Comment from CHENG, DAVIS
DAVIS CHENGSupportIndividual
Summary: Dr. Davis W. Cheng, a former research molecular biologist and federal compliance inspector, offers his scientific expertise to support the USDA APHIS in implementing a new regulatory framework for genetically engineered (GE) plants. He proposes a multi-track approach involving near-term administrative actions, comprehensive rulemaking based on specific "scientific pillars," and a science-based governance architecture for post-market environmental monitoring.
WHO DOES THE WORK AND HOW SCIENTIFICALLY SOUND GE PLANT RISK ASSESSMENT FRAMEWORK?
An Offer of Scientific Expertise in Support of Implementation
This comment is the third in a series responding to the USDA Animal and Plant Health Inspection Service (APHIS) Request for Information (RFI), Docket No. USDA-2026-0133 (91 Fed. Reg. 27868, May 15, 2026). The first comment (June 22, 2026) established that no approved Genetically Engineered (GE) plant poses materially greater plant pest risk than its conventional counterpart under the current narrow definition, while documenting unaddressed ecological risks. The second comment (June 25, 2026) proposed a scientifically sound replacement framework comprising five efficiency recommendations (E-1 through E-5) and six scientific pillars (Pillars 1 through 6).
Rather than prescribing administrative procedures to experienced agency professionals who understand their own regulatory system, this third comment offers the scientific expertise of the author - developed through decades of research in genetics and genetic engineering, federal compliance work, and regulatory science - in support of the implementation efforts that APHIS and its partner agencies will lead. The comment identifies three categories of contribution. Track 1 offers scientific support for five near-term administrative actions (E-1 through E-5) that can proceed without rulemaking. Track 2 provides detailed scientific input for the comprehensive rulemaking that will incorporate Pillars 1 through 6 into a successor regulation to 7 CFR Part 340. Track 3 identifies two elements requiring Congressional action or White House direction and provides scientific context for each.
This comment also offers a science-based governance architecture for post-market environmental monitoring (PMEM), drawing on analysis of the EU mandatory PMEM model and U.S. institutional capabilities, tying together E-5 (PMEM as an Efficiency Investment) and Pillar 4 (Mandatory PMEM). Together, the three comments offer scientific grounding for a regulatory framework that is risk-proportionate, legally sound, and operationally achievable.