July 29, 20 IO 

Michael C. Gregoire 

Deputy Administrator 

Bioteclmology Regulatory Services 

Animal and Plant Health Inspection Service 

U.S. Department of Agriculture 

4700 River Road, Unit 98 

Riverdale, MD 20737 

Re: Petition 03-323-0Ip for Non-Regulated Status, Roundup ReadV® Sugarbeet -I; 

Event H7 Supplemcntal Regucst for "Partial Deregulation" or Similar Administrative Action 

Dear Mr. Gregoire: 

Monsanto Company ("Monsanto") and KWS SAAT AG ("KWS")jointly filed the petition 

for nonregulated status for Roundup Ready sugarbeet' Event H7-1 ("RRSB") which USDA's 

Animal and Plant Health Inspection Service ("APHIS") previously granted in March 2005. In light 

of recent developments in litigation, and with the support of thousands of sugarbeet growers 

nationwide and all sugarbeet cooperatives, processors and seed-producers, Monsanto and KWS 

jointly submit this supplemental request for "partial deregulation" or similar administrative action, 

as set forth below. 

Background 

On March 17,2005, APHIS granted nonregulated status for RRSB following nearly 100 

field trials, a 60-day comment period and issuance of an environmental assessment ("EA") 

concluding that the event presented "no significant impact on the human environment." In the 

years thereafter, a majority of our nation's sugarbeet growers apopted RRSB; wide-scale RRSB 

seed production began by 2006, and the multi-year process to develop appropriate RRSB varieties 

for growers in IO states resulted in RRSB cultivation on roughly 95% of all U.S. sugarbeet 

acreage. The Governrnent of Canada likewise approved RRSB for cultivation and human and 

animal consumption, and the European Union, Japan, Mexico, South Korea, Australia, New 

Zealand, China, Colombia, Russia, Singapore, and the Philippines each approved impOltation of 

sugar and other products derived from RRSB. Today, RRSB is processed into roughly half of our 

nation's domestic sugar supply. 

, ® Roundup and Roundup Ready are registered trademarks of Monsanto Technology LLC. 
On September 21, 2009, however, a Federal district COUlt in San Francisco lUled that 

APHIS's 2005 EA for RRSB did not adequately evaluate potential cross-pollination from RRSB 

seed crops to other crops. The COUlt held that APHIS "did not consider the effects of gene 

transmission on conventional farmers and consumers of sugar beet seed or of gene transmission to 

the related crops of red table beets and Swiss chard" and noted that such "seed production takes 

place primarily in the Willamette Valley of Oregon." Cellter for Food Safety v. Vilsack ("CFS''), 

No. 08-484, 2009 WL 3047227, *5, 13-14 (N.D. Cal. Sept. 21, 2009). That litigation is currently 

in the remedies phase, where the plaintiffs in the suit have sought a judicial order halting further 

planting of RRSB. Representatives of the thousands of sugarbeet growers nationwide along with 

sugarbeet cooperatives and processors, the seed companies who produce RRSB seed and Monsanto 

have intervened in this suit to urge the court not to halt ongoing or future RRSB cultivation. 

Specifically, the district court has been presented with evidence that an order immediately halting 

RRSB planting would have profound consequences for the nation's growers and many other 

parties, including that: 

• F81ming communities could suffer losses exceeding $2 billion; 

• Approximately eight sugarbeet processing facilities would close (likely forever); 

• More than 5,500 jobs would be lost; and 

• The resulting domestic sugar shortages would, under USDA estimates, cost 

consumers $2.972 billion in 20 II alone. 

Recently, the Supreme COUlt has addressed deregulation of a similar crop, Roundup Ready 

alfalfa, and provided significant guidance applicable here. See Monsanto Co. v. Geer/son Seed 

Farms, No. 09-475, -- S. Ct. --, 2010 WL 2471057 (2010). The Supreme Court concluded that, 

even where a COUIt has held that APHIS has violated NEP A with respect to a complete 

deregulation detennination,"[a]t that point, it was for the agency [APHIS] to decide whether and to 

what extent it would pursue apartial deregulation." Id. at *13. "If ... a limited and temporary 

deregulation satisfied applicable statutory and regulatory requirements, it could proceed with such 

a deregulation even if it had not yet finished (he onerous ElS required for complete deregulation." 

!d. The Supreme Court went on to identify a combination of geogl'aphic restrictions, isolation 

distances, and enforcement measures tllat could serve to eliminate any risk of "injury at all, much 

less irreparable injUly." Id. at *15. 

In light of this recent Supreme Court lUling, the Govemment has represented to the district 

court in San Francisco that, in the event the comt vacates the existing RRSB deregulation, APHIS 

has authority to deregulate "in part" to "allow planting to occur under the conditions proposed by 

APHIS while the EIS is being prepared." As APHIS explained, it could take such action if 

"[i]ntervenors submitted a new petition 01' a supplement 01' amendment to a previous petition for a 

determination ofnonregulated status ofRRSB." Federal Defs.' Supp. Br. on Penn. Inj. Reliefat I, 

13-14. The Governmen( further explained that the Supreme Court's decision in "Monsanto clearly 

indicates that this type of intelim administrative action would be permissible." !d. at 14; see also 

Monsanto, 2010 WL 2471057, at *15 (citing "representation from the Solicitor General" that 

APHIS has authority to do so). Separ'ately, based on its expClt analyses and review, APHIS has 

proposed to the district eomi a series of carefully tailored interim measures designed to address any 

potential risk of harm to other pmties from continued cultivation ofRRSB during the time period 

necessary for APHIS to reevaluate the RRSB petition for nonregulated status. Although there has 

been no record of any harm to any grower of any other crops in the multiple years of wide-scale 

RRSB production without these restrictions in place, the intervenors in this litigation have agreed 

that these additional interim requirements will reduce further an already negligible potential for 

any impact to other parties from RRSB. 

2 
Request for Interim Measures 

With the support of each of the sugarbeel growers, cooperatives, processors and seed 

companies who have intervened in the pending RRSB litigation, Monsanto and KWS now jointly 

request that, in the event the court in the RRSB litigation vacates the existing deregulation 

determination, APHIS grant nonregulated status ill pari or take similar administrative action to 

authorize continued cultivation of the RRSB crop subject to Ihe carefully tailored interim measures 

proposed by APHIS. Petitioners believe this request is appropriate in this context hecause: 

(1) As APHIS explained its recent Supplemental Brief, the U.S. Supreme Court has 

clarified that APHIS has authority to implement interim measures through paltial deregulation or 

similar means for this purpose; 

(2) Sugarbeet growers nationwide, along with sugarbeet cooperatives, processors, seed 

companies and other interests, face significant harm from any halt in RRSB planting, cultivation, 

harvesting or processing; and 

(3) Petitioners are requesting that APHIS implement measures that APHIS has already 

itself reviewed, analyzed and supported in the litigation context. 

Attached to this letter is an Environmental Report, providing additional analysis of the 

proposed interim measures. The analysis in APHIS's Oliginal EA addressing Monsanto and 

KWS's petition, along with the SOOO-page administrative record relating thereto and this 

Environmental Report all support petitioners' request for partial deregulation or similar 

administrative action. 

Thank you very much for your attention to this matter. 

Sincerely, 

H. Keith Reding, Ph.D. 

Regulatory Affairs Manag 

3 
ussche 

Executive Board ofKWS SAAT AG 

Dr. Peter Hofmann 

Head of Sugar Beet Division 

4 
ENVIRONMENTAL REPORT 

Interim Measures for Cultivation of 

Roundup Ready® Sugar Beet Event H7-1 

July 30, 2010 
ACCase 

a.e. 

ALS 

AMS 

AP 

APHIS 

APM 

ARS 

ASTA 

BNF 

BRS 

CEQ 

CFIA 

CFR 

CFS 

CMS 

cPAD 

CTIC 

DEIS 

DNA 

EA 

EC 

EEC 

EFSA 

EIQ 

EIS 

EPA 

EPSPS 

ER 

ERS 

EU 

FDA 

FFDCA 

FIFRA 

Event H7-1 

Draft ER 

ACRONYMS AND ABBREVIATIONS 

acetyl-CoA carboxylase (enzyme) 

acid equivalent 

acetolactate synthase (enzyme) 

Agricultural Marketing Service (USDA) 

Adventitious presence 

Animal and Plant Health Inspection Service (USDA) 

American Public Media 

Agricultural Research Service (ARS) 

American Seed Trade Association 

Biotechnology Notification Files 

Biotechnology Regulatory Service (USDA APHIS) 

Council on Environmental Quality 

Canadian Food Inspection Agency 

Code of Federal Regulations 

Center for Food Safety 

cytoplasmic male sterility 

chronic Population Adjusted Dose 

Conservation Technology Information Center 

Draft Environmental Impact Statement 

Deoxyribonucleic Acid 

Environmental Assessment 

European Commission (EU) 

Estimated Environmental Concentration 

European Food Safety Authority 

Environmental Impact Quotient 

Environmental Impact Statement 

Environmental Protection Agency (US) 

5-enolpyruvylshikimate-3-phosphate synthase (enzyme) 

Environmental Report 

Economic Research Service (USDA) 

European Union 

Food and Drug Administration (US) 

Federal Food, Drug, and Cosmetic Act 

Federal Insecticide, Fungicide, and Rodenticide Act 

Acronyms 

7/28/2010 
FONSI 

FQPA 

FSA 

FSANZ 

ft 

GE 

GM 

GMO 

GPS 

GR 

GT 

HQ 

HTS 

1M/NRC 

IPM 

IPA 

ISF 

NASS 

NEPA 

NOAEL 

NOP 

NRC 

OECD 

OP 

OSTP 

PCR 

PHI 

PNT 

POEA 

PPA 

PPE 

PPI 

rDNA 

RED 

Event H7-1 

Draft ER 

Finding of No Significant Impact 

Food Quality Protection Act 

Farm Service Agency 

Food Standards Australia New Zealand 

feet 

Genetic engineering or genetically engineered 

Genetically modified 

Genetically modified organism 

Global Positioning System 

Glyphosate resistant 

Glyphosate-tolerant 

Hazard quotient 

Harmonized Tariff Schedule 

Institute of Medicine and National Research Council 

Integrated pest management 

Isopropylamine 

International Seed Federation 

National Agricultural Statistical Service (USDA) 

National Environmental Policy Act 

No-Observed-Adverse-Effect-Level 

National Organic Program 

National Research Council 

Organization for Economic Cooperation and Development 

Open-pollinated 

Office of Science and Technology Policy 

Polymerase chain reaction 

Post Harvest Intervals 

Plant with a Novel Trait 

Polyethoxylated Tallow Amine 

Plant Protection Act 

Personal Protective Equipment 

Pre-plant incorporated (herbicide) 

Recombinant DNA 

Reregistration Eligibility Decision 

ii 

Table of Contents 

7/28/2010 
RfD 

RR 

R&D 

SBRED 

SOP 

TUG 

T-DNA 

UC 

U.S. 

USC 

USDA 

USDC 

USFWS 

WCBS 

WHO 

WSSA 

WVSSA 

Event H7-1 

Draft ER 

Reference Dose 

Roundup Ready® 

Research and Development 

Sugar beet Research and Education Board of Minnesota and North Dakota 

Standard Operating Procedures 

Technology Use Guide 

Transferred DNA 

University of California 

United States 

United States Code 

US Department of Agriculture 

U.S. District Court 

U.S. Fish and Wildlife Service 

West Coast Beet Seed Company 

World Health Organization 

Weed Science Society of America 

Willametle Valley Specialty Seed Association 

iii 

Table of Contents 

7/28/2010 
TABLE OF CONTENTS 

INTRODUCTION ................................................................................. 1 

1.1 PURPOSE OF THIS ER ................................................................ 1 

1.1.1 Background ...................................................................... 1 

1.1.2 Purpose of and need for action ............................................ 3 

1.1.3 APHIS proposed interim measures/time frames for 

implementation ................................................................. 3 

1.2 RATIONALE FOR CREATION OF EVENT H7-1 .................................. 8 

1.3 COURT RULING AND ISSUES IDENTIFIED ..................................... 9 

1.3.1 Gene transmission from H7-1 sugar beets in production fields .. 9 

1.3.2 Gene transmission to conventional sugar beets in seed 

production ...................................................................... 10 

1.3.3 Gene transmission to red table beets and Swiss chard .......... 10 

1.3.4 Socioeconomic impacts ..................................................... 10 

1.3.5 Willingness of buyers to accept sugar derived from GE sugar 

beets ............................................................................. 11 

1.3.6 Restrictions/labeling requirements by some countries on GE 

products ......................................................................... 11 

1.3.7 Potential for development of glyphosate-resistant weeds ....... 11 

1.3.8 Cumulative effects of increased use of glyphosate ................ 12 

1.4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK 12 

1.4.1 USDA Regulatory Authority ............................................... 13 

1.4.2 EPA regulatory authority ................................................... 14 

1.4.3 FDA regulatory authority ................................................... 14 

1.5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGy .......... 15 

1.5.1 Non-GMO Project Working Standard ................................... 17 

1.5.2 Growth in organic and GE farming ...................................... 17 

1.6 COEXISTENCE IN US AGRICULTURE ........................................... 17 

1.6.1 Coexistence and biotechnology .......................................... 17 

1.6.2 USDA position on coexistence and biotechnology .................. 18 

1.6.3 Coexistence in US crop production ..................................... 19 

1.7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL 

BIOTECHNOLOGy .................................................................... 20 

1.8 ALTERNATIVES CONSIDERED .................................................... 21 

Event H7-1 

Draft ER 

1.8.1 Alternative 1 - No Action (full regulation) ............................ 21 

1.8.2 Alternative 2 - Partial Deregulation with Interim Conditions ... 21 

iv 

Table of Contents 

7/28/2010 
SECTION 2.0 AFFECTED ENVIROMENT ............................................. 22 

AFFECTED ENVIROMENT .................................................................. 22 

2.1 SUGAR BEET CHARACTERISTICS AND USES ................................ 22 

2.2 ACCEPTANCE OF EVENT H7-1 SUGAR BEETS ............................... 23 

2.3 SUGAR BEET ROOT PRODUCTION .............................................. 24 

2.3.1 US Production by regions .................................................. 24 

2.3.2 Grower-processor relationships .......................................... 27 

2.3.3 Sugar beet cultivation practices ......................................... 29 

2.3.4 Sugar beet bolters and volunteers ...................................... 31 

2.4 GENE FLOW ............................................................................ 36 

2.5 SUGAR BEET WEED MANAGEMENT ............................................. 39 

2.5.1 Weed characteristics and concerns ..................................... 39 

2.5.2 Sugar beets and weeds ..................................................... 40 

2.5.3 Problem weeds in sugar beet production ............................. 41 

2.5.4 Other non-herbicide weed management practices ................. 43 

2.5.5 Use of herbicides to control weeds ..................................... 43 

2.5.6 Weed control with conventional sugar beets ........................ 43 

2.5.7 Weed control with event H7-1 ........................................... 51 

2.6 HERBICIDE RESISTANCE .......................................................... 51 

2.7 SUGAR BEET SEED PRODUCTION ............................................... 53 

2.7.1 Variety development ........................................................ 53 

2.7.2 Hybrids and cytoplasmic male sterility ................................ 54 

2.7.3 Commercial sugar beet seed production .............................. 55 

2.8 RED TABLE BEET, SWISS CHARD, AND SPINACH BEET PRODUCTION62 

2.S.1 Vegetable beet production ................................................. 62 

2.S.2 Red table beet and Swiss chard seed production .................. 63 

2.S.3 Organic Red Table Beet and Swiss Chard Production ............. 65 

2.9 NATIVE AND UNCULTIVATED NON-NATIVE BEETS ........................ 70 

2.9.1 Native beets .................................................................... 70 

2.9.2 Uncultivated wild beets in the US ....................................... 70 

2.9.3 Weed beets ..................................................................... 74 

2.9.4 Feral crops ...................................................................... 75 

2.10 FOOD AND FEED USES OF SUGAR BEET ...................... 76 

2.11 

2.12 

Event H7-1 

Draft ER 

PHYSICAL AND BIOLOGICAL ISSUES ........................... 76 

SOCIOECONOMICS AND HEALTH ................................ 76 

v 

Table of Contents 

7/28/2010 
SECTION 3.0 ENVIRONMENTAL CONSEQUENCES ............................. 78 

3.1 PLANT PEST PROPERTIES AND UNINTENDED EFFECTS .................. 78 

3.1.1 Background .................................................................... 78 

3.1.2 Evaluation of intended effects ............................................ 82 

3.1.3 Evaluation of possible unintended effects ............................ 83 

3.2 WEEDINESS PROPERTIES, VOLUNTEERS AND FERAL CROPS .......... 85 

3.2.1 Weediness properties of sugar beet.. .................................. 85 

3.2.2 Event H7-1 sugar beet and weediness ................................ 85 

3.2.3 Sugar beet volunteers ...................................................... 86 

3.2.4 Impact summary ............................................................. 87 

3.3 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON 

CONVENTIONAL SUGAR BEET CROPS ......................................... 88 

3.3.1 Pollen sources in production fields ...................................... 88 

3.3.2 Potential for gene flow in root production fields .................... 89 

3.3.3 Potential for mixing of event H7-1 and conventional sugar beets89 

3.3.4 Consequences of gene flow in production fields .................... 90 

3.3.5 Potential consequences from mechanical mixing ................... 90 

3.3.6 Impact Summary ............................................................. 91 

3.4 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON ORGANIC SUGAR BEET 

CROPS ................................................................................... 92 

3.4.1 Impact summary ............................................................. 92 

3.5 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON OTHER BETA (NONSEED) CROPS ......................................................................... 92 

3.5.1 Impact summary ............................................................. 93 

3.6 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON OTHER BETA 

SEED PRODUCTION AREAS ....................................................... 94 

3.6.1 Impact summary ............................................................. 94 

3.7 IMPACTS OF EVENT H7-1 ROOT CROPS ON NATIVE BEETS ............ 95 

3.7.1 Impact summary ............................................................. 95 

3.8 IMPACTS OF EVENT H7-1 CROPS ON NON-NATIVE WILD AND 

WEED BEETS ........................................................................... 95 

3.8.1 Impact summary ............................................................. 96 

3.9 IMPACTS OF EVENT H7-1 SEED PRODUCTION ON CONVENTIONAL 

SUGAR BEET AND OTHER BETA SEED CROPS .............................. 97 

Event H7-1 

Draft ER 

3.9.1 Maintaining seed purity, identify and quality ........................ 97 

3.9.2 Summary of practices for sugar beet seed production ........... 98 

3.9.3 Sugar beet seed production since 2007 ............................... 98 

3.9.4 Measured sugar beet pollen dispersal ................................. 100 

3.9.5 Modeled sugar beet pollen dispersal .................................. 101 

vi 

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7/28/2010 
3.9.6 Site-specific assessment of cross-pollination potential in the 

Willamette Valley ............................................................ 101 

3.9.7 Use of event H7-1 trait on male-sterile female .................... 102 

3.9.8 Red table beet offtypes .................................................... 102 

3.9.9 No sensitivity to event H7-1 by conventional sugar beet 

growers; Stewardship regarding mechanical mixing ............. 103 

3.9.10 Question of zero tolerance ............................................... 104 

3.9.11 Seed availability ............................................................. 105 

3.9.12 Impact Summary ............................................................ 105 

3.10 LIVESTOCK PRODUCTION SySTEMS ........................... 107 

3.11 FOOD AND FEED ..................................................... 107 

3.11.1 FDA authority and policy .................................................. 108 

3.11.2 FDA biotechnology consultation note to the file BNF 000090.109 

3.11.3 Health Canada approval 2005 ........................................... 112 

3.11.4 Canadian Food Inspection Agency (CFIA) approval 2005 ...... 112 

3.11.5 EFSA risk assessment and EC authorization ........................ 113 

3.11.6 Other approvals .............................................................. 114 

3.11.7 Willingness of the buyer to accept sugar from event H7-1. .... 115 

3.11.8 Impacts ......................................................................... 115 

3.12 WEED CONTROL AND GLYPHOSATE RESISTANCE ......... 116 

3.12.1 Herbicide-resistant weeds ................................................ 116 

3.12.2 Glyphosate-resistant weeds .............................................. 119 

3.12.3 Impact summary ............................................................ 122 

3.13 PHYSICAL. .............................................................. 123 

3.13.1 Land Use ....................................................................... 123 

3.13.2 Air Quality and Climate .................................................... 125 

3.13.3 Surface water quality ...................................................... 126 

3.13.4 Groundwater quality ........................................................ 127 

3.14 BIOLOGICAL ........................................................... 128 

3.14.1 Plant and Animal Exposure to Glyphosate ........................... 128 

3.14.2 Threatened and Endangered Species ................................. 134 

3.15 HUMAN HEALTH AND SAFETY .................................... 136 

3.15.1 Consumer Health and Safety ............................................ 136 

3.15.2 Hazard Identification and Exposure Assessment for Field 

Workers ........................................................................ 137 

3.16 ECONOMIC IMPACTS ................................................ 139 

Event H7-1 

Draft ER 

3.16.1 Sugar beet processing ..................................................... 139 

3.16.2 USDA's role in sugar marketing ......................................... 140 

3.16.3 Economic Impacts ........................................................... 140 

vii 

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7/28/2010 
3.17 SOCIAL AND ECONOMIC IMPACTS ON RED BEET AND 

CHARD GROWERS .................................................................. 145 

SECTION 4.0 CUMULATIVE IMPACTS ............................................. 148 

4.1 CLASS OF ACTIONS TO BE ANALyZED ....................................... 148 

4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS .. 148 

4.3 PARTIAL. CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF 

GLYPHOSATE RESISTANT WEEDS ............................................. 149 

4.4 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE 

USAGE WITH THE CULTIVATION OF GLYPHOSATE TOLERANT CROPS149 

Event H7-1 

Draft ER 

4.4.1 Land Use, Air Quality and Climate ..................................... 152 

4.4.2 Water Quality ................................................................. 152 

4.4.3 Biological ....................................................................... 153 

4.4.4 Human Health and Safety ................................................ 154 

4.4.5 Summary of Potential Cumulative Impacts from Increased Use 

of Glyphosate ................................................................. 160 

viii 

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7/28/2010 
APPENDICES 

A Willametle Valley Specialty Seed Association (WVSSA) specialty seed production 

isolation guidelines and Columbia basin vegetable seed field isolation standards 

B West Coast Beet Seed Company protocol for genetically modified (GM) seed production 

and GM grower guidelines 

C International Seed Federation Code of Conduct 

D Sugar Beet Production by County and State 

E 2010 Technology Use Guide (TUG) 

TABLES 

Table 2-1 

Table 2.2 

Table 2-3 

Table 2-4 

Table 3-1 

Table 3-2 

Table 3-3 

Table 4-1 

Table 4-2 

Table 4-3 

Table 4-4 

Table 4-5 

FIGURES 

Figure 1-1 

Figure 2-1 

Figure 2-2 

Figure 2-3. 

Figure 2-4 

Figure 2-5 

Figure 2-6. 

Figure 2-7 

Figure 2-8 

Figure 2-9 

Figure 2-10 

Figure 4-1 

Event H7-1 

Draft ER 

U.S. sugar beet production, 2009/2010 season 

Rotational crops following U.S. sugar beet production and an estirnation of 

rotational crops as Roundup Ready® crops 

Herbicide applications to sugar beet acres in the U.S., 2000 

Effectiveness of herbicides on major weeds in sugar beets 

Major sugar beet weeds with resistance to herbicide groups used in sugar beets 

Sugar beet acres planted 2005 to 2010 

Production loss and project costs from a GT sugar beet injunction 

Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on 

Freshwater Fish 

Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on 

Freshwater Aquatic Invertebrates 

Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on 

Aquatic Plants (Algae and Duckweed) 

Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison 1 

Exposure Mitigation 

Potential Reduction in Risk from Use of Glyphosate Compared to Traditional 

Herbicides Used in US Sugar Beet Production 

Alternative 3 Roundup Ready® Sugar Beet-Free Zone 

U.S. sugar beet regions and county production 

2010 distribution by state of acres planted in sugar beets 

Herbicide resistance worldwide 

Willametle Valley 

Distribution of "other" organic vegetable production, 2008 

California acreage of organic beets (non-sugar), 2007 

California gross sales of organic beets (non-sugar), 2007 

California acreage of organiC Swiss chard, 2007 

California gross sales of organic Swiss chard, 2007 

All CA counties with Beta records 

Growth in adoption of genetically engineered crops in US 

ix 

Table of Contents 

7/28/2010 
INTRODUCTION 

This Environmental Report (ER) examines the environmental impacts of continued cultivation of 

Roundup Ready® sugar beet event H7-1 (event H7-1) for a temporary period subject to a range 

of interim measures, including geographic restrictions, stewardship requirements and other 

limitations -- identified and analyzed by the US Department of Agriculture's (USDA) Animal and 

Plant Health Inspection Service (APHIS) in Center for Food Safety v. Vi/sack, No. OB-4B4, N.D. 

Cal. This ER is provided in connection with the petitioners' supplemental request for nonregulated status in part (commonly known as "partial deregulation") for event H7-1. This 

document is intended to provide information that may be utilized by APHIS in complying with the 

National Environmental Policy Act (NEPA)' and its applicable regulations2 either in connection 

with partial deregulation of event H7-1 or for any other regulatory or administrative action by 

APHIS adopting the interim measures addressed herein. The interim measures are intended to 

apply until APHIS completes its NEPA review of the petition for nonregulated status for event 

H7-1 and reaches a final determination regarding the petition. 

The sugar produced from sugar beets, which were planted on approximately 1.2 million acres in 

the US in 2010, accounts for over half the US sugar production. Cash receipts for sugar beets 

were $1.3 billion in the 2007-200B crop year. Event H7-1, which has been genetically 

engineered to be tolerant to the herbicide glyphosate, has been grown on a large scale in the 

US for multiple years and accounted for approximately 95 percent of the sugar beet planted in 

the US in the 2009/2010 crop year (USDA NASS, 201 ~b; USDA ERS, 2009a and 2009b). 

1.1 PURPOSE OF THIS ER 

1.1.1 Background 

In 2003, under the requirements of the Plant Protection Act (PPA),3 Monsanto Company and 

KWS SAAT AG (Monsanto/KWS) submitted a petition (Petition No. 03-323-01P) to APHIS for a 

determination of non-regulated status for event H7-1 and all progeny derived by conventional 

breeding from this event (Schneider, 2003). APHIS, through its Biotechnology Regulatory 

Service (BRS), is one of three federal agencies responsible for regulating biotechnology in the 

US under the Coordinated Framework described in Section 1.4. APHIS regulates genetically 

engineered (GE) organisms that may be plant pests, the Environmental Protection Agency 

, NEPA of 1969, as amended; Title 42 of the US Code (42 USC) §§4321-4347 

2 Council on Environmental Quality (CEQ) regulations implement NEPA and are found in Title 40 of the Code of 

Federal Regulations (40 CFR), Parts 1500 through 1508. The U.S. Department of Agriculture has implemented 

NEPA regulations, which are found at 7 CFR Part 1b, as has APHIS, and those are found at 7 CFR part 372. 

3 7 USC §§7701-7786 

Event H7-1 

Draft ER 1 

Introduction 

7/28/2010 
(EPA) regulates plant incorporated protectants and herbicides used with herbicide-tolerant 

crops, and the US Department of Health and Human Services' Food and Drug Administration 

(FDA) regulates food and animal feed. The FDA completed its consultation process for event 

H7-1 in 2004 and EPA agreed that its previous approval for glyphosate residue in sugar beet 

roots, tops and dried pulp was also applicable to event H7-1 ((Tarantino, 2004; Bonette, 2004; 

Schneider, 2003, p. 14). NEPA requires federal agencies to evaluate the potential impact of 

proposed major federal actions and consider such impacts during the decision-making process. 

After agency review for safety, including an evaluation of relevant scientific data and all public 

comments relating to potential plant pest risks and related environmental impacts, APHIS 

issued an EA pursuant to NEPA in 2005 (USDA APHIS, 2005). Based on that EA, APHIS 

reached a finding of no significant impact (FONSI) on the environment from the unconfined 

cUltivation and agricultural use of event H7-1 and its progeny (USDA APHIS, 2005, p. 1). 

Accordingly, in March 2005, APHIS granted non-regulated status to event H7-1 (USDA APHIS, 

2005, p. 26). 

After event H7-1 was deregulated, the multi-year process of bringing it to commercial production 

began. Large scale commercial seed production began in 2006 to produce the seed crop used 

for planting root crops in 2008. Small scale root production occurred in 2006 and 2007. In 

January 2008, the Organic Seed Alliance, Sierra Club, High Mowing Organic Seeds, and the 

Center for Food Safety (CFS) filed a lawsuit against the USDA over its decision to deregulate 

event H7-1, claiming the USDA failed to take a "hard look" at the environmental effects of its 

decision to deregulate. The plaintiffs in the suit did not seek a preliminary injunction to halt 

planting. In September 2009, the court granted the plaintiffs' motion for summary judgment in 

the merits phase of the lawsuit, concluding that APHIS was required to prepare an 

environmental impact statement (EIS) before approving its deregulation of GE sugar beets. In 

December 2009, the court issued a schedule for the remedies phase of the lawsuit. At that 

point, representatives of thousands of family farms that were growing event H7-1 sugar beet 

root crops along with the four seed companies who produced seed and other interested parties 

were permitted to participate in the suit. 

In May 2010, while the remedies phase of the lawsuit was proceeding, Cindy Smith, the APHIS 

Administrator, filed a declaration in the suit anticipating completion of the EIS in May 2012 

(Smith, 2010b, pp. 7-8) and suggested that the court enter an order imposing certain interim 

measures that would allow continued cultivation of event H7-1. These interim measures would 

include geographic restrictions and a range of stewardship reqUirements, and would apply for a 

Event H7-1 

Draft ER 2 

Introduction 

7/28/2010 
temporary period pending completion of the EIS and the corresponding record of decision 

(ROD), and implementation of that decision. (Smith, 2010b, pp. 19-22). Alternatively, 

Administrator Smith proposed that the Court remand the case to APHIS with the intention that 

APHIS would take action to implement these interim measures administratively. On May 25, 

2010, APHIS issued a notice of intent to prepare an EIS and a proposed scope of study (APHIS 

2010). 

On June 21,2010, the U.S. Supreme Court ruled in litigation related to Roundup Ready® 

alfalfa, clarifying that a court in a NEPA case may not preemptively bar APHIS from issuing a 

"partial deregulation" or taking other administrative action to implement interim measures for 

cUltivation of a genetically engineered crop while the agency completes an EIS evaluating 

complete deregulation. Monsanto Co. v. Geertson Seed Farms, No. 09-475, 561 U.S. (2010). 

1.1.2 Purpose of and need for action. 

The purpose of this ER, which has been prepared to support an anticipated EA, is to examine 

the environmental impacts of implementing interim measures, either through a partial 

deregulation of event H7-1 lines of glyphosate tolerant sugar beets or certain other 

administrative means. The interim measures have been identified to address concerns 

regarding potential impacts related to the planting and cultivation of event H7-1 while the EIS 

evaluating complete deregulation is being prepared. If APHIS concludes that an EA supports a 

FONSI for such interim rneasures, APHIS could decide to implement such measures through 

"partial deregulation" pending APHIS's determination on complete deregulation. 

1.1.3 APHIS proposed interim measures/time frames for implementation 

APHIS' proposed interim measures for Roundup Ready® sugar beets (RRSB), to be 

implemented either through a partial deregulation or other administrative means, are detailed 

below. These measures are the same as those proposed by Administrator Smith to the court 

(Smith, 2010b, pp. 19-22), along with time frames for implementation of those measures . 

.Interil1l11leaSlires Proposed by APHIS to tfle COllrt 

Administrator Smith proposed the following interim measures in the lawsuit discussed above: 

1) Roundup ReadY' Sugar Beet-Free Zone 

The planting of RRSB is prohibited in the entire State of California and in the State of 

Washington in the following counties west of the Cascades: Clallam, Jefferson, Grays Harbor, 

Island, Pacific, Mason, Thurston, Lewis, Cowlitz, Clark, Whatcom, Skagit, Snohomish, King, 

Event H7-1 

Draft ER 3 

Introduction 

7/28/2010 
Pierce, Skamania, San Juan, Kitsap, and Wahkiakum Counties. [These counties are shown in 

this ER in Figure 1-1]. 

2) A Coexistence Zone for Beta Seed Crop Production in the Willamette Valley in Oregon 

a. All parties to this action who grow Beta seed crops in the Willamette Valley must adhere 

to a four mile isolation distance between RRSB seed crops and other Beta seed crops. 

b. All parties to this action who grow Beta seed crops in the Willamette Valley must follow 

the Willamette Valley Specialty Seed Association (WVSSA) pinning procedures. 

3) Disclosure of Information Regarding Male Fertile RRSB Seed Crops. 

All growers of RRSB male fertile seed crops must provide locations with GPS coordinates to 

APHIS/BRS of any RRSB male fertile seed crops in the United States that exist at the time the 

Court's Order is issued or that are planted at any time during the interim period in which the EIS 

is being prepared. Information regarding existing plantings must be provided to APHIS within 

30 days after issuance of the Order; information regarding future plantings during the interim 

period must be provided to APHIS within one week after the completion of planting of any RRSB 

male fertile seed crops. Within 60 days after issuance of the Order, APHIS/BRS shall set up a 

toll-free number that growers of non-GE Beta seed crops may use to request from APHIS/BRS 

the approximate distances from the nearest RRSB male fertile seed crop to their non-GE Beta 

seed crop. 

Upon calling this number, the caller shall certify to APHIS/BRS that the caller is a grower of nonGE Beta seed crops or intends to grow non-GE Beta seed crops at an existing location in the 

United States. APHIS/BRS shall only provide to the caller the approximate distance from the 

nearest RRSB male fertile seed crop location to the caller's non-GE Beta seed crop. 

Event H7-1 

Draft ER 4 

Introduction 

7/28/2010 
BRITISHCOLUt'v\BIA ~,-~"-"-,,-,,-,,-,,-,,--,,,,-,,-,,,,-,,--,-,,~"-",-"-1 

Chelan 

Kittitas 

Yakima 

Klickitat 

OI,ECON 

Figure 1-1. Roundup Ready® Sugar Beet-Free Zone 

Sources: Smith, 2010b; National Atlas ofthe United States 

Event H7-1 

Draft ER 5 

Okanogan 

Douglas 

Grant 

Benton 

Ferry Slevens 

Lincoln 

Adams 

Franklin 

- Wall, Wall, 

Pend 

Dreme 

Spokane 

Whitman 

Garfield 

Introduction 

7/28/2010 
4) Measures to Prevent Mixing of Conventional Sugar Beet Seed and RRSB. 

RRSB seed producers shall follow protocols to ensure that mechanical mixing of material 

containing the RRSB trait and non-GE Beta seeds does not occur. Those protocols shall 

include: 

a. A visual identification system for RRSB material (basic seed, stock seed, transplants 

(stecklings), and commercial seed) that accompanies seed material throughout the 

production system to delivery to ultimate purchaser; 

b. A companion seed-lot based tracking and tracing system that is fully auditable; 

c. Requirements for physical separation of RRSB material at all points in the seed 

production process from non-GE Beta material; 

d. Requirements for monitoring, treating, and cleaning of all planting, cultivation and 

harvesting equipment to prevent RRSB seed, pollen or stecklings from being physically 

transferred out of production areas by inadvertent means; 

e. Requirements for disposal of all unused RRSB stecklings by returning unused stecklings 

to the nursery field of origin and subsequent destruction through standard agricultural 

practices (physical destruction with tillage and chemical destruction in the subsequent 

crop);); 

f. Requirements for contained seed transport from field to cleaning facility, vehicle cleaning 

after transport of RRSB seed before use for other purposes, and devitalization of RRSB 

material derived from cleaning vehicles or processing facilities; 

g. Prohibition on grower production of a RRSB seed and chard/red beet seed production 

on the same location/premises in the same year; 

h. Prohibition on RRSB seed grower use or sharing of planting/cultivation equipment that 

might be used in a non-GE Beta seed production in the same growing year; 

i. Prohibition on RRSB seed grower use of the same combine to harvest RRSB and nonGE Beta seed in the same year; 

Event H7-1 

Draft ER 6 

Introduction 

7/28/2010 
j. Provisions to force same-year sprouting of any RRSB seed left behind in production field 

for removal and destruction; plus 3-year monitoring of fields thereafter, along with 

removal and destruction of any beet plants; 

k. Employee training in all aspects of a. through j. above; 

I. No RRSB seed shall be cleaned or processed in any processing facility that also cleans 

and processes red beet or Swiss chard seed; 

m. Recordkeeping to document compliance of a-I. 

5) Control of Any Bolters in the RRSB Root Crop Fields. 

All RRSB root crop growers must have contractual measures in place that require RRSB root 

crop growers to survey, identify, and eliminate any bolters in their root crop fields before they 

produce pollen or set seed. 

6) Control of Any Bolters in Harvested RRSB Root Crop in Outdoor Storage. 

All sugar beet processors or cooperatives that use RRSB must have measures in place to 

survey, identify, and eliminate any bolters in outdoor storage before they produce pollen or set 

seed. 

7) Third Party Audit for Compliance. 

APHIS will require third party audits to ensure that RRSB producers comply with requirements 

in paragraphs two and four above. APHIS expects that AMS [Agricultural Marketing Service], 

USDA, will be the third party auditor using its AMS-USDA Process Verified Program. 

Time ji'ame for Implemelltatioll 

While certain interim measures could be implemented shortly after APHIS issues its interim 

order of partial deregulation or takes other administrative action regarding event H7-1 (e.g., Item 

3), certain measures may require some additional time to fully implement. This ER makes the 

following assumptions as to when the various components of the interim measures would be 

implemented: 

(1) RRSB-free zone. The sugar beet seed companies have represented that no RRSB 

sugar beet crops have been or would be planted in California or the subject counties in 

Washington State. Thus, these restrictions can be implemented immediately. 

Event H7-1 

Draft ER 7 

Introduction 

7/28/2010 
(2) Willametie Valley coexistence zone 

While certain isolation distance and pinning requirements have already existed for years, the 

four-mile isolation distance and the pinning and audit requirements proposed in the interim 

measures will be implemented in full with the summer 2011 seed crop planting, which will occur 

in July and August of 2011 (Items 2 and 7). The current isolation distance provided by the 

Willamette Valley Specialty Seed Association pinning provisions is four miles between sugar 

beet seed crops on one hand and open-pollinated (OP) red beet or chard seed crops on the 

other. Most of these crops will have been pinned and planted by the end of August 2010. 

3) Disclosure of information regarding male fertile crops 

Time frames are included in the proposed interim measures, described above. 

4) Measures to prevent mixing of seed 

While these measures have already largely been implemented in the major seed production 

area, as discussed in Section 2.7.3 of this ER, we assume that full implementation will occur 

before the 2011 seed harvest. 

5) Control of bolters - root crop fields 

Contracts requiring control of bolters are in place currently for the 2011 spring planting. 

6) Control of bolters - root crop outdoor storage 

These measures will be in place before the 2011 harvest. 

7) Third-party audits 

Measures would be in place at the time of the partial deregulation or other administrative action 

imposing the interim measures. 

1.2 RATIONALE FOR CREATION OF EVENT H7-1 

Event H7-1 offers sugar beet growers a simpler, more flexible, and less expensive alternative 

for weed control relative to conventional weed control measures. 

According to the World Agriculture Series volume Sugar Beets, "Weeds have been a major 

problem in sugar beet since the crop was first grown in the late 1700s" and "unlike insects, 

diseases and nematodes, weeds occur in all sugar beet fields every year, usually at populations 

that cause crop failure unless controlled" (May and Wilson, 2006, p. 359). Other researchers, 

Event H7-1 

Draft ER 8 

Introduction 

7/28/2010 
working before the introduction of event H7-1, have reported that "weed management is one of 

the main production costs with sugar beet" (Odero et ai, 2008, p. 50). 

As discussed in detail in Section 2.5, prior to widespread cUltivation of event H7-1, sugar beet 

growers used a variety of means to control weeds, and herbicides are a key component. 

Herbicides are used by virtually all sugar beet growers; in 2000, approximately 98 percent of 

planted sugar beet acres received one or more herbicide applications (Ali, 2004, Table 4). In 

the 2000 growing season, 12 different active ingredients formulated as various herbicide 

products were commonly used in U.S. sugar beet production with a total of about 1.4 million 

pounds of herbicides applied (USDA APHIS, 2005, pp. 6-7). Typical conventional weed control 

consists of multiple applications of several different herbicides, often combined with hand or 

mechanical weeding (Odero et ai, 2008). 

Glyphosate is little-used for conventional sugar beets (those without glyphosate tolerance) 

because it damages the plants. With glyphosate-tolerant sugar beets, growers have an 

additional option for weed control. 

1.3 COURT RULING AND ISSUES IDENTIFIED 

During the lawsuit discussed above, the court identified certain specific issues as requiring 

additional analysis by APHIS (US District Court [US DC] 2008). These issues are described 

below and are addressed in the Affected Environment and Environmental Consequences 

sections of this ER. Additionally, this ER addresses issues that were not found to be 

problematic by the court in APHIS' initial EA. These issues are nevertheless addressed again 

here to ensure full disclosure and analysis of any potential impacts associated with partial 

deregulation of event H7 -1 under the proposed interim measures. 

1.3.1 Gene transmission from H7-1 sugar beets in production fields 

Sugar beet is largely wind pollinated and has a biennial, two year life cycle when grown for 

seed; plants develop a large root the first year, then overwinter and flower, producing a seed 

stalk the second year. When grown to produce sugar, sugar beet roots are harvested during 

the first year while still in the vegetative (non-flowering) phase. Sugar beets grown for root 

crops rarely flower and thus rarely produce any pollen. However, certain conditions such as low 

temperatures after planting and longer day length can occasionally cause the sugar beet to 

"bolt" or produce a seed stalk (which can ultimately flower) during the first growing season (8ell 

1946; Jaggard et a/. 1983; Durrant and Jaggard 1988). Thus, further analysis to determine the 

Event H7-1 

Draft ER 9 

Introduction 

7/28/2010 
potential for gene transmission from event H7-1 being grown for root production to conventional 

sugar beets was conducted and is discussed in Section 3.3 of this ER. 

1.3.2 Gene transmission to conventional sugar beets in seed production 

Unlike sugar beet root production, seed production requires that the plants flower, become 

pollinated and develop seed. The court concluded that APHIS did not take a "hard look" at the 

potential for gene transmission in seed production in its initial EA in reference to the 2003 

petition, and did not consider the fact that isolation distances set by the Oregon Seed 

Certification Standards are voluntary; whether the isolation distances were actually followed and 

are likely to be followed in the future; or if the isolation distances are sufficient to protect the 

non-GE crops that are inter-fertile with sugar beets. Therefore, further analysis to determine the 

potential for gene transmission from sugar beets being produced for seed production was 

conducted and is discussed in Section 3.9 of this ER. 

1.3.3 Gene transmission to red table beets and Swiss chard 

Cross-pollination between cultivated sugar beet and sexually compatible Beta species can 

occur when these plants grow close together and have overlapping flowering periods. The court 

found that because sugar beet pollen can travel large distances by wind, and because seed for 

sugar beets, Swiss chard, and table beets (which are all members of the same species and are 

all sexually compatible) are all grown in one valley in Oregon (albeit principally in different parts 

of the same valley), additional analysis is required to determine whether deregulation may 

significantly affect the environment as a result of any potential cross-pollination. Therefore, 

further analysis was conducted and is discussed in Sections 3.5 and 3.6 of this ER. 

1.3.4 Socioeconomic impacts 

The court found that APHIS failed to analyze in its initial EA the socio-economic impacts of 

deregulating event H7 -1 on farmers and processors seeking to avoid GE sugar beets and 

derived products, stating, 

Economic effects are relevant and must be addressed in the environmental review 

"when they are 'interrelated' with 'natural or physical environmental effects. '" Ashley 

Creek Phosphate Co. v. Norton, 420 F.3d 934, 944 (9th Cir. 2005) (emphasis in 

original) (quoting 40 C.F.R. 1508.14); see also Geertson Seed Fanns v. Johanns, 2007 

WL 518624, *7 (N.D. Cal. Feb. 13,2007). In Geertson Seed Farms, the court found 

that "the economic effects on the organic and conventional fanners of the govemment's 

deregulation decision are interrelated with, and, indeed, a direct result of, the effect on 

Event H7-1 

Draft ER 10 

Introduction 

7/28/2010 
the physical environment; namely, the alteration of a plant specie[sj' DNA through the 

transmission of the genetically engineered gene to the organic and conventional [crop]." 

