If you had only the excerpt from Animal and Plant Health Inspection Service
statement that Paul posted to go on, you'd be stunned to learn that
some eucalyptus species are highly invasive in California.  It seems to me
that engineering cold-tolerance into eucalyptus presents a serious risk of
expanding its potential range as an invader.

My concern is not so much with the field test (which I think can plausibly
be controlled) as with eventual commercialization and widespread
distribution of these trees in places eucalyptus is not currently able to
invade.  After this carefully-controlled test under conditions that minimize
the risk of harmful effects, how much more testing is needed before the
trees can go to market?  Once they're on the market, we can't expect the
consumer to monitor the trees quite so carefully.  The only test that will
definitively tell us if these trees will be invasive is their release in the
environment under poorly-regulated conditions, and if they're invasive, we
will most likely only know it once they're beyond our control.

This, in turn, brings up a more general concern of mine.  If we haven't
introduced a species to a region, we obviously don't know if it will be
invasive; why does this always seem to be seen as an argument in favor of
introduction?

For an argument against the approval of the field trial that doesn't involve
the prefix "franken-," you could try the Union of Concerned Scientists:
http://www.ucsusa.org/food_and_agriculture/solutions/sensible_pharma_crops/ucs-comments-to-usda-on-2.html
.

Jim Crants

On Sun, Jun 21, 2009 at 4:50 PM, Paul Cherubini <[email protected]> wrote:

> To learn about the benefits of GM eucalyptus visit the ArborGen
> website: http://www.arborgen.com/newsroom.php
>
> "ArborGen trees will allow landowners to grow more wood on less
> land with fewer agricultural inputs, thus protecting our native forests
> and ecosystems."
>
> To learn about why the United States Animal and Plant Health
> Inspection Service doesn't consider GM eucalyptus field tests
> dangerous for the environment, google "arborgen USDA"
> and you'll find this notice:
>
> http://tinyurl.com/mutlmu
> Animal and Plant Health Inspection Service
> Finding of No Significant Impact and Decision Notice
>
> 1. The field test sites are located on secure, private land in
> Baldwin County, Alabama, and are physically isolated
> from any sexually compatible Eucalyptus.
>
> 2. There is little probability of asexual spread since this hybrid
> Eucalyptus does not propagate readily without the aid of
> special environmental conditions.
>
> 3. Eucalyptus seed is not adapted to wind dispersal so
> the dispersal of seed is expected to be limited to the
> proximity of the field test area.
>
> 4. It is unlikely that viable seeds will be produced by the
> Eucalyptus hybrids in the field test, and it is unlikely that
> any seeds produced will be able to germinate andproduce
> viable offspring. Therefore, APHIS concludes that it is not
> reasonably foreseeable that Eucalyptus seeds will be spread
> by severe wind events and establish outside of the field site.
>
> 5. If any seeds were to be formed due to crossing within the
> field test, there is very little probability that they will
> germinate since Eucalyptus seeds have very limited
> stored food reserves, are intolerant of shade or weedy
> competition, and need contact with bare mineral soil
> to successfully germinate.
>
> 6. If any viable seeds were to be produced and grow
> into seedlings, they will be easily identified by monitoring
> the field sites and destroyed with herbicide treatment or
> removed by physical means.
>
> 8. Horizontal movement of the introduced genes is
> extremely unlikely. The foreign DNA is stably integrated
> into the plant genome.
>
> 9. No adverse consequences to non-target organisms or
> environmental quality are expected from the field release
> of these transgenic Eucalyptus for the reasons stated below.
>
> Paul Cherubini
> El Dorado, Calif.
>



-- 
James Crants, PhD
Scientist, University of Minnesota
Agronomy and Plant Genetics
Cell:  (734) 474-7478

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