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Old 28-08-2003, 12:42 PM
Mooshie peas
 
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Default Bt pesticide resistance

On Thu, 28 Aug 2003 12:34:33 +0200, Torsten Brinch
posted:

On Thu, 28 Aug 2003 08:47:58 GMT, "Gordon Couger"
wrote:
..
When the someone lies about their affiliation with a university,


We've already dealt with that. Elaine Ingham has in fact
association with Oregon State University. You have not presented
evidence that she has overstressed or misrepresented her association
to the university in her evidence to the Royal Commission.

the publication of a paper


We've already dealt with that, too. The paper had in fact been
published, when Elaine Ingham referred to it before the Commission,
she did not lie about its publication.

and claims higher statistical certainty than they
have trials


That's just statistical mumbojumbo. It claims -what- _??_

and discard data without documentation


Again, you said data that did not agree with the findings
was discarded. -What documentation do you have for that?-

I don't look any further.


I did check my evaluation of the statistics of the paper because it had been
some time since I had worked through a statistical presentation and didn't
want to make an error.


Nice to know, but you know, that reads more like a diary entry.

What we are interested in here is -what- did your alleged
statistical evaluation consist of, -what- were your observations,
and -what- did you conclude based on that.

Any one of the improprieties she fostered on the Royal Commission is
inexcusable in total they constitute fraud. And the scientific community
and most of the press agreed.


If that is so, how come there is no meat on your alleged
improprieties?



Does this help?

=======================================
Evidence in Rebuttal - Life Sciences Network
20 February 2001, 9:24 am
Press Release: New Zealand Life Sciences Network

Evidence in Rebuttal

Rebuttal of written and verbal evidence presented by Dr Elaine R
Ingham (written brief and presentation to the Royal Commission on
Genetic Engineering, 1 February 2001).

Genetically engineered Klebsiella planticola: A threat to terrestrial
plant life?

Dr Christian Walter, Forest Research Institute Ltd, Rotorua, New
Zealand
Dr Michael V Berridge, Malaghan Institute of Medical Research,
Wellington, New Zealand
Dr David Tribe, Department of Microbiology and Immunology, University
of Melbourne, Parkville, Australia 3010


Executive Summary

This joint statement of evidence provides rebuttal of assertions about
the safety of genetic modification made in the witness brief and
verbal evidence presented by Dr Elaine R Ingham, on behalf of the
Green Party, and submitted to the Royal Commission on Genetic
Engineering on 1 February 2001.

In this rebuttal we detail scientific issues arising from the brief of
evidence and analyse conclusions drawn by Dr Ingham based on
scientific results published in cited reviewed papers.

The main conclusion presented by Dr Ingham is that a genetically
engineered Klebsiella planticola bacterium, if released into the
environment, has the potential to kill all terrestrial plant life on
the planet.

Her further assertion is that US authorities approved field trials
involving the modified bacterium with little or no understanding of
the ecological consequences and it was only as a result of independent
action by herself and a student Michael Holmes that possible
environmental disaster was avoided.

Dr Ingham cites a paper: Holmes, M. and E.R. Ingham. (1999) Ecological
effects of genetically engineered Klebsiella planticola released into
agricultural soil with varying clay content. Appl. Soil Ecol.
3:394-399. to justify reaching the above conclusions.

It is our opinion, having reviewed the published results of the
research undertaken by Holmes and Ingham, that Dr Ingham's conclusions
are not substantiated by that research, and are therefore
scientifically unsustainable.

Dr Ingham¡¦s assertions have been published widely on the Internet and
elsewhere. However, we have been unable to find any evidence that Dr
Ingham has submitted her assertions about threats to terrestrial plant
life to scientific publication in a peer-reviewed journal.

Our own literature search and resulting evidence further demonstrates
that natural alcohol producing varieties of Klebsiella planticola
already exist, and are routinely found in nature; however, no adverse
consequences of this alcohol production on any organisms including
plants have been observed.

We are presenting this rebuttal statement because it is our strong
opinion Dr Ingham has presented unsupported and inaccurate information
to the Royal Commission by incorrectly interpreting published
scientific information. We are therefore of the opinion that Dr
Ingham's assertions have no scientific validity.

