155 Rivington St.
New York, NY 10002
30th April 2013
Dear Perry Chen, Charles Adler and Yancey Strickler:
Request for Kickstarter to cancel the Synthetic Biology ‘Glowing Plant: Natural Lighting with No Electricity’ project
We are writing to express our concern, in the strongest possible terms, about the listing of a project on Kickstarter that, if actualized, will likely result in widespread, random and uncontrolled release of bioengineered seeds and plants produced through the controversial and risky techniques of synthetic biology. We request that this project, which is explicitly designed as a promotional stunt for the new technology while posing real world risks to the environment, be removed from Kickstarter.
On April 23rd your website hosted the launch of a project to "Create Glowing Plants using Synthetic Biology" (Seehttp://www.kickstarter.com/projects/antonyevans/glowing-plants-natural-lighting-with-no-electricit.). This project, proposed by a team of synthetic biologists based in the Bay Area, promises, "All backers from the USA who back the project with $40 or more will receive seeds to grow a glowing plant at home. Once we have the plant, it is just a matter of breeding enough offspring to grow seeds for all backers. You can expect around 50-100 small seeds in the packet." Other levels of rewards include shipping backers a live synthetic organism (an engineered Arabidopsis plant), shipping vials of synthetic DNA and engineering a backer’s name or message as DNA code into the genome of all the plants and seeds that will be produced.
At present, over 2000 backers have made financial pledges that – amounts to approximately 200,000 viable engineered seeds due to be mailed around the United States for unregulated and unmonitored environmental release in about a year’s time. To our knowledge, this would be the first ever intentional environmental release of an avowedly "synthetic biology" organism anywhere in the world.
To put it none too finely: What on earth were assessors at Kickstarter thinking when they green-lighted this project? In case your assessors are unfamiliar with the topic of Synthetic Biology and the emerging controversy around this highly risky technology, we have appended a bibliography at the end of this letter and a description below. You can also find further material at http://www.synbiowatch.org.
We note from Kickstarter’s guidelines that certain types of products, including sunglasses, bath products and energy drinks, cannot be promoted via Kickstarter for ethical reasons. It shocked us to learn that something as clearly untested and controversial as experimental synthetic organisms should be regarded by Kickstarter as less problematic than sunglasses. We notice also that your guidelines suggest a project may be suspended if it is closely associated with "fraudulent or high risk activity." In our view, distributing hundreds of thousands of viable synthetic biology seeds in a nationwide uncontrolled experiment would, from a biosafety perspective, seem to be precisely “a high risk activity.”
A little background on synthetic biology
As you are no doubt aware, synthetic biology is a form of 'extreme genetic engineering' in which computer-designed and machine-made strands of DNA are engineered into living organisms to change their behavior. It is a step-change from previous 'transgenic' genetic engineering approaches which, while also massively controversial and subject to international bans and moratoria, utilized only naturally occurring DNA sequences. Synthetic biology, while well funded industrially, and perhaps intriguing on the face of it, is still an immature and highly experimental field using a powerful technology to invent life-forms that have no existing parallels in nature. Those life-forms are alive, viable, reproducing and their behavior outside the laboratory is at this point impossible to predict.
For this reason many of those who have so far addressed the question of how to govern this new and emerging field have erred on the side of caution and recommended against releasing synthetic organisms to the environment at this time. That is the implicit recommendation of advice from the 193 countries of the United Nations Convention on Biological Diversity (CBD), which, in 2010, advised:
"Parties and other Governments [are] to apply the precautionary approach in accordance with the Preamble to the Convention, and the Cartagena Protocol, to the introduction and use of living modified organisms for the production of biofuels as well as to the field release of synthetic life, cell, or genome into the environment, acknowledging the entitlement of Parties, in accordance with domestic legislation, to suspend the release of synthetic life, cell, or genome into the environment.” COP10 , Decision X37, para 16. (2010)
Last October the CBD reaffirmed:
"Recognizing the development of technologies associated with synthetic life, cells or genomes, and the scientific uncertainties of their potential impact on the conservation and sustainable use of biological diversity, urges Parties and invites other Governments to take a precautionary approach, in accordance with the preamble of the Convention and with Article 14, when addressing threats of significant reduction or loss of biological diversity posed by organisms, components and products resulting from synthetic biology." COP11 Decision XI, Para 4 (2012).
The CBD is now preparing a study in order to advise further international response.
In 2010, President Obama's Commission on Bioethical Issues investigated the matter of synthetic biology and raised significant concerns about environmental release of synthetic organisms noting that existing biosafety legislation for transgenic species may be insufficient for field release of synthetic organisms and that new risk assessment may be required. The Commission pointed out:
“At this early stage of development, the potential for harm through the inadvertent environmental release of organisms or other bioactive materials produced by synthetic biology requires safeguards and monitoring…Currently, the behavior of synthetic biological systems remains unpredictable. Function cannot typically be accurately predicted based on DNA sequence alone or by the shape and other characteristics of the proteins and the biological systems for which it codes. Also unknown is how synthetic biological systems will evolve. In most cases, biological systems that have been engineered by scientists quickly revert to ‘wild type’ (i.e., evolve to lose their engineered function rather than gain a new one). Although this notion may be reassuring, it does not rule out the possibility that systems might evolve in unpredictable and harmful ways, particularly if released outside the laboratory.”
