Talk:RSB Criteria on Technologies

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PLEASE NOTE THAT THE PRINCIPLE ON BIOTECHNOLOGIES IS NOW DISCUSSED ON A SEPARATE PAGE HERE!

Contents

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Principle: "The use of biotechnologies for biofuels production should improve their social and/or environmental performance, and always be consistent with national or international biosafety protocols"

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Criteria content and Wording

First Draft Proposition of the RSB Secretariat:

  • The use of biotechnologies to increase crops yield should also result in a decrease of water consumption per (ha/kg of biomass/MJ of useful energy???? To be decided) as compared to the original consumption of the same crop used in a traditional way (On that, I agree that we need to discuss on the term “traditional”. We cannot mention “natural” species since all of them have been improved through crossbreeding). This criterion could come under the WATER principle
    • This is too technically difficult and restrictive to be applied in all conditions. I suggest we simply assert no additional water use for biotech crops, compared to conventional ones, preferably less. Kirk Leonard
  • Same criteria for fertilizers and pesticides.This criterion could come under the WATER and SOIL principles
    • Without naming names, yes, but since the large majority of biotech crops are pesticide-resistant, it should be clearly stated that crops that require chemical inputs or lead to increased pesticide use should not be used. They run counter to sustainability and environmental health. Kirk Leonard
  • Evidences should be provided based on sound long-term scientific studies (define how much?).
    • Oooh, tough question. I suggest, as a starting stake, that we require at least a year in greenhouse conditions and an additional four years in controlled field trials. Kirk Leonard
  • The use of GE crops should not represent an additional risk to the perpetuity of incomes for the farmers.
    • If you have looked at the deGrassi report I cited, you know this is a tough issue, too. It goes to the cultural, political and agricutural appropriateness of biotech crops. I would suggest a criterion simply stating farm incomes must be maintained or improved. Kirk Leonard
  • Gene flow from GE crops toward non-GE crops or wild plants must be avoided. Sterile GE crops can be used as long as farmers can be ensured of a perennial use of this crop.
    • Another tough one. Agronomists think they have nailed this one with buffer zones, but no one can control the wind. Is it enough to say GE crops must not contaminate other farmers' crops or wild plants? I still can't get comfortable with terminator crops because they create a perennial dependency which can be increasingly costly, subjecting farmers to the whims of sole-source suppliers of patented seeds. I can't document it, but I suspect that seed-saving and experimentation by farmers has led to improved crop varieties, adapted to local conditions.Kirk Leonard

Another participant's (Christian Hardtke) Suggestion:

  • biotechnology in processing biomass for biofuel production (i.e. at the microbial level, contained systems): "anything goes"
    • I agree that contained systems, and greenhouses in the instance of plants, are safer. "Anything goes," however is a stretch for me. I would suggest we refer to other protocols on biosafety that prescribe containment requirements for GE organisms. Kirk Leonard
  • biotechnology in upstream biomass production for biofuels:
    • That to me is a no-no because it gets back to GE contamination of other cultivated crops, wild plants, and trees. "Upstream" production using GE plants must meet the criteria suggested above. Kirk Leonard
    1. In open systems, case by case. For instance, I think it could make sense for cellulosic ethanol, i.e. engineering desirable cell wall properties into a sterile hybrid like miscanthus might be a good idea.
      • I don't understand this, but I think you are saying we shouldn't worry about non-food GE plants. I have to go into soil science mode here, which also provides an opportunity for me to note that changing one gene, let alone thousands in an organism or a plant is not an insular event. Genes live in an interactive system and changing one can change the entire system... we don't know very much about that at this point and should therefore be most cautious:). There are hundreds of thousands of soil organisms, which live and interact with plants in ways we barely understand yet, probably 98% of which we haven't even studied, or named:). We get the basics, but all we may know is the phyla, maybe the family when we look through a microscope. When we modify a gene in a plant, we have no idea what the corresponding effect will be among soil organisms, or what kind of changes we may be introducing into the soil ecosystem. I wouldn't want to be running out there planting this GE misacantus quite so readily, at least until we'd had a chance to observe it in a greenhouse, and then in the soil conditions we propose to put it in. Just my bias, I suppose... assessment of the effects of GE plants should include soil ecosystem effects. Kirk Leonard
    2. In contained systems (microalgae): "anything goes".
      • What is "microalgae?" Once again, I agree that containment is better, but "anything goes" is hard for me to accept. What happens if I get it under my fingernail, it ends up in my sink, and eventually clogs the whole sewer system?:) Kirk Leonard
  • Generally, however, I think that for biomass production, GMOs are not an imminent necessity. In all cases of GMOs for biofuels, a clear environmental benefit must be demonstrated, since this is the primary reason for biofuel production.
    • I agree without qualification. Go organic!Kirk Leonard

