USDA/APHIS aims to support widely dispersed field trials with reckless disregard for safety and in flagrant violation of the precautionary principle, said Prof. Joe from London-based The Institute of Science in Society (ISIS). This report has been submitted to the USDA/APHIS on behalf of ISIS

According to ISIS, the US forest biotechnology company ArborGen has had considerable success in getting permission from USDA/APHIS (United States Department of Agriculture/Animal and Plant Health Inspection Service) to undertake open field trials of the companies genetically modified (GM) eucalyptus. The first field test of modified eucalyptus was undertaken in Alabama and reached a Finding of No Significant Impact (FONSI).
 
However, ISIS objected to the application for an earlier field test. Further field tests were carried out in Florida. Now, ArborGen proposes a gigantic follow-up by submitting two applications for field testing on 29 sites ranging in size from 0.5 to 20 acres located in Alabama, Florida, Texas and Louisiana .

USDA/APHIS has prepared a Revised Draft Environmental Assessment in response to the applications, to continue research on the transgenic Eucalyptus trees currently permitted, to be issued permits to plant additional trees, and for the environmental release of transgenic eucalyptus trees that will be allowed to flower on 28 of the 29 proposed sites.
 
These plants are a clone, coded EH1, derived from a hybrid of Eucalyptus grandis X Eucalyptus urophylla , and have been genetically engineered with different constructs. The purpose of the environmental release is to assess the effectiveness of gene constructs intended to confer cold tolerance, to alter lignin biosynthesis; and to alter fertility. In addition, the trees have been engineered with a selectable marker gene.

The two combined permits requested by ArborGen would allow flowering on up to 330 acres across all 28 locations, in fields ranging from 0.5 to 20 acres. Gene used as selectable marker

The kanamycin resistance selectable marker gene engineered into the trees is accepted as being safe according to APHIS. In a number of instances, plants transformed with this gene have been deregulated by APHIS (e.g. corn, rapeseed, cotton, and papaya in past petitions). It should be pointed out that the food and feed crops deregulated by APHIS were not labeled and there has been no effort to study the impact of the antibiotic resistance gene on the human population or for that matter farm animals. Therefore, the gene is essentially untested, and APHIS has no ground in assuming that the use of that gene has no significant impact.

The cold hardiness modification

The most significant modification is the introduction of genes for cold hardiness. The genes introduced include a protein transcription factor called C-Repeat Binding Factor (CBF) driven by a cold hardy stress - inducible promoter. The transcription factor regulated the expression of a number of genes conferring frost hardiness. Using the stress-inducible promoter to drive CBF transgene expression significantly improves freeze tolerance without negatively impacting other agronomically important traits.
 
The cold-inducible promoter causes the gene to be expressed under cold temperatures, thus mitigating the potential of reduced growth at low temperatures. A constitutive promoter such as that of CaMV used to drive CBF transgene would reduce plant growth. A patent application submitted by ArborGen reports the CBF gene sequences employed by ArborGen in GM Ecalyptus.

Given the propensity of the CBF transgenes to produce detrimental growth impacts when controlled by a constitutive promoter, it is advisable make a fuller study of the proteome (the entire set of proteins expressed by a genome, cell, tissue or organism) of the plants modified with CBF and the stress inducible promoter. The presumption that the effects of transgenic CBF and its cold inducible promoter has no harmful side effects is unwarranted without a fuller study.

Gene for altered fertility

According to APHIS, the barnase gene has been engineered into several other crops that have been previously reviewed and addressed in multiple environmental assessments by APHIS, and granted non-regulated status: Male sterile corn, rapeseed and chicory. There is no reason to believe that the function and expression of this gene will be any different from the plants in which it has been previously assessed.
 
In greenhouse tests using tobacco and an early flowering model Eucalyptus, the applicant has found that the barnase gene demonstrated 100 percent efficacy in preventing pollen formation. In developing flower buds from field grown transgenic Eucalyptus lines containing this cassette, 90 percent of lines showed complete pollen ablation.
 
Recent observations from the replicated field study being conducted in Alabama under the approved BRS permit confirm that cold tolerant trees grown at the site and allowed to flower did not produce any viable pollen. APHIS concluded that barnase will have no significant impact on the environment.

APHIS ignores the fact that the product of the barnase gene is barnase ribonuclease, a powerful cell toxin poisoning humans, small mammals and bird. The same toxin has been engineered to kill cancer cells.
 
A patent application submitted by ArborGen in 2009 stated: “Accordingly, there exists a need for a reproductive ablation system having reduced barnase induced toxicity and minimal leaky expression in a plant's vegetative tissues.” The leakiness and toxicity of barnase was not mentioned in the APHIS assessment.