, but the relative difference was small. Five events 

(F10, F37, E24, G11 and H37) had significant reductions in total yield. There was no obvious 

correlation between decreased yield and increased disease or pest stress except possibly for event 

G11, since greater insect stress was observed than in the parental control at four of 48 insect 

observations on this event. Event J55 had significantly reduced early emergence (Simplot, 

2013a). However, no differences were detected between the transformed potato lines and 

conventional potato in growth, reproduction, or interactions with pests and diseases, that would 

indicate a significant change in agronomic practices would be necessary for the commercial 

production of these transformed lines (Simplot, 2013a). 

Potatoes are not known to be weedy or persistent; they are incapable of survival outside of 

cultivation (Holm et al., 1979), (Love, 1994b), (Muenscher, 1980a), (OECD, 1997a; 1997b). 

Potato tubers have a fairly low frost tolerance; shallow tubers and those exposed to the surface 

are often destroyed by frost, but in temperate climates up to 20% of tubers left in the soil show 

no dormancy and will sprout the next season (Andersson and de Vicente, 2010). Volunteer 

potatoes, growing from overwintered tubers, can be a weed problem in the following crop but are 

easily controlled with cultivation and herbicides and do not persist as weeds for more than a few 

years (Andersson and de Vicente, 2010). 

The data presented by Simplot demonstrate that Simplot InnateTM Potato is, for the most part,

phenotypically and agronomically similar to the respective parent varieties and do not exhibit 

meaningful changes in characteristics that would make them weedier or more persistent than 

their respective parent varieties (Simplot, 2013a). Because of the reductions in emergence and 

yield, some of the Simplot InnateTM Potato events appear to have a reduced potential for 

weediness (USDA-APHIS, 2013a). Furthermore, JR Simplot did not observe any differences 

during the completed post-harvesting volunteer monitoring of the Simplot InnateTM Potato field 

test sites from 3 years of field testing that would indicate that these potatoes have properties that 
74

would increase their survivability compared to conventional potatoes. Volunteers were rarely 

observed, were easily controlled, and are not engineered for resistance to herbicides (Simplot, 

2013a). Based on the agronomic field data and literature survey concerning weediness potential 

of the crop, APHIS has determined that the Simplot InnateTM Potato is unlikely to persist as a 

troublesome weed or to have an impact on current weed management practices (USDA-APHIS, 

2013a).

APHIS evaluated the potential of Simplot InnateTM Potato to cross with native plants and listed 

species, and the possibility that such crosses could result in hybrids that could affect critical 

habitat. As discussed thoroughly in sections 2.4.3 and 4.4.3 Gene Flow and Weediness, APHIS 

has determined that there is little risk of gene flow to related plant species and no risk to 

unrelated plant species from the cultivation of Simplot InnateTM Potato. The events derived from 

Russet Burbank produces few flowers and is male sterile, and those derived from variety “H” are 

completely sterile (Simplot, 2013a; Simplot, 2013b). The events derived from Ranger Russet, 

Atlantic, and “G” are likely to produce fertile pollen, but this should have little consequence in 

regards to gene flow to related plants. Among native Solanum spp. in the US, cultivated potato 

is potentially sexually-compatible only with two tuber-bearing species, S. jamesii and S. 

stoloniferum (previously S. fendleri (Spooner et al., 2004a; Spooner et al., 2004b). These two 

species are found only in Texas, New Mexico, and Arizona, and S. jamesii is further found in 

Colorado and Utah. In some cases these species are found in counties with commercial potato 

production (Simplot, 2013a), (USDA-NRCS, 2013b; 2013a), (USDA-NRCS, 2013a; 2013b). As 

discussed thoroughly in the PPRA, numerous biological and geographic obstacles make gene 

flow from these cultivated potato varieties to the two wild relatives a highly unlikely occurrence, 

and there have been no reports that such crosses have ever occurred naturally (Love, 1994a; 

Love, 1994b), (US-EPA, 2011b; 2011c). However, because it is scientifically plausible that 

cultivated potatoes could hybridize with S. stoloniferum, the PPRA considered the potential 

impact on the weediness of S. stoloniferum if gene introgression from Simplot InnateTM Potato 

were to occur. The resulting analysis concluded that the novel phenotypes (low acrylamide 

potential and reduced black spot bruise) did not impart any significant change in the agronomic 

properties or response to biotic or abiotic stresses that would cause them to be more weedy

(USDA-APHIS, 2013b; 2013a).

