GE Free New Zealand

In Food and Environment Inc.

PO Box 13402, Wellington, NZ Ph +64- 4 - 477 4744

www.gefree.org.nz

10/10/2010

GE Free NZ in Food and Environment Inc:

GE Free NZ in Food and Environment is an Incorporated Society. It is a non-political voluntary community organisationproviding information to its member and the public on issues concerning genetic modification. It also participates in forums working on committees and with government bodies.

They are in constant dialogue with regulators in New Zealand and have made submissions on ERMA on behalf of its members.

GE Free NZ has read the correspondence letter in Nature Biotechnology[1] from Christian Walter, Matthias Fladung & Wout Boerjan p.657 with interest as it covers some data on the GE pine trials carried out in New Zealand.

Background:

The New Zealand regulatory body ERMA (Environmental Risk Management Authority) approved an application (GMF 99001 & GMF 99005) [1] from the Forest Research Institute now Scion to field test trial GE pine trees that were to be herbicide tolerant and to carry traits that would alter or influence their reproductive development,

The trees, Pinus radiata (Monterrey Pine) herbicide resistant and Picea abies (Norway spruce) were engineered with herbicide tolerant genes the bar gene resistant to the glufosinate-ammonium herbicides Buster and ALS gene resistant genes to sulfonylurea herbicides (Escort).

These trials were approved in June 2000, due to a 2 year voluntary moratorium on the GE field trials, they were kept in indoor containment facility until July 2003 when they were planted out in an open facility surrounded by forest in Rotorua Redwood Park.

1.  In the trials cuttings were taken from the GE trees (unknown species) and grown in the outdoor shade house, in 2004 male catkins were detected and taken indoors. GE pine cuttings produced viable pollen anthers in the first year in stress conditions. The precocious reproductive structures were formed on 9 trees from –

I.  Transformation event “LEAFY” which produced 6 cuttings that developed catkins.

II.  Transformation event “CONSTANS” which produced 2 cuttings that developed catkins

III.  Transformation event “LEAFY/APETALA” which produced cuttings that developed 1 catkin.

As seen in the table from Walter Christian from a letter on the 10th May 2006 [2] relating to an OIA request to ERMA. The information provided shows that GE pine trees pollen could germinate after 8 days. The pollen was seeded on a geneticin culture the results showed that 2 of the 9 pollen lines were viable and germinated, the pollen was also able to stay viable for 8 days up to germination.

There was no expertise shown in monitoring or management of the field trial that was closed down before reproductive structures on the GE trees could be initiated.

The GE P.abies trial (GMF99005) was terminated in October 2005 after 2 years in the field as they were “very small (10-20cm in height) and severely unhealthy”

In September 2006 17 genetically engineered radiata pines were planted in the site these carried traits of the Leafy like gene (PRFLL) a gene involved with reproductive development.

The P.radiata herbicide resistant and reproductive gene trait trees (GMF 99001) grew in the field until 2008 where poor facility management allowed entry by unknown persons who cut down and removed the newly 17 GE trees carrying reproductive genes.

The trial was officially closed down in 2008 where post monitoring of material at the site has been undertaken.

Our Concerns:

The concerns we have over this trial and the publication in the letter is that all the information gathered from Christian Walter is unpublished data.

This data however cannot be called robust as the studies on the trees were taken in the first two years of establishment which appeared to be very poor. The raw data has never been provided and we are still awaiting it. However of concern is that after only four seasons there was recorded a difference between the microbial populations but dismissed, as the raw data is not available even though it has been 5 years since it was completed it is difficult of any peer review on the findings to be looked at. .

The length of time that the trial on each tree event line was carried out in was between 2-5 years at the most, not 9 years as specified. This means that there can be no environmental or bio diverse safety data gathered and confirmed when there is such a paucity of data.

The trial researchers showed poor control compliance as to the pruning’s and height of the trees, further questioning the robustness of any information that has been provided.

The unpublished data Dr. Walter refers to is circumstantial and poorly conceived and does not show any benefit to the economy, environmental or flora and fauna that is any different to traditionally bred trees.

