July 5, 2017

U.S. Department of Agriculture
Animal and Plant Health Inspection Service
Attn: Cindy Eck
Biotechnology Regulatory Services
4700 River Road

Riverdale, MD 20737

Re: ArborGen Inc. Petition (11-019-01p) for Determination of Non-Regulated Status for Freeze Tolerant Eucalyptus Lines FTE 427 and FTE 435 (Docket No. APHIS 2012 0030):
1. Draft Environmental Impact Statement, EIS No. 20170061 (April 2017) (APHIS 2012-0030-0635); and
2. Plant Pest Risk Assessment (March 2017) (APHIS-2012-0030-0634).

Dear Ms. Eck:

We [the undersigned] strongly oppose USDA’s proposed commercial approval of ArborGen’s genetically engineered (GE), freeze tolerant eucalyptus, which would be the first-ever genetically engineered forest tree in the US to gain such an approval.  As described in these comments, the novel risks and significant adverse impacts of ArborGen’s GE eucalyptus trees are high, with no benefits to society.  To prevent irreparable harm to vulnerable ecosystems, GE eucalyptus should not be approved.  

To make the GE “freeze tolerant” eucalyptus, ArborGen genetically engineered a hybrid eucalyptus tree with gene sequences from 6 different species of bacteria and plants.  ArborGen plans to market its GE eucalyptus in southeastern states, from Texas to South Carolina.  There are no eucalyptus species native to North America, and many of the plants and animals which reside on this continent, including endangered species, will be unable to find suitable habitats—appropriate food, nesting sites, germination sites, and so on—within eucalyptus plantations or eucalyptus-invaded natural areas.  In fact, decades of experience with even non-genetically engineered eucalyptus plantations throughout the world provide clear evidence of their serious environmental, social, and economic impacts, which cannot be ignored.  

Allowing GE eucalyptus plantations would cause significant adverse environmental and socioeconomic impacts.  For example:

• They will be intensively managed using industrial forestry practices—heavy machinery, fertilizers and pesticides—that degrade soils and pollute air and water, harming many plants and animals, and affecting nearby communities.

• Eucalyptus plantations use more water than other trees in the southeast, decreasing stream flow and ground water, and stressing ecosystems already suffering from more frequent and intense droughts because of climate change.

• Eucalyptus are highly flammable, and canopy fires spread quickly.  Pines that grow in the same area compound the potential for catastrophic fires.

• These genetically uniform plantations will be magnets for plant pests and pathogens that were not present or were rare in the southeast before.  Along with that will come greater use of toxic pesticides and risky biological control agents.

• GE eucalyptus’ progeny will likely escape plantations and become invasive, as have non-GE eucalyptus in some parts of the U.S. already.  If GE eucalyptus spread into natural areas they will displace native trees and the species that depend on them, deplete water resources, and increase fire hazards that put nearby communities in danger.

Claims that GE trees’ offspring will not escape are fatally undercut by the U.S.’s 30-year experiment with GE crops, which have escaped containment over and over again, despite industry and USDA’s claims that they would not.  GE trees are even more likely to escape and spread than GE crops, given their much longer lives and the unpredictable, changing conditions that can occur over that course of time; as well as the feral characteristics that enable them to thrive in the wild, unlike most highly-domesticated annual crops.

Introduced invasive species, including many trees, are an intractable environmental problem worldwide.  It is difficult to keep them from entering ecosystems, and once established, essentially impossible to eradicate them.  Keeping prospective invasive species out in the first place is the only viable solution.  Deliberately introducing them, especially when there is foreknowledge of negative impacts, is foolhardy.

In its proposed approval USDA has downplayed or ignored these significant risks.  These eucalyptus are the first GE forest trees to ever be considered for approval by USDA, and are also the first fast-growing, commercially viable eucalyptus to be able to withstand cold weather that would extend their range.  Replacing native forests or existing timber plantations with any kind of eucalyptus would be bad enough, but as a direct result of freeze tolerance, USDA predicts that the land area covered by commercial eucalyptus plantations will expand greatly in the US, from less than 20,000 acres in central and southern Florida now to over a million acres across seven southeastern states over the next 30 years.  This would have devastating consequences across the southern states, which are home to some of the most biodiverse ecosystems in the world, and are already precariously threatened by climate change and sprawl.

While Americans’ environmental and socioeconomic short and long term interests will be damaged by the proposed approval, the only clear winner from approval of these GE eucalyptus is their producer, the company ArborGen.  ArborGen is promoting GE eucalyptus for use in “green energy” biomass and biofuels projects which face serious criticism given their direct and indirect impacts on land use, failure to reduce greenhouse gas emissions, negative impacts on air and water, and high costs.  Throughout the U.S., and especially in the southeastern states, residents are opposing the expansion of wood pellet export facilities, even as policymakers in Europe are reconsidering the mistake of subsidizing combustion of imported wood pellets as “renewable energy.”  The scale of demand for wood to produce energy is simply not sustainable and policymakers are gradually recognizing that protecting native forests is more effective for addressing climate than burning trees.

All of the very significant negative agronomic, social, and environmental impacts of commercial plantations of GE eucalyptus and their spread into natural areas can be prevented if USDA takes the sensible action of denying approval.

We strongly urge USDA to reject ArborGen’s Petition (11-019-01p) for Determination of Non-Regulated Status for Freeze Tolerant Eucalyptus Lines FTE 427 and FTE 435.  

Signatories:

Foundation Earth
International Center for Technology Assessment
Center for Food Safety