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.

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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

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

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.

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

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

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.

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

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.

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.

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

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.

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.

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

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

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,

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.

"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

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

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.

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.

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.

Articles and Websites

Ahmad, Mudassar, et al. "Protein Expression in Pichia Pastoris: Recent Achievements and Perspectives for Heterologous Protein Production." Applied Microbiology and

Biotechnology, vol. 98, no. 12, 2014, pp. 5301-5317., doi:10.1007/s00253-014-5732-5.

"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 Food and Drug Administration, 4 Jan. 2018, www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/ucm2006851 .htm.

Coller, Jeremy, and Catherine Howard. "The Future of Food: The Investment Case For a Protein Shake Up." 2016.

Downie, J. Allan. "Legume Haemoglobins: Symbiotic Nitrogen Fixation Needs Bloody

Nodules." Current Biology, vol. 15, no. 6, 29 Mar. 2005, doi:10.1016/j.cub.2005.03.007.

Firbank, Les G. "The Beef with Sustainability." Nature Ecology & Evolution, vol. 2, no. 1, Apr. 2017, pp. 5-6., doi:10.1038/s41559-017-0422-1.

Food Safety Magazine. "Generally Recognized as Safe (GRAS) -How U.S. FDA's GRAS Notification Program Works." U S Food and Drug Administration, Jan. 2006, www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/ucrmo83022.htm.

Eshel, Gidon. "Land, Irrigation Water, Greenhouse Gas, and Reactive Nitrogen Burdens of Meat, Eggs, and Dairy Production in the United States." Proceedings of the National Academy

0'Sciences of the United States ofAmerica, vol. 111, no. 33. 19 Aug. 2014, pp. 11996-12001.

Eshel, Gidon, et al. "Reply to Tichenor: Proposed Update to Beef Greenhouse Gas Footprint Is Numerically Questionable and Well within Current Uncertainty Bounds: Fig. ." Proceedings of the National Academy of Sciences, vol. 112, no. 8, 24 Feb. 2015, doi: 10.1073/pnas. 1422670112.

Goldstein, Benjamin, et al. "Potential to Curb the Environmental Burdens of American Beef Consumption Using a Novel Plant-Based Beef Substitute." I'los One, vol. 12, no. 12, June 2017, doi: 10.1371/journal.pone.0189029.

"IF- Heme -_{The Magic Ingredient in Impossible Burger." Impossible Foods, 14 Sept. 2017,}

impossiblefoods.app.box.com/v/presskit/file/224480611426.

"IF Sustainability Report 2017." Impossible Foods, 25 May 2017, impossiblefoods.app.box.com /v/presskit/file/1 761.87206081.

"Impossible Burger Now Sold at More Than 1,000 Restaurants Nationwide." Impossible Foods, 21 Mar. 2018, impossiblefoods.app.box.com/v/presskit/file/284189330432.

Muir, Ayr. "86 The Meatball Sandwich (Impossible Meat) Boston!" Introducing Impossible Bwger -Clover Food Lab, 19 Oct. 2017, www.cloverfoodlab.com/2017/10/19/86-the-meatball-sandwich-impossible-meat-boston/.

Muir, Ayr. "Aspirations and Fears for the Clover Brand." Introducing Impossible Burger - Clover Food Lab, 5 Aug. 2008, www.cloverfoodlab.com/2008/08/05/goals-for-the-clover-brand/.

Lab, 28 Sept. 2017, www.cloverfoodlab.com/2017/09/28/how-it-feels-to-sell-Impossible -meat/.

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

Muir, Ayr. "Welcome to Clover Food Lab." Introducing Impossible Burger -Clover Food Lab, www.cloverfoodlab.com/about/.

"The Agonizing Dilemma of Animal Testing." Impossible Foods, 11 Aug. 2017, impossiblefoods .app.box.com/v/presskit/file/209055 143216.

Tichenor, Nicole. "Role of Dairy in the Carbon Footprint of US Beef." Proceedings of the National Academy of Sciences, vol. 112, no. 8, 24 Feb. 2015,

doi:10.1073/pnas.1421941112.

Tichenor, Nicole E., et al. "Life Cycle Environmental Consequences of Grass-Fed and Dairy Beef Production Systems in the Northeastern United States." Journal of Cleaner Production, vol. 142, 24 Nov. 2016, pp. 1619-1628., doi:10.1016/j.jclepro.2016.11.138.

U.S. Food and Drug Administration. "GRAS Substances (SCOGS) Database -History of the GRAS List and SCOGS Reviews." USFood and Drug Administration, 4 Jan. 2018, www.fda.gov/Food/IngredientsPackagingLabeling/GRAS/SCOGS/ucmO84142.htm.

U.S. Food and Drug Administration. "GRAS Substances (SCOGS) Database." US. Food and Drug Administration, 28 Mar. 2018, www.fda.gov/Food/IngredientsPackagingLabeling/ GRAS/SCOGS/default.htm.

between the FDA and Impossible Foods." Friends of the Earth, 2017.

U.S. Food and Drug Administration, Office of Food Additive Safety, et al. "Gras Notification For Soy Leghemoglobin Protein Preparation Derived From Pichia Pastoris." Impossible Foods, 2017