Comment from Butler, David

The USDA's current approach to regulating genetically engineered/genetically modified organisms (GMOs) is outdated and does not reflect the extensive scientific literature and real-world experience accumulated over the past three decades. Historically, USDA oversight of GMO crops has focused primarily on whether a genetically engineered plant poses a direct plant pest risk. This narrow regulatory lens ignores the broader agricultural systems in which many GMO crops are designed to function. The majority of GMO acreage in the United States consists of crops engineered to tolerate herbicides or produce insecticidal compounds. These traits are intended to be used in conjunction with specific chemical inputs and therefore cannot be meaningfully evaluated in isolation. A scientifically credible regulatory framework should assess the foreseeable impacts of GMO crops as they are actually used in agricultural settings. Herbicide-tolerant crops have contributed to widespread herbicide use and have been associated with documented damage to neighboring farms, orchards, gardens, native vegetation, and wildlife habitat through herbicide drift. The consequences extend beyond plants and include potential effects on biodiversity, pollinators, endangered species, ecosystems, and human communities. The widespread adoption of dicamba-tolerant crops provides a clear example of the shortcomings of USDA's current approach. Millions of acres of non-target vegetation have been damaged by dicamba drift, demonstrating that the impacts of these cropping systems extend far beyond the fields in which they are planted. Similarly, insecticidal GMO crops containing plant-incorporated protectants (PIPs) have contributed to the evolution of resistant insect populations, creating pressures for additional pest-control measures. These outcomes should be considered when evaluating the long-term sustainability and environmental consequences of GMO technologies. The emergence of gene editing, synthetic biology, and other advanced genetic engineering techniques further underscores the need for a modernized regulatory framework. Many of these products are novel and present questions that were not contemplated when existing regulations were developed decades ago. USDA should strengthen—not weaken—its oversight of genetically engineered organisms and ensure that regulatory decisions are based on comprehensive, independent, peer-reviewed science and the lessons learned from decades of commercial GMO cultivation.