Section
5.0
5
­
Benefits
5
­
Comment
Excerpts
Commenter
Name:
Frank
Kohn
Commenter
Organization
Name:
Frank
Kohn
Comment
Number:
30506­
064001
Excerpt
Number:
2
Excerpt
Text:
The
additional
value
provided
to
growers
could
be
a
critical
component
in
maintaining
viable
economic
farming
conditions,
especially
for
the
smaller
acreage
farmer.
Growers
are
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
that
void.

Commenter
Name:
Richard
Lohnes
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Co.
Comment
Number:
30509­
017000
Excerpt
Number:
2
Excerpt
Text:
Rootworm
protected
corn
targets
the
insect(
s)
that
eat
the
corn
roots
and
do
not
affect
the
beneficial
insects.
The
soil
is
a
living
organism,
and
I
believe
that
we
can
do
it
damage
using
chemicals
that
kill
all
or
many
insects
just
to
eliminate
the
"
bad
guys."
Insects
and
nematodes
building
the
soil
and
not
feeding
on
corn
roots
will
not
be
eliminated
using
this
technology.
We
need
a
healthy
soil
to
feed
this
nation
and
I
believe
that
rootworm
protected
corn
will
result
in
a
healthier
less
toxic
soil.

Commenter
Name:
William
Fleming
Commenter
Organization
Name:
William
Fleming
Comment
Number:
30509­
019000
Excerpt
Number:
1
Excerpt
Text:
I
understand
that
you
are
considering
biotech
corn
root
worm
resistant
corn.
I
have
studied
this
technology
and
it's
potential
application.
I
have
concluded
that
it
is
a
good
and
useful
technology
and
one
that
should
be
approved.

Not
only
is
it
environmentally
friendly,
but
I
believe
it
will
reduce
the
cost
to
produce
by
the
farmer.

Commenter
Name:
Stephen
Sears
Commenter
Organization
Name:
Stephen
Sears
Comment
Number:
30509­
036000
Excerpt
Number:
1
Excerpt
Text:
Please
consider
this
letter
as
a
reguest
to
consider
the
very
sound
technology
of
controlling
the
corn
rootworm.
by
biological
means.
It
is
for
sure
a
better
mouse
trap.
Thank
you
for
giving
us
the
opportunity
to
express
ourselves.
Lets
let
science
be
impartial
in
this
instance
and
take
good
advice
from
the
finest
minds
we
have
today
regarding
this
technology..
Section
5.0
5
­
2
Commenter
Name:
Robert
Witte
Commenter
Organization
Name:
Robert
Witte
Comment
Number:
30509­
040001
Excerpt
Number:
1
Excerpt
Text:
I'm
writing
to
tell
you
that
I
support
the
registration
of
corn
rootworm
protected
corn
and
to
urge
the
E.
P.
A.
to
consider
the
benefits
to
our
environment,
the
safety
to
those
who
handle
the
seed
corn
versus
handling
bulk
insecticides,
and
the
economics
of
keeping
farmers
competitive
with
the
world
market
place.

Commenter
Name:
Ron
Breckon
Commenter
Organization
Name:
Ron
Breckon
Comment
Number:
30509­
040004
Excerpt
Number:
1
Excerpt
Text:
The
biotech
technology
is
expected
to
give
better
control
with
less
impact
on
the
environment
along
with
user
safety.

Commenter
Name:
Gerald
Wilde
Commenter
Organization
Name:
Kansas
State
University
­
Department
of
Entomology
Comment
Number:
30509­
055000
Excerpt
Number:
1
Excerpt
Text:
Having
been
involved
in
the
testing
of
their
product.
I
have
seen
first
hand
the
remarkable
level
of
western
corn
rootworm
control
this
product
can
deliver.
At
the
same
time
I
am
aware
of
numerous
studies
which
have
been
conducted
to
deal
with
the
insect
resistance
management
aspect
of
this
product
and
the
studies
to
determine
any
possible
adverse
effects
on
non­
target
organisms.
These
studies
and
others
lead
me
to
believe
that
this
transgenic
rootworm
protected
corn
product
should
be
registered
as
it
will
be
a
valuable
pest
management
tool
for
the
corn
producers
of
the
U.
S.
and
other
parts
of
the
world.

Commenter
Name:
Thomas
Nickson
Commenter
Organization
Name:
Thomas
Nickson
Comment
Number:
30509­
056000
Excerpt
Number:
1
Excerpt
Text:
Currently
in
the
US,
more
insecticide
is
applied
to
corn
to
control
the
corn
rootworm
pest
than
any
other
pest.
The
data
collected
to
date
strongly
indicate
that
growers
will
reduce
the
amount
of
pesticide
applied
to
control
this
insect
once
this
product
is
approved.
Furthermore,
there
is
no
data
to
suggest
that
the
risks
associated
with
this
product
exceed
those
currently
present
with
the
practices
in
use.
In
fact,
there
is
evidence
to
suggest
that
the
risks
will
be
less.
This
product
has
the
potential
to
reduce
grower
exposure
to
certain
insecticides
as
well
as
provide
effective
and
specific
control
of
a
major
pest.

Commenter
Name:
Erik
Martin
Section
5.0
5
­
3
Commenter
Organization
Name:
Erik
Martin
Comment
Number:
30509­
057000
Excerpt
Number:
1
Excerpt
Text:
The
truth
is
that
most
transgenic
crops
are
more
benificial
to
the
environment
than
traditional
seed.
In
particular,
plants
designed
to
combat
the
corn
root
worm
are
a
true
blessing
to
both
the
success
of
American
farmers,
and
the
environment
as
a
whole.
Bt
has
repeatedly
been
found
to
be
harmless
in
humans
and
livestock,
further,
it
is
often
not
even
expressed
in
the
seed.
Beyond
that
it
is
easily
broken
down,
and
a
wonderful
alternative
to
traditional
pesticides.

Commenter
Name:
Roger
Youngman
Commenter
Organization
Name:
Virginia
Tech
University
Comment
Number:
30509­
061000
Excerpt
Number:
3
Excerpt
Text:
Although
I
continue
to
urge
growers
to
rotate
their
cornfields
whenever
possible
to
break
the
corn
rootworm
lifecycle,
many
are
reluctant
or
unable
to
do
so.
It
is
my
feeling
that
the
commercial
availability
of
corn
rootworm­
protected
Bt
corn
hybrids
represents
a
powerful
addition
to
the
arsenal
of
pest
management
options
currently
available
to
growers
for
managing
corn
rootworms.

Commenter
Name:
Bryan
Hurley
Commenter
Organization
Name:
Bryan
Hurley
Comment
Number:
30509­
066004
Excerpt
Number:
1
Excerpt
Text:
I
think
more
broadly
speaking
the
technology
under
development
for
control
of
corn
rootworm
has
tremendous
benefits
that
we'd
be
remiss
to
ignore.
As
a
society,
we
have
in
our
reach
technology
that
can
revolutionize
the
way
our
food
is
produced
in
overwhelmingly
positive
ways.

To
allow
baseless
claims
made
by
activist
organizations
inhibit
or
slow
this
technology
is
inconceivable
to
me.
If
we
take
a
step
back
and
weigh
this
technology
on
its
merit
and
on
the
benefit
it
promises,
we
stand
too
lose
too
much
if
we
do
no
move
forward.

Commenter
Name:
David
Gustafson
Commenter
Organization
Name:
David
Gustafson
Comment
Number:
30509­
066014
Excerpt
Number:
1
Excerpt
Text:
I
have
personally
seen
other
types
of
transgenic
corn
systems
­­
such
as
Liberty
Link.
and
Roundup
Ready
­­
play
a
similar
role
in
improving
drinking
water
quality
in
vulnerable
watersheds
of
the
Corn
Belt.
Many
Community
Water
Systems
in
these
areas
have
difficulties
meeting
water
quality
standards
for
the
triazine
herbicides.
Because
neither
glufosinate
nor
glyphosate
has
the
same
potential
to
reach
water
supplies,
growers
are
able
to
use
transgenic
corn
as
an
important
mitigation
tool
to
improve
water
quality.
The
new
CRW
technology
will
give
growers
yet
another
option
to
enhance
the
environmental
sustainability
of
Section
5.0
5
­
4
intensive
row
agriculture
in
the
US.

Commenter
Name:
Stephen
Wratten
Commenter
Organization
Name:
Stephen
Wratten
Comment
Number:
30509­
066016
Excerpt
Number:
2
Excerpt
Text:
The
traditional
insecticides
are
often
being
de­
registered
due
to
various
safety
concerns.
Growers
are
losing
insecticide
choices
and
are
in
need
of
effective
alternatives
to
fill
that
void
Commenter
Name:
Dennis
Clavin
Commenter
Organization
Name:
Pennsylvania
State
University
Comment
Number:
30509­
069000
Excerpt
Number:
3
Excerpt
Text:
Aside
from
these
non­
point
source
pollution
issues,
biotech
corn
rootworm
corn
would
greatly
reduce
the
grower's
potential
for
contact
with
toxic
materials
and
their
need
for
on­
farm
storage,
a
major
worker
protection
issue.
In
addition,
biotech
corn
rootworm
corn
would
provide
growers
with
simplicity
and
convenience
by
eliminating
the
need
for
insecticide
boxes
or
liquid
applicators,
application
equipment
calibration,
and
storage
of
insecticides.

The
product
also
provides
an
ideal
fit
with
current
integrated
pest
management
(
IPM)
programs.
Because
adult
rootworms
can
be
scouted
during
the
previous
year,
farmers
can
select
only
those
fields
with
economic
infestations
for
use
of
the
technology.
This
is
an
advantage
over
the
biotech
products
currently
marketed
for
European
corn
borer
control.

Commenter
Name:
Brad
Biddick
Commenter
Organization
Name:
Brad
Biddick
Comment
Number:
30509­
073000
Excerpt
Number:
2
Excerpt
Text:
The
opportunity
to
provide
seed
with
the
ability
to
protect
itself
from
a
pest
as
widespread
as
the
corn
rootworm
is
one
opportunity
we
should
capture.
The
seed
industry
is
accountable,
professional
and
small
enough
to
provide
control.
All
corn
seed
passes
through
the
seed
industry
pipe.
It
is
a
natural
way
to
professionally
affect
"
the
basic
production
methods
of
every
corn
grower.

Commenter
Name:
James
Shearl
Commenter
Organization
Name:
Golden
Haarvest
Seeds,
Inc.
Comment
Number:
30509­
074000
Excerpt
Number:
1
Excerpt
Text:
Corn
rootworm
protected
corn
is
the
single
most
important
biotechnology
development
yet.
It
delivers
safe
and
excellent
control
of
corn
rootworm
and
will
greatly
reduce
the
use
of
pesticides.
From
our
company
tests
we
know
this
product
will
greatly
improve
corn
yields
while
reducing
pesticide
use.
Section
5.0
5
­
5
Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
3
Excerpt
Text:
­
84
percent
said
they
would
be
interested
or
very
interested
in
using
anew
seed
resistant
to
corn
rootworms
­
32
percent
said
they
would
use
this
new
seed
in
the
first
year
it
is
offered
and
nearly
half
(
48%)
said
they
would
use
it
on
continuous
corn
acres.

Commenter
Name:
Robert
Osgood
Commenter
Organization
Name:
Robert
Osgood
Comment
Number:
30509­
082006
Excerpt
Number:
2
Excerpt
Text:
Farmers
and
their
families
will
also
benefit
from
a
safer
work
environment
and
their
corn
will
be
more
cost
competitive
in
the
world
market.
Lower
costs
of
production
may
also
be
passed
on
to
the
consumer
but
this
is
a
more
complicated
issue
involving
business
decisions
at
many
levels.

Commenter
Name:
Lance
Santo
Commenter
Organization
Name:
Lance
Santo
Comment
Number:
30509­
082009
Excerpt
Number:
1
Excerpt
Text:
This
new
biotech
rootworm
product
advantages
are:

1.
Environmentally
friendly
tool
that
growers
could
use
safely.

2.
Reduce
insecticides
usage
and
minimize
impact
on
the
environment.
Soil­
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.

3.
Minimize
insecticide
exposure
(
due
to
handling,
application
and
possible
drift
of
insecticides)
to
workers
and
community.

4.
Works
well
with
integrated
pest
management
(
IPM)
programs.

5.
Less
or
no
adverse
effects
on
beneficial
insects.

6.
Provides
more
consistent
control
of
the
corn
rootworm
than
insecticides
that
may
have
more
variable
performance
due
to
varying
soil
and
weather
conditions.

7.
Provides
a
non­
chemical
alternative
to
control
an
economically
damaging
pest.

Commenter
Name:
Dave
Seehusen
Section
5.0
5
­
6
Commenter
Organization
Name:
Land
O'Lakes,
Inc.
Comment
Number:
30509­
085000
Excerpt
Number:
1
Excerpt
Text:
I
personally
support
the
registration
of
corn
rootworm
protected
seed
because
it
would
provide
the
American
public
with
a
better
environment.
It
would
provide
farmers
better
control
of
rootworms.
By
reducing
insecticide
handling,
corn
^
rootworm
protected
corn
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families.
This
technology
should
be
an
excellent
economic
benefit
to
farmers
and
reduce
their
time
handling
toxic
products.

Commenter
Name:
Ron
Fitchorn
Commenter
Organization
Name:
Illinois
Corn
Growers
Association
Comment
Number:
30509­
104000
Excerpt
Number:
1
Excerpt
Text:
The
ICGA
supports
the
development
of
new
biotechnology
products
to
help
reduce
the
environmental
impact
of
pesticides
and
increase
productivity
of
growing
corn.
Bt
corn
rootworm
protected
corn
offers
many
potential
benefits
to
our
members
and
society
at
large
in
reduced
use
of
insecticides.
Safety
of
farmers
and
their
families;
decreased
demands
for
chemical
storage,
transportation
and
disposal
of
chemical
containers;
and
easy
integration
with
integrated
pest
management
programs
are
some
of
these
benefits.

Commenter
Name:
Bruce
Hammond
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509­
108008
Excerpt
Number:
4
Excerpt
Text:
This
could
have
important
human
and
animal
health
potential
in
areas
where
insect
damage
causes
significant
mycotoxin
contamination
of
corn.
I
am
excited
about
the
current
and
future
potential
benefits
of
the
Bt
technology
and
hope
that
EPA
recognizes
these
benefits
and
gives
the
technology
the
opportunity
to
benefit
farmers,
the
environment,
and
ultimately,
the
consumer.

Commenter
Name:
Thomas
O'Connor
Commenter
Organization
Name:
National
Grain
and
Feed
Association
Comment
Number:
30509­
112000
Excerpt
Number:
1
Excerpt
Text:
The
NGFA
supports
continued
development
of
biotechnology.'
Monsanto
believes
the
new
rootworm
technology
can
reduce
insecticide
use
and
associated
exposure
to
the
environment
and
users,
reduce
costs
to
farmers,
and
provide
superior
performance
over
current
insecticides.
These
are
important
benefits
that
should
be
carefully
weighed
by
regulators.

Commenter
Name:
Chastitie
Herman
Commenter
Organization
Name:
Chastitie
Herman
Section
5.0
5
­
7
Comment
Number:
30509B­
024000
Excerpt
Number:
1
Excerpt
Text:
Registration
of
this
product
will
ultimately
reduce
the
amount
of
pesticides
used
in
our
soils
along
with
a
reduced
economic
yield
loss
from
the
damage
of
the
corn
rootworm.

Commenter
Name:
Jeff
Sernett
Commenter
Organization
Name:
Jeff
Sernett
Comment
Number:
30509B­
025000
Excerpt
Number:
4
Excerpt
Text:
Corn
rootworm
protected
corn
will
provide
corn
growers,
the
environment
and
consumers,
with
a
number
of
advantages
if
it
is
approved
for
use
in
the
United
States.
I
also
understand­
that
this
product
has
full
feed
and
food
registration
for
import
in
Japan,
which
is
a
significantly
important
trading
partner
for
us.

Commenter
Name:
Gary
Drimmer
Commenter
Organization
Name:
Gary
Drimmer
Comment
Number:
30509B­
027010
Excerpt
Number:
1
Excerpt
Text:
In
addition
to
improving
the
ability
to
produce
food
in
a
more
economical
and
safer
way,
the
approval
of
this
new
form
of
^
Bt
corn
will
give
added
strength
to
the
acceptance
of
genetically
engineered
foods
around
the
world,
just
through
the
addition
of
a
larger
percentage
of
GE
corn
on
the
world
market.
As
the
markets
recognize
that
these
foods
are
safe
for
human
consumption
and
the
environment,
the
market
will
be
able
to
adapt
the
next
generation
of
products
that
will
be
more
output
related
with
added
benefits
to
our
health.
This
is
going
to
be
an
important
step
for
all
of
humanity.

Commenter
Name:
Quentin
Martin
Commenter
Organization
Name:
Quentin
Martin
Comment
Number:
30509B­
027015
Excerpt
Number:
1
Excerpt
Text:
There
is
no
question
in
my
mind
that
transgenic
control
of
rootworm
would
have
a
very
positive
environmental
effect.
For
those
farmers
who
grow
a
significant
amount
of
corn,
crop
rotation
alone
is
not
a
complete
enough
line
of
defense.
Ontario
corn
producers
have
demonstrated
a
responsible
use
of
Bt
corn,
and
the
same
would
be
true
for
rootworm
protected
corn.

Commenter
Name:
Jeff
Hinen
Commenter
Organization
Name:
Jeff
Hinen
Comment
Number:
30509B­
029000
Excerpt
Number:
2
Excerpt
Text:
In
order
to
manage
this
pest,
I
currently
use
very
toxic
insecticides
that
I
do
not
like
exposing
myself
or
my
family
to,
but
I
feel
I
must
in
order
to
compete.
I
also
do
not
like
putting
these
chemicals
into
my
soil
Section
5.0
5
­
8
where
they
can
potentially
contaminate
the
water
I
drink.
These
are
the
primary
reasons
why
I
need
these
new
corn
hybrids,
resistant
to
this
pest
on
my
farm.
I
would
like
to
use
these
hybrids
because
they
are
simple
to
use
(
no
way
to
overdose
the
rate
in
the
soil),
provide
me
effective
control
for
the
entire
growing
season,
are
not
toxic
to
me
when
I
handle
them
or
to
my
children
if
they
are
exposed
to
them,
and
they
fit
my
current
overall
pest
control
IPM
programs.

Commenter
Name:
Jay
Lehr
Commenter
Organization
Name:
The
Heartland
Institute
Comment
Number:
30509B­
030003
Excerpt
Number:
1
Excerpt
Text:
It
is
common
knowledge
that
25%
of
all
crops
in
the
developing
countries
are
contaminated
with
mycotoxins
carried
by
pests
such
as
the
European
Corn
Borer
and
corn
root
worm.
In
1993
The
World
Bank
reported
that
about
40%
of
disability
adjusted
life
years
in
developing
countries
are
due
to
disease
linked
to
mycotoxins
in
grains.
Bt
corns
greatest
contribution
will
ultimately
be
saving
the
lives
and
futures
for
millions
of
men
and
women
in
the
Third
World.

Adding
one
or
two
specific
genes
to
a
crop
plant
can
help
it
resists
disease
infection.
Add
other
genes
and
that
plant
can
produce
biologic
insecticides
to
ward
off
pests.

Commenter
Name:
Jay
Lehr
Commenter
Organization
Name:
The
Heartland
Institute
Comment
Number:
30509B­
030003
Excerpt
Number:
2
Excerpt
Text:
Bt
corn
is
a
product
that
can
reduce
disease
and
improve
diets
for
human
populations
around
the
world.
Scientifically
there
are
simply
no
down
sides
to
its
widespread
use,
but
the
fear­
mongering
goes
on
never
the
less.
We
must
not
allow
junk
science
and
out
right
fraud
by
those
who
would
eliminate
all
advanced
technology
in
order
to
drive
people
off
the
lowest
wrung
of
life's
ladder
and
preserve
the
earth
for
lesser
animals
than
man.

Commenter
Name:
Greg
Lackner
Commenter
Organization
Name:
Greg
Lackner
Comment
Number:
30509B­
030005
Excerpt
Number:
1
Excerpt
Text:
In
a
letter
to
the
editors
of
Nature
published
last
November,
a
scientist
with
a
history
of
anti­
technology
advocacy
and
his
assistant
claimed
to
have
tested
samples
of
corn
grown
on
farms
in
Southern
Mexico.
They
reported
that
by
using
genetic
tests,
they
had
found
the
local
corn
was
"
contaminated"
by
genetically
modified
corn.

Three
groups
of
University­
based
scientists,
working
independently,
examined
the
research
data
and
found
it
to
be
erroneous.
Each
group
has
submitted
formal
letters
to
Nature
challenging
the
letter's
validity.
In
addition,
the
editors
of
the
Transgenic
Research
Journal
examined
the
data
and
have
determined
it
to
be
"
fundamentally
flawed."
On
March
1,
a
petition
signed
by
nearly
one
hundred
prominent
scientists
was
Section
5.0
5
­
9
released,
calling
for
greater
scrutiny
of
the
report.

In
a
comprehensive
review
of
the
controversy
published
in
the
February
issue
of
the
Transgenic
Research
Journal,
the
Center
for
the
Improvement
of
Maize
and
wheat
in
Mexico
stated,
"
no
credible
scientific
evidence
is
presented
in
the
paper
to
support
claims
made
by
the
authors
that
gene
flow
between
transgenic
maize
and
traditional
maize
landraces
[
or
strains]
has
taken
place."
The
reviewers
found
it
"
most
frustrating"
that
the
authors
failed
to
use
more
reliable
techniques
to
determine
the
presence
of
the
transgenes.

An
editorial
note
in
this
week's
edition
of
Nature
officially
ended
the
scam:
"
Nature
has
concluded
that
the
evidence
available
is
not
sufficient
to
justify
the
publication
of
the
original
paper."

Even
as
the
claim
at
the
base
of
the
controversy
was
being
debunked,
environmental
groups
were
spreading
the
lie
to
media
outlets
around
the
[
letter
was
cutoff]

Commenter
Name:
Maarten
Chirspeels
Commenter
Organization
Name:
Maarten
Chirspeels
Comment
Number:
30509B­
030008
Excerpt
Number:
1
Excerpt
Text:
I
am
quite
familiar
with
the
procedures
to
create
GM
crops
and
the
benefits
and
possible
drawbacks
associated
with
them.
I
have
written
extensively
on
the
subject.
All
evidence
to
date
suggests
that
insect
resistant
GM
crops
reduce
pesticide
costs
to
farmers
and
can
have
real
benefits
for
the
environment.
Approval
by
USDA
and
EPA
of
rootworm
resistant
corn
is
an
important
step
towards
more
sustainable
agriculture,
improving
our
environment,
and
supporting
America's
farmers.

Commenter
Name:
Stephen
Dudley
Commenter
Organization
Name:
Stephen
Dudley
Comment
Number:
30509B­
030010
Excerpt
Number:
1
Excerpt
Text:
I
support
the
use
of
biotech
engineered
corn.
If
we
can
produce
more
food
for
our
tables,
substantially
reduce
the
amount
of
chemicals
introduced
into
the
soil
and
our
groundwater,
then
in
my
eyes
it
is
a
"
win
win"
situation
for
everyone.
Protect
the
environment.
feed
the
hungry
......
USE
BT
CORN!

Commenter
Name:
Bill
Thorne
Commenter
Organization
Name:
Bill
Thorne
Comment
Number:
30509B­
030011
Excerpt
Number:
1
Excerpt
Text:
I
agree
with
those
who
believe
that
when
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides
resulting
in
the
elimination
of
millions
of
pounds
of
chemical
pesticides,
increased
yields
for
certain
crops
and
delivered
significant
economic
benefits
to
farmers
and
consumers.
Section
5.0
5
­
10
Commenter
Name:
John
Balkcum
Commenter
Organization
Name:
John
Balkcum
Comment
Number:
30509B­
030014
Excerpt
Number:
1
Excerpt
Text:
During
the
1800'
s
about
90%
of
America
farmed
and
food
was
scare.
Today
thanks
to
the
technology
and
science
available
today
only
3%
of
America
farms
and
we
have
more
food
than
can
be
sold,
donated,
turned
into
fuel
an
animal
feed.

I
have
heard
for
decades
from
fear
mongering
socialists
like
Ted
Danson
and
Ted
Turner
that
the
strain
of
pollution,
pesticides
and
land
overuse
would
kill
us
all
and
destroy
our
earth.
Allow
science
and
technology
to
continue
providing
better,
more
nutritious
food
for
America
and
the
world.

Commenter
Name:
Karl
Bagnall
Commenter
Organization
Name:
Karl
Bagnall
Comment
Number:
30509B­
030017
Excerpt
Number:
1
Excerpt
Text:
As
a
consumer
of
corn
products
and
having
been
a
farmer
in
the
earlier
portion
of
my
life,
I
think
that
it
is
of
utmost
importance
that
the
research
to
develop
stronger
disease
and
pest
resistant
strains
of
food
products
be
continued
across
the
board.
not
just
with
corn.
Our
world
population
increases
at
a
rate
of
10%
a
year
now
and
in
a
few
short
years
there
will
not
be
enough
food
to
feed
everybody.
So
we
had
better
start
doing
something
now
to
either
increase
food
production
or
reduce
the
number
of
consumers.
I'd
rather
support
the
first
choice
rather
than
the
second.

Commenter
Name:
Leon
Corzine
Commenter
Organization
Name:
National
Corn
Growers
Assoc.
Comment
Number:
30509B­
036000
Excerpt
Number:
1
Excerpt
Text:
­
It
also
decreases
growers
time
and
expenses
associated
with
application,
equipment
and
upkeep
Commenter
Name:
Joan
O'Brien
Commenter
Organization
Name:
Iowa
Seed
Association
Comment
Number:
30509B­
043000
Excerpt
Number:
3
Excerpt
Text:
Corn
rootworm
protected
corn
will
provide
corn
growers,
the
environment
and
consumers,
with
a
number
of
advantages
if
it
is
approved
for
use
in
the
United
States.
I
understand
this
product
has
full
feed
and
food
registration
for
import
in
Japan.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Comment
Number:
30509B­
082000
Section
5.0
5
­
11
Excerpt
Number:
3
Excerpt
Text:
The
main
point
is
that
a
product
like
corn
event
MON
863
as
a
plant
incorporated
insecticide
is
a
good
substitute
for
the
currently
used
insecticides
and
as
such
will
likely
be
rapidly
adopted
by
farmers.

Commenter
Name:
Dennis
Ward
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509B­
086000
Excerpt
Number:
1
Excerpt
Text:
Monsanto
Company
has
developed,
through
the
use
of
recombinant
DNA
techniques,
corn
plants
that
are
protected
from
damage
due
to
corn
rootworm
larval
feeding.
This
transgenic
corn,
designated
corn
event
MON
863,
has
been
genetically
engineered
to
express
a
variant
of
the
Cry3.
Bbl
protein
derived
from
Bacillus
thuringiensis.
Upon
regulatory
approval,
hybrid
corn
varieties
containing
event
MON
863
will
be
marketed
under
the
brand
name,
YieldGard
Rootworm.
These
hybrids
will
offer
significant
benefits
to
corn
growers
and
society,
including
more
convenient
corn
rootworm.
(
CRW)
management,
more
consistent
control
of
the
CRW
larvae,
and
the
potential
for
major
reductions
in
human
and
environmental
exposure
to
conventional
insecticides.

Commenter
Name:
Dennis
Ward
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509B­
086000
Excerpt
Number:
24
Excerpt
Text:
MON
863
is
a
highly
effective
product
and
will
offer
real
benefits
to
farmers
and
society.
The
proposed
interim
MM
plan
for
MON
863
corn
has
been
designed
with
input
from
key
stakeholders,
including
academic,
government
and
industry
scientists,
crop
consultants
and
growers.
The
interim
plan
will
evolve
over
time
as
new
information
is
developed,
just
as
the
current
IRM
plan
for
YieldGard
Corn
Borer
evolved
over
time.
During
the
initial
years
that
MON
863
corn
is
on
the
market,
additional
research
will
be
collected
on
pest
biology,
product
dose
and
grower
implementation
practices.
These
research
results
will
be
used
to
design
an
improved
IRM
plan
that
will
ensure
durability
of
CRW­
protected
hybrids.

