BIO Comments to USDA’s Office of Budget and Program Analysis on Identifying Regulatory Reform Initiatives, September 15, 2017
September 15, 2017
Office of Budget and Program Analysis
United States Department of Agriculture
Jamie L. Whitten Building, Room 101-A
1400 Independence Ave SW
Washington DC 20250
Re: Identifying Regulatory Reform Initiatives
Dear Ms. Adcock:
The Biotechnology Innovation Organization (BIO) is pleased to submit these comments in response to the USDA’s request for information on “Identifying Regulatory Reform Initiatives,” published in the Federal Register on July 17, 2017.1 Thank you for the opportunity to provide input as the U.S. Department of Agriculture (USDA or the Agency) considers opportunities to improve customer service and remove unintended barriers to participation in its programs in ways that least interfere with its customers and allow USDA to accomplish its mission.
BIO is the world's largest bioscience trade association representing nearly 1,000 biotechnology companies, academic institutions, state biotechnology centers and related organizations across the United States and in more than 30 other nations. BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology products. BIO represents the majority of agricultural biotechnology product developers in North America, including companies developing products subject to USDA oversight. We focus our comments here on the regulatory oversight of products of agricultural biotechnology by USDA’s Animal and Plant Health Inspection Service (APHIS). BIO may submit additional comments on other aspects of USDA programs in future segments of this comment period.
Over the past two decades, commodity crops improved with biotechnology have been integrated into agricultural systems so completely that in countries where they are available, biotech seeds are viewed as the routine choice, not the exception; 18 million farmers in 26 countries grew biotech crops in 2015.2 The economic and societal impacts of using biotech seeds have been considerable and entirely positive. Biotechnology enhanced seeds have added $72.9 billion in agricultural value to the global economy, to date, and $6.9 billion in 2015 alone.3 Globally, their use has reduced the use of pesticides by 37%; increased crop yields by 22%; and improved farmer incomes by, on average, 68%...