Can This Burger Save the Planet?

Synthetic Beef and the Dream of an American Animal-Free Diet

by

Ashley Junger

B.A., Biology and English Literature

DePauw University, 2016

SUBMITTED TO THE PROGRAM IN COMPARATIVE MEDIA STUDIES/WRITING IN

PARTIAL FULFILLMENT OF THE REQUIREMENTS FOR THE DEGREE OF

MASTER OF SCIENCE IN SCIENCE WRITING

AT THE
MASSACHUSETTS INSTITUTE OF TECHNOLOGY

SEPTEMBER 2018

C 2018 Ashley Junger. All rights reserved.

The author hereby grants to MIT permission to reproduce and to distribute publicly paper and
electronic copies of this thesis document in whole or in part in any medium now known or
hereafter created.

___Signature redacted
Signature of Author:
P am in parae Media Studies/ Writing

Si natL re redacted May25,2018

Certified by:
*,sor-of Science Writing

Signature redacted
Accepted by:
MASSACHUSETTS INSTITUTE
MASSACHUESS NSTITUTE Seth Mr1Kdin, Ass' iate Professor of Science Writing
OF TECHNOLOGY
Director, Graduate Program in Science Writing
JUL 262018
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 2

Can This Burger Save the Planet? Synthetic Beef and the Dream of an
American Animal-Free Diet

by

Ashley Junger

Submitted to the Program in Comparative Media Studies/Writing on May 18, 2018 in partial
fulfillment of the requirements for the Degree of Master of Science in Science Writing

ABSTRACT

Sustainable food movements are focused on reducing meat consumption for one simple reason:
meat is extremely environmentally costly. This enormous resource use by one industry makes it
an appealing target for those looking to reduce American resource use. As a result, many are
looking at ways to make livestock more sustainable. And there are two main ways to do so.
Clover Food Lab represents one idea: a return to local farming with an emphasis on a plant-based
diet. Impossible Foods is the second: using biotechnology to provide a sacrifice free alternative,
synthetic beef. These companies aren't solutions in of themselves, but proposals on the way
solutions should be implemented. The partnership between these two opposing strategies reveals
the promises and pitfalls of trying to reform the American diet and, most importantly, that above
all else our food system is unsustainable as it is now.

Thesis Supervisor: Thomas Levenson

Title: Professor of Science Writing
 3

Can this Burger Save the Planet?

Synthetic Beef and the Dream of an American Animal-Free Diet

In the back of a little restaurant on Cambridge street, in the heart of Boston, Toto's 1980's hit,
"Africa", floats from an unseen radio. Aproned and gloved employees chop, stir, and season
while carts are wheeled back and forth. Three gigantic pots sit on boilers, gently simmering
gallons of soup.

This location of Clover Food Lab, aptly named CloverHUB, bustles to prep and package
ingredients to supply Clover's restaurants and food trucks. But, more than just shredded carrots
and sliced potatoes radiate from this store- this location is also the source of Clover's newest
additions to their menu.

Founded in 2008 by Ayr Muir, Clover Food Lab started out as a single food truck and has now
expanded to a small chain of restaurants scattered around Boston. A distant cousin to famed
naturalist John Muir, Ayr shares the conservationist spirit. Everything about Clover is designed
with the ideal of sustainability in mind, especially the menu.

Clover constantly rotates their menu to incorporate in-season ingredients, and, consequently, is
constantly looking for new recipe ideas- new ways to serve whatever veggies are being grown at
local farms. These new ideas need to be tested- the 'lab' part of Clover Food Lab, and that's why
a group gathers here every Tuesday evening.

The meeting is open to the public, so at first glance the group often looks mismatched- some
older men in suits, some younger people in t-shirts and jeans, and a few people somewhere in
between- all sporting haimets. Clover's head chef leads the meeting, dicing up food into bite size
 4

servings so everyone can have a taste. Attendees record their impressions in little pamphlets-
whether Clover should develop it further, test it at a restaurant, or scrap the idea.

The Food Development Meetings are a mash of test versions of old favorites and prototypes of
new proposals. Almost every week someone brings in their own recipe, whether it's tofu, protein
bars, or soup- the group passes around samples while the owner talks about their inspiration and
the sourcing of their ingredients.

One Tuesday in the fall of 2017, an ingredient unlike anything on the vegetarian restaurant's
menu sits on the large stainless steel table: beef. While it bleeds and browns like traditional beef,
this is something else entirely- synthetic beef. Using only plant ingredients, Impossible Foods
claims to have created a burger impossibly close to cow-based ones.

