From: Global Justice Ecology Project <[log in to unmask]>

Please forward widely


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

(If you have not already done so, 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 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!

STOP Genetically Engineered Trees Campaign

A project of Global Justice Ecology Project
P.O. Box  412
  Hinesburg, VT  05461  U.S.
  +1.802.482.2689 ph/fax
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Biotechnology Project
  c/o Institute for Social Ecology
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