Comment by the World Rainforest Movement on the Petition of ArborGen Inc. seeking a Determination of Nonregulated Status for Freeze Tolerant Eucalyptus

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To: APHIS (Animal and Plant Health Inspection Service)

Montevideo, April 10, 2013

The World Rainforest Movement (WRM) is an international organization, founded in 1987 and based in Uruguay, working on tropical forest and forest-related issues, including industrial tree plantations.

For many years, the WRM has monitored and studied several aspects of the expansion of industrial tree plantations worldwide. One of these is the trend promoted by tree plantation companies to introduce plantations of genetically engineered trees.

In one of our most recent publications – An overview of industrial tree plantations in the Global South: conflicts, trends and resistance struggles   (http://www.wrm.org.uy/publications/EJOLTplantations.pdf (1)) - we address the issue of genetically engineered trees. With this letter we would like to draw your attention to the analysis presented in this last publication.

As the publication documents, the main focus of research into genetic manipulation in trees has been on forcing some naturally-occurring genes to be overactive, silencing others, or inserting genes from one species into another.One reason has been toincrease tolerance to cold conditions in trees, as in the case assessed now by APHIS.

The objectives and consequently the risks of such genetic manipulation are many:  there has been, for example, discussion about genetically modifying trees so that they produce new products, such as chemicals. An especially fast-growing area of research is the engineering of trees to maximize production of wood biomass-based ethanol. Industrial tree plantation corporations are especially interested in increasing trees' pest resistance or changing their growth rates or the qualities of the wood they produce. Pulp producers look for GE techniques that create eucalyptus and pine varieties with a lower lignin content, making them more malleable in pulping processes. They are also anticipating GE tree varieties that grow faster or are more tolerant to adverse soil and climate conditions. And plantation companies such as Aracruz/Fibria and Suzano in Brazil are not only waiting for GE-based improvements to trees to be developed elsewhere, but are themselves investing in the technology, always focusing their efforts on making the raw material they produce even more homogenized and the characteristics of the trees they grow even more narrowly tailored to the needs of their machines. The justification, in the words of Aracruz/Fibria, is that “genetic engineering of forest species can bring benefits to society through sustainable development”(2). Our recent report as well as numerous case studies on large-scale monoculture plantations however do not support this claim, and there is no indication that the assumption would be any more valid in the case of GE tree plantations than in non-GE tree plantations.

Pesticide-resistant trees are perhaps the most problematic GE tree development. Glyphosate-resistant tree monocultures would effectively prevent any other species from surviving under eucalyptus or pine, creating an even emptier green desert than the current monocultures, with far more damaging environmental and health impacts. Eventually, however, resistance to Glyphosate develops among pests and other species alike, necessitating ever-increasing chemical application. While pesticide application is increasing in any case, the use of Monsanto´s Roundup Ready apparently increased even more after glyphosate-resistant soybeans were introduced in Brazil.(3)

Biological contamination is a particular problem with GE trees that pollinate, since pollination allows genetically modified organisms (GMOs) to spread over long distances via air. Pine trees can spread their pollen for 3,000 kilometers (4), and those seeds can germinate even after three years. This and other qualities of pine make its genetic manipulation a great risk to natural forests. According to published research, ‘it would be difficult to contain the pollen from GE loblolly pine trees.’(5) The fact that trees live much longer than food crops adds to the contamination dangers; as the same research concluded, ‘The long life span of pine trees makes it difficult to evaluate the environmental impacts of GE varieties.’

One of the biggest problems is the unreliable science of genetic manipulation itself: our current understanding of what genes do and how life is formed, as well as of how genes behave when transplanted to other species, is very limited. It is our understanding that none of these overarching risks have been resolved by the applicant. Should they materialise the consequences would cause environmental impacts that may or may not be possible to contain or repair once they have occurred. Approving the petition presented to APHIS would thus expose people and the environment to these risks (a) without any clear understanding of the potential consequences or likelihood of being (un-) able to contain an incident should it arise or (b) without significant social or environmental benefits that could be considered to outweigh the risks to the local population or the environment.

