USDA May Allow Genetically Modified Trees to Be Released Into the Wild
By Anne Petermann
On August 18, 2020, the U.S. Department of Agriculture (USDA) published a petition by researchers at the State University of New York College of Environmental Science and Forestry (ESF) seeking federal approval to release their genetically engineered (GE) Darling 58 (D58) American chestnut tree into U.S. forests. Researchers claim the transgenic D58 tree will resist the fungal blight that, coupled with rampant overlogging, decimated the American chestnut population in the early 20th century. In fact, the GE American chestnut is a Trojan horse meant to open the doors to commercial GE trees designed for industrial plantations.
The D58 would be the first GE forest tree approved in the U.S. and the first GMO intended to spread in the wild. (GE canola plants were discovered in the wild in 2010 but that was unplanned.) "This is a project to rapidly domesticate a wild species through genetic engineering and accelerated breeding, and then to put it back into ecosystems to form self-perpetuating populations—an intentional evolutionary intervention that has never been attempted before with any species," explain scientists at the Center for Food Safety (CFS) and International Center for Technology Assessment (ICTA), which are nonprofits based in Washington, D.C.
"The Southern U.S. is global ground zero for the forest products industry and we see genetically engineered chestnut trees as this industry's sneaky way of opening the floodgates for 'frankentrees' that will harm forests, biodiversity and local communities across the region," explains Scot Quaranda of Dogwood Alliance, a nonprofit based in North Carolina that works to protect Southern U.S. forests. "Our natural forests that support wildlife and the economic sovereignty of rural communities will rapidly be replaced with tree plantations for wood pellets, paper and more, leaving environmental and climate injustice in their wake."
The GE American chestnut faces an uphill battle due to decades of opposition to GE trees by Indigenous peoples, scientists, students, activists, foresters and others, including a GE tree ban by the Forest Stewardship Council and a United Nations decision that warns countries of the dangers of GE trees and urges use of the precautionary principle while addressing the issue.
By October 19, 2020, the close of the public comment period on the petition, 109 organizations, representing millions of members, plus an additional 123,426 individuals had registered their opposition to the D58. The next step is the creation of a draft Environmental Impact Statement (EIS) by the USDA recommending action on the petition. The American Chestnut Foundation (TACF) estimates this could take up to a year to complete. Following this, another public comment period will be undertaken to review the draft EIS, after which the agency will develop a final EIS with a decision on the petition.
D58 Safety Studies 'Invalid,' Warn Scientists
While American chestnut trees are known to live hundreds of years, D58 trees have only been growing since 2017, calling into question the ESF petition assertion that "Darling 58 has been studied in detail and no plant pest or environmental risks have been observed."
In a report on the GE American chestnut she co-wrote, Dr. Rachel Smolker from Biofuelwatch explains, "Given the long lifespan of trees and varying environmental conditions they face, we cannot extrapolate from tests done on very young trees under controlled lab and field conditions. How GE trees might behave in the diverse and changing context of natural forests over long periods of time is unknown and likely to remain unknown even after they are released."
Scientists at CFS and ICTA warn of problems with the D58 safety studies, writing, "Given the young age of Darling 58 trees and corresponding dearth of tissue samples, conclusions from most of the animal experiments described in the Petition are too preliminary to depend upon."
In studying ESF's assessment of the impacts of inserting the blight-resistant oxalate oxidase (OxO) transgene into the chestnut genome, both CFS and ICTA further point out that some D58 studies did not, in fact, use material from transgenic D58 trees, rendering them invalid. "Petitioners did experiments to study how bumblebees might be affected by Darling 58, but did not have enough Darling 58 pollen for the experiments so used non-transgenic pollen instead, to which they added purified OxO from barley seeds. … Other important initial studies on animals reported in the Petition are of limited use because they involved feeding leaves from the Darling 4 instead of Darling 58… even though Darling 4 has much lower levels of OxO in leaves… again invalidating the conclusions for risk assessments." The Darling 4 was an earlier version of the American chestnut genetically engineered with the OxO transgene.
While researchers have argued that a strict regulatory process will ensure the safety of the D58 GE tree, a 2019 report by the National Academies of Sciences, Engineering, and Medicine titled, "Forest Health and Biotechnology: Possibilities and Considerations," raises flags: "Forest health is not accounted for in the regulations for the use of biotechnology or for other approaches to mitigating forest tree insect pests or pathogens. … There are no specific regulations or policies that those agencies apply to biotech trees."
Profit Motive Trumping Morality?
Proponents argue that there can be no downside to releasing a tree engineered to resist an introduced blight. But like fire suppression, which has led to devastating wildfires due to an unnatural buildup of flammable materials in the forest, the future impacts of even a well-meaning action can become catastrophic, especially in combination with the unpredictable effects of climate change and extreme weather. Yet, researchers are engineering trees with the conviction that because they can, they should.