Commenter
Name:
Julie
Doane
Commenter
Organization
Name:
Julie
Doane
Comment
Number:
30509B­
091000
Excerpt
Number:
2
Excerpt
Text:
The
USDA
and
EPA
are
currently
reviewing
applications
for
biotechnology
improved
corn
rootwormprotected
corn.
When
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides.
According
to
the
U.
S.
Department
of
Agriculture
and
numerous
independent
studies,
similar
biotechnology­
improved
crops
have
already
resulted
in
the
elimination
of
millions
of
pounds
of
chemical
pesticides,
increased
yields
for
certain
crops
and
delivered
significant
economic
benefits
to
farmers
and
consumers.
Section
5.0
5
­
12
Commenter
Name:
Laron
Peters
Commenter
Organization
Name:
Laron
Peters
Comment
Number:
30509B­
092002
Excerpt
Number:
1
Excerpt
Text:
The
corn
rootworm
is
a
very
significant
pest
in
Nebraska
if
not
the
most
significant.
It
is
also
an
important
pest
in
other
corn
growing
regions.
Approval
of
this
technology
will
provide
many
advantages.
Some
are:
more
stable
yield
in
environments
where
corn
rootworm
is
a
problem,
reduction
in
the
use
of
insecticides,
reduced
pesticide
handling
and
container
disposal,
reduced
worker
exposure
to
hazardous
material.

Commenter
Name:
Laron
Peters
Commenter
Organization
Name:
Laron
Peters
Comment
Number:
30509B­
092002
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
biotechnology
expresses
control
through
a
safe,
naturally
occurring
Bt
protein
in
the
root
system.
The
expression
of
this
protein
is
throughout
the
growing
season
providing
continual
protection
against
this
harmful
insect.
Approval
by
USDA
and
EPA
is
an
important
step
toward
more
sustainable
agriculture.

Commenter
Name:
Don
Bockelman
Commenter
Organization
Name:
Don
Bockelman
Comment
Number:
30509B­
092008
Excerpt
Number:
2
Excerpt
Text:
I
do
know
that
this
technology
is
important
to
corn
production
and
has
many
benefits.
(
1)
Biological
control
of
the
pest
by
a
BT
protein,
similar
to
those
that
have
been
applied
safely
for
years,
and
which
recently
has
been
use
safely
and
effectively
in
transgenic
BT
corn.
(
2)
Reduction
of
toxic
pesticides
in
the
environment,
less
movement
and
less
production
of
toxic
chemicals,
and
fever
container
disposal
problems.
(
3)
Much
safer
(
no
risk)
for
the
farmer
that
would
normally
be
at
risk
for
chemical
exposure.
(
4)
Specifically
targets
the
pest
and
reduces
the
risk
to
non­
targeted
organism
and
the
environment.
(
4)
Would
increase
corn
productivity
and
hopefully
increase
the
profit
margin
for
farmers.
(
5)
Yield
loss
to
corn
rootworms
can
be
high.
Increase
spread
of
rootworms
adapting
to
soybean
fields
is
becoming
a
problem,
leaving
rotational
practices
less
effective
for
control
in
areas
of
heavy
corn
production.
Leaves
an
option
for
farmers
that
don't
want/
like
to
apply
insecticides
on
these
acreages.

Commenter
Name:
Mark
Gruhn
Commenter
Organization
Name:
Mark
Gruhn
Comment
Number:
30509B­
092010
Excerpt
Number:
1
Excerpt
Text:
CRW
protection
will
help
sustain
corn
yields
while
reducing
the
use
of
insecticides.
If
we
can
do
this,
I
think
this
will
be
a
tremendous
first
step
in
building
a
larger
earthworm
population.
I've
seen
a
"
soil
test"
of
earthworm
castings
and
the
level
of
available
nutrients
was
unbelievably
high.
I
believe
we
can
one
day
Section
5.0
5
­
13
reach
a
level
of
earthworms
where
supplemental
nitrogen,
phosphate
and
potash
may
be
greatly
decreased
or
even
eliminated.
Imagine
what
that
would
do
for
water
quality!

Commenter
Name:
Clinton
Pilcher
Commenter
Organization
Name:
Clinton
Pilcher
Comment
Number:
30509B­
092015
Excerpt
Number:
2
Excerpt
Text:
There
are
many
advantages
to
using
this
technology
as
an
additional
pest
management
tool:

1)
Reduced
Insecticide
Use
2)
Reduced
pesticide
exposure
to
applicators
Note:
Farmers
surveyed
(
Pilcher
and
Rice
1998)
said
the
greatest
advantage
to
this
technology
would
be
reduced
insectice
exposure
and
use.
3)
Reduced
environmental
contamination
(
soil
and
water)
4)
Yield
loss
prevention
5)
Saved
labor
time.
in
reducing
calibration
of
equipment
and
equipment
repair
6)
Saved
money
on
equipment
for
pesticide
application
7)
Potentially
could
save
money
on
reduced
scouting
costs
for
rootworm
8)
No
worries
on
fertilizer/
pesticide
interaction
concerns
9)
High
specifity
of
this
product
for
corn
rootworm
10)
Consistency
in
control
over
currently
used
soil­
insecticide
products
11)
Fits
well
within
current
IPM/
Sustainable
Agriculture
practices
which
are
highly
encouraged
Commenter
Name:
Dan
Swalla
Commenter
Organization
Name:
Dan
Swalla
Comment
Number:
30509B­
092018
Excerpt
Number:
1
Excerpt
Text:
Corn
rootworm­
protected
corn
will
be
very
good
for
farmers
and
for
the
environment.

Commenter
Name:
Kevin
Cook
Commenter
Organization
Name:
Kevin
Cook
Comment
Number:
30509B­
092020
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
resistance
technology
has
been
tested
for
a
couple
years
in
field
studies
for
efficacy
and
ecological
safety.
Other
similar
products
have
been
on
the
market
for
several
years
and
have
provided
farmers
with
an
excellent
method
of
controlling
pests
while
minimizing
the
use
of
hazardous
chemicals.
Although
there
can
never
be
a
guarantee
that
no
unforeseen
problem
could
arise
in
the
future
from
use
of
bioengineered
traits,
the
fact
that
none
has
risen
over
the
past
7
or
so
years
since
these
products
were
released
in
the
United
States
suggests
that
the
probability
of
such
an
occurrence
is
very
unlikely.

Commenter
Name:
Mark
Kulda
Section
5.0
5
­
14
Commenter
Organization
Name:
Mark
Kulda
Comment
Number:
30509B­
092021
Excerpt
Number:
1
Excerpt
Text:
Please
support
these
very
important
technologies.
Soon
you
will
be
asked
to
approve
BT
corn
that
helps
protect
against
pests
while
using
less
pesticides,
land,
labor
and
other
inputs.
This
efficiency
will
tremendously
help
us.
Please
vote
to
approve
it.

Commenter
Name:
Joseph
Borsa
Commenter
Organization
Name:
Joseph
Borsa
Comment
Number:
30509B­
092030
Excerpt
Number:
2
Excerpt
Text:
This
technology
is
a
blessing
bestowed
upon
mankind
to
help
us
deal
with
the
difficult
task
of
feeding
a
growing
human
population
while
at
the
same
time
protecting
the
environment
and
wildlife.

Commenter
Name:
Dennis
Falgout
Commenter
Organization
Name:
Dennis
Falgout
Comment
Number:
30509B­
092035
Excerpt
Number:
1
Excerpt
Text:
I
am
persuaded
by
the
European
Union
equivalent
of
the
USDA
and
the
US
FDA,
both
of
whom
have
said
that
GM
food
is
at
least
as
safe
as
conventional
food.
I
also
believe
that
GM
will
enable
feeding
of
the
world's
population
with
a
minimum
of
farmland,
and
a
minimum
of
energy.

Commenter
Name:
Larry
Passage
Commenter
Organization
Name:
Larry
Passage
Comment
Number:
30509B­
092043
Excerpt
Number:
1
Excerpt
Text:
Seems
like
the
sensible
thing
to
do,
using
technology
to
our
advantage,
reducing
chemicals
placed
in
soil,
reducing
cost
of
equipment
&
fuel
in
distributing
them
Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
2
Excerpt
Text:
This
product
offers
significant
opportunity
to
benefit
consumers
and
corn
growers.
By
making
this
product
widely
available,
we
will
reap
considerable
environmental
benefits
through
a
reduction
of
pesticides.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Section
5.0
5
­
15
Excerpt
Number:
7
Excerpt
Text:
In
addition
to
benefits
for
agriculture,
there
are
benefits
for
the
consumer
as
well.
A
recent
report
from
the
American
Phytopathological
Society
(
APS)
outlines
the
benefits
of
Bt
corn
to
both
human
health
and
the
environment.
According
to
Gary
Munkvold,
plant
pathologist
at
Iowa
State
University
and
an
APS
member,
the
innovative
Bt
technology
has
a
distinct
health
benefit
of
discouraging
the
buildup
of
mycotoxins
in
corn.
Mycotoxin
build­
up
is
directly
related
to
certain
fungal
plant
diseases,
which
can
be
increased
by
insect
damage
in
crops.
Some
of
these
toxins,
such
as
furnonisin,
can
be
fatal
to
horses
and
pigs
and
are
probable
human
carcinogens.
Lower
mycotoxin
concentrations
clearly
represent
a
benefit
to
the
public..

These
studies
conducted
by
Dr
Munkvold
looked
at
Bt
to
control
the
European
corn
borer.
However,
corn
rootworm
puts
similar
stress
on
the
corn
plant,
making
it
more
susceptible
to
invasion
of
molds
and
mycotoxins.
We
expect
that
rootworm.
Bt
would
also
reduce
the
mycotoxins
in
corn.

Commenter
Name:
Jim
Steward
Commenter
Organization
Name:
Steward
Seeds,
Inc.
Comment
Number:
30509B­
L001
Excerpt
Number:
3
Excerpt
Text:
Corn
rootworm
protected
corn
will
provide
corn
growers,
the
environment
and
consumers,
with
a
number
of
advantages
if
it
is
approved
for
use
in
the
United
States.
I
also
understand
that
this
product
has
full
feed
and
food
registration
for
import
in
Japan.

Commenter
Name:
Jim
Steward
Commenter
Organization
Name:
Steward
Seeds,
Inc.
Comment
Number:
30509B­
L001
Excerpt
Number:
4
Excerpt
Text:
Over
time,
there
will
be
a
need
for
increased
production
of
all
food
and
grain
products.
Using
biotechnology
to
enable
a
higher
more
consistent
level
of
food
and
grain
production
consuming
the
same
or
fewer
resources
is
in
the
best
interest
of
all.

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Memebers
Comment
Number:
OPP02­
0016
Excerpt
Number:
3
Excerpt
Text:
In
the
midst
of
these
problems,
transgenic
corn
resistant
to
corn
rootworms
offers
a
new
management
alternative
with
several
positive
features.
The
transgenic
events
expressing
Cry3Bb
that
are
proposed
for
registration
provide
root
protection
and
reduce
corn
rootworm
emergence
equivalent
to,
or
better
than,
soil
insecticides.
From
a
health
and
safety
perspective,
transgenic
corn
expressing
Cry3Bb
eliminates
applicator,
handler,
and
farm
worker
exposure
to
insecticides.
With
a
narrow
spectrum
of
activity,
transgenic
corn
also
eliminates
or
greatly
reduces
the
environmental
concerns
generated
by
broader
Section
5.0
5
­
16
spectrum
insecticides.
The
technology
is
easy
to
use
and
does
not
delay
planting.
Nor
does
it
require
special
application
equipment,
the
need
for
calibration,
or
the
disposal/
return
of
containers.
Performance
consistency
is
improved
since
each
plant
is
protected
and
this
protection
is
relatively
unaffected
by
weather.
Given
these
positive
features,
adoption
of
transgenic
technology
may
be
rapid
in
some
parts
of
the
Corn
Belt
once
it
becomes
commercially
available.

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Members
Comment
Number:
OPP02­
0016
Excerpt
Number:
28
Excerpt
Text:
A
conditional
registration
for
Mon
863
also
would
allow
farmers
to
gain
experience
with
the
technology
on
a
limited
basis
and
permit
IRM
adjustments
to
be
made
to
address
the
needs
of
end­
users.
Surveys
indicate
that
growers
want
the
technology
and
the
perceived
benefits
over
conventional
insecticides
(
e.
g.,
ease
of
use;
consistent
plant
to
plant
root
protection;
root
protection
equivalent
to,
or
better
than,
soil
insecticides;
performance
relatively
unaffected
by
weather;
elimination
of
human
exposure
(
e.
g.,
handler,
applicator,
farm
workers/
scouts,
etc.)
before
and
after
application
of
insecticides).
Therefore,
it
is
important
to
remember
that
our
challenge
is
to
develop
an
IRM
plan
that
is
biologically
responsible
(
to
preserve
susceptibility)
but
at
the
same
time
develop
the
plan
with
the
end­
user
in
mind
so
that
the
technology
will
be
easily
adopted
by
clientele
that
choose
to
use
it
and
IRM
compliance
will
be
high.

Commenter
Name:
N/
A
Commenter
Organization
Name:
Center
for
Science
in
the
Public
Interest
Comment
Number:
OPP02­
0028
Excerpt
Number:
23
Excerpt
Text:
Monsanto
also
argues
that
adoption
of
MON
863
varieties
may
occur
slowly
compared
to
Cryl
corn
because,
unlike
the
case
with
Bt
Cryl
targeted
to
European
Corn
Borer,
relatively
effective
chemical
alternatives
exist
for
CRW.
However,
adoption
of
MON
863
may
be
motivated
by
other
reasons.
For
example,
other
reported
reasons
for
the
widespread
rapid
adoption
of
glyphosate
resistant
soybeans
are
grower
convenience
and
time
saving
and
fewer
restrictions
on
crop
rotation.
The
same
may
be
true
for
MON
863
corn.

Commenter
Name:
Helen
Inman
Commenter
Organization
Name:
Helen
Inman
Comment
Number:
OPP02­
0036
Excerpt
Number:
2
Excerpt
Text:
As
a
producer
in
an
ever­
changing
agricultural
world,
I
have
come
to
realize
the
potential
of
biotechnology
to
farmers
and
consumers.
Currently
on
our
farming
operation,
100
percent
of
our
soybeans
are
herbicide
resistant
and
about
55
percent
of
our
corn
is
Bt.
We
make
all
of
our
planting
decisions
based
on
safety,
economics
and
marketability.
For
instance,
it's
not
always
practical
to
plant
herbicide
resistant
corn,
depending
on
the
final
market
for
our
grain.

EPA
Response:
Section
5.0
5
­
17
The
Agency
agrees
with
these
commenters
that
MON
863
will
provide
numerous
benefits
to
field
corn
growers
in
the
U.
S.
Such
benefits
include
increased
yields,
reduced
use
of
higher
risk
pesticides,
reduced
risk
to
human
heath
(
through
high
risk
pesticide
use
reduction),
reduced
environmental
risks
(
via
pesticide
use
reduction),
economic
benefits
to
growers
(
through
increased
yields
and
reduced
rootworm
control
costs),
and
practical
benefits
to
growers
(
ease
of
use
relative
to
chemical
control
alternatives).
The
Agency's
complete
assessment
of
benefits
for
MON
863
can
be
found
Chapter
E
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document.

Commenter
Name:
David
Mertens
Commenter
Organization
Name:
David
Mertens
Comment
Number:
30509­
025000
Excerpt
Number:
1
Excerpt
Text:
Corn
Rootworm
protected
corn
will
not
significantly
reduce
the
insecticide
use
on
these
corn
acres.
There
are
alternative
treatments
present
we
are
using
which
not
only
control
the
Corn
Rootworm
but
also
a
host
of
secondary
pests.

EPA
Response:
The
Agency
disagrees
with
this
comment.
Efficacy
data
have
shown
that
MON
863
is
as
effective
(
better
in
many
cases)
as
conventional
chemical
pesticides
in
reducing
corn
rootworm
damage.
Therefore,
the
number
of
acres
treated
with
conventional
pesticides
for
corn
rootworm
control
will
be
substantially
reduced
as
MON
863
adoption
increases.
According
to
the
Agency's
analysis,
for
every
acre
of
corn
planted
to
MON
863,
it
is
projected
that
one
less
acre
of
corn
will
be
treated
with
conventional
insecticides.
For
the
2003
growing
season,
the
expected
MON
863
adoption
of
one
million
acres
would
correspond
to
one
million
fewer
acres
treated
with
chemical
pesticides.
By
the
2007
growing
season,
use
of
MON
863
could
reduce
pesticide
acre
treatments
by
up
to
7
million.
The
Agency's
complete
assessment
of
pesticide
use
reduction
can
be
found
in
Chapter
E
(
section
7.1.6)
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document
(
BRAD).

As
the
commenter
has
indicated,
MON
863
is
not
labeled
for
secondary
soil
pests
(
i.
e.
cutworm,
wireworm,
maggots,
and
grubs)
that
may
also
be
controlled
with
conventional
insecticides
targeted
for
corn
rootworm.
However,
it
is
possible
that
MON
863
corn
may
be
sold
with
seed
treatments
to
protect
against
such
secondary
pests.
In
addition,
given
that
a
technology
fee
will
be
charged
to
MON
863
users,
it
is
unlikely
that
growers
with
significant
secondary
pest
problems
(
requiring
pesticide
treatment)
would
chose
to
plant
MON
863,
since
those
growers
would
not
save
money
by
reducing
insecticide
costs.
The
Agency's
economic
analysis
of
grower
adoption
for
MON
863
can
be
found
in
section
7
of
the
BRAD.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
20
Excerpt
Text:
E.
MON
863
Benefits
May
Be
Modest
for
Farmers
and
the
Environment.
Section
5.0
5
­
18
The
major
argument
advanced
by
Monsanto
in
support
of
MON
863
corn
is
that
the
technology
will
reduce
corn
insecticide
use
and
risks,
while
also
simplifying
farm
management.
A
reduction
in
insecticide
use
will
surely
occur
on
nearly
all
acres
planted
to
MON
863
corn
varieties.
Two
possible
benefits
could
follow
as
a
result:
(
1)
reduced
costs
to
growers
and/
or
increased
net
income;
and
(
2)
reduced
environmental
and
human
health
impacts
from
insecticide
treatments.
To
the
extent
MON
863
corn
triggers
an
increase
in
continuous
corn,
increased
pest
pressure
will
erode
both
benefits
to
some
degree.

Farm­
level
economic
benefits
will
be
modest,
since
seed
companies
will
charge
a
technology
fee
premium
for
MON
863
corn;
the
size
of
the
technology
fee
will
almost
certainly
equal
or
exceed
by
a
small
margin
the
cost
of
standard
insecticide
treatments.
[
Footnote
16:
Two
factors
will
tend
to
place
downward
pressure
on
tech
fee
premiums:
first,
MON
863'
s
minor
improvement
in
CRW
control
compared
to
standard
insecticide
treatments
and
second,
competitive
pressures,
as
insecticide
manufacturers
reduce
the
cost
of
their
products
to
retain
or
regain
market
share
from
MON
863.]
It
is
also
clear
that
there
is
no
basis
to
expect
a
yield
increase
in
fields
planted
to
MON
863
corn,
since
commonly
used
corn
soil
insecticides
provide
essentially
the
same
level
of
protection
against
root
damage.

EPA
Response:
The
Agency
disagrees
with
this
comment
and
believes
MON
863
growers
will
realize
significant
benefits.
The
Agency's
complete
assessment
of
benefits
for
MON
863
can
be
found
Chapter
E
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document
(
BRAD).
Specifically,
the
Agency
has
calculated
that
growers
planting
MON
863
corn
can
expect
to
see
average
benefits
of
$
6.56
per
acre
and
a
potential
profit
increase
of
10%.
These
benefits
are
calculated
based
on
expected
yield
improvements,
reduced
insecticide
costs,
and
practical
benefits
related
to
a
more
flexible
and
safer
product
(
relative
to
conventional
insecticides)
for
growers
to
use.
Potential
increase
in
pest
pressure
was
also
taken
into
account
­
it
was
assumed
that
corn
rootworm
infested
acres
will
increase
by
2.6%
per
year.
In
addition,
a
technology
fee
cost
of
$
15
per
acre
was
used
for
the
analysis
(
determined
with
a
simulated
demand
curve
for
MON863
­
see
chapter
E,
section
7.1.4
of
the
BRAD).
As
a
number
of
other
commenters
have
indicated,
the
economic
benefits
of
MON
863
will
be
significant
for
many
growers.

In
terms
of
yield
benefits,
the
Agency
has
estimated
that
MON
863
growers
may
observe
modest
yield
increases
of
1.5
to
4.5%
over
corn
treated
with
conventional
pesticides.
As
the
commenter
has
noted,
the
efficacy
of
MON
863
and
conventional
insecticides
is
comparable.
Section
5.1
Section
5
­
19
5.1
­
Efficacy
5.1
­
Comment
Excerpts
Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Company
Comment
Number:
30509­
018000
Excerpt
Number:
3
Excerpt
Text:
The
corn
rootworm
protected
corn
has
the
potential
to
provide
superior
and
consistent
performance
over
the
existing
insecticides.
In
a
plot
grown
here
in
the
summer
of
2000
that
contained
corn
rootworm
protected
corn,
the
results
were
amazing.
When
corn
rootworm
protected
corn
was
compared
against
several
current
corn
rootworm
insecticides.
the
corn
rootworm
protected
corn
averaged
50
bushels
per
acre
better
than
the
corn
treated
with
the
current
insecticides.
You
have
to
be
impressed
with
these
results
from
one
year
at
one
location.
I
have
seen
farmers
fields
with
around
30
rootworm
beetles,
the
adult
stage,
per
plant
and
almost
no
roots.
The
yield
was
less
than
10%
of
normal.
With
that
financial
loss,
those
individuals
would
not
hesitate
to
plant
the
corn
rootworm
protected
corn
when
it
is
approved
by
the
United
States
and
key
export
markets.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Company
Comment
Number:
30509­
018000
Excerpt
Number:
4
Excerpt
Text:
I
support
this
new
technology
because
it
reduces
the
usage
of
insecticides,
thereby
reducing
the
farmer,
his
family,
and
the
human
races
exposure
to
insecticides,
makes
for
a
better
environment
for
other
living
things,
and
has
a
better
efficacy
than
existing
products
for
corn
rootworms.
I
urge
the
EPA
to
support
this
new
technology
for
me
and
my
seed
corn
customers.

Commenter
Name:
Tom
Hunsley
Commenter
Organization
Name:
Growmark,
Inc.
Comment
Number:
30509­
023000
Excerpt
Number:
3
Excerpt
Text:
­
Through
improved
and
more
consistent
rootworm
control
it
will
offer
reduced
cost
of
production
for
corn.

Commenter
Name:
Kelly
Montgomery
Commenter
Organization
Name:
Kelly
Montgomery
Comment
Number:
30509­
027006
Excerpt
Number:
3
Excerpt
Text:
It
appears
that
corn
protected
by
biotech
means
will­
have
the
potential
to
provide
more
consistent
control
of
rootworm
and
be
less
subject
to
failure
from
extreme
environmental
conditions.
Section
5.1
Section
5
­
20
Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509­
028000
Excerpt
Number:
2
Excerpt
Text:
By
eliminating
this
treatment
I
can
realize
three
major
benefits.

1.
Less
insecticide
use
in
the
environment.
2.
Less
exposure
to
insecticides
for
myself
and
my
employees.
3.
More
profit
in
my
farming
operation.

Commenter
Name:
Chris
Shires
Commenter
Organization
Name:
Chris
Shires
Comment
Number:
30509­
034000
Excerpt
Number:
1
Excerpt
Text:
I
have
seen
the
results
from
corn
rootworm
protected
efficacy
plots
and
believe
it
will
be
a
valuable
tool
for
farmers
to
use
both
in
the
US
and
abroad.

The
results
I
witnessed
were
very
encouraging.
There
was
a
consistent
improvement
in
root
mass
and
a
noticeable
reduction
in
plant
goose
necking
(
lodging).
Therefore
I
personally
support
the
registration
of
rootworm­
protected
corn.

Commenter
Name:
Dean
Heffta
Commenter
Organization
Name:
Dean
Heffta
Comment
Number:
30509­
039000
Excerpt
Number:
3
Excerpt
Text:
Also,
corn
rootworm
protected
corn
has
the
potential
to
provide
superior
performance
over
current
insecticides.
This
technology
could
provide
a
significant
economic
value
to
the
farmers
who
are
impacted
by
the
corn
rootworm.
Often
with
insecticides,
performance
depends
upon
the
growing
conditions
and
corn
rootworm
protected
corn
would
provide
an
increase
in
the
consistency
of
pest
control.

Commenter
Name:
Todd
Burrus
Commenter
Organization
Name:
Todd
Burrus
Comment
Number:
30509­
040017
Excerpt
Number:
2
Excerpt
Text:
This
method
of
control
would
give
superior
control
(
and
season
long).

Commenter
Name:
Todd
Sieben
Commenter
Organization
Name:
Illinois
State
Senate
Comment
Number:
30509­
046000
Section
5.1
Section
5
­
21
Excerpt
Number:
2
Excerpt
Text:
The
potential
to
provide
superior
performance
and
a
more
consistent
control
of
the
damaging
corn
rootworm
pests
is
better
with
corn­
rootworm
protected
corn
than
would
be
given
by
the
more
unpredictable
performance
due
to
varying
growing
conditions
of
other
insecticides.
Many
growers
are
also
at
risk
of
losing
choices
(
i.
e.,
organophosphates
and
carbamates)
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
the
void.

Commenter
Name:
Arthur
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509­
053000
Excerpt
Number:
3
Excerpt
Text:
As
an
added
benefit,
corn
rootworm
protected
corn
would
be
more
effective
in
the
control
of
corn
rootworm.

Commenter
Name:
Phillip
Sloderbeck
Commenter
Organization
Name:
Phillip
Sloderbeck
Comment
Number:
30509­
056000
Excerpt
Number:
3
Excerpt
Text:
I
have
been
very
impressed
with
the
levels
of
rootworm
protection
seen
in
the
corn
rootworm
protected
corn
that
I
have
evaluated
in
our
research
plots
and
from
the
data
I
have
seen
from
other
states.

Commenter
Name:
Rodger
Mansfield
Commenter
Organization
Name:
Rodger
Mansfield
Comment
Number:
30509­
060000
Excerpt
Number:
3
Excerpt
Text:
Finally,
biotech
corn
rootworm
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
insecticides
that
may
have
more
variable
performance
due
to
varying
growing
conditions.
Growers
are
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
that
void.

Commenter
Name:
Stephen
Wratten
Commenter
Organization
Name:
Stephen
Wratten
Comment
Number:
30509­
066016
Excerpt
Number:
1
Excerpt
Text:
Another
problem
is
that
it
is
difficult
to
see
the
insects
in
the
soil
chewing
on
rootsInsect­­
control
via
biotech
corn
rootworm
corn
would
provide
built­
in
control,
ready
to
work
when
the
insect
arrives.
Growers
gain
simplicity
and
convenience.

Commenter
Name:
Matthew
Kraus
Section
5.1
Section
5
­
22
Commenter
Organization
Name:
Matthew
Kraus
Comment
Number:
30509­
066022
Excerpt
Number:
2
Excerpt
Text:
We
should
not
let
another
season
pass
in
this
unique
opportunity
to
reduce
corn
rootworm
insecticides
while
increasing
farmer
safety
and
agricultural
productivity!

Thank
you
for
your
consideration
in
helping
move
this
important
corn
rootworm
technology
forward.

Commenter
Name:
Dennis
Clavin
Commenter
Organization
Name:
Pennsylvania
State
University
Comment
Number:
30509­
069000
Excerpt
Number:
4
Excerpt
Text:
Finally,
biotech
corn
rootworm
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
insecticides
that
may
have
more
variable
performance
due
to
varying
growing
conditions.
Under
Pennsylvania
growing
conditions
hatch
of
larvae
can
occur
after
the
soil
insecticide
has
degradated
to
non­
toxic
concentration;
thus
leading
to
insecticide
failures.
The
biotech
corn
rootworm
material
provides
longer
season
protection
reducing
the
likelihood
of
a
complete
failure.
Growers
are
currently
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
the
potential
void.