Not only are we concerned about the scientifically unsupportable and
exaggerated assertions made, we are also concerned that a number of
other submitters have relied on those assertions to support their own
claims about the impacts of genetic modification.



Dr Ingham's assertions


1. In the late 1980's a bacterium, Klebsiella planticola, was
genetically modified to produce alcohol from post harvest crop
residues (Feldmann et al, Appl. Microbiol. Biotechnol. 31: 152-157
1989).

2. Following fermentation, the residue could have been available as a
fertiliser. (Ingham, witness brief)

3. Dr Ingham gave evidence that, under her supervision while an
Associate Professor at Oregon State University, graduate student
Michael Holmes conducted laboratory-based experiments on the
genetically modified Klebsiella planticola bacterium, after it had
been approved by the USEPA for field trials in soil with wheat plants.
(Witness Brief, Exec Summ. Para 2)

4. It was claimed this work resulted in a refereed paper, cited by
Ingham as: Holmes, M. and E.R. Ingham. (1999) Ecological effects of
genetically engineered Klebsiella planticola released into
agricultural soil with varying clay content. Appl. Soil Ecol.
3:394-399. (Witness Brief, Citation 1)

5. The conclusions drawn by Dr Ingham we
"h The GM organisms killed all wheat plants in microcosms into which
the organisms were added, and
"h none of the wheat plants were killed in microcosms into which the
non-engineered parent organism or just water were added. (Witness
Brief, Exec Summ, para 2)

Dr Ingham also stated that:

"h " With a single release, we know that bacteria can spread over
large distances, probably world-wide." (Witness Brief, Exec Summ, para
3)
"h ¡§The engineered bacterium produces far beyond the required amount
of alcohol per gram soil than required to kill any terrestrial
plant¡?. (Witness Brief, Exec Summ, para 4)
"h ¡§This would result in the death of all terrestrial plants, because
the parent bacterium has been found in the root systems of all plants
where anyone has looked for its presence¡?. (Witness Brief, Exec Summ,
para 4)
"h ¡§This could have been (in the case of release) the single most
devastating impact on human beings since we would likely have lost
corn, wheat, barley, vegetable crops, trees, bushes, etc, conceivably
all terrestrial plants." (Witness Brief, Exec Summ, para 4)

6. In her written witness statement to the Royal Commission, Dr Ingham
supports her conclusions by reference to the paper (Holmes and Ingham
1999), mentioned above.

Assertions relied on by other persons

7. The same reference to the Holmes and Ingham paper appears in:
http://www.safe2use.com/ca-ipm/01-02-05-report.htm and in:
http://www.safe2use.com/ca-ipm/01-02-05-study.htm, entitled:
Klebsiella planticola ¡V The Gene-Altered Monster That Almost Got
Away.

8. Further, this paper was referenced by many others. As an example,
see:
Green Party Submission (Section B(c) 2.13 para 39), and in
Genetic Engineering, Food and Our Environment: A Brief Guide. Luke
Anderson Scribe Publications Melbourne 2000. p 49-50 describes the
Klebsiella planticola work by scientists at Oregon State University.
Anderson claimed the experiments showed that the bacteria were able to
persist in the soil, and that once released would be very difficult to
eliminate.

Also, the evidence was widely reported in the NZ news media with
headlines like. "GM bacteria could kill all life - US expert" (Evening
Post and Christchurch Press 2 Feb 2001).


Rebuttal evidence


In light of the seriousness of the situation, we wish to make the
following points:

Non-existence of scientific paper relied on

9. A literature search conducted by the authors and other scientists
has established the paper mentioned in par. 2 as (Holmes, M. and E.R.
Ingham. (1999) Ecological effects of genetically engineered Klebsiella
planticola released into agricultural soil with varying clay content.
Appl. Soil Ecol. 3:394-399.) does not exist in the scientific
literature.

10. The 1999 edition of Applied Soil Ecology is Volume 11, not Volume
3.

11. Pages 394 ¡V 399 do not exist in volume 11, which has a total of
273 pages.

12. A literature search was conducted to assess whether the paper
cited by Ingham exists in another volume of Applied Soil Ecology or in
another refereed journal.

