FLORIGENE PTY LTD

1 PARK DRIVE

BUNDOORA

VICTORIA 3083

AUSTRALIA

TEL +61 3 9243 3800

FAX +61 3 9243 3888 John Cordts

USDA
Unit 147 4700 River Rd

Riverdale MD 20737-1236

USA

DATE: 23/12/09

Subject: Petition number 08-315-01p for a de termination of non-regulated status for Rosa X hybrida varieties IF D-52401-4 and IFD-52901-9 – ADDENDUM 1.

Dear John,

As requested Florigene is submitting “Addendum 1: pests and disease for roses” to add to petition 08-315-01p. This addendum outlines some of the common pest and diseases

found in roses. It also includes information from our growers in California and Colombia stating that the two transgenic lines included in the petition are normal with regard to susceptibility and control.

This addendum contains no CBI information.

Kind Regards,

Katherine Terdich Regulatory AffairsADDENDUM 1: PEST AND DISE ASE ISSUES FOR ROSES

Roses like all plants can be affected by a va riety of pests and di seases. Commercial production of plants free of pest s and disease requires freque nt observations and strategic planning. Prevention is essential for good disease control. Since the 1980’s all commercial growers use integrated pest mana gement (IPM) systems to control pests and

diseases. IPM forecasts conditions which are favourable for disease epidemics and utilises sprays only when necessary.

The most widely distributed fungal disease of roses is Powdery Mildew. Powdery Mildew is caused by the fungus Podosphaera pannosa. It usually begins to develop on young stem tissues, especially at the base of the thorns. The fungus can also attack leaves and flowers leading to poor growth and flow ers of poor quality. Control of the fungus is achieved by protective sprays such as Benomyl, Captan, and Triforine. Other preventive measures include; removal of infected shoot s and lowering night humidity (in glasshouse conditions).

Table 1 outlines a variety of other pest and di seases that can affect roses and describes

treatment.

Table 1: Some common pest and diseases of Roses and the recommended treatment (Horst, 1995; Stroom et al ., 2008; Roberts et al, 2003)

Pest/disease Treatment Two spotted mite ETI miticides, fenpyr oximate (Dynamite) and tebufenpyrad (Pyranica) for adult stages and Ovicides, clofentezine (Apollo) for eggs. Introduce predatory mite Phytoseiulus persimilis Downy mildew Lowering humidity a nd keeping temperature constant.

Removal of infected tissues a nd spray with fungicidal sprays such as Metiram, Fosetyl-aluminium or Propamocarb.

Rust Removal of infected tissues and spray with fungicidal sprays such as Thiram, Maneb or Zineb at ten day intervals

Verticullium wilt Sterilise soil before planting Botrytis blight Lowering humidity and keeping temperature constant.

Removal of infected tissues a nd spray with fungicidal sprays

such as Clorthalonil or Fenhexamide Black spot (minor problem in glasshouse grown roses) Removal of infected tissue s and spray with Mancozeb, Ziram, Triforine, Dodine or Kresoxim-methyl. Aphids Removing them by hand, high-pressure watering wands especially designed for insect control, release of natural predators and parasites, and/ or a variety of organic and synthetic pesticides. Japanese bettle, Rose

chafers Hand pick if infestation is li ght. The insecticides carbaryl (Sevin), acephate (Orthene), diazinon, and chlorpyrifos (Dursban) control these beetles.

Viruses such as Rose Mosaic Virus (RMV) Ensure certified virus free root stocks (if grafting). Destroy plants when infected. If av ailable, heat treatment and meristem tip culture may be used to obtain clean material.The following paragraphs are excerpts from an email from Jackson and Perkins noting their specific experience with pest and diseases when deal ing with the transgenic rose
lines IFD-52401-4 and IFD-52901-9.

Jackson and Perkins Wholesale, Inc. has gr own the Florigene transgenic lines at the Somis, California facility for the past 4 years. These cultivars have grown normally in all respects. When grown under cover they su ffer from 3 different pests, as do all commercially grown cut roses in California. These roses can become infected with the two spotted spider mite (Tetranychus urticae), with powder mildew (Podosphaera pannosa) and with downy mildew (Peronospora sparsa). These are ubiquitous pests throughout all of the United States and infect roses anywhere roses are grown commercially. All three pests can be controlled using common treatments and conventional protocols. These transgenic li nes are completely normal with regard to susceptibility and control.

These three pests are most common when th e roses are most actively growing. Mites prefer the warmth of long summer days. At the Somis location we treat for this pest usually 3-5 times a year. Powdery mildew is common when the seasons change from winter to spring and from summer to fall. The large temperature change from day to night encourages the conditions necessary for disease development. By properly controlling the greenhouse environment you can eliminate or near ly eliminate this disease. We spray for it 2 or 3 times a year. Downy mildew is mostly a fall to winter disease that likes cool moist conditions. It is a rare event in a greenhouse. We only spray for this occasionall y - perhaps once a year.

In Colombia, transgenic rose lines IFD-52401-4 and IFD-52901-9 have been grown within a very large rose grow ing facility, adjacent to both th e parental control and other

commercial rose varieties. Under these condi tions, pest and disease control measures are

more intense as commercial flower must be co mpletely free of disease and insect damage, as flowers are intended for export. Th e crop, including the transgenic lines, was chemically treated on a weekly basis, with treatments including Vertimec, Teldor and Previcur. The grower noted that the transgenic and parental controls were susceptible to Mildew, but that there was no difference be tween the transgenic lines and parental

control.

References Horst, R.K. 1995. Compendium of rose di seases. The American Phytopathological Society Press (APS press), Minnesota, USA.

Roberts, A.V., Debener, T. and Gudin, S. 2003. Encyclopedia of rose science. Volume 1. Elsevier Academic Press, San Diego, USA.

Stroom, K., Fetzer, J. and Kr ischik, V. 2008. Insect pests of roses. University of

Minnesota. http://www.extension.umn.edu/di stribution/horticulture/DG6953.html