Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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-----------------------------------------: IN RE: :

: Public Forum Roundup Ready Sugar Beet : Draft Environmental Impact Statement :

-----------------------------------------:

Fargo, North Dakota Tuesday, November 15, 2011

The following pages constitute the proceedings

held in the above-captioned matter before the United

States Department of Agriculture Animal and Plant Health

Inspection Service Biotechnology Regulatory Services,

held the Holiday Inn, 3803 13th Avenue South, Harvest

Hall Boardroom, Fargo, North Dakota, before Joy Filipski

of Capital Reporting Company.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 A P P E A R A N C E S 2 Richard George 3 Rebecca Stankiewicz Gabel 4 Neil Hoffman 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4

1 P R O C E E D I N G S 2 (Whereupon, the following proceedings 3 were had to-wit: 4 MR. GEORGE: I want to thank you all for 5 coming out here on a cold afternoon in Fargo, North 6 Dakota. 7 As part of the public participation process, 8 we're holding this public meeting to solicit your 9 comments of the Draft Environmental Impact Statement 10 for H7-1 sugar beets, also known as Glyphosate 11 tolerant, or Roundup Ready sugar beets. 12 My name's Dick George and I'm communications 13 branch chief of Biotechnology Regulatory Services, part 14 of APHIS, the Animal and Plant Health Inspection 15 Service, which, in turn, is part of USDA. 16 So listening to public comments is a very 17 important part of our process. We value your input. 18 We are very glad and grateful that you've taken the 19 trouble to come here today and to be a part of our 20 process. 21 Also with me are Rebecca Stankiewicz Gabel, 22 senior environmental protection specialist. She's 23 working the mike in, in the middle of the room. 24 And also Neil Hoffman, the science advisor to 25 the office of the deputy administrator. Neil has been

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1 I N D E X 2 PUBLIC COMMENTS: PAGE NO. 3 Terry Cayko 8 Steven Sing 12 4 David Berg 17 Curtis Knutson 23 5 Beau Bateman 28 Kelvin Thompsen 30 6 Keith McNamara 35 Marc Stevens 38 7 Douglas Etten 41 David Roche 45 8 Jeff Mortenson 50 Scott Krogstad 52 9 Daniel Olson 53 Craig Steiger 55 10 Mark Herickhoff 61 Mohamed Khan 64 11 Matthew Hasbargen 68 Todd Dvorak 72 12 Eric Erdman 73 Tim Osowski 76 13 Trent Eidem 79 Dane Braun 83 14 Jeff Stachler 84 Troy Newhouse 86 15 Erik Bakke 89 Nathaniel Hultgren 92 16 17 18 19 20 21 22 23 24 25 5

1 taking, signing names at the back of the room. 2 Neil and Rebecca are project managers of this 3 Environmental Impact Statement for H7-1 sugar beets. 4 Our purpose today is to take your comments 5 and to make them part of the public record. 6 You can also enter comments into the public 7 record by going to regulations dot gov, on the web and 8 entering H7-1 sugar beets in the search box. 9 The public comment period ends on December 10 the 13th. 11 All public comments will be considered before 12 a determination is made on the regulatory status of H7- 13 1 sugar beets. 14 On the table in the back of the room, we've 15 placed some handouts, including an Executive Summary of 16 the Draft EIS, fact sheets and other background 17 information. Please feel free to take this 18 information. 19 We are providing speakers three to five 20 minutes to present their comments. We will cut you off 21 at five minutes. You don't have to talk for three 22 minutes if you don't want to, 30 seconds is just fine, 23 but if you, if you have -- if you can say what you want 24 to say in less time, there's nothing wrong with that. 25 If you forgot to note at the sign-in that youCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 would like to speak, so, please do so now at the sign2 in table so we make sure that we don't miss you. 3 Rebecca will be our timer and we'll let you 4 know when your time is up. 5 We appreciate everyone being polite and 6 offering comments in a civil way. 7 In order to give everyone an equal 8 opportunity to speak, it's necessary to enforce the 9 five limit, five-minute time limit, unfortunately. So 10 even if you're not finished, we'll have to move on to 11 the next speaker. We appreciate your understanding. 12 When your name is called, please come to the 13 microphone in the center of the room. Please begin by 14 stating and spelling your name for our court reporter, 15 Joy Filipski, here, here in the corner. 16 A very important part of her job is getting 17 people's names right and getting their affiliations 18 correct. So, please, when you begin to speak, state 19 your name, spell your name and then tell us any 20 affiliation that you have with an organization if, if 21 you have one. 22 Your time will start after you've introduced 23 yourselves. 24 If you haven't already done so, please 25 provide Rebecca the written version of your statement 8

1 discuss or debate the issues or announce these in the 2 Draft EIS. 3 It's very important to remember that any 4 comments provided during this informal session are not 5 on the record. To be on the record, your comments must 6 be provided either during the listening session or as a 7 written comment. 8 This concludes our introduction. We'll now 9 begin to take your comments. And I will take them in 10 the order in which people signed up. 11 And our first comment is -- comes from Terry 12 Cayko. 13 Terry, if you could come to the mike, please. 14 State your name, spell your name and tell us 15 any affiliation if you have one. Thank you. 16 MR. CAYKO: Committee members. My name is 17 Terry Cayko, and it is spelled: T-e-r-r-y C-a-y-k-o. 18 I'm a family farmer growing sugar beets in 19 McKenzie County in northwestern North Dakota along the 20 Montana-North Dakota border. 21 I've grown sugar beets for over 40 years for 22 Sidney Sugars, Incorporated. And I am the past 23 president of the Montana-Dakota Sugar Beet Growers 24 Association and currently serving as a director on the 25 board.

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1 at the end of your, at the end of your five-minute time 2 period. 3 If you, by chance, have a couple of copies 4 of, of what it is you intend to say, it would be 5 helpful if you provided one to our court reporter to 6 have before you speak. If not, that's fine as well. 7 You can also put written comments in the 8 comment box, which is on the table in the left rear of 9 the room. 10 And we also on that table have two copies of 11 the Draft Environmental Impact Statement. You're 12 welcome to look at those, to glance through those, 13 however, they are display copies. 14 If you would like your own copy of the Draft 15 Environmental Impact Statement, Neil Hoffman is holding 16 up a disk. On the table in the back we have a pile of 17 disks of the Draft EIS, you're welcome to take one of 18 those disks. 19 In addition, the Draft EIS is available on 20 our website as well. 21 If we have time after our speakers are 22 finished, we'll have an informal session in the back of 23 the room. 24 The purpose of this session is for us to 25 answer clarifying questions about our process, not to 9

1 I typically farm 370 acres of sugar beets 2 each year. They are in a three-year rotation with 3 spring wheat, barley or durum. 4 For the past four years, 2008 through 2011, I 5 have planted 100 percent of my sugar beets with Roundup 6 Ready seed. 7 I currently grow Roundup Ready sugar beets 8 under compliance agreements between APHIS and Sidney 9 Sugars, Incorporated. 10 I appreciate the hard work reflected in the 11 Draft Environmental Impact Statement prepared by APHIS. 12 I support proposal Alternative 2, full deregulation of 13 Roundup Ready sugar beets. 14 There are many benefits provided by Roundup 15 Ready sugar beet technology. Weed control is a major 16 challenge in sugar beet farming in our growing area. 17 Since we irrigate from the Yellowstone and 18 Missouri Rivers, there are a lot of weed seeds that 19 come into our fields. And to control these weeds before 20 Roundup Ready sugar beets, we had to apply as many as 21 six different herbicides and apply them at four timely 22 applications. 23 You can't always have perfect weather when 24 you have such a narrow window for application when 25 these herb -- different herbicides have to be appliedCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 in five to seven-day intervals. 2 These herbicides are more toxic and you have 3 a longer waiting period after application before your 4 workers can return to the fields. 5 There was always weed escapes and it was hand 6 -- it was hard and scarce to find hand labor and they 7 were very costly. The effect on the sugar beets always 8 stunted growth at least 10 to 14 days. 9 With Round -- Roundup Ready sugar beets, two 10 to three applications is very effective weed control 11 for the growing season. It is also much more flexible 12 in application timing and not as weather dependent. 13 Other environmental benefits include reduced 14 tillage, fewer passes through the fields with tractors, 15 meaning less fuel and lower emissions. Reduced risk 16 herbicides and little or no hand labor equals less 17 human exposure to more toxic chemicals. 18 Good stewardship practices have always 19 contributed to better yields and reduced farming 20 challenges, like weed competition and weed resistance. 21 The partial deregulation and compliance 22 agreements did not meaningfully change the way I farm 23 because key requirements of that program were already 24 part of my farming practices. For example, crop 25 rotation, identification and removal of bolters, weed 12

1 region. Operating costs would increase immensely. 2 Chemical costs would be very high and you may not even 3 be able to obtain these chemicals anymore. 4 Our region would have reduced acreage and may 5 very well cause the factory in Sidney, Montana, to 6 close because there would not be enough sugar beets to 7 run the factory profitably. 8 We would like to be able to turn our 9 operations over to the next generation. 10 Thank you. 11 MR. GEORGE: Thank you, Mr. Cayko. 12 Our next speaker will be Steve Sing, please. 13 MR. SING: Good afternoon. My name is Steven 14 Sing. S-t-e-v-e-n S-i-n-g. 15 And I live in Sidney, Montana. And I've been 16 involved with sugar beet production and processing for 17 36 years. 18 During the first 27 years, I was employed by 19 American Crystal Sugar Company as an agriculturalist, 20 ag manager and ag operations manager. 21 Last nine years, I've been the general 22 manager of Sidney Sugars, Incorporated, in Sidney, 23 Montana. Our growing area covers northeast Montana and 24 northwest North Dakota. 25 Sidney Sugars, Incorporated, is a wholly11

1 resistance training, and maybe most important, 2 application of herbicides at required rates. 3 My Technology Use Agreement with Monsanto 4 also requires that I follow certain stewardship 5 requirements. 6 Before planting Roundup Ready sugar beets, I 7 underwent considerable training on the use of Roundup 8 Ready technology and annual herbicide, weed resistant 9 training. Also, use of crop rotation to reduce weed 10 pressures and the likelihood of resistant weeds through 11 different modes of action are a must. 12 In my growing region, there's no risk of 13 cross-pollination from Roundup Ready sugar beets. 14 First, you don't let beets flower. They are 15 harvested in the first year. They only flower in the 16 second year. There are rare first-year bolters and if 17 they are, they are removed and destroyed. 18 Second, even if a sugar beet were left in the 19 ground, it would not survive the winter in our growing 20 area with wint -- with temperatures well below zero for 21 ex -- extended periods of time. 22 And, third, sexually compatible table beets 23 and chard are not grown in our region. 24 The impact of the loss of Roundup Ready sugar 25 beet technology would be devastating for our growing 13

1 owned subsidiary of American Crystal Sugar Company. 2 The factory's been in continuous operation since 1925. 3 It's been a very important part of the economy in that 4 region of the country. 5 The factory pays more than $45 million to the 6 sugar beet growers for their crop and over $8 million 7 in wages and benefits to our 245 employees. 8 We're one of two sugar beet processing plants 9 in the United States that is not a cooperative. It's a 10 very important fact because of how our contract to grow 11 sugar beets works. 12 A proposed contract is negotiated between 13 Sidney Sugars, Incorporated, and the Montana-Dakota 14 Sugar Beet Growers Association. 15 The contract can cover several years at a 16 time. Individual growers, however, sign a one-year 17 agreement to provide sugar beets to the factory. 18 They can grow the crop one year and if the 19 economics change, they can decide to not grow the crop 20 in subsequent years. 21 The acreage trend since we acquired the 22 factory shows this very well. Declines in weed control 23 effectiveness and resulting poor yields received in 24 some areas cause the growers to look for more 25 economical and profitable avenues to pursue on theirCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 farm. 2 In 2003, growers contracted 41,500 acres. By 3 2008, this total had dropped to 15,300 acres. 4 2009, growers started using a Roundup Ready 5 sugar beet variety extensively and the crop contracted 6 rose to 24,900 acres. And it rose again in 2010 to 7 31,100. 8 All the acres since 2009 have been Roundup 9 Ready sugar beets. 10 Because these new varieties proved to save 11 the growers money, time and reduced exposure to 12 chemicals, the acres contracted in 2011 were 33,200. 13 Sidney Sugars, Incorporated, Incorporated, 14 appreciates the hard work done by many people in APHIS 15 to prepare a thorough Draft Environmental Impact 16 Statement. We support proposal Alternative 2, full 17 deregulate -- deregulation of Roundup Ready sugar 18 beets. 19 Weed control and stand establishment in the 20 spring are two of our, our growers' major challenges. 21 Our growers are very progressive and they fight weeds 22 every year. This is because the irrigation water to 23 grow the crop is provided by an open canal system over 24 400 miles long. New batches of weed seeds are brought 25 into the fields every year through the irrigation 16