From ‘New Directions – The Ethics of Synthetic Biology and Emerging Technologies’ – report of The Presidential Commission for the Study of Bioethical Issues (2010)
The insurance industry raised similar concerns:
“Synthetic organisms may infect or displace natural ones: they may find a new niche and become hard to eradicate. The future is uncertain and just because something hasn't happened yet does not mean it cannot happen.”
From Lloyds Emerging Risks Team Report, Synthetic Biology: Influencing Development
And 116 civil society groups have called for a moratorium on any release of synthetic organisms:
"Governmental bodies, international organizations and relevant parties must immediately implement strong precautionary and comprehensive oversight mechanisms enacting, incorporating and internalizing these basic principles. Until that time, there must be a moratorium on the release and commercial use of synthetic organisms and their products to prevent direct or indirect harm to people and the environment."
From The Principles for the Oversight of Synthetic Biology.
More generally, synthetic biology has been the subject of intense concern for a host of risks ranging from the potential to create new pathogens and bioweapons to the detrimental impacts on the livelihoods of poor farmers in the developing world. Just last week, a study by an Oxford University-based group identified synthetic biology as one of the leading existential risks facing our species. In a BBC report of that study, the former head of the UK Royal Society, Sir Martin Rees raised his concerns that release of synthetic organisms “could have unforeseen ecological side-effects.”
Despite these risks, synthetic biology remains largely unregulated in the United States. Federal agencies are currently relying on antiquated laws written before the advent of biotechnology to regulate these new technologies. For example, the US Department of Agriculture regulates genetically engineered crops through plant pest laws. As the Kickstarter project description explains, since the glowing plants won’t be transformed using a plant pest (typically an agrobacterium for genetically engineered crops), they say these plants will not need to be regulated by the USDA. We find it extremely troubling that Kickstarter would allow and encourage these Bay-area synthetic biologists to take advantage of this loop-hole in outdated U.S. regulations and distribute hundreds of thousands of novel synthetic organisms for casualized mass plantings across the country. That is not responsible behavior.
A 'Cause' Project
While modifying plants to glow green is not a new innovation or technically very difficult, the proponents of the "Create Glowing Plants using Synthetic Biology" project have been very clear that the aim of their Kickstarter campaign is as much about putting a 'green glow' on the controversial field of Synthetic Biology as anything else. In an interview, Glowing Plant founder Antony Evans explained, "The main goal of our project is to inspire people and awaken them to the potentials of this technology. A lot of people don't know that you can print DNA. A lot of people don't appreciate the power of the whole DIY Bio Movement and Kickstarter is a great way of getting publicity around the capabilities of this technology. So it’s really a demonstration project to inspire people to get involved with the amateur DIY Bio movement."
To that end, in addition to possibly indulging a crass marketing agenda, part of the funds they raise are being channeled into lobbying and policy work:
“Funds raised will also be used to support our work to develop an open policy framework for DIY Bio work involving recombinant DNA. This framework will provide guidelines to help others who are inspired by this project navigate the regulatory and social challenges inherent in community based synthetic biology. The framework will include recommendations for what kinds of projects are safe for DIY Bio enthusiasts and recommendations for the processes which should be put in place (such as getting experts to review the plans).”
This would seem to be a clear example of a “cause campaign,” which we note is prohibited in the Kickstarter guidelines.
In light of the ecological risks and the controversial and experimental nature of synthetic biology, we are asking Kickstarter to cancel its approval of this project and to inform backers expecting to receive engineered seed in the mail that the project is too "high risk" to continue. If backers are interested in supporting a more genuinely sustainable light project they could for example choose to fund any one of a number of Kickstarter solar power projects such as the Folding USB Solar Cell: http://www.kickstarter.com/projects/browndoggadgets/folding-usb-solar-cell
ETC Group (Action Group on Erosion, Technology and Concentration)
Friends of the Earth US.
A Short Bibliography on Synthetic Biology:
- Extreme Genetic Engineering - An Introduction to Synthetic Biology (ETC Group)– available online at http://www.etcgroup.org/content/extreme-genetic-engineering-introduction-synthetic-biology
- Synthetic Biology 101 (Friends of The Earth) – available online at ibcloud.s3.amazonaws.com/93/41/1/971/Issue_brief_-_Synthetic_biology_101.pdf
- The Principles for the Oversight of Synthetic Biology – available online at http://www.foe.org/news/archives/2012-03-global-coalition-calls-oversigh...
- Submission on Synthetic Biology as a New And Emerging Issue to The Convention on Biological Diversity - The International Civil Society Working Group on Synthetic Biology – available online at http://www.cbd.int/doc/emerging-issues/Int-Civil-Soc-WG-Synthetic-Biology-2011-013-en.pdf
- The New Biomassters – Synthetic Biology and the Next Assault on Biodiversity and Livelihoods (ETC Group)– available online at http://www.etcgroup.org/content/new-biomassters