COMMENTS NEEDED BY NOVEMBER 3 TO STOP GE PAPAYA IN FLORIDA!

Help stop the commercial planting of genetically engineered papayas in Florida and the mainland US -- the first major cultivated GE tree on the US mainland.

The US Department of Agriculture is accepting public comments between now and November 3, 2008 on a petition that would allow commercial growing and marketing of the first genetically engineered (GE) papaya trees on mainland US soil. If approved, this would remove all regulatory oversight of this GE variety by USDA of a virus-resistant papaya tree known as the Ring Spot Virus Resistant Papaya.

This petition has implications for all other GE tree species, as the USDA and the industry want to gauge what the public's reaction will be. It is critical that all concerned about the threat of GE foods and GE trees respond to this USDA petition. Several hundred field trials of GE trees have been conducted already, many for forest trees, such as poplar, loblolly pine, and sweetgum, that grow on millions of acres in natural environments across the US.

The USDA admits that this GE papaya will contaminate both organic and conventional non-genetically engineered papaya groves if it is approved. Since all commercial papaya trees are cultivars that are relatively cross compatible within the same species, Carica papaya, contamination via GE papaya pollen carried by wind, bees and other insects will infiltrate the papaya groves of organic and conventional growers. The proposed buffer zones between GE papaya and other papayas will not prevent genetic contamination from being spread by pollinating insects.

Approval of this GE papaya tree also further opens the door to the commercialization of GE varieties of other tropical and subtropical tree species. In Hawaii, a previously approved virus resistant papaya has caused extensive contamination of organic, conventional and wild papaya groves on most of the Hawaiian Islands in just a few years. This contamination has spread far more quickly than the USDA predicted in its initial assessment. Once native and cultivated papaya varieties are contaminated with transgenic pollen and the resulting seeds are planted, there is no calling it back.

[Sample comments to submit below.  Please add any additional comments of your own.]

1. Go to
http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=09000064806cf607
<http://www.regulations.gov/fdmspublic/component/main?main=DocumentDetail&o=
09000064806cf607>
2. Double click on Docket - APHIS-2008-0054  - at the top of the page.
3. Double click on small yellowish box directly below "ADD COMMENTS" in the right hand column.
4. Enter public commenter information. You may add attachments to document your concerns.
5. Double click on NEXT STEP under ACTION at page bottom to enter your comments into Docket.

The following comments are in reference to Docket No. APHIS-2008-0054. I oppose the deregulation of genetically engineered papaya trees for the
following reasons:

1. Genetic contamination is a serious and growing threat. Flowers and seeds in organic and conventional papaya groves will become contaminated with GE papaya genes via pollen transported by bees and other insects that travel many miles in search of pollen. The result is that organic and conventional papaya growers will lose their markets for non-GE papayas as DNA testing confirms the contamination, as it already has with GE papayas in Hawaii. An organic tree might remain organic itself, but the pollen, honey and seeds will be contaminated, and trees planted from the GE papaya seeds will bear contaminated fruit.

2. The approval of perennial GE papaya trees would be a dangerous precedent setting step by USDA, opening the floodgates for more GE trees including fruit, nut, ornamental, and paper-pulp and timber species, as well as trees engineered for soil remediation, and other traits. Approximately 80 species and varieties of trees are currently undergoing gene splicing research and development for commercial use. Many of these are native species vital to ecosystems in much of the US.

3. There are serious and mounting concerns about a broad range of health effects associated with consumption of GE crops, GE pollen, and GE-produced honey. For example, consumers may suffer allergic reactions due to unexpected toxins in GE foods. The GE papaya pollen may produce unintended effects such as allergic reactions in sensitive individuals and the USDA has not properly evaluated the potential for allergic reactions. The USDA has also failed to consider the potential for allergens or other novel substances in the GE papayas, GE papaya pollen, or GE papaya-produced honey to interfere with pharmaceuticals being used by consumers.

4. The papaya fruit, seeds, latex, and leaves contain carpaine, an anthelmintic alkaloid that could be dangerous in high doses to the heart (it affects myocardium directly) and the circulatory system. Carpaine is one of the major alkaloid components of papayas, and has been studied for its cardiovascular effects. The USDA has not fully evaluated the health effects of alkaloids such as carpaine and related alkaloids on consumers eating GE papaya, pollen, honey or fruit juices and foods containing GE papaya ingredients. The USDA has not fully studied whether the GE papaya trees produce a different alkaloid chemistry or overall phytochemistry compared to organic, conventional or wild papayas. Other papaya alkaloids and phytochemicals have not been adequately studied for their human health effects. This despite widespread evidence that the genetic engineering of plants can alter expression of genetic traits apparently unrelated to the intentionally inserted trait.

5. There are serious and mounting concerns about the genetic stability of the artificial gene combinations and the artificially inserted genes used in GE papaya trees. The USDA claims that the papaya ring spot viral resistance gene and other inserted genes are sufficiently genetically stable, but the testing has only been performed for approximately ten years and not the entire, decades-long pollen-producing life span of a papaya tree. Over the long life of a papaya tree, an RNA virus such as papaya ring spot virus is susceptible to many cycles of recombination, leading to the creation of new plant viruses that could infect a wide variety of plants. This can also occur with the viral DNA that has been inserted into these papayas.

6. The deregulatory petition completely ignores potential effects on bees and other pollinator species. Today honey bee colony collapse disorder known as CCD is a serious and growing problem for apiaries and bee-pollinated crops including in Florida where the GE papaya trees will be grown. Although unintended effects are common in GE crops (and are part of regulatory human health assessments), there is extremely little assessment of possible environmental impacts from unintended effects. There are no studies that would allow us to evaluate the potential hazards of GE tree pollen or GE papaya tree pollen for a variety of insects, or for consumers of honey. We also do not know how animals and insects that browse on papaya leaves might be affected.

7. The USDA's environmental assessment admits that the GE papaya readily hybridizes within its species Carica papaya. Thus, there may be a significant potential for gene flow into native perennial papaya varieties. GE papaya trees will be long lived, and capable of contaminating orchards and native papaya tree populations for several decades. One GE papaya tree will be able to produce thousands of GE seeds and extensive quantities of pollen, and will be capable of spreading fertile GE papaya seeds and pollen into the environment for many years. The petition did not adequately evaluate the relative fitness of GE papaya varieties as compared to native papayas; it is possible that the GE varieties would become more successful in natural settings, and out-compete non-GE varieties, as they have in parts of Hawaii. We challenge the USDA's spurious claim that contamination would be positive by reducing potential reservoirs for harboring the papaya ring spot virus in the wild; this claim is
not supported by any data.

8. There has been no short-term or long-term safety testing or feeding trials for toxicity or other adverse effects of the construct of eight genes inserted into the GE papaya trees. GE papayas have not been tested on animals, birds or humans for safety. Toxicity tests are necessary since unintended genetic effects are known to occur with gene splicing. USDA has ignored the need for scientific studies of gene splicing and for comprehensive studies of the environmental consequences of GE plantings since the USDA has not adequately consulted with the Food and Drug Administration or the U.S. Environmental Protection Agency for their regulatory input.