1 field, uses less fuel than conventional varieties and 2 lower emissions to the air. 3 Roundup Ready herbicide is also less risky to 4 use than conventional herbicides. Because weeds are 5 efficiently killed by Roundup, fieldworkers are less 6 exposed to chemicals that are more toxic. 7 Our grower practices -- our growers practice 8 good stewardship every year, they always have. They 9 rotate their crops to reduce disease, apply chemicals 10 at the proper rates, identify and remove bolters and 11 attend continuing education classes provided on weed 12 resistance training and proper tillage techniques to 13 reduce erosion. 14 These stewardship practices are part of the 15 annual training provided by the agricultural staff at 16 our grower meetings. 17 If we lose the use of Roundup Ready sugar 18 beet technology, the acres planted for Sidney Sugars, 19 Incorporated, will decline. 20 Their op -- the growers' operating costs and 21 ours will sh -- will rise sharply. They will switch to 22 more profitable crops. This could have a very serious 23 affect on the ability of Sidney Sugars, Incorporated, 24 to survive. 25 If Sidney Sugars, Incorporated, closes its

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1 water. 2 Without Roundup Ready sugar beets, growers 3 must use combinations of herbicides to try to control 4 these weeds. This results in several applications that 5 must be exactly timed and started when the beets are 6 very small. 7 Conventional herbicides needed for weed 8 control inhibit the growth of the small crop and result 9 in a loss of seedlings and reduction in the final 10 stand. 11 Growers can effectively use less chemical to 12 grow the crop by planting Roundup Ready sugar beets. 13 This reduces their cost and increases the yield because 14 the crop is not held back. 15 It is also safer than using several chemicals 16 in combination to accomplish less weed control. 17 Because Roundup reduces the weed pressure, the factory 18 runs much better, we don't have the trash to handle and 19 plug up machinery and reduce the amount of sugar 20 extracted from each ton of sugar beets that the growers 21 deliver. 22 Roundup Ready sugar beets are also 23 environmentally beneficial. Using Roundup herbicide to 24 control weeds reduces the amount of tillage needed to 25 raise the crop. This means fewer trips through the 17

1 doors, it would have a devastating affect on many, many 2 families and business -- businesses in northeastern 3 Montana and northwestern North Dakota. 4 Thank you. 5 MR. GEORGE: Thank you, Mr. Sing. 6 Next will be David Berg, please. 7 MR. BERG: Good afternoon. David Berg. 8 President and chief executive of American Crystal Sugar 9 Company based in Moorhead. 10 On behalf of 2,850 shareholders of American 11 Crystal, we would like to welcome you to the Red River 12 Valley. It is one of the most concentrated and one of 13 the most efficient sugar beet production, processing, 14 production and processing regions in the world. 15 American Crystal's grateful for the 16 opportunity you're giving us today to provide input on 17 a subject of a lot of importance to our grower/owners. 18 We're appreciative of the very open and 19 collaborative approach that USDA has demonstrated in 20 arriving at sound and science-based, decisions based 21 related to the potential deregulation of Roundup Ready 22 sugar beets. 23 As we're aware, the population of the world 24 recently passed the 7-billion person mark. Population 25 growth continues at a dramatic pace. And I don'tCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 believe any of us are in the position to completely 2 rule out a branch of agricultural research or 3 technology. 4 Farmers and food processors must be able to 5 continue to develop their productivity and efficiency. 6 To do otherwise is to condemn literally millions of 7 current and future people to lives of hunger or even 8 starvation. 9 I believe biotechnology's one of the most 10 important tools which farmers must have access to. 11 As I said earlier, there are approximately 12 2,850 shareholders who cooperatively own and operate 13 American Crystal. 14 2011, the company's shareholders harvested 15 approximately 442,000 acres of sugar beets or around 37 16 percent of the total U.S. 17 harvested in the area. Final data are not 18 yet available, but our estimate is that 84 percent of 19 these acres were planted to Roundup Ready varieties. 20 Production of Roundup Ready sugar beets 21 during 2011 at American Crystal was conducted pursuant 22 to the compliance agreements with USDA, consistent with 23 the environmental assessment, assessment issued by the 24 agency earlier this year. 25 To my knowledge, the effort was nearly 20

1 a sugar beet field can be strangled to the level of 2 economic loss by poor weed control. 3 The benefits of Roundup Ready sugar beets are 4 well documented in the Draft EIS and in other 5 publications from USDA, as well as from academic and 6 private researchers. 7 The chief benefits include reduced field 8 tillage, which provides fuel savings. 9 Use of Roundup Ready herbicide means a large 10 volume of alternative, more toxic herbicides can be 11 avoided. 12 Also, the broad spectrum control afforded by 13 Roundup Ready makes it much less likely that hand labor 14 needs to be deployed. 15 It's also important to point out that the 16 ownership structure of American Crystal means a 17 cooperative stock and op -- and overall farming 18 operations are almost always passed from generation to 19 generation. This highlights the importance that 20 farmers in the region place in careful stewardship of 21 their land. They understand and by nature can adapt to 22 their careful measures involved in a partial 23 deregulation in place during 2011. 24 American Crystal provides multiple 25 opportunities each year where agronomy staff delivers

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1 universally successful. 2 Poor early-season growing conditions in the 3 Red River Valley caused many American Crystal growers 4 to remark that they were extremely happy to have access 5 to Roundup Ready this year. 6 Wet field conditions during much -- in -- of 7 May and June would have made it extremely difficult to 8 nearly impossible to perform weed control with 9 conventional varieties this year. 10 American Crystal and its shareholders 11 appreciate the large, careful effort that USDA has 12 contributed in preparation for issue -- issuance of the 13 Draft Environmental Impact Statement on October 11th of 14 this year. 15 We believe the EIS presents an exhaustive 16 record of the potential impacts of use of Roundup Ready 17 and we fully endorse the proposed Alternative 2, full 18 deregulation of Roundup Ready sugar beet technology. 19 My experience at American Crystal includes 20 the position of vice president of agriculture. During 21 the time I held that job, I gained firsthand knowledge 22 of the critical importance of weed control in sugar 23 beet production. 24 A variety of weeds threaten the economic 25 viability of the beet crop, and in, in any single year, 21

1 direct training to small groups of producers. Best 2 practices related to weed control has always been a 3 part of this training. And in the past year, adherence 4 to compliance agreements was a major part. 5 The high prevalence of Roundup Ready 6 varieties among our shareholders indicate this 7 technology's an important element in their agro -- 8 agronomic toolbox. It provides flexibility in the 9 timing of herbicide application during extremely busy 10 periods. This flexibility allows them to perform tasks 11 related to other crops at their farms on, at optimal 12 times, adding to their overall efficiency and success. 13 One important aspect of Roundup Ready 14 varieties may be unique to our northern climate. The 15 preharvest interval for application of Roundup on a 16 sugar beet field is 30 days, while for other 17 nonGlyphosate herbicides, the interval is as long as 90 18 days. 19 In Minnesota and North Dakota, cold spring 20 weather frequently delays planting the sugar beet crop. 21 This frequently means the last permissible date to 22 apply alternative herbicides is beyond the preharvest 23 interval. 24 As a practical matter, this could mean that 25 no herbicide application may be made for criticalCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 periods during the growing season. This could have 2 extremely negative consequences for the affected 3 grower. 4 The very rapid adoption of Roundup Ready 5 varieties among American Crystal shareholders indicates 6 this technology fits their agronomic and economic 7 needs. 8 I believe it's clear that losing Roundup 9 Ready as an option would bring about serious, negative 10 outcomes for individual American Crystal growers and 11 for the cooperative as a whole. 12 These outcomes would be very likely reduced 13 total sugar beet acreage and production which would 14 limit the co-op's total volume. Because sugar beet 15 processing is a high fixed-cost business, having 16 sufficient volume of beets to process is a key economic 17 driver for the company. 18 Reduced acreage and production would have a 19 large, negative effect on grower payment, and, in turn, 20 profitability. 21 In summary, American Crystal's grateful to, 22 grateful to USDA for the work it's done to allow the 23 usage of Roundup Ready technology. Most importantly, 24 the company strongly endorses full dereg -- full 25 deregulation option for which USDA has indicated as its 24

1 We have been raising Roundup Ready sugar 2 beets since 2008. In 2008, we raised 66 percent of our 3 crop using Roundup Ready seeds. And since then, we have 4 been about a hundred percent Roundup Ready grow on our 5 sugar beet crop. 6 We currently raise Roundup Ready sugar beets 7 under the compliance agreement between APHIS and 8 American Crystal Sugar Company. 9 We appreciate the hard work done by APHIS in 10 the Draft Environmental Impact Statement. We fully 11 support Alternative 2, full deregulation of Roundup 12 Ready sugar beets. 13 On our farm, Roundup Ready technology has 14 allowed us to become better producers of sugar. It has 15 allowed us to be -- to better manager of time in the 16 weed growing season. We have much better weed control 17 in our sugar beets, which allows us better yields, less 18 exposure to harsh chemicals for ourselves and for our 19 employees. 20 The costs for, the costs for weed control are 21 similar to growing conventional seeds, but because we 22 can use less tillage and cultivation, Roundup Ready 23 seeds have allowed us to cut our fuel costs, produce 24 less pollution because we are running our tractors 25 less. And we've also have, have less labor costs.

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1 preferred option. 2 Thank you again for this opportunity to share 3 this recommendation today. 4 MR. GEORGE: Thank you, Mr. Berg. 5 Our next speaker is Curt Knutson. 6 MR. KNUTSON: Good afternoon. My name is 7 Curtis Knutson, or Knutson if you're from the 8 Southeast. It's spelled: C-u-r-t-i-s K-n-u-t-s-o-n. 9 I am a farmer. I wish to speak in favor of 10 the USDA's Alternative 2, full dereg -- deregulation of 11 Roundup Ready sugar beets. 12 I have grown sugar beets for 40 years in Polk 13 County in Minnesota. 14 I also serve on the board of directors for 15 American Crystal Sugar Company and currently serve as 16 the chairman of the ag committee for the board. 17 I also work as a sales agent for the Crystal 18 beet seed division. 19 We farm about 4,000 acres of wheat, soybeans 20 and sugar beets. We have a small herd of Angus cattle. 21 We also breed and raise quarter houses for our own use. 22 We also custom farm 1500 acres. Along with raising a 23 thousand acres of sugar beets for American Crystal 24 Sugar Company, we custom farm 500 acres of sugar beets 25 for a neighbor. 25

1 It also lets us be less reliant on good 2 weather, because our window of application for 3 herbicides is much wider. That reduces stress on all 4 our farm employees. 5 Conventional herbicides are more toxic and 6 need to be applied on a five to seven-day interval, 7 even if the weather does not permit and was a dreaded 8 part of our summer growing season. 9 We used to be a five-spray applica -- what 10 used to be a five-spray application season with 11 conventional herbicides is now a two and sometimes 12 three-application season with Roundup Ready seeds and 13 much less time sensitive. 14 Allowing us to pick much better weather 15 conditions to apply herbicide, which -- with, with much 16 less exposure, and above all, much less stress. 17 We are burning much less expensive fuel and 18 putting less harmful emissions into the air. 19 The particular -- the partial deregulation of 20 Roundup Ready technology has not changed our farming 21 practices much. Most of the requirements are the 22 compliance agreement that were already used to meet -- 23 excuse me. Most of the requirements of the compliance 24 agreement were already used to meet the Technology Use 25 Agreement with Monsanto.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 We had already been destroying bolters during 2 the growing season and properly following labels and 3 application of Glyphosate herbicides. Keeping records 4 on seed used and where they were planted has always 5 been part of our farming program before and continues 6 to be applied now. 7 Other requirements on crop rotation and 8 proper training of employees was a part of our farming 9 practices before the com -- compliance agreement. 10 Proper monitoring of resistant weeds and use 11 of proper chemicals has always been part of our weed 12 control program. 13 There is also no risk of cross-pollination of 14 sugar beets in our growing region, region, as we have 15 always rogued bolters as a good husbandry practice. 16 We do not let bolters flower, it is not 17 allowed under the Monsanto agreement. 18 Furthermore, freezing winters virtually 19 ensure that any beet left in the field would not 20 produce a viable seed the following year. It is simply 21 destroyed by the extremely cold winters. 22 If we lost the ability to use Roundup Ready 23 technology on our farm, it would mean reduced sugar 24 production from each acre and increased costs for each 25 growing -- for growing each acre. 28