A review of the USFWS database of listed species indicates that there are three species of the 

Solanaceae family in the genus Solanum that are listed as endangered. Aiakeakua popolo (S. 

sandwicense) and popolo ku mai (S. incompletum) both found only in Hawaii, and Erubia (S. 

drymophilum) found only in Puerto Rico. There are also two candidate species: popolo (S. 

nelsonii) found only in Hawaii, and marron bacora (S. conocarpum) found only in the U.S. 

Virgin Islands (USFWS, 2014a). Crosses between these species and Simplot InnateTM Potato 

would be highly unlikely because these species are not found in areas of potato production and 

even if they were found together, crosses would be unlikely because the biology of potato as

described in sections 2.4.3 and 4.4.3 Gene Flow and Weediness, and in the PPRA (USDAAPHIS, 2013a). 

Based on agronomic field data, literature surveyed on potato weediness potential, and the 

unlikelihood of crosses with wild relatives, APHIS has concluded that Simplot InnateTM Potato

will have no effect on threatened or endangered plant species or critical habitat.
75

Threatened and Endangered Animal Species

For its effects analysis on TES animal species, APHIS focused on the likelihood of species to be 

exposed to Simplot InnateTM Potato and possible effects that could occur as a result of such 

contact. Exposure of TES species to Simplot InnateTM Potato is only likely if the species occur 

in the areas where potato is grown, because potato plant parts (seeds, tubers, pollen, vegetation, 

crop debris) are not readily transported long distances without human intervention. Threatened 

and endangered animal species that may be exposed to Simplot InnateTM Potato would be those 

TES that inhabit potato fields and may feed on Simplot InnateTM Potato. Few if any TES are 

likely to use potato fields because they do not provide suitable habitat. In general, the majority

of threatened and endangered species are found in more natural habitats (USFWS, 2011).

Little information can be found concerning threatened or endangered species in farm fields, 

especially potato fields. In an Environmental Assessment on the use of genetically engineered 

corn and soybean in refuges in the mid-west, the USFWS reported that whooping crane (Grus 

americana), sandhill crane (Grus canadensis pulla), piping plover (Charadrius melodus), 

interior least tern (Sterna antillarum), and Sprague’s pipit (Anthus spragueii; a candidate

species) occasionally feed in farmed sites (USFWS, 2011). Although possible that these bird 

species may visit potato fields during migratory periods, it is unlikely they would be present 

during normal farming operations (USFWS, 2011). USDA-APHIS Wildlife Services has 

received complaints for damage to corn, wheat, and potatoes caused by sandhill cranes(USDAAPHIS, 2013d).

As discussed in Section 2.4.1, Animal Communities, there are few animals reported to consume 

potato plants in an agricultural setting. This is not surprising considering the foliage and stems 

of potato contain toxic glycoalkaloids known to cause illness when consumed (Sinden, 1987b). 

Known exceptions are whitetail deer, wild boar, and voles (Marinette County, 2014), (O'Brien, 

2005), (Taylor, 2014). There are two listed sub-species of white-tailed deer and three listed vole 

species within States that have commercial potato production. The Columbia white-tailed deer 

(Odocoileus virginianus leucurus) has two populations; one population in Douglass County, 

Oregon was delisted in 2003. The other, listed as endangered, is located in the lower Columbia 

River Valley in Washington State (USFWS, 1983). Neither population is found in areas of 

significant potato production as indicated in Figure 1, Potato Growing Regions of the U.S.

