i

JR Simplot Company Petition (14-093-01p) for 

Determination of Nonregulated Status for InnateTM

Potatoes with Late Blight Resistance, Low Acrylamide 

Potential, Reduced Black Spot and Lowered Reducing 

Sugars: Russet Burbank Event W8

OECD Unique Identifier: SPS-000W8-4

Draft Environmental Assessment 

February 2015

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. 
ii

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

LIST OF FIGURES........................................................................................................................ vii

LIST OF TABLES.......................................................................................................................... vii

ACRONYMS AND ABBREVIATIONS ........................................................................................... viii

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

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

1.1.1 The APHIS Regulatory Authority ..............................................................................1

1.1.2 Purpose of this Product............................................................................................2

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

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

1.2.2 Environmental Protection Agency..................................................................................4

1.2.3 Food and Drug Administration.......................................................................................5

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

1.3.1 Public Involvement.........................................................................................................6

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

2.1.2 General Agronomic Practices.......................................................................................12

2.2 Physical Environment..........................................................................................................25

2.2.1 Water Resources..........................................................................................................25

2.2.2 Soil Quality....................................................................................................................26

2.2.3 Air Quality.....................................................................................................................28

2.2.4 Climate Change.............................................................................................................28

2.3 Biological Resources............................................................................................................29

2.3.1 Animal Communities....................................................................................................29
TABLE OF CONTENTS PAGE

(Continued)

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2.3.2 Plant Communities.......................................................................................................30

2.3.3 Gene Flow and Weediness...........................................................................................31

2.3.4 Microorganisms............................................................................................................32

2.3.5 Biodiversity...................................................................................................................33

2.4 Human and Animal Health..................................................................................................34

2.4.1 Consumer Health..........................................................................................................34

2.4.2 Worker Health..............................................................................................................37

2.4.3 Animal Feed..................................................................................................................38

2.5 Socioeconomics...................................................................................................................40

2.5.1 Domestic Economic Environment................................................................................40

2.5.2 Trade Economic Environment......................................................................................44

2.5.3 Organically Certified Economic Environment ..............................................................44

3. ALTERNATIVES............................................................................................................................47

3.1 No Action Alternative: Continuation as a Regulated Article..............................................47

3.2 Preferred Alternative: Determination That Simplot InnateTM W8 Potato Is No Longer a Regulated 

Article ............................................................................................................................47

3.3 Alternatives Considered But Rejected from Further Consideration...................................47

3.3.1 Prohibit Any Simplot InnateTM W8 Potato from Being Released ..................................48

3.3.2 Approve the Petition in Part.........................................................................................48

3.3.4 Requirement of Testing for Simplot InnateTM W8 Potato.............................................49

3.4 Comparison of Alternatives ................................................................................................49

4 ENVIRONMENTAL CONSEQUENCES............................................................................................55

4.1 Environmental Consequences.............................................................................................55

4.2 Scope of Analysis.................................................................................................................55

4.3 Agricultural Production of Potato.......................................................................................56

4.3.1 Acreage and Area of Potato Production.......................................................................56

4.3.2 Agronomic Practices.....................................................................................................56

4.3.3 Potato Seed Production ...............................................................................................58
TABLE OF CONTENTS PAGE

(Continued)

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4.3.4 Organic Potato Production...........................................................................................58

4.4 Physical Environment..........................................................................................................59

4.4.1 Water Resources..........................................................................................................59

4.4.2 Soil Quality....................................................................................................................60

4.4.3 Air Quality.....................................................................................................................61

4.4.4 Climate Change.............................................................................................................61

4.5. Biological Resources...........................................................................................................62

4.5.1 Animal Communities....................................................................................................62

4.5.2 Plant Communities.......................................................................................................65

4.5.3 Gene Flow and Weediness...........................................................................................66

4.4.5 Biodiversity...................................................................................................................67

4.6 Human and Animal Health..................................................................................................68

4.6.1 Human Health ..............................................................................................................68

4.6.2 Worker Safety...............................................................................................................69

4.6.3 Animal Feed..................................................................................................................70

4.7.1 Domestic Economic Environment................................................................................70

4.7.2 Trade Economic Environment......................................................................................72

5 CUMULATIVE IMPACTS .........................................................................................................73

5.1 Assumptions Used for Cumulative Impacts Analysis..........................................................73

5.2 Past and Present and Reasonably Foreseeable Actions .....................................................74

6 THREATENED AND ENDANGERED SPECIES ...........................................................................77

6.1 Potential Effects of Simplot InnateTM W8 potato on TES and Critical Habitat ................79

7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES RELATING TO

ENVIRONMENTAL IMPACTS .................................................................................................83

7.1 Executive Orders with Domestic Implications ....................................................................83

7.2 International Implications...................................................................................................88

7.3 Compliance with Clean Water Act and Clean Air Act..........................................................89

7.4 Impacts on Unique Characteristics of Geographic Areas....................................................89
TABLE OF CONTENTS PAGE

(Continued)

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8 REFERENCES ..........................................................................................................................91
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LIST OF FIGURES

Figure 1. Potato Growing Regions of the United States (USDA-NASS, 2007)............................................11

LIST OF TABLES

Table 1. Agronomic Inputs for Russet Varieties.........................................................................................10

Table 2. Major Potato Production States in 2013.......................................................................................11

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

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

Table 5. Major Weeds of Potato ................................................................................................................22

Table 6. US Per Capita Potato Consumption 2012 (lb/person/yr).............................................................34

Table 7. US 2012 Potato Utilization ...........................................................................................................39

Table 8. Summary of Issues of Potential Impacts and Consequences of Alternatives..............................49
viii

 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

CWA

DNA 

Clean Water Act

deoxyribonucleic acid

EA Environmental Assessment

EIS Environmental Impact Statement

EO Executive Order

EPA US Environmental Protection Agency

ESA Endangered Species Act of 1973

FDA US 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
ix

 ACRONYMS AND ABBREVIATIONS

GHG greenhouse gas

IPM

IPPC

Integrated Pest Management

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

NRCS

PIP

PM

PPA

PPM

PPRA

RNA

SSA

TES

TPS

National Historic Preservation Act

National Marine Fisheries Service

National Organic Program (of USDA AMS)

non-point source

National Research Council

Natural Resources Conservation Service

plant-incorporated protectants

particulate matter

Plant Protection Act

parts per million

Plant Pest Risk Assessment

ribonucleic acid

sole source aquifer

threatened and endangered species

true potato seed
x

 ACRONYMS AND ABBREVIATIONS

U.S.

USDA

USDA-ERS

USDA-FAS

USDA-NASS

USDA-NOP

WPS

United States

US Department of Agriculture

US Department of Agriculture-Economic Research Service

US Department of Agriculture-Foreign Agricultural Service

US Department of Agriculture-National Agricultural Statistics Service

US Department of Agriculture-National Organic Program

Worker Protection Standard (for agricultural pesticides)
1

1 PURPOSE AND NEED

1.1 Background

J.R. Simplot1 of Boise, Idaho, submitted petition 14-093-01p to the United States Department of 

Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) in March 2014, seeking a 

determination of nonregulated status for Simplot InnateTM W8 potato genetically engineered (GE) with

late blight resistance, low acrylamide potential, reduced black spot and lower reducing sugars. The 

petition was deemed complete by APHIS on June 26, 2014, and was published in the Federal Register on 

November 10, 2014 (79 FR 66689-66690). Public comments were due by January 9, 2015.

Simplot InnateTM W8 potato is currently regulated under 7 CFR part 340. Interstate movements and 

confined field releases of Simplot InnateTM W8 potato were conducted under notifications acknowledged 

by APHIS in 2012 and 2013. These field trials were conducted in Idaho, Minnesota, North Dakota,

Washington, and Wisconsin. Data resulting from these field trials are similar to data requirements for 

other petitions submitted to APHIS and described in Simplot’s InnateTM W8 potato petition (Simplot, 

2014) and analyzed for plant pest risk in the APHIS Plant Pest Risk Assessment (PPRA) (USDA-APHIS, 

2014b).

The petition stated that APHIS should not regulate Simplot InnateTM W8 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 W8 potato, any progeny derived from crosses between Simplot 

InnateTM W8 potato and conventional potato, and crosses of Simplot InnateTM W8 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.

1.1.1 Regulatory Authority

“Protecting American agriculture” is the basic charge of the U.S. Department of Agriculture's (USDA) 

Animal and Plant Health Inspection Service (APHIS). APHIS provides leadership in ensuring the health 

and care of plants and animals. The agency improves agricultural productivity and competitiveness, and 

contributes to the national economy and the public health. USDA asserts that all methods of 

agricultural production (conventional, organic, or the use of genetically engineered (GE) varieties) can 

provide benefits to the environment, consumers, and farm income. 

APHIS is responsible for regulating GE organisms and plants under the authority of plant pest provisions 

in the Plant Protection Act of 2000, as amended (7 USC § 7701 et seq.) to ensure that they do not pose a 

plant pest risk to the environment.

The FDA regulates GE organisms under the authority of the Federal Food, Drug, and Cosmetic Act. The 

FDA is responsible for ensuring the safety and proper labeling of all plant-derived foods and feeds, 

including those that are genetically engineered. To help developers of food and feed derived from GE 

 

1 Referred to as the JR Simplot Company or Simplot hereinafter
2

crops comply with their obligations under Federal food safety laws, FDA encourages them to participate 

in a voluntary consultation process. All food and feed derived from GE crops currently on the market in 

the United States have successfully completed this consultation process. The FDA policy statement 

concerning regulation of products derived from new plant varieties, including those genetically 

engineered, was published in the Federal Register on May 29, 1992 (57 FR 22984-23005). Under this 

policy, FDA uses what is termed a consultation process to ensure that human food and animal feed 

safety issues or other regulatory issues (e.g., labeling) are resolved prior to commercial distribution of 

bioengineered food.

The EPA regulates plant-incorporated protectants under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA). EPA also sets tolerance limits for residues of pesticides on and in food and 

animal feed, or establishes an exemption from the requirement for a tolerance, under the Federal Food, 

Drug and Cosmetic Act (FFDCA) and regulates certain biological control organisms under the Toxic 

Substances Control Act (TSCA). The EPA is responsible for regulating the sale, distribution and use of 

pesticides, including pesticides that are produced by an organism through techniques of modern 

biotechnology.

1.1.2 Purpose of this Product

Simplot’s InnateTM potato, which contains traits for lowered acrylamide potential and reduced black spot 

bruise, was determined to be nonregulated on November 10, 2014 (79 FR 66688). The Simplot InnateTM

W8 potato is a Russet Burbank which contains these traits, plus two other traits for lowered reducing 

sugars and late blight resistance.

As discussed in Simplot’s petition for nonregulation of Simplot InnateTM potato (Simplot, 2013), APHIS’ 

Plant Pest Risk Assessment (PPRA) (USDA-APHIS, 2013a) and subsequent Environmental Assessment 

(EA) (USDA-APHIS, 2014a), Simplot InnateTM potato was genetically engineered to provide a potato that 

produces up to a 70% reduction of the neurotoxicant and putative carcinogen, acrylamide, and 

decreased potential for black spot bruise. Acrylamide forms in potatoes and other starchy foods under 

high-temperature cooking conditions (O'Brien et al., 1989), and the acrylamide reduction potential in 

Simplot InnateTM W8 potato is a significant human health benefit, helping to address consumer concerns 

about the health effects of acrylamide ingestion (NTP, 2012; FDA, 2013c). Black spot bruise is a postharvest 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 (USDA-APHIS, 2014b). This blackening negatively affects tuber quality in processing 

French fries and chips, posing an economic deficit to growers since damaged potatoes must be trimmed 

or culled, significantly reducing yield (USDA-APHIS, 2014b). 

The technology used to produce Simplot InnateTM potato has been utilized to introduce two new 

additional traits into the most popular variety of potato for processing, Russet Burbank (NPC, 2013). 

These new traits are late blight resistance and lowered reducing sugars. There currently are no varieties 

available that produce potatoes with late blight resistance (McGrath, 2010), low reducing sugars, low 

acrylamide formation, and reduced black spot and at the same time maintaining all the other 

compositional, nutritional and flavor traits required by the food industry (Simplot, 2014). Late blight, 

caused by the oomycete pathogen, Phytophthora infestans, is the most destructive potato disease
3

worldwide, and was responsible for the Irish potato famine of the 1840s. Control of this disease incurs 

significant costs to growers owing from fungicide applications and yield loss from diseased plants (Fry, 

2008). Reducing sugars increase over the length of time that potatoes are stored prior to use in 

processing, with high levels leading to unacceptably brown fries and chips and alteration in flavor, 

contributing to acrylamide formation, and resulting in consumer rejection (Bhaskar et al., 2010). 

Processors typically reject potato loads with a reducing sugar content above 2%, which comprises about 

20% of potatoes produced (Simplot, 2014), so a trait which prevents accumulation of reducing sugars to 

unacceptably high levels would be economically beneficial to growers. 

The intended purpose of the W8 potato line is to provide the potato processing industry with new 

varieties that possess late blight resistance, reduced acrylamide potential in certain processed or heated 

potato products, reduced black spot bruise, and lowered reducing sugars. All of these changes are 

intended to benefit potato consumers, producers, and processors. The late blight resistance trait may 

lower the need for fungicides for control of late blight disease and may lessen the discards of potatoes 

that are infected which may lead to increased yield and less chemical residues on potatoes, fields and 

waste water. The low acrylamide potential is intended to benefit consumers because of concerns about 

the health effects of ingesting acrylamide, and to benefit the industry relative to Proposition 65 in the 

State of California. The reduced black spot bruise 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 pick-outs. By lowering reducing sugars with the use of the W8 potato line, storage of potatoes 

for the fry and chip market could be accomplished at a lower temperature which would lower incidence 

of storage diseases and keep taste/color quality in the desired ranges.

1.2 Coordinated Regulatory Framework for Genetically-Engineered Organisms

In 1986, the Office of Science and Technology Policy (OSTP) described a comprehensive Federal 

regulatory policy for ensuring the safety of biotechnology research and products entitled “The 

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

Coordinated Framework). The Coordinated Framework 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 required 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 PPA, as amended (7 United States Code (U.S.C.) 7701–7772), regulate the 
4

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 pose a 

plant pest risk. 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.

1.2.2 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 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 (EUP) 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 the 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, 2011c).

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 
5

reasonable certainty of no harm under the FFDCA, as amended by the FQPA. FDA enforces the pesticide 

tolerances set by EPA.

According to Simplot’s petition, an experimental use permit (EUP) application was submitted to EPA on 

December 16, 2013, for field testing of Simplot InnateTM W8 potatoes. An EUP, also for Simplot InnateTM 

W8 potatoes potatoes, with a Petition for Temporary Tolerance Exemption, was submitted February 20, 

2014. A Section 3 Registration will be filed after experiments are completed under the Simplot InnateTM 

W8 potatoes EUPs (Simplot, 2014). 

1.2.3 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 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.

The J.R. Simplot Company submitted a letter of consultation on April 14, 2014, which FDA is still

reviewing (BNF No. 000146).

1.3 Purpose and Need for This APHIS Action

APHIS responds to petitioners that request a determination of nonregulated status of GE organisms (7 

CFR 340.6), including GE plants such as Simplot InnateTM W8 potato. When a petition for nonregulated 

status is submitted, APHIS performs analyses to determine if the GE organism poses 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 pose a plant pest risk. 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.

