GM Technology in the Forest Sector: A Scoping Study for WWF
11/1/99
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RELAYED TEXT STARTS HERE:
Title: GM Technology in the Forest Sector: A Scoping Study for WWF
Source: Rachel Asante Owusu
Status: Copyright 1999, contact source for permission to reprint
Date: November 1999
Byline: Rachel Asante Owusu
Contents
Executive Summary
Introduction
Commercial attractions of biotechnology to the
industrial forest sector
Growth and development of GM technology in the
forest and related sectors
Regulations for the testing and commercial
production of GM tree species
Regulating the international trade in GM forest
products
Conclusions: WWF's response to biotechnology in the
forest sector
Executive Summary
It is becoming increasing difficult to determine how the GM issue
will unfold over the next 18 months. In a recent report to WWF, it
was stated that "although GM trees posed a risk to biodiversity
conservation, the main threat would continue to come from GM
agriculture". In the light of this scoping study, such a statement,
while probably true, cannot be taken as definite. While
biotechnology may be under siege or even in trouble in the food crop
sector, it is growing strong in the non-food sector, including
industrial forestry. Genetic modification offers the industrial
forest sector, with its long-standing limitations on tree
improvement, potential for development that would not have been
thought possible 15 years ago.
Poorly regulated and controlled commercialisation of biotechnology in
the forest sector poses additional risks compared with agriculture.
The long timeframe and typically remote locations of plantations mean
that additional safeguards are required in national and international
biosafety protocols. However, while the real risk of genetic
pollution and invasiveness should not be underestimated, more
immediate problems associated with the intensification of land use
should not be forgotten either. Biotechnology may inadvertently
become yet another driver for inappropriate plantation development.
Increased soil nutrient and water demand of fast growing species on
short rotations could lead to irrecoverable loss of site
productivity.
Since 1988 there have been 116 confirmed GM tree trials around the
world. Analysis of the data shows that the growth in trials and
number of species used has risen sharply since 1995. There is a sharp
North-South divide on the type of trial and the research institutions
involved. In North America and the European Union, research is
typically controlled by government and academia, while in the
countries of Latin America, Africa and South-east Asia, research is
being driven by the private sector. All the indications are that
commercial GM plantations will make their debut in Indonesia, Chile
and possibly Brazil. Little information was available from China but
it is suspected that transgenic trees will be an important issue
there.
As all indications point towards the fact that biotechnology is here
to stay, it is recommended that WWF seek to facilitate an agreed set
of guidelines between industry, government, NGOs and other
stakeholders on environmental regulations and safeguards concerning
the testing and commercialisation of GM trees. A complementary work
programme is proposed.
1 Introduction
1.1 BACKGROUND TO THE STUDY
Over the past two years, public, media and NGO attention has focused
on GM agricultural crops with little consideration being given to
transgenic trees. In May 1999, WWF International commissioned a short
report entitled Genetic Modification in Tropical Forestry , whose aim
was to establish whether biotechnology was an emerging "forest"
issue.
The report concluded that biotechnology was indeed an emerging
"forest" issue and highlighted that although transgenic trees are not
yet being grown commercially, a series of GM field trials are already
under way. The report also drew two more general conclusions
concerning biotechnology and the environment: first, that although
concern over GM technology at present tends to concentrate on health
risks, the more serious environmental and social impacts are being
under-estimated. Second, that high profile campaigns (eg Greenpeace)
on GM technology should be complemented by scientifically-based
lobbying and advocacy for watertight monitoring and regulation of GM
field trials and international trade. Finally, the report recommended
that, as an initial step, WWF should assess the extent to which GM
technology impacts upon the forest sector by undertaking a 15-day
scoping study.
This report is the product of that study, which included attendance
at the Forest Biotechnology 99 symposium at Keble College, Oxford, in
July. Its purpose is to provide an informed basis on which a more
substantial programme of forest-related policy and advocacy work on
biotechnology can be developed. In particular, this report seeks to
ascertain the degree to which GM technology has already impacted upon
the forest and forest-related sectors, evaluate its future potential
and briefly review the adequacy of national and international
controls governing testing, production and trade.
This report has been commissioned by the International Conservation
Department of WWF-UK and the Forests For Life Programme Unit of WWF
International.
1.2 THE ENVIRONMENT AND GM TREES: A CAUSE FOR CONCERN?
Given that biotechnology is an emerging issue in the forest sector,
it is appropriate to begin this study by considering whether the
utilisation of GM trees represents sufficient risk and uncertainty as
to merit prioritisation by environmental NGOs. Is it not
strategically more important to deal with GM agricultural crops?
After all, tree crop plantations (whether for timber, resins, fruits
or other products) only occupy a very small proportion of the world's
surface area compared with agriculture.
1.2.1 Risk and uncertainty - the time factor
Insertion of a novel (introduced) gene can have collateral impact on
the rest of the host's genome, resulting in unintended side effects
such as salmon engineered for fast growth also developing green-
tainted flesh. Most of the time such collateral effects will be
immediately recognisable, but in some instances it may alter the
behaviour of silent genes, ie those that are activated only under
certain circumstances. Of particular concern are the risks associated
with collateral alterations to stress-activated genes, for such
effects cannot be anticipated until the stress response is actually
triggered.
With annual and short-lived perennial agricultural crops the
relatively limited cycle can act as an informal, if unsatisfactory,
safeguard. Changes in the ecological or physiological behaviour of an
agricultural crop will be relatively easy to detect and, given
resources, remedial action can take place. However, trees differ from
most agricultural crops in that they persist in the landscape for
long periods of time. This different timeframe not only increases the
probability that any one tree crop will be subjected to a much wider
range of stress conditions
(eg temperature extremes, insect attack, effects of climate change),
but also that any stress-induced side-effect of GM technology will be
much harder to detect and address.
The time factor also has a bearing on the risk of novel gene
mutagenesis (random changes to the genetic code). Current GM
technology operates under the assumption that the novel gene is just
as stable as those naturally found within the host's genome. However,
this is far from certain and scientists are only now starting to
understand gene regulation and repair processes. Some recent
experience points towards novel genes being inherently less stable.
One area where novel gene breakdown is of real concern is plant
sterility. In order to allay fears that a GM crop could become a
super-weed (and to ensure regular GM seed sales), plant breeders can
insert a gene for male sterility along with the desired novel gene.
However, should the function of the introduced sterility gene become
impaired, supposedly "safe" GM crops will be able to breed and enter
the environment. Yet again, the fact that trees have much longer life
cycles means that the probability of novel gene breakdown is higher
while the chances of detecting such an occurrence are much lower.
1.2.2 Risk and uncertainty - the location factor
A large number of tree plantations are grown on marginal agricultural
or forest land in remote locations. Even a high-input, clonal
plantation is a lot less intensively managed than the average field
of corn. Remote locations and less intensive management regimes mean
limited opportunities for monitoring, control and enforcement of
regulations while making early detection of unanticipated problems
(see 1.2.1) highly unlikely.
Furthermore, while most of the world's agriculture takes place within
highly modified landscapes, plantations are often established in
close proximity to stands of natural forest. In instances where
plantations, or trials, of GM trees species are established close to
pools of naturally-occurring wild relatives, the likelihood of
genetic pollution will be high. Those who attempt to down-play the
risks of genetic pollution are being somewhat disingenuous, for plant
breeders have long been concerned with the reverse problem - breeding
plot contamination from the influx of wild pollen (Arriola).
Worryingly, the feasible distance over which gene flow can occur has
been revised upwards. Recent studies on both temperate conifers
(Hedrick & Savoleinen) and tropical broadleaved species (Boshier &
Billingham) indicate that long distance dispersal of small amounts of
pollen can be considerable. Indeed, given the dynamics of gene flow
(pine pollen can be dispersed in excess of 600 km), it would be
surprising if some novel gene escape has not already taken place from
the GM tree trials that are currently under way.