Commenter
Name:
Rhonda
Mannion
Commenter
Organization
Name:
Rhonda
Mannion
Comment
Number:
30509­
070000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
a
significant
pest
problem
in
the
United
States.
If
approved
in
the
United
States,
this
new
biotech
rootworm
product
would
benefit
both
the
general
public
via
reduced
exposure
to
potentially
dangerous
insecticides
as
well
as
help
protect
our
environment.

Commenter
Name:
Rhonda
Mannion
Commenter
Organization
Name:
Rhonda
Mannion
Comment
Number:
30509­
070000
Excerpt
Number:
3
Excerpt
Text:
In
addition,
the
prevention
(
not
control)
of
corn
rootworms
will
significantly
reduce
the
number
of
burrows
in
the
corn
plant,
which
has
been
shown
to
have
direct
impact
on
the
level
of
mycotoxins.
A
reduction
in
mycotoxin
and
related
toxins
will
further
improve
the
overall
health
of
Americans.

Commenter
Name:
Jared
Bruckhart
Commenter
Organization
Name:
Chemgro
Seeds
Comment
Number:
30509­
081000
Excerpt
Number:
1
Section
5.1
Section
5
­
23
Excerpt
Text:
I
personally
support
the
registration
of
corn
rootworm
protected
corn
because
of
the
reduced
amount
of
insecticides
that
will
be
needed.
This
technology
will
also
provide
the
effectiveness
that
is
needed,
without
the
farmer
having
to
personally
handle
the
product.

Commenter
Name:
Jared
Bruckhart
Commenter
Organization
Name:
Chemgro
Seeds
Comment
Number:
30509­
081000
Excerpt
Number:
3
Excerpt
Text:
Another
benefit­
is
that
corn­
rootworm
protected
corn
is
specific
and
consistent.
This
technology
will
control
only
the
target
insect
that
feeds
on
the
corn
plant.
With
current
control
methods,
any
non­
target
insect
that
enters
the
band
of
insecticide
will
be
killed.
This
will
no
longer
occur
with
the
use
of
corn
rootworm
protected
corn.

Commenter
Name:
Merlyn
Carlson
Commenter
Organization
Name:
State
of
Nebraska
­
Department
of
Agriculture
Comment
Number:
30509­
086000
Excerpt
Number:
2
Excerpt
Text:
In
order
to
manage
this
pest
efficiently,
growers
throughout
Nebraska
use
insecticides
and
crop
rotation.
Recent
surveys
indicate
that
3.4
million
acres
of
Nebraska
farmland
were
treated
with
13
different
insecticides
for
corn
rootworm
control,
including
such
products
as
methyl
parathion.
Insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.

Corn
rootworm
protected
corn
will
provide
corn
growers,
the
environment,
and
consumers,
with
a
number
of
advantages
if
it
is
approved
for
use
in
the
United
States
and
in
foreign
markets.

­
First,
corn
receives
maximum,
more
consistent,
protection
because
the
plant
automatically
protects
itself
from
the
insect.

­
Second,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.
This
is
important
because
regulatory
pressures
mean
many
farmers
are
at
risk
of
losing
some
insecticide
choices
(
i.
e.,
organophosphates
and
carbamates)
and
are
in
need
of
effective
alternatives
to
fill
the
void.
The
use
of
less
chemicals
is
also
a
health
benefit
to
consumers
and
the
environment.

­
Third,
with
reduced
insecticide
use,
corn
growers
and
their
families
have
less
risk
of
insecticide
exposure.

Commenter
Name:
David
Swinford
Commenter
Organization
Name:
Texas
House
of
Representatives
Comment
Number:
30509­
095000
Excerpt
Number:
2
Excerpt
Text:
Section
5.1
Section
5
­
24
­
Corn
rootworm
protected
corn
has
the
potential
to
provide
superior
performance
over
current
insecticides.

Commenter
Name:
David
Swinford
Commenter
Organization
Name:
Texas
House
of
Representatives
Comment
Number:
30509­
095000
Excerpt
Number:
3
Excerpt
Text:
­
Corn
rootworm
protected
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
insecticides
that
may
have
unpredictable
performance
due
to
varying
growing
conditions.

Commenter
Name:
Lisa
Watson
Commenter
Organization
Name:
Lisa
Watson
Comment
Number:
30509­
108000
Excerpt
Number:
1
Excerpt
Text:
I
would
like
to
express
support
for
new
technologies
such
as
corn
protected
from
corn
rootworm,
a
product
currently
under
review
by
EPA.

We
must
constantly
strive
to
develop
safe,
new
technologies
that
will
allow
our
farmers
to
produce
food
with
fewer
inputs
and
external
resources.
The
corn
rootworm
technology
appears
to
offer
such
an
opportunity.

While
the
safety
of
various
applied
insecticides
is
a
hotly
debated
issue,
few
growers
or
consumers
would
disagree
that
reducing
exposure
is
a
move
in
the
right
direction.

Commenter
Name:
Bruce
Hammond
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509­
108008
Excerpt
Number:
1
Excerpt
Text:
I
firmly
believe
that
providing
in
plant
protection
against
insect
pests
will
be
highly
beneficial
to
the
environment
and
will
result
in
the
production
of
healthier
corn
plants.

Commenter
Name:
Bruce
Hammond
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509­
108008
Excerpt
Number:
3
Excerpt
Text:
I
am
also
studying
the
impacts
of
the
Bt
technology
on
mycotoxin
levels
in
corn.
We
have
found
that
one
of
the
Bt
proteins,
Cry
1Ab
protects
corn
against
corn
borer
damage
resulting
in
less
fusaria
ear
rot
and
reduced
fumonisin
contamination.
This
product
provides
the
first
opportunity
to
reduce
fumonisin
contamination
in
corn;
future
products
may
be
able
to
provide
a.
broader
control
of
other
mycotoxins.
Section
5.1
Section
5
­
25
Commenter
Name:
Kelly
Hasbargen
Commenter
Organization
Name:
Seeds
2000,
Inc.
Comment
Number:
30509­
110000
Excerpt
Number:
3
Excerpt
Text:
In
addition,
corn
rootworm
protected
corn
appears
to
provide
control
of
corn
rootworms
equal
or
superior
to
currently
used
insecticides
resulting
in
more
consistent
control
and
less
economic
lots.

Commenter
Name:
Dean
Urmston
Commenter
Organization
Name:
American
Seed
Trade
Association,
Inc.
Comment
Number:
30509­
118000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm.
is
a
significant
pest
problem
in
the
United
States.
If
approved,
this
new
biotech
rootworm.
product
would
be
a
much
needed,
environmentally
friendly
tool
that
growers
could
use.
Soil
insecticide
applications
for
corn
rootworm.
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.
Adoption
of
biotech
corn
rootworm
protected
corn
will
help
growers
reduce
overall
insecticide
use.

In
addition,
biotech
corn
rootworm.
corn
would
provide
growers
with
simplicity
and
convenience.
Because
of
this
product's
in­
seed
protection,
growers
have
the
convenience
of
greatly
reducing
the
handling
of
corn
rootworm
insecticides.
This
provides
an
ideal
fit
with
current
integrated
pest
management
(
IPM)
programs.

Finally,
biotech
corn
rootworm.
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
insecticides
that
may
have
more
variable
performance
due
to
varying
growing
conditions.
Growers
are
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
that
void.

Commenter
Name:
Doran
Zumbach
Commenter
Organization
Name:
Doran
Zumbach
Comment
Number:
30509­
120000
Excerpt
Number:
1
Excerpt
Text:
The
reason
for
my
letter
to
you
today
is
to
personally
issue
my
support
for
the
registration
of
corn
rootworm,
protected
corn.
This
would
allow
me
to
grow
corn
in
a
more
environmentally
kind
manor.
I
would
be
able
to
discontinue
the
use
of
the
organophosphates
insecticide
that
I
must
use
to
control
the
corn
rootworm.
I
am
sure
that
it
would
give
me
more
complete
and
more
reliable
control
of
this
pest.
It
would
also
rid
my
family
and
myself
to
the
possibility
of
exposure
to
this
insecticide.
In
addition
to
these
advantages
it
helps
me
to
assure
a
safe
abundant
food
supply.

Commenter
Name:
Tom
Haywood
Commenter
Organization
Name:
State
of
Texas
Senate
Comment
Number:
30509­
L01
Excerpt
Number:
2
Excerpt
Text:
Section
5.1
Section
5
­
26
As
you
know,
corn
rootworm
can
cause
severe
yield
loss
if
left
untreated.
Yield
loss
typically
ranges
from
8
to
16
percent,
and
can
be
as
high
as
55
percent
including
increased
harvest
costs
from
lodging.
Chemical
insecticides
registered
for
corn
rootworm
control
were
applied
in
Texas
alone
on
some
732,000
acres
of
corn
in
2000.
It
is
important
to
retain
our
market
edge
by
having
the
ability
to
choose
some
new
types
of
technologies.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn,
Co.
Comment
Number:
30509B­
020000
Excerpt
Number:
1
Excerpt
Text:
I
support
the
registration
of
corn
rootworm
protected
corn.
This
new
biotechnology
is
1)
better
for
the
environment
because
of
reduced
insecticide
use
by
the
American
farmer,
2)
simple
to
use
because
of
reduced
handling
and
farmer
exposure
to
insecticides,
3)
gives
effective
and
consistent
control
of
corn
rootworm.
pests,
and
4)
fits
with
current
IPM
procdures.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn,
Co.
Comment
Number:
30509B­
020000
Excerpt
Number:
3
Excerpt
Text:
Insecticides
are
giving
less
effective
control
of
corn
rootworms
in
central
Illinois.
Farmers
are
using
more
insecticides
and
spraying
more
often
to
control
this
pest.
I
saw
in
2001
a
farmer
field
that
did
not
pollinate
well
because
the
rootworm
beetle
pressure
was
so
great,
and
he
sprayed
four
times
in
one
week
to
control
the
rootworm
beetles
during
pollination.
I
recommended
the
spraying.
The
plots
that
I
have
seen
with
the
new
corn
rootworm,
protected
corn
technology
have
all
shown
much
better
insect
control
than
adjacent
plants
treated
with
insecticides.
This
new
technology
helps
everybody,
the
American
farmer,
the
environment,
and
the
consumer.

Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509B­
022000
Excerpt
Number:
2
Excerpt
Text:
In
the
past
we
have
used
various
soil
applied
insecticides
for
control
of
corn
rootworm
but
the
efficacy
of
these
products,
plus
the
danger
to
handlers
and
the
environment,
has
led
to
a
reduction
in
their
use.
Now
we
are
spraying
the
adult
rootworm.
beetles
in
efforts
to
control
the
population
of
larva
in
the
next
season.
This
is
effective,
but
costly,
and
requires
up
to
two
aerial
applications
of
insecticide.

Corn
root
worm
protected
corn
would
allow
us
to
handle
and
apply
less
insecticide.
It
would
be
more
cost
effective
and
would
provide
better
control
of
the
target
pest.
It
would
be
safer
for
me,
my
employees,
and
my
crop
consultant.

Commenter
Name:
Jeff
Sernett
Section
5.1
Section
5
­
27
Commenter
Organization
Name:
Jeff
Sernett
Comment
Number:
30509B­
025000
Excerpt
Number:
5
Excerpt
Text:
Some
of
the
benefits
of
corn
rootworm
protected
corn
include
maximum,
consistent
protection
because
the
corn
protects
itself
via
protein
generation
from
the
insect.
Secondly,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.
The
use
of
fewer
chemicals
is
also
likely
a
health
benefit
to
farmers,
consumers
and
the
environment.

Commenter
Name:
Eric
Sachs
Commenter
Organization
Name:
Eric
Sachs
Comment
Number:
30509B­
027002
Excerpt
Number:
1
Excerpt
Text:
Research
shows
that
YieldGard
Rootworm
(
YG
RW)
will
offer
significant
benefits
to
corn
growers
and
society,
including
more
convenient
corn
rootworm
management,
more
consistent
control
of
the
corn
rootworm,
reduced
human
and
environmental
exposure
to
insecticides
and
less
overall
environmental
impact.

Commenter
Name:
Eric
Sachs
Commenter
Organization
Name:
Eric
Sachs
Comment
Number:
30509B­
027002
Excerpt
Number:
2
Excerpt
Text:
Although
farmers
currently
use
insecticides
and
crop
rotation
to
manage
this
pest,
corn
rootworms
have
developed
resistance
to
these
practices
and
they
are
becoming
increasingly
less
effective
as
resistance
spreads.
The
new
corn
rootworm
protected
corn
product
will
provide
an
alternative
control
option
for
farmers
that
will
augment
the
existing
pest
management
programs
and
consequently
slow
the
spread
of
resistance.
This
is
a
integrated
pest
management
that
is
supported
by
this
new
corn
rootworm
foundational
principle
in
protection
technology
developed
through
biotechnology.

Commenter
Name:
Martina
Newell
Commenter
Organization
Name:
UC
­
Systemwide
Biotechnology
Research
and
Education
Program
Comment
Number:
30509B­
030006
Excerpt
Number:
3
Excerpt
Text:
From
an
efficacy
point
of
view,
since
the
insecticidal
protein
is
expressed
in
the
roots
throughout
the
growing
season,
rootworm
protected
corn
has
the
potential
to
provide
more
consistent
control
and
lessen
the
possibility
of
failure
that
may
occur
with
chemical
insecticides.

Commenter
Name:
Bill
Thorne
Commenter
Organization
Name:
Bill
Thorne
Comment
Number:
30509B­
030011
Excerpt
Number:
2
Section
5.1
Section
5
­
28
Excerpt
Text:
Corn
rootworm­
protected
corn
will
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
chemical
insecticides,
helping
to
reduce
the
possibility
of
failure
that
sometimes
occurs
with
soil
insecticides.

Commenter
Name:
Kevin
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509B­
038000
Excerpt
Number:
1
Excerpt
Text:
Because
of
the
technology's
in­
seed
protection,
handling
corn
rootworm
insecticides
at
planting
is
not
necessary.
This
technology
would
eliminate
myself
from
having
to
handle
the
insecticides.
This
would
decrease
the
need
for
storage,
transportation,
and
disposal
of
chemical
insecticides.

Commenter
Name:
Kevin
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509B­
038000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
protected
corn
expresses
a
naturally
occurring
Bt
protein
the
roots
throughout
the
growing
season
which
helps
reduce
the
possibility
of
failures
that
sometimes
occurs
with
soil
insecticides.
By
planting
in
early
April,
the
insecticides
have
the
tendency
to
get
washed
through
the
soil
with
heavy
rains
that
occur
in
the.
spring.
Currently,
insecticides
only
last
for
60
days;
thus,
conflicts
with
the
corn
rootworm
hatch
in
June,
resulting
in
failure
by
the
insecticide.

Commenter
Name:
Joan
O'Brien
Commenter
Organization
Name:
Iowa
Seed
Association
Comment
Number:
30509B­
043000
Excerpt
Number:
4
Excerpt
Text:
Some
of
the
benefits
of
corn
rootworm
protected
corn
include
maximum,
consistent
protection
because
the
corn
protects
itself
automatically
from
the
insect.
Secondly,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.

Commenter
Name:
Brad
Paschen
Commenter
Organization
Name:
Brad
Paschen
Comment
Number:
30509B­
044000
Excerpt
Number:
3
Excerpt
Text:
Rootworm
protected
corn
provides
more
consistent
control
of
this
damaging
pest
than
insecticides.

Commenter
Name:
Robert
Wensink
Commenter
Organization
Name:
Wensink
Farm
Seeds,
Inc.
Comment
Number:
30509B­
045000
Section
5.1
Section
5
­
29
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
protective
technology
will
provide
more
consistent
control
than
insecticides
in
protecting
plants
from
the
destructive
rootworm
pest.
Soil
insecticides
can
leach
from
the
protective
root
zone,
whereas
the
rootworm
protective
technology
expresses
a
naturally
occurring
Bt
protein
in
the
plants
roots
throughout
the
growing
season.

Commenter
Name:
Douglas
Tallamy
Commenter
Organization
Name:
University
of
Delaware
Comment
Number:
30509B­
053000
Excerpt
Number:
3
Excerpt
Text:
We
must
not
lose
sight
of
the
proper
control
in
arguments
for
and
against
genetically
modified
products.
We
should
not
compare
such
products
to
no
control
measures
but
rather
to
the
chemical
insecticide
which
these
products
will
replace.
I
have
not
heard
anyone
claim
that
genetically
modified
products
pose
a
threat
of
any
consequence
when
compared
to
the
continued
long­
term
use
of
chemical
insecticides.
Preventing
the
evolution
of
resistance
to
Bt
corn
lines
is
a
top
priority
for
Monsanto
and
researchers
across
the
country,
but
the
continued
reliance
on
chemical
insecticides
does
not
alleviate
this
concern.
In
fact,
rootworm
resistance
to
chemical
insecticides
is
already
a
problem
in
several
areas
of
the
upper
Midwest.

Genetically
modified
products
offer
the
potential
to
combat
agricultural
pests
in
new,
more
efficient,
more
effective,
and
safer
ways
than
past
practices.
To
not
fully
explore
the
use
of
these
products
would
be
to
stymie
the
greatest
advance
in
pest
management
in
half
a
century.

Commenter
Name:
Dennis
Ward
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509B­
086000
Excerpt
Number:
10
Excerpt
Text:
Scientific
Background:
MON
863
does
not
confer
a
high
dose
against
CRW.
However,
university
field
trials
have
established
that
MON
863
provides
superior
efficacy
and
consistency
under
a
variety
of
environmental
conditions
compared
with
all
other
control
tactics
available
to
growers.
This
superior
pest
protection
has
the
potential
to
significantly
reduce
the
use
of
insecticides
to
control
losses
from
corn
rootworm
and
reduce
human
and
animal
insecticide
exposure
on
the
farm
and
in
the
agroecosystem.

Commenter
Name:
Connie
McDevitt
Commenter
Organization
Name:
Connie
McDevitt
Comment
Number:
30509B­
092001
Excerpt
Number:
1
Excerpt
Text:
Please
allow
farmers
to
choose
to
grow
their
crops
with
the
best
technology
possible.
The
science
behind
biotech
traits
such
as
Roundup
Ready,
Bt
crops,
and
corn
rootworm
protected
crops
is
proven
through
rigourous
yield
and
efficacy
testing
under
the
scrutiny
of
the
USDA
and
EPA.
Section
5.1
Section
5
­
30
Commenter
Name:
Dan
Heavner
Commenter
Organization
Name:
Dan
Heavner
Comment
Number:
30509B­
092004
Excerpt
Number:
2
Excerpt
Text:
Adoption
of
this
technology
would
give
farmers
another
very
beneficial
tool
in
corn
production.
Helping
growers
protect
against
a
pest
that
is
very
detrimental
to
their
current
crop
yields.

Commenter
Name:
Kathy
Klepfer
Commenter
Organization
Name:
Kathy
Klepfer
Comment
Number:
30509B­
092009
Excerpt
Number:
1
Excerpt
Text:
This
is
an
important
technology
that
will
be
beneficial
to
farmers
while
being
environmentally
safe.
This
is
the
type
of
technology
that
we
need
in
this
country.
When
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides.

Commenter
Name:
Robert
Nichols
Commenter
Organization
Name:
Robert
Nichols
Comment
Number:
30509B­
092023
Excerpt
Number:
1
Excerpt
Text:
As
a
science
writer
I
urge
you
to
support
the
safe
and
well­
researched
new
technologies,
such
as
corn
improved
using
biotechnology,
to
protect
against
pests.
Such
technologies
are
very
efficient
way
to
produce
food
that
is
both
safe
important.
Such
technologies
offer
a
better
more
for
people
and
better
for
the
environment
Commenter
Name:
Lee
Stromberg
Commenter
Organization
Name:
Lee
Stromberg
Comment
Number:
30509B­
092040
Excerpt
Number:
1
Excerpt
Text:
I
support
the
approval
of
bioengineered
crops
in
general,
and
this
specific
corn
rootworm
protected
corn
New
technologies
will
enable
American
farmers
to
remain
at
the
forefront
of
world
agriculture.
They
have
the
ability
to
reduce
insecticide
use,
increase
or
preserve
yields,
and
offer
improved
health
benefits.

Commenter
Name:
Dennis
Avery
Commenter
Organization
Name:
Dennis
Avery
Comment
Number:
30509B­
092044
Excerpt
Number:
1
Excerpt
Text:
The
world
must
triple
its
yields
on
the
land
we
currently
farm
over
the
next
40
years,
to
supply
high­
quality
diets
for
a
larger,
more
affluent
population­­
and
their
pets.
Without
higher
yields,
we
will
destroy
Section
5.1
Section
5
­
31
wildlands
to
grow
the
crops.
We
probably
cannot
achieve
a
tripling
of
yields
without
biotechnology
in
agriculture.
We
should
regulate
biotechnology
carefully,
because
it
is
powerful,
but
we
should
also
keep
in
mind
the
urgency
of
the
conservation
mission.
I
hope
you
will
approve
the
new
variety
of
corn
which
contains
a
pesticide
to
protect
it
against
corn
rootworm
with
all
deliberate
speed.

Commenter
Name:
Chris
DiFonzo
Commenter
Organization
Name:
Michigan
State
University
Comment
Number:
30809B­
028000
Excerpt
Number:
1
Excerpt
Text:
For
the
last
several
years,
I
have
monitored
plots
of
the
Cry
3Bb
corn
rootworm­
protected
corn
in
Michigan.
In
my
experience,
this
technology
performed
as
well
against
corn
rootworm
as
the
common
conventional
soil
insecticides
used
by
corn
growers
in
the
state
­
Aztec­
Counter,
Force,
and
Lorsban.

EPA
Response:
The
Agency
agrees
with
these
commenters
that
MON
863
will
provide
sufficient
efficacy
against
corn
rootworm
to
potentially
replace
the
use
of
chemical
pesticides.
In
comparative
efficacy
studies,
MON
863
was
as
effective
or
more
effective
than
registered
conventional
insecticides
(
terbufos,
tefluthrin,
and
chlorpyrifos)
in
protecting
corn
roots
from
rootworm
feeding
damage.
In
almost
all
trials,
rootworm
damage
to
MON
863
was
kept
below
the
economic
threshold
for
pesticide
treatment.
The
Agency's
complete
assessment
of
MON
863
efficacy
can
be
found
in
Chapter
E
(
section
5)
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document.

Commenter
Name:
Charles
Benbrook
Commenter
Organization
Name:
Union
of
Concerned
Scientists
Comment
Number:
30509­
115000
Excerpt
Number:
12
Excerpt
Text:
6.
Efficacy
Data
Are
Skewed;
Key
Question
Is
Raised
The
submission
includes
a
summary
of
efficacy
trials
carried
out
in
seven
locations
(
Volume
1).
Plants
were
mechanically
infested
at
the
V2
growth
stage
with
1,200
to
1,600
eggs
per
square
foot.
Before
the
plants
were
dug
up
to
inspect
roots
for
damage,
ELISA
kits
were
used
in
the
field
to
identify
any
plants
not
expressing
the
Cry
3Bb
endotoxin.
According
to
the
submission,
"
negative
plants
were
removed"
(
Volume
1,
page
56).

Removing
plants
not
expressing
the
Cry
3Bb
endotoxin
in
an
efficacy
trial
of
MON
863
engineered
corn
would
seem
to
undermine
the
basic
purpose
of
the
study.
At
a
minimum,
Monsanto
should
have
reported
the
number
of
plants
not
expressing
the
Cry
3Bb
protein,
as
well
as
the
percent
of
plants
not
expressing
the
endotoxin.
If
the
percent
of
plants
not
expressing
the
Cry
3Bb
endotoxin
is
in
fact
above
the
normal
rate
at
which
corn
hybrids
fail
to
express
a
specified
trait,
Monsanto
should
have
offered
some
explanation
of
why,
since
non­
expression
will
have
significant
implications
for
product
performance
and
in
the
design
of
resistance
management
plans.

EPA
Response:
Section
5.1
Section
5
­
32
The
Agency
disagrees
with
this
commenter's
contention
that
the
efficacy
data
for
MON
863
have
been
skewed
by
the
methodology
of
the
study.
The
use
of
artificial
infestations
and
the
elimination
of
nonexpressing
plants
are
common
practices
in
controlled
field
experiments
to
evaluate
the
efficacy
of
transgenic
crops.
The
Agency
understands
that
in
salable
transgenic
seed
sold
to
growers,
the
percentage
of
"
off­
types"
(
non­
expressing
plants)
is
very
low
and
would
be
extremely
unlikely
to
adversely
affect
efficacy
in
the
field.
The
Agency's
complete
assessment
of
MON
863
efficacy
can
be
found
in
Chapter
E
(
section
5)
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
47
Excerpt
Text:
MON
863
Efficacy
Is
Comparable
to
Widely
Used
Insecticides.

The
relatively
low
dose
delivered
by
MON
863
explains
the
large
difference
observed
in
the
efficacy
of
Cry
3Bb
corn
compared
to
the
efficacy
of
MON
810
corn
engineered
to
control
the
ECB.
While
the
ECB
is
a
less
damaging
insect
than
corn
rootworms,
some
20
percent
of
corn
acreage
has
been
planted
to
ECB
Bt
varieties
since
1999
(
Fernandez­
Cornejo
et
al.,
2000;
Benbrook,
2001).
Nearly
all
field
data
confirm
a
high
level
of
efficacy.
Between
95
percent
and
100
percent
control
of
ECBs
is
routinely
achieved
(
EPA,
2001);
optimally
timed
and
properly
applied
insecticides,
on
the
other
hand,
achieve
only
about
75
percent
ECB
control
and
in
many
cases,
substantially
less.
But
the
ECB
does
not
reach
damaging
levels
in
most
years
in
much
of
the
Corn
Belt
and
hence
the
added
expense
of
Bt­
ECB
corn
varieties
does
not
pay
off
for
many
farmers,
despite
its
potential
to
be
effective
(
Hyde
et
al.,
1999;
Duffy,
2000).
For
these
reasons,
the
investment
in
higher­
priced
Bt
corn
for
ECB
has
been
largely
an
economic
wash
for
farmers
collectively
(
Benbrook,
2002).

Monsanto
corn
rootworm
survival
trials
in
2000
show
that
17
to
62
percent
of
the
corn
rootworm
larvae
feeding
on
MON
863
corn
survive
(
Vaughn
et
al.,
2001,
page
23).
This
explains
the
fact
that
in
2000
efficacy
trials,
there
were
on
average
"
visible
feeding
scars"
on
roots
at
the
seven
locations
where
root
damage
was
sampled
using
Protocol
1
(
manual
infestation
with
800
CRW
larvae
eggs
per
foot
of
row
space).

A
one­
to­
six
scale
is
used
to
rate
corn
rootworm
root
feeding
damage
and
is
based
on
research
done
at
Iowa
State
University
(
cited
in
Pilcher,
2001).
A
"
Root
Damage
Rating"
(
RDR)
is
assigned
as
follows:

1
=
No
feeding
scars
2
=
Visible
scars,
but
no
roots
pruned
to
within
4
cm
of
the
stalk
3
=
One
or
more
roots
pruned
to
within
4
cm
of
the
stalk
4
=
One
node's
worth
of
pruned
roots
Section
5.1
Section
5
­
33
5
=
Two
nodes'
worth
of
pruned
roots
6
=
Three
or
more
nodes'
worth
of
pruned
roots.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
48
Excerpt
Text:
The
economic
threshold
for
treatment
is
generally
set
at
a
RDR
of
3.
In
200
efficacy
trials
under
Protocol
1,
MON
863
performed
slightly
better
than
terbufos.
Mean
RDRs
across
seven
locations
for
the
three
insecticide
standards
were
2.26,
2.4
and
2.4,
compared
to
a
MON
863
RDR
of
2.02.
The
control
RDR
was
3.91.
The
differences
observed
between
MON
863
and
the
three
insecticide
standards
were
not
significantly
different
from
each
other
at
p
less
then/
equal
to
0.05
(
Pilcher,
2001).

