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The following letter was submitted electronically to the Office of Science and Technology Policy (OSTP) on January 20, 2023 in response to a Request for Information on the National Biotechnology and Biomanufacturing Initiative. Download a PDF of the letter here.


The Institute for Agriculture and Trade Policy (IATP) appreciates this opportunity to respond to the RFI about biotechnology and biomanufacturing solutions to achieve societal goals in food, agriculture and climate. We urge OSTP to give as much consideration to the broader systems to which any solution is applied, as to the proposed solution itself. In the case of food and agriculture solutions, the primary systems are biodiversity and the climate. We focus on three of the RFI's 17 questions.  

2. Public engagement and acceptance are of critical importance for successful implementation of biotechnology solutions for societal challenges. How might social, behavioral, and economic sciences contribute to understanding possible paths to success and any hurdles? What public engagement and participatory models have shown promise for increasing trust and understanding of biotechnology? 

A major source of public distrust in biotechnology is the U.S. system for exempting food and agriculture products derived from genetic engineering (GE) techniques from pre-market safety assessments. According to one analysis of this system in the U.S. Department of Agriculture, as codified in the so-call SECURE rule, “99% of GM plants will be exempt from premarket field testing and data-based risk assessment requirements.”2 This system for exempting new GE plant varieties from risk assessment, as advocated for by GE product developers, is “reconstituting the same conditions that led to the public rejection and mistrust of the first generation of GM foods.”3 First generation products were mostly feed grains for livestock, rather than products for direct human consumption, such as fresh horticulture products. As a result, and in the absence of labeling to clearly distinguish GE agriculture and food products from non-GE products,4 public rejection and mistrust by retail consumers could result for products with GE traits designed to attract consumers. 

Public engagement strategies that employ findings of behavioral science, whether or not directly financed by industry, may not overcome distrust of a regulatory system that eschews risk assessment for most products and that makes the “substantial equivalence” doctrine the fulcrum of risk management decisions. Focus groups to test consumer responses to different explanations used to justify an exemptive system of GE food and agriculture oversight are not likely to build trust.  

Agencies routinely classify biosafety data about GM food and agriculture products as Confidential Business Information (CBI).5 The combination of exemptions from risk assessment and CBI classifications of a product’s biosafety data requires the public to trust that any voluntary submissions of data by product developers to USDA regulatory scientists provide an adequate basis for determination of exemptive status. If the primary purpose of the exemptive system is to provide biotech product developers, their corporations and investors with regulatory certainty and predictability, public engagement strategies to foster trust in the GE products and the exemptive system will be hard to distinguish from corporate public relations.  

To increase trust and understanding of biotechnology, it is imperative that OSTP show that it has considered solutions to an identified social challenge other than those of biotechnology. In other words, OSTP should review responses to this and other RFIs using comparative technology analysis, before promoting persuasive solution responses to receive federal policy and investment. Otherwise, biotechnology, or more specifically, different techniques of genetic engineering, become the “hammer” for every challenge. For example, climate science models project as much as a 24% decrease in maize yields by 2030, while wheat yields are projected to increase by as much as 18% in “major breadbasket regions.”6 Rather than assume that the multi-trait genetic engineering of seeds is an optimal solution to maize yield decrease and to induce public support for that solution, OSTP should develop a policy that instructs agencies to compare the evidence of other practices or technologies to meet this climate-related and other identified challenges.  

OSTP should review research into non-GE methods to cultivate wheat and other food crops in non-irrigated agriculture under the climate change challenge. For example, OSTP should instruct USDA to review data and studies that document agricultural practices to build soil microbial mass and biodiversity that can sustain crop yields in adverse, if not extreme, agri-environmental conditions with reduced use of agricultural chemicals and no use of GE seeds, usually engineered to resist proprietary pesticide products.7 If the purpose of the RFI is to solicit research ideas to address Grand Challenges, such as the impact of climate change on agricultural production and food systems, OSTP must cast a wider net than to foster yet more research in projects and products whose repeated mono-cropping use will contribute to further eroding biodiversity and/or exacerbating climate change.  

If agricultural system challenges are defined to require biotechnology solutions, it will be difficult to distinguish public engagement from corporate claims for biotechnology. The U.S. plant and animal agricultural biodiversity crisis is a Grand Challenge that cannot be “solved” by applying GE techniques to the narrow and narrowing species of “production agriculture.” Indeed, if a solution is shown to further reduce biodiversity and agricultural resilience to climate change, OSTP promotion of that solution is likely to increase distrust.  

To continue reading, please download a PDF of the letter.