In her book Can Science Make Sense of Life?, Dr. Sheila Jasanoff, Pforzheimer Professor of Science and Technology Studies at the Harvard Kennedy School, explains the implications of this arrogance. "For life scientists and their enthusiastic promoters, the arc of the technologically possible, often coincident with the promise of financial gain, increasingly… defines the boundaries of the morally permissible."
Researcher William Powell, whose GE American chestnut research has received both financial and technical support from companies with a vested interest in the approval of the GE American chestnut—including Monsanto, ArborGen and Duke Energy—defends his approach. In an article in the Conversation, Powell says, "One of the key advantages of genetic engineering is that it's far less disruptive to the original chestnut genome—and thus to its ecologically important characteristics. The trees remain more true to form with less chance of unforeseen and unwanted side effects. Once these genes are inserted, they become a normal part of the tree's genome and are inherited just like any other gene."
However, in a briefing paper published by the Federation of German Scientists, Dr. Ricarda Steinbrecher, a molecular geneticist, and Antje Lorch, a biologist, counter that the genetic engineering process is inherently risky. The paper states, "It is well documented that the processes of plant transformation give rise to many mutations throughout the plant genome as well as at the insertion site of the transgene. … Any robust risk assessment study needs to take several generations into account, for example to assess the stability and heritability of the transgene, unintended side effects and changes due to transformation impact."
Why the American Chestnut?
The D58 American chestnut is the culmination of decades of effort to open the doors to GE trees in the U.S. by biotechnology and timber companies. In 1999, Monsanto joined with timber companies from the U.S. and New Zealand to form a "forestry biotechnology joint venture," which later became ArborGen, one of the world's leaders in GE tree research and development. GE tree research was originally focused on trees and traits valued by the forest products industry; trees like poplar, pine and eucalyptus, and traits like insect resistance, herbicide tolerance, faster growth or altered wood composition.
American chestnut seedling. Anne Petermann
Other early associations—including the Tree Genetic Engineering Research Cooperative at Oregon State University, launched in 1994—brought together university researchers with timber and biotechnology giants as well as the U.S. Forest Service to develop genetically engineered trees for industrial timber plantations.
These efforts were met with widespread opposition and sabotage, leading the industry to conclude that they needed a charismatic "test tree" to try to win over the public opinion relating to GE trees.
A 2007 published paper explains, "There is opposition to commercial application of trees, engineered specifically for fast growth and increased yields, by those whose stance is that the value accrues only to 'big companies.' It will remain for traits that have broad societal benefits, such as conservation… for acceptance to be gained."
The D58 is seen as a positive example for the beleaguered biotechnology industry of the benefits of 'biotechnology for conservation.' Duke Energy also sees the American chestnut for its value as a greenwashing tool. Duke Energy invested millions into the GE American chestnut through the Forest Health Initiative. Its hope was to use the American chestnut to help "green" its devastated mountaintop removal mining lands.
Naturalist and author Bernd Heinrich has one such grove growing on his land in Maine. In a New York Times op-ed in 2013, he wrote, "I have been enjoying American chestnuts for several years now, harvested from some trees that are now part of my forest of 600 acres in western Maine. I planted four seedlings in the spring of 1982. Beyond all my expectations, the trees thrived, and some are now 35 feet tall. … In my small corner of western Maine, the American chestnut is now promising to again become a significant component of the ecosystem."
Once dominant in Eastern U.S. forests, the American chestnut was highly valued for its beautiful and rot-resistant wood, and abundant nuts. While few actually remember the tree, which largely disappeared from the landscape by the 1920s, a public relations effort was launched in the early 2010s with articles appearing in numerous major publications heralding the return of this "mighty giant" through the wonders of genetic engineering. Millions of American chestnut stumps, meanwhile, continue to send up shoots that occasionally grow into trees large enough to produce nuts, and in some locations, wild American chestnuts are spreading on their own, showing at least some evolving blight tolerance.
Another decades-long program by the American Chestnut Cooperators' Foundation is successfully breeding pure wild American chestnuts that are naturally blight-resistant.
In spite of examples like this, GE chestnut proponents have declared the American chestnut functionally extinct, and insist that its survival hinges on the release of unproven and risky genetic engineered American chestnut trees into forests. But Lois Breault-Melican, a former board member of the American Chestnut Foundation who publicly resigned from the TACF over the organization's support for the GE American chestnut, points out that this argument ignores the risks posed to organic and other chestnut growers: "These growers are concerned about the potential GMO contamination of their orchards caused by the unregulated and unmonitored planting of genetically engineered American chestnut trees. If the USDA approves these GE American chestnuts, the integrity of chestnut orchards would be forever compromised."
Indigenous Sovereignty Concerns
Indigenous peoples in the regions of proposed D58 releases have expressed concern that unregulated distribution of a GE tree would violate their sovereign right to keep their territories free from GMOs. They insist that Indigenous peoples be consulted in the process of reviewing the D58 American chestnut.