The
Monsanto
efficacy
trials
also
show
that
insecticide
standards
frequently
outperform
MON
863
­
something
that
has
never
been
observed
with
Bt
corn
for
ECB
control.
Three
protocols
were
tested
in
each
of
seven
locations
in
2000.
Two
of
the
protocols
allow
comparison
of
MON
863
performance
to
each
of
three
insecticide
standards
in
seven
locations,
or
a
total
of
42
comparisons
(
two
times
three
times
seven).
The
third
protocol
involved
just
one
insecticide,
and
hence
7
more
comparisons,
for
a
grand
total
of
49
direct
comparisons
of
MON
863
to
an
insecticide
standard.
In
12
of
these
49
cases,
the
best
insecticide
performed
equal
to
or
better
than
MON
863
in
a
given
location
(
24
percent
of
the
cases).
In
all
three
protocols,
each
insecticide
standard,
on
average
reduced
corn
rootworm
feeding
damage
to
or
below
a
RDR
of
2.4,
well
below
the
economic
threshold
of
level
of
3.
Most
differences
between
average
MON
863
and
insecticide
RDRs
were
not
statistically
significant.

Further
insights
on
efficacy
emerge
from
the
one
ecological
impacts
field
trial
reported
to
date
(
Bhatti
et
al.,
2001).
Table
8
in
this
study
compares
the
impacts
of
MON
863
corn
to
a
soil
insecticide
standard
(
Force,
applied
in
furrow).
Mean
abundance
data
are
reported
for
two
corn
rootworm
species
(
Diabrotica
barberi
and
Diabrotica
virgifera)
and
show
that
with
no
insecticide,
there
was
a
mean
abundance
of
4.3
in
the
MON
863
plots
versus
6.8
in
the
control
(
RX670)
plots.
Curiously
though,
in
the
in­
furrow
soil
insecticide
plots
planted
to
MON
863
corn,
mean
abundance
of
corn
rootworms
increased.
In
the
case
of
Diabrotica
barberi
in
the
insecticide
treated
MON
863
plots,
the
mean
abundance
was
5.5,
compared
to
4.8
in
the
control
plot
(
not
MON
863
corn)
treated
with
the
same
insecticide.

EPA
Response:
The
Agency
generally
agrees
with
this
commenter's
assessment
of
the
efficacy
of
MON
863.
As
the
commenter
indicates,
the
efficacy
of
MON
863
is
comparable
to
slightly
better
than
conventional
insecticides
registered
for
control
of
corn
rootworm.
However,
the
Agency
disagrees
with
the
statement
that
"
insecticide
standards
frequently
outperform
MON
863."
Although
the
efficacy
trials
did
not
show
statistical
significance,
the
average
root
damage
ratings
(
RDR)
for
MON
863
were
less
than
the
conventional
pesticides
tested
in
all
of
the
trials.
The
commenter
noted
that
the
chemical
insecticides
scored
better
in
only
24%
of
the
observations,
meaning
that
76%
of
the
time
MON
863
scored
as
well
or
outperformed
the
tested
pesticides.
MON
863
corn
also
offers
advantages
in
other
areas
that
contribute
to
Section
5.1
Section
5
­
34
efficacy.
For
example,
the
Cry3Bb
protein
is
expressed
throughout
the
growing
season
and
is
not
subject
to
the
environmental
factors
that
may
degrade
the
potency
of
conventional
pesticides.

The
commenter
noted
that
another
registered
Bt
corn
hybrid,
MON
810
has
much
greater
efficacy
against
its
target
pest
(
European
corn
borer)
relative
to
MON
863.
However,
a
direct
comparison
between
the
two
hybrids
is
not
valid
because
they
are
targeted
against
different
insect
orders
(
Lepidoptera
vs.
Coleoptera)
that
feed
on
different
parts
of
the
plant.
Also,
the
high
survival
of
rootworm
noted
on
MON
863
is
not
necessarily
indicative
of
efficacy,
as
the
performance
trials
summarized
above
and
in
the
comment
have
demonstrated.

The
fact
that
MON
863
efficacy
is
comparable
to
conventional
insecticides
indicates
the
hybrid
should
serve
well
as
an
alternative
control
measure
for
rootworm.
That
the
performance
of
MON
863
is
not
(
statistically)
significantly
better
than
insecticides
does
not
diminish
its
value
to
growers
with
rootworm
infestations.
Indeed,
the
efficacy
trials
cited
in
the
comment
showed
that
MON
863
kept
rootworm
feeding
damage
below
economic
thresholds
in
almost
all
of
the
observations.

The
Agency's
complete
assessment
of
MON
863
efficacy
can
be
found
in
Chapter
E
(
section
5)
of
the
Event
MON
863
Bt
Cry3Bb1
Corn
Biopesticides
Registration
Action
Document.
Section
5.2
Section
5
­
35
5.2
­
Decreased
Pesticide
Use
5.2
­
Comment
Excerpts
Commenter
Name:
Frank
Kohn
Commenter
Organization
Name:
Frank
Kohn
Comment
Number:
30506­
064001
Excerpt
Number:
1
Excerpt
Text:
Today's
farmers
continually
face
increasing
challenges
in
improving
their
time
and
operational
efficiency.
Biotech
corn
rootworm
corn
would
provide
growers
with
simplicity
and
convenience.
Because
of
this
product's
in­
seed
protection,
growers
have
the
convenience
of
greatly
reducing
the
handling
time
and
hassles
of
dealing­
with
corn
rootworm
insecticides.

Commenter
Name:
Richard
Lohnes
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Co.
Comment
Number:
30509­
017000
Excerpt
Number:
1
Excerpt
Text:
Rootworm
protected
corn
means
that
my
fellow
corn
growers
and
me
will
not
have
to
handle
and
be
exposed
to
chemical
products
that
we
need
to
control
corn
rootworms.
This
is
a
big
deal
to
me.
I
do
not
want
myself,
my
employees
or
my
collogues
to
be
exposed
to
harmful
chemicals,
and
the
products
that
can
kill
insects
can
also
make
us
sick.
I
am
for
any
system
that
promotes
good
stewardship
of
resources
and
reduces
human
exposure
to
harmful
chemicals.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Company
Comment
Number:
30509­
018000
Excerpt
Number:
2
Excerpt
Text:
This
new
technology
would
be
safer
for
the
environment
and
me
because
I
would
reduce
the
application
of
the
35,000lbs
of
insecticide
I
am
putting
on
the
soil
this
year.
Earthworms
and
other
soil
life
would
benefit.
I
worry
all
the
time
about
our
sandy
irrigated
fields.
Our
water
table
and
supply
for
drinking
water
under
the
sandy
soils
would
not
become
so
contaminated
with
reduced
insecticide
applications.
I
would
be
personally
healthier
because
of
reduced
application
exposure.
I
try
to
maximize
my
protection
when
handling
these
insecticides
but
I
still
have
the
insecticides
on
my
skin.
A
corn
rootworm
insecticide
known
as
Force
will
burn
when
it
touches
my
skin.
In
a
field
at
planting
time,
wipe
some
sweat
off
my
brow,
scratch
a
facial
itch,
rub
an
eye,
and
I
am
immediately
told
by
the
burning
sensation
that
I
have
an
insecticide
on
my
face.
The
corn
rootworm
protected
corn
is
derived
from
a
Bacillus
thuringiensis
protein.
It
is
specific
for
the
insect
it
kills
while
not
affecting
beneficial
insects,
birds,
fish,
livestock,
or
humans.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn
Company
Comment
Number:
30509­
018000
Section
5.2
Section
5
­
36
Excerpt
Number:
4
Excerpt
Text:
I
support
this
new
technology
because
it
reduces
the
usage
of
insecticides,
thereby
reducing
the
farmer,
his
family,
and
the
human
races
exposure
to
insecticides,
makes
for
a
better
environment
for
other
living
things,
and
has
a
better
efficacy
than
existing
products
for
corn
rootworms.
I
urge
the
EPA
to
support
this
new
technology
for
me
and
my
seed
corn
customers.

Commenter
Name:
Tom
Hunsley
Commenter
Organization
Name:
Growmark,
Inc.
Comment
Number:
30509­
023000
Excerpt
Number:
2
Excerpt
Text:
­
It
will
greatly
reduce
the
amount
of
insecticides
being
introduced
into
the
environment.

Commenter
Name:
Harold
Cooper
Commenter
Organization
Name:
Premier
AG
Co­
Op,
Inc.
Comment
Number:
30509­
024000
Excerpt
Number:
1
Excerpt
Text:
Our
environment
would
benefit
from
having
no
manmade
chemicals
added
directly
or
indirectly
to
our
soil
and
water
through
leaching
or
runoff.
A
second
benefactor
of
Rootworm
Protected­
corn
is
the
health
of
those
physically
handling
Corn
Rootworm.
insecticides.
I've
experienced
the
ill
effects
(
headaches
and
dizziness)
from
handling
these
insecticides.

Commenter
Name:
David
Mertens
Commenter
Organization
Name:
David
Mertens
Comment
Number:
30509­
025000
Excerpt
Number:
1
Excerpt
Text:
Corn
Rootworm
protected
corn
will
not
significantly
reduce
the
insecticide
use
on
these
corn
acres.
There
are
alternative
treatments
present
we
are
using
which
not
only
control
the
Corn
Rootworm
but
also
a
host
of
secondary
pests.

Commenter
Name:
David
Good
Commenter
Organization
Name:
David
Good
Comment
Number:
30509­
026000
Excerpt
Number:
1
Excerpt
Text:
I
want
you
to
know
that
I
strongly
support
the
registration
of
corn
root­
worm
protected
hybrid
corn.
I
believe
that
any
time
you
can
replace
a
poison
insecticide
with
genetic
protection
right
in
the
plant
it
is
only
sensible
to
do
it.

In
the
seed
corn
industry
we
plant
test
plots
to
prove
various
things
such
as
yield
differences
between
hybrids
etc.
Changing
the
corn
in
planter
boxes
after
planting
each
pass
puts
a
person
in
close
proximity
to
Section
5.2
Section
5
­
37
the
insecticide
and
the
poisonous
fumes
it
puts
off.
I
got
extremely
sick
from
breathing
those
fumes
several
times
during
my
employment
as
a
district
sales
manager
for
various
seed
companies
over
the
course
of
my
career.
This
danger
could
be
eliminated
with
this
technology!

Commenter
Name:
John
Love
Commenter
Organization
Name:
John
Love
Comment
Number:
30509­
027004
Excerpt
Number:
1
Excerpt
Text:
I
feel
that
the
risk
of
pesticide
exposure
would
be
reduced
significantly
since
growers
would
no
longer
have
to
handle
rootwork
insecticide
at
planting
if
they
chose
resistant
corn
hybrids.
This
is
a
concern
that
most
producers
have,
and
the
choice
to
not
handle
insecticides
would
be
a
easy
one
for
most
of
them
to
make.
Currently
there
are
few
options
other
than
to
handle
insecticides
at
planting
time.
The
resistance
product
gives
them
much
needed
flexibility
to
at
is
good
not
only
for
their
farms,
but
their
families
as
insecticides
is
their
exposure
is
greatly
reduced.

Commenter
Name:
Kelly
Montgomery
Commenter
Organization
Name:
Kelly
Montgomery
Comment
Number:
30509­
027006
Excerpt
Number:
2
Excerpt
Text:
The
advent
of
this
technology
would
allow
for
control
of
rootworm
by
through
the
seed
(
plants)
and
thus
reduce
the
need
for
soil­
applied
insecticides.
Reducing
insecticide
use
for
control
of
rootworms
will
be
beneficial
to
the
environment
and
will
allow
growers
to
reduce
their
physical
exposure
to
insecticides.

Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509­
028000
Excerpt
Number:
1
Excerpt
Text:
I
support
the
registration
of
corn
rootworm
protected
corn.
We
currently
treat
every
acre
of
continuous
corn
(
80%
of
total
acres)
with
some
type
of
insecticide
to
control
corn
rootworm.
If
corn
rootworm
protected
corn
is
as
effective
in
controlling
corn
rootworm
as
Bt
corn
has
been
in
controlling
corn
borers
I
will
be
able
to
eliminate
this
insecticide
treatment
entirely.

Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509­
028000
Excerpt
Number:
2
Excerpt
Text:
By
eliminating
this
treatment
I
can
realize
three
major
benefits.

1.
Less
insecticide
use
in
the
environment.
Section
5.2
Section
5
­
38
2.
Less
exposure
to
insecticides
for
myself
and
my
employees.
3.
More
profit
in
my
farming
operation.

Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509­
028000
Excerpt
Number:
3
Excerpt
Text:
With
the
use
of
Bt
corn
borer
protected
corn
we
eliminated
at
least
one
chemical
treatment
each
year
and
sometimes
two.
I
am
convinced
that
if
we
are
provided
a
stacked
Bt
product
for
both
corn
borers
and
corn
rootworms,
that
many
years,
I
will
not
need
to
apply
an
insecticide
treatment
at
all.
This
is
my
goal.

Commenter
Name:
Harry
Brokish
Commenter
Organization
Name:
AgReliant
Genetics
Comment
Number:
30509­
029000
Excerpt
Number:
3
Excerpt
Text:
The
use
of
corn
rootworm
protected
corn
is
very
beneficial
to
the
American
farmer.
It
would
give
them
the
necessary
crop
protection
against
the
corn
rootworm
and
avoid
the
need
to
handle
insecticides.
Additionally,
there
would
not
be
the
problem
of
disposal
of
the
insecticide
containers.

Commenter
Name:
Alex
Avery
Commenter
Organization
Name:
Alex
Avery
Comment
Number:
30509­
030002
Excerpt
Number:
1
Excerpt
Text:
Bt
crops
are
safer
for
wildlife
such
as
monarch
butterflies
and
because
they
reduce
the
use
of
broadspectrum
insecticides
and
allow
for
higher
productivity,
they
are
considerably
more
"
eco­
friendly"
than
conventional
or
organic
crops.
They
should
be
reviewed
and
approved
if
no
significant
and
credible
health
or
environmental
safety
issues
are
forseen.

Commenter
Name:
Jerry
Courson
Commenter
Organization
Name:
Jerry
Courson
Comment
Number:
30509­
033000
Excerpt
Number:
1
Excerpt
Text:
Because
of
technology's
in­
seed
protection
that
provides
corn
rootworm
control,
growers
have
the
option
of
not
handling
and
applying
these
insecticides
at
planting.
This
decreases
the
need
for
storage,
transportation
and
disposal
of
chemical
insecticides
and
their
containers.
By
reducing
insecticide
handling,
corn
rootworm
protected
corn
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families,
also
reducing
the
environmental
concern
of
pesticide
runoff
into
our
watersheds
and
ground
water
contamination.

Commenter
Name:
Chris
Shires
Section
5.2
Section
5
­
39
Commenter
Organization
Name:
Chris
Shires
Comment
Number:
30509­
034000
Excerpt
Number:
2
Excerpt
Text:
Insecticide
use
and
potential
environmental
contamination
from
their
use
can
be
greatly
reduced
with
the
adoption
of
this­
technology.
Reduction
in
the
use
of
insecticides
for
the
control
of
corn
rootworm
decreases
farmers,
their
families
and
employees
as
well
as
the
general
public
from
exposure
to
dangerous
organophosphate
pesticides.
These
insecticides
have
a
past
record
of
inconsistent
performance
and
crop
injury.
Corn
rootworm
protected
corn
has
the
potential
to
provide
more
consistent
control,
to
reduce
the
unpredictability
of
performance
due
to
varying
growing
conditions,
and
give
farmers
another
safe
alternative
to
current
insecticides
on
today's
market.

Commenter
Name:
William
Pickart
Commenter
Organization
Name:
Fairacre
Farms,
Inc.
Comment
Number:
30509­
037000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworms
have
been
a
proven
significant
agronomic
problem
for
us,
and
we
have
been
certified
as
private
pesticide
applicators
in
order
to
apply
pesticides
to
control
rootworms
in
our
cornfields.
These
pesticides
are
not
only
costly,
but
present
a
risk
of
exposure,
even
with
our
care
and
training.

The
biotech
rootworm
product
provides
in­
seed
protection
from
rootworms,
which
is
an
ideal
fit
for
integrated
pest
management
systems
(
IPM.)
We
will
not
be
transporting
and
handling
rootworm
pesticides,
and
we
will
not
be
applying
pesticides
as
a
preventative
measure,
as
is
currently
the
practice
where
an
uncertainty
exists
as
to
the
infestation
in
first­
year
corn.

Also,
EPA
is
considering
removing
certain
effective
pesticides
currently
approved
for
corn
rootworms.
Biotech
corn
rootworm
control
would
take
the
place
of
those
pesticides,
and
eliminate
any
possible
pesticide
exposure
risk
It
would
offer
an
environmentally
friendly
tool
for
rootworm
control.

Commenter
Name:
Ed
Sand
Commenter
Organization
Name:
Ed
Sand
Comment
Number:
30509­
038000
Excerpt
Number:
1
Excerpt
Text:
I
personally
support
the
registration
of
corn
rootworm
protected
corn
because
any
time
we
can
eliminate
insecticides
applied
to
the
soil
or
sprayed
on
a
crop,
we
can
reduce
exposure
on
land,
crops
and
farmer
producers.

Because
of
the
technologies
in
seed
protection,
growers
have
the
convenience
of
not
handling
corn
rootworm
insecticides
at
planting
time.

Insecticides
are
not
always
compatible
to
farm
operators,
but
were
up
to
this
point
necessary
for
crop
production
and
profitability.
My
brother
was
hospitalized
one
time
from
an
allergic
reaction
to
a
corn
Section
5.2
Section
5
­
40
rootworm
insecticide.
He
has
since
given
up
farming,
but
had
this
technology
been
available,
would
have
saved
him
from
tremendous
discomfort.

Commenter
Name:
Dean
Heffta
Commenter
Organization
Name:
Dean
Heffta
Comment
Number:
30509­
039000
Excerpt
Number:
2
Excerpt
Text:
By
reducing
insecticide
handling,
corn
rootworm
protected
corn
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families.
The
toxicity
of
the
insecticides
currently
used
is
a
concern
for
everyone
involved
in
their
handling
and
use.
I
personally
have
concerns
for
the
deleterious
affects
these
insecticides
may
impose
on
the
people
and
the
environment
exposed
to
them.
However,
the
economics
and
agronomics
involved
in
farming
often
warrant
their
use.

Commenter
Name:
Doug
Wilson
Commenter
Organization
Name:
Doug
Wilson
Comment
Number:
30509­
040002
Excerpt
Number:
1
Excerpt
Text:
Soil
intake
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
U.
S.
This
would
greatly
reduce
overall
insecticide
use.

Growers
are
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
that
need.

Commenter
Name:
Tony
McCormick
Commenter
Organization
Name:
Tony
McCormick
Comment
Number:
30509­
040005
Excerpt
Number:
1
Excerpt
Text:
I'm
writing
this
letter
in
support
for
registration
of
the
new
biotech
corn
rootworm
product
that
the
EPA
is
currently
reviewing.
I
would
like
to
see
this
product
in
production.
I
feel
it
would
help
cut
my
exposure
to
harmful
chemical
insecticides.
I
think
this
biotech
root
product
would
also
cut
down
on
chemical
run­
off
into
our
lakes
and
streams,
protecting
others
from
possible
exposure
to
insecticides.

Commenter
Name:
Tom
Burrur
Commenter
Organization
Name:
Tom
Burrur
Comment
Number:
30509­
040006
Excerpt
Number:
2
Excerpt
Text:
The
biotech
control
of
corn
rootworms
will
allow
me
as
well
as
growers
across
the
world
to
reduce
insecticide
exposure.

This
will
provide
an
ideal
fix
for
integrated
pest
management
programs
(
IPM).
Section
5.2
Section
5
­
41
We
know
it
is
likely
that
insecticides
are
going
to
be
lost
in
the
years
ahead
as
regulatory
pressure
will
continue
to
heighten.

Commenter
Name:
Roger
Fricke
Commenter
Organization
Name:
Roger
Fricke
Comment
Number:
30509­
040008
Excerpt
Number:
1
Excerpt
Text:
I
am
writing
this
letter
to
express
my
concern
of
the
hazards
of
using
soil
insecticides
versus
biotech
corn
technology
for
the
control
of
corn
rootworm
in
corn.

Working
for
a
seed
corn
company
mean
handling
and
using
various
insecticides
in
the
spring
of
the
year.
Some
are
toxic
and
extremely
hazardous
to
handle.
Skin
irritation,
eye
problem
and
appetite
problem
occur
frequently.

Biotech
corn
enhancement
is
the
answer
to
elimination
of
these
problems.

Commenter
Name:
Mike
Walker
Commenter
Organization
Name:
Burrus
Seed
Company
Comment
Number:
30509­
040010
Excerpt
Number:
1
Excerpt
Text:
My
name
is
Mike
Walker.
I
am
the
spray
operator
for
Burrus
Seed
Company.
By
supporting
this
I
will
have
to
handle
less
chemicals.

Commenter
Name:
Paul
Mueller
Commenter
Organization
Name:
Paul
Mueller
Comment
Number:
30509­
040011
Excerpt
Number:
1
Excerpt
Text:
I
am
writing
in
regards
to
the
registration
of
the
new
corn
rootworm
product.
I
like
the
idea
of
not
having
to
use
soil
applied
insecticides.
This
would
reduce
exposure
to
the
user
and
be
better
for
the
environment
and
non­
target
organisms.
There
would
be
no
danger
of
run­
off
into
rivers
and
streams.
Even
though
I
support
the
registration
of
the
new
corn
rootworm
product,
I
also
believe
it
should
be
cleared
for
market
everywhere
before
it
is
available
to
growers.

Commenter
Name:
Greg
Schone
Commenter
Organization
Name:
Greg
Schone
Comment
Number:
30509­
040014
Excerpt
Number:
1
Excerpt
Text:
I
would
like
to
give
my
support
for
the
registration
of
new
biotech
rootworm
product
that
the
EPA
is
currently
reviewing.
The
biotech
control
of
corn
rootworm
would
allow
growers
to
reduce
insecticide
exposure
on
their
farms.
This
provides
a
more
consistent
control
of
an
increasing
problem.
With
the
risk
Section
5.2
Section
5
­
42
of
losing
insecticide
choices,
this
would
be
an
acceptable
choice!

Commenter
Name:
Mark
A.
Parks
Commenter
Organization
Name:
Burrus
Seed
Farms
Comment
Number:
30509­
040015
Excerpt
Number:
2
Excerpt
Text:
As
planting
time
is
close
at
hand,
this
is
what
time
of
year
where
the
most
exposure
to
insecticides
for
rootworm
control
is
the
most.
Planting
time
is
also
the
most
possible
time
for
water
contamination
from
any
pesticide.
If
this
can
be
reduced
or
eliminated
the
better
off
everybody
will
be.

Commenter
Name:
Don
Rhoade
Commenter
Organization
Name:
Don
Rhoade
Comment
Number:
30509­
040016
Excerpt
Number:
1
Excerpt
Text:
If
approved,
this
new
technology
will
greatly
reduce
the
amount
of
pesticides
placed
in
the
environment
each
year.
This
new
technology
will
be
user
friendly
and
will
match
the
current
integrated
pest
management
programs.

With
the
current
AG
industry
struggling
economically,
a
new
insecticide
choice
is
a
welcome
addition
to
the
insecticide
arena.

Commenter
Name:
Todd
Burrus
Commenter
Organization
Name:
Todd
Burrus
Comment
Number:
30509­
040017
Excerpt
Number:
1
Excerpt
Text:
The
big
asset
is
less
organophosphate
chemicals
being
applied
to
soil
and
less
exposure
to
us
farmers.
This
would
help
give
us
an
environmentally
safe
alternative.

Commenter
Name:
Todd
Sieben
Commenter
Organization
Name:
Illinois
State
Senate
Comment
Number:
30509­
046000
Excerpt
Number:
1
Excerpt
Text:
Currently
the
number
one
use
of
insecticides
in
the
Unites
States
is
soil
insecticide
applications
for
corn
rootworm
control.
By
using
corn
rootworm
protected
corn
it
will
help
growers
reduce
the
overall
use
of
insecticides.
This
will
allow­
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families.

With
the
technology
of
in­
seed
protection,
growers
do
not
have
to
handle
corn
rootworm
insecticides
when
planting.
When
growers
do
not
have
to
use
insecticides
at
planting
it
decreases
the
need
for
storage,
transportation
and
disposal
of
the
chemical
and
the
containers
in
which
they
come
in.
The
time
and
Section
5.2
Section
5
­
43
expenses
that
are
spent
with
application,
equipment
upkeep
and
calibration
is
also
decreased
with
the
use
of
corn
rootworm
protected
corn.
Corn
rootworm
protected
corn
also
provides
an
ideal
fit
with
the
current
integrated
pest
management
(
IPM)
programs.

Commenter
Name:
Julie
Trisler
Commenter
Organization
Name:
Trisler
Seed
Farms,
Inc.
Comment
Number:
30509­
047000
Excerpt
Number:
2
Excerpt
Text:
The
benefits
of
registering
corn
rootworm
protected
corn
are
numerous.
Because
the
technology
is
in­
seed
protection
we
can
stop
handling
insecticide
which
will
greatly
reduce
the
exposure
the
farmer
has
when
he
has
to
handle
granular
insecticide.
This
also
decreases
the
need
for
storage,
transportation,
and
disposal
of
chemical
insecticides.

Commenter
Name:
Mike
Schau
Commenter
Organization
Name:
Wyffels
Hybrids,
Inc.
Comment
Number:
30509­
048000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
protected
corn
should
greatly
reduce
insecticide
use
for
corn
rootworm
control
on
our
corn
grower's
farms
because
protected
corn
has
the
ability
to
withstand
rootworm
infestations.
By
reducing
insecticide
handling,
corn
rootworm,
protected
corn
will
allow
our
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families.
Currently
our
corn
growers
manage
the
corn
rootworm
pest
through
the
use
of
pesticides.

Commenter
Name:
Michelle
Wood
Commenter
Organization
Name:
Michelle
Wood
Comment
Number:
30509­
051000
Excerpt
Number:
2
Excerpt
Text:
In
addition,
this
technology
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms
and
around
their
families.

Commenter
Name:
Marilyn
Bartelt
Commenter
Organization
Name:
Marilyn
Bartelt
Comment
Number:
30509­
052000
Excerpt
Number:
2
Excerpt
Text:
I
would
like
to
have
access
to
the
corn
rootworm
biotech
product
for
two
main
reasons:

1.
If
allowed
to
use
this
biotech
product
on
our
farm,
we
would
be
able
to
significantly
decrease
the
amount
of
insecticides
we
currently
use
to
fight
the
corn
rootworm
pest.

2.
This
biotech
product
would
be
a
much
safer
option
for
my
family
to
allow
us
to
continue
protecting
our
Section
5.2
Section
5
­
44
corn
crop
against
the
costly
pest.

Commenter
Name:
Marilyn
Bartelt
Commenter
Organization
Name:
Marilyn
Bartelt
Comment
Number:
30509­
052000
Excerpt
Number:
3
Excerpt
Text:
Not
only
would
reduced
insecticide
usage
be
better
for
the
environment,
having
a
biotech
option
for
corn
rootworm
control
will
also
allow
my
husband,
sons
and
I
to
reduce
or
eliminate
our
exposure
to
the
harmful
insecticides
that
we
currently
have
to
use.

Commenter
Name:
Arthur
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509­
053000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
arguably
the
most
damaging
pest
to
corn.
Previously,
in
our
region
of
the
eastern
Corn
Belt,
growers
could
control
corn
rootworm
by
means
of
crop
rotation.
With
the
spread
of
a
variant
of
the
western
corn
rootworm,
crop
rotation
is
no
longer
effective.
As
I
expect
you
are
aware,
this
has
forced
a
vast
number
of
corn
growers
to
apply
rootworm
insecticides
on
all
of
their
acres
going
to
corn
rather
than
just
on
continuous
corn
acres.
Hence,
insecticide
use
in
the
eastern
Corn
Belt
has
greatly
increased.

