Dear participants to the Open-ended Online Forum and AHTEG,

I am pleased to invite you to take part in the discussion on the first draft of the guidance on "Risk Assessment of Living Modified Trees" (available at https://bch.cbd.int/onlineconferences/discussiongroups_ra.shtml).

This discussion will be take place from 5 to 17 September 2011 (1:00am GMT) at the link above.

Your comments in this discussion may focus, for instance on:

- Whether all issues relevant to this topic have been included in this draft and, if not, which ones should be added;

- Suggestions for improvements to the current text and/or structure; and

- Suggestions for background documents to be included (please provide the full reference and indicate to which section(s) of the guidance the background material is relevant).

Please do not hesitate to contact me (manoela.miranda@cbd.int) if you have any question or encounter problems when posting comments.

Best regards,
Manoela

Dear Beatrix
Many thanks for a wondeful Job
I have only one comment. ideas in article 16.4 of the protocol are not well reflected in the document although they are quite important noting the long life span of some trees.

"Each Party shall endeavour to ensure that any living modified organism, whether imported or locally developed, has undergone an appropriate period of observation that is commensurate with its life-cycle or generation time before it is put to its intended use."

warm regards,
O.A.El-Kawy

Dear colleagues,

Thanks to all who have participated to the elaboration of the first draft of this guidance.
I would like to share some comments of Didier Breyer in the sense that much of the background information (as outlined through lines 7 to 111) could be reduced to explanations on the reasoning of developing a specific guidance for the risk assessment of living modified trees while focusing on the specificities that makes trees particular in terms of risk assessment.

Nevertheless, considering the information provided in the background section, I wondered whether there is any particular reason why (domesticated) trees for ornamental purposes have not been mentioned?

I also support the view that the document could gain clarity by explaining how the points related to steps 2 and 3 of the RA process are crucial in determining the biological significance of any specific characteristics identified in step 1. For example, line 130 mentioned the capacity of trees to reproduce its genetic material under certain conditions by its ability to make sprout. This particularity is mentioned again in line 251 “ the potential for vegetative propagation is an overall characteristic ….to establish new plant individuals. It is unfortunate that this notion is mentioned readily after an example of transgenic trees assessed as having the potential to become invasive (line 249). I think it could be made more clear that the potential of vegetative propagation is not a concern per se, neither is persistence (e.g. life span) a concern on itself (line 256). However, these are indeed points that warrant an evaluation of the likelihood (if the adverse effect is being realized) and an evaluation of the consequences should these adverse effect be realized (step é and 3 of the RA process).


Finally, I would like to add some specific comments/suggestions:

Line 175: What is meant with “transformation related tissue culture” , are these tissue culture obtained by transformation protocols other than A.tumefaciens mediated transformation or ballistic methods?

Line 226 :
I would propose: “….via seeds, pollen and vegetative propagules”

Kindest regards,
Katia Pauwels, PhD
Scientific Institute of Public Health, Belgium

Heello to all:

Sorry to come at the end.

The terminology and language such as use of "GMO" instead of LMOs does not have concomitance with the Cartagena Protocol language, while some members of the draft group insists the association with the language use jumping directly to the decision documents on forest biotech at CBD.
This effort is not logical in terms of procedure as we cannot jump to CBD directly as the SWGs and AHTEG are directly under the Cartagena Protocol MOP and everything should go at first following the language of the Protocol, and the contradicting language between Cartagena protocol and CBD on forest biotechnology issue should be at first proposed at MOP of the Cartagena without any change or provide relevant explanation why altering the Cartagena language. It is CBD oversight which did
not intake the language of Cartagena protocol. If CBD on forest Biotechnology continue then the Cartagena Protocol Language does not have meaning.  AHTEG should not by-pass Cartagena but at first use the terminology and language of the protocol as the present draft intorductory statements do not reflect Protocol.


