1 of 3

Dow AgroSciences LLC dowagro.com

9330 Zionsville Road Indianapolis, IN 46268 USA 

308/2E

May 27, 2014

Document Processing Desk

Office of Pesticide Programs (7504P)

U.S. Environmental Protection Agency

Room S-4900, One Potomac Yard

2777 South Crystal Drive

Arlington, VA 22202-4501

Attn: Ann Sibold, Team Leader 92

Corn Plant Incorporated Protectants with DvSnf7 dsRNA (a double stranded RNA transcript 

comprising a DvSnf7 inverted repeat sequence derived from Diabrotica virgifera) in combination 

with Bacillus thuringiensis Cry Proteins (Cry1A.105, Cry2Ab2, Cry3Bb1, Cry1F and Cry34/35Ab1

and the genetic material necessary for their production in corn

EPA No.: 62719-EUP-X

APPLICATION FOR EXPERIMENTAL USE PERMIT TO TEST THE STACKED TRAIT INSECT 

CONTROL CORN, COMBINATIONS NECESSARY FOR THE PRODUCTION AND CONTROLS

CONTAINING THE EVENTS, MON 89034, MON 88017, MON 87411, TC1507 AND DAS-59122-7 

Dow AgroSciences LLC and Monsanto Company have used conventional breeding techniques to develop 

the combined trait corn product that includes the plant-incorporated protectant MON 87411 alone and in 

combination with the traits, MON 89034, MON 88017, TC1507 and DAS-59122-7 which confers multiple 

modes of insect resistance to above-ground and below-ground insect pests. Each single event product 

contributes specific benefits to the combined product. MON 87411 produces a double stranded RNA 

(dsRNA) transcript comprising a DvSnf7 inverted repeat sequence derived from Diabrotica virgifera and 

the modified Bacillus thuringiensis subsp. kumamotoensis Cry3Bb1 protein to protect corn against corn 

rootworm (Diabrotica spp., CRW) larval feeding. MON 89034 produces two insecticidal proteins that 

protect against feeding damage caused by European corn borer (Ostrinia nubilalis; ECB) and other 

lepidopteran insect pests. MON 89034 was registered by EPA (EPA Reg. No.: 524-575) in June 2008. 

TC1507 produces the B. thuringiensis var. aizawai Cry1F protein to selectively control larvae of the ECB 

and other lepidopteran insect pests. TC1507 was registered by the EPA (EPA Reg. No. 68467-2) in May, 

2001. MON 88017 produces a modified B. thuringiensis subsp. kumamotoensis Cry3Bb1 protein to 

protect against corn rootworm larval feeding. MON 88017 was registered by the EPA (EPA Reg. No. 

524-551) in December, 2005. DAS-59122-7 produces the B. thuringiensis strain PS149B1 

Cry34Ab1/Cry35Ab1 binary insecticidal crystal proteins to protect against CRW. DAS-59122-7 was 

registered by EPA (EPA Reg. No. 68467-5) in August, 2005.

Enclosed is an application for an EUP to test the plant-incorporated protectant, MON 87411 alone and in 

combination with the traits, MON 89034, MON 88017, TC1507 and DAS-59122-7. The experimental 

program will provide information from research for breeding and observation nurseries, yield and 

herbicide tolerance trials, insect efficacy trials, product characterization and performance trials and insect 

resistance management trials.
2 of 3

Dow AgroSciences requests that the proposed EUP be granted from January 1, 2015 through March 31, 

2016.

A list of Participants who will supervise the experimental work conducted under this EUP is included. A 

list of cooperators involved in the program and counties where trials will be planted will be provided to the 

Agency in advance of planting.

Since this submission includes materials registered and owned by Dow AgroSciences and Monsanto 

Company, the Confidential Statements of Formula (CSFs) for eight of the products in this EUP application 

are provided by way of reference. The CSF for the Stacked Trait Insect Control Corn, Combinations 

Necessary for the Production and Controls Containing the Events, MON 89034, MON 88017, MON 87411, 

TC1507 and DAS-59122-7 is provided in the confidential attachment.

No plant material produced under this EUP will be used as either food or feed.

Monsanto previously provided a letter to EPA allowing EPA to discuss with Dow AgroSciences the 

development of the Plant-Incorporated Protectants that are the subject of this EUP.

The contents of the submission are listed below. A CD-ROM containing the fully releasable (“A”) 

documents in .pdf format is also provided.

Contents of the Submission

Volume/ 

Classification

MRID Contents

A Transmittal Document (this letter)

Volume 1 Administrative Materials

A Transmittal Document entitled “Application for an Experimental Use 

Permit 62719-EUP-X

A Application for Experimental Use Permit, EPA Form 8570-17, dated 

May 27, 2014

A Certification with Respect to Data Citation, EPA Form 8570-34, 

dated May 27, 2014

C

Basic Confidential Statement of Formula, EPA Form 8570-4, dated 

May 27, 2014. Stacked Trait Insect Control Corn, Combinations 

Necessary for the Production and Controls Containing the Events, MON 

89034, MON 88017, MON 87411, TC1507 and DAS-59122-7 (11

pages)

A Sections A - F

C Section G

List of Participants 

A

Data Matrix, EPA Form 8570-35, dated May 27, 2014 for Stacked Trait 

Insect Control Corn, Combinations Necessary for the Production and 

Controls Containing the Events, MON 89034, MON 88017, MON 87411, 

TC1507 and DAS-59122-7 (Agency Copy) 

A

Data Matrix, EPA Form 8570-35, dated May 27, 2014 Stacked Trait 

Insect Control Corn, Combinations Necessary for the Production and 

Controls Containing the Events, MON 89034, MON 88017, MON 87411, 

TC1507 and DAS-59122-7corn (Public Copy)
3 of 3

A

Complimentary Copy of the PRIA Service Fee for $49,000.00

Pay.gov Tracking ID: 25FHPJ6G; 

Agency Tracking ID: 74610166993

Complimentary Copy of the PRIA Service Fee for $42,165.00

Pay.gov Tracking ID: 25FI8VCV; 

Agency Tracking ID: 74610671008

Should you require any additional information, please feel free to contact me at (317) 337-3195.

Regards,

Greg Bradfisch, Ph.D.

Regulatory Leader – Biotech

317-337-3195