[gone35]

Exactly, (...)

Seriously? As the CEO of the company and the person ultimately responsible for this project, it is troubling that you endorse these simplistic and erroneous views of plant biosafety. Fitness is notoriously ecosystem-dependent and hard to predict, which is why microcosm and field experiments-based risk assessments exist in the first place --it unfortunately can't just be eyeballed from a simple metabolic account like that. And either way there is the additional risk of transgene flow, which is even more long-term and less understood --especially for such relatively distant horizontal transfers.

You might have (unaccountably) skirted APHIS regulation, but that doesn't mean you don't have an ethical obligation to (1) thoroughly assess the biosafety of these plants; and (2) be frank in communicating these risks (and their uncertainty) to the public, even if they do not make as clean of a narrative as one would like.

[technotony]

One of the things we try to do with this project is simplify things so that people can more clearly understand. Intuitively it's not clear why there are risk from our work (beyond the unknown unknowns). We have engaged in a number of panels with expert ecologists and after one an MIT professor asked why we were always talking about glowing plants as there were no serious risks here. You can read one of the reports here: http://www.wilsoncenter.org/sites/default/files/SYNBIO_res_a...

Also, specifically to your point about transgene flow. Higher level organisms (eg animals, plants) very very rarely exchange DNA - this is a good thing or else you might start photosynthesizing after eating salad for lunch. There are a couple of recent papers saying maybe (and that's maybe in a scientific probability, ie small probability) this happens on the order of millions of years. APHIS doesn't even look at this issue anymore, here's their comment on it:

Potential impacts from transferring genetic information from plant to organisms with which it cannot interbreed • First, many genomes (or parts thereof) have been sequenced from bacteria that are closely associated with plants including Agrobacterium and Rhizobium (Kaneko et al. 2000; Wood et al. 2001; Kaneko et al. 2002). There is no evidence that these organisms contain genes derived from plants. • Second, in cases where review of sequence data implied that horizontal gene transfer occurred, these events are believed to occur on an evolutionary time scale on the order of millions of years (Koonin et al. 2001; Brown 2003). • Third, transgene DNA promoters and coding sequences are optimized for plant expression, not prokaryotic bacterial expression. Thus even if horizontal gene transfer occurred, proteins corresponding to the transgenes are not likely to be produced. • Fourth, the FDA has evaluated horizontal gene transfer from the use of antibiotic resistance marker genes, and concluded that the likelihood of transfer of antibiotic resistance genes from plant genomes to microorganisms in the gastrointestinal tract of humans or animals, or in the environment, is remote (Council for Biotechnology Information, 2001; http://vm.cfsan.fda.gov/~dms/opa-armg.html, accessed 1/26/10). • Finally, a recent review of issues related to horizontal gene transfer concluded that this type of gene transfer is unlikely to occur and poses negligible risks to human health or the environment (Keese 2008).

[gone35]

Intuitively it's not clear why there are risks from our work.

Far from it! The very workshop minutes you are citing [1, Appendix 3] directly contradict your point, with participants raising a number of serious concerns about your project:

"Many questions focused on the ethical and philosophical issues associated with the project, including matters of consenting public and responsible science practice. However, only questions relating to the research agenda, like those impacting regulatory consideration and potential ecological effects, are included here.

Ecological interactions:

- How will the impact of the bioluminescence from the plants on wild organisms be tracked across seed destinations? If this can’t be tracked or known ahead of time, then how is the application ready for release?

- How have the interactions of insects with the glowing plant been characterized? Does this have the potential to disrupt pollinators?

- Arabadopsis is frequently used in laboratories specifically because it is easy to grow and is a weedy species. How does this align with comments made regarding the difficulty of growing the plants, and the extreme unlikelihood that the seeds would take root and grow if released outdoors?

- Were any types of biocontrol mechanisms employed or tested in the system? Why was sterility not introduced into the system when it could serve such a purpose?

Determining regulatory coverage:

- Habitats of relevance.

- Tests for characterizing the application: The seed packets will not be regulated because the seeds were created using gene guns, while the DIY maker kits will be regulated because the system will rely on Agrobacterium. Neither can be shipped internationally. However, once these are distributed, how will use be monitored? If the plants are expected to be sent to thousands of individual sites around the country, how are habitats of relevance being determined? Are all of these locations being tracked, characterized, and assessed for specific vulnerabilities in advance of product release? The USDA APHIS test framework is insufficient for this purpose. How could a model be developed to evaluate such a widely distributed application? What questions would need addressing in order to appropriately characterize the effort?

- Demonstration of impact: Compare the altered plants to other mustards, and assess how well they grow. A series of greenhouse competition assays in a variety of environ- ments would be a good start, and any identified differences could point to areas requiring further study. Also study known pathway interactions up- and downstream. Emphasize the study of the resulting phenotypes, not the genetic modifications."

[1] http://www.wilsoncenter.org/sites/default/files/SYNBIO_res_a...

[gone35]

In regards to your "response" to the risk of transgene flow, frankly I don't even know where to begin...

First, what you cite is not a comment from APHIS, but a verbatim quote from an earlier post from your company blog [1]; which is supposed to be a draft outline of proposed biosafety tests, but which largely consists of paraphrases and language from two already completed APHIS plant pest risk assessments for a completely unrelated rose variety using plasmid transgenes, some of whose conclusions and comments you then use to (wrongly) extrapolate about your product and its risks. This is highly misleading, to say the least.

Second, your statements about transgene flow risk are outdated and mischaracterize current knowledge. Suffice to say, your technical team (or even any of the experts you engage with, say, in SYNBIO 7) is more than capable of briefing you on the current re-assessment and state of the art.

Best of luck with your project, but do keep in mind ethical obligations to your stakeholders override any other imperatives or agendas you might have.

[1] http://blog.glowingplant.com/post/57840496382/tests-we-plan-...