Those tasting the vegan meat that Tuesday evening were there to help Clover decide if a mass
produced, genetically-modified 'beef' belongs on the menu of a restaurant whose mission is to
get people excited about eating local and organic vegetables.

While beef in a vegetarian restaurant seems oxymoronic, both companies share a common goal:
to make the American diet more sustainable by getting the average consumer to eat less meat.
Sustainable food movements are focused on reducing meat consumption for one simple reason:
meat is extremely environmentally costly. Estimates vary, but researchers put it between 14 and
20 percent of total U.S. greenhouse gas emissions. Additionally, livestock uses exorbitant land
and water resources- over one quarter of the earth's land is used as graze land, and to produce
just one pound of beef over 1,700 gallons of water are needed.
 5

This enormous resource use by one industry makes it an appealing target for those looking to
reduce American resource use. As a result, many are looking at ways to make livestock more
sustainable. And there are two main ways to do so.

Clover represents one idea of how to save the planet- a return to local farming and an emphasis
on a plant-based diet. It is an old and fundamentalist idea, that everything needed for a
sustainable diet is already at consumers' fingertips. The challenge here is convincing people to
give up their eating habits, and to permanently and radically change their diets. But as the
consensus of climate scientists that meat is wreaking environmental havoc gains more attention,
others are looking for new ways to overcome the high environmental cost of meat that puts less
onus on the consumer.

That brings us to the second strategy to make animal agriculture more sustainable:
biotechnology. Many are pushing biotechnology as the new solution to this problem, pointing to
it as a way to offer consumers the appealing elements of meat without the environmental burden.
This is centered on the idea that more technology, not less, is the future of food that will save the
planet. But these products are uncharted territory, their long-term sustainability, production, and
marketability are so far untested. And nobody is quite sure yet how they fit into sustainable food
movements that have largely focused on promoting vegetables.

Clover Food Lab is providing a test case for this new strategy. While Impossible Foods' beef has
been added to the menus of over 1,000 restaurants since it went on the market in 2016, most are
burger restaurants. Of the vegetarian restaurants, few, if any, have as clear of a food philosophy
as Clover. Above all else, Clover is on a mission "to make meat lovers into vegetable lovers,"
according to the company website.

One of the reasons Clover has such a concrete philosophy behind their menu is because it was
founded not by someone who wanted to serve food, but by someone who wanted to help save the
world. As an MIT material science graduate, Muir didn't originally set out to break into the food
 6

industry. "I never dreamed of working in a restaurant or starting a restaurant," Muir said. But
more than anything else Muir was propelled by a desire to do something to reduce the burdens of
human activity on the environment. "If I could change what people were eating, I'd have a
bigger impact than anything else I could do," said Muir.

To create his vision of sustainable fast food, Muir completely rejects traditional fast food
approaches. Most fast food is shipped in frozen; Clover has no freezers. All of their ingredients
are fresh and 40-85% are locally sourced. Whereas most fast food is laden with preservatives,
"natural flavors," "flavor enhancers," or "artificial flavors," Clover sticks to natural and mostly
organic ingredients. Usually fast food comes with a lot of paper and plastic waste; all packaging
at Clover is compostable.

At the same time, Muir wanted to ensure that his restaurants would be convenient and enjoyable
as the average fast food chain. Their three and a half minute average serve time makes them just
a little slower than McDonald's, which clocks in at an average of three minutes.

Clover's most notable deviation from other fast food restaurants is it's lack of meat. Instead of
burgers and nuggets, customers are offered chickpea fritters and eggplant sandwiches. Muir's
strategy of making vegetarian meals appealing to a mass market is aimed not at transforming
people's diets, but simply changing their lunch. It is very difficult to convince people to change
their entire lifestyle, but much easier to get someone to eat a different kind of meal once a week
or once a month. "If we feed vegetarians or vegans animal-free products the most impact we
could have is maybe make it a little bit easier to be a vegetarian or vegan," said Muir. "Whereas
if we serve people who otherwise eat meat, then every meal we're serving is a substitute."

The answer to Muir's original question of: "Can you make a menu without meat that will really
appeal to people who don't see anything wrong with eating meat?" seems clearly to be "yes."
The chain has seen remarkable growth over the last nine years- expanding from just one food
 7

truck to twelve restaurants and seven food trucks- and it has no signs of slowing down.
"Hopefully, we're just at the very beginning of what we're doing," said Muir.

