Mounting Concerns: The Debate Surrounding Biotechnology In The Forest Sector Lara Vallely Summer 2002

Since the late 1980s, thousands of field-tests have occurred involving genetically modified plants in the United States. APHIS has approved over 3,000 environmental releases of GM corn, and 700 and 600 releases of GM potato and soybean respectively. Additionally, it has approved hundreds of field tests each for cotton, tomato, wheat, and tobacco plants. Field releases involving GM trees have occurred at a much lower level, although biotechnology in the forest sector has grown significantly since its conception. Numerous reasons, including technical problems, ecological, ethical, and political concerns, have functioned together to delay biotechnology�s impending role in forestry. Despite this slowdown, and to the dismay of many weary citizens, biotech has made a steady trek towards the research, testing, and, commercialization of GM trees across the globe. This paper will explore some of the concerns surrounding biotechnology in the forest sector, and attempt to answer the questions: �What�s different about trees to regulate them differently than annual agricultural crops?,� and, �Why have different protocol between trees and agricultural crops?� To do so, I will examine the environmental and political concerns of biotechnology in forestry, and attempt to make sense of the social debate surrounding the genetic modification of trees. First though, a look at the numbers-

A GROWING TREND

Since its conception, APHIS has approved thousands of releases and field-tests of genetically modified plants. Trees � primarily poplars � make up a fairly small proportion of these plants being released and tested. Of the more than 4300 plants that have been approved under notification or permit applications to be released, less than 100- or about 2% - are trees.¹ The following table gives a brief overview of the number of trees commonly used for timber in the US that have been approved for field-testing by APHIS. The last column represents the percentage of timber trees to total crops approved by APHIS.

Table 1: # of Field tests for Timber Crops by Date Range
(Source: http://www.isb.vt.edu/cfdocs/fieldtests1.cfm)

	Poplar	Pine	Walnut	Cottonwood	Total	Total # APHIS approved crops	% Timber Trees to Total Crops
1987-1991	1	0	2	0	3	181	1.7
1992-1996	3	0	2	0	5	2354	.2
1997-2001	52	15	8	7	82	4804	1.7
Total	56	15	12	7	90	7339	1.2

Although the number of GM trees that are released into the environment may seem minute next to the hundreds of agricultural crops that seek APHIS approval annually, there is, as one researcher noted, �Seeds of a quiet GM revolution being sown in the world�s forests.�² Field tests of GM trees have increased dramatically in the last decade � in the first 7 months of the current year 9 field tests of GM poplars averaging over 2 acres each have been approved. This is more than twice the number of poplars seeking APHIS�s approval between 1987-1996.³

This �revolution� has occurred, and continues to occur, not only in the United States, but increasingly worldwide. Although the US has carried out the majority of field-tests involving GM trees (61%), countries with confirmed field trials of GM tree species also include Australia, Belgium, Canada, Chile, Finland, France, Germany, Indonesia, Italy, Japan, New Zealand, Portugal, Spain, UK, Uruguay, and South Africa. Additionally, the vast majority of trees being tested (75%) are timber-producing species.⁴

The current trends among desired and expressed traits for GM trees include herbicide tolerance, insect resistance, reduced lignin content, sterility, fungal resistance, and increased growth rates.

Steven Strauss, one of the leaders of the forest biotech movement, noted the significant environmental and social concerns associated with GM trees, and the immense role these concerns will play in determining if this new technology will make its way towards commercialization and widespread publicly approved use.

The challenges to ethical uses of GM trees in forestry reside not in the process by which they are created, but rather in how their new characteristics and use will affect the environment and society. Substantial benefits have been documented in laboratory and field experiments. However, there are reasonable ecological and social concerns based on precedents from other kinds of agricultural technology. The key problems are deciding when our knowledge base is adequate, when there has been sufficient public discussion, and when there is adequate social consensus that the net effects for proposed uses are positive. If the process of public evaluation is scientifically sound and democratically rigorous, it should be possible to enjoy a continuing flow of new products from this rapidly maturing technology for the benefit of forestry in coming decades. If it is not, the technology may remain on the shelf in spite of its technical merits.⁵

I. Ecological Concerns:

Numerous ecological concerns and risks are associated with biotechnology�s merge into forestry. These risks constitute one of the � if not the greatest � delaying factors warding off the commercialization of GM trees. Environmental concerns, along with food safety, consumer choice, economic power, and the plight of small farmers, are also the basis for much of the social opposition that exists toward GM crops (which, ultimately, also functions to delay tree commercialization). These concerns, nonetheless, are likely the greatest reason trees have not applied, or reached deregulation status from APHIS.