13. Biological Abstracts 1995-2000 does not contain this paper.
Searches on the internet (ISI¡¦s Web of Science and Entrez databases)
were unsuccessful. The paper referenced by Dr Ingham could not be
found.

14. When questioned in correspondence by Dr Sean Devine of the
Association of Crown Research Institutes, Dr Ingham stated that the
reference quoted was in error and that Michael Holmes was still
working on the paper. A request for a copy of the unpublished paper
has not been responded to.

15. The Executive Director of the NZ Life Sciences Network sought
information to clarify the position on 5 February. (copy of email
attached)

Assertions unsupported by research

16. In an email response on 9 February, Dr Ingham substituted the
following published scientific paper as supporting her witness
statement:
Holmes, M.T., E.R. Ingham, J.D. Doyle, and C.W. Hendricks. 1999.
Effects of Klebsiella planticola SDF20 on soil biota and wheat growth
in sandy soil. Applied Soil Ecology. 11: 67-78. The reply went on to
state that "This paper fully supports the conclusions and
extrapolations Dr. Ingham gave in her testimony. Even grade school
students can follow the logic." (copy of email reply attached)

17. No further papers by Holmes and Ingham on this subject (Klebsiella
planticola) were found despite extensive literature searches conducted
by individual scientists.

18. The substituted published paper refers only to the growth of one
genotype of spring wheat (Triticum aestivum L) in a particular type of
low organic sandy soil under laboratory conditions, un-inoculated or
inoculated with 108 SDF15 parental or 108 SDF20 genetically modified
Klebsiella planticola organisms (wild type Klebsiella planticola was
not used). Consequently, conclusions can only relate to these
conditions. To make a broad generalisation, such as that made by Dr
Ingham, appropriate experimental controls and more than one set of
conditions should be investigated.

Claim that Klebsiella approved for field trials by FDA incorrect

19. In her witness presentation to the Royal Commission, Dr Ingham
claimed that the genetically engineered Klebsiella strain had been
cleared by the authorities for a field trial experiment. ¡§¡Kfield
tests have already been approved by the USEPA by the time we did our
research. So, this microorganism was going to be released. What is the
logical outcome of releasing this engineered organism out into the
real world? We have never been able to bring back from a release like
this, an organism once it's released. The time we have to control is
before it's released out into the real world, and yet that organism
has passed all the different TSCA and USDA tests required to let it
loose¡K¡? (RCGM Transcript Page 3250 35-46)

20. Further, Dr Ingham claimed that all risk analysis studies to
satisfy the authorities were conducted before the application for
field trial was made.

21. It appears, however, that the research referenced by Dr Ingham has
never been in front of the relevant authorities in the United States.
The USDA (United States Department of Agriculture) database and the
ISB database (Information Systems for Biotechnology) have no mention
of any field trial application or granted approval relating to any
Klebsiella planticola research. No specific citations of docket
numbers or other proof of assertion have been offered by Dr Ingham.

22. Moreover, correspondence from Dr Janet Anderson (EPA, Environment
Protection Agency), and Dr Sally McCammon, Animal and Plant Health
Inspection Service (APHIS) (emails attached) indicates no record of an
approval for field trials of K. planticola as submitted by Dr Ingham
(Witness Brief, Exec Summ, para 2).


Relevant extracts from transcript

23. The following extract from the transcript of the Royal Commission
proceedings is relevant:

MS FITZSIMONS: ¡KI think perhaps - what we're talking about here, Dr
Ingham, is field trials and whether field trials should continue to be
allowed because they will increase our scientific knowledge. And, I
think it would be useful, perhaps, if you told us what you think the
effect outside the field trial plot could have been if that klebsiella
field trial had gone ahead.

DR INGHAM: The likely effect of allowing that field trial would have
been to destroy terrestrial plants, mainly because we have no way of -
with the regulatory testing that's currently allowed, doesn't test for
those ecological effects. We don't understand the ecology well enough,
even in a laboratory quite often, to do the appropriate testing that
we'd be able to predict what would happen in a field test. So, we're
running such risks, by pretending that we might know what would happen
in a field test, that we could unleash some really unpleasant effects
on the ecology of the world.

