Translating Vision into Action: FAS Commentary on the NSCEB Final Report and the Future of U.S. Biotechnology
Advancing the U.S. leadership in emerging biotechnology is a strategic imperative, one that will shape regional development within the U.S., economic competitiveness abroad, and our national security for decades to come. In the past few years, the contribution of biotechnology to the U.S. economy (referred to as the bioeconomy) has grown significantly, contributing over $210 billion to GDP and creating more than 640,000 domestic jobs, cementing its role as a major and expanding economic force. The impact of biotechnologies and biomanufacturing can be seen across diverse sectors and geographies, with applications spanning agriculture, energy, industrial manufacturing, and health. As biotechnology continues to drive innovation, it is emerging as a core engine of the next industrial revolution.
To maximize the strategic potential of emerging biotechnology, Congress established the bipartisan National Security Commission on Emerging Biotechnology (NSCEB) through the FY22 National Defense Authorization Act. The commission was tasked with conducting a comprehensive review of how advancements in biotechnology and related technologies will shape the current and future missions of the Department of Defense (DOD), and developing actionable policy recommendations to support the adoption and advancement of biotechnology within DOD and across the federal government. This effort culminated in a report, “Charting the Future of Biotechnology”, delivered to Congress in April 2025. The final report outlines 49 recommendations aimed at accelerating biotechnology innovation and scaling the U.S. biomanufacturing base, reinforcing the bioeconomy as a strategic pillar of national security and economic competitiveness.
In addition to developing a series of recommendations to promote and grow the U.S. bioeconomy, the Commission has also been tasked with facilitating the implementation and adoption of these policy recommendations by Congress and relevant federal agencies. To date, several pieces of legislation have been introduced in both the 118th and 119th Congress that incorporate recommendations from NSCEB’s interim and final reports (Table 1). This Legislation Tracker will be updated as this legislation moves through the process and as new bills are introduced.
The NSCEB report represents a critical policy opportunity for the U.S. bioeconomy. It proposes an injection of $15 billion to support sustained growth in biotechnology innovation and biomanufacturing through strategic investment and improved coordination. This level of investment is significant and would signal congressional support for the bioeconomy that goes beyond that seen in CHIPS and Science Act and the Inflation Reduction Act of 2022. This much needed infusion of federal investment offers a timely opportunity to build on existing momentum and unlock the next phase of U.S. leadership in the bioeconomy.
The recommendations in the report should be seen as opportunities for engagement with the Commission and with Congress for further refinement of these policy ideas. As the Commission begins its work on implementation, they have called on stakeholders across the bioeconomy to help refine and strengthen its proposals. Responding to this need, the Federation of American Scientists (FAS) has identified priority areas requiring greater clarity and has issued an open call for supplemental recommendations and policy proposals through the Day One Open Call process.
Overall, FAS supports the Commission’s final report and we applaud the Commission’s efforts to elevate the national conversation around emerging biotechnologies. The report provides a necessary foundation for long-term federal strategy and investment in biotechnology and biomanufacturing. At the same time, there remain clear opportunities to strengthen the recommendations through greater specificity and deeper stakeholder engagement. Two overarching decisions by the Commission deserve some additional scrutiny. First, the report’s adversarial framing towards China, while grounded in strategic reality, risks overlooking opportunities for targeted collaboration that could yield global benefits, particularly in areas where scientific progress depends on multinational cooperation. Second, the final report gives limited attention to the agricultural sector, despite its clear relevance to national security and the DOD’s growing interest in agricultural biotechnology. The “Additional Considerations” section does include a constructive call to modernize the USDA’s BioPreferred Program and update federal classification systems, recommendations that echo those issued by FAS. A more comprehensive approach toward this sector is needed.
The following sections summarize the report’s key pillars and provide analysis, highlighting core recommendations and identifying opportunities where additional detail and stakeholder input, through the Day One Open Call, will be essential for translating the report’s vision into actionable, high-impact policy. Additionally, the Supplementary Recommendations Table for the NSCEB Final Report (Table 2) lists each of the recommendations from the pillars and cross references related proposals from prior FAS work, subject matter experts, and Day One Memos submitted by external stakeholders.
