Comment from Johnson, William

Please consider this; the USDA's current regulatory framework for genetically engineered organisms is outdated and insufficient to address the potential impacts of modern biotechnology on public health, agriculture, and the environment. Since the commercialization of the first GMO crops in the 1990s, scientific understanding of genetic engineering technologies and their associated agricultural systems has expanded dramatically. Yet USDA regulations remain largely focused on whether a GMO plant poses a plant pest risk. This limited inquiry fails to account for the broader consequences of how genetically engineered crops are actually used. Many GMO crops are engineered specifically to withstand herbicides or produce insecticidal compounds. As a result, they are inseparable from the pesticides associated with their use. Evaluating the crop while excluding consideration of the accompanying pesticide system does not provide a complete picture of potential risks. The widespread adoption of herbicide-tolerant crops has been accompanied by herbicide drift incidents, weed resistance, and increasing reliance on multiple herbicides. These outcomes can affect neighboring farms, rural communities, ecosystems, and food production systems. Likewise, insecticidal GMO crops have contributed to the development of resistant pest populations, creating challenges similar to those associated with conventional insecticides. Emerging technologies such as gene editing and synthetic biology raise additional concerns because they enable the creation of increasingly complex and novel organisms. Regulatory frameworks developed decades ago are not equipped to adequately evaluate these innovations. Consumers, farmers, and communities deserve a regulatory system that considers all reasonably foreseeable impacts of genetically engineered organisms. USDA should update its regulations to reflect current science, real-world experience, and the public interest rather than continuing to rely on a limited and outdated model of oversight and limited information provided by the biotech corporations that profit from commercialization of these novel organisms. Thank you for your consideration.