So, I think there is an inherent risk, a danger that we face in
allowing field tests, if we don't do a really good job of assessing
what's going on in the laboratory.

So, we have to back up and say, "you can't let things out of the
laboratory until we really truly can understand the ecology of that
organism and what it could potentially do out in the real world". We
don't understand that yet. It's going to be many many years before we
do.

MR HODSON QC: Dr Ingham, as I understand it, the fact that terrestrial
plants have not ceased to exist, means that the klebsiella would stop
at some stage where it was still contained and able to be stopped; is
that right?

DR INGHAM: It was not - klebsiella planticola engineered to produce
alcohol was not released out in the field; the field tests were not
allowed. And so, since we stopped that, we were able to keep it in the
laboratory. We wouldn't want to have done the field testing under any
conditions when we don't understand those organisms well enough to be
able to predict what possible effect they have out in the field.

DR FLEMING: Dr Ingham, this is Jean Fleming from the Royal Commission
speaking. Could you please describe exactly who made the discovery
about the growing of klebsiella - well, what happens when wheat was
grown in a field with - or in soil with klebsiella? At what stage did
this happen, and was this part of the regulatory system, please?

DR INGHAM: The testing that was performed by Fyfra(?) - TOSKA, AFIS
tests were to add the klebsiella planticola into duck food, into fish
food and daphnia into the water column with daphnia; and, none of
those tests indicate the effect on plants. We're not required to do
that kind of testing, genetically engineered organisms.

So, when we came along and started adding that organism to soil so it
could move into the root system of a plant, grow on the exudates
actually produced by the plant, and now start making alcohol in the
root system of the plant, an unexpected unpredicted occurrence
happened, which was seven days after the genetically engineered
klebsiella planticola was added to the soil; all of those wheat plants
turned into slime.

DR FLEMING: Can you tell me the connection between the work required
to allow this to go to field release, and the work that you've just
described with the soil and the wheat plants?

DR INGHAM: In different types of testing the first tier of tests are
those three tests that I've already described. Only if you see an
impact on the ducks, or the fish, or the daphnia, would you go onto
the next tier of testing.

DR FLEMING: I understand this, and I'm sorry to interrupt you, we're
running out of time. Was it the same people who were doing the tests
required for field release, that discovered the effect on plants? Or
were - was your group separate to the other group?

DR INGHAM: My group was entirely separate from those people doing the
regulatory testing.

DR FLEMING: Thank you.

CHAIR: Well, I'm sorry to come in here, but we need to clear this up.
Dr Ingham; now, I'm not a scientist, and I'm not clear in my mind
about this, but was what happened an unexpected result in the sense of
a recombination of organisms producing a new harmful bacteria? Or,
alternatively, was it a predictable result and the point is that it
slipped through a gap or a deficiency in the regulatory process?

DR INGHAM: The organism - the ecology of the organism was not well
enough understood for us to predict that effect. So, it was an
unexpected, unpredicted effect until you begin to understand the
ecology of that organism, and only in hindsight were we capable of
understanding what happened, and now guarding against those kinds of
effects.

This happens all the time with genetically engineered organisms, where
we do not understand the ecological, environmental effect of these
organisms until it's too late. We would see the same with that
nematode for the possums possibly. Once it's released out there into
the real world, when the field tests occurred and we got an effect on
non-target organisms, would we understand, possibly, that that was not
a very intelligent thing to do, allow that field test?

We don't understand the ecology of these systems well enough to
blithely forge ahead and assume we understand what's going to happen
with any of these organisms.

CHAIR: Yes, thank you.


Discussion of scientific bases for assertions

24. The research undertaken by Holmes, Ingham et al, which resulted in
the one published paper on the effects of a modified Klebsiella
planticola on soil biota was, however, partly funded by the EPA and
reviewed by the Agency prior to publication. (ref Acknowledgements:
¡§¡KThe research described in this article has been funded in part by
the US Environmental Protection Agency. This article has been
subjected to the Agency¡¦s peer and administrative review, and it has
been approved for publication as an EPA document¡K¡?).