In this EA, APHIS is responding to a petition from Simplot requesting a determination of nonregulated 

status for Simplot InnateTM W8 potato. APHIS considers the potential environmental effects of an 

agency determination of nonregulated status of Simplot InnateTM W8 potato consistent with regulations 

for implementing the National Environmental Policy Act (NEPA; 40 CFR parts 1500-1508), and the APHIS 

NEPA-implementing regulations and procedures (7 CFR part 1b, and 7 CFR part 372). This EA specifically 
6

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

nonregulated status for Simplot InnateTM W8 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 published in the Federal Register2, 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 its EA and PPRA. The availability of the petition 

for public comment is announced in a Federal Register notice.

Second Opportunity for Public Involvement

The draft PPRA and draft EA are developed, and a notice of their availability is published in a second 

Federal Register notice. This second notice follows one of the following 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 

 

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

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. APHIS 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 notice published on March 6, 20123.

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 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 W8 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 W8 potato.

The petition was published in the Federal Register on November 10, 2014 (79 FR 66689-66690). Public 

comments were due by January 9, 2015. A total of 130 individual comments were received, of which 60 

supported the petition, and 68 opposed the petition. Of the 68 opposing comments, one contained an 

attachment with 22,673 signatures; 22 comments were substantially similar to each other; and 7 

comments were submitted by one individual. Of the 60 comments favoring determination of 

nonregulation, 2 were duplicates. 

1.4 Issues Considered

The list of resource areas considered in this EA was 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 address concerns raised in previous and unrelated 

 

3This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf
8

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: 

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.

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

of these issues in this EA with citations where appropriate. In general, those commenters opposing the 
9

petition expressed their disagreement with GE crops; favored longer term safety testing for Simplot 

InnateTM W8 potato; and suggested that RNAi technology is not safe for use. Two commenters asked for 

the public comment period to be extended, and also stated that due to the complexity of the product, 

an EIS was needed. 

Commenters favoring the petition cited health benefits from reduced acrylamide; reduced wastage and 

crop loss; lengthening of storage periods with less reliance on sprout inhibitors; and reduced use of 

fungicides to prevent late blight. 

2 AFFECTED ENVIRONMENT

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

impacted by Simplot InnateTM W8 potato production. Relevant environmental components include the 

agricultural production area of Simplot InnateTM W8 potato, 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; Zaheer and Akhtar, 2014). 

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

(Center, 2010). After China, India, Russia, and the Ukraine, the U.S. is the fifth largest potato producing 

country (FAO, 2013; Zaheer and Akhtar, 2014), with annual production over the last three years of 

between 404-467 million centum weight (cwt)(centum weight = 100 pounds), grown on 1.0-1.1M acres 

(USDA-NASS, 2013b).

The Russet Burbank potato cultivar was transformed by Simplot to produce the Simplot InnateTM W8 

potato (Simplot, 2014). Russet Burbank is a brown, smooth-skinned, white-fleshed potato that is highyielding, has a low sugar content and stores well for long periods of time (Nevada, 2014). Taste panels 

rate Russet Burbank highly for flavor (Nevada, 2014). Originally developed by Luther Burbank in the 

early 1870s (PAA, 2013), Russet Burbank is the most popular potato variety in the U.S. (Nevada, 2014), 

is used primarily for baking, and for processing into French fries and chips (NPC, 2013; Nevada, 2014; 

University, 2014). In 2012, Russet Burbank was planted on approximately 40% of the acreage devoted 

to potatoes in the U.S. (University, 2014), especially in the Pacific Northwest and Midwest (Nevada, 

2014). 

The cultivar’s low sugar content is especially advantageous since high sugar contributes to acrylamide 

production during cooking, decreased processing quality (Driskill et al., 2007), and consistent low sugar 

content during the storage period (Nevada, 2014; University, 2014). Russet Burbank tolerates the plant 

disease common scab well (PAA, 2013) but is susceptible to black spot bruise and dehydration (Nevada, 

2014) and to pathogens such as Fusarium and Verticillium wilts, leafroll and net necrosis, potato virus Y, 

and late blight (PAA, 2013). Russet Burbank is sterile and produces only a few white flowers during 

production (PAA, 2013). Table 1 summarizes some of the agronomic requirements for this variety.
10

Table 1. Agronomic Inputs for Russet Varieties

Russet Varieties

Planting Date April 1 to May 10

Planting Rate 15,000 - 18,000 seed pc or 17 – 23 cwt/A

Row Spacing 34-36” between rows 

Seed Spacing 10-12” within row

Fertilizer For 600 cwt/A yields and optimum soil 

test levels:

250 lb N – 100 lb P2O5 – 330 lb K2O per 

acre

Yield/Plant 2-4 lb

Yield/Acre 400-700 cwt/A

Harvest Date September 1 to October 15

Source: (PAA, 2013)

2.1.1 Land Use

Potatoes are grown across most of the continental U.S., with six States (Idaho, Washington, Wisconsin, 

North Dakota, Oregon, and Colorado) accounting for approximately 73% of annual production (USDANASS, 2014d; 2014b)(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, lower power and labor costs, more favorable weather, and available arable land (Guenther, 

2010a). 

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 and 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 (USDA-NASS, 

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 W8 potato may be grown in any of the U.S.

potato-growing regions.
11

Figure 1. Potato Growing Regions of the United States (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 harvested acreage has declined over the years, total 

production has increased (Guenther, 2010b). For example, in the 1930s, 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, 2010b). Total acres of potatoes harvested in 2012, 2013 and 2014 were 1.13, 1.05 

and 1.07 million acres, respectively (USDA-ERS, 2014; USDA-NASS, 2014b). Total annual U.S. production 

has been over 400 million cwt every year since 1990, with per acre yield approximately 407 cwt (Table 

2), which represents an eightfold increase in yield per acre since the 1990s (USDA-NASS, 2010). 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; 2013a).

The top ten potato producing states are shown in Table 2 (USDA-NASS, 2013c). Highest yields are in 

regions where daytime temperatures exceed 100° F during the hottest part of the growing season, and 

where nights are cool (about 65° F) (Rosen, 2010d), such as in Washington’s Columbia Basin, eastern 

Oregon, and Idaho.

Table 2. Major Potato Production States in 2013
12

State

Production 

(1,000 cwt)

Total U.S.

Production

(percent)

Potato Harvest 

(acres)

Idaho 131,131 30.2 316,000

Washington 96,000 22.1 160,000

Wisconsin 26,040 6.0 64,000

North Dakota 22,620 5.2 78,000

Oregon 21,582 5.0 39,600

Colorado 20,304 4.7 54,000

Minnesota 17,325 4.0 45,000

Michigan 15,840 3.6 44,000

Maine 15,660 3.6 54,000

California 14,369 3.3 26,500

Source: (USDA-NASS, 2014b)

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

processing (Guenther, 2010b). Harvested potatoes are either used for food (~93%), feed (<1%), 

industrial purposes (<1%) or as “seed” for planting (5%) (NPC, 2012; USDA-NASS, 2013c; 2014a). 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, 2014b), while approximately 35% of annual output is 

processed into frozen products (such as frozen fries and wedges), chips, dehydrated potato and starch

(25%), or canned potatoes (0.4%), and 6% is replanted as seed potato. Americans eat, on average, 

approximately 115 lbs. of potatoes per person per year, of which about two thirds is consumed as 

processed potato products (USDA-ERS, 2010).

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

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

into feed rations at livestock feedlot operations (Simplot, 2014).

2.1.2 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 
13

processing and fresh market through the winter, spring and summer 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 root-zone 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

(Shock, 2010). Specific guidelines for irrigation depend on geographic region and factors typical of that 

region such as temperature, relative humidity, and day length. 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, by preparing the soil so that infiltration of water is increased, 

and also by 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 black spot 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, due to limitations in conventional 

breeding. Each parent variety must be independently transformed to achieve the desired phenotype in 

that variety (USDA-APHIS, 2014b). If a single 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 
14

be difficult to reconstitute the desirable characteristics of the original variety (Llorente et al., 2011; 

Simplot, 2014).

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 mitigate disease pressure 

is to till green manure crops (crops which are left to decompose on fields to provide cover or mulch for a 

subsequent crop) 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 with other crops increases the risk of 

insect, disease, and nematode pressure; decreases soil nutrient levels; and increases erosion potential

(Delahaut, 2000; Hall et al., 2000; Bennett and O'Rourke, 2002; Larkin, 2003; Hopkins et al., 2004).

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 potato 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: 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
15

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

insects and diseases (Johnson, 2007). More than 150 species of insects may damage potatoes, most of 

which cause only minor economic injury. However, several species cause more damage 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 

US, 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, of which 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, are prevalent in 

potato crops (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).

Growers may 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 lists the major insect pests of potato.

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

Potato psyllid Bactericera (Paratrioza) cockerelli

Potato Tuberworm or 

Tuber Moth

Phthorimaea operculella
16

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

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 (Arif et al., 2012; USDA-APHIS, 2014b).

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

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

diseases of potato. Some of these diseases 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

Common Name Scientific Name

Potato Spindle Tuber 

Viroid Member of Pospiviridae

Potato Virus A,M, X, Y

Members of Potyviridae,

Carlavirus, 

Tobacco Rattle Virus Tobravirus

Fungi

Late blight Phytophthora 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
18

Common Name Scientific Name

Root knot Meloidogyne spp.

Columbia root knot Meloidogyne chitwoodi

Root lesion Pratylenchus penetrans

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

Late Blight

The disease known as late blight of potato is caused by an oomycete pathogen, Phytophthora infestans

(Cooke et al., 2012). Late blight is renowned in history as the causative agent of the Irish potato famine 

during the 1840s, which resulted in widespread potato crop failure and famine, and waves of migration 

from Ireland (Herman and Williams, 2012). Within the U.S., the pathogen was first reported in 1843, in 

New York City and Philadelphia (Nowicki et al., 2012; Akino et al., 2014), and became widespread 

throughout the rest of the world by 1845 (Fry, 2008). Late blight is prevalent in many areas of the U.S.

and is now found in nearly every potato state (Simplot, 2014). For example, in Idaho, the top-producing 

potato state, late blight has occurred in nearly every commercial potato field over the last 20 years, 

resulting in severe losses during some of those years (Miller et al., 2006).

Worldwide, late blight is a very destructive disease capable of destroying a potato crop in only a few 

days (Vleeshouwers et al., 2011), and outbreaks frequently turn into epidemics (Fry, 2008). Its success 

as a pathogen is due in part to its reproductive cycle and its ability to adapt quickly to resistant plants 

(Vleeshouwers et al., 2011). The late blight pathogen spreads quickly through infected fields, causing 

widespread foliar necrosis resulting in plant death and significant yield reduction. Infected tubers can 

cause lesions and rot that destroys entire lots in storage (Simplot, 2014). Because the primary source of 

infection is infested potato tubers, potato is generally the main crop affected by late blight (McGrath, 

2010). However, the pathogen will also infect other solanaceous plants and crops such as tomato and 

eggplant (Akino et al., 2014). Agricultural areas where potato and tomato are grown near each other, 

and grown all year round are at greater risk of developing late blight (Nowicki et al., 2012).

Phytophthora infestans is capable of reproducing either sexually or asexually (Nowicki et al., 2012). Fry 

et al. (1993) notes that the diversity of genotypes resulting from sexual reproduction can fuel more 

virulence in populations. Asexual reproduction of P. infestans can be viewed as a mechanism to greatly 

increase population growth under favorable environmental conditions (Fry, 2008), and may drive 

epidemics (Nowicki et al., 2012). Occurrence/predominance of only 1 mating type in a geographic area 

suggests that asexual reproduction is the only means of propagation in these areas (Fry et al., 1993). 

Population displacement of “old” populations or sexual recombination within the aggressive “new” 

population has resulted in severe outbreaks worldwide in recent decades (Chowdappa et al., 2014). 

These “new” populations have been associated with fungicide resistance or an ability to overcome host 

resistance (Chowdappa et al., 2014).

P. infestans usually overwinters on potato tubers or on one of its alternate hosts, tomatoes in 

greenhouses, so that the annual disease cycle may be difficult to break (Bush et al., 2012). Infected 

tubers from the previous season produce infected seedlings, a significant source of late blight inoculum. 

In the development of late blight disease on susceptible plants, P. infestans produces thousands of 
19

sporangia per lesion (Nowicki et al., 2012), each of which can, in turn, produce as many as 300,000 

sporangia per day (Fry and Goodwin, 1997). Once a potato plant is infected, late blight spores can be 

propagated for as long as the foliage is still green (Bohl et al., 2003). Dispersal is by wind (Bohl et al., 

2003; McGrath, 2010), frequently over long distances of up to 30 miles, as well as dispersal by infected 

tubers moved by humans and animals (Aylor et al., 2001; Bohl et al., 2003; Miller et al., 2006; Nowicki et 

al., 2012; Akino et al., 2014; Rowe et al., No Date). Dispersal during cloudy days or at night helps protect 

spores from the lethal effects of UV radiation (McGrath, 2010). Wind and rain may dislodge spores on 

infected plants, and winds may carry them into potato fields as far away as 10 miles, thereby initiating 

another disease cycle (Rowe et al., No Date). Spores may remain viable for up to a week (McGrath, 

2010; Nowicki et al., 2012). Spore and infected tuber movement is critical to epidemic development

(Fall et al., 2014). Depending on environmental conditions, regeneration time can be short, in as little as 

5-7 days (Nowicki et al., 2012). 

Late blight disease has several foliar symptoms in potato, including wilting, damping-off, and chlorosis

(Akino et al., 2014). The pathogen produces characteristic circular or irregular leaf lesions which are 

surrounded by a light yellowish-green margin which merges with healthy tissue. Lesions typically 

develop on lower leaves first because it is more humid closer to the soil, and on leaf edges or petioles 

where dew remains longer (Kirk et al., 2004). Symptoms typically appear within 5 to 7 days after 

infection (Bohl et al., 2003), and the disease cycle of colonization of uninfected plants, sporulation, and 

dispersal of spores to new plants can take place in less than five days (Fry and Goodwin, 1997). Once a 

potato field is infected, P. infestans has the potential to completely destroy the plants in the field in 

about a week (Nowicki et al., 2012). 

Lesions on tubers are shallow, sunken, coppery-brown dry rot spots which spread in an irregular pattern 

from the exterior of the tuber to the first 1/8 to 1⁄2 inch of the underlying flesh. The flesh beneath 

lesions is granular and tan to copper brown (Rowe et al., No Date). Lesion formation may be slowed 

under cool and dry storage conditions, but if storage is prolonged, lesions appear sunken and dried 

(Rowe et al., No Date). Lesions quickly get bigger and their color deepens to a range of dark brown to 

purple-black (Rowe et al., No Date). Infested tubers are also vulnerable to attack from bacteria, fungi, 

and other pathogens, which deteriorate tubers further (Kirk et al., 2004; Schumann and D'Arcy, 2005; 

Bush et al., 2012; Rowe et al., No Date). Reportedly, late blight lesions on tubers are less obvious on 

some cultivars, including the Russet varieties (Kirk et al., 2004), which may make diagnosis more 

difficult.