1 As a sales agent for Crystal seed, it has 2 always been important to sell high quality, high3 producing seeds to my neighbors and friends. 4 Our coopera -- our cooperative has always had 5 a refined system of official multiyear coded tests to 6 ensure good quality seed. That includes testing for 7 traits of disease and pest tolerance, vigor, bolters, 8 purity, stand establishment and sugar yield per acre. 9 This system was in place long before Roundup 10 Ready sugar beets. Each variety must meet standards to 11 be placed on the approved list. 12 Growers in our region must plant only seeds 13 from this approved list. It has ensured that seeds we 14 grow are safe and productive for our region. 15 Our system of approval will continue to do 16 the same in the future. 17 Thank you very much. 18 MR. GEORGE: Thank you, sir. 19 Our next speaker is Beau Bateman. 20 MR. BATEMAN: Good afternoon. My name's Beau 21 Bateman. That's bravo, echo, alpha, uniform. Bateman, 22 like Batman with an E in the middle. 23 I'm a farmer from Grand Forks, North Dakota, 24 we grow sugar beets for American Crystal Sugar Company. 25 I'm also the chairman of the research and education

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1 It would also probably cut our life shorter, 2 due to added stress to an already risky way of life. 3 On the company side of the issue, Roundup 4 Ready technology allows our ag staff to spend much less 5 time on weed control issues with growers. That allows 6 them to concentrate on other important issues that 7 arise like disease outbreaks, crop-size projection -- 8 projections that influence the start-up times for our 9 factories. 10 Growers have adopted the new Roundup Ready 11 technology on a vast majority of their acres. It is 12 estimated that less than 1 percent of our acres will be 13 planted to conventional varieties this coming season. 14 It seems to be a much preferred system of sugar beet 15 production. 16 Because of the ease of Roundup Ready 17 technology, risk from growers, risk from growers moving 18 into alternative crops is reduced, ensuring an adequate 19 supply of raw product to run our mills in an efficient 20 manner. 21 Other crops are easier to grow and with comm 22 -- competitive commodity prices, attracting acres for 23 sugar beets needed has been a problem in the past. 24 With Roundup Ready technology, the risk has been 25 reduced. 29

1 board for Minnesota-North Dakota Sugar Beet Research. 2 So I can talk to you from that perspective. 3 We have, on an annual basis, three-quarters 4 of a million dollars raised by farmers to dedicate 5 towards research. 6 There is a radio program on Public Radio 7 called Car Talk, two brothers, Tom and Ray Magliozzi, 8 seek to determine problems with automobiles through 9 call-in telephone. 10 They eliminate different parts of the problem 11 to try and get to what the person will call in and say 12 is a wobble in my car by asking left turn, right turn, 13 are you going forward, backward, when did it start, 14 have you changed your tires. 15 They need to eliminate all these extra 16 variables, these extra noise, if you will, to determine 17 the problem. 18 In research, we've got a lot more issues than 19 just weed control. But the use of Roundup Ready sugar 20 beets enables us to control the weeds and reduce or 21 eliminate one of the variables in our research projects 22 that makes the rest of the data more clean. It 23 accelerates the adoption of new information, new 24 technology to help us control insects and soil-borne 25 diseases by eliminating the noise that comes from weedCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 control. 2 In addition, we're exploring hyperspectural 3 retina -- reflectance data, airplane and satellite 4 data. If we can reduce the variability of reflectance 5 of a sugar beet crop just as they produce a stress, 6 which would change the reflectance of the beet leaf as 7 recorded, then we can get more consistent data. 8 So from that perspective, those of us farmers 9 that all contribute to research that's spent at the 10 USDA Agricultural Research Center here in Fargo, as 11 well as both land-grant colleges of NDSU and University 12 of Minnesota, we support full deregulation of the 13 Roundup Ready genetic to enable us to accelerate and 14 discover new products to help us control issues beyond 15 simply weeds in the production of sugar beets. 16 Thank you. 17 MR. GEORGE: Thank you very much. 18 Kelvin Thompsen. 19 MR. THOMPSEN: Good afternoon. My name is 20 Kelvin Thompsen. K-e-l-v-i-n T-h-o-m-p-s-e-n. 21 I serve as president and CEO of Southern 22 Minnesota Beet Sugar Cooperative, SMBSC for short, 23 located in Renville, Minnesota. 24 SMBSC was formed in 1975, is a hundred 25 percent grower owned by some 509 shareholder/producers 32

1 percent of the co-op's acreage. 2 In 2011, SMBSC's shareholders planted over 3 119,000 acres using Roundup Ready sugar beet varieties. 4 Prior to 2008, and the availability of 5 Roundup Ready sugar beet varieties, our cooperative 6 relied entirely on the use of tank mixes, which 7 included several conventional herbicides required for 8 weed control. 9 The use of conventional herbicides required 10 many field applications with a very narrow opportunity 11 window for application. 12 Weather and temperature variations negatively 13 impacted the effectiveness of conventional herbicides. 14 Weed control's marginal at best, plant injury was high 15 and the result was lower crop yields and poorer sugar 16 beet quality. 17 In addition, human exposure to more toxic 18 chemical was much greater when our only choice was to 19 use conventional herbicides. 20 Weed control is a significant challenge in 21 sugar beet farming. SMBSC's use of Roundup Ready sugar 22 beet variety since 2008 has significantly improved our 23 weed control, reduced sugar beet plant injury and 24 increased our harvested yields per acre. 25 Many other benefits have been realized with

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1 who raise 120,000 acres of sugar beets. 2 Shareholders' sugar beets are then refined in 3 their factory to produce in excess of 700 million 4 pounds of pure white sugar. 5 SMBSC' sugar production alone is a very 6 essential food ingredient to the diets of nearly 10.8 7 million Americans given today's per capita consumption 8 rate. 9 SMBSC' shareholders produce some 3 million 10 tons of sugar beets in 17 counties located in southern 11 Minnesota. 12 SMBSC's factory employs over 280 year-round 13 people, in addition to 450 seasonal employees during 14 the sugar beet harvest. 15 Sugar beet and sugar production is a vital 16 contributor to the local economies of southern 17 Minnesota, with a cash infusion of nearly $750 million 18 annually. 19 The maintenance of infrastructure, schools, 20 et cetera, of Renville County rely heavily on the 21 nearly $1 million of property taxes paid by SMBSC 22 annually. 23 Roundup Ready sugar beets were first grown by 24 our shareholders in 2008. And by 2010, the adoption of 25 Roundup Ready sugar beet varieties increased to 99 33

1 planting of Roundup Ready sugar beet varieties at 2 Southern Minnesota Beet Sugar, such as fewer passes 3 across the field with a tractor, less fuel required, 4 lower emissions, and more importantly, less human 5 exposure to more toxic chemicals. 6 SMBSC's growing area recorded at least 20 7 inches of rainfall from March to July of 2011. The 8 resultant crop yield was just over 17 tons per acre. 9 Our normal yield prior to this year has averaged nearly 10 26 tons per acre. 11 Although this year's crop yield was depressed 12 by a significant rainfall and cold weather experienced 13 during the growing season, or I should say, lack of a 14 growing season, the end result would have been disaster 15 if our shareholders would have planted conventional 16 sugar beet varieties and used conventional herbicides. 17 Critical application timings required with 18 the use of conventional herbicides would have been so 19 disrupted by the frequent rain -- rainfall, that weed 20 growth would have surpassed crop growth. Many fields 21 would have been abandoned and crop yields would have 22 been significantly less than they were. 23 This would have been an economic disaster for 24 Southern Minnesota Beet Sugar Cooperative and the 25 economies in southern Minnesota.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 The planting of Roundup Ready sugar beet 2 varieties in SMBSC's growing area in 2011 avoided 3 serious economic disaster for the cooperative and its 4 shareholders. 5 In addition, any future loss of the Roundup 6 Ready technology would force growers to produce crops 7 other than sugar beets and reduce the available sugar 8 beet acreage to our cooperative. 9 Lower sugar beet volume would increase 10 operating costs, lower shareholder payments to a point 11 at which the cooperative's sustainability could be very 12 short-term. 13 Prior to the partial deregulation of Roundup 14 Ready sugar beet, our shareholders already implemented 15 good stewardship practices. Lengthening of crop 16 rotations to assist in dise -- disease control, 17 alternation of fungicide chemistries to reduce disease 18 resistance, application of herbicides at required rates 19 and weed resistance training are just a few examples of 20 good stewardship practices which have been in place for 21 several years. 22 SMBSC appreciates the hard work by APHIS, 23 which is reflected in the Draft Environmental Impact 24 Statement. SMBSC strongly supports proposed 25 Alternative No. 2 in the Draft EIS for the full 36

1 annually on our farm in a four-year rotation. We have 2 grown Roundup Ready sugar beets for four years. 3 In 2008, when Roundup Ready sugar beets came 4 out, we planted our allotted amount. In 2009 and '10, 5 we have planted a, a hundred percent Roundup Ready 6 sugar beets. 7 I currently grow Roundup Ready sugar beets 8 under compliance agreements between APHIS and Southern 9 Minnesota Beet Sugar Cooperative. 10 The use of Roundup Ready technology in sugar 11 beets has allowed for many bene -- beneficial 12 agronomic, cultural changes to take place in our 13 operation. Weed control in our sugar beets is achieved 14 in three sprayings versus five sprayings for a 15 conventional sugar beet herbicide. 16 Roundup Ready technology has a greater window 17 for timing of application in comparison to the 18 conventional herbicide that had to be sprayed on a 19 strict seven to ten-day interval. 20 We are able to maintain season-long control 21 without expensive hand laborers that are hard to find. 22 Row crop cultivation is virtually eliminated 23 as weed co -- as a weed control aid. Less passes in the 24 field means less diesel fuel burnt and results in more 25 soil conservation.

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1 deregulation of Roundup Ready sugar beets. 2 Thank you for your time. 3 MR. GEORGE: Thank you. 4 Keith McNamara. 5 MR. McNAMARA: Good evening. My name's Keith 6 McNamara. K-e-i-t-h. McNamara, M-c-N-a-m-a-r-a. 7 I reside on our third-generation family farm 8 near Bird Island, Minnesota. I am a farm operator. 9 Farm -- our farm operation cultivates land in Renville 10 and surrounding counties in southern Minnesota. 11 I've grown sugar beets for 18 years and our 12 family unit has grown sugar beets since the 1960s. 13 Growing sugar beets on our farm is a part of my 14 heritage and has allowed for economic stability. 15 And I've served on the Southern Minnesota 16 Beet Sugar Cooperative board since 2003, in various 17 roles, and served on numerous board committee. 18 And I've also served on the Sugar Beet 19 Research and Education Board of Minnesota and North 20 Dakota for the past three years. Last year, I was 21 elected to the American Sugar Beet Growers board. 22 The crops that are grown in our cropping 23 rotation are corn and soybean, navy beans, sugar beets 24 and some alfalfa. 25 We raise a thousand acres of sugar beets 37

1 The quality of life goes up because we are 2 not exposed to as many harmful toxins and have more 3 time for family. 4 My personal sugar beet yields in 2011 were 5 not exceptional, but I still am grateful to have been 6 able to plant Roundup Ready sugar beets in 2011. 7 Without it, our crop would have been a total disaster. 8 And with the wet spring, we were unable to have 9 consistent application. And thanks to this technology, 10 we'll still -- we were still able to achieve weed 11 control and a reasonable crop for the challenging year 12 it was. 13 The shareholder resources committee and staff 14 at SMBSC go to great lengths to ensure that our growers 15 obtain the best possible seed for the upcoming sugar 16 beet crops. The committee diligently reviews the 17 entries that are entered into the coded variety trials. 18 Factors that are evaluated in candidate 19 varieties are: disease tolerance, performance in our 20 growing region, observation for bolters, varietal 21 purity, stand establishment, yield in both tons per 22 acre and re -- recoverable sugar per acre. 23 When varieties have met our three-year 24 testing period, period criteria, they are placed on a 25 fully-approved variety list.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 Our growers at SMBSC can only plant what is 2 offered on this approved list. This process is very 3 important to the long-term viability of SMBSC. It was 4 in place prior to the Roundup Ready sugar beets. 5 I have great appreciation for the effort that 6 has gone into the Draft Environmental Impact Statement 7 prepared by APHIS. 8 As a grower, director -- direct -- and 9 shareholder, I support full deregulation of Roundup 10 Ready sugar beets described as Alternative No. 2 in the 11 Draft EIS. 12 Thank you. 13 MR. GEORGE: Thank you. 14 Next is Marc Stevens. 15 MR. STEVENS: Thank you for allowing me to 16 speak this afternoon. My name is Marc Stevens. M-a-r17 c S-t-e-v-e-n-s. 18 I live and work on the farm I grew up on 19 northeast of Montevideo, Minnesota. My wife and I have 20 farmed since I graduated from the University of 21 Minnesota in 1987. 22 I bought my first beet shares in 1990. And 23 currently raise sugar beets, corn, soybeans, sweet corn 24 and sweet peas. We farm about 1400 acres, 25 predominantly with family labor. 40

1 application in comparison to conventional herbicides 2 that had to be sprayed on a strict seven to ten-day 3 schedule. 4 I'm able to maintain season-long weed control 5 without hand laborers with the addition of Roundup to 6 our available chemicals. 7 I still have my row crop cultivators, but did 8 not have to use them this last year. 9 Less passes in the field means less diesel 10 fuel used and results in more, more soil conservation. 11 But more importantly, fewer passes in the fields means 12 I have more time to spend with my family. 13 As stated earlier, I have great faith in the 14 Roundup Ready technology and believe it to be safe for 15 myself, my family and the people around the world who 16 are benefited by the production of safe, affordable 17 food that U.S. farmers raise. 18 I have a great appreciate for the effort that 19 has gone into the Draft EIS prepared by APHIS. 20 As a SMBSC grower, shareholder and director, 21 I support Alternative 2, full deregulation of Roundup 22 Ready sugar beets in the Draft EIS. 23 Thank you. 24 MR. GEORGE: Thank you. 25 Our next speaker is Douglas Etten.

