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### Supplemental Information to Support the NEPA Analysis for the Determination of Nonregulated Status of Dicamba

- Tolerant Soybean MON 87708 and Dicamba

- and Glufosinate

- Tolerant Cotton MON 88701

I

nformation regarding trends in tillage practices in corn, cotton and soybean

OECD Unique Identifiers: MON

- 877Ø8

- 9 (soybean) and MON

- 887Ø1

- 3 (cotton) Monsanto Petition Numbers: 10

- SY

- 210U (soybean) and 12

- CT

- 244U/ 12

- CT

- 244U

- S (cotton) USDA Petition Numbers: 10

- 188

- 01p (soybean) and 12

- 185

- 01p_a1 (cotton)

D ecember 19, 2013

Submitted by :
Rhonda M. Mannion, B.S.

Monsanto Company 800 North Lindbergh Blvd. St. Louis, MO 63167 Phone: (314) 694

- 8785

Fax: (314) 694

- 3080 E

- mail: rhonda.m.mannion@monsanto.com

Prepared by: J.K. Soteres, Ph.D. and R.M. Mannion, B.S.

### Release of Information

Monsanto is submitting the infOlmation in this petition for review by the USDA as part of the regulatory process. By submitting this infOlmation, Monsanto does not authorize its release to
any third party. In the event the USDA receives a Freedom of Information Act request, pursuant
to 5 

### U.S.C. § 552, 

### and 7 CFR Part 1, 

### covering all or some of this infOlmation, Monsanto expects that, in advance of the release of the document(s), USDA will provide Monsanto with a copy of the material proposed to be released and the 0ppOliunity to object to the release of any infOlmation based on appropriate legal grounds, e.g., 

### responsiveness, confidentiality, and/or competitive concerns. Monsanto understands that a copy of this information may be made available to the public in a reading room and upon individual request as part of a public comment period. Except in accordance with the foregoing, Monsanto does not authorize the release, publication or other distribution of this infOlmation (including website posting) without Monsanto's prior notice and consent.

Certification

The undersigned submits this supplement under 7 CFR §340.6 

### to request that the Administrator make a determination that the miicle should not be regulated under 7 CFR Pmi 340



### Rhonda Mannion, B. 

### S. Regulatory Affairs Manager
Tel: (314) 694-8785


### Fax: (314) 694-8414



### ©2013 Monsanto Company. All Rights Reserved.

This document is protected under copyright law. This document is for use only by the regulatory authority to which it has been submitted by Monsanto Company and only in support of actions requested by Monsanto Company. Any other use of this material, without prior written consent of Monsanto, is strictly prohibited. By submitting this document, Monsanto does not grant any party or entity any right to use or license the information or intellectual propeliy described in this document.

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### Introduction

Recently there have been speculation and in some cases, reports
, that the growth of conservation tillage acres and

, in particular

, no

- till acres has slowed or is reversing in some parts of the country. Accordingly

, Monsanto undertook an analysis of grower market researc h information from an independent market research company and follow up consultation with leading conservation tillage experts to understand more precisely current tillage trends and reasons for these trends in key soybean , corn and cotton growing areas.

M ultiple factors could influenc e conservation tillage practices. G rowth in the spread of glyphosate

- resistant weed populations has been speculated or reported to be one such factor, because of the need for some farmers to incorporate more tillage into the ir farming operations in order to control some difficult to control weed species, such as Palmer amaranth . F or example, where populations of glyphosate

- resistant Palmer amaranth have grown large in areas such as Georgia, western Tennessee, and Arkansas

, w eed control experts recommend deep pre

- plant tillage as one way to reduce the population before other weed control measures are applied ( Culpepper, et al. 2013 ; Culpepper, et al. 2011 ; Price, et al. 2011 )

. However, growers and leading conservation experts themselves report a range of factors other than weed management that can and do influence farmer practices relative to conservation tillage practices

.

Materials and Methods

This analysis used market research data from a n unpublished national grower survey conducted by a third party market research co mpany . The data retrieved from this database included the number of crop acres planted conventionally, in a no

- till system
, or in a reduced tillage system

. No

- till acres are defined as those in which the farmer d oes not till the ground after the harvest of the last crop and before planting a new crop. Reduced tillage (r educed

- till) is defined as situations where the farmer practices various types of reduced tillage after harvest of the last crop and before planting the new crop where significant crop res idues (~ 15%

- 30%) are left on the soil surface. Examples of reduced tillage practices include ridge

- till (planting row crops on permanent ridges), strip

- till (planting crops directly in narrow strips that had been tilled), and mulch

- till (any reduced tilla ge system that leaves at least 1/3 of soil surface covered with crop residue)

. Conventional tillage (conventional) is defined as situations where the farmer conducts several tillage operations such that the new crop is planted into soil with little to no surface residue.