While
rootworm
insecticide
products
are
safe
when
handled
correctly
and
carefully,
growers
would
gladly
switch
to
a
safer
product
if
it
were
available.
I
believe
corn
rootworm
protected
corn
would
be
safer
to
the
grower
and
safe
to
tile
environment.

Commenter
Name:
Arthur
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509­
053000
Excerpt
Number:
4
Excerpt
Text:
Additionally,
control
of
this
pest
with
rootworm
protected
corn
is
much
easier,
convenient
and
less
time
consuming
than
with
insecticides.
The
elimination
for
the
need
of
insecticide
boxes
when
purchasing
a
planter
would
be
a
cost
savings
to
farmers
that
have
suffered
long
term
financial
stress
from
low
grain
prices.
Not
having
to
deal
with
those
bags
of
insecticides
during
the
planting
operation
would.
be
a
freedom
to
farmers.
Just
ask
a
corn
grower.

Commenter
Name:
Thomas
Nickson
Commenter
Organization
Name:
Thomas
Nickson
Comment
Number:
30509­
056000
Excerpt
Number:
1
Excerpt
Text:
Currently
in
the
US,
more
insecticide
is
applied
to
corn
to
control
the
corn
rootworm
pest
than
any
other
pest.
The
data
collected
to
date
strongly
indicate
that
growers
will
reduce
the
amount
of
pesticide
applied
Section
5.2
Section
5
­
45
to
control
this
insect
once
this
product
is
approved.
Furthermore,
there
is
no
data
to
suggest
that
the
risks
associated
with
this
product
exceed
those
currently
present
with
the
practices
in
use.
In
fact,
there
is
evidence
to
suggest
that
the
risks
will
be
less.
This
product
has
the
potential
to
reduce
grower
exposure
to
certain
insecticides
as
well
as
provide
effective
and
specific
control
of
a
major
pest.

Commenter
Name:
Phillip
Sloderbeck
Commenter
Organization
Name:
Phillip
Sloderbeck
Comment
Number:
30509­
056000
Excerpt
Number:
4
Excerpt
Text:
The
registration
of
corn
rootworm
protected
corn
would
give
growers
another
option
to
add
to
their
corn
rootworm
management
plans
and
reduce
the
reliance
on
the
various
insecticides.
This
would
greatly
reduce
the
pounds
of
insecticides
used
on
corn
in
the
area.
It
would
be
very
helpful
on
early
planted
corn
where
soil
insecticides
really
don't
last
long
enough
to
provide
full
protection
from
heavy
rootworm
pressure.
In
addition
its
use
in
conjunction
with
corn
borer
resistant
hybrids
would
greatly
reduce
the
need
for
insecticide
application
later
in
the
season,
which
could
be
very
beneficial
in
reducing
spider
mite
management
problems.

Commenter
Name:
Rodger
Mansfield
Commenter
Organization
Name:
Rodger
Mansfield
Comment
Number:
30509­
060000
Excerpt
Number:
2
Excerpt
Text:
Soil
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States,
and
adoption
of
biotech
corn
rootworm
protected
corn
will
help
growers
reduce
overall
insecticide
use.
This
biotech
control
of
corn
rootworm
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms.

In
addition,
biotech
corn
rootworm
corn
would
provide
growers
with
simplicity
and
convenience.
Because
of
this
product's
in­
seed
protection,
growers
have
the
convenience
of
greatly
reducing
the
handling
of
corn
rootworm
insecticides.
This
provides
an
ideal
fit
with
current
integrated
pest
management
(
IPM)
programs.

Commenter
Name:
Roger
Youngman
Commenter
Organization
Name:
Virginia
Tech
University
Comment
Number:
30509­
061000
Excerpt
Number:
4
Excerpt
Text:
Make
no
mistake,
I
do
not
expect
rootworm­
protected
Bt
corn
by
itself
to
solve
the
corn
rootworm
problem
in
Virginia
or
elsewhere.
However,
the
incorporation
of
this
new
technology
into
existing
corn
rootworm
pest
management
programs
should
greatly
help
growers
reduce
their
reliance
on
indiscriminate
use
of
conventional
soil
insecticides
at
planting.
This
approach
is
both
good
for
the
environment
as
well
as
for
growers
who
must
deal
with
corn
rootworms
every
time
they
plant
corn.

Commenter
Name:
Doug
Boisen
Section
5.2
Section
5
­
46
Commenter
Organization
Name:
Nebraska
Corn
Development,
Utilization
and
Marketing
Board
Comment
Number:
30509­
062000
Excerpt
Number:
2
Excerpt
Text:
Soil
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States,
and
adoption
of
biotech
corn
rootworm
protected
corn
would
help
growers
reduce
overall
insecticide
use.

Commenter
Name:
Scott
Merritt
Commenter
Organization
Name:
Nebraska
Corn
Growers
Association
Comment
Number:
30509­
063000
Excerpt
Number:
1
Excerpt
Text:
On
behalf
of
the
Nebraska
Corn
Growers
Association,
we
would
like
to
extend
our
support.
of
the
review
by
your
agency
of
corn
rootworm
protected
corn.

NeCGA
supports
the
science­
based
review
by
EPA
and
the
other
federal
agencies
to
insure
the
safe
implementation
of
biotech
products.

Commenter
Name:
Scott
Merritt
Commenter
Organization
Name:
Nebraska
Corn
Growers
Association
Comment
Number:
30509­
063000
Excerpt
Number:
2
Excerpt
Text:
Nebraska
producers
have
a
strong
interest
in
advances
in
rootworm
protection
technology.
Nebraska
has
a
long
history
of
corn
rootworm
pressure
that
has
caused
financial
hardship
and
consistent
management
challenges.
The
opportunity
to
address
this
problem
with
new
tools
that
are
non­
chemical
insecticide
provide
options
that
may
be
effective
and
more
environmentally
friendly.
Nebraska's
leading
insecticide
use
is
to
control
corn
rootworm,
thus
any
reduction
would
provide
benefits
to
our
state.

Corn
producers
are
faced
with
the
reduction
of
options,
such
as
organophosphates,
and
are
hopeful
the
new
technology
is
available.

We
request
that
EPA
move
forward
in
the
approval
process
of
GE
corn
rootworm.

Commenter
Name:
Marlin
Edwards
Commenter
Organization
Name:
Marlin
Edwards
Comment
Number:
30509­
064000
Excerpt
Number:
1
Excerpt
Text:
I'm
aware
that
corn
rootworm
insecticides
are
a
large
percentage
of
the
total
agricultural
insecticide
application
market.
These
insecticides
are
a
much
greater
acute
and
chronic
risk
to
consumers
and
to
the
environment
than
are
the
Bt
proteins
used
in
the
biotech
corn
rootworm
product.
It
is
important
for
us
to
Section
5.2
Section
5
­
47
demonstrate
the
courage
and
leadership
required
to
improve
the
way
we
produce
food,
despite
pressures
by
those
who
appear
to
prefer
to
resist
change
rather
than
evaluating
the
risks
and
benefits
provided
by
the
real
alternatives
we
have
available
to
us
in
agriculture.

The
Bt­
based
control
of
corn
rootworm
will
be
safer
in
application
than
the
chemical
alternatives,
will
provide
a
very
effective
contribution
to
pest
control,
will
be
better
for
the
environment
and,
in
this
manner,
will
be
a
better
alternative
for
the
general
public,
even
if
this
is
unappreciated
by
some.

Commenter
Name:
Deb
Krotz
Commenter
Organization
Name:
Deb
Krotz
Comment
Number:
30509­
064012
Excerpt
Number:
2
Excerpt
Text:
Planting­
time
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States,
and
adoption
of
biotech
corn
rootworm
protected
corn
will
help
growers
reduce
overall
insecticide
use.
This
biotech
control
of
corn
rootworm
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms.
The
impact
granular
insecticides
have
on
wildlife
and
avain
populations
has
been
identified
as
high
risk
by
the
EPA,
this
is
your
chance
to
do
something
about
it.

Commenter
Name:
John
Haugen
Commenter
Organization
Name:
John
Haugen
Comment
Number:
30509­
064035
Excerpt
Number:
1
Excerpt
Text:
It
is
imperative
that
this
scientific
advance,
which
helps
reduce
the
necessary
amount
and
toxicity
of
pesticides,
be
approved
for
use
on
America's
farms.
It
is
shear
irresponsibility
to
allow
the
current
level
of
pesticide
spraying
to
continue
when
safe
alternative
methods
are
available.

Commenter
Name:
Glenn
Skinner
Commenter
Organization
Name:
Wyffels
Hybrids,
Inc.
Comment
Number:
30509­
065000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
protected
corn
will
reduce
the
amount
of
insecticides
applied
at
planting.
This
will
result
in
less
exposure
by
the
farmers
who
plant
it,
and
less
broad
spectrum
insecticides
being
applied
to
the
soil,
which
can
negatively
affect
non­
target
organisms.

Commenter
Name:
Kevin
Glenn
Commenter
Organization
Name:
Kevin
Glenn
Comment
Number:
30509­
066003
Excerpt
Number:
1
Excerpt
Text:
This
biotech
control
of
corn
rootworm
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms,
thereby
improving
our
environment
and
also
their
work
conditions
by
greatly
reducing
the
handling
of
corn
Section
5.2
Section
5
­
48
rootworm
insecticides
­
also
not
a
small
benefit
of
the
biotech
corn
rootworm
product.

Commenter
Name:
Kevin
Glenn
Commenter
Organization
Name:
Kevin
Glenn
Comment
Number:
30509­
066003
Excerpt
Number:
2
Excerpt
Text:
In
addition,
the
environment
benefits
by
lower
levels
of
manufacture
of
the
insecticides
currently
required
for
effective
control
of
the
corn
rootworm
pest.

Commenter
Name:
Michael
Rogers
Commenter
Organization
Name:
Michael
Rogers
Comment
Number:
30509­
066013
Excerpt
Number:
1
Excerpt
Text:
This
product
will
result
in
decrease
use
of
organophosphonate
insecticides
and
will
thus
be
very
beneficial
to
the
environment.
It
will
also
improve
safety
and
health
for
both
farm
workers
and
consumers.

Commenter
Name:
Matthew
Kraus
Commenter
Organization
Name:
Matthew
Kraus
Comment
Number:
30509­
066022
Excerpt
Number:
2
Excerpt
Text:
We
should
not
let
another
season
pass
in
this
unique
opportunity
to
reduce
corn
rootworm
insecticides
while
increasing
farmer
safety
and
agricultural
productivity!

Thank
you
for
your
consideration
in
helping
move
this
important
corn
rootworm
technology
forward.

Commenter
Name:
H.
E.
Navarrete
Commenter
Organization
Name:
H.
E.
Navarrete
Comment
Number:
30509­
068004
Excerpt
Number:
1
Excerpt
Text:
This
technology
is
an
environmentally
friendly
tool,
that
should
be
an
option
in
the
farmers'
arsenal
to
help
increase
yields
while
using
less
insecticides.

Commenter
Name:
Dennis
Clavin
Commenter
Organization
Name:
Pennsylvania
State
University
Comment
Number:
30509­
069000
Excerpt
Number:
2
Excerpt
Text:
Soil
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
Pennsylvania,
and
adoption
of
biotech
corn
rootworm
protected
corn
will
help
growers
reduce
overall
Section
5.2
Section
5
­
49
insecticide
use.
This
biotech
control
of
corn
rootworm
will
allow
growers
to
reduce
insecticide
exposure
on
their
farms.

In
Pennsylvania,
approximately
40%
of
the
1.5
million
acres
of
field
corn
is
treated
to
protect
against
the
complex
of
northern
and
western
corn
rootworm.
This
represents
approximately
588,000
pounds
of
active
ingredients
applied
each
year
to
the
state's
corn
crop.
If
transgenic
corn
captures
80%
of
this
market,
then
about
470,400
lb.
fewer
soil
insecticides
will
be
applied
each
year.
This
is
quite
a
significant
reduction
of
insecticides
that
have
the
potential
to
contaminate
both
ground
and
surface
water
resources.
Much
of
the
state's
prime
agricultural
land
is
drained
into
the
Chesapeake
Bay.

Commenter
Name:
Joe
Merschman
Commenter
Organization
Name:
Merschman
Seeds,
Inc.
Comment
Number:
30509­
072000
Excerpt
Number:
1
Excerpt
Text:
I
am
writing
this
letter
in
support
of
the
registration
of
corn
root
worm
protected
corn.
This
technology
is
very
important
to
the
American
farmer
and
our
environment
by
eliminating
toxic
pesticides
farmers
use
to
control
root
worms.

Commenter
Name:
Joe
Merschman
Commenter
Organization
Name:
Merschman
Seeds,
Inc.
Comment
Number:
30509­
072000
Excerpt
Number:
2
Excerpt
Text:
I
am
aware
of
farmers
who
have
literally
been
hospitalized
because
of
handling
corn
root
worm
insecticides.
In
the
spring
it
is
usually
windy
and
it
is
almost
impossible
to
handle
root
worm
insecticide
without
coming
in
contact
with
the
dust.
Corn
root
worm
protected
corn
would
totally
eliminate
this
risk
to
farmers
and
their
families.

Commenter
Name:
Brad
Biddick
Commenter
Organization
Name:
Brad
Biddick
Comment
Number:
30509­
073000
Excerpt
Number:
3
Excerpt
Text:
Personally,
to
reduce
the
use
of
corn
rootworm
pesticides
would
be
a
good
thing
for
the
grower
and
the
soil..
My
employees
are
involved
here,
too.
We
grow
corn
for
seed,
but
we
still
grow
corn
and
that
means
using
a
corn
rootworm
pesticide
or
go
out
of
business.
It
is
that.
stark.
It
certainly
is
not
the
choice
of
every
corn
grower
to
buy
and
apply
pesticides
on
corn
acres.
New
technology
is
adding
insecticides
directly
to
the
seed,
but
it
is
still
an
insecticide.
Isn't
it
simply
smart
to
use
every
means
at
your
disposal
to
assure
your
success,
your
livelihood,
your
food
supply?
With
your
responsibility
of
protecting
the
environment,
you
should
be
so
lucky
to
have
this
marvelous
tool
come
along
and
allow
us
to
wean
ourselves
away
from
the
status
quo
of
pesticides.
You
really
can
protect
the
parties
involved.
Section
5.2
Section
5
­
50
Commenter
Name:
M
Stanton
Commenter
Organization
Name:
M
Stanton
Comment
Number:
30509­
076001
Excerpt
Number:
1
Excerpt
Text:
The
replacement
of
chemical
soil
insecticide
applications
by
bio­
engineered
products
provides
safer,
more
specific
control
of
insects.

Commenter
Name:
M
Stanton
Commenter
Organization
Name:
M
Stanton
Comment
Number:
30509­
076001
Excerpt
Number:
2
Excerpt
Text:
As
in
case
of
cotton,
the
corn/
corn
rootworm
combination
currently
has
high
levels
of
insecticide
use
and,
thus,
approval
of
this
product
is
likely
to
give
significant
benefit
by
reducing
the
use
of
these
insecticides.
Farm
workers
and
their
families
will
have
less
exposure
to
chemicals
and
the
general
public
will
benefit
by
having
more
environmentally
friendly
methods
of
farming.

Commenter
Name:
Dan
Spearman
Commenter
Organization
Name:
Dan
Spearman
Comment
Number:
30509­
076002
Excerpt
Number:
1
Excerpt
Text:
Replacement
of
soil
insecticides
applications
with
a
biotechnology
rootworm
corn
would
be
a
substantial
improvement
for
farmers
and
the
environment
and
the
continuing
of
technology
advancement
that
benefits
all
of
us
globally.
This
would
allow
American
farmers
to
reduce,
if
not
eliminate
the
use
of
organophosphates
and
carbamates
as
a
means
of
protecting
their
corn
crop
from
the
damaging
corn
rootworm
pest.
This
is
an
obvious
positive
to
the
American
farmer
through
reduced
exposure
and
to
the
environment
by
potentially
improved
water
quality
and
a
better
habitat
for
birds
and
other
wildlife.
Biotechnology
rootworm
protected
corn
would
also
be
specific
in
its
target­
only
corn
rootworm.
Soil
insecticides
are
not
nearly
that
specific
in
their
control
activity.

Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
7
Excerpt
Text:
­
Clearly,
CRW
corn
reduces
these
greatest
concerns.
For
the
top
two
evaluated:
exposure
of
other
family
members
to
insecticides
and
exposure
to
the
insecticide
when
filling
insecticide
boxes,
the
percent
of
respondents
claiming
they
are
extremely
concerned
dropped
from
,76%
and
72%
to
44%
and
43%,
respectively.
These
concerns
may
be
further
reduced
as
growers
become
more
educated
regarding
CRW
corn
safety.

Commenter
Name:
Jared
Bruckhart
Section
5.2
Section
5
­
51
Commenter
Organization
Name:
Chemgro
Seeds
Comment
Number:
30509­
081000
Excerpt
Number:
1
Excerpt
Text:
I
personally
support
the
registration
of
corn
rootworm
protected
corn
because
of
the
reduced
amount
of
insecticides
that
will
be
needed.
This
technology
will
also
provide
the
effectiveness
that
is
needed,
without
the
farmer
having
to
personally
handle
the
product.

Commenter
Name:
Jared
Bruckhart
Commenter
Organization
Name:
Chemgro
Seeds
Comment
Number:
30509­
081000
Excerpt
Number:
2
Excerpt
Text:
User
safety
is
a
huge
benefit
of
corn
rootworm
protected
corn
hybrids.
As
it
is
now,
a
farmer
must
apply
the
insecticide
to
control
corn
rootworm
through
his
corn
planter.
This
method
leaves
it
open
for
him,
his
employees,
or
family
to
be
exposed
by
skin
contact,
or
breathing
the
dust
when
filling
the
planter.

Commenter
Name:
Robert
Osgood
Commenter
Organization
Name:
Robert
Osgood
Comment
Number:
30509­
082006
Excerpt
Number:
1
Excerpt
Text:
Biotechnology
is
clearly
the
most
environmentally
sensitive
solution
to
the
corn
root
worm
problem.
To
deny
the
application
for
approval
would
go
against
EPA
policy
on
pesticide
use
reduction.
A
decision
to
approve
the
new
technology
would
benefit
the
environment
owing
to
­
he
reduction
in
pesticide
use.

Commenter
Name:
Lance
Santo
Commenter
Organization
Name:
Lance
Santo
Comment
Number:
30509­
082009
Excerpt
Number:
1
Excerpt
Text:
This
new
biotech
rootworm
product
advantages
are:

1.
Environmentally
friendly
tool
that
growers
could
use
safely.

2.
Reduce
insecticides
usage
and
minimize
impact
on
the
environment.
Soil­
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.

3.
Minimize
insecticide
exposure
(
due
to
handling,
application
and
possible
drift
of
insecticides)
to
workers
and
community.

4.
Works
well
with
integrated
pest
management
(
IPM)
programs.

5.
Less
or
no
adverse
effects
on
beneficial
insects.
Section
5.2
Section
5
­
52
6.
Provides
more
consistent
control
of
the
corn
rootworm
than
insecticides
that
may
have
more
variable
performance
due
to
varying
soil
and
weather
conditions.

7.
Provides
a
non­
chemical
alternative
to
control
an
economically
damaging
pest.

Commenter
Name:
Darrell
Nelson
Commenter
Organization
Name:
University
of
Nebraska,
Lincoln
Comment
Number:
30509­
083000
Excerpt
Number:
2
Excerpt
Text:
We
believe
that
registration
of
corn
rootworm
protected
corn
should
be
approved
by
USEPA
because
the
use
of
hybrids
with
this
trait
will
significantly
reduce
the
amount
of
pesticides
used
in
corn
production.
Currently,
corn
rootworm
insecticides
are
the
largest
use
for
insecticides
in
the
United
States.
A
large
reduction
in
insecticide
use
will
directly
result
in
less
exposure
of
farmers
and
farm
workers
to
insecticides
and
will
reduce
the
possibility
for
a
degradation
of
the
environment
by
insecticides.
The
corn
rootworm
protected
corn
will
be
a
welcome
addition
to
the
technologies
that
are
currently
a
Dart
of
the
Integrated
Pest
Management
used
in
Nebraska
corn
fields.

Commenter
Name:
Joe
Haines
Commenter
Organization
Name:
Ohio
Deparment
of
Agriculture
Comment
Number:
30509­
084000
Excerpt
Number:
1
Excerpt
Text:
The
Ohio
Department
of
Agriculture
believes
in
using
the
best
technology
available
in
crop
protection
materials.
Ohio
producers
need
the
best
tools
available
to
deal
with
insects
and
pests
which
pose
a
threat
to
crop
success
through
yield
reduction.

The
corn
rootworm
is
a
pest
which
has
the
ability
to­
reduce
corn
yield
in
Ohio
and
has
been
traditionally
dealt
with
by
the
use
of
soil
insecticides.
Keeping
in
mind
that
the
Ohio
Department
of
Agriculture
is
firmly
behind
providing
the
safest
possible
food
supply,
I
believe
it
is
important
to
continue
the
pursuit
of
alternative
methods
for
crop
protection,
which
will
reduce
the
total
volume
of
pesticides
placed
into,
crop
production
annually.

Commenter
Name:
Joe
Haines
Commenter
Organization
Name:
Ohio
Deparment
of
Agriculture
Comment
Number:
30509­
084000
Excerpt
Number:
2
Excerpt
Text:
We
stand
behind
the
good
faith
efforts
which
are
intended
to
benefit
crop
producers
and
consumers.
As
long
as
biotechnology
provides
adequate
protection
of
crops
and
offers
a
safe
product
to
consumers,
we
want
to
support
this
effort.

Commenter
Name:
Merlyn
Carlson
Commenter
Organization
Name:
State
of
Nebraska
­
Department
of
Agriculture
Section
5.2
Section
5
­
53
Comment
Number:
30509­
086000
Excerpt
Number:
2
Excerpt
Text:
In
order
to
manage
this
pest
efficiently,
growers
throughout
Nebraska
use
insecticides
and
crop
rotation.
Recent
surveys
indicate
that
3.4
million
acres
of
Nebraska
farmland
were
treated
with
13
different
insecticides
for
corn
rootworm
control,
including
such
products
as
methyl
parathion.
Insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.

Corn
rootworm
protected
corn
will
provide
corn
growers,
the
environment,
and
consumers,
with
a
number
of
advantages
if
it
is
approved
for
use
in
the
United
States
and
in
foreign
markets.

­
First,
corn
receives
maximum,
more
consistent,
protection
because
the
plant
automatically
protects
itself
from
the
insect.

­
Second,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.
This
is
important
because
regulatory
pressures
mean
many
farmers
are
at
risk
of
losing
some
insecticide
choices
(
i.
e.,
organophosphates
and
carbamates)
and
are
in
need
of
effective
alternatives
to
fill
the
void.
The
use
of
less
chemicals
is
also
a
health
benefit
to
consumers
and
the
environment.

­
Third,
with
reduced
insecticide
use,
corn
growers
and
their
families
have
less
risk
of
insecticide
exposure.

Commenter
Name:
Lynn
McDonald
Commenter
Organization
Name:
Triumph
Seed
Company
Comment
Number:
30509­
094000
Excerpt
Number:
2
Excerpt
Text:
Within
our
market
territory
the
corn
rootworm
is
constantly
a
problem
demanding
­
the
application
of
an
insecticide
for
control
and
adequate
crop
stand
establishment.
The
use
of
a
genetically
protected
corn
seedling
would
dramatically
reduce
or
eliminate
the
need.
for
insecticide,
thereby
assisting
in
establishing
a
cleaner
environment
as
well
as
reducing
potential
hazards
to
farm
workers
who
use
the
chemicals.

Commenter
Name:
David
Swinford
Commenter
Organization
Name:
Texas
House
of
Representatives
Comment
Number:
30509­
095000
Excerpt
Number:
4
Excerpt
Text:
­
Growers
are
at
risk
of
losing
insecticide
choices
(
i.
e.,
organophosphates
and
carbamates)
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
the
Void.

Commenter
Name:
Robert
Wensink
Commenter
Organization
Name:
Robert
Wensink
Comment
Number:
30509­
098000
Excerpt
Number:
1
Section
5.2
Section
5
­
54
Excerpt
Text:
Currently,
farmers
attempt
to
control
corn
rootworm
pest
by
applying
insecticides
on
their
corn
fields.

We
enthusiastic
support
the
registration
of
corn
rootworm­
protected
corn
because
the
product
will
substantially
reduce
insecticide
use
on
field
corn.
The
reduced
application
of
rootworm
insecticides
will
lessen
chemical
exposures
to
growers,
farm
families,
and
rural
communities.
In
addition,
the
reduced
application
of
insecticides
will
also
decrease
the
probability
of
surface
and
ground
water
contamination
to
our
environment.

Commenter
Name:
Roy
Johnson
Commenter
Organization
Name:
Garst
Seed
Company
Comment
Number:
30509­
099000
Excerpt
Number:
2
Excerpt
Text:
Soil
insecticides
for
corn
rootworm
control
are
currently
the
number
one
use
of
insecticides
in
the
United
States.
I
do
not
know
how
many
million
pounds
of
insecticide
are
actually
used
annually,
but
I
an
certain
it
is
substantial.
While
insecticides
are
the
best
current
method
of
controlling
this
pest,
I
would
like
to
see
an
effective
and
safer
alternative
like
corn
rootworm
protected
technology.

I
can
recall
from
nearly
30
years
ago
walking
corn
fields
as
an
FFA
student
in
high
school
and
observing
millions
of
dead
earthworms
in
a
"
band"
over
corn
rows
from
use
of
corn
insecticides
(
Furadan,
I
believe
was
the
product).
While
this
was
a
concern,
it
was
better
than
the
alternative
of
corn
rootworm
damaged
plants
later
in
the
season.
However,
this
image
has
stayed
with
me
for
many
years.

An
alternative
like
corn
rootworm
transgenic
technology
appears
to
provide
more
consistent
control
of
corn
rootworm
larvae
and
does
not
have
the
non­
target
damage
insecticides
pose.
This
fact,
plus
more
importantly,
that
it
is
safer
for
the
grower,
are
very
tangible
benefits.

Commenter
Name:
Max
Wenck
Commenter
Organization
Name:
Max
Wenck
Comment
Number:
30509­
107000
Excerpt
Number:
2
Excerpt
Text:
Our
family
has
farming
operations
in
Wisconsin
and
South
Dakota.
Currently,
we
have
to
use
insecticides
to
control
corn
rootworm.
These
insecticides
are
dangerous
to
work
with,
no
matter
how
careful
you
try
to
be
with
handling.

Commenter
Name:
Max
Wenck
Commenter
Organization
Name:
Max
Wenck
Comment
Number:
30509­
107000
Excerpt
Number:
3
Excerpt
Text:
Please
consider
these
two
points.
Section
5.2
Section
5
­
55
First,
if
U.
S.
farmers
could
plant
biotech
corn
that
was
resistant
to
corn
rootworm
they
could
potentially
get
more
consistent
pest
control,
significantly
reduce
soil
insecticide
use
and
eliminate
grower
handling
and
exposure.

Second,
I
think
informed
consumers
are
supportive
of
this
technology
too.
A
study
of
consumers
conducted
in
1999
by
the
American
Farm
Bureau
Federation
and
Philip
Morris
found
that
73
percent
of
consumers,
when
asked
about
alternatives
to
the
uses
of
farm
chemicals
said
they
would
be
willing
to
accept
biotechnology
to
develop
crops
that
require
fewer
pesticides.

Commenter
Name:
Lisa
Watson
Commenter
Organization
Name:
Lisa
Watson
Comment
Number:
30509­
108000
Excerpt
Number:
1
Excerpt
Text:
I
would
like
to
express
support
for
new
technologies
such
as
corn
protected
from
corn
rootworm,
a
product
currently
under
review
by
EPA.

We
must
constantly
strive
to
develop
safe,
new
technologies
that
will
allow
our
farmers
to
produce
food
with
fewer
inputs
and
external
resources.
The
corn
rootworm
technology
appears
to
offer
such
an
opportunity.

While
the
safety
of
various
applied
insecticides
is
a
hotly
debated
issue,
few
growers
or
consumers
would
disagree
that
reducing
exposure
is
a
move
in
the
right
direction.

