Comment from CHENG, DAVIS
DAVIS CHENGSupportAcademic
Summary: Dr. Davis W. Cheng, a research scientist and former government official, proposes a new regulatory framework for genetically engineered (GE) plants that balances scientific rigor with operational efficiency. He advocates for a tiered, risk-proportionate assessment system, international data sharing, and mandatory post-market environmental monitoring to improve the current USDA APHIS oversight.
This comment responds to USDA APHIS Request for Information Docket No. USDA-2026-0133 (91 Fed. Reg. 27868, May 15, 2026), which asks, among other questions, to "describe key elements of a regulatory framework, including oversight of field trials, that would enable a scientifically sound assessment of a modified organism's plant pest risk." Building on the companion scientific comment of June 22, 2026, this comment addresses three questions: (1) What is the current risk assessment framework and how does it work? (2) Where are its principal scientific deficiencies? (3) What would a genuinely scientifically sound and operationally efficient replacement look like?
The analysis begins -- in Section 5 -- with five concrete efficiency recommendations that directly advance APHIS's stated goal of a proportionate, predictable regulatory pathway. Section 6 then presents the six scientific pillars of a sound framework: tiered risk-proportionate assessment, mandatory problem formulation, expanded ecological risk scope, post-market environmental monitoring, a product-based regulatory trigger covering CRISPR and RNAi, and strengthened containment with proportionate liability. A central argument of this comment is that these efficiency and scientific goals are mutually reinforcing, not in conflict: a better-designed framework processes low-risk products faster, generates real-world feedback that improves future decisions, and prevents the costly contamination incidents that disrupt trade and burden APHIS enforcement.