Now, after 10 years, Clover is making room to stray from their traditional vegetable strategy, and
introduce an item to the menu that is almost the antithesis of their approach so far. Impossible's
beef is mass produced, genetically modified, and is meat. While it is made of plant ingredients, it
is designed to look, smell, and taste like beef. Impossible isn't trying to convince customers to
eat something other than meat; rather, they want customers to eat a different kind of meat. This
departure from Clover's original philosophy seems to be a recognition that their strategy needs a
boost. No matter how tasty the vegetable, some people will still want a burger. And Clover is
adapting to capture that market.

Impossible Foods is not the first to produce an animal-free product that imitates meat. Many
companies mimic meat products to appeal to a vegan and vegetarian customer base. The
vegetarian section of grocery store freezer isles are filled with "chick'n" nuggets and soysage.
And these products are having an impact; alternative meat sales grew to $109 million in 2015.

But Impossible isn't looking to appeal to those who are interested in eating meat-free. Instead,
they aim for customers that eat meat regardless of its environmental impacts. Their product is
designed to be a sacrifice-free substitute for meat- the same thing consumers crave, without the
animal inputs.

Quite a few companies have popped up over the last few years attacking the same problem.
Some, like Beyond Beef, want to make a believable plant-based burger, but shy away from
genetic engineering. Others, like Memphis Meats, have taken the idea to another extreme, and
are trying to create a way to grow animal tissues in a lab without animals- beef without the cow.
 8

And it it is not a coincidence that these companies looking to increase the sustainability of meat
consumption are starting with beef. Not all animal products are equal in terms of environmental
impact, and beef has been shown to be the worst offender. Gideon Eshel, a professor of
Environmental Science and Physics at Bard College, and his colleagues, evaluated how much
land, water, and nitrogen was needed to generate the feed required to produce dairy, beef,
poultry, pork, and eggs. They also calculated the greenhouse gases produced at every production
stage for each category- from farm to processing to distribution.

Consistently, they found that beef was the worst environmental offender- and not by a little bit
either. While the other categories are about the same level of resource intensiveness, beef uses 28
times more land, 11 times more irrigation water, and 5 times more greenhouse gas emissions than
anything else. "If you want to do one thing, one change to your diet that will be unquestionably
the single best step you could take, avoid beef," said Eshel.

Eshel explains this huge gap through the concept of "newborn debt." Newborn debt totals the
amount of resources an animal uses before it's born. For cows this newborn debt is enormous,
much higher than other livestock animals. It boils down to two factors: cows are big, and they
only have one baby at a time. So farmers have to spend more resources sustaining cows and their
pregnancies than other animals, with less reward. And even though cows are much bigger than
their barnyard companions and consequently produce more meat per animal, their bulk doesn't
cancel out this imbalance. Eshel's results are weighted by the cost per consumed calorie. Any
way you slice it, beef is a bad deal.

Other groups have attempted to perform similar calculations, and there is some debate over the
exact numbers associated with resource use and livestock. Researchers have to rely on
incomplete data, and since no two farms operate in quite the same way, generalizing is difficult.
But the data is clear on cows. They're so much more costly than other types of livestock that the
noise from uncertainty doesn't even come close to drowning it out. "I'm willing to bet the farm
 9

that there will be nothing- not in twelve years and not in one hundred and twelve years- that will
change the conclusion that beef by far is the biggest offender," said Eshel.

This is the reason so many people are focused on beef as the key to making agriculture more
sustainable in the US- it's the biggest piece of the resource pie. "It's not a very reasonable
allocation of finite resources," said Eshel. Helen Harwatt, who has been studying climate change
mitigation for over ten years, agrees that beef should be on its way out. "It really makes a lot of
sense to take out this hugely inefficient food from the food system."

However, Nicole Tichenor, a postdoctoral research fellow at The Sustainability Institute at the
University of New Hampshire, isn't as quick to take beef out of the equation. "In an idealized
system, we don't need to eliminate beef from the earth for it to move to sustainability. It just
needs to look very different than it does now," said Tichenor. She argues that it's not the beef
that's the problem; it's how it's being raised. Many methods to make cattle production more
sustainable have been proposed: feeding them parts of crops that humans can't eat, capturing
methane, grazing them on land that otherwise would be unproductive.