Id., 2007 WL 518624, *8 (emphasis added). 

The court held that APHIS was required to consider these effects in assessing whether the 

impact of its proposed action of deregulation was significant. Therefore, further analysis was 

conducted and is discussed in Section 3.17 of this ER. 

1.3.5 Willingness of buyers to accept sugar derived from GE sugar beets 

The court's ruling included a reference to a 2004 comment from Imperial Sugar, a company that 

at that time processed sugar beets (but no longer does) and currently produces and markets 

only cane sugar. Imperial Sugar raised a concern in response to the petition for deregulation 

that buyers of industrial and consumer sugars have expressed reluctance or opposition to 

receiving sugar derived from GE sugar beet. Imperial Sugar's opinion was that the industrial 

buyers' reluctance was caused by their belief that consumers would react negatively to products 

containing or derived from GE crops. Imperial Sugar was therefore concerned that industrial 

buyers would be unwilling to test the reaction of consumers by using sugar from event H7-1 in 

their branded products. 

Currently, event H7-1 sugar beet is processed into a large percentage of our domestic sugar 

supply, and has been well accepted. Nevertheless, further analysis of this issue was conducted 

and is discussed in Section 3.11 of this ER. 

1.3.6 Restrictionsllabeling requirements by some countries on GE products 

Imperial Sugar also commented that some countries will not allow GE products to be imported 

and that many nations require labeling of food products with GE content. However, less than 

two percent of the sugar produced in the US is exported (USDA FAS, 2010), and exports of 

products derived from event H7-1 sugar beets are expressly allowed in many foreign countries. 

Further information is available in Section 3.11 of this ER. 

1.3.7 Potential for development of glyphosate-resistant weeds 

As the adoption of glyphosate-tolerant crops has grown, the use of glyphosate has increased 

(National Research Council [NRC]. 2010, Figures S-1, S-2, and S-3; Young, 2006). Concerns 

have been expressed that increased use of glyphosate may lead to development of glyphosateresistant weeds. Further information is available in Sections 2.5 and 3.12 of this ER. 

Event H7·1 

Draft ER 11 

Introduction 

7/28/2010 
1.3.8 Cumulative effects of increased use of glyphosate 

Further analysis of cumulative impacts from increased use of glyphosate was conducted and is 

discussed in Section 4 of this ER. However, since this ER is intended to address only the 

period of time until the EIS is completed, cumulative effects are considered for that time period. 

1.4 FEDERAL REGULATORY AUTHORITY - COORDINATED FRAMEWORK 

Interagency coordination in scientific and technical matters is the responsibility of the federal 

Office of Science and Technology Policy (OSTP), which was established by law in 1976. A 

large part of the OSTP's mission is "to ensure that the policies of the Executive Branch are 

informed by sound science" and to "ensure that the scientific and technical work of the 

Executive Branch is properly coordinated so as to provide the greatest benefit to society" 

(OSTP, undated). 

In 1986, the OSTP published a "comprehensive federal regulatory policy for ensuring the safety 

of biotechnology research and products", the Coordinated Framework for the Regulation of 

Biotechnology (Coordinated Framework) (OSTP, 1986). The OSTP concluded that the goal of 

ensuring biotechnology safety could be achieved within existing laws (OSTP, 1986). 

The Coordinated Framework specifies three federal agencies responsible for regulating 

biotechnology in the US: USDA's APHIS, the EPA, and the FDA. APHIS regulates GE 

organisms under the Plant Protection Act of 2000 (PPA). EPA regulates plant-incorporated 

protectants and herbicides used with herbicide-tolerant crops under the Federal Insecticide, 

Fungicide, and Rodenticide Act (FIFRA) and Federal Food, Drug, and Cosmetic Act (FFDCA). 

FDA regulates food (including animal feed, but not including meat and poultry, which is 

regulated by USDA), including food and feed produced through biotechnology, under the 

authority of the FFDCA. Products are regulated according to their intended use and some 

products are regulated by more than one agency. Together, these agencies ensure that the 

products of modern biotechnology are safe to grow, safe to eat, and safe for the environment. 

USDA, EPA, and FDA enforce agency-specific regulations to products of biotechnology that are 

based on the specific nature of each GE organism. 

In 2001, in a joint CEQ/OSTP assessment of federal environmental regulations pertaining to 

agricultural biotechnology, the CEQ and OSTP found that "no significant negative environmental 

impacts have been associated with the use of any previously approved biotechnology product" 

(CEQ/OSP, 2001, p. 1). 

Event H7-1 

Draft ER 12 

Introduction 

7/28/2010 
For glyphosate-tolerant sugar beet event H7-1, the plant is reviewed by USDA and FDA, 

whereas EPA is responsible for registering the use of the glyphosate herbicide and establishing 

a tolerance for allowable glyphosate residues. As indicated herein, although certain issues such 

as weed resistance and impacts of glyphosate on animals or plants are addressed by EPA (not 

APHIS), this ER nevertheless addresses those issues. 

1.4.1 USDA Regulatory Authority 

The Animal and Plant Health Inspection Service (APHIS) Biotechnology Regulatory Service 

(BRS) mission is to protect US agriculture and the environment using a dynamic and sciencebased regulatory framework that allows for the safe development and use of GE organisms. 

Under its authority from the PPA, APHIS regulates the introduction (importation, interstate 

movement, or release into the environment) of certain GE organisms and products' A GE 

organism is presumed to be a regulated article if the donor organism, recipient organism, vector, 

or vector agent used in engineering the organism belongs to one of the taxa listed in the 

regulation' and is also presumed to be a plant pest. APHIS also has authority under these rules 

to regulate a GE organism if it has reason to believe that the GE organism may be a plant pest 

or APHIS does not have sufficient information to determine that the GE organism is unlikely to 

pose a plant pest risks 

Under APHIS' regulations a person may petition APHIS to evaluate submitted data and 

determine that a particular regulated article is unlikely to pose a plant pest risk, and, therefore, 

should no longer be regulated. 7 The petitioner is required to provide information related to plant 

pest risk that the agency may use to determine whether the regulated article is unlikely to 

present a greater plant pest risk than the unmodified organism. 8 If the agency determines that 

the regulated article is unlikely to pose a plant pest risk, the GE organism will be granted 

nonregulated status. In such a case, APHIS authorizations (i.e. permits and notifications) 

would no longer be required for environmental release, importation, or interstate movement of 

the non-regulated article or its progeny. 

It was under these regulations that Monsanto/KWS submitted the petition for a determination of 

non-regulated status for event H7-1 (Schneider, 2003). Event H7-1 sugar beets were 

considered regulated because they contain non-coding DNA segments derived from plant 

: 7 C.F.R §.340 

7 C.F.R §.340.2 

6 7 C.F.R §.340.1 

77 C.F.R §.340.6 entitled "Petition for determination of nonregulated status" 

Bid. §340.6(c)(4) 

Event H7-1 

Draft ER 13 

Introduction 

7/28/2010 
pathogens and the vector agent used to deliver the transforming DNA is a plant pathogen (See 

Section 3.1 for a discussion of these concepts) (APHIS, 2005, p. 4). 

1.4.2 EPA regulatory authority 

EPA is responsible for regulation of pesticides (including herbicides such as glyphosate) under 

the FIFRA. 9 FIFRA requires that all pesticides be registered before distribution, sale, and use, 

unless exempted by EPA regulation. Before a product is registered as a pesticide under FIFRA, 

it must be shown that when used in accordance with the label, it will not result in unreasonable 

adverse effects on the environment. EPA granted the registration of glyphosate for use over the 

top of sugar beets on March 31, 1999. 

Under the Federal Food, Drug, and Cosmetic Act (FFDCA), as amended,'° pesticides added to 

(or contained in) raw agricultural commodities generally are considered to be unsafe unless a 

tolerance or exemption from tolerance has been established. EPA establishes residue 

tolerances for pestiCides under the authority of the FFDCA. EPA is required, before establishing 

pesticide tolerance to reach a safety determination based on a finding of reasonable certainty of 

no harm under the FFDCA, as amended by the Food Quality Protection Act of 1996 (FQPA). 

The FDA enforces the tolerances set by the EPA. EPA established a tolerance for glyphosate 

residue found on beets, including sugar, roots, tops, and dried pulp on April 14, 1999 (64 Fed. 

Reg. 18360). 

1.4.3 FDA regulatory authority 

In 1992 FDA, which has primary regulatory authority over food and feed safety, published a 

policy statement in the Federal Register concerning regulation of products derived from new 

plant varieties, including those genetically engineered (FDA, 1992). Under this policy, FDA 

uses a consultation process to ensure that human food and animal feed safety issues or other 

regulatory issues (e.g. labeling) are resolved prior to commercial distribution of a bioengineered 

food. Monsanto/KWS submitted a food and feed safety and nutritional assessment summary for 

event H7-1 to FDA in April 2003. FDA completed its consultation process in August 2004 

(Tarantino, 2004; Bonette, 2004). 

9 7 USC §136 et seq. 

10 21 U.S.C. § 301 et seq. 

Event H7-1 

Draft ER 14 

Introduction 

7/28/2010 
1.5 THE NATIONAL ORGANIC PROGRAM AND BIOTECHNOLOGY 

Congress passed The Organic Foods Production Act of 1990 (OFPA) to avoid the confusion 

and misrepresentation then taking place in the "organic" marketplace." The OFPA required the 

USDA to establish a National Organic Program (NOP) to develop uniform standards and a 

certification process for those producing and handling food products offered for sale as 

"organically produced."'2 The OFPA requires certification under the NOP, which was finalized in 

2000, to be process-based. '3 "The certification process does not guarantee particular attributes 

of the end product; rather it specifies and audits the methods and procedures by which the 

product is produced" (Ronald and Fouche, 2006). The NOP defines certain "excluded 

methods" of breeding that cannot be used in organic production, describing them as "means 

that are not possible under natural conditions or processes."" Along with genetic engineering, 

three other modern breeding techniques are specified as "excluded methods" in the 

regulations. 's Thus, a certified organic grower cannot intentionally plant seeds that were 

developed by these specific excluded methods. However, because "organic" is based on 

process and not product, the mere presence of plant materials produced through excluded 

methods in a crop will not jeopardize the integrity of products labeled as organic, as long as the 

grower follows the required organic production protocol. Also, other modern breeding methods -

for example, induced radiation or chemical mutagenesis - are not specified as excluded 

methods by the NOP (discussed in Section 3.1.1). 

All organic growers' production plans must be approved by an organic certifying agent before 

the farm can be certified as "organic."'6 Such plans must include, among other things, steps the 

organic grower is taking to avoid what the NOP refers to as "genetic drift" from any neighboring 

crops using excluded methods." Certification must include on-site inspections of the farm to 

verify the procedures set forth in the organic production plan." 

Thus, the NOP recognizes the coexistence of organic growers with neighboring growers who 

may choose to grow products developed using certain methods of biotechnology. So long as an 

organic grower follows an approved organic method of production that seeks to avoid contact 

11 7 USC § 6501 et seq. 

12 7 C.F.R. Part 205, announced at 65 Fed. Reg. 80548 (Dec. 21,2000). 

13 7 U.S.C. 6503(a). 14 7 C.F.R. § 205.2 15 {d. 

16 See 7 C.F.R. Part 205, Subpt. E. 

17 See id. at 205.201; 65 Fed. Reg. at 80556 (discussing "genetic drift"). 

18 7 C.F.R. § 205.403. 

Even! H7-1 

Draft ER 15 

Introduction 

7/28/2010 
with these specific biotechnology-derived crops, if some residue of the biotechnology-derived 

plant material is later found in the organic crop (or food produced from it), neither the crop (or 

food) nor the organic farm is in danger of losing its organic status. No grower or seed producer 

has lost organic certification due to inadvertent transmission of genetic material from a 

genetically engineered crop. 

In the context of the genetic drift discussion, in the preamble of the NOP regulations, USDA 

emphasized that it is the use of excluded methods as a production method that is prohibited, not 

the mere presence of a product of excluded method: 

It is particularly important to remember that organic standards are process based. 

Certifying agents attest to the ability of organic operations to follow a set of production 

standards and practices that meet the requirements of the Act and the regulations. This 

regulation prohibits the use of excluded methods in organic operations. The presence 

of a detectable residue of a product of excluded methods alone does not necessarily 

constitute a violation of this regulation. As long as an organic operation has not used 

excluded methods and takes reasonable steps to avoid contact with the products of 

excluded methods as detailed in their approved organic system plan, the unintentional 

presence of the products of excluded methods should not affect the status of an organic 

product or operation.'9 

The NOP calls for testing only if there is "reason to believe" that a grower has used excluded 

methods'>o The preamble states that a "reason to believe" may be triggered by situations such 

as a formal, written complaint to the certifying agent regarding the practices of a certified 

organic operation; the proximity of a certified organic operation to a potential source of drift; or 

the product from a certified organic operation being unaffected when neighboring fields or crops 

are infested with pests." 

This testing provision does not establish a zero tolerance standard for the presence of products 

of excluded methods in organically labeled food. Rather, it serves as a warning that excluded 

methods may have been used: "Any detectable residues of. . . a product produced using 

excluded methods found in or on samples during analysis will serve as a warning indicator to 

the certifying agent.,,22 

[Tlhese regulations do not establish a "zero tolerance" standard. . . [A] 

positive detection of a product of excluded methods would trigger an 

investigation by the certifying agent to determine if a violation of organic 

production or handling standards occurred. The presence of a detectable 

19 65 Fed. Reg. at 80556. 

20 7 C.F.R. § 205.670(b). 

21 See 65 Fed. Reg. at 80629. 

22 Id. at 80628. 

Event H7-1 

Draft ER 16 

Introduction 

7/28/2010 
residue alone does not necessarily indicate use of a product of excluded 

methods that would constitute a violation of the standards."23 

Only if the organic producer intentionally used excluded methods of crop production will that 

producer be subject to suspension or revocation of organic certification. There is no evidence 

that any organic grower has lost certification due to unintended presence of GE material. 

1.5.1 Non-GMO Project Working Standard 

The Non-GMO Project is a non-profit organization created by leading players in the organic 

industry to "offer consumers a consistent non-GMO choice for organic and natural products that 

are produced without genetic engineering or recombinant DNA technologies" (Non-GMO 

Project, 201 Oa). The Non-GMO Project has created a working standard to implement its goal. 

The standard sets action thresholds for "GMO" (GE) adventitious presence for certain products. 

If these action thresholds are exceeded, the participant must investigate the cause of the 

exceedance and take corrective action (Non-GMO Project, 2010, p. 13). The standard sets a 

threshold of 0.25% for GE material for the presence of GE traits in non-GE seeds (p. 28), and a 

0.9% threshold for non-GE food or feed (p.14). 

1.5.2 Growth in organic and GE farming 

Expansion of organic farming has succeeded at the same time as the growth of GE crops. 

Consumer demand for organically produced goods "has shown double-digit growth for well over 

a decade" and organic products "are now available in nearly 20,000 natural food stores and 

three of four conventional grocery stores." Organic products "have shifted from being a lifestyle 

choice for a small share of consumers to being consumed at least occasionally by a majority of 

Americans" (USDA ERS, 2009c). 

1.6 COEXISTENCE IN US AGRICULTURE 

1.6.1 Coexistence and biotechnology 

Coexistence of different varieties of sexually compatible crops has long been a part of 

agriculture, especially in seed production, where large investments are made in developing new 

varieties and high seed purity levels are required by the Federal Seed Act implementing 

regulations. 24 The aspect of coexistence most relevant to this document is that related to 

specific methods of crop production. In this context, coexistence refers to the "concurrent 

cultivation of conventional, organic, and genetically engineered (GE) crops consistent with 

23 Id. at 80632. 

24 7 CFR § 201 

Event H7-1 

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Introduction 

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underlying consumer preferences and choices" (USDA Advisory Committee, 2008). The 

differences among these crops that are particularly relevant to coexistence in this ER are in the 

types of breeding methods (sometimes referred to as "genetic modifications") that are 

associated with each of the three types of crops. 

"Genetic engineering" is defined by APHIS regulations as "the genetic modification of 

organisms by recombinant DNA techniques.,,25 Recombinant DNA (rONA) techniques are 

discussed in Section 3.1.1 of this ER. While there are many ways to genetically modify a crop, 

the APHIS definition of GE crops applies only to those developed using rONA techniques, which 

are among the more modern breeding methods. 

Organic crops are those produced in accordance with the requirements of the NOP, discussed 

in Section 1.5. 

Conventional crops are simply those that are neither GE nor organic. They may be 

commodity crops (mass produced), or they may be identity preserved, with some characteristic 

tailored for a specific end user. Identity-preserved usually refers to a "specialty, high-value, 

premium or niche market" (Massey, 2002). One type of identity preserved product that has 

been produced since the introduction of GE crops is "non-GE;" however, there are no 

mandatory standards governing the use and/or marketing of "non-GE" products (USDA 

Advisory Committee, 2008). 

Farmers who want to maximize their profitability must decide whether the higher prices 

(premiums) they may receive for organic or identity-preserved crops are sufficient to offset the 

added managerial costs of producing these crops. As researchers have noted, "Although yields 

on organic farms are sometimes less than those of conventional systems, price premiums make 

it an attractive option for growers looking for specialized markets and a higher-value product" 

(Ronald and Fouche, 2006). There is such a niche market for organic red beets and organic 

Swiss chard. However, no premium or niche market exists for either conventional or organic 

sugar beets. 

1.6.2 USDA position on coexistence and biotechnology 

It is USDA's position that all three methods of agricultural production described above can 

provide benefits to the environment, consumers, and the agricultural economy (Smith, 2010b). 

25 7 CFR §340.1 

Event H7-1 

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Introduction 

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1.6.3 Coexistence in US crop production 

Since the time GE crops were introduced in the US in the mid-1990s, organic markets have 

grown and expanded (Smith, 2010b, p. 10). 

The USDA Advisory Committee on Biotechnology and 21" Century Agriculture who reported 

that "coexistence among the three categories of crops is a distinguishing characteristic of U.S. 

agriculture, and makes it different from some other parts of the world ," expressed its belief that 

US agriculture supports coexistence, and recommended continued government support of 

coexistence (USDA Advisory Committee, 2008). Among the Committee's findings: 

• The U.S. is the largest producer of GE crops in the world. 

• The U.S. is one of the largest producers of organic crops in the world. 

• The U.S. is one of the largest exporters of conventionally-grown, identity preserved, 

non-GE crops in the world. 

• Some U.S. farmers currently are producing a combination of organic, conventional, 

and GE crops on the same farm. 

Among the coexistence-enabling factors the Committee identified are the existing "legal and 

regulatory framework that has enabled different markets to develop" without foreclosing the 

ability of "participants in the food and feed supply chain to establish standards and procedures 

(e.g., not setting specific mandatory adventitious presence (AP) thresholds and having processbased rather than product-based organic standards)." At the same time, development of 

practices and testing methods that allow for voluntary thresholds has also enabled coexistence 

(USDA Advisory Committee, 2008). 

As APHIS has previously observed, "studies of coexistence of major GE and non-GE crops in 

North America and the European Union (E.U.) demonstrated that there has been no significant 

gene flow from GE crops and that GE and non-GE crops are coexisting with minimal adverse 

economic effects" (Smith, 201 ~b, pp. 11-12) (citing Gealy et. ai, 2007; Brookes and Barfoot, 

2003; Brookes and Barfoot, 2004(a) and (b), and Walz 2004)). In addition, "the agricultural 

markets and local entities have addressed coexistence through contractual arrangements, 

management measures, and marketing arrangements. This market-based approach to 

coexistence has created economic opportunities for all kinds of producers of agricultural 

products." (ld. p.9). RRSB is one of fifteen glyphosate-tolerant events previously deregulated 

by USDA. See APHIS, EPA, Petitions of Non-Regulated Status Granted or Pending by APHIS 

as of February 2, 2010, http://www.aphis.usda.gov/brs/not_reg.html. 

Event H7-1 

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Introduction 

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1.7 ROLE OF THE NATIONAL ACADEMIES IN AGRICULTURAL 

BIOTECHNOLOGY 

The analyses in this ER are based on published, peer-reviewed scientific papers; federal 

government assessments; assessments from international agencies; information from 

specialists from many universities; data collected by Monsanto/KWS under controlled 

conditions; and information from other relevant sources. One resource used for this ER is the 

National Academies (NA), a private, non-profit institution that advises the nation on scientific 

and technical matters. It consists of the National Academy of Sciences (NAS), the National 

Academy of Engineering, the Institute of Medicine (1M) and the National Research Council 

(NRC) (NA, 2010). Scientists, engineers and health professionals are elected by their peers to 

the academy and serve pro bono. Reports are prepared by committees of members with 

specialized expertise and reviewed by outside anonymous experts (Alberts, 1999). 

The NA has been active in studies related to agricultural biotechnology since the 1970s, works 

cooperatively with federal agencies, and its reports have provided guidance and 

recommendations for process improvement to regulatory agencies (Alberts, 1999). The NRC 

1989 guidelines for field testing of genetically engineered organisms were used as the basis for 

agency procedures for field trials (Alberts, 1999; NRC, 1989). In studies in 1987 and 2000 the 

NRC emphasized that the characteristics of the modified organism should be the object of a risk 

assessment, and not the methods by which the modifications were accomplished; and that the 

risks associated with recombinant DNA techniques are the same in kind as risks from other 

types of genetic modification (NRC, 1987; NRC, 2000). This position was re-iterated in a 2004 

study prepared jointly by the 1M and the NRC. Whether such compositional changes result in 

unintended health effects is dependent on the nature of the substances altered and the 

biological consequences of the compounds. To date, "no adverse health effects attributed to 

genetiC engineering have been documented in the human population" (1M/NRC, 2004, p. 8). In 

a 2002 report, the NRC "found that the current standards used by the federal government to 

assure environmental safety of transgenic plants were higher than the standards used in 

assuring safety of other agricultural practices and technologies" (NRC, 2002). The NRC reports 

that, while biotechnology is not without risk, since the first commercial introduction of transgenic 

plants, "biotechnology has provided enormous benefits to agricultural crop production" (NRC, 

2008). NRC's latest report on biotechnology in agriculture evaluates the impact of genetically 

engineered crops on farm sustainability. The authors concluded that an understanding of 

impacts on all farmers will help ensure that GE technology contributes to sustain ability and that 

Event H7-1 

Draft ER 20 

Introduction 

7/28/2010 
commercialized GE traits to date, when used properly, "have been effective at reducing pest 

problems with economic and environmental benefit to farmers" (NRC, 2010). 

1.8 ALTERNATIVES CONSIDERED 

In addition to the alternative of partial deregulation or other administrative action implementing 

the interim conditions (Alternative 2), this ER considers the alternative of full regulation 

(Alternative 1). 

1.8.1 Alternative 1 - No Action (full regulation) 

In conducting NEPA review, agencies consider a No Action alternative, which provides a 

baseline against which action alternatives can be evaluated. This ER identifies the No Action 

alternative as a return to full regulation - or the status quo existing when the petition for 

deregulation of event H7 -1 was initially submitted. Under this alternative, the introduction of 

event H7-1 lines of glyphosate tolerant sugar beets would be fully regulated and would require 

permits issued or notifications acknowledged by APHIS until APHIS completes its EIS and 

issues a Record of Decision (ROD) regarding whether to deregulate H7-1 lines of glyphosate 

tolerant sugar beets. For purposes of this analysis, we assume that Alternative 1 would not 

involve widespread event H7-1 sugar beet cultivation, and instead would contemplate a return 

to conventional sugar beet crops or to crops other than sugar beet. Note: As indicated above, 

the status quo is event H7-1 sugar beets comprising 95 percent of the U.S. sugar beet crop. 

1.8.2 Alternative 2 - Partial Deregulation with Interim Conditions 

Under this alternative, the introduction of event H7-1 lines of glyphosate tolerant sugar beets 

would be allowed under interim conditions until APHIS completes its EIS" issues a Record of 

Decision, and that decision takes effect -- currently anticipated for mid-2012 (Smith, 2010b, p. 

8). 

Event H7-1 

Draft ER 21 

Introduction 

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AFFECTED ENVIRONMENT 

This section describes the affected environment and provides other contextual information for 

an understanding of the environmental consequences analyzed in Section 3. 

2.1 SUGAR BEET CHARACTERISTICS AND USES 

Sugar beet (Beta vulgaris L.) is a biennial plant that was developed in Europe in the 18th 

century from white fodder (animal feed) beets. Sugar reserves are stored in the sugar beet root 

during the first growing season for an energy source during overwintering. The roots are 

harvested for sugar at the end of the first growing season but plants that overwinter in a mild 

climate will produce flowering stems and seed during the following summer and fall. Sugar beet 

roots will not survive the winter in any of the growing regions except California (Cattanach et ai, 

1991).). 

Pollination. The sugar beet is cross-pollinated (pollination occurs between plants rather than 

within single plant) by wind (Cattahach et ai, 1991). 

Climate. Sugar beets have adapted to a very wide range of climatic conditions. Sugar beets 

primarily are a temperate zone crop produced in the Northern Hemisphere at latitudes of 30 to 

600N. The sugar beet plant grows until harvested or growth is stopped by a hard freeze. Sugar 

beets primarily grow tops until the leaf canopy completely covers the soil surface in a field. This 

normally takes 70 to 90 days from planting. Optimal daytime temperatures are 60 to 80°F for 

the first 90 days of plant growth. Regions with long day length are most suitable for sugar beet 

growth. The most favorable environment for producing a sugar beet crop from 90 days after 

emergence to harvest is bright, sunny days with 65 to 80° F temperatures followed by nighttime 

temperatures of 40 to 50°F. These environmental conditions maximize yield and quality in a 

sugar beet crop. Sugar beets are successfully produced under irrigation in areas with very low 

rainfall and in regions relying on natural rainfall (Cattanach et ai, 1991). 

Products. Sugar beets contain from 13 to 22 percent sucrose. Sugar beet pulp and molasses 

are proceSSing by-products used as feed supplements for livestock. These products provide 

required fiber in rations and increase the palatability of feeds. Molasses by-products from sugar 

beet processing are used in the alcohol, pharmaceuticals, and bakers' yeast industries 

(Cattanach et ai, 1991). 

Event H7-1 

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Affected Environment 

7/28/2010 
2.2 ACCEPTANCE OF EVENT H7-1 SUGAR BEETS 

Event H7-1 sugar beets were first available for commercial production in 2007 (Lilleboe, 2008). 

In the 2009/10 crop year, event H7-1 varieties accounted for about 95 percent of planted area, 

up from about 60 percent in 2008/09 (USDA ERS, 2009a). Since, as noted in Section 1, no 

event H7 -1 sugar beets have been grown in California and California represents approximately 

3 percent of US sugar beet production (Table 2-1),98 percent of the planted 2009/2010 sugar 

beet crop in the remaining US sugar beet regions was event H7-1. 

T a e bl 21 - US S ugar B ee tP ro d uc r lon, 2009/2010 S 

Region/State 1,000 short tons 

Great Lakes 

Michi[.1an 3,318 

Total 3,318 

Upper Midwest 

Minnesota 10,641 

North Dakota 4,796 

Total 15,437 

Great Plains 

Colorado 963 

Montana 1,001 

Nebraska 1,294 

Wyomin[.1 678 

Total 3,936 

Northwest 

Idaho 5,591 

Oregon 395 

Total 5,986 

Far West 

California 886 

Total 886 

Source: USDA ERS, 2010a, Table 14 

Event H7-1 

Draft ER 23 

eason 

Percent of US Total 

11 

52 

13 

20 

3 

Affected Environment 

7/28/2010 
2.3 SUGAR BEET ROOT PRODUCTION 

2.3.1 US Production by regions 

The US is among the world's largest sugar producers. Unlike most other producing countries, 

the US has both large and well-developed sugarcane and sugar beet industries. Since the mid1990s, sugarcane has accounted for about 45 percent of the total sugar produced in the US, 

and sugar beets for about 55 percent of production. Since 1961, planted sugar beet acreage 

has fluctuated within the range of 1.1 million (low in 1982) to 1.6 million (high in 1975) (USDA 

NASS 2010a). Annual cash receipts for sugar beets in the US in the past few years have 

ranged up to $1.5 billion (USDA ERS, 2009b). 

Figure 2-1 shows the five major US sugar beet producing regions, along with 2008 production 

by county. 

Great Lakes. Great Lakes sugar beet production, now entirely in Michigan, occurs in the flat 

area around Saginaw Bay. Sugar beets grown in the Great Lakes region do not require 

irrigation. The Great Lakes region also includes Ohio, where sugar beets were last produced in 

2004. 

Upper Midwest. The Upper Midwest is the largest sugar beet production region in the US, with 

the majority of this production in the Red River Valley. The Red River flows north into Canada 

and forms most of the North Dakota-Minnesota border. It flows through a broad, flat valley 

formed by an ancient glacial lake. The Minnesota River Valley, another broad, flat glacial valley 

that crosses southern Minnesota and is almost continuous with the Red River Valley, is also a 

large production area. Irrigation is uncommon in the Red River/Minnesota River Valleys (Ali, 

2004). There is another, much smaller Upper Midwest production area along the Montana 

border of North Dakota, in the valley of the Yellowstone River and its tributaries. 

Great Plains. The Northern Great Plains region includes production areas in northern 

Wyoming and southern Montana. The major sugar beet growing areas in the Northern Great 

Plains are the sandy loam soils along the Yellowstone River and its tributaries (Mikkelson and 

Petrof, 1999, p. 2). The Southern Great Plains subregion includes growing areas in western 

Nebraska, southeastern Wyoming and northeastern Colorado, primarily in the valley of the 

Platte River and its tributaries. All Great Plains sugar beet production requires irrigation 

(Thomas et ai, 2000, p. 1; Mikkelson and Petrof, 1999, p. 3; McDonald et ai, 2003, p. 2). 

Event H7-1 

Draft ER 24 

Affected Environment 

7/28/2010 
Tons 

! Not Estimated 

i-~', < 100,000 

I

······· 100,000 - 249,999 

i 250,000 - 499,999 

mil! 500,000 - 749,999 

. 750,000 - 999,999 

1,000,000 + 

.. Sugar beet processing facility, 2010 

U,S. Department of Agriculture, National Agricultural Stalislias Service 

Sugarbeets 2008 

Production by County 

Figure 2-1. US sugar beet regions and 2008 county production. 

Event H7-1 

Draft ER 25 

,c t! [, r 

USD' A .",,([mlllliN'.~. 

~ 

:t-\. .;: !ii~ Clr'~1' -' 

Affected Environment 

7/28/2010 
The Great Plains region previously included New Mexico and Texas, where sugar beets were 

last harvested in 1997. 

Northwest. Most production in the Northwest region is in the sandy loam soil of the Snake 

River Valley in Idaho. This area also requires irrigation (Traveller and Gallian, 2000, p. 1). In 

addition, production occurs in southeast Washington state, east of the Cascade mountains. 

Far West (California). The only sugar producing area in California is in the Imperial Valley in 

the far southern end of the state, where the only remaining sugar processing plant in California 

exists. Production occurred in the Central Valley (near the middle of the state) through 2008; 

however, the last processing plant in this area closed in 2008. As recently as the 1990s, nearly 

30 percent of sugar beet production was in the Central Valley; there were also small areas of 

production in coastal counties (but production in those regions no longer exist) (California Beet 

Growers Association, 1998, p.1). 

US production for the 2009/2010 season (harvested in 2009 and processed in 2009/2010) is 

shown in Table 2-1. In 2010, sugar beet was planted on 1.2 million acres (USDA ERS, 2010a, 

Table 14). Sugar beet production by county from 2005 to 2008, including acres planted, acres 

harvested, yield per acre, total yield and sucrose percent, is tabulated in Appendix D. 

The distribution of planted acreage by state is shown in Figure 2-2. 

illMN 

m! NO 

ill 10 

illMI 

o;1NE 

MT 

Wy 

co 

CA 

OR 

Figure 2-2. 2010 distribution by state of acres planted in sugar beet 

Source: USDA NASS, 2010a 

Event H7-1 

Draft ER 26 

Affected Environment 

7/28/2010 
2.3.2 Grower-processor relationships 

Sugar beet production, more than most crops, requires close coordination between the grower 

and the processor. The crop is of little value without a processor to extract the sugar, and a 

sugar processing facility cannot stay in business without a reliable supply of beets (Kaffka and 

Hills, 1994, p. 2). While a type of syrup can be made on a small scale, home garden production 

of sugar would be impractical; processing cannot be duplicated successfully in a home kitchen 

(California Beet Growers Association, 1998, p. 3). Sugar beets are 75 percent water and 

expensive to transport long distances (Michigan Sugar Company, 2010a). For economic 

reasons, sugar beets are typically grown within 60 miles of a processing facility, but may be 

grown up to 100 miles away (Western Sugar Cooperative, 2006a). Locations of the 22 

processing facilities in operation in 2010 are shown in Figure 2-2. While existing facilities have 

been upgraded, no new currently operating processing facilities have been built in the US since 

1975. An estimated cost for an average-sized new facility in 1991 was $100 million (Cattanach 

et ai, 1991, p. 16). The cost would be substantially higher today due to inflation and other 

factors. 

Sugar beet production and processing in the US is done almost entirely by grower-owned 

cooperatives. The cooperatives own the processing facilities and the sugar beet farmers are 

members of the cooperatives. The members own shares of stock that require them to grow a 

specified acreage of beets in proportion to their stock ownership in the cooperative and 

guarantee processing for their beets. US companies are summarized by regions below. 

Cooperatives are owned by growers Who are principally family farmers. According to the 2007 

US Census of Agriculture, over 4,000 farms grow sugar beets (USDA ERS 2009b). 

Great Lakes. Michigan Sugar Company, the third-largest sugar beet processor in the US, 

processes all the sugar beets in the Great Lakes region, as well as beets from Ontario, 

Canada .. The cooperative has over 1,000 grower-shareholders who grow sugar beets on 

150,000 acres each year. The sugar beets are processed into sugar at factories in Bay City, 

Sebewaing, Caro and Croswell. The cooperative employs 450 year-round and 1,200 seasonal 

employees, generates nearly $400 million in direct economic activity annually in the local 

communities in which it operate, and annually produces nearly one billion pounds of sugar 

(Michigan Sugar Company, 201 ~b). 

Upper Midwest. Three cooperatives operate in the Upper Midwest. American Crystal Sugar 

Company, the largest sugar beet producer in the US, is owned by approximately 3,000 

Event H7-1 

Draft ER 27 

Affected Environment 

7/28/2010 
shareholders who raise 500,000 acres of sugar beets in the Red River Valley of Minnesota and 

North Dakota. The company operates five sugar processing facilities in the Red River Valley: 

three in Minnesota (Crookston, East Grand Forks and Moorhead) and two in North Dakota 

(Drayton and Hillsboro). American Crystal also operates a sugar beet processing facility in 

eastern Montana at Sidney, under the name Sidney Sugars Incorporated. American Crystal's 

fiscal year 2009 Red River Valley crop averaged 25.4 tons per acre with 17.6 percent sugar 

content.. In 2009, the company produced approximately 3 billion tons of sugar and 681,000 

tons of agri-products (molasses and pulp) (American Crystal Sugar Company, 2009). Minn-Dak 

Farmers Cooperative, with 450 shareholders, operates a processing facility in Wahpeton, in the 

far southeast corner of North Dakota. Minn-Dak also operates a yeast factory, which uses 

molasses from sugar beet processing (Minn-Dak Farmers Cooperative, undated). The 

Southern Minnesota Beet Sugar Cooperative has approximately 600 shareholders who farm 

120,000 acres, and operates a processing facility near Renville, Minnesota (Southern 

Minnesota Beet Sugar Cooperative, 2010). 

Great Plains. The Western Sugar Cooperative, with 135,000 acres and five factories, 

processes most of the Great Plains sugar beet. Processing facilities are in Fort Morgan, 

Colorado; Billings, Montana; Scottsbluff, Nebraska; and Lovell and Torrington, Wyoming. 

Wyoming Sugar Beet Company, LLC is not a cooperative, but works through the Washakie 

Farmers Cooperative to acquire beets for its plant in Worland, Wyoming (Boland, 2003). 

Northwest. The Amalgamated Sugar Company LLC processes all the sugar beet in the 

Northwest region. Amalgamated is owned by Snake River Sugar Company, a grower-owned 

cooperative, and is headquartered in Boise, Idaho with processing plants in Paul, Twin Falls, 

and Nampa, Idaho (Snake River Sugar Company, 2009). 

Far West (California). Spreckels Sugar Company, a subsidiary of Southern Minnesota Beet 

Sugar Cooperative, operates a sugar beet processing facility in Brawley, California, in the 

Imperial Valley. Yields in the Imperial Valley are higher than anywhere else in the US, 

averaging approximately 40 tons per acre (Spreckels Sugar, 2009). 

Event H7-1 

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Affected Environment 

7/28/2010 
Tillage systems are defined 

by the amount of crop residue 

remaining on the soil. 

Conventional tillage systems 

leave less than 30 percent of 

crop residue remaining on the 

soil when planting another crop. 

Conservation tillage leaves 30 

percent or more of the previous 

crop residue covering the soil 

when planting another crop. 

Reduced tillage leaves 15 to 

30 percent of the previous crop 

residue covering the soil when 

planting another crop. 

Mulch tillage disturbs the soil 

prior to planting . . Tillage tools 

such as chisels, field cultivators, 

disks or blades are used. Weed 

control is accomplished with 

herbicides and/or cultivation. 

No Till leaves the soil 

undisturbed. 

With strip tillage, a specific 

type of conservation tillage, 

tillage is confined to narrow 

strips where seeds will be 

planted. Strip tillage is usually 

done in the fall. The loosened 

soil creates a ridge 3 to 4 inches 

high, which improves soil 

drainage and warming. By 

spring, it usually settles down to 

1 or 2 inches high, and after 

planting the field is flat. 

Sources: AI." 2004, p. 32; 

2.3.3 Sugar beet cUltivation practices 

Seed bed preparation and tillage. The objectives of 

seedbed preparation are to manage crop residue (the 

leftover vegetative matter from the previous crop), 

minimize erosion, improve soil structure, and eliminate 

early season weeds. Tillage, which can be done in fall 

and spring, can help improve soil structure and eliminate 

early weeds, but tillage can also increase erosion. Notill, strip tillage in previous crop residues, and other 

conservation tillage systems (see definitions at left) 

require more planning and better management 

(Cattanach et ai, 1991). In addition to the reduced tillage 

methods (noted at left), no-till productions systems do not 

have any associated tillage where weed control is 

entirely through chemical means. A survey conducted in 

2000, before event H7 -1 sugar beets were available, 

found that use of conventional tillage for sugar beet 

production varied by region from 64 percent of acreage in 

the Red River Valley in the Upper Midwest to 96 percent 

of acreage in the Northwest (California was not included 

because there was too little data). Growers in the Red 

River Valley reported using reduced tillage on 16 percent 

of sugar beet acres and mulch tillage on 20 percent (Ali, 

2004). Because weeds can be effectively controlled with 

glyphosate applications, event H7-1 sugar beets may be 

grown with less tillage (NRC, 2010, p. 6; Duke and Cerdeira, 2007, p. 3; Wilson, 2009). 

In the Idaho (Northwest), prior to glyphosate tolerant sugar beets conventional tillage was 

essential for weed control, minimizing soil erosion and improving soil structure (Ali, 2004; 

Traveller and Gallian, 2000, p. 1). Since the introduction of event H7-1, some farmers in the 

Northwest have switched to strip tillage and have reported reduced fuel and labor costs and 

Event H7-1 

Draft ER 29 

Affected Environment 

7/28/2010 
reduced wind erosion (Ulleboe, 2008). Researchers in Idaho found that while conventional 

tillage was necessary for weed control with conventional beets, the practice has little to no 

benefit with g[yphosate-to[erant sugar beets (Miller and MiI[er, 2008). 

[n much of the Great Plains region, conventional sugar beets were cultivated using conservation 

tillage systems; however, deep til[age, which is used to improve drainage, was utilized to help 

reduce the risk of soil borne diseases (main[y the beet necrotic yellow vein virus causing 

rhizomania) (McDona[d et ai, 2003, p.2). Farmers in the Great Plains have reported that strip 

tilling and event H7-1 have "been a great marriage," with strip tilling resulting in reduced wind 

erosion, reduced irrigation requirements and fuel and time savings (U[[eboe, 2010). 

Michigan Sugar Company recommends conservation til[age practices to help control erosion 

resulting from strong early spring wind in the Great Lakes region (Michigan Sugar Company, 

2009, p. 2). However, since the introduction of the event H7 -1 this growing region has the 

option of implementing varying methods of reduced tillage systems. 

Recent studies by North Dakota State University have found that since the introduction of event 

H7-1, strip tiI[age is a viable option for sugar beet production that reduces fuel and fertilizer 

costs and susceptibility to wind erosion (Overstreet et ai, 2009). A member of the Minn-Dak 

Farmers Cooperative, who farms about 1,100 acres of sugar beets annually, has found that 

instead of three post-emergence til[age trips across the fields, with event H7-1 he now needs 

"litt[e to no tillage post-emergence" (Mauch, 2010, p. 3). 

Planting and harvesting times. [n all regions except the Far West (California), sugar beet root 

crops are planted in early spring (March through May, depending on latitude and location) and 

harvested in fall (September through November, also varying with regions) (McDona[d et ai, 

2003; Mikke[son and Petrof, 1999, p 3; Michigan Sugar Company, 2010b). 

[n the Imperial Valley in California, sugar beets are planted in September and October and 

harvested from April to Ju[y (California Beet Growers Association, 1999, p. 1). 

Crop rotations. Sugar beets tend to be grown with other crops in three- to five-year rotations, 

although sometimes two years is used. The rotation results in improved soil fertility, fewer 

problems with diseases, and improved yields and quality of beets. The impact of certain soil 

borne diseases, nematodes (parasitic, microscopic worms) and weeds are minimized through 

Event H7-1 

Draft ER 30 

Affected Environment 

7/28/2010 
crop rotations (Mikkelson and Petrof, 1999, p. 3; USDA ERS, 2009b, p. 2; Hirnyck et ai, 2005, p. 

13). 

To assess the likelihood that the rotational crops planted after event H7-1 sugar beet would be 

another glyphosate-tolerant crop an analysis of rotations to other crops was conducted and 

included in the petition (Schneider, 2003, Table VII-13). This rotational crop table has been 

updated with crop information from the 2007 planting season and includes projected acreage for 

recently commercialized glyphosate-tolerant crops (Table 2-2). 

2.3.4 Sugar beet bolters and volunteers 

Bolting. Sugar beet, if left to grow in a temperate climate, is a biennial plant that produces an 

enlarged root the first year and flowers in the second year. Typically, the plant is induced to 

flower through a process called vernalization that occurs during prolonged exposure to cooler 

temperatures. Occasionally sugar beets will bolt (produce a seed stalk that may ultimately 

flower) in their first year of production; however, with breeding, bolting tendency has been 

reduced. Much effort has gone into producing sugar beets that resist bolting, and today's 

varieties show little bolting (DECO, 2001, p. 15). No difference in bolting characteristics would 

be expected between conventional and event H7-1 sugar beets, as the introduction of the 

glyphosate tolerant trait does not affect the bolting characteristics of the sugar beet. In the 

2000-2001 variety field trials with lines containing event H7-1 reported in the petition, six of 12 

event H7-1 sugar beet varieties had 0.00 percent bolters; for those varieties with bolters, the 

percentages were 0.03 percent for three; 0.06 percent for two, and 0.19 percent for one. All 

entries were established as six row plots forty feet in length with six replications at each location 

in 2000, and four replications at each location in 2001 (Schneider, 2003, Table VI-9). Darmency 

et al report bolting percents now as low as 0.01 percent (2009, p. 1090). While Darmency et al 

were referring to conventional sugar beets, event H7-1 would not affect bolting characteristics, 

and breeders continue to select for low rates of bolting. 

