ITIF submitted comments to the U.S. Department of Agriculture’s (USDA) Animal and Plant Health Inspection Service on its proposed revisions to regulations governing crops improved through biotechnology. USDA is proposing the most significant revisions since 1992 to regulations governing development and use of crops improved through biotechnology. They document the remarkable safety record accrued over three decades of experience, yet propose a new and undefined regulatory process that would treat demonstrably safe innovations as guilty until proven innocent. There is no scientific justification for this proposal in data or experience, and it would abandon the science-based policy for risk assessment of biotech innovations laid down in 1986. The proposal needs drastic revisions to bring it in line with experience so as to serve the public good.