For an RSB principle on biotechnology utilized in biofuel production:
Biotechnology, or any technology used in the production of biofuels should improve the environmental safety and performance of biofuel crops, and always be consistent with national laws and international protocols. (As a citizen, I hope and expect that when a Democrat is elected US president, the US will ratify and sign the Cartagena Protocol...;). The criteria we have advanced -- less use of water, fertilizers, pesticides, and the maintenance or improvement of farm incomes -- should stand. (Aside: I would note an apparently new biotech trick, from a checkbiotech article today... an application for carbon credits for GM rice in China...because it reduced synthetic fertilizer requirements. While that appears to be a good thing, it also appears that the level of fertilizer use was already way too much, caused by extraordinary cropping requirements. Off our path, somewhat, but I have to say that carbon credits to correct a situation that never should have happened seems inappropriate.)
Additionally, a criterion addressing the cultural, and agricultural appropriateness of new crop technologies is needed. No crops or GMPs should be marketed based on soil conditions, irrigation, mechanization, or processing capacities that are not in place. Absent these, the first three requirements will likely lead to crop failures and the latter to increased GHG costs due to increased transportation requirements. With respect to GMPs, on a case-by-case basis, for "upstream" crops, we should require:
1) A year of scientific research in a greenhouse, looking at the effects identified by Kowalchuk, plus productivity and gene flow characteristics.
2) Four years of scientific study in target environments looking for the same effects. Every country, state, province, environment and soil presents different host conditions.
3) Continuous monitoring for gene flows, persistence, and soil ecosystem effects (e.g., recovery, functional maintenance). We need more, cumulative information about what we may be causing to happen to the planet, and our soils, with what we grow!
4) Crops that depend on or require pesticide or chemical applications should not be supported.Kirk Leonard (January 2008)

  • I think the technology has to be judged on a case by case basis, thus we should avoid setting up rules that are too inflexible. My suggestion is that 1) and 2) should be replaced by a reference to the Cartagena Biosafety Protocol.
    3) is a very good suggestion that also makes sense scientifically.
    4) is a statement that is too simplistic in my opinion because of the points stated above. I think it should be omitted.
    Finally, I would also like to ad once more that as far as I understood, our task is not to define novel agricultural strategies. As I mentioned before, much of the current GMO debate is pertinent for biofuels as such (e.g. containment), but often very likely not in particular (e.g. herbicide resistance). Christian Hardtke (10th January 2008)

In reference to the first Virtual Meeting of the Expert Panel on Biotechnologies, Christian made a stong point that may have been overlooked when he said biotech will be essential for mazimizing biofuel values, and clearly he is in a position to know. That, to me, makes a principle clearly addressing biotech essential, since we also know biotech will be heavily marketed for biofuels. Kirk Leonard (11th January 2008)

  • Looking at the bigger picture of the principles, I have to conclude with respect to our teleconference that what is stated in the principles 1-10 already sets the stage that is applicable to any technology, including biotechnologies. The biotechnologies principle as it is stated now basically reiterates some of the other principles, turning things in round.
    So in the end, my answer to “biotechnology principle – unavoidable?” would be no, it is avoidable. Christian Hardtke (14th January 2008)
    • Whichever, biotechnology (at least for the fermentation part) is essential for maximizing biofuel value, though plant engineering might -or might not- be an absolute necessity. It is stil too early to say. On the other hand, biofuels might also be only a transient solution to the transportation problem: electricity would be a much more convenient energy currency: easy to transport, multiple ways of producing it, does not degrade the environment (well, if ones stays away from coal).Alain Vertes(15th January 2008)
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Knowledge Transfer and Farmer's dependencies