Before specifically examining the different environmental concerns, it is important to note that the risks associated with these concerns exist on 3 distinct levels of GMO use:

1. Risks associated with research
2. Risks associated with the application of this research in limited field-tests
3. Risks associated with widespread and large-scale use of the results of research and field-testing.⁶

Table 2: Overview of Benefits and Concerns of Common Traits Deployed to GM Trees

Trait	Motivating Factors to Employ Trait	Associated Environmental Concerns
Herbicide Tolerant	Herbicide tolerance is one of the most common traits being tested in GM trees today. Of the 108 pines, cottonwoods, poplars, and walnut trees that were approved for field-testing, 1/3 of them (33) were genetically modified for herbicidal resistance (the rate is significantly higher for poplars - 40% of the 69 approved field-tests were for GM herbicide tolerant poplars)7 . This trait is popular because it enables growers to manage weeds quickly and easily.	A major concern existing about the employment of HT GM trees is Increased dependence and irresponsible use of herbicides. Water and soil contamination concerns exist also. Additionally, if HT GM trees escape into the wild, they will be much more difficult to manage.
Insect Resistant	Insect resistance allows resistance to existing and potential pests. The most common example is the insertion of a gene carrying Bacillus thuringensis (Bt) bacteria. Scientists add the Bt gene to the tree�s genetic material, enabling the tree to produce BT and create lifelong protection from targeted pests itself.	Bt is a wide-spectrum pesticide, and it is capable of affecting both target and non-target organisms (including beneficial species). 8 Pollen containing the BT gene undoubtedly drifts, resulting in increased pesticidal exposure to numerous insects. Reduced numbers of insect species � both target and non-target species � may disrupt forest food webs and ecosystem processes (including reduced populations of predators, parasites, scavengers, pollinators, and endangered or valued species). Other concerns exist that insects will develop resistance to inserted pesticides more rapidly than to those delivered by sprays.9
Reduced Lignin Content	During paper production, lignin is removed via an expensive process that is very polluting. Reduced levels would make this process, faster, cheaper, and less toxic.	Fewer and less intense concerns have surfaced over altered lignin content. Two relatively minor concerns are the disruption of wood decomposition by soil microorganisms and possible increased use of pesticides if trees are more susceptible to insect attacks.10
Sterility	Sterility would prohibit GM tree gene flow and contamination to neighboring unmodified trees. Many believe it should be a prerequisite to commercialization. Additionally, sterile trees would utilize more energy to growth, as no energy would be utilized for reproduction purposes.	Due to the complexity of gene interaction and the long life of trees, concern exists as to whether long-term sterility in trees could be ensured. Additionally, forest plantations may be the only refuge for forest-dependent insect and animal life in particular locations. Removing the reproductive parts of trees (flowers, fruits, and cones), negatively impacts these dependents.11

There are, inevitably, concerns associated with the general use of transgenic trees. Not associated with specific traits themselves, these concerns exist based on the natural characteristics inherent in trees, plantation farming, and silviculture management. The following is a brief overview. Special emphasis is given to how the concerns are stronger for GM trees than GM annual crops, and how these concerns are increased dependent on plot size.

The Time Factor

Increased concerns exist for trees over annual crops from their considerably longer life span. Inserting a gene into a host plant has a potential to impact the rest of the host�s genetic make up, which could have significant side effects. Such effects may be immediately identifiable, but others may remain �silent.� Because trees live longer, they are more susceptible to variable environmental conditions (climactic extremes, insect attacks, ect) than annual crops, which may trigger these silent genes, and cause new, unexpected, characteristics in the trees.¹²

One of the principle environmental concerns related to GM trees is associated with their long life span and field�testing. Annual agriculture GM crops are field-tested for several generations to determine genetic stability, extent of geneflow, and their potential invasiveness.¹³ If the same data and testing standards were applied to trees, field-tests could take 100s of years to complete � a very unrealistic and unlikely proposition. Currently, as the following table reflects, average time of field-trials for GM timber trees only covers a span of a few years, if that.

Table 3. Average Field-Test Length and Size of APHIS approved Trials of GM Poplar, Pine, Cottonwood, and Walnut Tree.
(Source: http://www.isb.vt.edu/cfdocs/fieldtests2.cfm)

Tree	Number APHIS Approved Tests 1987 to July 2002)	Average Field-Test Length	Average Field-Test Size (Acres)
Poplars	65	1 yr, 2 months	1.5
Pines	17	6 yrs, 8 months	0.25
Walnut	12	4 yrs, 7 months	1.9
Cottonwoods	7	3 yrs, 9 months	2.6

