On October 19, 2020 the initial public comment period by the United States Department of Agriculture (USDA) on the petition for deregulation of Darling 58 genetically engineered (GE or genetically modified) American Chestnut closed.

Historically, there has been strong public opposition to GE trees, a trend which continues to be seen with the current proposal. The public comment period closed with 109 organizations, representing millions of members, officially opposed to the proposal to plant Darling 58 in forests. 123,426 individuals have also registered opposition to the genetically engineered American chestnut. More than 400 organizations have previously endorsed a full global ban on the release of all GE trees into the environment.

To read the full press release visit: https://stopgetrees.org/press-conference/

Below are submissions to the USDA from members of the Campaign to STOP GE Trees (to view the full submission click the link):


With colleagues at Global Justice Ecology Project, I coauthored Biotechnology For Forest Health: The Test Case of The Genetically Engineered American Chestnut. This report followed the National Academy of Sciences workshop
“Biotechnology for Forest Health.” Following participation in that workshop we sought to provide a comprehensive detailed argument against the GE chestnut. Our report lays out well-researched reasoning which leads us to advise that USDA reject the petition for deregulation of Darling58 chestnut.

Canadian Biotechnology Action Network (CBAN)

The Canadian Biotechnology Action Network asks the US Department of Agriculture to deny the request to deregulate the genetically engineered (GE or genetically modified) American chestnut “Darling 58” in order to protect forest ecosystems in North America and, in particular, to prevent any contamination from this genetically modified organism (GMO) into Canada. Such GE contamination, originating from the US, could adversely impact the environment in Canada and could jeopardize American chestnut recovery strategies in Canada.

Center for Food Safety (CFS) and the International Center for Technology Assessment (ICTA)

Blight-tolerant American chestnut (Castanea dentata) Darling 58 cultivar is genetically engineered with an oxalate oxidase (OxO) gene from wheat intended to allow offspring that receive it to survive infections from the ascomycete fungus Cryphonectria parasitica well enough that the trees can become dominant overstory species in forests again. This is a project to rapidly domesticate a wild species through genetic engineering and accelerated breeding, and then to put it back into ecosystems to form self-perpetuating populations (Westbrook et al 2020 at 94) – an intentional evolutionary intervention that has never been attempted before with any species. The large spatial scale throughout eastern North America (Petition at 25, 27) and long timeline of more than a century to gauge success (e.g. Petition at 39-40) requires that this unprecedented experiment be carefully evaluated before deregulation by the Animal and Plant Health Inspection Service (APHIS) of the United States Department of Agriculture (USDA).

Global Justice Ecology Project

The genetically engineered (GE) American chestnut is promoted as a test case to sway public opinion toward supporting the use of biotechnology for forest conservation, and to pave the way for the introduction of other GE trees. However, most other GE trees in development would be grown in industrial monoculture plantations, for the commercial production of timber, pulp and biofuels. A close look at who is promoting the GE American chestnut reveals direct and indirect financial and other links between the nonprofit The American Chestnut Foundation, the researchers developing the GE AC, tree biotechnology company ArborGen, biotechnology company Monsanto (now Bayer), Duke Energy, government agencies, and other entities including the Forest Health Initiative and the Institute of Forest Biosciences that are deeply invested in advancing the use of biotechnology for forest restoration as a public relations tool.

Indigenous Environmental Network

If approved, the GE American chestnut tree (GEAC) would be the first genetically modified organism released with the intention of spreading into the wild. The Indigenous elders and community peoples who we’ve consulted with have expressed concern that this and each successive step taken toward genetically altering the building blocks of life (DNA), by unnaturally combining DNA from totally unrelated organisms is not the way to right the wrongs that to date humans have caused. They are opposed to genetically engineering plants, animals, naturally occurring organisms that are not found in nature and in so doing, is dangerous at best and catastrophic in the long run.

Other submissions:

Genewatch UK

We note that the largest Darling 58 GE trees alive are only about 3 years old, and that no Darling 58 trees are yet mature enough to produce female flowers. This stands in stark contrast to the timescales over which these GE trees will impact ecosystems. Individual trees may live hundreds of years (even if they remain stunted by blight and do not become canopy trees), and the uncontrolled spread of pollen and chestnuts means they will impact ecosystems in perpetuity.

John Wallace & Karen Frailey

While ostensibly an attempt to bring back the American Chestnut (Castanea dentata) (AC) from its current decimated levels resulting from the introduced fungal blight (Cryphonectria parasitica) and from massive logging at the turn of the 20th century, a thorough review of the potential impacts have not been adequately addressed. Once the new D58 trees are released there will be little that can be done to effectively track or limit, much less reverse the spread of the never before introduced GE material into the forests. It is imperative that more, long term studies are undertaken which more completely and thoroughly analyze the possible impacts prior to lifting the USDA regulatory status of the experimental, D58 organism.


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