TRANSGENICS BAN TO BE CONSIDERED BY F&G COMMISSION

[Dallas E. Weaver, Ph.D.]

Looks like the NRCD, et.al. still want to ban zebra danio research 
(all the research presented at Madison would classify as 
transgenic by their definition).   They tried the same thing in SB 
1525 in our state legislature and I raised question about the impact 
on the research community. That bill got held in committee, so 
now they are trying to get the F&G to implement a ban.  

These people won't give up and are a real threat to zebra 
researches and support businesses like Scientific Hatcheries.  

Please pass the enclosed letter (below) on to others in the zebra 
research community.  They need to know what the Natural 
Resources Defense Council, Institute for Fisheries Resources, 
PCFF and the Ocean Conservancy are up to. The second sentence 
in first paragraph says it all: "We urge that the moratorium 
specifically apply to the importation and production of transgenic 
forms of fish by the aquaculture industry in California, and include 
ornamental aquatic species, such as transgenic zebra fish."  They 
are trying to legislate a ban and consider a "moratorium" as a 
tactical step.  

The zebra community needs to organize a response.  Senator Sher 
from the Stanford University area was the force behind initial 
legislative attempt.  The legislative representatives from the 
universities don't seem to be aware that this can cause major 
problems and don't want to oppose environmental organizations.  

Thank You,
Dallas

PS:  They like the following definition of transgenic:

1 Transgenic fish means a fish that has been genetically altered by 
introducing a gene from another species at the molecular or cellular 
level by means that are not possible under natural conditions or 
processes, including, but not limited to, recombinant DNA and 
RNA techniques, gene deletion and doubling, or changing the 
position of the gene, but excluding DNA vaccines, ploidy 
manipulations used for sterilization or sex selection, and fish 
produced by matings between closely related species, as in 
traditional hybridization. -- If I remember correctly, ploidy 
manipulations were used in creating the AB lines and all the 
products from those lines.  

PS2:  Getting the Fish and Game involved in your research 
protocols even with permits would slow research and increase 
costs.  Imagine getting the F&G to approval for every shipment of 
fish or embryos, like they already do in the case of aquaculture fish 
-- it takes 2 to 4 weeks to get a permit for each shipment.  The fact 
that you can't bring a salmon egg of any kind or species into Calif. 
without F&G approval and inspection and they won't approve 
Atlantic Salmon (with or without transgenes) shows that the real 
issue is genetic manipulation and GMO's not transgenic salmon.   
This is a modern day Luddite movement and we are the targets.  
-- 

Dallas E. Weaver, Ph.D.                     Scientific Hatcheries
deweaver at gte.net                            5542 Engineer Dr.
714-890-0138                                Huntington Beach, CA Fax
714-890-3778                                   92649

~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

July 23, 2002 

Robert Treanor 
Executive Director 
California Fish and Game Commission 
1416 Ninth Street 
Sacramento, CA 94244-2090 

Dear Mr. Treanor: 

We are writing you to request the commission to adopt an official 
moratorium on importation, transportation, possession and 
production of "transgenic" species of fish in California. We urge 
that the moratorium specifically apply to the importation and 
production of transgenic forms of fish by the aquaculture industry in 
California, and include ornamental aquatic species, such as 
transgenic zebra fish. We ask that the moratorium remain in place 
until the department completes a review of the adequacy of the 
state's existing regulatory requirements and makes 
recommendations on what, if any, additional measures or 
safeguards are necessary to ensure that transgenic species do not 
pose a threat to California's native fish and wildlife. 

Under current law, the Fish and Game Commission and DFG are 
responsible for stewardship of the state's fish and wildlife 
resources, and regulating the activities of the aquaculture industry 
in California (Fish and Game Code Sec. 15005, et. seq.). While the 
aquaculture industry in California is generally responsible in 
producing healthy seafood for consumers with minimal impact to 
the environment, we are concerned that recent developments in 
genetic engineering make current regulatory requirements 
inadequate. The commission has already adopted regulations that 
expressly ban production of certain exotic species, but these rules 
do not currently cover transgenic species of fish. Our organizations 
have met repeatedly with representatives from the California 
Aquaculture Association to craft a definition of "transgenic" that 
exempts standard aquaculture techniques such as sterilization and 
only addresses fish that have been crafted out of multiple species 
(1). We recommend the Commission use this definition. 

We are concerned because a Massachusetts-based company, 
Aqua Bounty, has developed a transgenic species of Atlantic 
salmon that can grow nearly 3 times the rate of a normal salmon 
due to the injection of DNA from the Artic char. Aqua Bounty is 
currently seeking the approval of the U.S. Food and Drug 
Administration (FDA) to produce these transgenic salmon for 
human consumption, but FDA is not specifically required by federal 
law to consult with state or federal fisheries management agencies 
on the inherit ecological risks. 

History has shown that commercially- grown fish can and do 
regularly escape into the wild. Escaped farmed salmon have 
survived in the wild, were found spawning in the Tsitika River on 
Vancouver Island, and have been identified in 77 rivers and streams 
in British Columbia, competing with wild salmon for food and 
habitat. The corporations that create transgenic fish admit that they 
cannot guarantee 100% sterility of fish reared in commercial 
facilities, and it only takes a handful of fish to create a problem of 
than $20 million over the past four years attempting to eradicate 
northern pike from Lake Davis with poison and explosives, all with 
little success. 

For these reasons, we request that the commission adopt a 
moratorium for a minimum of two years to give DFG time to 
conduct a review and consult with the scientific community, 
aquaculture interests, plus other affected parties and stakeholders. 
Transgenic species should be barred from this state until, and only 
if, the department determines they can be safely produced and 
possessed without harming our native fish and wildlife. 

Please do not hesitate to contact any one of us if the commission 
has any questions or needs additional information on this important 
issue. If the Commission is able to place this matter on their 
agenda for its August 29-30th meeting, we would welcome the 
opportunity to make a presentation at that time 

Thank you.  

Sincerely, 

Kate Wing
Natural Resources Defense Council 

Natasha Benjamin 
Institute for Fisheries Resources 

Zeke Grader
Pacific Coast Federation of Fishermen's Associations 

Karen Reyna 
The Ocean Conservancy 


1 Transgenic fish means a fish that has been genetically altered by 
introducing a gene from another species at the molecular or cellular 
level by means that are not possible under natural conditions or 
processes, including, but not limited to, recombinant DNA and 
RNA techniques, gene deletion and doubling, or changing the 
position of the gene, but excluding DNA vaccines, ploidy 
manipulations used for sterilization or sex selection, and fish 
produced by matings between closely related species, as in 
traditional hybridization.