1.2.3 GM technology as a factor in unsustainable plantation
development
Between 1980 and 1995 the plantation area in the developing world
doubled and is expected to double again by 2010. This expansion of
forest plantations has often taken place at the expense of natural
forest and local people's rights. While many NGOs continue to express
their concern over industrial plantations (eg the Montevideo
Declaration) there have also been positive developments such as the
increase in area of plantations under FSC certification and renewed
interest in the utilisation of native species.
GM super-trees could reverse the modest social or environmental gains
in plantation management that have been made over the past decade.
Evidence is now emerging that well managed plantations might indeed
be sustainable in the "narrow sense" of sustained yield (Evans,
1999). This means that given good management practices, plantation
tree crops could be grown in perpetuity on the same site without
adversely affecting the soil's nutrient status and structure or its
hydrological functions. However, the introduction of trees modified
for rapid growth could mean shorter, more intense rotations, greater
water demand and reduced opportunity for nutrient recycling.
Over the course of two or three production rotations, site
productivity would begin to decline, requiring increased fertiliser
inputs or - more likely in tropical countries - leading to land
abandonment. The land base that would be required to support
plantation activities would therefore expand much more rapidly than
previously anticipated, possibly impacting on natural forests and
other sites of high biodiversity value.
Admittedly there is little direct evidence either to support or
reject this scenario - but exactly the same pattern of land use has
unfolded with mangrove clearance for shrimp production. Indeed, the
main impact that GM technology could have on the environment may not
be genetic pollution or super weeds but rather the contribution that
it might make to unsustainable land use. Unfortunately, most GM tree
trials do not even consider nutrient and hydrological cycling issues.
2 Commercial attractions of biotechnology
to the industrial forest sector
For the past 50 years plant breeders have sought to add value to tree
crops by increasing the frequency of favourable genes in the
commercial planting stock. This has been achieved through laborious
and time-consuming techniques that are underpinned by classical
Mendelian genetics: isolating individuals with the desired trait,
collecting and testing their progeny and crossing high performing
individuals. Within the past 25 years advances in vegetative
propagation techniques have enabled forest nurseries to produce large
quantities of monoclonal planting stock by taking cuttings from the
very best individuals: nevertheless, advances in breeding are still
limited by the uncertainty that nature provides through sexual
reproduction. Furthermore, in many cases the desired traits simply do
not exist (or are so rare as to be impossible to isolate) within a
species' breeding population. Biotechnology has overcome these
limitations.
Although genetic engineering allows for the development of transgenic
super-trees, until recently commercialisation was hampered by the
inability of biotech companies to produce large numbers of GM
planting stock over a short time period at low cost. The
mechanisation of a cloning technique called somatic embryogenesis has
overcome this last hurdle. Somatic embryogenesis differs from
traditional cloning techniques in that it allows very large
quantities of seedlings to be produced from very small amounts of
plant tissue. However, it initially proved to be too expensive for
use in commercial forestry because each cluster of differentiated
tree shoots had to be manually plucked from the source tissue before
being carefully placed into growth medium. ForBio, an Australian
plant biotechnology company, has managed to automate this labour-
intensive production stage by using robots, thus allowing the mass
production of both GM and non-GM trees from tissue culture to become
commercially viable.
It is not inconceivable that biotechnology may offer relatively
greater benefits to the industrial forestry sector than to
agriculture. Forest scientists will be free to work with only genes
of primary interest, delivering improved provenances to the industry
in a matter of months rather than years. As there are few direct
health concerns it is unlikely that the issue of GM trees will muster
the same public opposition as GM food crops have. Indeed, a recent
review by Deutsche Bank has declared GM food crops "dead", basically
because it foresees a two-tiered marketing system evolve. However,
where it advises SELL on companies producing GM food crops, it
continues to recommend BUY for those that market other (non-food) GM
products. The industrial forest sector, with its long-standing
limitations on tree improvement and a global turnover of US$ 400
billion on unprocessed timber alone, may well be the natural ally for
biotechnology companies eager to demonstrate the commercial viability
of their product away from the spotlight of adverse publicity.
2.1 LIGNIN MODIFICATION
Lignin is a complex organic macromolecule that is a key component of
the cell wall. In addition to conferring strength properties it is
also a constituent of the tree's defence mechanism and can account
for between 15 and 35 per cent of dry weight in woody species.
Nevertheless, in the pulp and paper industry, lignin - especially
that found in conifers - is undesirable and its removal from wood
fibres is a costly and environmentally hazardous process.
Scientists have targeted those genes that code for the enzymes that
catalyse the synthesis of monolignols, the building blocks of lignin.
This has permitted the development of transgenic poplars with low or
modified lignin content. If grown commercially, such trees would
reduce pulping costs along with "end-of-pipe" pollution from pulping
effluent. But claims of environmental benefits must be considered in
the context of the whole production cycle. Modified or lower lignin
content may well impair a tree's pest resistance, requiring the use
of additional pesticides. Low lignin can also accelerate wood decay,
affecting soil structure and biology and leading to increased
fertiliser use. Environmentalists are also concerned that low lignin
traits could become incorporated into wild relatives of transgenic
species, accelerating their life cycle and thus modifying ecological
processes.
2.2 INCREASED GROWTH RATE
Fast growth is an obvious trait targeted by forest biotechnologists.
This can be obtained by a number of methods although ForBio is
anticipating that the most reliable results can be achieved through
the introduction of plant sterility into transgenic tree species.
Typically, between 15 and 30 per cent of a plant's energy supply is
used in its reproductive structures such as flowers, cones and
fruits. Elimination of these structures would permit additional
energy to be redirected towards tree growth. In field trials,
transgenic poplars grow at up to four times the rate of the
traditional softwood conifers that are used for newsprint.
Companies such as International Paper have argued that higher growth
rates allow more wood to be grown on less land and that this has
inherent environmental benefits. The reality is that trees modified
for rapid growth may well sequester more, and therefore recycle less,
nutrients and water, and that this could have a long-term deleterious
effect on site productivity. There is also the risk that fast-growing
transgenic tree species could become serious invasive weeds,
disrupting natural forest ecosystems.
2.3 HERBICIDE TOLERANCE
Herbicide-tolerant crops are already being grown in many countries
throughout the world and scientists are now examining whether such
properties can be transferred to tree species. As with agricultural
crops, the main focus of research is on general systemic herbicides
such as Round-Up (glyphosate). The benefits claimed for herbicide
tolerance are that it would allow forest managers to reduce the
number and intensity of applications, thus minimising maintenance
costs at the start of the rotation, especially on difficult sites. On
some planting sites, ground preparation could be minimised through
better weed control, and this in turn could reduce sediment run-off
and soil erosion.
Herbicide-tolerant tree species could eventually pose a threat to
other forms of land use and thus people's livelihoods. If the seed of
non-sterile, herbicide-tolerant trees is easily dispersed, the
control of woody invasives in some tropical pastureland could become
a serious problem. Furthermore, reduced herbicide application may
only be a temporary benefit. There is little doubt that regular use
of a narrow spectrum of herbicides will augment selection pressure on
target weeds in the short run and facilitate herbicide-resistance in
the long term. The US Department of Agriculture has recently revealed
that many farmers who have converted to GM production are using just
as much herbicide as their counterparts who continued to produce
conventional crops. USDA divided America into regions and studied the
performance of GM cotton, maize and soya beans. It was discovered
that in seven out of 12 regions farmers cultivating GM crops were
obliged to apply similar quantities of herbicide as those cultivating
non-modified crops. Interestingly, the research also indicated that
GM yields were not significantly better in 66 per cent of their
sample sites.