For bolting to occur, the plants first require exposure to temperatures around 40 to 42 degrees F 

(others report 34 to 39 degrees F in the 4 to 5 leaf stage; conditions are variety-dependent), 

followed by exposure to increasing day length (12 hours or more). Varieties differ in their 

sensitivity to bolting, with easy bolting lines requiring only a few to 1000 hours of exposure to 

low temperatures, while bolting-resistant lines may require 2000 hours or more. Beets can devernalize when exposed to high temperatures (DECO, 2001, p. 15). 

Event H7-1 

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Affected Environment 

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Bolting depletes the root of simple sugars, translocating this stored energy into the aboveground biomass, making the root woody and worthless as a source of sugar. Bolters are taller 

than the rest of the crop. Thus, bolters are effectively weeds within a sugar beet field. The 

woody roots that result from bolters can damage harvesting and processing equipment 

(Ellstrand, 2003, p. 5-7). For these reasons, growers remove bolters. A bolter is evident in a 

field weeks before the seed stalk would flower to produce pollen or seed. Thus, stewardship 

can be 100% successful in eliminating any small probability of flowering. 

Event H7-1 

Draft ER 32 

Affected Environment 

7/28/2010 
Table 2-2. 

A 

State 

CA 

CO 

ID 

MI 

MN 

Event H7-1 

Draft ER 

Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® crops 

\all acrea ges are expressea as 1 uuu acres) 

8 C 0 E F 

Percent of 

Total Major Crops Total Acreage Rotational Rotational 

Sugar Beet That Follow of Rotation Crop Crop Acres 

Acres1 Sugar Beet Crop in States1 Rotated Following 

In Rotatlon2 Following Sugar Beee 

SUf:lar Beee 

50 Barley 130 7.7% 10 

Dry Beans 92 5.4% 5 

Durum 95 10.5% 10 

Oats 260 3.8% 10 

Spring Wheal 530 2.8% 15 

Total: 1,107 Total: 50 

44 Barley 85 5% 4 

Corn 1200 3% 31 

Dry Beans 92 8% 7 

Potato 78 3% 2 

Total: 1,455 Total: 44 

212 Alfalfa 730 1.5% 11 

Barley 730 4.4% 32 

Corn 190 3.2% 6 

Dry Beans 95 4.2% 4 

Spring Wheat 530 30.0% 159 

Total: 2,275 Total: 212 

180 Corn 2.250 5.2% 117 

Dry Beans 270 6.7% 18 

Soybean 2.050 2.2% 45 

Total: 4,570 Total: 180 

505 Barley 210 23.8% 50 

Soybean 7.200 4.9 354 

Spring Wheat 2,000 5.1% 101 

Total: 9,410 Total: 505 

33 

G H 

Percent Percent Roundup Rotational Ready® Crop of Total Rotational Sugar Beee Crop Optlon5

,6 

20% NA 

10% NA 

20% NA 

20% NA 

30% NA 

10% NA 

70% 52% 

15% NA 

5% NA 

5% 500/0 

15% NA 

3% 52% 

2% NA 

75% NA 

65% 52% 

10% NA 

25% 91% 

10% NA 

70% 91% 

20% NA 

I 

Acreage of 

Roundup 

Ready® 

Rotational 

Crop Option7 

0 

0 

0 

0 

0 

Total: 0 

0 

16 

0 

0 

Total: 16 

6 

0 

3 

0 

0 

Total: 9 

61 

0 

41 

Total: 102 

0 

322 

0 

Total: 322 

J K I 

Percent of Estimated 

Sugar Beet Percentage of 

Acres Roundup 

Preceding Ready® Crops, 

Major 

RotationsB 

as Major 

Rotationss 

4.52% 0% 

3.02% 1.10% 

9.32% 0.40% 

3.94% 2.23% 

5.37% 3.42% 

Affected Environment 

7/28/2010 
Table 2-2. 

A 

State 

MT 

ND 

NE 

WY 

Overall 

Event H7-1 

Draft ER 

Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® crops 

(all acrea ges are expressed as 1UUO acres) 

B C D E F 

Percent of 

Total Major Crops Total Acreage Rotational Rotational 

That Follow Crop Crop Acres Sugar Beet Sugar Beet of Rotation Rotated Following Acres' Crop in States 1 

In Rotation2 Following Sugar Beee 

Sugar Beee 

5B Sarley 1.200 2.4% 29 

Corn 65 21.5 % 14 

Dry Beans 27 33.3% 9 

Spring Wheat 3.750 0.2% 6 

Total: 5,042 Total: 58 

265 Barley 1.600 2.5% 40 

Corn 1.230 3.3% 40 

Durum 2.100 0.6% 13 

Soybean 2,670 4.0% 106 

Spring Wheat 6,900 1.0% 66 

Total: 14,500 Total: 265 

57 Corn 8,400 0.3% 29 

Dry Beans 1B5 11.9% 22 

Winter Wheat 1.650 0.4% 6 

Total: 10,235 Total: 57 

40 Barley 90 24.4% 22 

Corn BO 12.5% 10 

Dry Beans 32 12.5% 4 

Sugar Beet 40 10% 4 

Total: 242 Total: 40 

1,411 Ifalfa 730 1.5% 11 

Barley 4.045 4.6% 186 

porn 13.415 1.8% 247 

Dry Beans 793 8.7% 69 

34 

G H 

Percent Percent Roundup Rotational 

Crop of Total Ready® 

Rotational Sugar Seee Crop Option5

,6 

50'Yo NA 

25% 52% 

15% NA 

10% NA 

15% NA 

15% 52% 

5% NA 

40% 91% 

25% NA 

50% 52% 

40% NA 

10% NA 

55% NA 

25% 52% 

10% NA 

10% 95% 

0.8% 50% 

13.2% NA 

17.5% 52% 

4.9% NA 

I 

Acreage of 

Roundup 

Ready® 

Rotational 

Crop Option7 

0 

7 

0 

0 

Total: 7 

0 

21 

0 

96 

0 

Total: 117 

15 

0 

0 

Total: 15 

0 

5 

0 

2 

Total: 7 

6 

0 

12B 

0 

J K 

Percent of Estimated 

Sugar Beet Percentage of 

Acres Roundup 

Preceding Ready® Crops 

Major 

RotationsB 

as Major 

Rotations9 

1.15% 0.14% 

1.83% 0.81% 

0.56% 0.15% 

16.53% 2.89% 

Affected Environment 

7/28/2010 
Table 2-2. Rotational crops following US sugar beet production and an estimation of rotational crops as Roundup Ready® crops 

(all acrea es are expressed as 1000 acres) 

A B C 0 E F G H I J K 

Percent of Percent Acreage of Percent of Estimated 

Total Major Crops Total Acreage Rotational Rotational Percent Roundup Roundup Sugar Beet Percentage of 

State Sugar Beet That Follow of Rotation Crop Crop Acres Rotational Ready® Ready® Acres Roundup 

Acres1 Sugar Beet Crop In States1 Rotated Following Crop of Total Rotational Rotational Preceding Ready® Crops 

In Rotatlon2 Following Sugar Beee Sugar Beet4 

Crop Options,s Crop Optlon7 Major as Major 

Sugar Beee RotationsD Rotations9 

Durum 2195 1.0% 23 1.6% NA 0 

Oats 260 3.8% 10 0.7% NA 0 

Potato 78 2.6% 2 0.1% NA 0 

Soybean 11,920 4.2% 505 35.6% 91% 460 

Spring Wheat 13,710 2.5% 347 24.6% NA 0 

Sugar Beet 40 10% 4 0.3% 95% 2 

\'\Anter Wheat 1,650 0.4% 6 0.4% NA 0 

State Totals Total: Total: Total: 2.89% 1.22% 48,836 1,411 596 

Legend: 

NA denotes not applicable. 

1 Acreage planted of the specific crop is based on 2002 planting data (USDA-NASS. 2003). 

2 Rotated crops and acreage following sugar beet production are based on communications from individual local experts. i.e., university agronomists, USDA-ARS and Monsanto field 

personnel. 

3 Column E obtained by dividing Column F by Column D and multiplying by 100. 

4 Column G obtained by dividing Column F by Column B and multiplying by 100. 

5 Roundup Ready® rotational crop penetration rates for corn and soybean are based on 2007 plantings (USDA-NASS, 2007); penetration rates for alfalfa are assumed to be 50% for 

the purpose of this assessment to represent potential future plantings. 

6 Roundup Ready® rotational crop penetration rates for corn and soybean are based on 2007 plantings (USDA-NASS, 2007); penetration rates for sugar beet are assumed to be 95% 

for the purpose of this assessment to represent potential future plantings. 

7 Column I obtained by multiplying Column F by Column H. 

B Column J obtained by dividing Column B by Column D Total and multiplying by 100. 

g Column K obtained by dividing Column I Total by Column D Total and multiplying by 100. 

Event H7-1 

Draft ER 35 

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In the Imperial Valley in California, sugar beets are planted in September, grow through the 

winter months, and are harvested the following April through June. Vernalization occurs more 

frequently in the Imperial Valley than in the other US regions, where sugar beet is planted in the 

spring and harvested in the fall. If the winter in the Imperial Valley is unusually cold and 

harvesting is delayed, some bolters can develop (California Beet Growers Association, 1998, 

pp. 3-5; Bartsch et ai, 2003). 

Sugar beet volunteers. Volunteers are plants from a previous crop that are found in 

subsequent crops. In most crops, volunteers grow from seeds. If sugar beet bolters are 

allowed to go to seed in certain more temperate climates, the seed may sprout and cause 

volunteers in later years, in other crops. Groundkeepers are a type of volunteer derived from 

vegetative tissue (small roots) left in the field after harvest, which can grow in the next season if 

not controlled. 

In most parts of the US where sugar beets are grown, beet roots would not be expected to 

survive the winter, and therefore groundkeepers would be of little concern (Panella, 2003). 

Cattanach et aI., who focused on production in the northern plains and upper Midwest (including 

North Dakota and Minnesota), reported that sugar beets could not survive the winter in these 

areas (1991). 

Sugar beets are not good competitors with other crops. Any that survive can be reservoirs for 

beet diseases and good management practices dictate that they be removed (Kaffka, 1998). 

2.4 GENE FLOW 

Definition. Gene flow has been defined as the "incorporation of genes into the gene pool of 

one population from one or more populations" (Futuyma, 1998). Gene flow is a basic biological 

process in plant evolution and in plant breeding, and itself does not pose a risk (Bartsch et ai, 

2003; Ellstrand, 2006, p. 116). 

How gene flow is addressed in this document. In this section we provide some background 

information on gene flow, which is included in several different discussions of impacts, as 

follows: 

• Potential for gene flow from event H7-1 sugar beet crops to conventional sugar beet 

crops (Section 3.3) 

• Potential for gene flow from event H7-1 sugar beet to crops to organic sugar beet crops 

(Section 3.4) 

• Potential for gene flow from event H7-1 sugar beet crops to other Beta crops (Section 

3.5) 

Event H7-1 

Draft ER 36 

Affected Environment 

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• Potential for gene fiow from event H7-1 sugar beet crops to other Beta seed production 

areas (Section 3.6) 

• Potential for gene fiow from event H7-1 sugar beet crops to native beets (Section 3.7) 

• Potential for gene fiow from event H7-1 sugar beets crops to weed beets (Section 3.8) 

• Potential for gene flow from event H7-1 sugar beet to any of the above receptors, in 

sugar beet seed production (Section 3.9) 

Hybridization. In plant biology, when gene fiow occurs between individuals from genetically 

distinct populations and a new plant is formed, the new plant is called a hybrid (Ellstrand, 2003, 

p. 10). Hybridization is usually thought of as the breeding of closely related species resulting in 

the creation of a plant that has characteristics different from either parent. Usually this occurs 

through deliberate human efforts; however, it can also occur indirectly from human intervention, 

or in nature. For example, when plants are moved to a new environment (with or without human 

intervention), they may hybridize with plants of a closely related species or subspecies in that 

new location. 

For natural hybridization to occur between two distinct populations, the plants from the two 

populations must fiower at the same time, they must be close enough so that the pollen can be 

carried from the male parent to the female parent, fertilization must occur, and the resulting 

embryo must be able to develop into a viable seed that can germinate and form a new plant 

(Ellstrand, 2003, pp. 11-13). 

Introgression. Hybridization may occur in one generation, but in most cases, does not 

continue on its own. If it does, and stable new populations result, the process is called 

introgression. For introgression to occur, hybridization of offspring back with the parent types 

(backcrossing) must occur several times. Because hybrids of distantly related species may not 

produce viable seed, introgression is much less common than hybridization. For example, in 

studies done with canola and a weedy relative, backcrossing from the hybrids to the weeds 

occurred at one-hundredth to one-thousandth the rate of the original hybridization (reported in 

Stewart, 2008, p. 2). Nevertheless, when weed species are introduced to new areas, there is 

the potential that those introduced plants may hybridize with other closely related species. 

Novel hybrids therefore may be created. In addition, novel hybrids may be created through 

back-crossing (Le. introgression) with parent species which may change the native species with 

non-native genetic material. Invasive weeds can result from hybridization events, which mix 

genetic material potentially producing a wide array of genotypes. Some of these genotypes 

may exhibit increased invasive properties (USDA ARS, 2008). 

Event H7-1 

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Characteristics that favor natural hybridization between two populations when the above 

requirements are met include (Mallory-Smith and Zapiola, 2008, p. 429): 

• Presence of feral populations (domestic populations gone wild) and uncontrolled 

volunteers 

• Presence of a high number of highly compatible relatives 

• Self-incompatibility 

• Large pollen source 

• Large amounts of pollen produced 

• Lightweight pollen 

• Strong winds (wind pollinated) 

• Large insect populations (insect pollinated) 

• Long pollen viability 

Feral populations are discussed in Section 2.9.4. Volunteers, which are plants from a 

previous crop that are found in a later crop, are common in agriculture and were discussed in 

Section 3.2.3. 

Highly compatible relatives of sugar beets present in the US include red table beets, spinach 

(or leaf) beets, and Swiss chard (discussed in Sections 3.5, 3.6 and 3.9); and weed beets of the 

same or closely related species (discussed in Section 3.8). 

Sugar beets and other members of the species B. vulgaris are self-incompatible; that is, 

fertilization does not occur between the male and female parts on the same plant. Selfincompatible plants must outcross: for fertilization to occur, the pollen from the male part of one 

plant must be caught by the sticky stigma within the fiower of the female part of another plant. 

Sugar beets are largely pollinated by wind (Mallory-Smith and Zapiola, 2008, Table 1; OECD, 

2001, p. 21). The potential for longer-distance gene fiow increases with higher wind speeds 

(Mallory-Smith and Zapiola, 2008, p. 3). Depending on wind conditions, wind-borne sugar beet 

pollen can be distributed horizontally at least 4,500 meters (2.8 miles) (OECD, 2001, p. 22). 

However, as discussed in Section 3.9, the vast majority of the pollen does not travel these great 

distances, and the very small amount that does is unlikely to pollinate another plant. 

Successful wind-pollinated fiowering plants must produce large amounts of pollen: the 

chances of any single wind-blown pollen grain landing on and being held by the stigma of 

Event H7-1 

Draft ER 38 

Affected Environment 

7/28/2010 
another plant are very small. Pollen occurs in "clouds": scientists have estimated sugar beet 

pollen production at one billion pollen grains per plant (Schneider, 1942, as reported in OECD, 

2001, p. 22). There is great competition within this cloud for the limited available ovules (only 

one each), and the stray pollen from another source has extremely limited opportunity for 

success. In a large, densely planted area such as a seed production field, pollination is much 

more likely from the pollen cloud within the field than from stray pollen from another field 

(Westgate, 2010, p. 3; Hoffman, 2010a, p. 8)). 

While pollen can be maintained for longer periods under laboratory conditions, scientists report 

that sugar beet pollen viability under natural conditions is limited to 24 hours (OECD, 2001, P 

22; Hoffman, 2010a, p. 8). 

2.5 SUGAR BEET WEED MANAGEMENT 

This section addresses weed management in sugar beets. Uncultivated wild beets, including 

feral beets and weed beets, are described in Section 2.9. 

2.5.1 Weed characteristics and concerns 

While a weed can be defined as any unwanted plant, problem weeds are those that are 

competitive and persistent within a given cropping system. 

Competition for light, water and nutrients. A grower tries to capture the plant resources -

primarily light, water, and plant essential nutrients; however, competitive weeds often secure 

some of these resources for their growth, at the expense of the crop. Some common 

characteristics of competitive weeds are rapid seedling establishment, high growth rates, prolific 

root systems and large leaf areas. 

Competition for light is probably the most important weed consideration for sugar beets, 

particularly in irrigated fields, which promote improved growing conditions. Sugar beets 

ultimately convert solar energy into sucrose, and reduction in light can have a dramatic impact 

on yields. Thus, weeds that grow taller than sugar beets, especially those with broad leaves, 

compete with available sunlight that the sugar beet would have used to make sucrose. 

Barnyardgrass (Echinoch/oa crus-gal/i), for example, has broad, flat leaves and can grow up to 

5 ft tall, as can Canada thistle (Cirsium arvense). Common lambsquarter (Chenopodium a/bum) 

and kochia (Kochia scoparia) are fast-growing weeds that can grow to six ft tall and quickly 

shade sugar beet seedlings. Wild oat (Avena fatua) and green foxtail (Setaria viridis) grow to 

heights ranging from approximately 26 to 41 inches. Sugar beet, by comparison, takes months 

Event H7-1 

Draft ER 39 

Affected Environment 

7/28/2010 
to reach its final height of approximately 22 inches (Tranel, 2003; McDonald et ai, 2003, pp. 9-

12; Mesbah et ai, 1994, p. 1). 

A plant's ability to compete for water is determined largely by the volume of soil the roots 

occupy. Weeds with large root systems are more likely to be detrimental to sugar beets during 

periods of water stress. Some perennial weeds can store a multi-year food supply in their roots 

(Tranel, 2003; McDonald et ai, 2003, pp. -12; Mesbah et ai, 1994, p. 1). 

Plants that develop a root system early in the season have long roots relative to the part of the 

plant above ground and have high uptake potential can compete successfully for nutrients. 

Simply applying more fertilizer does not solve the problem and may exacerbate it by stimulating 

weed grow1h; weeds often absorb nutrients faster and in greater amounts than sugar beets 

(Mesbah et ai, 1994, p. 1). 

Weed persistence. Persistent weeds are able to survive year after year on a given piece of 

land, in spite of a farmer's efforts to control them. Some plants are both competitive and 

persistent through the production of large numbers of seeds. The bushy wild proso millet 

(Panicum miliaceum), for example, shatters upon contact when mature, and can produce 400 to 

12,000 seeds per square foot. While high reproductive rates also contribute to a weed's 

persistence, dormancy is the most important trait in persistence. Cultivated soils typically 

contain thousands of seeds per square meter, waiting for the opportunity to germinate. Some 

weed seeds, for example, velvetleaf (Abuti/on theophrasti), can remain viable in the soil for up to 

50 years (McDonald et ai, 2003, p. 12). Many perennial weed species have the ability to 

reproduce from root fragments. Canada thistle, for example, has a deep, spreading root system 

that can continue to send up shoots after the surface plant has been removed multiple times. 

Some weeds have the ability to alter their characteristic in response to stress; for example, 

some weeds respond to drought by flowering and going to seed early (Tranel, 2003; McDonald 

et ai, 2003, pp. 9-12). 

2.5.2 Sugar beets and weeds 

The sugar beet plant is a poor competitor against weeds, especially from emergence until the 

sugar beet leaves shade the ground. Emerging sugar beets are small, lack vigor, and take 

approximately two months to shade the ground. Thus, weeds have a long period to become 

established and compete. To avoid yield loss from weed competition, weeds need to be 

controlled within four weeks after sugar beet emergence and weed control needs to be 

Event H7-1 

Draft ER 40 

Affected Environment 

7/28/2010 
maintained throughout the season (Cattanach et ai, 1991, p. 6; California Beet Growers 

Association, 1999, p. 25; McDonald et ai, 2003, p. 13; Mikkelson and Petrof, 1999, p 19). 

Uncontrolled weeds that emerge with the crop may cause from 30 to 100 percent yield losses 

(California Beet Growers Association, 1999; p. 25; Sprague, 2009). Increasing weed density 

causes increasing magnitude of yield loss, although the relationship is not linear: a few weeds 

may not affect yield, and at high weed populations the weeds begin competing with one 

another. While yield losses are the major concern, weeds create other problems. Late-season 

weeds can hinder harvesting operations. For example, infestations of wild mustard can cause 

loss of small beets during harvesting. Many weed species host pathogens (curly top virus), 

nematodes (sugar beet cyst nematode) and insects (aphids). High levels of weed control are 

essential for profitable sugar beet production (California Beet Growers Association, 1999; p. 25; 

Mikkelson and Petrof, 1999, p 19; Mesbah et ai, 1994). Prior to adoption of event H7-1 sugar 

beets, growers regularly used multiple chemical herbicides to attempt to control weeds. (Cole, 

2010a, pp. 12-13; Cole, 2010b, pp. 10-14; Kniss, 2010, p. 5; Wilson, 2010a, p. 9; Hoffman, 

2010, p. 12). 

2.5.3 Problem weeds in sugar beet production 

The USDA Agricultural Research Service (ARS) has identified the following weeds as problem 

weeds in sugar beets that have previously prevented production of maximum yields to 

conventional crops: kochia (Kochia scoparia), pigweed (Amaranthus spp.), common 

lambsquarter (Chenopodium album), nightshade (Solanum spp.) , common mallow (Malva 

neglecta), cocklebur (Xanthium strumarium), barnyardgrass (Enchinochloa crus-galli), foxtail 

(Setaria), wild millet (Panicum miliaceum), wild oats (Avena fatua), sowthistle (Sonchus L.), 

Canada thistle (Cirsium arvense), nutsedge (Cirsium arvense), and dodder (Cuscuta L.) (USDA 

ARS, 2008, P 61). Most of these weeds, and others, are present throughout all the sugar beet 

growing regions. Weeds are classified as annual or perennial. An annual is a plant that 

completes its life cycle in one year or less and reproduces only by seed. Annuals are further 

classified as broad leaf or grass. Perennials are plants that live for more than two years. They 

may reproduce by seeds, rhizomes (underground creeping stems) or other underground parts. 

Kochia (Kochia scoparia), an annual broad leaf plant, is a member of the Goosefoot family, the 

same family as sugar beet. Weeds in the same family as a crop often thrive in the same 

growing conditions. 

Event H7-1 

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Affected Environment 

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Pigweed (Amaranthus spp.) is a broadleaf annual that is a weed problem in many crops. There 

are several species; red root pigweed is most common (UC Integrated Pest Management [IPM] 

2010). 

Common lambsquarter (Chenopodium album )is an annual broad leaf in the same family as 

sugar beets. With its rapid growth and large size it quickly removes soil moisture (McDonald et 

al,2003). 

Nightshade (Solanum spp.) is a broad leaf annual that grows 6-24 inches tall (McDonald et ai, 

2003). 

Common mallow (Malva neglecta) and cocklebur (Xanthium strumarium) are widespread 

broad leaf annuals. 

8arnyardgrass (Enchinochloa crus-galli, foxtail (Setaria), wild millet (Panicum miliaceum) and 

wild oats (Avena fatua) are annual grasses. 

Sowthistle (Sonchus L.) is a perennial plant that reaches a height of 3 to 7 feet and reproduces 

by seed and underground roots. 

Canada thistle (Cirsium arvense) is a perennial that reproduces by seeds and underground 

roots and grows 2 to 5 feet tall. The roots extend several feet deep and some distance 

horizontally. Canada thistle is the most prevalent and persistent non-grass weed in Minnesota, 

and is the no. 1 noxious weed in Colorado. It is a problem weed in all growing regions. 

(Durgan, 1998, p. 8; Colorado Department of Agriculture, undated; McDonald et ai, 2003, p. 10). 

Nutsedges (Cyperus spp.) are among the most problematic weeds of agriculture in temperate 

to tropical zones worldwide. They are difficult to control, often form dense colonies, and can 

greatly reduce crop yields. Nutsedges reproduce primarily by rhizomes (UC IPM 2010). 

Dodder (Cuscuta L.) is an annual parasitic weed that grows only by penetrating tissues of host 

plants to obtain water and nutrients. Each plant produces thousands of seeds that can remain 

dormant in the soil for years cue IPM, 20 10). 

Velvetleaf (Abutilon theophrastl) is a broad leaf annual that grows 2-7 feet tall (McDonald et ai, 

p. 12; USDA 1999a, pp. 18-19). 

Ragweed (Ambrosia spp.) are annual broad leaf weeds that can be very competitive with crops. 

Event H7-1 

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Affected Environment 

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2.5.4 Other non-herbicide weed management practices 

In addition to crop rotation and tillage, discussed above, sugar beet growers of conventional 

sugar beets have other non-herbicide means to manage weeds. Narrow row widths (22 - 24 

inches) are commonly used by both conventional and sugar beet growers and those growing 

glyphosate-tolerant sugar beets, for quicker canopy closure (Cattanach et ai, 1991; McDonald et 

ai, 2003; Mikkelson and Petrof, 1999, p. 21). With respect to glyphosate-tolerant sugar beets in 

particular, because these crops do not require cultivation (i.e., in-crop tillage), sugar beet 

growers are switching to narrow-row production. With narrower rows, glyphoste-tolerant sugar 

beets can achieve canopy closure earlier in the growing season, which deprives weeds of 

sunlight and therefore retards late season weed growth (Wilson, 201 ~b, p. 4). Growers also use 

weed-free seed. Additionally, nearly all growers scout their fields for weeds (Ali, 2004). 

2.5.5 Use of herbicides to control weeds 

Herbicide use is regulated by EPA under FIFRA, rather than by APHIS, and EPA has granted 

glyphosate reduced risk status (Schneider, 2008, p. 4). Herbicides are used by virtually all 

sugar beet growers; in 2000 approximately 98 percent of planted acres received one or more 

herbicide applications (Ali, 2004, Table 4). Herbicides may be used before the crop emerges 

from the ground (pre-emergence) or after (post-emergence). Pre-plant incorporated (PPI) 

herbicides are mixed in with the soil before planting. The application method, whether PPI, preemergence or post-emergence, largely determines when the herbicide will contact plants and 

the portion of the plant contacted. In selecting a herbicide, a grower must consider, among 

other factors, the potential adverse effects on the crop, whether the herbicide is registered for 

use on the crop, residual effects that may limit crops that can be grown in rotation, effectiveness 

on expected weeds, and cost. 

Herbicide mode of action. Herbicides are chemicals that move into a plant and disrupt a vital 

process. They are classified according to their mode of action, which is the overall manner in 

which the herbicide affects a plant at the tissue or cellular level. Most herbicides bind to, and 

thereby block the action of, a specific enzyme"6 

2.5.6 Weed control with conventional sugar beets 

Conventional sugar beet growers use the weed control measures discussed above, plus a 

variety of herbicides. There are hundreds of commercial herbicides; only a fraction of that total 

can be appropriate for use with conventional sugar beet (Table 2-3). 

26 An enzyme is a biological catalyst and is usually a protein. Enzymes are discussed in more detail in Section 3.1.1. 

Event H7-1 

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The Weed Science Society of America (WSSA) has classified herbicides by group number, 

based on their mode of action. As shown in Table 2-3, herbicides commonly used with sugar 

beet include group numbers 1, 2, 3, 4, 5, 8, and 9 (Tranel, 2008, Dexter et ai, 1994; Ross and 

Childs, undated): 

Group 1 herbicides inhibit the action of the enzyme ACCase 

Group 2 herbicides inhibit the action of the enzyme ALS 

Group 3 herbicides inhibit cell division (mitosis inhibitors) 

Group 4 herbicides mimic the plant growth hormone auxin and cause uncontrolled cell growth 

(synthetic auxins) 

Group 5 herbicides inhibit photosynthesis 

Group 8 herbicides inhibit a single key enzyme involved in fatty acid synthesis 

Group 9 herbicides inhibit the action of the enzyme ESPSP 

Table 2-4 summarizes the effectiveness of the herbicides in Table 2-3 on the important sugar 

beet weeds identified by USDA ARS. As the table shows, no single herbicide is effective on all 

weeds. Some of these herbicides can be mixed together and applied at the same time (tankmixed). For conventional sugar beets, glyphosate can be applied only pre-emergence. Blank 

cells indicate no data were available for that source. 

Current practices for weed control in conventional sugar beets include tillage, pre-plant 

incorporation of grass and broad leaf herbicides, and in-crop use of grass and broadleaf 

herbicide tank mixtures (Dexter and Luecke, 2003; Dexter and Zollinger, 2003; WSSA, 1994). 

Each of these practices has limitations. Cultivation and pre-plant incorporation of herbicides are 

associated with narrow windows of application, which is based on a specific weed size or crop 

stage (Baker et aI., 1982; Baker and Johnson, 1979; Campbell and Janzen, 1995; Fawcett, 

1995). Additionally, herbicide performance and crop injury are influenced heavily by soil pH, 

target weed size, crop size, air temperature, and irrigation practices. Morever, many of the 

currently applied herbicides leave soil residues, whose persistence can impact crop rotation 

options in subsequent seasons (Dexter and Zollinger, 2003; WSSA, 1994) 

Event H7-1 

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Affected Environment 

7/28/2010 
· -_.- - _ ... _. --_._- - _.- _._----- --- ---- -_ .... - - . -- Agricultural Trade Name WSSA Mode of Acreage Number of 

Chemical Treated Applications 

(Herbicide) (typical) Action Group No. (%) per Year 

Clethodim Select 1 46 2.5 

Clopyralid Stinger 4 74 2.8 

Cycloate Ro-Neet 8 5 1.0 

Desmedipham Betanex 5 94 2.8 

EPTC Eptam 8 6 1.0 

Ethofumesate Nortron 8 37 2.1 

Glyphosate (Several) 9 13 1.1 

Phenmedipham Betamix 5 80 2.6 

Pyrazon Pyramin HRAC Group C1 6 1.0 

Quizalofop. ethyl Assure II 1 10 1.6 

Sethoxydim Poast 1 11 1.7 

Trifluralin Treflan HFP 3 5 1.0 

~ 

Triflusulfuronmethyl Upbeet 2 83 2.7 

1 1.565 million acres were planted in the US in 2000. All values are averages. Source: National 

Agriculture Statistics Service (www.usda.govlnass); www.weedscience.org; www.hracglobalcom. 

Event H7-1 

Draft ER 45 

Rate per 

Application 

(lb/appli.lac) 

0.04 

0.03 

1.84 

0.07 

2.61 

0.06 

0.39 

0.05 

0.82 

0.04 

0.19 

0.65 

0.008 

Rate per Total Applied 

Acre per Year 

tlb/ac) i1.000 Ib) 

0.11 77 

0.09 102 

1.84 139 

0.18 270 

2.64 230 

0.14 82 

0.43 86 

0.14 170 

0.85 76 

0.06 9 

0.33 56 

0.66 55 

0.02 29 

Affected Environment 

7/28/2010 
Table 2-4. Effectiveness of herbicides on major weeds in sugar beets. 

Broadleaves 

iii" 

Herbicide z 3 0 

""0 

",. 

",. ::r 0 "'0 0 ~ " en 0 

A 3 0 in '" .g 3 OJ 3 i5: a " ::r CD " OJ 3 =3 a ::r CD ru '" ""0 a a !)l. iii· CD "- <= ~ :J " :J "- CD ~ en 

Pre-plant incorporated 

Ro-Neet .... .. . ..... . ... ... . . ..•... .. 

M! Sugar P G F P F 

NDSU P F-G F-G P F-G F-G F-G 

Uof!D P E G P E P F 

Pre-emergence 

Nortron . . . . . . . 

. .. 

M! Sugar F G G F G 

NDSU F-G G-E F-G P P-F P F-G 

Uof!D F-G G-E F-G P G-E P F 

pyramin . . .... . ... ... . . . .. .... 

M! Sugar P G G P E 

UoflD P G-E F-G P G P P 

Eptam . . ...... .. . .... 

NDSU F F-G I F-G P F-G F-G I G 

U of ID I F I F-G I F-P I p I G I P I F-G I 

E= excellent, G = good, F = fair, P = poor, N = no effect. 

Event H7-1 

Draft ER 46 

Grasses 

CD 

OJ 

::; 

'< 

OJ ~ a. i5: (Q 

~ 3 OJ 

en 

en [ 

.... . ......... G 

G 

G 

. . 

P 

P 

G 

• ••• .. 

P 

P 

. . 

G-E 

G I 

(f) 

0 

-n ~ a ::r 

1i ~ ~ CD 

G N 

G-E 

G P 

F N 

F-G 

G G 

.. 

P I N 

P P 

. 

I G-E 

I G I F 

Perennials Parasite 

Z 

<= 

in 

to 

"- (Q 

CD 

. ..... 

G 

F 

. 

P 

P 

N 

P 

.. 

I F 

0 

OJ 

:J 

OJ 

"- OJ 0 

5' 0 

~ "-"- CD CD 

~ 

.. 

N 

N 

P P 

N 

N 

P P . . 

N I 

P P 

I N I 

I p I P 

Affected Environment 

7/28/2010 
Table 2-4. Effectiveness of herbicides on major weeds in sugar beets. 

Herbicide 

A 

0 

C1 

::r 

oj" 

Post-emergence 

Nortron i ........ 

M/ Sugar 

Pyramin 

M/ Sugar 

Betamix· 

M/ Sugar 

NOSU 

UoflD 

Betanex 

NOSU 

Upbeet· .... 

M/ Sugar 

NOSU 

Uof/O 

Event H7-1 

Draft ER 

-

-

. . ... 

F 

F 

P-F 

.. 

P-F 

-

poE 

G 

. 

Broadleaves 

z cO· 0 

lJ 0 ::r cO· ~ C1 

"' '" " ::r CD CD W 0- CD "- c "- CD ~ 

. .... ......... . .. 

.. . ..................• 

F G P 

.. 

. 

F F P 

. . . . 

G F F 

G F-G P-F 

G-E F-G F . 

G-E F-G P 

. .....•..... 

F F F 

F F N 

G-E G F 

Grasses 

[JJ 

or w 

3 ::; 

0-0 ~ 0 '< w ~ "' 0 3 0 a. 0: .g 3 w 3 0: '" W 3 3 =3 0 OJ ;:"0 00 W "' ~ ::J in: " ::J iii" "' 

. ... . .. .. i .. ... ... .. .. . 

F P 

. 

.... .. ... . 

F N 

. ... . . .. .. . ... . .. .. 

E P 

G P N P 

E P P P-F 

. . .. . . 

G P N P 

.. ..... ... 

..... 

. 

P P 

P G N N 

G F P P 

47 

-n 

0 

~ W 

-

.. 

.. .. ..... 

F 

.. 

N 

F 

F 

F 

P 

P 

F-G 

P 

Perennials Parasite 

rn z 0 

~ ~ 

"' ::r CD 

!a "-

m '" CD 

.. ... ... 

N N 

.............. 

P N 

. .. . . 

N N 

E P 

..... -

. .. 

N N 

G P 

0 

w 

::J 

w 

"-w 0 

5' 0 

Ui· "- "- m CD 

~ 

.. ...... . . 

N 

P 

... 

N 

N 

P P 

-: . . 

N 

. . . . 

P 

N 

P P 

Affected Environment 

7/28/2010 
Table 2-4. Effectiveness of herbicides on major weeds in sugar beets. 

Broadleaves Grasses 

[JJ 

ill ID 

Herbicide z 3 3 <5. 0 tTo 

~ "U 0 0 '< 

ID ~ <5. :::r " :>; '" 0 3 0 a 5: en -g 3 5: "Tl 0 '" '" :::r ID 3 <0 0 ro ID 3 3 " C1> ID =3 0 ~ 

:::r tT ;:"0 ID ID ~ C1> "- 00 iii· "- C1> ~ g: :J '" m: ~ '" :J 

en '" 

Sf' Inger c .....• . ..... .....• : . ...•• ···c_, .. .... . ..- ...................................... ... ............. ....•........... . ...... 

M! Sugar N P F E P 

NDSU N P F-G E P-F 

U af!D P P F-G E F 

Progress (a mixture of Bela mix plus Nortron) . 

. 

M! SUQar F G G F E 

NDSU F-G G G F G-E 

AssurelllSelect (Assure 1.1 only for.U ofID) ....... .. 

M! Sugar N N N N N 

NDSU N N N N N 

UaflD P P P P P 

Poast .. . . ........ .. ..... 

M! SUQar N N N N N 

UaflD P P P P P 

E= excellent, G = good, F = fair, P = poor, N = no effect. 

Event H7-1 

Draft ER 

N N 

P N P P 

P P P P 

... •• .. > . .. 

P F 

P N P F-G 

... ......• .. ..... ... ..... ... 

G E 

N E E E 

P G-E E E 

... . . ......... E E 

P G-E E E 

48 

Perennials Parasite 

0 

ID 

:J (jJ Z ID 

0 "-

~ c ID 0 en :::r s: 0 C1> C;;. "- C;;. "- ~ <0 "- ro CD ro g: 

.. . ...••.•...•. > ... . ....... 

G N G 

G-E 

G P E P 

.. . ... 

N N N 

N ... . .. ... .. ... . . .. N N N 

N 

P P P P 

. .... 

N N N 

P P - P 

Affected Environment 

7/28/2010 
Table 2-4. Effectiveness of herbicides on major weeds in sugar beets. 

Broadleaves Grasses Perennials Parasite 

OJ 0 OJ w w Herbicide Z 3 3 ::J 

<15' 0 0"0 ~ '< ~ (fJ Z W 

." 0 0 w 0 C>-

<15' ::; 0 <n 0 3 0 a c: ~ c: w A 0 en -§3 c: -n en 0 :;; "'" w 3 to 0 ::; SO 0 o ::; m W 3 3 <1> C>- <1> W =3 0 iil ~ e;;' C>- e;;' ::; 0" ;0.0 00 W C>-

iir <1> C>- c: ~ ::J :;; ::J en <n [ W m to m <1> C>- <1> ~ <n - <1> ~ 

Glyphosate. . ...... ·.i> ....... '.' .. ':' ...................... .... .............. . ............. .' > ....... ." ...... . ... / ." 

M! Sugar G E G E G E E - F G 

NDSU F-E E P-G E P-E P-G G-E E E G-E 

Select ". ." 

.' .. . •.... ' .. ........ . .... . ". . ... ..... ..... 

Uof!D P P P P P 

Treflan HFP . ". .' .. . ....... . '.' . 

,J!..2tJD F I_G_I P_-' P 1_ F-G 1 

E= excellent, G = good, F = fair, P = poor, N = no effect. 

Blank celis mean no data were available for that source. 

P 

....... 

P 

G-E E E P . 

. . . ' ..... . '

" . 

1 

F 

1 G 1 1 G 1 

P 

Sources: M! Sugar: Michigan Sugar, 2009; NDSU: Slach!er and Zollinger, 2009; U of 10: MOIishila, 2009 

Event H7-1 

Draft ER 49 

P 

' . 

1 P 

P P 

.. .' . 

1 P 1 

P 

Affected Environment 

7/28/2010 
Conventional weed control options are complex due to the need for several applications of 

multiple tank-mixed herbicides to achieve long-term, broad-spectrum weed control. As an 

example, a common practice in sugar beet production is to use "micro-rates" of herbicides 

(Dexter and Zollinger, 2003). This is accomplished by tank mixing multiple herbicides at 

reduced rates in combination with an oil additive. The components of the tank mixture may 

include Betanex (desmedipham), Betamix (phenmedipham + desmedipham), Nortron 

(ethofumesate), Upbeet (triflusulfuron methyl), and Stinger (clopyralid); and Select (chlethodim), 

if grasses are present. A minimum of three applications is recommended, beginning at the 

cotyledon growth stage and followed by weekly applications of this herbicide mixture. The intent 

of the micro-rate program is to lower overall herbicide costs and reduce the potential for crop 

injury. 

A member of the Minn-Dak Farmers Cooperative, who farms about 1,100 acres of sugar beets 

annually, described his conventional weed control system (Mauch, 2010, pp. 2-3): 

Prior to planting Roundup Ready® sugar beet, my herbicide regimen for conventional beet 

seed was very complicated and labor intensive. Pre-emergence, I used a combination of 

Eptam (which is very toxic to the sugar beet) and RoNeet (which is very expensive). 

Approximately two weeks after the beet plants emerge, I started spraying a mix of 

BetaMix, Betanex, Up Beet, Nortron and Stinger and adjunctives to make the herbicides 

stick better to the crops. This would be sprayed four times (approximately once a week). 

Even after spraying several times, there were still weeds and I then needed to hire manual 

labor to hoe and pull out the weeds. 

This description of the complexity of conventional weed control is similar to that provided by 

researchers evaluating weed management in sugar beets (Odero et ai, 2008). Odero et al 

evaluated 20 different weed treatment alternatives for conventional sugar beets and found that 

the following treatment yielded the highest net economic return: PPI treatment with Nortron 

(ethofumesate), followed by three micro-rate treatments of a tank mixture of Betamix 

(phenmedipham + desmedipham) and Nortron (ethofumesate), followed by Outlook 

(dimethenamid-P); with hand-hoeing following each herbicide application. 

Other researchers have also found that a combination of herbicides plus hand hoeing is 

required to effectively control weeds in conventional sugar beets (Dexter and Luecke, 2003). 

Hand-weeding is necessary in many situations; however, it is cost-prohibitive as a replacement 

for herbicides. USDA data shows that in 2000, conventional sugar beet growers spent an 

Event H7-1 

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Affected Environment 

7/28/2010 
average of $94.28/acre for all chemicals (insecticides, herbicides, fungicides, etc.) (Ali, 2004, p. 

7). Five-year studies of the cost of hand-weeding sugar beet at the University of California -

Davis, as reported by the California Beet Growers Association, found that the cost of hand 

weeding was between $260 to over $650 per acre (California Beet Growers Association, 1999, 

p. 29). Using the midyear of 1996 as the base year, this is equivalent to approximately $373 to 

$914 per acre in 2010 dollars, or approximately three to seven times what sugar beet growers 

spent on all chemicals. More recently, scientists in Wyoming have found that net returns for 

optimal herbicide application combined with hand weeding are more than twice the net returns 

for hand weeding alone (Odero et ai, 2008, Table 4). 

2.5.7 Weed control with event H7-1 

In-crop applications of glyphosate can be made from crop emergence up to 30 days prior to 

harvest. This flexibility allows the grower a wider window of application, with the application 

timing based on weed pressure, not on crop stage. Typically only 2-3 post-emergence 

applications of glyphosate are applied with GE sugar beets (Mauch, 2010; Grant, 2010). The 

broad spectrum of weed control offered by glyphosate (Table 2-4) reduces the need for tank 

mixing with additional herbicides. However, the use of other herbicides in combination with or in 

sequence with glyphosate is recommended as needed under specific conditions to address 

select weed and/or weed resistance issues. 

Monsanto's Technology Use Guide (TUG, 2010, Appendix E) provides specific weed control 

recommendations for event H7-1 sugar beet. The TUG recommends the use of "mechanical 

weed control/cultivation and/or residual herbicides" with event H7-1 sugar beets, where 

appropriate, and "additional herbicide modes of action/residual herbicides and/or mechanical 

weed control in other Roundup Ready® crops" rotated with event H7-1 (TUG, 2010, p. 40). 

2.6 HERBICIDE RESISTANCE 

Herbicide resistance is "the inherited ability of a plant to survive and reproduce following 

exposure to a dose of herbicide normally lethal to the wild type" (WSSA, 1998). 

Herbicide resistance is a result of natural selection. Plants of a given species are not all 

identical; they are made up of "biotypes" with various genetic traits. Biotypes possess certain 

traits or characteristics not common to the entire population. Herbicides, that suppress or kill 

weeds, can exert selection pressure on weed populations. When a herbicide is applied, the 

plants with resistance to it, which had no special survival qualities before the herbicide was 

Event H7-1 

Draft ER 51 

Affected Environment 

7/28/2010 
introduced, become the survivors who are then able to reproduce and pass on their genes. 