25. In our opinion, the evidence in relation to field trial
applications presented to the Commission by Dr Ingham is false and
misleading.

26. The abstract of the substituted paper states:
" Further investigation is needed to determine the extent these
observations may occur in situ but this study using soil microcosms
was the first step in assessing potential for the release of
genetically engineered microorganisms to result in ecological
effects."
This statement recognises the limitations of the study and the need
for further investigation to relate the results to environmental
effect in the real world. These limitations were not disclosed to the
Royal Commission.

27. The parental SDF15 strain appears to be a pyruvate-formate-lyase
mutant of Klebsiella planticola. (Feldmann et al, Appl. Microbiol.
Biotechnol. 31: 152-157 1989). Pyruvate-formate-lyase is the main
enzyme in enteric bacteria in the anaerobic production of organic
acids. In related bacteria Escherichia coli (see review by J. Knappe,
Chapter 13 in Vol 1 of Escherichia coli and Salmonella typ(h)imurium
Editor F. C. Neidhardt, American Society for Microbiology 1987) and
such a mutation blocks a pathway for alcohol formation and causes the
cells to develop extra nutrient requirements (namely acetate) as the
mutation destroys the natural pathway of acetate formation. Acetate is
a vital building block for the cells. In Klebsiella planticola this
mutation demonstrably blocks natural alcohol and acetate formation
(Feldmann 1989). It is therefore highly unlikely that such a mutant
bacteria would have a chance of long-term survival in natural
ecosystems, let alone spread across the world. As a result of its
deficiency it would have a selective disadvantage in a natural
ecosystem. This mutant strain of Klebsiella planticola was genetically
modified by adding a pyruvate decarboxylase gene from Zymomonas
mobilis. As a result, strain SDF20 has been enabled to produce
alcohol, and it still retains the pyruvate-formate-lyase mutation.

28. As no wild-type control was included in the Holmes et al 1999
paper, we have no way of knowing whether or not the interference with
wheat growth was merely a result of large numbers of bacteria added to
the soil microcosms. A defective mutant, deficient in ability to make
alcohol such as SDF15 does not help in this interpretation.

29. The study assesses the persistence of the engineered (and
non-engineered) Klebsiella planticola in one particular type of sandy
low-organic soil, over a period of 8 weeks. Also, changes in the soil
flora (nematodes and wheat plants) are studied. Over the 8 week test
period, the numbers of SDF15 (parental) and SDF20 (GM) in both planted
and unplanted soil declined by 6 orders of magnitude (1 million-fold)
indicating that these organisms are incapable of surviving under the
conditions of the experiment. The survival curve did not reach a
plateau by 8 weeks and when the data are re-evaluated by log10/log2
plots, bacterial annihilation would probably have occurred by about 20
weeks. In contrast, active bacterial biomass did not decline
significantly over 8 weeks in planted pots (Fig 2b).

30. The paper fails to address the threshold of SDF20 required for
plant survival e.g. 106 SDF20 /gdw may not cause plant death and so be
a safe limit to test for use as a fertiliser.

31. These facts make any conclusions that the recombinant strain SDF20
has an unusual inhibitory effect on plant growth due to alcohol
formation impossible to substantiate, as the amount of wheat damage by
the wild-type Klebsiella planticola was not evaluated.

32. Holmes et al 1999 claim that Klebsiella planticola exists in
various soil types in nature, however they do not make reference to
naturally occurring numbers of this bacterium. It is unlikely that the
bacterial titer would ever be in the 108 /gdw range in nature and
SDF20 at 100/gdw would be highly unlikely to be toxic to plants.

33. The claim that these GM bacteria "can spread over large distance,
probably world-wide" (Witness Brief, paragraph 4) is not supported by
the evidence presented in the paper.

34. Bacterial species (for example Escherichia coli) generally consist
of strains or clones which may be adapted to particular ecological
niches ( ie they are ecotypes). This point is discussed
authoritatively in D. S. Guttman, Trends in Ecology and Evolution
(TREE) Vol 12 p16-21 (1997). In this paper Guttman discusses how
ecological population structure may explain the survival of many
different clones or strains in a species.

