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COLLEGE OF ENVIRONMENTAL SCIENCE AND FORESTRY

[13 November 2007]

[SUBMISSION: ENGLISH]

Question 1. Does your country have any plantations, either commercial or experimental, of genetically modified trees?

Yes. I am conducting research on Castanea dentata (American chestnut), Ulmus Americana (American elm), and hybrid poplar in efforts to enhance resistance to exotic pathogens introduced into this country. Transgenic trees from each of these species are currently being field tested. These are just a part of the over 350 field trials representing over 20 species of transgenic trees approved by the United States Department of Agriculture. In addition to these field trials, the U.S. has deregulated genetically engineered papaya that is resistant to papaya ring spot virus. This transgenic tree has been widely planted in Hawaii and is benefiting the small farmer. Soon a second tree species is expected to be deregulated, plum trees engineered to be resistant to plum pox virus. It is our hopes that within the next five to six years, transgenic American chestnut, engineered to be resistant to chestnut blight, and transgenic American elm, engineered to be resistant to Dutch-elm disease and elm yellows, will be deregulated. We can then use these to help restore these heritage tree species that were devastated by exotic pathogens.

Among all these various field trials, I have not seen any reputable reports of negative impacts or harm to the environment or biodiversity, indicating that trials of genetically modified trees can be performed safely with current regulations. In fact, our research goals to restore tree species driven to the brink of extinction by exotic pathogens will eventually restore biodiversity and benefit the environment. Details on field trials are available to the public at http://www.isb.vt.edu/ and from the US Department of Agriculture.
If yes, please answer all remaining questions.

If no, please state the reason why:
Question 2. Has your country developed any platform/discussion forum/national committee etc. dealing with genetically modified trees?
Yes. I have held many open debates at the SUNY College of Environmental

Science and Forestry and I know this is a common practice among professors in this field of study. Nationally, there has been several open forums, some of which I have attended and some that I have missed. The ones I know of include: USDA APHIS meeting held July 8-9, 2003 IUFRO Sponsored ‘Tree Biotechnology in the New Millennium’ (July 22-27, 2001) The Institute for Forest Biotechnology sponsored meetings: ‘Modifying Reproduction in Urban Trees (February 12-13, 2003) New Century, New Trees’ (November 16-17, 2004) Growing Trees & Stemming Risks (March 20-21, 2006). Professional societies have often held special sessions to discuss genetically modified trees at their annual or semi-annual meetings, including the Society of In-Vitro Biology, Southern Forest Tree Improvement Conference, and IUFRO Tree Biotechnology, among others.

If yes, please answer the remaining questions

If no, please state the reason why:
3. Does your country have any guidelines or regulations for minimizing the impacts of genetically modified trees for scientific and/or commercial purposes?
Unfortunately this is a biased question. Guidelines should look at both the risks and benefits of genetically modified trees. It should not be assumed that there are only risks. In fact, not developing a genetically modified tree can have its own risks. For example, in my research, not developing pathogen resistant trees could lead to extinction of the species and have a negative impact on all the organisms that use these trees.
So I ask that the Secretariat to also recognize the positive impacts of genetically modified trees. These can include species restoration, detoxifying pollution, alternative fuels, enhancing food production, among many others.
To answer the question above, yes, the United States has a very good system to regulate the process from moving trees from the research lab into field trials and then deregulation.
If yes, please list them according to the categories below: We need to provide documentation of the benefits associated with biotech trees and the factors that need to be considered for risk analysis and what make a risk a not acceptable risk.

If no, please explain the reason why here:
Environmental impacts of genetically modified trees (Example: effects on native ecosystems, use of herbicide)
I will use the example I know best, the development of genetically modified Castanea dentata (American chestnut) to be resistant to chestnut blight. Before the introduction of this exotic disease there were an estimated three to six billion C. dentata trees in the eastern United States and Canada. Within 50 years, the blight decimated these trees so that today only a few million survive as nonreproducing stump sprouts. As the trees died during the epidemic, there was also a decline in many wildlife species that used the nuts from these trees to survive the winter. The eastern U.S. forests have returned, but much different, with oaks and maples replacing the spaces once occupied by the chestnut. These new trees do not produce as large or as consistent a mast crop as the chestnut and therefore the forest cannot support as many organisms as in the past. The restoration of the American chestnut tree through the use of genetic engineering will benefit the forest by allowing larger numbers of wildlife and a more diverse forest to return.