(USDA-NASS, 2007). The endangered Key deer (Odocoileus virginianus clavium) is found 

only on the extreme tip of southern Florida far from any commercial potato production (USFWS, 

2014c). The three vole species are listed as endangered. The Amargosa vole (Microus 

californicus scirpensis) is found in Inyo County in southeast California which is not an area of 

potato production (USFWS, 2014b). The Florida salt marsh vole (Microtus pennsylvanicus 

dukecampbelli) is found in saltmarshes of Levy County in coastal Florida, also not in areas of 

potato production (USFWS, 2014d). The Hualapai Mexican Vole (Microtus mexicanus 

hualapaiensis) is found in Mohave County, Arizona, where potatoes are a minor crop. However, 

the species would be unlikely to be found in potato fields because it is found only in woodlands 

and grasslands in the canyons of the Hualapai Mountains (USFWS, 1991). 

Although unlikely, APHIS considered the possible effects on TES if they were to consume 

Simplot InnateTM Potato. Detailed compositional analyses of the ten events are found in 

Appendix 9 of the petition. The compositional assessments determined the amounts of 1) 
76

moisture, protein, total fat, ash, crude fiber, carbohydrate and calories; 2) vitamins B6, B3 and C;

3) minerals copper, magnesium and potassium; 4) glycoalkaloids; 5) free amino acids; and 6) 

total amino acids for tubers collected from events grown in 2009, 2010, and 2011 in potatogrowing areas of the United States (Simplot, 2013a; Simplot, 2013b). The potato events 

described in the petition were found to be no different compositionally when compared to 

untransformed controls, except for the intended traits (Simplot, 2013a; Simplot, 2013b). As 

discussed in Section 4.4.6 Human Health, issues with allergies to Simplot InnateTM Potato would 

be unlikely beyond what individuals with potato allergies would normally experience. The 

modifications did not alter the quality of potato as food other than lower levels of acrylamide 

after cooking, and lower black spot bruise. Simplot submitted a safety and nutritional 

assessment of food and feed derived from Simplot InnateTM Potato to the FDA on February 12, 

2013 (BNF No. 141) (Simplot, 2013a; Simplot, 2013b). FDA is presently evaluating the 

submission. 

As discussed in Section 4.4.1, Animal Communities, there are a large number of insects that feed 

on potato leaves and other insects that feed on those pests. No differences were observed for 

insects or other animals interacting within the potato ecosystem during the field trials, leading to 

the conclusion that Simplot InnateTM potatoes would have the same impact on other organisms as 

conventional potatoes (Simplot, 2013a; Simplot, 2013b). There is no evidence that animal 

exposure to Simplot InnateTM Potato would have any effect or be any less attractive as food, 

refuge, cover and nesting sites as non GE varieties of potatoes.

APHIS considered the possibility that Simplot InnateTM Potato could serve as a host plant for a 

threatened 

or endangered species. A review of the species list reveals that there are no members of the 

genus Solanum that serve as a host plant for any threatened or endangered species (USDAAPHIS, 2014a; 2014b).

Considering the lack of expected exposure and the expectation that such exposure would produce 

no response different than potato varieties currently in production, cultivation of Simplot 

InnateTM Potatoes and their progeny are expected to have no effect on threatened or endangered 

animals.

Summary

After reviewing the possible effects of allowing the environmental release of Simplot InnateTM 

Potato, APHIS has not identified any stressor that could affect the reproduction, numbers, or 

distribution of a listed TES or species proposed for listing. APHIS also considered the potential 

effect of a determination of nonregulated status of Simplot InnateTM Potato on designated critical 

habitat and habitat proposed for designation, and could identify no differences from effects that 

would occur from the production of other potato varieties. Potato is not considered a particularly 

competitive plant species and has been selected for domestication and cultivation under 

conditions not normally found in natural settings (Holm et al., 1979; Muenscher, 1980b; 

Muenscher, 1980a; Love, 1994a; Love, 1994b; OECD, 1997a; 1997b). There is no ability of

Simplot InnateTM Potato to naturally hybridize with any wild Solanum species, including listed 

species. Simplot InnateTM Potato will not serve as a host species for any listed species or species 
77

proposed for listing. Consumption of Simplot InnateTM Potato by any listed species or species 

proposed for listing will not result in a toxic or allergic reaction. Based on these factors, APHIS 

has concluded that a determination of nonregulated status of Simplot InnateTM Potato, and the 

corresponding environmental release of these potato events will have no effect on listed species 

or species proposed for listing, and would not affect designated habitat or habitat proposed for 

designation. Because of this no-effect determination, consultation under Section 7(a)(2) of the 

Act or the concurrences of the USFWS or NMFS is not required.

