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

The online discussion for editorial improvements of the draft guidance on "Risk Assessment of LM Trees" is now open at http://bch.cbd.int/onlineconferences/discussiongroups_ra.shtml. This discussion follows an extensive revision of this draft guidance during the face-to-face meeting of the AHTEG Sub-working Groups held in Bonn, Germany, 13-15 February 2012.

Participants of the Open-ended Group and the AHTEG are invited to suggest ways to improve the readability and user friendliness of this document. Please make your suggestions for improvements directly to the text of the draft guidance (version of 22 Feb 2012; available in the attachment and through link above) in the "track changes" mode.

As per the revised tentative calendar of activities (see http://bch.cbd.int/onlineconferences/calendar_ra.shtml), please note that this is the last round of online discussion prior to the regional real-time online conferences and fourth meeting of the AHTEG.

//This discussion will be open from 27 February till 11 March 2012 (1:00 a.m. GMT). //

Your feedback on this document during this final round of online discussion is very important. 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 Manoela,

Thank you for this latest draft of the LM tree guidance.  I am attaching a track changes version with suggestions for improved readability and user friendliness as you requested.  This version is considerably rearranged and edited compared to the last version, which makes tracking of the edits very challenging.   I note recent comments from Isao Tojo and Paulo Andrade suggesting that there are still some unresolved issues and questions in the Monitoring document and I feel that parts of the LM tree document similarly still need additional consideration. 

In particular, I am quite concerned about some of the new text that has been added since the January 16 version.

Notably, Footnote 11 states that some Parties have expressed the view that fruit trees should not be included in this document.  However, my understanding is that the Parties have not yet provided input to this document, but would do so at the COP-MOP.  While the AHTEG includes experts nominated by Parties, do these experts speak with the authority of the Parties or do they represent their own views and perspectives?  If the latter of these is the case it would be more accurate to say, “Some members of the AHTEG and on-line forum of experts are of the view …”

Footnote 17 expands on the concept of invasive species.  I am very concerned here by the modifying or redefining of well established and accepted terminology.  Under the proposed new definition of ‘invasive species’, any introduction of a species (for example even a small-scale field trial), could be interpreted as being “invasive”.  Extending this line of reasoning could result in characterizing any/all LMOs as invasive species, which cannot be supported scientifically.  Any consideration of whether an LMO could become an invasive species is not limited to trees and so should be addressed under the Roadmap.  The potential for an LMO to persist, relative to the comparator, would be an element in this and is fundamental in any risk assessment, and is already well addressed in the Roadmap.

On one final note, checking through the Literature citations about half of these are no longer cited in the text, presumably as a result of the many rearrangements and modifications that have been made over the various drafts.  This is unfortunate from a user friendliness perspective as I believe that some of these provided useful background information to risk assessors who may be unfamiliar with trees.

As always, I very much appreciate the opportunity to review and provide input on these documents.

Best regards to all,
Les

Dear all,

Although the tree document is improved from previous versions, there are a number of areas for improvement, and the attached file includes suggested track changes and comments to explain the reason for the proposed changes. Wherever possible, I have tried to acknowledge the areas that were in apparent agreement in the Bonn discussions but not revised in the text in a manner that reflected the consensus of the discussions.

- David Heron

Dear David,

Many thanks for your message. I talked again to my friend in the Forestry Academy and prefer to keep the original statement from a published book chapter (Ewald,D. Hu,J. Yang,M. (2006) Transgenic forest trees in China. In; Fladung,M. Ewald,D. (Eds) Tree transgenesis: recent developments, Springer Berlin. pp 25-45). The paragraph in the end of the New Scientist report"Wang did not respond to New Scientist's requests for further comment. But Dietrich Ewald of the Institute for Forest Genetics and Forest Tree Breeding in Waldsieversdorf, Germany says information on Chinese field trials with GM trees would be published soon in international journals". Obviously the magazine might not be confident with what Wang had talked about.

The transgenic poplar is approved for commercialization in China, but not in such a large scale as people say.

Thanks you and best wishes

Wei