Comments to the United States Department of Agriculture

The United States Department of Agriculture’s (USDA) Animal Plant Health Inspection Service (APHIS) published their draft Environmental Impact Statement and draft Plant Pest Risk Assessment recommending approval of the petition to allow the unrestricted and unmonitored release of the first-ever GMO plant (a GE American chestnut tree) into the wild with the intent to spread and contaminate wild relatives.

In response, thousands of individuals and organizations commented to APHIS rejecting this draft approval, and over 150,000 others registered their opposition through sign on letters and petitions. Some of these organizations and their comments are listed below.

An additional 400 organizations have endorsed the Stop GE Tree Campaign’s call for a global ban on the release of genetically engineered trees into the environment.

See this comments from Rural Coalition:

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…

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.

Registered Opposition to the Release of GE American Chestnut Trees into Wild Forests

Signed an Online Petition with Rainforest Rescue

Signed onto the Comment by Friends of the Earth, US

Rainforest Rescue support affected communities in mobilizing and asserting their rights against plans for deforestation. Its online petition for the GE Chestnut was backed by 119,560 signatures. (Comment )

Global Justice Ecology Project explores and exposes the intertwined root causes of social injustice, ecological destruction, and economic domination (Comments #1, #2, #3, and #4)

EcoNexus is a public interest research organization consisting of scientists and dedicated researchers analyzing and reporting on new technologies that have the potential for significant negative impacts on biodiversity and ecosystems. (Comment)

Rural Coalition is an alliance of farmers, farm workers, indigenous, migrant, and working people from the United States, Mexico, Canada, and beyond (Comment)

Biofuelwatch, based in the UK and US, provides information and undertake advocacy and campaigning in relation to the climate, biodiversity, land and human rights and public health impacts of large-scale industrial bioenergy (Comments #1 and #2)

Bioscience Research Project conduct independent scientific analysis of genetic engineering and its risks. (Comment)

Friends of the Earth International is the world’s largest grassroots environmental federation with 73 national member groups. Friends of the Earth submitted comments on behalf of over 4 million online supporters and members. (Comments #1 and #2)

Friends of the Earth, US submitted its comment on behalf of over 21,159 supporters (Comment)

Indigenous Environmental Network convenes local, regional and national meetings on environmental and economic justice issues, and provides support, resources and referral to Indigenous communities and youth throughout primarily North America – and globally. (Comment)

Canadian Biotechnology Action Network members include farmer associations, environmental and social justice organizations, and regional coalitions of grassroots groups. (Comment)

Global Forest Coalition is an international coalition of 126 NGOs and Indigenous Peoples’ Organizations (Comment)

World Rainforest Movement is an international initiative that aims to contribute to struggles, reflections and political actions of forest-dependent peoples, indigenous, peasants and other communities in the global South (Comment)

International Center for Technology Assessmentis a non-profit, bi-partisan organization committed to providing the public with full assessments and analyses of technological impacts on society. (Comment)

Northeast Organic Farming Association of New York is an organization of farmers, gardeners, and consumers working together to create a sustainable regional food system. (Comments #1, #2, and #3)

Canadian Chestnut Council includes scientists, conservationists, farmers, woodlot owners, students and retirees in southern Ontario and as far afield as Nova Scotia and British Columbia (Comment)

Center for Food Safety has spent twenty years organizing a food movement that is fighting the industrial model and promoting organic, ecological, and sustainable alternatives. (Comment).

Planetary CARE has over 3000 community members and their mission is a planet where thriving regional farm communities supply nutrient-dense food for humanity while living in harmony with Nature. (Comments #1, #2, and #3)

Breadtree Farms is growing the regenerative chestnut industry in the Northeastern United States (Comment)

Conservation Congress protect National Forest lands and native wildlife in northern California. It is part of Voices for Public Lands (VPL) (Comment)

Save the Pine Barrens are a statewide network of groups and individuals taking action to protect our land and water (Comment)

GMWatch is an independent organisation that seeks to counter the corporate political power and propaganda of the GMO industry and its supporters. (Comment)

GMO Science are physicians, biochemists, plant geneticists, and other scientists that provide a public platform to discuss GE crop and food impacts. (Comment)

Cloud Forest Organics has a 170-acre pilot site in the upper Amazon where they are developing a next generation production model and new uses for ancient tree crops (Comment)

Red de Acción por los Derechos Ambientales RADA works in the south-central part of Chile. Their main priority is to promote and defend the environment as a human right. (Comment)

Langelle Photography is run by a concerned photographer whose work spans five decades and six continents and provides a home for documentary photographic images concerning social, ecological and economic struggles. (Comments #1 and #2)

Mangrove Action Project is a US-based nonprofit that works with forest communities, research academics, forest and environment departments, policy makers, and international policy and funding groups. (Comments #1, #2, and #3 )

Test Biotech is a non-profit organization that provides information and scientific expertise on the risks associated with genetic engineering, completely independent of the biotech industry. (Comment)

The Instituto Resiliencia (Resilience Institute) is part of the Knowledge Center for Sustainability and officially recognized by the United Nations University. (Comment)

Institute for Responsible Technology work in 45+ countries to educate the public and change-makers about the health risks and environmental dangers of GMOs and associated pesticides. (Comment)

Soil Resources Initiative visit African villages to teach regenerative agriculture techniques and provide advice on forming co-ops. (Comment)

The German Federal Agency for Nature Conservation is the scientific authority of the German federal government responsible for national and international nature conservation. (Comment)

Bay Area Coalition for Headwaters work in collaboration with grassroots activists and organizations in Northern California. (Comment)

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