7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES 

RELATING TO ENVIRONMENTAL IMPACTS

7.1 Executive Orders with Domestic Implications

The following executive orders require consideration of the potential impacts of the Federal 

action to various segments of the population.

 Executive Order (EO) 12898 (US-NARA, 2010), "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations,"

requires Federal agencies to conduct their programs, policies, and activities that 

substantially affect human health or the environment in a manner so as not to exclude 

persons and populations from participation in or benefiting from such programs. It 

also enforces existing statutes to prevent minority and low-income communities from 

being subjected to disproportionately high and adverse human health or 

environmental effects. 

 EO 13045, “Protection of Children from Environmental Health Risks and Safety 

Risks,” acknowledges that children may suffer disproportionately from 

environmental health and safety risks because of their developmental stage, greater 

metabolic activity levels, and behavior patterns, as compared to adults. The EO (to 

the extent permitted by law and consistent with the agency’s mission) requires each 

Federal agency to identify, assess, and address environmental health risks and safety 

risks that may disproportionately affect children.

The No Action and Preferred Alternatives were analyzed with respect to EO 12898 and EO 

13045. Neither alternative is expected to have a disproportionate adverse effect on 

minorities, low-income populations, or children. Based on the information submitted by the 

applicant and reviewed by APHIS, Simplot InnateTM Potato is agronomically, 

phenotypically, and biochemically similar to conventional potatoes except for the low 

acrylamide potential and reduced black spot bruise trait. To establish that the new cultivars 

are nutritionally equivalent to their parent cultivars, Simplot InnateTM Potato and the control 

Ranger Russet potato were subjected to nutritional and proximate analysis, and measured for 

free amino acids, total amino acids, glycoalkaloids, sugars, and acrylamide levels. Results of 

the analysis are described below.
78

Reduced free asparagine (ASN) and total ASP + ASN, increased free GLN and total GLU + 

GLN, reduced acrylamide, and lowered reducing sugars were observed and expected as a 

result of gene silencing. This reduction would benefit consumers by addressing a food safety 

issue that is of concern to the potato industry (NTP, 2011). Other significant differences 

occurred that were not expected. J3 tubers contained an average of 0.117 mg/100 g 

pyridoxine (vitamin B6) as compared to the controls, which had 0.124 mg/100g. J55 also 

had decreased pyridoxine. J3 tubers had an average of 134 ppm of free VAL as compared to 

the controls, which had 147 ppm. J55 also experienced decreased VAL; H37 had decreased 

LYS; F37 had increased free ARG; G11 had increased total LYS and PRO; F10 and F37 had 

increased vitamin C and niacin; E12 and E24 had decreased sucrose; and H37 had increased 

sucrose. These observed differences fall within the normal ranges for potatoes. 

Potatoes also were tested for reducing sugars and acrylamide after storage. Many of the 

events had lowered levels of reducing sugars at the time of harvest or one month of storage, 

but significant differences were not routinely observed after 2-5 months. Storage up to 7 

months yielded consistently lower acrylamide levels in most events than in the controls, 

although there were exceptions with the G and H varieties. Overall, the modifications from 

insertion of pSIM1278 resulted in reductions in acrylamide that persisted throughout the 

storage period.