  • Let us not forget that the target is to encourage better practices throughout the chain of custody. Chains of custodies exist in all kinds of forms and set-ups, as do agricultural systems. Improvement is the key word here, and fair access to knowledge & ownership as well. As Christian rightly says: there are many GMO variants, and there is no single judgement to make there. Case-by-case is the right path. As long as access to knowledge and ownership is not monopolized, and as long as we seek (gradual) improvement on social, ecological and economical criteria, then we do a good job. We could even develop measuring rods with metric improvements, and give normative improvement schemes as precondition to, say, continuation of some sort of certification.
    For GMOs, the clue here is that we should avoid stimulating relations with increased dependencies. Avoid also a decrease in knowledge transfers. So, for instance, if farmers decide to shift from non-GMO to GMO (or if they are forced so by exterior factors), let us ascertain ourselves that the farmer keeps on mastering his farm, and - if possible - has even options to better practices. For instance, GMOs with terminators built-in to make the seed material sterile in order to enforce farmers to buy each year new plant material, obviously increases their dependency to the seed supplier, and should therefore be not allowed under the RSB BMPs. In the other hand, if for instance farmers suffer from diseases which are hard to control, but through improved biotech plant material this could be overcome, and if farmers hence would be stimulated to create their own nurseries and laboratories so as to be able to self-help them - such better practices should be stimulated. Especially in more remote areas where farmers don't have access to capital or knowledge, the RSB should stimulate the transfer of GMO knowledge and instrumentation as integral part of the principles.
    If we were to agree on these progressive steps, it makes sense to develop a methodological framework measuring continuous improvement, be it on organic agriculture, permaculture, moshpa non GMO, moshpa GMO, or even conventional plough driven, high input agriculture. A classification per system could be useful and based on that one could define gradual improvement steps, rather then having bottom lines to agree on.
    There is always space for improvement! Jeroen Douglas (18th January 2008)
    • What is moshpa?
      You bring up a set of important but difficult issues that we have touched on -- access to knowledge, technology, ownership, decreasing external dependencies, certification -- and which do need both implicit and explicit inclusion in our principles. I wish I was smart enough to suggest specifically how.
      As an admirer of The Natural Step, I like your notion of "progressive steps." Could you describe more a framework/classification system for measuring continuous improvement that we might be able to include in Environmental or Biotechnology criteria? Kirk Leonard (19th January 2008)
      • MOSHPA stands for MOdern Sustainable High Productivity Agriculture. It is a movement with many followers in US, Brazil, Argentina. The centre of the movement is the focus on no-till.
        Two more issues:
        a. knowledge transfer should be part of the criteria indicators. It is integral part of any best practice to spread the good news around and give support where necessary;
        b. Improvement schemes are tailor-made. I am not an expert on GMO, so I cannot answer that particular question at full, but I could give you an example. Modern soybean production uses a lot of RR soybean variants. The roundup ready kills about any herb (and insect), but the resistant RR bean. The use to it is glyphosates. Though not being extremely hazardous (according WHO), it would be a better practice to either applicate more secure (manually for instance), or do non-chemical weeding. This to avoid drift and tremendous overspill of the agrotoxic.The amount of glyphosates used is really incredible, so reducing this one way or another would be a better practice. And you could do some scaling there, giving improvement points.
        Hope this example is clear.Jeroen Douglas (19th January 2008)
        • Thanks, Jeroen. I'd not heard of Moshpa. Good acronym, great set of thoughts. Good to learn it's out there.
          I agree knowledge transfer is important and should be included in our criteria. I think we'll have to rely on open-source web sites for that, though. Current ag capitalism seems not to be interested in providing good information.
          With respect to the scaling of glyphosate, minimal use, from a soil perspective, seems important. Somehow, it's seen as low-impact, but all similar toxins and synthetic fertilizers are generally in salt forms ("-ates"), which cause soil organism death from osmotic shock (collapse of cell walls), guaranteed to seriously disrupt soil ecosystems. Some, critical organisms which stressed plants have to have can recover within a growing season, but the full community of organisms takes years to recover, from single applications!
          Said this before... RSB should not support biofuel crops which depend on or require agrotoxic inputs. The level of use is, as you say, incredible, and a better practice would be to stop it. No way are they sustainable. Kirk Leonard (20th January 2008)
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Hybrid technology