Other parts of the potato plant also deteriorate when infected with late blight. When stems are 

infected, they turn brown or black (Rowe et al., No Date), and all of the tissue above the stem dies

(McGrath, 2010). Vine death may occur very quickly under favorable conditions (Rowe et al., No Date). 

Even flowers show symptoms of infection (Porter et al., 2004). 

Besides lesions, there are several other diagnostic characters for late blight infection in potato fields. 

The appearance of white, velvety growth on foliage is characteristic of late blight (Kirk et al., 2004). In a 

field hard hit with late blight, dying plants emit a distinctive odor (Kirk et al., 2004).

When tomato is infected, symptoms are similar (Schumann and D'Arcy, 2005). Generally, the genotypes 

of P. infestans attacking tomato appear to be less virulent than those infecting potato (McGrath, 2010), 
20

and those strains specialized to attack tomatoes may be less pathogenic to potato than potato-adapted 

genotypes (Fry, 2008).

Potato crop vulnerability to late blight is influenced by factors such as weather (Sparks et al., 2014) and 

agronomic practices. Cool, cloudy, wet or humid weather with soil temperatures < 65 F. favors disease 

development (Bohl et al., 2003; Kirk et al., 2004; Miller et al., 2006; Gigot et al., 2009; Bush et al., 2012; 

Herman and Williams, 2012; Majeed et al., 2014; Rowe et al., No Date).

During cultivation of a potato crop, additional measures may be taken to minimize the development of 

late blight. These include water management such that moisture in the fields, particularly standing 

water, is minimized, by scheduling irrigations at times such that the foliage has the time to dry out 

before the next water application, and early enough in the day so that dew formation is decreased (Bohl

et al., 2003; Miller et al., 2006). 

Irrigating fields after rains or humid weather may also raise probability of disease development because 

water may dislodge spores from plants or soil and move to other, uninfected locations (Miller et al., 

2006; Rowe et al., No Date). In addition, the use of sprinkler irrigation may heighten vulnerability to P. 

infestans due to the potential for subsequent heavy dew formation (Miller et al., 2006). Operation of 

other agricultural machinery and equipment may also physically spread spores (Miller et al., 2006). 

There are several methods described in the literature to prevent late blight development. At present, 

there are no methods such as labeled fungicides which will kill late blight once the plant is infected 

(Miller et al., 2006), so disease prevention is currently crucial for growers. Most notable is fungicide 

treatment, which can be highly protective, especially under “late blight weather conditions” (Cooke et 

al., 2011; Nowicki et al., 2012; Rowe et al., No Date). Because fungicides operate as protectants rather 

than eradicators of the disease, they need to be applied prior to the expected timing for disease 

development. Forecasts of predicted disease assist growers with fungicide spray timing, and are 

available through disease forecast systems (Bohl et al., 2003). Typically, growers apply fungicides about 

two weeks before predicted infection of fields in their geographic area (Miller et al., 2006), and 

frequently need to be reapplied on a regular basis to achieve full protection (Wiik, 2014). For example, 

growers in northern Europe spray fungicides 10-15 times per season in order to control late blight (Jones

et al., 2014). In the U.S., more than 2000 tons of fungicide were sprayed in 2001. Such frequent 

chemical treatments impose a heavy economic burden on growers (Fry, 2008). Some sources (e.g., 

(Miller et al., 2006)) recommend alternating fungicides by different chemical class to achieve greater 

protection. Recent research indicates that systemic fungicides perform better than do contact 

fungicides (Majeed et al., 2014).

Crop rotation of potato with a second crop may break the cycle of infection (Miller et al., 2006; Cooke et 

al., 2011), except in some northern states where P. infestans spores cannot overwinter (McGrath, 2010). 

Cultural practices such as land sharing and shorter rotation periods between potato crops may result in 

increased survival of volunteer potato plants and tubers which may be infected (Gigot et al., 2009). 

Volunteer potatoes and tomatoes are a potential source of P. infestans inoculum (Eberlein et al., 1998; 

Miller et al., 2006; Everman and Long, 2010; Cooke et al., 2011; Rowe et al., No Date). Spores may 

persist in overwintered volunteer potato plants, and in the soil for two months under typical field 

conditions (Cooke et al., 2011). Volunteers typically augment and accelerate epidemics of P. infestans
21

rather than initiate them (Cooke et al., 2011). In areas with warmer winter temperatures, spores may 

survive overwintering (Gigot et al., 2009; McGrath, 2010; Cooke et al., 2011), and rain can wash spores 

down plants into the soil (McGrath, 2010), where they can survive until the next year’s growing season 

(Cooke et al., 2011). This source of inoculum can be remedied by monitoring for and destroying any 

volunteer potatoes and tomatoes (McGrath, 2010; Rowe et al., No Date).

Because P. infestans is capable of infecting alternative hosts such as such as black nightshade, Solanum 

nigrum, bittersweet, S. dulcamara, and hairy nightshade, S. physafolium (Gronberg et al., 2012),

management of solanaceous weeds may help to control late blight (McGrath, 2010). In addition to 

serving as reservoirs for infection, weeds may also contribute to infection in potato fields by restricting 

air movement within the potato canopy (Kirk et al., 2004), and impeding adequate spray coverage with 

fungicides (Miller et al., 2006).

Growers frequently discard defective potatoes into cull piles (Miller et al., 2006; Johnson, 2010; Rowe et 

al., No Date), which are another major source of P.infestans infection. In some geographic areas, if cull 

piles are small enough, the tubers will freeze and any infection will be killed (Kirk et al., 2004). Tuber 

decomposition in cull piles can be hastened by covering with plastic tarps to increase temperatures 

within the piles (Kirk et al., 2004).

Another important source of late blight disease is infested seed tubers (Kirk et al., 2004; Miller et al., 

2006; Cooke et al., 2011). Usually, tubers are infected in the field when being handled (Cooke et al., 

2011). To reduce the risk of late blight affecting potato crops, growers are advised to plant only certified 

seed potatoes (Kirk et al., 2004; Johnson et al., 2010; McGrath, 2010; Rowe et al., No Date). Seed 

treatment with an appropriate product labelled for that purpose may also help to reduce chances of 

infection. Such treatments do not kill the spores, but decrease infection of seed tubers (Bohl et al., 

2003). P. infestans has been documented to spread in cut seed, with length of storage correlated with 

probability of disease spread (Lambert et al., 1998).

Infection risk can also be minimized by placement position of seed during planting; planting seed deeper 

is preferred since tubers developing closer to the soil surface are more at risk of infection because of 

proximity to infected plant parts above the soil (Bohl et al., 2003). Growers are also advised to restrict 

planting to areas which can be easily sprayed with fungicides, as well as to avoid planting in field 

locations which are likely to be wetter than usual, such as in low areas which may accumulate standing 

water, or in the path of a center pivot irrigation system (Bohl et al., 2003).

Because excess nitrogen often encourages heavy vine growth and leads to an extended time period for 

potential late blight infection, growers are frequently advised to avoid any unnecessary fertilizing during 

the growth cycle (Miller et al., 2006).

Prudent growers will monitor for late blight symptoms on a regular basis and begin scouting early 

enough to catch symptoms when they are still small and infection of nearby fields can be mitigated 

(Miller et al., 2006). This is a challenge because such small early lesions are not easily detected visually 

until 2 to 4 days following infection (Fry, 2008; Nowicki et al., 2012).

Late blight-prediction models (sometimes referred to as Decision Support Systems (DSS)) which indicate 

that weather conditions or other factor predispose a geographic area to late blight infection, provide 

growers with cues for when to scout fields more frequently during that time (Bohl et al., 2003). In the 
22

last several years, late outbreak prediction models have been used to attempt to predict favorable 

weather conditions in specific geographic areas, so that growers may be able to have advance notice in 

order to decide when to treat fields with fungicides (Herman and Williams, 2012). Decision support 

systems are not perfect: growers generally do not know if late blight spores are present in their fields, 

thus, spraying fungicides when weather conditions are ripe for a late blight attack may actually waste 

resources in the form of chemicals and labor. However, these systems have become popular worldwide 

for forecasting potential late blight risk (Fall et al., 2014). 

Harvest is a sensitive time period for spread of late blight (Rowe et al., No Date). Sources vary in 

recommendations of how long before harvest to kill vines, approximately 2-3 weeks beforehand 

(Johnson et al., 2010; Rowe et al., No Date), while Olsen et al. (2005) states that there is some flexibility 

in timing of vine kill. Growers are advised to avoid harvesting during periods of wet weather (Bohl et al., 

2003; Miller et al., 2006) or when tuber pulp temperatures exceed 65oF, since late blight and other 

pathogens are more active in warmer temperatures (Bohl et al., 2003).

The use of resistant cultivars is also an important option (Johnson et al., 2010), which should lead to 

increased yield. However, most popular potato cultivars on market are not highly resistant (Fry, 2008).

Development of late blight resistant cultivars is an important step toward protection of potato from this 

devastating disease. Historically, traditional breeding programs have been used toward this aim, and 

are slow and inefficient (Vleeshouwers et al., 2011). Because of its adaptability, P. infestans has evolved 

so that resistance genes have been rapidly overcome by new P. infestans races (Jones et al., 2014). In 

addition, traditional crop breeding may unintentionally break up favorable combinations of other alleles 

or introduce other deleterious alleles of genes linked to disease resistance (Jones et al., 2014). 

A benefit of plants with late blight resistance genes is that fields may require less frequent spraying with 

fungicides, which will reduce the costs and associated environmental impacts substantially (Jones et al., 

2014).

Other pathogenic microorganisms which are associated with diseases of potatoes, is discussed in Section 

2.1.2, General Agronomic Practices, Disease Control.

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 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
23

Hairy nightshade (Solanum 

sarrachoides)

Common lambsquarters 

(Chenopodium album)

Redroot pigweed 

(Amaranthus retroflexus)

Ragweed (Ambrosia 

artemisiifolia)

Kochia (Kochia scoparia)

Pennsylvania smartweed 

(Polygonum pennsylvanicum)

Barnyardgrass (Echinochloa 

crus-galli)

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, S-ethyl dipropylcarbamothioate (EPTC), and metolochlor 

(USDA, 2000; Bechinski et al., 2001; 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 diseases 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 there is little 

probability of successful establishment (OECD, 1997). 

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. 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 
24

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 U.S. 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) 

(USDA-NASS, 2008). 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 2.5.1, 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% of the 2012 annual potato crop was used as seed (NPC, 2012) in the form of 

seed potatoes. Certified seed potatoes are produced to ensure genetic purity and to reduce disease 

introduction (NPC, 2012). 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). The use of good quality seed potatoes is important 

to successful potato culture. It is recommended that ideal seed size is about two to four ounces, about 

the size of a golf ball (Hollingsworth, No Date).

There are 16 potato seed certification agencies in the US, including one in each major production state

(NPC, 2012). 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 2013 in order of decreasing production 

were Idaho (>33,000 acres planted), North Dakota, Montana, Maine, Colorado, Wisconsin, Nebraska and 

Minnesota (>5,000 acres harvested) (USDA-NASS, 2014c).

Potato Processing and Storage

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

potatoes and dehydrated potatoes (Driskill et al., 2007). 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 long-distance shipping 

is expensive. Therefore, chipping plants tend to be located near heavily populated areas (Guenther, 

2010c).

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 
25

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).

Tubers for fry processing account for 36% of all U.S. potato production, and >50% of the land area for US 

potato production is planted in Russet Burbank and Ranger Russet (Zhu et al., 2014).

2.2 Physical Environment

2.2.1 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 US 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, 2005; 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 US is irrigation, representing approximately 67.2% of all the groundwater pumped 

each day (McCray, 2009). In the US, 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 US and its territories (US-EPA, 2011d). 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, 

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

associated with high applications of manure or fertilizers or excessive irrigation (Zebarth et al., 1999; 

DEFRA, 2006). 
26

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 pollution. 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, 

2005). 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, 2005). 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 (USEPA, 2005). 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 erosion-mediated sedimentation can increase 

fertilizer runoff, thereby increasing nutrient loading and facilitating higher water turbidity, algal blooms, 

and oxygen depletion (Skaggs et al., 1993; US-EPA, 2005). 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).

Most of the potatoes produced in the US 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 US (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). 

2.2.2 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 
27

medium for terrestrial plant life (USDA-NRCS, 2004). 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, 1999). 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 carbonnitrogen ratio, numbers of microorganisms and soil fauna all vary seasonally, as well as over extended 

periods of time (USDA-NRCS, 1999). 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, 

1999). 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., 1996). 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., 2004).

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 susceptible to 

diseases like tuber rot (Plissey and Erhardt, 2000; Johnson and Sideman, 2006). 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, 
28

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), 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).

2.2.3 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 (SIP) (US-EPA, 2011d). Regulation 

of agricultural sources within a SIP does not appear to be typical. For example, based on a review of the 

available plans in Idaho, 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, 2011d). 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 U.S. EPA regulates mobile source emissions by reformulated gasoline and automobile pollution 

control devices (US-EPA, 2011d). Stricter requirements, such as vapor recovery nozzles on gas pumps, 

may apply in non-attainment areas.

2.2.4 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 
29

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 U.S. 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 

U.S. 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 U.S. EPA, represented 

6.3% 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 U.S. 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%; enteric fermentation (primarily methane emissions from cattle), 

33%; manure management, 16%; and rice cultivation, 2%. 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% of the total (DEFRA, 

2006; US-EPA, 2012a).

2.3 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.

2.3.1 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 
30

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, 1987). 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 (USDAAPHIS, 2013b). 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). USDA-APHIS Wildlife Services has also received complaints for damage caused by 

sandhill cranes (USDA-APHIS, 2013b).

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. 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, 2007; Simplot, 2013; 

2014). 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, 2007) 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 broad-spectrum insecticides are potentially toxic to invertebrates and vertebrates. 

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

2000; 2009b).

2.3.2 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 2.1, 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 U.S. 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 2.1.2, General Agronomic Practices. 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 
31

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, 

1997). Section 2.3.3, Gene Flow and Weediness, discusses this subject. Because Russet Burbank is 

sterile (PAA, 2009), there is virtually no chance for gene flow.

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). 

2.3.3 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.

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; and 

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 (Holm et al., 1979; Muenscher, 1980; Love, 1994; OECD, 

1997).

Gene flow by hybridization is not possible for the Russet Burbank cultivar because it is sterile (PAA, 

2009; NSF, 2011; Simplot, 2013; 2014) 

In general, pollination of fertile varieties of potato is mostly by bumblebees (Bombus impatiens), which 

have a relatively short flight range (less than three kilometers) (OECD, 1997). Pollen dispersal by nectarseeking pollinators is limited because potato flowers have no nectar. The honeybee (Apis mellifera) and 

Bombus fervidus are not attracted to them, and wind plays an insignificant role in pollination (OECD, 
32

1997). 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). In addition, the effect on 

pollinators is probably not important since potatoes are cloned . Based on the relative lack of pollinator 

importance in potato production, APHIS does not further consider pollinator issues in this assessment.

For fertile potato varieties, about 80-100% 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 (Pallais, 1987; Simplot, 2013). Russet Burbank is fully sterile, precluding any 

possibility of TPS production. But plants produced from TPS are no weedier than volunteer plants 

produced from overwintered 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, 1997). 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, 1997).

