Subj:   letter to Convention on Biological Diversity urging a ban   
Date:   10/6/2006 6:52:18 AM Central Standard Time  
From:    [log in to unmask] (Laurel Hopwood)
Sender:    [log in to unmask] (Biotech Forum)
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In conjunction with the Sierra Club US - Canada International 
Committee  and US International Committees, we signed on to this 
letter.  Many thanks to Sierra Club Genetic Engineering Committee 
member, Neil Carman, PhD, for helping to create the message.
Laurel Hopwood, Chair, Sierra Club Genetic Engineering Committee member

Background:
Sign-on letter to Convention on Biological Diversity (CBD) urging a 
ban on genetically modified trees

At its last Conference of the Parties (COP8), the Convention on 
Biological Diversity adopted a very important Decision 
(VIII/19),"Recommending "Parties to take a precautionary approach 
when addressing the issue of genetically modified trees".

That Decision recognized "the uncertainties related to the potential 
environmental and socio-economic impacts, including long-term and 
transboundary impacts, of genetically modified trees on global forest 
biological diversity, as well as on the livelihoods of indigenous and 
local communities, and given the absence of reliable data and of 
capacity in some countries to undertake risk assessments and to 
evaluate those potential impacts".

This is a very important step in the right direction, which needs to 
be supported against the pressure that will be put on the CBD by the 
powerful pro-GM tree lobby.

Given that the COP8 Decision has invited everyone "to provide 
relevant views and information to the Secretariat for inclusion in 
this assessment", a number of organizations have produced a joint 
letter to be sent to the Secretariat providing information and 
analysis on the issue and calling for a "mandatory decision declaring 
an immediate ban on the release of GM trees."

The letter concludes that "GM trees have no role to play in the 
conservation of global forest biological diversity and, on the 
contrary, are likely to reduce forest biodiversity, with attendant 
social consequences. The high risks indicated by the available though 
incomplete science show that the technology could result in the 
extinction of forest plant and animal species with severe negative 
impacts on biodiversity" and urges the CBD "to move forward from the 
current recommendation to Parties to take a precautionary approach, 
to a mandatory decision declaring an immediate ban on the release of 
GM trees."

LETTER:

CBD Secretariat
Dear Mr Djoghlaf,

The undersigned wish to express our full support for the COP 8's 
Decision VIII/19 (Forest biological diversity: implementation of the 
programme of work), which "Recommends Parties to take a precautionary 
approach when addressing the issue of genetically modified trees".

We also support the reasons for the adoption of the above Decision 
which states that: "Recognizing the uncertainties related to the 
potential environmental and socio-economic impacts, including 
long-term and transboundary impacts, of genetically modified trees on 
global forest biological diversity, as well as on the livelihoods of 
indigenous and local communities, and given the absence of reliable 
data and of capacity in some countries to undertake risk assessments 
and to evaluate those potential impacts".

Given that the Decision also "Invites Parties, other Governments and 
relevant organizations, including indigenous and local communities, 
as well as relevant stakeholders, to provide relevant views and 
information to the Secretariat for inclusion in this assessment," we 
would like to contribute to this assessment.

A look at the main genetically modified (GM) tree research currently 
being carried out shows that it is focused on a very narrow range of 
aims:

- herbicide resistance
- insect resistance
- tree sterility
- lower lignin and higher cellulose content
- resistance to cold, salt or drought
- faster growth

None of the above can be seen as being beneficial to global forest 
biological diversity, which needs accompanying flora species 
(impacted by herbicides), insects and related food chains (impacted 
by insect resistant trees), flowers and seeds (inexistent with tree 
sterility), wood resistant to strong winds (lower lignin content 
makes trees weaker), trees and plants adapted to local environments 
(impacted by alien trees resistant to cold, salt or drought), intact 
soils and sufficient water (depleted by fast-growing trees) In 
addition, genetically engineered tree plantations are likely to be 
developed where biologically diverse forests now stand, following the 
trend of monoculture plantations that have replaced native forests 
around the world.

This indicates that GM trees are not beneficial for global forest 
biological diversity. It is also clear that those genetic 
modifications are being carried out for industrial and not 
environmental reasons and, if released, would result in industrial 
plantations with low biodiversity, largely devoid of other living 
organisms, thus effectively depleting forest biological diversity.

This leads to the main question: Can genetically modified trees have 
a negative impact on global forest biological diversity?

