Synthetic biology has spawned a debate about how society and the international community should go about policy-making, especially given the potential for both transformative benefits and existential threats. One important voice in this debate has been the report of the Presidential Commission for the Study of Bioethical Issues, New Directions: The Ethics of Synthetic Biology and Emerging Technologies. We now have an equally important new voice in "The Ethics of Synthetic Biology: Next Steps and Prior Questions," by Kaebnick, Gusmano, and Murray.1 One of the more significant contributions of the paper is its exploration of the difficulties of developing policy that appropriately addresses the risks and benefits of synthetic biology. In this comment I want to develop this point further and emphasize how the proper methodology for addressing synthetic biology's ethical and public policy issues are affected by the unpredictable and complex causal webs in synthetic biology (which have analogs in other new and emerging technologies).The debate about synthetic biology has featured prominent promises that synthetic biology makes the creation of synthetic cells simple and predictable because it adopts the methods of traditional engineering.2 Nevertheless, no one in the debate denies that the synthetic cells created in synthetic biology are extremely complex. The "complexity" of a synthetic cell refers to the organization of the causal web among all of its material chemical components. We can call a causal web "complex" if it is highly parallel (has many nodes) with many local and loopy links (positive and negative feedback loops), if the nodes have many upstream and downstream links (that is, the nodes are context-sensitive and synergistic), and if node response is nonlinear.Complex causal webs are characterized by what we can call "weak emergence." That is, some of the properties of the web are generated by the web itself-that is, by the rules that govern the response of each node and by the web's initial and boundary conditions-and the quickest way to determine the web's precise global state is to simulate (or observe) the web. Complex causal webs with weak emergent properties are found throughout biological systems, including those created in synthetic biology. Given their complexity, it is perhaps no surprise that the precise global behavior of a complex causal web is unpredictable, even given complete information about the state and rules governing all of the parts of the web. The methodological consequences for complex causal webs are also perhaps no great surprise, and three are especially worth emphasizing here. First, we should expect the unexpected in the behavior of complex causal webs. Their behavior is difficult to predict and control, except by extensive and systematic observation, experimentation, and computer simulation. As a result, we must learn from experience if we want to discover the typical global behavior patterns of complex causal webs. Furthermore, it takes a continual plurality of observations...