Today, we led a coalition letter to the Environmental Protection Agency signed by leading biotechnology and policy institutions and leaders recommending a pro-innovation pathway for advanced biocontrol technologies, including gene drives, other genetic technologies, and microbe-based systems. The letter comes after Executive Order 14333 directed the agency to update its regulations for a campaign against invasive mosquitoes and ticks in Washington, D.C.
Dear Administrator Zeldin,
We represent a broad coalition of industry, policy, science, and conservation institutions and leaders. We have a proven record of both developing and deploying some of the safest and most effective pest biocontrol technologies and advancing transformative policy ideas in Washington, D.C. and beyond.
The proliferation of the most destructive pests, including invasive mosquitoes and disease-carrying ticks, is a threat to Americans’ health, families’ enjoyment of the outdoors, and our landscapes. We applaud President Trump’s Executive Order 14433, “Eliminating Disease-Carrying Pests and Restoring Enjoyment of the Great Outdoors,” targeting invasive mosquitoes and disease-carrying ticks in Washington, D.C.
The order correctly identifies the importance of advanced biocontrol technologies in this effort. In coordination with local and state governments, an approach that integrates existing and new biotechnologies along with conventional methods is critical for success. Further, the Environmental Protection Agency’s directive to develop a regulatory framework for these technologies would not only support invasive mosquito and tick control in Washington, but it could also enable combatting destructive pests and invasive species throughout the country, including the New World screwworm, rodents, Asian carp, and more. It would also help reduce the use of broad-spectrum, chemical pesticides, mitigating exposure for Americans. In that spirit, we are writing to highlight three recommendations for the EPA’s biocontrol regulatory framework:
- Develop a safety-based regulatory pathway for advanced biocontrol technologies: For many novel biocontrol technologies, the necessary data and review standards for EPA registration are unclear. In coordination with other relevant agencies, we encourage the EPA to develop a technology-neutral, safety-based regulatory pathway for biocontrol products applicable for methods including Wolbachia-based Incompatible Insect Technique, precision-guided Sterile Insect Technique, gene drives, and technologies not yet developed. The pathway should apply proportionate standards based on the particular characteristics of the product, including target species status, self-limiting nature, and reversibility. The pathway should also apply to amendments of registered products, such as new geographies and use patterns, without reopening existing registrations. To enable management of other destructive pests, we also encourage the EPA to design this pathway to be applicable for technologies targeting species including invasive plants and non-insect animals.
- Base labeling restrictions on science: Consistent with applicable law, the use of advanced biocontrol technologies should be permitted by the EPA wherever the science indicates it is safe and effective. When geographic restrictions are appropriate, we encourage the EPA to provide a science-based justification, using guidance based on the interaction of the product with a particular environment rather than simply relying on political boundaries like state borders as ecological proxies. We also encourage the EPA to give timely review to registrant-requested amendments that refine existing restrictions where the science supports it.
- Assess new biocontrol technologies on time: Late pesticide application determinations from the EPA fell from 74% in FY 2024 to 65% in FY 2025, and we appreciate your efforts to mitigate review time and reduce backlog actions. But so far, few applications for the commercial use of biocontrol technologies have received a decision within the statutory 15-22 month timeline targets. In implementing President Trump’s executive order, we encourage the EPA to expedite review of pending applications and continue its commitment to optimize pesticide registration by using all available tools, including AI systems, budget requests to Congress, and staffing adjustments, to review new biocontrol technologies on time.
At this moment, the EPA stands at a critical position. By applying commonsense steps to expeditiously review a range of biocontrol technologies based on the strongest safety and effectiveness standards, it can help catalyze a new era of wise stewardship. We look forward to supporting the EPA and the rest of the administration in safely managing the most destructive pests in Washington, D.C. and beyond.
Sincerely,
Zach Graves
President and CEO
Foundation for American Innovation*
Max Bodach
Executive Vice President
Foundation for American Innovation*
Ian Banks
Director of Science and Innovation
Foundation for American Innovation*
Isaiah Menning
Research Fellow
Foundation for American Innovation*
American Conservation Coalition
The Breakthrough Institute
The Heritage Foundation
Omar Akbari
Tata Chancellor's Endowed Professor
University of California San Diego*
Alex Dehgan
CEO
Conservation X Labs*
Joshua Elliott
Chief Scientist
Renaissance Philanthropy*
Grey Frandsen
CEO
Flyttr, Inc.*
Galen Hines-Pierce
Founder and Principal
Minerva Fund*
Nikolay Kandul
Founder and CEO
Synvect, Inc.*
Todd Montgomery
Founder
Bee Safe Mosquito Control*
Ryan Orbuch
Partner
Lowercarbon Capital*
Gerald W. Parker
Associate Dean for Global One Health
College of Veterinary Medicine & Biomedical Sciences, Texas A&M University*
Giorgio Rocca
Co-founder and CEO
Biocentis*
Maya Rosen
Writer and researcher, author of “Mosquitoes are a choice”
Maximillian Seunik
Executive Director
Screwworm Free Future*
John Shelton
Vice President of Policy
Advancing American Freedom*
Katelyn Shelton
Visiting Fellow
Ethics and Public Policy Center*
Lyman Stone
Director of the Pronatalism Initiative
Institute for Family Studies*
*Organization listed for identification purposes only.
