The Forest Landowners Association strongly supports the research efforts of ArborGen LLC. The proposed research will be very valuable to the future success of the forestry and biofuels industry. As private landowners growing and managing trees, it is important that our product can be utilized by the new and growing renewable biofuels industry. Attendees at the recent 66th Annual Forest Landowners Conference had the opportunity to submit individual letters of support for this project and now you can, too. Just follow the instructions below on submitting comments. Thank you for your efforts to assist the private forest landowner and please be sure to have your comments submitted by May 21.
It would be preferable to send comments in your own words directly to USDA. Some important background information on both Eucalyptus and the opportunities for using woody biomass and cellulose for bioenergy is below. Please review this information and feel free to use any of it as part of your comments.
To submit comments to USDA using the internet:
• Go to www.regulations.gov
• Check the option “Documents open for public comment”
• In the “Keyword or ID” box, type ‘ArborGen’
• Click “Submit”
• Click on the Docket ID – APHIS-2007-0027
• You will see a number of documents, all are tagged with the APHIS-2007-0027 number. Click on the icons (.pdf, .doc, or .txt to view individual files)
• Click on the “Add Comments” icon on the right side of the page
• Enter the required name and address information
• You can either type directly or copy and paste comments into the “General Comments” box
• Alternatively, you can attach a file containing your comments. An entry in the “General Comments” box is required (for example – ‘Comments attached’)
• Click on the “Next Step” button
Thank you for your help! If you have any questions, please contact Les Pearson with ArborGen at LXPEARS@arborgen.com.
Background on Eucalyptus
Eucalyptus is a fast growing, high-yield hardwood and several species of this tree are grown commercially in many parts of the world for pulp to produce high quality paper. Eucalyptus is also considered to be an ideal species for bioenergy feedstock. At present, this commercially important Eucalyptus species can not be grown in most parts of the Southeastern U.S. due to limitations imposed by the cold winter climate.
Genetically enhanced cold tolerant Eucalyptus will allow production of a short rotation hardwood species for pulping and bioenergy feedstock in the Southeastern U.S., thus playing a key role in national security and economic development in the region.
There are no wild relatives of Eucalyptus that occur naturally in the U.S.A. Some species of Eucalyptus are currently grown in warmer regions of Florida and California. Eucalyptus species have been grown in Florida for decades and have not demonstrated any invasive characteristics. An overview of the biology of Eucalyptus grandis has been published by the U.S. Forest Service. There are no anticipated long-term environmental impacts on the field site. At the end of the trial the trees will be harvested for feedstock analysis and any remaining material will be destroyed.
In their evaluation of the permit, BRS considers the potential for release outside the test site. A key consideration is the possibility of gene flow to non-transgenic trees. There are several factors in the biology of Eucalyptus that lead to a conclusion that gene flow from the site is not a significant concern. These factors are discussed below:
Within the test plot, as well as other test plots at this site, the potential for crossing among individuals is effectively zero due to self-incompatibility because the trees are from the same parental stock. This means that there is no significant risk for viable seed production or seed dispersal beyond the site.
Eucalyptus is not native to the U.S., so there are no native trees with which the test trees can cross breed. Pollen dispersal is limited to a relatively short distance because Eucalyptus is pollinated mainly by bees and, other than trees planted in ArborGen trials, there are no other planted Eucalyptus in the vicinity of the test site.
In the extremely unlikely possibility that seed could be produced in the test, the seed is not adapted to wind dispersal and would be limited to an area of 50m around the test. Due to their distinct morphology and ease of identification, monitoring for any volunteer Eucalyptus in and around the test site and their removal would be easily managed.
Although Eucalyptus is known to resprout from cut stumps, these are easily controlled by treatment with herbicides. There is no evidence for natural vegetative propagation in these Eucalyptus hybrids. Although Eucalyptus is often propagated as vegetative cuttings, this process requires specific cultural treatments and controlled laboratory or greenhouse conditions.
Background on Bioenergy and Woody Biomass Feedstock
Opportunities for developing technology to produce renewable bioenergy (biofuels and biopower) have recently gathered significant momentum in public policy, research, and media coverage. In his 2007 State of the Union address, President Bush set an alternative fuel consumption goal of 35 billion gallons by 2017. The amount of biomass required to produce this amount of fuel greatly exceeds the supply of existing starch-based feedstocks for current biofuels production processes, thus presenting an opportunity for ligno-cellulosic feedstocks and purpose-grown trees. Fast growing trees, such as Eucalyptus, provide added value for their use as a biofuels feedstock and for several bioenergy conversion technologies.
There are numerous possible conversion pathways for production of energy crops from lingo-cellulosic materials, but one feature is common of each: a large and sustainable supply of feedstock is required. Trees grown in dedicated working plantations made possible by the application of biotechnology traits are one potential source contributing to this biomass feedstock.
The use of trees, specifically Eucalyptus, as a dedicated energy crop offers several unique benefit
National security: Fast growing, high yield trees and the cultivation of these trees as a dedicated energy crop reduces our dependence on foreign oil.
Existing infrastructure: Throughout the southeastern U.S., infrastructure already exists for planting, harvesting, handling and processing wood for pulp that could also support the production, processing and distribution of this energy crop.
Ready on demand/Energy inventory: Biomass from purpose-grown trees, like Eucalyptus, can be harvested and processed year-round as needed to meet the nation’s dynamic energy demands.
Regional importance: The South accounts for fully 62 percent of U.S. timber production. Biorefining of wood pulp would provide economic and energy solutions for the region, where much of the nation’s domestic fuel supply is currently refined.
Rapid production: ArborGen technology enables rapid tree growth. Trees developed with ArborGen technology have the potential to grow in 5–to–7 year rotations, with production rates exceeding long-term targets of 10 dry tons of biomass per acre per year.
Environmental benefits: Cellulosic ethanol offers significant environmental benefits, reducing greenhouse gases by 85 percent over reformulated gasoline. Further, cellulosic ethanol has a net energy balance of 8 to 10 or more, compared to a net energy balance of 1.3 for corn-based ethanol.
Lack of Displacement: Today, most commercially available ethanol in the U.S. is produced from sugars or starches obtained from corn and grains. The production of cellulosic ethanol from trees does not create competing demand for food products.