35. Hence it does not necessarily follow that because K. planticola
has been reported world wide, that a particular strain (eg SDF15 or
SDF20) will also occur in all or even many of these locations, as the
species K. planticola almost certainly consists of many different
ecotypes.

36. The claim that "these bacteria would get into the root systems of
all terrestrial plants" (Witness Brief, paragraph 4) is not supported
by the evidence in the paper.

37. The claim that "the engineered bacteria produces far beyond the
required amount of alcohol per gram soil than required to kill any
terrestrial plants because the parent bacterium has been found in the
root systems of all plants where anyone has looked for its presence"
(Witness Brief, paragraph 4) is not supported by the evidence.
Furthermore, the GM parental bacteria, SDF15, appears to be an
environmentally non-viable mutant derived from Klebsiella planticola
(Feldmann et al, Appl. Microbiol. Biotechnol 31: 152-157 1989) and so
would not be expected to form significant populations under natural
conditions.

38. The claim that "This could have been the single most devastating
impact on human beings since we would likely have lost corn, wheat,
barley, vegetable crops, trees, bushes, etc, conceivably all
terrestrial plants " (Witness Brief, paragraph 4) is not supported by
the evidence. Neither does such a statement appear in the published
paper by Holmes et al 1999.

39. Refer to 3.4, research around nematodes, and figure 4b:
After 3 weeks SDF20-soil has more nematodes than SDF15-soil. At week 8
(the only other data point after week 2) it is the opposite. Also, if
the lsd bar is taken into account, the differences between SDF15 and
SDF 20, and un-inoculated soil, do not appear significant.

40. Based on this lack of data, any claims relating to the effects of
non-engineered or engineered bacteria on nematodes are not supported
by the evidence in this paper.

41. Movement of genes such as those conferring ability to produce
alcohol into bacteria of the genus Klebsiella from other species
definitely occurs in nature, so that novel bacteria analogous to SDF20
are expected to occur naturally. (see for instance Lorenz, MG &
Wackernagel, W (1994) Bacterial Gene Transfer by Natural Genetic
Transformation in the Environment. Microbiological Reviews, 58-3,
563-602,)

42. Just one recent example of the extensive scientific literature on
this concept of gene mobility is given in a paper ¡§Horizontal gene
transfer among genomes: The complexity hypothesis¡?, R. Jain et al.
Proc. Natl. Acad. Aci USA, Vol 96 pp3801-3806 (1999), which states
¡?The extensive amount of horizontal [gene] transfer between
prokaryotes [bacteria] make it clear that horizontal transfer [i.e.
movement of genes between different bacterial species] must be a major
contributor to the evolution of genomes. The taxonomic breadth and
extent of transfer has been so vast that one can think of the
operational gene component of prokaryotes [i.e. all known bacteria] as
a single global organism.¡?
This recent quotation summarises current scientifically
uncontroversial consensus opinion, namely that genes readily move
between different bacterial species in nature.

43. The genus Klebsiella is a member of the family Enterobacteriaceae,
which includes also Escherichia and Salmonella well studied for their
ability to gain and lose foreign genes The recent paper
¡§Genome sequence of enterohaemorrhagic Escherichia coli O157:H7, N.
T. Perna et al Nature Vol409 p529-533 (2001),
has revealed this bacterium has inherited over 1000 genes from other
species. Gene movement between different genera of Enterobacteria can
be carried out by conjugation, or bacterial mating, and by viruses
that ferry genes between species. For example Table 5.2 of the
advanced text ¡§Infectious multiple drug Resistance¡? by S. Falkow,
Pion Press 1975 gives documentation of the movement of genes between
the genus Klebsiella and other Enterobacteriaceae by mating.

44. S. Falkow also states (p78) that genes are promiscuously
transferred among the members of the Enterobactericeae by mating
factors. Thus the mechanisms by which Klebsiella exchanges genes with
other bacteria were well known even in 1975. The alcohol genes in
SDF20 come from the bacterium Zymomonas mobilis. Mating between
Zymomonas and other bacteria such as Escherichia coli was first
reported in 1980 (see a review ¡§Alcohol production by Zymomonas
mobilis¡? P. L. Rogers, K J. Lee, M L Skotnicki and D Tribe: Advances
in Biochemical Engineering Vol 23 p37-84 (1982). Feldmann et al,
(Appl. Microbiol. Biotechnol 31: 152-157, 1989 (use bacterial mating
between Escherichia coli and Klebsiella planticola to construct strain
SDF20).