Kind regards,


Kazuo Watanabe

POSTED ON BEHALF OF STEVE STRAUSS

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I am writing as an observer to comment on the document “RISK ASSESSMENT OF LIVING MODIFIED TREES” that was open for comment under the discussion group "Risk Assessment of LM Trees", 5-17 September 2011.

I am a Distinguished Professor of Forest Biotechnology in the College of Forestry at Oregon State University in the USA.  I have taught and conducted research in forest genetics and transgenic biotechnology for 30 years thus believe I understand both genetic, ecological, and surrounding social issues of GM trees in considerable depth.  You can view my background, publications and CV at this web site: http://www.cof.orst.edu/coops/tbgrc/Staff/strauss/index.htm 

GENERAL EVALUATION
I was most unhappy with the tenor and content of the document, and believe an entire rewrite is warranted.  It had many value judgments that posing as scientific statements of fact, and lacked sufficient context to guide the formulation and design of relevant risk assessments.
 
SPECIFIC COMMENTS

1. The document considered intensively grown tree plantations as equivalent to natural forests, when societies throughout the world have chosen to allow, and often to encourage, plantations because of their very high social and economic value for wood production compared to management and harvest of wild forests.  This is similar to the decision to create agricultural fields rather than to conduct a hunter-gatherer-foraging kind of food production.  These forests are intentionally highly simplified in ecological structure and diversity because of the large social benefits, and sparing on impacts on wild forests, that they bring.  The impacts from GM trees in plantation systems should only be compared to the already very large impacts implicit to plantation forests, such as from short planting and harvest cycles with evenly spaced plantations of single species or genotypes, usually under intensive weed control and fertilization.  Thus, consideration of “landscape architecture” and “ecosystem function services” (e.g. illness 222-223) needs to be considered within a social framework that has already chosen to simplify and allocate these amenities these in a highly differential manner. 

2. The document stated in more than one place that forest trees are “unique” (e.g., line 88 and nearby) or are “ecosystems in themselves” (e.g., line 100) or have “extensive interactions with other organisms” (e.g., line 145 and nearby) or are crucial to “food webs” (e.g., line 258).  In fact many of their traits including perennial habit, vegetative persistence, and support of complex ecological communities are shared by many other plant species that are not trees nor part of forests.  The long-lived grasses that dominate native prairies are good examples.  Thus, these exaggerations and value judgments do not belong in a scientific document.
 
3. Wood was considered as a potential vegetative propagule with respect to possible transboundary movement, and thus movement of wood should be carefully considered (line 131 and nearby).  The large majority of wood is dead and unable to serve as propagules; only rarely, when dormant and well-preserved branch or root sections are shipped, are they effective propagues, and even then usually need to be planted and cared for by humans.  Likewise, normal vegetative propagule movement, such as through branches, is rarely found outside of the Salicaeae among industrially grown plantation trees.  Moreover, even there it is the major source of spread only special environments, such as in high elevation and wild Populus tremula/tremuloides (where no GM trees are intended). Thus, the sections are misleading.

4. The document often said that forest trees were little domesticated (e.g., see line 106 and 205 and nearby).  In fact, some of the most widely grown and intensively bred trees are highly domesticated, which can be accomplished in a single generation in case the case of interspecific hybrids in Populus and Eucalyptus.  These trees are usually highly infertile because of their hybrid genotypes and often produce highly variable and maladapted progeny, thus are substantially domesticated with respect to their ability to invade natural habitats.  These are the same types of genotypes most likely to use GM varieties in plantation forestry in the future. 

5. The conventional wisdom of tree breeding that local rather than exotic provenances are best (lines 147-153) are now being seriously questioned worldwide as global climate change substantially alters growing seasons, frost periods, high temperatures, and drought cycles.  Exotic kinds of trees, including some kinds of GM trees with enhanced abiotic or biotic stress tolerance properties, may be desirable and important for sustaining forest productivity and even survival in many environments. 