2.4 INSECT RESISTANCE
One of the most successful agents of biological control, first
discovered in the early 1980s, is Bacillus thuringiensis (Bt), a
bacterium that produces insecticidal chemicals. When ingested, the
bacterial spores germinate, producing a toxin that eventually kills
the insect. Different strains of bacterium make their own toxin and,
to date, scientists have discovered the genetic code for more than 50
Bt insecticides. Several commercial crops have been genetically
modified to contain Bt insecticide, including corn, potato and
cotton. Field trials of Bt-modified poplar, spruce, walnut and apple
have already taken place.
There are several claimed advantages of the Bt insecticide over
conventional pesticides. The use of GM insect-resistant plants
reduces the necessity for conventional pesticide, and as the Bt toxin
quickly denatures in ultraviolet light it will not persist long
enough to pollute soil and water. Bacterial toxins are also claimed
to be more species-specific and therefore safe for non-target plant-
feeding species. However, this claim has been brought into doubt by
recent research on monarch butterflies, a non-target species found to
be susceptible to the pollen of Bt maize.
Scientists openly acknowledge that Bt crops will augment the
selection pressure placed on target pests and that this will
inevitably lead to an increased frequency of Bt-resistance genes
within the insect's gene pool. In order to counteract this threat,
biotechnology companies such as Monsanto advocate that farmers adopt
a refuge strategy. This consists of establishing a discrete outer
buffer of a non-Bt crop around the Bt crop of the same species at a
1:5 ratio. The idea is to create a sufficiently large enough non-Bt
feeding ground so that Bt resistance confers no real long-term
advantage within the target insect population.
Research published by the University of Arizona has now cast doubt on
the long-term efficacy of Bt-insect resistance in crops, even where a
refuge strategy is rigorously pursued. It has been demonstrated that
Bt-resistant and Bt-susceptible pink bollworms (a cotton pest) mature
sexually at differential rates. Therefore Bt-resistant insects are
more likely to breed among themselves and, contrary to the
conventional wisdom that underpins the refuge strategy, a Bt-
resistant insect population will quickly develop. Given that Bt-crops
eliminate some competition from other insect herbivores, this new
population should rapidly expand.
One of the problems with Bt resistance is that, despite claims to the
contrary, it behaves as a fairly wide-spectrum pesticide.
Biotechnologists are now looking at engineering much more specific
resistance into trees. Genfor SA and the Forest Research Institute of
New Zealand are presently developing a transgenic Pinus radiata that
is resistant to the European shoot moth, a pest of great economic
importance for the Chilean forestry industry. Similarly, the
University of Dundee is seeking to reverse the damage and landscape-
level impact caused by Dutch elm disease through introducing
pathogen-tolerant genes into Ulmus procera and U. glabra.
2.5 PRODUCT UNIFORMITY
One of the main problems with wood as a raw material is that it is an
inherently variable product. From the production point of view,
plantations have a major advantage over natural forest in that they
offer large amounts of material whose sawing, seasoning and other
working properties are largely predictable and uniform. However, even
in plantations, lack of product uniformity can be a commercial
drawback.
While differences in tree height, trunk diameter, branch spacing and
tendency to branch can all be controlled by silvicultural
interventions, this demands time and resources. Obviously trees that
could deliver a similar or even more uniform product for less
effort/expenditure would offer a large commercial advantage.
Consideration as to how this might be achieved is still in its
infancy, and to date no known field trials have been established.
Indeed, it is likely that a number of modified genetic
characteristics would have to be inserted into target tree species to
obtain the desired effect - for example improved self pruning and
maintenance or enhancement of any growth advantage.
In conclusion, while product uniformity may be the most elusive to
obtain, it may also provide the greatest commercial dividends. But
from the social point of view, it would mean less opportunity for
local employment, as forests could be managed with even smaller work
forces. Environmentally, it could further simplify the structure of
plantations and thus further reduce their ability to deliver an
already limited range of ecological and social forest functions.
2.6 CARBON SEQUESTRATION
Although the rules for the sequestration and storage of biotic carbon
have not been fully agreed by the United Nations Framework Convention
on Climate Change, the possibility of utilising trees as "carbon
sinks" that could slow the rate of global warming has been the focus
of much speculation and debate. As a consequence of this, some CO2
emitting industries have already turned their attention towards the
feasibility of engineering tree species that can sequester and store
high levels of carbon.
Since 1993, Toyota, the Japanese car manufacturer, has established
several field trials in Japan to test the efficacy of transgenic
carbon sequestering trees. While there has been an observable
increase in carbon sequestration and storage, Toyota scientists also
reported an unacceptable increase in water consumption. Toyota has
currently turned its attention away from transgenics towards
tetraploidy (doubling the number of chromosomes that a plant
naturally carries). Tree breeders have known about tetraploidy for
many years but its commercial applications have been mainly limited
to the development of ornamental shrubs and trees. One reason why it
has not entered mainstream tree breeding is that, although it confers
some advantages such as vigorous growth (ergo higher rates of carbon
sequestration), the quality of the wood is notoriously weak (Wright).
If this problem cannot be resolved, Toyota's "designer" trees will
fail in their principal objective: to sequester and store carbon. It
is therefore probable that those seeking to develop trees with
enhanced rates of carbon sequestration will return to GM technology
sooner rather than later.
2.7 NON-COMMERCIAL DESIRABLE TRAITS
In addition to commercial advantage, trials are also under way to
introduce characteristics that do not add value per se to the host
organism. These non-commercial desirable traits may be necessary
either as a prerequisite for wild release or as an unavoidable stage
in the manipulation process.
2.7.1 Sterility
Although sterility may confer commercial advantage under some
conditions (see section 2.2), it may also become a prerequisite for
GM release. Many advisory bodies such as English Nature believe that
before GM crops can be released they must be made sterile to prevent
novel gene escape into wild populations. However, as discussed
earlier, the behaviour of essentially "silent" genes is problematic,
especially over the time-scales involved in plantation forestry. For
example, transgenic aspens grown in Germany to evaluate herbicide
tolerance also displayed precocious flowering at year three.
Normally, flowering in poplar is not expected before year eight.
Many concerns over unstable or incomplete sterility arise from the
fact that engineered sterility is usually gender-specific. ForBio is
the first biotechnology research institution to genetically engineer
total sterility into trees by blocking the development of both male
and female sexual structures at very early stages of growth. It is
fair to say that this development will lessen (though not eliminate)
the likelihood that the sterility safeguard could break down in the
future. However, some ecologists are horrified at the prospect of
sterile trees, for although plantations are poor imitations of
natural forest they may be the only repository of remnant, forest-
dependent insect life in a particular locality. Remove the flowers,
fruits and cones - and the plantation, to all intents and purposes,
becomes sterile itself.
2.7.2 Non - "antibiotic resistant" marker genes
Contrary to the image portrayed by biotechnology companies, novel
gene transfer can be a hit and miss affair. At one stage in the
transfer process, when the novel gene has been inserted into bacteria
to facilitate replication, it is necessary to distinguish those
bacteria that possess the desired gene from those that do not. To
distinguish between the haves and the have-nots, an additional marker
gene accompanies the novel "desired" gene. Often this marker gene is
for antibiotic resistance, so that only the bacteria with the "novel
gene plus marker" construct will grow on a medium containing the
antibiotic. This makes antibiotic-resistant markers very useful in GM
technology, by saving time that would otherwise be spent verifying
the presence of the new gene construct.
Unlike GM food crops, the safety of antibiotic resistance markers in
tree species is debatable. Theoretically, there is a risk that trees
could transfer this resistance horizontally (via asexual mechanisms)
to biomedically significant micro-organisms - but such risks are
exceptionally small. Even so, companies may not wish to attract
adverse publicity, especially when the use of antibiotic-resistant
markers is unnecessary. Innocuous alternatives are now available,
such as the GUS ( -glycuronidase) reporter gene which monitors the
expression of novel gene constructs by showing blue when positive.