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 potato fields (Love, 

1994). 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 U.S. 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, there are several biological barriers 

to gene transfer such as multiple ploidy levels and endosperm imbalances (Love, 1994). Hybridization 

between native and cultivated potatoes has never been reported in the U.S., although gene transfer has 

been accomplished using special laboratory techniques (Love, 1994; US-EPA, 2011b).

2.3.4 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., 2004) 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., 1996; 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., 2004; Rosen, 2010a). 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 
33

diversity in the rhizosphere may be extensive and differs from the microbial community in the bulk soil

(Garbeva et al., 2004).

Larkin (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 soil-borne 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 and the number of misshapen tubers. 

Larkin (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-barley-potato 

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).

2.3.5 Biodiversity

Biodiversity refers to all plants, animals, and microorganisms interacting in an ecosystem. Biodiversity 

provides valuable genetic resources for crop improvement (Harlan, 1975; Wilson, 1988), 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, notillage, composting, green manuring (growing a crop specifically for the purpose of incorporating it into 

the soil in order to provide nutrients and organic matter), and 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 
34

Section 2.1, Agricultural Production and Agronomic Practices, and animals in Section 2.3.1, Animal 

Communities.

2.4 Human and Animal Health

Humans are either consumers of potato and products derived from it, or are workers who produce 

potato crops. Under the FFDCA, it is the responsibility of food and feed manufacturers to ensure 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 used 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. FDA evaluates the submission and 

responds to the developer by letter. Simplot submitted a letter of consultation on April 14, 2014, which

FDA is still reviewing (BNF No. 000146).

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). Genetic modification, as a source of uncertainty, is common to all forms of 

plant breeding. 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 generally conclude that there are no significant nutritional differences in conventional versus GE 

plants for food or animal feed (Faust, 2002; Flachowsky et al., 2005).

2.4.1 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; FAO, 2008; Bushway, 2010). They have the highest 

protein content (around 2.1% 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, persons with diabetes 

or similar conditions may need to eat potatoes sparingly. 

U.S. per capita potato consumption is summarized in Table 6. 

Table 6. U.S. Per Capita Potato Consumption 2012 (lb/person/yr)

Fresh 

Market

Processing

All 

Potatoes Canned Frozen Chips Dehydrated Total 

Processing
35

35.5 0.9 49.8 16.9 13.2 80.8 116.3

Source: (Council, 2014)

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 baking and frying.

Glycoalkaloids

Glycoalkaloids are nitrogenous secondary metabolites found in many plant species (Friedman and Dao, 

1990), whose functions are to defend against pests, predators, and pathogens (Friedman, 2006; Ruprich

et al., 2009). The two major glycoalkaloids present in potato are alpha-solanine and alpha-chaconine 

(Friedman and Dao, 1990; Friedman, 2006).

At high levels, glycoalkaloids in potatoes can be toxic, and can cause poisoning symptoms such as 

headache, acute gastrointestinal distress (nausea, diarrhea, vomiting, abdominal pain), and a burning 

sensation in the mouth (Friedman, 1997; Ruprich et al., 2009; Petersson et al., 2013). In more severe 

cases of poisoning, these symptoms may be followed by drowsiness, apathy, visual disturbance, shallow 

breathing, rapid and weak pulse, loss of consciousness and coma, and even death (Friedman, 1997; 

2006; Ruprich et al., 2009). A lethal dose for humans is approximately 1-2 mg/kg of body weight

(Friedman et al., 1997). Cases of mild toxicity are frequently overlooked and go undiagnosed because 

symptoms may be confused with other causes of stomach upset (Ruprich et al., 2009). In vertebrates, 

glycoalkaloids disrupt cell membrane transport of calcium ions and acetylcholinesterase function 

(Friedman, 1997; Ruprich et al., 2009).

For food safety purposes, an upper limit for glycoalkaloid content of 200 mg/kg of potato is generally 

accepted (Sinden, 1987; Friedman, 2006; Petersson et al., 2013). Levels greater than 14 mg/kg fresh 

weight potatoes can be perceived as bitter to human (Friedman, 2006), which appears to be an indicator 

of the presence of glycoalkaloids since naturally bitter potato cultivars contain higher levels of 

glycoalkaloids than do cultivars that do not taste bitter (Jansky, 2010).

Although glycoalkaloids are synthesized throughout the potato plant (Friedman, 1997; Petersson et al., 

2013), the highest levels are in metabolically active parts of the plant such as flowers, new leaves, and 

sprouts (Friedman, 1997; Petersson et al., 2013). Comparatively, tubers have the lowest glycoalkaloid 

levels in fresh potatoes (Friedman and Dao, 1990), while sprouts, leaves and roots have greater amounts

(Friedman and Dao, 1990). Higher leaves contain more total glycoalkaloids than do lower leaves. 

Within tubers, the highest levels are within the first 1mm of the skin, decreasing significantly toward the 

center of the tuber (Kozukue and Kozukue, 1987), so that removing the first 3-4 mm of the skin generally 

removes almost all of the glycoalkaloid content in tubers (Friedman, 2006). Larger tubers have higher

glycoalkaloid content (Friedman, 2006). Genetic transformation does not appear to affect glycoalkaloid 

levels (Birch et al., 2002).

Glycoalkaloid content appears to vary by cultivar and geographic location (Sinden and Webb, 1972; 

Friedman et al., 1997). Levels can also be affected by environmental factors such as higher temperature 
36

and more light (Friedman et al., 1997). Delaying harvest date tends to decrease glycoalkaloid 

production (Ruprich et al., 2009).

U.S. commercial potato varieties typically have glycoalkaloid ranges below the recommended rate of 

200 mg/kg of fresh weigh potato (a range of 20-130 ppm) (Sinden and Webb, 1972; Friedman and Dao, 

1990; Friedman, 2003). These levels are not affected by cooking (Friedman et al., 1997), but may be 

affected by processing operations such as slicing, peeling, and preparation for freezing and chip 

production (Friedman et al., 1997). A higher concentration of glycoalkaloids ends up in skins of frozen 

and processed potato products, and potato chips contain more than fries (Friedman and Dao, 1990).

During storage, when harvested tubers are exposed to light or become damaged, glycoalkaloid content 

may rise, and may result in green areas of coloration on potato skins (Sinden, 1987; Center, 2010)

(Friedman and Dao, 1990; Friedman, 1997); these changes differ with cultivar and genotype (Petersson

et al., 2013). 

Patatins

Patatins are a family of proteins comprising 30 to 40% of the soluble protein in potatoes (Mignery et al., 

1988). Allergic reactions to cooked potatoes are considered to be very uncommon and were reported 

only in children (De Swert et al., 2002). Patatin was identified as the major allergen involved in this 

reaction (De Swert et al., 2007). Individuals who are allergic to patatin would need to avoid eating 

potatoes because potato protein naturally contains a relatively large proportion of patatin.

Acrylamide

Of greatest importance 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, 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 
37

higher the greater the acrylamide concentration (Arvanitoyannis et al., 2008; Pedreschi, 2009; Halford et 

al., 2012a; Kotsiou et al., 2013).

Important variables leading to acrylamide formation and affecting acrylamide concentration in cooked 

potatoes include the reducing sugar content, processing/cooking temperature and method, 

cooking/processing time, moisture content, and additives (Halford et al., 2012a; Kotsiou et al., 2013). In 

turn, concentrations of sugars and amino acids are influenced by cultivar, fertilizers, climate, and 

storage conditions (Pedreschi, 2009). 

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). Because of higher rates of 

consumption of potato chips and French fries by children, adolescents, and males under the age of 

twenty-five, acrylamide exposure to these groups is likely to be higher (Dybing et al., 2005). Acrylamide 

is also present in other foods such as coffee, some breads, biscuits, gingerbread, and processed onion 

mix and dip mixes. Smoking may also contribute to human exposure to acrylamide (Friedman, 2003; 

Chawla et al., 2012; Kotsiou et al., 2013).

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 Food and Agriculture 

Organization/World Health Organization (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, 2013b).

2.4.2 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 U.S.-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 

require 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.
38

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 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)).

2.4.3 Animal Feed

Potatoes used as livestock feed accounted for approximately 1% 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, 2013c). 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, 2010d).
39

Table 7. U.S. 2012 Potato Utilization

Utilization Item CWT (1,000) (% of potatoes 

harvested) 

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 283,220 (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%)

Total Production 462,766

Source: (USDA-NASS, 2013c)

Potatoes constitute at least part of the diet for several domestic animals, including dogs, 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 lbs. of grain) (Corbett, No Date).
40

Feed does not include the leafy green foliage of potato plants since flowers, sprouts, and foliage have

abundant glycoalkaloids, which are potentially poisonous for livestock (Sinden, 1987).

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. Consequently, any uncertainty in this area 

is addressed during an FDA inquiry process. 

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 April 14, 2014, which FDA is currently reviewing (BNF No. 000146).

2.5 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.

2.5.1 Domestic Economic Environment

Potatoes contribute approximately 15 % of farm sales receipts for vegetables, making potatoes the 

leading vegetable crop in the U.S. (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. The Russet Burbank variety is primarily used for French fries, but can be used 

fresh for baking (Pavek et al., 1992; PAA, 2009). 

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, 2010d). Because potato sales for livestock feed usually receive the lowest 

price, potatoes are not sold for livestock feed if other uses are available (Guenther, 2010d).
41

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, although recently, some western growers have entered the packing 

business, often in partnerships or cooperatives with other growers (Guenther, 2010b).

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 the rest. Others purchase off-grade 

potatoes from fresh packers for processing (Guenther, 2010c).

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% 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 September-August marketing 

year. Less than 10% 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).

Sale values per acre are 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, 2010d).

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% of total production costs in eastern Idaho in 2007 (Patterson, 

2010). Potato production costs for irrigation in the western U.S. ranges between $1,500 and $3,500 per 
42

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 return over variable costs for a 

small farm (30-50 acres) with 100% organic premiums is $1,026/acre and $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).

In general, post-harvest losses are a significant part of the production costs of fruits and vegetables, and 

may reach as high as 50% (Martinez and Whitaker, 1995; Llorente et al., 2011). 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

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., 2012).

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 products (Hunt et al., 1993; Steffens, 1994; 
43

Stremmel et al., 2010; Llorente et al., 2011; 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 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 multi-gene 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). 

Reducing Sugars

The levels of reducing sugars (sugars which can be oxidized) in potato are critically important because of 

maintenance of product quality throughout storage and processing (Olsen et al., 2005). In potato, the 

reducing sugars of interest are glucose and fructose (Olsen et al., 2005). High levels of reducing sugars 

may lead to unacceptably dark colors when cooking frozen or processed potatoes, and bitter taste

(Bethke et al., 2009). In addition, reducing sugars react with amino acids during cooking in the Maillard 

reaction (O'Brien et al., 1989; Bhaskar et al., 2010), and as such, are important factors in acrylamide 

formation in fried potato products (Zhu et al., 2014).

At harvest, most potatoes contain low levels of reducing sugars. Minimizing the time between vine kill 

and harvest is recommended to maintain these low levels (Olsen et al., 2005). In general, the lower the 

storage temperature for tubers, the greater the concentration of sugars (Olsen et al., 2005). Because 

potatoes may frequently need to be stored for up to 12 months before processing, maintenance of low 

levels of reducing sugars is a challenge for processors (Olsen et al., 2005). If tubers are stored too long, 

reducing sugars tend to accumulate (Driskill et al., 2007). If sugar levels rise too high, processors may 

reject them for use as fries or chips, and growers may be forced to sell them for lower prices to other 

markets (Driskill et al., 2007).

Currently potatoes that are intended for fry production are kept at 46o-48oF (Olsen et al., 2005; Driskill

et al., 2007; Wu et al., 2011), which represents a compromise between the potential weight loss, 

increased disease pressure and accompanying spoilage, and sprouting, that comes with warmer 

temperatures, and the problems of cold-induced sweetening (CIS), which leads to increased acrylamide 

potential, and decreased product quality (Driskill et al., 2007).

Another problem caused by high levels or reducing sugars is called sugar end defect by the potato 

industry (Driskill et al., 2007) which can result from uneven environmental conditions during tuber 

initiation and early tuber bulking (Zhu et al., 2014). This occurs when reducing sugar levels rise and 

preferentially settle in the basal end of the potato, so that there is an uneven distribution of sugars in 

processed potatoes and a resulting darker color in those sections: for example, one end of a French fry 

will be darker than the other (Zhu et al., 2014). If levels of sugar ends are extremely high, the potatoes 

cannot be used for premium French fries, and may result in loss of economic value to the processors 

(Zhu et al., 2014). These defects may also result in higher prices for consumers (Zhu et al., 2014).

For all of these reasons, breeders and growers strive to produce potatoes destined for processing that 

maintain a stable, relatively low level of reducing sugars throughout storage (Driskill et al., 2007). 
44

2.5.2 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% in value and 79% in volume during the 

last 10 marketing years (Board, 2013). Frozen potato products comprise 60% 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 (Board, 2012; USDA-ERS, 

2013). Mexico provides the U.S. with the largest market for exporting potato flakes and granules and is 

the second largest market destination for frozen potatoes (Board, 2012; USDA-ERS, 2013).

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 U.S. will facilitate the growth of the export market by continuing to gain 

new market access, as recently occurred for fresh table-stock to the Philippines (Board, 2013).

2.5.3 Organically Certified Economic Environment

In the U.S., products produced using only specific methods and certified under the USDA AMS National 

Organic Program (NOP) definition of organic farming can be marketed and labeled as “organic” (USDAAMS, 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.

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 . . . .”
45

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 (USDA-AMS, 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

The organic sector is rapidly growing both in the U.S. 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
46

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 reflect 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).
47

3. ALTERNATIVES

This document analyzes the potential environmental consequences of a determination of nonregulated 

status of Simplot InnateTM W8 potato. 

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 W8 potato and 

progeny derived from Simplot InnateTM W8 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 W8 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 W8 potato. 

This alternative is not the Preferred Alternative because a Plant Pest Risk Assessment (PPRA) found 

Simplot InnateTM W8 potato is unlikely to pose a plant pest risk (USDA-APHIS, 2014b). 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 W8 Potato Is No Longer a Regulated 

Article

Under this alternative, Simplot InnateTM W8 potato and derived progeny would no longer be regulated 

articles under the regulations at 7 CFR part 340. Permits issued or notifications acknowledged by APHIS 

would no longer be required for introductions of Simplot InnateTM W8 potato and progeny derived from 

this event. Under this alternative, growers may have future access to Simplot InnateTM W8 potato and 

progeny derived from this event if the developer decides to commercialize Simplot InnateTM W8 potato.

This alternative meets the purpose and need to respond appropriately to a petition for nonregulated 

status when there is a determination of no pest risk. Based on the PPRA conclusion that Simplot 

InnateTM W8 potato is unlikely to pose a plant pest risk (USDA-APHIS, 2014b), conferring nonregulated

status to Simplot InnateTM W8 potato is a response that is consistent with the plant pest provisions of 

the Plant Protection Act and the regulations codified in 7 CFR part 340.