6. The document focuses on risks of changes to status quo, however, the rapidly rising world demand for solid wood, pulp, and bioenergy products—together with increased climate and forest pest injury—is putting serious and growing stresses on all kinds of forests.  The document lacks any perspectives on the risks to forests of doing nothing with advanced GM methods given these serious social and ecological stresses.  The long term and ecologically thorough risk assessments demanded throughout the document will make the use of GM increasingly impractical, taking a major tool for plantation forest improvement away from tree breeders (in fact, this has already begun under the CBD:  Strauss, S.H., H. Tan, W. Boerjan, and R. Sedjo. (2009) Strangled at birth? Forest biotech and the Convention on Biological Diversity. Nature Biotechnology 27:519-527).  .  Tree breeders themselves rarely wait for more than a fraction of a rotation to begin to make selection decisions, thus there is no reason for the more specifically modified GM trees to do otherwise.
 
7. The document suggests that instability of transgenic traits in trees is a serious issue (line 88 and nearby).  However, it is has been known for several years that stable expression of transgenes and associated traits is what is predominantly observed in the field with transgenic forest trees; instability is rare and easily managed (Brunner, A., J. Li, S. DiFazio, O. Shevchenko, R. Mohamed, B. Montgomery, A. Elias, K. Van Wormer, S.P. DiFazio, & S.H. Strauss. (2007) Genetic containment of forest plantations. Tree Genetics & Genomes 3:75-100).  Thus, the document is once again quite misleading.

I hope that these comments are useful.  As you can see, the flaws in perspective and fact are inherent to the very structure of the document—with its powerful anti-GM and anti-plantation bias.  I strongly urge that it be discarded and a new, more neutral document be drafted.

Thanks for considering these comments
Steve Strauss, Distinguished Professor

I am not an expert in forestry or trees, but I also have serious concerns about this document in terms of consistency and comlementarity with the Roadmap, and how the document it might be used.  I agree with Steve Strauss's overall evaluation, and many of his specific comments.  I also note that the language is convoluedt and highly unsuitable as a guidance document.  In some places it simply does not make sense (e.g.lines 64-67, 130-131, 142-144)
The Backgound section could be cut to about two paragraphs or less, as it is not relevant to (what I assume to be) the purpose of the document, ie to supplement the Roadmap by providing guidance on specific aspects relevant to risk assesssment for LM trees.

The language is more prescriptive than is appropriate for guidance - considerable use of 'should' and 'have to be' and 'is needed' where 'might' and 'could be considered' would be adequate. In addition the language is somewhat negative, and indicates a 'worst case' perspective.  For example, there is the impression that all trees share the same characteristics (such as ability to propagate from branches) 

The Introduction section could also be significantly reduced.  The material on the uniqueness of trees is confusing and mixed up with scope.  Perhaps this section could be re-ordered so that it included a definition, and a short descriptions of what the guidance is intended to cover (ie is is just forest trees?).  The section from 74-87 would best be included in an Appendix.   And what is the point of lines 88-106 in the context of the guidance?  The specific matters referred to mught be better addressed in sections further down.

The guidance is in fact 'slight' and reads as an academic document rather than a practical guide.  The essence of the document spans about 190 lines and I wonder whether there is really any sufficient point of difference that makes the guidance necessary? On the other hand, if it were possible to provide some genuine guidance by expanding the 'points to consider' and explaining why and how these matters should be considered then it might be of some use.

In my view the document in its current form has little value, and it might be preferable for the AHTEG to go back to consider what the additional guidance (generally) is intended to achieve, what it is about 'trees' that requires specific guidance, and then to dcide whether a separate document is warranted.

We need to remember that what we are trying to achieve is guidance to help people implement Annex III of the Protocol and that if any of this guidance strays beyond the scope of the Protocol then it has little value.    

At the least the process of developing guidance should be suspended until the Roadmap has been completed to avoid the risk of inconsistency between documents.
regards
janet gough

Dear Beatrix

Thank you  for these document.