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1 Growing sugar beets on our farm is a vital 2 part of my operation and has allowed for a longer 3 rotation and economic diversity. 4 I have served on the Southern Minnesota Beet 5 Sugar Cooperative board since 2008 and have 6 participated on numerous board committees since 7 joining. I've also been active at the county and state 8 level of other commodity groups and Minnesota Farm 9 Bureau. 10 I was slow to adopt Roundup Ready technology 11 when it became available in soybeans but was quick to 12 adopt it in sugar beets, due to my understanding and 13 faith in the technology. 14 I've grown Roundup Ready sugar beets for four 15 years. I currently grow Roundup Ready sugar beets 16 under compliance agreements between APHIS and Southern 17 Minnesota Beet Sugar Cooperative. 18 The use of Roundup Ready technology in sugar 19 beets has allowed for many beneficial agronomic and 20 cultural changes to take place in my operation. 21 With Roundup available to me, I have a tool 22 that gives me confidence in being able to control tough 23 weeds even when Mother Nature throws me curve balls, 24 like this past growth -- growing season. 25 Roundup has a greater window for timing of 41

1 MR. ETTEN: Good afternoon. I'm Doug Etten, 2 E-t-t-e-n. 3 I raise sugar beets in Wilkin County, in west 4 central Minnesota. And I've grown beets since 1974 for 5 Minn-Dak Farmers Co-op. I've been on the board of 6 directors since 1997, and for the past four years, have 7 had the honor to serve as chairman. 8 I also serve on the board of directors of the 9 American Sugar Beet Growers and, for the past number of 10 years and continue in that role currently. 11 I farm together with my two sons and we 12 typically raise around 1200 acres of sugar beets. 13 We've had access to Roundup Ready sugar beets 14 since 2008, when we had around 50 percent Roundup Ready 15 seed. 16 Since that time, we've had a hundred percent 17 Roundup Ready beet seed. 18 For 2011, we were very grateful to have the 19 ability to raise Roundup beets under the compliance 20 agreements between APHIS and Minn-Dak Farmers Co-op 21 through the partial, partial deregulation. 22 And we now have the Draft EIS available for 23 comments and we appreciate all the hard work that APHIS 24 has done and got this together for going forward. 25 For the sugar beet crop under theCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 conventional system, weed control was always a 2 challenge. Whenever we would encounter reduced stands 3 of beets in areas of a field, or entire fields, we 4 would inevit -- inevitably have a weed-infested mess to 5 deal with. 6 The chemicals we had available were 7 ineffective, since the weeds quickly became too large 8 to control when the sugar beets did not form a good 9 canopy. 10 With the option of Roundup Ready beets, we 11 can now control the weeds in those problem areas. And 12 this has led to better, cleaner and higher, higher 13 quality crops for our farm. 14 This past year, our co-op experienced excess 15 moisture for roughly two-thirds of the growing season 16 over a large portion of our 120,000 acres. 17 Many of the fields in these areas suffered 18 from sickly beets and reduced stands, which is the 19 perfect scenario for weeds to thrive. 20 Under the con -- conventional system, we 21 would have needed to spray these fields three to four 22 times at seven-day intervals, with a tank mix of 23 anywhere from three to five different chemicals, plus 24 additives. 25 With the frequent rain events of a year like 44

1 This has the potential to save on some of our 2 fall, tillage in the preceding fall and also leave more 3 residue on the surface, which is a -- good for the 4 environment and the carbon and all, all that besides. 5 All these things lead to less fuel 6 consumption and equipment wear and tear. 7 With all the potential for the environmental 8 benefits, it's hard to imagine how so-called 9 environmentalists can argue against this technology. 10 Especially since Glyphosate is also a lower-risk 11 chemical than the conventional chemicals we have 12 available. 13 To address the issue of re -- of weed 14 resistance on our farm, we have started the use of 15 different families of chemicals on our corn and soybean 16 crops. 17 We use Glyphosate on the corn, plus another 18 pass with Status. 19 On soybeans, we're switching to other modes 20 of action, such as LibertyLink soybeans. 21 We also have wheat in our four-year rotation 22 and we treat the wheat with Bronate, which also helps 23 to stop any chance of resistance developing. 24 For the past four years, under the Roundup 25 Ready stewardship agreement, we have had the

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1 we experienced in 2011, that spray schedule becomes 2 impossible to manage and the weeds quickly can take 3 over. 4 But now with Glyphosate, those weeds that get 5 too large can still be controlled. 6 Typically Glyphosate takes care of a field in 7 two passes, but in, in years like this, with extreme 8 cases of weeds, we sometimes need a third pass. 9 Under the conventional system, many of the 10 fields in these wet areas would have been abandoned 11 this year due to the weeds. But with Roundup beets, 12 these fields were almost totally harvested. 13 This difference also has a huge financial 14 impact to our crop insurance. 15 With the introduction of Roundup Ready beets, 16 we have the abilit -- ability to become more environ -- 17 environmentally friendly as well. 18 As mentioned, we can reduce field passes for 19 spraying by two times on average. We can also reduce 20 our tillage significantly. 21 The need to cultivate after planting is 22 almost eliminated, saving two to three passes. 23 This also allows us to leave more residue on 24 the surface without the problem of plugging our 25 cultivators. 45

1 responsibility to control bolters. Most years' bolters 2 are nonevents, as was the case on our, on our farm in 3 crop year 2010. 4 On our 1200 acres, we removed a total of four 5 bolters. So with roughly 40,000 plants per acre, that 6 amounts to one bolter for each 120 million plants. 7 In 2011, one variety had some additional 8 bolters, but still a very controllable amount. 9 Having grown sugar beets for 37 years and 10 seeing a minimal presence of bolters each year, to my 11 knowledge, we have never had a cross-pollination -- 12 crop -- cross-pollination issue with any other plants 13 in our region. 14 So for all of the above-mentioned reasons, I 15 strongly support Alternative 2, full deregulation of 16 Roundup Ready sugar beets. 17 Thank you. 18 MR. GEORGE: Thank you, Doug Etten. Sorry 19 about your name. 20 I got it right this time, did I? 21 MR. ETTEN: Thank you. 22 MR. GEORGE: David Roche. 23 MR. ROCHE: Good afternoon. 24 My name is David Roche, R-o-c-h-e. 25 I am the president and chief executiveCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 officer of Minn-Dak Farmers Cooperative, located in 2 Wahpeton, North Dakota. 3 Our cooperative is owned by approximately 500 4 local shareholders who are all active in the growing of 5 sugar beets on their farms and rented acreage. 6 Our co-op, in 2011, contracted with 7 shareholders to plant, manage, harvest and deliver 8 about 120,000 acres of sugar beets. 9 In our most recently completed fiscal year, 10 revenue generated from the 2010 crop exceeded $345 11 million, representing the sales proceeds from the more 12 than 722 million pounds of sugar and co-products 13 produced from the crop. 14 For the past four years, virtually all of our 15 contracted acreage has been grown to Roundup Ready 16 sugar beets, including the 2011 crop year, which was 17 grown in accordance with regulations as required under 18 the partial deregulation of Roundup Ready sugar beet 19 seed. 20 The benefits of Roundup Ready sugar beet seed 21 to farmers have been well documented in prior comments 22 submitted in regard to the environmental assessment and 23 partial deregulation of Roundup Ready sugar beet seed. 24 I would like to comment on the importance of 25 Roundup Ready sugar beet seed to our cooperatives' 48

1 Although the yield, in terms of tons of sugar 2 beets per acre, was low, those beets are very valuable 3 to our cooperative in terms of more fully utilizing our 4 processing capacity. 5 In addition, had those 20,000 acres been 6 abandoned, and not harvested, in the absence of Roundup 7 seed, they would have lar -- they would have likely 8 generated more than $7 million crop insurance claim, or 9 claims. 10 Instead, those beets are being processed and 11 it's estimated they will generate approximately $9.7 12 million in revenue for our farmer/shareholders. 13 Minn-Dak Farmers Cooperative recommends to 14 our shareholder/growers that this type of technology be 15 respected in the highest regard and, therefore, be 16 preserved for generations to come. 17 Our cooperative has taken a very proactive 18 approach to the issue of weed resistance associated 19 with the use of the Roundup Ready system, not only in 20 sugar beets, but in the rotational crops as well. 21 Minn-Dak has and continues to convey this 22 important message to all of our shareholder/growers 23 through newsletters, meetings, grower-directed contact 24 with our ag staff. 25 If our farmer/shareholders were to lose the

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1 shareholders from both the perspective of farm 2 management and with regard to the impact on our sugar 3 beet processing cooperative. 4 Some of the benefits -- excuse me -- to the 5 sugar beet processing cooperatives, like ours, are 6 listed below. 7 With superior weed control, due to the use of 8 Roundup Ready sugar beet seed, our farmers have 9 experienced both increased yields and reduced operating 10 costs on their farms. 11 The Roundup Ready sugar beet seed weed 12 control regimen is much less complex to manage, this 13 allowed for reduced use of other sugar -- herbicides. 14 During the 2011 crop year, most of our 15 growing areas were impacted by excessive rainfall, as 16 you've heard mentioned this afternoon. 17 Without the use of Roundup Ready sugar beet 18 seed, it's estimated we would have lost approximately 19 20,000 acres of growing crop due to saturated fields 20 being overtaken by weeds and made to be unharvestable. 21 Since these 20,000 acres of rain-damaged 22 sugar beets, which came from Roundup seed, were able to 23 be harvested, our cooperative had 150,000 tons of 24 additional sugar beets to process, than would have been 25 otherwise possible. 49

1 ability to utilize Roundup Ready sugar beet seed, our 2 cooperative would likely experience a significant 3 decline in the volume of sugar beets to process. 4 With the added costs, complexity and risk 5 associated with conventional seed, many shareholders 6 would likely plant at only minimum levels or sell their 7 stock in the cooperative. 8 With su -- with reduced interest in sugar 9 beet production, more sellers of cooperative stock than 10 buyers, the value of cooperative stock would likely 11 diminish significantly. 12 Minn-Dak Farmers Cooperative certainly 13 appreciates the hard work by the Department in the 14 preparation of the Draft Environmental Impact 15 Statement. We strongly support Alternative 2, which is 16 full deregulation of Roundup Ready sugar beets. 17 Thank you. 18 MR. GEORGE: Thank you. 19 Next is Matt Hasbargen. 20 Matt? 21 He's not here? 22 MR. ROCHE: Matt is one of our growers, and 23 he was anticipating being a little bit delayed, if he 24 could save his place for a little later, that would be 25 appreciated.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 MR. GEORGE: No problem. 2 MR. ROCHE: Thank you. 3 MR. GEORGE: In that case, we'll go to 4 Jeffrey Mortenson, please. 5 MR. MORTENSON: My name is Jeff Mortenson. 6 J-e-f-f M-o-r-t-e-n-s-o-n. 7 I'm a farmer from Kennedy, Minnesota. I 8 currently raise wheat, soybeans and sugar beets. 9 I've grown sugar beets with my brother for 14 10 years for the American Crystal Sugar Company. 11 My family has raised sugar beets since 1965 12 for American Crystal Sugar Company. 13 We currently grow about 650 acres of sugar 14 beets each year. 15 The first two years available to us, we 16 planted roughly 25 percent of our acreage to Roundup 17 Ready sugar beets. Then the following years, we went 18 to a hundred percent Roundup Ready sugar beets on our, 19 on our crop. 20 I am very appreciative of the work that APHIS 21 did, which allowed us to grow the Roundup Ready sugar 22 beets this past growing season. 23 But with all due respect, I feel that those 24 rules are really unnecessary. I am here to offer my 25 full support for full deregulation of Roundup Ready 52