With repeated application of the same herbicide and no other herbicide or weed control practice, 

the resistant biotype becomes the dominant biotype in that weed community. In the mid-1950s, 

Harper (1957) theorized that annual, repeated use of any herbicide could lead to shifts in weed 

species composition within a crop-weed community. Similarly, Sandeen et al. (1982) suggested 

that a normal variability in response to herbicides exists among plant species and tolerance can 

increase with repeated use of an herbicide. Indeed, as of June 27,2010, 341 herbicide 

resistant weed biotypes have been reported to be resistant to 19 different herbicide modes of 

action (Heap, 2010). Glyphosate-resistant weeds account for 5 percent of the herbicide 

resistant biotypes while weeds resistant to herbicides that inhibit acetolactate synthase (ALS), 

such as Upbeet, accountfor 31 percent of the herbicide resistant biotypes. (Wilson, 2010a, p. 

6). 

Figure 2-3 shows the increase in herbicide resistant biotypes with time. Among the herbicides 

commonly used in conventional sugar beet, Assure II, Poast, and Select are ACCase inhibitors; 

Upbeet is an ALS inhibitor; Trefian HFP is a dinitroaniline; Stinger is a synthetic auxin, and 

glyphosate is a glycine. Figure 2-3 shows only the number of confirmed resistant biotypes. The 

total extent and distribution of resistant biotype varies widely. Details of herbicide resistant 

weed in sugar beets are discussed in Section 3.12. 

For as long as herbicide resistance has been a known phenomenon, public sector weed 

scientist, private sector weed scientist and growers have been identifying methods to address 

the problem. For instance, when a farmer uses multiple weed control tools to achieve weed 

control, herbicide resistance biotypes will be controlled and the resistance biotype generally will 

not become the dominant biotype within a population (Gunsolus, 2002; Cole, 201 Oa, p. 4). Sy 

contrast, weed resistance is known to occur most rapidly in areas where there is a sole reliance 

on a single herbicide used repeatedly over multiple crop generations for the management of a 

specific weed spectrum. 

When a grower encounters a biotype that is resistant to an herbicide he is using, the grower 

must use an alternate method of weed control. Management practices that can be used to 

retard the development of resistance, such as those routinely used by sugar beet growers, 

include herbicide mixtures, herbicide rotation, crop rotation, and increased cultivation. 

Event H7-1 

Draft ER 52 

Affected Environment 

7/28/2010 
120 

-m-ACCase Inhibitors 

100 ---k-ALS Inhibitors 

- Dinitroa.'1iiines 

~ 

0- -±-Triazines 

i?- 80 ~. --Q- Ureas, Amides 

0 -+-Bypyridiliums i!i ~ - ~ -+-Synthetic AUirim -, 

::: 60 ~Glycines E 

~ 

.~ 

.-

~ 40 '-

0 

~ 

"" <= 

~ ~O 

o~~ .. ~~~~~~ 

1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 1010 

Year Source: IallHeap 

h Up :/V{ eeclSci en ce. com 

Figure 2-3. Herbicide resistance worldwide 

Management practices that can be used to retard the development of resistance. such as those 

routinely used by sugar beet growers, include herbicide mixtures, herbicide rotation, crop 

rotation, and cultivation_ The WSSA reports: "Weed scientists know that the best defense 

against weed resistance is to proactively use a combination of agronomic practices, including 

the judicious use of herbicides with alternative modes of action either concurrently or 

sequentially" (WSSA, 2010b)_ 

2.7 SUGAR BEET SEED PRODUCTION 

2.7.1 Variety development 

When developing plant varieties for commercial release, plant breeders select individual plants 

with desirable characteristics, such as higher yields or pathogen resistance_ This breeding 

involves transferring pollen from one source plant to fertilize another plant Once plants with the 

desired traits have been selected, a population of those plants with similar characteristics are 

classified as varieties_ 

Commercial sugar beet variety development has been done exclusively by private sugar and 

seed companies in the US. Currently these are CrystallACH, Hilleshog (Syngenta), Seedex, 

Event H7-1 

Draft ER 53 

Affected Environment 

7/28/2010 
Betaseed (KWS) and SESVanderhavefHolly. As plant breeders continue to develop new 

germplasm, the identification of desirable traits (e.g., resistance to specific diseases, high sugar 

content, etc.) is incorporated into the development of new varieties. Due to geographic 

variability in weather, growing conditions, climate, insect and disease susceptibility vary from 

region to region, different varieties are developed for different regions. Sugar beet company 

selection committees in each region establish a list of approved varieties based on coded 

variety trials, which are designed to give an unbiased evaluation of the genetic potential of all 

sugar beet variety entries while other variables (stand, fertility, moisture levels, etc.) are kept 

constant. Growers may grow only those varieties that appear on the sugar beet company 

approved list for that region. Variety trials insure the use of the most productive varieties to 

maximize returns to the growers and sugar companies. Trials last 2 to 3 years and involve 

millions of plants each year. 

2.7.2 Hybrids and cytoplasmic male sterility 

To produce seed for commercial planting of the chosen variety, some crops, such as cotton and 

soybeans, rely on the same individual plant to serve as the female (pollen acceptor) and male 

(pollen donor) to produce seed. Other crops, such as corn and sugar beet, rely on two different 

varieties, called inbreds, to produce hybrid seed that carries traits from both parent lines. 

Hybrid varieties typically exhibit greater vigor than the parent lines on which they are based, 

resulting in plants with higher yields, better resistance to stress, and other desirable traits. 

Once a biotech plant such as event H7-1 has been developed, researchers will use that plant to 

breed the biotech trait to other varieties. In breeding sugar beet varieties for future commercial 

production, the biotech trait could be maintained on either the male or female plants. For 

greater breeding flexibility and efficiency in producing new varieties, plant breeders may prefer 

to breed additional varieties by introducing the biotech trait on male pollinator population of 

plants and use those plants to fertilize the same male-sterile female plants (Skaracis and De 

Biaggi, 2005). If the biotech trait is only on the female (male sterile) plant with eMS, as 

discussed below, that trait cannot be transferred to other plants in order to breed new inbreds. 

In hybrid sugar beet seed production, although each plant flower contains both male (the 

anther) and female (the stigma) parts, individual plants can be made female-only, or male 

sterile. Male sterility results in the failure of plants to produce functional anther, pollen or male 

gametes (Hovland, 2010, p. 2). In order for seed multiplication of the male sterile or female 

plant to occur, plant breeders develop a partner line ("0-Type") which is genetically identical to 

its equivalent male sterile or female line with the exception of its ability to produce pollen. This 

Event H7-1 

Draft ER 54 

Affected Environment 

7/28/2010 
identical O-Type is then used as the pollinator (male plant) to pollinate the female plant, 

resulting in offspring that will again be male sterile and not produce pollen. This seed, after 

meeting quality criteria relative to any impurities, is then used as the male sterile or female basic 

seed in the commercial seed production fields. This system is known as Cytoplasmic Male 

Sterility (CMS). It is the system used in many other crops to develop male sterile or female 

basic seed lines that do not produce pollen. Using female-only plants in seed production 

ensures that the hybrid seed harvested from those plants will be a cross between the two parent 

lines. Male and female lines are planted in alternating strips in a sugar beet seed production 

field, typically with two to four times as many female rows as male rows to maximize the amount 

of seed collected (Hoffman, 2010a, p.5). Often stecklings (small transplants) are used for the 

male lines. After pollination occurs, the male plants are destroyed (Holly Hybrids, 2007). Only 

CorvaUis 

~ 

~ 

Eugene, 

01 ~ 

~ p WODdburn 

.:; /' ~ J 

:!. ./ 

Salem 

* 

Of"""".'":,,, 

.. 1.'''''''' 

Oregon 

City 

s"J!/i"'''lrj,·,·r , 

., 

.'{: 

"'-:.", , 

;', ., 

':: 

o C;""P'''~~" /(""" 

Figure 2-4. Willamette Valley 

Source: Givler and Wel/s, 2001 

very rarely would a CMS fertile plant produce pollen 

and such plants can be identified and rogued. 

One producer reports identifying only two pollenproducing plants within a crop of over eleven million 

total plants (Anfinrud deposition, 2010,178). 

In the Willamette Valley, 78.6% of the 2009-2010 seed 

crop were grown with the glyphosate-tolerant trait on 

the female inbred. These female inbreds are male 

sterile because of the CMS trait and thus are bred not 

to produce pollen. (Preliminary Injunction Hearing, 

March 5, 2010, pgs. 17-18; 25). Therefore, the risk of 

transferring the glyphosate-tolerant trait to other plants 

from these seed production fields is negligible or zero. 

2.7.3 Commercial sugar beet seed production 

Willamette Valley 

At least ninety-five percent of the Oregon sugar beet 

seed production (equal to 70% or more of the total US 

55 

Affected Environment 

7/28/2010 
production), is in the Willamette Valley, located between the Coast Range and the Cascade 

Range (Figure 2-4 at left) (Stankiewicz Gabel, 2010, p. 7). The valley is over 100 miles long. 

The climate is cool enough for winter vernalization (prolonged exposure to a minimum cool 

temperature for a prolonged period of time that enables the plant to flower) but warm enough for 

the roots to live through the winter. Summers are very dry, producing ideal conditions for seed 

harvesting. While sugar beet is normally a biennial plant, conditions in the valley are such that 

seed can be produced in one year rather than two. Sugar beet seeds are planted in August or 

September and vernalize over the winter. The following spring, the plant produces a seed stalk 

(bolt). Seeds are harvested in late July to August. One seed company, Betaseed, grows the 

basic and commercial seed for its varieties at the southern and southeastern fringes of the 

Willamette Valley .. Syngenta develops its varieties elsewhere, and then ships the basic seed to 

West Coast Beet Seed Company (WCBS) for the commercial production. SESVanderHave 

develops its varieties both in the Willamette Valley and elsewhere, and ships basic seed 

produced elsewhere to West Coast Beet Seed Company (WCBS) for seed production. WCBS 

is jointly owned by a group of sugar beet seed and sugar companies. 

With its unique growing conditions, the Willamette Valley is used for seed production for many 

different kinds of seeds. In addition to seeds, many vegetables are also grown in the valley. It 

is a major area for production of "most temperate vegetables, herbs and vegetable seeds" 

(Mansour, 1999). Because high quality and seed purity are important to many growers, and 

because the valley is the site of varied seed production, sugar beet seed production companies 

have worked cooperatively to develop and implement protocols to maintain seed purity and 

quality. Most seed companies, including both WCBS and Betaseed, belong to the Willamette 

Valley Specialty Seed Association (WVSSA) and follow the guidelines for isolation and minimum 

separation distances between fields (Appendix A). 

WCBS and Betaseed have developed explicit standard operating procedures and grower 

guidelines that are intended to minimize and/or eliminate the possibility of inadvertent seed 

mixing (Appendix B). 

Maintainillg the illtegrity of seeds 

Currently, the WVSSA implements pinning procedures and isolation guidelines for seed 

production within the Willamette Valley. Pinning procedures identify the geographic location of 

production fields by placing pins and flags on a map. This is used to establish isolation 

distances between seed production fields. Additionally, WCBS and Betaseed have instituted 

Event H7-1 

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Affected Environment 

7/28/2010 
protocols and management practices to further maintain the integrity of seed which are 

essentially the same as required by Item 4 of the interim measures (Section 1.1.3). Seed 

production and quality control are a significant cost, to seed companies, and these companies 

within the Willamette Valley and throughout seed production areas carefully control growing 

conditions and production practices to ensure that seed is pure and of high quality - despite the 

fact that quality control in seed production carries significant cost. 

weBS Seed Production. WeBS currently produces much of the sugar beet seed for some of 

the sugar beet seed companies .. WeBS obtains basic seed from these sugar beet companies 

to further increase these small seed volumes into larger commercial quantities. Management of 

these fields and planting locations is controlled utilizing a tracking and tracing system 

distinguishing seed lots from the moment of initial delivery of seed, designated for seed 

production, to WeBS throughout the subsequent planting and harvest. This management 

further continues until the delivery of the finished packaged seed to the customer. Some 

companies further incorporate various computerized and digital tracking systems designed to 

manage real-time seed batch movement and quality testing. Many of these companies have 

sealed packaging and specified color coding designations to further identify seed batches/lots. 

(Meier, 2010, p. 3). Similarly, other companies ship event H7-1 sugar beet seed in packages 

accompanied by a declarations document that states the event H7-1 status of the basic seed 

(Anfinrud, 2010, p. 2). 

weBS contracts to individual growers for seed production. WeBS prohibits production of a red 

beet or Swiss chard seed crop by any WeBS grower in a year in which that grower is producing 

sugar beet seed, whether genetically engineered (GE) or conventional. WeBS also prohibits 

the sharing of planting, cultivation and harvesting equipment for red beet/Swiss chard and sugar 

beet seed, whether they are producing GE or conventional sugar beet seed (Loberg, 2010, p. 2; 

also in Appendix B of this ER27). In addition, WeBS requires its growers, by contract, to adhere 

to minimum isolation distance within a three mile radius of any GT field (Appendix B). 

weBS maintains control of all material, whether GE or conventional, from point of origin to 

return of the seed to the seed company (Appendix B). This includes control of the disposal of 

any excess GE stecklings that are not used for seed production. When those stecklings are not 

used for seed production and remain in the nursery field, such stecklings are uprooted and 

27 These requirements are in the Appendix B WeBS protocol, under the heading "GM Grower Guidelines." While the 

title is "guidelines," the protocol is clear that these restrictions are included in WeBS contracts with growers. 

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mixed into the soil during tillage for soil preparation for the next crop. Destruction occurs with 

this tillage and is followed by chemical control in the subsequent crop. Stecklings that are 

removed from the nursery, but are not used, are destroyed or securely disposed. The prevailing 

method is returning unused stecklings to the nursery field of origin and subsequent destruction 

through standard agricultural practices (physical destruction with tillage and chemical 

destruction in the subsequent crop) (Loberg, 2010, p 2; and Appendix B of this ER). 

Precleaning of seed at WeBS for shipment to the seed development company takes place in 

the dedicated WeBS facility. This process removes sticks, chaff, weeds and the like that may 

be contained in the seed when initially harvested. Because WeBS does not handle red beet or 

Swiss chard seed, its seed precleaning operations present no opportunity for mechanical mixing 

of sugar beet seed, whether conventional or GE, with red beet or Swiss chard seed. In years 

when WeBS produces both GE and conventional sugar beet seed, physical separation 

requirements and cleaning protocols protect against inadvertent mixing. In 2009, only two 

growers produced conventional seed for WeBS. All of this conventional seed was pre-cleaned 

at the end of the season, after completion of the pre-cleaning of the event H7-1 seed and after 

complete cleaning of the equipment. 

After the pre-cleaning, WeBS returns the seeds to the seed development company in sealed 

containers with color-coded labeling and shipping documents, which are checked upon arrival at 

seed processing facilities. Syngenta, for example, marks each container with a computergenerated and tracked batch number (Meier, 2010). SESVanderHave labels its event H7-1 

seed with an orange triangle. (Anfinrud, 2010, at p. 3). 

Betaseed seed production. Betaseed performs its own basic seed production, and like 

WeBS, it contracts commercial seed production to individual growers. Betaseed has adopted 

standard operating procedures (SOPs) that require all materials to be adequately identified and 

tracked through a computerized, bar-coded system from basic seed production to commercial 

seed production to final processing and shipping. All Betaseed personnel involved in seed 

production are trained in the SOPs and required to sign an acknowledgement that they have 

read, understood, and will comply with the SOPs (Lehner, 2010, p. 10). 

Betaseed supervises its commercial seed growers' practices for conformance with Betaseed's 

stewardship requirements. Betaseed's grower contracts provide for such supervision, as well 

as Betaseed's right to enter the grower's fields and take remedial action if the grower does not 

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comply with Betaseed's instructions. Betaseed pins all of its commercial seed fields in 

compliance with the WVSSA's pinning rules to ensure that isolation distance guidelines are 

followed. In addition, Betaseed requires its growers, by contract, to adhere to isolation 

distances of four miles from other crops that may cross-pollinate with sugar beets .. Betaseed 

also requires growers to clean their equipment before and after harvesting a sugar beet variety, 

and to monitor for and eliminate volunteer sugar beets. According to the SOPs, Betaseed 

personnel are present for the beginning of every harvest by a commercial grower. Betaseed 

provides bar-coded tote boxes into which the harvested seed is placed for transport to 

Betaseed's processing facility (Lehner, 2010, pp. 3-5). 

Betaseed performs "grow-outs" each year in which it plants samples of its commercial seed lots 

to ensure that the seed produces the expected variety of plant. Betaseed's grow-out 

observation plot did not produce any off-types this year (Lehner, 2010, p. 3). 

Syngenta seed processing. Syngenta processes sugar beet seed in its facility in Longmont, 

Colorado that is used only for sugar beet processing; a small percentage of the seed is 

processed by third party seed vendors in separate facilities dedicated to sugar beet processing 

(facilities where no red beets or Swiss chard seeds are processed). Processing of seed 

requires seven months and involves polishing, sorting by size, pelleting, treatment with 

fungicides and insecticides required by certain customers, coloring, packaging and shipping to 

growers in sealed packages. Syngenta maintains an extensive tracking and tracing system for 

every seed lot. This system includes a visual color identification of all RRSB material; a 

computerized, real-time record of seed batch movement, periodic germination and genetic 

identity testing; and extensive employee training. Syngenta also uses cleaning protocols to 

prevent any inadvertent mixing of RRSB and conventional sugar beet seed during processing. 

The cleaning process requires the removal of all RRSB seeds from the equipment and the plant 

floor. "Chase" seed is used to ensure that all GT seed has been removed from the equipment 

(Meier, 2010). with color-coded labels (Meier, 2010). 

SESVanderHave seed processing, storage, treating, packaging, warehousing, 

transportation and distribution. Neither SESVanderHave, its growers nor its contractors are 

involved in any respect in chard or red beet breeding, production or processing. 

SESVanderHave's GE protocols require that conventional seed and event H7 -1 seed are never 

handled or processed at the same time. For example, SESVanderHave does not allow its 

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processing contractors to process conventional seed at the same time that they are processing 

event H7-1 seed. (Anfinrud, 2010, p. 3). 

SESVanderHave receiving/storage of unprocessed seed protocols. SESVanderHave has 

additional GE protocols that apply to unprocessed seed shipped from West Coast Beet Seed. 

All event H7-1 seed products are identified upon arrival at bulk storage facilities. Shipping 

documents from West Coast Beet Seed are used to double check the seeds that arrive in 

Sheridan, Wyoming facilities. Also, proper disposal of reject or spilled seed is established by 

variety, lot and size. Product is unloaded only after insuring that storage bins and label bins 

have appropriate markings (event H7-1 products are labeled with an orange triangle). 

(Anfinrud, 2010, p. 3). 

SESVanderHave seed processing/storage protocols. Seed processed on behalf of 

SESVanderHave by third parties are subject to contractual arrangements that require 

compliance by processing contractors with SESVanderHave's GE protocols designed to prevent 

mixing of event H7-1 seed with other seeds during the various processing, treating, packaging, 

warehousing, transportation and distribution stages. Before dumping seed into the seed 

processing line, necessary equipment (conveyors, legs, distributors, storage bins) is cleaned. 

Product is unloaded only after insuring that storage bins have appropriate markings (event H7-1 

products are labeled with an orange triangle). A key lock and appropriate label is placed on 

each bin discharge slide. Once product is in storage bins, the tops of bins are sealed by tinning 

pipe. If necessary, unloading equipment is cleaned and seed is disposed of in proper manner 

followed by a documented inspection. Bins with event H7-1 products are labeled with an 

orange triangle. Processed seed is placed into properly labeled storage totes and clean-down 

procedures are followed between seed lots. Rejected seed is disposed in a local landfill. All 

event H7-1 seed totes are labeled with an orange triangle. Totes are then transferred to the 

warehouse and put in inventory by variety, lot number, warehouse and slot. (Anfinrud, 2010, p. 

3). 

SESVanderHave treating and packaging protocols. Product to be primed, pelleted, treated 

and packaged is identified. When event H7-1 seed enters any facility under contract with 

SESVanderHave, the necessary equipment (legs, distributors, blending system, Delta screen, 

treater, conveyors, aspirators, and bagging scale) is thoroughly cleaned before the product is 

introduced. All processes require documentation of weights introduced and weights after 

contract processing is complete. All contractors have been audited by SESVanderHave 

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personnel to assure compliance with GE protocols. Final packaging of event H7-1 seed is done 

in approved packages with proper labels. Packaged seed is transferred to the warehouse and 

put on inventory by variety, lot, treatment, warehouse, and slot. When treating of event H7-1 

seed is completed, if necessary, all treatinglpackaging equipment is cleaned following cleandown procedures. Reject seed is disposed of in an appropriate manner. (Anfinrud, 2010, p. 4). 

SESVanderHave warehOUSing, transportation and distribution protocols. Seed to be 

shipped is identified by printing delivery orders that identify event H7-1 seed. Warehouse crews 

stage loads. Each pallet of event H7 -1 seed is identified with a cover sheet. Any broken bags 

during transportation are recovered and returned to the originator for proper repair or disposal. 

Drivers are informed that event H7 -1 seed is present on loads. Sales and marketing personnel 

confirm that event H7-1 seed shipments are to approved customer locations (Anfinrud, 2010, p. 

4). 

SESVanderHave Auditing of Compliance with GE Protocols. SESVanderHave audits its 

contractors' compliance with its GE protocols as well as its own compliance to assure that 

SESVanderHave's standards of stewardship are maintained. SESVanderHave employees as 

well as outside consultants have worked on the audits, which have covered production, storage, 

processing, priming, pelleting, coating, packaging, handling, shipping and distribution of event 

H7-1 sugar beet seed. (Anfinrud, 2010, p. 4). 

Betaseed seed proceSSing. Betaseed processes and packages its own seed for distribution. 

Betaseed does not produce or process seed of any Beta species other than sugar beets, so 

there is no potential for mixing of GE seed with seed of any other Beta species in Betaseed's 

processing facility (Peters, 2010, p. 2). 

Betaseed employs a computerized tracking system to ensure that all of its varieties of seed are 

kept separate as they are processed. All processing steps are recorded and auditable. Every 

box of seed that is processed is accompanied by both a human readable label and a bar-code 

containing information about the seed, including whether it is GE or conventional. Seed cannot 

be loaded into Betaseed's processing equipment until the bar-code accompanying the seed has 

been scanned and the seed is determined to be of the intended variety. In the last two seasons, 

Betaseed has only processed one variety of conventional seed (and only a single lot of this 

variety in the last season). To avoid the possibility of any mixing of GE seed with the 

conventional variety, Betaseed processed its conventional seed before processing any of its GE 

seed. Betaseed thoroughly cleans its entire processing system before and after processing 

conventional seed (Peters, 2010, pp. 2-4). 

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Betaseed also conducts bioassay tests on each lot of seed at least twice as the seed is 

processed through its plant to ensure that lots of GM varieties are glyphosate resistant and that 

conventional varieties do not contain GM seeds (Peters, 2010, p. 4). 

2.8 RED TABLE BEET, SWISS CHARD, AND SPINACH BEET PRODUCTION 

2.8.1 Vegetable beet production 

In the USDA database, "beets" include red table beets, Swiss chard, and spinach beets (grown 

for the leaves). In the following discussion, these products are referred to as "vegetable beets." 

In 2007, the most recent year for which published data are available, 8,412 acres of beets were 

harvested in the US, on 2,744 farms, for an average of three acres per farm. Approximately 63 

percent of the acreage was for processed beets, and the rest for the fresh market (USDA 

NASS, 2010b). The total value of vegetable beet production in 1999, the most recent year for 

which USDA has data available, was approximately $7 million. Based on the most recent year 

for which USDA has both harvested acreage and production value data (1997), the average 

value of vegetable beet production per acre was approximately $720, which would be roughly 

$1,000 in 2010, adjusted for inflation (USDA NASS, 2010b). 

There is little overlap between areas of major vegetable beet production and sugar beet root 

production. Over half the 2007 acreage of vegetable beets (59 percent) was in two states, New 

York and Wisconsin, where sugar beets are not grown. California harvested 979 acres of 

vegetable beets in 2007. All California counties with five or more harvested acres reported are 

coastal. 28 Sugar beets are grown only Imperial County in California. Oregon harvested 425 

acres of vegetable beets, but no vegetable beet production was reported in the two Oregon 

counties with sugar beet root crops; however, some vegetable beet crops are grown in the 

Willamette Valley. One county in Colorado (Larimer), and one county in Michigan (Lapeer), 

reported both sugar beet and vegetable beet harvests. No more than 7 acres of vegetable 

beets were harvested in any single Minnesota county. Harvested vegetable beet acreage for all 

other sugar beet producing states in 2007 was ten acres or less each (Montana, Idaho, 

Nebraska, North Dakota, and Wyoming) (USDA NASS, 2010b). Although there is little overlap 

in major production areas, based on USDA FSA (Farm Service Agency) data, vegetable beet 

crops and sugar beet crops can sometimes be found growing in adjacent fields (Stankiewicz 

Gabel, 2010, p. 8). 

28 These results, which don't distinguish between organic and conventional, are not completely consistent with the 

State of California organic results discussed in Section 2.4.3, probably because of variations in the database of 

growers reporting. 

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2.8.2 Red table beet and Swiss chard seed production 

The most comprehensive data currently available for red table beet and Swiss chard seed 

production is from the FSA, however, the FSA does not distinguish between organic and 

conventional. Also, FSA does not include leaf beet seed production, which is apparently minor. 

According to data from the USDA FSA, red table beet seed in 2009 was grown on 

approximately 1,130 acres, with 92% grown in Washington State, 7% in Oregon and 1 % in 

California; and Swiss chard seed in 2009 was grown on approXimately 166 acres, with 51 % 

grown in Washington State and 49% in California. Based on FSA data, there are no counties 

where both Swiss chard and table beet seed are grown, and only one county, in the Willamette 

Valley, where both sugar beet seed and table beet seed are grown, In that county the FSA data 

lists only two table beet seed fields, The total FSA-reported red table beet seed production in 

Oregon is approximately 79 acres (Stankiewicz Gabel, 2010, p, 7), There is also minor Swiss 

chard seed production in Oregon, 

Based on older USDA published data, ninety-five percent of US red table beet seed production 

(650 to 700 acres) occurs within the small-seeded vegetable seed production area of western 

Washington State that includes Skagit, Island and Snohomish counties (See Figure 2-1 for 

locations) (Foss, 2007), These data do not exactly match the FSA data because they are for 

different years, and planting practices change from year to year. 

Neither sugar beet root crops nor sugar beet seed crops are grown in the part of western 

Washington where the majority of the US red table beet and Swiss chard seed production 

occurs, Very little sugar beet root crop is produced in Washington State; the nearest processing 

facility is far to the south, in southern Idaho, In 2008, only one county, Benton reported sugar 

beet production (1,600 acres) (USDA NASS, 201 Ob), Benton County is in the Columbia Basin 

on the east side of the Cascade Range, There is no reported production of Beta seeds other 

than minor sugar beet in the Columbia Basin, 

Due the extreme distance of this sugar beet production area from the Idaho processing facility, it 

is very unlikely that anyone would consider growing west of the Cascade range, in the area of 

other Beta production, As set forth in Section 2,3,2, transportation costs and proximity to a 

processing facility are key limiting factors in where to grow sugar beets. 

The locations of red table beet and Swiss chard seed production in California are not known, but 

sugar beet root crops are grown only in the Imperial Valley, and these are conventional sugar 

beets, 

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As discussed in Section 2.7.3, the majority of the US sugar beet seed production occurs in the 

Willamette Valley where seed production for the various beet products (sugar beet, table beet 

and chard) is divided along geographical lines. Sugar beet seed is grown in the southern and 

central portions of the valley, table beet seed is grown in the northern region, and Swiss chard 

seed is grown at the margins. 29 The total estimated red table beet and Swiss chard seed 

production in the Willamette Valley in 2010 is 100 to 120 acres (McReynolds, 2010). Based on 

the FSA data, this appears to be all or virtually all of red table beet and Swiss chard seed 

production in Oregon. 

Commercial seed production for red table beet is similar to that for sugar beet. Seed companies 

retain ownership of the seed, the growing crop, and the harvested seed. Growers produce and 

harvest the crop, and are then paid the contract price if the resulting seed meets contract quality 

criteria, typically an 85 percent seed germination rate and 99 percent purity (Foss, 2007). 

Typically, the red table beet crop is planted in seed beds in mid-June. Plants not displaying true 

varietal characteristics are removed by hand. In October, the beets are topped mechanically, 

dug, placed in windrows, and covered with about one foot of soil to protect the roots against 

freezing during the winter. In March or early April, the over-wintered roots (stecklings), are 

removed from the windrows and brought to Skagit County for transplanting into production 

fields. Exposure of the roots to the winter season in windrows, followed by transplanting into 

fields in the spring, vernalizes the stecklings. Seed harvest occurs in late summer and early fall 

(August to September). The crop is cut, placed in windrows, dried 10 to 14 days in the field, 

and then threshed mechanically to capture the seed (Foss, 2007). 

No information for Swiss chard seed production practices was found. 

29 Morton, 2010, p. 149:24-150:20. 

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2.8.3 Organic Red Table Beet and Swiss Chard Production 

California is the only state for which organic red table beet and Swiss chard production data are 

publicly available. In USDA's reports, red table beets and Swiss chard are included in the "other 

vegetable" organic category. California accounts for 76 percent of "other" organic vegetable 

production within the sugar-beet producing states, and there is very little or no organic 

production of red table beets, Swiss chard, or leaf beets in the four rnajor sugar beet production 

states (MN, NO, MI and 10) (Figure 2-5) (USDA, 2010c). The 2007 acreage and dollar value of 

organic red table beets and Swiss chard in California are shown in Figures 2-6 through 2-9. No 

data were found for organic seed production of red table beets, Swiss chard or spinach beets. 

" CA 

rnWA 

[TIeo 

mOR 

" MI 

ttlMN 

" ID 

" MT 

WY 

Figure 2-5. Distribution of "other" organic vegetable production across sugar 

beet producing states, 2008 

Source: USDA.2010c 

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Legend 

o Lesslhan 1 

o 1 to 10 

~ 1010100 

NEV/\Ot\ 

Tu!.!c 

Figure 2-6. California acreage of organic beets (non-sugar), 2007 

Source: Califomia Department of Food and Agriculture, 2010 

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Legend 

D Less than $1,000 

D $1,000 to $10,000 

$10,000 10 S100,000 

ill $100,000 10 $165,000 

Figure 2-7. California gross sales of organic beets (non-sugar), 2007 

Source: Califomia Department of Food and Agriculture, 2010 

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Dul 

Ilm!~ , 

Legend 

o Less than 1 

TuM, 

o 1 to 10 

Flun~;; 

10t0100 

III more than 100 

TuIJ·~ 

KtHl 

Figure 2-8. California acreage of organic Swiss chard, 2007 

Source: Califomia Department of Food and Agriculture, 2010 

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Legend 

D Less than $1 ,000 

D S1,DDDto$1D,DDD 

~ $1D,DDDto$1DD,DDD 

III $100,000 to $400,000 

Ir:y" 

Figure 2-9. California gross sales of organic Swiss chard, 2007 

Source: Califomia Department of Food and Agriculture, 2010 

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2.9 NATIVE AND UNCULTIVATED NON-NATIVE BEETS 

Plants that are native to a particular area or ecosystem are those that are not introduced by 

humans, but occur at those locations without human intervention. 

Non-native beets fall into one of three categories: wild plants, weeds and feral beets. Nonnative wild beets are those that that were never cultivated, and grow on their own outside of an 

agricultural/horticultural setting. Weeds, discussed in Section 2.5, included unwanted plants in 

an agricultural/horticultural setting. Feral beets are those that were originally domesticated, but 

have escaped cultivation and grow on their own. 

2.9.1 Native beets 

No native members of the genus Beta are found in North America (USDA, 2010a; Mansfeld, 

1986, as reported in DECO, 2001, Table 3). Thus, all of the Beta species in North America, 

both cultivated and uncultivated, were introduced through human intervention from outside the 

continent. 

2.9.2 Uncultivated wild beets in the US 

Beta species in tlte US and potential for hybridization with sligar beet 

The USDA reports two Beta species in the US: Beta procumbens and Beta vulgaris. Some 

researchers (e.g., Bartsch and Ellstrand, 1999; Bartsch et ai, 2003) consider Beta macrocarpa 

as a separate species; however, USDA ARS reports that the designation was changed in 2000 

to B. vulgaris ssp. macrocarpa (USDA/ARS, 2010a). B. procumbens can be artificially crossed 

with sugar beet (a B. vulgaris subspecies), but the plants usually die at the seedling stage 

(DECO, 2001, p. 25). In any case, B. procumbus in the US has been identified only in 

Pennsylvania, where sugar beet is not grown (USDA ARS, 2010a). Sugar beet hybridizes with 

all B. vulgaris subspecies, including B. vulgaris ssp. macrocarpa. The hybrids are all annuals, 

flowering in the first year and producing little or no root or sugar yield (Messean et ai, 2009, p. 

49). 

B. macrocarpa (or B. vulgaris ssp. macrocarpa). There is some scientific disagreement 

about the compatibility of sugar beet and B. vulgaris ssp. macrocarpa (referred to hereafter as 

B. macrocarpa, the terminology in all sources except USDNARS 2010a). DECO reports that B. 

vulgaris and B. macrocarpa are fully compatible and the resulting hybrids are vigorous and 

fertile (DECO, 2001, p. 24). In contrast, Dr. R.T. Lewellen, a USDA, ARS geneticist who has 

worked with sugar beet at the USDA/ARS Salinas Research Station for many years has done 

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research on B. macrocarpa and has concluded that it does not outcross readily to sugar beet. 

This is because B. macrocarpa usually bolts and flowers too early to cause a risk of 

hybridization with sugar beet. Additionally, any hybrid of sugar beet and B. macrocarpa would 

possess several genetic factors that pose a challenge to the plants' survival in nature. For 

example, the hybrid would be mostly pollen sterile and would have disturbed genetic ratios and 

growth habit. Finally, because B. macrocarpa is self-fertile, a cross could only be made with 

sugar beet by using self-sterile or male sterile sugar beet plants - something which is unlikely to 

occur in nature (Panella, 2003). 

Other researchers have also found that hybridization between B. macrocarpa and sugar beet is 

relatively rare because the flowering times usually do not overlap (Bartsch et ai, 2003, p. 108; 

McFarlane, 1975 as reported in DECO, 2001, p. 24). In addition, based on genetic studies, 

Bartsch and Ellstrand (1999) report a "strong genetic differentiation between B. vulgaris and B. 

macrocarpa, which supports the notion that the latter is a separate species" and find it 

"remarkable" that hybridization between the two "is still possible" (pp. 1126 and 1129). 

Sugar beets have been grown in the Imperial Valley since 1932 (Spreckels Sugar, 2009). As 

noted above, the earliest dated collected Beta specimen is from 1938; however, Bartch and 

Ellstrand reference observations of uncultivated wild beets in the Imperial Valley from 1928 

(Bartsch and Ellstrand, 1999, p. 1126). When Bartsch and Ellstrand did their research in 1998 

and found evidence of introgression between B. macrocarpa and B. vulgaris in two percent of 

the B. macrocarpa tested, sugar beets had been grown in the Imperial Valley for 66 years. 

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Figure 2-10. All CA counties with beta 

records 

Source: Consortium of California Herbaria, 2008 

Uncultivated wild beets in California 

The USDA/ARS has 13 B. vulgaris var. 

maritima30 and 7 B. vulgaris ssp. macrocarpa 

collected specimens in its National Plant 

Germoplasm System, all donated in 1985 by 

J.S. McFarlane of the USDA ARS Salinas, 

California office. The two B. vulgaris ssp. 

macrocarpa samples with collection 

information included were both from the 

Imperial Valley; one was collected from a 

sugar beet field in 1968; collection information 

for the other was not noted (USDAIARS, 

2010a). The Consortium of California, which 

keeps a database of 16 herbaria (collections 

of plant specimens) throughout the state, 

documents 172 Beta accessions from 15 

counties, collected between 1896 and 2006 

(counties show in Figure 2-10 at left) 

(Consortium of California Herbaria, 2008). 

Forty of the specimens are designated B. 

macrocarpa, 19 as B. vulgaris ssp. maritima, 

one simply as Beta, and the rest are 

designated B. vulgariS. Seventeen of the 

accessions are from Imperial County: 14 of 

these are designated B. macrocarpa, one is designated B. vulgaris, and one was originally 

identified as vulgaris and later corrected to macrocarpa. Imperial County collection dates 

ranged from 1938 to 1998 (Consortium of California Herberia, 2008). Calflora's database 

includes herberbia records, plus other documented or recorded observations. California 

counties with records of B. vulgaris or B. macrocarpa are shown in Figure 2-12, along with 

sugar beet production areas (shown as blue dots). 

30 Specimens were originally identified as Beta vulgaris ssp. maritima 

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There have been a number of hypotheses regarding the origin of the California uncultivated wild 

beets, including that at least some of them are wild (feral) sugar beets (Johnson and Burtch, 

1959, as referenced in Bartsch and Ellstrand, 1999, p. 1120). However, based on genetic 

analysis, Bartsch and Ellstrand (1999) concluded that the uncultivated wild beets in California 

have two independent and primary genetic origins, one from European B. macrocarpa (the 

uncultivated wild beets found in the Imperial Valley and on the Channel Islands) and one from 

European B. vulgaris (beets from all other areas in California where uncultivated wild beets are 

found). They found that what they termed the B. macrocarpa of the Imperial Valley and the 

Channel Islands were, with the exception of one population, "genetically identical with a Spanish 

B. macrocarpa from the Mediterranean area of Cartagena" (Bartsch and Ellstrand, 1 999, p. 

1126). The singe exception was a population in the Imperial Valley of B. macrocarpa that 

showed genetic similarities with B. vulgaris, which led them to conclude that the sugar beet (a 

subspecies of B. vulgaris) had introgressed with B. macrocarpa (Bartsch and Ellstrand, p. 

1126). Bartsch and Ellstrand concluded that the other uncultivated wild beets in California are 

descended from cultivated Swiss chard and red table beets, European sea beets, and 

hybridized populations among these (Bartsch and Ellstrand, 1999, p. 1128). 

Uncultivated beets in other sugar beet seed or root production regions 

One record for uncultivated B. vulgaris was found for Oregon: a specimen collected in 1 998 

from Corvallis in Benton County, by Andrew A. Duncan (Rice, 2010). Two records for 

uncultivated B. vulgaris were found in Michigan, one of which was in Tuscola County, which is in 

the Great Lakes Region of sugar beet production (USDA 2010a). USDA shows five counties in 

western Montana with B. vulgaris records (Madison, Gallatin, Ravilli, Missoula, Pondera and 

Cascade), based on Booth and Wright's 1996 Flora or Montana (USDA 2010a). None of these 

counties are in that part of Montana included in the Great Plains Region of sugar beet 

production (Figure 2-2). In addition, Rice (2010), a more updated source, shows no Beta 

records for Montana (2010). While there is widespread information about uncultivated beets in 

California, no other information was found other than that summarized here for uncultivated 

beets in any other sugar beet seed or root production areas. Since these records indicate only 

"B. vulgaris" it is not possible to determine from the information whether these plants are sugar 

beets or some other subspecies. 

In addition, USDA has previously concluded that BetaB. vulgaris only poses a weed issue for 

sugar beet crops in the Imperial Valley of California (USDA APHIS, 2005). 

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DEFINITIONS 

Ecosystem - the complex of a 

community of organisms and its 

environment 

Species - graup of organisms all of 

which have a high degree of physical 

and genetic similarity, generally 

interbreed only among themselves, 

and show persistent differences from 

members of allied graups of 

organisms. 

Introduction intentional or 

unintentional escape, release, 

dissemination, or placement of a 

species into an ecosystem as a result 

a/human activit;y. 

Native species - with respect to a 

particular ecosystem, a species that, 

other than as a result of an 

introduction, historically occurred or 

occurs in that ecosystem. 

Alien species - with respect to a 

particular ecosystem, any species, 

including its seeds, eggs, spores or 

other biological material capable of 

prapagating that species, that is not 

native to that ecosystem. 

Invasive species - alien species 

whose introduction does or is likely 

to cause economic damage or 

environmental harm or harm to 

human health. 

Invasive plants - introduced species 

that can thrive in areas beyond their 

natural range of dispersal. These 

plants are characteristically 

adaptableJ aggressive, and have a 

high reproductive capacity. Their 

vigor combined with a lack of natural 

enemies often leads to outbreak 

problems. 

Sources: Executive Order 13112 -

Invasive Species (1999); USDA 

National Agricultural Library, 2010. 

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2.9.3 Weed beets 

Beets (genus Beta) generally are not weeds: there are 

no Beta species included in the Weed Science Society of 

America's (WSSA) list of 3,488 weeds (2010a). No Beta 

species are included among the 1,553 weeds in the 

USDA database of invasive and noxious weeds (USDA, 

2010b). 

Weed beets in Europeall sugar beet production 

We discuss the problem of weed beets in European 

production fields because it is a concern in Europe and 

may raise questions about whether the same issues may 

occur in the US, and, if so, what impact the use of event 

H7-1 sugar beet would have. Weed beets have been a 

serious problem in European sugar beet production since 

the 1970s (May, 2001; Desplanque et ai, 2002; Ellstrand, 

2003). In 2000, some sugar beet fields in the EU were 

growing more weeds than beets (Ellstrand, 2003). 

Weeds of the same or closely related species as the crop 

can present special problems. Their seeds and young 

plants may be indistinguishable, and they will have very 

similar responses to herbicides. Unlike sugar beets, the 

weed beets flower in the first year, and produce many 

seeds. Because they are the same species, any 

herbicide that is effective on the weed beet will also 

damage or destroy the sugar beet. Thus, the weed 

beets must be manually removed, and the grower often 

does not find that the weed beets are not sugar beets 

until they bolt. The weed beets form a seed bank that 

can persist for years. While weed beets and native sea 

beets grow in many parts of Europe, the weed beets in 

the production fields apparently do not originate from 

weeds near the production fields. In the 1990s, the 

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problem was traced to hybridization of weed beets with the sugar beets grown in seed 

production areas (Ellstrand, 2003, p. 70-73). Sugar beet and sea beet (B. vulgaris ssp. 

maritima) hybridize freely and the resulting progeny are fully fertile. Sugar beet and sea beet 

also share a common flowering period. Sugar beets are grown in many parts of Europe, but 

seed production occurs mainly in the temperate climate regions of southwest France and 

northeast Italy, where weed beets are also present (Bartsch et ai, 2003). 

While the sugar beets and weed beets introgress with each other, and the weed beets and the 

native sea beets that grow along much of the Atlantic European and the Mediterranean also 

introgress with each other, in a century of sugar beet production, gene flow from sugar beets 

has not altered the genetic diversity of wild sea beets in the region, including in the seed 

production areas (Bartsch et ai, 2003). 

Weed beets ill the Imperial Valley 

In the US, the only reports of weed beets as a problem have been in sugar beet production in 

the Imperial Valley (Lewellen et ai, 2003; Bartsch et ai, 2003; Lilleboe, 2009). The weed beet 

situation in the Imperial Valley is very different from that in Europe. The weed beets in Europe 

originated from seed production fields, where the sugar beet plants and nearby wild beets all 

flower at the same time, and the resulting hybrids apparently contaminated the seed supply. 

Thus, the European weed beets in sugar beet root production fields originated from the 

inadvertent planting of the weed beet seeds along with the sugar beet seeds. In the Imperial 

Valley, the weed beets are B. macrocarpa, which were present in the Imperial Valley before the 

introduction of sugar beets, and have coexisted with sugar beets since 1938 with very little 

hybridization (Bartsch and Ellstrand, 1999; Bartsch et ai, 2003). 

2.9.4 Feral crops 

Based on available data, de-domestication has occurred in only a few crops. These feral crops 

are of minor importance compared with other weeds (Gressel, 2005). In North America, the 

feral plants that cause much of the economic damage are imported horticultural plants; for 

example, Japanese privet (Ligustrum japonicum), Japanese honeysuckle (Lonicera japonica) 

and kudzu (Pueraria lobata) (Gressel, 2005). 

Scientists from Oregon State University report that there are no feral sugar beet crops in the US 

(Mallory-Smith and Zapiola, 2008, Table 1). As discussed in Section 2.5.3, in California, the 

only sugar beet growing state with documented beet populations (as opposed to the isolated 

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reports from a few other locations), genetic assessment of uncultivated wild beets has not 

supported the conclusion that any of these beets are feral crops. 