45. Klebsiella planticola SDF20 is genetically engineered to produce
alcohol. The authors claim that this novel feature has resulted in
changes in the soil microflora in their experiments, and death of
wheat plants. Alcohol producing genes are present in many bacterial
species and other microorganisms, and horizontal gene transfer can
theoretically transfer such gene into non-engineered Klebsiella
strains under natural conditions. As noted, horizontal gene transfer
is a common process in the bacterial world, and its significance for
gene exchange between species in a natural environment is an accepted
concept amongst supporters and opponents of genetic engineering.

46. The amount of alcohol produced in soil microcosms by SDF20 was 20
micrograms per milliliter (as measured by Holmes et al 1999). This
concentration is several hundred times lower than that required to
affect plant growth (10 milligrams per milliliter), as indicated in a
review by Jones, RP, Enzyme Microbio. Technol. 11: 130-153, 1989. No
data are presented to support any assertion that the wilting and
chlorotic effects noted on plants at 8 weeks are due to over
production of alcohol rather than any of the numerous possible
alternative explanations

47. At AgResearch in Dunedin, Jarvis et al. have isolated a Klebsiella
planticola strain from red deer (Jarvis GN, Moore ER, Thiele JH
(1997): Formate and alcohol are the major products of glycerol
fermentation produced by a Klebsiella planticola strain isolated from
red deer. This is a non-engineered naturally occurring bacterial
strain. It has the natural capacity to produce alcohol. The authors
state that fermentation of glycerol to formate and alcohol supported
the growth of the bacterial culture. Glycerol can be used by the
bacterium as sole carbon source. This is scientific evidence for the
existence of a Klebsiella planticola bacterium in nature, and which is
capable of producing alcohol. Further evidence of alcohol formation is
given in Feldmann et al, 1989 (Appl. Microbiol. Biotechnol 31:
152-157, who show that wild type Klebsiella planticola readily
ferments the sugar xylose to alcohol.

48. The paper by Holmes et al 1999 has no data on competition between
strain SDF20 and other bacteria in the particular environment they
have chosen. No long-term studies were conducted on competition
between wild type and engineered bacteria, wild type and other
bacteria in the soil, or engineered bacteria and other bacteria in
this soil. The presence of an extra alcohol related plasmid, by
placing a metabolic burden on strain SDF20, is a prima facie reason
why SDF20 might be a poor ecological competitor. These are just some
reasons why the fate of the engineered strain in natural conditions
cannot be extrapolated from this study.

49. Further, a natural soil ecosystem contains numerous different
bacterial species, some of which can adapt to use alcohol as energy
for their metabolism. In case of introduction of an alcohol producing
Klebsiella, those natural bacteria would find an ecological niche in
the said environment and would multiply. The result of such a natural
balancing process would be a degradation of the alcohol produced by
Klebsiella through other soil bacteria. Harm to plants in such case
would be reduced.

Dr Ingham given the opportunity but has not contradicted this rebuttal
evidence

Because of the seriousness of Dr Ingham's assertions, and in light of
the various issues raised in this rebuttal evidence, we considered
that it was important to give Dr Ingham the opportunity to correct any
inaccuracies prior to the evidence being delivered to the Commission.
Accordingly, we wrote to Dr Ingham on 16 February 2001 attaching a
copy of the evidence to be presented, requesting that if we had made
any factual errors, she contact us within 48 hours so that we could
rectify those inaccuracies.

At the time of the delivery of this evidence to the Commission, we had
received no response from Dr Ingham.

Conclusion:

In conclusion, it is our opinion that Dr Ingham has presented
inaccurate, careless and exaggerated information to the Royal
Commission; incorrectly interpreting published scientific information
and generating speculative doomsday scenarios that are not
scientifically supportable.


ENDS



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