Cultural impacts of genetically modified trees (Example: positive or negative impacts on indigenous and local communities and their traditional knowledge)
The American chestnut was widely used by the indigenous peoples of the United

States. In fact, as the native Americans originally migrated from the west into the east, their impacts on the environment increased the chestnuts portions in the forest from about 10% of the mature trees to 25% of the mature trees. The European settlers in the United States relied on the American chestnut to feed their livestock and for building materials. The restoration of the American chestnut tree through the use of genetic engineering will benefit both the indigenous peoples as well as society as a whole.

Socio-economic impacts of genetically modified trees (Example: positive or negative effects on quantity, quality and economic value of forest production; positive or negative impacts on livelihoods of communities)
Restoration of the American chestnut by genetic engineering will also benefit the quality and economics of the forest. In addition to its nut crop, which can be used as food, feed, or feedstock for biofuels, the chestnut wood is highly valued. It is a fairly fast growing hardwood species with strait grain and highly rot resistant wood. Therefore the return of this tree would benefit the economics of the small and large farmer alike. I only used the American chestnut in this answer, but similar benefits as well as unique other benefits can been applied to other genetically engineered trees.

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* UNEP/CBD/SBSTTA/13/1.

1 Directive 2001/18/EC of the European Parliament and of the Council of 12 March 2001 on the deliberate release into the environment of genetically modified organisms and repealing Council Directive 90/220/EC

2 Regulation (EC) No 1829/2003 of the European Parliament and of the Council of 22 September 2004 on genetically modified food and feed

3 Commission Decision of 24 July 2002 establishing guidance notes supplementing Annex II to Directive 2001/18/EC of the European Parliament and of the council on the deliberate release into the environment of genetically modified organisms and repealing Council Directive 90/220/EEC (2002/623/EC)

4 Council Directive of 23 April 1990 on the contained use of genetically modified organisms (90/219/EEC), as amended by Council Directive of 26 October 1998

5 The 2% balance is in miscellaneous reserves etc.

6 The indigenous people of New Zealand.

7 Under the Resource Management Act “sustainable management” means managing the use, development and protection of natural and physical resources in a way, or at a rate, which enables people and communities to provide for their social, economic and cultural wellbeing and for their health and safety while (a) sustaining the potential of natural and physical resources to meet the reasonably foreseeable needs of future generations; and (b) safeguarding the life-supporting capacity of air, water, soil and avoiding, remedying, or mitigating any adverse effects of activities on the environment.

8 A Royal Commission is the highest body for hearing and investigation available in New

Zealand.

9 The HSNO Act came into effect for new organisms in 1998.

10 Wilson A, Latham J and Steinbrecher R (2004). Genome Scrambling – Myth or Reality? Transformation-Induced Mutations in Transgenic Crop Plants. EcoNexus Technical Report. The full 36 p report or the 4 p summary are freely available at www.econexus.info.

11 T-DNA is transfer DNA from the pathogenic bacteria Agrobacterium tumefaciens.

12 Round-Up Ready plants are resistant to the herbicide Round-Up manufactured exclusively by the Monsanto Co.

13 A field test of 16 Picea abies (Norway spruce) trees has come to an end and the trees destroyed

14 Rubicon is also a one-third partner in the US tree biotechnology company, ArborGen

15 See also www.gm.govt.nz

16 The exception is some designated low-risk situations where Institutional Biological Safety Committees are delegated authority by ERMA

17 The sections in italics are quoting the HSNO (Methodology) Order

18 Charity, J.A. and K. Klimaszewska. 2005. Persistence of Agrobacterium tumefaciens in transformed conifers. Environmental Biosafety Research, 4, 167-177.

19 Brockerhoff, E.G. 2005. Biodiversity in plantation forests. In M. Colley (ed). Forest Handbook. New Zealand Institute of Forestry, Christchurch.

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