Based on this information, and the poor competitive characteristics of sugar beets, we have 

concluded that the existence of feral sugar beet crops in the US is unlikely, and any that might 

exist are negligible. 

2.10 FOOD AND FEED USES OF SUGAR BEET 

In addition to producing granulated sugar, sugar beet processing facilities produce a co-product 

known as dried beet pulp. Pulp is the dried fiber residue left after most of the sugar has been 

extracted from the sliced beets. Dried beet pulp is typically sold as either a shred (with or 

without molasses added) or in pellet form for animal feed. Beet molasses is produced in 

quantities ranging from 4 percent to 5 percent of the weight of the beets and contains about 50 

percent sugar. Beet molasses is used for production of yeast, chemicals and pharmaceuticals, 

as well as in the production of mixed cattle feeds (Southern Minnesota Beet Sugar Cooperative, 

2010a). 

Multiple countries that regulate the importation of biotechnology-derived crops and derived 

products have granted regulatory approval to event H7 -1 sugar beets for food and feed uses, 

including Japan, Canada, Mexico, European Union, South Korea, Australia, New Zealand, 

China, Colombia, Russian Federation, Singapore, and the Philippines (FSANZ, 2005; 

Monsanto/KWS 2007; Berg 2010). Canada and Japan have also approved event H7 -1 sugar 

beets for cultivation in those countries (Sato, 2008; CFIA, 2005). 

2.11 PHYSICAL AND BIOLOGICAL ISSUES 

The affected environment for land use, air quality, water quality, ecology, threatened and 

endangered species, and other sensitive wildlife is the area in the sugar beet root producing 

areas (shown in Figure 2-1) and in the seed producing region in the Willamette Valley, the seed 

producing region (Figure 2-4). The affected environment for climate is global, as impacts on 

climate change are global issue. 

2.12 SOCIOECONOMICS AND HEALTH 

The affected environment for socioeconomic issues includes those individuals or groups who 

could be economically impacted if their food, feed, or agricultural products are adversely 

affected by event H7-1. It also includes those who would be economically impacted if event H7-

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1 becomes a regulated article: growers of event H7-1 sugar beets, sugar processors, seed 

companies, and sugar marketers and sugar buyers. Potential impacts to the first group are 

discussed primarily in Section 3.11 and impacts to the second group are discussed in Section 

3.16. The potential for health impacts to individuals who may come into contact with 

glyphosate-tolerant sugar beets or beet seeds, or sugar or other products derived from 

glyphosate-tolerant sugar beets is discussed in Sections 3.11 and 3.15. Health effects of 

potential exposure to herbicides are discussed in Section 3.15. 

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ENVIRONMENTAL CONSEQUENCES 

Section 3 of this ER examines the possible impacts of a partial deregulation of H7-1 or similar 

administrative action. 

3.1 PLANT PEST PROPERTIES AND UNINTENDED EFFECTS 

APHIS previously determined, based on scientific analysis and in accordance with its 

obligations under the Plant Protection Act, that sugar beet event H7 -1 is not a plant pest and 

does not exhibit plant pathogenic properties (USDA APHIS, 2005). 

APHIS considered the potential for the transformation process, the introduced DNA sequences, 

or their expression products to cause or aggravate disease symptoms in sugar beet event H7-1 

and its progeny or in other plants. APHIS also addressed the potential for event H7-1 to 

become a weed or make other plants that it breeds with into weeds. 

APHIS also considered whether data indicate that unintended effects would arise from 

engineering of these plants. APHIS considered information from the scientific literature as well 

as laboratory and field data collected during the trials with event H7-1 that was provided by 

Monsanto/KWS in its petition (included in Schneider, 2003). 

Based on the analysis summarized below, there are no impacts resulting from plant pest 

properties, introduced or aggravated disease symptoms, or unintended effects under any of the 

alternatives. Details of the Monsanto/KWS studies are included in the petition (Schneider, 

2003). 

3.1.1 Background 

Plant genetic modification 

Plant genetic modification by humans ranges from the simple approach of selection - where 

seeds of plants with desired traits are saved and replanted - to complex methods such as the 

use of recombinant DNA (rONA; see definitions on next page). Crossing (and then recrossing) 

two sexually compatible plants by taking the pollen from one plant and brushing it onto the pistil 

of another is still the mainstay of modern plant breeding (1M/NRC, 2004). Both conventional 

breeding and rONA methods can involve changes in the sequence, order, and regulation of 

genes in a plant and can use many of the same enzymes. However, with conventional breeding 

all the tens of thousands of genes in the plant are involved, and with the rONA method only a 

few genes are involved. In classical breeding, crosses can be accomplished only between 

closely related species, and therefore only traits that are already present in those species can 

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be targeted. In contrast, the rDNA approach can use 

genes from any living organism, thus opening the door to 

vast potential in trait development (Lemaux, 2008, p. 774; 

AMA,2000). 

Other examples of plant genetic modification include cell 

fusion (the protective cell wall is stripped and cells are 

fused by some external force) and induced mutagenesis 

(inducing mutations in seeds by ionizing radiation or 

carcinogenic chemicals) (Ronald and Adamchak p. 88). 

Mutagenic techniques, which have been in use since the 

late 1920s, create random mutations and are limited by 

their inability to target a desired trait (FDA, 1992; 

Lundqvist, 2009, p. 39). 

Agl'obactel'iul1l 

Agrobacterium tumefaciens (Agrobacterium) is a soil 

microbe that has been called "nature's own genetic 

engineer" because of its ability to transfer a fragment of its 

own DNA into a host plant (AMA, 2000). (See definitions 

at right.) The transferred DNA is stably integrated into the 

plant DNA, and the plant incorporates and expresses the 

transferred genes. The transferred DNA (T-DNA) 

reprograms the host plant cells to grow into callus tissue 

and produce certain amino acid derivatives that are a food 

source for the Agrobacterium. On a macro scale, the 

callus tissue growth is called crown gall disease. In the 

early 1980s scientists developed strains of Agrobacterium 

with T-DNA that lacked the disease-carrying genes 

("disarmed" Agrobacterium). Agrobacterium 

transformation system has been utilized in the 

development of a large number of genetically engineered 

plants in commercial production (1M/NRC, 2004, pp. 28-

29). The method uses a DNA molecule called a vector 

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DEFINITIONS 

Nucleotide - basic building block of 

nucleic acids such as DNA. Each 

nucleotide is made up afa nitrogen~ 

containing group, a sugar, and a 

phosphate group. 

Nucleic acid - a chain of 

nucleotides. 

DNA - deoxyribonucleic acid - a 

type of nucleic acid that acts as the 

genetic material in most living 

things. 

Chromosome - a DNA molecule 

containing all or parts of the 

genome o/an organism, which has 

the ability to replicate. 

Genome - the complete set of genes 

in an organism. 

Gene - the basic unit of heredity; it 

is a segment of DNA on a specific 

site on a chromosome. 

Amino acid - one of20 chemical 

building blocksfor proteins; there 

are also nonprotein amino acids. 

Cotalyst- a chemical that speeds 

up a chemical reaction but is not 

changed by the chemical reaction. 

Enzyme - a biological catalyst; 

usually a protein. 

RecombinantDNA (rDNA) 

techniques - procedures used to 

join together DNA segments. Under 

appropriate conditions, a rDNA 

molecule can enter a cell and 

replicate there. 

Mutation - any change in the base 

sequence of DNA. 

Diploid - containing two sets of 

chromosomes {one from each 

porentO. 

Sources: Sadava, 2008; 1M/NRC, 

2004; biology online; GMO Safety, 

2010a. 

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that serves as a carrier to insert T-DNA that contains specific genetic elements. These genetic 

elements are organized into a gene cassette, which consists of a gene encoding for a single 

biological function plus other genetic elements necessary for the expression of that gene when 

introduced into the plant. Other elements in the gene cassette include a promoter, which can 

be thought of as the "on switch" for the gene encoding for the desired trait; and a targeting 

sequence, which makes sure the gene product, typically a protein, ends up in the right location 

within the cell (such as the chloroplast). 

Unintended effects /1'0111 breeding 

Most crops naturally produce allergens, toxins or other antinutritional substances; these often 

serve the plant as natural defense compounds against pests or pathogens (FDA, 1992). Plant 

breeders typically monitor the levels of antinutritional substances relevant to their crop. For 

example, solanine is a naturally-occurring toxin produced by potatoes and is part of the plant's 

defense against insects and fungus. Potato breeders typically monitor solanine levels and 

reject lines that generate too much of it (1M/NRC, 2004). 

Scientists from the Institute of Medicine (1M) and the National Research Council (NRC) ranked 

breeding methods according to their relative likelihood of producing unintended effects, which 

they hypothesized would correspond to the degree of genetic disruption associated with the 

method. Selection from a homogeneous population was ranked at one end of the spectrum 

(less likely to produce unintended effects) and induced mutagenesis (from chemicals or 

radiation) was ranked at the other end (more likely). Agrobacterium transfer of rONA was 

among the methods ranked in between (1M/NRC, 2004, Figure ES-1). Recent studies in Europe 

comparing transgenic and conventional barley suggest that conventional breeding may cause 

more unintended effects than rONA methods, likely because of the very large number of genes 

that are affected in conventional breeding techniques (Sonnewald, 2010). These results are 

consistent with those observed by APHIS with event H7-1 and many other plants produced 

through rONA methods: except for the intended trait, the GE plant is found to be substantially 

equivalent to its non-GE counterpart. 

Glyphosate tolerance 

As discussed in Section 2, glyphosate acts by inhibiting the action of the enzyme 5-

enolpyruvylshikimate-3-phosphate synthase, EPSPS, in plants. EPSPS is a catalyst for a 

reaction necessary for the production of certain amino acids essential for plant growth. When 

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plants are treated with glyphosate the EPSPS enzyme is inhibited, they cannot produce the 

amino acids needed for continued growth and eventually die. The EPSPS protein and the 

reaction it catalyzes are present in all plants and microbes. There are variations in the amino 

acid sequence of EPSPS among different plants and bacteria. Glyphosate tolerance is 

achieved by introducing an EPSPS enzyme, termed CP4 EPSPS, that is not inhibited in the 

presence of glyphosate. An Agrobacterium strain (designated CP4) was the source of the cp4 

epsps gene that encodes for the CP4 EPSPS enzyme (Schneider, 2003). The CP4 EPSPS 

enzyme carries out the same enzymatic reaction in the plant as the native EPSPS; however, 

when plants that contain the CP4 EPSPS are sprayed with glyphosate, they are able to continue 

to produce the essential amino acids needed for plant growth. The objective of the genetic 

modification in event H7-1 was to simplify and improve weed management practices in sugar 

beet by conferring tolerance to glyphosate. 

Tralls/ormatioll system 

Event H7-1 was developed using a disarmed Agrobacterium-mediated transformation of a sugar 

beet variety used in plant breeding. Cotyledons (part of the seed embryo) derived from sterile 

seedlings of the diploid sugar beet line 3S0057 were used as the explant source. An explant is 

any portion of a plant that is to be used to initiate culture. These cotyledons were immersed in 

an Agrobacterium suspension and co-cultured for two to four days. The explants were then 

transferred to selective media containing 500 mg/l carbenicillin to eliminate the Agrobacteria. 

Glyphosate was used for selection of glyphosate-tolerant tissue, with tissue containing a genetic 

insertion to confer glyphosate tolerance assigned a unique number, such as event H7-1. After 

approximately seven weeks, the developed plantlets were transferred to rooting media and 

placed in a greenhouse. All subsequently developed event H7-1 sugar beet breeding lines and 

variety candidates were derived by traditional plant-breeding methods (Schneider, 2003, pp. 20-

21). 

DNA sequellces illserted illto sligar beet evellt H7-1 

Data supplied in the petition and reviewed by APHIS (Section VA, pp 29-44) support the 

conclusion that event H7-1 contains the following gene cassette: 

1) a promoter from a modified figwort mosaic virus, 

2) targeting sequence from the plant Arabidopsis thaliana, 

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3) the EPSPS gene from Agrobacierium sp. strain CP4, and 

4) a portion of a gene from pea that directs genetic processing 

This same gene cassette is present in other Roundup Ready® cotton and canola, which have 

previously been deregulated by USDA (Schneider, 2003, p. 24). The non-coding promoter is 

from the plant pathogen figwort mosaic virus. The promoter cannot cause plant disease and 

serves a purely regulatory function for the EPSPS gene. The CP4 EPSPS gene does not cause 

disease and has a history of safe use in a number of genetically engineered plants (e.g., corn, 

cotton and soybean varieties). 

3.1.2 Evaluation of intended effects 

Analysis of inheritance 

Data was provided and reviewed by APHIS that demonstrates stable integration and inheritance 

of the EPSPS gene cassette over several breeding generations. Statistical analyses show that 

glyphosate tolerance is inherited as a dominant trait in a typical Mendelian manner (Schneider, 

2003, Table V-2, pp. 45-46). 

Analysis of gene e:'(pression 

The level of CP4 EPSPS protein was determined from tissues collected from field trials with 

event H7 -1 conducted at several locations. Using standard laboratory techniques, protein 

concentrations from H7-1 beet leaves and processed roots (brei) were determined (Schneider, 

2003, Table V-3, p. 50). EPSPS proteins are ubiquitous in plants and microorganisms and have 

not been associated with hazards from consumption or to the environment. Crops that contain 

the CP4 EPSPS protein have been granted non-regulated status have included corn, soybean, 

cotton, rapeseed and sugar beet (USDA APHIS, 2010a). In 2009, significant acreages of corn 

(59 million acres or 68% of the total corn acres), upland cotton (6.3 million acres or 71 % of the 

total cotton acres) and soybean (70.5 million acres or 91% of the total soybean acres) grown in 

the US were planted with herbicide tolerant varieties (USDA NASS, 2010c). Although the data 

include all herbicide tolerant varieties, glyphosate tolerant ones (containing CP4 EPSPS) 

predominate. All have also undergone FDA review (FDA, 2010). 

Analysis of the intended trait 

Numerous field trials were conducted in the US (Schneider, 2003, Tables VI-4 to VI-6) and in 

Europe (Schneider, 2003, Table VI-7) to evaluate event H7-1 in different genetic backgrounds 

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and in different environments. Standard field trials evaluated 1) agronomic performance, 2) 

disease and pest resistance performance, 3) steckling (seedling) production and 4) seed 

multiplication. Standard industry farming practices for the various locales was used in these 

trials. These practices would typically include control measures for weeds, diseases and 

insects. Where glyphosate was used in trials, no negative impacts from application glyphosate 

were noted. 

3.1.3 Evaluation of possible unintended effects 

Disease and pest susceptibility 

In trials conducted from 1998 to 2002, qualitative and quantitative data addressing disease 

susceptibility and overall agronomic performance of event H7-1 were collected to assess 

possible effects from introduction of the CP4 EPSPS gene cassette. As summarized below, 

information collected from these trials indicate that event H7 -1 does not alter sugar beet's 

susceptibility to diseases and pests. Experience in production fields since 2007 supports this 

conclusion. 

Nursery trials in US. During the 2000 and 2001 growing seasons, quantitative data was 

collected from variety trials at Betaseed nurseries for comparison of varieties with event H7 -1 to 

conventional varieties for relative resistance to four common sugar beet diseases: Cercospora 

leaf spot, Aphanomyces root rot, Rhizoctonia root rot, and curly top virus. In these trials, results 

of season-long testing for disease susceptibility from one to three varieties with the H7-1 event 

were compared with four conventional varieties. The results indicated that the disease 

susceptibility of the H7-1 varieties was within the range of the conventional varieties (Schneider, 

2003, Section A.1). 

Field trials in US. A total of 98 separate Monsanto/KWS field trials were conducted in the US 

from 1998 to 2002 included comparative evaluation of susceptibility to the four diseases 

evaluated in the nursery trials, plus several fungal seedling diseases and Rhizomania 

(Schneider, 2003, Section VI.A.2). Together, these are the major diseases of economic 

importance affecting sugar beet production in the US (Schneider, 2003, p. 60). At all but six trial 

locations there were no differences observed between the event H7-1 varieties and the 

conventional comparators. At one trial site increased susceptibility to powdery mildew was 

noted while at three other sites decreased susceptibility was noted. At two trial sites increased 

susceptibility to Cercospora leaf spot was also noted. Given the interactions between the 

environment, the genetic backgrounds of the cultivars used and some inherent genetic 

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variability within sugar beet varieties, these results are not unexpected and do not indicate an 

increased pest risk. A similar likely insignificant difference was noted in a greenhouse trial using 

different Fusarium fungus isolates. Other researchers have suggested that it may be difficult to 

predict field results from greenhouse/laboratory experiments control lines or differences outside 

the range of conventional sugar beet norms. 

Field trials in Europe. Additional field trials were conducted with event H7-1 in Europe in 1998 

and 1999 and monitored for several diseases and nematode worms. No diseases or nematode 

symptoms were reported in any of the trials for either event H7-1 or conventional control sugar 

beets (Schneider, 2003, Section A.3). 

Gene silencing 

In evolutionary biology, a homologous trait is one derived from a common ancestor that appears 

in multiple species. Homology may be manifested on a macro scale, for example, in the 

similarity in mammal forelimbs, and on a genetic scale, in DNA sequences. AI-Kaff, et al.(1998) 

have noted gene silencing effects when transgenic plants have been infected by a virus with 

DNA sequence homology to a portion of the introduced genes. The only virus-derived DNA in 

the event H7-1 gene cassette is the promoter, which is from the figwort mosaic virus. None of 

the viral diseases of beet is related to figwort mosaic virus (Whitney and Duffus, 1986) so 

silencing of the EPSPS gene would not be expected, and has not been observed. 

Compositional evaluation 

Monsanto/KWS compared the composition of event H7-1 sugar beets with conventional sugar 

beets derived from the same parent line ("near isogenic control line"). To eliminate the influence 

of normal genetic variation between different hereditary lines and varieties, isogenic lines are 

usually used as a standard for comparison (GMO Safety, 2010a). The analysis of H7-1 sugar 

beets for compositional changes was included in Section VI.C of the petition (Schneider, 2003) 

and was also part of the Monsanto/KWS submission to FDA in the consultation process (See 

Section 3.11 for a discussion of the FDA consultation process and results). While FDA uses 

these data as indicators of possible nutritional changes, APHIS views them as a general 

indicator of possible unintended changes. 

Compositional analyses evaluating carbohydrates, proteins, fiber, fat, sugars, the antinutrient 

saponin, and eighteen amino acids (a total of 55 statistical comparisons) in tops (leaves) and 

roots (brei) identified seven statistically different values compared with the near isogenic control 

line. All analyses fell within the range of values observed for both the near isogenic control line 

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and conventional sugar beet varieties, providing additional evidence that event H7-1 sugar beet 

does not exhibit unexpected or unintended effects (Schneider, 2003). 

3.2 WEEDINESS PROPERTIES, VOLUNTEERS AND FERAL CROPS 

This section addresses two questions: 

1. What are the weediness properties of sugar beet? 

2. Is the event H7-1 sugar beet more likely to become a weed than a conventional sugar 

beet? 

3.2.1 Weediness properties of sugar beet 

As discussed in Section 2.5, sugar beets (8. vulgaris) are poor competitors with both weeds and 

other crops (i.e., beet can compete only with members of their own species). This is discussed 

in Section 3.8. 

3.2.2 Event H7-1 sugar beet and weediness 

Some scientists, for example, Ellstrand, 2006, have raised the question of "unintended crop 

descendents from transgenic crops." Ellstrand states (p. 116): "The possibility of unintended 

reproduction by transgenic crops has raised questions about whether their descendents might 

cause problems. These problems have fallen into two broad categories: first, the direct feral 

descendents of the crops may prove to be new weeds or invasive plants, and second, that 

unintended hybrids between transgenic crops and other plants could lead to certain problems." 

This section discusses the weediness properties of H7-1 sugar beet, and addresses the 

concern of direct descendents of the crop that "may prove to be new weeds or invasive plants." 

Hybridization is addressed in several later sections. 

Event H7-1 was field tested in North America from 1998 to 2003 and in Europe from 1998 to 

1999. In these trials, no differences were observed between H7-1 lines and non-transgenic 

lines with respect to the plants' ability to persist or compete as a weed (Schneider, 2003; USDA 

APHIS, 2005). In these evaluations, APHIS considered data relating to plant vigor, bolting, 

seedling emergence, seed germination, seed dormancy and other characteristics (USDA 

APHIS, 2005). 

In a separate evaluation, the Canadian Food Inspection Agency (CFIA), whose responsibilities 

include regulation of the introduction of animal food and plants (including crops) to Canada, 

reached the same conclusion about the weediness potential of event H7-1 compared with nonEvent H7-1 

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transgenic sugar beet. In 2005, the CFIA authorized the "unconfined release into the 

environment and livestock feed use of the sugar beet event H7-1" (CFIA, 2005). In its 

evaluation of event H7-1, CFIA "determined that germination, flowering, root yield, susceptibility 

to plant pests and diseases typical to sugar beet and bolting percentage were within the normal 

range of expression of these traits currently displayed by commercial sugar beet hybrids" (CFIA, 

2005). The CFIA reached the following conclusions (CFIA, 2005): 

No competitive advantage was conferred to these plants, other than that 

conferred by tolerance to glyphosate herbicide. Resistance to Roundup® 

agricultural herbicides will not, in itself, render sugar beet weedy or invasive of 

natural habitats since none of the reproductive or growth characteristics were 

modified. 

The above considerations, together with the fact that the novel traits have no 

intended effects on weediness or invasiveness, led the CFIA to conclude that the 

H7-1 sugar beet event has no altered weed or invasiveness potential compared 

to currently commercialized sugar beet. 

Thus, the potential for event H7-1 to become a weed or invasive plant was determined to 

to be no greater than conventional sugar beets. Neither sugar beets or other beta 

species plants are considered a weed issue in any state other than California. 

3.2.3 Sugar beet volunteers 

Volunteers, which are plants from a previous crop that are found in a later crop, may result from 

bolters or groundkeepers. Refer to Section 2.3.4 for a detailed discussion. 

Root productio11 

While several scientists have reported that volunteer glyph os ate tolerant plants could in theory 

become a problem in rotational crops when both rotational crops are glyphosate tolerant, none 

provided specific information or data relevant to sugar beets (e.g., Cerdeira and Duke, 2006; 

Owen and Zelaya, 2005; York et ai, 204; NRC, 2010). Since sugar beet is grown for the 

vegetable and not the seed, volunteers in a root crop could occur only from the rare plant that 

has bolted, if it is allowed to go to seed. Groundkeepers are cold sensitive and only rarely 

survive winter conditions in most sugar beet production areas (Grant, 2010,p. 7; Cattanach et ai, 

1991; Panella, 2003). 

As discussed in Section 2.3.4, bolters deplete the sugar content of the root and cause problems 

with harvesting. Thus, good management practices and the grower's own interest dictate 

removal of bolters. Sugar beet varieties are specifically bred to make bolters rare. Volunteers 

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are unlikely even if bolters are not removed because a series of unlikely events must each 

coincide to produce volunteers. If a bolter is not removed, it must be pOllinated by another 

bolter, and be allowed to go to seed; the seed must then survive the winter freeze and 

germinate. And even if this does occur, the resulting volunteer would need to successfully 

compete with the next year's crop, and could be controlled by mechanical means or by several 

registered herbicides other than glyphosate that can be used on sugar beet volunteers (Meister, 

2009). Depending on the rotation crops chosen to follow sugar beet (in the normal 3-4 year 

rotation), growers can use tillage and/or herbicides. Examples of some herbicides are 

methylsulfuron methyl, 2,4-dichlorophenoxyacetic acid (2,4 D) and 3,6-dichloro-o-anisic acid 

(dicamba) for the control of any volunteers prior to planting and after crop emergence. 

Seed production 

Control of volunteers is more of a concern with seed production, for both conventional and event 

H7-1 sugar beet, to maintain seed purity. As discussed in Section 2.7.3, WCBS and Betaseed 

control all seed production in the Willamette Valley. WCBS has detailed requirements in it 

protocol (in Appendix B of this ER) for post-harvest field management. After harvesting, the 

fields are shallow tilled and irrigated to promote sprouting of shattered seeds (unless sufficient 

rainfall to promote sprouting has occurred). Fall plowing is not allowed. After the seed is 

allowed to sprout, it is controlled by herbicides or other means. All equipment is cleaned 

according to WCBS procedures before it leave the fields. Fields used for growing event H7-1 

are inspected by WCBS "for a minimum of five years or until no volunteers are noted (Appendix 

B). Betaseed has similar requirements. 

3.2.4 Impact summary 

Alternative 1 

Under Alternative 1, there would be no impact from event H7-1 1 on weediness or volunteers. 

Alternative 2 

Weediness properties. Based on the information summarized in the subsection, APHIS has 

concluded that sugar beet does not exhibit weediness properties, and that event H7-1 does not 

exhibit any altered weediness properties when compared with conventional sugar beet. 

Therefore, Alternative 2 would not impact the weediness characteristics of sugar beet. 

Feral crops. As explained in Section 2.9, the existence offeral sugar beet crops in the US is 

highly unlikely, and any population that may exist would be negligible. Because there are no 

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known or suspected feral crops of sugar beets in the US, Alternative 2 would not impact feral 

sugar beet crops. 

Volunteers in root crop fields. Volunteers resulting from root crops are generally not a 

concern because the crop is harvested in the vegetative stage, bolters are generally rogued 

(removed), and the occasional volunteer would be unlikely to survive the winter freeze and 

could be controlled by other means than glyphosate. The interim measures further reduce the 

potential for any volunteers resulting frorn a root crop by requiring complete control of bolters. 

Under the proposed interim measures, all event H7-1 root crop growers will have measures in 

place that require them to survey, identify, and eliminate any bolters in their root crop fields 

before they produce pollen or set seed (Item 5). Therefore, no or negligible impacts from event 

H7-1 volunteers in root crop fields would be expected under Alternative 2. 

Volunteers in seed production fields. Managing volunteers in seed production fields is an 

important part of seed growers' efforts to maintain seed purity. WCBS and Betaseed have 

protocols in place to force same-year sprouting of seed left behind in the production field, plus 

long-term monitoring (five years for WCBS) of production fields to identify and remove any 

volunteers. The interim measures contain a universal requirement to force same-year 

sprouting, of any event H7-1 seed left behind in the production field, and subsequent removal 

and destruction of plants (item 4.j); 3-year monitoring of fields for volunteers along with removal 

and destruction (Item 4j); employee training (Item 4k); recordkeeping to document compliance 

(item 4m); and third-party audits for compliance (Item 7). Given the existing industry standards 

coupled with the mandates of the interim measures to control volunteers, no or negligible 

impacts from event H7-1 volunteers in seed production fields would be expected under 

Alternative 2. 

3.3 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON 

CONVENTIONAL SUGAR BEET CROPS 

This section considers the possibility of impacts from event H7-1 sugar beet crops on 

conventional sugar beet crops through gene flow (refer to Section 2.4 for a general discussion 

of gene flow), or by mixing in harvesting, transportation, stockpiling, or processing. 

3.3.1 Pollen sources in production fields 

As discussed throughout this document, in production fields sugar beets are grown for their 

roots and are harvested before they flower. The only sources of event H7-1 pollen in production 

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fields would be from uncontrolled bolters. Refer to Section 2.3.4 for a detailed discussion of 

bolting. 

3.3.2 Potential for gene flow in root production fields 

Because sugar beets are harvested in the vegetative stage, before they flower, there is little 

potential for cross-pollination between root production fields. Cross-pollination, if it occurred 

could potentially result in adventitious (inadvertent) presence of genetic material from the crop in 

one field into a nearby crop's field. Scientists from Oregon State University report that for sugar 

beet "gene flow via pollen or seed in root production fields is generally not an issue" (MallorySmith and Zapiola, 2008, p. 433). Messean et al concur: "the potential for adventitious 

presence of GM material in non-GM sug81 heet production is low through cross-polli~ation since 

the harvest is vegetative" (2009, p. 49). The Eur~pean Commission (the executive body of the 

European Union [EU]) Scientific Committee on Plants (2001) also :Jssessed the potential for 

adventitious presence of event H7-1 sugar beet at various stages offarm production. The 

Committee identified seed production as the major potential source of adventitious presence, 

with other sources, including planting, cultivation, cross-pollination, volunteers, harvesting and 

production all with no or minor potential contributions (p. 8). 

Because pollen dispersal is a concern with sugar beet seed production, it is discussed in detail 

in the analysis of impacts in seed production (Section 3.9). The Section 3.9 discussion 

evaluates distances over which cross pollination may occur; this is an issue with little relevance 

to root production. 

3.3.3 Potential for mixing of event H7-1 and conventional sugar beets 

As discussed in Section 2.2, 95 percent of sugar beet seeds planted in the US in 2010 were 

glyphosate-tolerant. Except in California, where only conventional sugar beet has been grown 

to date, production, processing and rnarketing within the industry no longer distinguishes 

between event H7-1 and conventional sugar beet crops-they are processed and marketed 

together. The 22 sugar beet processing facilities in the US process a cornbination of event H7-1 

and conventional sugar beets. As discussed in Section 2.3, no currently operating sugar beet 

processing facilities have been built in the US since 1975. Because a processing facility is 

required for sugar production, the 22 processing facilities account for all the beet sugar 

produced in the US. Markets have been available for the sugar, beet pulp, molasses and other 

products (Kaffka and Hills, 1994, p. 2; California Beet Growers Association, 1998; Western 

Sugar Cooperative, 2006a; Michigan Sugar Company, 2010b; American Crystal Sugar 

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Company, 2009; Minn-Dak Farmers Cooperative, undated; Snake River Sugar Company, 

2009). 

3.3.4 Consequences of gene flow in production fields 

We have found no reports of cross-pollination between event H7-1 sugar beet root production 

fields and conventional sugar beet crops since event H7-1 sugar beets were first grown in 

production fields in limited quantities the US in 2006. As discussed above, because sugar beets 

are harvested in the vegetative stage, bolters are uncommon, and it is good management 

practice to remove bolters, pollen movement, or gene flow between event H7-1 and 

conventional crops is expected to be minimal. 

If bolters occurred in two nearby fields, one with event H7-1 and one with conventional sugar 

beets, and the bolters were not controlled and were allowed to flower, a conventional plant 

could potentially become fertilized with event H7-1 pollen, and the resulting seeds may contain 

the event H7-1 trait. This occurrence would not affect the conventional sugar beet crop 

because it would be harvested before these new resulting seeds grew into sugar beet plants, if 

they did. If the seeds germinated and the resulting plants survived the winter, which is unlikely 

in most sugar beet production areas, the volunteer plants would appear in the conventional 

sugar beet farmer's next rotational crop, and (if they survived) would be treated as weeds, as 

described in Section 3.3, and would be eliminated. 

There is evidence that growers pay close attention to bolters. All growers that submitted 

declarations in the sugar beet litigation declared that bolters are easy to spot in their fields and if 

seen they would destroy them. There is no evidence that we have seen to the contrary. Any 

conventional sugar beet grower concerned about this occurrence could prevent it by controlling 

bolters in his sugar beet crop, which is normally stewardship for any sugar beet crop. 

3.3.5 Potential consequences from mechanical mixing 

With the exception of the Imperial Valley where only conventional sugar beets have been 

grown, grown, commingling of harvested beets from H7-1 seed and conventional seed has 

occurred since 2007, with no consequences. 

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3.3.6 Impact Summary 

Altemative 1 

Under Alternative 1, there would be no gene flow impact from event H7 -1 root crop production 

to conventional sugar beet crops. 

Altemative 2 

Gene flow. Even without the interim measures, impacts from event H7-1 sugar beet root crops 

to conventional sugar beet root crops have not occurred and would not be expected because: 1) 

sugar beets are harvested in the vegetative stage, before they flower; 2) if bolting and crosspollination occurred in nearby fields, the root crop would not be affected; 3) any conventional 

grower who wanted to be certain of preventing cross pollination could do so by controlling 

bolters in his own root production fields; 4) a volunteer event H7-1 hybrid appearing in a 

subsequent crop resulting from cross pollination in root production fields can be controlled using 

standard weed control practices and would not likely survive the winter in most growing areas in 

any event. 

The interim measures further reduce the potential for gene flow from event H7-1 root crops to 

conventional root crops by requiring complete control of bolters. Under the proposed interim 

measures, commercial event H7 -1 root crop growers will have measures in place that require 

them to survey, identify, and eliminate any bolters in their root crop fields before they produce 

pollen or set seed (Item 5). Item 6 of the interim measures requires event H7-1 processors or 

cooperatives to survey, identify, and eliminate any bolters in outdoor storage before they 

produce pollen or set seed. Therefore, no or negligible impacts from gene flow from event H7-1 

sugar beet root crops to conventional sugar beet root crops would be expected under 

Alternative 2. 

Mixing of harvested beets. Currently, by mutual agreement among growers, cooperatives, 

processors and marketers, event H7-1 sugar beets and conventional sugar beets are harvested, 

transported, stockpiled, processed and marketed without distinction in all areas except 

California, where event H7-1 sugar beet has not been grown. No impacts have occurred and 

none are expected. Through the interim measure (Item 1) prohibiting planting of event H7-1 in 

California, this status quo will be maintained. Therefore, under Alternative 2, no impacts are 

expected resulting from mechanical mixing of event H7 -1 and conventional sugar beets. 

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3.4 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON ORGANIC SUGAR BEET 

CROPS 

Based on all available information, we have concluded that there is essentially no organic sugar 

beet production in the US. The only reference to organic sugar beet production we found was 

from the State of California, where 0.02 to 0.03 acre of sugar beet production in Los Angeles 

County was reported from 2002 to 2007, with most recent annual sales of five dollars (California 

Department of Food and Agriculture, 2010). California is by far the largest producer of organic 

commodities in the US, accounting for approximately one-third of sales in 2008 (USDA, 201 Oc, 

Table 1). USDA tracks production of a number of organic crops, but not organic sugar beets. 

Although no other information was found, similar production may be occurring in other states. 

We have found no other information about organic sugar beet production in the US. As 

discussed in Section 2.3, all the commercial sugar beet grown in the US is processed into sugar 

at one of the 22 processing facilities, none of which process organic sugar beets. 

3.4.1 Impact summary 

Based on the above discussion, neither alternative would be expected to result in impacts to 

organic sugar beet production, because there is essentially zero organic sugar beet production 

in the US. 

There is a substantial European organic sugar beet business, and American organic farmers 

may in the future decide to grow organic sugar beets. This would most likely be small-scale 

production, as no processing facility would be available. The presence of event H7-1 sugar 

beet would not inhibit the development of an organic sugar beet industry. As discussed in 

Section 3.4, a grower of organic sugar beets could ensure no cross-pollination from event H7-1 

fields by controlling any bolters in his sugar beet crop. As discussed in Section 3.9, organic 

sugar beet seed is available from European suppliers. Therefore, Alternative 2 is not expected 

to result in impacts to organic farmers who may choose to grow sugar beets in the future. 

3.5 IMPACTS OFOF EVENT H7-1 ROOT CROPS ON OTHER BETA (NONSEED) CROPS 

The cultivated forms of B. vulgaris, including sugar beet, red table beet, Swiss chard, and 

spinach (leaf) beets are all varietal members of the subspecies vulgaris (B. vulgaris ssp. 

vulgaris) (OECD, 2001, Table 2). They are all biennial and all are sexually compatible with 

sugar beets (OECD, 2001). Whether grown for leaves or roots, beet crops are all harvested in 

their first year before they produce seed. In addition, as discussed in Section 2.8.1, there is 

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virtually no overlap between sugar beet root production areas and major areas of production of 

other Beta crops. 

Most growers purchase seed for their table beet crops; however, a few organic gardeners may 

allow part of their crop to vernalize then to go to seed and then save the seed for replanting. If a 

sugar beet production root crop was grown close to a table beet crop that was allowed to go to 

seed and the sugar beet crop had uncontrolled bolters that flowered at the same time as the 

other beet crop, there would be some very small potential for hybridization between the sugar 

beet and other beet. Based on the discussion in Section 3.3, this occurrence would be 

expected to be exceedingly rare and unlikely to occur. The situation would be no different for 

event H7-1 or conventional sugar beet. There is no indication that this has occurred since wide 

scale H7-1 beet root production began in 2008. 

3.5.1 Impact summary 

Alternative 1 

Under Alternative 1, there would be no impacts from event H7-1 root crop production on other 

Beta crops. 

Alternative 2 

Assuming no interim measure provisions, impacts from event H7-1 sugar beet root crops to 

conventional sugar beet root crops have not occurred and would not be expected because: 1) 

sugar beets are harvested in the vegetative stage, before they flower; 2) if bolting and crosspollination occurred between event H7-1 and other Beta vegetable crops, the harvested crop 

would not be affected; 3) any grower of Beta vegetable crops who wanted to be certain of 

preventing cross pollination could do so by controlling bolters in her own vegetable crop fields; 

4) a volunteer event H7-1 hybrid appearing in a subsequent crop resulting from cross pollination 

can be controlled using standard weed control practices and 5) major production of sugar beet 

root crops and other Beta vegetable crops do not coincide. In addition, among the sugar beet 

production areas, organic Beta vegetable growers, who may sometimes save their own seed, 

are concentrated in California, where only conventional sugar beet is grown. 

The interim measures further reduce the potential for gene flow from event H7-1 root crops to 

other Beta vegetable crops by requiring complete control of bolters. Under the proposed interim 

measures, all event H7-1 root crop growers will have measures in place that require them to 

survey, identify, and eliminate any bolters in their root crop fields before they produce pollen or 

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set seed (Item 5). Item 6 of the interim measures requires event H7-1 processors or 

cooperatives to survey, identify, and eliminate any bolters in outdoor storage before they 

produce pollen or set seed. Therefore, no or negligible impacts from gene flow from event H7-1 

sugar beet root crops to other Beta vegetable crops would be expected under Alternative 2. 

The prohibition on growing event H7-1 in California (interim measure Item 1), where the majority 

of the organic Beta vegetable crops in sugar beet production areas is grown, will further reduce 

the potential for any impact. 

In the multiple years of cultivation to date of GT sugar beet on a wide scale, there are no 

indications that gene flow has occurred." 

3.6 IMPACTS OF EVENT H7-1 SUGAR BEET ROOT CROPS ON OTHER BETA 

SEED PRODUCTION AREAS 

As discussed in Section 2.8, nearly all red table beet and Swiss chard seed production occurs in 

western Washington State and in California, where event H7-1 sugar beet root crops are not 

grown. A small amount of red table beet and Swiss chard seed production occurs in the 

Willamette Valley, where sugar beet root crops are not grown. Spinach beet seed production, if 

it exists separately from red table beet and Swiss chard production, is apparently very small. 

3.6.1 Impact summary 

Alternative 1 

Under Alternative 1, there would be no impacts from event H7 -1 production on other Beta crops. 

Alternative 2 

Even without the interim measures, impacts from event H7-1 sugar beet root crops to seed 

production areas for red table beets and Swiss chard (other Beta seed crops) have not occurred 

and would not be expected because: 1) sugar beets are harvested in the vegetative stage, 

before they flower; 2) seed production for red table beets and Swiss chard does not occur in or 

near the same geographic areas as event H7-7 sugar beet root production. 

Even if the unlikely event there were isolated areas of other Beta seed crops outside the main 

production areas (seed savers) and near sugar beet root crops, the interim measures further 

reduce the potential for gene flow from event H7-1 root crops to other Beta seed crops by 

requiring complete control of bolters. Under the proposed interim measures, all event H7-1 root 

31 Hofer Decl. (Dkt. #48) If 14; Berg Dec!. (Dkt. #39) 1115; Grant Dec!. (Dkt. #45) 1118; Lehner Dec!. (Dkt. #252) 11 

6. 

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crop growers will have measures in place that require them to survey, identify, and eliminate 

any bolters in their root crop fields before they produce pollen or set seed (Item 5). Item 6 of the 

interim measures requires event H7-1 processors or cooperatives to survey, identify, and 

eliminate any bolters in outdoor storage before they produce pollen or set seed. Therefore, no 

or negligible impacts from gene flow from event H7 -1 sugar beet root crops to other Beta seed 

crops would be expected under Alternative 2. The prohibition on growing event H7-1 in 

California and the Western Washington counties where the majority of the US red table beet 

and Swiss chard seed production occurs (interim measure Item 1), will further reduce the 

potential for any impact. In the multiple years of wide scale cultivation of H7-1 sugar beets, 

there have been no indications that that any gene flow has occurred 32 

3.7 IMPACTS OF EVENT H7-1 ROOT CROPS ON NATIVE BEETS 

As discussed in Section 2.9, no native members of the genus Beta are found in North America. 

Therefore, gene flow to native beets will not occur under either alternative. 

The absence of native Beta plants in North American is an important difference for sugar beet 

production concerns (both event H7-1 and conventional) from other regions of the world, in 

particular, the EU, where "[ilt is considered essential to preserve the diversity of sea beet [wild 

B. vulgaris ssp. maritimal for any long term plant breeding strategy, and for conservation and 

study in its own right" (Messean et ai, 2009, p. 40). 

3.7.1 Impact summary 

Because there are no native beet populations in the US, there would be no impact with either 

alternative. 

3.8 IMPACTS OF EVENT H7-1 CROPS ON NON-NATIVE WILD AND 

WEEDBEETS 

Non-native wild and weed beets are described in detail in Section 2.9. Except for isolated 

reports in Michigan and Oregon, all the known populations of non-native wild and weed beets in 

sugar beet root production states occur in California, where event H7-1 sugar beets are not 

grown. As discussed in Section 2.9, B. macrocatpa weed beets are a weed issue in the 

Imperial Valley, the only major sugar beet production area in California. Even so, research in 

1998 found only minor introgression between the sugar beets and B. macrocarpa after 66 years 

of coexistence in the Imperial Valley (Bartsch and Ellstrand, 1999). 

32 Hofer Decl.. (Ok!.. #48) 11 14; Berg Decl .. (Ok!.. #39) 11 15; Grant Decl.. (Ok!.. #45) 11 18; Lehner Decl.. (Ok!. 

. #252) '116. 

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3.8.1 Impact summary 

Alternative 1 

Under Alternative 1, there would be no effect of gene flow from event H7-1 to non-native wild or 

weed beets. 

Alternative 2 

APHIS has previously concluded that there are no issues with weed beet populations in the U.S. 

outside California. Within the states where event H7-1 root crops are grown, there are reports 

of non-native wild beets from Montana, Oregon and Michigan. The reports from Montana are 

dated; more recent data do not indicate the presence of non-native wild or weed beets in 

Montana. Also, the report was from a part of Montana where sugar beets root crops are not 

grown. The single report from Oregon is from an area where sugar beet root crops are not 

grown. One of the Michigan reports was from a county where sugar beet crops are produced. 

No additional information was found, and weed beets are not reported as a weed problem in 

sugar beet root production in Michigan (Michigan Sugar Company, 2009). Based on the 

absence of any information about any uncultivated beet populations in Michigan (and the 

challenges in surviving winter) non-native wild or weed beet populations are expected to be 

nonexistent or minor. The only potential for impact from a sugar beet root crop would be by 

gene flow from an uncontrolled bolter, assuming any non-native wild or weed beet is close 

enough to the bolter and flowering at the same time, so that it might be pollinated. Based on 

this information, the potential for impact from sugar beet root production crops on non-native 

wild or weed beets appears to be negligible. It would be non-existent with the proposed interim 

measures. Under the proposed interim measures, all event H7-1 root crop growers will have 

measures in place that require them to survey, identify, and eliminate any bolters in their root 

crop fields before they produce pollen or set seed (item 5). Item 6 of the interim measures 

reqUires event H7-1 processors or cooperatives to survey, identify, and eliminate any bolters in 

outdoor storage before they produce pollen or set seed In the multiple years of H7-1 cUltivation 

to date, there have been no issues identified with wild or weed beets. 

Non-native wild and weed beet populations exist in California. However, no event H7-1 

commercial crops have been grown in California, and Item 1 of the interim measures prohibits 

growing event H7-1 crops in California. 

Therefore, under Alternative 2, no impacts to non-native wild or weed beets would be expected. 