  • On the hybrids question:
    I think there is a little misunderstanding. Some hybrids are infertile, some others are not. In all cases hybrid seed tend to loose their productivity benefits when kept and reused. I think you will find lots of detail information in genetic and plant breeding literature. I think even Wikipedia is not too bad. I think the confusion comes because I made the comment in relation to the discussion about infertility to improve the environmental profile. I said that this would be a too controversial approach because it causes other social issues for especially subsistence farmers who want to save seeds for their own purposes. This is when I said that the issue is a little different with hybrids, because of the points mentioned above. Juan Gonzalez-Valero (16th January 2008)
    • Genetic engineering is already being used in biofuels, and undoubtedly will be used increasingly in second generation biofuels. The point of this intervention is to emphasis the point that GM crops are not sterile, which is why they are patented and why farmers must sign a contract not to replant seeds from their harvest. Technologies do exist for sterilising GM seeds, a technology that is called “genetic use restriction technology” (GURTs) by proponents and “terminator technology” by opponents. The Conference of the Parties of the CBD has regularly called for these technologies to be rejected, and the owners of the patents, which include the US Department of Agriculture, have pledged not to use them. We certainly do not need to go into such detail, but it is as well to be thoroughly informed on the issues.Jeff McNeely (18th January 2008)
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Benchmark (Biotechs compared to what?)

  • I think there is one aspect that has to be clarified to frame the discussion, maybe it has already been defined before I joined. This aspect is what do we refer to as a benchmark when we talk about benefits? I think the benchmark should be common agricultural practice, i.e the typical high intensity farming which produces the bulk of our food. If this is the benchmark, then we can more clearly define realistic relative benefits, rather than fictional absolute ones. Christian Hardtke (10th January 2008)
    • I am uncomfortable with the notion of comparing GM crops and "conventional" counterparts as Christian has proposed. Unless I am greatly mistaken, the large-scale degradation of croplands internationally has much to do with conventional, chemical-based practices.
      I understand that we live in a world where intensive agriculture means high-input, generally chemical methods, internationally marketed and used. I don't think that's inherently sustainable, and comparisons to that are of marginal, sustainable value.
      In the course of learning about genetic engineering in greater depth, I've come to believe it can be used safely, in concert with biology, so I suggest a more biologically-oriented baseline is most appropriate. Unlike the majority of GMPs used and marketed today, based on pesticide and other anti-biotic uses, there are efforts and some results that present greater natural harmony, as it were. I think the anti-biotic GMP efforts have been monumentally misleading, and that they will be regarded in the future, along with our petroleum economies, as odd -- as in "What were we thinking?"
      The baseline for comparison should be local or regional certified organic crops and soils. Kirk Leonard (18th January 2008)
      • Well, from a scientist’s point of view it can be simply frustrating to follow developments like these. There are surely various reasons to adopt GMOs or reject them, but they should be openly stated and not hidden behind pretexts, and acknowledge the scientific evidence, not turn it upside down.
        As GMOs are a highly complex and technical topic, their judgment also requires specific competences, something that I believe is also relevant for our discussion. For instance, regarding the table Sebastien distributed, I strongly believe that the first points should be replaced by a reference to Biosafety legislation. I do not think that we have the competence to arbitrarily define such things as time lines (1 year greenhouse, 4 years in target environment). Unfortunately, our discussion has so far been very focused on current GMOs, we do not know what is to come in biofuels and whether or not this will take longer or shorter safety procedures. The case by case approach might also be the key here, it could for instance depend on the length of a crop’s life cycle.
        The same thing goes for organic farming. I don’t think we’re in a position to arbitrarily define this as the baseline. Another aspect in my opinion is that our recommendations should be realistic to have some impact. I think the wording we elaborated in the teleconference, something like “compared to the prevalent local agricultural practice” takes this into account.
        Just by interest, would Miscanthus or Switchgrass culture qualify as organic farming?Christian Hardtke (18th January 2008)
        • Switchgrass is used organically in the US, by the way, often in damaged land recovery. I don't know about miscanthus, but yes, I think both can be used in organic regimes. Switchgrass lends itself to organic practices because it improves soil and requires few inputs once established, which can easily be done with organic inputs. I can even feature that GM variants could be grown organically, hmm?
          A "silver lining" I am seeing emerge with biofuels is that many of the feedstocks are suitable for marginal and damaged lands, and are not food crops. Naming them in our criteria seems a potentially good idea.
          I agree that the 1-year/4-year suggestion I made may be inappropriate. I put that out just to set a stake, seeking some boundaries around GMP releases, agreeing also that some may take longer or shorter periods of focused study, per the cropping cycle.
          The "biosafety legislation" I have seen is so complex and convoluted as to be incomprehensible and impractical. Which biosafety legislation? I have not re-visited the Cartagena Protocol yet. I will do that this weekend, see if it gets at what I am trying to get at.
          Alarm bells went off for me when I realized how little GMP soil ecosystem effects have been studied, which is also why I suggested soils of certified organic operations would be a better baseline, but I can live with comparisons to "local prevailing crops and soils," as well.
          As Jeroen has noted, the most important thing is continuous improvement, in progressive steps.
          Sustainability requires healthy soils. We have badly damaged many temperate croplands, and watersheds, with our intensive, chemical agricultural practices. Organically cultivated soils are healthier and better for watersheds. Would you not agree with this? Organic is realistic and an essential consideration, but I agree we cannot specify that. I suggested it for testing only.
          GMPs have to be held to a standard of soil improvement, in addition to the "less water, less fertilizer, less pesticides, greater efficiency and productivity" we seek for assessing ALL biofuel crops.
          How do we get there, simply, clearly and succinctly? Kirk Leonard (19th January 2008)
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Impacts of GMPs on Soil