Commenter
Name:
David
Stark
Commenter
Organization
Name:
David
Stark
Comment
Number:
30509­
108007
Excerpt
Number:
1
Excerpt
Text:
While
most
of
this
is
a
form
letter,
I
want
to
add
that
I
feel
very
strongly
about
the
safety
and
benefits
of
biotechnology.
I
live
2
miles
from
the
Missouri
River,
and
about
18
from
the
Mississippi.
These
rivers
carry
a
lot
of
runoff
from
farms
across
the
middle
portion
of
the
US.
it
would
be
great
if
someday
the
water
would
actually
be
clear
instead
of
muddy
brown.
Biotechnology
can
help
reduce
the
pesticide
levels
in
these
rivers
and
the
soil
run­
off
from
farms.
This
undoubtedly
will
help
these
rivers
become
cleaner
and
safer.

Commenter
Name:
Bruce
Hammond
Commenter
Organization
Name:
Monsanto
Comment
Number:
30509­
108008
Excerpt
Number:
2
Excerpt
Text:
This
technology
also
provides
an
alternative
to
insecticide
use
which
will
provide
the
farmer
greater
options
in
the
management
of
his
corn
crop.

Commenter
Name:
Kelly
Hasbargen
Section
5.2
Section
5
­
56
Commenter
Organization
Name:
Seeds
2000,
Inc.
Comment
Number:
30509­
110000
Excerpt
Number:
2
Excerpt
Text:
Many
of
our
customers
in
the
southern
regions
of
our
trade
area
currently
use
preventive
insecticides
for
the
control
of
corn
rootworm.
The
introduction
of
corn.
rootworm
protected
corn
will
reduce
usage
and
exposure
to
these
harsh
pesticides,
which
will
benefit
both
the
environment
and
the
corn
producer.

Commenter
Name:
Scott
Campbell
Commenter
Organization
Name:
Campbell
Seed,
Inc.
Comment
Number:
30509­
111000
Excerpt
Number:
1
Excerpt
Text:
We
strongly
support
corn
rootworm
protected
corn
because
of
the
value
it
would
bring
our
customers
and
our
employees.
We
personally
farm
about
4000
acres.
We
raise
our
own
seed.
The
value
of
reduced
insecticide
would
be
great.
We
have
to
use
insecticide
on
every
acre
of
seed
corn
we
plant.
Reduced
exposure
to
our
customers,
their
families
and
our
employees
would
be
good.

Commenter
Name:
Scott
Campbell
Commenter
Organization
Name:
Campbell
Seed,
Inc.
Comment
Number:
30509­
111000
Excerpt
Number:
2
Excerpt
Text:
Using
seed
protected
with
rootworm
resistant
technology
would
be
convenient
and
reduce
the
time
needed
in
application
of
current
insecticides.
With
prices
as
low
as
they
are,
any
cost
efficiency
would
be
welcomed.
Storage
and
disposal
of
insecticides
and
their
containers
could
also
be
eliminated.

Regulatory
pressures
to
eliminate
use
of
insecticides
is
growing.
Seed
protected
technology
could
help
satisfy
the
green
peace
folks
and
still
allow
farmers
to
grow
their
crops
with
the
protection
needed
against
rootworms.

Commenter
Name:
Charles
Brown
Commenter
Organization
Name:
Brown
Seed
Farms,
Inc.
Comment
Number:
30509­
116000
Excerpt
Number:
1
Excerpt
Text:
I
support
the
registration
of
corn
rootworm
protected
corn
because
of
the
reduced
exposure
of
farmers
and
their
families
to
insecticides
that
work
on
the
nervous
system
of
humans
as
well
as
that
of
the
corn
rootworm.
Insecticides
effect
or
kill
all
organisms
including
non­
target
living
organisms
whereas
rootworm
protected
corn
would
only
effect
a
narrow
spectrum
of
insects.

Because
of
the
in­
seed
protection,
farmers
have
the
convenience
of
not
handling
corn
rootworm
insecticides
at
planting.
This
reduces
the
need
for
storage,
transportation
and
disposal
of
chemical
insecticides
and
their
containers.
Section
5.2
Section
5
­
57
Commenter
Name:
Douglas
Tallamy
Commenter
Organization
Name:
University
of
Delaware
­
Deparment
of
Entomology
and
Applied
Ecology
Comment
Number:
30509­
117000
Excerpt
Number:
3
Excerpt
Text:
Wise
use
of
BT
corn
against
corn
rootworms
would
considerably
reduce
the
pesticides
applied
to
US
corn
overnight,
and,
as
a
direct
consequence,
reduce
monarch
mortality
associated
with
conventional
corn
plantings.
The
reduction
of
pesticide
has
been
a
national
goal
for
decades.
Now
that
we
have
the
technology
to
attain
this
goal,
registration
of
this
technology
is
threatened
because
of
misguided
national
hysteria.
I
urge
that
we
return
to
logic
and
reason
in
this
matter.

Commenter
Name:
Dean
Urmston
Commenter
Organization
Name:
American
Seed
Trade
Association,
Inc.
Comment
Number:
30509­
118000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm.
is
a
significant
pest
problem
in
the
United
States.
If
approved,
this
new
biotech
rootworm.
product
would
be
a
much
needed,
environmentally
friendly
tool
that
growers
could
use.
Soil
insecticide
applications
for
corn
rootworm.
control
are
currently
the
number
one
use
of
all
insecticides
in
the
United
States.
Adoption
of
biotech
corn
rootworm
protected
corn
will
help
growers
reduce
overall
insecticide
use.

In
addition,
biotech
corn
rootworm.
corn
would
provide
growers
with
simplicity
and
convenience.
Because
of
this
product's
in­
seed
protection,
growers
have
the
convenience
of
greatly
reducing
the
handling
of
corn
rootworm
insecticides.
This
provides
an
ideal
fit
with
current
integrated
pest
management
(
IPM)
programs.

Finally,
biotech
corn
rootworm.
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
insecticides
that
may
have
more
variable
performance
due
to
varying
growing
conditions.
Growers
are
at
risk
of
losing
insecticide
choices
due
to
regulatory
pressures
and
are
in
need
of
effective
alternatives
to
fill
that
void.

Commenter
Name:
Doran
Zumbach
Commenter
Organization
Name:
Doran
Zumbach
Comment
Number:
30509­
120000
Excerpt
Number:
1
Excerpt
Text:
The
reason
for
my
letter
to
you
today
is
to
personally
issue
my
support
for
the
registration
of
corn
rootworm,
protected
corn.
This
would
allow
me
to
grow
corn
in
a
more
environmentally
kind
manor.
I
would
be
able
to
discontinue
the
use
of
the
organophosphates
insecticide
that
I
must
use
to
control
the
corn
rootworm.
I
am
sure
that
it
would
give
me
more
complete
and
more
reliable
control
of
this
pest.
It
would
also
rid
my
family
and
myself
to
the
possibility
of
exposure
to
this
insecticide.
In
addition
to
these
advantages
it
helps
me
to
assure
a
safe
abundant
food
supply.

Commenter
Name:
David
Strawn
Section
5.2
Section
5
­
58
Commenter
Organization
Name:
Wyffels
Hybrids,
Inc.
Comment
Number:
30509­
L02
Excerpt
Number:
2
Excerpt
Text:
The
benefits
I
see
are
reduction
in
handling
of
restricted
use
pesticide
chemicals
by
farmers.
My
experience
is
that
no
matter
how
careful
one
is
for
his/
her
own
well
being
the
risk
is
there
in
the
handling.
My
customers
always
bring
up
the
personal
risk
factor
when
I
interact
with
them
on
their
farms.
Currently
my
customers
handle
rootworm
pest
through
the
use
of
a
variety
of
applied
chemicals.
These
chemicals
work
effectively
for
their
design
but
the
danger
id
always
there
of
physical
contact
or
spillage.
I
have
seen
spillage
which
requires
substantial
time
cost
and
risk
clean
up.

Commenter
Name:
Steven
Pueppke
Commenter
Organization
Name:
University
of
Illinois
at
Urbana­
Champaign
Comment
Number:
30509B­
019000
Excerpt
Number:
2
Excerpt
Text:
There
is
evidence
that
the
availability
of
corn
rootworm
protected
corn
will
have
a
number
of
agricultural
and
environmental
benefits.
One
of
the
most
important
is
effectiveness
in
controlling
the
pest.
Control
is
more
consistent
than
that
currently
available
with
insecticide
applications,
and
it
can
be
achieved.
simply,
with
reduced
human
exposure
to
insecticides.
This
new
technology
also
fits
well
with
existing
integrated
pest
management
programs
for
corn
rootworm
control.

Commenter
Name:
Steven
Pueppke
Commenter
Organization
Name:
University
of
Illinois
at
Urbana­
Champaign
Comment
Number:
30509B­
019000
Excerpt
Number:
3
Excerpt
Text:
A
second
benefit
of
the
technology
relates
to
the
environment.
Simply
stated,
corn
rootworm
protected
corn
holds
the
promise
to
significantly
reduce
total
insecticide
use
in
this
country.
This
is
a
goal
that
I
fully
support.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn,
Co.
Comment
Number:
30509B­
020000
Excerpt
Number:
1
Excerpt
Text:
I
support
the
registration
of
corn
rootworm
protected
corn.
This
new
biotechnology
is
1)
better
for
the
environment
because
of
reduced
insecticide
use
by
the
American
farmer,
2)
simple
to
use
because
of
reduced
handling
and
farmer
exposure
to
insecticides,
3)
gives
effective
and
consistent
control
of
corn
rootworm.
pests,
and
4)
fits
with
current
IPM
procdures.

Commenter
Name:
Dale
Brown
Commenter
Organization
Name:
Pfister
Hybrid
Corn,
Co.
Comment
Number:
30509B­
020000
Section
5.2
Section
5
­
59
Excerpt
Number:
2
Excerpt
Text:
I
have
several
reasons
why
I
support
this
technology.
I
know
of
a
farmer
who
spilled
a
rootworm.
liquid
insecticide,
furadan,
on
himself
a
few
years
ago.
He
was
sick
in
just
a
few
minutes.
He
did
not
realize
that
such
a
small
amount
of
chemical
could
make
him
so
sick
and
require
such
quick
medical
attention.
This
rootworm
technology
will
eliminate
these
worker
exposures.

Commenter
Name:
Bob
Mohror
Commenter
Organization
Name:
Bob
Mohror
Comment
Number:
30509B­
021000
Excerpt
Number:
1
Excerpt
Text:
This
petition
should
be
approved
to
reduce
the
usage
of
soil
insecticides
necessary
to
control
the
corn
root
worm
damage
done
to
corn
every
season.

The
reduced
soil
insecticide
has
several
benefits
including
less
exposure
to
farmers
and
other
applicators,
less
potential
damage
to
non
target
insects
and
reduced
potential
for
groundwater
contamination.

Commenter
Name:
Dee
Vaughan
Commenter
Organization
Name:
Dee
Vaughan
Comment
Number:
30509B­
022000
Excerpt
Number:
2
Excerpt
Text:
In
the
past
we
have
used
various
soil
applied
insecticides
for
control
of
corn
rootworm
but
the
efficacy
of
these
products,
plus
the
danger
to
handlers
and
the
environment,
has
led
to
a
reduction
in
their
use.
Now
we
are
spraying
the
adult
rootworm.
beetles
in
efforts
to
control
the
population
of
larva
in
the
next
season.
This
is
effective,
but
costly,
and
requires
up
to
two
aerial
applications
of
insecticide.

Corn
root
worm
protected
corn
would
allow
us
to
handle
and
apply
less
insecticide.
It
would
be
more
cost
effective
and
would
provide
better
control
of
the
target
pest.
It
would
be
safer
for
me,
my
employees,
and
my
crop
consultant.

Commenter
Name:
Jim
Happel
Commenter
Organization
Name:
Growmark,
Inc.
Comment
Number:
30509B­
023000
Excerpt
Number:
1
Excerpt
Text:
I
want
to
express
my
support
of
the
registration
of
rootworm­
protected
corn.

Farmers
spend
millions
of
dollars
each
year
to
protect
corn
from
the
damage
caused
by
the
corn
rootworm.
In
addition
this
technology
would
reduce
the
insecticide
used
currently
to
protect
corn
from
this
damaging
insect.

Commenter
Name:
Chastitie
Herman
Section
5.2
Section
5
­
60
Commenter
Organization
Name:
Chastitie
Herman
Comment
Number:
30509B­
024000
Excerpt
Number:
2
Excerpt
Text:
Environmentally,
growers
will
use
less
insecticides.
Currently,
the
most
widely
used
insecticide
is
for
the
control
of
corn
rootworm,
which
costs
the
grower
approximately
$
1
billion
annually.
Also,
the
use
of
corn
rootworm
protected
corn
would
eliminate
the
handling
and
exposure
of
insecticides
­
the
technology
is
simply
"
in
the
seed."
This
decreases­
the
need
for
storage,
transportation
and
disposal
of
chemical
insecticides
and
their
containers.

Commenter
Name:
Jeff
Sernett
Commenter
Organization
Name:
Jeff
Sernett
Comment
Number:
30509B­
025000
Excerpt
Number:
3
Excerpt
Text:
The
insecticides
that
are
presently
used
do
have
significant
safety
concerns
if
not
used
according
to
the
labeled
procedure
and
are
also
quite
hazardous
to
aquatic
and
bird
species.
This
is
a
small,
but
very
significant
reason
to
allow
new
technology
to
enter
the
marketplace
like
corn
rootworm
resistance.

Commenter
Name:
Jeff
Sernett
Commenter
Organization
Name:
Jeff
Sernett
Comment
Number:
30509B­
025000
Excerpt
Number:
5
Excerpt
Text:
Some
of
the
benefits
of
corn
rootworm
protected
corn
include
maximum,
consistent
protection
because
the
corn
protects
itself
via
protein
generation
from
the
insect.
Secondly,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.
The
use
of
fewer
chemicals
is
also
likely
a
health
benefit
to
farmers,
consumers
and
the
environment.

Commenter
Name:
Eric
Sachs
Commenter
Organization
Name:
Eric
Sachs
Comment
Number:
30509B­
027002
Excerpt
Number:
1
Excerpt
Text:
Research
shows
that
YieldGard
Rootworm
(
YG
RW)
will
offer
significant
benefits
to
corn
growers
and
society,
including
more
convenient
corn
rootworm
management,
more
consistent
control
of
the
corn
rootworm,
reduced
human
and
environmental
exposure
to
insecticides
and
less
overall
environmental
impact.

Commenter
Name:
Seth
Kanter
Commenter
Organization
Name:
Seth
Kanter
Comment
Number:
30509B­
027006
Excerpt
Number:
1
Excerpt
Text:
Section
5.2
Section
5
­
61
I
support
of
the
use
of
rootworm­
protected
corn
developed
through
biotechnology.
People
that
oppose
biotechnology
are
at
cross
purposes
to
what
they
purport
to
support.
Biotechnology
is
safe
and
it
reduces
the
amount
of
land
needed
for
farming,
and
it
reduces
that
amount
of
pesticides,
herbicides,
and
fertilizers
needed
as
well.

Commenter
Name:
Thomas
Beals
Commenter
Organization
Name:
Thomas
Beals
Comment
Number:
30509B­
027009
Excerpt
Number:
1
Excerpt
Text:
Reduced
insecticide
use
would
have
benefits
along
the
whole
insecticide
supply
chain;
it
will:
Reduce
insecticide
handling
and
exposure
­­
This
decreases
the
need
for
storage,
transportation
and
disposal
of
chemical
insecticides
and
their
containers;
reduce
in­
field
and
other
handling
exposure
of
farm
workers
to
chemical
insecticides;
reduce
farm
labor
time
and
costs­
decreases
growers
time
and
expenses
associated
with
application
and
equipment
upkeep
for
spraying
of
chemical
insecticides;
and
finally
reduce
exposure
of
beneficial
insects
to
insecticide,
thereby
improving
ecological
balance,
resilience,
and
diversity.

Commenter
Name:
Jeff
Hinen
Commenter
Organization
Name:
Jeff
Hinen
Comment
Number:
30509B­
029000
Excerpt
Number:
2
Excerpt
Text:
In
order
to
manage
this
pest,
I
currently
use
very
toxic
insecticides
that
I
do
not
like
exposing
myself
or
my
family
to,
but
I
feel
I
must
in
order
to
compete.
I
also
do
not
like
putting
these
chemicals
into
my
soil
where
they
can
potentially
contaminate
the
water
I
drink.
These
are
the
primary
reasons
why
I
need
these
new
corn
hybrids,
resistant
to
this
pest
on
my
farm.
I
would
like
to
use
these
hybrids
because
they
are
simple
to
use
(
no
way
to
overdose
the
rate
in
the
soil),
provide
me
effective
control
for
the
entire
growing
season,
are
not
toxic
to
me
when
I
handle
them
or
to
my
children
if
they
are
exposed
to
them,
and
they
fit
my
current
overall
pest
control
IPM
programs.

Commenter
Name:
Martina
Newell
Commenter
Organization
Name:
UC
­
Systemwide
Biotechnology
Research
and
Education
Program
Comment
Number:
30509B­
030006
Excerpt
Number:
2
Excerpt
Text:
In
addition
to
the
direct
benefit,
this
will
have
a
collateral
effect
in
that
costs
of
storage,
transportation
and
application
of
chemicals
will
be
greatly
reduced
if
not
eliminated
in
many
instances.

Commenter
Name:
Gregory
Carney
Commenter
Organization
Name:
Gregory
Carney
Comment
Number:
30509B­
030007
Excerpt
Number:
1
Excerpt
Text:
I'm
a
consumer
and
not
a
farmer,
but
anything
that
reduces
the
current
use
of
pesticides
I
feel
is
good
for
Section
5.2
Section
5
­
62
me.
I
am
aware
that
there
may
be
some
possibility
of
an
unexpected
consequence
of
using
this
new
strain
of
corn,
but
there
is
always
some
risk
when
something
new
is
tried.
If
the
science
has
not
found
evidence
of
problems,
this
has
got
to
be
a
better
alternative
than
dumping
toxic
chemicals
on
something
that
we
eventually
consume.
I'm
ready
to
give
this
a
shot.

Commenter
Name:
Bill
Thorne
Commenter
Organization
Name:
Bill
Thorne
Comment
Number:
30509B­
030011
Excerpt
Number:
1
Excerpt
Text:
I
agree
with
those
who
believe
that
when
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides
resulting
in
the
elimination
of
millions
of
pounds
of
chemical
pesticides,
increased
yields
for
certain
crops
and
delivered
significant
economic
benefits
to
farmers
and
consumers.

Commenter
Name:
Patty
Judge
Commenter
Organization
Name:
Iowa
Department
of
Agriculture
and
Land
Stewardship
Comment
Number:
30509B­
033000
Excerpt
Number:
3
Excerpt
Text:
Rootworm
protected
corn
will
provide
Iowa
corn
growers
with
another
tool
for
use
in
controlling
rootworms
while
also
reducing
insecticide
use.
A
reduction
in
the
use
of
corn
rootworm
insecticides
will
result
in
less
exposure
to
the
corn
grower
while
planting
corn
and
less
exposure
to
the
environment.

Commenter
Name:
Richard
Hellmich
Commenter
Organization
Name:
USDA­
ARS
Comment
Number:
30509B­
034000
Excerpt
Number:
2
Excerpt
Text:
Entomologists
who
have
worked
with
corn
insects
see
this
rootworm
transgenic
corn
as
an
opportunity
to
significantly
reduce
the
use
of
insecticides.
In
the
U.
S.
more
insecticides
are
applied
to
control
rootworm
than
any
other
insect
pest.
This
transgenic
corn
would
allow
growers
to
reduce
soil
insecticide
applications
and
it
would
be
an
important
integrated
pest
management
(
IPM)
tool.
Growers
have
told
me
that
they
are
interested
in
this
corn,
if
for
no
other
reason,
because
they
do
not
like
to
use
or
handle
insecticides.

Commenter
Name:
Bruce
Chassy
Commenter
Organization
Name:
University
of
Illinois
at
Urbana­
Champaign
Comment
Number:
30509B­
039000
Excerpt
Number:
2
Excerpt
Text:
My
principal
concern
in
this
matter'
is
that
more
insecticides
are
used
against
corn
rootworm
in
the
US
each
year
than
a
re
used
against
any
other
pest.
Approval
of
rootworm
protected
corn
would
therefore
greatly
lower
the
application
of
pesticides
that
at
the
least
pose
risks
to
farmers,
farm
workers
and
surrounding
communities.
The
insecticidal
protein
is
itself
well
known
to
degrade
quickly
in
the
Section
5.2
Section
5
­
63
environment
and
to
be
highly
specific
toward
its
targeted
pests.

Commenter
Name:
TJ
Hale
Commenter
Organization
Name:
Trisler
Seed
Farms,
Inc.
Comment
Number:
30509B­
040000
Excerpt
Number:
2
Excerpt
Text:
The
damage
from
corn
rootworm
has
caused
a
major
crop
management
shift
over
the
past
5­
7
years.
More
granular
insecticides
are
being
used
than
ever
before.
These
products
are
often
times
restricted
use
pesticides
and
very
inconvenient
to
use.
Rootworm
protected
corn
will
reduce
the
amount
of
soil
applied
insecticides
used
and
provide
a
uniform
level
of
crop
protection
that
is
safer
for
the
user
and
the
environment.
An
additional
benefit
will
be
reduced
concerns
for
the
disposal
of
used
packaging
material
from
soil
applied
products.
Our
customers
and
the
environment
will
equally
share
in
the
benefits
of
this
new
technology.

Commenter
Name:
Doran
Zumbach
Commenter
Organization
Name:
Z­
Valley
Grain
Comment
Number:
30509B­
041000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworms
are
the
most
significant
pest
problem
that
corn
farmers
throughout
this
county
face.
As
farmers,
our
only
choice
to
control
these
rootworms
has
been
the
use
of
insecticides
that
are
in
some
cases
very
dangerous
to
the
farmer
applicator.
My
experience
is
that
these
insecticides
only
offer
partial
control
and
in
addition
kill
insects
that
are
advantageous.
I
know
that
the
use
of
corn
rootworm
protected
corn
would:

1.
Reduce
Insecticide
use
2.
Reduce
insecticide
handling
and
exposure
risks.
3.
Offer
the
farmer
more
consistent
control
and
at
the
same
time
helping
us
to
protect
the
environment.

Commenter
Name:
Joan
O'Brien
Commenter
Organization
Name:
Iowa
Seed
Association
Comment
Number:
30509B­
043000
Excerpt
Number:
4
Excerpt
Text:
Some
of
the
benefits
of
corn
rootworm
protected
corn
include
maximum,
consistent
protection
because
the
corn
protects
itself
automatically
from
the
insect.
Secondly,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.

Commenter
Name:
Brad
Paschen
Commenter
Organization
Name:
Brad
Paschen
Comment
Number:
30509B­
044000
Excerpt
Number:
2
Excerpt
Text:
Section
5.2
Section
5
­
64
Soil
insecticides
that
control
the
corn
rootworm
are
currently
the
No.
I
use
of
insecticides
in
the
United
States.

Corn
rootworm
resistant
corn
would
reduce
overall
insecticide
use,
exposure,
and
would
protect
the
environment.

Commenter
Name:
Robert
Wensink
Commenter
Organization
Name:
Wensink
Farm
Seeds,
Inc.
Comment
Number:
30509B­
045000
Excerpt
Number:
1
Excerpt
Text:
We
have
over
1000
farmers
who
would
benefit
from
corn
rootworm
protective
technology.
Soil
insecticides
for
rootworm
control
is
the
primary
insectide
used
by
our
farmers.
The
adoption
of
this
corn
rootworm
technology
would
substantially
reduce
their
overall
insectide
applications.
This
consequently,
would
reduce
farmer
exposure
to
toxic
chemicals
and
reduce
environmental
contamination
from
chemical
insecticides
and
their
storage
containers.

Commenter
Name:
Jennifer
Riebe
Commenter
Organization
Name:
Jennifer
Riebe
Comment
Number:
30509B­
054000
Excerpt
Number:
1
Excerpt
Text:
In
the
U.
S.,
more
insecticide
is
applied
to
corn
to
control
corn
rootworms
than
any
other
pest.
Such
pesticides
are
applied
preventatively
to
the
soil,
where
they
may
potentially
contaminate
groundwater,
runoff
ditches,
ponds,
and
other
areas.
We
have
an
increasing
knowledge
of
detrimental
effects
of
even
trace
amounts
of
pesticides
on
vertebrate
physiological
development
(
i.
e.
amphibians).
Consequently,
growers
desperately
need
environmentally
benign,
cost
effective
alternatives
for
pest
control,
such
as
might
be
offered
by
Bt
crops.
As
a
mother,
I
would
rather
feed
my
family
food
grown
from
Bt
corn
than
from
corn
grown
with
conventional
pesticides.
As
a
resident
in
a
rural
agricultural
area,
I
would
prefer
that
my
corn
growing
neighbors
use
Bt
corn
than
treat
their
crops
with
insecticide.
I
believe
that
the
unintended
and
already
quantified
effects
of
using
conventional
insecticides
far
outweigh
potential
negative
impacts
from
using
Bt
corn.

Commenter
Name:
Stephen
Howell
Commenter
Organization
Name:
Stephen
Howell
Comment
Number:
30509B­
081000
Excerpt
Number:
2
Excerpt
Text:
Monsanto's
application
to
deploy
corn
hybrids
containing
event
MON
863
expressing
cry3Bb
gene
appears
to
be
a
prudent
use
of
transgenic
technology
to
protect
crops
plants
and
improve
farming
practices.
It
is
my
belief
that
adoption
of
corn
rootworm
protected
corn
would
help
growers
reduce
overall
insecticide
use.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Section
5.2
Section
5
­
65
Comment
Number:
30509B­
082000
Excerpt
Number:
1
Excerpt
Text:
I
support
the
registration
request
and
explain
my
reasons
below.
In
short,
my
reasons
are:

1)
Availability
of
corn
event
MON
863
will
reduce
the
human
health
and
environmental
costs
of
insecticides
currently
used
for
corn
rootworm
control
in
corn.

2)
Farmers
want
corn
hybrids
expressing
event
MON
863
for
a
variety
of
reasons,
including:
a)
Reduced
human
health
and
environmental
costs
due
to
insecticides
b)
Event
MON
863
gives
effective
and
consistent
control
of
corn
rootworm
larvae
3)
The
major
risks
identified
at
this
time
with
the
registration
of
event
MON
863
outweigh
the
costs
of
not
registering
event
MON
863.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Comment
Number:
30509B­
082000
Excerpt
Number:
4
Excerpt
Text:
These
survey
results
are
somewhat
dated
(
1995)
and
from
only
one
state,
but
I
believe
that
the
general
findings
would
still
holds
true
if
the
survey
were
repeated
today
in
other
locations.
Farmers
want
a
product
such
as
Bt
corn
for
corn
rootworm
control
to
reduce
insecticides
in
the
environment
and
the
exposure
to
insecticides
of
themselves
and
those
they
work
with.
The
potential
for
higher
yields
is
not
the
key
determinant
for
farmers;
rather
insecticide
exposure
is
the
more
important
issue
to
farmers.
This
is
not
to
say
that
the
financial
impact
of
corn
rootworm
is
not
a
concern
to
farmers.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Comment
Number:
30509B­
082000
Excerpt
Number:
7
Excerpt
Text:
I
hope
this
letter
makes
the
point
that
I
believe
that
corn
event
MON
863
provides
a
substantial
benefit
because
it
reduce
the.
exposure
of
farmers
and
farm
workers
to
hazardous
insecticides
and
will
reduce
the
level
of
these
insecticides
in
the
environment.
Farmers
and
others
concerned
about
the
environment
value
these
benefits.

Commenter
Name:
Julie
Doane
Commenter
Organization
Name:
Julie
Doane
Comment
Number:
30509B­
091000
Excerpt
Number:
1
Excerpt
Text:
Please
add
my
name
to
the
growing
list
of
people
who
urge
you
to
support
the
safe
and
well­
researched
new
technologies,
such
as
corn
improved
using
biotechnology,
to
protect
against
pests.
Such
technologies
are
Section
5.2
Section
5
­
66
very
important.
They
contribute
to
responsible
production
of
more
food
to
feed
a
growing
world
while
using
less
pesticides,
land,
labor
and
other
inputs.

