The Danger of Releasing Genetically Modified Trees Into the Wild
A genetically engineered chestnut tree may be the first to spread into forests, setting dangerous global precedents.
Genetic engineering (sometimes called genetic modification), leads to the creation of genetically modified organisms (GMOs) by making changes directly to the genetic material of an organism, without mating, through the introduction of genetic material, or by using techniques that induce changes to the organism’s genome. These invasive processes can result in genetic errors and lead to other unexpected consequences.
Genetically Engineered (GE) Trees
Trees such as American chestnut, eucalyptus, poplar, sweetgum and pine are being genetically engineered to have new traits such as faster growth, insect and disease resistance, herbicide tolerance, and altered wood composition. None of these GE trees are legal yet, but a genetically engineered (GE) blight-resistant American chestnut is being proposed for release into forests in the US and Canada.
If legalized, GE trees threaten to spread freely in the wild, contaminating native forests, damaging ecosystems, and harming communities. Trees spread their pollen and seeds over many miles through wind and water or by insects and animals. Locating and monitoring all GE trees and their progeny will be nearly impossible, especially over a long period of time. Trees also have a very long life cycle and can live for decades or centuries. This means that any contamination would be both irreversible and widespread. It also means that the risks GE trees pose to forests and communities are not possible to assess.
Potential Health Risks of GE Trees
People living near GE tree plantations could face health risks from the use of toxic chemicals on tree plantations, which would be greater if the trees were engineered to tolerate herbicides. If the trees are genetically engineered to be insect resistant, the pollen will contain insecticidal properties and could trigger asthma or allergic reactions. Tree nuts, such as GE American chestnuts, would need long-term assessments for food safety.
GE Trees: Climate Change Impact
Every year forests are destroyed to expand industrial tree plantations. These land use changes worsen climate change, destroy natural habitats, and threaten the lives, livelihoods, and cultures of forest-dependent and Indigenous peoples and communities. Trees that are genetically engineered to grow even faster could provide greater incentives to expand tree plantations, displacing more communities and native ecosystems. In addition, eucalyptus and pine plantations are extremely flammable and have contributed to deadly firestorms. Fast-growing eucalyptus trees also deplete groundwater and soils. In Chile, Indigenous Mapuche communities near tree plantations have lost access to water.
Genetically Engineered American Chestnut Tree
Scientists have genetically engineered an American chestnut tree to tolerate an introduced blight that killed large numbers of these trees in the wild. The tree is transgenic, meaning that it has been genetically engineered using genes from other species.
The researchers are seeking government approval to release this GE American chestnut tree into the wild so that it will spread throughout our forests. If legalized, this would be the first GE plant ever to be released into the wild with the intent to contaminate wild relatives.
It would also be the first-ever GE tree approved in the U.S., opening the doors to others. There are no long-term risk assessments to understand the environmental, social, or health risks posed by releasing this GE tree into wild forests, and such assessments may not even be possible.
In November 2022, the Animal and Plant Health Inspection Service of the U.S. Department of Agriculture (USDA) released a draft environmental impact statement and draft plant pest risk assessment that will permit the unrestricted planting of GE chestnut trees on both public and private lands.
Promise and Perils of the GE Chestnut Tree
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 genetically 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.”
Petition to Deregulate D58 American Chestnut Tree
On August 18, 2020, the 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.)
Growing Concerns About Safety
Donald Davis, a founding member of the American Chestnut Foundation, former Fulbright Fellow, and author of the first comprehensive history of this American species, The American Chestnut: An Environmental History, wrote in an opinion piece in The Hill in November 2022: “I am deeply concerned that individuals endorsing the unregulated status of the GE chestnut have not sufficiently educated themselves about potential problems associated with genetically modified trees.”
“This [D58 American Chestnut] 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.
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 2019 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 [the] 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.”
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.”
In an August 30, 2022, story in the Washington Post, Edward Messina, director of the Office of Pesticide Programs at the Environmental Protection Agency, which is also reviewing the GE American chestnut petition, stated that “The big policy question is: Should we bring back forests with genetically modified Chestnut trees? That’s a pretty heavy question. This case sits right at the intersection of cutting-edge science and public policy consideration … Just because we can do something, should we?”
Opposition to GE Trees
Organizations representing tens of millions have endorsed the “Campaign to STOP GE Trees” to demand that the USDA reject the petition to deregulate the D58 GE American chestnut tree.
Greenpeace USA, Friends of the Earth, the Center for Food Safety, Climate Justice Alliance, Food and Water Watch, Indigenous Environmental Network, Environmental Paper Network, Dogwood Alliance, Global Forest Coalition, the Organic Consumers’ Association, and Rural Coalition are among the more than 50 groups that have joined with the Campaign to STOP GE Trees to take an official stand against the proposal.
“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 USDA public comment period on the D58 petition, 109 organizations, representing millions of members, plus an additional 123,426 individuals had registered their opposition to the D58.
More than 130 environmental and social justice groups from 34 countries, including 10 FSC members, signed an open letter hosted by the Campaign to STOP GE Trees, calling on FSC to continue prohibiting the use of genetically engineered trees and to refrain from engaging with field experiments.
In April 2023, the Indigenous Environmental Network (IEN) said that the United Nations Permanent Forum on Indigenous Issues should urge “Indigenous Peoples, states and the United Nations to ban genetically modified trees and their wood products given the risks they pose to the world’s trees, forests, biodiversity and Indigenous Peoples.” IEN also urged “the International Monetary Fund, the United Framework Convention on Climate Change, UNDP and UNEP to ban the use of living beings including but not limited to whales, fish, elephants, lions, tigers, bears, and buffalo for carbon markets and biodiversity offsets.”
