Comment from Persistence Analytics Group LLC

Comment on USDA-2026-0133 Modified Organisms Subject to the Plant Protection Act Persistence Analytics Group LLC / United Grid submits this comment regarding USDA’s Request for Information on modified organisms subject to the Plant Protection Act. PAG / United Grid does not oppose agricultural biotechnology, plant science innovation, or responsible development of modified organisms. These tools may support food security, crop resilience, disease resistance, climate adaptation, supply-chain stability, and agricultural competitiveness. However, any future framework should be evaluated through an implementation-integrity and assumption-verification standard. The key issue is not only whether a modified organism is beneficial, innovative, or low risk in concept. The key issue is whether the assumptions behind that determination are transparent, evidence-supported, monitored, and accountable over time. USDA should ensure that any future framework addresses the following: 1. Risk-assumption transparency Developers should clearly identify the assumptions supporting exemption, permit treatment, deregulation, or other regulatory status, including plant pest risk, noxious weed risk, gene flow, trait stability, environmental persistence, and interaction with existing agricultural systems. 2. Field-condition verification Controlled-condition findings should be distinguished from field performance. USDA should consider whether assumptions remain credible under real planting, weather, soil, pest, pollinator, regional, and management conditions. 3. Trait durability Where modified traits are justified by resilience, resistance, yield, disease control, or reduced input use, USDA should encourage evidence of whether those traits remain durable over time. 4. Proportionate oversight Regulation should be proportionate to actual risk, not simply the method used to produce the organism. Low-risk organisms should not face unnecessary burden, but risk-based deregulation should still rest on clear evidence. 5. Biosecurity and containment For organisms with potential spread, persistence, cross-breeding, or ecosystem interaction concerns, USDA should require appropriate containment, monitoring, mitigation, recall, or corrective-action procedures. 6. Post-approval monitoring If regulatory treatment is based on particular assumptions, USDA should consider triggers for reassessment if new evidence emerges, including unexpected spread, pest interaction, resistance breakdown, environmental effects, or trade disruption. 7. Small-entity burden USDA should avoid disproportionate burdens on smaller developers, universities, public researchers, and agricultural innovators. A predictable pathway should reduce uncertainty without weakening risk visibility. 8. Supply-chain and trade impacts Modified organisms can affect seed systems, commodity flows, export markets, processing facilities, insurance, growers, and downstream buyers. USDA should consider how regulatory decisions interact with agricultural infrastructure and market reliability. The broader principle is simple: Innovation should move forward, but regulatory decisions should not rely on unverified assumptions. A modern Plant Protection Act framework should distinguish between announced benefit, projected benefit, demonstrated safety, field durability, and verified lifecycle performance. PAG / United Grid recommends that USDA structure future rulemaking around practical questions: What assumption supports the regulatory treatment? What evidence proves it? What uncertainty remains? Who monitors performance after deployment? What triggers reassessment? Who owns the risk if assumptions fail? Agricultural biotechnology can strengthen American resilience. But resilience depends on verified implementation, not just approval. Respectfully submitted, Neil P. Osnato Founder Persistence Analytics Group LLC | United Grid National Security & Infrastructure Risk Analytics Demand Durability | Grid Stress | Load Integrity SAM.gov registered UEI: D3VYU39H6DX9 D-U-N-S: 142849930 CAGE: 19T34 neil@persistenceanalyticsgroup.com 609-464-9055 https://persistenceanalyticsgroup.com/