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3.9 IMPACTS OF EVENT H7-1 SEED PRODUCTION ON CONVENTIONAL 

SUGAR BEET AND OTHER BETA SEED CROPS 

It is possible, without proper stewardship, for cross-pollination and gene flow between crop 

types during seed production, because that is where pollination happens. Also, absent 

appropriate stewardship measures, physical mixing of seeds is possible during harvesting, seed 

cleaning, packaging and transport. 

3.9.1 Maintaining seed purity, identify and quality 

The Federal Seed Act and its implementing regulations" establish basic standards for 

certification of seed, which are carried out by state seed certifying agencies. A state seed 

certifying agency is created by state law, has authority to certify seed, and has standards and 

procedures approved by USDA "to assure the genetic purity and identity of the seed certified." 

Seed certifying agencies' standards and procedures must meet or exceed those specified in the 

USDA regulations. 34 

However, sugar beet seed is generally not certified, and seed companies have established their 

own standards, as described in Section 2. There are certified wheat, soybean and corn seed 

growers who produce their seed to sell to farmers for planting their commercial crops. This 

issue is not relevant in sugar beets, because none of the sugar beet root growers harvest any 

sugar beet seed. All sugar beet seed producers sell all of their seed to seed companies to be 

sold to farmers. Even if sugar beet root growers could save some seed, they have no means 

for processing it (so it would work in a planter) and providing the appropriate seed treatments 

and would never take the risk of trying to plant it because of the uncertainty of what they have. 

While sugar beet seed is generally not certified, the Oregon Seed Certification Service (OSeS) 

standards for certified seed and the corresponding isolation distances are reported here, as 

additional data points on what to expect in seed purity from a given isolation distance. The 

oses has set the following standards for those items for certified sugar beet seed (OSeS, 

1993): 

• Pure seed, minimum: 99.00% 

• Other crops, maximum: 0.10% 

• Inert matter, maximum: 1.00% 

33 7 C. F. R. §CFR 201 

34 7 U.S.C. §USC 1551(a)(25) and 7 C.F.R. §CFR 201.67 

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• Weed seed, maximum: 0.10% 

Minimum isolation distances required for certified seed are as follows (OSCS, 1993): 

• From sugar beet pollen of similar ploidy or between fields where male sterility is not used 

- 2,600 ft (0.49 mile) 

• From other pollinator or genus Beta that is not a sugar beet - 8,000 ft (1.5 mile) 

The maximum specified OSCS required isolation distance for sugar beet seed production is 

10,200 ft (1.9 miles, from other, non-sugar beet Beta species) for "stock" seed which has a 

maximum allowable concentration of "other crop" seed of 0.00% (OSCS, 1993). 

3.9.2 Summary of practices for sugar beet seed production 

All of the sugar beet seed in the Willamette Valley is produced by either West Coast Beet Seed 

Company (WCBSC) or by Betaseed (see Section 2.7 of this ER). WCBSC has developed 

explicit standard operating procedures and grower guidelines that are intended to minimize 

and/or eliminate the possibility of pollen-flow between fields of related Beta species (See 

Section 2.7 and Appendix B). Both WCBS and Betaseed belong to the Willamette Valley 

Specialty Seed Association (WVSSA) and follow the guidelines for isolation and minimum 

separation distances between fields (Appendix A). The minimum isolation distance from event 

H7-1 ("GMO") sugar beet and all other open pollinated Beta crops, in both the WCBS protocol 

and the WVSSA gUidelines is four miles. All growers of commercial specialty seed in the 

Willamette Valley are members of the WVSSA (Loberg, 2010). This includes all commercial 

companies raising Beta species. The isolation distances required by WVSSA between Event 

H7-1 sugar beets and other Beta species such as chard or table beets is 2.1 miles further than 

the maximum required OCCS isolation distance for stock seed discussed above. 

Principles of quality assurance for sugar beet seed production have been set forth in an 

industry-endorsed Code of Conduct (Appendix C). The Sugar Beet Code of Conduct adopted 

by the beet group of the International Seed Federation (ISF) describes the measures the sugar 

beet seed industry has taken to deliver high quality varieties, including measures to minimize 

adventitious presence of transgenic sugar beet seed in non-transgenic Beta seed. The Code of 

Conduct document has been agreed on by Syngenta Seeds, SESVanderHave, Danisco Seed, 

Fr. Strube Saatzucht KG, A. Dieckmann-Heimburg, KWS (owns Betaseed), and affiliated 

companies. 

3.9.3 Sugar beet seed production since 2007 

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Commercial H7-1 sugar beet seed has been produced since 2005, with the first major seed 

production year in 2006. The total acreage of H7-1 sugar beet in the Willamette Valley since 

2008 has been between 4000 and 5000 acres (Gabel, 2010, p. 7; Pierson, 2010, p.10). Only 

one grower who sells organic beet or chard seed has been identified in the Willamette Valley. 

That grower produced chard seed on approximately 1-3 acres at the Western margin of the 

Willamette Valley. He has tested his organic chard seed using a PCR test capable of detecting 

0.01% GE content during this period (Morton, 2010, 61:15-62:6). That seed has been tested 

each year since 2007 and to date has not detected the presence of any H7-1 sugar beet. 

(Hoffman, 2010a, p. 15; Morton, 2010, 36:8-17,75:19-77:13,99:6-21,112:10-14; Stearns, 

2010, 40:4-15, 49:6-16). 

In May 2009, an incident was reported involving event H7-1 steckling disposal that raised 

questions regarding one sugar beet seed company's stewardship and disposal requirements for 

those materials (Roseboro, 2009). Stecklings are sugar beet roots that may be transplanted 

into hybrid sugar beet fields. In or around May 2009, the Pro Bark garden store in Corvalis, 

Oregon procured a quantity of peat moss from Betaseed. Betaseed had used the peat moss to 

transport a shipment of sugar beet stecklings, and after the shipment had been transplanted, 

some quantity of stecklings remained in the peat moss. After Pro Bark obtained the peat moss 

Pro Bark mixed it with potting soil and offered it for sale as a fertile soil mixture. Betaseed 

learned that the mix was being sold and that it contained some stecklings, and at that point, Pro 

Bark's records indicated that it had sold portions of the mixture to thirty customers located in the 

Corvalis and Albany area. Betaseed repossessed the portion of the mixture that had not been 

sold. Betaseed personnel visited twenty of the thirty customers who had purchased portions of 

the mixture and removed any stecklings or steckling fragments found in the mixture. The 

owner of Pro Bark contacted seven additional purchasers and requested that they inspect for 

and destroy any stecklings they had purchased (Lehner 2010, pp 7-10.) 

Betaseed reported that the stecklings found in the mixture after repossessing it were not likely to 

survive and produce pollen. Most of the stecklings were fragmented, rotting or dead. Also, 

because a large percentage of Betaseed hybrid sugar beet fields in the Willamette Valley in 

2009 had the event H7-1 gene only on the non-pollinating female plant (see Section 2.7), the 

shipment of stecklings that Betaseed had transported in the peat moss was composed of less 

than 5% H7-1 male pollinators. Therefore, according to Betaseed, the chances that any 

steckling in the peat moss was intact, alive and a male H7-1 pollinator were remote. In addition, 

given the time of year when the fertile mixture was sold, cross-pollination would have been very 

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unlikely even if the stecklings had been able to produce pollen, and there were no subsequent 

reports of any cross-pollination from the stecklings. Betaseed subsequently revised its 

Standard Operating Procedures to provide for proper disposal of the peat moss in which it 

transports stecklings (Lehner, 2010, pp. 7-10). 

3.9.4 Measured sugar beet pollen dispersal 

Many studies have been done to measure distances over which cross-pollination may occur in 

Beta species, with a range of results (e.g., Bartsch et ai, 2003; Chamberlain, 1967; Darmencyet 

ai, 2009; Darmency et ai, 2007; Fenart et ai, 2007). Darmency et al (2009) summarized a 

literature review of studies on pollen flow in sugar beet (values reported in meters converted to 

feet): 

Authors Maximum dispersal 

Alibert et al (2005) 2.1% at 700 ft 

Archimowitsch (1949) 0.3% at 2,000 ft 

Bateman (1947) 0.07% at 62 ft 

Brants et al (1992) 8% at 250 ft 

Dark (1971) 0.1% at 100 ft 

Dark (1971) 3,900 ft max (using a pollen trap, not hybrid seed 

production) 

Darmency et al (2007) 1.3% at 920 ft 

Jensen and Bogh (1942) 2,600 ft max (using a pollen trap, not hybrid seed 

production) 

Madsen (1994) 0.31 % at 250 ft 

Saeglitz et al (2000) 40% at 660 ft 

Scott and Longden (1970) 26 ft max (using a pollen trap, not hybrid seed 

production') 

Stewart and Cambell (1952) 10% at 50 ft 

Vigouroux et al (1999) 1.2% at 50 ft 

Note. The maximum dispersal was " the highest rate at the farthest distance to which pollen or hybrrds 

were found in the study". 

Darmency et al (2009, p. 1085) note that the experiments "were hardly comparable because the 

experimental design varied widely." The researchers also found that nearly all fertilization from 

pollen source occurs near the field (within about 0.3 miles). The summary table does not make 

distinction between mere pollen presence and actual hybridization, which, as discussed 

previously, can be very different. Darmency et al did not report how many, if any, of these 

studies used isolated bait plants rather than groups of receptor plants that would be producing 

their own pollen cloud, which, as discussed above, could make a substantial difference (i.e., the 

percentages of pollination by an outside source are much smaller with competition). Also, in 

their own experiments, even when the pollen reached the target plant and hybridization did 

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occur, Darmency et al found a large drop in germination rates in seeds produced by plants 

removed from the source, with approximately 40 percent at the source dropping to one percent 

at around 1,000 feet from the source (2009, p. 1087). 

3.9.5 Modeled sugar beet pollen dispersal 

Research scientists specializing in modeling pollen dispersal have modeled the sugar beet 

pollen dispersal for outcrossing to the organic Beta production field of a Plaintiffs declarant who 

believed his fields would be cross-pollinated by event H7-1. The nearest event H7-1 field was 

6.9 miles distant. Using conservative assumptions and modeling conditions for the three days 

during the "pollen shed" period when wind conditions were most likely to result in crosspollination (June 22, 23, and 27), the modelers obtained the following results for likelihood of 

outcrossing: June 22,1 in 4.9 million; June 23, one in 1.1 billion; and June 27,1 in 222 million. 

The risk of any successful pollination in these circumstances is highly remote. 

3.9.6 Site-specific assessment of cross-pollination potential in the Willamette Valley 

This discussion focuses on the Willamette Valley because it is the only known location where 

event H7-1 commercial seed production and commercial seed production of Swiss chard and 

red table beet coexist. At least three qualified scientists have evaluated the potential for gene 

flow from event H7-1 to other Beta seed crops in the Willamette Valley: Mark Westgate, PhD, 

whose results are summarized above; Neil Hoffman, PhD. and Leonard Panella, PhD. 

Westgate is a professor of crop production and physiology at Iowa State University, whose 

"scientific research focuses on understanding environmental factors that affect pollination and 

seed formation" (Westgate, 2010, p. 1). Hoffman is a plant physiologist who is currently an 

APHIS official. Among his previous positions were professor of plant biology at the Carnegie 

Institution and Stanford University (Hoffman 2010a, p. 1). Panella, a plant genetiCist, is 

research leader of the sugar beet research unit at the USDA ARS Crop Research Laboratory in 

Fort Collins, Colorado (Panella, 2010, p. 1). 

Westgate explains that most pollen falls within the "immediately surrounding" area of the source 

field. In addition, many other factors affect the possibility of cross pollination in two Beta seed 

production fields, including receptiveness of the female, wind and humidity conditions, viability 

of the pollen, and competition (see Section 2.4 for a general discussion of these factors). For 

example, Swiss chard and table beets that are grown for seed are primarily open pollinated (all 

plants produce pollen) rather than hybrids using male sterile females, as is used in the 

production of most sugar beet seed (discussed in Section 2.7). The pollen cloud in an open 

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pollinated field is "typically four times more dense than the local pollen cloud for a standard 

hybrid field" with "billions" of pollen grains per square meter making it much more difficult for a 

small amount of the stray pollen that might be carried on the wind from another field to compete 

in the open pollinated fields (Westgate, p .. 5). Westgate concludes, in general, "when all the 

principal factors affecting pollination are considered, the probability of pollination of table beet or 

chard fields by sugar beet pollen in the Willamette Valley is infinitesimally small" (Westgate, 

2010, p. 6). 

Hoffman indicates that nearly all fertilization from a pollen source (99.9%) occurs within the first 

500 m (about 0.3 miles), and that any pollen that might reach another downwind field would 

have to compete with pollen from that field. Based on his assessment of conditions in the 

Willamette Valley, Hoffman concluded that the 4-mile isolation distance (as articulated in Interim 

measure No.2) "to isolate unlike sexually compatible crops such as Swiss chard, table beets 

and sugar beets is more than 12 times the distance needed to reduce cross-pollination between 

RRSB and Swiss chard to 0.1 % (1 seed in 1000) in a worst case scenario without competition 

from a local pollen source" (Hoffman, 2010a, p. 14). Hoffman expects the level of gene flow to 

be less than one seed in 10,000 (0.01%) with a four mile isolation distance. Panella concurred 

with Hoffman's analysis and conclusion (Panella, 2010, p. 5). Carol Mallory-Smith, PhD, 

professor in the Department of Agriculture at Oregon State University in the Willamette Valley, 

concluded that the "proposed restrictions [interim measure including a 4 mile isolation distance] 

will provide significant safeguards to protect Beta species seed producers while the EIS is being 

conducted" and that the risk of geneflow would be "extremely low." (Mallory-Smith, 2010, pp. 1-

2). 

3.9.7 Use of event H7-1 trait on male-sterile female 

Seed production companies use a hybrid seed production system in which the event H7-1 trait 

is on the female (male sterile plants) in a large proportion of commercial seed production fields. 

In the Willamette Valley at least two seed companies use this system exclusively (Anfinrud, 

2010, pp. 1-2; Lehner, 2010, pp. 5-6; Meier, 2010, p. 8). Essentially zero event H7-1 pollen is 

produced by these "female side" seed production fields. As a result of these methods, 78.6% of 

the currently growing GE sugar beet seed crop in the Willamette Valley is male-sterile female. 

Because these plants produce virtually zero pollen, they eliminate any realistic risk for 

unintentional spread of the GE trait. 

3.9.8 Red table beet offtypes 

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Seed companies growing sugar beets in the Willametle Valley occasionally find a very small 

percentage of off-types from red table beet crops. Seed companies have indicated a very low 

level of off-types in sugar beet crops, and one seed company reports that its latest "observation 

plots did not produce any off-types" (Lehner, 2010, p. 3). Customers (i.e., growers of 

commercial sugar beet root crops) have likewise indicated that after inspecting the millions of 

plants grown in variety trials conducted over several years, "the number of chard or red beet offtypes were so small as to be, for all intents and purposes, not quantifiable." (Grant, 2010, p.6; 

Berg, 2010, p. 5; Hofer, 2010, p.4). Seed companies regularly perform grow out tests to 

determine if there are any issues with off-types (Lehner, 2010, p.3; Hovland, 2010, pp. 2-3). 

Red table beet offtypes in sugar beet fields could occur due to nearby backyard gardeners 

growing red table beets, or might occur from open pollinated red table beet fields upwind from 

sugar beet fields. (Anfinrud, 2010, 109: 13-17). In an open pollinated field, every plant sheds 

pollen (Stander, 2010, p. 2). Thus an acre of open pollinated red table beets would produce far 

more pollen than an acre of hybrid sugar beet fields, where the only one-fourth to one-third of 

the plants produce pollen (Westgate, 2010, p. 5). The Willametle Valley Specialty Seed 

Association pinning guidelines and isolation distances require 4 mile isolation distances 

between open pollinated red beet and sugar beet fields, in order to limit red beet off types in 

sugar beet fields (Stander, 2010, p. 2). The potential for sugar beet gene transmission to open 

pollinated red beet fields is very low, because as indicated, a greater volume of pollen per acre 

are shed by the open pOllinated field (Westgate, 2010, p. 5) (indicating "billions" of pollen grains 

per square meter shed by an open pollinated red beet field).). 

3.9.9 No sensitivity to event H7 -1 by conventional sugar beet growers; Stewardship 

regarding mechanical mixing 

There is no indication of sensitivity by customers for conventional sugar beet seed to the 

possibility of an inadvertent presence of event H7-1 genetic material in the conventional seed 

(Pierson, 2010, p. 17). First, there is currently no market in the U.S. for organic sugar beets 

(Pierson, 2010, p. 17). Second, in most areas where both event H7-1 and conventional sugar 

beets are grown, both types of beets would be combined and processed together, with no effort 

to differentiate between sugar from H7-1 and conventional beets (Pierson, 2010, pp. 16-17). 

The sugar from conventional beets does not differ chemically or in any other way from the sugar 

from H7-1 beets (Hoffman, 2010, p. 16). 

As set forth in Section 2.7.3, each of the seed companies producing H7-1 seed utilizes detailed 

measures to address the possibility of mechanical mixing of H7-1 and conventional sugar beet 

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seed. These measures would be subject to audit under the interim measures to ensure that 

they continue to be utilized and are successful. 

Because seed production for red beet and chard seed crops is completely separate from sugar 

beet seed production, there is virtually no risk of mechanical mixing. As discussed in Section 

2.8, the two types of production employ different growers, different equipment and different 

facilties. Accordingly, there is no significant risk of mixing. 

3.9.10 Question of zero tolerance 

We have identified one organic seed producer who has chosen to produce organic chard seed 

(among several other organic crops) in the Willamette Valley. This organic producer has 

approximately one to three acres of production on the Western margin of the Valley. He has 

indicated that he faces a risk of genetic transfer from event H7-1 seed fields, and that he sells to 

customers for his organiC chard with zero tolerance for any level of outcrossing with event H7-

1. That producer has tested his chard seeds since 2007 with a PCR genetic test and found no 

indications of event H7-1 traits in his crops. To date, he has not lost sales due to a risk of cross 

pollination from Event H7-1. He reports that the costs of the peR testing for multiple years 

since 2007 have totaled roughly $700, and that a positive test for event H7-1 for his crop could 

negatively affect the reputation that producer has with his customers. That seed producer has 

also indicated in public statements through the media that he is not concerned about a risk of 

cross-pollination from event H7 -1 seed fields where the GE trait is on the female non-pollinator 

(Morton, 2009, 9: 12-19). A seed retailer who buys from that producer has reported that he has 

multiple sources for chard seed outside the Willamette Valley, including in California, but 

continues to purchase from that producer nevertheless. 

In addition, both that seed producer and the seed retailer have participated in the development 

of a consensus standard setting a threshold for the presence of GE traits in organic food 

products and in seed. The Non-GMO Project Working Standard, sponsored by leading players 

in the organic industry (including Whole Foods), specifically permits crops to be verified "nonGMO" despite the presence of a low level of biotech content-O.25% for GE sugar beet seed 

and other Beta seed crops (Non-GMO Project, 2010, pp. 25, 34) and 0.9% in organic food and 

feed. Section 2.4.3 of the Working Standard explains that its product content standards apply to 

the crops listed on Appendix B, plus "close relatives of these crops that are subject to cross 

pollination" (Non-GMO Project, 2010, p. 12). Appendix B specifically lists "sugar beets" as one 

of those crops "with GMO Risk" subject to the standard, and also expressly identifies "chard" 

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and "table beets" as close relatives for which cross-pollination is possible (Non-GMO Project, 

2010, p. 34). Section 2.6 explains that "[t]he Non-GMO Project has established" a 0.1% GMO 

content threshold for "seed and other propagation materials" for all crops listed in Appendix B, 

but the standards include a specific variance of 0.25% for sugar beet seeds and other crops 

identified (Non-GMO Project, 2010, pp. 14,34). This 0.25% level is thus the Working 

Standard's current threshold for "non-GMO" sugar beet seed and other Beta seed crops. 

Other commercial producers of sugar beet, red beet or chard seed in the Willamette Valley have 

all consented to and abide by the Willamette Valley Specialty Seed Association standards, 

discussed in Section 2.7 and Appendix A. 

3.9.11 Seed availability 

As discussed in Section 2.7, sugar beet variety development is competitive, technological, and 

expensive multi-year activity. Seed companies develop varieties with traits they expect growers 

to want, and the sugar beet companies seed selection committees chose the varieties they wish 

to grow. It is a market-driven process, where the grower cooperatives themselves determine 

what is available for planting. Every year, each sugar beet company has a number of varieties 

that growers may choose from. As the popularity of event H7-1 sugar beet among growers has 

grown, there have been fewer available conventional varieties and more event H7-1 varieties; 

however, conventional varieties have been available. There is no organic sugar beet seed 

production in the sugar beet seed production areas. 

Conventional and/or organic sugar beet seeds are available from some US seed suppliers 

(conventional), and from European seed companies (conventional and organic). 

(SESVaderHave, 2010; Millington Seed Company, 2010). KWS has some 250 varieties of 

sugar beet seeds available, including organic (KWS, Grain, 2008). Organic sugar beet is a 

noteworthy crop in the EU (Eurostat, 2010). Not all organic beets are processed into sugar; 

some are used to produce a syrup that is integrated into organic food preparations (Ceddia and 

Cerezo, 2008). 

3.9.12 Impact Summary 

Alternative 1 

Under Alternative 1, there would be no gene flow impacts to growers of organic or conventional 

Beta seed from the production of event H7-1 sugar beet seed. 

Alternative 2 

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Under Alternative 2, no or negligible impacts from event H7-1 seed production on growers of 

organic or conventional Beta seed are expected for the following reasons: 

• The large majority of red beet and chard seed crops are grown in different geographic 

areas than are Event H7-1 sugarbeets. 

• Even in the Willamelte Valley (where most sugarbeet seed crops and a limited acreage 

of other beta species seed crops are grown), there have been no reported impacts since 

H7-1 commercial seed production began in 2006, and with the proposed interim 

measures, the potential for impacts would be further reduced. 

• Based on 1) the use in the majority of the event H7-1 seed production of the trait on the 

male-sterile female; 2) results of sugar beet pollination outcrossing data in the published 

scientific literature; 3) site-specific modeling; 4) the relationship between expected seed 

purity levels and isolation distances determined by the OSCS; 5) the results of 

experience and testing in the Willamelte Valley seed production area since 2007 and, 6) 

the analysis and conclusions of qualified scientists who specifically addressed this issue, 

the 4-mile isolation distance (Interim measure Item 2) is expected to result in eliminating 

any significant risk that cross-pollination of organic or conventional red beet or chard 

crops will occur, and if it happens, make the rate of outcrossing very low if not 

undetectable --likely at rates of less than 1 in 10,000 (less than one seed in 10,000 with 

the event H7-1 trait). This is, for example, far less than the non-GMO Project proposed 

tolerance levels for sugar beet and other Beta seed (0.25%) (Non-GMO Project, 2010), 

• The use of hybrids with the event H7-1 trait on the female, in combination with the 

disclosure requirements regarding male fertile event H7-1 seed crops (Interim measure 

Item 3) will drastically reduce the potential for cross-pollination. For the large majority of 

H7-1 seed fields (with the trait on the female), there is essentially zero risk of crossing 

with a red beet or chard seed crop. For those fields with the H7 -1 gene on the male 

pollinator, the isolation distances will reduce any risk significantly, and producers of red 

beet and chard can ascertain what those distances are and take appropriate measures 

(to position their fields, scout for off-types, conduct genetic testing, or through other 

means discussed herein) if they are concerned about any level of risk. 

• The interim measure to prevent seed mixing (Interim measure Item 4), which makes 

current seed and steckling production and handling practices mandatory (described in 

Section 2), will make the potentially low level presence of event H7-1 in conventional 

sugar beet seed negligible and will eliminate adventitious presence of event H7-1 in 

other Beta seeds. 

Conventional sugar beet seed will continue to be available as long as growers continue to 

choose it in the variety trials. Growers who purchase seed purchase a specific variety, which is 

labeled as such. 

In addition, in the event unwanted transmission of H7-1 traits to a red beet or chard crop did 

occur, there are multiple means for a seed producer to address it. First, because a seed 

producer of red beet or chard growing beta species typically will inspect each plant remove any 

off-types from his production fields, any preexisting unwanted cross between a sugar beet and 

red beet or chard plant can be addressed before seed is produced with an unwanted trait 

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(Stander, 2010, pp. 3 - 4). Second, once seed is produced, a grower typically will perform growout tests on a sample of the seed to confirm that the seed is producing plants without undesired 

off-types. This can also identify any issues. Third, multiple types of genetic testing can be 

conducted to confirm the lack of any H7-1 trait (Hovland, 2010, pp. 2 - 3). While PCR testing is 

available with a very high level of sensitivity (to 0.01 %), inexpensive genetic strip tests capable 

of identifying H7-1 are also available for $2 to $4 per test, with a sensitivity of approximately 

0.1 % (Stander, 2010, pp. 4 - 5). Such testing may be utilized in a manner that employs 

samples from multiple seed plants and reduces the number of tests required per field. In the 

event of a positive test, the seed producer may use additional testing to isolate the source of the 

portion of his field producing that result (Id). Further, retailers of seed with sensitivity to H7-1 

content may also conduct grow out tests, or utilize the same genetic testing methods to address 

any concerns they may have (Id) 

As discussed in Section 3.17, in light of the above factors, the socioeconomic impacts on 

farmers growing red table beet and Swiss chard seed are negligible. 

3.10 LIVESTOCK PRODUCTION SYSTEMS 

The only impacts to livestock production systems would be related to animal feed, which is 

discussed in Section 3.11. 

3.11 FOOD AND FEED 

Both food (sugar and molasses derivatives) and animal feed (molasses and beet pulp) are 

derived from sugar beets. In this section we summarize the large body of scientific evidence 

that has been developed that supports the conclusion that food and feed derived from event H7-

1 sugar beets are as safe and healthy as food and feed derived from conventional sugar beets. 

While the evidence has largely been developed by Monsanto and/or KWS and the contract 

research organizations supported by Monsanto and/or KWS, it has been evaluated and peer 

reviewed by panels of government scientists from the US, Canada, the European Union (EU), 

Japan, Australia, New Zealand, Mexico, South Korea, the Russian Federation, China, 

Singapore, Colombia and the Philippines, all of whom have approved, or recommended for 

approval, the use of products from event H7-1 in their countries (FSANZ, 2005; Monsanto/KWS 

2007; Berg 2010). 

We begin with a summary of FDA's authority and policy under the federal Food, Drug and 

Cosmetic Act (FFDCA) with regard to ensuring the safety of food and feed derived from new 

plant varieties developed using rONA methods. We then document each element FDA 

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evaluated in its consultation process. Then we summarize the evaluations and conclusions of 

several other international scientific oversight groups. 

3.11.1 FDA authority and policy 

FDA policy statement. In 1992, the FDA issued a policy statement clarifying its interpretation 

of the FFDCA, regarding foods (including animal feed) derived from new plant varieties, 

including plants developed by the newer methods of genetic modification, including rONA. The 

purpose of the policy is "to ensure that relevant scientific, safety, and regulatory issues are 

resolved prior to the introduction of such products into the marketplace" (FDA, 1992). FDA is 

the "primary federal agency responsible for ensuring the safety of commercial food and food 

additives, except meat and poultry products" and "FDA has ample authority under the act's 

[FFDCA] safety provisions to regulate and ensure the safety of foods derived from new plant 

varieties, including plants developed by new techniques. This includes authority to require, 

where necessary, a premarket safety review by FDA prior to marketing of the food" (FDA, 

1992). Under section 402(a)(1) of the FFDCA, a food is adulterated and thus unlawful "if it 

bears or contains an added poisonous or deleterious sUbstance that may render the food 

injurious to health or a naturally occurring substance that is ordinarily injurious" (FDA, 1992). 

FDA has the authority to ensure safety of new foods. FDA considers its existing statutory 

authority under the FFDCA and its implementing regulations "to be fully adequate to ensure the 

safety of new food ingredients and foods derived from new varieties of plants, regardless of the 

process by which such foods and ingredients are produced" (FDA, 1992). "The existing tools 

provide this assurance because they impose a clear legal duty on producers to assure the 

safety of foods they offer to consumers; this legal duty is backed up by strong enforcement 

powers; and FDA has authority to require premarket review and approval in cases where such 

review is required to protect public health" (FDA, 1992). 

Developers have the responsibility to evaluate the safety of new foods. "It is the 

responsibility of the producer of a new food to evaluate the safety of the food and assure that 

the safety requirement of section 402(a)(1) of the act is met. FDA provides gUidance to the 

industry regarding prudent, scientific approaches to evaluating the safety of foods derived from 

new plant varieties, including the safety of the added substances that are subject to section 

402(a)(1) of the act. FDA encourages informal consultation between producers and FDA 

scientists to ensure that safety concerns are resolved" (FDA, 1992). 

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Foods developed by new methods do not present greater safety concerns. "FDA believes 

that the new techniques are extensions at the molecular level of traditional methods and will be 

used to achieve the same goals as pursued with traditional plant breeding. The agency is not 

aware of any information showing that foods derived by these new methods differ from other 

foods in any meaningful or uniform way, or that, as a class, foods developed by the new 

techniques present any different or greater safety concern than foods developed by traditional 

plant breeding" (FDA, 1992). 

FDA's goal is to ensure the safety of all food and feed. "The goal of the FDA's evaluation of 

information on new plant varieties provided by developers during the consultation process is to 

ensure that human food and animal feed safety issues or other regulatory issues (e.g. labeling) 

are resolved prior to commercial distribution" (FDA, 1997). 

3.11.2 FDA biotechnology consultation note to the file BNF 000090 

FDA makes the contents of its biotechnology notification files (BNFs) available on the internet 

(see reference FDA, 2004; event H7-1 is BNF 000090)35. FDA documented its conSUltation with 

Monsanto/KWS on event H7-1 in a note to the file dated August 7, 2004 (Bonette, 2004). That 

information is summarized below. 

Characterization, inheritance, and stability o/the introduced DNA 

Using standard analytical techniques, Monsanto/KWS verified that event H7-1 contained a 

single copy of the EPSPS cassette, and that all components were intact (Bonnette, 2004; 

Schneider, 2003, p. 43). 

Monsanto/KWS conducted crosses using conventional breeding techniques resulting in 27 

breeding experiments over four generations. These studies indicate that the introduced trait 

(glyphosate tolerance) was stably inherited as a dominant trait (Bonette, 2004; Schneider, 2003, 

p.44). 

Using standard analytical techniques, Monsanto/KWS demonstrated the stable integration of the 

T-DNA over three generations (Bonette, 2004; Schneider, 2003, p. 47). 

Introduced substance - CP4 EPSPS enzyme 

As discussed in Section 3.1.1, EPSPS is a catalyst for a reaction necessary for the production 

of certain aromatic amino acids essential for plant growth and has a similar function in bacteria 

35 http://www. accessdata. fda. gov/scripts/fcn/fcn DetaiiNavigation. cfm?rpt=bioListing &id= 19 

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and fungi (for example, baker's yeast). While EPSPS is present in plants, bacteria and fungi, it 

is not present in animals; animals do not make their own aromatic amino acids, but rather obtain 

them from the foods they consume. Thus, EPSPS is normally present in food and feeds derived 

from plant and microbial sources (Harrison et ai, 1996). There are variations in the genetic 

makeup (amino acid sequences) of EPSPS among different plants and bacteria. The EPSPS 

from Agrobacterium sp. strain CP4 is just one variant of EPSPS. A unique characteristic of the 

CP4 EPSPS is that, unlike EPSPS enzymes commonly found in plants, it retains its catalytic 

activity in the presence of glyphosate (Bonnette, 2004; Schneider, 2003, pp 50-51; Padgette et 

ai, 1995). 

Concentrations in sugar beet. In 1999, field trials were conducted at six distinct field locations 

distributed across Europe in the major sugar beet production areas. The event H7-1 sugar 

beets were treated with a Roundup agricultural herbicide. Samples of brei (root tissue 

processed using standard sugar beet industry methods) and top (leaf) tissues were collected 

and analyzed for levels of the CP4 EPSPS protein. On average, concentrations of the CP4 

EPSPS protein, on a fresh weight basis, were similar in the leaf tissue (161 [1g/g) and in the root 

tissue (181 [1g/g). The range of mean levels of the CP4 EPSPS protein in top (leaf) tissue was 

112 to 201 [1g/g and in root (brei) were 145 to 202 [1g/g across the sites (Schneider, 2003). 

Toxicity of CP4 EPSPS. Studies were conducted on mice, using CP4 EPSPS doses of 400, 

100 and 40 milligrams (mg) of CP4 EPSPS per kilogram of body weight per day (mg/kg body wt 

-d). For a typical 0.03-kg mouse, the 400 mglkg body wtld dose equated to 12 mg CP4 EPSPS 

per mouse per day. The study was designed to reflect a 1 ,ODD-fold factor of safety on the 

highest possible human exposure to CP4-EPSPS, based on assumed exposures to soybean, 

potato, tomato and corn at the time the study was done (Harrison et ai, 1996)36. The daily CP4 

EPSPS content in the maximum mouse exposure was equivalent to the amount in 

approximately 160 pounds of H7-1 sugar beets. No treatment-related adverse effects were 

observed, and there were no significant difference in any measured endpoints between the CP4 

EPSPS treated mice and the control group (Harrison, et ai, 1996, p. 735). 

Monsanto/KWS also compared the amino acid sequence of CP4 EPSPS to protein sequences 

in the public domain ALLPEPTIDES database using the FASTA algorithm, and reported no 

biologically relevant sequence similarities between CP4 EPSPS protein and known protein 

36 Note that this was a theoretical exercise as no glyphosate tolerant potatoes or tomatoes are commercially grown. 

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toxins were observed (Bonnette, 2004). A peptide is a molecule consisting of several linked 

amino acids (GMO Safety, 201 Oa). 

Allergenicity. Allergens can be derived from many sources: in animal hair, pollen, insect bites, 

dust mites, plants, pharmaceuticals, and food. Approximately 20,000 allergens have been 

identified. Most allergens in food are high molecular weight proteins and are rather resistant to 

gastric acid and digestive enzymes (GMO Safety, 201 Oa). 

Monsanto/KWS searched a comprehensive database of allergens (Hileman et ai, 2002) 

containing sequences of known allergens, for amino acid homology to the CP4-EPSPS protein, 

and concluded that there was no immunologically significant amino acid sequence homology 

between the CP4 EPSPS protein and amino acid sequences of allergens in the database 

(Bonnette, 2004). 

Monsanto/KWS discussed two studies relevant to the mammalian digestibility of CP4 EPSPS. 

In the first study, the CP4 EPSPS protein was exposed to simulated gastric (stomach) and 

intestinal fluids that were prepared according to the US Pharmacopoeia (1990). The half-life of 

the CP4 EPSPS protein was reported to be less than 15 seconds in the gastric fluid, greatly 

minimizing any potential for the protein to be absorbed in the intestine. The half-life was less 

than ten minutes in the simulated intestinal fluid (Harrison et ai, 1996, p 738). The second study 

reported similar results (Bonnette, 2004). 

Food andjeed llses ojsllgar beet 

The main food use of sugar beet is for the extraction of sucrose from sugar beet roots through a 

process involving hot water extraction, followed by purification, evaporation, and centrifuge 

separation of sucrose crystals (granular sugar). Refined sucrose does not contain protein or 

other genetic material. This process also yields sugar beet molasses and sugar beet pulp, 

which are often pelleted and used in animal feed. The leafy sugar beet "tops" are usually left in 

the field, but they may occasionally be fed to ruminant animals (Bonnette, 2004). 

Compositional analysis 

To assess whether sugar beet event H7-1 is as safe and nutritious as conventional sugar beet 

varieties, Monsanto/KWS compared the composition of the hybrid lines containing event H7-1, 

produced through conventional breeding, to the composition of the corresponding nontransgenic, control. Tops (leaves) and brei (processed roots) were analyzed using standard 

methods or other suitable methods (Bonnette, 2004). 

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These analyses included proximate values (crude ash, crude fiber, crude fat, crude protein and 

dry matter), carbohydrates, quality parameters, saponins (naturally-occurring antinutrients that 

have a bitter taste and can act as a deterrent to foraging), and eighteen amino acids. Quality 

parameters measured in root samples included percent sucrose, invert sugar, sodium, 

potassium and alpha-amino nitrogen. All analyses were conducted as a single analysis for the 

root (brei) and top (leaf) samples collected as three replica samples from each of five field trials 

sited. Fifty-five statistical comparisons were made with the control line, of which seven were 

found to be statistically different (p<0.05). Based on the statistical methods, three of these 

seven would have been expected based on chance. In all seven cases, the ranges for the 

statistically different components in event H7-1 significantly overlapped or fell completely within 

the range of values observed for the control, the conventional reference varieties and for 

available published values from conventional sugar beet varieties (Schneider, 2003, Section C). 

COl/clusion 

Based on the data submitted, the FDA considered the consultation process to be complete, and 

acknowledged this in a note to the file and a letter to Monsanto (Bonnette, 2004; Tarantino, 

2004). 

3.11.3 Health Canada approval 2005 

Health Canada's Food Directorate has legislated responsibility for premarket assessment of 

"novel foods." Under Canadian regulations, sugar derived from event H7-1 sugar beet is a 

novel food because it is derived from a plant that has been genetically modified to exhibit 

characteristics that were not previously observed in the plant (Health Canada, 2005). 

Health Canada "conducted a comprehensive assessment of this sugar beet according to its 

Guidelines for the Safety Assessment of Novel Foods," reviewing the same information 

Monsanto/KWS provided to FDA in its consultation, and made the following conclusion (Health 

Canada, 2005: 

Health Canada's review of the information presented in support of the food use of sugar 

from glyphosate tolerant sugar beet lines containing event H7-1 concluded that the food 

use of sugar from sugar beet lines containing this event does not raise concerns related to 

safety. Health Canada is of the opinion that sugar from sugar beet lines containing event 

H7 -1 is as safe and nutritious as sugar from current commercial sugar beet varieties. 

3.11.4 Canadian Food Inspection Agency (CFIA) approval 2005 

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The CFIA evaluated event H7-1 both as a crop to be potentially grown in Canada, and as 

livestock feed, and approved both uses in 2005. Based its evaluation of data provided by 

Monsanto/KWS, and as summarized in its Decision Document 002005-54, the CFIA 

"determined that this plant with a novel trait (PNT) and novel feed does not present altered 

environmental risk nor does it present livestock feed safety concerns when compared to 

currently commercialized sugar beet varieties in Canada" (CFIA, 2005). 

3.11.5 EFSA risk assessment and EC authorization 

The European Food Safety Authority (EFSA) is an independent European agency funded by the 

EU budget for the purpose of assessing risks associated with the food chain. Risk assessment 

is a specialized field of applied science that involves reviewing scientific data and studies to 

evaluate risks associated with certain hazards (EFSA 2010). EFSA conducts risk assessment, 

but does not have authority to authorize use. The European Commission (EC), which is the 

executive body of the EU, determines whether or not a genetically modified item will be 

authorized for use in the EU. 

Scope and process. The scope of the Monsanto/KWS application to the EFSA was for food 

and feed, and not as a crop intended for cultivation in the EU (EFSA, 2006, p. 1). The EFSA 

used the same data Monsanto/KWS provided to the FDA, Health Canada, and the CFIA, and 

also requested additional information. The Scientific Panel on Genetically Modified Organisms 

(GMO Panel) developed an opinion that was then adopted by the EFSA. Subsequently, in 

2007, the EC authorized "the placing on the market of food and feed produced from genetically 

modified sugar beet H7-1" (EC, 2007). During the EFSA risk assessment process, Member 

states comment on the draft decisions and can request further analysis; the GMO Panel also 

can request additional information from the applicant. 

Detectable presence of CP4 EPSPS. The GMO Panel reported that if the CP4 EPSPS protein 

was present in the sugar, which was unlikely, it was below the detection limit of 0.004 parts per 

million (ppm). No DNA was detected in the sugar and the molasses is also "free from DNA and 

protein (limit of detection 0.002 ppm)." The CP4 EPSPS protein is present in pulp at levels 

around 500 ppm on a dry weight basis (EFSA, 2006, p. 9). 

Safety of the CP4 EPSPS protein. The GMO Panel noted the "long history of dietary exposure 

to EPSPS proteins" for humans and animals the fact that "previous applications for glyphosate 

tolerant crops containing the CP4 EPSPS protein have been evaluated and found to be safe for 

human andlor animal consumption in previous [EFSA] opinions." The GMO Panel concluded 

that "a toxicological assessment of new constituents is not applicable" (EFSA, 2006, P 10). 

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Additional toxicity study. In response to EFSA information requests, Monsanto/KWs 

conducted a gO-day toxicity study, feeding processed pulp to rats, which did not indicate any 

adverse effects. The GMO Panel reported additional studies of sugar beet pulp to sheep, also 

with no adverse effects (EFSA, 2006)37. 

Allergenicity. In addition to evaluating the potential allergenicity of the CP4 EPSPS protein, 

the GMO Panel considered whether the insertion of the transgene could result in modifications 

of the pattern of expression of other potentially allergenic proteins within the sugar beet plant. 

The Panel did not consider the issue to be relevant, as sugar beet is not a major allergenic food, 

and overexpression of an existing protein "would be unlikely to alter the overall allergenicity of 

the whole plant (EFSA, 2006, p. 12).38 

No need for post-market monitoring. The GMO Panel noted "No risks to human and animal 

health were identified in studies of the CP4 EPSPS protein expressed in sugar beet H7-1, and 

in studies of the genetically modified sugar beet itself. Thus, foods and feeds produced from 

sugar beet H7 -1 is as safe and nutritious as foods and feeds derived from conventional sugar 

beets." The Panel recommended no post-market monitoring (EFSA, 2006, p. 13). 

Conclusions. The GMO Panel stated the following in its conclusions (EFSA, 2006, p. 13): 

• Sugar and molasses have been shown to be free from DNA and protein 

• Animals fed with pulp will be exposed to the CP4 EPSPS protein 

• The CP4 EPSPS protein has been evaluated and found to be safe for human and/or 

animal consumption 

• The molecular characterization and the comparative compositional analysis did not 

indicate the occurrence of any unintended effects due to the genetic modification 

• Products from sugar beet H7-1 are safe as food and feed 

• The nutritional value of the sugar beet H7-1 and the derived sugar beet products is 

comparable to that of the analogous products from conventional sugar beet 

• The risk of allergenicity is of no concern with this product 

3.11.6 Other approvals 

Japan approved the use of event H7-1 in feed 2003, in food in 2005, and the environmental in 

2007 (Sato, 2008). Studies by the Japanese National Food Research Institute have confirmed 

that there is no detectable DNA in sugar from sugar beets, with the conclusions that "sugar beet 

37 http://jas.fass.orqlcqilcontenUfuIl183121400 

38 http://jas. fass. orqlcgilcontenUfull183/21400 

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DNA was degraded at an early stage of sugar processing" (Oguchi et ai, 2009). Event H7-1 has 

also been approved for food and feed use in Mexico, South Korea, Australia, New Zealand, 

China, Colombia, the Russian Federation, Singapore and the Philippines (FSANZ, 2005; 

Monsanto/KWS 2007; Berg 2010). 

3.11.7 Willingness of the buyer to accept sugar from event H7-1 

Market concerns about willingness of buyers to accept sugar, molasses, and/or pulp derived 

from event H7-1 have not resulted in any perceptible change in the demand for US-produced 

beet sugar or other fractions. Based on the regulatory approvals obtained in domestic and 

international markets, sugar, molasses, and pulp derived from event H7-1 is being successfully 

marketed. 

As summarized above, there is a large body of scientific evidence that has been reviewed and 

validated by several international scientific panels that supports the safety of the sugar and 

other fractions derived from event H7-1 for food and feed use. If there are consumers who do 

not wish to purchase sugar made from event H7-1 for reasons other than safety and health, 

they have the option of buying sugar made from sugarcane, which is not currently produced 

using lines that were developed using modern biotechnology. However, the majority of food 

products containing beet sugar, such as cakes, candy, ice cream and other sweets, are likely to 

contain sugar derived from sugar beet varieties containing event H7-1. Most commercial food 

and beverage products are also likely to contain corn or soy products derived from biotech 

crops (Goldsbrough, 2000). 