Table 2: Supplementary Recommendations Table for the NSCEB Final Report
Pillar 1. Prioritize Biotechnology at the National Level
Pillar 1 of the report emphasizes the need to prioritize biotechnology at the national level. The recommendations within this pillar are essential for the development of a cohesive national strategy, and we encourage Congress to consider incorporating terminology and drawing on previous policy related to the bioeconomy to ensure that previous progress related to emerging biotechnologies is not lost.
A central recommendation within this Pillar is the establishment of the National Biotechnology Coordination Office (NBCO), which would reduce fragmentation and elevate biotechnology as a national priority. To succeed, the NBCO must address challenges faced by past coordination bodies and be empowered by the administration to drive cross-agency strategy despite differing institutional perspectives. While the presidential appointment of the director could lend authority, it also risks politicization and strategic shifts that may destabilize the sector. Success will depend on clarity of roles, coordination across functions, and strong institutional support for implementation.
FAS provided several additional recommendations and insights on these topics (see Table 2) to make them more nuanced and actionable by Congress, including:
- Coordinating the U.S. Government Approach to the Bioeconomy by Sarah Carter
- A National Bioeconomy Manufacturing and Innovation Initiative by Alexander Titus
Pillar 2. Mobilize the Private Sector to get U.S. Products to Scale
Pillar 2 of the final report focuses on mobilizing the private sector to strengthen biotechnology products by addressing key challenges to the sector, including regulatory reform, financing obstacles, and infrastructure and data needs. While the report correctly identifies long standing regulatory bottlenecks for products of biotechnology under the Coordinated Framework, including unclear oversight and interagency conflicts, it also acknowledges statutory complexities that make reform difficult. Empowering the Office of Management and Budget’s Office of Information and Regulatory Affairs (OIRA) to mediate these disputes is a promising approach, but would require statutory reinforcement. Similarly, proposals to modernize regulatory capacity, such as agency fellowships and regulatory science programs, highlight a critical need for technical expertise within government, though questions remain about institutional placement and long-term sustainability.
On financing and infrastructure, the report points to real gaps in early-stage capital and scale-up capacity, particularly for bridging the “Valley of Death” for biotechnology manufacturing. Concepts like advance market commitments and a new investment fund have potential, but their impact will depend heavily on design, risk management, and alignment with existing capital pipelines. The infrastructure recommendations are strong, but coordination challenges, particularly among national labs, regional hubs, and entities like BioMADE, must be addressed to avoid duplication or underutilization and approaches to securing bioeconomy infrastructure and data are underdeveloped. It will be critical to better define what constitutes critical biotechnology infrastructure and how it should be protected.
FAS provided significant expertise on these topics (see Table 2), such as:
- Coordinating the U.S. Government Approach to the Bioeconomy by Sarah Carter
- Regulations for the Bioeconomy by Sarah Carter
- A National Frontier Tech Public-Private Partnership to Spur Economic Growth by Katie Rae, Orin Hoffman & Michael Kearney
- De-Risking the U.S. Bioeconomy by Establishing Financial Mechanisms to Drive Growth and Innovation by Nazish Jeffery & Zak Weston
- Advancing the U.S. Bioindustrial Production Sector by Michael Fisher
- Closing Critical Gaps from Lab to Market by Phil Weilerstein, Shaheen Mamawala, and Heath Naquin
- Strengthening the U.S. Biomanufacturing Sector Through Standardization by Chris Stowers
- Summary Report – December 7, 2022, Bioeconomy Policy Workshop: Financial and Economic Tools
- Project BOoST: A Biomanufacturing Test Facility Network for Bioprocess Optimization, Scaling, and Training by Ed Charles & Chris Fracchia
One of the NSCEB’s recommendations in particular would benefit from additional input from external subject matter experts to make it more concrete and actionable for Congress:
- Recommendation 2.2d: Congress should improve the effectiveness and reach of the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs to support early-stage innovation. Specifically, stakeholder input on:
- Which areas of biotechnology or sectors within the bioeconomy would most benefit from SBIR and STTR investment?
- How can these programs better support not only early- but also late-stage innovation?
If you have specific policy suggestions related to this topic, we encourage you to submit your ideas through the Day One Open Call page at FAS.
