Global Justice Ecology Project and the STOP GE Trees Campaign are seeking a global ban on the release of genetically engineered (GE) trees into the environment

At its last Conference of the Parties (COP8), the Convention on Biological Diversity adopted a very important Decision in relation to the issue of genetically engineered trees and invited everyone "to provide relevant views and information to the Secretariat for inclusion in this assessment". Given that a number of organizations have produced a joint letter (below) to be sent to the Secretariat providing information and analysis on the issue and calling for a "mandatory decision declaring an immediate ban on the release of GM trees."

To support this effort, please sign the petition to the United Nations below:

CBD Secretariat
Dear Dr. Djoghlaf,

The undersigned wish to express our full support for the COP 8's Decision VIII/19 (Forest biological diversity: implementation of the programme of work), which "Recommends Parties to take a precautionary approach when addressing the issue of genetically modified trees".

We also support the reasons for the adoption of the CBD COP-8 with regard to GE trees which states: "Recognizing the uncertainties related to the potential environmental and socio-economic impacts, including long-term and transboundary impacts, of genetically modified trees on global forest biological diversity, as well as on the livelihoods of indigenous and local communities, and given the absence of reliable data and of capacity in some countries to undertake risk assessments and to evaluate those potential impacts".

Given that the Decision also "Invites Parties, other Governments and relevant organizations, including indigenous and local communities, as well as relevant stakeholders, to provide relevant views and information to the Secretariat for inclusion in this assessment," we would like to contribute to this assessment.

A look at the main genetically engineered (GE) tree research currently being carried out shows that it is focused on a very narrow range of aims:

- herbicide resistance
- insect resistance
- tree sterility
- lower lignin and higher cellulose content
- resistance to cold, salt or drought
- faster growth

None of the above can be seen as being beneficial to global forest biological diversity, which needs accompanying flora species (impacted by herbicides), insects and related food chains (impacted by insect resistant trees), flowers and seeds (inexistent with tree sterility), wood resistant to strong winds (lower lignin content makes trees weaker), trees and plants adapted to local environments (impacted by alien trees resistant to cold, salt or drought), intact soils and sufficient water (depleted by fast-growing trees) In addition, genetically engineered tree plantations are likely to be developed where biologically diverse forests now stand, following the trend of monoculture plantations that have replaced native forests around the world.

This indicates that GE trees are not beneficial for global forest biological diversity. It is also clear that those genetic modifications are being carried out for industrial and not environmental reasons and, if released, would result in industrial plantations with low biodiversity, largely devoid of other living organisms, thus effectively depleting forest biological diversity.

This leads to the main question: Can genetically modified trees have a negative impact on global forest biological diversity?

The main threats of GE trees are:

- Substitution of diverse forests by genetically modified tree monocultures. This is already happening with "conventional" tree monocultures (oil palm, eucalyptus, pines, acacias, and gmelinas) and there is no reason to believe that it would be different with GE trees. On the contrary, corporations like ArborGen have postulated that pulp from plantations of GE trees could bring in considerably higher profits than pulp from conventional monocultures, indicating that corporations intend to rapidly implement large scale industrial GE tree plantations.

- Contamination of non-GM trees of the same species or genus. This contamination is particularly dangerous in the case of the most widespread plantation tree-eucalyptus -whose many species have the capacity to hybridise and could therefore be easily pollinated by GE eucalyptus. It is also dangerous in other plantation species such as pines, poplars and acacias. In China, the only country where GE trees are planted on a commercial scale, contamination of native poplar trees has already been documented.

- Contamination of related tree species. Tree pollen can travel very long distances and could contaminate non-GM trees both of the same species as well as other related species in entire regions and countries. This would mean that native trees might acquire the genetically modified traits of GM trees. For instance, they might become resistant to insects, i.e. produce toxins, thus resulting in the depletion of certain insect populations and dependent plant and animal species. The "solution" of developing flowerless trees creates false confidence in the supposed safety of the technology and runs the risk of passing on any of the modified genes to trees in the wild - if sterility were to fail in just one single tree in one year.

- Trees with less lignin (and higher cellulose content) would be more prone to pest attacks, and potentially increased windfalls, and would rot more quickly, altering soil structure and releasing CO2 more quickly, thus contributing to climate change. Decomposing forest dead wood provides an essential habitat for a high diversity of flora and fauna. Disturbing the rate of wood decomposition would have a dramatic effect on species populations, the consequences of which have not been studied. These trees would also show altered characteristics during storm, flooding and possibly drought.

- Contamination of forest ecosystems and other habitats with GE trees via seed. Trees produce abundant fruit and seed, often capable of travelling long distances either carried by air, water, animals and human activities. Trees genetically engineered for faster growth, salt tolerance, short daylight adaptation or cold tolerance could out-compete common pioneer species or populate rare or marginal habitats previously uninhabitable to trees.

- Impacts on the livelihoods of indigenous and local communities. The environmental release and commercial use of GE trees in industrial GE tree plantations would provide no goods to local communities, and would impact on their traditional use of forest resources, including fruit, seed, insects, animals, honey, and fibres. In the long run, contamination of native tree species could wipe out most of the resources they depend on.

- Risks to human health: Many studies have been done on the potential human health impacts of GM crops and the risks involved are manifold. Few risk assessment studies apply specifically to trees and though they are likely to share similar risks to plant crops, trees are also know to have other specific areas of concern when genetically modified. The longevity of trees makes the necessary multi-generational risks assessment studies impossible to carry out in the short-term. Yet it is known that aberrations of intended gene expression may only become apparent when studied over several generations. Unexpected gene expression is known to have occurred in elm trees, for example.

- Increased contamination of soils, water and air from toxic herbicides used in conjunction with herbicide-resistant trees, or inhalation of pollen from insect-resistant trees could have serious impacts on the health of indigenous and local communities.

- There are likely to be significant impacts on women and indigenous peoples, the traditional caretakers of biodiversity. In many communities, women are the ones who think in terms of generations. It is women in rural and indigenous communities who will bear the greatest burden of the impacts of GE tree plantations, just as they currently bear the brunt of the impacts from conventional monoculture tree plantations. Women and children will likely bear the brunt of any human health consequences of GE trees, for example resulting from inhalation of large quantities of Bt toxin from the pollen of insect-resistant Bt trees.

In conclusion, GE trees have no role to play in the conservation of global forest biological diversity and, on the contrary, are likely to reduce forest biodiversity, with attendant social consequences. The high risks indicated by the available though incomplete science show that the technology could result in the extinction of forest plant and animal species with severe negative impacts on biodiversity.

We therefore urge the Convention on Biological Diversity to move forward from the current recommendation to Parties to take a precautionary approach, to a mandatory decision declaring an immediate ban on the release of GE trees.

Yours sincerely,