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GLOBAL FOREST COALLITION

[02 November 2006]

[SUBMISSION: ENGLISH]

Genetically Engineered Trees are an Unnecessary Threat to Biodiversity
The Global Forest Coalition (GFC) thinks that the release into the environment of genetically engineered (GE) trees is bound to harm biodiversity in multiple ways and with predictable catastrophic consequences for nature and human populations. Therefore, the release of GE trees is an unnecessary threat to biodiversity.
The known effects of GE trees on biodiversity are generally negative. It is well known to the scientific community engineering tree varieties that leases of GE trees into the environment will be likely to cause negative effects on biodiversity and nature in general. The scientific community engaged in this research admits serious uncertainties as to how GE trees may affect nature, giving no reasonably reliable safety guaranties to justify their use. This position is only realistic, as trees are basically uncontrollable, for they grow massive, live for decades - even centuries -, produce enormous amounts of pollen and some reproduce asexually; guaranteeing constant dissemination of the transgenes for as long as they live.
The use of Agrobacterium as the main transfer agent for the transgenes involved should be sufficient to ban any prospect of GE trees be released into nature. Until quite recently, the genetic engineering community has assumed that Agrobacterium does not infect animal cells, and certainly would not transfer genes into them. But this has been proved wrong. Kunik et al (2001) reported that T-DNA¹¹ can be transferred to the chromosomes of human cancer cells (Kunik et al, 2001).
Other widely recognized negative aspects of genetic engineering of trees – that may justify banning them all together - is that they are mainly developed to express glyphosate resistance, insect resistance and lignin reduction or modification. If traits like these – as they likely may - find pathways for vertical or horizontal transfer, we would be facing irreversible damage to potentially all biota.
Trees engineered for glyphosate resistance, for instance, would promote the emergence of glyphosate resistant weeds. Recent studies conducted in various US states, show that the number of resistant weed species has increased across the country and that farmers need to resort back to herbicides such as Dicamba, Paraquat and 2,4-D (Southeast Farm Press, October 19 2006). Phasing out these herbicides was a key reason for engineering Round-Up Ready¹² plants.
GE trees designed to contain less lignin than their species normal content, to speed up growth or as a means to improve pulp yield or absorb more (and faster) carbon, would be more vulnerable to pest attacks and, as experienced in a field trial by the Toyota Corporation, they consume disproportionately more water than normal trees (Rautner 2001).
The greatest threat to biodiversity emanating from GE trees is the spread of the insecticidal traits, induced by transgenes naturally occurring in Bacillus thuringiensis (Bt), to forests trees. Beneficial insect predators that fed on insect pests feeding on Bt plants produced in GE crops were harmed even when the pests themselves were not affected by the toxins (Dutton et al 2002). One class of Bt toxins (Cry1A) was found to harm butterflies, lacewings and mice (Ho and Cummins, 2005). Another class (Cry3A) acts against insects belonging to the Order Coleoptera (beetles, weevils and stylopids) (Wu et al, 2000), which contains some 28,600 species. Bt toxins are known to leach out of the roots into the soil, with potentially huge impacts on the soil biota (Ho and Cummins, 2005).
The risks posed by this scenario are awesome and may include widespread extinctions of flora and fauna, collapse of agricultural systems, and diseases in animals, including humans.
The GFC believes that the Convention on Biological Diversity must intervene to avoid the release into nature of GE trees by urging parties to apply the Precautionary Principle to ban this technology within their jurisdictions.
References
Dutton A, Klein H, Romeis J and Bigler F. “Uptake of Bt-toxin by herbivores feeding on transgenic maize and consequences for the predator Chrysoperia carnea”, Ecological Entomology 2002.
Rautner, M. (2001), "Designer Trees" Biotechnology and Development Monitor, No. 44.
Wu S-J, Koller CN, Miller DL, Bauer LS and Dean DH. Enhanced toxicity of Bacillus thuringiensis Cry3A d-endotoxin in coleopterans by mutagenesis in a receptor binding loop. FEBS Letters 2000.

GOLDAMER CONSULTING

[28 August 2006]

[SUBMISSION: ENGLISH]

1. Does your country have any plantations, either commercial or experimental, of genetically modified trees?
No, but we have GM cotton, maize and soybean. There is a need (i) to produce GM trees that will grow in areas that are presently considered to be marginal for forest plantations, (ii) to exploit the benefits of GM trees to control pests and diseases, (iii) to establish suitable and appropriate renewable resources, and (iv) to improve the quality of the products currently produced from forested areas in South Africa.

If yes, please answer all remaining questions.

If no, please state the reason why: No organization/institution has yet applied for a permit under the GMO Act to undertake laboratory or contained field trials.
2. Has your country developed any platform/discussion forum/national committee etc. dealing with genetically modified trees?
Yes, South Africa has the necessary legislative framework to accommodate the testing, evaluation and introduction of GM trees. The SA Forestry industry also has a national forum where this matter can be discussed.

If yes, please answer all 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?
Yes, there is a legal framework in place which includes the GMO Act and the Environmental Management Act.


If yes, please list them according to the categories below: The Genetically Modified Organisms Act, 1997 (Act No. 15 of 1997), Plant Improvement Act, 1976 (Act No. 53 of 1976), Plant Breeders’ Rights Act, 1976 (Act No.15of 1976)
If no, please explain the reason why here:

Environmental impacts of genetically modified trees (Example: effects on native ecosystems, use of herbicide) The National Environmental Management Act, 1998 (Act No. 117 of 1998). The NEMA: Biodiversity Act, 2004 (Act No. 10 of 2004) which replaces the Forest Act, 1984 (Act No. 122 of 1984).

Cultural impacts of genetically modified trees (Example: positive or negative impacts on indigenous and local communities and their traditional knowledge)
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)

There are no GM trees being commercially grown in SA at present, however, socio-economic studies have been conducted on the cultivation of GM cotton.