Research also confirmed that there the levels of natural glycoalkaloids, a toxin commonly

found in solanaceous crops including potato, were not increased overall in the events. The 

safety limit is 20mg/100g as described by Sinden (Sinden, 1987a). There were, however, 

higher mean levels of glycoalkaloids in the G event (20.3 mg/100g) and the comparative 

untransformed control (19.8 mg/100g), but this was attributed to additional handling at the 

storage sites and subsequent exposure to light and temperature fluctuations. This finding 

indicates that there would not be safety issues as a result of the introduction of the reduced 

acrylamide potential and low black spot bruise traits in Simplot InnateTM Potato.

Patatin is a storage glycoprotein found in potatoes that makes up approximately 40 percent of 

the soluble protein in tubers. Some allergies have been detected in children as a result of 

patatin; however, these allergies are only in children and are uncommon (De Swert et al., 

2002; 2007). Children who are allergic to potatoes would avoid them; therefore, any changes 

in patatin levels in Simplot InnateTM Potato would not impact these children. 

The nutritional analysis establishes the safety of Simplot InnateTM Potato to humans, 

including minorities, low-income populations, and children who might be exposed to them 

through agricultural production and/or processing. No additional safety precautions would 

need to be taken. 

Simplot initiated the consultation process with FDA for the commercial distribution of 

Simplot InnateTM Potato and submitted a safety and nutritional assessment of food and feed 

derived from Simplot InnateTM Potato to the FDA (Simplot, 2013a). FDA is presently 

evaluating the submission. 
79

Based on these factors, a determination of nonregulated status of Simplot InnateTM Potato is 

not expected to have a disproportionate adverse effect on minorities, low-income 

populations, or children.

The following executive order addresses Federal responsibilities regarding the introduction and 

effects of invasive species:

EO 1311 (US-NARA, 2010), “Invasive Species,” states that Federal agencies take 

action to prevent the introduction of invasive species, to provide for their control, 

and to minimize the economic, ecological, and human health impacts that 

invasive species cause. 

Potatoes are not listed in the United States as a noxious weed species by the Federal government 

(7 CFR Part 360; (USDA-NRCS, 2014), nor is it listed as an invasive species by major invasive 

plant databases. Standard potato growing practices make it highly unlikely that potatoes would 

persist in a field from one crop cycle to the next. In areas where potatoes are grown as a rotation 

crop, any potatoes left in the field would be eliminated by tilling, field preparations with 

herbicides, and harsh winters. Potato growers rarely leave the ground fallow to maximize 

economic return; however, any potatoes that grew inadvertently in a fallow field would not be 

protected with insecticide or fungicide and would be susceptible to the Colorado potato beetle 

and early blight.

Potatoes are not known to escape from fields or show weediness potential. Potato seedlings 

grown from tubers have difficulty establishing themselves as they are poor competitors against 

grasses, trees, and shrubs. This characteristic significantly reduces the chance that potatoes will 

become feral. In addition, the traits incorporated into Simplot InnateTM Potato are not associated 

with weediness and will not help plants thrive outside of cultivation. Based on historical 

experience with potatoes and data submitted by the applicant and reviewed by APHIS, Simplot 

InnateTM Potato is not expected to become weedy or invasive.

The following executive order requires the protection of migratory bird populations:

EO 13186 (US-NARA, 2010), “Responsibilities of Federal Agencies to Protect 

Migratory Birds,” states that federal agencies taking actions that have, or are 

likely to have, a measurable negative effect on migratory bird populations are 

directed to develop and implement, within two years, a Memorandum of 

Understanding (MOU) with the Fish and Wildlife Service that shall promote the 

conservation of migratory bird populations. 

Migratory birds are not attracted to potato fields for potatoes; however, waterfowl forage 

extensively in agricultural fields in the fall and winter and are at risk for exposure to pesticides. 

In addition, raptors are at risk of exposure to pesticides if they consume dead or dying waterfowl 

from the fields. However, the ten Simplot InnateTM Potato events are similar to their 

conventional counterparts and would not require additional use of pesticide applications. 