3.3 Alternatives Considered But Rejected from Further Consideration

APHIS assembled a list of alternatives that might be considered for Simplot InnateTM W8 potato. The 

agency evaluated these alternatives, in light of the agency's authority, environmental safety, efficacy, 

practicality, and other concerns. APHIS rejected several alternatives based on the discussions 

summarized in this section. 
48

3.3.1 Prohibit Any Simplot InnateTM W8 Potato from Being Released

In response to public comments stating a preference for GE organisms to not enter the marketplace, 

APHIS considered prohibiting the release of Simplot InnateTM W8 potato, including denying any permits 

associated with the field testing. APHIS determined this alternative is not a reasonable alternative 

because APHIS found Simplot InnateTM W8 potato is unlikely to pose a plant pest risk (USDA-APHIS, 

2014b).

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 W8 potato is unlikely to pose a plant pest risk, there is no regulatory basis for 

considering approval of the petition only in part.

3.3.3 Isolation Distance between Simplot InnateTM W8 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 W8 potato from conventional or specialty 

potato production. Isolation distances may be useful when wind-borne pollen is likely to disseminate 

genes long distances. Potato is not considered to be a wind-pollinated crop (OECD, 1997b), so imposing 

an ineffective restriction makes this alternative unreasonable. Further, an alternative based on 

requiring isolation distances would be inconsistent with the finding that Simplot InnateTM W8 potato is 

unlikely to pose a plant pest risk (USDA-APHIS, 2014b).

APHIS also considered geographically restricting the production of Simplot InnateTM W8 potato. The 

restrictions could be based either on the production locations of non-GE potato in organic production 

systems, or production systems for GE-sensitive markets, or in response to public concerns regarding 

possible gene movement between GE and non-GE plants. The PPRA did not identify geographic 

differences associated with any identifiable plant pest risks for Simplot InnateTM W8 potato (USDAAPHIS, 2014b) and found it will not exhibit a greater plant pest risk in any geographically restricted area. 

To restrict production locations when there is unlikely to be any productive value creates an ineffective 

restriction that makes this alternative unreasonable. Further, an alternative based on restrictions to 

production locations would be inconsistent with the finding that Simplot InnateTM W8 potato is unlikely 

to pose a plant pest risk (USDA-APHIS, 2014b).

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 provisions of the PPA. 

Nevertheless, APHIS is not expecting significant effects. However, individuals might choose on their own 

to geographically isolate their non-GE potato production systems from Simplot InnateTM W8 potato, or to 

use isolation distances and other management practices to minimize gene movement between potato 
49

fields. Information to assist growers in making informed management decisions for Simplot InnateTM W8 

potato is available from the Association of Official Seed Certifying Agencies (AOSCA, 2010).

3.3.4 Requirement of Testing for Simplot InnateTM W8 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 even if it was 

within APHIS’s statutory authority to establish this type of system. The inability to implement and 

maintain this type of system makes this potential alternative unreasonable.

3.4 Comparison of Alternatives 

Table 8 includes a summary of the potential impacts associated with selection of the alternatives 

evaluated in this EA. The potential environmental consequences are presented in Section 4 of this EA.

Table 8. 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, 2014b)

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 W8 potato may 

reduce acreage dedicated to 

conventional potatoes.

Agronomic Practices

Agronomic practices will 

remain the same as used 

currently.

Unchanged from No Action 

Alternative,.
50

Table 8. Summary of Issues of Potential Impacts and Consequences of Alternatives

Attribute/Measure Alternative A: No Action Alternative B: Determination 

of Nonregulated Status

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

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.
51

Table 8. Summary of Issues of Potential Impacts and Consequences of Alternatives

Attribute/Measure Alternative A: No Action Alternative B: Determination 

of Nonregulated Status

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 activitiessuch 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 ofthe

chemicals, as well asmotor 

vehicle emissionsfrom 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.

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 W8 tubers may be 

exposed to increased levels 

of glutamine, but this is not 

expected to be detrimental.
52

Table 8. Summary of Issues of Potential Impacts and Consequences of Alternatives

Attribute/Measure Alternative A: No Action Alternative B: Determination 

of Nonregulated Status

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 W8 potato with 

conventional varieties, 

resulting progeny may 

contain lowered polyphenol 

oxidase levels. However, this 

is not expected to be 

detrimental. Simplot InnateTM 

W8 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 W8 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

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 

could be reduced 

approximately 60-70%, which 

would benefit human health.
53

Table 8. Summary of Issues of Potential Impacts and Consequences of Alternatives

Attribute/Measure Alternative A: No Action Alternative B: Determination 

of Nonregulated Status

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, lower reducing 

sugars) and potential reduced 

wastage (low bruising, late 

blight resistance), Simplot 

InnateTM W8 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 W8 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 W8 traits are 

approved by importing 

countries, it may make up a 

larger percentage of potato 

import markets.

Other Regulatory Approvals

U.S.

FDA completed 

consultations, EPA tolerance 

exemptions and conditional 

pesticide registrations 

granted

FDA is currently reviewing 

Simplot’s voluntary 

consultation submission of 

April 14, 2014.
54

Table 8. 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 W8 potato.

Compliance with Other Laws

CWA, CAA, EOs Fully compliant Fully compliant 
55

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 W8 potato does not pose a plant pest risk (Preferred Alternative). 

Potential environmental impacts from the No Action Alternative and the Preferred Alternative for 

Simplot InnateTM W8 potato are described in detail throughout this section. A summary of potential 

environmental impacts is presented in Table 8 (Section 3.4, Comparison of Alternatives). 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 W8 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). 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 W8 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 W8 potato to occur 

anywhere in the U.S., APHIS will limit the environmental analysis to those areas that currently support 

potato production.
56

4.3 Agricultural Production of Potato 

4.3.1 Acreage and Area of Potato Production

Acreage in potato production decreased in recent years, whereas potato yields increased dramatically. 

Potato acres harvested 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 in the U.S. (USDA-NASS, 2012b). 

Per-acre yields, which averaged 397 cwt per acre in 2011 and 401 cwt per acre in 2012 increased eightfold since the early 1900s and doubled since the early 1960s (USDA-NASS, 2013a). 

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. While harvested acreage has declined over the years, total production has increased 

(Guenther, 2010b). Under the No Action alternative, agricultural land used for potato production will 

likely decline as potato production yield increases. 

Preferred Alternative: Acreage and Area of Potato Production

If APHIS chooses the Preferred Alternative, the Simplot InnateTM W8 potato event may become 

commercially available to the general public. Simplot InnateTM W8 potato is not expected to affect 

overall demand for potatoes, but growers who now purchase conventional varieties of Russet Burbank, 

Ranger Russet and Atlantic potato seed would have the option of purchasing the Simplot InnateTM W8 

variety instead. With the traits of late blight resistance, reduced acrylamide potential, reduced black 

spot bruising, and lower levels of reducing sugars, the Simplot InnateTM W8 potato may replace other 

varieties of potato currently on the market, resulting in increased market share for the Simplot InnateTM

W8 potato. 

Simplot’s data demonstrate no differences in morphological characteristics and agronomic requirements 

between Simplot InnateTM W8 potato and other potato cultivars (Simplot, 2014) and Simplot InnateTM 

W8 potato 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 InnateTM W8 potato.

As described in the petition (Simplot, 2014), the agronomic characteristics of the Simplot InnateTM W8 

event are essentially the same as their conventional counterparts, and therefore would be grown in the 

same way as their conventional counterparts. The Simplot InnateTM W8 potato event does 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 as in the No Action Alternative.

4.3.2 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. 
57

Preferred Alternative: Agronomic Practices

The agronomic evaluation of the Simplot InnateTM W8 potato event is summarized in Section 11 of the 

petition, with details provided in Section 11.1.3; analysis of disease susceptibility is presented in petition 

Section 11.2 (Simplot, 2014). Since all the Simplot InnateTM W8 potato event is 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, 

2014). 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 (Simplot, 

2014).

Simplot InnateTM W8 potato has been engineered to be resistant only to certain strains of one particular 

disease of potato, late blight. It is unknown whether this will lead to a reduction in frequency of 

fungicide application and volume for growers. However, no other changes to current agronomic 

practices will be needed to grow the potatoes, thus the incorporated traits are not expected to affect 

agronomic practices other than potential reduction in fungicide use and volume (Simplot, 2014; USDAAPHIS, 2014b). All events considered for deregulation were selected to exhibit comparable phenotypic 

characteristics to the control varieties when grown using standard industry practices.

Late Blight Resistance

The Potato Late Blight Resistance Gene (Rpi-vnt1) encodes a resistance protein, VNT1, which reacts with 

a pathogen-specific effector protein to halt the spread of infection (Simplot, 2014). Widely consumed 

plant species that are reported to contain disease-resistance (R) genes include the Solanaceae family, 

Zea mays (maize), Glycine max (soybeans), Oryza sativa L. (rice), and Triticum aestivum L. (common 

wheat) (Bakker et al., 2011). In addition to these common cultivated crops, the Rpi-vnt1 gene is 

identical to the Rpi-phu1 gene (Rodewald and Trognitz, 2013) found in some S. phureja species, a potato 

species consisting of many varieties which are currently consumed by indigenous people in South 

America. The presence of similar or identical genes in frequently consumed tomatoes and potatoes that 

have not had negative impacts on human health establishes a history of safe use (Simplot, 2014).

Resistance to P. infestans occurs in many tuber-bearing wild Solanum species that belong to the highly 

diverse section Petota Dumort. (Vleeshouwers et al., 2011). Wild relatives of potato are a source of late 

blight resistance genes (Jones et al., 2014). To date, 21 R-genes that confer differential resistance 

specificities to P. infestans isolates have been cloned from various Solanum species crops (Vleeshouwers

et al., 2011). Most Solanum R genes appear to have coevolved with P. infestans at its center of origin in 

central Mexico (Vleeshouwers et al., 2011).

Biochemical characterization and safety assessment of the VNT1 protein suggested a negligible risk 

associated with using VNT1 to confer late blight resistance to potato cultivars. The encoded VNT1 

protein is native to Solanum species and provides protection against P. infestans, the causal agent of 
58

late-blight disease. Currently VNT1 represents only one of 68 distinct R-genes that have been 

characterized from wild Solanum species, which shows the breadth and importance of these genes to 

potato biology (Rodewald and Trognitz 2013).

Additionally, Simplot InnateTM W8 potato had less evidence of scab (as measured by mean percent 

lesion coverage of the tuber) than did the control line, and the lesions produced by the disease were less 

severe than in the control line. This result will be monitored in future field and storage studies to 

determine if this pattern of resistance to scab persists in commercial production (USDA-APHIS, 2014b). 

If so, this finding will improve the agronomic properties of Simplot InnateTM W8 potato for future 

development, but will not change the plant pest potential of the tuber.

In summary, 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 (Simplot, 2014). Field trials conducted by Simplot over multiple years showed no 

evidence for altered growth characteristics such as increased plant vigor, increased tuber set, early 

tuber sprouting, or delayed senescence. In addition to observations on insect stressors, there were no 

trends observed with respect to significant differences in W8 potato responses to disease stressors in 

the 95 observations made, including bacterial and fungal pathogens. The only agronomic difference 

detected is that the W8 event is more resistant to late blight. (USDA-APHIS, 2014b).

Based on these analyses, if APHIS chooses the preferred Alternative, there would be no expected 

differences in general agronomic practices than if the No Action alternative is chosen.

4.3.3 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, 2014b), selection of the Preferred Alternative is not expected to result in any changes in 

potato seed production.

4.3.4 Organic Potato Production

No Action Alternative: Organic Potato Production

In the U.S., 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.
59

The organic sector is rapidly growing both in the US and the European Union (EU). Together, consumer 

purchases in these two regions made up 95% 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 (USDAERS, 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). However, certain markets or contracts may have defined thresholds (NonGMO-Project, 2010).

4.4 Physical Environment

4.4.1 Water Resources

No Action Alternative: Water Resources

The majority of potato production utilizes irrigation as a water source. As discussed in Section 2.2.1, 

Water Resources, agricultural production can be detrimental to water quality by adding sediments from

erosion via surface water, nutrient loading from fertilizers into groundwater, and pesticide runoff. 
60

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 W8 potatoes. Simplot’s studies demonstrate no differences in morphological 

characteristics and agronomic requirements between Simplot InnateTM W8 potato and other potato 

varieties (Simplot, 2014). 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 W8 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.

4.4.2 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., 1996).

If APHIS chooses the No Action alternative, impacts on soil quality are expected to continue.

Preferred Alternative: Soil Quality

A determination of nonregulated status for Simplot InnateTM W8 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. Other studies of the effect of GE crops on soil characteristics have not shown significant 

effects. For example, Bruinsma (2003) found no differences in soil attributable to a GE potato cultivar 

transformed to produce T4 lysozyme. Simplot’s studies demonstrate that agronomic characteristics and 

cultivation practices required for Simplot InnateTM W8 potato production are indistinguishable from 

practices used to grow other potato varieties (Simplot, 2014). Except for the incorporated traits, the 
61

event is 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.

4.4.3 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 2.2.3, Air 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, 2014) demonstrate that no changes to agronomic 

practices will be required to grow Simplot InnateTM W8 potato. As discussed in Section 2.2.3, Air Quality, 

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 event and the controls. The results indicated that no changes from the site-specific practices used 

for conventional varieties would be needed for production of the event.

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.

4.4.4 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, 2014) and APHIS PPRA (USDA-APHIS, 2014b), Simplot InnateTM 

W8 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 

W8 potato, the agricultural impacts of potato production on climate change are also unlikely to change 

under the Preferred Alternative.
62

4.5. Biological Resources

4.5.1 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 are 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, 2014) demonstrates that changes in agronomic practices, 

including practices related to pesticide use and erosion mitigation, are not required for production of 

Simplot InnateTM W8 potato. The W8 event has 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 W8 potatoes would have the same impact on other organisms as conventional potatoes

(Simplot, 2014). Aside from the targeted traits, the Simplot InnateTM W8 potato is compositionally 

similar to conventional potatoes (Simplot, 2014; USDA-APHIS, 2014b).

APHIS reviewed Simplot’s data on field trials (USDA-APHIS, 2014b) and impacts by insects, and 

concluded that Simplot InnateTM W8 potato would suffer no greater insect pressure than conventional 

potatoes (USDA-APHIS, 2014b). For example, no increase in aphid infestation or damage was reported 

in the field observations for the Simplot InnateTM W8 potato event (Simplot, 2014). In addition, since

potatoes are propagated vegetatively from seed potato tuber pieces, pollination by bumblebees is not 

important to potato tuber production. 

Simplot InnateTM W8 contains traits for reduced acrylamide formation, reduced black spot bruise, 

lowered reducing sugars, and late blight resistance. 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 (Plaisted, 1980; Steffens, 1994). However, the trichomes of cultivated potatoes 

contain low amounts of PPO which is not thought to be involved in 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 
63

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 

also 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). These dark-pigmented polyphenols, also referred 

to as melanins, result in the darkening of potato tissue following mechanical bruising (Thygesen et al., 

1995). Ppo5, the PPO gene silenced in W8 is the primary form found in potato tubers, and is the primary 

PPO gene detected in older tubers (Thygesen et al., 1995). Ppo5 transcripts were down-regulated in 

tubers, but not in stems, roots, leaves and flowers in W8 compared to the non-transgenic control 

varieties (Simplot, 2014). This suggests that except for tubers, Simplot InnateTM W8 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, 2014; USDA-APHIS, 2014b).