The main threats are:

- Substitution of diverse forests by genetically modified tree 
monocultures. This is already happening with "conventional" tree 
monocultures (oil palm, eucalyptus, pines, acacias, and gmelinas) and 
there is no reason to believe that it would be different with GM 
trees. On the contrary, corporations like ArborGen have postulated 
that pulp from plantations of GM trees could bring in considerably 
higher profits than pulp from conventional monocultures, indicating 
that corporations intend to rapidly implement large scale industrial 
GM tree plantations.

- Contamination of non-GM trees of the same species or genus. This 
contamination is particularly dangerous in the case of the most 
widespread plantation tree-eucalyptus -whose many species have the 
capacity to hybridise and could therefore be easily pollinated by GM 
eucalyptus. It is also dangerous in other plantation species such as 
pines, poplars and acacias. In China, the only country where GM trees 
are planted on a commercial scale, contamination of native poplar 
trees has already been documented.

- Contamination of related tree species. Tree pollen can travel very 
long distances and could contaminate non-GM trees both of the same 
species as well as other related species in entire regions and 
countries. This would mean that native trees might acquire the 
genetically modified traits of GM trees. For instance, they might 
become resistant to insects, i.e. produce toxins, thus resulting in 
the depletion of certain insect populations and dependent plant and 
animal species. The "solution" of developing flowerless trees creates 
false confidence in the supposed safety of the technology and runs 
the risk of passing on any of the modified genes to trees in the wild 
- if sterility were to fail in just one single tree in one year.

- Trees with less lignin (and higher cellulose content) would be more 
prone to pest attacks, and potentially increased windfalls, and would 
rot more quickly, altering soil structure and releasing CO2 more 
quickly, thus contributing to climate change. Decomposing forest dead 
wood provides an essential habitat for a high diversity of flora and 
fauna. Disturbing the rate of wood decomposition would have a 
dramatic effect on species populations, the consequences of which 
have not been studied. These trees would also show altered 
characteristics during storm, flooding and possibly drought.

- Contamination of forest ecosystems and other habitats with GM trees 
via seed. Trees produce abundant fruit and seed, often capable of 
travelling long distances either carried by air, water, animals and 
human activities. Trees genetically engineered for faster growth, 
salt tolerance, short daylight adaptation or cold tolerance could 
out-compete common pioneer species or populate rare or marginal 
habitats previously uninhabitable to trees.

- Impacts on the livelihoods of indigenous and local communities. The 
environmental release and commercial use of GM trees in industrial GM 
tree plantations would provide no goods to local communities, and 
would impact on their traditional use of forest resources, including 
fruit, seed, insects, animals, honey, and fibres. In the long run, 
contamination of native tree species could wipe out most of the 
resources they depend on.

- Many studies have been done on the potential human health impacts 
of GM crops and the risks involved are manifold. Few risk assessment 
studies apply specifically to trees and though they are likely to 
share similar risks to plant crops, trees are also know to have other 
specific areas of concern when genetically modified. The longevity of 
trees makes the necessary multi-generational risks assessment studies 
impossible to carry out in the short-term. Yet it is known that 
aberrations of intended gene expression may only become apparent when 
studied over several generations. Unexpected gene expression is known 
to have occurred in elm trees, for example.

- Increased contamination of soils, water and air from toxic 
herbicides used in conjunction with herbicide-resistant trees, or 
inhalation of pollen from insect-resistant trees could have serious 
impacts on the health of indigenous and local communities.

- There are significant likely impacts on women and indigenous 
peoples, the traditional caretakers of biodiversity. In many 
communities, women are the ones who think in terms of generations. It 
is women in rural and indigenous communities who will bear the 
greatest burden of the impacts of GM tree plantations, just as they 
currently bear the brunt of the impacts from conventional monoculture 
tree plantations. Women and children will likely bear the brunt of 
any human health consequences of GE trees, for example resulting from 
inhalation of large quantities of Bt toxin from the pollen of 
insect-resistant Bt trees.

In conclusion, GM trees have no role to play in the conservation of 
global forest biological diversity and, on the contrary, are likely 
to reduce forest biodiversity, with attendant social consequences. 
The high risks indicated by the available though incomplete science 
show that the technology could result in the extinction of forest 
plant and animal species with severe negative impacts on biodiversity.

We therefore urge the Convention on Biological Diversity to move 
forward from the current recommendation to Parties to take a 
precautionary approach, to a mandatory decision declaring an 
immediate ban on the release of GM trees.

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