1 to offer my support, again, for full deregulation of 2 the Roundup Ready sugar beets. 3 MR. GEORGE: Thank you very much. 4 Scott Krogstad. 5 MR. KROGSTAD: My name is Scott Krogstad. S6 c-o-t-t K-r-o-g-s-t-a-d. 7 I'm a farmer from Thompson, North Dakota, in, 8 which is in Grand Forks. And we also farm in Traill 9 County, in eastern North Dakota. 10 I represent our family farm. We grow about 11 1400 acres of sugar beets, along with corn, soybeans 12 and edible beans and wheat. 13 On our farm, we switched to Roundup Ready. 14 We were, we were 50 percent Roundup Ready in 2008 and 15 have been a hundred percent since then. 16 And I'd just like to make a couple comments 17 that maybe haven't been addressed totally. 18 I agree with everything else that's been 19 said. 20 On our soil, we have some fairly light soil 21 and the -- being able to go without cultivation has 22 really reduced our soil erosion and obviously fuel, 23 fuel consumption. 24 The Jeff before me did mention about less 25 water use. Using Roundup, we only use 5 gallons of

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1 sugar beets. 2 The use of Roundup Ready technology has had 3 many benefits. 4 With conventional beets, we used to spray 5 anywhere from four to five, and sometimes six times a 6 year for weed control, with the combination of six to 7 seven different types of chemicals in each pass. 8 With Roundup, we are using roughly three less 9 sprays to control weeds. And so just with that, the 10 water we are saving on our farm is roughly 20,000 11 gallons of less water being used with less 12 applications. 13 Also, that means less diesel fuel being used 14 and less exhaust emitted into the air, which is also 15 good for the environment. 16 I feel there should be no concern in growing 17 Roundup Ready sugar beets in the Red River Valley. 18 There's no risk of cross-pollination. We are already 19 required to remove the bolters with our Monsanto 20 technology agreements. And also beets in our area do 21 not over winter survive with the freezing temperatures. 22 So, again, I feel that there's no reason for 23 anyone to be concerned with the farmers growing Roundup 24 Ready sugar beets. 25 I would like to thank you for the opportunity 53

1 water per acre, where before, we were using 20 gallons 2 of water per acre on each spray, so that -- do the 3 math, that's, that's a lot of water that we're not 4 using and that's beneficial to the environment. 5 And I would also like to mention the, the 6 chemical use. In the, the subsequent year following 7 Roundup beets, we use a lot less chemical on whatever 8 crop we're, we're spraying because the fields are that 9 much cleaner. So I think that's a very positive impact 10 to the environment, reduction of -- in chemical use. 11 Representing our farm, we definitely want to 12 support the full deregulation of, of Roundup Ready 13 sugar beets. 14 Thank you. 15 MR. GEORGE: Thank you. 16 Daniel Olson. 17 MR. OLSON: Daniel Olson. D-a-n-i-e-l O-l-s18 o-n. 19 First grade was the tougher years of my life. 20 And I farm, I farm in Reynolds, North Dakota, 21 and raise sugar beets for American Crystal. I grow 22 about 400 acres of sugar beets. Since the deregulation 23 of Roundup sugar beets, I have steadily increased my 24 acres in Roundup Ready sugar beets. I planted a 25 hundred percent Roundup Ready for the first time lastCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 year. 2 The biggest benefit I saw was the convenience 3 of spraying later for the first shot of Glyphosate. I 4 typically would spray three times in the conventional 5 system before I would spray once in the Roundup Ready 6 system. 7 I was able to focus on planting my other 8 crops on a timely basis, rather than spend time 9 spraying the sugar beets, the conventional sugar beets. 10 That is very important, because sometimes we 11 have only a short window to work in to plant the other 12 crops. 13 Early planting is very important in our area 14 for crops like wheat and corn. 15 The other major benefit of Roundup Ready 16 beets is that the next year, the fields have less 17 weeds, so I am reducing my chemical usage on the other 18 crops. 19 And I thank you for all your hard work your 20 agency has done to ensure that we can utilize this 21 valuable tool. 22 I support full deregulation of Roundup Ready 23 sugar beets and appreciate all your work you have done 24 on behalf of the Environmental Impact Statement. 25 There have been no problems with Roundup 56

1 members of American Crystal Sugar Company. We also 2 raise spring wheat, dry edible beans, soybeans and 3 sunflowers. 4 Our farm typically raises 700 acres of sugar 5 beets each year. We have planted a hundred percent 6 Roundup Ready sugar beets since 2008, when they were 7 first approved. 8 We currently grow Roundup sugar beets, 9 Roundup Ready sugar beets under the current compliance 10 agreement between APHIS and American Crystal Sugar 11 Company. 12 I am here today to speak in support of full 13 deregulation of Roundup Ready sugar beets. 14 I can certainly respect the time and effort 15 that has already been put forth in the Draft 16 Environmental Impact Statement prepared by APHIS. 17 I would like to speak a little today on how 18 the use of technology of Roundup Ready sugar beets 19 benefits my farm and the co-op that I am a member of. 20 Prior to raising Roundup Ready sugar beets, 21 weed control was the biggest challenge we had in 22 raising our crop of sugar beets. 23 Using conventional sugar beet -- herbicides 24 on our sugar beet crop was labor-intensive and costly. 25 The selection of herb -- herbicides for use in growth

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1 Ready beets on my farm since I started planting them in 2 2008. We've never had a problem with conventional 3 beets as a weed, so I don't know why we would have a 4 problem with Roundup Ready beets as a weed. The 5 chemicals we use in our rotational crops take care of 6 them. 7 The loss of this technology would be a step 8 back for production for sugar beets and for the other 9 crops. 10 There's supposed to be 9 billion people on 11 this planet by 2050. How will we feed all those people 12 if our technology is limited? 13 MR. GEORGE: Thank you. 14 Craig Steiger. 15 MR. STEIGER: Craig Steiger. C-r-a-i-g S-t-e16 i-g-e-r. 17 Thank you for the opportunity to speak to you 18 today. 19 I farm near Cavalier, North Dakota, located 20 in the northeast corner of the state. I'm the fourth 21 generation to operate this farm. 22 I currently farm with my father and I've been 23 engaged in the oper -- I've been engaged in the 24 operation since 1991. 25 We raise sugar beets on our farm as co-op 57

1 of sugar beets was limited and the herbicides were not 2 always effective. Because of that, limited 3 effectiveness, timing of application was important. 4 During peak weed control times, our farm had 5 labor that was dedicated to nothing but herbicide 6 application on sugar beets. 7 That cost of labor could be doing other 8 things on a diversified farm. 9 We sometimes found ourselves pushing the 10 envelope, envelope on proper application. Sometimes 11 applications were made at very odd times of the day to 12 increase effectiveness. 13 Rates were cut to avoid damage to beets and 14 the number of applications were increased. Four 15 applications per season on our farm was common. 16 And because of the limitations with these 17 herbicides, tank mixes of several different herbicides 18 were often used, creating a mixture that could 19 sometimes cause problems in the sprayer as well as 20 cause crop damage and increased chance of exposure to 21 workers. 22 The limitations of these herbicides often 23 created the need to hire hand labor to remove weed 24 escapes from sugar beet fields. Good hand labor was 25 becoming increasingly, increasingly expensive and hardCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 to find. 2 Hand weeding, in the last several years, 3 prior to Roundup Ready sugar beet, was often abandoned 4 and many farms suffered economic loss on their crop to 5 avoid the expense and hassle of finding good labor. 6 This resulted in not only a loss to, to farms, but 7 economic loss to our, our co-op. 8 Having Roundup Ready sugar beets available on 9 our farm is all about us becoming more productive and 10 more efficient and being better stewards of our land 11 and employees. 12 Timing of the application is not nearly as 13 big an issue. Application happens in a manner that is 14 much friendlier to the environment because we can 15 afford to wait out rain and wind events. 16 Tank mixing of herbicides has been 17 eliminated, creating fewer chances of exposure to 18 workers. 19 Application of Roundup is most often only two 20 applications per season on our farm, resulting in near 21 perfect weed control, with no damage to the sugar beet 22 crop. 23 Eliminating weed competition increases 24 yields. Eliminating two trips across the field with 25 sprayers reduces cost by saving time and fuel. 60

1 crop safety, employee safety and environmental -- 2 environmentally safer alternative form of herbicide 3 than was previously available. 4 Our farm certainly looks forward to the 5 future of many similar advances that Roundup Ready 6 sugar beets has given to us. 7 Thank you for taking the time to consider and 8 evaluate this tool for sugar beet growers in this 9 region and, and across the country. 10 Thank you for allowing me to share my 11 thoughts today. 12 MR. GEORGE: Thank you. 13 Marc Stevens, please? 14 MR. STEVENS: I already spoke. 15 MR. GEORGE: Sorry? 16 Marc Stevens? 17 MS. STANKIEWICZ GABEL: He already -- 18 MR. GEORGE: Steven -- 19 MS. STANKIEWICZ GABEL: -- spoke. 20 MR. GEORGE: Uhm? 21 MS. STANKIEWICZ GABEL: He already spoke. 22 MR. GEORGE: Oh, forgot to tell me. 23 There's a question mark, Steve Fritz? 24 No. Okay, decided not to. 25 Mark Herickhoff.

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1 We have not used hand labor in sugar beet 2 fields on our farm since the introduction of Roundup 3 Ready sugar beets, reducing chance of exposure of 4 pesticide residue to workers. 5 And researchers confirm that Glyphosate is 6 much safer to people and the environment than 7 herbicides we previously had available. 8 Roundup Ready sugar beets has had a very 9 significant, positive impact on my farm and for 10 American Crystal Sugar Company. Overall, overall yield 11 and quality have improved considerably since the 12 introduction of this technology. 13 We have always strived for excellent weed 14 control, but now we are able to do it efficiently and 15 have excellent results. 16 Yields have increased enough that we can 17 raise more sugar on fewer acres, allowing us to use 18 some of those acres to di -- diversify into other 19 crops, increasing productivity on our farm. 20 Our farm, as well as many others in this 21 region, strives to imple -- implement new technology 22 that has been proven to give us a return on investment. 23 Roundup Ready sugar beets has been one tool 24 available to us that's given us more than a financial 25 return, it has given us very reliable weed control, 61

1 MR. HERICKHOFF: Good evening. 2 I'm -- my name is Mark Herickhoff, spelled: 3 H-e-r-i-c-k-h-o-f-f. 4 And I'm from Belgrade, Minnesota. We grow for 5 Southern Minnesota Sugar at Renville. 6 And I've farmed for approximately 40 years. 7 And I've grown sugar beets for about 12 years. And I 8 don't have a title. 9 But I'd like to give you the Paul Harvey part 10 of this story, okay. 11 I have, I've, I've sprayed ditches for our 12 local Watershed District for a number of years. And I 13 needed to have a -- special endorsements to do that. 14 So we -- I had to go to these classes, okay, to get 15 this commercial applicator's license. 16 And I was over at Detroit Lakes, Minnesota, 17 here, three years ago, to get this endorsement. 18 And, of course, the classes are all day. And 19 they're put on in January. And, and the -- a couple 20 people that were putting this on, had on the screen, 21 they had a list of the chemicals that they had found in 22 the Mississippi River. 23 And there were about four to five different 24 chemical families, okay. 25 Some of them were -- like Atrazine was at theCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 top, I recall that. Velossa was in there, and a few of 2 the, the common ones that we all, that we all can 3 relate to. 4 And I'm sitting there and I'm saying: holy 5 cow, doesn't anybody -- isn't anybody going to ask 6 about Roundup, you know? Haven't, haven't they found 7 Roundup? 8 And nobody did, you know. 9 So I finally raised my hand and I said: 10 where's Roundup? 11 You know, Roundup's been out for about 20 12 years, maybe 15, okay. 13 And the guy said: well, he said, we can't 14 find it. 15 And I says: what are you talking about? 16 It's been out for 15 years and you haven't 17 been able to detect Roundup? 18 No, he said, we, we have no technology that 19 can detect Roundup. 20 I didn't pursue it. I would like to have 21 said a lot more. But, you've got to remember, the 22 regulators are sitting in the back of the room, so if 23 they get your number, you know, they may be calling on 24 you. 25 But, anyway, I think the bottom line of this 64