Either way both Eshel and Tichenor agree that beef production as it is now is unsustainable, and
the solution lies in fewer cows. But with demand for beef on the rise globally, market forces are
pushing in the opposite direction. The Food and Agriculture Organization of the United Nations
predicts that global demand for beef will increase by 65% from 2005 to 2050. And this is where
Impossible Foods, and companies like it see their opportunity to dramatically impact the market.
If they can provide a product that satisfies the world's demand for beef while avoiding the
environmental impacts of raising cows, they can make the consumption of meat markedly more
sustainable.
 10

Brown wanted to find a sacrifice-free solution so that customers could easily and simply
integrate meatless meals into their lives without having to change any habits or forfeit any
enjoyment. To do this, Impossible set out to redesign the veggie burger by augmenting traditional
plant components with high tech gene editing.

Impossible scientists started the development process by analyzing beef burgers "from cow to
bun" to determine what makes them craveable. The researchers singled out heme, a protein
common in blood, as the source of human meat lust. Impossible Foods calls heme their "magic
ingredient," as, according to their website, it's what "makes meat smell, sizzle, bleed, and taste
gloriously meaty." According to Impossible, people don't want the beef, they want the heme.

Heme is an iron-containing protein, and is a main component in hemoglobin, which carries

oxygen in the blood. It's what gives blood its red tint, and makes it taste metallic. But luckily for
Impossible, heme isn't exclusive to animals. Some plants, mainly legumes, also produce small
amounts of heme. Accordingly, Brown set his sights on soy, a common legume, as the source of
this plant based "blood." But he quickly realized that growing, harvesting, and processing
enough soy plants to extract enough leghemoglobin to produce burgers would consume huge
amounts of the same resources he is trying to conserve. This left Brown with a common genetic
engineering problem- he needed large quantities of a single protein and he didn't need the rest of
whatever organism might contain that gene.

There is a common biotechnology solution to this kind of problem: yeast. From medicines to
scents to alcohol, yeast has been used by many as single celled factories. Impossible Foods took
the genes that encode for leghemoglobin in soy and spliced them into yeast. When this
genetically altered yeast ferments, the soy leghemoglobin (SLH) protein is produced in large
quantities. With this, Impossible Foods can manufacture huge vats of the heme compound with
just some fungus and sugar- no large-scale agriculture required.
 11

The result is a pale pink and frothy liquid. The next steps separate the SLH from the yeast
mixture. The first round of filtration first bursts the yeast cells, then filters out any solid particles
and cellular fragments. Next, the liquid is further concentrated to remove excess water. This
leaves a thick deep red product, one that looks strikingly like blood. To get from there to
Impossible's "meat," the SLH is then simply stirred into wheat protein, coconut oil, and potato
protein. The result is a textured product, red and speckled with fat, like beef.

Everything about this burger is designed to mimic the animal-derived version. From the smell to
the consistency, each aspect of the plant based beef was analyzed and purposefully constructed to
replicate the experience of eating a traditional burger. And while Impossible Foods hasn't
perfectly created beef with plants yet, they're making fast progress. According to David Lipman,
Impossible Foods' Chief Science Officer, when Impossible Foods first started testing their
product over 90% of people preferred the traditional beef. Now, five years later, they're close to
50/50.

Brown likens his plant beef to the automobile. Before Ford, horses were the standard- slow and
costly, yet they dominated the transportation industry. Once the Model T rolled out and cars
became affordable to most Americans, animal was replaced with technology swiftly and
irreversibly. But, just like Ford, Impossible Foods aims to improve on the product they're
replacing. "We have a goal to make the Impossible burger better than beef from a cow this year,"
said Lipman. In this, Impossible Foods has an advantage: it is constantly experimenting and
innovating, while the cattle are not. "The cow is not a moving target. It's not going to get any
better," said Lipman.

Walking into Clover Food Lab, customers enter a stark minimalist interior. White tables lining
white walls juxtapose the row of refrigerators behind the counter, filled with transparent tubs of
colorful vegetables. The kitchen is on full display for customers- while they eat they can watch
 12

employees prep for the next meal. Flat screens mounted on the wall display that day's menu,
strikethroughs indicate what's sold out for the day and little beaker symbols tell customers what
items are on a test run. On September 22nd, 2017, select Clover menus featured an unusual item
paired with a beaker symbol- The Impossible Meatball Sandwich, making Clover Food Lab the
first restaurant to serve Impossible's beef in Boston.

Clover's addition of the synthetic beef marked a departure from their original strategy of getting
meat eaters to love vegetables. Even after adding the synthetic beef to the menu, Muir wasn't
convinced it belonged at his restaurant. "For us it's a little bit of an experiment and we're trying
to decide if it belongs on the menu, and if it should stay," said Muir.

