Sign on Letter Opposing Deregulation of the Genetically Engineered American Chestnut Tree (Darling 54)

Docket No: APHIS-2020-0030

To the USDA,

We, the undersigned, strongly oppose the deregulation of the genetically engineered American chestnut tree known as Darling 54. This petition—submitted by SUNY-ESF—raises serious scientific, ecological, and ethical concerns and must be rejected.

A Faulty Tree Built on a Flawed Foundation

The Darling 54 tree, originally misidentified as “Darling 58,” contains a critical genetic defect caused by the unintended deletion of the SAL1 gene, weakening the tree’s health and resilience. According to The American Chestnut Foundation (TACF), which helped fund and develop this project, Darling 54 suffers from:

• Stunted growth and poor survival,
• Inconsistent or declining blight resistance, and
• High mortality, especially in genetically engineered (GE) trees compared to their non-GE siblings.

These are not minor issues—they are systemic failures that make Darling 54 unsuitable for restoration.

A Major Research Mistake—and a Lack of Transparency

SUNY-ESF researchers mistakenly gave TACF the wrong pollen in 2016. As a result, all research over the past decade was conducted on Darling 54, not the tree originally described in the USDA petition. TACF only discovered the error in 2023 and subsequently withdrew its support, citing a lack of transparency and scientific accountability.

TACF has publicly stated that these genetic problems “cannot be explained by growing conditions or parentage” and that the GE trees perform worse than their non-GE siblings under the same conditions.

Irreversible Risks to Forest Ecosystems

This is the first petition ever to allow a genetically engineered plant to be released into the wild to self-propagate. American chestnuts are known to live for 200 or more years. Once deregulated, Darling 54 trees could spread transgenic pollen to wild populations, introducing permanent genetic changes into native ecosystems. With field trials lasting only 3–5 years, the long-term ecological impacts remain unknown—yet the consequences could last for centuries.

Commercialization Should Not Drive Restoration

SUNY-ESF has entered a licensing agreement with American Castanea Inc., a for-profit company planning to mass-produce and sell GE seedlings. This undermines public trust by turning a taxpayer-funded conservation effort into a private biotech venture—all while serious genetic defects remain unresolved.

Safer, Non-GE Alternatives Exist

Non-GE breeding programs have already produced blight-tolerant American chestnuts through traditional crossbreeding and ecological stewardship. Wild chestnuts are also naturally recovering in parts of New England—proving that genetic engineering is not the only path forward.

We urge USDA-APHIS to reject the Darling 54 deregulation petition and support ecologically sound, non-GE restoration methods grounded in credible science, transparency, and long-term stewardship of our forests.

Press Release

NOTE: A PDF of this Press Release can be found here.

FOR IMMEDIATE RELEASE
Contact: Steve Taylor
Email: steve@globaljusticeecology.org
Phone: +1 314 210 1322

USDA Poised to Approve Release of Genetically Engineered Trees Based on Botched Research

Defective GMO Chestnut Rejected by Top Chestnut Researchers

June 12, 2025 — Washington, D.C. — In a move sparking outrage among forest conservationists, scientists, and watchdog groups, the US Department of Agriculture (USDA) has opened a new 45-day public comment period on a highly controversial proposal to deregulate the a genetically engineered (GE) American chestnut tree—a GE tree that is now known to suffer from severe genetic defects, mislabeled data, and performance limitations in field tests.

This marks the first-ever request to approve a GE forest tree, or any GE plant, for widespread environmental release. If approved, it would allow the unregulated planting and spread of genetically engineered pollen, nuts and trees across eastern U.S. forests—despite growing concerns from leading researchers and conservation organizations.

“This isn’t a restoration project, it’s a genetically flawed science experiment poised for commercialization at the expense of our forests,” said Anne Petermann of Global Justice Ecology Project. “We are appalled that the USDA is seriously considering approving this risky GE tree when they know it is based on ten years of flawed research and has exhibited severe problems in controlled field tests.

The forests deserve real science, not flawed experiments. The American chestnut deserves restoration, not commodification.”