The introduction background and the introduction are very necessary; as it is important make a contextualization of transgenic trees since most of experiences is with short-cycle GE crops.

A very important aspect is that it should be a clear distinction between "forests" and "tree plantations", as there are terms equivalent. A forest is a natural ecosystem in which it would be unacceptable the introduction of GM trees.

A very important aspect is that it should be a clear distinction between "forests" and "tree plantations", as there are terms equivalent. A forest is a natural ecosystem in which it would be unacceptable the introduction of GM trees.

In the introduction I would point out that a forest is not just an ecosystem where trees interact with other biological communities, but forest ecosystems interact with other ecosystems. In tropical rainforests, there is a strong interaction between ecological dynamics of the forest, wetlands and rivers. Any stress factor in these ecosystems, will take effect on the surrounding ecosystems, and are aspects to be considered when it comes to GM trees.

Another aspect to consider is the edge effect, which can be one of the effects of the presence of GM tree plantations. The edge effect affects the composition of plant communities. Near the edge of the typical species of a climax community, are displaced by pioneer species. The edge effect also affects the eco-physiology of plants, such as its tolerance to variations in temperature and humidity as well as water potential. Since the edge effect also produces changes in the microclimate, which is strongly determined by plant communities present, this phenomenon also affects microbial communities. Microclimatic effects due to the edge were recorded up to 30 meters into the forest, from the deforested area. The edge effect also affects the phyllosphere microorganisms which are more exposed to temperature changes, to fluctuations in moisture and water power at the edge, which in the shade.

It is also necessary to remember the many endemic and endangered species in forest ecosystems, and that some types of forest themselves, are in danger of disappearing (eg tropical dry forests).

The technology package must also have to be taken into account. For example, if the GM will promote the use of more fertilizers and pesticides and whether to increase water requirements. Remember that the most widespread forest crop in the world is eucalyptus. This tree is highly demanding of water. It would be important to know for example if the genetic modification introduced into a transgenic eucalyptus will further increase its water requirements. Additionally, the eucalyptus is a very invasive. Will genetic modification and technological package associated with invasiveness?

In relation with the potential receiving environment, it is important to consider the presence of endemic species, wild relatives of endangered species, and how the transgenic tree will affect the entire food chain (due to the cascade effect).

Since the receiving environment is not empty of human societies, it should be considered that many forest ecosystems are very important in sustaining indigenous and traditional communities around the world, it is important to consider how the technological model that is based on transgenic tree to be released into the environment, change the pattern of land use, if this is a model that generates land grabbing. Also, how a plantation of transgenic trees will exacerbate the impacts of current industrial tree monocultures.

Exposure

It should consider not just the exposure to new genetic constructs, but also the technological package. For example, one of the topics that is been working on GM trees is herbicide resistance. Exposure to the herbicide should also be considered. Similarly, consider the s exposure of human communities living in the influence area of transgenic plantation, given their various vulnerabilities, their culture (in most of the cases very traditional and attach to the dynamics of the forest).

In response to Elizabeth Bravo’s comment that GM trees would be unacceptable in natural ecosystems, I believe that Elizabeth and possibly many others may not be aware of a coordinated research program to evaluate the potential application of biotechnology to mitigate threats to forest ecosystems.  The Forest Health Initiative in the US is examining GM technology as a tool in helping restore the American chestnut.  Given the expected increases in threats to forests from climate change and associated increased pests and diseases, including the devastation that introduced exotic pests can have, it is important that we evaluate all possible tools to help protect forest ecosystems.