The farmer market research d ata w as sorted by crop (soybeans, cotton , and corn ) and state. Select ed states were combined into growing region s ( East, Midwest

, Southeast

, Mid

- South

, and W est
, as indicated in Table 1 )

. Data was retrieved fo r the period from 1998 through 2013 for soybeans and corn

, and through 2012 for cotton (Note: 2013 cotton data from the market research company is not current ly available )

. The estimated acreage of each tillage type for each crop and growing region was co nverted to percent of total crop planted acreage and submitted for statistical regression analysis over the designated time period. The data was analyzed to fit a linear or quadratic regression model at the 5% level of significance. D etails o f the statist ical analysis are provided in the statistical report found in Appendix A.Monsanto Company Petitions 10

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### To understand possible reasons for some of the changes observed in this data set, Monsanto worked with CTIC (Conservation Tillage Information Center, www.ctic.org ) to conduct a survey of leading conservation tillage experts in select Midwest

, Southeast ern and Mid

- South

. ( Note: experts from these areas were surveyed because they represent the major regions for the production of soybean, corn and cot ton, and because they represent the areas with the highest levels of herbicide resistant weeds). In this survey

, the experts were asked to indicate the level of importance of 11 different factors to farmers as they make decisions as to which tillage syste m and in general how much tillage they will use on their farm(s). Examples of factors included “manage excess crop residue,” “manage existing weeds,” “manage disease,” “economics,” and “prevent weed resistance.” To rank the factors, a number from 1 to 4 was assigned to each response category, with 1 assigned to “ not important or not mentioned ” and 4 assigned to

“ extremely important ”

. The experts were not limited in the number of factors to which they could assign an individual ranking. ( i.e. , the expert s could rank all

– or none

– of the 11 factors as “extremely important”)

. The assigned number was multiplied by the number of responses from the experts and then added together for each factor . The factors with the 5 highest numerical sums are listed in Table 3 for each crop and region. The detailed results of this survey for corn, soybeans and cotton can be found in Appendix B.

Table 1

. States in each Geographic Region
Region Crop Focus States East Corn, soybean Connecticut, Delaware, Maine, Maryla nd, Massachusetts, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, West Virginia

Southeast Corn, cotton, soybean Alabama, Georgia, S. Carolina, N. Carolina, Virginia, Florida Mid

- South Corn, cotton, soybean Mississippi, Louisian a, Arkansas, Tennessee

Midwest Corn, cotton, soybean Ohio, Michigan, Indiana, Illinois, Wisconsin, Missouri, Minnesota, Iowa, Kentucky, Kansas, Nebraska, N. Dakota, S. Dakota West Corn, cotton, soybean Arizona, California, New Mexico, Oklahoma, Texas, C olorado, Idaho, Montana, Nevada, Utah, Washington, Wyoming

Results and Discussion

A summary of the results of the grower market research data analysis on tillage trends can be found in Table 2. Key points are as follows:

**•** From 1998 to 2007, the conv entional tillage acreage decreased and no

- till acres increased across all crops and geographic areas. Likewise, reduced tillage acres generally increased during this time period , although for some areas and crops, no significant relationshipMonsanto Company Petitions 10

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### between the t illage practice and time could be detected

. T he growth in no

- til l and reduced tillage acres coincides with, and was facilitated by

, the growth in glyphosate

tolerant corn, soybean and cotton acres ( Givens, et al. 2009a ; Givens, et al. 2009b ; McClelland, et al. 2000 ; Osteen and Fernandez

- Cornejo 2013 ; Sankula 2006 ; Towery and Werblow 2010 )

.

**•** Since 2007, however, some crops in some geographic a reas have continued to see growth in no

- till acreage, while other crops in other geographic areas have seen decreases in no

till acreage, accompanied by an increase in conventional and/or reduced tillage acreage. A more detailed, crop

- by

- crop discussion i s presented below.

