Trump s USDA Gambles America s Forests on a Defective GMO Chestnut Tree

Experimental trials of GM chestnut trees at Tower Hill Botanic Garden in Massachusetts. Public domain.

On August 20, the U.S. Department of Agriculture made the unprecedented decision to deregulate a transgenic American chestnut, Darling 54 (D54), genetically modified to contain oxalic oxidase (OxO), an enzyme from wheat, to resist the chestnut blight fungus. The D54 deregulation petition was submitted to USDA’s Animal Plant Health Inspection Service (APHIS) by the State University of New York College of Environmental Science and Forestry (SUNY-ESF).

With that decision, the US cleared the way for the world’s first ever genetically engineered plant designed explicitly for release and self-spread in wild ecosystems. That means that as soon as the Environmental Protection Agency gives final approval–transgenic chestnuts could be sold for unregulated planting across the eastern United States, including lands bordering State and National Forests and Parks, tribal lands, and commercial chestnut orchards.

Prior to that decision, on June 29, the EPA quietly closed the comment period for an Experimental Use Permit to grow the D54 in field trials on 280 acres across some 28 eastern states plus Washington, DC. Although the EPA acknowledged the permit “may be of regional and national significance,” it received only four comments—two from USDA and SUNY-ESF. Despite this lack of public input, the EPA is allowing large outdoor field trials of transgenic chestnut trees across a wide swath of the country.

Some view this as a triumph: a tree that might withstand the blight that killed millions. The reality, however, is far more troubling: USDA’s decision is scientifically unsound, procedurally flawed, and environmentally reckless. Neither the SUNY-ESF petition nor USDA’s assessment provides sufficient evidence to justify deregulation. The petition relies on short-term studies of very young trees—research that cannot meaningfully predict how GE chestnuts will behave in complex forest ecosystems over time. Studies on pollen containment and dispersal were ignored, blight tolerance was inconsistent, and the trees were sickly with high mortality rates—facts corroborated by SUNY-ESF’s own research partners at the American Chestnut Foundation in 2023.

To add insult to injury, USDA-APHIS compounded these scientific gaps with its own procedural failures. The agency did not consult its Draft Environmental Impact Statement or the public comments submitted in response, a clear violation of the National Environmental Policy Act. It failed to adequately address “containment, weediness, gene flow, and blight spread”—issues central to evaluating ecological safety. A responsible process would have required multi-year, multi-site pollen dispersal studies; assessments of cumulative ecological impacts, including pollinator behavior and prescribed-fire interactions; evaluations of impacts on tribal populations; economic risks to organic producers; and safeguards for existing non-GE chestnut breeding programs. None of that was done.

Proponents of deregulation often claim the American chestnut is “functionally extinct.” It is not. Hundreds of millions of chestnut trees still survive in the eastern deciduous forest, and hundreds of thousands are large enough to flower. Persisting as stump sprouts, saplings, and scattered large adults, these trees are living reservoirs of genetic diversity. Releasing defective transgenic chestnuts into this landscape risks contaminating surviving wild chestnuts with irreversible traits.

A recent Washington Post article on the Darling 54 chestnut, planted on the White House lawn this spring, included a warning that such plantings could have “unknown consequences.” Michael Hansen, a senior staff scientist for Consumer Reports, underscored the point: “We are in uncharted territory…it could affect the fitness of the [wild] trees or how they interact with the ecosystem. You don’t know until you do these studies.” A whistleblower told the Washington Post that Trump’s White House violated the USDA permit for the transgenic chestnut trees by neglecting to control the trees’ pollen, potentially contaminating wild chestnuts growing in Rock Creek Park and other nearby areas. Not long after this violation, Trump’s USDA deregulated the D54 chestnuts.

USDA’s decision raises serious concerns about releasing transgenic chestnuts into the wild. Darling 54 trees will interbreed with wild populations, permanently altering the species’ germplasm. Once released, those genes cannot be recalled. The ecological consequences could unfold over centuries, not decades. Trees are not annual crops; they are long-lived organisms embedded in intricate ecological networks. Castanea dentata has existed for roughly forty million years; scientists have studied the blight fungus for barely a century. Believing a genetically engineered tree–or the pathogen attacking it–will behave predictably based on a few decades of research is not science; it is wishful thinking.

Chestnut restoration is a noble undertaking, but must be pursued with caution and respect for the species’ genomic heritage. The best future for the American chestnut is one in which wild Castanea dentata thrives again in the eastern forest. By advancing deregulation on such an unstable scientific foundation, USDA has set a dangerous precedent for the governance of genetically engineered forest species. The decision is legally indefensible, ecologically irresponsible, and almost certain to be challenged in federal court—where, on the merits, it should be overturned.