1 So I think we need to think about that. 2 I think the bolter thing is a joke, total 3 joke. On our 1500 acres of beets, we didn't have any 4 reports from our staff or people that -- so -- I don't 5 know what others have found. 6 But to me it's just a joke. There's no other 7 way to say it, it's, it's wasting your time and our 8 money. 9 And so, with that, I guess I support full 10 dereg -- deregulation and -- of the Roundup Ready sugar 11 beet. 12 MR. GEORGE: Thank you very much. 13 MR. HERICKHOFF: Thank you. 14 MR. GEORGE: David Berg. 15 MR. BERG: I already had my turn, thank you. 16 MR. GEORGE: Mohamed Khan. 17 Thank you. 18 MR. KHAN: Good after -- good afternoon and, 19 thank you, Mr. Chairman. 20 My name is Mohamed Khan. M-o-h-a-m-e-d K-h-a21 n. 22 And I'm the extension sugar beet specialist 23 for North Dakota State University and the University of 24 Minnesota. 25 I have conducted educational programs and

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1 whole thing is that this technology's so good, that we 2 got the biggest river in the Mississippi, in the 3 Mississippi, in North America, and the powers that be 4 can't find the, the chemical. 5 That's how good it is. 6 And then we've got people who want to 7 eliminate it for us. Is somebody -- you know, when we 8 first grew sugar beets for the first seven, eight 9 years, there were times, honestly, that I mixed up the 10 seven chemicals at one time to mix a load of, of 11 herbicides. And I know all these farmers know that in 12 this room. 13 And then we're trying to eliminate the best 14 chemical that we've ever had. And we can't find it. 15 I think that we need to think about some of 16 that. 17 You know, we increase our yields about 10 to 18 20 percent with Roundup in our operation. 19 And we ex -- we import about 25 percent of 20 the sugar currently. Do we want to -- what are we 21 going to do, do we want to import more sugar, do we 22 want to go to 35 or 40 percent? If we go to 23 conventional. 24 And then what's going to happen with our 25 rivers, our streams. 65

1 research in sugar beet for the past 13 years and I have 2 the research data for the past 41 years. 3 I concur with other, with the, what the other 4 speakers have presented. 5 I will just give you a few highlights of some 6 additional issues. 7 Weeds, as we have heard, were considered as 8 the worst production problem for many years. Poor weed 9 control not only resulted in reduced yield from 10 competition, but very importantly, delays harvesting 11 operations, which can be costly to farmers, especially 12 if there's an early freeze or heavy rainfall. Just ask 13 my friends from Minn-Dak. 14 Most growers use two applications of 15 Glyphosate and have reported excellent weed control. 16 I have personally conducted several tests 17 which show that Glyphosate can be safely mixed with 18 most of the insecticides and fungicides used in sugar 19 beet without causing phytotoxicity. 20 Growers wisely use mixtures when possible to 21 reduce the number of passes over a field, to reduce 22 fossil fuel and, most importantly, to reduce their cost 23 of production. 24 Based on the crops produced here in North 25 Dakota and Minnesota, there is no issue of cross-Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 pollination, since sugar beet and none of its relatives 2 are grown for seeds in these states. 3 Over the past four years, sugar cooperatives 4 have successfully used Roundup Ready sugar beet to 5 produce a safe, affordable and reliable source of sugar 6 that is accepted by consumers, many of whom are our 7 sugar beet growers. 8 Weed control was the most important problem 9 for sugar beet growers since beets were first grown in 10 Europe, and later, in the United States. 11 An annual sugar beet survey started in the 12 1970s, conducted for North Dakota and Minnesota, showed 13 that weeds were considered as the most important 14 problem from the '70s until 2008. 15 In 2009 and 2010, weed control was not 16 considered as a great of problem. Instead, Rhizoctonia 17 and Aphanomyces root rot were considered as the major 18 problem. 19 Should USDA/APHIS decide on Alternative 1, 20 growers will have to contend with managing weeds using 21 conventional herbicides, which are not as effective as 22 Glyphosate. They'll have to use tillage to assist with 23 weed control, which will probably lead to more 24 Rhizoctonia crown rot, which happens when you have soil 25 intrusion into the crown of plants. 68

1 MR. GEORGE: Thank you. 2 Matthew Hasbargen, please. 3 MR. HASBARGEN: My name is Matthew Hasbargen. 4 M-a-t-t-h-e-w H-a-s-b-a-r-g-e-n. 5 I'm a third-generation sugar beet farmer from 6 Breckenridge, Minnesota. My family has grown sugar 7 beets since the 1960s. And I've been, been raising my 8 own sugar beets for the last 20 years for the Minn-Dak 9 Farmers Cooperative in Wahpeton, North Dakota. 10 This past year, I raised about 1800 acres of 11 sugar beets. I also raised corn, soybeans and wheat. 12 I embrace the introduction of Roundup Ready 13 sugar beets in 2008 by planting 900 acres, which was 14 the most that our co-op would allow. And then 2009 15 through 2010, growing the maximum amount, a hundred 16 percent of my crop. 17 I currently am growing Roundup Ready sugar 18 beets under compliance agreements between APHIS and the 19 Minn-Dak Farmers Cooperative. 20 I really appreciate the hard work reflected 21 in the Draft Environmental Impact Statement prepared by 22 APHIS. I support the proposed Alternative 2, full 23 deregulation of Roundup Ready sugar beets. 24 The reason why I understand it -- or why I 25 promote it, is if you go back 20 years ago to the way

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1 And in addition, the sugar beet industry will 2 not have the opportunity to utilize genetic engineering 3 to help manage disease -- diseases such as Rhizoctonia 4 and Aphanomyces root rot. 5 Very importantly, timely application of 6 fungicides, such a Quadris, which is used to control 7 Rhizoctonia root rot, will be hindered. Why, this 8 fungicide cannot be safely mixed with conventional 9 herbicides, since it must be applied three or more days 10 prior to or after conventional herbicide application. 11 Mr. Chairman, scientific evidence have not 12 indicated any major, negative consequences of planting 13 and using Roundup Ready sugar beets and commercial 14 production to date has been shown to be very safe. 15 I have read your sev -- 729 pages, Draft 16 Environmental Impact Statement, October, 2011, for 17 Glyphosate tolerant H7-1 sugar beets, request for 18 nonregulated status, which addressed the environmental 19 consequences of using Roundup Ready sugar beet and of 20 alternatives. 21 I agree with your assessment. As such, I 22 strongly im -- implore you to choose Alternative 1 23 (sic) and grant full deregulation of H7-1 Roundup Ready 24 sugar beet. 25 Thank you. 69

1 we started to farm with nonRoundup Ready sugar beets, 2 or as we called them, conventional sugar beets, and 3 that is due to weed control in those beets. 4 The key to growing a good sugar beet crop is 5 good weed control. 6 We used to use band sprayers, broadcast 7 sprayers, cultivators and also hand labor to get this 8 accomplished. 9 We'd start in April, after the beets would 10 plant -- were planted, by doing a soil-side -- soil11 applied herb -- fungicide. And then once the beets came 12 out of the ground, we'd band spray up to seven 13 different chemicals, three to five times during that 14 growing season. 15 The mixture and handling of the seven 16 different chemicals was com -- was a complex process, 17 requiring strict management oversight. 18 Once all the chemicals were mixed in the tank 19 and ready to go, I had only a few hours to get those 20 sprayed off before the mixture started to precipitate 21 in the tank. 22 Ideally, I could apply the chemical by 23 ground, but if it was a wet spring, I would have to 24 hire an airplane to apply the chemical. This was very 25 costly and tricky endeavor, since the mixture ofCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 chemicals could kill pretty much any of the other crops 2 surrounding the field. 3 Appli -- after application, you could tell 4 that the conventional herbicide damaged the beets 5 slightly. It would take awhile for the beets to grow 6 out of the chemical shock. 7 Because I was only controlling the weeds in 8 an 11-inch band over the top of the beets, I would also 9 have to use a cultivator to control the weeds in 10 between the row. 11 We traditionally would cultivate three to 12 four times per year. Even with perfect chemical 13 application timing, it's virtually impossible to 14 control all of, all of the weeds in a conventional 15 sugar beet field, thus, hand labor was required every 16 year to clean up the fields. This was very hard work. 17 Overall, we make between 10 to 12 passes with 18 a piece of equipment to control weeds in a conventional 19 sugar beet field. 20 Now with the Roundup Ready system, it's 21 greatly streamlined our weed control processes. The 22 only tool we use is a broadcast sprayer. We simply 23 make two to three passes over the field, spraying 24 Roundup to control the weeds. 25 I no longer have to mix individual chemicals 72

1 Roundup Ready technology, I'm going to save over a 2 tanker lab -- load of fuel every season. 3 Thank you. 4 MR. GEORGE: Thank you. 5 The last name I have is David Roche, but you 6 already spoke. Am I right? 7 MR. ROCHE: Yes. 8 MR. GEORGE: The next name I -- I have to 9 confess, I can't make this name out. 10 It's a person that's with ACSC, from Warren, 11 Minnesota. 12 MR. DVORAK: Dvorak? 13 MR. GEORGE: It starts with a T, that's about 14 the only letter I can -- 15 MR. DVORAK: That'd be me. 16 MR. GEORGE: Okay. You must be a doctor. 17 MR. DVORAK: Hello. My name is Todd Dvorak. 18 T-o-d-d D-v-o-r-a-k. 19 I'm a farmer from Warren, Minnesota, I farm 20 with my dad, Ted, and brother, Eric. 21 I'm a fourth-generation sugar beet grower and 22 have been growing beets for American Crystal since 23 2004. Our operation typically grows 400 acres each 24 year. 25 Our farm has seen a great benefit to growing

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1 and dump them into the sprayer tank. Roundup comes in a 2 250-gallon bulk system, so I can stand by the chemical 3 truck and just turn valves to fill the sprayer. 4 Additionally, there is no need for 5 cultivation or hand labor. This saves me time, money 6 and most, importantly, exposure to harmful chemicals. 7 The 10 to 12 passes has now been reduced down 8 to two to three. 9 Good stewardship is an essential part of 10 farming. The partial deregulation and compliance 11 agreements have worked in conjunction with my farming 12 practices. 13 For example, I've always tried to vary my 14 crop rotation to keep weed, weed pressure low and 15 reduce the resistance of weeds to chemicals. I follow, 16 I follow chemical labels to make sure I use the 17 appropriate rate of chemicals to control weeds. 18 I also identify and remove all bolters in my 19 sugar beet fields. 20 The loss of the Roundup Ready sugar beet 21 technology would be a great loss for my farm and the 22 environment. The impacts are great due to the increase 23 in number of trips across the field to control the 24 weeds in a conventional sugar beet crop. The fuel 25 savings alone are staggering, staggering. With the 73

1 Roundup Ready sugar beets. The excellent weed control, 2 followed by the wider application window, allows us to 3 grow higher-yielding sugar beets, while maintaining a 4 clean field. 5 Roundup Ready sugar beets have also reduced 6 the chemicals we have needed to use and handle for weed 7 control. Using one product versus three to four in 8 combination have simplified our weed control program, 9 along with fewer passes across the field and less 10 exposure to chemicals. 11 In closing, I appreciate the work done by 12 APHIS in the Draft of the Environmental Impact 13 Statement and I support Alternative 2 and full 14 deregulation of Roundup Ready sugar beets. 15 Thank you. 16 MR. GEORGE: Thank you. 17 Eric Erdman. 18 MR. ERDMAN: Hi. Eric Erdman. E-r-i-c E-r-d19 m-a-n. 20 I farm in Polk County, northwestern 21 Minnesota, growing sugar beets for American Crystal. 22 My family's been farming sugar beets for 23 three generations. And we currently farm about 1500 24 acres, consisting of wheat, soybeans and sugar beets. 25 We have utilized the Roundup Ready technologyCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 in the past, but did not use Roundup Ready sugar beets 2 last year, due to the uncertainty of the seed. 3 We needed to select specialized varieties due 4 to disease pressures in our soils. And planting 5 varieties that were not compatible would have resulted 6 in very poor yield and possible abandonment of the 7 fields. 8 With that, I fully support the full 9 deregulation of Roundup Ready seed. 10 This year was a challenging one to be a sugar 11 beet farmer. A wet, cool spring delayed the planting. 12 And as soon as planting was completed, the weather 13 heated up and multiple storms rolled through. 14 Although we were extremely lucky and did not 15 receive an abundance of rain, like many others, 16 conventional beets offered many challenges that Roundup 17 would not have. 18 On one particular quarter, we made six trips 19 over the field with conventional herbicides and early20 season fungicide treatments. With Roundup, that would 21 have been easily cut in half, if not down to two trips. 22 Conventional loads many times have between 23 three and six different chemicals being tank mixed, 24 whereas, Roundup would cut that down to one or two. 25 That is a lot more chemical being applied per 76