Simplot assessed nematode damage of Simplot InnateTM W8 potato, and results showed no more 

nematode damage than in control potatoes (Simplot, 2014). 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 resistance of Simplot InnateTM W8 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) 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 and Marnet (2012) evaluated the role of specific phenolics in quantitative resistance to two 

pathogens, P. infestans, the causal agent of late blight, and Pectobacterium atrosepticum (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 W8 potato tubers contain 

increased levels of glutamine (Simplot, 2014) because the enzyme asparagine synthetase also functions 

to deaminate glutamine to glutamate (Lam et al., 1996). 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 (USDA-APHIS, 2014b). 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 
64

by some researchers. For example, Wang et al. (2008) reported that intestinal dysfunction and atrophy 

were prevented when piglets’ diets were supplemented with glutamine. Similarly, 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. (1990) demonstrated that added glutamine protects rat 

intestinal mucosa following radiation therapy.

There were no significant differences between the event and its respective control varieties for mean 

glycoalkaloid toxin content, and levels were below the accepted safety limit (Simplot, 2014).

In its petition, Simplot (Simplot, 2014) assessed susceptibility of Simplot InnateTM W8 potato to several 

diseases, and showed that the potato is resistant to late blight without any change in susceptibility or 

loss of resistance to other diseases. Because of the specificity of the Rpi-vnt1 protein in Simplot 

InnateTM W8 potato, and the observed disease susceptibility panel, the Simplot InnateTM W8 potato is 

highly unlikely to adversely impact soil or plant-associated fungi or bacteria (USDA-APHIS, 2014b). 

Potato Late Blight Resistance Gene (Rpi-vnt1) encodes a protein that halts the spread of the infection by 

the pathogen. The mechanism of action for the expressed effector protein is very specific and extremely 

unlikely to impact other organisms such as insects and other non-target organisms (Simplot, 2014).

There is no evidence that animal exposure to Simplot InnateTM W8 potato would have any effect or be 

any less attractive as food, refuge, cover and nesting sites as non-GE varieties of potatoes. Simplot 

InnateTM W8 potato tubers are nutritionally and compositionally similar to the respective parental 

control and other commercial potato varieties with the exception of the intentional changes conferred 

by the introduced or silenced genes (USDA-APHIS, 2014b). The results of the beneficial arthropod and 

pest arthropod abundance monitoring produced no significant differences between the Simplot 

InnateTM W8 event and the control for any of the arthropods collected (USDA-APHIS, 2014b). APHIS 

concludes that exposure to and/or consumption of Simplot InnateTM W8 tubers or other plant parts is 

unlikely to have adverse impacts on organisms beneficial to agriculture (USDA-APHIS, 2014b).

Accordingly, based on the results of the studies presented here, it seems unlikely that the VNT1 protein 

will have any impact on human health through allergenicity or toxicity, or any environmental impacts to 

non-target mammals, birds, fish, or insects due to the low expression and lack of toxic effects of the 

protein. There is negligible risk of environmental contamination and no persistence in the environment 

because of the low expression of the VNT1 protein in potato tubers. The prevalence of similar 

resistance genes throughout edible crops suggests that extremely low levels of similar proteins are 

widespread in nature and unlikely to pose risk to human health, non-targets or the environment (USDAAPHIS, 2014b). The introduced genes did not significantly alter the observed insect pest infestation and 

disease occurrence or resulting damage in Simplot InnateTM W8 potato relative to the control line under 

the typical recommended pest management conditions. Therefore, APHIS concludes that based on the 

compositional similarity of Simplot InnateTM W8 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, 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 (USDA-APHIS, 2014b). 

In general, migratory birds are not expected to feed on potato plants because of their glycoalkaloid 

content, while cover and nesting sites also appear comparable to conventional varieties because the GE

plants are agronomically similar. Considering all that is known about Simplot InnateTM W8 potato lines 
65

and their production, there is nothing to indicate that migratory birds would interact or be affected any 

differently than they would with other potato varieties currently grown.

With regard to non-target organisms such as insects, birds or mammals, consumption of Simplot 

InnateTM W8 potato is unlikely to substantially affect them. Simplot’s data demonstrates that the 

composition of Simplot InnateTM W8 potato does not substantially differ from conventional potato 

varieties (Simplot, 2014).

The literature contains reports of exposure of transgenic organisms to non-target organisms, although 

there have been no studies done with Simplot InnateTM W8 potato. Exposure may occur via feeding on 

the roots of GE plants or eating plant parts or exudates produced by GE plants (Cowgill et al., 2002). No 

detectable effects have been found in studies of soil organisms (microorganisms and fungi) (Celis et al., 

2004; Milling et al., 2004). Variables other than the genetic modification and its associated production 

of transgenic proteins were found to be responsible for any changes in soil populations. For example, 

soil type and texture had the most effect on bacterial communities; the availability and amount of 

organic carbon in soils greatly influenced activity and structure of bacterial communities; and host plant 

genotype and developmental stage contributed to any community changes (Rasche et al., 2006). The 

effects due to the genetic changes were found to be either transient or minor compared to other 

factors. A study on the effect of GE potatoes on invertebrates showed that the potato did not influence 

the density or number of soil nematodes in the soil (Celis et al., 2004).

APHIS did 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, 

2014b).

4.5.2 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 W8 potatoes 

do not require any changes to agronomic inputs when compared with conventional potatoes (Simplot, 

2014). There would be no change in herbicide use or patterns. Under the Preferred Alternative, 

potential impacts to plant communities are not anticipated to be different compared to the No Action 

Alternative.

The silencing of the gene responsible for asparagine synthesis and thus the lower acrylamidepotential 

leads to somewhat heightened levels of glutamine in Simplot InnateTM W8 potato, but levels are within 

acceptable limits (OECD, 1997). In the very unlikely event of hybridization of Simplot InnateTM W8 

potato, resulting progeny may have altered 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).
66

As discussed in Section 4.5.1, Animal Communities, consumption of Simplot InnateTM W8 potato is not 

expected to change herbivore-plant interactions.

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.

4.5.3 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, 2014b) which might make potato, including Simplot InnateTM W8 potato more susceptible 

to gene flow or weediness.

As discussed in Section 2.3.3, Gene Flow and Weediness, Russet Burbank potato is sterile and produces 

few flowers (PAA, 2013). Fertile varieties of potato pose little potential for outcrossing because of their 

lack of nectar and therefore attractiveness to honey bees (OECD, 1997) and their self-pollinating biology

(Gillund et al., 2013). Hybridization potential is nil because of these factors and because commercial 

potatoes do not exhibit weedy characteristics (Love, 1994). There are few wild potato varieties in the 

US, and of those, most are geographically isolated from commercial production areas (US-EPA, 2011b).

The data presented by Simplot demonstrate that the Simplot InnateTM W8 potato is phenotypically and 

agronomically similar to its Russet Burbank parent variety and does not exhibit meaningful changes in 

characteristics that would make them weedier or more persistent than the parent variety. In fact, 

because of its reduction in early emergence and large tuber yield, the Simplot InnateTM W8 potato

appears to have a reduced potential for weediness (USDA-APHIS, 2014b). Furthermore, Simplot did not 

observe any differences during the completed post-harvesting volunteer monitoring of the Simplot 

InnateTM W8 potato field test sites from 2 years of field testing that would lead them to conclude that 

these potatoes have properties that would increase their survivability compared to conventional 

potatoes (Simplot, 2014).

With respect to gene flow, the genetic modification in the Simplot InnateTM W8 potato is not expected 

to increase the potential for gene flow (USDA-APHIS, 2014b) compared to the nontransgenic recipient or 

other varieties of the crop commonly grown. Gene flow from Russet Burbank Event W8 is nonexistent

because the variety is sterile (PAA, 2009).

The late blight resistance gene, Rpi-vnt1, encodes a resistance protein, VNT1, which reacts with a 

pathogen-specific effector protein to halt the spread of infection. This resistance would not enhance 

the potato survivability beyond what would be normally expected for potatoes. Therefore, Simplot 

InnateTM W8 potato is unlikely to be any weedier than conventional potato (USDA-APHIS, 2014b).

4.5.4 Microorganisms
67

No Action Alternative: Microorganisms

If APHIS chooses the No Action Alternative, potato crop interactions with microorganisms are expected 

to remain the same over time. 

Preferred Alternative: Microorganisms

Under the Preferred Alternative, the impacts to microorganisms are expected to be the same as if the 

No Action Alternative is chosen. The evaluation presented in the petition (Simplot, 2014) 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 Simplot InnateTM W8 potato event (USDA-APHIS, 2014b).

Tuber browning can be a plant response to infection by microbial pathogens, so modified potato tubers 

may not exhibit the same degree of symptoms as conventional varieties. Plant infection can also induce 

the production of other compounds that produce browning (e.g. phenolics) so a complete absence of 

symptoms in GE varieties is unlikely (USDA-APHIS, 2014b). If there are no disease symptoms, or if 

symptoms are reduced below action thresholds, then it is unlikely a farmer would increase pesticide use.

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).

4.4.5 Biodiversity

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 

country. This will allow for continued trends of biodiversity occurring outside the borders of agricultural 

fields even though biodiversity. Biodiversity is expected to continue to be fairly low within agricultural 

fields.

Preferred Alternative: Biodiversity

Under the Preferred Alternative, biodiversity is unlikely to be substantially changed in comparison to the 

No Action Alternative. First, the evaluation presented in the petition (Simplot, 2014) demonstrates that 

changes in agronomic practices would not be required to incorporate production of the event. This 

means cultivation, management, and land-use decisions related to Simplot InnateTM W8 potatoes are not 

different from conventional potato cultivars. With the possible exception of fungicide application and 

volume, which may remain the same or decrease because of the late blight resistance trait, agronomic 

practices such as irrigation, pesticide application, fertilizer applications, and agriculture equipment 

would be unchanged by the addition of these two varieties. Thirdly, flora and fauna that typically 

inhabit potato fields will continue to be affected by currently used management plans and production 

systems. 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.
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4.6 Human and Animal Health

4.6.1 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 chips. Per capita 

consumption data are shown in Table 6. As discussed in Section 2.4.1, Consumer Health, potential 

toxins in potatoes are acrylamide, which forms subsequent to high-temperature cooking, and 

glycoalkaloids. Patatin is allergenic to a very small percentage 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 W8 potato is widely adopted, 

acrylamide content in cooked potatoes could be significantly reduced, leading to potential health 

benefits for consumers. Compared with conventional potatoes, Simplot InnateTM W8 potato contains, 

on average, 78-84% less acrylamide when cooked (Simplot, 2014). As discussed in Section 2.4.1, 

Consumer 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 recommendations (FDA, 2013c)

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 W8 potato in French

fries and other frozen potato products. In the absence of these alternative varieties, food producers 

voluntarily alter their production practices to reduce acrylamide in their products. Deployment of 

Simplot InnateTM W8 potato genes would allow them an alternative way to produce reduced acrylamide 

products.

The lowered reducing sugar trait will also potentially lead to improvements in human health due to its 

ability to decrease acrylamide formation potential even further. 

The late blight resistance gene will likely improve potato yield, and will indirectly improve human health 

by increasing food availability.

The data presented in the petition shows that the Simplot InnateTM W8 potato event is at least as safe 

and nutritious for food as the untransformed controls (Simplot, 2014). The compositional analyses of 

the event is summarized in the petition, with detailed results in Section 8 (Simplot, 2014). 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) 
69

glycoalkaloids; 5) free amino acids; and 6) total amino acids for tubers collected from events grown in 

2012 and 2013 in potato-growing areas of the U.S. Observed changes in asparagine 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.

Based on the results in results in the petition (Simplot, 2014), the potato event described in this petition 

does not appear to be compositionally different in comparison to untransformed controls, except for 

the intended traits. Therefore, issues with allergies are not expected to differ from those in the 

currently affected environment or under the No Action alternative.

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 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 this event 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).

4.6.2 Worker Safety 

No Action Alternative: Worker Safety

If APHIS were to choose the No Action alternative, farm and food production workers would continue to 

be exposed to the same types and amounts of hazards as they currently experience in potato production 

and food processing.

Preferred Alternative: Worker Safety

Under the Preferred Alternative, there will be no changes in agronomic or food production practices in 

order to produce food and feed from Simplot InnateTM W8 potato (Simplot, 2014). Consequently,

impacts to worker health resulting from approval of the petition are expected to be the same as if the 

No Action Alternative is chosen.

Simplot demonstrates in its petition that the agronomic inputs required to cultivate Simplot InnateTM W8 

potato are functionally equivalent to those required for conventional potatoes (Simplot, 2014). Current 

health and safety protocols are not likely to require changes to accommodate the production or 

handling of Simplot InnateTM W8 potatoes because the characteristics of the potatoes are not altered. 

Normal harvesting, transport, and storage conditions designed to minimize the accumulation of 

glycoalkaloids and acrylamide do not need to be altered to accommodate these potato varieties. Since 

fungicide use should remain the same or decrease, but should not increase, workers should be exposed 

to no more than pesticides than under the No Action Alternative.
70

4.6.3 Animal Feed

No Action Alternative: Animal Feed

As discussed in Section 2.4.3, 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 Simplot InnateTM W8 event is summarized in Section 8 of the petition, 

with detailed results in Section 8 (Simplot, 2014). Additionally, the nutritional and compositional 

differences between Simplot InnateTMW8 potatoes and conventional potatoes were evaluated in the 

PPRA (USDA-APHIS, 2014b) and found to be similar. The composition of Simplot InnateTMW8 potatoes is

within the ranges of normal variation with conventional potatoes with respect to protein and 

carbohydrate content available in feed (USDA-APHIS, 2014b). As a result, incorporation of Simplot 

InnateTMW8 potatoes into animal feed is unlikely to affect palatability of the feed.

In conclusion, the data presented in the petition shows that potatoes from the event are as safe and 

nutritious for feed as the untransformed controls, and if APHIS were to choose the Preferred 

Alternative, the use of potatoes as livestock feed would be no different than if the No Action Alternative 

was chosen.

4.7 Socioeconomic Impacts

4.7.1 Domestic Economic Environment

No Action Alternative: Domestic Economic Environment

The domestic economic environment is discussed in Section 2.5.1, Socioeconomic: Domestic Economic 

Environment, and potato utilization in the country 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 1% 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 Simplot InnateTM W8 potato event will become available 

for commercial production. Because of the reduced potential for black spot bruise of Simplot InnateTM 

W8 potato, wastage is expected to decrease. This will lead to greater efficiency in processing, and an 

improved revenue stream for product producers. Overall, if APHIS chooses the Preferred Alternative, 

the introduction of Simplot InnateTM W8 potato are likely to have positive economic impacts on potato 

growers that choose to grow Simplot InnateTM W8 potato.
71

Potatoes with low acrylamide potential, reduced black spot bruise, lowered reducing sugars, and late 

blight resistance 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 and 

its products. As adoption of the potato event 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, 2014).

Organic potato growers are not anticipated to incur additional operating costs to as a result of the 

Preferred Alternative. See Section 4.3.4, Organic Potato Production, for further discussion.