3.11.8 Impacts 

Based on the scientific evidence summarized in this section, impacts on food and feed are not 

expected with either alternative. Food and feed derived from event H7-1 is equivalent to food 

and feed derived from conventional sugar beets. Because both conventional and event H7-1 

sugar beets are processed in the same facilities, there is no distinction in the US between food 

and feed derived from conventional and event H7-1 sugar beets. Markets are available for all 

the food and feed produced. Because there is no commercial organic sugar beet industry in the 

US, organic sugar beet production is not impacted in any way. 

Aside from sugar, the other products from sugar beets (molasses and pulp) are not major 

consumer items and can easily be avoided by consumers who do not wish to be exposed to GE 

products. As discussed above, there is no detectable DNA in processed sugar; however, 

consumers who wish to avoid all products derived from GE crops can purchase cane sugar 

rather than beet sugar. While processed foods, the situation is similar to that for corn and soy 

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products: even without event H7-1, it would be very difficult for a consumer to avoid products 

derived from GE crops. 

3.12 WEED CONTROL AND GL YPHOSATE RESISTANCE 

As indicted in Section 1, EPA is responsible for regulation of glyphosate and thus for issues of 

weed resistance to glyphosate (EPA, 2003) .. This report nevertheless analyzes those issues. 

APHIS's 2005 EA did so as well, and the court did not find a deficiency in that analysis. APHIS 

has performed other herbicide resistance analyses in many E As conducted as part of the 

petition review process (see http://www.aphis.usda.gov/biotechnology/not_reg.html). 

3.12.1 Herbicide-resistant weeds 

As explained in Section 2.5, not all weed species respond the same to every herbicide mode of 

action. Instead, a weed species can have a natural resistance to a particular mode of action, 

and if a grower employs only that mode of action, over time, the naturally resistant species will 

overtake other weed species in that area. This is often referred to as a shift in the weed 

population. It is for this reason that growers may need to use multiple products to control the full 

spectrum of weeds in a field. 

Sugar beet weed management, including major weeds in sugar beets, herbicides used, 

herbicide mode of action and herbicide resistance, was discussed in Section 2.4. Table 3-1 

summarizes the major sugar beet weeds in terms of resistance to herbicide groups used in 

sugar beets for the states where sugar beets are grown commercially. A weed is listed for a 

state when herbicide resistance has been confirmed. The table does not show the extent of the 

weeds with the noted resistance; this would vary widely. References for the table are included 

at the bottom of the table. 

As of June 27, 2010, 194 herbicide-resistant weed species (341 herbicide resistant weed 

biotypes) have been documented worldwide (Heap, 2010). These species have been reported 

to be resistant to 19 different herbicide modes of action (Heap, 2010). Approximately five 

Table 3-1 Major sugar beet weeds with resistance to herbicides groups used in 

sugar beets 1 

California 

Species 

I. Echinochloa crus-galli 

2. Echil1ochloa crus-galli 

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Common Name 

Bamyardgrass 

Bamyardgrass 

Year' 

1000 

2000 

116 

Herbicide Mode of Action 

ACCase inhibitor 

fatty acid synthesis inhibitor. 

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Colorado 

SRecies 

1. Aramanthus retroflexus 

2. Kochia scoparia 

3. Kochia scoparia 

4. Avena/alllG 

Idaho 

SRecies 

1. Kochia scopal'ia 

2. Avena/a/lIG 

3. Avenafatua 

4. Kochia scoparia 

5. Aramantus retrofleXlls 

Michigan 

SRecies 

1. Chenopodium album 

2. Amaral1thlls tubercula/us 

3. Amaranthus powe/lis 

4. Amaranthus powel/is 

5. Amarantl1lls retroflexlIs 

6. Chenopodium a/bl{111 

7. A l11arclI1thus hybridlls 

8. Abutilol7 theophrasti 

9. Solanum ptycanthul1l 

10. Sola17l111l ptycanthul1l 

11. Kochia scoparia 

12. Setaria/aberi 

Minnesota 

SRecies 

I. Chenopodium album 

2. Abutilon Iheop!Jrasli 

3. Amal'anthus retroflexlis 

4. Avena/alua 

5. Amaranthus tuburculatus 

6. Ambrosia trifida 

7. Kochia scoparia 

8. Xallthium strllll1arilll1l 

7. Setaria/aberi 

9. Setaria viridis 

10. Setaria Illtescens 

11. Ambrosia trifida 

12. Amal'al1thus tuberclI/atlls 

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Common Name Year2 

Redroot pigweed 1982 

Kochia 1982 

Kochia 1989 

Wild Oat 1997 

Common Name Year2 

Kochia 1989 

Wild Oat 1992 

Wild Oat 1993 

Kochia 1997 

Redroot pigweed 2005 

Common Name Year2 

Larnbsquarters 1975 

Tall waterhemp 2000 

Powell Amaranth 2001 

PO\""elI Amaranth 2001 

Redroot Pigweed 2001 

Lambsquarters 2001 

Smooth Pigweed 2002 

Velvetleaf 2004 

East. Black nightshade 2004 

East. Black nightshade 2004 

Kochia 2005 

Giant Foxtail 2006 

Common Name Year" 

Lambsquarters 1982 

Velvetleaf 1991 

Redroot Pigweed 1991 

Wild Oat 1991 

Tall Waterhemp 2007 

Giant ragweed 2006 

Kochia 1994 

Common cocklebur 1994 

Giant Foxtail 1996 

Robust White Foxtail 1996 

(var. robusta·alba Schreiber) 

Yellow Foxtail 1997 

Giant ragweed 

Tall waterhemp 

2006 

2007 

117 

Herbicide Mode of Action 

photosystems II inhibitors 

photosystems II inhibitors 

ALS inhibitors 

ACCase inhibitors 

Herbicide Mode of Action 

ALS inhibitors 

ACCase inhibitors 

fatty acid synthesis inhibitor. 

synthetic auxins 

photosysterns II inhibitors 

Herbicide Mode of Action 

photosystems II inhibitors. 

ALS inhibitors 

photosystem II inhibitors 

ureas and amides 

photosystems II inhibitors. 

ALS inhibitors 

ALS inhibitors 

photosystems II inhibitors 

photosystems II inhibitors 

photosystems II inhibitors. 

ALS inhibitors 

ALS inhibitors 

Herbicide Mode of Action 

photosystems II inhibitors. (PI) 

PI 

PI 

ACCase inhibitors 

glycine. ALS. PI 

glycine. ALS inhibitors. PI 

ALS inhibitors 

ALS inhibitors 

ALS inhibitors 

ALS inhibitors 

ALS inhibitors 

glycines 

glycines 

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Montana 

SQecies 

1. Kochia scoparia 

2. Kochia scoparia 

3. Avena/alaG 

4. AvenafatuG 

5. Kochia scoparia 

6. Avena/alau 

7. Avena/alllG 

Nebraska 

SQecies 

1. Amaranthus Ilfberculalus 

North Dakota 

SQecies 

1. Kochia scoparia 

2. Setaria viridis 

3. Avena/allio 

4. Kochia scoparia 

5. Avenafatua 

6. Kochta scoparia 

7. Amarantl11ls retrojlexIIs 

8. Solanum plycunlhllm 

Oregon 

SQecies 

1. Avena/alua 

2. Avena/ailla 

3. Kochia scoparia 

4. Amaranthus retroflexus 

Washington 

SQecies 

1. Kochia scoparia 

2. Avena /alZia 

3. Amaranthlfs polt'ellis 

4. Sonchus ajper 

Wyoming 

SQecies 

1. Kochia scoparia 

2. Kochia scoparia 

Legend: 

Common Name 

Kochia 

Kochia 

Wild Oat 

Wild Oat 

Kochia 

Wild Oat 

Wild Oat 

Common Name 

Tall waterhemp 

Common Name 

Kochia 

Green Foxtail 

Wild Oat 

Kochia 

Wild Oat 

Kochia 

Redroot Pigweed 

Eastern Blk.Nightshade 

Common Name 

Wild Oat 

Wild Oat 

Kochia 

Redroot Pigweed 

Common Name 

Kochia 

Wild Oat 

Powell Amaranth 

Spiny Sowthistle 

Common Name 

Kochia 

Kochia 

Year2 

1984 

1989 

1990 

1990 

1995 

1996 

2002 

Year2 

1996 

Year2 

1987 

1989 

1991 

1995 

1996 

1998 

1999 

1999 

Year2 

1190 

1990 

1993 

1994 

Year2 

1989 

1991 

1992 

2000 

1984 

1996 

Herbicide Mode of Action 

photosystems II inhibitors 

ALS inhibitors 

fatty acid synthesis inhibitor. 

ACCase inhibitors 

synthetic auxins 

ALS inhibitors 

ACCase inhibitors 

Herbicide Mode of Action 

photosystem II inhibitors 

Herbicide Mode of Action 

ALS inhibitors 

mitois inhibitors 

ACCase inhibitors 

synthetic auxins 

ALS inhibitors 

photosystems II inhibitors 

ALS inhibitors 

ALS inhibitors 

Herbicide Mode of Action 

ACCase inhibitors 

mitosis inhibitors 

ALS inhibitors 

photosystems If inhibitors. 

Herbicide Mode of Action 

ALS inhibitors 

ACCase inhibitors 

photosystem II inhibitors 

ALS inhibitors 

Herbicide Mode of Action 

photosystems 11 inhibitors 

ALS inhibitors 

Source: Heap, I. The International Survey of Herbicide-resistant Weeds. Online. Internet. Accessed on June 

21,2010 at: wVI/w.weedscience.com. 

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2 Year resistance was ftrst reported. 

percent of resistant species have resistance to EPSPS inhibitors (glycines, which include 

glyphosate). Refer to Figure 2-3 for the distribution by herbicide mode of action. 

Measures to reduce the development of herbicide resistance are discussed in Section 2.5. 

3.12.2 Glyphosate-resistant weeds 

As discussed in Section 2.5, herbicide resistance is not a unique or new phenomenon. The 

development of weeds resistant to a particular herbicide mode of action is an issue that growers 

have faced for decades. As with other herbicide modes of action, not all weeds respond the 

same to glyphosate, and some species naturally vary in their tolerance to the herbicide. 

Because of the nature of glyphosate and its high degree of specificity, generally speaking, there 

is a reduced potential that there will be a selection for weed resistance. Glyphosate is a 

nonselective, foliar-applied, broad spectrum, post-emergent herbicide compared to many other 

herbicide groups. It operates by binding to a specific enzyme in plants thereby interfering with 

the plant's required metabolic process. Glyphosate is the only herbicide that binds with this 

enzyme, and therefore it is highly specific (Cole, 201 Oa, p5). 

Currently in the U.S., there are two known mechanisms of glyphosate resistance. The first is 

the exclusion mechanism in which glyphosate is either prevented from moving to growing cells 

or from reaching the target protein. Mechanisms that confer this form of resistance are 

relatively rare and are not common across plant species. The second mechanism, gene 

amplification, results from an increase in enzyme gene copies in the plant which leads to higher 

levels of resistance to glyphosate (Cole, 201 Oa, p.5). 

Accordingly, while glyphosate has been used extensively for over three decades, there have 

been relatively few cases of resistance development, as compared to many other herbicides 

and when considering the substantial glyphosate-treated acreage worldwide (approximately 1 

billion acres) and the total number of weeds that the herbicide can control. In the U.S., there 

are ten weed species where glyphosate-resistant biotypes are known to exist in certain areas of 

the country (19 weeds have been reported to have developed glyphosate resistance at some 

location worldwide). These resistant weeds represent a relatively small minority of the overall 

weed population. For example, in 2009, approximately 135 million of the 173 acres of corn, 

soybeans and cotton in the U.S. were planted with a herbicide tolerant variety, with the most 

common tolerance trait being glyphosate tolerance (USDA NASS, 2009a). At the same time, 

only about 6% of the total planted corn, soybean and cotton acres in the U.S. are estimated to 

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have some level of presence of weeds resistant to glyphosate (Ian Heap as reported by WSSA, 

2010). 

A weed scientist from the University of Wyoming who specializes in sugar beet weed control, 

has testified that in the coming years, "it is highly unlikely that the use of glyphosate in 

connection with GR [glyphosate resistant] sugar beet will result in the same conditions that have 

led to GR weeds in otherGR crops" (Kniss, 2010, p. 3). This is in part because of the 

fundamentally different growing practices with sugar beet. Kniss reports that more diverse 

cropping systems (with more rotations and herbicide modes of action), such as those used with 

sugar beets "are less likely to result in weed resistance issues" (Kniss, 2010, p. 3). 

Approximately half of the GR weeds noted worldwide to date have been found in non-GR 

cropping systems (such as orchards). In the U.S., of the confirmed GR weeds, two evolved 

where there was no GR crop use (roadsides, vineyards, and tree crops) (Kniss, 2010a, p. 2). 

GR sugar beet production systems are different than other GR crops, in part because multiple 

year crop rotations are an integral component of effect weed and pest management programs 

for the sugar beet crop in all sugar beet growing regions (Kniss, 2010a, p. 3). Given that the 

sugar beet crop is susceptible to many diseases, nematodes, and insects, multiple crop rotation 

is required to limit the economic impact of those pests. As such, sugar beet production grower 

agreements with sugar processers will typically prohibit growers from planting a sugar beet crop 

in consecutive years (Kniss, 201 Oa, p. 3). 

Instead, sugar beets are generally grown on a three- to four-year rotation. While other GR 

crops may be included in the rotation with GR sugar beets (with the exact rotation varying in 

different sugar beet growing regions) (Table 2-2), "the crop rotation in itself will reduce the 

potential for herbicide resistant weed development due to changing cultural practices between 

crops (such as planting date, harvest date, tillage practices, etc.)" (Kniss, 2010, p. 4). 

As discussed above, the characteristics of glyphosate itself reduce the potential for the 

development of herbicide resistance as compared to other herbicide families. As such, certain 

herbicide families have been classified according to their risk of resistant weed development. 

Beckie (2006) lists acetolactate synthase (ALS) and acetyl CoA carboxylase (ACCase) inhibiting 

herbicides as "High" risk for resistance development, while glyphosate is considered a "Low" 

risk herbicide for the development of herbicide resistant weeds. ALS and ACCase inhibiting 

herbicides are commonly used in conventional sugar beet production, and weeds resistant to 

these two herbicide groups are widely distributed across sugar beet growing regions of the U.S. 

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(Kniss, 201 Oa, p4) (Figure 2-4). Glyphosate tolerant sugar beets can help delay resistance to 

these herbicides (Kniss, 2010, pp. 4 - 5): 

In fact, glyphosate resistant sugar beet adds to the diversity of herbicide modes of action in 

many sugar beet crop rotations because it introduces a new mode of action (glyphosate) 

into the rotation with non-glyphosate-resistant crops, that tend to rely heavily upon 

acetolactate synthase ("ALS") inhibitors. ALS inhibiting herbicides pose a far greater risk 

of developing weed resistance than does glyphosate. By adding glyphosate to their crop 

rotations, growers of GR sugar beet actually decrease the likelihood of developing 

resistance to ALS inhibitors, just as the use of other crops and alternative modes of action 

in rotation with GR sugar beet reduce the likelihood of glyphosate resistant weeds. 

Use of herbicides with different modes of action, either concurrently or sequentially, is an 

important defense against weed resistance (Weed Science Society of American [WSSA], 

2010b). "Use of a single product or mode of action for weed management is not sustainable. 

Some of the best and most sustainable approaches to prevent resistance include diversified 

weed management practices, rotation of modes of action and especially the use of multiple 

product ingredients with differing modes of action" (WSSA, 2010). 

The WSSA reports higher levels of awareness among growers regarding the need to minimize 

the potential for development of glyphosate resistance: "In a market research study that 

surveyed 350 growers in 2005 and again in 2009, in response to the question, 'are you doing 

anything to proactively minimize the potential for resistance to glyphosate to develop,' 67% said 

yes in 2005 and 87% said yes in 2009" (David Shaw, as reported in WSSA, 2010). "In a 2007 

survey of 400 corn, soybean and cotton growers, resistance management programs were often 

or always used by 70% or more of all three grower groups" (Frisvold and Hurley as reported by 

WSSA, 2010). There is widespread information available from universities and other sources 

regarding glyphosate resistance. Public universities (i.e. North Dakota State University, 

University of Minnesota), herbicide manufacturers ( i.e. www.weedresistancemanagement.com. 

www.resistancefighter.com) and crop commodity groups (i.e. National Corn Growers 

Association, American Soybean Association) have internet web sites with information on 

prevention and management of herbicide resistance. An example of information provided by 

public universities is Dr. Don Morishita, a weed scientist at the University of Idaho, who advises 

sugar beet growers on weed resistance management strategies (Dumas, 2008). The Sugar 

Industry Biotech Council provides weed resistance resources on its website. Monsanto includes 

information on weed resistance management practices in its Technology Use Guide that is 

mailed annually to all licensed growers. The sugar beet industry associations also hold annual 

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meetings where weed resistance management practices and other stewardship measures are 

included as part of the proceedings. 

Sugar beet growers in particular have strong financial and practical interests in managing weeds 

effectively to reduce the development of herbicide resistance in order to maximize yield 

potential. Sugar beets are a high-value crop, and competition from weeds for moisture and light 

can negatively impact yields and the overall value of the crop. The development of glyphosateresistant weeds harms the economic return per acre for the individual farmer and the entire 

sugar beet industry (Cole, 2010a, p11). 

As such, strategies and recommendations to delay the development of glyphosate-resistant 

weeds have been developed for event H7-1 sugar beets (TUG, Appendix E). Specifically, the 

TUG recommends the use of "mechanical weed control/cultivation and/or residual herbicides" 

with event H7-1 sugar beets, where appropriate, and "additional herbicide modes of 

action/residual herbicides and/or mechanical weed control in other Roundup Ready® crops" 

rotated with event H7-1 (TUG, 2010, p. 40). In addition to the financial incentive to follow these 

recommendations, all Roundup Ready technology users, including sugar beet growers, are 

contractually obligated through the Monsanto Technology Stewardship Agreement to follow the 

TUG. 

3.12.3 Impact summary 

Alternative 1 

Under Alternative 1, there would be no effect of event H7-1 on the potential for weeds to 

develop resistance to glyphosate, given that glyphosate use is minimal with conventional sugar 

beets. Growers would continue to use conventional weed control methods, including other 

herbicide modes of action, to the extent such conventional herbicides are available (see Section 

2.5). A return to conventional herbicides could have consequences for development of further 

resistance to those herbicides. 

As discussed above, glyphosate use in GR sugar beet has proven to be an effective tool against 

weeds resistant to non-glyphosate herbicides, such as ALS-inhibitors and ACCase-inhibitors. If 

the planting of H7-1 sugar beets is substantially curtailed, a valuable tool for herbicide resistant 

weed management will be unavailable to sugar beet growers, and the impact of weeds resistant 

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to other herbicides may increase, although the impact would likely be small since sugar beets 

are a relatively small crop (Kniss, 201 Oa, p. 7). 

Alternative 2 

Under Alternative 2, impacts, if any, with respect to the development of glyphosate-tolerant 

weeds in sugar beet crops in the timeframe considered in this ER are expected to be very small. 

First, sugar beets are a relatively small crop, (event H7-1 accounts for less than one percent of 

the glyphosate-resistant crops grown in the US), suggesting that the likelihood for the 

development of new glyphosate-resistant weed populations when compared to other herbicide 

resistant crops is smaller. Second, as discussed above, the nature of glyphosate itself and the 

growing practices for sugar beets makes it less likely that new glyphosate-resistant weed 

populations will develop in sugar beets as a result of the use of glyphosate in sugar beets. 

Additionally, there is a high level of awareness about the potential for glyphosate resistant 

weeds and many readily available resources to assist growers with management strategies. 

Indeed, event H7-1 growers are required to follow Monsanto's TUG, including its 

recommendations for adopting growing practices aimed at reducing the development of 

glyphosate-resistant weed populations. Finally, because herbicide resistance is a heritable trait, 

it takes multiple growing seasons for herbicide tolerant weeds to emerge and become the 

predominant biotype in a specific area (Cole, 201 Oa, p. 4). Researchers have concluded that 

even if growers completely relied on only one herbicide, it is likely to take at least five years for a 

herbicide-resistant weed population to develop (Kniss, 2010a, p4; Beckie 2006, Neve, 2008; 

Werth et aI., 2008). This is a reason why crop monitoring and follow up by University and 

industry weed scientist in cases of suspected resistance are important parts of all herbicide 

resistance stewardship programs. 

3.13 PHYSICAL 

3.13.1 Land Use 

As discussed in Section 2.3, acreage planted in sugar beets in the US has changed little over 

the past 50 years (since 1961), ranging from a low of 1.1 million acres in 1982 (slightly less than 

the 2008 acreage) to a high of 1.6 million acres in 1975. Table 3-2 shows planted sugar beet 

acreage for the last six years. While there have been changes within individual states, overall 

the range is small. As discussed in Section 2, a small part of the sugar beet crop was event 

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Table 3-2 Sugar Beet Acres Planted 2005 to 2010 

Location 2005 2006 2007 2008 2009 2010 

California 44,400 43,300 40,000 26,000 25,300 25,000 

Colorado 36,400 42,100 32,000 33,800 35,100 29,800 

Idaho 169,000 188,000 169,000 131,000 164,000 169,000 

Michigan 154,000 155,000 150,000 137,000 138,000 147,000 

Minnesota 491,000 504,000 486,000 440,000 464,000 445,000 

Montana 53,900 53,600 47,500 31,700 38,400 42,400 

Nebraska 48,400 61,300 47,500 45,200 53,000 46,000 

North 255,000 261,000 252,000 208,000 225,000 227,000 Dakota 

Oregon 9,800 13,100 12,000 6,700 10,600 11,000 

Washington 1,700 2,000 2,000 1,600 --- ---

Wyoming 36,200 42,800 30,800 29,700 32,400 32,000 

US Total 1,299,800 1,366,200 1,268,800 1,090,700 1,185,800 1,174,200 

Source: USDA NASS, 2010 

H7-1 in 2007, and in 2010, 95 percent of the planted crop was event H7 -1. During this time 

period, the planted sugar beet acreage remained within the range of pre-event H7 -1 plantings 

since 1961. 

As discussed in Section 2, sugar beet production is highly structured, vertically integrated, and 

centered on production facilities that are grower owned .. To maintain a healthy industry, 

production cannot fluctuate much from year to year: a certain level of production is needed to 

support the major investment of a processing facility, and a processing facility has limited 

capacity. The sugar beet grower is bound to the local processing facility and the local 

processing facility is bound to the sugar beet grower. Barring some unusual disruption in the 

industry, large fluctuations from year to year would not be expected. 

Crop data also provides no indication that the introduction and widespread adoption of GE crops 

in general has resulted in any significant change to the total US acreage devoted to agricultural 

production. The acres in the US planted to principal crops, which include corn, sorghum, oats, 

barley, winter wheat, rye, durum, spring wheat, rice, soybean, peanuts, sunflower, cotton, dry 

edible beans, potatoes, canola, proso millet, and sugar beets, has remained relatively constant 

over the past 25 years (USDA NASS, 2010). From 1983 to 1995, the average yearly acreage of 

principal crops was 328 million (USDA NASS, 2010). Biotechnology-derived crops were 

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introduced in 1996, and in 2009, 321 million acres of principal crops were planted, which is not a 

significant change (USDA NASS, 2009a). 

Alternative 1 

Under Alternative 1, plantings of event H7-1 sugar beet would be limited and only occur under 

notification or permit issued by APHIS. Growers would not have the option of planting event 

H7-1 sugar beets. Since sugar beet growers are farmers who also grow other crops, those who 

would have grown sugar beets could most likely grow some crop, but they could nevertheless 

suffer significant losses as a result (See Section 2.3). They may choose to grow conventional 

beets or other crops. A number of factors may influence this decision, including availability of 

herbicides for conventional sugar beets, availability and cost of specialty cultivating equipment, 

availability of desirable varieties of sugar beet, and the potential penalty or lost ownership 

shares in the cooperative for not growing sugar beets. In the short term (the term considered by 

this ER), Alternative 1 could potentially result in a large decrease in sugar beet production. 

However, changes in land use would not be expected and the land use is likely to remain 

agricultural. 

Alternative 2 

Under Alternative 2, growers who choose to do so could continue to plant event H7-1 sugar 

beets. Sugar beet acreage would be expected to be similar to the levels of the past 50 years. 

Land use that is agricultural would be expected to remain so and other land use would not be 

impacted. 

3.13.2 Air Quality and Climate 

Alternative 1 

Under Alternative 1, plantings of event H7-1 sugar beet would be limited and only occur under 

notification or permit issued by APHIS. Because the use of glyphosate as a post-emergence 

herbicide has resulted and is expected to continue to result in an increase in conservation tillage 

practices, an increase in the use of mechanical tilling would be expected under Alternative 1, if 

growers would choose to plant conventional sugar beets. If growers would choose other crops, 

the effects would depend on what the other crops would be. Emissions related to global 

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warming, ozone depletion, summer smog and carcinogenicity, among others, were found to be 

lower in glyphosate-tolerant crop systems than conventional systems (Bennett et aI., 2004). 

Therefore, Alternative 1 would be expected to have slightly greater impacts on air quality and 

climate, if growers planted conventional sugar beets rather than event H7-1 sugar beets. 

Alternative 2 

Under Alternative 2, growers who choose to do so could continue to plant event H7-1 sugar 

beets. The continued use of event H7 -1 sugar beets may result in continued increases in 

conservation tillage, as discussed in Section 2 (changing to conservation tillage practice is 

gradual, as it often requires different management practices and often requires new equipment). 

Therefore, Alternative 2 would lead to a small but positive impact on air quality and climate 

relative to Alternative 1. 

3.13.3 Surface water quality 

Surface water may be impacted from sugar beet production by runoff from sugar beet fields that 

carries soil particles and herbicides or other pesticides to streams, rivers, lakes, wetlands and 

other water bodies. As discussed below, based on existing data, the soil component of runoff is 

a much more important contributor to surface water impacts than is the pesticide component. 

Alternative 1 

Under Alternative 1, plantings of event H7-1 sugar beet would be limited and only occur under 

notification or permit issued by APHIS. Under Alternative 1, growers who are now growing 

event H7-1 sugar beets and who would choose to grow conventional sugar beets would need to 

use other practices for weed management. These practices would likely consist of some 

combination of herbicide use and increased tillage (beyond conservation tillage). 

If Alternative 1 would result in increased use of tillage for weed control, overall adverse surface 

water impacts are likely to be greater than with Alternative 2. Tillage causes widespread soil 

disturbance. Thus, wind and water erosion, topsoil loss and the resulting sedimentation and 

turbidity in streams are likely to increase with increased tillage. In 2009, based on the states' 

water quality reports, EPA identified sedimentation and turbidity as two of the top 10 causes of 

impairment to surface water in the U.S. in general; in 2007, EPA identified 

sedimentation/siltation as the leading cause of impairment to rivers and streams in particular 

(EPA, 2009, p. 15; EPA, 2007, p. 9). Although a comprehensive data set has not yet been 

developed to prove the point, EPA has projected conservation tillage to be "the major soil 

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protection method and candidate best management practice for improving surface water quality" 

(EPA, 2002). EPA identifies conservation tillage as the first of its CORE 4 agricultural 

management practices for water quality protection (EPA, 2008a). 

Based on the states' water quality reports to EPA, which EPA makes available through its 

National Assessment Database, pesticides in general and herbicides in particular are a 

relatively minor contributor to impairment of surface water in the U.S., compared to 

sedimentation/siltation and turbidity (EPA 2008b). Of the pesticides that were reported as 

contributing to impairment, almost all are previously used, highly persistent chemicals that are 

no longer registered for use in the U.S. Only one herbicide, atrazine, was found (EPA 2008b). 

In summary, based on EPA data, herbicides in general are very minor contributors to surface 

water impairment in the U.S., whereas sedimentation/siltation and turbidity are major 

contributors. Alternative 1, compared with Alternative 2, would likely result in a different mix of 

herbicides used and may result in increased tillage. Increased tillage could contribute to 

adverse surface water impacts through increased runoff of soil particles to surface water bodies. 

Alternative 2 

Alternative 2 would result in continued application of glyphosate herbicides to event H7-1 sugar 

beets. Herbicides that adsorb strongly, such as glyphosate, are less likely to degrade or 

volatilize (USDA APHIS, 2009). 

Other herbicides used on sugar beets have varying chemical fates, but, in general, most are 

more persistent and are characterized by higher mobility in soils, making them more apt to 

continually contaminate surrounding water systems. 

3.13.4 Groundwater quality 

Alternative 1 

Under Alternative 1, if growers choose to grow conventional sugar beets, the potential for 

impacts to groundwater would be similar to that prior to the widespread adoption of event H7-1 

sugar beets. If herbicides are used that do not bind strongly to soil particles, and have a higher 

potential to leach into groundwater, the potential for migration to groundwater may be higher 

than with Alternative 2. 

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Alternative 2 

Because glyphosate binds strongly to soil, and has a low potential to leach into groundwater, it 

is unlikely to impact groundwater. 

3.14 BIOLOGICAL 

Potential environmental effects of pesticide use are carefully considered as a part of the FIFRA 

pesticide registration process. Prior to the approval of a new pesticide or a new use of that 

pesticide (including a change in pesticide application rates and/or timing) and before 

reregistering an existing pesticide, EPA must consider the potential for environmental effects 

and make a determination that no unreasonable adverse effects to the environment will be 

caused by the new pesticide, new use or continued use. 

To make this determination, EPA requires a comprehensive set of environmental fate and 

ecotoxicological data on the pesticide's active ingredient (US 40 CFR Part 158). EPA uses 

these data to assess the pesticide's potential environmental risk (exposure/hazard). The 

required data include both short- and long-term hazard data on representative organisms that 

are used to predict hazards to terrestrial animals (birds, nontarget insects, and mammals), 

aquatic animals (freshwater fish and invertebrates, estuarine and marine organisms), and 

nontarget plants (terrestrial and aquatic). 

Information regarding the impacts of glyphosate on the biological environment is summarized 

below. Additional information on this topic is also being considered in the USDA APHIS Draft 

Environmental Impact Statement (DEIS) on the Deregulation of Glyphosate Tolerant Alfalfa 

(Docket No. APHIS-2007-0044). This information is applicable to the use of glyphosate in event 

H7-1 sugar beet since the maximum single in-crop application rate for GT alfalfa (1.55 Ib a.e.lA) 

is greater than the maximum single in-crop application rate for sugar beet (1.125Ib a.e.lA). 

3.14.1 Plant and Animal Exposure to Glyphosate 

Animals 

The equivalence of the CP4 EPSPS enzyme to native EPSPS except for tolerance to 

glyphosate is discussed in Sections 3.1 and 3.11. A number of researchers have conducted 

laboratory investigations with different types of arthropods exposed to genetically engineered 

crops containing the CP4 EPSPS protein (Goldstein, 2003; Boongird et aI., 2003; Jamornman, 

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et aI., 2003; Harvey et aI., 2003). Representative pollinators, soil organisms, beneficial 

arthropods and pest species were exposed to tissues (pollen, seed, and foliage) from GE crops 

that contain the CP4 EPSPS protein, to evaluate potential toxicity. These studies, although 

varying in design, all reported a lack of toxicity observed in various species exposed to these 

crops (Nahas et aI., 2001; Dunfield and Germida, 2003, Siciliano and Germida 1999). 

As a part of the reregistration evaluation under FIFRA, EPA conducted an ecological 

assessment for glyphosate. This assessment compared the results from toxicity tests with 

glyphosate conducted with various plant and animal species to a conservative estimate of 

glyphosate exposure in the environment, the Estimated Environmental Concentration (EEC) .. 

Glyphosate is practically nontoxic to slightly toxic to birds, freshwater fish, marine and estuarine 

species, aquatic invertebrates and mammals and practically nontoxic to honey bees (which are 

used to assess effects on nontarget insects in general) (EPA, 1993, pp. 50, 38 - 40, 45, 47, 48 -

50). Glyphosate has a low octanol-water coefficient, indicating that it has a tendency to remain 

in the water phase rather than move from the water phase into fatty substances; therefore, it is 

not expected to accumulate in fish or other animal tissues. 

In the Reregistration Eligibility Decision (RED) for glyphosate (EPA, 1993, p. 53), the exposure 

estimates were determined assuming an application rate of 5.06251b a.e., which exceeds the 

maximum labelled use rate for a single application for agricultural purposes. When the EECs 

were calculated for aquatic plants and animals, the direct application of this rate to water was 

assumed. Based on this assessment, EPA concluded that effects to birds, mammals, fish and 

invertebrates are minimal based on available data (EPA, 1993). 

The glyphosate end-use products used in agriculture contain a surfactant to facilitate the uptake 

of glyphosate into the plant (Ashton and Crafts, 1981). Depending on the surfactant used, the 

toxicity of the end-use product may range from practically nontoxic to moderately toxic to fish 

and aquatic invertebrates (EPA, 1993, pp. 42 - 45). For this reason, the 1993 Glyphosate RED 

stated that some formulated end-use products of glyphosate needed to be labeled as "Toxic to 

fish" if they were labeled for direct application to water bodies. Due to the associated hazard to 

fish and other aquatic organisms, glyphosate end-use products that are labeled for applications 

to water bodies generally do not contain surfactant, or contain a surfactant approved for direct 

application to water bodies. 

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Soil Microorganisms 

Microorganisms produce aromatic amino acids through the shikimate pathway, similar to plants. 

Since glyphosate inhibits this pathway, it could be expected that glyphosate would be toxic to 

microorganisms. However, field studies show that glyphosate has little effect on soil 

microorganisms, and, in some cases, field studies have shown an increase in microbial activity 

due to the presence of glyphosate (USDA FS, 2003). 

Based on the data available on glyphosate usage, chemical fate, and toxicity, glyphosate is not 

expected to pose an acute or chronic risk to the following categories of wildlife: (EPA, 1993) 

• birds, 

• mammals, 

• terrestrial invertebrates, 

• aquatic invertebrates, and 

• fish 

• soil microorganisms 

Alte1'1lative 1 

Under Alternative 1, the potential for impacts to animal species may be greater than with 

Alternative 2 because of the return to greater use of additional herbicides, potentially with higher 

toxicities. 

Altemative 2 

As stated previously, Alternative 2 is expected to result in the continued use and application of 

glyphosate-based herbicide formulations. This could result in continued glyphosate exposure to 

animal species within and adjacent to those fields through drift, as discussed previously, and a 

decrease in exposure to other herbicides from runoff and! or drift (USDA APHIS, 2009) . 

. . . . . Considering the potential for aquatic exposure to glyphosate formulations from 

terrestrial uses, EPA recently evaluated the effect of glyphosate and its formulations on another 

amphibian species, the California red-legged frog, and concluded that aquatic exposure to 

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glyphosate or its formulations posed no risk to this threatened species (EPA, 2008b). Because 

EPA considered a wide range of application rates in their evaluation for the red-legged frog, this 

conclusion can also be applied to amphibians exposed to glyphosate from applications on event 

H7-1 sugar beet. Any possible adverse impacts to amphibians resulting from the deregulation 

of event H7 -1 sugar beet may be offset by the shift from other herbicides used in sugar beet 

cultivation, which are considered to have higher environmental impacts in general. . 

Additionally, amphibian habitat in watersheds where event H7-1 sugar beet is produced could 

be improved through conservation tillage, resulting in decreased soil erosion, decreased 

sedimentation in runoff, and decreased turbidity in ponds, lakes, and rivers fed by surface 

waters. 

Plallts 

Glyphosate is a non-selective herbicide with post-emergence activity on essentially all annual 

and perennial plants. As discussed in Section 3.1.1, this activity is due to inhibition of EPSPS, 

an enzyme involved in aromatic amino acid synthesis. As with any herbicide, a risk exists that 

spray drift could pose issues for plants on the borders of the target field However, EPA takes the 

potential for spray drift into account when conducting the risk assessment it uses to establish 

pesticide application rates and direction for use, which are designed to minimize spray drift 

risks .. As discussed earlier, glyphosate binds tightly to agricultural soils and is not likely to 

move offsite dissolved in water. Moreover, glyphosate is not taken up from agricultural soil by 

plants. However, because drift is a potential means of exposure to non-target plants adjacent to 

an event H7 -1 sugar beet field; Monsanto conducted a threatened and endangered (TE) 

species risk assessment to evaluate the impacts to plants (and animals) from the use of 

glyphosate-based herbicides in conjunction with glyphosate-tolerant plants. The complete 

assessment was submitted to APHIS and has been reviewed by APHIS scientists to support the 

petition for deregulation of glyphosate-tolerant alfalfa. The assessment is available on the 

APHIS, BRS website at http://www.aphis.usda.gov/biotechnology/alfalfa_documents.shtml 

The assessment identified some plant, but no animal, species for which glyphosate when 

aerially applied could pose issues in areas bordering fields in certain locations where sugar 

beets are grown. To address any such risks, Monsanto developed Pre-Serve, a web-based 

program designed to eliminate any potential impacts on TE plants resulting from the agricultural 

use of herbicides that contain glyphosate. 

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Pre-Serve instructs growers to observe specific precautions when spraying glyphosate 

herbicides on Roundup Ready® crops near TE plant species that may be at risk. Only a very 

small percentage of glyphosate applications will require mitigation measures. This is because 

the vast majority of U.S. cropland is outside of the Pre-Serve Use Limitation Areas - areas 

where threatened or endangered plant species may be present - and most glyphosate 

applications are made using ground application equipment at rates below 3.5 pounds of active 

ingredient per acre (Ib a.e./acre), which will not impact the TE plant species. 

Growers who are licensed to purchase and use seeds containing Roundup Ready® technology 

are required contractually to follow the requirements in Monsanto's Technology Use Guide. 

This includes the requirement to access the Pre-Serve website (www.pre-serve.org) or contact 

Monsanto before applying glyphosate-based herbicide products to crops grown from these 

seeds. This website will guide growers and applicators through a user-friendly, four-step 

process to determine whether their fields are located within Use Limitation Areas and, if so, to 

identify the mitigation measures that must be taken. For fields located within Use Limitation 

Areas, the following mandatory steps must be taken to reduce potential risks to TE plant 

species: 

• Ground applications are limited to rates of less than 3.5 Ib a.e./acre (most uses). 

• Aerial applications may be prohibited in buffer zones along perimeters of fields. The size 

of buffer zones can be minimized by employing a coarser spray droplet size. 

• In specified counties, aerial applicators will be required to observe a new maximum use 

rate of 0.92 Ib a.e./acre (26 fl. ozlA Roundup PowerMAX® or WeatherMAX®) if using 

medium spray droplets'9, but can apply the current full labeled rate (1.55 Ib a.e./acre or 

44 fl. ozlacre of Roundup PowerMAX or WeatherMAX) if using coarse spray droplets. 

In addition to the instructions provided by Pre-Serve, mitigations from local, state or federal 

protection programs andlor landowner agreements may apply. Monsanto's licensees are 

required to follow these measures where applicable. . 

® Roundup Ready is a registered trademark of Monsanto Technology LLC. 

39 In counties where listed plant species observations wefe present, but not within 250 ft of a relevant land use, actual 

separation distance was not assessed. In these counties aerial application rates with medium sized droplets are 

restricted to 0.92 Ib a.e.lacre to avoid exposure to listed TE plant species that might be within 417 It of the application 

area, and thus within an area where aerial application at 1.55 Ib a.e./acre using medium-sized spray droplets would 

present a potential risk based on the Tier 1 assessment. This restriction will be eliminated in many cases by further 

distance assessments. 

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The Pre-Serve web-based system, as described above, enables growers and applicators to 

take steps where necessary to avoid potential effects to TE plant species from application of 

glyphosate-based agricultural herbicides. 

Alternative 1 

Under Alternative 1, the rates and volumes of glyphosate applications on sugar beet crops 

would likely return to the level of use that existed prior to the deregulation of event H7-1 sugar 

beets. Growers would use an array of other herbicides, some of which may be applied at 

greater volumes compared to glyphosate. The herbicides used in conventional sugar beet 

systems have been found, in general, to have somewhat greater human health or environmental 

impacts than glyphosate (USDA, 2004). This is consistent with the EPA decision to grant 

reduced risk status for glyphosate use in glyphosate-tolerant sugar beets. Error! 

Bookmark not defined. Comparison of results from terrestrial and aquatic plant studies 

with predicted exposure from herbicide use suggests that most of the herbicides used in 

conventional sugar beet systems may have more effect than glyphosate on aquatic or terrestrial 

plant species. These herbicides are selective herbicides that kill only particular groups of plants 

such as annual grasses, perennial grasses, or broad leaf weed species and thus require the use 

of more than one herbicide to achieve satisfactory weed control. 

Altern ative 2 

Alternative 2 is expected to result in continued use and application of glyphosate-based 

herbicide formulations. This could result in some incidental glyphosate exposure to terrestrial 

and aquatic plants in the vicinity of event H7-1 beet fields by spray drift. The EPA has 

concluded that glyphosate use on event H7 -1 sugar beet can be considered to pose reduced 

risk compared to other herbicides used for weed control in conventional sugar beets40 

. . Hundreds of millions of acres of other GT crops have been treated with glyphosate for over 

ten years with minimal impact to adjacent non-target terrestrial plants including crops when 

appropriate drift minimization measures are practiced. Because glyphosate binds strongly to 

soil particles and has no herbicidal activity after binding to soil, no effects on aquatic plants will 

result from surface water runoff from glyphosate use on event H7-1 sugar beet in accordance 

with labeled directions for use.. Conservation tillage and no tillage practices that are possible 

40 A reduced risk decision is made at the use level based on a comparison between the proposed use of the 

pesticide and existing alternatives currently registered on that use site. A list of decisions regarding Reduced Risk 

Status can be found at http://www.epa.gov/opprd001/workplan/reducedrisk.html 

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when glyphosate is used have the potential to decrease surface water runoff and sedimentation 

which further benefits aquatic organisms. 

3.14.2 Threatened and Endangered Species 

As the action agency for pesticide registrations EPA has the responsibility to conduct an 

assessment of effects of a registration action on endangered species. The EPA Endangered 

Species Protection Program web site, http://www.epa.gov/espp/, describes the EPA 

assessment process for endangered species. Some of the elements of that process, generally 

taken from the web site, are summarized below. 

When registering a pesticide or reassessing the potential ecological risks from use of a currently 

registered pesticide, EPA evaluates extensive exposure and ecological effects data to 

determine how a pesticide will move through and break down in the environment. Risks to 

birds, fish, invertebrates, mammals and plants are routinely assessed and used in EPA's 

determinations of whether a pesticide may be licensed for use in the U.S. 

EPA's core pesticide risk assessment and regulatory processes ensure that protections are in 

place for all populations of nontarget species. Because endangered species may need specific 

protection, EPA has developed risk assessment procedures described in the Overview of the 

Ecological Risk Assessment Process (U.S. EPA, 2004d, p. 7) to determine whether individuals 

of a listed species have the potential to be harmed by a pesticide, and if so, what specific 

protections may be appropriate. EPA's conclusion regarding the potential risks a pesticide may 

pose to a listed species and any designated critical habitat for the species, after conducting a 

thorough ecological risk assessment, results in an "effects determination." 

As a part of the endangered species effects assessment for the California red-legged frog, EPA 

evaluated the effect of glyphosate at rates up to 7.95 Ib a.e.lA on fish, amphibians, aquatic 

invertebrates, aquatic plants, birds, mammals, and terrestrial invertebrates. This assessment 

determined that at the maximum application rate for in-crop applications of glyphosate to GT 

sugar beets (1.125Ib a.e.lA) there would be no effects of glyphosate on the following taxa of 

threatened and endangered species: fish, amphibians, birds, and mammals. EPA also 

determined that glyphosate formulations would have no effect on threatened or endangered 

fish, amphibians, birds, and mammals. Although not specifically discussed in the assessment, 

from the EEC's and effects endpoints presented, it can also be determined that there would be 

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no effects of glyphosate or its formulations on threatened or endangered vascular aquatic 

plants, and aquatic invertebrates (EPA, 2008b).2008). non-endangered small .H7-1 . 

Monsanto has designed a web-based program (www.Pre-Serve.org), designed to ensure no 

effect of glyphosate applications on threatened and endangered plant species. Pre-Serve 

instructs growers to observe specific precautions when spraying glyphosate herbicides on 

glyphosate-tolerant crops near threatened and endangered plant species that may be at risk. 

