OPEN LETTER & SUPPORTING STATEMENT TO BE SENT TO CTNBio to STOP GE Trees and Support the call by Brazilian and Latin American groups to reject Genetically Engineered eucalyptus trees
FuturaGene, a biotechnology firm owned by Brazilian pulp and paper company Suzano, has requested authorization from the Brazilian Biosafety Commission (CTNBio) for the commercial release of its genetically engineered eucalyptus trees in Brazil.
A letter has been issued by Brazilian and Latin American organizations (including CEPEDES; Terra de Direitos and the Latin American Network against Plantations) to CTNBio to urge them to deny this approval. As the Brazilian Open Letter (attached below) explains, if approved, use of GE eucalyptus trees will aggravate the already well-known negative impacts that non-GE industrial eucalyptus tree plantations already pose to communities´ livelihoods.
We ask your organization to sign on to the statement below in support of this Brazilian letter, which will be sent to CTNBio, the Brazilian governmental institution in charge of authorizing the release of GMOs. Their letter expresses deep concern and urges the CTNBio not to authorize the commercial release of GE eucalyptus by Suzano/FuturaGene.
The Campaign to STOP GE Trees
including Biofuelwatch, Canadian Biotechnology Action Network, Global Justice Ecology Project, Indigenous Environmental Network, World Rainforest Movement
Letter Adressed To: Brazilian National Technical Biosafety Commission (CTNBio) – see statement below
We, the undersigned, have been informed that FuturaGene, a biotechnology firm wholly owned by the pulp and paper company Suzano, has submitted a request for commercial planting of its yield enhanced genetically modified eucalyptus trees.
Suzano/FuturaGene, as well as other companies like Fibria (ex-Aracruz) and ArborGen, have been conducting research and field experiments on GM Trees for years.
Suzano/FuturaGene´s interest has been to increase the productivity of their tree plantations. They argue that their new GM tree will result in a 20% increase in productivity and by doing so will increase “competitiveness and environmental and socio-economic gains through higher productivity using less land and therefore overall lower chemical inputs and lowered carbon release, as well as making land available for food production or conservation and enhancing the income of outgrowers.” (1) These myths do not stand up to real facts and are addressed below.
GM TREES WILL ADD TO THE PROBLEMS CAUSED BY INDUSTRIAL TREE PLANTATIONS, NOT REDUCE THEM
The use of faster growing GM trees in industrial plantations will exacerbate the already well-known negative social and environmental impacts caused by industrial tree plantations while introducing yet further impacts and knock-on effects due to the additional risks inherent to genetic engineering.
Industrial tree plantation companies have long promised that gains in productivity would lead to less land use. This is a myth. In Brazil, for example, where the productivity of monoculture tree plantations per hectare increased from 27 m3/ha/year in the 1980s to 44 m3/ha/year currently, the area covered by plantations has increased from about 4 million hectares at the end of the 1980s to more than 7.2 million hectares today. Historically, there is thus no evidence that in Brazil, increases in productivity led to less land being occupied by industrial tree plantations. A newly formed association, Indústria Brasileira de Árvores (Ibá), representing the Brazilian industrial tree plantation industry states that they intend to double the area of industrial tree plantations to 14 million hectares by 2020.
SUZANO SEEKS TO EXPLOIT NEW MARKETS FOR PLANTATION TREES
Suzano recently opened a new pulp mill in the state of Maranhão with an 1.5 million tons/year capacity. Huge areas of land covered with tree monocultures will be needed to fulfill Suzano’s wood demand for pulp, as well as for an added demand, in particular its plans to explore new uses of its wood with a project in the same state to produce and export wood pellets for energy production, to cofire with coal in the UK. The use of biomass for industrial scale energy production remains highly controversial, and its negative social, environmental and climate impacts have been documented widely. Both the pulp and wood pellet projects aim solely at profiting from new market opportunities, which is the mission of Suzano.
BRAZILIAN PEOPLE AND ENVIRONMENT WOULD PAY THE COSTS
While profits from this expansion accrue to Suzano shareholders, the social, ecological and economic costs as well as increased risk to regional food sovereignty and health will be borne by the Brazilian public, and local communities surrounded by plantations in particular.
Many and serious conflicts over access to land already exist, and living conditions of communities surrounded by Suzano’s operations have deteriorated to the point that communities are now struggling to guarantee their food sovereignty and are increasingly at risk of losing their territories (2) .
GM CROPS LEAD TO INCREASED APPLICATIONS OF AGROTOXINS
Further, there is no plausible reason to expect that the use of “chemical inputs”, including agrotoxins, will decrease as a result of planting GM trees. On the contrary, it will increase with the increasing occupation of land which is planned to take place and the intensification of growing cycles and the ensuing nutrient depletion of soil and land. Brazil, sadly, is already the world’s leading consumer of agrotoxins, causing injury to hundreds if not thousands of victims per year, putting further strain on already insufficient public health provision. Industrial tree monocultures, lacking biodiversity, and promoted at very large scale, will augment the application of agrotoxins by huge amounts. The argument used by the GM technology lobby that the introduction of GM crops—such as soy and maize—results in less use of pesticides and fertilizers has already been proven to be false. In countries including Brazil, Argentina, and the United States – front-runners in GM soy & maize production—research has shown not a decrease, but rather an alarming increase in the use of agrotoxins (3).
DAMAGING SOIL AND WATER SUPPLIES
Genetically modifying trees to make them grow faster, while planting them on a continuously expanding portion of the land in ever larger industrial tree plantations, will only lead to further depletion of soil nutrients and fresh water. This is especially true for eucalyptus trees, already notorious for their voracious water consumption, which has been shown to result in the overall drying out of surrounding soils, springs and waterways. Communities living around non-GM tree plantations within and outside of Brazil have already widely reported water shortage and soil depletion. The introduction of faster growing GM Trees will only further aggravate this situation.