2.8 OVERALL UTILITY OF GENETICALLY MODIFIED TRAITS
TO THE INDUSTRIAL FOREST SECTOR
Table 2.1 summarises how the industrial forest sector perceives the
utility of those modified traits discussed above. While environmental
claims may be the most frequently cited utility, this must be treated
with the utmost caution as the real driving force is that of the
industrial forest sector's "bottom-line". The expense and effort of
biotechnology will only be justified for those traits that are
economically important and which cannot be delivered by conventional
plant breeding techniques within a reasonable period of time. It is
perhaps worthwhile reiterating that industrial forestry has been
limited by conventional tree improvement, and that the prospect
offered to it by biotechnology may be too good to turn down. One
credible scenario for the development of biotechnology in the forest
and agriculture sectors over the next two years is that investment in
GM food crops, especially in developed countries, declines while
investment in GM tree crops in Chile and Indonesia, and possibly
Brazil and China, develops rapidly.
3 Growth and development of GM technology in the forest and related sectors
3.1 GLOBAL TRENDS
The following analysis is based on reliable data sources only. It has
been drawn from databases maintained by governments and/or
multilateral organisations such as OECD (Organisation for Economic
Cooperation and Development), reports in scientific papers and
conference proceedings, and direct communication with research
institutes. Partial information - for example, general articles in
the popular press - has not been used unless it has been verified by
a reliable independent source. Unapproved applications for wild
release have not been included either. It is therefore important to
understand that the following information represents an under-
estimate of the extent that GM trees species have been released into
the environment. Given the rapid growth in the number of field
trials, it is also important to realise that this information will be
out of date within three to six months from the time of writing.
Given the limited period of this study, it proved impossible to
ascertain whether any field trials or commercial release of GM tree
species had taken place in China or India. However, given the
advanced state of biotechnology in both countries and the growing
internal demand for forest products, field trials may have already
started.
3.1.1 Global overview
Based on a preliminary survey there have been 116 confirmed field
trials, involving at least 24 tree species, in 17 countries since
1988. The survey incorporated tree species for both fruit and timber
production, although 76 per cent fell into the latter category. A map
illustrating the distribution of GM tree field trials, by country, is
presented as Figure 3.1.
Based on the data collected for this survey, there have been no
confirmed reports of commercial production of GM trees. However this
situation is far from clear; Shell Forests believes that there is
still a significant body of development to be carried out to prove
that the technology is sound, environmentally acceptable and
economically worthwhile. In its view, the commercial application of
GM trees is still several years away. Nevertheless three important
consortia have been formed over the past four years (see box 3.1) and
indications are that commercial production may soon begin in
Indonesia, with Chile following closely behind.
Box 3.1 Forestry-biotech joint ventures: a prelude to commercial
production
Over the past four years, three important joint ventures between
forestry and biotech companies have been agreed. While the formation
of these consortia has passed relatively unnoticed, their
significance should not be underestimated, for it represents the
transition of forest biotechnology from minor to major league.
Fletcher Challenge Forests, International Paper, Monsanto and
Westvaco Announced 6 April 1999 and worth US$ 60 million over five
years, this joint venture is perhaps the best known of the three
forest-biotech consortia. The joint venture will seek to acquire
genomic forestry intellectual property rights from universities,
independent labs and others in order to position itself to market new
advances in forest biotechnology. Obviously, its main area of
interest concerns plantation species such as poplar, radiata and
loblolly pine and eucalyptus. Targeted genetic improvements are
herbicide tolerance, improved growth rates and product uniformity
(especially fibre quality). Of all three consortia, its primary
objective would appear to be the capture, application and marketing
of genetic patents.
Monfori Nusantra Established in 1996, this Indonesian company is a
joint venture between Monsanto and ForBio, an Australian plant
biotechnology company. The primary objective is wood fibre production
and a new automated plant that enables mass propagation of planting
stock from tissue culture has already been opened. The aim is to
produce 10 million seedlings per year. Five trial sites have been
established in Sumatra and Kalimantan, and initial results indicate
that the rotation for species such as teak, acacia and eucalyptus
could be halved. Little has been heard of the initiative over the
past year and its plans may have suffered as a result of the Asian
economic crisis. Nevertheless, the ForBio website still publicises
the relationship.
GenFor SA Announced on 10 March 1999 and worth an initial investment
of US$ 5 million, this is a joint venture between Fundaci>n Chile,
Interlink Associates (USA) and Silvagen Inc (Canada). The consortium
is partly financed by the Chilean Development Agency (Corfo) and
seeks to focus primarily on the development of transgenic radiata
pine that has enhanced pest and disease resistance, faster growth
rates and better pulping qualities. The first field trials of
transgenic radiata pine will probably be for resistance to the
European shoot moth and are due to start in early 2000.
3.1.2 Global
growth in GM-tree field trials
The first confirmed record of a wild release of a genetically
modified tree species is that of a poplar trial in Gent, Belgium in
1988. The first half of the 1990s witnessed a modest growth in
research trials that never exceeded five per year. However, over the
same period biotechnologists had extended their trials to incorporate
11 tree species, although they continued to focus on a narrow range
of traits, namely herbicide resistance and disease/pest resistance.
The latter half of the 1990s has seen an exponential increase in the
number of trials and in the number of species tested. In 1998 alone -
the last year sampled - there were 44 new trials, an increase of more
than 50 per cent on the cumulative total of all preceding GM tree
trials.
Figure 3.2 Number of new GM tree (timber & fruit) releases per year
3.1.3 GM tree species
There are now at least 24 species that have been subject to
transgenic modification and released into the environment, albeit
through controlled field trials. Table 3.1 gives details of the
species that have been modified and field tested, including the first
recorded year of their release. It is interesting to note that the
last three years (1996-1998) saw the number of trial species more
than double. Other sources have reported more extensive lists of
transgenic tree species, including almond (Prunus amygdalus), cocoa
(Theobroma cocoa), coffee (Coffea arabica), elm (Ulmus spp.), larch
(Larix spp.) and pear (Pyrus communis). However, no independent
verification of field trials for these species could be obtained, and
it is likely that some of these additional reports refer only to
greenhouse trials.
Table 3.1 GM tree species that have been released into the
environment through field trials.
Common name
Scientific name
First year of
release
*European aspen
Populus tremula
1988
American black
walnut
Juglans nigra
1989
*Poplar
Populus spp.
1989
Papaya
Carica papaya
1991
*Apple
Malus domestica
1991
*European sweet
chestnut
Castanea sativa
1992
Plum
Prunus domestica
1992
*Red river gum
Eucalyptus
camaldulensis
1993
Black spruce
Picea mariana
1993
Sweetgum
Liquidambar
styraciflua
1994
*European black
poplar
Populus nigra
1995
*Silver birch
Betula pendula
1996
American chestnut
Castanea dentata
1996
*Sweet orange
Citrus spp.
1996
*Tasmanian blue
gum
Eucalyptus
globulus
1996
*Norway spruce
Picea abies
1996
Pine
Pinus spp
1996
*Scots pine
Pinus sylvestris
1996
Acacia mangium
Acacia mangium
1997
Monterey pine
Pinus radiata
1997
Teak
Tectona grandis
1997
Flooded gum
Eucalyptus grandis
1998
*Olive
Olea europea
1998
Pine
Pinus spp.
1998
Eastern
cottonwood
Populus deltoides
1998
Quaking aspen
Populus
tremuloides
1998
*Cherry
Prunus avium
1998
(?Denotes modified species grown in Europe)
3.2 GM TECHNOLOGY AND FORESTS IN THE EUROPEAN UNION
There have been 31 releases of GM tree species since 1988 in the
European Union, distributed among eight member states (Belgium,
Finland, France, Germany, Italy, Portugal, Spain and the United
Kingdom). The EU holds a comprehensive database of transgenic
releases and member states are obliged to update it. The vast
majority of trials have been initiated by either academic or state
research institutions. However, three private companies, Shell
Forestry, Zeneca Ltd and Stora Celbi have also established trials.