The proposal by IEN is extremely significant because it counters the false narrative that projects such as the genetically engineered American chestnut tree enjoy support from Indigenous Peoples in general, and focuses on the very real threat that GE trees pose to the natural world and Indigenous Peoples.
“There are attempts to commercialize nature to take over Mother Earth,” said Clair Charlo, a representative of the Indigenous Environmental Network. “The continued onslaught of violence against Mother Earth and Father Sky must stop,” adding that “the Earth is not for sale.”
“It cannot be overstated that the ongoing challenges for Black, Native American, and other historically underserved farmers and communities engaged in small-scale agriculture often accrue a disproportionate burden of unforeseen ecological and economic consequences,” stated a comment from Rural Coalition filed with the USDA's Animal Plant Health Inspection Service (APHIS). “Citing our community-based research and prior comments on GE trees, we draw on what we have learned from the case of the [invasive] eastern red cedar (Juniperus virginiana) to emphasize the need to find out what is currently unknown in the GE American Chestnut research and restoration experiment. In addition to potential weediness and the impacts on humans, agriculture, plants, and animals, APHIS must also consider the possibility that Darling 58 will not resume its historical role as a keystone canopy species and that in the interim (century) may affect current canopy trees and keystone species (such as Oak, Maple, Hickory); as well as produce unknown effects on the wild habitat of animals and pollinators. We therefore strongly recommend no action on the petition at this time. We further recommend continued public engagement by a wider array of stakeholders, including those likely to be directly affected, objective monitoring by federal agencies, and increased cross-sector, interdisciplinary collaboration in what is proposed to be a wholly novel, large-scale restoration project seeking to radically change existing natural forests and ecosystems by introducing a precedent-setting transgenic tree.”
A list of organizations with links to their comments of opposition to the release of the Genetically Engineered American Chestnut is available on the STOP GE Trees website.
Forest Stewardship Council Rejects GE Trees as a Danger to Forests
The Board of the Forest Stewardship Council (FSC), the world’s leading forest product certifier, decided at their March 2023 meeting to back away from a process that critics charge would have put forests at risk and would have opened the door to overturning FSC’s long-time core certification policy that prohibits the commercial use of genetically engineered trees.
“FSC is right to reject genetically engineered trees as a danger to forests,” said Kaitlyn Duthie-Kannikkatt of the Canadian Biotechnology Action Network, which closely monitored the FSC discussions. “The field testing and release of GE trees pose unprecedented threats to forests, wildlife, and communities that live near them.”
This decision by the FSC to reject GE trees reflects the serious questions of ecology and science raised by this technology that has been glossed over in recent years by corporate interests. In the United States, for example, even though GE trees pose significant social, ecological, and economic risks, there is no protection offered by regulations as agencies are completely unprepared to assess those risks–either in the short-term or over the decades and millennia that GE trees could live and act upon the environment.
The Campaign to STOP GE Trees is hailing this as a victory in forest protection. The FSC decided not to proceed with a project to oversee field tests of GE trees, called a “genetically engineering learning process.”
As of 2023, the only commercial-scale plantations of GE trees in the world are GE poplars planted in China in 2001. However, Suzano, a Brazilian-based pulp producer and FSC certificate holder, was given permission by the Brazilian government in 2021 to commercially grow eucalyptus trees that are genetically engineered to tolerate glyphosate-based herbicides. Under FSC’s policy, Suzano will not be able to grow their GE trees commercially without first leaving the FSC, a move that could have a potentially significant impact on their markets.
Other GE trees currently being advanced face a similar hurdle. Timber from GE poplars or pines developed by the company Living Carbon could not be certified as sustainable under the FSC Policy, limiting their value in a market looking for “sustainable” wood and paper. Likewise, wood or other products from the Darling 58 genetically engineered chestnut tree currently being evaluated for deregulation by the US Department of Agriculture would be ineligible for FSC certification.
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.
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 [the] 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.”
Indigenous Sovereignty Concerns
Indigenous peoples in the regions of proposed D58 releases have expressed concern that the 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 GE 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 research out of Oregon State University published in 2021 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.
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.
Controversy Surrounding MOU
Following the initial publication of this article, Reuters reported that a Memorandum of Understanding (MOU) was signed on April 21, 2021, 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.
Brazil: International Campaign to STOP GE Trees
Members of the Campaign to STOP GE Trees from the United States, New Zealand, Ireland, Japan, Germany, Brazil, UK and Canada visited Brazil in May and June 2023 to develop plans for the international campaign to stop the commercial development of genetically engineered trees, and to support and highlight opposition to the plans by the Suzano pulp and paper company to develop plantations of genetically engineered eucalyptus trees in Brazil.
The Campaign met with Brazilian NGOs, traditional Indigenous Quilombola communities, MST (Landless Workers Movement) camps, including documenting and amplifying the voices and concerns of rural communities on the front lines of resisting the devastating social and ecological impacts of industrial tree plantations.
The Campaign also met with the Environmental Caucus of Brazil's Chamber of Deputies, the Ministry of the Environment and the Ministry of Indigenous Peoples. Today the Campaign will meet with the Ministry of Agrarian Development and present formal testimonies and demands from traditional communities to the Ministries.
In a meeting with the Stop GE Trees Campaign on June 3, 2023, Secretary Moises Savian of the Brazilian Ministry of Agrarian Development and Family Farming stated that transgenic eucalyptus trees make no sense are are linked to market interests that want to sell insecticides.