Challenges exist to guarantee GM trees do not pose unreasonable harm to the environment. Because trees are long-lived and have more complex relationships with their environment than agricultural crops, field-testing seems especially pertinent for forestry. But, as field-testing only occurs over a minute part of a tree�s life cycle, it will be difficult to acquire data relative to the amount of data received when testing annual crops. Because of this, �Establishing agreement about the environmental safety of releasing GM trees to the environment will pose more challenges than for GM crops.� ¹⁴

Intensifying Plantation Silviculture

There are several concerns related to the intensification of plantation silviculture. Shorter and more intensive rotations equate to increased water and nutrient demands and allow for less nutrient recycling. Together, these factors inevitably lead to a decline in site productivity. The latter is a particularly strong concern, especially for tropical countries, where a decline in site productivity results in increased fertilizer requirements, or more likely, land abandonment. The risk of land abandonment would undermine the toted benefit of transgenic trees � taking pressure off natural forests � as the land base that would be required to support plantation activities would be larger than anticipated.¹⁵

Location

Ecological and environmental impacts of GM trees are likely to differ depending on location and context. Location factors � make-up of surrounding land and the previous use of land where a transgenic plantation is placed � will greatly determine the negative and positive environmental implications of using GM trees on a commercial level.

Make-up of surrounding land � native species vs. exotics

Plantations of GM trees in the continental north � most notably Canada and the United States � will likely be made of manipulated tree species (poplar and pine) that were originally native to the plantation location. Accordingly, the surrounding tree populations will be made up in large part of wild genetically similar trees.¹⁶ This set up poses a significant risk of introgression of transgenic genes to non-transgenic plants.¹⁷ If surrounding trees are genetically similar enough to the transgenic trees of the plantation (which is the case in this scenario), the GM tree genes will be transferred to native unmodified species. This is especially likely, as the most common timber trees � pine and poplar � are pollinated by wind, and their pollen is often carried for numerous miles (estimates show pine pollen can travel 400 miles by wind). This is a concern of many, as �gene contamination� has the potential to irreversibly change the genome of a tree species and �Impact the ecological functioning of the entire forest in important, even if subtle, ways.� ¹⁸

Plantations in the south will likely be made up of GM exotic tree species. The primary environmental concern is that manipulated exotic trees may contain novel genes that allow them to escape, then thrive, and likely become invasive in foreign, previously, uninhabited territory. The potential to become invasive is exacerbated for GM trees, as traits like herbicide tolerance, increased growth rates, and insect resistance give them an edge over native trees.¹⁹

Initial Condition of Transgenic Plantation Land

The environment surrounding a transgenic plantation will be affected on two levels � from the transgenic trees themselves, and from the alteration of land into a plantation. Plantation effects (effects from vegetative species composition and stand structure in a tree plantation) directly influence biodiversity, as organisms are very responsive to vegetative composition and stand structure of their habitat. Although every scenario will be case specific, in general, biodiversity and land that previously existed as native forest would be negatively impacted by a transformation to transgenic plantations. For other initial conditions � including an existing plantation, agricultural field, or native vegetation � transgenic plantations have the potential to have negative, neutral, or positive affects on the land based on the plantation�s management. See the following chart for an overview. ²⁰

Table 4. Influences of Transgenic Plantations on Biodiversity based on Initial Condition of Land.
(Source: taken from �Biodiversity Implications of Transgenic Plantations,� John P. Hayes, http://www.fsl.orst.edu/tgerc/iufro2001/eprocd_27.pdf)

	Forested		Non-forested
Initial Conditions	Existing Plantation	Native Forest	Agricultural field	Native vegetation
Potential effects on biodiversity	Transgenic effects	Plantation effects + Transgenic Effects	Plantation effects + Transgenic Effects	Plantation effects + Transgenic Effects

Environmental Concerns Related to Regulation

Environmental concerns have surfaced over the commercialization of transgenic trees in regards to their regulatory process. These concerns, outlined below, have formed a backbone of distrust by some constituents with regulatory agencies. This distrust has helped heighten the social resistance towards biotechnology from average consumers, which, ultimately, factors to delay and impede upon the commercialization and use of GM trees in the US and other countries.

Perhaps the biggest concern associated with regulation is that deregulation is absolute. Before a GM plant can be commercialized, it must petition for a deregulated status. If granted, APHIS gives up all regulatory authority over the transgenic plant and its future offspring. Many, including an NRC committee reviewing the regulation of transgenic plants, disagree with the post-commercialization lack of monitoring.²¹

Other concerns over the regulatory process from an environmental protection perspective are rooted in the following factors:

• Environmental assessments should be interpreted as confined to the US � APHIS oversight is limited to how GM plants are moved and released in the US. Their procedures do not examine how plants will impact environments different than in the states, and accordingly, should not be considered safe and suitable in other countries because they were approved through APHIS regulation.
• Inadequate weed assessment � Plants passing through notification must not be considered a noxious weed in the location they are to be grown. APHIS relies on a single weed list to determine if a plant is considered a weed or invasive, which is likely an inadequate method to make this determination.
• There is no acreage limit for transgenic plants grown under notification or permit � This is a point of concern because often ecological effects are scale dependent and more likely to occur at larger spatial scales. Also, as plantings are larger, the scale of release increases�making it more difficult to check if performance standards are being met.
• APHIS assesses deregulation petitions largely based on environmental effects considered on small spatial scales, while potential effects from large scales are rarely considered. This is especially cause for concern, as commercialization typically entails scaled-up land space.²²

It is important to note that the concerns outlined above � related to specific traits, the general use of GM trees, or regulation � do not occur separately and independently of other concerns. For example, location, lifespan, and management affect the risk of gene escape and contamination. The complexity of relationships between trees and their ecosystem (insects, birds, other vegetation), and the fact that trees exist in �wilder� areas often farther from human supervision than annual agricultural plants, make analyzing these concerns and the risks associated with them more difficult.

IV. Social Concerns

The rise in the research, testing, and commercialization of GM plants has been accompanied by increasingly clamorous social resistance. Biotechnology united numerous movements and NGOs focused on a variety of social issues. Food safety, consumer choice, farmer�s rights, property rights, spirituality in a technological world, economic justice and global trade, corporate influence and economic justice, and hunger and the environment are some of the issues that have formed the backbone for the overwhelming opposition towards GM plants.²³ This opposition has had tangible effects: field trials of GM trees have been destroyed and organizations have been afraid to openly support a recent conference on biotechnology in forestry for fear of �retribution.� ²⁴ Numerous reasons�stemming from a conglomerate mix of ethical, political, social, and environmental issues�have resulted in the apprehension towards genetic modification of plants, and especially trees. This section will look at the socio-political factors that have helped shaped rising opposition.

Socio-political argument

Critics of biotech have seen the technology as a means for select corporations to increase their control over the world�s food system. As one researcher noted, for many opponents to biotechnology, the GM movement has functioned as a �token in a process of globalization that is intensifying the economic power of multinational companies and international capital.�²⁵

Tangible factors have lead to this perspective amongst those opposing biotech industries. Paul Thompson, an applied ethicist, has outlined 4 main events that have occurred that have likely shaped their perspective, and accordingly, resistance.

1. In the 1980s and early 1990s agricultural industries saw the potential profitability in genetic technologies. To benefit from the impending biotechnology revolution, they saw the need to �vertically integrate� the technology and discovery process.� This resulted in major seed, agri-chemical, and forest products companies consolidating.
2. At the same time, US patent law changed significantly. Patent rights over genes, gene processes, and whole organisms expanded. In the perspective of social activists, �bigger, consolidated life-science companies had new legal tools at their disposal for concentrating economic power and exerting control.�
3. The change in patent resulted in changing the relationship between industry and academic research also. Academia realized they would need industry partners to continue research in the �new era� of industrial patents. Some argue this process worked to �blur the distinction between research and development.�
4. At the same time, people began to associate the economic decline of rural areas and family farms with the trend towards bigger, more efficient, and corporate farms. The disenchantment with the loss of the family farm accompanied the change in perspective towards technology and agriculture with the green revolution. As Thompson noted, the green revolution �result(ed) in a considerable cooling of enthusiasm for productivity enhancing technologies in the developing world.�

Although all may not agree with Thompson�s assessment of events leading up to social-political resistance towards biotechnology, it is undeniable that such resistance exists, and that GM crops have been significantly stigmatized by its existence. Resistance has been destructive on very real levels to researchers. Several times field trials of GM trees have been vandalized. In March of 2001, GM trees being tested under the auspices of Oregon State University were destroyed. This event was the 7th of at least 6 other field tests that were vandalized in the US.²⁶ Vandalism has not just occurred on field trial plots or in the U.S. At the University of Washington, a laboratory was fire-bombed.²⁷ In England, 152 GM trees being field tested were destroyed overnight in 1999. At the time, they were the only GM trees being grown in Britain. A year earlier, a plot of GM apple trees was destroyed also.²⁸

V. Where to go from here

People with very different perspectives have clearly spoken on where the biotech movement in forestry needs to go. Those who support the movement and those who are weary of GM trees see progress and improvement through public debate, transparent regulation, and a continued dialogue amongst parties on all sides of the issue.²⁹ Ultimately, only through a transparent process and increased dialogue between different parties (industry, regulatory authorities, NGOs, and consumers) will these concerns be addressed and, hopefully, reconciled.³⁰

Notes

• Part One - US Regulatory Process For Genetically Modified Trees
• Part Two - Mounting Concerns: The Debate Surrounding Biotechnology In The Forest Sector