Environmental activists destroyed two of Zeneca's poplar trials at
its site in Jealott's Hill in a recent protest attack.
Approximately 40 per cent of the trials have been designed to
evaluate marker genes (a genetic modification of an organism so that
it produces a substance not occurring naturally by which the presence
of the novel gene constructs can be traced), while a further 25 per
cent examine herbicide tolerance. Other traits being investigated
include male sterility, enhanced growth, lignin modification and
insect and disease resistance. With the exception of Eucalyptus
camaldulensis and E. Globulus, the other 11 species are either native
to, or have been naturalised within Europe. Among these are poplar,
olive, birch, Norway spruce and Scots pine. Two thirds of all
releases have occurred since 1995.
3.3 GM TECHNOLOGY AND FORESTS IN CANADA AND THE US
By far and away the largest number of GM tree releases via field
trials has taken place in the United States and Canada: 61 per cent
of the worldwide total. Between 1998 and 1999, 71 confirmed releases
have taken place. Like the European Union, the USDA maintains a
comprehensive database that contains information and status reports
on all GM release applications (whether approved or denied). All but
one of the confirmed North American releases have taken place in the
United States, and by far the majority of these (over 56 per cent)
are located in Oregon, California and Washington State. Ten other
states, principally in the North-east, have also established trials.
Like Europe, the majority of trials are under the auspices of
government or academic research institutions, and only 13 per cent
are directly under the control of four private sector companies
(Union Camp, Westvaco, Weyerhauser and Monsanto).
Interestingly, compared with Europe, there has been a marked
difference in terms of modified traits. The majority of the releases
in Canada and the US have been designed to evaluate insect or disease
resistance (53 per cent) and herbicide tolerance (17 per cent). There
appears to be limited interest in traits such as sterility (4 per
cent), although engineered sterility is often used by GM proponents
as an example of how the industry has built environmental safeguards
into their trials. There is also a more limited species range being
tested than in Europe. Only eight tree species have been confirmed as
being transgenic, and of these three are fruit trees. Half of all
trials have been on poplar species, followed by American black walnut
(14 per cent). Four trials of Papaya have been released in Hawaii.
Finally, 80 per cent of all trials in North America have been
released since 1995.
3.4 GM TECHNOLOGY AND FORESTS IN ASIA AND OCEANIA
Asia and Oceania provide an interesting comparison with North America
and the European Union. Like Latin America and Africa there are
relatively few trials, but most are directly under the control of the
private sector. Of the 10 confirmed trials in this region, only 30
per cent originate from government or academic institutions. However,
this split should be interpreted with caution for there was not
sufficient time to make contact with reliable sources in China and
India. If there are GM tree trials under way in those two countries,
then it is highly likely that they are state-funded. There has also
been a sharp increase during 1999 (a year excluded from analysis as
it is difficult to distinguish between applications and established
trials) in applications for GM tree trials in New Zealand. These came
from an even mix of academia and the private sector.
Five tree species have been recorded as being modified: apple,
radiata pine, eucalyptus, teak and Acacia mangium. All the trials,
with the exception of an apple trial in Australia, have been
established since 1995. Another area in which Europe/North America
differs from Asia/Oceania is the type of traits that are being
tested: 41 per cent of trials are field evaluations for growth
performance while another 37 per cent are designed to test trees
modified for sterility. These two traits are compatible and, in some
cases, are being examined in the same field trial. In part, this can
be explained by the fact that ForBio, an Australian biotechnology
company that has pioneered total plant sterility, is involved in the
trials. It also reflects the fact that many of these trials are
explicitly commercial in nature.
In conclusion, it may be the case that GM tree trials are much more
extensive in Asia than are highlighted in this report. China and
India may well have a GM tree programme, while commercial production
of transgenic trees species may have already started in Kalimantan
and Sumatra. It is probably safe to conclude that GM tree trials can
be found beyond the confirmed reports in Australia, Indonesia, Japan
and New Zealand.
3.5 GM TECHNOLOGY AND FORESTS IN LATIN AMERICA
Latin America has only three reported trials of GM tree species
Eucalyptus globulus, Pinus radiata and Eucalyptus grandis, which are
limited to Chile and Uruguay. It was not possible to obtain
information from Argentina, but there is reason to suspect that GM
tree species field trials, supported by New Zealand's Forest Research
Institute, will soon be established there. Shell has applied for
permission to establish trials in Brazil but this is being delayed by
a conflict between state and federal government over GM releases.
Like Asia, GM trials are being financed and directly supervised by
the private sector. From confirmed reports received, there is no
government or academic involvement, although again it must be
emphasised that a comprehensive survey of the region could not be
carried out in the time available. The traits being examined are
lignin modification (40 per cent) and herbicide tolerance (40 per
cent).
3.6 GM TECHNOLOGY AND FORESTS IN AFRICA
Confirmed GM trials in Africa are limited to one in South Africa.
This is a pine modified for sterility and is financed and supervised
by Shell Forestry. However, unconfirmed information from other
sources indicates that this is not the true situation, and that the
industrial forest sector in South Africa (and possibly Zimbabwe) is
exploring the use of GM tree species. Furthermore, if specific
transgenic technologies were developed for southern Africa, it is not
unreasonable to expect that they would quickly spread to other
countries in the region.
In conclusion, more attention should be focused on ascertaining the
full extent of GM technology within the Asian, Latin American and
African forest sectors. While their contribution to the global whole
may appear modest, it is in these regions that private companies have
declared their intention to establish commercial GM plantations.
Conversely, it is anticipated that field-based research will continue
in North America and Europe for several more years before any
decision about scaling-up to commercial production is taken.
4 Regulations for the testing and commercial production of GM tree
species
Being based on OECD guidelines, the regulatory frameworks put in
place to oversee the experimental and commercial release of
genetically modified organisms are broadly similar in most
industrialised countries. The OECD published recommendations in 1986
concerning the safety of transgenic organisms, and although these are
not binding on any member state, they have influenced regulations in
many countries including Germany, Japan, the Netherlands and the US.
Conversely, many developing countries lack even an elementary
regulatory framework for genetic engineering, presenting an
opportunity to those multinationals that wish to invest in GMOs but
are restricted by regulations in industrialised countries.
In September a workshop organised by the Norwegian Institute for
Nature Research was convened in Trondheim on behalf of the OECD's
Working Group on Harmonisation of Regulatory Oversight in
Biotechnology to consider environmental implications of GM trees. Its
principal objective was to examine whether environmental
considerations surrounding genetically modified trees were
sufficiently different from those concerning other GMOs as to merit
the establishment of separate guidelines. The intended output of the
workshop was a set of recommendations on GM trees that would be
submitted to the OECD's biotechnology working group. The workshop was
important inasmuch as any recommendations produced could be included
in future OECD guidelines, and these could form the basis of national
regulations on GM trees.
A full assessment of the safeguards and loopholes provided by each
set of national regulations lies outside the scope of this study.
However, one area of concern is that all regulations for transgenic
species were designed principally to control the wild release of
annual and short-lived perennial agricultural crops. There has been
little consideration of tree crops and the biosafety issues that are
peculiar to them. While there is little direct evidence to suggest
that this situation presents an immediate environmental risk, it
makes good sense that governments should begin to deal with this
issue now rather than wait until an unforeseen problem emerges.
Central to the formulation of appropriate regulations for GM tree
crops are properly controlled, long-term field studies designed to
examine not only novel gene stability and transgenic behaviour but
also tree crop-induced fluxes in soil nutrient status and soil water
availability. The New Zealand Forest Research Institute has applied
to undertake a 22-year study of sterility in transgenic radiata pine
- but such long-term thinking is the exception rather the rule.
