By Lynn L. Bergeson and Carla N. Hutton
The U.S. Government Accountability Office (GAO) published a “Science & Tech Spotlight” on synthetic biology on April 17, 2023. GAO defines synthetic biology as “a multidisciplinary field of biotechnology that involves engineering the genetic material of organisms -- such as viruses, bacteria, yeast, plants, or animals -- to have new characteristics.” According to GAO, scientists are currently exploring the use of synthetic biology to address environmental challenges by engineering organisms to use carbon dioxide, produce biofuels for vehicles, and transform methane into biodegradable plastics. GAO notes that the synthetic biology market could grow from about $10 billion in 2021 to between $37 billion and $100 billion dollars by 2030. Opportunities include:
- Widely adaptable. Synthetic biology holds the potential to help diagnose and treat diseases, improve industrial processes, and address some environmental challenges;
- More equitable access to biotechnology. Some of the tools needed for synthetic biology are low-cost and widely available, which could make access to beneficial applications more equitable; and
- Conservation efforts. Synthetic biology could support endangered species conservation, for example, by altering the genes of endangered plants to make them resilient to diseases.
GAO notes the following challenges:
- Safety and security concerns. Synthetic biology could pose a significant threat to national security if it were used for nefarious purposes, such as developing new biological or chemical weapons. Additionally, the computational tools used for synthetic biology could be vulnerable to cyberthreats such as automation hacking. For example, a bad actor could manipulate or steal information and use it to create drugs, weapons, or other harmful products.
- Environmental effects. Organisms made using synthetic biology and released into the environment could have unknown, unintended, and potentially irreversible effects on ecosystems. Such effects could be widespread if, for example, these organisms negatively affected food or water systems.
- Public acceptance and access. The public may hesitate to accept certain applications of synthetic biology due to concerns about interfering with nature and about unintended effects. In addition, some medical applications could be inaccessible for some patients due to cost or location of treatment centers.
GAO concludes the “Science & Tech Spotlight” with the following policy context and questions:
- Do policymakers have adequate access to expertise and resources to evaluate the societal effects and public policy implications of synthetic biology research and development?
- How effective is the coordination among 1) domestic and 2) global stakeholders for monitoring and assessing the risks associated with advances in synthetic biology research and applications?
- Is the current regulatory framework sufficient to address ongoing and future applications and their effects without unnecessarily hindering U.S. competitiveness in synthetic biology?
By Lynn L. Bergeson and Carla N. Hutton
The U.S. Government Accountability Office (GAO) publicly released a report on March 27, 2023, entitled Sustainable Aviation Fuel: Agencies Should Track Progress toward Ambitious Federal Goals. According to GAO, sustainable aviation fuel (SAF) production and use in the United States have increased in recent years; this fuel is now used by airlines at two major commercial airports in California. GAO states that while U.S. production reached 15.8 million gallons in 2022, it accounted for less than 0.1 percent of the total jet fuel used by major U.S. airlines, “fall[ing] well below the previous Federal Aviation Administration goal for U.S. airlines to use 1 billion gallons of SAF per year by 2018.”
To reduce greenhouse gas emissions (GHG) from the aviation sector, the White House announced an SAF Grand Challenge in September 2021. The Grand Challenge goal is to supply three billion gallons of SAF per year by 2030 and 100 percent of expected domestic commercial jet fuel use by 2050. GAO was asked to review the federal role in SAF. GAO’s report discusses the state of SAF production and use for the U.S. commercial aviation industry and factors shaping this market, identifies how federal agencies have supported SAF, and assesses how they will monitor progress toward Grand Challenge goals. According to GAO, the roadmap published by the U.S. Department of Transportation (DOT), U.S. Department of Energy (DOE), and U.S. Department of Agriculture (USDA) does not establish performance measures to monitor, evaluate, and report the results of these actions. GAO states that without performance measures, the agencies are not well positioned to evaluate the effectiveness of federal government actions to meet the Grand Challenge goals. In contrast, according to GAO, establishing and using such measures can help identify progress on the extent to which SAF is contributing to emission reductions.