Cold-induced sweetening and the resulting potential for acrylamide formation is addressed by the 

suppression of the Vlnv gene (Bhaskar et al., 2010) in Simplot InnateTM W8 potato. The VInv gene 

silencing cassette in pSIM1678 resulted in decreased levels of vacuolar invertase, an enzyme which 

converts sucrose into glucose and fructose. When levels of invertase are decreased in potatoes, 

reducing sugars glucose and fructose remain at low levels during storage while sucrose increases, 

especially when held below typical storage temperatures of 46 - 48°F for French fry potatoes. Before 

testing for invertase activity, tubers were stored at 39°F for one month. Three replicates for each of 

Simplot InnateTM W8 and Russet Burbank control were used for the assay which was measured by the 

accumulation of glucose. Simplot InnateTM W8 tubers had an 85% reduction in vacuolar invertase activity 

in cold-stored tubers compared to controls. The reduced vacuolar invertase activity in W8 tubers is 

associated with reduced RNA accumulation from the VInv gene and lower levels of reducing sugars 

glucose and fructose (Simplot, 2014).

All Simplot InnateTM W8 tubers contained more sucrose than control samples at harvest and after 

multiple storage time points at both 38 ̊F and 46 ̊F. The increase in sucrose was expected from silencing 

the VInv gene, thus inhibiting the conversion of sucrose into the reducing sugars glucose and fructose.

The mean levels of sucrose for W8 were within the tolerance interval and combined literature ranges, 

and therefore would be considered substantially equivalent to the controls. Human consumption of 

potato with increased sucrose levels would be digested by humans into fructose and glucose (Combes 

and Monsan, 1983). 

By silencing vacuolar invertase in potato, growers should be able to store potatoes destined for 

processing at significantly lower temperatures, decreasing loss from disease and yield losses from higher 

respiration rates related to typical storage at 46 – 48  ̊F. (Simplot, 2014). Storage at lower temperatures 

may provide other advantages such as disease reduction, minimization of moisture loss, and reduction 

of anti-sprouting chemicals (Simplot, 2014).

For the Russet Burbank event Simplot InnateTM W8 potato, there should be significant economic and 

quality benefits from lower levels of reducing sugars. In addition, less reducing sugar will result in lower 
72

levels of acrylamide after cooking, a significant advantage considering the health concerns associated 

with acrylamide (NTP, 2012; FDA, 2013a).

4.7.2 Trade Economic Environment

As discussed in Section 2.5.2, 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 US exports of 

frozen potatoes, while Canada is the largest US export market for chips and fresh potatoes. The US 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 as affected by 

market forces.

Preferred Alternative: Trade Economic Environment

If APHIS chooses the preferred alternative, U.S. potato exports are expected to continue as affected by 

market forces. Approval for the event will be sought in Canada, Japan and Mexico (Simplot, 2014) 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. These approvals should ensure continued trade with key 

export markets. 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 comparison to some biotech crops, the Simplot InnateTM W8 potato is expected to be viewed more 

favorably by regulatory organizations due to the lack of pesticidal traits and marker-free transformation 

methods. For these reasons, it is anticipated to pose fewer implications for export markets.
73

If APHIS chooses the Preferred Alternative, as with the domestic economic environment, the 

introduction of this potato event may have positive economic impacts on export markets, recognizing 

that some additional costs could be incurred.

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 PPA, including disease tolerance, nitrogen utilization, and herbicide 

tolerance, would be considered a cumulative impact.

5.1 Assumptions Used for Cumulative Impacts Analysis

Cumulative effects are qualitatively analyzed for each environmental issue assessed in Section 4, 

Environmental Consequences by focusing on the Preferred Alternative in consideration of related

activities including past, present and reasonably foreseeable future actions including the production of 

potato progeny. 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 in that area.

APHIS considered the potential for Simplot InnateTM W8 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 W8 potato are 

indistinguishable from practices used to grow conventional potatoes (Simplot, 2014; USDA-APHIS, 

2014b). This implies 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 W8 potato could 

replace other commercially available potato cultivars, without requiring production on new, previously 

non-cropped land. Land use changes associated with approving the petition do not appear 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.

Potential reasonably foreseeable cumulative effects are analyzed under the assumption that some 

growers have used commonly accepted best management practices (BMPs) in the past, and would 

continue to use these practices when reasonable under the circumstances for their chosen system and 
74

cultivars during potato production. APHIS recognizes, however, that not all growers choose to use the 

same BMPs. 

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. The analysis showed Simplot InnateTM W8 potato is a

potato cultivar that is agronomically and compositionally similar to other commercially available potato

cultivars, so it is expected that Simplot InnateTM W8 potato would replace other similar cultivars without 

expanding the acreage of area devoted to potato production. There is no reason to anticipate changes 

to the availability of non-GE potato cultivars on the market based on the entry of this variety into the 

market.

Approving the petition for a determination of nonregulated status for Simplot InnateTM W8 potato is not 

expected to change current potato production practices. Studies conducted by Simplot demonstrate 

the agronomic characteristics and cultivation practices of Simplot InnateTM W8 potato are 

indistinguishable from practices used to grow other potato cultivars (Simplot, 2014; USDA-APHIS, 

2014b). Consequently, progeny bearing these genes also appear unlikely to require different practices.

Organic growers use common practices to maintain the organic status in their potato production,

including employing adequate isolation distances between the organic potato field and the fields of 

neighbors to minimize the chance that pollen will be carried among 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 is routinely utilized by growers, packers 

and retailers in the U.S. market to satisfy consumer preference and demand. Availability of another 

potato cultivar, such as Simplot InnateTM W8 potato under the Preferred Alternative, is not expected to 

impact the organic production of potatoes any differently than other potato cultivars currently being 

grown. Progeny bearing these genes may become deliberately added to specific potato cultivars based 

on market demand, and the choice to produce those modified varieties remains with each individual 

farmer.

Based on the information described in Section 4.7.1, Domestic Trade Environment, APHIS concludes that

a determination of nonregulated status of Simplot InnateTM W8 potato will have no foreseeable adverse 

cumulative effects on domestic commerce. Simplot InnateTM W8 potato has the potential to improve 

potato processing capabilities and also improves 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. Progeny 

bearing these genes are anticipated to have the same potential for benefits. Based on these factors, no 

net negative cumulative impacts on domestic economics are identified associated with the production 

of Simplot InnateTM W8 potato.

Approving the petition for a determination of nonregulated status to Simplot InnateTM W8 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 W8 potato is agronomically similar to other potato 
75

cultivars. Because of its similarity to other potato cultivars, adoption of Simplot InnateTM W8 potato is 

expected to replace other similar cultivars without impacting water, soil, air quality, and climate change

differently from other potato varieties. Cumulative impacts due to climate change are anticipated to be 

the same for the Simplot InnateTM W8 event and conventional potatoes because their agronomic 

characteristics remain similar. Additionally, potato production in the U.S. occurs on less than 1% of the 

acreage as compared to the acreage occupied by corn and soybeans (USDA-NASS, 2012b) so the 

magnitude of any climate change due to potato production changes appears unlikely to be detectable.

Cumulative impacts of the Preferred Alternative to microorganisms and biodiversity are not expected to

be significantly different than under the No Action Alternative because Simplot InnateTM W8 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 the Simplot InnateTM W8 potato event and conventional potatoes based on multiple years of 

field data, compositional analysis, and a lack of changes in 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. Consequently, 

this variety does not present a safety risk, or pose an increased weediness risk in relation to other 

currently available potatoes based on the information summarized in the PPRA (USDA-APHIS, 2014b).

Cumulative impacts to animal communities would be the same for the Simplot InnateTM W8 potato event

and conventional potatoes. Three years of field data as well as compositional analysis and molecular 

stability show that the Simplot InnateTM W8 potato event is equivalent to conventional potatoes

(Simplot, 2014). 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. Animals consuming Simplot InnateTM W8 potato may be exposed 

to increased levels of glutamine, but research on dietary supplementation with glutamine has not had 

any negative animal health effects. In the future, multiple potato varieties carrying these genes may 

lead to an increased risk of exposure to increased levels of glutamine, but consumers are more likely to 

substitute varieties rather than increasing their potato consumption.

In general, cumulative effects on human consumer health are expected to be the same for the Simplot 

InnateTM W8 potato event and conventional potatoes. There are two major exceptions: the Simplot 

InnateTM W8 potato contains significantly less acrylamide-forming potential than conventional potatoes, 

and less reducing sugars than conventional potatoes. Reduced levels of acrylamide in cooked potatoes 

are associated with human health benefits in consumers. Reduced potential to form acrylamide should 

result in significant human health benefits, particularly for those with a diet high in potato products

produced by cooking at high temperatures. Compared with the conventional varieties, Simplot InnateTM 

W8 potato contained on average 78-84% less acrylamide (Simplot, 2014). Adoption of these potatoes 

could result in a significant reduction in dietary intake of acrylamide and decrease exposure to this 

naturally occurring substance found to cause cancer in laboratory animals (NTP, 2011).

In addition, total protein and glycoalkaloid levels in Simplot InnateTM W8 potato were unchanged 

compared with the control varieties (Simplot, 2014). Although patatin was not measured during the 

studies (Simplot, 2014), any potential exposure to patatin is not expected to be different under the 

Preferred Alternative than under the No Action Alternative. Some allergies have been detected in 
76

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 potatoes under the No 

Action Alternative; therefore, any changes in patatin levels in Simplot InnateTM W8 potato would not 

impact these children, as they are already avoiding potatoes due to the high proportion of patatin 

already occurring in conventional potato varieties (Mignery et al., 1988).

Cumulative impacts to worker safety would be expected to be the same for the Simplot InnateTM W8 

potato event and conventional potatoes because the agronomic practices are not expected to change.

Livestock consuming raw potatoes are not expected to realize any health benefits from reduced 

acrylamide-forming potential in these potatoes. Simplot submitted a safety and nutritional assessment 

of food and feed derived from Simplot InnateTM W8 potato to the FDA on date April 14, 2014 (BNF No. 

000146). The FDA is presently evaluating the submission. There are no changes in food and feed safety 

expected to occur under the Preferred Alternative.

Cumulative impacts on the domestic economic environment generally would be similar for the Simplot 

InnateTM W8 potato event and conventional potatoes, although some economic impact is expected 

because of the potential health benefits associated with these new potatoes. This event grows similarly 

and has similar biochemical composition to conventional potatoes, however, the low acrylamide, 

reducing sugars, black spot bruise, and late blight resistant traits add value that could increase the price 

received for these potatoes. Potatoes with these traits 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. To the extent that these traits become incorporated into 

many other existing varieties, this added market value is anticipated to diminish. 

Cumulative impacts to the trade economic environment generally would be similar for the Simplot 

InnateTM W8 event and conventional potatoes, unless the potential health benefits become an important 

factor in international marketing. Increased demand is expected to lead to increased supply of these 

potatoes, but to the extent that other countries indiscriminately block importation of GE foods, these 

opportunities may be missed.

Introduction of Simplot InnateTM W8 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, 2014). The Simplot InnateTM W8 potato could have 

cumulative economic impacts on the domestic potato market and procedures developed to manage 

product purity in the supply chain.

Upon introduction, procedures will be implemented to prevent unintended mixing of Simplot InnateTM 

W8 potato 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 InnateTM W8 potatoes be found 

in the market from accidental mixing. The Simplot InnateTM W8 potatoes could have cumulative trade 
77

economic impacts on the potato export market and procedures developed to manage product purity in 

the supply chain.

Simplot InnateTM W8 potato, and the deployment of the genes in this variety, may offer protection 

against black spot bruise, lower reducing sugars, late blight resistance and reduced acrylamide potential.

During processing, potatoes are routinely culled due to black spot bruise when making French fries or 

potato chips. However, with Simplot InnateTM W8 potato, fewer potatoes will be lost to black spot 

bruise, resulting in less waste. Similarly, the late blight resistance gene should markedly improve 

survival of potato crops threatened with late blight, and consequently, increase yield. As a result of 

increased usable yield per pound existing production becomes more efficient, so less acreage can meet 

the demand for potatoes. Reductions in potato acreage are associated with fewer agricultural inputs 

and concomitant environmental benefits with associated positive environmental impacts related to land 

use and agricultural inputs. For the purposes of this cumulative impacts discussion, however, it is 

conservatively assumed that land use and agronomic inputs would potentially decline or remain the 

same, and are unlikely to increase.

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 
78

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 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 also 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 pesticide use associated with GE crops because EPA has both regulatory 

authority over the labeling of pesticides under FIFRA, and the necessary technical expertise to assess 

pesticide effects on the environment. 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 Simplot InnateTM W8 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.

 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-listed TES 

species and species proposed for listing, as well as designated critical habitat and habitat proposed for 

designation.
79

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, 2015a; 2015b). Prior to this review, APHIS considered the potential for Simplot InnateTM 

W8 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 W8 potato are essentially indistinguishable from 

practices used to grow other potato varieties (Simplot, 2014; USDA-APHIS, 2014c; 2014b). Simplot 

InnateTM W8 potato may be expected to replace other varieties of potato currently cultivated, and 

APHIS does not expect the cultivation of Simplot InnateTM W8 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 W8 potato on TES species in the areas of the U.S. where potatoes are currently grown.

Simplot has used a genetic engineering approach to introduce into the background of commercial 

potato cultivars four traits that are of interest to potato consumers, producers and processors: late 

blight resistance, reduced acrylamide potential in certain processed or heated potato products, 

reduced black spot bruise, and lowered reducing sugars (Simplot, 2014). The Simplot InnateTM W8 

potato event was constructed by first transforming Russet Burbank with plasmid, pSIM1278, followed 

by transformation with a second plasmid, pSIM1678 to produce the stacked traits. The objective was 

to incorporate the new phenotypes into event W8, while maintaining all of the desirable characteristics 

originally selected by potato breeders (Simplot, 2014).

As described in the petition and PPRA, 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 enzymes (Simplot, 2014). 

For its analysis on TES plants and critical habitat, APHIS focused on the agronomic differences between

Simplot InnateTM W8 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.

For its analysis of effects on TES animals, APHIS focused on the implications of exposure to Simplot 

InnateTM W8 potato, and the potential for an effect resulting from the gene silencing activity that sets 

Simplot InnateTM W8 potato apart from other potato lines currently in production.

6.1 Potential Effects of Simplot InnateTM W8 potato on TES and Critical Habitat

The agronomic and morphologic characteristics data provided by Simplot were used in the APHIS 

analysis of the weediness potential for InnateTM Event W8 Potato, and further evaluated for the potential 

to impact TES and critical habitat. Agronomic studies conducted by JR Simplot during 2012 and 2013 

tested the hypothesis that there would be no change in agronomic practices used to produce Simplot 

InnateTM W8 potato in comparison with conventional potato (Simplot, 2014). Agronomic evaluations 
80

were conducted in geographically distinct sites selected to represent most of the main production areas 

for potatoes in the USA. 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, 2014). Relative to the Russet Burbank control, there was no 

consistent trend among the InnateTM Event W8 for significant increases in final emergence, stems per 

plant, or vine desiccation. There were no statistically significant reductions in total yield. The Simplot 

InnateTM W8 potato was lower than the control for early emergence (39.5% vs 61.5%), and plant vigor 

(3.0 vs 3.7); and shorter than the control for plant height (40.4 vs 45.1 cm). All of these detected 

differences were within the conventional variety range for potato. Simplot InnateTM W8 potato did not 

display any notable differences to the control in tolerance to abiotic stresses or biotic stresses (Simplot, 

2014) .