The following quote from the Forest Health Initiative web site says it better than I can:
(From: http://foresthealthinitiative.org/resources.html )
“With continued globalization and a changing climate, threats to forests will increase in coming years potentially leading to catastrophic change to forest ecosystems. While traditional tree breeding and propagation approaches will continue to have a prominent place in forest management and restoration, the severity and types of threats facing the nation’s forested areas require the U.S. to respond more quickly to protect the future of our nation’s forests. Biotechnology can play a vital role in the ability to tackle today’s environmental problems. However, advances in biotechnology are needed to effectively address these challenges if forest health is to be maintained and enhanced. Further, it is important to determine the limitations of biotechnology for individual species restoration and for the protection from catastrophic loss. Acquiring this knowledge will enable partners to better respond to short- and long-term conservation needs and demands. We recognize that science is only part of the answer. Biotechnology can play a critical role in addressing forest health threats when strong societal support and robust regulatory processes undergird the use of these scientific tools. “

As the technology evolves beyond the so-called “input traits” that have been the mainstay of GM crop applications to date (herbicide tolerance, insect/virus resistance), we should consider that there may be applications that could provide positive contributions to maintaining or even restoring biological diversity.  With an estimated 58 million acres of US forests alone threatened by insects and diseases (see: http://www.fs.fed.us/foresthealth/technology/images/RiskMap_agents_hillshade_md.jpg ) the Forest Health Initiative is an important first step in understanding if this technology has a role to play in managing these threats.

Thanks,
Les

POSTED ON BEHALF OF LES PEARSON

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As a developer of LM trees, I appreciate the opportunity to provide feedback on the draft guidance.  I have extensive experience in working with risk assessors here in the United States (with nearly 300 field trials of LM trees approved). I am also familiar with the Brazil Biosafety system and have followed closely processes adopted by other Parties (for example New Zealand approvals for LM tree field trials). 

I have attached a ‘track changes’ version of the draft guidance that includes many edits and suggestions, based upon my experience.  These range from editorial changes to more substantive modifications.  Recognizing that this is a first draft, my aim is to provide a thorough and comprehensive review in an attempt to make it of practical use to Parties that may not yet have experience with LM trees.  I echo comments from Steve Strauss and Janet Gough that the document needs an extensive re-write and hope that my detailed comments will be helpful in such an endeavor.  Clearly, there is much work still to do and I anticipate there will be other versions as we further refine this document to get to a final working form.

I highlight a few key concepts here, but offer many more suggestions in the attached document.

An important consideration is to determine key characteristics set trees apart from all other plant species?  Many of the characteristics listed in the document are not specific to trees.  (Please see further comments in the attached document).  In contrast, the sheer physical size of even a young individual tree is not addressed. Ironically, this characteristic makes data from greenhouse experimentation more difficult, and thus less meaningful for trees compared to other plants.  Similarly, but not necessarily specific to trees, the late onset of sexual maturity tends to favor the development of the primary transgenic line rather than crosses from the primary event as would be typical for most annual crops.  In this same vein, vegetative propagation and the use of varieties (consider ‘Golden Delicious’ apples, but also ‘Cabernet Sauvignon’ grapes and ‘King Edward’ potatoes for that matter) would lead developers to avoid any kind of crossing as this would recombine the specific combination of characteristics that are desired in these varieties.  

I do not believe that any of these make a risk assessment more challenging than they would be for other crop.  These characteristics are simply aspects that the assessor should be aware of in the case that they may be more familiar with annual row crops than with trees.

Section on Comparative Approach – suggesting that trees do not fit this approach.  This is one of the basic principles of Annex III and is not limited to only “annual crops with high degree of domestication.” In considering a risk assessment for an LM tree, the assessor must begin from the context of introducing the non-modified tree – with its particular reproductive characteristics, degree of domestication, etc. – and consider how the LM tree may differ from this base line scenario.

One final thought: given the “vast diversity” of trees (Introduction) and the overlap of many of the listed characteristics with other types of plants. Would it be in fact more important for the AHTEG, and more valuable to risk assessors, to instead consider guidance for perennial plants rather than just “trees”?  It seems that concentrating on this characterisitc would offer important insights for risk assessors who may have only dealt with annual crops previously.