Commenter
Name:
Julie
Doane
Commenter
Organization
Name:
Julie
Doane
Comment
Number:
30509B­
091000
Excerpt
Number:
2
Excerpt
Text:
The
USDA
and
EPA
are
currently
reviewing
applications
for
biotechnology
improved
corn
rootwormprotected
corn.
When
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides.
According
to
the
U.
S.
Department
of
Agriculture
and
numerous
independent
studies,
similar
biotechnology­
improved
crops
have
already
resulted
in
the
elimination
of
millions
of
pounds
of
chemical
pesticides,
increased
yields
for
certain
crops
and
delivered
significant
economic
benefits
to
farmers
and
consumers.

Commenter
Name:
Julie
Doane
Commenter
Organization
Name:
Julie
Doane
Comment
Number:
30509B­
091000
Excerpt
Number:
4
Excerpt
Text:
Reduce
chemical
insecticide
use
­­
Soil
insecticide
applications
for
corn
rootworm
control
are
currently
the
No.
1
use
of
insecticides
in
the
United
States.
Adoption
of
corn
rootworm
protected
corn
will
help
growers
reduce
overall
insecticide
use.

Reduce
insecticide
handling
and
exposure
­­
Decreases
the
need
for
storage,
transportation
and
disposal
of
chemical
insecticides
and
their
containers
and
reduces
in­
field
and
other
handling
exposure
of
farm
workers
to
chemical
insecticides.

Reduce
farm
labor
time
and
costs
­­
Decreases
growers'
time
and
expenses
associated
with
application
and
equipment
upkeep
for
spraying
of
chemical
insecticides.
Corn
rootworm
protected
corn
has
the
potential
to
provide
more
consistent
control
of
the
damaging
corn
rootworm
pest
than
chemical
insecticides.
Corn
rootworm
protected
corn
expresses
a
safe,
naturally
occurring
Bt
protein
in
the
roots
throughout
the
growing
season,
which
helps
reduce
the
possibility
of
failure
that
sometimes
occurs
with
soil
insecticides.

Commenter
Name:
Marvin
Boerboom
Commenter
Organization
Name:
Marvin
Boerboom
Comment
Number:
30509B­
092000
Excerpt
Number:
1
Excerpt
Text:
I
would
like
to
encourage
you
to
approve
the
use
of
Corn
Root
Worm
technology.
I
work
with
Farmers
across
southern
Minnesota
and
see
increasingly
more
and
more
extended
diapause
corn
root
worm
pressure
in
the
corn
fields.
Anything
we
can
do
to
help
increase
the
productivity
of
these
field
will
help
stabilize
yields
and
the,
rural
farming
economy.
It
is
a
shame
to
apply
insecticides
across
huge
numbers
of
acres
as
insurance
against
the
corn
root
worm
damage
when
we
could
control
them
thru
biotechnology
and
protect
Section
5.2
Section
5
­
67
our
wildlife
and
groundwater.

Please
support
this
technology!!!!

Commenter
Name:
Dale
Dowden
Commenter
Organization
Name:
Dale
Dowden
Comment
Number:
30509B­
092003
Excerpt
Number:
2
Excerpt
Text:
The
reduction
of
chemical
insecticides
use
for
rootworm
control
would
be
significant
in
helping
the
environment.

Commenter
Name:
Dan
Heavner
Commenter
Organization
Name:
Dan
Heavner
Comment
Number:
30509B­
092004
Excerpt
Number:
1
Excerpt
Text:
I
would
like
to
add
my
name
to
the
list
of
supporters
of
Corn
^
Rootworm­
Protected
corn.
The
benefits
are
great
for
both
the
environment
and
the
farmer.
By
reducing
pesticide
rates
added
into
the
environment.
We
are
not
only
protecting
the
natural
resources
that
are
present,
but
we
are
also
protecting
the
farmers
that
are
at
potential
exposure
risks
to
current
insecticide
products.

Commenter
Name:
Paulette
Pierson
Commenter
Organization
Name:
Paulette
Pierson
Comment
Number:
30509B­
092007
Excerpt
Number:
1
Excerpt
Text:
I
urge
you
to
support
the
registration
of
the
pending
biotechnology­
improved
corn
rootworm­
protected
corn.
Biotechnology
and
this
technology
in
particular
offers
the
potential
to
reduce
the
application
of
pesticides
to
our
soil.
The
technology
has
been
well
researched
by
universities
and
have
found
it
to
be
effective.
Corn
rootworm
protected
corn
is
much
safer
for
the
grower
to
use
­
no
planter
box
insecticides
to
handle
and
safer
for
our
government.

Commenter
Name:
Don
Bockelman
Commenter
Organization
Name:
Don
Bockelman
Comment
Number:
30509B­
092008
Excerpt
Number:
2
Excerpt
Text:
I
do
know
that
this
technology
is
important
to
corn
production
and
has
many
benefits.
(
1)
Biological
control
of
the
pest
by
a
BT
protein,
similar
to
those
that
have
been
applied
safely
for
years,
and
which
recently
has
been
use
safely
and
effectively
in
transgenic
BT
corn.
(
2)
Reduction
of
toxic
pesticides
in
the
environment,
less
movement
and
less
production
of
toxic
chemicals,
and
fever
container
disposal
problems.
(
3)
Much
safer
(
no
risk)
for
the
farmer
that
would
normally
be
at
risk
for
chemical
exposure.
(
4)
Specifically
targets
the
pest
and
reduces
the
risk
to
non­
targeted
organism
and
the
environment.
(
4)
Would
increase
corn
Section
5.2
Section
5
­
68
productivity
and
hopefully
increase
the
profit
margin
for
farmers.
(
5)
Yield
loss
to
corn
rootworms
can
be
high.
Increase
spread
of
rootworms
adapting
to
soybean
fields
is
becoming
a
problem,
leaving
rotational
practices
less
effective
for
control
in
areas
of
heavy
corn
production.
Leaves
an
option
for
farmers
that
don't
want/
like
to
apply
insecticides
on
these
acreages.

Commenter
Name:
Kathy
Klepfer
Commenter
Organization
Name:
Kathy
Klepfer
Comment
Number:
30509B­
092009
Excerpt
Number:
1
Excerpt
Text:
This
is
an
important
technology
that
will
be
beneficial
to
farmers
while
being
environmentally
safe.
This
is
the
type
of
technology
that
we
need
in
this
country.
When
approved,
this
corn
will
enable
farmers
to
improve
yields,
control
costs
and
reduce
the
use
of
chemical
insecticides.

Commenter
Name:
Arlen
Eggerling
Commenter
Organization
Name:
Hawkeye
Hybrids
Comment
Number:
30509B­
092011
Excerpt
Number:
1
Excerpt
Text:
Secondly,
because
the
plant
can
protect
itself,
corn
growers
can
reduce
the
amount
of
insecticide
they
apply.
The
use
of
fewer
chemicals
is
also
likely
a
health
benefit
to
farmers,
consumers
and
the
environment.

Commenter
Name:
Nicholas
Schneider
Commenter
Organization
Name:
Golden
Harvest,
Thorp
Seed
Co.
Comment
Number:
30509B­
092012
Excerpt
Number:
2
Excerpt
Text:
The
approval
of
corn
rootworm
protected
corn
will
reduce
dependence
on
insecticides,
reduce
handling
of
pesticides
products
by
growers,
and
reduce
some
of
the
economic
risks
growers
face
every
season.
Many
soil­
applied
insecticides
also
can
cause
unfavorable
crop
responses
when
used
with
come
popular
herbicides.
A
healthy
crop
is
essential
for
a
successful
farming
operation.
Corn
rootworm­
protected
corn
is
one
process
through
which
crop
health
will
be
improved.
Please
consider
these
positive
attributes
of
corn
rootworm­
protected
corn
when
rendering
decisions
pertaining
to
this
technology.

Commenter
Name:
Thomas
Carlson
Commenter
Organization
Name:
Thomas
Carlson
Comment
Number:
30509B­
092014
Excerpt
Number:
1
Excerpt
Text:
I
am
concerned
about
our
water
supply
in
South
Dakota
and
in
the
United
States.
There
are
some
studies
that
indicate
that
many
wells
in
Iowa
have
traces
of
agricultural
chemicals.
The
biotechnology
of
inserting
genes
into
corn
that
help
control
European
Corn
Borers
and
Corn
rootworms
is
excellent
because
it
reduces
the
need
for
chemicals
that
could
leach
into
water
supply.
Section
5.2
Section
5
­
69
Commenter
Name:
Clinton
Pilcher
Commenter
Organization
Name:
Clinton
Pilcher
Comment
Number:
30509B­
092015
Excerpt
Number:
2
Excerpt
Text:
There
are
many
advantages
to
using
this
technology
as
an
additional
pest
management
tool:

1)
Reduced
Insecticide
Use
2)
Reduced
pesticide
exposure
to
applicators
Note:
Farmers
surveyed
(
Pilcher
and
Rice
1998)
said
the
greatest
advantage
to
this
technology
would
be
reduced
insectice
exposure
and
use.
3)
Reduced
environmental
contamination
(
soil
and
water)
4)
Yield
loss
prevention
5)
Saved
labor
time.
in
reducing
calibration
of
equipment
and
equipment
repair
6)
Saved
money
on
equipment
for
pesticide
application
7)
Potentially
could
save
money
on
reduced
scouting
costs
for
rootworm
8)
No
worries
on
fertilizer/
pesticide
interaction
concerns
9)
High
specifity
of
this
product
for
corn
rootworm
10)
Consistency
in
control
over
currently
used
soil­
insecticide
products
11)
Fits
well
within
current
IPM/
Sustainable
Agriculture
practices
which
are
highly
encouraged
Commenter
Name:
Bruce
Vogel
Commenter
Organization
Name:
Bruce
Vogel
Comment
Number:
30509B­
092024
Excerpt
Number:
1
Excerpt
Text:
It
seems
to
me
that
a
biologically
resistant
breed
of
Corn
(
or
tree/
animal/
human)
is
more
desirable
than
a
non
resistant
one
that
requires
the
application
of
chemicals
(
or
medicines/
vaccines).
Moderation,
I
also
believe,
is
advisable
when
progressing
on
these
issues.

Commenter
Name:
Brian
Hurley
Commenter
Organization
Name:
Brian
Hurley
Comment
Number:
30509B­
092026
Excerpt
Number:
1
Excerpt
Text:
This
is
a
solution
the
benefits
the
environment
­­
as
a
reduction
in
chemical
usage
would
likely
translate
to
an
improved
ecological
environment,
where
there
would
be
a
significant
decrease
in
the
number
of
concerning
ecological
events
such
as
bird
and
fish
kills.

Commenter
Name:
Bryan
Hurley
Commenter
Organization
Name:
Bryan
Hurley
Comment
Number:
30509B­
092027
Excerpt
Number:
3
Excerpt
Text:
Section
5.2
Section
5
­
70
And,
bridging
both
American
farmers
and
consumers
is
the
very
real
potential
for
biotechnology
to
reduce
the
amount
of
pesticides
sprayed
in
the
environment
and
on
America's
food
crops.
The
EPA
stated
in
an
article
in
the
Washington
Post
last
August
that:
"...[
A]
s
much
as
8.5
million
pounds
of
insecticides
would
not
be
used
if
the
[
rootworm]
technology
lives
up
to
the
promise
it's
showing
...
That
affords
some
rather
dramatic
decreases
in
insecticide
use
that
would
have
a
tremendous
impact
on
both
the
environment
and
farm
workers
themselves."

A
biotechnology­
derived
corn
variety
is
the
essence
of
the
application
of
modem
technology
and
scientific
advancement
to
improve
on
a
fundamental
practice
of
society.
More
than
60
percent
of
these
chemicals
­­
from
the
organophosphate,
pyrethroid
and
carbamate
classes
of
chemicals
­­
are
being
reviewed
by
the
EPA
under
the
Food
Quality
Protection
Act
(
FQPA).
One
aspect
of
this
review
is
an
analysis
of
the
toxicity
of
these
chemistries
in
relation
to
the
exposure
to
children.
Nearly
all
of
these
chemicals
are
classified
as
"
Restricted
Use
Pesticides"
due
to
toxicity
measures.

The
logical
alternative
to
this
chemical
use
is
in­
plant
protection
provided
by
the
tools
of
modern
biotechnology.
In
allowing
the
plant
to
protect
itself
from
the
devastating
damage
of
the
corn
rootworm,
farmers
will
be
able
to
improve
rootworm
control
while
avoiding
exposure
to
the
organophosphates
and
other
chemistries
currently
handled
at
planting
time.

Perhaps
more
importantly,
this
directly
benefits
the
average
consumer.
One
of
the
most
significant
benefits
of
plant
biotechnology
that
has
not
received
prominent
attention
in
the
ongoing
debate
about
this
technology
is
the
fact
that
the
first
generation
biotechnology
products
have
significantly
reduced
the
amount
of
synthetic
chemical
insectides
used
on
commodity
crops
today.
If
America's
farmers
are
not
spraying
millions
of
pounds
of
synthetic
chemicals,
there
are
.
less
of
those
chemicals
in
the
environment,
That
means
there
are
less
pesticides
being
used
to
produce
the
food
we
buy
­
which
is
a
very
real
and
profound
benefit
for
consumers.

The
widespread
use
of
a
corn­
rootworm
protected
corn
plant
would
be
the
prototypical
win­
win
solution
for
all
parties
involved
­­
improving
the
health
of
America's
farmers
by
reducing
exposure
to
synthetic
chemicals
while
also
benefit
consumers
by
reducing
the
amount
of
chemicals.

Commenter
Name:
Jonathan
Quarles
Commenter
Organization
Name:
Jonathan
Quarles
Comment
Number:
30509B­
092029
Excerpt
Number:
1
Excerpt
Text:
Biotechnology
can
positively
impact
farm
life
through
a
reduction
in
chemical
applications
and
more
profitable
harvest
for
growers.
Currently,
farmers
use
insecticides
and
crop
rotation
to
manage
this
pest.

Commenter
Name:
Bill
Kuhn
Commenter
Organization
Name:
Bill
Kuhn
Comment
Number:
30509B­
092036
Excerpt
Number:
2
Excerpt
Text:
Thus,
utilize
the
science
to
show
the
safety
of
the
technology
and
promote
the
benefits
and
identify
any
Section
5.2
Section
5
­
71
risks
and
describe
them
well.
In
the
case
of
corn
rootworm
resistance
for
example
there
are
some
key
points
of
value:

­
Will
result
in
reduced
pesticide
usage
that
is
better
for
environment
­
Will
be
of
benefit
to
growers
by
giving
them
another
option
against
a
significant
pest
­
Will
be
good
for
processors
because
of
more
dependable
supply
of
grain
with
less
chemical
application
on
the
plants.

Commenter
Name:
Lee
Stromberg
Commenter
Organization
Name:
Lee
Stromberg
Comment
Number:
30509B­
092040
Excerpt
Number:
1
Excerpt
Text:
I
support
the
approval
of
bioengineered
crops
in
general,
and
this
specific
corn
rootworm
protected
corn
New
technologies
will
enable
American
farmers
to
remain
at
the
forefront
of
world
agriculture.
They
have
the
ability
to
reduce
insecticide
use,
increase
or
preserve
yields,
and
offer
improved
health
benefits.

Commenter
Name:
Gary
Schultz
Commenter
Organization
Name:
Gary
Schultz
Comment
Number:
30509B­
092042
Excerpt
Number:
1
Excerpt
Text:
This
technology
can
help
improve
productivity
of
farmers
worldwide
while
at
the
same
time
reducing
the
amount
of
pesticide
that
is
used
to
control
this
yield
robbing
pest.
Farmers
and
their
families
realize
the
risk
that
they
face
to
their
health
when
they
utilize
these
soil
applied
pesticides
but
they
take
that
risk
in
order
to
product
a
profitable
corn
crop.

Commenter
Name:
Gary
Schultz
Commenter
Organization
Name:
Gary
Schultz
Comment
Number:
30509B­
092042
Excerpt
Number:
2
Excerpt
Text:
As
scientist
at
the
USDA
review
regulatory
applications
for
this
new
Technology
I
would
ask
that
they
carefully
consider
the
benefits
not
only
to
farmer
but
also
to
wildlife
and
fish
that
would
otherwise
be
exposed
to
the
soil
applied
insecticides
that
are
being
used
today.
I
have
no
doubt
that
approval
of
this
product
will.
improve
the
environment
within
the
corn
producing
states
of
the
USA
and
the
world.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
2
Excerpt
Text:
This
product
offers
significant
opportunity
to
benefit
consumers
and
corn
growers.
By
making
this
product
Section
5.2
Section
5
­
72
widely
available,
we
will
reap
considerable
environmental
benefits
through
a
reduction
of
pesticides.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
4
Excerpt
Text:
Farmers
have
used
insecticides
to
control
the
corn
rootworm.
Because
there
is
no
"
rescue"
treatment,
these
insecticides
are
typically
applied
in
the
spring
during
planting.
Farmers
who
plant
corn
in
the
same
field
for
two
or
more
consecutive
years
typically
apply
a
corn
rootworm
insecticide.
Now
farmers
are
forced
to
apply
insecticides
on
corn
in
rotation
to
control
the
corn
rootworm.
This
has
resulted
in
farmers
applying
insecticides
on
about
23
percent
of
the
corn
crop.
Adoption
of
the
Bt
rootworm
product
would
significantly
reduce
the
growing
amount
of
insecticides
used
on
corn.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
6
Excerpt
Text:
Significant
benefits
to
farmers
could
be
realized
by
the
release
of
a
corn
plant
that
is
not
susceptible
to
the
corn
rootworm..
For
example,
handling
fewer
pesticides
would
result
in
improved
farmer
health
and
safety.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
9
Excerpt
Text:
However,
if
farmers
are
required
to
leave
a
20
percent
refuge
in
the
field,
they
are
certainly
going
to
apply
an
insecticide
on
the
refuge.
Which
means
that
farmers
are
still
exposed
to
handling,
storing
and
applying
insecticides.
Adopting
refuge
requirements
that
minimize
the
handling
of
insecticides
would
be
beneficial
to
the
grower
and
the
environment.

Commenter
Name:
Jim
Steward
Commenter
Organization
Name:
Steward
Seeds,
Inc.
Comment
Number:
30509B­
L001
Excerpt
Number:
2
Excerpt
Text:
To
manage
this
pest
effectively,
growers
throughout
the
nation
use
insecticides
and
crop
rotation.
Insecticide
applications
for
corn
rootworm
are
the
number
one
use
of
all
insecticides
in
the
United
States.
By
using
corn
rootworm
protected
corn,
the
plant
can
effectively
protect
itself
and
corn
growers
will
reduce
the
amount
of
insecticide
they
apply.
The
use
of
fewer
chemicals
is
a
health
benefit
to
farmers,
consumers
and
the
environment!

Commenter
Name:
Russell
Eulgem
Section
5.2
Section
5
­
73
Commenter
Organization
Name:
Russell
Eulgem
Comment
Number:
30590­
050000
Excerpt
Number:
2
Excerpt
Text:
The
farmers
I
currently
deal
with
must
use
insecticides
to
protect
their
crop
from
loss
due
to
rootworms.
I
feel
the
elimination
of
these
insecticides
would
be
very
beneficial.

Commenter
Name:
Chris
DiFonzo
Commenter
Organization
Name:
Michigan
State
University
Comment
Number:
30809B­
028000
Excerpt
Number:
2
Excerpt
Text:
In
Michigan,
about
50%
of
corn
growers
rotate
their
fields
for
agronomic
and
economic
reasons,
eliminating.
their
rootworm
problem
and
soil
insecticide
use.
However,
a
significant
number
of
the
remaining
growers
cannot
rotate
because
of
constraints
on
land
ownership,
manure
use,
and/
or
the
planting
of
farmland
to­
perennial
forages
like
alfalfa.
As
you
may
guess,
most
of
these
individuals
are
dairy
producers.
Some
of
these
farms
plant
corn
after
corn
for
10
to
12
years,
and
many
use
soil
insecticides.
Another
important
issue
is
the
spread
of
a
rotation­
resistant
variant
of
corn
rootworm
from
Indiana
into
Michigan.
This
variant
is
present
in
the
southern
tier
of
Michigan
counties.
It
has
not
yet
caused
the
significant
damage
seen
in
Indiana
and
Illinois,
but
some
growers
are
already
beginning
to
use
soil
insecticide
in
first­
year
corn
as
'
insurance'.

Commenter
Name:
Chris
DiFonzo
Commenter
Organization
Name:
Michigan
State
University
Comment
Number:
30809B­
028000
Excerpt
Number:
3
Excerpt
Text:
Cry
3Bb
transgenic
corn
would
fit
nicely
into
certain
production
systems
in
Michigan,
especially
in
dairy
operations
where
corn
could
be
fed
on­
farm.
What
intrigues
me
most
about
rootworm­
protected
corn
is
the
real
possibility
of
replacement
of
old
OP
and
carbamate
technology
in
Michigan.
The
introduction
of
European
corn
borer­
protected
corn
a
few
years
ago
did
little
to
change
insecticide
use
in
Michigan
field
crops.
Growers'
in
my
state
rarely,
if
ever.,
spray
for
corn
borer.
Corn
borer­
protected
corn
thus
did
not
significantly
reduce
OP
applications
or
applicator
exposure
[
note
that
this
is
not
true
for
other
parts
of
the
country
where
corn
borer
is
a
significant
problem].
However,
a
significant
number
of
growers
in
Michigan
do
use
soil
insecticides
targeted
for
corn
rootworm.
These
growers
recognize
the
risks
of
handling
soil
insecticides,
and
wish
they
did
not
have
to
fiddle
around
at
planting
with
insecticide
boxes,
calibration,
and
protective
equipment.
These
growers
also
understand
the
environmental
issue
of
using
soil
insecticides
in
a
state
surrounded
by
water.
Use
of
rootworm­
protected
corn
would
offer
an
alternative
in
Michigan
that
­
in
my
opinion
­
will
truly,
measurably
reduce
soil
insecticide
use,
worker
exposure,
and
impact
to
the
environment.

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Members
Section
5.2
Section
5
­
74
Comment
Number:
OPP02­
0016
Excerpt
Number:
3
Excerpt
Text:
In
the
midst
of
these
problems,
transgenic
corn
resistant
to
corn
rootworms
offers
a
new
management
alternative
with
several
positive
features.
The
transgenic
events
expressing
Cry3Bb
that
are
proposed
for
registration
provide
root
protection
and
reduce
corn
rootworm
emergence
equivalent
to,
or
better
than,
soil
insecticides.
From
a
health
and
safety
perspective,
transgenic
corn
expressing
Cry3Bb
eliminates
applicator,
handler,
and
farm
worker
exposure
to
insecticides.
With
a
narrow
spectrum
of
activity,
transgenic
corn
also
eliminates
or
greatly
reduces
the
environmental
concerns
generated
by
broader
spectrum
insecticides.
The
technology
is
easy
to
use
and
does
not
delay
planting.
Nor
does
it
require
special
application
equipment,
the
need
for
calibration,
or
the
disposal/
return
of
containers.
Performance
consistency
is
improved
since
each
plant
is
protected
and
this
protection
is
relatively
unaffected
by
weather.
Given
these
positive
features,
adoption
of
transgenic
technology
may
be
rapid
in
some
parts
of
the
Corn
Belt
once
it
becomes
commercially
available.

Commenter
Name:
National
Wild
Turkey
Federation
Commenter
Organization
Name:
National
Wild
Turkey
Federation
Comment
Number:
OPP02­
0026
Excerpt
Number:
2
Excerpt
Text:
Data
collected,
to
date,
suggest
that
the
corn
rootworm
control
biotechnology
that
you
are
evaluating
(
Monsanto
event
863)
will
further
reduce
insecticide
usage
on
many
rural
landscapes.
Obvious
is
the
fact
that
approval
and
adoption
of
this
technology
will
create
wildlife
benefits
in
the
form
of
reduced
potential
for
exposure
of
turkeys
and
other
wildlife
species
to
restricted
use
insecticides.

Commenter
Name:
John
Foster
Commenter
Organization
Name:
John
Foster
Comment
Number:
OPP02­
0027
Excerpt
Number:
2
Excerpt
Text:
I
believe
that
the
introduction
of
MON
863
has
the
potential
to
bring
clear
and
measurable
ecological
benefits
to
corn
production
systems
in
terms
of
reduced
insecticide
usage
and
hence
reduced
worker
exposure
Commenter
Name:
Helen
Inman
Commenter
Organization
Name:
Helen
Inman
Comment
Number:
OPP02­
0036
Excerpt
Number:
5
Excerpt
Text:
It
is
important
to
note
that
with
this
technology,
farms
like
ours
will
have
the
ability
to
significantly
reduce
the
use
of
pesticides.
However,
we
will
still
need
access
to
basic
chemistry
to
control
some
pests.
Agriculture
is
different
from
other
industries
since
farmers
control
very
few
factors
in
production.
We
must
have
the
flexibility
to
address
unforeseen
occurrences.
Section
5.2
Section
5
­
75
EPA
Response:
The
Agency
agrees
that
MON
863
has
significant
potential
to
reduce
the
use
of
more
harmful
chemical
insecticides.
The
Agency
agrees
that
the
health
related
benefits
of
MON
863
are
of
significant
value
to
farmers.
The
fact
that
MON
863
substitutes
for
harmful
insecticides
has
been
included
in
the
quantitative
calculations
of
benefits.
Specifically,
the
cost
of
an
insecticide
application
includes
the
out
of
pocket
costs
of
$
12.50
per
acre
plus
an
additional
$
2.50
per
acre
to
account
for
the
difficulty
in
use
and
increased
toxicity
relative
to
the
safety
and
ease
of
use
of
MON
863.

Commenter
Name:
Teresa
Gruber
Commenter
Organization
Name:
Council
for
Agricultural
Science
and
Technology
Comment
Number:
OPP02­
0037
Excerpt
Number:
2
Excerpt
Text:
Furthermore,
adoption
of
Bt
corn
for
rootworm
control
will
likely
have
significant
environmental
benefits
relative
to
conventional
corn
systems
in
the
reduction
of
insecticide
use
after
planting,
which
should
result
in
reduced
human
exposure
to
harmful
toxins,
and
greater
efficiencies
in
land
and
energy
use.

EPA
Response:
The
Agency
agrees
that
MON
863
will
improve
yields
and
thus
reduce
the
amount
of
land
required
to
grow
a
given
amount
of
corn.
The
Agency
agrees
that
MON
863
has
significant
potential
to
reduce
the
use
of
more
harmful
chemical
insecticides.
The
Agency
agrees
that
the
health
related
benefits
of
MON
863
are
of
significant
value
to
farmers.
The
fact
that
MON
863
substitutes
for
harmful
insecticides
has
been
included
in
the
quantitative
calculations
of
benefits.
Specifically,
the
cost
of
an
insecticide
application
includes
the
out
of
pocket
costs
of
$
12.50
per
acre
plus
an
additional
$
2.50
per
acre
to
account
for
the
difficulty
in
use
and
increased
toxicity
relative
to
the
safety
and
ease
of
use
of
MON
863.
Commenter
Name:
Charles
Benbrook
Commenter
Organization
Name:
Union
of
Concerned
Scientists
Comment
Number:
30509­
115000
Excerpt
Number:
18
Excerpt
Text:
1.
Impacts
on
Insecticide
Use
Citing
USDA
pesticide
use
data,
the
June
2000
Monsanto
application
states
that
32
percent
of
corn
acres
were
treated
in
1998
with
an
insecticide
registered
for
corn
rootworm
control.
While
narrowly
true,
this
statement
is
misleading
since
some
insecticides
registered
for
both
ECB
and
CRW
control
are
applied
largely
or
fully
for
ECB
control,
or
to
manage
other
insects.

