My comments to the USDA about de-regulation of a transgenic, disease resistant line of American Chestnut

The kind of tree that was once abundant in the US (Wikimedia commons)

For years, public sector scientists have been working on a remedy for the disease-related near extinction of the American Chestnut which was once the dominant large tree in the forests of the Apalacian mountains.  I've heard updates about this over the years at "biotech bootcamp" events and I admire the patience and resolve that they have demonstrated in this ambitious effort.  Here is what I wrote to the agency:

Submitted Sunday 8/23 tracking # 1k4-9ijy-kaf2

 

I am writing in support of the petition for deregulated status for a transgenic American Chestnut event which has been submitted by the State University of New York College of Environmental Science and Forestry. This submission is the culmination of a long-term effort to develop a means by which this key forest species could be restored to its historical role in the forest ecosystems of Eastern North America -  a role that has been seriously compromised since the accidental introduction of a fungus which is a deadly pathogen of Chestnuts.  Although it will certainly take a long time to re-establish such a long-lived species, this strategy is the best hope we have of  achieving that very desirable environmental outcome.

 

My graduate training was in the field of plant pathology at UC Davis in the late 1970s and early 80s, so I can appreciate the challenge of counteracting this disease of this in natural forest settings. Since that time, I have also had the opportunity to closely follow progress in the science of plant biotechnology in both academic and commercial research.  The decades of experience that now exist concerning the safe and beneficial applications of transgenic technology in global agriculture demonstrate that broad deployment of this advance in a forestry setting is also something that can proceed without any undesirable or unmanageable outcomes.  Indeed, as other commenters have noted, reestablishment of this species could be expected to contribute significantly to carbon sequestration and thus help to address climate change. (see https://pubag.nal.usda.gov/catalog/757823). This sort of solution also needs to be considered for other cases where introduced exotic pests compromise the health of our forests ( see https://www.ncbi.nlm.nih.gov/pmc/articles/PMC6680343/)

 

It is significant that this project has been carried out by non-commercial entities simply focused on environmental goals. As an indicator of that, the event in question ("Darling 58") was never patented. The plan has always been to make that and related lines available for free for backcrossing into lines from multiple public Chestnut breeding and restoration efforts.  Many of the other comments that have been submitted to APHIS about this petition are from those researchers who are awaiting the opportunity to be involved in those next steps.

 

The gene that was chosen for insertion into chestnuts is for the very commonly occurring enzyme Oxalate Oxidase or "OxO."  It has always been a part of the plant genome and the human diet so there are no anticipated problems if it is expressed in reintroduced trees. The enzyme is not fungicidal itself but rather detoxifies a chemical that the fungus produces to weaken the Chestnut tree's defense mechanisms.  That kind of trait is less likely to select for resistance, something that is very important since re-establishment will be a long-term project. It is also logical that the trait will be backcrossed into many Chestnut lines to insure sufficient genetic diversity since this species will face the need for adaptation to climate change and other challenges.

 

In the absence of negative outcomes from decades of plant biotechnology, the main objection to projects such as this tends to be based on the "precautionary principle" - the idea that there is no proof that nothing undesirable could ever occur.  As such, that objection fails to consider the consequences on not employing the technology.   In this case inaction would mean that important forest ecosystems will continue to lack the natural "keystone species" which is so important for the wildlife to thrive as it once did in these areas.  The objection to human intervention in a natural system is also flawed in that human activity has already occurred with the introduction of that destructive pest.  Indeed, it makes sense to employ the best solutions available to us as humans who strive to be good stewards of our environment. The deregulation of this transgenic event by APHIS is an excellent next step towards that goal.

 

Why The Current Round Of Ag-Chem Consolidations Worries This Agricultural Scientist

This no-till field is good for the environment and the food supply.
Such innovations involve many expert contributions

I am concerned that we may be on the verge of a major loss of knowledge and experience in the agricultural sector. In the 40 years I have worked with agricultural technology companies I have witnessed many changes. There was a major round of consolidation in the late 1990s and that is happening again today. There are reasons that these trends can make business sense and can be good for shareholders. There can also be problematic aspects of consolidation. Many expressed concerns with antitrust issues in the Monsanto-Syngenta connection, which didn't end up happening, and now with the Dupont-Dow merger, which looks like it will.

That isn't what worries me -- it will still be a competitive sector. I'm concerned about a likely loss of expert knowledge about agriculture.

When companies merge there is a seemingly irresistible financial incentive to get the most experienced (and thus highly paid) employees to take early retirement as a way to deal with "redundancies." Perhaps this won't be as much of an issue with Syngenta, a chemical discovery and biotech company that agreed Wednesday to be bought by ChemChina, a generics player. However, if the retirement strategy is employed in this or the rest of the current wave of consolidations, it will lead to a loss of deep knowledge and experience that could not come at a worse juncture in the history of the food supply.  (Let me be clear that I have no insider information about any of the pending deals or corporate employment plans.  I have consulted across the industry since 1996, but at the mid-level technology level, not in corporate strategy or financial circles).

Between 1960 and 2010, agricultural output increased mainly through higher yields.
That required a great deal of technical and farmer innovation driven by knowledge
(based on FAOStats data)

Global agriculture is a diverse and complex phenomenon that involves unique challenges and unpredictable risks. The extraordinary success of this industry in meeting food demand while improving sustainability relies on a combination of business understanding and technical knowledge that is not easily learned. People with decades of experience on either the business or science side (or often both) are critical to negotiating the threats and opportunities before us. It will be far from trivial to meet the food demand of the growing population and the consumption desires of the expanding middle classes in previously poor regions. To do this without needing to expand the base of farmed land will require talent and expertise. This increased demand is happening with the added uncertainty of climate change and the spread of "exotic" pests in an ever more connected world. A major wave of retirements could seriously compromise our resources of skill, experience and wisdom needed to meet these challenges.

This likely retirement scenario is even more concerning because of the lack of new, skilled talent coming into the agricultural industry. Ag technology companies have been having an extraordinarily difficult time finding qualified new hires because very few young people today are interested in the scientific fields that are critical for agriculture (entomology, agronomy, soil science, plant pathology, plant breeding...).  I don't know the reasons, but I suspect that the widespread demonization of "industrial agriculture" has much to do with this phenomenon. As it is, companies are having to hire people with other degrees (e.g. environmental sciences or even the humanities) and train them from scratch. That isn't impossible with bright and willing people, but if many of their best potential mentors are departing, it becomes far more difficult.

I don't want to imply that the sky is falling. There are still a great many talented people who will be involved in advancing agricultural technology.  However, I do think that the industry and/or society needs to consider some creative ways to allow continued access to the collective experience of those who may soon "retire".  Consulting or some sort of part time "emeritus" status might be possibilities, but those can have tax and retirement income problems. For many industries we would be wise to fix our system so we don't dis-incentivize a graceful wind-down of careers. Perhaps some of the retirees can be hired by other AgChem companies who need their expertise. With modern life expectancies, retirement in one's 60s can easily mean 20 years of lost contribution potential.  It's not that I begrudge my slightly older colleagues a well deserved rest or the chance to start a new chapter in their lives. I just don't want society to lose the unique aspects of what they know.

Your thoughts and comments are welcome here and/or via email (savage.sd@gmail.com)