  • WHY IS SOIL IMPORTANT?

The "green revolution" of the 1950's, and to some extent, the "biotech revolution" of the 1990's presented us the promise of increased yields, better food, fewer problems. In the US, it certainly brought us fewer farmers, but lower food quality. Both have ignored soil health and quality, a fundamental requirement of sustainable productivity. We are totally dependent on our soils for:
- biomass production;
- regulation of water quality and quantity;
- regulation of the recycling of nutrients and other elements, both within the soil itself and the Earth's biosphere as a whole;
- provision of mechanical support for living organisms and their structures.
This is viewed by some studies as including the support of man-made structures;
- carbon sequestration and regulation of carbon balance; and
- bioremediation of waste (the filtration, buffering, degradation, immobilisation and detoxification of organic and inorganic substances).(From "Mechanisms for Investigating Changes in Soil Ecology due to GMO eRleases" C. Cartwright, J. Kirton & A. Lilley, July 2004). The wondrous diversity of soils and their microbial ecosystems make all this happen, together with the plants we plant. I could say more. Do I need to? Kirk Leonard (10th January 2008)

    • Clearly, soil is more important than commonly recognized and affected by various treatments, from fertilizer to pesticides to herbicides. But this is true for "chemical" agriculture in general, whether transgenic or not. The studies have to address the chemical in the first place. Among the crops, there is again no reason to single out transgenics from a scientific point of view.
      This brings me to a side point I wanted to mention. A Swiss government-deployed life cycle analysis stated that 1st generation biofuels do not make sense for Switzerland. Instead, they supported the use of agricultural and household waste for biofuel production. This statement ignored that organic waste is largely used to produce humus to keep our soils productive. Diverting this waste to biofuel production would be highly detrimental to agriculture as a whole. I therefore think that somewhere it should be stated that biomass for biofuel production should be grown intentionally for this purpose.Christian Hardtke (10th January 2008)
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Existing policies and regulation

  • I had intended to get this to you earlier, but along the way, I discovered an excellent web site(www.checkbiotech.org) which I would recommend to all: provides a daily digest of news on both biofuels and genetics which I found distracting enough to delay this communication. They appear to be about as objective as anyone on biotech.

The soil ecosystem effects of genetically modified plants, GMPs (though more specifically and appropriately, genetically engineered crops), have not been adequately assessed. What I regard as a seminal report on 25 such studies (http://www.defra.gov.uk/environment/gm/research/epg-1-5-214.htm) presents scattered efforts, unfocused and inconclusive in terms of both soil microbiology and methodology.
I once again must express some amazement: Is it true that there is no international standard or protocol for the release of GMOs or GMPs into the environment? The only, somewhat arcane, document I could find, a "Manual for Assessing the Ecological and Health Effects of Genetically Engineered Organisms" (http://www.edmonds-institute.org/manp2pr.pdf) appears to have been ignored by the world at large.
Are there no legal international standard protocols or guidance for the release of genetically engineered organisms or plants into the environment?! Nothing we can refer to?
I realize this is well beyond the purview of RSB, but if this is the case, as least we might be able to establish something, albeit advisory, for biofuels. Kirk Leonard (10th january 2008)