Pillar 3. Maximize the Benefits of Biotechnology for Defense
Pillar 3 of the final report focuses on maximizing the benefits of biotechnology for national defense, with an emphasis on the intelligence community and the Department of Defense (DOD). This pillar includes recommendations related to BioMADE oversight as well as internal workforce education on biotechnology. While oversight of BioMADE is important, it is unclear why additional oversight from Congress is needed for this manufacturing institute above and beyond that provided by its federal sponsor. Additionally, it will be essential for DOD to establish a mechanism for regularly updating workforce education in biotechnology, given the sector’s rapid and continuous evolution.
More broadly, this Pillar appropriately reframes biotechnology as a strategic capability, beyond its traditional role in R&D. This shift in perspective is timely, but realizing the potential of these technologies will require significant institutional change. Ethical use frameworks, particularly around dual-use risks (warfighter enhancement, surveillance, and environmental impact) must be developed through a transparent process that extends beyond DOD to include external stakeholders and independent organizations. In addition, proposed investment and export controls aimed at limiting adversarial advantage must be carefully scoped and implemented. The Department of Commerce (DOC) has published multiple Requests for Information (2018, 2020) to understand and delineate “high-risk” biotech products. Yet, DOC has not added new biotech products to the export list, which highlights the complexity of this task, and underscores the need for precision to avoid stifling beneficial collaboration or disrupting global supply chains.
FAS provided several additional recommendations and insights on these topics (see Table 2) to make them more nuanced and actionable by Congress, including:
- CLimate Improvements through Modern Biotechnology (CLIMB) — A National Center for Bioengineering Solutions to Climate Change and Environmental Challenges by Jennifer Panlilio & Hanny Rivera
- A Foundational Technology Development and Deployment Office to Create Jobs by Katie Rae, Michael Kearney, and Orin Hoffman
Pillar 4. Out-Innovate our Strategic Competitors
Pillar 4 of the NSCEB’s report offers recommendations for strengthening the biotechnology sector to out-innovate global competitors. It focuses on building robust data ecosystems, enhancing biosecurity, and expanding bio R&D infrastructure within the U.S. A central theme is the creation of a modern biological data ecosystem, which would provide the foundational infrastructure necessary to accelerate innovation. While a biological data ecosystem and associated standards are timely, several technical and governance challenges must be addressed, like harmonizing legacy systems, defining AI-readiness, and coordinating cloud lab integration. These complexities present an opportunity for stakeholder engagement and thoughtful design.
Within the Pillar, proposals that call for expanding National Lab capabilities and funding interdisciplinary biotechnology research are directionally strong, but success will depend on interagency coordination and alignment with industry needs. Finally, the report calls for stronger governance of biosafety and biosecurity, though its assertion that past efforts have “failed” could benefit from more nuanced analysis.
While FAS provided expertise on these topics (see Table 2), such as:
- A National Bioeconomy Manufacturing and Innovation Initiative by Alexander Titus
- Kickstarting Collaborative, AI-Ready Datasets in the Life Sciences with Government-funded Projects by Erika DeBenedictis, Ben Andrew, and Pete Kelly
- Creating a National Exposome Project by Gurdane Bhutani, Gary Miller, and Sandeep Patel
- Accelerating Biomanufacturing and Producing Cost-Effective Amino Acids through a Grand Challenge by Allison Berke
- Accelerating Bioindustry Through Research, Innovation, and Translation by Jon Roberts
A few of the report’s recommendations would benefit from additional stakeholder input to enhance clarity and ensure they are actionable for Congress:
- Recommendation 4.1c: Congress should authorize and fund the Department of Interior to create a Sequencing Public Lands Initiative to collect new data from U.S. public lands that researchers can use to drive innovation and Recommendation 4.1d: Congress should authorize the National Science Foundation to establish a network of “cloud labs,” giving researchers state-of-the-art tools to make data generation easier. Specifically, stakeholder input on:
- What type of data should be generated and what types of data generation or collection should be prioritized?
- How can we best draw on or expand existing cloud lab capabilities?
- Recommendation 4.3b: Congress should initiate a grand research challenge focused on making biotechnology predictably engineerable. Specifically, stakeholder input on:
- What specific grand challenge should Congress pursue and how should it be implemented?
- How should the U.S. government engage the scientific community (and others) in establishing and pursuing grand challenges for biotechnology?
- Recommendation 4.4a: Congress must direct the executive branch to advance safe, secure, and responsible biotechnology research and innovation. Specifically, stakeholder input on:
- The report calls for establishment of a body within the U.S. government for this purpose. What should this look like and how would it operate?
