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USDA’s Genetically Engineered Tree Public Comment Period Launched!

Please submit comments today! Help stop the uncontrollable release of genetically engineered trees into wild forests in the US.

Submit comments here: https://www.regulations.gov/commenton/APHIS-2020-0030-8291


Background: 

The US Department of Agriculture has released a draft Environmental Impact Statement that recommends approving the unrestricted planting of genetically engineered (GE) American chestnut trees in wild forests. 

This comes despite the lack of information about the long-term risks to forests, biodiversity, communities or human health. 

If approved, this GE American chestnut tree (known as Darling 58 or D58) would be the first-ever genetically engineered forest tree planted outside field tests in North America. It would also be the first-ever genetically engineered plant released anywhere with the purpose of spreading freely through wild ecosystems. 

If approved, it would unleash a massive, irreversible experiment in our forests.


More Information and Sample comments:

(Feel free to use any or all of the following in your public comment submission)

The D58 GE American chestnut threatens forests and biodiversity

  • If the GE AC is released, it will be planted specifically to spread freely through forests. Once it is released in the wild, tracking or reversing its spread would be impossible. Any unexpected occurrence could threaten the ecological health of whole forest ecosystems.
  • The researchers propose to plant GE AC trees in wild forests so that the blight-tolerant GE trees would spread GE pollen and seeds, and cross-pollinate with remaining wild American chestnuts. The GE version of the American chestnut will not restore, but replace the wild American chestnut. The D58 GE American chestnut itself could drive the wild American chestnut into extinction.
  • It is not possible to assess the risks of releasing this GE tree into the wild because we do not know what will happen in highly complex forest ecosystems that are subject to environmental stresses and climate change, especially over multiple generations of American chestnut trees which can live for over 200 years. The long-term impacts of its release on ecosystems are unknown, and likely can never be known.
  • Locating and monitoring all the GE trees and their progeny in our forests will be nearly impossible, especially over a long period of time. In fact, there can be no comprehensive monitoring because the public will be able to freely plant and share the trees. If something goes wrong there will be no way to reverse the problem.
  • Without the free, prior, and informed consent of Indigenous nations whose territories span the range of the American chestnut, the release of D58 GE American chestnut violates Indigenous sovereignty.
  • D58 GE AC pollen and nuts will spread across borders and jurisdictions. Deregulating the American chestnut in the US will have a direct impact on research taking place in Canada to restore American chestnut populations through conventional breeding.  
  • Existing animal and plant habitat could be disrupted if the D58 replaces other trees, like oaks, that have become established in forests in place of the American chestnut. 

Risk Assessments of the D58 GE American chestnut are inadequate

  • Animal species could be harmed by eating GE pollen, nuts, leaves and other parts of the D58 tree. Animal feeding studies on the D58 GE American chestnut, however, did not use the D58, but rather earlier versions of the GE tree that have a lower expression of the GE trait. 
  • Feeding studies to examine potential impacts on bees did not use D58 pollen, but non-transgenic chestnut pollen.
  • The data submitted to the USDA for deregulation of the GE American chestnut is insufficient to assess the environmental risks. For example, the D58 trees were only in field trials for three growing seasons.

The GE American chestnut tree may risk disaster for nothing

  • The blight tolerance trait that has been genetically engineered into the American chestnut tree may not even work. The trait may not be stable over the long lifespan of the trees, and faced with variable conditions in the wild. 
  • The survival of American chestnuts is challenged by other lethal pathogens, as well as a variety of other stressors including climate change. Whether the Darling 58 will grow tall enough and live long enough to establish in forests, as the American chestnut once did, is unknown. Its risks could be for nothing.
  • The release of a GE American chestnut tree into forests would be a large-scale, irreversible experiment. 

The GE American chestnut tree threatens American chestnut restoration efforts

  • Dedicated researchers and volunteers in Canada and the US have been breeding naturally blight-resistant American chestnut trees with the aim of restoring truly wild American chestnut trees. Other groups are using conventional breeding and crossing the American chestnut with naturally blight-resistant Chinese chestnuts. All these efforts will be undermined, and potentially rendered null by the release of the D58 GE American chestnut tree designed to spread and cross-breed.

The GE American chestnut is a Trojan Horse to advance other GE trees for industrial purposes

  • Supporters of the GE American chestnut have called it a “test tree” or “poster child” intended to undermine widespread public opposition to GE trees.
  • Development of the GE American chestnut is tied to industrial profit motives. Monsanto and ArborGen provided early financial and technical support, and Duke Energy, the largest electric power holding company in the US, funded the tree’s development with an eye to future plantations for wood pellets, lumber and forest carbon offsets.

For a detailed examination of the threats and impacts of the D58 GE American chestnut, please download the white paper: Biotechnology for Forest Health, the Test Case of the Genetically Engineered American chestnut https://stopgetrees.org/wp-content/uploads/2019/04/biotechnology-for-forest-health-test-case-american-chestnut-report-WEB-1.pdf

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