Comment from Anonymous
Anonymous AnonymousSupportAcademic
Summary: A university researcher argues that the proposed action to reinstate exemptions for the interstate movement of disarmed Agrobacterium strains is necessary to facilitate scientific research and maximize the return on public investment. They contend that the current permitting requirements cause unnecessary delays and do not pose significant environmental risks.
I am a researcher working at a public university. My research involves the use of organisms in the genus Agrobacterium that have been disarmed and are no longer pathogenic. Researchers all over the United States are developing new versions of disarmed Agrobacterium that can be useful for research on plant transformation and to generate transgenic plants for research purposes. These organisms were previously exempted from a requirement for permits for inter-state movement under the May 2020 amendments to the SECURE rule. Since the National Family Farm Coalition v. Vilsack, 758 F.Supp.3d 1060 (N.D. Cal. 2024) ruling went into effect, the pre-May 2020 regulations were restored and disarmed Agrobacterium strains are no longer exempt from interstate movement permitting requirements. Since there is a growing need to develop methods for plant transformation at research institutions across the US, it is extremely important to be able to rapidly disseminate and share research materials. Scientists working on plant transformation are not all located in the same U.S. State and it is often necessary to share disarmed Agrobacterium strains with researcher at a different institution in another U.S. State. The requirement for a permit for interstate movement of disarmed Agrobacterium strains unnecessary delays and inhibits the sharing of research materials. Furthermore, newly disarmed Agrobacterium strains are often developed by researchers at public universities using public funds. Rapid sharing of research materials enhances the return on investment of those public funds. Re-instating the May 2020 exemptions will facilitate research on plant transformation and capitalize on public investment in scientific research without posing any real risks to the environment. I would also like to comment more specifically on the questions that were posed in this solicitation, but I was unable to conduct a proper scholarly review due to the rather brief public comment period. I would like to request an extension of the deadline for public comments to allow for meaningful feedback.