"Today, there remain large areas of traditional and treaty lands on which much is forested and managed as sovereign territory of many different Native American Peoples," explains BJ McManama of the Indigenous Environmental Network. "These forests are not only a source of economic self-determination but hold great cultural significance to include sacred sites where trees are an element of sustenance, knowledge and familial identity. Every living being within the forests [is] related in some form and nothing within these lands lives in isolation; therefore, changing or altering the original instructions of any one or any part of these elements threatens the natural order established over millennia."
The Eastern Band of Cherokee, members of the Lumbee Tribe of central North Carolina and Seminole Peoples from unceded Florida territory joined the Campaign to STOP GE Trees for an October 2014 gathering in the mountains of North Carolina to protest GE trees as a form of colonization. Their concerns were focused on the GE American chestnut trees.
Lisa Montelongo, a member of the Eastern Band of the Cherokee, explained, "I'm very concerned that GE trees would impact our future generations and their traditional uses of trees. Our basket makers, people that use wood for the natural colors of our clay work—there would be no natural life, no cycle of life in GE tree plantations."
Following the camp, the Band's Tribal Council passed a unanimous resolution prohibiting GE trees from their lands: Eastern Band of the Cherokee Indians (EBCI) Tribal Council Resolution No. 31 (2015): "We commit to rejecting biomass, genetically engineering the natural world, carbon trading, carbon offsets and carbon sequestration schemes as they are false solutions to the climate change." Concerns were focused on the inability of the tribe to keep the GE American chestnut tree off of their lands if it were released into surrounding forests, which they describe as a violation of the Free, Prior and Informed Consent mandate under the UN's Declaration on the Rights of Indigenous Peoples.
Global Impact of the Genetically Engineered D58 American Chestnut Tree
In the end, the potential deregulation of the D58 is not about restoring a "mighty giant" to Eastern U.S. forests. Its approval is about paving the way for the deregulation of all GE trees, toward the creation of an oxymoronic future "bioeconomy" where biodiverse forests are replaced with specially engineered trees for the manufacture of fuels, chemicals, textiles, plastics and other goods in a "green" version of "business as usual." Implicit in this scheme is a massive increase in the consumption of wood. This in turn will drive accelerated conversion of carbon-rich native forests, critical for climate regulation, and other ecosystems for conversion to fast-growing plantations that include GE trees with traits to expedite their use as feedstocks. Existing non-native plantations of eucalyptus, the most common plantation tree, are already notorious for their devastating social, ecological and climate change impacts. But new research out of Oregon State University is attempting to "green" these plantations with claims that eucalyptus trees can be genetically engineered to be infertile, through a process to "knock out LEAFY," the gene believed to control flower formation. The research claims this would prevent eucalyptus trees from invading native ecosystems, though it does nothing to address the ability of eucalyptus to spread asexually through vegetative propagation.
American chestnut tree, Halifax, Nova Scotia, Canada. Canadian Biotechnology Action Network
This new technology also does nothing to address the serious problems caused by industrial plantations of eucalyptus. These impacts, outlined in detail by the World Rainforest Movement, include depletion of fresh water; forced displacement of Indigenous groups, rural communities and subsistence farmers; and catastrophic wildfires. In fact, the addition of GE trees to these plantations could exacerbate known impacts and/or lead to new, unknown and potentially irreversible problems.
Another attempt to "green" GE trees for the bioeconomy involves the development of trees specially engineered to store extra carbon as a supposed climate change mitigation tool. But a new article in Yale Environment 360 challenges schemes like this that focus on tree planting for climate mitigation. Echoing the findings of the World Rainforest Movement and others, the article reports "a growing number of scientists and environmentalists are challenging this narrative on tree-planting. They say that planting programs, especially those based on large numerical targets, can wreck natural ecosystems, dry up water supplies, damage agriculture, push people off their land—and even make global warming worse." In addition, they say, "Tree planting can distract from the greater priorities of protecting existing forests and reducing fossil fuel use."
The attempts to greenwash genetically engineered trees with their unpredictable and irreversible impacts are being opposed globally by a broad coalition of scientists, Indigenous peoples, agronomists, peasant farmers, foresters, teachers and others, as well as organizations focused on protecting forests, human rights and climate justice. GE trees have no place in an ecologically and socially just future.
Author's note: Following the initial publication of this article, Reuters reported that a Memorandum of Understanding (MOU) was signed on April 21 between the Eastern Band of the Cherokee Indians (EBCI) and the American Chestnut Foundation. The MOU, described by EBCI members as highly controversial, would allow the planting of GE American chestnuts on Cherokee land.
Anne Petermann is the executive director of Global Justice Ecology Project. She has been working on issues related to protecting forests and defending the rights of Indigenous peoples since 1990 and co-founded the first global campaign against genetically engineered trees in 2000. In the years since, she has presented the social and ecological dangers of genetically engineered trees at conferences, with community groups, and at the United Nations and other international fora on five continents. She currently coordinates the Campaign to STOP GE Trees, which she co-founded in 2014. Follow her on Twitter: @AnneGJEP.