Comment submitted by Aaron Seltzer

To whom this may concern, Thank you for presenting me with the opportunity to comment on this proposed experimental use permit 100506-EUP-R. As a supporter of American Chestnut restoration, I am convinced approving this experimental use permit would have beneficial environmental effects and support the EPA making this decision. Restoration of the American Chestnut to the ecosystem in a timely manner could be important for key species associated with the tree such as Andrena rehni and the endangered in many locations Neotoma magister with evidence it relied on the American Chestnut as a food source. Solely relying on a hybrid breeding strategy instead risks failure with the now established number of genes involved with Chinese Chestnut resistance to Chestnut Blight or the hybrid retaining resistance having such a high percentage of Chinese Chestnut genes to either limit its benefit to the natural ecosystem or even have possible harmful effects if planted on a truly massive scale in a restoration effort. When it comes to opponents of approval of the OxO American Chestnut for deregulation and general release, a widely stated past objection from them, including during the most recent public comment period for USDA APHIS, was the lack of current sufficient evidence it could be successful and survive once planted, including in various environmental conditions and planting scenarios. https://www.federalregister.gov/documents/2026/05/29/2026-10714/pesticide-experimental-use-permit-receipt-of-application-comment-request-march-2026#addresses Approval of this permit will allow SUNY ESF to more definitively answer this question while without the approval regulators will lack key data to allow them to potentially make a more informed decision in the future through future plantings of studies of these OxO trees and subsequent studies of them. Denial of this permit for the highly speculative reason that the OxO American Chestnut might fail to be successful in the wild would not be valid scientific reason for the EPA to make such a decision in this case. Approval of this experimental use permit could also allow SUNY ESF to obtain data related to the restoration of the American Chestnut and best techniques to use for plantings which could provide helpful information for restoration efforts even beyond American chestnut trees containing OxO using genetic engineering. I therefore urge the EPA to approve this permit in a timely manner so this data can be obtained and the American Chestnut can come closer to being restored to the ecosystem in a functional way. Sincerely, Aaron Seltzer