For now Muir has a rather simple metric to determine if the product is right for Clover: "If
Impossible is bringing new customers to Clover who wouldn't come otherwise, then it's
probably a good thing for us to have," said Muir. "If instead, it's cannibalizing other products
that we would otherwise be selling, it's probably a terrible thing for us to have."

For now the Impossible meatball is growing Clover's customer base, allowing them to provide
more customers with a vegetable-based meal instead of, presumably, a meat-based one. This
metric is important to Muir because, despite Impossible Foods mission to make American diets
more sustainable, they really only accomplish that goal in certain circumstances.

Last December, a study in which Impossible Foods researchers took part, assessed how well the
company's plant-based burger matched up to claims of sustainability. The investigators measured
the protein sources by how much agricultural input, livestock, processing, and transport was
needed to deliver each kilogram of protein to a consumer's plate. They found that the Impossible
burger consumes a fraction of the resources needed for beef, but that its total impact ranked
closer to other meats than to popular plant based proteins.
 13

So if you're environmentally conscious and your only goal in changing your diet is to have the
smallest impact possible, you're better off ordering the tofu or the tempeh. However, Impossible
Foods' product isn't aimed at people already willing to make sacrifices in their diet for the
benefit of the environment. They're targeting themselves at people who don't care what the
environmental costs are, they want a burger.

And weighed against that standard, Impossible Foods' burgers are markedly more sustainable.
Each one that a customer eats instead of a beef burger is a huge reduction in the land, water, and
greenhouse gases needed for that meal. The study found that if 10% of beef was replaced with
the Impossible burger, it would save the area of New Hampshire in land occupation and would
reduce the amount of greenhouse gas released equivalent to removing one to two million US
drivers.

However, carnivores aren't the only ones who will be chowing down on Impossible beef. The
burger itself is vegan, and is often served with vegetarian ingredients. Consequently, it's gained a
lot of attention from those groups. In fact, when Muir launched Impossible meatballs at Clover
most of the complaints were from vegans, angry that the sandwich's eggs and cheese would
prevent them from being able to order the plant-based product.

Such eagerness suggests that Impossible Foods' beef has the potential to actually increase the
environmental impact of Americans' diets. If the product remains in its niche, mostly popular
with vegetarians and vegans, it could increase the environmental footprint of meatless eating.
The authors of the sustainability paper dismiss this as a "marginal" possibility. They claim the
savings from beef are great enough to counteract any vegetarians or vegans swapping the burger
in for a few meals. But this type of trade-off is hard to measure. Nobody asks about your dietary
habits when you buy the burger, and there's really no procedure for what to do when your
relatively successful product is having unintended consequences.
 14

Additionally, the way Impossible Foods' beef is produced could shift environmental burdens to
parts of the world that are more sensitive to those impacts. Two ingredients essential to the
Impossible burger, coconut protein and sugar, fed to the yeast as it ferments, are grown in
tropical climates. Because the number of different species in those forests is so high, agricultural
activities in those areas are more likely to have a greater impact on a larger number of plants and
animals. And demand for enough coconut and sugar to supply the world with plant-based burgers
is sure to drastically increase the environmental stress on those areas.

While these issues are by no means fatal to the Impossible idea, they do represent a common
issue with using simple technological fixes for complex problems- the results often yield new
problems outside of the original scope of the product. These solutions aren't net zero- if adopted
by consumers as Brown plans, the Impossible beef could potentially have a huge impact on the
amount of resources used to produce food, but some of the excitement has to be tempered by the
reality of what it takes to achieve such outcomes.

Beyond the murky realm of sustainability, engineered food like the Impossible burger raises
another issue: how should the product be regulated? The United States Food and Drug
Administration (FDA) regulates cosmetics, foods, and drugs. The safety of everything from
lipstick to insulin is their responsibility. This wide range of jurisdiction leaves FDA with a heavy
caseload that they must confront with increasingly out of date tools. The last major update to the
regulations guiding the agency on food additives were in 1958, when Congress gave FDA power
to regulate them.

While FDA has been regulating genetically modified crops for years, it gets fuzzier when the
food they're overseeing is a plant protein made without any plants. The FDA doesn't have any
power to regulate the technology that makes a food, only the final product, the stuff Americans
will actually eat. This collision between ancient proteins, new technologies, and government
 15

regulation has sparked a debate about whether FDA regulations are specific and stringent enough
to handle the inevitable influx of biotech food into American markets.