**•** Corn: From 1998 to 2007, the conventional tillage acreage decreased and no

- till acres increased across all geographic areas. From 2007 through 2013, the trends varied across region s :

o In the West and East, conventional tilled corn acre s continued to decrease, and

no

- till acreage continued to increase. Reduced tillage acres also increased in the West, but there was no clear trend in the East.

o In the Midwest, conventional tilled corn acres contin ued to decrease but there appeared to be a shift from strict no

- til l practices to reduced tillage acres where some tillage is practiced but significant (15%

- 30%) crop residues remain on the surface at planting

.

o In the Southeast , conventional tillage acres planted to corn tended to level off or increase while no

- till acres tended to decrease.

o In the Mid

- South , there were no significant trends in conventional or no

- till acreage, but reduced till acres increased throughout the time period.

**•** Soybean: From 1998 to 2007, the conventional tillage acrea ge decreased and no

- till acres increased across all geographic areas. From 2007

- 2013, the trends varied across region:

o In the West, conventional tilled soybean acres continued to decrease, and no

- till acreage continued to increase. There was no significa nt trend for reduced tillage

acres.

o In the East, Midwest, Southeast and Mid

- South regions, conventional tilled soybean acres were flat or increas ing, while no

- till acres were flat or decreas ing

. R educed tillage acres in the Midwest increased during the sa me time period, but there was no clear relationship between time and reduced tillage plantings in the East, Southeast or Mid

- South regions (not significant at the 95% confidence interval). Thus, i n the M idwest

, the reduction in no

- till acres appears in la rge part
to be offset by an increase in reduced tillage acres , but similar offsetting does not appear to be occurring in other regions.

**•** Cotton: From 1998 to 2007, the conventional tillage acreage decreased and no

- till acres increased across all geographi c areas. From 2007

- 2012, the trends varied across regions:Monsanto Company Petitions 10

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### o In the West, conventional tilled soybean acres continued to decrease, and no

- till acreage continued to increase. Reduced tillage acres also continued to increase.

o I n the Midwest, Southeast and Mi d

- South, conventionally

- tilled cotton acres tended to be flat or increase , while a clear increase was found in the Mid

- South region. Reduced tillage acres increased in the Midwest and Southeast d uring this period , but both no

- till and reduced tillage acrea ges decreased in the Mid

- South region

. Thus, in the Midwest and Southeast, the reduction in no

- till acres appears in large part to be offset by an increase in reduced tillage acres, but similar offsetting does not appear to be occurring in the Mid

- South.

Overall , changes in tillage practices from 2007 to 2012 (cotton) / 20 13 (soybean and corn) varied by crop and region relative to changes seen in the earlier period from 1998 to 2006 where consistent trends were observed across all the regions (i.e.

, increas e in no

- till and reduced tillage with a decrease in conventional tillage systems).

In order to understand the reasons growers adopt specific tillage practices

, a survey was conducted of top conservation tillage experts across the Midwest (for corn and soy beans)

, Southeast and Mid

- South regions (combined, for corn, soybeans

, and cotton)

. In Table 3

, the top 5 factors

, according to conservation tillage experts, governing farmer decisions relative to which tillage practice they adopt for their farm are provi ded by crop and region of the country. Key findings included:

**•** Economics (i.e.

, the importance of cost of production and/or commodity prices), and managing soil moisture (i.e.

, less tillage conserves soil moisture) were top

- 5 factors across all the crops a nd regions.

**•** Seed bed preparation was a top

- 5 factor in 4 out of 5 crop x region segments

.

**•** M anaging excessive crop residue (i.e.

, excessive prior crop residue may require more tillage) and managing weeds (existing weeds or preventing weed resistance) wer e important factors in 3 out of 5 crop x region segments.

**•** Managing weeds was an important factor across all soybean and cotton regional segments , but was not a top 5 factor for corn in either regional segment

. Th e difference between corn and the other c rops is likely because growers have a broad range of herbicide options (including atrazine, dicamba and 2,4

- D) that are effective against species that are difficult to control in soybeans and cotton , i.e., glyphosate resistant Palmer amaranth and waterhemp

. This survey of conservation tillage experts highlights that farmers consider multiple factors when making decisions as to wha t type tillage system to employ.