Heather Lee of the Campaign to STOP GE Trees added,

“the university researchers at SUNY ESF should withdraw their application because the D54 GE chestnut they seek to deregulate fails to work as promised. The USDA should immediately reject this profoundly risky proposal from researchers who have been careless with their GE research material and are engaged in a dispute over field test results. Independent researchers from several institutions have found the D54 to have significant problems, which researchers at ESF reject as ‘exaggerated or misleading’. Clearly they cannot be trusted with a project of this magnitude.”

They Tested the Wrong Tree—For Nearly a Decade

The initial petition was submitted in 2020 by the State University of New York’s College of Environmental Science and Forestry (SUNY-ESF) but then revised in 2024 when a major research error was uncovered. The research was backed by The American Chestnut Foundation (TACF) until December 2023 when TACF announced the error and major performance limitations observed in field tests.

Researchers discovered that the GE trees they had been studying for over seven years were not the “Darling 58” GE American chestnut described in the petition—but Darling 54, a separate and severely compromised variant. In Darling 54, a critical gene, SAL1, had been deleted during the genetic engineering process. They suffered from stunted growth, high mortality rates, and failure to resist chestnut blight.

TACF’s review of the test data found that these GE trees often fared worse than their non-GE siblings. Despite these negative results, SUNY-ESF continues to pursue deregulation—and minimize the problems.

“Growth retardation, health issues, and cankering of Darling trees continue to be observed and documented across multiple sites, including [SUNY-ESF’s] own orchards,” TACF stated on their website. “These issues are seen specifically in OxO-positive [GE] trees… The stark contrast cannot be explained by growing conditions.”

In a June 2024 statement in a New York Intelligencer article, then President of TACF, Dr. William Pitt drew attention to SUNY’s lack of transparency about the error. “To this day, we’ve never heard anything directly from ESF,” says Pitt, the American Chestnut Foundation’s president. If Tan and Klak (third party scientists) hadn’t shared their findings, Pitt wonders if ESF ever would have “told us, told the public, told anyone.” “As a nonprofit organization, we can’t hide things from our members or the public. If we wouldn’t have brought this out, we would be complicit with a cover-up.”

Commercial Interests vs. Public Interest

Meanwhile, SUNY-ESF has signed a commercial licensing agreement with for-profit corporation American Castanea Inc, which plans to mass-clone and sell millions of Darling 54 trees using AI-driven propagation methods—turning what was pitched as a public ecological project into a private biotech venture.

A Dangerous Precedent for Genetically Engineered Forests

This proposal is about more than one tree. Groups warn that corporations like ArborGen and Duke Energy in the US, and Suzano in Brazil, are watching closely, hoping this deregulation opens the door to widespread planting of GE trees for industrial use—biomass, carbon offsets, pulp, and more.

“The GE chestnut is a Trojan horse,” said Dr. Rachel Smolker, director of Biofuelwatch. “It’s being used to normalize GE trees for profit—not for restoration.”

Key Reasons to Reject the Darling 54 Petition:

• It’s the wrong tree: The data submitted to USDA is from the Darling 54—not the originally proposed Darling 58.
• It’s genetically damaged: In Darling 54, the insertion of transgenes deleted an important gene (SAL1). These trees have weakened resistance, high mortality rates, and abnormal growth.
• It’s irreversible: Once planted, GE American chestnuts can interbreed with and spread defective traits into wild American chestnut trees, and nuts and pollen can spread engineered DNA into native ecosystems.
• It’s driven by profit: What started under the guise of a public restoration effort is being converted into a private revenue stream.
• It sets a dangerous precedent: Deregulating this GE tree for planting into the wild paves the way for the release of other genetically engineered products including commercial forest species.
• Careless mistakes by researchers

Global Justice Ecology Project and the Campaign to STOP GE Trees are calling on the public to speak out before the USDA’s comment period ends on July 21st.

Find GJEP’s public sign on letter here: https://stopgetrees.org/no-ge-chestnut

Find the full docket of USDA and ESF documents, including the new petition for deregulation, draft Environmental Impact Statement and draft Plant Pest Risk Assessment along with a link to submit public comments:
https://www.regulations.gov/docket/APHIS-2020-0030/comments?postedDateFrom=2025-06-09&postedDateTo=2025-06-11

Link to Earth Island Institute Article on Darling 58 “Lessons from the Unsuccessful GM Chestnut Experiment”