As an observer present at the May 13 meeting of the science review committee I would like to respond to several comments made at that meeting by Prof. Mike Wilson.

1. In introducing his draft on recombination of viral transgene sequences with plant viruses Prof. Wilson stated that in all of the (10) published papers demonstrating recombination, the transgene possessed a viral replication origin. This statement is factually incorrect. In four of the publications (Frischmuth and Stanley 1998, Schoelz and Wintermantel 1993; Wintermantel and Schoelz 1996; Kiraly et al 1998) no viral replication origins were present yet recombination with the transgene occurred frequently. Prof. Wilson¹s statement is true only for those transgenes which recombined with RNA viruses.

Although his statement is true for RNA viruses it does not follow that recombination with transgenes lacking replication origins will not occur. Those papers that address this question suggest only that removal of replication origins reduces the recombination rate.

2. He further stated that no one would now include a viral replication origin in a transgenic sequence. The panel should be aware that in 1999 the USDA granted commercial approval to a virus-resistant potato including a transgene containing a potyviral replication origin. The New Leaf Y potato therefore set a precedent and the USDA has given no indication since that it would not do the same again.

3. The views of Prof. Wilson reflect only 1 strand of professional opinion among virologists. This quote comes from four viral molecular ecologists Gibbs, Armstrong, Weiller and Gibbs (1997) and I hope that the committees¹ conclusions will reflect the divergent opinions of professional virologists on this matter: ²Thus crops that have been genetically transformed with viral genes and that present opportunities for recombination with naturally spreading viruses are likely to produce viruses with novel host ranges or ones that produce altered symptoms.² (Gibbs et al 1997).

4. In my view only specific and clear recommendations (from the panel) to disallow inclusion of viral replication origins, to specify use of the shortest possible viral sequences, and the inclusion of comprehensive and distributed disablement of transgene coding sequences will be sufficient to prevent the likelihood of evolution of new RNA and DNA viruses by recombination with transgenes. Such recommendations would be in line with suggestions made strongly in the scientific literature (eg Power 2002, Hammond et al 1999) but so far ignored by the USDA.

5. Refs are found in my submission; Latham and Steinbrecher 2003. Jonathan Latham (PhD)