Much of FDA's power to regulate food comes from its mandate to ensure the safety of food
additives, which include "any substance that is reasonably expected to become a component of
food." This is sufficiently general to require the FDA to examine pretty much every food
substance. There simply isn't enough manpower or hours in the day do so, to test every
component of every food. So Congress created an exemption to the rule: food additives don't
need FDA approval if they are generally recognized as safe- a standard better known by the
acronym GRAS. If a product meets FDA's standards to be recognized as generally safe, they are
able to skip pre-market approval, saving time and money.

The GRAS exemption was meant to create an easy way for companies to get products that had
long been in the human diet through FDA oversight. There's no need to test cellulose for safety,
as it makes up the cell walls of virtually every plant. Humans have been eating it since there
were humans- if it was dangerous, we'd already know. However, some argue that this exemption
allows companies to sidestep FDA regulation. Companies can decide that their product is GRAS
and put that product on the market, meaning that companies can skip the premarket approval
process required for non-GRAS food additives and color additives, instead, reviewing their
inventions themselves. Michael Hansen, a senior staff scientist at Consumers Union, likens this
process to students being able to take home open book exams, grade them themselves, and then
not have to turn them into the teacher.

Impossible Foods isn't doing anything radically new. Many products, including cheese and beer,
use genetically modified yeast. But Impossible is unique in that they are producing a protein that
is analogous to a long-eaten protein, but has not actually been consumed itself. Impossible Foods
claims that their high-tech additive, soy leghemoglobin, is "structurally very similar" to animal
hemoglobin. And because heme has been consumed through animal products since humans
began to hunt, Impossible Foods argues that the safety of heme in meat is evidence that their
 16

product is safe. But the product is derived from plants, not animals, and comes from part of the
plant that hasn't been widely eaten by humans before.

Mitchell Cheeseman, a lawyer who worked at the FDA for twenty years helping to develop the
GRAS notice program acknowledges that from the outside this process can seem flawed. "It's a
troubling concept for many people, particularly those who aren't practitioners of it," said
Cheeseman. But, he says, "it doesn't change safety standards."

The problem is that such safety standards are imposed only after the fact. The FDA doesn't
determine what type of regulations their product is subject to ahead of time; they only tell a
company when they're using the wrong ones. Impossible Foods complied with GRAS
regulations simply by convening a panel of three experts, who in 2014 unanimously concluded
the product is safe.

While such a panel is all that's legally necessary, many companies seek further assurance that
their product will not be questioned once it enters the market. The FDA never 'certifies' nor
'approves' any food additives as GRAS. Instead they sent a "no comment letter." While this
letter contains no legal guarantees, it signals to the company that the FDA has no comments
about their product, meaning the FDA is unlikely to take regulatory action or sue later.

Impossible Foods sought a no comment letter for their soy leghemoglobin in 2014, sending FDA
their panel's findings and additional data. Instead of the assurance the company hoped to receive,
the FDA responded with many questions about the data they had collected. In the end, the agency
sent Impossible Foods a letter stating: "FDA believes that the arguments presented, individually
and collectively, do not establish the safety of SLH for consumption, nor do they point to a
general recognition of safety."

Impossible withdrew their request for a no-comment letter later in 2014. Still, their burger went
on the market in 2016. Because the panel review was sufficient to claim GRAS status,
 17

Impossible's plant-meat can be sold as any other GRAS additive, despite the FDA's concern
about their data. "This GRAS is really a loophole that now can allow companies to basically
rubber stamp and say anything they want," said Hansen. "It's just amazing to me that the FDA
told them that the data was not good enough and that they needed to do more... And they still
went on the market."

Cheeseman doesn't see the Impossible situation as proving that the FDA process is flawed. "If
the manufacturer can't respond to all the questions the FDA has adequately, the FDA can say you
don't have a basis for this being GRAS." However, the FDA doesn't have many options when
challenging a food additive. Most of their regulatory heft is in their ability to send letters. Their
most powerful weapon, a lawsuit, is an expensive and political move. "I can't see that in this
present administration," said Hansen. This leaves many doubtful that the FDA could intervene
even if they wanted to.

Brown largely dismisses this debate, as he considers the whole conversation moot. Impossible
submitted a new GRAS notice to the FDA in 2017, adding much of the data asked for after the
original notice, including animal testing (a radical step for a vegan company). Brown believes
the FDA will soon respond to this new notice with no comments, ending any debate about
Impossible Foods' regulatory status. And Cheeseman agrees that there's nothing particularly
exceptional about Impossible Foods' interaction with the FDA. It's common for companies to
withdraw GRAS notices in response to questions, and their approach to assessing the safety of
their proteins isn't unusual. "I'd call it sound science," said Cheeseman.