1 we strictly follow the rule and guideline set forth by 2 the EPA. 3 And with Roundup, we've worked closely with 4 APH -- American Crystal, APHIS and Monsanto to ensure 5 this technology will be here for us to use in the 6 future. 7 Thank you. 8 MR. GEORGE: Thank you. 9 Tim Osowski. 10 MR. OSOWSKI: Tim Osowski. O-s-o-w-s-k-i. 11 Hello. I farm near Argyle, Minnesota, with 12 my brother, father, uncle and two cousins. 13 Along with sugar beets, we plant wheat, 14 soybeans, corn and edible beans. 15 I have grown sugar beets for American Crystal 16 since 2001, and we now raise about 2,000 acres. 17 I am a member of the Minnesota Association of 18 Wheat Growers and serve on their state board. And also 19 on my local township board. 20 In 2008, we planted about half of our sugar 21 beet acres to Roundup Ready, which was reduced because 22 of availability of seed. And since then, we have 23 planted all of our sugar beet acres to Roundup Ready. 24 The major reason we have used the Roundup 25 Ready technology is the superior weed control over

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1 time, allowing for a lot more opportunity for errors, 2 so -- 3 Roundup allows the ability to mix in certain 4 fungicides with the herbicide, where some conventional 5 chemicals do not, due to the volatility of it. 6 The timing of the applications with chemical, 7 conventional chemicals, is also much more critical. 8 Through this growing season, like may years before, we 9 were forced to spray when conditions were not ideal. 10 We had to spray when the temperature was warmer and, 11 therefore, we'd notice some damage due to the herbicide 12 that's there. 13 Along with less chemical, Roundup has allowed 14 us the opportunity not to cultivate. 15 The combination of less spraying, with less 16 cultivation, uses less fuel and less trips across the 17 field, resulting in a lot less wheel tracks and compac 18 -- compaction, also, which improves yields. 19 Roundup has been very dependable on our farm. 20 And it has allowed us better control over some weeds, 21 primarily kochia and wild oats, where we've experienced 22 problems and conventional -- with conventional 23 chemicals. 24 Being st -- good stewards of land has always 25 been a priority on the, our farm. With all chemicals, 77

1 herbicides and methods used on now nonRoundup Ready 2 beets. 3 Before utilizing Roundup Ready sugar beets, 4 we would apply three to six applications of four or 5 five herbicides, along with two cultivations. And 6 sometimes hand labor was also necessary, which is 7 difficult to find and very expensive. 8 Additional difficulty in using hand labor was 9 the, the more toxic herbicides used. And nonRoundup 10 sugar beets required the workers to be out of the 11 fields longer after applications of such herbicides. 12 Even with multiple trips across the field, 13 which requires more fuel to be used, we often had less 14 than desirable weed control, which resulted in lower 15 crop yields and often harvest difficulties. 16 The use of Roundup has enabled us to have 17 excellent weed control and application timing 18 flexibility, while only applying the herbicide two 19 times. 20 We have always used -- utilized crop 21 rotations to improve the quality and quantity of our 22 sugar beet crop. And we have continued to do so since 23 using the Roundup Ready technology. 24 The use of crop rotations allows us to use 25 different mode-of-action chemicals that will reduce theCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 possibility of resistant weeds on our fields. 2 We also use tillage before and after all 3 crops that we grow to reduce weed pressure. 4 The Technology Use Agreement with Monsanto 5 requires applications of Glyphosate in accordance with 6 the label. And I do so to further prevent the 7 possibility of resistant weeds. 8 The training and practices required by the 9 compliance agreement did not change the way I farm, 10 because we had already implemented those practices. 11 We have removed rare bolters during field 12 inspections. We rotate for the improvement of all 13 crops that we raise. And we train our employees to 14 handle seed and chemical with care in accordance with 15 the labels. 16 My employees and I take training on chemical 17 application through the Minnesota Department of 18 Agriculture and we had trainings, training on use of 19 Roundup Ready technology specific to sugar beets prior 20 to planting. We are educated and continually informed 21 of changes on the use of Roundup Ready technology. 22 I would like to extend an appreciation to 23 members of APHIS for work done on the Draft 24 Environmental Impact Statement and to support proposal 25 Alternative 2, full deregulation of Roundup Ready sugar 80

1 grandfather. 2 I've been farming for eight years, all of 3 which I've grown sugar beets for American Crystal Sugar 4 Company. But my dad's been growing sugar beets for 5 American Crystal Sugar Company for 34 years. 6 Together, we farm just shy of 600 acres of 7 sugar beets each year. 8 In the past three years, we've planted 100 9 percent of our sugar beet acres to Roundup Ready sugar 10 beets. 11 Our 2011 Roundup Ready sugar beet crop was 12 planted under compliance agreements between APHIS and 13 American Crystal Sugar Company, under the grower unit 14 name Terry Eidem. 15 Although we currently grow wheat and 16 soybeans, in addition to sugar beets, we view our 17 operation, first and foremost, as a sugar beet farm. 18 And that's a source of pride for me, as well as my 19 entire family. 20 That pride has led me to become even more 21 involved in the sugar beet industry. I currently sell 22 sugar beet seed for Seedex, Incorporated, as well as I 23 serve on the Red River Valley Sugar Beet Growers 24 Association and Bateman's research and education board. 25 But mostly that pride requires me to be a

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1 beets, which will allow for long-term planting for me 2 and the seed companies I purchase seed from. 3 In production agriculture in the Red River 4 Valley, weather is our largest variable in growing a 5 crop, and the use of this technology enables us to 6 reduce the risk from weather events and consistently 7 produce a crop for our cooperative and consumers. 8 Thank you. 9 MR. GEORGE: Thank you. 10 Trent Eidem. 11 MR. EIDEM: Hi, my name's Trent, T-r-e-n-t, 12 Eidem, E-i-d-e-m. 13 Again, that's E, as in the excitement on my 14 son's face because I'm home with him rather running the 15 sprayer through the field again; I, as in increased 16 production; D, as in deregulation of Roundup Ready 17 sugar beets; E, as in excellent weed control; and M, as 18 in more, more crops to mirror the increased production 19 -- or increased demand. 20 First off, let me thank you and everyone here 21 with APHIS and APHIS as a whole for all the work 22 they've done in preparing the Draft EIS. 23 That being said, again, my name is Trent 24 Eidem. I farm northeast of Moorhead, Minnesota. I 25 farm with my father, who took over the farm from my 81

1 great steward of the land. Stewardship has always and 2 will always be a vital part of our operation. 3 Because of that, along with the stewardship 4 practices required by my Technology Use Agreement with 5 Monsanto, the partial deregulation and compliance 6 agreement did not cause me to make any substantial 7 changes to my growing practices in 2011. 8 We understand the value of crop rotation, 9 using the proper herbicide rates in our field, bolter 10 removal and weed resistance training. And there -- 11 therefore, they have been and will continue to be a 12 part of our operation going forward. 13 This is one of the many reasons why I support 14 Alternative 2, the full deregulation for Roundup Ready 15 sugar beets. 16 Roundup Ready sugar beets offer several 17 advantages to conventional sugar beets for our 18 operation. 19 Roundup Ready sugar beets offer a far more 20 effective weed control alternative to the microrate 21 programs of the past. 22 Instead of making four to five applications 23 with a cocktail of several chemicals, Roundup Ready 24 sugar beets allow us to make one -- make two to three 25 applications with significantly fewer chemicals to mix.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 The microrates cause injury to the beets. 2 They also -- they're also more toxic and have a much 3 more window of application than Roundup. 4 So Roundup Ready sugar beets allow for safer, 5 more effective weed control, with the added bonus of 6 fewer passes over the field, minimizing fuel used and 7 emissions. 8 With weed control being one of the most 9 difficult challenges we face, that is invaluable. 10 The issue of cross-contamination is not an 11 issue at all in the Red River Valley. First of all, 12 chard and table beets are not grown in this area, 13 making cross-contamination impossible. 14 Secondly, we harvest our sugar beets after 15 one year, whereas, sugar beets do not flower until the 16 second year. With the few exceptions to that rule, 17 first-year bolters are removed and destroyed. 18 Secondly, we harvest -- or I'm sorry, I'm -- 19 If, if a beet should escape the lifter, we -- 20 it stands little chance against the often harsh winters 21 we experience here in the Red River Valley. 22 Roun -- Roundup Ready sugar beets are 23 important to this area, they're important to me and 24 they're important to my family. 25 So, again, I will reiterate my full support 84

1 h-r-i-n-g. 2 The sugar beet industry is very important to 3 our state and to the region. North Dakota's the number4 two producing state only behind our neighbors to the 5 east, Minnesota. We have sugar beets on both the east 6 and west side of, of the state. 7 Roundup Ready technology gives producers 8 greater control over weed management, while decreasing 9 the environmental impact, with fewer pesticide 10 applications and less disturbance of the soil. 11 Roundup Ready technology gives our producers 12 another tool in the toolbox for weed control. 13 The Agriculture Commissioner is in full 14 support of Roundup -- of deregulation of Roundup Ready 15 sugar beets. 16 Our farmers are great stewards of the land 17 and will continue that stewardship in the future. 18 I thank APHIS for your work and for this 19 meeting. 20 MR. GEORGE: Thank you. 21 Jeff Stachler. 22 MR. STACHLER: Good evening. My name is Jeff 23 Stachler. J-e-f-f S-t-a-c-h-l-e-r. 24 Good evening. Sugar beet growers should have 25 the opportunity to choose the type of weed control

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1 of Alternative No. 2, the full deregulation of Roundup 2 Ready sugar beets. And I urge APHIS to take the steps 3 necessary to move to full deregulation of Roundup Ready 4 sugar beets. 5 As the third generation on my family farm, 6 one of the biggest goals in my life is to continue to 7 grow the farm so that it not only continues to be a 8 viable lifestyle option for my son, but that it 9 continues to be a source of pride for my entire family. 10 I fully believe that Roundup Ready sugar 11 beets will be an integral part of that process. 12 Thank you for your time. 13 MR. GEORGE: Thank you. 14 Dane Braun. 15 MR. BRAUN: Hello, I'm Dane Braun. D-a-n-e B16 r-a-u-n. 17 I'm, I'm the program and policy analyst for 18 the North Dakota Department of Agriculture. I grew up 19 on a farm in Trentwood County, Minnesota, a sugar beet 20 farm. 21 Unfortunately, I left before Roundup Ready 22 sugar beets came around, so I was one of the unlucky to 23 go weed the fields. 24 A couple comments on behalf of the 25 Agriculture Commissioner, Doug Goehring. D-o-u-g G-o-e85

1 practices that best fit their operation. 2 Roundup Ready sugar beets have provided the 3 most effective weed control in the history of sugar 4 beet production in Minnesota and North Dakota, based on 5 our annual survey of Minnesota and North Dakota sugar 6 beet growers. 7 According to this survey, Roundup Ready sugar 8 beet has reduced the number of weed control passes 9 across the field compared to conventional sugar beets. 10 As with any technology, there are risks 11 involved with planting Roundup Ready sugar beet, 12 however, these risks are limited and manageable by 13 growers and the industry. 14 Therefore, I support Alternative 2, full 15 deregulation of Roundup Ready sugar beet as proposed by 16 the Draft Roundup Ready Sugar Beet Environmental Impact 17 Statement. 18 And I thank APHIS for their diligent work in 19 preparing this Draft Environmental Impact Statement. 20 Thank you very much. 21 MR. GEORGE: I have a couple here with an, 22 with an X in the column, I'm not sure if this is 23 indicating that you want to speak or not. 24 One is Beau Bateman, who I believe spoke 25 already. Am I right?Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 MR. BATEMAN: Correct. 2 MR. GEORGE: Okay. 3 Same thing with Doug Etten. Etten. 4 MR. ETTEN: Yes, sir. 5 MR. GEORGE: Okay. I'm slow, but trainable. 6 Troy, Troy Newhouse. 7 MR. NEWHOUSE: Hello. My name is Troy 8 Newhouse, from Fisher, Minnesota, be speaking on behalf 9 of our farm. 10 My father had a few words to, to say, so he 11 asked me if I would read them. He could not make it 12 today or this evening. And after that, I will kind of 13 give my own opinion of how I feel, so -- 14 COURT REPORTER: Can you please state your 15 name -- 16 MR. NEWHOUSE: Yeah, -- 17 COURT REPORTER: -- or spell -- 18 MR. NEWHOUSE: -- I'm sorry. 19 COURT REPORTER: -- it. 20 MR. NEWHOUSE: Troy Newhouse. T-r-o-y N-e-w21 h-o-u-s-e. 22 COURT REPORTER: Thank you. 23 MR. NEWHOUSE: Now this is from my father. 24 I have farmed in Fisher, Minnesota, for 36 25 years. I raise sugar beets for the American Crystal 88

