The USDA is accepting public comments on a petition requesting the unprecedented approval of a genetically engineered (GE or genetically modified) tree designed to be planted in our forests and spread freely in the wild. The comments may be submitted until October 19th.  Submit a public comment here.

Researchers at the SUNY School of Environmental Science and Forestry (ESF) are seeking USDA and EPA approval for “Darling 58,” a GE transgenic American Chestnut tree which they claim is tolerant to the blight that helped drive American chestnut trees to near extinction.

But corporations including Monsanto, ArborGen, Weyerhaeuser and others view the chestnut as a “test case” to overcome widespread public opposition to GE trees and open the door to approval of other economically valuable GE trees, like poplar and pine designed for industrial plantations.

Not only would this tree be the first ever GE forest tree approved for unrestricted planting in North America, it would also be the first genetically modified organism (GMO) designed to spread into ecosystems.

There are no long-term risk assessments of the impact of these GE trees on forests or other ecosystems, and scientists note it is not possible to conduct such assessments. Meanwhile, release of fertile GE American chestnut trees into forests would be irreversible. The Precautionary Principle mandates that before such an irreversible action is taken, it must be proven safe. There is no evidence that the GE American chestnut tree is safe in forest ecosystems over time.

Indigenous peoples have not consented to the release of this GE tree which could spread across their territories and ancestral lands. Elders and wisdom keepers warn this is another attempt to control and commodify the living world. Each step taken in this direction has the potential to further threaten biodiversity already weakened by unchecked natural resource exploitation. Spread of the GE American chestnut tree onto Indigenous lands without permission violates the UN’s Free, Prior and Informed Consent (FPIC) mandate.

In summary, we must stop the GE American chestnut due to:

  • National Academies of Science-identified USDA and EPA regulatory inadequacies,
  • a lack of science proving long-term safety in a forest ecosystem.
  • concerns of Indigenous Peoples whose lands fall in the trees’ proposed range,
  • the precedent it would set to open the door to other commercial GE trees.

More information can be found in an in-depth white paper detailing the science and risks associated with the GE American chestnut tree. See also an editorial featured in The Hill outlining these concerns, written presentations by Campaign to STOP GE Trees representatives to the National Academies of Science.

 

Submit a Public Comment Here

 

Here are some sample public comments that you could choose from:

Sample Public Comments

[As a citizen, farmer, consumer, environmentalist, biologist, botanist, etc.]

Sample 1

[Insert background or qualification] I oppose the proposed approval of genetically engineered forest trees in the United States, and urge the USDA to deny the petition from XXX to approve genetically engineered Blight-Tolerant Darling 58 (D58) American Chestnut.

The genetically engineered American chestnut submitted for review uses an oxalate oxidase enzyme (OxO) from wheat that appears to limit, but not destroy, the spread of chestnut blight (Cryphonectria parasitica) on juvenile American chestnut trees. While the OxO enzymes appear to be non-toxic, all relied-upon testing regarding the D58 trees is insufficient, at best.

All D58 testing was executed within a very short timeframe and was done on young trees – less that 5 years old! – so do not reflect the pre-blight lifespan of the wild American chestnut. For example, young trees are known to be more resistant to blight. And American chestnut trees can live for well over 200 years and face fluctuating environmental conditions over their lifespans: drought, flood, heat, pests and the basic changes associated with aging. All these factors could influence how genes are expressed over time and whether or not the trees will retain blight resistance and withstand other challenges. We cannot rely on extrapolation from test results from young trees to assume that blight resistance will be functional over a longer period and under the variable conditions of natural forests. It would be irresponsible to release this genetically engineered tree into the wild without even knowing if they will have the same long lifespan of their wild American chestnut counterparts.

There is simply no way to know if the OxO enzyme will remain safe and effective over time, posing a serious environmental threat to forest ecosystems and wildlife that cannot be prevented. The cumulative impacts from introducing this organism have not been thoroughly considered and I strongly urge the USDA to reject this application.

Sample 2

[Insert background or qualification] I strongly oppose the proposed approval of genetically engineered forest trees in the United States, and urge the USDA to deny the petition from XXX to approve genetically engineered Blight-Tolerant Darling 58 (D58) American Chestnut.

The project to genetically engineer American chestnut trees has oversimplified the science and certainty involved in engineering pathogen resistance. The research on the D58 American chestnut has occurred against a backdrop of efforts by many other researchers to genetically engineer agricultural crop plants to be resistant to viral, bacterial and fungal pathogens. However, successful engineering of pathogen resistance has been remarkably elusive.

A single gene construct, the oxalate oxidase enzyme (OxO) from wheat, is unlikely to be effective on its own in conferring durable blight resistance. One frequent problem is that engineering resistant to one pathogen, often leaves plants more susceptible to other pathogens or stresses, or reduces plant growth significantly. Another problem is the loss of pathogen resistance over time. A modification that may initially be effective can be rendered ineffective as the pathogen adapts. Given such limited success with commonly cultivated and short-lived domestic crop plants, the prospects for successful and durable engineering of fungal pathogen resistance into a long-lived wild forest tree species appear remote.

We do not know how genetically engineered trees might behave in the diverse and changing context of natural forests over long periods of time, nor will we know even after they are released. This poses many significant impacts and risks to our native forest ecosystems.

I strongly urge the USDA to reject this application.

Sample 3

[Insert background or qualification] I oppose the proposed approval of genetically engineered forest trees in the United States, and urge the USDA to deny the petition from XXX to approve genetically engineered Blight-Tolerant Darling 58 (D58) American Chestnut.

The genetically engineered American chestnut raises particular concerns in relation to Indigenous peoples’ territorial sovereignty, and the application of the UN’s Free, Prior and Informed Consent (FPIC) requirement when dealing with issues impacting Indigenous peoples or their territories. Granting nonregulated status to D58 trees will not give proper consideration to Indigenous peoples whose traditional lands fall within the historical range of American chestnut trees and the potential propagation of their genetically engineered counterparts.

Indigenous peoples have not yet consented to the release of this genetically engineered tree and the spread of D58 trees onto their territories is a violation of the FPIC mandate. Indigenous peoples in the regions of proposed D58 releases have expressed concern that unregulated distribution of a genetically engineered tree would violate their sovereign right to keep their territories free from genetically modified organisms. If released, genetically engineered American chestnuts will spread uncontrolled and will not respect territorial borders. Each step taken in this direction has the potential to further threaten biodiversity already weakened by unchecked natural resource exploitation.

I demand the USDA prohibit release of genetically engineered trees and reject this application.

Thank you!!

 

Submit a Public Comment Here