    • I take it that you know all about the EU legislation on the deliberate release into the environment of genetically modified organisms and the contained use of genetically modified micro-organisms. This is the basis for all the GM plants that are evaluated in the EU. Kirsten Birkegaard Stær (10th January 2008)
      • Like Kirsten, I am not sure how to understand the question on regulations. I am sure you are aware of the Biosafety regulations inventory under CBD that, while not perfect, has a fairly comprehensive collection of regulations in place.
        Here the link: http://bch.cbd.int Juan Gonzalez-Valero (11th January 2008)
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Downstream vs Upstream use of biotechnologies

  • I think we have to explicitly split upstream and downstream. By this I mean GMOs to provide raw materials (plants) versus GMOs to process the raw materials (yeasts, bacteria, fungi, etc.). Since the downstream part happens in contained bioreactor systems, a lot can be done here. E.g., engineer Clostridium or Zymomonas genes for metabolization of C5 sugars into yeast to give superfermenting yeast; modify expression hosts for large scale production of biomass-degrading enzymes; etc. All this is bioreactor level, that's why I wrote "anything goes".

Regarding GMO plants, I do not know your background, so just in case here are a few considerations and clarifications:

    • First, I think that current practice of using food crops for biomass production is not sustainable. This is mainly because the high input needed for production severly impairs the environmental benefits of the derived biofuels. For instance, the energy intensive production of standard nitrogen fertilizer via the Haber-Bosch process will always significantly bring down the net life cycle carbon and energy balance of biofuel produced from such crops.
    • Second, there are reasons why food crops need so much input. These are mostly morphogenetic. For instance, our wheat varieties have been shaped by a strong evolutionary force of selection, the farmers. Compared to their wild ancestors, all cereals have been selected for more grains, bigger grains, and grains with elevated starch and, most importantly, storage protein content. Pushing plant productivity from carbohydrates to proteins means that the plant needs much more nitrogen input, since the relative nitrogen content of protein is much higher than that of carbohydrates.
    • Third, based on the above and other considerations, I think that only cellulosic biofuel is a realistic near-carbon neutral biofuel with highly positive energy balance.
    • Fourth, if the efforts concentrate on cellulosic ethanol, then conventional food crops are out of the game. Related varieties, such as highly productive primitive wheat races might be useful, but the focus is of course already on energy crops like miscanthus or switchgrass. Now importantly, if the latter are the main targets for genetic modification, then the conventional controversy around GMOs becomes to a large degree irrelevant.
    • Why? Because food crops have many shortcomings that are part of their selection history, while energy crops are still rather wild. The promise of GM technology for agriculture was to add back to the food crops what they had lost during the often 5000 year selection process: important variants of particular genes, for instance genes that help to battle herbivores, or genes that help them to survive adverse conditions. Plants like miscanthus or switch grass are by comparison genetically very robust.
    • Therefore, traits like herbicide or insect resistance will not be of equal importance when it comes to energy crops. Rather, genetic modifications will aim to make the cellulosic biomass produced by these plants more accessible for fermentation and thus biofuel production.
    • To some degree, this will probably favor cis-genic approaches, resulting in what some like to call cis-genic plants that should not be part of transgenic regulation. The article found by Tamara exemplifies this nicely. For example, probably we can find a tree species for biomass production. Unfortunately, the most productive variety is a hardwood variety, with the tough lignin type that has an extra covalent bond. In another, less productive variety, we might find a gene variant that cleaves the extra lignin bond. If we transfer this gene variety in the productive variety by biotechnology, we might produce a productive variety with softer wood that is easier processed downstream. Please note that biotechnology is imperative here. Breeding would take much too long, and one would likely lose the high productivity of the parent, because of the multigenic nature of the traits of interest. We would end up with a tree though, which although genetically engineered only contains genes from the same species (based on modern, marker-free production of genetically engineered plants), so no regulation needed.
    • A note on miscanthus: an excellent plant, a sterile hybrid between two species, we're combining thousands of genes (hey, is that legal??? ;) ) and throw the product out in the field. The beneficial effect on growth (hybrid vigor) is fixed, because the plant is sterile and can not redistribute the genetic information, we just grow it by cuttings. On top of this, it is a plant with a C4-type photosynthesis, thus much more water efficient (100-150g of water evaporated per 1g of carbon fixed, compared to 400-500g for C3 plants typically found in Norther climates). The only problem: we might end up with miscanthus monocultures, and although it is a tough plant, there is one pest that might cause problems. Potential biotechnology contribution: produce numerous miscanthus varieties by marker-assisted hybridization approaches, make cis- or trans-genic miscanthus to battle pests; outcrossing? Not possible.
    • Finally, Kirk, I surely understand your concern for the environment. But depending on the case, and herbicide resistant has always been the worst case, the environmental effects of single gene modifications, for instance on the soil community, will practically always be negligeable (even for herbicide or insect resistance genes, check some of the papers attached). Again, within the limits of careful case by case consideration, I cannot feel bad releasing plants modified for one or a few genes into our landscape. Non-endemic, ornamental plants are all over the place, this gene pollution has been going on for hundreds of years before transgenic plants were invented. So to say, transgenics cannot trigger an ecological catastrophe in places where it already happenened. But finally, in the case of genetic modification of energy crops, this might not even be a concern because of cis-genic approaches.
    • Regarding formulations, I favor formulating positive (should) rather than negative (should not) recommendations. Christian Hardtke (December 2007)
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Gene flow and other risks