4.1 A BRIEF OVERVIEW OF EUROPEAN UNION REGULATIONS
In 1988 the European Union published a framework for the regulation
of biotechnology to help member states harmonise their own national
legislation. This led to the 1990 Directive 90/220/EEC on the
Voluntary Release of Genetically Modified Organisms into the
Environment. All member states have now passed legislation that is in
line with this directive.
Within the EU most of the responsibility concerning the release of
GMOs lies with the individual member state. It is its prerogative to
decide the character and extent of experimental trials that take
place within its national territory. Once a GMO release has been
approved, member states are then obliged to monitor its human health
and environmental impacts. Interestingly, consent for the marketing
of products consisting of or containing GMOs within the EU, or any of
its member states, can only be obtained from the Commission (shared
between DGIII - Industry and DGVI - Agriculture). Similarly,
transport of GM products within the EU is controlled by DGVII
(Transport).
Any company or institution wishing to undertake deliberate release of
a GMO must first submit notification to the competent authority
within the member state. This notification must include a technical
dossier that contains a full risk assessment and appropriate safety
and emergency response measures. In the case of the manufacture or
distribution of GM products, precise instructions and conditions for
use must be provided in the dossier, along with a proposal for
labelling and packaging. On receipt of notification, the national
authority is required to respond within 90 days. Each member state
must also the send the Commission (DGXI - Environment) a summary of
each notification within 30 days of its receipt. The Commission then
forwards these summaries to the other member states for information
and, where appropriate, for comment.
Within the past 18 months the Commission has proposed two important
initiatives on GMOs. The first, presented in February 1998 and
approved by the Parliament (subject to amendments) in March 1999, was
to review and amend Directive 90/220/EEC (governing the deliberate
release of GMOs into the environment). The proposal sought to:
1 make the procedure for granting consent to companies wishing to
market GMOs more efficient and more transparent, limited to a fixed
period and conditional of compulsory monitoring of health impacts;
and
2 make provision for a common methodology to assess the risks
associated with the release of GMOs into the environment and a
mechanism which would allow the release of any GMO to be modified,
suspended or terminated where new information on the risks of such
release became available.
Once the proposal is adopted, the Commission will be obliged to
consult the competent scientific committees on any question which may
affect human health or the environment upon the release of any GMO.
The second proposal sets out minimum requirements relating to the
genetic characters and external quality of forest reproductive
material marketed within the EU. Member states will be obliged to
develop a register of approved source material for tree species that
are planted commercially within its territory. Should the source
material be transgenic by nature, an environmental risk assessment
will be mandatory in line with standards laid out in Directive
90/220/EEC. Individual member states will then be required to make
this information available to the Commission and other countries
within the Union.
4.2 THE REGULATORY FRAMEWORK IN THE UK
Both the marketing and deliberate release of GMOs in the United
Kingdom is subject to the Environmental Protection Act and the
Genetically Modified Organisms (deliberate release) Regulations.
Release into the environment may only take place if there is prior
consent from the Secretary of State for the Environment and from the
Ministry of Agriculture, Fisheries and Foods.
Fifteen advisory committees have been established to assist the
government on various aspects of biotechnology. The Advisory
Committee on Releases to the Environment (ACRE) is responsible for
determining the safety of GMO field trials and the marketing of GMOs.
ACRE is required to assess each new application and provides advice
on the risks that it may pose to human health and the environment. It
will recommend to the government whether consent should be granted
for the application and the degree of risk management required as a
condition of release. ACRE has faced mounting criticism for its links
with the biotechnology industry, and in April 1999 the government
undertook to replace 10 of its 13 members in order to broaden the
committee's membership and restore public confidence.
The Prime Minister recently set up a new cabinet committee to oversee
developments in the biotechnology industry, with the aim of ensuring
that there are no gaps or unnecessary overlaps in the UK framework of
regulatory and advisory committees. As a result of its deliberations,
two new commissions have been created. The Human Genetics Commission
will advise on genetic technologies and their impact on humans, while
the Agricultural and Environmental Biotechnology Commission will
focus on biodiversity and other environmental issues associated with
GM plants and crops.
4.3 THE REGULATORY FRAMEWORK IN THE US
The agencies primarily responsible for regulating biotechnology in
the United States are the US Department of Agriculture (USDA), the
Environmental Protection Agency (EPA), and the Food and Drug
Administration. GM products are regulated according to their intended
use, with some products falling under the remit of more than one
agency. In the case of GM trees the agency responsible is the USDA;
however, where modified traits may have an environmental impact - for
example, insect resistance (Bt plants) or herbicide tolerance - the
EPA will also conduct a regulatory review.
The USDA regulates novel plant release through its Animal Plant
Health Inspection Agency (APHIS). Applicants for GM releases must
provide details of the organism, the genes transformed, their
products and the purpose of release. In the case of field trials the
experimental design and precautions against accidental escape of the
GMO must also be included in the application. APHIS may also demand
special precautions such as closed containers for transport to field
site and field cages to minimise the risk of pollen escape. APHIS
permits for release into the environment are usually issued or denied
within 120 days and during that time state officials will inspect the
facilities to determine security and operating conditions. Permits
for field trials are renewed annually.
Before commercialisation, genetically engineered plants must conform
to standards set by State and Federal marketing statutes. There are
no national requirements for varietal registration of new plants.
4.4 THE REGULATORY FRAMEWORK IN NEW ZEALAND
The Environmental Risk Management Authority (ERMA) controls the
development, import, testing and release of genetically modified
organisms in New Zealand. GMOs are regulated under the Hazardous
Substances and New Organism Act, the purpose of which is to protect
the environment and public health. Before granting approval for the
release of any GMO, ERMA must take into account the sustainability of
all native and "valued" plants; the intrinsic value of the ecosystem;
and the economic and related benefits to be derived from the product.
Applications for the development of GMOs in containment at
universities and research centres are defined as low risk
developments. In these cases ERMA can delegate approval to special
committees established by research organisations. The committees must
keep detailed records and report their actions to ERMA.
While the New Zealand regulatory framework is thorough in many
aspects there are also elements that give cause for concern - for
example, designated "low risk developments" are not publicly
notified. Furthermore, while ERMA may attach conditions on field
trials of GM trees, such safeguards cannot automatically be extended
to transgenic plantations approved for commercial production on the
basis that HSNO declares consent for general release as
unconditional. Therefore, ERMA has no control over future use of the
GM product.
4.5 THE REGULATORY FRAMEWORK IN JAPAN
Regulation of GM trees in Japan is the responsibility of three
ministries. The Ministry of Education, Sport and Culture controls all
experimentation in university research facilities while the Science
and Technology Agency oversees all other research in private sector
and "non-academic" institutions. Applications for commercial
production of GM trees must be addressed to the Ministry of
Agriculture, Forestry and Fisheries.
Before any GMO is released for field trials or commercial production
it must first be grown in a simulated environment and assessed for
biosafety. In the case of GM trees no minimum time requirement is
given for biosafety to be ascertained. Under these artificial
conditions GM trees are not allowed to propagate naturally or
influence plants in the outside area via pollen. There is
insufficient information to ascertain the strengths and weaknesses of
this regulatory framework.
4.6 AN OVERVIEW OF NATIONAL REGULATIONS
With the exception of the European Union, no other regulatory system
has made provision for the additional complications posed by the
long-term persistence of GM trees in the landscape. The feasibility
of managing gene flow and minimising the risks of genetic pollution
appear only to have been considered in the US and Japan, and only
under certain conditions. Nevertheless, even in these cases the risk
of eventual pollen release, due to either act of God or human error,
must increase significantly over time. Furthermore, the impact on
non-target organisms has not been satisfactorily addressed with GM
agricultural crops and - given the lifespan of trees - this issue
becomes more pressing.
