Comment submitted by Ann Thresher

To Whomever it may Concern, I am aware that you will be receiving numerous comments from top conservation, agriculture, and genetic researchers. Here, I wanted to offer a different perspective. I am an environmental ethicist, with a specialty in genetic tools. I am also a public policy researcher, working on the intersection of these two domains. The upcoming regulatory decision surrounding Knockout SWD is an important one for many reasons, and one that needs to be carefully scrutinised not just for risk, efficacy, and impact, but for the ethics of these emerging technologies. Knockout is particularly interesting as an ethical test case because: 1.It is a non-heritable genetic modification, reducing the risk of long-term off-target effects and bypassing concerns about human right to permanently modify species at the genetic level for our own benefit. 2.It offers a way to reduce the use of harmful pesticides that are part of an ongoing insect apocalypse. 3.It significantly reduces the current mass-killing of insects, an under-considered moral cost of much of agriculture pest control. 4.It sets precedence for using these kinds of technologies to address some of the worst moral harms humans have created, including deploying genetic tools for mitigating the invasive species crisis and helping restore ecosystems devastated by climate change. 5.It raises questions about what a ‘good’ state for ecosystems and animals is, and how to weigh these against the well-being of humans. How much can we change the world to suit our own goals? What are our long-term aims for the animals and ecosystems around us? 6.It opens up questions about who gets to decide on where and when to deploy these technologies, particularly since these species will not respect domestic or international borders. 7.It opens up questions about how much we should treat species as tools for human benefit, rather than actors in their own rights with their own projects and goals. Anthropocentric models are notoriously fraught and ethically hard to defend, and non-human perspectives need to be a part of our regulation and deployment of these technologies. 8.It sets the stage for further conversations about more intensive genetic technologies including ones that could permanently alter ecosystems, such as the coral restoration work being currently done in the US and abroad. Environmental ethicists are experts in these issues, and I want to encourage you to reach out and engage with the field during your considerations, alongside other experts in genetic tools and agriculture. Regards, Professor Ann C Thresher