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 commenter opposes the proposed action, arguing that the regulatory framework favors companies over the public and fails to adequately address the risks of releasing genetically modified microorganisms (GMMs). They demand strict requirements, including unlimited liability for polluters, free detection kits for the public, and long-term biomonitoring.

The commenter argues that the government should do more to ensure public transparency regarding modified organisms, specifically by implementing better labeling requirements. They express concern that current practices may favor corporate interests over public safety and advocate for greater accountability for government officials.

An individual commenter opposes the proposed action, arguing that it grants too much power to a foreign company and poses a threat to public health and safety. They demand that the chemical in question be outlawed rather than protected under the Plant Protection Act.

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.

An individual expresses strong opposition to the proposed deregulation of modified organisms in agriculture. They argue that these practices pose significant risks to human health, the environment, and animal welfare, and they demand greater accountability and transparency for the entities involved.

Dr. Davis W. Cheng, a research scientist and former government official, proposes a new regulatory framework for genetically engineered (GE) plants that balances scientific rigor with operational efficiency. He advocates for a tiered, risk-proportionate assessment system, international data sharing, and mandatory post-market environmental monitoring to improve the current USDA APHIS oversight.

Davis W. Cheng, a former government biologist and scientist, argues that the current "plant pest risk" regulatory framework is too narrow to capture the systemic ecological risks of commercial GE crops, such as superweed proliferation and Bt resistance. He recommends broadening the risk assessment paradigm to include population-level effects and instituting mandatory post-market monitoring.