As Impossible is the first to put a synthetic meat on the market, examining their interaction with
regulation provides a test case into how the safety of novel foods is likely to be handled. While
experts don't have any major concerns about Impossible Foods' beef, besides some allergenicity
worries, other products might not be the same. Impossible is forging a path for synthetic meats
with their interactions with the FDA, opening the door for more companies to follow in their
footsteps- and more are sure to come.
 18

"Right now at the FDA and USDA regulations are incredibly inadequate," said Dana Perls, the
senior food and technology campaigner for Friends of The Earth, an environmental activist
organization with more than one million members in 74 countries. "That really means that we
need to overhaul a very broken regulatory process particularly with regard to new genetic
engineering."

These changes are unlikely to happen anytime soon, however, because few consumers seem to
take notice of the debate. Perls argues that interactions with the FDA should have an effect on
consumers view of the company. "The fact that impossible foods declared something safe
without any data and before testing it does not make them trustworthy in the eyes of the public,"
said Perls. But this apprehension largely hinges on technicalities, legal definitions, and the FDA's
regulations- none of which are common knowledge for most consumers.

Impossible Foods' exponential growth over the last two years, seems to indicate that a good
number of consumers have no qualms about eating a product the FDA has questions about. In
fact, Impossible products consistently accounted for 15 to 20% of all sandwich and platter sales
at Clover in the four months since its premiere, with one fourth of those sales going to customers
who are repeatedly ordering the plant-meatballs, according to Clover.

Indeed, Muir says that he hasn't gotten any complaints about Impossible Foods' FDA status or
the fact that its GMO. Actually, most complaints have focused less on the product itself and more
on how it's being served- according to Muir, his biggest naysayers are vegans, agitated that the
product is being served with eggs and cheese.

And Muir thinks that Impossible Foods is attracting avid attention while Clover is not because
Impossible Foods is being used as a test case for those who have opinions on the role biotech in
food. "I think that [Impossible Foods is] going to deal with all those more extreme agendas and
 19

issues. Our audience is so different than that," said Muir. "The customers we're selling to
couldn't care less. If you told every one of them, they don't care."

So although some who closely follow this process find it alarming, consumers appear to be
apathetic. And without real pushback from consumers, FDA and agro-biotech companies alike
are unlikely to change their regulatory ways. Leaving a outdated and overburdened FDA to
regulate the most advanced biotech food on the market the same way it regulates some of the
oldest food on the market.

Impossible Foods' production facility stands in a commercial district in Oakland, California. Its
exterior is boxy, beige, and unremarkable, except for a multicolored mural on the front that says:
"Made in Oakland, Not Mars." Inside a stainless steel production line churns out the nations'
total current supply of plant-based beef. The fermenting, churning, and mixing results in flash
frozen patties, sealed tightly into packages of eight, the top of which is emblazoned with the
word IMPOSSIBLE in black and white. They whizz down a conveyor belt, into a freezer to be
stored until they're distributed all over the country. From New York to Orlando to St. Louis to
Los Angeles, the plant-based beef is shipping out to almost every major city. There restaurants
will season and sear it, placing it on a bun once destined for a beef burger.

As factories go, this one is unprepossessing - not obviously the place that will completely
reinvent the livestock industry. Merely turning your head is enough to see the span of the
production process- from fermentation to freezing. There is no hustle or bustle. A few employees
clad in stark white lab coats, hair nets, gloves, and safety glasses, man each station.

Many seem to believe in Impossible Foods ability to achieve their goals. Over the 6 years
they've been in business, they have received over $250 million in investments. But they're still
very far from their target of replacing the world's livestock industry. The facility in Oakland is
 20

Impossible's only large scale factory, and it just reached full production this year, producing 6
million pounds of plant-based meat each year. Meanwhile, the Department of Agriculture reports
that over 26 billion pounds of beef were produced commercially in the United States in 2017,
meaning Impossible is currently only producing 0.023 percent of the nation's beef. Even if
Impossible Foods manages to sustain their incredible current rate of increasing production by 6
million pounds every two years, by their 2035 goal they'd still only be producing less than half
of one percent of the beef in the U.S. alone. And this scale-up assumes that consumer interest
would double every two years as well.

Right now Impossible's synthetic beef is only available to a limited market. It has been
undeniably successful as a product served in upscale burger restaurants, but this means its
success so far can only be measured in terms of nice foodie interest. Even in the relatively few
stores it is currently served in, it tends to be the most expensive item on the menu. At Clover the
Impossible meatball items are five dollars more expensive than the average platter or sandwich.

