It is truly irresponsible for the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service (APHIS) to approve the release of the Darling 54 transgenic American chestnut.
In my own assessment, neither the SUNY-ESF petitions, nor the plant pest risk assessment (PPRA) documents provide enough evidence to warrant such a decision. The SUNY-ESF petitions relied on outdated, incomplete, and misleading scientific studies, particularly regarding pollen dispersal, blight spread rates as well as the blight resistance of Darling 54 chestnuts.
USDA-APHIS also did not consult its own Draft EIS, or the public comments submitted after its publication, which is in violation of NEPA rules. It also failed to adequately address the issues of containment, weediness, gene flow, and blight spread—all critically important factors in determining the ecological safety of transgenic chestnuts.
As I have documented elsewhere (Davis 2025), the risks of permanently altering American chestnut germplasm far outweighs any short‑term restoration benefits. Instead of deregulation, the USDA should have 1) conducted multi‑year, multi‑site pollen‑dispersal studies before considering deregulation; 2) assessed cumulative ecological impacts, including blight dynamics, pollinator behavior, and the impact of fire on transgenic chestnuts; 3) fully evaluated economic risks to organic and non‑GMO producers; 4) safeguarded non‑GE American chestnut breeding programs; and 5) maintained regulated status until containment and the long‑term genetic stability of transgenic chestnuts has been fully demonstrated.
Hundreds of millions of American chestnuts still survive in the eastern deciduous forest, including millions of blooming‑size trees. Such numbers challenge the assumption that the species is “functionally extinct” and raise concerns about the urgency–and potential hazards–of releasing transgenic trees into the wild.
The SUNY‑ESF petitions relied almost entirely on short‑term studies of very young trees, leaving major uncertainties about Oxalate Oxidase (OxO) accumulation in forest soils, the durability of blight tolerance in mature trees, and the ecological consequences of intercrossing Darling 54 with wild populations over decades.
By advancing deregulation on such a thin and unstable scientific foundation, USDA-APHIS set a dangerous precedent for the governance of genetically engineered forest species. This action is legally indefensible, ecologically reckless, and almost certain to be challenged in federal court—where it, on the merits, should be overturned.
Donald E. Davis, Ph.D.
Author, The American Chestnut: An Environmental History (2025).
Canada has not approved the release of this GE tree and yet it threatens to spread across our border, putting endangered American chestnuts at risk. Who will be responsible and accountable for these genetically engineered trees in North America in the coming years and centuries?
– Lucy Sharratt, Coordinator, Canadian Biotechnology Action Network cban.ca/trees
As long-time chestnut advocates, we are grateful for this opportunity to speak out against the Trump administration’s approval of the GE chestnut.
We spent 16 years, 2003 to 2019, loyally supporting the back cross breeding program of The American Chestnut Foundation (TACF) by planting and taking care of chestnut orchards across the state. In addition, we gave many “Chestnut 101” presentations to garden clubs, environmental groups and schools. We were told that chestnut restoration was a conservation experiment that could take 100 years or longer. In other words, we were working with “tree time” not some arbitrary corporate, profit driven timeline.
As the years went by, TACF’s messaging changed, reporting that the back cross breeding program was not living up to expectations, and including a sense of urgency about embracing genetic engineering as “just another tool in the toolbox” to help with restoration.
Our suspicions about the end game began upon discovering that the founder of the TACF-NY Chapter was not a forest ecologist as one might expect, but rather a shopping mall developer! A deeper dive revealed that many of the GE tree advocates were giant timber and paper corporations whose end game is to use genetic engineering to maximize profits. After resigning from TACF because of their embrace of GE chestnuts, we joined the American Chestnut Cooperators Foundation (ACCF), which uses only intercrossed pure American chestnut survivors. We also reached out to the Global Justice Ecology Project, who offered support and advice against the use of GE trees for any reason.
On August 27, the day of the USDA decision, we visited the New England Botanic Garden in Boylston MA and were thrilled by the comeback of their native chestnut trees, including one that had 11 burs on it. ACCF chestnuts have been planted there recently, and we look forward to helping with their care.
We believe chestnuts can recover on their own. Tom Wessels’s 1997 book Reading the Forested Landscape describes a stand of American chestnut trees in the southern Berkshires. We did some difficult bushwhacking and found them. We are also seeing healthy chestnut trees along roadsides and in parks. Less than a quarter mile from our home, we found several flowering chestnut trees near the ball field and rail trail.
It would be a shame to corrupt this natural regeneration process with lab grown manufactured chestnut trees that have not been adequately tested for long term viability, not to mention the effects these GE chestnuts could have upon the wildlife that eat them.
Lois Breault-Melican & Denis Melican