Conclusions

From 1998

- 2007, no

- till acreage increased steadily across all crops and all region s, with an accompanying decrease in conventional tillage. A more complicated picture emerged after 2007, with some crops and regions continuing to experience increases in no

- till and decreases in conventional tillage , while other crops and regions experie nced decreases in no

- till acreage, either accompanied by increases in reduced tillage acreage and/ or in conventional tillage.Monsanto Company Petitions 10

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### Based upon information provided by conservation tillage experts regarding the most important factors governing farmer’s decision s with respect to tillage practices , no one factor is dr iving these changes. Managing existing h erbicide resistance and/or mitigating the potential for resistance to develop is a factor is some regions

. For example

, academics have been recommending more p re

- plant tillage in parts of the Southeast and Mid

- South (AR, western TN, and MS) in order to better manage glyp hosate

- resistant Palmer amaranth

. But weed resistance management/mitigation does not appear to be a driver for other crops and regions. Indeed , the survey results indicate that higher corn and soybean grain prices

, along with more focus on seed bed preparation

, is likely to be a reason for some of switch to conventional tillage since a better stand (and thus higher potential yields) can usually be achieved in conventional tillage systems. Moreover, newer corn varieties can produce excessive crop residue

, which may also be causing a move to more tillage and may be needed to optimize crop stands in this period of high grain prices.

Based upon th e tillage trends seen over the last 5

- 6 years and with the information on the factors most influencing farmers’ decision on tillage practices, more study, appropriately directed research, education, and new technology from a weed management and crop produc tion standpoint are needed to maintain and further grow conservation tillage practices. In some areas and for some crops, managing existing herbicide resistance and/or mitigating the potential for resistance to develop has been reported as an important fa ctor in influencing farmer tillage decisions. DT soybean and DGT cotton are two new herbicide technologies that have the characteristics that can significantly assist in reversing stagnated and downward trends and promote new growth in conservation tillag e acres. Weed management has always been a limiting factor for many farmers in determining whether to adopt no

- till production practices because farmers had to rely primarily on soil residual herbicides. Glyphosate, in glyphosate

- tolerant crops, with its broad spectrum post

- emergence control provided a way to achieve consistent weed control in these situations and facilitated an increase in adoption of no

till and, in general, conservation tillage practices ( Fawcett and Towry, 2002 )

. The effectiveness of dicamba to provide post

- emergent control of broadleaf weeds, suggests that it too will promote adoption of no

- till and conservation tillage practices. Additionally, dicamba’s ability to control glyphosate resistant broadleaf weeds and its compatibility w ith glyphosate are characteristics that will facilitate the promotion of conservation tillage practices.Monsanto Company Petitions 10

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### Table 2. Trends in Tillage Practices in Soybean, Corn and Cotton

Crop Geography Tillage system Trend

1998

- 2007 2007

- 2012/13 Corn West Conventi onal Dec Dec No

- till Inc Inc Reduced

- till Inc Inc Midwest Conventional Dec Dec No

- till Inc Flat/Dec 1


### Reduced

- till Dec Inc Southeast Conventional Dec Flat/Inc 1



### No

- till Inc Dec Reduced

- till NS NS Mid

- South Conventional NS NS No

- til l NS NS Reduced

- till Inc Inc East Conventional Dec Dec No

- till Inc Inc Reduced

- till NS NS

Soybeans West Conventional Dec Dec No

- till Inc Inc Reduced

- till NS NS Midwest Conventional Dec Flat/Inc 1



### No

- till Inc Dec Reduced

- till Dec Inc Southeast Conventional Dec Flat No

- till Inc Flat Reduced

- till NS NS Mid

- South Conventional Dec Inc No

- till Inc Dec Reduced

- till NS NS East Conventional Dec Flat/Inc 1



### No

- till Inc Flat/Dec 1


### Reduced

- till NS NSMonsanto Company Petitions 10

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### Table 2 ( continued). Trends in Tillage Practices in Soybean, Corn and Cotton
Crop Geography Tillage system Trend

1998

- 2007 2007

- 2012/13 Cotton West Conventional Dec Dec No

- till Inc Inc Reduced

- till Inc Inc Southeast Conventional Dec Flat/Inc 1



### No

- t ill Inc Dec Reduced

- till Inc Inc Midwest Conventional Dec Flat/Inc 1



### No

- till Inc Dec Reduced

- till Inc Inc Mid

- South Conventional Dec Inc No

- till Inc Dec Reduced

- till Inc Dec NS=no significant trend at 5% C onfidence I nterval Inc= Inc rease Dec=decrease Flat=no change Source of data is propriety grower market research data (Monsanto, 2013).

1 

### Where the trend is indicated as two phases (i.e. Flat/Dec), this means that statistically the trend is for no change over the designated time period but the slope over the last two years of the time period tended to be either reflective of an increase or a decrease.