Cost is sure to go down as Impossible Foods increases their production. But since the barrier to
becoming a significant portion of the market, at this time, is so huge, requiring massive scale ups
in production and distribution, many see Impossible's beef as an upper-class novelty.
"Experimental sixteen dollar burgers aren't going to cut it," said Perls.

A synthetic beef take-over of the American market isn't impossible, but there are significant
barriers standing in the way. Their ability to translate their niche success to a broader market is
essential to facilitating a significant reduction in resource use. For a company defining
themselves as the future of food, Impossible Foods has a long way to go before they can achieve
a fraction of their goals.
 21

In the end, both Clover and Impossible share the same modest goal: save the world. Both are
dedicated to their own strategy on how to achieve that. Clover Food Lab, focusing on fresh local
vegetables. Impossible Foods, racing to develop a synthetic beef to compete with cows. And
while each is a noble effort, neither will be able to achieve their goal alone. Both companies are
too small, too limited to change the way America eats, much less the world.

Many potential solutions are vying for the top spot as the answer- all vegetable diets, animal
muscle grown in test tubes, realistic beef made with nothing but plants. And while many of these
solutions are enjoying exponential success, at this point they are little more than proof of a
concept.

What is significant about these two companies and their partnership is their approach to
achieving those goals. Clover's acceptance of Impossible's synthetic beef, and that product's
success in a restaurant focused on vegetables is an example of how biotech can fit in with
longstanding food sustainability strategies. Neither iteration of these strategies is perfect, and
their union is tenuous. But they provide an example of one way our food system could become
more sustainable.

These solutions must overcome overwhelming hurdles- from sustainability to regulations to

customer acceptance. And it is unclear whether these iterations or another will get the formula
right, and achieve a take-over of the livestock market. But it is certain that despite the hype and
fanfare, the underlying premise behind these two companies is and will continue to be true- the
food system is unsustainable and we need an answer.
 22

Sources and Further Reading

Interviews

Mitchell Cheeseman, managing director, regulatory & industry affairs department at Steptoe

&
Johnson LLP. Phone interview January 31, 2018.

Gideon Eshel, professor of environmental science and physics at Bard College. Phone interview
January 26, 2018

Helen Harwatt, lead consultant at Planet Friendly Food. Phone interview February 22, 2018.

Michael Hansen, senior staff scientist at Consumers Union. Phone interview February 1, 2018.

Impossible Foods Media Day 2018. In person March 21, 2018

Patrick Brown, Founder, CEO, Impossible Foods

David Lipman, chief science officer at Impossible Foods

Ayr Muir, Founder, CEO, Clover Food Lab. In person interview January 23, 2018

Dana Perls, senior food and technology campaigner, Friends of the Earth. Phone interview
December 15, 2017

Nicole Tichenor, postdoctoral research fellow at The Sustainability Institute at the University of
New Hampshire. Phone interview February 9, 2018.
 23

Articles and Websites

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"An Open Letter from Our CEO." Impossible Foods, 12 Aug. 2017, impossiblefoods.app.box.
com/v/presskit/file/208914633959.

CFSAN/Office of Food Additive Safety. "Generally Recognized as Safe (GRAS) - About the
GRAS Notification Program." U S Foodand DrugAdministration, 4 Jan. 2018,
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Coller, Jeremy, and Catherine Howard. "The Future of Food: The Investment Case For a Protein
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Downie, J. Allan. "Legume Haemoglobins: Symbiotic Nitrogen Fixation Needs Bloody

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the-meatball-sandwich-impossible-meat-boston/.

Muir, Ayr. "Aspirations and Fears for the Clover Brand." IntroducingImpossible Burger - Clover
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Muir, Ayr. "How It Feels to Sell Impossible Meat." IntroducingImpossible Burger - Clover Food
 25

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-meat/.

Muir, Ayr. "Introducing Impossible Burger." Introducing Impossible Burger - Clover FoodLab,
21 Sept. 2017, www.cloverfoodlab.com/2017/09/21/introducing-impossible-burger/.

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"The Agonizing Dilemma of Animal Testing." Impossible Foods, 11 Aug. 2017, impossiblefoods
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U.S. Food and Drug Administration. "GRAS Substances (SCOGS) Database - History of the
GRAS List and SCOGS Reviews." USFood and DrugAdministration, 4 Jan. 2018,
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 26

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