Sign on Letter Opposing Deregulation of the Genetically Engineered American Chestnut Tree (Darling 54) – SIGN ON HERE
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.