Simplot InnateTM Potato is therefore expected to have the same interactions with migratory birds 

as conventional potatoes.
80

7.2 International Implications

EO 12114 (US-NARA, 2010), “Environmental Effects Abroad of Major Federal Actions”

requires federal officials to take into consideration any potential environmental effects outside 

the U.S., its territories, and possessions that result from actions being taken. 

APHIS has given this EO careful consideration and does not expect a significant environmental 

impact outside the U.S. in the event of a determination of nonregulated status of Simplot 

InnateTM Potato. All existing national and international regulatory authorities and phytosanitary

regimes that currently apply to introductions of new potato cultivars internationally apply equally 

to those covered by an APHIS determination of nonregulated status under 7 CFR part 340. 

Any international trade of Simplot InnateTM Potato subsequent to a determination of 

nonregulated status of the product would be fully subject to national phytosanitary requirements 

and be in accordance with phytosanitary standards developed under the International Plant 

Protection Convention (IPPC, 2010). The purpose of the IPPC “is to secure a common and 

effective action to prevent the spread and introduction of pests of plants and plant products and 

to promote appropriate measures for their control” (IPPC, 2010). The protection it affords 

extends to natural flora and plant products and includes both direct and indirect damage by pests, 

including weeds. 

The IPPC establishes a standard for the reciprocal acceptance of phytosanitary certification 

among the nations that have signed or acceded to the Convention (172 countries as of March 

2010). In April 2004, a standard for PRA of living modified organisms (LMOs) was adopted at 

a meeting of the governing body of the IPPC as a supplement to an existing standard, 

International Standard for Phytosanitary Measure No. 11 (ISPM-11, Pest Risk Analysis for 

Quarantine Pests). The standard acknowledges that all LMOs will not present a pest risk and 

that a determination needs to be made early in the PRA for importation as to whether the LMO 

poses a potential pest risk resulting from the genetic modification. APHIS pest risk assessment 

procedures for genetically engineered organisms are consistent with the guidance developed 

under the IPPC. In addition, issues that may relate to commercialization and transboundary

movement of particular agricultural commodities produced through biotechnology are being 

addressed in other international forums and through national regulations.

The Cartagena Protocol on Biosafety is a treaty under the United Nations Convention on 

Biological Diversity (CBD) that established a framework for the safe transboundary movement, 

with respect to the environment and biodiversity, of LMOs, which include those modified 

through biotechnology. The Protocol came into force on September 11, 2003, and 160 countries 

are Parties to it as of December 2010 (CBD, 2010). Although the U.S. is not a party to the CBD, 

and thus not a party to the Cartagena Protocol on Biosafety, U.S. exporters will still need to 

comply with those regulations that importing countries which are Parties to the Protocol have 

promulgated to comply with their obligations. The first intentional transboundary movement of 

LMOs intended for environmental release (field trials or commercial planting) will require 

consent from the importing country under an advanced informed agreement (AIA) provision, 

which includes a requirement for a risk assessment consistent with Annex III of the Protocol and 

the required documentation.
81

LMOs imported for food, feed, or processing (FFP) are exempt from the AIA procedure, and are 

covered under Article 11 and Annex II of the Protocol. Under Article 11, Parties must post 

decisions to the Biosafety Clearinghouse database on domestic use of LMOs for FFP that may be 

subject to transboundary movement. To facilitate compliance with obligations to this protocol, 

the U.S. Government has developed a website that provides the status of all regulatory reviews 

completed for different uses of bioengineered products (NBII, 2010). These data will be

available to the Biosafety Clearinghouse. 

APHIS continues to work toward harmonization of biosafety and biotechnology consensus 

documents, guidelines, and regulations, including within the North American Plant Protection 

Organization (NAPPO), which includes Mexico, Canada, and the U.S., and within the 

Organization for Economic Cooperation and Development (OECD). NAPPO has completed 

three modules of the Regional Standards for Phytosanitary Measures (RSPM) No. 14, 

Importation and Release into the Environment of Transgenic Plants in NAPPO Member 

Countries (NAPPO, 2009).

