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The Indigenous Environmental Network “convenes local, regional and national meetings on environmental and economic justice issues, and provides support, resources and referral to Indigenous communities and youth throughout primarily North America – and in recent years – globally” – Our History, Indigenous Environmental Network

The following comments submitted by the Indigenous Environmental Network were posted on Jan 30, 2023:

The Indigenous Environmental Network submits the following comments to oppose the final determination by USDA-APHIS / APHIS-2020-0030-8291 of nonregulated status of the genetically engineered American chestnut tree: Darling58 (GEACD58).

One of the more prominent arguments by researchers is the traditional methods of breeding
resistance into this tree is taking too long. However, history teaches us that negative
unintended consequences have resulted by not taking enough time to consider as many factors
as possible. Restoring this tree into our lives and forests is important work and has the
potential for either success or failure that requires more investigation before nonregulated
status is granted and widespread distribution of the D58 genetically engineered American
chestnut tree takes place.

Furthermore, there has been significant work done breeding blight resistance to the American
chestnut using traditional breeding processes with related tree species that have a natural
immunity to the blight. This process is a more measured and responsible and there are
significant examples of blight resistance successes.

The unregulated and intentional release of GE trees in the US would irreversibly contaminate
wild forests and threaten successful restoration efforts projects focused on wild trees in the US
and Canada.

Long term impacts to ecosystems and human health from GE trees that can live for 100s of
years are completely unknown and threaten forests impacted by logging, introduced pests and
pathogens, urban sprawl, and climate change. It is a “massive, irreversible experiment” with
our forests.

It is dangerously presumptive that a single gene construct, the oxalate oxidase enzyme (OxO)
from wheat will lead to conferring durable blight resistance. The outcomes have shown that
engineering resistance to one pathogen, often leaves plants more susceptible to other
pathogens, biological stress or may reduce plant growth significantly and over time pathogen
resistance over all becomes less effective or not effective at all.

As stated within the DEIS and DPPRA, the addition of the OxO enzymes does not kill the blight
but allows the tree to live with the blight without it succumbing to the effects of the fungus.
The D58 American chestnut trees are a potential plant pest that will concentrate the blight in
the areas where these trees can act as a reservoir for blight, posing a possible risk of infection
to other native trees and plants.

Because the intention of the release of this genetically engineered tree is to spread in the wild,
across the full range of the American chestnut, the unconfined release of DEAC D58 trees
represents, by definition, a plant pest risk as a potential invasive. This spread of Darling 58 is
intended to occur across many ecosystems and landscapes including in Canada.

A decision to permit release of this GE tree would set a dangerous precedent for the release of
other genetically engineered/modified GE/GMO trees into the wild as well as the deregulation
of other species and variants of GE trees, where cumulative environmental impacts are likely to
increase over time. There has been no consideration of the potential threats and negative
impacts that would result in these environments. No life form within biological regions or the
entire earth for that matter, lives in isolation and therefore altering the genetic code of multiple
living entities within a region has the potential to severely limit or eliminate the vital biological
interactions that have been established for countless millennia.

There is no evidence only assumptions that the OXO trait will continue to be viable over time
and multiple generations of progeny that may or may not have carried this gene or what
mutations might have occurred that wouldn’t be known in the less than a decade that D58 has
been cultivated and studied. This short time span is insignificant when considering the age and
maturation of existing bio regions that are measured in countless centuries. me span.

In closing:
Our position on genetic engineering is grounded in our Traditional Indigenous Knowledge (TIK)
that serves to support and direct the work toward universal understanding of and our
adherence to the natural laws that maintain earth’s biodiverse relationships of all living beings.
As Indigenous Peoples, our responsibility is to adhere to our sacred relationship to nature’s
original instructions within these constructs. As humans, with our fragmented understanding of
these complexities, we identify these instructions in the context of DNA.

Our position is solidly grounded in the indisputable truth that no life form lives in isolation, given
the countless complex relationships above, on, and below the surface of Mother Earth. And
because humans lack the depth of knowledge of these highly complex and far-reaching
relationships, we are compelled to do all we can to prevent the purposeful release of the GEAC
and generally the manipulation of DNA that will facilitate any manner of ownership,
commodification, and control of living entities.

There are far too many examples of genetic manipulation for applications that has and
continues to contribute to a 65% population decline in pollinators across the world for so-called
modern industrial agriculture operations. These genetic manipulations include resistance to
chemicals, promotes accelerated growth, pest, and pathogen resistance, and for cultivation in
non-native environments. These applications and uses have caused unintended and dramatic
negative impacts to biodiversity, human health, and countless other non-target life forms.

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