Table 3. Top 5 Factors G overning Farmer’s Tillage Practice Decisions

Factor Midwest Corn (14 Experts) Midwest Soybeans (13 Experts) South Corn (6 Experts) South Soybeans (6 Experts) South Cotton (6 Experts)

1 Managing soil moisture Excessive crop residue Economics Economics Economics

2 Seed bed preparation Seed bed preparation Seed bed preparation Managing existing weeds Ma naging existing weeds 3 Economics Economics Excessive crop residue Seed bed preparation Availability of Labor 4 Excessive crop residue Managing existing weeds Improving

water penetration Managing soil moisture Managing soil moisture

5 Managing soil temp erature Managing soil moisture Managing soil moisture Preventing weed resistance Use of strip till / vertical tillage toolsMonsanto Company Petitions 10-188- 01p/12-185-01p_a1 Page 10 of 65 

### References:

Culpepper, A.S., J. Kichler and A.C. York. 2013. University of Georgia programs for controlling Palmer amaranth in 2013 cotton. University of Georgia Cooperative Extension, Athens, Georgia.

Culpepper, A.S., A.C. York and L.E. Steck el. 2011. Glyphosate-resist ant Palmer amaranth management in cotton. 2011 Proceedings, Southern Weed Science Society, San Juan, Puerto Rico.

Fawcett, R. and D. Towery. 2002. Conservati on tillage and plant biotechnology: How new technologies can improve the environment by reducing the need to plow. Conservation Technology Information Cent er, Purdue, Indiana.

Givens, W.A., D.R. Shaw, W.G. Johnson, S.C. Weller, B.G. Young, R.G. Wilson, M.D.K. Owen and D. Jordan. 2009a. A grower survey of herbicid e use patterns in glyphosate-resistant cropping systems. Weed Technology 23:156-161.

Givens, W.A., D.R. Shaw, G.R. Kruger, W.G. Johnson, S.C. Weller, B.G. Young, R.G. Wilson, M.D.K. Owen and D. Jordan. 2009b. Survey of tillage trends following the adoption of glyphosate-resistant crops. Weed Technology 23:150-155.

McClelland, M.R., J.L. Barrentine, K.J. Br yant and E.P. Webster. 2000. Roundup Ready cotton programs in conservation tillage. Pages 197-201 in Proceedings of the 2000 Cotton Research Meeting, Fayetteville, Arkansas.

Osteen, C.D. and J. Fernandez-Cornejo. 2013. Econo mic and policy issues of U.S. agricultural pesticide use trends. Pest Management Science 69:1001-1025.

Price, A.J., K.S. Balkcom, S.A. Culpepper, J.A. Kelton, R.L. Nichol s and H. Schomberg. 2011. Glyphosate-resistant Palmer amaranth: A threat to conservation tillage. Journal of Soil and Water Conservation 66:265-275.

Sankula, S. 2006. Quantification of the impact s on US agriculture of biotechnology-derived crops planted in 2005. National Center for Food and Agricultural Polic y, Washington, D.C.

Towery, D. and S. Werblow. 2010. Facilitating conservation farming pr actices and enhancing environmental sustainability with agricultur al biotechnology: Exective summary. Conservation Technology Information Center, West Lafayette, Indiana.Monsanto Company Petitions 10

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### A ppendix A: Statistical Analysis of Tillage M arket Research Data

Summary of Statistical Analysis of Tillage Data

Purpose

Assess if tillage practices have significantly changed between 1998 and 2007, and between 2007 and 2013 (or 2012, for cotton)

.
Data Description

For the analysis PROC MEANS in SAS was used to calculate the acres that utilized each tillage type and total acres for each crop, region and year. The percent of total acres was calculated by dividing acres that utilized each tillage type by total acres.

Statistical Methods and Resul ts

A quadratic regression model of the following form was fit for each crop, region and tillage type combination:

Percent of total acres = β 0 

### + β 1 

### *Year + β 2 

### *Year* Year + ε (1)

in which β 0 

### is the intercept, β 1 

### is the linear slope, β 2 

### is the quadratic slope and ε is the residual error. PROC MIXED in SAS was used to fit model (1) separately for each crop, region and tillage type combinatio n. Tests were performed to determine if the quadratic slopes of the regression lines were significantly different from zero. These tests are displayed in Table 1. Twenty of the 42 tests observed quadratic slopes that were significantly different from ze ro at the 5% level of significance.