  • I have read or reviewed 60 biotech research reports and articles, most from Christian, over 500 pages of studies. I have learned a lot and had a good deal of information confirmed.
    As I said in the prior email, it's clear scientists are enjoying biotechnology research (and I'm enjoying reading it, mostly:), but clearly, companies marketing biotech products are ahead of independent research, and regulators are behind the times. No surprises there, I suppose.
    Along the way, I found a useful, new acronym - GMPs - genetically modified plants. Instead of referring to GMOs and GE plants, which are distinct GE products, I will use GMOs and GMPs henceforth.
    For our deliberations, I go back to Christian's propositions from earlier emails, further encouraging and informed and "lively discussion," hopefully.
    I have to preface this with a statement of amazement. Many articles looked at herbicide-resistant GMPs, and a few at herbicide-tolerant GMPs. None apparently or appropriately addressed soil ecosystem effects. That is a serious deficiency, because without healthy, quality soil, what kind of agricultural productivity can we expect?
    Another amazing and sobering pair of assertions I found was worldwide, agricultural practices have led to 37-67% of croplands being "degraded." I would like to think that if we get our biotech and environmental principles right, we might be able to affect that. Onward....
    I stated concerns about GMP transgene flows. Per the set of studies I read, Christian is correct that it is rare, less than 1%, and with little annual GMP persistence. With respect to RSB biotech criteria, I still think it should be monitored, but is not major concern. I cannot say the same about horizontal gene flows, however. There is a bit more on that below.
    Christian suggested: "biotechnology in processing biomass for biofuel production (i.e. at the microbial level, contained systems): "anything goes."
    While I still have a problem with "anything goes," I trust that protocols for GMO containment and our colleagues at Genencor and Novozymes will ensure the safety and efficacy of this aspect of GE for biofuels will be appropriately addressed in our criteria. I am not as concerned about GMOs as I am with GMPs. They present a safer and potentially more productive set of applications.
    [An aside, however: Does everyone realize that GE is now virtually a desktop technology, apparently? I recently found a new proposed protocol from MIT (US), somewhat mindboggling, at www.jcvi.org/research/synthetic-genomics-report. This is a diversion, not worth reading except for those in the business probably, perhaps only a sign of how strangely paranoid my country has become, but useful to know of, I suppose.]
    Christian also said "biotechnology in upstream biomass production for biofuels" and "In open systems, case by case. For instance, I think it could make sense for cellulosic ethanol, i.e. engineering desirable cell wall properties into a sterile hybrid like miscanthus might be a good idea."
    I think he's saying "anything goes" again, but each crop should be assessed separately -- in target environments. Based on my reading of the materials Christian sent and other literature, I agree as long as monitored transgene flows remain below 1%, persistence is low, and soil ecosystem effects are tested before open system use; and in the instance of sterile hybrids, as well as non-sterile GMPs, they meet acceptable soil recovery parameters. Persistence and soil recovery are measures of what happens after a GMP is no longer planted in a given location. With sterile hybrids, presumably, persistence would be a non-issue.
    I still think a year in greenhouse testing and four years of controlled tests in target environments is a necessary minimum precaution.
    [Another aside: Craig Venter, a seminal genetic science pioneer, was interviewed on US public television last evening. He stated that "well under 1%" of biology (organisms, genes, their dependencies and interactions) is understood or has been studied. I know that to be true for soil organisms -- he was talking ALL organisms. The unknowns are vastly greater than what is known. Proceeding on a careful, case-by-case basis is the only prudent, responsible path].
    On pest-resistant GMPs, Bt being the most widely known, evidence has shown that they can reduce herbicide requirements, have good target and minimal non-target effects, and can produce improved yields -- when appropriate conditions (e.g., irrigation, soil types) are present. Bt cotton in India is an example of largely inappropriate marketing.