Dear colleagues,
I would like to lend my support to the recommendation made by others in this discussion to rewrite this document.  As pointed out by others already, the characteristics of trees that are presented as reasons for special consideration are not unique to LM trees.  Therefore, the guidance should go back to the beginning to devote more thought to those characteristics that are unique to trees that would require further elaboration in light of Annex III.  I have provided a few examples to illustrate this point.
Lines 179-181: Points to consider
Point (a) I assume has to do with somaclonal variation, which is a phenomenon for any tissue culture propagated plant, not just LM trees.  And in any case, these variants are already selected out during the product development process for the LMO.
Point (b) is already taken into account in 9 (c, d and e) of Annex III
Point (c) is irrelevant, as pointed out by Dr. Strauss.  Incidentally, this point to consider seems to be included because of the mistaken assumption that tree breeding is conducted in the same way as annual crops, contrary to the stated intention of the guidance.
Lines 193-201: Points to consider
None of these points address anything unique to trees, and as pointed out by Dr. Strauss, might not even be a consideration, as in point (a).
Furthermore, as comments by Dr. Strauss and Les Pearson show, there are factual inaccuracies relating to trees that require correction.  It is important to the credibility of any guidance that it be at least factually correct.
If we are to focus on the real point of this guidance, which is to help risk assessors with little experience, then the best help we can provide is to avoid drawing them to get lost in the trails here but redirect them back to the roadmap and ultimately back to Annex III.  Therefore, I agree with Janet Gough that until the roadmap is firmly established and that point of reference exists, it would be best to suspend this activity and start afresh when we have a firmer basis.

Dear Colleagues,

I appreciate the efforts of contributors in drafting this document and thank for the opportunity to give my following suggestions.

The background needs to be reduced to just the decision of the COP that has led to the development of this guidance. I feel that several of the background statements (“socio-economic issues”, “livelihoods of indigenous and local communities”, “absence of capacity in some countries”) are not uniquely linked to trees.

The exclusion of palms from the scope of guidance is not justified. True, they are not trees in the strict botanical sense. But in terms of their structure, size, longevity, dispersal and, hence, the risk concerns they are like typical trees.

The document practically ignores horticultural and plantation crops in terms of their specific and distinct features from forest trees, which would call for judicious application of the present guidance. Papaya is grown for just around two years when it is uprooted due to declining yield. Tree species used as rootstock are not allowed to sprout in field. Soil related issues of intensively managed short and medium term plantations seem to be no different from those of annual cereals or cotton grown successively over several years. Hence, the special concerns regarding forest tree LMOs and the points to consider in conducting the risk assessment as detailed in the document may not be relevant in several cases beyond what is already given in Road Map. In this regard, I would extend the suggestion of Les Pearson to consider guidelines for perennial trees, excluding those that are not treated as long-term perennials under cultivation.

Best regards,
Jawahir Karihaloo

Thanks Jawahir for your comments.  I agree with your point that for some short-lived perennials the considerations would be very similar to annual crops grown successively over several years. 

To clarify my suggestion, this was to consider if guidance was more appropriate for perennials in general, which would include trees (including palms), shrubs, grasses, grapevines, etc.

Regards,
Les

Dear participants,

I appreciate the opportunity to comment on this draft of the document “Risk assessment of living modified trees” Please consider the following.

Similar to a point I made in the parallel discussion on the document “Post-release monitoring and long-term effects of LMOs released into the environment,” I think care should be taken not to draw general conclusions about the strength of risk assessments. On lines 154-156, it indicates that all environmental risk assessments are of limited predictive power. While I agree that the long lifespan of trees is an important point that should be considered during the risk assessment, I think constructive advice on how this should be considered would be more useful than simply identifying this pre-emptively as a potential flaw in the risk assessment.

I also disagree with the statement on lines 142-144 that suggests that the comparative approach used for crops would not apply to trees. I think that in the majority of cases such a comparative approach would still be the most appropriate. It would be more useful if the document gave concrete examples of when the comparative approach may not be appropriate and provided suggestions as to alternative approaches that could then be applied.

