USDA accepting comments on GE plum trees, the first temperate GE tree

Alert: Stop the commercial planting of genetically engineered
plums-the first temperate GE tree

(Please follow the directions at the bottom of this email to inform
the USDA of your opposition to GE plum trees before July 17th. )

The US Department of Agriculture is accepting public comments between
now and July 17, 2006 on a petition that would allow commercial
growing and marketing of the first genetically engineered (GE) plum
trees. If approved, this would remove all regulatory oversight of
this GE variety, a virus-resistant plum tree known as the Honey
Sweet Pox Potyvirus Resistant plum. This would open the door to GE
varieties of many other related stone fruits, such as peaches,
apricots, cherries and almonds, that are susceptible to the same
virus. Ironically, this virus is not even found in the US today
according to the USDA, and is certainly not a significant
agricultural problem here.

The USDA admits that this GE plum will contaminate both organic and
conventional non-genetically engineered plum orchards if it is
approved. Since all commercial plum trees are cultivars that are
relatively cross compatible within the same species, Prunus
domestica, contamination via GE plum pollen carried by bees and other
insects will infiltrate the plum orchards of organic and conventional
growers. The proposed buffer zones between GE plums and other plums
will not prevent genetic contamination from being spread by
pollinating insects.

Because this GE plum tree is also the first genetically engineered
temperate tree proposed for commercial planting, it also opens the
door to the commercialization of GE varieties of other temperate
trees such as poplars, pines, and walnuts.

The one GE fruit tree that has previously been approved, a virus
resistant Hawaiian papaya, has caused extensive contamination of
organic, conventional and wild papaya orchards on most of the
Hawaiian Islands in just a few years. This contamination has spread
far more quickly than the USDA predicted in its initial assessment.
Once native and cultivated plum varieties are contaminated with
transgenic pollen, there is no calling it back.

This petition has implications for all other GE tree species, as the
USDA and the industry want to gauge what the public's reaction will
be. It is critical that all concerned about the threat of GE foods
and GE trees respond to this USDA petition.


[Comments to submit below. Please add any additional comments of your own.]

The following comments are in reference to Docket No. APHIS-2006-0084

I oppose the deregulation of genetically engineered plum trees for
the following reasons:

1. Genetic contamination is a serious threat. Flowers and fruit in
organic and conventional plum orchards will become contaminated with
GE plum genes via pollen transported by bees and other insects that
travel many miles in search of pollen. The result is that organic and
conventional plum growers will lose their markets for non-GE plums as
DNA testing confirms the contamination, as it has with GE papayas in
Hawaii. An organic tree might remain organic itself, but the fruit
and seeds will become contaminated.

2. The approval of GE plums would be a precedent setting step by
USDA, opening the floodgates for more GE trees including fruit, nut,
ornamental, and paper-pulp species, as well as trees engineered for
soil remediation, and other traits. Approximately 80 species and
varieties of trees are currently undergoing gene splicing research
and development for commercial use.

3. There is a serious concern about the genetic stability of the
inserted genes in GE plum trees. USDA claims that the plum pox viral
resistance gene and other inserted genes are sufficiently genetically
stable, but the testing has only been performed over ten years and
not the entire pollen-producing life span of a plum tree. Over the
life of a tree, an RNA virus such as plum pox is susceptible to many
cycles of recombination, leading to the creation of new plant viruses
that could infect a wide variety of plants. This can also occur with
the viral DNA that has been inserted into these plums.

4. The plum pox virus is not currently known to exist in the US as a
problem for plum growers. Thus there is no justification for exposing
other trees, plants, insects and people to the various hazards posed
by GE plums.

5. The deregulatory petition completely ignores potential effects on
bees and other pollinator species. There are no studies that would
allow us to evaluate the potential hazards of GE tree pollen for a
variety of insects, or for consumers of honey. We also do not know
how animals and insects that browse on plum leaves might be affected.

6. The USDA's environmental assessment admits that the GE plum
readily hybridizes within its species. Thus, there is a significant
potential for gene flow into native plum varieties. Wild plum trees
are perennial species living for several decades and populations
exist in dozens of states from coast to coast. GE plum trees will be
long lived, and capable of contaminating orchards and native plum
tree populations for several decades. One GE plum tree will be able
to produce thousands of GE seeds and extensive quantities of GE
pollen, and will be capable of spreading fertile GE plum seeds and
pollen into the environment for many years. The petition did not
adequately evaluate the relative fitness of GE plum varieties as
compared to native plums; it is possible that the GE varieties would
become more successful in natural settings, and out-compete non-GE
varieties. We challenge the USDA spurious claim that contamination
would be positive by reducing potential reservoirs for harboring the
plum pox virus in the wild.

7. There has been no short-term or long-term safety testing or
feeding trials for toxicity and other adverse effects of the genes
inserted into the GE plum trees. GE plums have not been tested on
animals, birds or humans for safety. Toxicity tests are necessary
since unintended genetic effects are known to occur with gene
splicing. USDA has ignored the need for scientific studies of gene
splicing and for comprehensive studies of the environmental
consequences of GE plantings.


The US Department of Agriculture is accepting public comments between
now and July 17, 2006 on the petition to formally deregulate and
allow commercial growing and marketing of GE plums.

To submit your comments, send an original and three copies with your
name and address to Docket No. APHIS-2006-0084, Regulatory Analysis
and Development, PPD, APHIS, Station 3A-03.8, 4700 River Road, Unit
118, Riverdale, MD 20737-1238. If you wish to submit a comment using
the Internet, go to http://www.regulations.gov. In the "Agency" box,
select "Animal and Plant Health Inspection Service" from the
drop-down menu; select "NOTICES" as the Document Type and
APHIS-2006-0084 as the "Keyword or ID." Then press "submit" to submit
or view public comments as well as the agency's supporting materials;
click just beneath "Add Comments" and scroll down to submit your
letter.

Feel free to copy and paste any or all of the 7 points above, along
with any comments of your own. Please forward this widely among your
friends and other contacts.

Thanks for helping us STOP the genetic engineering of trees!
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STOP Genetically Engineered Trees Campaign
http://www.stopgetrees.org

A project of Global Justice Ecology Project
P.O. Box 412
Hinesburg, VT 05461 U.S.
+1.802.482.2689 ph/fax
info [at] globaljusticeecology.org
http://www.globaljusticeecology.org

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Biotechnology Project
c/o Institute for Social Ecology
P.O. Box 93
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