A safer option would be a clear ban on GE trees. From a perspective of public interest, public health and environmental protection, an even better, cheaper alternative, particularly in view of the risks and high costs of GE research, would be to steer away from this technology altogether. Local forest and forest-dependent populations could give guidance on what kind of research would be preferable, and should participate in any decisions made on what research should be done and how it should be implemented, working together with (other) researchers on issues such as agriculture, agroforestry and agroecology. This type of collaboration between local agroecology/forestry practicing communities and researchers already exists in some places in, for example, Latin America and India (Altieri and Toledo, 2011).

One additional comment is that in the case of plantations of fast-growing trees like eucalyptus, one of the first problems has to do with water, crucial for any human being but especially for rural communities dependent on water for economic activities such as agriculture and cattle grazing (6) . The question of whether industrial tree plantations of e.g. eucalyptus dry up local rivers, streams and wells has been one of the most contested issues involving local people and industrial tree plantation firms. In all documented accounts of local community reactions to these tree plantations, most often eucalyptus, without exception, people complain that their water sources have dwindled or dried up. South Africa, a country where water is a scarce and disputed resource, has been a pioneer country in terms of concern about impacts of industrial tree plantations on water. Tree plantations (eucalyptus) have been monitored in nine catchments since 1936 and a number of impacts have been confirmed: ‘Solid and fairly conclusive results on the impacts of tree plantations on water have come out, including certain rules of thumb. … The onset of streamflow reductions was evident approximately at five years, and is strongly associated with plantation age, up to a peak reduction occurring at around 15 years, followed by a gentle decline in water use. … in the case of eucalyptus [5-7 years old], the average [water use per day per tree] may range from 100 to 1000 liters depending on where the landscape is. Trees next to a stream can use twice that amount of water because they have more access to it. The conclusions of the study and documentary come in support of an urgently needed debate on the peril of large scale monoculture tree plantations, particularly regarding the issue of water in every country where they are being established’ (WRM,2010b, see footnote 6

).

In the past few years, the South African evidence has been supplemented by growing scientific support for the complaints of local communities. In 2005, a group of 10 scientists, synthesizing over 600 global observations, published a report in the journal Science concluding that in general, tree ‘plantations decreased stream flow by 227 millimetres per year globally …, with 13% of streams drying completely for at least 1 year’ (Jackson et al., 2005, see footnote 6).

Even one of the leading academic apologists for industrial tree plantations from Brazil admits indirectly that where these plantations occupy more than 20% of a watershed, which is overwhelmingly the case, water availability will decline (Carrere, 2010, see footnote 6). Walter de Paula Lima, professor at the well-known Forestry Department of Sao Paulo University (ESALQ) in Brazil, and author of several publications on the issue funded by industrial tree plantation firms, states in a2010 publication that ‘some experimental studies in watersheds (...) show that there is no change in runoff if these plantations occupy only 20% of the area of the watersheds’. ITPs also affect local water in another way: local streams and rivers are contaminated by chemicals used in ITPs, affecting fisheries, drinking water availability, and bathing and swimming. Affected communities often become dependent on externally-provided clean water.

Finally, we would like to invite you to consider the evidence on the impacts of GE Trees documented in materials listed in the special section on this issue on our website (http://www.wrm.org.uy/subjects/biotechnology.html). In addition to the aforementioned publication the website contains additional information on the aforementioned and other aspects, for example in:

1.  “Genetically modified trees: the ultimate threat to forests”. By Chris Lang, published in 2004 by WRM and Friends of the Eearth (see http://www.wrm.org.uy/subjects/GMTrees/text.pdf);
2. “Transgenic Trees”, published in 2007 by the World Rainforest Movement (seehttp://www.wrm.org.uy/subjects/GMTrees/briefing_GMT.pdf)

These documents and others in the section on the WRM website strengthen arguments for your institution NOT to approve the petition from ArborGen Inc. seeking a determination of nonregulated status of Freeze Tolerant Eucalyptus lines designated 427 and 435, which have been genetically engineered (GE) to be more tolerant to cold conditions.

Yours sincerely,

Winfridus Overbeek
International Coordinator
World Rainforest Movement

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