Comment submitted by Crystal Wulff

To Whom It May Concern: I respectfully submit this comment urging the Environmental Protection Agency to deny the proposal authorizing the release of up to 64 million laboratory-modified mosquitoes into the environments of Florida and California. My concern is not opposition to scientific research or efforts to combat mosquito-borne disease. Rather, my concern arises from a basic principle of biological science and environmental stewardship: when living organisms are released into open ecosystems, the experiment no longer remains confined to the laboratory. The proposed release involves millions of modified insects being intentionally introduced into complex natural environments. While proponents argue that these mosquitoes may reduce populations of disease-carrying mosquitoes, the scale of the release demands a level of caution proportional to the potential consequences. Once these organisms are released, there is no practical mechanism to recall them, fully contain them, or reverse the environmental intervention if unforeseen effects emerge. History demonstrates that environmental and biological interventions often produce consequences that were not anticipated at the time of implementation. This is not necessarily because scientists are careless, but because living ecosystems are extraordinarily complex and contain countless interactions that cannot be fully modeled or predicted in advance. The long-term effects of large-scale mosquito suppression on local ecological systems remain uncertain. Questions remain regarding species replacement, evolutionary adaptation, changes in mosquito population dynamics, and other secondary effects that may not become apparent for years or even decades. The absence of evidence of harm is not the same as evidence of long-term safety. Florida and California contain some of the most environmentally diverse ecosystems in the nation, including wetlands, coastal habitats, springs, agricultural regions, and sensitive wildlife areas. These ecosystems are public resources that should not be subjected to large-scale biological modification without clear, comprehensive, and independently verified evidence demonstrating long-term environmental safety. The burden of proof should rest upon those seeking authorization for the release. Before millions of modified organisms are intentionally introduced into the environment, independent long-term studies should establish not only the intended benefits but also the absence of significant ecological risks. At present, that burden has not been sufficiently satisfied. Scientific progress is best served by caution, transparency, and rigorous independent review. Once released, living organisms cannot simply be recalled if predictions prove incorrect. Prudence therefore requires that uncertainty be resolved before implementation rather than after consequences occur. For these reasons, I respectfully urge the EPA to deny this proposal and require additional independent long-term ecological evaluation before any authorization is granted.