Docket Number: APHIS-2020-0030
Petition for Determination of Non-regulated Status: State University of New York College of Environmental Science and Forestry; Blight-Resistant Darling 58 American Chestnut
Thank you for this opportunity to Comment on Docket Number: APHIS-2020-0030.
The Northeast Organic Farming Association – Interstate Council (NOFA-IC) is a regional federation of seven independent state NOFA Chapters in NY, VT, NH, MA, CT, RI and NJ.
Founded in 1971, NOFA is one of the oldest organic farming education and advocacy groups in the country. Beyond their work on state initiatives, the Chapters work together regionally, nationally and internationally via the NOFA Interstate Council (NOFA-IC), a separate 501(c)(3) organization. Under the auspices of NOFA-IC the Interstate NOFA Policy Program coordinates and carries out joint policy initiatives.
NOFA-IC Opposes Release of the Darling 58 genetically engineered chestnut
Researchers at the SUNY College of Environmental Science and Forestry (ESF) in Syracuse, NY claim to have created, through biotechnology, a blight resistant American chestnut variety. They are requesting USDA approval to plant genetically engineered (GE) American chestnut trees into the wild throughout the eastern U.S. Chestnut forest range in an unprecedented uncontrolled experiment intended to proliferate their genetically modified Darling 58 construct with the goal of “pollinating” (i.e. contaminating) and eventually replacing large numbers of existing wild American chestnuts with unproven genetically engineered wheat DNA mutations under the façade of “species renovation”.
If approved by USDA, this would be the first GE forest tree green-lighted for unrestricted planting in North America forests and the first-ever genetically modified organism (GMO) designed to purposely spread into and infect wild ecosystems to permanently degrade and replace the DNA of wild Chestnut trees via the proliferation of GE pollen and seed. In this vast uncontrolled experiment further ecological side effects remain unknown. Once released, consequent attempts to monitor or reverse their spread would not be possible. Such an irresponsible GE release into the wild is both dangerous and potentially destructive to the very ecosystems the SUNY project claims to protect.
Not only are long range risk assessments of irreversible contamination via the novel genetically engineered trees (which can live for 250 years) deficient — but also further unpredictable ecological effects on native flora and fauna, soils, water, pollinators as well as impacts on the legions of foundational micro-organisms that constitute the basis of a healthy ecosystem remain as an incalculable consequence.
“Saving the Beloved American Chestnut” as a precedent for further industrial GE forest releases Since the retreat of the last glacier about 15,000 years ago there have been huge changes to the northeast regional climate as species began colonizing the raw, scraped landscape – spruces 12,000 years ago; oak, maple, elm, and other hardwoods 3,000 years after that and hickory not until 5,000 years ago. As a relatively new invader arriving from Asia only 2,000 years ago, the so-called “American Chestnut” (Castanea dentata) came to dominate an already assembled ecosystem throughout an extensive North American Eastern Woodlands range because of its fast growing properties; great height (250 feet plus); longevity; heavy seed (nut) production and dense crown canopy that shaded out other competitive species, leading to an estimated 4 billion trees spread over 200 million acres. (Indeed, even SUNY/ESF’s stated goal of restoring the American Chestnut would have further major ecological and economic impacts on modern American forestry).
However, during the early 1900’s a pathogenic fungus known as Chestnut Blight (Cryphonectria parasitica) was brought into New York City from Asia and began decimating the US chestnut tree population. The fungus was introduced by the importation of the Japanese chestnut, a popular imported ornamental tree at the turn of the century. The fungus became widespread in the northeast by 1904 and pretty much wiped out chestnut forests on south by 1926. The blight creates deep fissures in the bark that girdles and kills mature trees. Nevertheless, to this day viable chestnut roots are still alive in widespread areas throughout Northeast woodlands where new growth re-sprouts from the stumps. The persistent root systems send up saplings that can grow to 30 feet tall, producing seed and nourishing the root systems before once again succumbing to the fungus fissures.
This limited form of regeneration ability gives hope for developing an ultimate natural resistance to the blight – and USDA should be investing in this instead. For decades groups including the American Chestnut Foundation in concert with local entities have been searching out and breeding back wild stock resistant varieties as well as developing hybrids with Chinese Chestnut strains in attempts to develop viable blight resistant types through conventional, state-of-the-art cross breeding techniques. More recently, however, the American Chestnut Foundation has teamed up with industrial entities including multinational timber corporations, biotech companies and pulp, paper and biofuel corporations along with Suny/ESF technicians to develop genetically engineered blight resistant chestnut trees and to advocate for their open release into wild forests – all in the name of saving the popular American Chestnut via a public relations ploy.
However, if approved the USDA allowance of this test case is designed to set a dangerous precedent authorizing the environmental release of other GE trees such as poplar, pine and eucalyptus that are in development for industrial timber plantations that use sizable quantities of fresh water, rely heavily on toxic chemicals and threaten to replace forests and displace rural and Indigenous communities globally – all with the aforementioned negative ecological effects.
Risk of releasing an invasive and imprecise technology into the wild The integrity of SUNY/ESF’s genetically engineered chestnut genome is also in question because the engineering process itself damages the chestnut genome. Despite oft-repeated claims by the biotech industry, genetic engineering is not a precise technology. In this case the technicians used basic genetic modification gene gun apparatus where packets of genetic material are shot into host cells to randomly disrupt DNA in the hopes of genetically modifying the host organism for sought after characteristics. However, the majority of the insertions harm the cells and often are fatal. The few cells that live are grown into young trees via tissue culture but because of genetic damage and mutations many grow poorly or contain undesirable traits. Those that exhibit positive qualities are grown on, but still carry genetic disruptions.
These disruptions are compounded because the inserted packet is an amalgamation containing the gene of interest along with multiple other sequences of DNA inserted to regulate and promote the production of the desired new chemical within the plant. Non-functional copies of parts of that packet, along with other DNA debris, wind up scattered through the chromosomes and damaging the modified organism. These damages can result in undesirable effects when the GE trees are later transplanted and mature in the wild. By then it is too late to retrieve the modified genetic material or undo the damage done to the forest environment.
Wheat Gene mutations problematic
After experimenting with various genes and combinations of genes, the SUNY ESF technicians ended up utilizing a gene sequence derived from wheat that causes the tree to produce an enzyme, oxalate oxidase (OxO). Once established this enzyme has the ability to inhibit the spread of the fungus, making it less lethal to the tree. In their promotional materials touting saving the American Chestnut the experimenters highlight that OxO is a common enzyme derived from ordinary wheat – what could be more innocuous?
Reviewing scientists, however, question whether the OxO trait will in fact enable restoration of the species, finding it highly unlikely because biotechnologists have found that in general engineering resistance to fungal pathogens has proven extremely challenging. Despite years of efforts in experiments with well-studied crops they have not been able to overcome fungi’s genetic ability to evade and evolve their way around plant defenses – making durable effective resistance extremely difficult. In the case of trying to produce chestnut resistance researchers are further hampered by their relative biotech unfamiliarity with long lived forest species where woody plant investments in defending against a particular pathogen can make them more susceptible to other pathogens and stresses encountered in the wild.
NOFA-IC Opposes Release of the Darling 58 genetically engineered chestnut
The above scientifically verified comments demonstrate multiple reasons why the genetically engineered chestnut’s release into the wild is highly risky, unwarranted, and potentially disastrous. USDA approval should be denied.
Interstate NOFA Policy Coordinator