In the 20 cases where the quadratic slopes were significant, a quadratic regression model was deemed appropriate. For the 22 cases where the quadratic slopes were not significant, a linear regression model of the fol lowing form was fit for each crop, region and tillage type combination:

Percent of total acres = β 0 

### + β 1 

### *Year + ε (2)

in which β 0 

### is the intercept, β 1 

### is the linear slope and ε is the residual error. PROC MIXED in SAS was used to fit model (2) separ ately for each crop, region and tillage type combination. Tests were performed to determine if the linear slopes of the regression lines were significantly different from zero. These tests are displayed in Table 2. Fourteen of the 22 tests observed line ar slopes that were significantly different from zero at the 5% level of significance.

In the 14 cases where the linear slopes were s ignificant, a linear regression model was deemed appropriate. For the 8 cases where the linear slopes were not signific ant, there was no significant change in tillage practices over time.Monsanto Company Petitions 10

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### Conclusions

In 8 of the 42 crop, region and tillage type combinations there was no significant change over time.

In 14 of the 42 crop, region and tillage type combinations the change over time can be described using a linear regression model.

In 20 of the 42 crop, region and tillage type combinations the change over time can be described using a quadratic regression model.

The regression parameter estimates for the crop and regi on combinations with a significant the change over time, are displayed in Table 3.

Plots of the percent total acres data and model fit are displayed in the Appendix.Monsanto Company Petitions 10

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- 1. Tests to Determine if the Quadratic Slopes of the Regression Lines Were Sign ificantly
Different From Zero

Crop Region Tillage_Type P

- value

Corn East Conservation 0.1381

Corn East Conventional 0.6663

Corn East No

- Till 0.1161

Corn MidSouth Conservation 0.5547

Corn MidSouth Conventional 0.1925

Corn MidSouth No

- Till 0.05 82

Corn MidWest Conservation 0.0218 *

Corn MidWest Conventional 0.5444

Corn MidWest No

- Till 0.0015 *

Corn Southeast Conservation 0.1322

Corn Southeast Conventional 0.0038 *

Corn Southeast No

- Till 0.0018 *

Corn West Conservation 0.9108

Corn West Conventional 0.2174

Corn West No

- Till 0.1183

Cotton MidSouth Conservation 0.0018 *

Cotton MidSouth Conventional <.0001 *

Cotton MidSouth No

- Till <.0001 *

Cotton MidWest Conservation 0.2096

Cotton MidWest Conventional 0.0017 *

Cotton MidWest No

- T ill <.0001 *

Cotton Southeast Conservation 0.7367

Cotton Southeast Conventional 0.0002 *

Cotton Southeast No

- Till <.0001 *

Cotton West Conservation 0.0539

Cotton West Conventional 0.0582

Cotton West No

- Till 0.8615
Soybeans East Conservation 0.46 10
Soybeans East Conventional 0.0051 *Monsanto Company Petitions 10

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### Table A

- 1 (continued). Tests to Determine if the Quadratic Slopes of the Regression Lines Were Significantly Different From Zero

Crop Region Tillage_Type P

- value
Soybeans East No

- Till 0.0017 *
Soybeans Mid South Conservation 0.5038
Soybeans MidSouth Conventional 0.0003 *
Soybeans MidSouth No

- Till 0.0013 *
Soybeans MidWest Conservation 0.0006 *
Soybeans MidWest Conventional 0.0056 *
Soybeans MidWest No

- Till 0.0002 *
Soybeans Southeast Conservation 0.32 08
Soybeans Southeast Conventional 0.0495 *
Soybeans Southeast No

- Till 0.0447 *
Soybeans West Conservation 0.1184
Soybeans West Conventional 0.0921
Soybeans West No

- Till 0.7472

Note: Twenty of the 42 tests observed quadratic slopes that were si gnificantly different from zero at the 5% level of significance. The tests that were significant at the 5% level are marked with an ‘*’.Monsanto Company Petitions 10

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### Table A

- 2. Tests to Determine if the Linear Slopes of the Regression Lines Were Significantly Different From Zero

Crop Region Tillage_Type P

- value

Corn East Conservation 0.2078

Corn East Conventional <.0001 *

Corn East No

- Till <.0001 *

Corn MidSouth Conservation 0.0195 *

Corn MidSouth Conventional 0.4904

Corn MidSouth No

- Till 0.3690

Corn MidWest Convention al 0.0011 *

Corn Southeast Conservation 0.0835

Corn West Conservation 0.0011 *

Corn West Conventional <.0001 *

Corn West No

- Till 0.0114 *

Cotton MidWest Conservation 0.0210 *

Cotton Southeast Conservation <.0001 *

Cotton West Conservation <.0001 *

Cotton West Conventional <.0001 *

Cotton West No

- Till 0.0001 *
Soybeans East Conservation 0.1917
Soybeans MidSouth Conservation 0.1896
Soybeans Southeast Conservation 0.6675
Soybeans West Conservation 0.1233
Soybeans West Conventional 0.0067 *
Soybeans West No