In fact the small differences in soil microorganisms were discounted as non significant and due to environmental variations. Longer and more robust studies must be continued on the effects on wildlife, insect and bird life and transfer of such things as antibiotic resistance genes through the detritus [4] and pollen [5] flows into the environment through the weather and water systems. The lack of information poses a real threat to the ecosystems flora and fauna.

There are no studies on the out crossing of GE and traditional Pinus species trees. Pines seeds can stay dormant for up to 15 years which threatens the indigenous forests of New Zealand as wilding pines pose a serious problem to the diversity of the environment and economy of the country.[8]

The rising resistance to antibiotic as seen in the recent NDM-1 superbug [6] is a chilling signal as these trees carry the bla genes and many other antibiotic marker genes. The continued use of these genes could lead to a health disaster of pandemic proportions and must be carefully considered in the overall discussions around environmental bio diversity. As many flora and fauna have their own resistant systems that have been evolved over the millennia, the breach of the genome that an organisms have built up over the years could make the need to use antibiotic treatment an expensive and costly event.

GURTS technology is also a threat as the cutting show, it is possible that under extreme stress conditions that technology actually allows a plant to mature early and produce pollen. Whatever this is it is not predictable and the unknown effects of such events on the flora and fauna are severely threatened.

The research into better production, management and processing of traditionally bred trees is showing promising results.[9] More data needs to be gathered before any relaxing of international laws around GE trees is considered.

These results from New Zealand cannot add to the support for a change in the UN rules around GURTS technology and GE trees and we would like to ask that there be no lifting of the rules around GE trees in this session of the COP proceedings in Nagoya.

Yours sincerely,

Claire Bleakley

President of GE Free NZ.

References:

[1] ERMA New Zealand Evaluation and Review Report. Application numbers: GMF 99001 and GMF99005 October 2000

[2] Environmental Risk Management Authority Decision on GMF 99001 and GMF 99005, 20 December 2000

[3] Annual report 2004 and letter from Walter Christian.

[4] Tank JL., Rosi-Marshall EJ., Royer T., Matt R. Whiles MR., Griffiths NA., Frauendorf TC., and Treering DJ, (2010)
Occurrence of maize detritus and a transgenic insecticidal protein (Cry1Ab) within the stream network of an agricultural landscape, PNAS, Published online before print September 27, 2010, doi: 10.1073/pnas.1006925107

[5] Williams C W, Long distance pine pollen still germinates after meso-scale dispersal. American Journal of Botany: 97(5):1–10. 2010.

[6] Kumarasamy K K., Toleman MA., Walsh TR., Bagaria J., Butt F., Balakrishnan R., Uma Chaudhary U., Doumith M., Giske CG., Irfan S., Krishnan P, Kumar AV., Maharjan S., Mushtaq S, Noorie T., Paterson DL., Pearson A, Perry C., Pike R., Rao B, Ray U., Sarma JS., Sharma M., Sheridan E., Thirunarayan MA., Turton J., Upadhyay S., Warner M., Welfare W., Livermore DM. and Woodford N., 2010 Emergence of a new antibiotic resistance mechanism in India, Pakistan, and the UK: a molecular, biological, and epidemiological study Lancet Infect Dis 2010; 10: 597–602 Published Online August 11, 2010 DOI:10.1016/S1473-3099(10)70143-2

[8] Potential threat of wilding pine http://www.doc.govt.nz/publications/conservation/threats-and-impacts/weeds/south-island-wilding-conifer-strategy/2-the-wilding-conifer-problem/2_4-potential-extent-of-the-wilding-conifer-problem/
[9] Diaz-vaz, J. E.; Ananías, R.A.; Rodríguez, S.; Torres, M.; Fernández, A; Poblete, H. Compression Wood in Pinus Radiata: II: density and chemical composition. Maderas. Ciencia y tecnología 11(2): 139-151, 2009 http://redalyc.uaemex.mx/pdf/485/48511411005.pdf

[1] Correspondence nature biotechnology volume 28 number 7 July 2010, p657.