If you have specific policy suggestions related to these topics, we encourage you to submit your ideas through the Day One Open Call at FAS.
Pillar 5. Build the Biotechnology Workforce of the Future
Pillar 5 of the final report looks to the future by offering recommendations to secure and build the biotechnology workforce needed in the future. It addresses both the modernization of the federal biotech workforce and the development of the broader U.S. biotech workforce. Modernizing the federal workforce requires more than training programs. It requires coordination across HR systems, consistent standards, and better integration of biotechnology experts into national security and diplomacy. Proposals to expand Congressional science capacity are long overdue and necessary to equip lawmakers to address rapidly evolving biotechnology issues. On the national level, scaling the biomanufacturing workforce will depend on aligning credentials with industry needs and securing input from labor, academia, and employers. Expanding biotechnology education is promising, but successful implementation will require investment in teacher training and curriculum development.
While FAS contributed several recommendations to support this critical capacity-building effort (see Table 2), such as:
- Gathering Industry Perspectives on how the U.S. Government can Support the Bioeconomy by Sarah Carter
- Meeting Biology’s “Sputnik Moment”: A Plan to Position the United States as a World Leader in the Bioeconomy by Natalie Kuldell
One of the NSCEB’s recommendation would benefit from additional stakeholder input to enhance its clarity and make it more actionable for Congress:
- Recommendation 5.2a: Congress must maximize the impact of domestic biomanufacturing workforce training programs. Specifically, stakeholder input on:
- How should the government approach creating competency models for biomanufacturing training and microcredentialing?
- Which specific areas are best suited for microcredentialing efforts?
If you have specific policy suggestions related to these topics, we encourage you to submit your ideas through the Day One Open Call at FAS.
Pillar 6. Mobilize the Collective Strengths of our Allies and Partners
Pillar 6 of the final report focuses on strengthening alliances and partnerships on the global stage to enhance the U.S. biotechnology sector. It highlights the role of the State Department (DOS) in facilitating this effort through development of foreign policy tools, strengthening global data and market infrastructure, and leading in the establishment of international standards within the sector. Elevating biotechnology within U.S. foreign policy is both timely and necessary, particularly as biotech becomes increasingly strategic in areas like health security, climate resilience, and defense. Leveraging existing tools like the International Technology Security and Innovation (ITSI) Fund could provide a solid foundation, but effective execution will require clearer interagency coordination, transparency in funding allocation, and defined metrics for impact, especially across overlapping technology domains.
Proposals to create shared data infrastructure, joint purchasing mechanisms, and international fellowships point to smart long-term strategies for building trust and interoperability with allies. Yet, success hinges on careful coordination, especially around sensitive areas like dual-use biotechnology export controls. If U.S. standards are significantly more restrictive than those of allies, it could create friction and undermine broader goals of international collaboration and leadership.
FAS provided several additional recommendations and insights on these topics (see Table 2) to make them more nuanced and actionable by Congress, including:
- A Matter of Trust: Helping the Bioeconomy Reach Its Full Potential with Translational Governance by Christopher J. Gillespie
- Strategic Investments the U.S. Should Make in the Bioeconomy Right Now by Nazish Jeffery
- Strengthening U.S. Engagement in International Standards Bodies by Natalie Thompson and Mark Montgomery
- What’s Next for the U.S. Bioeconomy? Defining It. by Nazish Jeffery
One particularly important recommendation emphasizes the need to engage the public and build trust in the sector by collecting data on public acceptance. This data can help inform national governance and ensure it is more responsive and translatable to public concerns.
Additional Considerations
The additional considerations section of the NSCEB report brings several key recommendations that do not fit with the rest of the report, though are still very important. Many focus on aligning federal leadership and economic infrastructure with the needs of a growing and strategically vital biotechnology sector. Elevating biotechnology leadership within DOD is a logical step to align R&D with budget authority and operational needs. Similarly, expanding the scope of the Bioenergy Technologies Office (BETO) beyond biofuels and codifying the Office of Critical and Emerging Technology (OCET) role reflects an overdue shift toward recognizing biotech’s relevance to national security and broader innovation policy, though these changes will require institutional buy-in and cultural adjustment. On the economic side, proposals to create a public-private innovation consortium are timely, especially for supporting smaller firms and navigating the convergence of biotechnology with other technologies, like AI. However, care should be taken to not overly narrow the scope at the expense of other critical intersections.
