Modified Organisms Subject to the Plant Protection Act

The commenter expresses concerns regarding the lack of transparency in federal biotechnology regulations and the expansion of categorical exclusions for genetic insects and vaccines. They also highlight issues with the Endangered Species Act implementation and the potential for biotechnology experiments on public and private lands.

The National Grain and Feed Association (NGFA) supports the USDA's role in regulating modified organisms under the Plant Protection Act, emphasizing that regulations must balance plant pest risk with the economic needs of the global agricultural supply chain. They advocate for mandatory pre-market notifications by biotechnology developers to ensure transparency, market access, and the protection of the fungibility of grain and feed commodities.

The American Seed Trade Association (ASTA) supports the USDA's efforts to modernize the regulatory framework for genetically engineered (GE) organisms to make it more risk-proportionate and science-based. They advocate for redefining "regulated articles" to focus on actual plant pest risks rather than the development process, while also requesting the restoration of specific exemptions and streamlined processes from the SECURE Rule.

The American Alliance for Biomanufacturing (AAB), a coalition of biomanufacturing industry leaders, supports the USDA's efforts to modernize the regulatory framework for modified organisms. They argue for a science-based, risk-focused approach that ensures regulatory predictability, interagency coordination, and efficient pathways to commercialize biotechnology for national economic and security benefits.

The National Corn Growers Association (NCGA) supports the development of a modern, risk-proportionate regulatory framework for modified organisms that prioritizes science-based risk assessment over the biotechnology method used. They advocate for streamlined review processes, international harmonization to protect export markets, and reduced regulatory burdens for smaller developers to ensure continued access to improved seed genetics.

Pivot Bio, a sustainable agriculture company, supports the USDA's effort to modernize biotechnology oversight and advocates for a science-based, risk-proportionate regulatory framework for modified organisms. They argue that regulations should focus on the characteristics and intended use of the final organism rather than the method of development, and they call for greater transparency, predictability, and streamlined pathways for commercialization.

A coalition of agricultural trade associations and organizations is requesting a 30-day extension of the public comment period for the Request for Information on Modified Organisms Subject to the Plant Protection Act. They argue that the current deadline is too short given the timing of the planting and harvesting seasons and that an extension would allow for more diverse and thoughtful stakeholder input.

The American Seed Trade Association (ASTA), representing seed production and distribution companies, requests that the USDA extend the public comment deadline for the RFI on Modified Organisms Subject to the Plant Protection Act. They argue that the current timeframe is too short for stakeholders to provide meaningful feedback and that an extension would ensure a more inclusive and robust regulatory process.

The commenter criticizes the USDA for a lack of transparency in the public comment process but ultimately supports the proposed action of moving toward a paradigm of quick deregulation for organisms assessed to pose a low risk. They argue that this approach would restore common sense to biotechnology regulation and benefit both large and small developers.