Comment from Hanson, Larry

I approve the message below because it would be disastrous to impact the ecological system with unintended consequences, a system that involved thousands of years of evolution. The USDA's regulation of genetically engineered crops has failed to keep pace with the realities faced by farmers and rural communities. For many years, USDA reviews have focused primarily on whether a GMO crop poses a plant pest risk. While this approach may satisfy a narrow legal requirement, it does not adequately address the real-world risks and impacts that GMO cropping systems can have on neighboring farms, agricultural economies, and rural landscapes. Many GMO crops are designed to tolerate herbicides. These crops are intended to be grown along with the application of those herbicides, making the crop and the chemical system inseparable. Any meaningful regulatory review should evaluate the combined impacts of the technology as it is actually used in the field. Farmers across the country have experienced the consequences of this regulatory blind spot. Herbicide drift has damaged conventional and organic crops, orchards, vineyards, gardens, and trees. Dicamba drift alone has affected millions of acres and generated conflict among neighboring farmers while imposing significant economic costs on those whose crops were harmed. The evolution of herbicide-resistant weeds has also created a cycle of escalating chemical use, forcing growers to adopt increasingly intensive weed-management strategies. Similarly, insect resistance associated with plant-incorporated protectants demonstrates that biological systems adapt to these technologies over time, often producing unintended consequences. As biotechnology advances through gene editing and synthetic biology, USDA should learn from past experience rather than repeat previous mistakes. Future regulations should fully evaluate environmental, agricultural, economic, and public health impacts before genetically engineered organisms are exempted from oversight or allowed to proceed through simplified review pathways. Farmers, consumers, and rural communities deserve a regulatory framework that is transparent, comprehensive, and grounded in the best available independent science.