Public Comments Submitted to USDA on July 16th, 2006
Family Farm Defenders, a national grassroots organization based in Madison, WI with
thousands of members in all fifty states, strongly opposes deregulation of the genetically engineered plum tree.
Among our concerns are the following:
Organic and conventional plum growers stand to suffer lost markets both domestically and
overseas with inevitable contamination if genetically engineered plums are allowed to enter commercial production. It is well known that pollen can be transported by bees, other insects, and wind for many miles from its original source. The USDA's own study
recogizes that plum readily hybridizes within its species. As has already occured with the papaya industry in Hawaii, plum growers will be forced to bear the costs of criminal
trespass by unwanted pollen and genetic contamination with no legal recourse. This is an
undue economic hardship that should not be foisted upon responsible farmers.
Plum farmers and fruit consumers have also expressed concern about the possible health
threats from genetically engineered plums, since the plum pox viral resistance gene and
other inserted foreign genetic material are apparently not very stable. To date, safety tests and feeding trials covering the entire productive lifespan of a genetically engineered plum tree have not been done. At minimum, genetically engineered plums should be tested on animals for toxicity before they are deemed GRAS and declared fit for human consumers.
Worse yet, the plum pox virus is not even known to exist in the US and is thus not a
serious problem for the U.S. plum industry. It seems reckless to expose people and the
environment to a novel genetic organism as a "solution" to a nonexistent problem. Once
again, this seems to be another thinly-veiled attempt by agribusiness to impose a costly
patented variety upon farmers who can ill afford to purchase more costly inputs.
Our farmers involved in the honey industry are also very concerned that the USDA has not
adequately addressed the impact of genetically engineered plum pollen (or for that matter
genetically engineered alfalfa pollen) on bees and honey itself. No one knows what will be the long term impact on insect pollinators or those people who will end up consuming honey containing residual genetically modified pollen. The USDA is mandated to protect public safety first, and should be diligently upholding the precautionary principle in all of its decisions regarding genetically modified organisms.
Like the recent hasty approval of genetically engineered alfalfa (which is now being
challenged in federal court), the proposed introduction of genetically engineered plum
continues a dangerous precedent on the part of the USDA. Genetically engineered
perennials like alfalfa or plum are much more likely to trigger unforeseen environmental
impacts and human health consequences since they are biologically active so much longer
than annuals like corn or soybeans. Dozens of other genetically modified trees - spruce,
poplar, apple, etc. - are now in the research and development pipeline, and this approval
could accelerate their introduction without adequate risk assessments or environmental
impact studies.
Once again, we urge the USDA to reject this proposed deregulation and commercial
introduction of the genetically engineered plum.