While FAS provided a few recommendations on these topics (see Table 2), such as:
- Summary Report – December 5, 2022, Bioeconomy Policy Workshop: Measurement and Language
- Laying the Groundwork for the Bioeconomy by Sarah Carter
One of the report’s recommendations would benefit from additional stakeholder input to enhance clarity and ensure that it is actionable for Congress:
- Recommendation 8: Congress should direct the National Science Foundation (NSF) to establish a federal grant program for a national system of community biology labs that would engage Americans in informal learning. Specifically, stakeholder input on:
- What is most needed to support community biology labs?
- Should community labs be incorporated within universities or run as independent institutions?
If you have specific policy suggestions related to these topics, we encourage you to submit your ideas through the Day One Open Call at FAS.
Next Steps for the U.S. Bioeconomy
The NSCEB’s final report outlines a vision for a national biotechnology strategy aimed at securing U.S. leadership in a sector that is not only rapidly advancing but also delivering significant economic returns, outpacing even AI. While the report offers thoughtful, well-grounded recommendations that address many of the core challenges facing the U.S. biotechnology landscape, several proposals would benefit from greater specificity and refinement to make them actionable in legislative form. This moment presents a unique opportunity for stakeholders across the biotechnology ecosystem to contribute meaningfully to the development of a national bioeconomy strategy.
The U.S. bioeconomy, which encompasses biotechnology, holds enormous strategic and economic potential. Without a clear, well-implemented plan, the nation risks repeating the mistakes of past industrial shifts, such as the decline in domestic semiconductor leadership. FAS urges Congress to act on the Commission’s recommendations and leverage FAS’ additional proposals to strengthen them further (see Table 2). We also call on the scientific community to provide additional input on these recommendations to ensure they are viable and impactful. If you have actionable policy ideas on how to shape the path forward for the U.S. bioeconomy, we encourage you to submit them through the Day One Open Call. Applicants with compelling ideas will be partnered with our team at FAS to develop their idea into an implementation ready policy memo. Click here to learn more about the Day One Open Call.
FAS Bioeconomy Open Call Areas
- Recommendation 2.2d (SBIR and STTR): Congress should improve the effectiveness and reach of the Small Business Innovation Research (SBIR) and Small Business Technology Transfer (STTR) programs to support early-stage innovation.
- Which areas of biotechnology or sectors within the bioeconomy would most benefit from SBIR and STTR investment?
- How can these programs better support not only early- but also late-stage innovation?
- Recommendation 4.1c (Bio Data Generation): Congress should authorize and fund the Department of Interior to create a Sequencing Public Lands Initiative to collect new data from U.S. public lands that researchers can use to drive innovation and Recommendation 4.1d: Congress should authorize the National Science Foundation to establish a network of “cloud labs,” giving researchers state-of-the-art tools to make data generation easier.
- What type of data should be generated and what types of data generation or collection should be prioritized?
- How can we best draw on or expand existing cloud lab capabilities?
- Recommendation 4.3b (Predictable BioEngineering): Congress should initiate a grand research challenge focused on making biotechnology predictably engineerable.
- What specific grand challenge should Congress pursue and how should it be implemented?
- How should the U.S. government engage the scientific community (and others) in establishing and pursuing grand challenges for biotechnology?
- Recommendation 4.4a (Safe, Secure, Responsible): Congress must direct the executive branch to advance safe, secure, and responsible biotechnology research and innovation.
- The report calls for establishment of a body within the U.S. government for this purpose. What should this look like and how would it operate?
- Recommendation 5.2a (Domestic Bio Workforce): Congress must maximize the impact of domestic biomanufacturing workforce training programs.
- How should the government approach creating competency models for biomanufacturing training and microcredentialing?
- Which specific areas are best suited for microcredentialing efforts?
- Additional Considerations #8 (Grant Programs): Congress should direct the National Science Foundation (NSF) to establish a federal grant program for a national system of community biology labs that would engage Americans in informal learning.
- What is most needed to support community biology labs?
- Should community labs be incorporated within universities or run as independent institutions?
Advancing the U.S. leadership in emerging biotechnology is a strategic imperative, one that will shape regional development within the U.S., economic competitiveness abroad, and our national security for decades to come.
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