Environmental contamination via human-mediated releases has, until the advent of biotechnology, been limited to open, abiotic systems, i.e., water, air, soil. While organismal incorporation and ecological concentration of human artifacts, such as DDT, has posed a significant problem, this has been limited to the 'somatic' realm because parental contaminant loads (heavy metals, dioxin, etc.) are not passed from one generation to the next as inherited, DNA-based characteristics. Germ line or 'lineage' pollution, a phenomenon made possible by the relatively recent development of technologies that allow manipulation genetic material, presents the prospect of human-mediated contamination of a 'closed' biotic system, a phyletic lineage.
From a botanical perspective, lineages potentially affected by this process are those targeted for 'improvement' via plant biotechnology. They include the small subset of crop plant taxa, relative to the global flora, that have co-evolved with human populations for milleania to provide food and fiber for humans and significant range extensions/population increases for the plants, both domesticated and free-living elements of a given lineage. Human investment in these lineages has involved careful manipulation and stewardship by elements of each human generation, representing all racial groups, since the origin of agriculture - more than 10,000 years. If modern application of plant biotechnology should eventually produce a negative impact on these lineages, the economic cost with regard to both person-hours invested and current market dynamics, would be massive. In addition, given the nature of the contamination, prospects for correction or reversal of the problem are minimal.
As was the case with DDT, current application of biotechnology, pushed by economic/strategic forces, is proceeding as a global experiment and, as was the case with DDT, consequences will be evident as transgenes move in unanticipated ways to produce unanticipated results. However, as opposed to the DDT episode, those responsible approving commercial (global) release of transgenic plants must frame their actions within a context of risk assessment and regulatory activity.
This writer became part of process by reviewing a document produced by Asgrow Seeds, an element of the Upjohn Company. I was asked to review a petition the Asgrow petition. This request did not come from the federal agency responsible for biotech regulation, USDA-APHIS-BBEP. My response to this focused on the simple fact that this petition is a corporate document, designed to accomplish a well defined goal. I assumed, at this early stage of the game, that this fact would be evident to all involved with review/approval of the petition. This, however, proved to be incorrect.
The story of the Asgrow petition is described by a Notice in the Federal Register (13 December 1994). As indicated by this document, at every opportunity for public comment, the majority of those responding were not in favor of this release. This majority opinion was at least partially expressed by a press release from the Environmental Defense Fund.
Initial public response to the Asgrow petition forced USDA-APHIS to go through the motions of taking a closer look at biological issues involved. I contracted with USDA-APHIS, at their request, to produce a report that centered on a series of questions posed by USDA-APHIS. This report, designed to debunk factual errors, ommision of references, and bias 'spin' of the Asgrow petition, is provided on the pages that follow. While it had no influence on the final regulatory decision, it does provide an overview, using this taxon as a model, for the biological/historical dynamics of crop/weed genetic/phyletic interactions. It also helps set the stage - with a suite of foundation data - for a biological experiment, fully approved by the U. S. government, that is now underway.
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