Best regards,
Jaimie Schnell

Dear Colleagues,

I appreciate the efforts of contributors in drafting this document and thank you for the opportunity to give the following suggestions.

The scope of the guidance on risk assessment of living modified trees in this document appears broader than what is supposed to be done under the CBP for trans-boundary movement of trees.  In addition, the scope of the risk assessment should not include socio-economic considerations or mention human health impacts related to exposure to tree pollen.

I have a few suggestions to text revisions which I have attached to this comment.  I look forward to reviewing and providing comments on the next version of this document.

Dear All,

I have serious and similar concerns about the PMEM document and the GM Tree document, so I therefore post this message in both on line discussions.

My concerns are very much along the lines of the concerns expressed by Louise Ball, Janet Gough, Adriana Otero-Arnai, Hector Quemada, Lucia de Souza, Hans Bergmans, Steven Strauss, Les Pearson, Karen Hokanson, Kazuo Watanabe, Jaimie Schnell and David Heron, and I will therefore not burden this posting by repeating those concerns.

In summary, I believe that both these documents (still) suffer from the same shortcomings as I posted on the first draft of the PMEM document, namely that these documents offer little practical guidance to people with limited experience, because they:
1) are difficult to understand due to inconsistencies and repetitive or incomprehensible language,
2) do not reflect the state of the art of knowledge and experience.

In addition, these documents - and in particular the PMEM document - convey a flavour that we have to start from scratch and that there must be adverse effects resulting from the introduction of GMOs.

In short, I fully support those who have suggested that these documents need a fundamental revision, and I propose that such revision should involve people with substantial experience in the respective fields.

This brings us to a key problem of the whole process, and that is that by adding new guidance documents to the list of documents to be developed, while at the same time we haven’t finalized the road map and other earlier guidance documents, we are spreading our resources very thin, and we run the risk of inconsistencies between the roadmap and the specific guidance documents.

I therefore, in support of the suggestion by Janet Gough, repeat my proposal that for now we suspend further work on the documents on PMEM and GM Trees and first properly finalise the road map and other guidance documents.

Regards

Piet

Dear All,

Recognizing the hard work that went into producing this draft and acknowledging that effort, I wish to add my name to the long list of commentors who have expressed support for the need to begin work on this guidance anew.  I think that we now have excellent input from qualified experts on LM trees like Steve Strauss, Les Pearson, Jawahir Karihaloo, and a great number of experts in risk assessment to begin the process of redrafting this guidance.  I further suggest that the working group on LM trees officially request support from Steve, Les, Jawahir as well as risk assessors like Janet Gough and Louise Ball in this new effort.

I also feel strongly that we must not attempt to extend the scope of any guidance undertake within the AHTEG to other programs of work with the CBD as has been suggested in the current draft of guidance on LM trees.

