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We the undersigned oppose ArborGen's field trials of genetically engineered (GE) Eucalyptus Trees in Alabama.

APHIS has conducted an inadequate Environmental Assessement (EA) in which they recommend approval to extend the GE Eucalyptus field trials by ArborGen to allow this unprecedented flowering and seed formation of a genetically engineered tree species.

Other reasons we oppose the Alabama GE Eucalyptus tree field trials:

* Approval of this field trial represents precedent setting approval for the first outdoor field trial release on the mainland US of GE Eucalyptus trees that allow flowering and seed formation in young trees. Once this GE tree flowering and seed production is allowed on the US mainland, it will be easier for APHIS to approve outdoor field trial releases of other GE trees for flowering and seed production.

* APHIS failed to conduct and prepare an Environmental Impact Statement (EIS) to comprehensively address all relevant issues related to the proposed GE Eucalyptus field trials.

* Eucalyptus species are introduced organisms into the US and grow well in certain warm climates such as the southern and southeast US regions.

* Escape of GE Eucalyptus hybrids through seeds and vegetative plant material are quite likely due to severe wind and rain events which APHIS failed to assess in the EA. In other countries where eucalyptus have been introduced, they are well known for escaping and colonizing native ecosystems.

* ArborGen's Baldwin County, Alabama field trial site is prone to impacts from severe storm events such as tornadoes and hurricanes that could blow GE eucalyptus seeds over long distances.

* APHIS failed to evaluate these severe storm events in the EA and should have performed an EIS to fully review regional weather phenomena on the field trials location and document high potential for escape of the seeds and vegetative material of GE Eucalyptus hybrids.

* Global warming and climate change will allow more extensive southern and southeast regions of the US to have weather patterns conducive to the introduction and propagation of escaped GE Eucalyptus hybrids, which APHIS failed to consider in the EA.

* In regions where droughts occur, eucalyptus are known to be at high risk of catching fire. The Southeast US is currently in the midst of such a drought. Additionally, eucalyptus plantations have been documented to deplete ground water and cause or exacerbate drought situations. None of these potential impacts were evaluated in the EA.

* In recent federal court decisions on genetically engineered perennial organisms like the GE bentgrass and GE alfalfa, the courts have recognized the potential ecological threats posed by the escape of perennial GE organisms--even in field trials.