Comments on RFI: regulatory considerations related to the review of modified organisms subject to the Plant Protection Act

This public comment was submitted in response to the U.S. Department of Agriculture's Request for Information (Docket USDA-2026-0133) on regulatory considerations for modified organisms under the Plant Protection Act. It argues that three decades of scientific evidence and thousands of regulatory risk assessments demonstrate that genetically modified organisms do not present greater plant pest risks than conventionally bred organisms. The comment advocates for a science-based, risk-proportionate regulatory framework that evaluates organisms according to their biological characteristics and intended traits rather than the breeding method used. It also discusses the role of biotechnology in reducing agricultural pest impacts, highlights regulatory challenges faced by smaller developers, and recommends a more transparent, adaptive, and innovation-friendly approach to oversight.

By Luiza Favaratto and Stuart J. Smyth Jun 3, 2026