APHIS also participates in the North American Biotechnology Initiative (NABI), a forum for 

information exchange and cooperation on agricultural biotechnology issues for the U.S., Mexico, 

and Canada. In addition, bilateral discussions on biotechnology regulatory issues are held 

regularly with other countries including Argentina, Brazil, Japan, China, and Korea.

7.3 Compliance with Clean Water Act and Clean Air Act

This EA evaluated the potential changes in potato production associated with a determination of 

nonregulated status of Simplot InnateTM Potato (Section 4.2) and determined that the cultivation 

of Simplot InnateTM Potato would not lead to the increased production or acreage of potato in 

U.S. agriculture. The ten Simplot InnateTM Potato events do not possess traits that would allow 

them to be grown in areas other than those where their conventional counterparts are grown. The 

low acrylamide potential and reduced black spot bruise trait conferred by the genetic 

modification to Simplot InnateTM Potatoes would not result in any changes in water usage for 

cultivation. As discussed in Section 4.3, there are no expected negative impacts to water 

resources or air quality associated with Simplot InnateTM Potato production. Based on these 

analyses, APHIS concludes that a determination of nonregulated status of Simplot InnateTM 

Potatoes would comply with the Clean Water Act and the Clean Air Act.

7.4 Impacts on Unique Characteristics of Geographic Areas

This EA evaluated the potential changes in potato production associated with a determination of 

nonregulated status of Simplot InnateTM Potato (Section 4.2) and determined that the cultivation 

of Simplot InnateTM Potato would not lead to the increased production or acreage of potato in 

U.S. agriculture. The ten Simplot InnateTM Potato events do not possess traits that would allow 

them to be grown in areas other than those where their conventional counterparts are grown. The 

low acrylamide potential and reduced black spot bruise trait conferred by the genetic 

modification to Simplot InnateTM Potatoes would not result in any changes in water usage for 

cultivation. As discussed in Section 4.3, there are no expected negative impacts to water 

resources or air quality associated with Simplot InnateTM Potato production. Based on these 
82

analyses, APHIS concludes that a determination of nonregulated status of Simplot InnateTM 

Potatoes would comply with the Clean Water Act and the Clean Air Act.

7.5 National Historic Preservation Act (NHPA) of 1966 as Amended 

The NHPA of 1966 and its implementing regulations (36 CFR 800) require Federal agencies to: 

1) determine whether activities they propose constitute "undertakings" that have the potential to 

cause effects on historic properties and 2) if so, to evaluate the effects of such undertakings on 

such historic resources and consult with the Advisory Council on Historic Preservation (i.e., 

State Historic Preservation Office, Tribal Historic Preservation Officers), as appropriate. 

APHIS’ proposed action, a determination of nonregulated status of Simplot InnateTM Potato is 

not expected to adversely impact cultural resources on tribal properties. Any farming activity 

that may be taken by farmers on tribal lands would only be conducted at the tribe’s request; thus, 

the tribes would have control over any potential conflict with cultural resources on tribal 

properties.

APHIS’ Preferred Alternative would have no impact on districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places, nor would it 

likely cause any loss or destruction of significant scientific, cultural, or historical resources. 

This action is limited to a determination of non-regulated status of Simplot InnateTM Potato. 

APHIS’ proposed action is not an undertaking that may directly or indirectly cause alteration in 

the character or use of historic properties protected under the NHPA. In general, common 

agricultural activities conducted under this action do not have the potential to introduce visual, 

atmospheric, or noise elements to areas in which they are used that could result in effects on the 

character or use of historic properties. For example, there is potential for increased noise on the 

use and enjoyment of a historic property during the operation of tractors and other mechanical 

equipment close to such sites. A built-in mitigating factor for this issue is that virtually all of 

the methods involved would only have temporary effects on the audible nature of a site and can 

be ended at any time to restore the audible qualities of such sites to their original condition with 

no further adverse effects. Additionally, these cultivation practices are already being conducted 

throughout the potato production regions. The cultivation of Simplot InnateTM Potato is not 

expected to change any of these agronomic practices that would result in an adverse impact 

under the NHPA.
83

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