Regards to all,
Tom Nickson

Dear All,

I would like to support the concerns expressed in previous postings by  Piet van der Meer, Louise Ball, Janet Gough, Adriana Otero-Arnai, Hector Quemada, Lucia de Souza, Hans Bergmans, Steven Strauss, Les Pearson, Karen Hokanson, Kazuo Watanabe, Jaimie Schnell and David Heron and all participants that suggested that a thorough revision is needed in the two documents (Guidance on Risk Assessment  of Trees and Guidance on Post-release Monitoring and Long-term Effects of LMOs Released into the Environment).  I also propose that such revision should involve people with substantial experience in the respective fields.
I would like to add a couple of comments specific to the Guidance on Risk Assessment  of Trees related  to the posting of Elizabeth Bravo from Equador. She mentions that Eucalyptus are “…highly demanding of water. It would be important to know for example if the genetic modification introduced into a transgenic eucalyptus will further increase its water requirements. Additionally, the eucalyptus is a very invasive. Will genetic modification and technological package associated with invasiveness?...”.
I would like to quote Les Pearson when he says that “…In considering a risk assessment for an LM tree, the assessor must begin from the context of introducing the non-modified tree – with its particular reproductive characteristics, degree of domestication, etc. – and consider how the LM tree may differ from this base line scenario…”
In this context the points raised by Elizabeth Bravo are common misunderstandings (not to say myths) about Eucalyptus (the non-modified tree) that need to be clarified,  before one starts to discuss the risk assessment of the modified tree.  We have been growing Eucalyptus In Brazil for many decades and have now more than 4,7 million hectares of planted Eucalyptus (source: ABRAF 2011).  There have been  extensive experiments conducted  on water use of Eucalyptus in Brazil, concluding that it indeed uses an expressive amount of water (1,092 mm/year), close to the annual rainfall (1,147 mm/year), but not  more than the native forest (1,167 mm/year). The same study showed that other crops such as coffee, sugarcane, and citrus have similar water consumption to that of the eucalyptus trees (http://www.aracruz.com.br/eucalipto/en/agua02.html). This information is used to plan and manage sustainable Eucalyptus plantings in the country.  The Brazilian experience also do not show that Eucalyptus behaves as an invasive species in Brazil.  This has been demonstrated recently in a report (da Silva et al, 2011, Forest Ecology and Management, 261:11:, Pages 2075-2080) where the authors found that, and I quote: “…The result shows the inability of eucalypts to adapt to condition outside of their natural range” (abstract at http://www.sciencedirect.com/science/article/pii/S0378112711001435).

POSTED ON BEHALF OF ANTJE LORCH

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Dear Beatrix, dear members of the AHTEG,

thank you very much for your guidance document on LM trees.

I appreciate the long introduction as well as the detailed explanation
why and how trees are different from (annual) crops, and how that
affects the requirements for the risk assessments.
Of course people working directly in this field will be aware of these
differences, but assuming that these documents are also of use to others
there is no harm in re-iterating these difference, just to ensure that
they are not accidentally overlooked.

It is also important to stress the potential impacts of GM trees on
sustainably managed forests as well as natural forests - not only on
tree plantations since the scope of the CBD and with it the scope of the
Cartagena Protocol are the effects on biodiversity as a whole and not
just effects within specific production systems.

Some more specific points:

- Line 107: The differences of fruit trees and forest trees should also
explicitely include grafted trees. There is already ongoing research on
GM trees boths as root stock as well as scion. The effects of transgenic
DNA and changed phenotypes on the other part of the tree merits a risk
assessment as well.

Line 115: Why are palms, bamboe etc excluded? Is the AHTEG covering them
in another document?

Line 118: Why are these transgenic trees developed for restoration of
forests excluded? If I remember correctly the development of Bt poplar
in China is also done with the stated reason to restore forests. Would
they be excluded, or this covered in another AHTEG document?

Line 131: "Thus all GM wood parts still capable of vegetative
reproduction should be seen as a living organisms."
I think the formulation of this sentence states quite well that dead
wood material would not be subject to the same assessment as material
that still can propagate, so this should answer Steve Strauss' concerns.
But just to be sure: Does "wood" in this context include root material
as well?

Line 208: Points to consider as receiving environment: In grafted trees
the root stock and the scion respectively are also receiving environments.

Line 213: There is no point (c) here? Is there something missing?

Line 234: Points to consider for dispersal and distribution patterns:
Timing of pollen production vs. receptivity of female flowers also needs
to include those of other varieties or species the tree in question is
known to hybridize with.

Line 257 : Points to consider for exposure in interaction/food webs:
Parasitic plants (both stem and root parasites) e.g. mistletoe and other
plants that only live on trees.

Line 274: Points to consider with respect to management: Where the
intended effect of GM trees result in changed management strategies
these also need to be considered. This especially includes the increased
use of herbicides in herbicide tolerant trees, or increase water use of
fast growing trees.

Once again, thank you for your extensive document.

Antje Lorch

EcoNexus, Project Manager GM Trees