We the undersigned, demand the USDA unconditionally reject ArborGen’s request to legalize genetically engineered (GE) eucalyptus trees (FTE 427 and FTE 435). [1]

The USDA must reject this GE eucalyptus tree and retract all outdoor field trials. Approval would be a precedent-setting action that could open the door to other GE trees such as poplar and pine that would impact regions all over North America.

There are far too many risks associated with GE eucalyptus trees including invasiveness, “explosive” flammability, fresh water depletion, destruction of native forests and biodiversity, harming endangered species and increasing applications of toxic chemicals.

Freeze Tolerant GE Eucalyptus Could Expand the Disaster of Eucalyptus Plantations

The devastating social and ecological impacts of plantations, especially eucalyptus are well documented and vast. [2]   ArborGen’s freeze tolerant GE eucalyptus trees could allow eucalyptus plantations to expand to new geographies around the world, impacting communities, forests and biodiversity in their path.

GE Eucalyptus Trees = Fresh Water Loss

Eucalyptus tree plantations use huge quantities of water and contribute to droughts.  In Brazil, Chile and South Africa, rivers are drying up and communities losing access to water due to eucalyptus plantations.  What water remains is contaminated with toxic chemicals used on the plantations. This disaster must be avoided in the Southeast US.

GE Eucalyptus Have Unpredictable & Irreversible Impacts

Unlike other GMOs, GE trees can live for many decades making it nearly impossible to assess their risks over their entire lifespan. In addition, genetic engineering processes cause mutations in the tree’s genome that can lead to unpredictable problems when the trees are exposed to environmental stresses like drought or disease. Forests are highly complex ecosystems, and the impacts GE trees will have on them would likely be unpredictable and irreversible.

GE Eucalyptus Trees are both Invasive and “Explosively Flammable”
Eucalyptus trees are documented as invasive in California and Hawaii and an expected invasive in Florida. The draft EIS acknowledges that this GE eucalyptus could become invasive. [3]

Eucalyptus are also notoriously flammable, especially in hot, dry conditions.  In 1991, eucalyptus trees contributed to massive wildfires in the Oakland Hills that burned 3,354 homes. Officials described the eucalyptus as “exploding” in the fires. California now spends millions each year to eradicate these invasive trees.

Planting invasive, water draining, explosively flammable GE eucalyptus plantations in the US South, where droughts have become a regular phenomenon, is a disaster waiting to happen.

GE Eucalyptus Trees Will Require More Toxic Chemicals

The toxic chemicals used on plantations contaminate air, water and soil, and poison people living nearby.  The USDA acknowledges that GE eucalyptus plantations will require even more toxic chemicals than existing pine plantations.

GE Tree Plantations Would Destroy Native Forests & Harm Endangered Species

ArborGen argues that GE trees would protect forests by growing more wood on less land. This directly contradicts the UN Food & Agriculture Organization (FAO). The FAO found that between 1990 and 2010, the amount of wood grown per hectare of land increased by 50%, while the land covered by plantations increased by over 60% [4].

Endangered species are especially threatened by this trend of destroying native forests for expansion of non-native GE tree plantations that cannot support wildlife.

USDA Must Apply the Precautionary Principle and Obey Public Opposition

When the petition for the release of GE eucalyptus field trials came out in 2013, public comments were 10,000 to one against their release. The USDA must both heed overwhelming public opposition and apply the Precautionary Principal. ArborGen’s dangerous GE eucalyptus trees must be rejected, and all field trials retracted.

NOTES

[1] Link to USDA APHIS Draft EIS of GE Freeze Tolerant Eucalyptus:
https://www.aphis.usda.gov/brs/aphisdocs/11_01901p_peis.pdf

[2] Link to documentation of impacts of industrial tree plantations:
http://wrm.org.uy/wp-content/uploads/2013/01/EJOLTplantations.pdf

[3] USDA APHIS Draft EIS of GE Freeze Tolerant Eucalyptus page 114

[4] According to the UN Food and Agriculture Organization between the years 1990 and 2010, the average yield of wood from plantations doubled, yet the amount of land occupied by those plantations increased over 60% from 97 million to 153 million hectares. [http://www.fao.org/docrep/013/i1757e/i1757e.pdf, Table 5.5, page 94]