1 nonexistent with today's environment. 2 Roundup technology also impacts the next 3 year's crop with lower weed pressures. Planting Roundup 4 Ready sugar beet is a very expensive process, but 5 significantly cheaper and more effective than 6 alternatives. 7 In the years past, we would mix four to five 8 and even more chemicals in a tanks -- tank mix because 9 of toxically -- because of that toxicity, the tank mix 10 could damage the beet crop. 11 In my farming career, I have reluctantly 12 implemented many new technologies. 13 I can second that. 14 Roundup Ready crops, specifically Roundup 15 Ready sugar beets, were the easiest to accept and has 16 had the largest impact on the quality of my life. 17 Sugar production is a complex business that 18 is com -- that is completed by hardy individuals, 19 however, the legacy that aging farmers should leave the 20 next, should not include a key reversal of new 21 technology that makes the quality of life better. 22 I've farmed with my father for six years now. 23 And we -- when sug -- Roundup Ready beets came 24 available in 2008, we didn't go full on board, we were 25 about 20 percent. And then exclusively, like he said,

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1 Cooperative. Approximately 30 percent of my acreage is 2 dedicated to sugar production. Other crops are edible 3 beans, soybeans, wheat and occasionally corn. 4 I have planted Roundup sugar beets for the 5 past two years exclusively. I can say without a doubt 6 that Roundup sugar beets make all our other crops 7 better. 8 We have and will follow all the rules 9 implemented to make the technology available. 10 Saying this, we fully support the 11 deregulation of Roundup Ready sugar beets and we do 12 appreciate the hard work of the APHIS group in drafting 13 the Environmental Impact Statement. 14 Roundup is a new technology that not only 15 makes our lives better, but also allows American sugar 16 producers to be more competitive in a world market. 17 Roundup technology not only impacts the 18 competitiveness of sugar production, but other crops as 19 well, edible bean -- edible beans in particular. 20 Weed control in any row crop is a major 21 challenge. In years past, weed control required timely 22 passes of complex chemical strategies that had varying 23 results. 24 Many times the applications were ineffective, 25 forcing us to find hand labor that is almost 89

1 in 2009 and 2010 and 2011. 2 It's improved our quality of life so much. 3 You know, with myself, being married, with a young 4 family, just that opportunity to get home at night is, 5 is a very invaluable asset that I feel is, is worth 6 every penny to raise sugar beets in, in the Roundup 7 version. 8 Extremely thankful for the partial 9 deregulation for the past year. It would have put us 10 in a very big pinch for this upcom -- this past growing 11 season, had we not had Roundup seed, because there was 12 a, a shortage of conventional varieties that are 13 effective with the disease packages that we desire. 14 So thank you. And, and we completely agree 15 with the, the, the full deregulation of, of -- in the 16 Alternative 2 measure. 17 So thank you for your time. 18 MR. GEORGE: Thank you. 19 Erik Bakke. 20 MR. BAKKE: My name is Erik Bakke. E-r-i-k B21 a-k-k-e. 22 And I farm in the Ulen, Minnesota area, and 23 have been growing sugar beets in the Moorhead district 24 of American Crystal Sugar Company since 2004, growing 25 approximately 700 acres annually.Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 Other crops in my rotation include wheat, 2 corn and soybeans. Roundup Ready sugar beets have been 3 a hundred percent of my operation since 2009. 4 I currently grow Roundup Ready sugar beets 5 under compliance agreements between American Crystal 6 Sugar Company and APHIS. 7 I recognize and appreciate the hard work 8 brought forth in the Draft of the Environmental Impact 9 Statement prepared by APHIS. And I fully support the 10 proposed Alternative 2, the full deregulation of 11 Roundup Ready sugar beets. 12 There are many benefits to growing Roundup 13 Ready sugar beets. The most of which is superior weed 14 control compared to conventional spraying methods. 15 The ability to control weeds with Roundup 16 allows produce -- producers to be much more flexible 17 with the timing of application, widening the window for 18 effective weed control. 19 I believe that Roundup Ready technology is 20 also better for our environment than conventional 21 planting, as it reduces the number of chemicals used, 22 as well as the amount of chemical that needs to be 23 handled by any one person. 24 With two or three applications of Roundup, 25 compared to four or five or more applications of 92

1 If I were to lose Roundup Ready sugar beets 2 in my operation, it would be a step backwards I 3 believe, resulting in reduced acres because of extra 4 workload, increased input costs due to more chemical, 5 machinery and labor needed. And last, but not least, 6 more than likely a drop in yields, reducing 7 profitability. 8 Thank you for your time and listening to my 9 comments. 10 MR. GEORGE: Thank you. 11 I have Matt Hasbargen on here again, but I 12 believe you already spoke. Am I right, yep? 13 MR. HASBARGEN: Correct. 14 MR. GEORGE: Nathaniel Hultgren. 15 MR. HULTGREN: I'm Nathaniel 16 Hultgren. That's: N-a-t-h-a-n-i-e-l. 17 Hultgren is: H-u-l-t-g-r-e-n. 18 I'm a third-generation beet farmer with 19 Southern Minnesota Beet Sugar Co-op. A fourth20 generation farmer from Raymond, Minnesota. 21 I currently farm with my brother and father 22 and all of our families depend on our operation for our 23 livelihood. 24 I feel that the issue we have before us today 25 is one of sound science, human progress and sustainable

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1 conventional chemicals, we are able to reduce tillage 2 practices, spray applications and hand labor, saving 3 money on reduced inputs, all while generating better 4 yields. 5 The compliance agreement we are currently 6 under did not greatly change the way I farm because 7 many of the key requirements were already being 8 implemented in my operation, such as identification and 9 removal of bolters, weed resistance management, crop 10 rotation and application of herbicides at labeled 11 rates. 12 These were already required in the Technology 13 Use Agreements signed with Monsanto upon planting their 14 genetics. 15 In my growing region, I believe there is no 16 risk of cross-pollination from Roundup Ready sugar 17 beets. 18 First-year beets do not flower and in the ev 19 -- and in the event of a rare first-year bolter, they 20 are being removed and destroyed. If a beet were left 21 in the ground, it would not survive our tough Minnesota 22 winters. 23 In addition, table and chard beets are not 24 grown in my region, eliminating cross-pollination 25 worries. 93

1 competitiveness in the global marketplace. 2 When viewed in the context of these three 3 elements, there's nothing but support from our family 4 for the full approval of full nonregulated status for 5 genetically-engineered sugar beets. 6 First of all, sound science. 7 As a sugar producer, my biggest concern is 8 the safety and satisfaction of our food customers, here 9 and around the world. 10 Studies have shown that there's no detectable 11 difference between sugar produced from conventional 12 sugar beets and sugar produced from genetically13 engineered sugar beets. 14 As farmers, we know that the pollen15 contamination cannot realistically be a concern, since 16 the sugar beets we raise for sugar production are not 17 alive long enough to produce any seed. And bolters are 18 dealt with in, in the event of any rare growth in the 19 first year. 20 While opponents of the Roundup Ready 21 technology may cite an increase in chemical use, we, as 22 sugar beet growers, know that is quite the opposite. 23 With conventional sugar beets, we were forced 24 to use three to four applications within two weeks of 25 each other, with often more toxic chemicals that wereCapital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 much less effective on the weeds. 2 These chemicals would often stunt sugar beet 3 growth, were far more detrimental to neighboring crops 4 if misapplied and usually required soil-applied 5 residual chemicals for optimal control. 6 Glyphosate is strictly an over-the-top 7 program with fewer applications, spaced farther apart, 8 with much more effective control, all while posing less 9 risk for neighboring crops, the soil and the sugar 10 product. 11 My second point is human progress. 12 Technological advancements have been used to 13 improve quality of life in healthcare, manufacturing, 14 energy production and education. Why should 15 agriculture be any different? 16 Biotechnology has been a huge advantage in 17 crop production thus far and the possibilities are 18 endless. 19 Glyphosate resistance is only the beginning. 20 Plants can be bred to be resistant to disease or to 21 produce certain enzymes for particular dietetic or 22 industrial needs. 23 Insect damage can be suppressed through the 24 use of biotechnology. When so many people on our 25 planet are starving and land use is becoming more of an 96

1 forced to import sugar, sugar that is of a lower 2 quality than our current high-quality American product. 3 The cost of a pound of sugar in the United 4 States would skyrocket and consumers would feel, feel 5 the pain when they can't afford their favorite grocery 6 items. 7 In closing, I want to thank APHIS for 8 allowing us to comment tonight on this subject. And I 9 hope American farmers are allowed to utilize all the 10 advancements that are available to them. 11 Together, with highly-reputable companies 12 that produce these technologies, and with the sound 13 management practices that we as American farmers are 14 known for, I'm confident that my family will be able to 15 continue to produce sugar for consumers in the United 16 States and across the world for generations to come. 17 Thank you. 18 MR. GEORGE: Thank you. 19 Is there anyone else who would care to speak 20 who has not yet spoken or perhaps I may have missed 21 somebody on this list? 22 Is there anyone else who would like to speak 23 today? 24 Okay. 25 In that case, I think what we'll do is not

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1 issue, is this a good time to take away these 2 progressive tools that allow us to produce more food on 3 less acres with less resources per acre? 4 My third point is global competitiveness. 5 What is the economic impact of 5 tons less 6 sugar beets per acre? Where in the world will sugar 7 production migrate to if disease forces certain areas 8 of the United States to cease sugar beet production? 9 If sugar beet growers and processors are not 10 allowed to utilize biotechnology to impro -- improve 11 their food product, defend against disease and increase 12 production efficiency, more and more factories and 13 family farms will discontinue sugar beet production. 14 Jobs will be lost, small-town businesses will 15 close. And, once again, regulation will cause the 16 movement of a successful industry overseas. 17 One must understand that the playing field in 18 agriculture is on a mountain with a much steeper slope 19 than there was ten years ago. 20 If producers must go back to conventional 21 beets, raising only 21 tons per acre, instead of 25, 22 for instance, the high cost of other inputs, such as 23 land rent and fertilizer, will not make that possible. 24 Farmers will not raise beets, factories will 25 close, people will lose their jobs and America will be 97

1 adjourn, but rather su -- kind of suspend the meeting. 2 We will stay here until 7:00 o'clock, so if 3 there are latecomers who come in, who would like to 4 make public comments, we'll be happy to take them. 5 I will remind you that it is also possible to 6 make public comments on the web. You can go to our 7 website, there's a link to regulations dot gov, where, 8 where you can also leave comments. 9 If you have comments that you would care to 10 leave in writing, even if you did not speak, you can 11 leave those in the public comment box that's in the 12 back of the room. 13 I'd like to thank everyone for coming out 14 today to share your comments with us. It's an 15 important part of our process. We welcome your input 16 and thank you for taking the trouble to be here today. 17 So with that, we're not going to adjourn, but 18 we will suspend here for a while. 19 Thank you. 20 (Whereupon, the proceedings were 21 suspended at 5:55 o'clock p.m.) 22 (Whereupon, the proceedings were 23 adjourned at 7:05 o'clock p.m.) 24 25Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011

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1 REPORTER'S CERTIFICATE 2 I, Joy Filipski, a general shorthand (Stenograph) 3 reporter, do hereby certify that the foregoing pages of 4 typewritten material constitutes a full, true and 5 correct transcript of my original Stenograph notes, as 6 they purport to contain, of the transcript of the 7 proceedings reported by me at the time and place 8 hereinbefore mentioned. 9 10 11 12 13 Joy Filipski 14 15 16 17 18 19 20 21 22 23 24 25Capital Reporting Company Roundup Ready Sugar Beet Environmental Impact Statement 11-15-2011 Page 1

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