- Till 0.0002 *

Note: Fourteen of the 22 tests observed linear slopes that were significantly different from zero at the 5% level of significance. The tests that were significant at the 5% level are marked with an ‘*’.Monsanto Company Petitions 10

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### Table A

- 3. Reg ression Parameter Estimates for the Crop and Region Combinations with a Significant the Change in Tillage Over Time

Crop Region Tillage Type Intercept Year Year*Year

Corn East Conventional 3466.72

- 1.7079

. Corn East No

- Till

- 3039.87 1.5340

. Corn MidS outh Conservation

- 1769.03 0.8933

. Corn MidWest Conservation 300587

- 299.62 0.07467

Corn MidWest Conventional 1114.90

- 0.5355

. Corn MidWest No

- Till

- 383597 381.93

- 0.09506

Corn Southeast Conventional 766604

- 763.20 0.1900

Corn Southeast No

- Till

- 120 2619 1198.66

- 0.2987

Corn West Conservation

- 2375.58 1.1991

. Corn West Conventional 3782.79

- 1.8592

. Corn West No

- Till

- 1307.20 0.6601

. Cotton MidSouth Conservation

- 1044452 1041.04

- 0.2594

Cotton MidSouth Conventional 2648507

- 2639.72 0.6577

Cott on MidSouth No

- Till

- 1603955 1598.68

- 0.3983

Cotton MidWest Conservation

- 2277.83 1.1529

. Cotton MidWest Conventional 1707629

- 1701.22 0.4237

Cotton MidWest No

- Till

- 2295716 2289.07

- 0.5706

Cotton Southeast Conservation

- 3534.42 1.7786

. Cotton South east Conventional 1405216

- 1399.58 0.3485

Cotton Southeast No

- Till

- 1304016 1300.48

- 0.3242

Cotton West Conservation

- 2656.63 1.3372

. Cotton West Conventional 4244.03

- 2.0828

. Cotton West No

- Till

- 1487.40 0.7456

. Soybeans East Conventional 902937

- 899.02 0.2238
Soybeans East No

- Till

- 1061879 1057.33

- 0.2632
Soybeans MidSouth Conventional 1373279

- 1368.84 0.3411
Soybeans MidSouth No

- Till

- 1208347 1204.77

- 0.3003
Soybeans MidWest Conservation 387479

- 386.03 0.09615
Soybeans MidWest Conventional 3 11116

- 309.83 0.07714Monsanto Company Petitions 10

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### Table A

- 3 (continued). Regression Parameter Estimates for the Crop and Region Combinations with a Significant the Change in Tillage Over Time

Crop Region Tillage Type Intercept Year Year*Year
Soybeans MidWest No

- Till

- 698495 695 .85

- 0.1733
Soybeans Southeast Conventional 600500

- 597.28 0.1485
Soybeans Southeast No

- Till

- 768636 765.12

- 0.1904
Soybeans West Conventional 3901.95

- 1.9250

. Soybeans West No

- Till

- 6423.22 3.2204

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### Appendi x A Figures

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### Appendix B: CTIC Survey Results of Leading Conservation Tillage Experts

The following pages summarize the results of the CTIC (Conservation Tillage Information Center) survey of 21 total (14 in Midwest and 7 in South) lea ding conservation tillage experts across the key agronomic regions of the U.S. for soybean, corn and cotton production. These experts were asked to rate the importance of 11 factors that could influence tillage practices of growers in their region. Respo nses the the question below are summarized on the following
pages.