Some of the regulations are decidedly short-term, allowing trials to
be strictly managed yet failing to make provision for the same
safeguards at general release. Perhaps most worrying is the fact that
while the regulations are rightly concerned with biosafety issues,
they tend to overlook the impact that fast-growing, long-lived plants
may have on-site productivity. While the prospect of horizontal
transfer of Bt genes into other organisms or genetic pollution
running rampant through wild relatives grabs the headlines, it is
likely that GM trees may first manifest themselves as a problem in
more mundane ways. GM super trees possess all the characteristics of
a good weed and risk becoming invasives, and very fast growing,
nutrient-demanding plantations operated on short rotations could
drive inappropriate plantation development.
5 Regulating the international trade in GM forest products
5.1 INTERNATIONAL TRADE IN GMOs
There are two main issues that concern GMOs in international trade:
the protection of intellectual property, and the regulation and
control in the movement of novel (artificial) life forms. However,
there are two sides to the intellectual property argument when it
comes to genetic material, and the way that it has been dealt with
illustrates the imbalances that pervade the global economic system.
5.1.1 Life form patents and intellectual property
The General Agreement on Tariffs and Trade (GATT) came into being in
1948 to encourage free trade. The main objective of its first seven
rounds was the reduction of conventional trade barriers, but at the
eighth (Uruguay) round negotiations were extended to include issues
such as the protection of life form patents. Obviously, guaranteeing
someone's right to benefit from the innovation that they have
invested in and developed is a key aspect of ensuring free trade, and
applies as much to plant breeders as it does to microchip
manufacturers. Rules concerning intellectual property were further
strengthened by the WTO under the TRIPS (Trade Related Aspects of
Intellectual Property Rights) agreement, helping to ensure that
companies holding patents on new life forms had exclusive worldwide
rights.
The current TRIPS agreement demands that all countries put
legislation in place to ensure the "effective" protection of plant
varieties, including trees. TRIPS went into full effect for
industrialised nations at the conclusion of the talks in 1995, but in
the case of developing countries full implementation was delayed for
an additional five years. Furthermore, under this agreement some
poorer countries were originally excluded from recognising life form
patents. TRIPS comes up for review in 1999 and there is mounting
pressure on developing countries to accept patents on life forms.
In August Kenya, on behalf of the African group of WTO members,
issued a proposal on TRIPS as part of the preparations for the
Seattle Ministerial Conference to be held November 1999. The proposal
asked for clarification that plants, animals and micro-organisms
should not be patentable. It also called for TRIPS to be harmonised
with the Convention on Biological Diversity (CBD) and the FAO's
International Undertaking on Plant Genetic Resources.
The call to harmonise TRIPS with CBD is important because it extends
the concept of intellectual property from the novel to the original
life form and thus broadens the issue of who should benefit from the
manipulation of genetic material. The CBD addresses intellectual
property with respect to the prospecting of biological material.
Article 15 of the CBD requires signatories to seek permission before
prospecting for genetic resources in a third country, and provides
for agreements to share the benefits of any resulting commercial
development. The CBD also encourages the transfer of biotechnology to
developing countries in order for them to make use of their own
genetic resources. However, key countries such as the US are not
signatories to the CBD and, unlike the WTO, the CBD does not have an
effective dispute settlement mechanism and is thus largely
unenforceable.
5.1.2 Regulating the international movement of genetically modified
material
The second big issue with respect to GMOs and international trade is
controlling the movement of GM material. Negotiations on a global
protocol to regulate international trade in GMOs broke down in
February 1999. The main reasons for failure was the insistence by the
Miami group of grain exporting countries led by the US, that
countries be allowed to export genetically modified commodities
without seeking permission from the importing country. The Miami
group also insisted that the protocol should not conflict with
existing trade agreements. EU member states along with most
developing countries and environmental groups wanted the protocol to
be an independent legal document. Developing countries were keen that
socio-economic impacts of GMOs be taken into account during any
assessment of their environmental risks, along with the provision for
compensation in the event of accidents involving the transport of
GMOs.
In response to the breakdown in negotiations, a few African countries
led by Ethiopia have now decided to take the initiative and introduce
national biosafety legislation. These countries are to be asked to
introduce legislation that would make it illegal for a country to
export genetically modified (GM) food without first seeking
permission from the importing country. The draft African legislation
also states that any person or organisation intending to export GM
food or use GM organisms in laboratory or field trials must first
carry out an evaluation of the risks to the environment, biological
diversity and human health. Such an evaluation must also include
socio-economic risks, such as the impact on jobs. Approval shall not
be given unless there is firm and sufficient evidence that the GM
organism, or the product of a GM organism, poses no risks to the
environment, biological diversity or health.
However, introducing Africa-wide legislation is fraught with
difficulties. One reason is that trade and foreign ministries in many
countries are not likely to support any proposed law that may
antagonise France - a country which maintains considerable influence
in the continent - or the United States. Furthermore, neither trade
nor foreign ministries are likely to agree to a set of measures that
mount a direct challenge to the international trading system.
5.2 WTO LIMITS ON PROTECTION OF
THE ENVIRONMENT AND/OR HUMAN HEALTH
The degree to which an individual country can restrict imports of GM
products is limited by WTO rules although Article XX of GATT allows
for measures that are necessary to protect public morals, human,
animal and plant life. "Trade Related Environmental Measures" (TREMS)
refers to any trade instrument aimed at protecting the environment.
But as WTO looks unfavourably on any restriction of trade, countries
that seek to apply high environmental standards must use very strong
scientific justification if they wish to limit the import of products
they consider an environmental threat. Furthermore, any limitations
must be based on the impact of the product and should not
discriminate on the means of production used. For example, if GM
timber could be proved to be a health risk - say by containing large
amounts of residual toxins - then trade discrimination would be
legal. Nut a country would find it very difficult to ban the import
of GM timber solely because it was worried about the impact that GM
plantations may have on the country of origin's environment. This
principle is know as PPM - production and process methods.
Environmentalists are concerned that in the rush to remove trade
barriers, it is becoming too easy to override national environmental
standards. In 1997 the US Environmental Protection Agency weakened
its regulations on contaminants in imported petrol in order to comply
with a WTO ruling that found such rules to be an unfair trade
restriction. The WTO tends to put the onus on the importing country
to prove that the contested article is unsafe.
The WTO does permit member countries to take precautionary measures
such as a moratorium when a government considers that insufficient
scientific evidence exists to allow a final decision on the safety of
a process or product. This of course runs contrary to the
precautionary principle. For example, Principle 15 of the Rio
Declaration states that where there are threats of serious or
irreversible damage, lack of full scientific certainty shall not be
used as a reason for postponing cost effective measures to prevent
environmental degradation. In this case principle 15 is at odds with
WTO philosophy.
At the end of November the WTO will meet in Seattle to consider,
among other issues, the accelerated liberalisation of forest product
trade. This will take place amid a series of continuing trade
disputes over environmental and health issues. For example, in July
1999 the US imposed $117 million of trade sanctions on EU products
ranging from truffles to bacon after the WTO ruled that the EU ban on
hormone-treated beef was in breach of its regulations. Furthermore,
the US Ambassador to the EU claimed that the Union is again on the
verge of breaching WTO rules over export restrictions on GM crops. A
moratorium on marketing GM produce has been declared by the
Commission until a tougher system of safety standards is finalised
and approved.
5.3 LABELLING GMOs AND FOREST CERTIFICATION
A potential trade dispute is set to develop over the issue of
labelling GM products in general, and transgenic food crops in
particular. Under the agreement on Technical Barriers to Trade (TBT),
labelling of certain products can be interpreted as a restriction to
trade and as such fall foul of WTO rules. The WTO TBT committee in
June 1999 discussed issues surrounding the EU regulation for the
labelling of GM corn and soybean. The US and Canada complained that
their exports of corn and soybean had been adversely affected by the
labelling requirements and that the EU measure was not based on a
clear rationale. Canada also produced a written complaint concerning
11 GM product labelling schemes operating in Australia, Japan, New
Zealand and Norway. Ottawa claims that such labelling schemes will
apply to foods that are essentially no different from their
conventional counterparts.