UNEXPECTED NEGATIVE EFFECTS OF GM CROPS COULD BE EVEN WORSE IN GM TREES
Serious uncertainties exist with respect to the potential environmental and socio-economic impacts of genetically engineered trees. Unexpected effects have already been reported for GM food crops, including for example the proliferation of herbicide resistant weeds, the emergence of secondary pests decimating crops, altered fertility such as higher rates of outcrossing, as well as increased allergenicity. Given the long and often complex life-cycle of trees and their interaction with biodiversity, predicting the outcomes and impacts of GM trees is practically impossible. While eucalyptus is non-native to Brazil, it is widely planted, and contamination of non-GM eucalyptus trees by GM eucalyptus is another serious risk, although FuturaGene, paradoxically, welcomes it (4). Will it alter invasiveness, attract new pests, weaken or deter predators? Such questions have neither been asked nor are there data to provide answers. The catalog of risks is high.
Based on the history of industrial tree plantations and the introduction of GM crops in general, we object to and deny industry’s claim that society as a whole would benefit from the commercial release and planting of GM trees. Existing evidence points squarely into the opposite direction. The only benefit we see from this new high-risk technology with unknown future impact (and possible associated incalculable cost) is that of increased profits to Suzano’s shareholders.
WE URGE NOT TO AUTHORIZE THE COMMERCIAL RELEASE OF GM TREES
For the aforementioned reasons, scientists, lawyers and organizations around the world are calling for a global moratorium on the commercial release of genetically modified trees, due to their unknown but potentially severe social and ecological impacts and incalculable economic risks, which would overwhelmingly accrue to the public.
Therefore, the undersigned organizations and people wish to express their deep concern and urge the CTNBio not to authorize the commercial release of yield enhanced GE eucalyptus by Suzano/FuturaGene or by any other company that also has, or will present in future, a request for such a release.
To sign on, please send your name, organization and country to the following address: email@example.com before June 15th.
1- See FuturaGene web site at http://www.futuragene.com
Statement in Support of the “Open Letter to CTNBio”:
The Campaign to Stop GE Trees, an international coalition of 248 groups from 49 countries, founded in 2004, supports a global ban on commercial deregulation of genetically engineered trees (also known as genetically modified trees) based on serious concerns about their impacts on biodiversity and human rights. The Campaign supports the position expressed herein, in solidarity with Brazilian and Latin American groups, calling upon CTNBio to pay heed to public resistance to GE trees and reject Futuragene’s request for commercial approval of GE trees.
The Campaign is joined by the undersigned organizations from around the world that endorse the call for a global ban on the release of genetically engineered trees into the environment, as well as those scientists and organizations that are calling for a moratorium on the release of GE trees until they are proven to have no damaging social or ecological impacts. As no such proof of safety currently exists, but there is significant evidence to the contrary, the release of GE trees must be stopped.
It is, for example, well-documented that increasing the growth rates of plantation trees (as Suzano has done with their GE eucalyptus
trees) results in the rapid expansion of plantations, not the opposite. 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]
Additionally, in 2008, the UN Convention on Biological Diversity, to which Brazil is a signatory, called for the application of the Precautionary Approach regarding GE trees, and a comprehensive and transparent assessment of their long-term social and ecological risks prior to any open release into the environment. If CTN Bio approves the commercialization of the GE eucalyptus in question, this decision would directly contravene decision IX/5(1) of the UN Convention on Biological Diversity.
The decision IX/5 (1) of the UN CBD Conference of the Partiesfrom 2008 states <http://www.cbd.int/decision/cop/?id=11648>
The Conference of the Parties, Urges Parties to:
(r) Reaffirm the need to take a precautionary approach when addressing the issue of genetically modified trees;
(s) Authorize the release of genetically modified trees only after completion of studies in containment, including in greenhouse and confined field trials, in accordance with national legislation where existent, addressing long–term effects as well as thorough, comprehensive, science-based and transparent risk assessments to avoid possible negative environmental impacts on forest biological diversity; /
(t) Also consider the potential socio-economic impacts of genetically modified trees as well as their potential impact on the livelihoods of indigenous and local communities;
(u) Acknowledge the entitlement of Parties, in accordance with their domestic legislation, to suspend the release of genetically modified trees, in particular where risk assessment so advises or where adequate capacities to undertake such assessment is not available;
(v) Further engage to develop risk-assessment criteria specifically for genetically modified trees;
(w) Note the results of the Norway – Canada Workshops on Risk Assessment for emerging applications for Living Modified Organisms (UNEP/CBD/BS/COP-MOP/4/INF/13);
(x) Welcome the decision of the fourth meeting of the Conference of the Parties serving as the meeting of the Parties to the Cartagena Protocol to establish an Ad Hoc Technical Expert Group on Risk Assessment and Risk Management that is also mandated to address the issue of genetically modified trees;
(y) Collaborate with relevant organizations on guidance for risk assessment of genetically modified trees and guidance addressing potential negative and positive environmental and socio – economic impacts on the conservation and sustainable use of forest biodiversity associated with the use of genetically modified trees;
(z) Provide the available information and the scientific evidence regarding the overall effects of genetically modified trees on the conservation and sustainable use of biological diversity to the Executive Secretary for dissemination through the clearing-house mechanism;
/ Where applicable, risks such as cross-pollination and spreading of seeds should be specifically addressed.
We therefore support the call to CTNBio and the Brazilian government made by Brazilian and Latin American groups to reject the application of Futuragene to commercially plant genetically engineered eucalyptus trees.