GAO recommended that DOT, DOE, and USDA develop and incorporate performance measures into the Grand Challenge roadmap. According to GAO, DOT and USDA concurred. DOE indicated the recommendation is completed and that planned roadmap activities will enable progress to be measured. GAO notes that as discussed in its report, it disagrees that the recommendation is completed.
By Lynn L. Bergeson
The U.S. Government Accountability Office (GAO) posted a WatchBlog item entitled “Can Chemical Recycling Reduce Plastic Pollution?” on October 5, 2021. The item looks at GAO’s September 2021 Science & Tech Spotlight: Advanced Plastic Recycling. According to GAO, chemical recycling could reduce the amount of plastic that ends up in landfills, potentially reducing the release of chemicals into the environment. Chemical recycling can produce high-quality raw materials, decreasing the demand for fossil fuels and other natural resources. GAO states that the obstacles to using chemical recycling include process and technology challenges, high startup and operating costs, and limited incentives for recycling innovation and investment. GAO notes that new plastics produced from fossil fuels are typically cheaper to produce than recycled plastics, in part due to transportation costs and limited recycling infrastructure, making recycled plastics less marketable. Key questions for policymakers include:
What steps could the federal government, states, and other stakeholders take to further incentivize chemical recycling rather than disposal? What are the potential benefits and challenges of these approaches?
What steps could policymakers take to support a transition toward a circular economy -- one in which products are not disposed of but are recycled for reuse including innovation -- and investment in manufacturing and recycling capacity?
What might policymakers do to promote advanced recycling technologies while also reducing the hazards associated with existing plastic production and recycling methods?
One issue that GAO fails to consider is the regulatory status of depolymerized plastic. Furthermore, making a polymer by depolymerizing plastic is, according to the Toxic Substances Control Act (TSCA) nomenclature rules, different than the virgin polymer. These nomenclature complications will likely be a barrier to the commercialization of the closed-loop chemical recycling of plastics.
By Lynn L. Bergeson and Ligia Duarte Botelho, M.A.
On January 13, 2020, U.S. Representative Cindy Axne announced that the Government Accountability Office (GAO) has responded to a bipartisan letter submitted by members of the House Biofuels Caucus (HBC) requesting an investigation into misuse of small refinery exemptions (SREs) by the U.S. Environmental Protection Agency (EPA). Submitted in August 2019, the bipartisan letter requested that GAO examine EPA’s review and approval of SRE waivers under the Renewable Fuel Standard (RFS). HBC’s letter also included a request for inspection of the U.S. Department of Energy’s (DOE) viability scores for SREs reviewed in 2018. HBC’s concerns were mostly related to the economic consequences to rural communities due to the exemption of approximately four billion gallons of fuel from the RFS in 2018. In addition to the aforementioned requests, HBC members asked that GAO also consider the following questions:
- Has DOE changed the criteria, the interpretation of the criteria, the methodology, or any other significant aspect of how it makes its recommendations to EPA for SREs?
- Other than the viability score provided by DOE, what other factors are being considered by EPA in awarding SRE waivers? How has this changed since the previous Administration?
- Since the development of DOE’s 2011 methodology, what percentage of applications that received a disqualifying viability score from the DOE were granted?
- How many times has DOE recommended a partial waiver for a refinery?
- Has EPA granted a partial waiver?
- Does EPA or DOE consider the economic viability of the parent refiner company when considering an application from an individual refinery?
- Does DOE take Renewable Identification Numbers (RIN) into account when assessing relief petitions?
On January 10, 2020, GAO responded to the bipartisan request, agreeing to review matters related to the approval of SRE waivers and stating that it will begin its work shortly. Mark E. Gaffigan, Managing Director of GAO’s Natural Resources and Environment, and his staff will be in charge of the investigation.
In August 2019, Axne had also submitted a letter to EPA’s Acting Inspector General (IG), Charles Sheehan, requesting an investigation of this matter. In its response letter to HBC, GAO stated that it will be in contact with the cognizant IG’s office to ensure that efforts are not duplicated.