No differences were detected between Simplot InnateTM W8 potato 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 this transformed line

(Simplot, 2014). 

Potatoes are not known to be weedy or persistent; they are incapable of survival outside of cultivation 

(Holm et al., 1979; Muenscher, 1980; Love, 1994; OECD, 1997). 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 the Simplot InnateTM W8 potato is for the most part 

phenotypically and agronomically similar to the respective parent variety and does not exhibit 

meaningful changes in characteristics that would make it weedier or more persistent than the parent 

variety (Simplot, 2014). Because of the reductions in emergence and yield, the Simplot InnateTM W8 

potato appears to have a reduced potential for weediness (USDA-APHIS, 2014b). Furthermore, postharvest monitoring of field test plots planted with the GE crop event under USDA-APHIS notifications 

and permits did not reveal any differences in survivability or persistence relative to other varieties of the 

same crop currently being grown. Volunteers were rarely observed, were easily controlled, and are not 

engineered for resistance to herbicides (Simplot, 2014). No differences were observed that would 

suggest that the Simplot InnateTM W8 potato is more likely to become a weed than the conventional 

varieties of the crop (USDA-APHIS, 2014c). Based on the agronomic field data and literature survey 

concerning weediness potential of the crop, APHIS has determined that the Simplot InnateTM W8 potato 

is unlikely to persist as a troublesome weed or to have an impact on current weed management 

practices (USDA-APHIS, 2014b). 

APHIS evaluated the potential of Simplot InnateTM W8 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 2.3.3 and 4.5.3 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 W8 potato. Simplot InnateTM W8 potato derived from Russet Burbank 
81

produces few flowers and is male sterile (Simplot, 2014). Among native Solanum spp. in the U.S., 

cultivated potato is potentially sexually-compatible only with two tuber-bearing species, S. jamesii and S. 

stoloniferum (previously S. fendleri (Spooner et al., 2004)). 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 (USDA-NRCS, 2013; Simplot, 2014). 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, 1994; US-EPA, 2011b)b. 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 W8 potato were to occur. The resulting analysis concluded that the novel phenotypes 

(low acrylamide potential, reduced black spot bruise, late blight resistance, and lowered reducing 

sugars) 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, 2014b).

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 W8 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 (USDA-APHIS, 2014b).

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 W8 potato will have no effect 

on threatened or endangered plant species or critical habitat.

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 W8 potato and possible effects that could occur as a result of such contact. 

Exposure of TES species to Simplot InnateTM W8 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 W8 potato would be those TES that inhabit potato 

fields and may feed on 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 
82

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, 2013b).

As discussed in Section 2.3.1 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, 1987). Known exceptions 

are whitetail deer, wild boar, and voles (O'Brien, 2005; Marinette County, 2014; 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 (Microtus 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 W8 potato. Detailed compositional is found in Section 8 of the petition. Simplot analyzed 

tubers of the Event W8 and its respective parent for the following constituents: protein, fat, ash, crude 

fiber, carbohydrates, calories, moisture, vitamin B3, vitamin B6, vitamin C, Cu, Mg, K, amino acids, and 

glycoalkaloids. 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) amino acids for tubers collected from events grown in 

2012 and 2013 in potato-growing areas of the U.S. (Simplot, 2014). Based on the compositional 

analyses presented in the petition, APHIS concludes that although raw tubers had some statistically 

significant differences in nutritional components (vitamins C and B6; certain amino acids) compared to 

the parental variety (Russet Burbank), they are within the normal range for commercial potato varieties. 

For the few cases when significant differences were detected between Simplot InnateTM W8 potato and 

its parental variety, the mean values for the W8 event all fell within the tolerance interval and within the 

combined literature range for potatoes (Simplot, 2014; USDA-APHIS, 2014b). 

As discussed in Section 4.6.1, Human Health, issues with allergies to Simplot InnateTM W8 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, lower 

black spot bruise, late blight resistance, and lowered reducing sugars. Simplot submitted a safety and 

nutritional assessment of food and feed derived from Simplot InnateTM W8 potato to the FDA on BNF No. 

000146. FDA is presently evaluating the submission. 
83

As discussed in Section 4.5.1, 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 the InnateTM potatoes would have the same impact on other organisms as conventional potatoes

(Simplot, 2014). There is no evidence that animal exposure to Simplot InnateTM W8 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 W8 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 (USDA-APHIS, 

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 W8 

potato 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 InnateTM Event W8 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 W8 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, 1980; Love, 1994; OECD, 1997). There is no ability of Simplot 

InnateTM W8 potato to naturally hybridize with any wild Solanum species, including listed species. 

Simplot InnateTM W8 potato will not serve as a host species for any listed species or species proposed for 

listing. Consumption of Simplot InnateTM W8 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 W8 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.
84

 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.

Neither the No Action nor the Preferred Alternative is expected to have a disproportionate adverse 

effect on minorities, low-income populations, or children because the Simplot InnateTM W8 potato 

event is agronomically, phenotypically, and biochemically similar to conventional potatoes except 

for the low acrylamide potential and reduced black spot bruise traits. To establish that the new 

cultivars are nutritionally equivalent to their parent cultivars, Simplot InnateTM W8 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. This means 

they are not likely to have adverse effects on individuals within those populations when they are 

consumed. At present, studies suggest that potatoes represent over 30% of vegetable consumption 

in U.S. children in and out of school (Olsho and Fernandes, 2013) and that urban/minority youths 

are more likely to consume more fried potato products than youths living in a non-urban 

environment (Davis and Carpenter, 2009). Olsho and Fernandes (2013) suggest that the targeting of 

potato preparation methods may represent a more viable method to improve the healthfulness of 

potato dishes, and as such, the introduction and use of Simplot InnateTM W8 potato may improve 

any disparate adverse effect associated with potato consumption in the U.S. 

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 could benefit consumers by addressing a food safety issue in potato 

industry (NTP, 2011). Other unexpected significant differences were reported, but the values are all 

within the normal ranges for potatoes. 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 deviations in 

various amino acids and vitamins, while experimentally significant, do not exceed the range of 

variation observed in conventional potato varieties (USDA-APHIS, 2014b). 
85

Potatoes also were tested for reducing sugars and acrylamide after storage. The event 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 compared to conventional potato varieties. Storage 

up to 7 months yielded consistently lower acrylamide levels in the event 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 confirmed that the overall levels of natural glycoalkaloids, a toxin commonly found in 

solanaceous crops including potato, were not increased in the Simplot InnateTM W8 event. The 

safety limit is 20mg/100g as described by Sinden (1987). As presented in the APHIS PPRA (USDAAPHIS, 2014b), while some Simplot InnateTM W8 potato events exhibited higher glycoalkaloid 

content, its respective controls also exhibited higher glycoalkaloid levels and that these observed 

concentrations of glycoalkaloids still remain in the range of typical potato glycoalkaloid levels 

described in the literature. This finding suggests that there are no safety concerns with Simplot 

InnateTM W8 potato due to similarities in composition.

Patatin is a potato storage glycoprotein that makes up approximately 40% of the soluble protein in 

tubers. Although patatin was not measured during the studies (Simplot, 2013), any potential 

exposure to patatin is not expected to be different as a result of a determination of nonregulated 

status for Simplot InnateTM W8 potato. 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 potatoes under the No Action Alternative; 

therefore, any changes in patatin levels in Simplot InnateTM W8 potato would not impact these 

children, as they are already avoiding potatoes due to the high proportion of patatin already 

occurring in conventional potato varieties (Mignery et al., 1988).

In summary, the compositional data presented in the Simplot petition (Simplot, 2014) and analyzed 

in the APHIS PPRA (USDA-APHIS, 2014b) indicates that Simplot InnateTM W8 potato does not 

substantially differ from conventional potato varieties with the exception of the introduced traits. 

As a result, Simplot InnateTM W8 potato is not expected to have a disproportionate adverse effect on 

minorities, low-income populations, or children.

Simplot initiated the consultation process with FDA for the commercial distribution of Simplot 

InnateTM W8 potato and submitted a safety and nutritional assessment of food and feed derived 

from Simplot InnateTM W8 potato to the FDA (Simplot, 2014). FDA is presently evaluating the 

submission. 

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 
86

minimize the economic, ecological, and human health impacts that invasive species 

cause. 

Based on historical experience with potatoes and data submitted by the applicant and reviewed 

by APHIS, Simplot InnateTM W8 potato is not expected to become weedy or invasive. Potatoes 

are not listed in the U.S. 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 generally are eliminated by tilling, field preparations with herbicides, 

and harsh winters. To maximize an economic return, potato growers rarely leave the ground 

fallow. Any potatoes inadvertently growing in a fallow field are not protected with insecticides

or fungicides; they would be susceptible to the Colorado potato beetle and early blight, and 

likely die.

Potatoes are not known to escape from fields (become feral) or show weediness potential. 

Potato seedlings grown from tubers have difficulty establishing because they are poor 

competitors against grasses, trees, and shrubs. The traits incorporated into Simplot InnateTM W8 

potato are not associated with weediness and these traits will not help plants thrive outside of 

cultivation.

The following Executive Order sets forth guidelines for consulting with Indian tribal governments:

EO 13175, “Consultation and Coordination with Indian Tribal Governments” states that each 

Indian tribe has the opportunity to participate in policy development to the greatest extent 

practicable and permitted by law. Each tribe has the opportunity for timely and meaningful 

government-to-government consultation with APHIS in developing policies that may have tribal 

implications. Such policies that could have substantial direct effects on one or more Indian 

tribes, on the relationship between the federal government and Indian tribes, or on the 

distribution of power and responsibilities between the federal government and Indian tribes. 

“Substantial direct effects” means positive, neutral, or negative effects and potential effects that 

APHIS or the tribes see as significant.

APHIS’ proposed action, a determination of nonregulated status of Simplot InnateTM W8 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 sent letters to Tribal entities when this petition was declared complete and 

made available to the public. There were no comments received from any tribal entities.

APHIS considered the impact to tribes or tribal properties in the EA (Section 7.5 National Historic 

Preservation Act [NHPA] of 1966 as Amended). As a result of that analysis, it was concluded 

that a determination of nonregulated status of Simplot InnateTM W8 potato will not adversely 

impact cultural resources on tribal properties. A determination of nonregulated status of 

Simplot InnateTM W8 potato GD743 will not adversely impact cultural resources on tribal 

properties. Any farming activities that may be taken by farmers on tribal lands are only 
87

conducted at the tribe’s request; thus, the tribes have control over any potential conflict with 

cultural resources on tribal properties. A determination of nonregulated status of Simplot 

InnateTM W8 potato 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 they likely 

cause any loss or destruction of significant scientific, cultural, or historic resources. This action is 

limited to a determination of nonregulated status of Simplot InnateTM W8 potato. Standard 

agricultural practices for land preparation, planting, irrigation, and harvesting would be used on 

these agricultural lands including the use of EPA registered pesticides. Applicant’s adherence to 

EPA label use restrictions for all pesticides will mitigate impacts to the human environment. A 

determination of nonregulated status of Simplot InnateTM W8 potato is not an undertaking that 

may directly or indirectly cause alteration in the character or use of historic properties protected 

under the National Historic Preservation Act. In general, common agricultural activities 

conducted under this action do not have the potential to introduce visual, atmospheric, or 

audible 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 audible effects on the use and 

enjoyment of a historic property when common agricultural practices, such as the operation of 

tractors and other mechanical equipment, are conducted 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 apple 

production regions. The cultivation of Simplot InnateTM W8 potato does not inherently change 

any of these agronomic practices so as to give rise to an impact under the NHPA.

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. 

APHIS has in place a signed MOU with the FWS (USDA-APHIS and USFWS, 2012). In accordance 

with this MOU, APHIS has considered the potential impacts of InnateTM W8 potato on migratory 

birds.

Based on historical experience with potatoes and data submitted by the applicant and reviewed 

by APHIS, Simplot InnateTM W8 potato is expected to have the same interactions with migratory 

birds as conventional potatoes. The applicant provided data to demonstrate the compositional 

equivalency of InnateTM W8 potato and other potato varieties currently grown. The 

modifications did not alter the quality of potato as food other than lower levels of acrylamide 

after cooking, and lower black spot bruise. There would be no effect from consumption of 

InnateTM W8 potato plant parts because there is nothing different between the plant parts of 

these varieties and plant parts of other potato varieties already in production. Migratory birds 

are not attracted to potato fields for potatoes; however, waterfowl forage extensively in 
88

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. With regard to pesticide use, the Simplot InnateTM W8 potato event is similar to their 

conventional cultivated potato counterparts, and therefore would not require additional use of 

pesticide applications. No “take” of a migratory bird is expected as a result of growing InnateTM 

W8 potato, and APHIS could not determine any mechanism by which take would occur, or 

would occur any differently than production of any other potato variety.

7.2 International Implications

 EO 12114 (US-NARA, 2010), “Environmental Effects Abroad of Major Federal Actions” requires 

agencies to consider the potential environmental effects outside the U.S., its territories, and 

possessions for proposed federal actions. APHIS does not expect a significant environmental 

impact outside the US in the event of a determination of nonregulated status of Simplot 

InnateTM W8 potato because existing national and international regulatory authorities and 

phytosanitary regimes will apply. 

Any international trade of Simplot InnateTM W8 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). 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). This 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. 

Issues that may relate to commercialization and transboundary movement of particular agricultural 

commodities produced through biotechnology are addressed through treaties, in international forums,

and through national regulations. These sources include the North American Plant Protection 

Organization (NAPPO), the Organization for Economic Cooperation and Development (OECD), and the 

North American Biotechnology Initiative (NABI), among others. For example, 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. Exporters need to comply with the 

regulations that importing countries who are Parties to the Protocol have promulgated. 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.
89

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 Federal 

government developed a website that provides the status of all regulatory reviews completed for 

different uses of bioengineered products (NBII, 2010). The applicable data used in analyses of the 

Simplot InnateTM W8 potato event will be available to the Biosafety Clearinghouse. 

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 W8 potato (Section 4.3, Agricultural Production of Potato) and 

determined that the cultivation of Simplot InnateTM W8 potato would not lead to the increased 

production or acreage of potato in U.S. agriculture. The Simplot InnateTM W8 potato event does 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 Simplot InnateTM W8 potatoes would not result in any 

changes in water usage for cultivation. As discussed in Section 4.3, Agricultural Production of Potato, 

there are no expected negative impacts to water resources or air quality associated with Simplot 

InnateTM W8 potato production. Based on these analyses, APHIS concludes that a determination of 

nonregulated status of Simplot InnateTM W8 potatoes would comply with the Clean Water Act and the 

Clean Air Act.

7.4 Impacts on Unique Characteristics of Geographic Areas

A determination of non-regulated status of Simplot InnateTM W8 potato is not expected to impact unique 

characteristics of geographic areas such as park lands, prime farm lands, wetlands, wild and scenic 

areas, or ecologically critical areas. 

The common agricultural practices that would be carried out in the cultivation of Simplot InnateTM W8 

potato are not expected to deviate from current practices. The product will be deployed on agricultural 

land currently suitable for production of potato, will replace existing varieties, and is not expected to 

increase the acreage of potato production. 

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’ 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 W8 potato.
90

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 W8 potato is not expected to change any of these agronomic practices 

that would result in an adverse impact under the NHPA.
91

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