Tables
2
and
3
provide
an
overview
of
insecticide
use
on
corn,
also
drawing
on
official
USDA
pesticide
use
survey
results
going
back
to
1971.
Table
2
reports
data
on
the
percent
of
corn
acres
treated.
Table
3
presents
pounds
applied
by
active
ingredient.
The
tables
disaggregate
insecticide
use
into
those
products
applied
predominantly
for
ECB
control,
those
applied
predominantly
for
corn
rootworm
control,
and
a
set
of
11
active
ingredients
applied
over
the
years
for
control
of
both
the
ECB
and
the
CRW,
and
on
some
farms,
control
of
other
insects.
Section
5.2
Section
5
­
76
Several
entomologists
were
consulted
in
developing
Tables
2
and
3.
There
is
little
disagreement
over
the
designation
of
insecticides
applied
predominantly
for
ECB
control
or
predominantly
for
corn
rootworm
control.
There
is
uncertainty,
however,
in
how
to
assign
a
portion
of
the
acres
treated
with
insecticides
applied
for
"
ECB
and
Other
[
Insect
pest]
Control"
to
the
ECB
versus
the
CRW.
In
the
tables
that
follow,
it
is
assumed
that
one­
quarter
of
the
acres
treated
with
"
ECB
and
Other
Control"
insecticides
were
applied
to
manage
the
ECB
and
one­
half
was
applied
targeting
the
corn
rootworm.
We
also
assume
that
the
remaining
one­
quarter
of
"
ECB
and
Other
Control"
acres
treated
and
pounds
applied
were
sprayed
to
manage
other
insect
pests.

While
the
percent
of
national
corn
acres
treated
for
control
of
the
corn
rootworm
went
up
from
1995
to
1998,
reflecting
the
emergence
of
CRWs
over
wintering
in
soybean
fields,
the
portion
of
acres
treated
went
down
in
1999
to
about
23
percent
­
well
less
than
the
32
percent
implied
by
Monsanto.
There
is,
moreover,
a
clear
shift
away
from
OP
insecticides
and
toward
synthetic
pyrethroids,
especially
the
effective,
relatively
new
product
tefluthrin,
now
the
market
leader.

Table
3
reports
pounds
applied
from
1971
through
1999
and
shows
an
almost
2
million
pound
decrease
in
corn
insecticides
applied
for
corn
rootworm
control
from
1998
to
1999.
The
drop
in
terbufos
and
fonofos
pounds
applied
accounts
for
much
of
the
drop.
Unfortunately,
use
of
the
highly
toxic
carbamate
insecticide
carbofuran
has
increased,
although
only
about
1
percent
of
acres
were
treated.

Corn
accounts
for
the
majority
of
insecticide
use
in
the
Midwest.
An
estimated
75
percent
of
corn
insecticide
use
in
1999
was
triggered
by
the
need
to
manage
the
corn
rootworm
(
Table
3).
Reducing
reliance
on
highly
toxic,
broad­
spectrum
corn
insecticides
such
as
terbufos,
carbofuran,
and
chlorpyrifos
would
contribute
significantly
to
regional
efforts
to
enhance
water
quality
and
lessen
bird
and
fish
kills.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
22
Excerpt
Text:
Reduced
Insecticide
Use
May
Deliver
Only
Modest
Benefits.

The
benefit
to
the
environment
and
human
health
from
reduced
insecticide
treatments
is
certainly
desirable
but,
for
reasons
set
forth
below,
may
be
modest
and
may
become
even
more
modest
in
the
next
few
years
if
new
insecticide­
based
products
are
marketed
and
adopted.
In
all
likelihood,
such
products
will
be
priced
competitively
to
deliver
equal
results
at
somewhat
lower
costs
to
farmers.

Risks
may
not
be
reduced
as
much
as
some
may
expect
because
farmers
have
already
taken
several
positive
steps
to
reduce
their
use
of
higher­
risk
corn
soil
insecticides.
Table
1
shows
that
many
high­
risk
products
that
were
once
used
on
millions
of
acres
nationwide
are
now
either
not
used
or
are
applied
on
more
modest
acreage.
These
insecticides
include
carbofuran
(
cause
of
major
bird
kills,
including
bald
eagles),
fonofos,
phorate,
all
chlorinated
hydrocarbons
(
endrin,
aldrin,
heptachlor,
toxaphene
and
DDT),
methyl
parathion,
and
parathion.

As
high­
risk
organophosphate
(
OP)
insecticides
have
dropped
from
widespread
use,
the
lower­
risk
OPs
and
Section
5.2
Section
5
­
77
synthetic
pyrethroids
have
gained
market
share.
Syngenta's
tefluthrin
(
Force)
is
now
the
most
widely
applied
rootworm
insecticide.
In
2001,
tefluthrin
accounted
for
almost
40
percent
of
the
corn
insecticide
acre­
treatments
targeting
rootworms.
[
Footnote
17:
Table
5
of
the
Monsanto
IRM
plan
document
(
Vaughn
et
al.,
2001)
contains
data
on
corn
insecticide
market
share
and
reports
that
tefluthrin
has
a
25
percent
market
share,
far
below
its
actual
nearly
40
percent
share
of
the
rootworm
market.
Table
5
combines
and
does
not
distinguish
between
insecticides
applied
to
control
rootworms,
ECBs,
and
other
insects.
Hence,
tefluthrin's
market
share
is
reported
relative
to
the
larger
volume
of
total
corn
insecticide
use.]
Force's
market
share
has
grown
steadily
since
its
introduction
in
the
early
1990s
and
further
growth
is
likely
given
recent
formulation
advances
and
price
cuts.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
24
Excerpt
Text:
In
general,
use
of
OPs
for
corn
rootworm
management
peaked
in
the
early
1990s
and
has
been
falling
since,
whereas
reliance
has
grown
comparably
on
the
synthetic
pyrethroids.
The
impacts
of
these
trends
on
pesticide
use
and
risks
are
relatively
straightforward.
Most
older
OPs
are
applied
at
10­
times
or
more
the
rate
of
synthetic
pyrethroids.
OPs
pose
acute
and
chronic
risks
to
a
broad
range
of
mammals,
birds,
fish,
and
soil
organisms.
Applicators
and
handlers
are
also
at
risk,
as
are
people
who
are
dependent
on
contaminated
sources
of
drinking
water.
[
Footnote
20:
20
In
EPA's
just
completed
cumulative
risk
assessment
of
the
OP
insecticides,
the
agency
concluded
that
exposures
via
drinking
water
accounted
for
a
small
share
of
total
OP
exposure.
In
addition,
the
best
available
data
suggest
that
urban
uses
of
OPs
are
the
most
common
cause
of
human
exposures
via
drinking
water.
Applicator
and
farm
worker
exposures
often
raise
serious
risk
concerns.]

Synthetic
pyrethroids
used
for
corn
rootworm
management
present
lower
risks
than
the
OPs.
The
pyrethroids
are
toxic
to
some
nontarget
organisms
including
shellfish,
some
small
aquatic
organisms,
and
a
range
of
beneficial
arthropods
though
these
organisms
are
impacted
less
when
corn
farmers
apply
the
chemicals
in
furrows
applications.
In
addition,
the
products
are
relatively
non­
toxic
to
mammals
and
are
rarely
implicated
in
bird
kills.

In
summary,
the
adverse
environmental
impacts
of
corn
insecticide
use
have
fortunately
trended
downward
since
the
early
1990s
as
a
result
of
the
switch
from
OP­
based
controls
to
synthetic
pyrethroids.
The
contemporary
risks
associated
with
insecticides
for
rootworm
control
are
likely
to
be
further
cut
as
new
technologies
are
commercialized.
Some
advances
target
rootworm
larvae
during
the
portion
of
their
lifecycle
when
they
attack
corn
roots.
Other
breakthroughs
target
adult
beetle
management
during
the
summer
months
when
insects
are
feeding
on
corn
foliage.

EPA
Response:
The
commenters
summarize
downward
trends
in
the
environmental
impacts
from
insecticide
use.
MON
863
should
contribute
to
this
trend.

5.3
­
Alternatives
to
MON
863
Section
5.3
Section
5
­
78
5.3
­
Comment
Excerpts
Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
1
Excerpt
Text:
­
Expressing
concerns
over
continued
use
of
soil­
applied
insecticides,
U.
S.
corn
farmers
told
Foundation
E.
A.
R.
T.
H.
they
would
switch
nearly
five
(
5)
million
corn
acres
if
they
had
access
to
a
more
environmentally­
friendly
seed
corn
that
controls
corn
rootworms.

Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
2
Excerpt
Text:
­
These
changes
in
farming
practices
would
result
in
a
reduction
of
2.4
million
pounds
of
active
ingredients
of
soil­
applied
insecticides
in
the
ECB
and
WCB
Commenter
Name:
Tom
Hunsley
Commenter
Organization
Name:
Growmark,
Inc.
Comment
Number:
30509­
023000
Excerpt
Number:
4
Excerpt
Text:
There
is
also
the
issue
that
corn
growers
may
be
at
risk
for
losing
the
most
effective
class
of
insecticides
due
to
regulatory
pressures
and
are
in
need
of
alternative
methods
of
rootworm
control.

EPA
Response:
The
Agency
agrees
that
the
commonly
used
insecticides
to
control
CRW
are
less
environmentally
friendly
than
MON
863
and
that
fact
factors
into
the
consideration
in
product
selection.
However,
the
likelihood
of
future
regulatory
actions
that
either
restrict
or
enhance
the
choice
of
alternatives
is
not
considered
in
the
benefits
assessment
since
such
predictions
are
speculative
and
would
prejudice
the
decision
process.

Commenter
Name:
Charles
Benbrook
Commenter
Organization
Name:
Union
of
Concerned
Scientists
Comment
Number:
30509­
115000
Excerpt
Number:
19
Excerpt
Text:
Pesticide
Alternatives
There
are
over
25
pesticides
registered
as
corn
insecticides
and
about
15
are
used
on
significant
acreage.
Use
is
declining
of
the
two
most
frequently
applied
OPs
­­
terbufos
and
chlorpyrifos.
Both
were
applied
to
Section
5.3
Section
5
­
79
about
5
percent
of
national
corn
acres
in
1999
at
a
rate
just
over
one
pound
of
active
ingredient
per
acre.

Together
these
two
insecticides
accounted
for
just
over
75
percent
of
total
insecticide
use
on
corn
in
1999.
Both
are
highly
toxic,
broad­
spectrum
products,
which
pose
a
range
of
risks
to
soil
organisms,
birds
and
fish,
and
the
farmers
and
applicators
handling
the
material.
When
applied
to
cornfields
before
or
at
planting,
these
products
rarely
show
up
as
residues
in
the
food
supply.
Chlorpyrifos
is
found
in
a
high
percentage
of
the
nation's
grain
supply,
including
corn
and
soybeans,
as
a
result
of
use
during
storage
(
see
the
annual
results
of
the
USDA's
"
Pesticide
Data
Program"
residue
testing).

The
most
promising
insecticide
alternative
to
OPs
and
carbofuran
is
the
relatively
new
synthetic
pyrethroid,
tefluthrin
(
Force).
In
1999
this
product
emerged
as
the
clear
market
leader,
with
7
percent
of
acres
treated,
2
percent
more
than
the
next
most
widely
used
insecticides.
The
average
rate
of
application
of
tefluthrin
is
just
one­
tenth
of
a
pound
per
acre.
In
addition,
tefluthrin
is
far
less
toxic
than
the
OPs
and
carbofuran,
especially
to
birds.
For
this
reason
the
widespread
adoption
of
tefluthrin
at
the
expense
of
OPs
and
carbamates
represents
a
significant
decline
in
the
overall
impacts
of
corn
insecticide
use.

Rhone
Poulenc
recently
received
full
registration
for
the
reduced
risk
insecticide
fipronil,
which
was
applied
to
about
1
percent
of
national
acres
in
both
1998
and
1999.
Fipronil
is
also
applied
at
a
relatively
low
rate
­
one­
tenth
of
a
pound
per
acre.
In
addition
there
are
several
other
new
active
ingredients
in
the
product
development
pipelines
of
pesticide
manufacturers.
Most
will
be
applied
at
low
rates
and
will
meet
EPA's
reduced
risk
criteria.

EPA
Response:
Chlorpyrifos
methyl
is
found
in
stored
grain
supplies
due
to
fumigation.
Chlorpyrifos
ethyl
is
used
on
corn
in
the
field.)
The
Agency
agrees
that
tefluthrin
is
the
market
leader.
As
noted
in
the
review,
Force
is
a
restricted
use
product
that
is
very
highly
toxic
to
freshwater
and
estuarine
fish
and
invertebrates.
The
trends
for
adoption
of
fipronil
have
been
considered
in
the
projection
of
insecticide
use
with
and
without
MON
863.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
25
Excerpt
Text:
The
number
and
diversity
of
conventional
pesticide,
reduced­
risk
pesticide,
and
biopesticide
options
for
corn
rootworm
control
reflect
the
interest
of
the
pesticide
industry
in
profiting
from
this
single
largest
insecticide
market.
Farmers
can
now
or
will
soon
be
able
to
choose
from
more
than
a
dozen
conventional
insecticides,
seven
reducedrisk
pesticides,
and
at
least
two
biopesticides.

In
the
case
of
the
leading
synthetic
pyrethroid
"
Force,"
risks
may
be
further
reduced
through
a
new
seed
encapsulation
technology.
Syngenta
has
developed
and
is
actively
marketing
"
Force
ST."
This
system,
targeting
the
larval
stage,
delivers
tefluthrin
insecticide
encapsulated
with
the
seed.
A
small
fraction
of
the
active
ingredient
typically
applied
during
a
field
application
is
required.
With
a
seed
coating,
no
insecticide
is
handled
on
the
farm,
no
above
ground
nontarget
organisms
are
exposed,
and
the
active
ingredient
is
delivered
where
it
is
needed.
This
technology,
to
the
degree
it
proves
effective,
will
further
reduce
the
Section
5.3
Section
5
­
80
amount
of
active
ingredient
applied.

Another
promising
development
in
the
treatment
of
adult
rootworm
beetles
involves
the
application
of
insecticides
formulated
with
baits
containing
cucurbitacins,
derived
from
either
gourd
root
powder
or
watermelons.
Cucurbitacins
are
powerful
and
highly
selective
attractants
for
adult
corn
rootworms.
According
to
a
story
in
the
November
2001
issue
of
Agricultural
Research,
the
"
bait­
and­
kill"
strategy
can
reduce
the
volume
of
insecticide
sprayed
by
a
remarkable
95
percent
to
98
percent.
A
big
advantage
of
this
technology
is
that
traditional
IPM
scouting
and
threshold
techniques
can
be
used
to
target
sprays
to
fields
where
beetle
pressure
appears
high
enough
to
warrant
insecticide
applications.
It
may
also
be
possible
to
adapt
this
technology
to
control
adult
beetles
moving
out
of
corn
into
soybean
fields.

An
August
2001
article
in
the
Journal
of
Economic
Entomology,
however,
documents
the
rapid
onset
of
carbaryl
resistance
in
areas
where
a
high
percent
of
corn
acres
were
treated
with
carbaryl­
cucurbitacin
bait
products.
This
finding
suggests
that
the
technology
places
considerable
selection
pressure
on
populations
because
of
its
efficacy.

In
addition
to
improvements
in
insecticide­
based
options
for
corn
rootworm
management,
a
range
of
cultural
practices,
including
rotations,
remain
highly
effective
in
most
circumstances
in
reducing
corn
rootworm
populations
and
root
damage.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
26
Excerpt
Text:
F.
Transgenic
Crop
Varieties
Engineered
for
Resistance
to
Corn
Rootworms
Are
Under
Development
and
May
Prove
More
Effective
Than
MON
863
Corn.

Developing
corn
varieties
resistant
to
the
corn
rootworm
complex
is
one
of
the
plant
breeder's
most
sought
after
goals.
Tremendous
effort
is
underway
in
the
private
sector,
mostly
using
transgenic
approaches.
Some
public
sector­
funded
breeding
activity
is
underway
to
produce
rootworm
resistant
corn
through
classical
breeder
techniques,
bolstered
by
marker­
assisted
selection.

Four
companies
are
now
actively
working
on
transgenic
corn
for
rootworm
control:
Monsanto,
Dow
AgroSciences,
DuPont/
Pioneer,
and
Syngenta.
Dow
and
Dupont/
Pioneer
are
working
in
partnership
(
Moellenbeck
et
al.,
2001).

Monsanto
has
progressed
farthest
in
product
development,
testing,
and
regulatory
review
with
its
MON
863
technology.
In
a
2001
year­
end
Agrow
review
article
on
Monsanto,
[
Footnote
21:
Agrow,
No.
394,
Feb.
15,
2002,
page
4.]
company
officials
said
that
they
hope
to
introduce
Cry
3Bb
rootworm
protected
corn
in
the
2003
season,
a
goal
that
has
been
slipping
for
two
years.
[
Footnote
22:
For
example,
in
the
November
21
issue
of
Farm
Journal,
Monsanto
was
more
optimistic,
suggesting
limited
commercial
release
in
2002.]

Dow
AgroSciences
and
DuPont/
Pioneer
are
perhaps
about
two
years
behind
Monsanto
with
another
Bt­
Section
5.3
Section
5
­
81
based
technology.
The
February
20,
2002
Federal
Register
contains
a
notice
announcing
the
issuance
of
four
EUPs
to
Dow
and
DuPont
for
their
rootworm
technology.
The
EUPs
cover
only
19
acres
each,
to
be
planted
in
either
Puerto
Rico
or
Hawaii,
evidence
that
this
technology
is
still
in
the
developmental
phase.
[
Footnote
23:
The
Dow
and
DuPont/
Pioneer
product
has
been
described
in
some
detail
in
a
July
2001
article
in
Nature
Biotechnology
(
Vol.
19)
by
a
large
team
led
by
Dr.
Daniel
Moellenbeck
of
Pioneer.
University
of
Minnesota
corn
IPM
expert
Ken
Ostlie
wrote
an
accompanying
"
News
and
Views"
piece
entitled
"
Crafting
crop
resistance
to
corn
rootworms."]

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
35
Excerpt
Text:
8.
Compare
the
risks
and
benefits
of
MON
863
to
the
full
range
of
pest­
control
strategies,
including
the
older
high­
risk
pesticides
that
are
losing
market
share,
reduced
risk
chemical
alternatives,
new
resistant
hybrids
(
both
transgenic
and
traditionally
bred),
and
prevention­
based
biointensive
IPM
systems.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
49
Excerpt
Text:
The
relatively
new
"
reduced
risk"
insecticide
fipronil
(
Aventis's
"
Regent")
was
used
on
4
percent
of
acres
in
2000
and
was
applied
at
0.1
pound
per
acre,
making
it
the
second
most
widely
used
corn
rootworm
product.
Bayer
Corporation
markets
the
combination
product
Aztec,
which
includes
the
OP
tebupirimiphos
and
the
synthetic
pyrethroid
cyfluthrin.
Farmers
using
Aztec
applied
on
average
0.12
pounds
of
tebupirimiphos
and
just
0.006
pounds
of
cyfluthrin
per
acre,
according
to
National
Agricultural
Statistics
Service
data.
This
product
held
about
11
percent
corn
rootworm
market
share
in
2000;
while
an
OP,
tebupirimiphos
is
less
toxic
than
the
leading
OPs
in
this
market
during
most
of
the
1980s
and
1990s
(
phorate,
terbufos,
chlorpyrifos).
As
part
of
its
implementation
of
the
Food
Quality
protection
Act
(
FQPA),
the
EPA
has
calculated
"
Relative
Potency
Factors"
(
RPFs)
for
all
currently
registered
OPs.
Methamidophos
(
Monitor)
is
the
reference
chemical
with
a
RPF
of
one.
Any
pesticide
with
a
RPF
less
than
one
is
less
toxic
than
the
reference
chemical;
any
with
a
RPF
greater
than
one
is
more
toxic.
[
Footnote
18:
Revised
RPFs
for
OP
insecticides
were
issued
April
25,
2002,
by
EPA,
and
are
accessible
at
www.
epa.
gov/
pesticides/
cumulative/
pra­
op/
rpf_
final.
htm.]

The
most
widely
used
OP
corn
rootworm
insecticide
is
Bayer's
terbufos
(
Counter),
which
has
a
RPF
of
0.85
compared
to
tebupirimiphos's
RPF
of
0.22.
Terbufos
is
applied
at
an
average
rate
of
1.14
pounds
per
acre,
10­
times
or
more
the
rate
of
tebupirimiphos
and
other
leading
synthetic
pyrethroid
soil
insecticides.
Lower
rates
of
application
augment
lower
toxicity
in
reducing
the
risks
associated
with
today's
lower­
risk
corn
insecticides
compared
to
older,
higher­
risk
products.
For
example,
the
per­
acre
risks
posed
by
terbufos
are
some
40
times
greater
than
tebupirimiphos,
based
on
EPA's
estimate
of
RPFs
(
one­
tenth
the
application
rate,
one­
fourth
the
toxicity).

Commenter
Name:
Rissler
Section
5.3
Section
5
­
82
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
50
Excerpt
Text:
Widely
used
OP
corn
insecticides
have
chronic
Reference
Doses
­
another
basic
measure
of
chronic
toxicity
used
by
EPA
­
in
the
range
0.0001
to
0.00001
mg/
kg/
day
(
milligrams
fed
per
kilogram
of
body
weight
per
day),
whereas
major
synthetic
pyrethroids
have
chronic
Reference
Doses
between
0.05
and
0.005.
[
Footnote
19:
19
Chronic
Reference
Doses
of
major
pesticides
found
in
food
are
reported
in
Table
3,
"
Update:
Pesticides
in
Children's
Foods,"
Consumers
Union,
May
2000,
accessible
at
www.
ecologicipm.
com/
findings_
CU.
html#
reports
<
http://
www.
ecologicipm.
com/
findings_
CU.
html#
reports>.]
Differences
in
acute
toxicity
are
even
more
striking
EPA
Response:
The
benefit
assessment
has
considered
the
trends
in
insecticide
use
and
the
shift
from
OP's
to
synthetic
pyrethroids
as
well
as
the
increasing
market
share
of
fipronil.
Nevertheless,
the
current
trends
indicate
that
the
majority
of
chemical
use
will
still
be
concentrated
in
the
OP's
and
synthetic
pyrethroids
which
are
all
more
toxic
than
MON
863.
The
use
of
seed
treatments
are
a
positive
factor
in
reducing
insecticide
use
but
are
not
a
complete
substitute
for
MON
863
since
they
only
protect
the
germinating
seed
and
seedling
from
CRW
while
MON
863
has
season
long
protection.
The
introduction
of
MON
863
is
projected
to
significantly
reduce
the
use
of
synthetic
pyrethroids
as
well
as
OPs.

The
Agency
agrees
that
the
acute
and
chronic
toxicity
of
the
chemical
insecticides
commonly
used
to
control
corn
rootworm
exceed
the
acute
and
chronic
toxicity
of
MON
863.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
27
Excerpt
Text:
Syngenta
is
actively
working
on
another
Bt­
based
technology,
although
little
information
is
publicly
available
on
the
toxin
involved,
the
transformation
technology,
performance,
or
timing.
One
possible
reason
for
slower
progress
made
by
Syngenta
is
the
need
for
additional
time
to
integrate
a
new
technology
with
the
potential
to
direct
the
expression
of
Bt
proteins
to
maize
root
systems.
Advanta
B.
V.
is
the
world's
sixth
largest
seed
company
and
was
started
as
a
joint
venture
of
AstraZeneca
(
now
Syngenta)
and
one
of
Europe's
largest
seed
companies,
VanderHave.
On
May
25,
2000
Advanta
Tech
Ltd,
an
operating
arm
of
Advanta
B.
V.,
filed
for
World
Patent
number
0029594,
covering
a
gene
promoter
technology
to
drive
upward
the
expression
of
Bt
toxins
in
corn
plant
roots
for
control
of
Coleopteran
insects,
including
corn
rootworms.
[
Footnote
24:
It
is
not
clear
who
now
controls
this
patent,
since
Advanta
was
not
part
of
the
Novartis­
AstraZeneca
merger
forming
Syngenta.
Since
the
work
was
paid
for
and
done
during
the
period
when
AstraZeneca
controlled
Advanta,
it
is
likely
that
Syngenta
either
now
owns
the
license
to
the
technology
or
will,
at
a
minimum,
have
favorable
access
to
it.]
The
ability
to
assure
markedly
higher
expression
levels
in
roots
compared
to
other
corn
plant
tissues
would
significantly
change
several
risk
parameters,
while
also
posing
less
of
a
physiological
drag
on
plants.
Section
5.3
Section
5
­
83
G.
Nontransgenic
Crop
Varieties
Resistant
to
Corn
Rootworms
Are
Also
Under
Development.

While
the
lion's
share
of
corn
rootworm­
related
breeding
effort
is
directed
toward
transgenic
technologies,
there
are
other
promising
efforts
underway
seeking
to
breed
a
higher
degree
of
resistance
to
corn
rootworms
into
commercial
hybrids
using
classical
breeding
techniques,
augmented
as
possible
through
markerassisted
selection
techniques.

Dr.
Mary
Eubanks,
president
of
a
small
company
called
Sun
Dance
Genetics,
has
worked
for
years
on
corn
genetics.
In
the
late
1980s,
Eubanks
developed
a
technique
that
allowed
her
to
cross
ancient,
wild
strains
of
corn
with
a
wild
relative,
Eastern
gamagrass,
Tripsacum
dactyloides
L.,
a
species
known
for
years
as
highly
tolerant
of
corn
rootworms
(
Eubanks,
2001a).

Past
efforts
to
cross
corn
and
Eastern
gamagrass
had
failed
to
produce
fertile
offspring;
her
newly
discovered
method
overcomes
this
hurdle
(
Eubanks,
2001b).
With
support
from
a
five­
year
National
Science
Foundation
(
NSF)
grant,
Eubanks
worked
throughout
the
1990s
to
move
rootworm
resistance
from
her
crosses
into
commercial
varieties.
Fourteen
generations
of
back­
crosses
have
now
been
completed
and
she
reports
achieving
a
high
level
of
rootworm
control
in
her
2001
plots
(
Eubanks,
2001a).
Data
provided
in
a
2001
final
report
to
the
NSF
document
her
significant
progress
and
suggest
that
with
a
concerted
effort,
classical
breeding
techniques
could
now
produce
viable,
rootworm­
protected
hybrids
within
a
few
years.

EPA
Response:
The
projection
of
benefits
is
based
on
current
technologies
and
the
analysis
does
not
speculate
on
the
impacts
of
future
developments.
While
development
of
non
transgenic
crop
varieties
may
augment
controls
for
corn
rootworm,
cancellation
of
existing
registrations
would
increase
the
benefits
of
MON
863.

Commenter
Name:
Dan
Bolling
Commenter
Organization
Name:
Dan
Bolling
Comment
Number:
30509­
045000
Excerpt
Number:
2
Excerpt
Text:
Alternative
approaches
to
corn
rootworm
exist,
like
better
crop
rotation.
We
are
not
in
a
crisis
without
alternatives
to
Bt
corn.
Before
registration
goes
forward,
a
full
environmental
risk
assessment
must
be
performed,
and
made
available
for
public
review
and
comment,
as
should
be
the
case
with
all
GE
crop
registration
applications.

EPA
Response:
The
Agency
disagrees
with
the
criteria
of
a
crisis
as
the
basis
for
registration.
Furthermore,
the
projections
of
benefits
are
based
on
our
best
estimate
as
to
what
growers
will
do
as
opposed
to
what
they
should
do.
Unless
adopted,
a
less
toxic
alternative
will
not
reduce
use
of
the
more
toxic
products.
Crop
rotation
may
decrease
applications
for
first
year
corn
but
not
eliminate
the
need
for
treatment
for
corn
rootworm.
The
benefit
assessment
notes
that
21.8%
(
12,518,000/
57,310,000)
of
first
year
corn
is
treated
by
an
insecticide,
in
year
2000.
Also,
crop
rotation
may
not
be
feasible
when
the
corn
is
needed
for
other
farm
operations,
a
situation
common
on
dairy
farms
for
example.
Also,
as
noted
in
the
review,
corn
rotation
may
be
losing
efficacy
due
for
northern
and
western
corn
rootworm
due
to
behavioral
adaptations.
