[PCA] Public comment: Petition to USDA to allow commercial growing of genetically engineered plums

[Patricia_DeAngelis at fws.gov]

Forwarding this message from another member.  For the full notice, follow 
the directions under: "to submit your comments online."

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  GENETICALLY ENGINEERED  (GE)  plums.

To submit your comments online:

Go to http://www.regulations.gov .
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.

To submit your comments by mail:

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. 

Thanks for helping us STOP the genetic engineering of trees!

Feel free to copy and paste any or all of the 7 points below, along with 
any 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  open  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.

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