Product labelling with respect to the forest sector has also been
discussed. The United States International Trade Commission (USTIC)
is currently investigating conditions of competition with respect to
US forest product trade. Special emphasis is being given to forest
practices that may constitute trade barriers and distort domestic and
international markets in Asia and Latin America. As highlighted
earlier in this report it is probable that Asia and Latin America
will be the first major sites for GM plantations, backed by North
American capital. As part of the enquiry, evidence was considered on
issues relating to FSC certification and labelling. While the issue
of trade restriction due to labelling in the forestry sector is not
before a WTO committee, it is worth noting that this may be the next
step if it is felt that US forest trade is being adversely affected.
At present GM tree products are excluded from the FSC certification
process. Although many international forest product companies are
funding GM tree trials in Asia and Latin America, few have openly
declared a position on the commercial use of such trees. The
increasing popularity of certified forest products may be perceived
as a brake on investment opportunities in otherwise profitable GM
plantations, and large companies may start lobbying governments
to move against certification as a trade barrier. If such labelling
were deemed contrary to WTO regulations, would other companies now
reluctant to endorse GMOs go back on what they have declared publicly
and begin to use transgenic planting stock?
6 Conclusions: WWF's response to biotechnology in the forest sector
6.1 THE FUTURE OF BIOTECHNOLOGY
It is becoming increasing difficult to determine how the GM issue
will unfold over the next 18 months. Three months ago, this author
maintained that while "GM trees posed a risk to biodiversity
conservation, the main threat would continue to come from GM
agriculture". In the light of this scoping study, that statement,
while still probably true, cannot be taken as definite. Indeed, many
might argue that the whole GM issue is a "dead duck", that companies
have had their fingers well and truly burnt with the
commercialisation of the technology and will now leave it alone.
Recent reports that Monsanto is considering pulling GM trials out of
the United Kingdom would seem to indicate that the high-profile
campaign conducted by Greenpeace and others is set to result in a
decisive victory.
Such conclusions are ill considered, for while some biotechnology
companies have suffered a number of setbacks in recent months - most
notably from falling stock prices - neither the science of
biotechnology nor the opportunities to commercialise innovation will
go away. This has been recognised by many governments and may partly
explain why a populist British government has, on this issue, set its
face so firmly against a public which (mistakenly) believes that GM
food crops pose a greater health risk than BSE. Governments are sure
that biotechnology is one of the industries of the future and are
particularly anxious not to lose the "innovation" race to other
countries.
The prospect of a quick media victory in Europe against GMOs should
be treated with caution by the environmental movement. If Monsanto
decides to pull out of the UK it is unlikely that the company will
simply lick its wounds, sell off investments in biotechnology and
return to the agrochemical business. It is more likely that GM
technology will be driven more quickly into countries such as China
and Brazil. While Asia has become the focus for calls for labelling
of GM food products (Australia, Japan, New Zealand and South Korea),
China is reported as being more interested in the potential that
biotechnology holds for an agricultural system required to feed and
clothe over a billion people. Last year alone China is reported as
planting over a million hectares of GM cotton. More worryingly, the
Brazilian Association of Seed Producers (Abrasem) has estimated that
illegally imported GM soybean seed might account for up to 10 percent
of Brazil's upcoming crop. Brazil currently has a moratorium on the
commercial production of GM crops.
It is also important to realise that much of the apparent success
against the commercialisation of biotechnology is limited to food
crops. While the British press made much of Deutsche Bank's recent
prognostication that "GMOs are dead", what they failed to report was
that the same review recommended that investors buy shares in
biotechnology companies involved in the development and distribution
of non-food crops.
6.2 BIOTECHNOLOGY AND THE FOREST SECTOR
Although there is little to point to in the way of commercial
production, biotechnology has already made its mark on the industrial
forest sector. One can expect to see transgenic planting stock being
released some time within the next couple of years. Even if the
biotechnology/forest alliance picks up some collateral damage from
the GM food crop debacle in Europe, this will largely be irrelevant
as GM trees are probably set to make their commercial debut in Latin
America and South-east Asia. In addition to Chile, Indonesia and
possibly Brazil, the country to watch will be China. Its decision
earlier this year to call a moratorium on the logging of natural
forests and plantations in key water catchments has already had a
knock-on effect within the region. It would be highly surprising if
China has not already established a programme of research to help
make good its internal timber deficit.
While there are many similarities between the environmental threats
posed by transgenic trees and those from GM agricultural crops
(genetic pollution, invasiveness, effects on biodiversity and so-on)
there are also six important issues that have largely been ignored:
1 The time and location factor (ie trees as crops are long-lived
perennials often located in remote areas where constant vigilance
against unanticipated problems is difficult, if not impossible). GM
forests may be managed in the centres of origin or close to natural
species, increasing the likelihood of cross-pollination;
2 The effect transgenic trees will have on long-term site
productivity; and
3 the potential threat posed by international trade in transgenic
roundwood to forest certification.
4 Trees are likely to be keystone species in their environment and
support more biodiversity than agricultural crops.
5 Unlike agricultural crops, trees have not been subject to the same
degree of domestication and research, and current knowledge
regarding the biology and ecology of tree species is inadequate.
More independent research is needed into tree biology, forest
ecology and the time and location factor.
6 The vast majority of current field trials only examine the direct
effects of the manipulated traits. Wider questions concerning the
environmental impact of accelerated growth or completely sterile
trees are not considered, yet it may be that these associated risks
are more likely to occur (a common feature in the history of land
use intensification) and therefore pose the greatest ecological
threats.
The whole situation concerning GM labelling and trade is unclear at
present. It is therefore unwise to speculate just how a "three-way
tango" between international trade, certification and transgenic
roundwood might be played out, although it is well to recognise that
the band has already struck up the tune. It is clear that the FSC
will have to take the whole biotechnology issue very seriously over
the next two or three years. With Home Depot recently indicating that
it wants to source its timber from well-managed sources by 2005,
there may soon be pressure from all sides (not just the US Department
of Trade) for explicit reasons why the FSC precludes transgenic trees
from certification.
6.3 RECOMMENDATIONS
In May 1999, WWF formulated a position statement on GMOs. It called
for a moratorium on the use or release of GMOs until ecological
interactions are fully researched; transparent comprehensive
environmental impact assessments of planned releases; and properly
regulated monitoring and control of gene technology. The position
paper was considered and balanced. The following recommendations will
help resolve whether biotechnology has a role in the forest sector.
General
1 It is far too early to judge whether biotechnology can make a safe
and effective contribution to the forest sector. Governments should
therefore declare a moratorium on the commercial release of
genetically modified tree species until i) properly agreed national
and international safeguards have been put in place and ii) the
risks concerning the behaviour of both novel traits and modified
tree species, over time, have been fully quantified.
2 Governments and industry must pursue a more open and honest policy
on biotechnology in the forest sector. Transparency and
inclusiveness should be key features of both regulation setting and
supervision, and this can only be achieved through involving civil
society in a public debate.
International regulation
3 At the international level, governments should undertake to break
the deadlock on the Biosafety Protocol within the Convention on
Biodiversity. They should accept the Convention as the foremost
international agreement on GMOs and until more reliable information
is available international regulation must be of a precautionary
nature.
Research
4 With a few exceptions, there is a lack of knowledge concerning the
genetics, physiology and ecology of most tree species. In such
cases, modification of a tree species' genome must be complemented
by auxiliary research that addresses the basic biological gaps in
our knowledge concerning that species.
5 Continuing field trials must be re-designed to examine not only the
behaviour of the introduced trait but also the broader
environmental impact of the modified tree species.
6 Research must be continued over a sufficient period of time to
enable researchers to quantify risk throughout a standard rotation
period.