    As I said above, the soil ecosystem effects of pest-resistant GMPs are largely unstudied. Persistence of the toxin in soils and concentrations in watersheds have been observed, with unknown effects. A significant risk of horizontal gene transfer (HGT) has been identified, but largely unstudied, apparently. HGT effects, soil resilience (capacity to sustain production) and recovery characteristics must be studied more and understood better, as should their accumulation in watersheds.
    On herbicide-tolerant GMPs, the research I have seen is so tilted and inadequate as to be laughable. Kirk Leonard (January 2008)
    • Horizontal gene transfer is one of the most overblown potential risks in the GMO debate. First, ahorizontal gene transfer in higher eukaryotes in nature in real time remains to be demonstrated (studies in this area so far demonstrate horizontal gene transfers that have occurred in the distant (mya) past along the way of evolution).
      Second, the risk includes the assumption that the occurence of horizontal transfer of a transgene is somehow problematic as such or has some type of negative effect. Even if such an effect would exist in a individual case, the risk is laughable considering the gene pollution of our landscapes with exotic species that has been going on for centuries.Christian Hardtke (10th January 2008)
  • Any GMP that depends on or requires herbicide or chemical use should not be supported for biofuels. Enough environmental damage -- the annual "dead zone" in the Gulf of Mexico below the Mississippi delta being the most widely-known example -- has been done. The only study I have seen of soil effects, the NAS report I referred to above, is ominous, but not unexpected from a soil science perspective.
    In summary, GMP gene flow appears not to be a concern, GMOs are a safer and potentially better biotechnology to pursue, pest-resistant GMPs may present a viable alternative to other hybrids, and herbicide-tolerant GMPs are environmentally damaging and unsustainable. Kirk Leonard(January 2008)
    • I think this is too simple of a statement concerning a complex topic. I do not see why herbicide-resistant GMOs should be generally more damaging than regular crops. Considering for instance that the only approved herbicide in this area is a very good short-lived herbicide, overall chemical input in the respective GMO cultures is even less than in comparable non-GMO cultures. One thing to ad is maybe that of course farmers should follow the instructions.
      This brings me to another point. The reasons I could think of that would make herbicide-resistant crops unsustainable are the following:
      - spreading of monoculture
      - spreading of resistant weeds (which could lead to excess herbicide application by farmers)
      Strategies against those two points have been defined and might be to some degree effective (plant GMO as well as non-GMO varieties, give weeds a non-treated refuge to supress spreading of herbicide-resistance in the population, etc.).
      Beyond that, I believe however that antibiotics provide a useful analogy. I.e. let's say there is only one approved antibiotic on the market. It works well, becomes a big success, is used in hospitals all over. Over time, some bacterial populations develop resistance against the antibiotic, they persist, the populations spreads, soon the antibiotic cannot be used in affected hospitals any more. What is the solution now? Drop the use of "antibiotics technology" altogether and accept the loss of the benefits? Obviously, the historical answer is no. Development of more antibiotics, combined treatments etc. to circumvent those problems was (and remains) the answer.
      By analogy, we would not need less herbicide-resistant crops, we would need more varieties carrying a given resistance to avoid monoculture, and we would need a bigger arsenal of effective and potentially more beneficial herbicides and the corresponding resistance genes. Current GMO regulations suppress development of both areas, which makes the technology for now not viable in the long term.Christian Hardtke (10th January 2008)
  • I will propose a framework and criteria for evaluating GMPs as biofuel crops before our January meeting. Perhaps one of our colleagues will do the same for GMOs?
    A final query: GMPs for disease resistance, salt and drought tolerance, adaptation to degraded soils and soil recovery, have been mentioned in our discussions, as well as in what I have read elsewhere, but I have found little evidence of their development. Where are they in development? Who is developing them? Kirk Leonard
    • The answer is simple: hardly any one feels like it. With GMOs proclaimed dead by public unreason, plant scientists largely do not feel like it's worth investing their time into this (me neither).Christian Hardtke (10th January 2008)
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