RegulatoryDarling 58 Blight-Tolerant American Chestnut
The SUNY College of Environmental Science & Forestry (ESF) and The American Chestnut Foundation (TACF) are excited to announce progress toward the likely release of Darling 58 blight-tolerant American chestnuts! The USDA-APHIS recently published two key documents for their regulatory review process, and they're again asking for public feedback via the Federal Register. These documents are draft versions of their final regulatory decisions, so we'd appreciate thoughtful and supportive comments as they prepare to finalize their decision.
The first document is a Plant Pest Risk Assessment (PPRA), which compares potential risks of Darling 58 compared to non-transgenic controls, and states whether the agency will continue to regulate Darling 58. This draft PPRA reviews the data presented in our Petition, and concludes that "Darling 58 American chestnut is unlikely to pose a plant pest risk" (draft EIS, p. 3-3). This means the agency would no longer regulate Darling 58 trees, which means we can begin planning for for public distribution and general planting.
The second document is an Environmental Impact Statement (EIS). While the EIS is not a yes/no regulatory decision document, it provides background information that the agency considers pertinent to the decision. It includes very thorough reviews of data in our petition and numerous independent sources, ranging from ecological interactions to socioeconomic impacts. This draft EIS acknowledges that environmental impacts associated with planting Darling 58 American chestnuts are likely to be either positive or similar to planting other types of chestnuts.
Key quotes and conclusions from both documents are shown below, and full documents are linked above. To read more and submit a comment, see the official NOTICE. Click on the blue "Comment" button under the title to post your support for deregulation of Darling 58. Generally favorable comments as well as experiential or substantive comments will both be welcome.
Draft PPRA excerpts:
- Re. safety of the OxO transgene: "Wheat oxalate oxidase enzyme has been well characterized, can effectively detoxify oxalate, and has no known safety concern for consumption by human and livestock." (p. 6)
- Re. impacts of other pests and diseases: "In summary, the introduced genes did not significantly alter the observed insect pest infestation and disease occurrence or resulting damage on Darling 58 compared to the control and other reference lines." (p. 8)
- Re. impacts on other organisms: "APHIS concludes exposure to and/or consumption of Darling 58 are unlikely to have any adverse impacts on organisms beneficial to agriculture" (p. 9)
- Re. potential for weediness: "These data indicate that Darling 58 American chestnut is unlikely to display the highly competitive and fast spreading behavior associated with weedy and/or invasive species." (p. 10)
- Re. impacts on wild related trees: "APHIS has determined that Darling 58 American chestnut is not expected to increase the weed risk potential of other species with which it can interbreed in the U.S. and its territories." (p. 13)
- Re. environmental interactions: "Apart from chestnut blight tolerance, no differences between modified and unmodified trees have been observed in response to plant-disease, plant-arthropod, or plant-environment interactions." (p. 15)
- Conclusion of Plant Pest Risk Assessment: "APHIS concludes that Darling 58 American chestnut is unlikely to pose a greater plant pest risk than its unmodified parent." (p. 21)
Draft EIS excerpts:
- Purpose of EIS: "APHIS has prepared this draft Environmental Impact Statement (EIS) to consider the potential environmental impacts of an agency determination of nonregulated status. Specifically, this draft EIS has been prepared in order to evaluate the impacts on the quality of the human environment that may result from a determination of nonregulated status of Darling 58 American chestnut." (p. iii)
- Executive Summary excerpts: "APHIS determined that the potential planting of Darling 58 American chestnut for restoration purposes or for any other purpose is likely to have some degree of impact on the environment… it is reasonable to believe there are likely to be positive impacts on the biodiversity of animal species… As American chestnut grows faster than other hardwood species, there may be positive impacts on climate change through greater carbon sequestration… " (p. iv - vi)
- Re. biodiversity: "While it is difficult to predict what impacts Darling 58 American chestnut will have on forest biodiversity, especially since the overall ecosystem has changed since American chestnut disappeared from the landscape, it is reasonable to believe that if Darling 58 American chestnut shows enhanced tolerance to chestnut blight and the trees are able to establish and spread, in the long term it will have positive impacts on increasing the biodiversity of animals and micro-organisms while decreasing the abundance of some tree species such as oaks." (p. 3.10)
- Re. human and animal health: "Nutritional analyses have confirmed that transgenic chestnuts are not nutritionally different than their wild-type relatives." (p. 3.11)
- Re. socioeconomic impacts: "Darling 58 American chestnut is not expected to alter the trade economic environment for chestnut as it is not expected to be used in commercial plantings." (p. 3.13)
- Re. Threatened & Endangered (T&E) species: "No effects on T&E species are expected from the OxO gene in Darling 58 American chestnut… APHIS has not identified any stressor that could negatively affect the reproduction, numbers, or distribution of a listed T&E species or species proposed for listing… no effects are expected to listed and proposed T&E species and critical habitat where Darling 58 American chestnut would be planted." (p. 4.53)
- Conclusion: "As discussed throughout this EIS, the impacts of a determination of nonregulated status for Darling 58 American chestnut are unlikely to be adverse." (p. 4.45)