As scientists with relevant background and research experience, we wish to register our opposition to the proposed deregulation of the SUNY College of Environmental Science and Forestry (ESF) genetically engineered (GE) “Darling 58” American chestnut. We believe the release of this GE tree into our forests would be reckless and potentially contribute further to the multitude of threats our forests are already facing. While the stated goal is to restore the American chestnut tree to wild forests, in our view that is highly unlikely to succeed. The risks are therefore not worth taking.

The GE American chestnut tree would be the first GE forest tree species to be deregulated with the stated purpose of restoring a species to wild forests. It would be planted specifically to spread freely through wild forests and to cross-pollinate remaining American chestnuts, altering their populations by introduction of novel genes. This is unprecedented-no other GE organisms have ever been released with the intention of genetically altering wild populations, much less in this uncontrolled way.

Conducting adequate environmental impact assessments for the spread of a through eastern forests is simply not possible. Dramatic new discoveries about forest ecology are being made on a regular basis, and demonstrate how little we really know about species interactions, geochemistry, and energy and nutrient fluxes in natural forests. Furthermore, climate change and the onslaught of new introduced invasive species and pathogens is creating ever greater uncertainty and unpredictability about the future of forest ecosystems.

Release of a GE American chestnut tree into forests would introduce unknown and unknowable risks that we simply cannot anticipate. Unlike domestic crops, American chestnut trees can continue to grow for hundreds of years. Field trials of seed derived Darling 58 engineered chestnuts were only started in 2017, but long-term studies would be needed to assess how a genetically engineered trait will manifest over time, across life stages and shifting ecological conditions that these trees may experience. Extrapolation from very young trees grown under controlled field trial conditions and laboratory oversight is insufficient and is likely to lead to erroneous assumptions and conclusions.    

Once released, the GE chestnut tree would be extremely difficult if not impossible to recall. The GE trees will be free to cross pollinate with remaining American chestnut trees, as well as those grown in orchards as part of the ongoing programs to develop blight-resistant chestnut trees through hybridization with naturally resistant Asian chestnut varieties, potentially undermining that effort.

We understand the appeal of restoring the American chestnut tree, but we do not support the use of genetic engineering to do so. Many forest tree species are experiencing decline and/or are threatened by introduced pathogens and environmental stresses. It is essential that we address the root causes, such as excessive logging to meet unsustainable demand for wood for pulp and bioenergy, sprawling development, climate change, lax phytosanitary regulations and invasive species, among others. Genetic engineering cannot solve these problems for us.

We urge the US Department of Agriculture to reject the petition for deregulation of the GE American chestnut.  It will introduce additional stresses to our forests, will not succeed in restoring this beloved species to the wild, and it will set an unfortunate precedent for the application of risky genetic engineering to addressing forest health threats rather than seeking solutions that address root causes of forest degradation and species loss.

For more information read:
Biotechnology for Forest Health? The Test Case of the Genetically Engineered American Chestnut http://bit.ly/white-paper-GE-trees