Original: english, spanish and french

GLASGOW CALEDONIAN UNIVERSITY

[05 September 2006]

[SUBMISSION: ENGLISH]

Question 1. Does your country have any plantations, either commercial or experimental, of genetically modified trees?
No.
If yes, please answer all remaining questions.

If no, please state the reason why:

No GM tree plantations in the UK at this time.

In the UK a total of five GM Tree Field trials have been carried out. The first two trials were successfully concluded. The last three trials, using fruit trees and a poplar hybrid were destroyed by genetic terrorists prior to completion. This last act of genetic terrorism (approx 2000) was particularly misguided, as it was claimed to be to ensure that the GM poplars did not form pollen, which would not have occurred since the trees were all female!

Other forest biotechnology research interests in the UK would like to proceed at least as far as small scale field trials, but the misguided actions of genetic terrorism groups would prevent trials from reaching fruition, even for trees designed for increased pathogen resistance, e.g. Ophiostoma fungal resistance, for which there is no current alternative, despite 35 years of conventional tree breeding in Europe.

The current EU Directives do not encourage research into GM technologies. This acts as a disincentive for scientific investment and has lead to many able researchers leaving Europe for more liberal regulatory climates. Although there are some early signs of a more positive agenda based upon the need for scientific evidence, the climate of public opinion in the UK and indeed much of EU, remains negative towards GM trees, in response to media frenzies and environmental activist scare stories, frequently, perhaps even always, lacking any basis in scientific evidence or fact, as prime examples of closed minds and categorically negative prejudice.

There is a clear need to accumulate biosafety and performance data on GM trees in Europe, or developed as a product of European research activity. This can best be done by allowing controlled field trials in the environment to take place. Any move to prohibit all GM tree release into the environment lacks logic, especially when, for example, species such as English elm, which does not normally set seed in the UK climate, is considered and is therefore unlikely to represent any risk of potential genetic contamination. Questions relating to potential contamination should better address whether any potential pollen escapes are of any ecological or economic consequence, or simply going to be diluted out, as the vast majority of traits studied to date have no, or slightly negative, reproductive fitness effects.

The closed and restrictive approach to certification adopted by the Forestry Stewardship Council, which prohibits any certificated use of land associated with GM trees adds to the constraints on scientific investigation of GM trees and the products of forest biotechnology in general.
Question 2. Has your country developed any platform/discussion forum/national committee etc. dealing with genetically modified trees?
Within the UK, the Institute of Forest Biotechnology (IFB) and University of Abertay Dundee, Scotland have hosted a successful European Forest Biotechnology Conference, encouraging discussions between all parties and open dialogue about what the potential benefits, risks or consequences of developing and if considered appropriate, deploying the products of forest biotechnology might be. The ‘European Forest Biotechnology Conference’ including representatives from green groups, Universities, European industry and research institutes, as well as government regulators and was chaired by Prof Kevan MA Gartland, a Director of IFB. Several other meetings and dialogues have been sponsored by IFB in this regard globally, including successful events in Chile on ‘Forest Biotechnology in Latin America’, N Carolina on ‘New Century New Trees’ and Vancouver, Canada on ‘Growing Trees and Stemming Risks - a Forum for Ecological Risk Assessment Dialogue’.
Conducting these types of open dialogue meetings requires all points of view to be prepared to participate in the discussions, however, this has proved very difficult to achieve as a number of deep ecologists and fundamentalist green activists refuse to partake in dialogue or constructive and balanced discussions.
3. Does your country have any guidelines or regulations for minimizing the impacts of genetically modified trees for scientific and/or commercial purposes?
This question is fundamentally flawed, as it appears to make the assumption that any scientific and/or commercial impacts or purposes of GM trees must require to be minimized. There is no logical or scientific evidence basis for this erroneous presumption. Many of the potential impacts of GM trees may have positive aspects, eg reductions in chemical or energy required for industrial processing, cheaper construction materials, higher calorific value fuels, pathogen resistant trees etc. There is at least as much, and almost certainly more, evidence for potentially positive impacts as for negative impacts needing to be minimized.
The UK has an Advisory committee on Release into the Environment (ACRE) which advises the relevant Secretaries of State as to potential deliberate release into the environment applications for all GM plants. Relevant legislation, reflecting EU Directives on environmental release guide these regulations. At the present time, the regulatory hurdles erected and the activities of genetic terrorists are such as to make it exceedingly difficult for Universities or small scale companies to meet the evidence requirements before any release application might be approved, or the trials conducted without acts of wanton vandalism taking place.
The European approach of assessing risk by regulating the process of GM itself, rather than a case by case carefully considered approach concentrating on the product itself and genetic similarity is holding back innovations in biotechnology. The European Union has recently commissioned the development of ‘Plants for the Future’ a Strategic Research Agenda coordinated by EuropaBio, pointing the way towards activities needed for a bio-based economy to reach fruition across Europe by 2025. This Strategic Research Agenda development process has involved interest groups from many different points of view and includes environmental sustainability as well as plant productivity and biodiversity interest groups.
Regulatory systems which consider only potentially negative impacts are, of necessity, flawed, as they appear to ignore the possibility of deployment of the products of new technology having any positive or favourable consequences, eg maintaining threatened tree species, preserving ecologically damaged landscapes, allowing areas of concentrated production to support forest and biodiversity refugia, using GM trees as enhanced biofuels or sustainable green job generators etc.
The Secretariat should also consider the adverse effects of not developing or deploying GM tree products, which may severely disadvantage developing country or disadvantaged regional economies. Decision support systems for GM trees must adequately consider ecological, societal and economic aspects of proposals, rather than remain the plaything of fundamentalist environmental groups.