Question: In general, how important are the following factors to the majority of the farmers in your region as they determine the total amount of tillage done to produce corn, regardless of whether the tillage is done prior to planting or done during the growing season? Choose the rating below that best reflects the importance of each factor in determining the amount of tillage being used.Monsanto Company Petitions 10

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### Table B

- 1. Midwest Corn (14 total Experts)

Nu mber of Experts Responding

Manage

excess

crop residue Manage existing weeds Manage Disease Manage Soil moisture Manage Soil temperature Prevent weed resistance Seed bed preparation Use of Strip till / vertical tillage tools Economics Availability of Labo r Water penetration

Not important / Not mentioned 4 6 4 4 4 8 4 6 6 8 6

Sometimes important 4 3 5 3 3 2 2 3 1 2 4

Quite important 2 2 4 5 5 2 3 2 3 2

Extremely important 4 3 1 2 2 2 5 3 7 1 2

Ranking Sum 1 34 30 30 33 33 26 37 30 36 25 28

1 Ranking Su m was calculated as follows, a number from 1 to 4 was assigned to each response category, with 1 assigned to ‘not important o r not mentioned’ and 4 assigned to ‘extremely important’. The assigned number was multiplied by the number of responses from the e xperts and then added together for each factor.Monsanto Company Petitions 10

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### Table B

- 2. Midwest Soybean (13 total Experts) Number of Experts Responding Manage

excess

crop residue Manage existing weeds Manage Disease Manage Soil moisture Manage Soil temperature Prevent weed

re sistance Seed bed preparation Use of Strip till / vertical tillage tools Economics Availability of Labor Water penetration

Not important / Not mentioned 6 4 7 3 5 6 4 10 4 2 4

Sometimes important 0 4 2 6 4 3 2 1 3 6 5

Quite important 1 2 2 2 1 2 3 0 2 3 2

Extremely important 6 3 2 2 3 2 4 2 4 1 1

Ranking Sum 1 33 30 25 29 28 26 33 20 32 27 24

1 Ranking Sum was calculated as follows, a number from 1 to 4 was assigned to each response category, with 1 assigned to ‘not i mportant or not mentioned’ and 4 ass igned to ‘extremely important’. The assigned number was multiplied by the number of responses from the experts and then added together for each factor.Monsanto Company Petitions 10

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### Table B

- 3. South Corn (6 total Experts)
Number of Experts Responding Manage

excess

crop residue Manage existing weeds Manage Disease Manage Soil moisture Manage Soil temperature Prevent weed resistance Seed bed preparation Use of Strip till / vertical tillage tools Economics Availability of Labor Water penetration

Not important / Not mentioned 2 2 3 1 2 2 1 2

Sometimes important 1 1 2 4 5 2 1 2 1 3 1

Quite important 3 1 1 2 1 4 2 2 1 1

Extremely important 1 1 1 3 1 2

Ranking Sum 1 13 11 10 14 11 13 18 12 20 14 15

1 Ranking Sum was calculated as follows, a number from 1 to 4 was assigned to each response category, with 1 assigned to ‘not important or not mentioned’ and 4 assigned to ‘extremely important’. The assigned number was multiplied by the number of responses from the e xperts and then added together for each factor.Monsanto Company Petitions 10

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### Table B

- 4. S outh

- Soybean (6 total Experts)
Number of Experts Responding Manage

excess

crop residue Manage existing weeds Manage Disease Manage Soil moisture Manage Soil temperature Prevent weed resistance Seed bed preparation Use of Strip till / vertical tillage

t ools Economics Availability of Labor Water penetration

Not important / Not mentioned 3 4 2 1 1 1

Sometimes important 2 2 1 3 4 1 2 3 1 2 3

Quite important 1 3 1 2 4 3 2 3 1 1

Extremely important 1 1 1 1 2 1 1

Ranking Sum 1 10 17 9 16 10 18 17 13 19 12 14

1 Ranking Sum was calculated as follows, a number from 1 to 4 was assigned to each response category, with 1 assigned to ‘not i mportant or not mentioned’ and 4 assigned to ‘extremely important’. The assigned number was multiplied by the numbe r of responses from the experts and then added together for each factor.Monsanto Company Petitions 10

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### Table B

- 5. South

- Cotton (6 total Experts)
Number of Experts Responding Manage

excess

crop residue Manage existing weeds Manage Disease Manage Soil moisture Manage Soil temperat ure Prevent weed resistance Seed bed preparation Use of Strip till / vertical tillage tools Economics Availability of Labor Water penetration

Not important / Not mentioned 3 2 1 2

Sometimes important 4 3 2 2 3 4 1 3 2 1

Quite important 1 1 1 3 1 1 3 2 4 3 2

Extremely important 1 2 1 1 1 1 2 1 1

Ranking Sum 1 15 17 10 17 11 18 16 16 20 17 14

1 Ranking Sum was calculated as follows, a number from 1 to 4 was assigned to each response category, with 1 assigned to ‘not i mportant or not mentioned’ and 4 assigned to ‘extremely important’. The assigned number was multiplied by the number of responses from the experts and then added together for each factor.