September 5, 2025
The Honorable Brooke Rollins
Secretary
U.S. Department of Agriculture
1400 Independence Ave SW
Washington, DC 20250
CC: Deputy Secretary Stephen Vaden
Re: Secretary Memorandum: SM 1078-015, Department of Agriculture Reorganization Plan
Dear Secretary Rollins,
Thank you for your leadership in proposing the Department of Agriculture Reorganization
Plan and for your willingness to consider and incorporate adjustments based on comments
from the USDA stakeholder community as details of the reorganization and relocation plan
are finalized.
We, the undersigned organizations, represent scientists and non-profit organizations who
regularly interface with USDA Biotechnology Regulatory Services (BRS); and we are writing
to ask that BRS remain in the National Capital Region (NCR).
As you know, BRS regulates the importation, interstate movement, and environmental
release of certain crops, insects, and microbes developed using modern genetic
techniques. Its workforce reflects a highly specialized expertise that cannot easily be
replaced. As scientists and developers use cutting-edge biotechnologies to provide the
U.S. agricultural sector with new and improved crops, microbes, and insects, we require
BRS oversight and guidance. Without BRS’s professional expertise in scientific and
regulatory matters, our nation’s product developers and farmers will be placed at an
international disadvantage as other countries’ regulatory processes proceed with greater
speed and efficiency.
BRS Should Remain in the National Capital Region to Protect U.S. Biotechnology
Leadership Through Federal Agency Coordination & Service to Stakeholders
BRS has long been a reliable, knowledgeable, and accessible partner for stakeholders
developing each new generation of agricultural innovation. Commitment to collaboration is
evident; even as the Covid pandemic shuttered offices and ended in-person meetings in
2020, BRS staff were among the first USDA workers back in the office resuming in-person
operations, recognizing the critical importance of face-to face engagement to discuss
highly technical concerns. BRS continues to engage with stakeholders either one-on-one
or through larger meetings, in which hundreds have participated over the last several years.
Just as vital as stakeholder engagement is coordination across federal agencies, which
avoids duplication of effort and ensures efficiency. Although other USDA programs may
benefit from newly co-located USDA offices, BRS benefits its stakeholders – and the nation
– most by coordinating with its federal regulatory counterparts in the Food and Drug
Administration (FDA) and the Environmental Protection Agency (EPA). These agencies,
alongside BRS, comprise the Coordinated Framework for the Regulation of Biotechnology.
In-person interagency meetings cannot be replaced virtually without sacrificing speed,
clarity, and the informal but essential coordination that comes from proximity.
Your memorandum cites relocation of USDA staff as necessary for recruitment, and we
recognize that the NCR does have a high cost of living. However, BRS has not had
challenges recruiting staff, and it was fully staffed before the Deferred Resignation Program
(DRP) and hiring freeze. Fully staffed, BRS was able to host in-person meetings, ramp up
expedient permitting, and execute a quick regulatory pivot following the vacatur of the
SECURE rule last fall.
The country depends on BRS to thoroughly and expediently move new innovations through
the regulatory process. With the BRS NCR staff at only 67 F.T.E.s, as requested in the
President’s FY 2026 Budget Request, and with a significant proportion of that staff working
as inspectors already dispersed throughout the country, any attrition of core NCR-based
staff through relocation will inevitably result in significant delays for approvals, putting our
agricultural industry directly in the crosshairs of global competitors.
Maintaining BRS in the NCR is not just a matter of convivence, it is a strategic imperative for
the nation and its farmers. The United States cannot afford to weaken BRS at a time when
global competition in agricultural biotechnology is intensifying. We respectfully urge USDA
to preserve BRS’s current location and ensure the nation’s continued leadership in
agriculture biotechnology.
Sincerely,
American Phytopathological Society
American Society for Microbiology
American Society of Agronomy
American Society of Plant Biologists
California Life Sciences
Crop Science Society of America
Entomological Society of America
Georgia Life Sciences
Montana Biosciences Organization
NC Life Sciences Organization
Oregon Bioscience Association
Soil Science Society of America
Weed Science Society of Americ