According to the U.S. Fish and Wildlife Service Endangered Species website, there are no TE 

terrestrial invertebrates in Colorado, Idaho, Nebraska, North Dakota, South Dakota, and 

Wyoming. 41 In other states, TE small terrestrial invertebrates, if present, are at no more risk 

than from applications of glyphosate to conventionally grown sugar beets. 

Alternative 1 

Under Alternative 1, the potential for impacts to threatened and endangered species may be 

greater than with Alternative 2 because of the use of certain herbicides with potentially higher 

toxicities. 

Alternative 2 

As indicated, EPA is responsible for and has previously conducted analyses regarding 

glyphosate impacts. Only two percent of glyphosate is applied aerially to all agricultural crops in 

the US (USDA APHIS, 2009). Given that aerial application in event H7-1 sugar beets is not 

expected to be any different than other agricultural production systems, approximately two 

percent of glyphosate used in event H7-1 sugar beets is expected to be applied aerially. 

Additionally, the use of buffer zones, based on the Pre-Serve program, between the sugar beet 

field and any potential threatened or endangered plant populations can prevent any adverse 

impacts due to drift of glyphosate from aerial applications (USDA APHIS, 2009), so that there 

will be no effect on endangered species. 

We evaluated the potential for deleterious effects or significant impacts on non-target 

organisms, including those on the US Fish and Wildlife Service (USFWS) threatened and 

endangered species list, from cultivation of event H7-1 sugar beet and its progeny. The enzyme 

CP4 EPSPS that confers glyphosate tolerance is from the bacterium Agrobacterium sp. strain 

CP4. This gene is similar to the gene that is normally present in sugar beets and is not known 

41 http://www.fws.gov/endangered/species/index.htm I 

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to have any toxic property (Schneider, 2003). Field observations of event H7-1 sugar beet 

event H7-1 revealed no negative effects on non-target organisms (Schneider, 2003). The lack 

of known toxicity for this enzyme suggests no potential for deleterious effects on beneficial 

organisms such as bees and earthworms. The high specificity of the enzyme for its substrates 

makes it unlikely that the introduced enzyme would metabolize endogenous substrates to 

produce compounds toxic to beneficial organisms (Schneider, 2003). 

3.15 HUMAN HEALTH AND SAFETY 

3.15.1 Consumer Health and Safety 

AlternatiJ1e 1 

Under Alternative 1, the potential for impacts to consumers may be greater than with Alternative 

2 because of the use of herbicides with higher toxicities. 

AlternatiJ1e 2 

The general public is not at a high risk of exposure to substantial levels of glyphosate under 

typical use conditions (EPA, 1993; USDA FS, 2003). Under Alternative 2, exposure to 

glyphosate would not increase beyond that currently experienced, since 95 percent of sugar 

beet is already event H7- 1. According to the EPA Glyphosate Fact Sheet (1993) glyphosate is 

of relatively low oral and dermal acute toxicity and has been placed in Toxicity Category III for 

these effects (Toxicity Category I indicates the highest degree of acute toxicity, and Category IV 

the lowest). The acute inhalation toxicity study was waived by EPA because glyphosate is 

nonvolatile and available adequate inhalation studies with end-use products show low toxicity. 

The use of glyphosate herbicide does not appear to result in adverse effects on development, 

reproduction, or endocrine systems in humans and other mammals. Under present and 

expected conditions of use, glyphosate herbicide does not pose a health risk to humans (EPA, 

1993). 

Additionally, the nature of glyphosate residue in plants and animals is adequately understood, 

and studies with a variety of plants indicate that uptake of glyphosate from soil is limited. The 

material that is taken up is readily translocated throughout the plant. In animals, ingested or 

absorbed most glyphosate is essentially not metabolized and is rapidly eliminated in urine and 

feces. Enforcement methods are available to detect residues of glyphosate in or on plant 

commodities, in water, and in animal commodities (EPA, 1993). 

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EPA conducted a dietary risk assessment for glyphosate based on a worst-case risk scenario, 

that is, assuming that 100 percent of all possible commodities/acreage were treated, and 

assuming that tolerance-level residues remained in/on all treated commodities. Based on the 

assessment, EPA concluded that the chronic dietary risk posed by glyphosate food uses is 

minimal (EPA, 1993). 

The addition of another GT crop to agricultural production may lead to a greater chance that a 

GT crop, including GT sugar beets may be grown near other food crops. This could lead to 

higher exposure to glyph os ate in the diet of the general public because there would be a greater 

chance for glyphosate residue to reach food crops via spray drift. Nonetheless, such increase 

risk of exposure to glyphosate residue will not result in increased risks to the general population 

because the current upper estimates of risk are based on highly conservative fruit and 

vegetable intake rates with an assumed high estimated amount of glyphosate residue. 

Glyphosate is registered for use as a direct application to weeds in several fruits and vegetables 

and tolerances are established in the consumable commodities of these crops. The current 

aggregate dietary risk assessment completed by EPA concludes there is no concern for any 

subpopulation regarding exposure to glyphosate, including the use on many fruits and 

vegetables and GT sugar beet (71 FR 76180, 2006). Moreover, the potential exists for 

decreases in the applications and subsequent residues of more toxic herbicides if GT sugar 

beet is deregulated. 

3.15.2 Hazard Identification and Exposure Assessment for Field Workers 

Alte1'l1atiJle 1 

Under Alternative 1, the potential for impacts to field workers may be greater than with 

Alternative 2 because of the increased need for hard labor to remove weeds and the use of 

herbicides with higher toxicities. 

Alte1'l1atiJle 2 

According to the RED document for glyphosate (EPA, 1993), glyphosate is of relatively low oral 

and dermal acute toxicity. For this reason, glyphosate has been aSSigned to Toxicity Categories 

III and IV for these effects (i.e., Toxicity Category I indicates the highest degree of acute toxicity, 

and Category IV the lowest). An acute inhalation study was waived by EPA because 

glyphosate is a non-volatile solid, and the studies conducted on the end-use product formulation 

are considered sufficient (EPA, 1993). Expert toxicological reviews from US EPA (1993) and 

the World Health Organization (WHO, 2004) are in agreement that glyphosate does not pose 

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any human acute exposure concerns for dietary exposures and thus negated the need to 

establish an acute reference dose. 

With regard to subchronic and chronic toxicity, one of the more consistent effects of exposure to 

glyphosate at high doses is reduced body weight gain compared to controls. Body weight loss 

is not seen in multiple subchronic studies, but has at times been noted in some chronic studies 

at excessively high doses", 20,000 ppm in diet (WHO, 2004). Other general and non-specific 

signs of toxicity from subchronic and chronic exposure to glyphosate include changes in liver 

weight, blood chemistry (may suggest mild liver toxicity), and liver pathology (USDA FS, 2003). 

Glyphosate is not considered a carcinogen; it has been classified by EPA as a Group E 

carcinogen (evidence of non-carcinogenicity for humans) (EPA, 1993; 2006). 

EPA has considered in its human health analysis the potential applicator and bystander 

exposure resulting from increased glyphosate use. Based on the toxicity of glyphosate and its 

registered uses, including use on glyphosate-tolerant crops, EPA has concluded that 

occupational exposures (short-term dermal and inhalation) to glyphosate are not of concern 

because no short-term dermal or inhalation toxicity endpoints have been identified for 

glyphosate (71 FR 76180, 2006). 

Additional evidence to support the EPA conclusion can be found in the Farm Family Exposure 

Study, a biomonitoring study of pesticide applicators conducted by independent investigators 

(Acquavella, et al. 2004). This biornonitoring study determined that the highest estimated 

bodily adsorption of glyphosate as the result of routine labeled applications of registered 

glyphosate-based agricultural herbicides to crops, including glyphosate-tolerant crops, was 

approximately 400 times lower than the RID established for glyphosate. Furthermore, 

investigators deterrnined that 40 percent of applicators did not have detectable exposure on the 

day of application, and 54 percent of the applicators had an estimated bodily adsorption of 

glyphosate rnore than 1000 times lower than the RID (Acquavella, et at., 2004). Use patterns 

and rates for glyphosate tolerant sugar beet are typical of most glyphosate agronomic practices. 

Therefore, the deregulation of glyphosate-tolerant sugar beet would not Significantly increase 

the exposure risk to pesticide applicators. 

Finally, the biomonitoring study also found little evidence of detectable exposure to individuals 

on the farrn who were not actively involved in or located in the imrnediate vicinity of labeled 

applications of glyphosate-based agricultural herbicides to crops. Considering the similarity of 

the use pattern and application rates of the glyphosate products in this study cornpared to those 

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registered for use on glyphosate-tolerant sugar beet and glyphosate-tolerant crops in general, 

bystander exposure attributed to the use of glyphosate on glyphosate-tolerant crops is expected 

to be negligible. Therefore, the use of currently registered pesticide products containing 

glyphosate in accordance with the labeling will not pose unreasonable risks or adverse effects 

to humans or the environment. In general, the herbicidal activity of glyphosate is due primarily 

to a metabolic pathway that does not occur in humans or other animals, and, thus, this 

mechanism of action is not directly relevant to the human health risk assessment. EPA 

considers glyphosate to be of low acute and chronic toxicity by the dermal route of exposure. 

Glyphosate is considered a Category IV dermal toxicant and is expected to cause only slight 

skin irritation (USDA APHIS, 2009). 

3.16 ECONOMIC IMPACTS 

3.16.1 Sugar beet processing 

Approximately 54% of the U.S. domestic sugar production comes from sugar beets (USDA 

Farm Service Agency [FSA], 2010). Refined sugar from sugar beets is the product of a multiyear cycle and involves beet seed suppliers, sugar beet growers, sugar beet processors, sugar 

users and consumers (USDA FSA, 2010). As part of that process, beet seed suppliers plant the 

commercial sugar beet seed crop in the fall of Year 1, which produces the commercial seeds 

harvested in the fall of Year 2. The commercial seed is processed over the winter and sold to 

sugar beet growers who plant it in the spring. Sugar beet growers harvest the beet root in the 

fall of Year 3 and deliver them to beet processing facilities owned by the beet processors. Beet 

sugar is extracted by beet processors beginning in the fall of Year 3 and throughout Year 4. 

The sugar produced from these beets is purchased by food manufacturers and consumers 

(USDA FSA, 2010). 

Of the sugar beet root crop planted in the spring of 2009, 95 percent was reported to be event 

H7-1 sugar beet seed. This is also the same for the sugar beet root crop planted in the spring 

of 2010, and harvested in the fall of 201 O. This represents 98 percent of the sugar beet root 

crop outside of California, where, as discussed in Section 2, event H7-1 has not been grown 

(USDA FSA, 2010). The harvesting of the 2010 root crop will begin between late August and 

early September, depending of the projected size of the sugar beet crop. The bigger the crop, 

the earlier the harvest will begin to make sure it is completed before the ground freezes. By late 

August, most of the crop's sugar will have been contracted for sale (USDA FSA, 2010). The 

economic impact of preventing that crop from being harvested and processed is discussed 

below. 

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3.16.2 USDA's role in sugar marketing 

The domestic sugar market is closely managed by USDA's sugar program and therefore, not 

governed solely by supply and demand. USDA controls domestically produced sugar through 

the Flexible Sugar Marketing Allotment Program, and controls foreign imports through the raw 

and refined sugar tariff-rate quotas (TRQs). Unlimited amounts of refined sugar can be 

imported under a high duty of 16.3 cents per pound and raw sugar of 15.36 cents per pound. 

Under section 156 of the Federal Agriculture Improvement and Reform Act of 1996, as 

amended by the Food Conservation, and Energy Act of 2008 (the Farm Bill), and the 

Harmonized Tariff Schedule of the United States (HTS). USDA is required to establish a range 

of acceptable market conditions, which means maintaining a price floor in potentially 

oversupplied situations by removing surplus supply, and maintaining "adequate supply" in 

potentially undersupplied market situations (USDA FSA, 2010). The minimum raw and refined 

sugar prices that the sugar program must support are the levels that would cause sugar beet 

and sugarcane processors to forfeit their sugar that was put up as collateral under the USDA 

sugar nonrecourse loan program. Sugar nonrecourse loans support raw cane sugar prices at 

21 cents per pound and refined beet sugar prices at 24 cents per pound. The nonrecourse 

loans support price because forfeiting the sugar collateral completely extinguishes the 

borrower's debt, thus sugar beet and sugarcane processors are assured of getting at least the 

USDA loan proceeds for their sugar. Loan collateral forfeiture also removes surplus sugar out 

of the market because the govemment is limited by the Farm Bill in its sugar disposal options 

(USDA FSA, 2010). 

At the other end of the range, the objective of maintaining "adequate supply" (as described in 

the Farm Bill) or "adequate supply at reasonable prices" (described in HTS) requires USDA to 

increase supply under tight markets, which will make domestic prices lower than they would 

otherwise be. However, there is no maximum sugar price strategy stipulated in federal law, as 

there is a minimum sugar price. Under the Flexible Sugar Marketing Allotments Program, the 

sugar beet processors are guaranteed a market share of 46 percent of the domestic market. If 

the sector cannot fulfill its quota, USDA is required to increase imports to maintain adequate 

supply (USDA FSA, 2010). 

3.16.3 Economic Impacts 

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Alternative 2 is not expected to result in adverse economic impacts. Growers and seed 

producers would continue to use and sell event H7-1 seed and crops and seek return on their 

investments. This section discusses the economic impacts of Alternative 1. 

Economic implications of a halt ill event H7-1 sugar beet cultivation 

Should the unrestricted use of event H7-1 sugar beets be impacted, effectively removing the 

product from the market, an estimated 4.25 million tons of beet sugar would be removed from 

the market (USDA FSA, 2010). This sugar is expected to supply about 40 percent of U.S. sugar 

consumption during 2011. 

Because the federal government has a major effect on sugar supply, and hence sugar price, the 

market reaction to a reduction in refined beet sugar is somewhat determined by USDA's supply 

management response. USDA has recently reacted to two similar, but smaller, events in 2005 

and 2008 (temporary loss of cane refineries) that demonstrate the potential effect from a 

reduction in sugar. In both cases, U.S. refined sugar prices averaged about 18 cents per pound 

above the world refined sugar price, even as USDA increased the world refined quota to 

moderate U.S. sugar prices (USDA FSA, 2010). However, an action that effectively precludes 

further planting, cultivation, processing, or other use of event H7-1 sugar beets would cause 

greater disruption and greater harm to the U.S. sugar market than caused by the 2005 or 2008 

disruptions because the reduction, 4.25 million tons, is 20 times larger than the loss of supply in 

2005 and 10 times larger than the loss in 2008 (USDA FSA, 2010). Prices increased 

substantially in those years, but were never high enough to cause sugar to be imported off the 

world market at the high tariff rate of 16.3 cents per pound. Under the scenario where event 

H7-1 sugar beet is effectively precluded, world sugar could enter under a high tariff and set the 

refined price in the U.S. market (USDA, 2010). 

Additionally, USDA learned from the temporary loss of cane refineries in 2005 and 2008 that 

many U.S. food manufacturers have difficulty using imported refined sugar because of 

differences in product quality or packaging. After the 2005 and 2008 events, a new business 

developed to clean, repackage, or liquefy imported refined sugar for domestic use. This was 

required because domestic food companies would not use the crystallized imported sugar in its 

original packaging (USDA FSA, 2010). 

U.S. sugar cane refiners are expected to run at near full capacity in 2011, therefore, they will not 

have the capacity to refine imported raw cane sugar to replace the 4.25 million tons of beet 

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sugar lost. Normally, USDA would increase the raw sugar TRQ to alleviate domestic sugar 

shortages. However, in 2011, domestic needs for sugar would have to be filled by increasing 

refined sugar imports by 6 times from an average of 690,000 tons over the past 3 years (USDA 

FSA,2010). This increase in refined sugar imports may cause an extensive disruption in the 

current refined sugar distribution system. For example, the 2.6 million tons would require about 

250,000 containers on at least 330 ships by the end of September 2010 (USDA FSA, 2010). 

If sugar beet root crop growers cannot harvest, they will experience an economic hardship 

because they will have incurred all the costs of producing the 2010 root crop except for 

harvesting. Further, they would incur the cost to destroy the crop to prepare the land for the 

next crop, and to prevent the sugar beet root crop from overwintering and reaching the flowering 

stage in 2011. Sugar beet processors are currently contracting FY 2011 beet sugar at 38 cents 

per pound (USDA FSA, 2010). Therefore, sugar beet growers and cooperative owners would 

also experience lost revenue estimated at $3.23 billion (4.25 million tons X 0.38 $llb X 2000 

Ibs/ton) (USDA FSA, 2010). 

Sugar beet processing factories, and the local economies organized around them, would 

experience economic hardship if beet processing factories were prevented from purchasing, 

processing, or selling sugar from event H7-1 sugar beets. The sugar beet processing factories 

would be idled, thousands of jobs would be lost and the livelihoods of many rural communities 

would be at stake (USDA FSA, 2010)Dr. Richard Sexton, an agricultural economist and an 

authority on agricultural cooperatives, recently conducted an investigation as to what the 

economic impact would be on growers and processors if the growing of GT sugarbeets was 

enjoined in 2011 and 2012. His results are particularly insightful because they rely, in part, on 

direct interviews and written surveys with each of the eight sugarbeet processing companies. Dr 

Sexton estimated that the consequences on a ban of GT sugarbeets in 2011 are: 1) 8 of 21 

sugarbeet processing plants would close (and unlikely to reopen); 2) grower crop income would 

be reduced by approximately $253 million; 3) sugarbeet processor worker salaries would be 

reduced by about $138 million dollars; and 4) the adverse economic impact on the local 

economies where sugarbeets are grown and processed would be approximately $1.1 billion. If a 

ban continued through 2012, Dr. Sexton estimated that processor full-time and seasonal 

employment would be lowered by approximately 1,570 workers, grower income would be 

reduced further by another $282 million and the adverse economic impact would be $964 million 

in lower net revenue to growers and their communities (Sexton 2010). Also, a. A 2004 study by 

the University of Idaho found that if sugar beet production and processing ceased in Idaho and 

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alternative crops were planted instead, Idaho would lose over 3,000 jobs and farm incomes 

would decline (given returns to corn, wheat, and other production options based on 2004 

projections). Sugar beet growers generally produce other crops, and their land would not 

remain idle; they have the equipment and expertise to produce other crops. The longer-term 

concern, however, is in terms of the impact on infrastructure, as some companies may not 

survive closing down for one season (USDA FSA, 2010). 

Additionally, individual sugar cooperative shareholders are significantly penalized for not 

fulfilling their contract. For example, one cooperative member stated that, "I currently own 485 

shares that are valued at $350 each and I am required to produce 485 acres of sugar beets 

annually to Western for processing. By contract, I am subject to an economic penalty of $350 

per share if my annual share of sugar beets is not delivered to Western for processing. Western 

has enforced this penalty against growers in the past" (Hofer, 2010). 

Sugar Beet Seed Production and Availability 

Only sugar beets grown from approved varieties can be utilized by growers for sugar beet 

production. The processor seed committee will establish a list of approved varieties from which 

growers may select. Once a variety has been approved for commercial production by the 

processor seed committee, the seed producer produces the seed in the quantities projected to 

be sold to the processor's growers. Seed suppliers must predict years in advance the likely 

demand for new varieties. If a seed supplier over predicts likely demand, the excess seed may 

be inventoried for a period that does not exceed the viability of the seed (Manning, 2010). 

The approved varieties have undergone extensive multi-year planting trials to determine how 

well each variety tolerates exposure to particular diseases and pests known to infest the 

growing region, particular growing conditions such as exposure to particular weather conditions, 

and the variety's ability to deliver acceptable yields per ton and sugar content (Manning, 2010). 

The approved variety list denotes sugar beet varieties that may be delivered to the processor for 

sugar production. As a cooperative member, a grower has a contract to deliver sugar beet from 

a specified number of acres. Sugar beet varieties that do not make the approved variety lists 

cannot be delivered to the processor for sugar production because they do not meet the 

standards set forth by the processor. A grower is not permitted by the processor to plant a 

sugar beet variety not on the approved list (Manning, 2010). 

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When event H7-1 sugar beet was deregulated in 2005, the industry began production of event 

H7-1 sugar beet seed. The majority of conventional seed varieties and seed available for the 

2011 crop year originated prior to 2007. Consequently, some approved varieties, including the 

genetic traits of those seed, and the inventory of some conventional seed now available were 

based on production decisions made many years ago (Manning, 2010). Certain seed producers 

have not engaged in new varietal development for conventional sugar beet since 2006/2007. 

Some processors have no conventional seed on their current approved variety list, while others 

still list some conventional seed varieties (Manning, 2010). Manning looked at the availability of 

sugar beet seed should event H7-1 sugar beet seed be unavailable. Based on Manning's 

analysis, all sugar beet growing regions in the U.S. would experience a shortfall of sugar beet 

seed to plant (Manning, 2010). The USDA FSA (2010) also stated that domestically-produced 

conventional sugar beet seed is in short supply because domestic seed companies have 

reduced production of conventional beet seed in recent years. 

Sugar beet seed produced outside the United States may not be suitable for commercial 

production in the U.S. Certain sugar beet seed varieties produced in the European Union (EU) 

or elsewhere have not undergone extensive multi-year variety trials in the U.S to determine if 

that variety meets the standards for disease resistance required by growers and beet 

processors. 

The limited availability of conventional seed could severely restrict plantings of sugar beets in 

2011 and sugar production in 2012 (USDA FSA, 2010). Based on information provided by 

sugar beet seed producers and buyers, UDSA FSA (2010) estimates that prohibiting the harvest 

of event H7-1 sugar beet seed in 2010, would reduce projected sugar beet root crop acreage by 

37 percent in 2011. Based on that estimate, the reduction in acres planted for sugar beet 

production would lower beet sugar production by an estimated 1.6 million tons in 2012 (lost 

acreage with unchanged yields and unchanged sugar recovery)(USDA FSA, 2010). The 

economic impact of a reduction in beet sugar supply on consumer costs and grower incomes in 

2012 would be severe (USDA FSA, 2010). However, the severity would be mitigated depending 

on the degree to which sugar users and consumers reduce their consumption of sugar or switch 

to non-sugar sweeteners. Manufacturers and consumers will have time to reduce their beet 

sugar use and manufacturing costs if a decision to prohibit event H7-1 sugar beets is 

announced at least a year before it affects domestic supply. USDA FSA (2010) estimates that 

U.S. demand for sugar could fall 1 percent due to the higher sugar costs in 2012. 

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If event H7 -1 sugar beet seed could not be planted in the spring of 2011 to grow the root crop, 

the 2012 U.S. refined sugar price is expected to rise from 33 cents per pound to 41 cents per 

pound, which includes transportation, product modification costs necessary to be suitable for 

American users, and the premium the U.S. Sugar Program provides domestic growers. Sugar 

users and consumers would pay a total of $1.6 billion additional for sugar in 2012 even if they 

consume less due to the higher sugar prices. Growers and processors are projected to 

experience a loss of 700 million in lost 2012 sugar beet and sugar sales (USDA FSA, 2010). 

A summary of the projected costs from an action that effectively precludes the planting, 

cultivation, and processing of event H7-1 sugar beets on sugar users and consumers and sugar 

beet growers and processors over the next two years is shown in Table 3-3. 

Herbicide Shortages 

The availability of herbicides is another factor that will likely affect a growers' decision to plant 

conventional sugar beet varieties. The advent of event H7-1 sugar beets caused a decline in 

the use of certain herbicides that were used with conventional sugar beet crops. The 

manufacturers of these herbicides have reduced production. Should growers plant conventional 

seed, the herbicides may not be available unless the manufacturers ramp up production to meet 

anticipated demands. This decision must be made far in advance of when the herbicides would 

be needed (Manning, 2010). 

Table 3-3. Production Loss and Project Costs from an event H7 -1 Sugar Beet Injunction 

Parent Commercial Commercial Harvest! Expected Sugar Cost to Cost to 

Seed Seed Seed Sales Sugar Production Growers Users! 

Planted Produced Planted Year Production Lost Consumers 

(1,000 tons) (Million $) 

lall2008 lal12009 spring 2010 2011 4,477 4,253 3,232 2,972 

18112009 fall 2010 spring 2011 2012 4,396 1,627 658 1,592 

Source. USDA FSA, 2010 

3.17 SOCIAL AND ECONOMIC IMPACTS ON RED BEET AND CHARD GROWERS 

Seed Production 

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In contrast to the very significant social and economic impacts identified in section 3.16 if H7-1 

sugarbeet cUltivation were halted, the effect of continued cultivation subject to the proposed 

interim measures would be minimal. As indicated in Section 2.8, most red beet and chard seed 

crops are grown in areas outside the Willamette Valley in Oregon where the large majority of 

sugarbeet seed crops are grown. The geographic limitations in the interim measures would 

preclude H7-1 seed cultivation in those areas and remove any chance of gene transfer between 

the crops. In the Willamette Valley, there is limited production of red beet and chard seed. See 

Section 2.8. The majority of such seed producers in those areas have agreed to and comply 

with the existing Willamette Valley Specialty Seed Association isolation distances for those 

areas, and have not reported issues or losses due to genetic transfer. There appears to be only 

very limited organic red beet and chard seed production in the Willamette Valley, and no 

indication of genetic transmission in the years since H7-1 seed cultivation began on a large 

scale in 2006. Although one identified organic grower has chosen to grow chard (among other 

organic crops) in the Western margins of the Valley, that grower has tested his crops on 

repeated occasions with peR tests over multiple years and found no indication of gene flow 

from H7-1 crops. 

In addition, in the years since 2006, seed companies producing H7-1 seed in the Willamette 

Valley have increasingly employed a "gene on the female" nonpollinator approach for H7-1 

production fields, meaning that those fields shed virtually zero pollen that could transmit H7-1 

genetic material. As a consequence, as discussed in Section 1.5, even an organic grower who 

chose to market and sell chard seed with a "zero tolerance" for H7 -1 genetic material would face 

no risk from such fields. 

The organic community's consensus Non-GMO Project Working Standard does not require zero 

tolerance - it contemplates a tolerance for GE traits in verified Non-GMO seed or 0.25%. The 

National Organic Program is a process-based standard; no organic grower has ever lost organic 

certification due to an unintended trace presence of a GE trait. Further, if an organic grower 

sensitive to H7-1 genetic material wished to ensure "zero tolerance," relatively inexpensive 

testing is available to do so, and common seed production methodologies can be employed to 

maintain a "zero tolerance" for organic seed if desired. This is discussed in Sections 1.5 and 

1.6. There is also no realistic prospect of mechanical mixing between red beet and chard seed 

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and H7-1 seed because the two production processes are entirely separate. As discussed in 

Section 2.7, seed is processed in different facilities, and no common equipment is used. 

Under APHIS's proposed interim measures, each seed company producing H7-1 would be 

subject to third party audits of compliance with the standards to ensure that the measures 

remained in place and were effective. Accordingly, Alternative 2 would have no or negligible 

social or economic impacts on red beet and chard crops, Alternative 1, by contrast, would have 

highly significant negative impacts on nationwide sugarbeet production, as discussed above. 

Root Crop Production 

As indicated above, including in Sections 2.8 there is little or no overlap of H7 -1 root crop 

production and red beet and chard seed production. To the extent certain red beet or chard 

seed savers may exist in root crop production areas (none have been identified), the measures 

for roguing bolters and related stewardship render the potential for genetic transmission from 

H7-1 negligible. As indicated, Alternative 2 would have no or negligible social or economic 

impacts on red beet and chard crops, By contrast, Alternative 1 would have highly significant 

impacts across multiple growing areas. 

Consumer Acceptance of the Sugar from Event H7-1 Sugar beets 

Since wide-scale production of event H7-1 sugar began, there has been no indication of 

significant concern regarding acceptance of H7-1 sugar producers of food products with sugar 

derived from these products or from consumers. The sugar is identical chemically to sugar from 

conventional sugarbeets (Baker, 2010a, pp. 2-3; Hoffman, 2010a, p. 10). In addition as 

indicated in Section 3.11.2, food and feed issues have been reviewed by FDA. This FDA review 

has not been challenged 

For any consumers who are nevertheless concerned about the source of this sugar, there are 

alternatives available. Cane sugar and other sweeteners are readily available for instance. 

And certain public interest groups, including the Institute for Responsible Technology, have 

publicized the readily available alternatives to sugarbeet sugar and other sweeteners derived 

from biotechnology (Burkam, 2010, p. 58). 

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CUMULATIVE IMPACTS 

This section discusses the cumulative impacts that may be associated with Alternative 2, when 

combined with other recent past, present, and reasonably foreseeable future actions within the 

affected environment. Alternative 2 is expected to be maintained for a short time duration, and 

an EIS will specifically address the environmental impacts associated with full deregulationin . 

Cumulative impacts that will occur before the EIS is completed are expected to be negligible. 

By contrast, as indicated in Section 3.16, the specific and cumulative impacts of Alternative 1 

are expected to be significant for growers nationwide. 

Cumulative impacts occur when the effects of an action are added to the effects of other actions 

occurring in a specific geographic area and timeframe. The cumUlative impact analysis follows 

CEQ's guidance: Considering Cumulative Effects Under the National Environmental Policy Act 

(CEQ, 1997). The steps associated with the analysis include: 

• Specify the class of actions for which effects are to be analyzed. 

• Designate the appropriate time and space domain in which the relevant actions 

occur. 

• Identify and characterize the set of receptors to be assessed. 

• Determine the magnitude of effects on the receptors and whether those effects are 

accumulating. 

4.1 CLASS OF ACTIONS TO BE ANALYZED 

This analysis addresses large, regional and national-scale trends and issues that have impacts 

that may accumulate with those of the proposed interim measures. 

4.2 GEOGRAPHIC AND TEMPORAL BOUNDARIES FOR THE ANALYSIS 

As described in Section 2, over the past 10 years, the number of acres planted annually in 

sugar beets in the US has ranged from 1.1 to 1.4 million (USDA ERS, 2009, Table 14). Event 

H7-1 sugar beets are produced in five major regions in the US, and commercial production of 

seeds takes place in the Willamette Valley of Oregon. Therefore, the spatial domain for past, 

present, and reasonably foreseeable future actions considers the five growing regions for issues 

associated with growing event H7-1 sugar beets; the Willamette Valley for issues associated 

with seed production; and the nation, and in some cases international areas, for issues 

associated with consumption of sugar beet food and feed products. Also, as indicated, the 

measures at issue would apply for a limited time period, estimated at less than 2 years. 

RESOURCES ANALYZED 

Issues evaluated in this cumUlative impacts analysis include some of the resource areas 

discussed in Chapters 2 and 3 including land use, air quality and climate, water quality, 

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biological, and human health and safety. In addition, specific topics analyzed include: 

cumulative impacts related to any possibility of development of glyphosate resistant weeds, and 

cumulative impacts of potential increased glyphosate usage with the cultivation of glyphosate 

tolerant crops. 

4.3 PARTIAL.CUMULATIVE IMPACTS RELATED TO THE DEVELOPMENT OF 

GLYPHOSATE RESISTANT WEEDS 

Glyphosate offers many benefits to the grower as a weed control product. Glyphosate controls 

a broad spectrum of grass and broad leaf weed species present in sugar beet production fields, 

has flexible use timings, and when used in glyphosate-tolerant crops, has a very high level of 

crop safety (see petition 03-323-01 p, Tables VII-4 and VII-4, pages 90 and 92, respectively). As 

the adoption of glyphosate-tolerant crops has grown, the use of glyphosate has increased over 

the past several years. With the increased use of glyphosate, there is also the potential for 

increased selection pressure for the development of glyphosate-resistant weeds (Section VIII). 

Because a glyphosate-based herbicide program is currently being used with event H7 -1 sugar 

beet, glyphosate use for event H7 -1 is not expected to increase beyond current levels, as 

market penetration is already at 95 percent. Current levels of glyphosate use in event H7-1 

sugar beets are a minor (approximately 0.7 percent) amount of total US glyphosate use. 

Additionally, with Alternative 2, growers still would have the currently available weed control 

tools (e.g., non-glyposate herbicides and cultural practices described in Section VII.B of petition 

03-323-01 p on page 88) needed on a small scale to manage any glyphosate-resistant weeds, 

whether they are present in sugar beet or other crop production fields. 

4.4 CUMULATIVE IMPACTS OF POTENTIAL INCREASED GLYPHOSATE 

USAGE WITH THE CULTIVATION OF GLYPHOSATE TOLERANT CROPS 

Studies of the relationship between genetically engineered crops and herbicide use has shown 

that an increase in glyphosate tolerant crops can result in a decrease in mechanical tillage 

(Brimner et aI., 2005; Fernandez-Cornejo, 2006; Gianessi and Reigner, 2006; Kleter et. aI., 

2007; Sankula, 2006; Johnson et aI., 2008). The potential cumulative impact from this reduction 

in mechanical tillage is discussed in the following sections. 

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According to the USDA ERS (2009), US farmers have adopted genetically engineered crops 

widely since their introduction in 1996. Soybeans and cotton genetically engineered with 

herbicide-tolerant traits have been the most widely and rapidly adopted GE crops in the US, 

followed by insect-resistant cotton and corn. Figure 4-1 shows the percentage of acres of 

genetically engineered crops in the US between 1996 and 2009. 

Percent of aCf8S 

100,----------------------------------------------, 

80 

.." HT Cotton 

60 

'0' Bt Cotton 

40 

20 

D1L--.--'--'--.---r--.--'---'--.--.--'--.--~ 

1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2DD8 2009 

Data for eaell crop category include varieti{}s with both HT and Bt (stacked) trailS. 

Sources: 1996·199!ldata aro from Fornandoz·Cornejo and McBride {ZOGl).1 I 

Figure 4-1 Growth in Adoption of Genetically Engineered Crops in US 

Source: Graph from USDA ERS, 2009 

Herbicide-tolerant crops, which are engineered to survive application of specific herbicides that 

previously would have damaged the crop, provide farmers with a broader variety of options for 

effective weed control. Based on USDA survey data, herbicide tolerant soybeans went from 17 

percent of US soybean acreage in 1997, to 68 percent in 2001 and 91 percent in 2009. 

Plantings of herbicide tolerant cotton expanded from approximately 10 percent of US acreage in 

1997 to 56 percent in 2001 and 71 percent in 2009. The adoption of herbicide tolerant corn, 

was slower in previous years, but has reached 68 percent of US corn acreage in 2009 (USDA 

ERS, 2009). 

Corn growers use the largest volume of herbicides. Approximately 96 percent of the 62.2 

million acres used for growing corn in the 10 major corn-producing States were treated with 

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more than 164 million pounds of herbicides in 1997 (USDA ERS, 2009). Soybean production in 

the US also uses a large amount of herbicides. Approximately 97 percent of the 66.2 million 

soybean acres in the 19 major soybean producing States were treated with more than 78 million 

pounds of herbicides in 1997 (USDA ERS, 2009). Cotton production relies heavily on 

herbicides to control weeds, often requiring applications of two or more herbicides at planting 

and postemergence herbicides later in the season (Culpepper and York, 1998). Close to 28 

million pounds of herbicides were applied to 97 percent of the 13 million acres devoted to 

upland cotton production in the 12 major cotton-producing States in 1997 (USDA ERS, 2009). 

Pesticide use on corn and soybeans has declined since the introduction of GE corn and 

soybeans in 1996. Several studies have analyzed the agronomic, environrnental, and econornic 

effects of adopting GE crops, including actual pesticide use changes associated with growing 

GE crops (McBride and Brooks, 2000; Fernandez-Cornejo, Klotz-Ingrarn, and Jans, 1999,2002; 

Giannessi and Carpenter, 1999; Culpepper and York, 1998; Marra et aI., 1998; Falck-Zepeda 

and Traxler, 1998; Fernandez-Cornejo and Klotz-Ingram, 1998; Gibson et aI., 1997; ReJesus et 

aI., 1997; Stark, 1997). Many of these studies have concluded that herbicide use is reduced 

with herbicide-tolerant varieties (USDA ERS, 2009). 

Studies conducted by the USDA also show an overall reduction in pesticide use related to the 

increased adoption ofGE crops. Based on the adoption ofGE crops between 1997 and 1998 

(except for herbicide-tolerant corn, which is modeled for 1996-97), the decline in pesticide use 

was estimated to be 19.1 million acre-treatments, 6.2 percent of total treatments (USDA ERS, 

2009). Most of the decline in pesticide acre treatments was from less herbicide used on 

soybeans, accounting for more than 80 percent of the reduction (16 million acre-treatments) 

(USDA ERS, 2009). 

The adoption of herbicide-tolerant crops such as event H7-1 sugar beets, glyphosate-tolerant 

soybeans, and glyphosate-tolerant corn results in the substitution of glyphosate for previously 

used herbicides. The glyphosate tolerant crops allow farmers to limit and Simplify herbicide 

treatments based around use of glyphosate, while a conventional weed control program can 

involve multiple applications of several herbicides. In addition, and more importantly, herbicidetolerant crops often allow farmers to use more benign herbicides (USDA ERS, 2009). 

There are known benefits associated with the use of glyphosate herbicides compared to 

herbicides currently used by sugar beet producers. Glyphosate has documented favorable 

characteristics with regard to risk to human health, non-target species, and the environment 

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(Malik et aI., 1989; Geisy et aI., 2000; Williams et aI., 2000). Glyphosate is classified by the 

EPA as a Group E pesticide (evidence of non-carcinogenicity for humans) (57 FR 8739). In 

1998, the EPA granted Reduced Risk status for an expedited review of the submitted residue 

data package supporting the use of glyphosate, as Roundup Ultra herbicide (EPA Registration 

No. 524-475) for use in glyphosate tolerant sugar beets. Reduced Risk status was granted by 

EPA based on a detailed hazard comparison of glyphosate to alternative herbicides available for 

weed control in sugar beet production (Reduced Risk petition document: MRID 44560501), and 

an overall conclusion that weed control with Roundup Ultra herbicide offers a substantial benefit 

to sugar beet growers in the form of reduced risk to human health, non-target species, and the 

environment. 

4.4.1 Land Use, Air Quality and Climate 

As discussed in Section 3, sugar beet acreage has fluctuated little for the past 50 years, was not 

impacted by the introduction of event H7-1, and is not expected to be impacted by continued 

use of event H7-1. Therefore, as discussed in Section 3, Alternative 2 is not expected to impact 

land use. As it is not expected to directly or indirectly impact land use, Alternative 2 would not 

have cumulative impacts on land use. 

As discussed in Section 3, Alternative 2 is expected to continue to have small positive impacts 

on air quality and climate, primarily resulting from reduced tillage. Consequently, Alternative 2 

is not expected to have any adverse cumulative impacts on air quality or climate. 

4.4.2 Water Quality 

As discussed in Section 3, the advent of glyphosate tolerant crops and the use of post-emergent 

herbicides that could be applied over a crop during the growing season have facilitated the use 

of conservation tillage farming practices, since weeds could be controlled after crop growth 

without tilling the soil (USDA ERS, 2009). The use of glyphosate tolerant crops (particularly 

soybeans) has intensified that trend since it often allows a more effective and less costly weed 

control regime than using other post-emergent herbicides (USDA ERS, 2009; Carpenter and 

Gianessi, 1999). 

The impact of conservation tillage (including no-till, ridge-till, and mulch-till) in controlling soil 

erosion and soil degradation is well documented (Edwards, 1995; Sandretto, 1997). By leaving 

substantial amounts of plant matter over the soil surface, conservation tillage 1) reduces soil 

erosion by wind; 2) reduces soil erosion by water; 3) increases water infiltration and moisture 

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retention; 4) reduces surface sediment and water runoff; and 5) reduces chemical runoff (USDA 

ERS, 2009). 

Glyphosate maypotentially be found in surface water runoff when erosion conditions lead to the 

loss of surface particles. However, as discussed in Section 3, partial deregulation of glyphosate 

tolerant crops typically leads to an increase in conservation tillage and no tillage systems, which 

would result in less mechanical disturbance of the soil during sugar beet cUltivation and thereby 

decrease the loss of surface soil. Because of this, and the fact that glyphosate binds strongly to 

soil particles, no-tillage and conservation tillage are expected to further reduce the likelihood of 

any impact surface water runoff (Wiebe and Gollehon, 2006). Therefore, no cumulative adverse 

impacts to surface water or groundwater are anticipated. 

4.4.3 Biological 

For non-target terrestrial species, available ecological assessments in EPA RED (EPA, 2003) 

documents or registration review summary documents provide the support that the use of 

glyphosate represents reductions in chronic risk to birds compared to trifluralin and sethoxydim, 

in acute risk to small mammals in comparison to EPTC, in chronic risk to mammals from 

quizalofop-p-ethyl, in acute risk to endangered birds and mammals from pyrazon, and in chronic 

risk to mammals and potentially birds from cycloate. For all other sugar beet herbicide 

products, as well as glyphosate, no significant risks to birds or other non-target terrestrial 

species were indicated in the available information. 

For non-target aquatic species, Tables 4-1, 4-2, and 4-3 provide summaries of the estimated 

exposure and hazard information for the traditional herbicides used in conventional sugar beet 

production, and present quantitative comparisons of the derived Risk Quotients. Exposure, 

defined as the EEC, was calculated for all products using the standard assumptions (assuming 

aerial application) of 5 percent drift of spray applied to a one-acre field onto water and 5 percent 

runoff from 10 treated acres into a one-acre pond six feet in depth. Herbicide treatments were 

based on the maximum single application rate taken from product labels. Hazard information 

(LC50 or EC50) for each active ingredient was taken from the EPA Ecotoxicology One-Liner 

Database (if available) or other EPA source documents and summarized in Tables 4-1,4-2 , 

and 4-3 as the upper and lower values from the range of values reported. Hazard information 

for the end-use formulated products is generally not readily available, thus this analysis is a 

comparison based solely on the active ingredients. Any label warnings and other available 

hazard andlor risk descriptions for non-target aquatic species are also included. The Risk 

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Quotient is determined for each active ingredient by dividing the EEC by the hazard (LC50 or 

EC50) value. 

Plants potentially at risk from the use of glyphosate are potentially at risk from the use of any 

herbicide. Like most herbicides, plants are highly sensitive to glyphosate. Monsanto has 

developed a program named Pre-Serve to address aerial spraying in areas where threatened 

plants may be located. Following label use instructions and use limitations described in PreServe swould address any such risk of exposure. Federal law requires pesticides to be used in 

accordance with the label.. Because glyphosate binds strongly to soil particles, conservation 

tillage and no tillage practices provide additional assurance that the impact to aquatic plants 

through decreasing soil-laden runoff are negligible. 

The labels for products containing desmedipham, phenmedipham, sethoxydim, clethodim and 

trifluralin include warnings of toxicity or adverse effects to fish, and/or aquatic invertebrates 

and/or aquatic plants. Risk Quotients that exceed the Trigger Value of 0.5 for aquatic animals 

and 1.0 for aquatic plants are highlighted in bold text in Tables 4-1, 4-2, and 4-3 as exceeding a 

Level of Concern, based on EPA Ecological Effects Rejection Analysis and Deterministic Risk 

Characterization Approach. Current sugar beet herbicide products containing triflusulfuron, 

trifluralin, and pyrazon are shown to exceed these Levels of ConcernAs supported by the EPA 

designation of reduced risk for application of glyphosate to H7-1 sugar beet,. glyphosate is a 

more environmentally preferred herbicide compared to other herbicides currently used in sugar 

beet production since glyphosate is generally less toxic and has favorable degradation 

properties. 

4.4.4 Human Health and Safety 

A tolerance increase was required to support approval for the use of glyphosate in the event H7-

1 sugar beet-cropping system compared to the limited pre-emergent use of glyphosate in 

conventional sugar beet production. However, the potential health effects of pesticide residues 

that may be present in food, regardless of whether they result from uses in conventional or 

glyphosate tolerant crops, are carefully considered by EPA before establishing maximum 

residue limits or tolerances. 

Before establishing a tolerance in an agricultural commodity, EPA must find that the potential 

resulting residues covered by the proposed tolerance will be "safe". Section 408(b)(2)(A)(ii) of 

the FFDCA [21 USC 346a(b)(2)(A)(i)] defines "safe" as a reasonable certainty that no harm will 

result from aggregate exposure to the pesticide chemical residue. As part of this determination, 

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the total maximum theoretical level of residue present in all food commodities with approved 

uses for the pesticide must not exceed the EPA established Reference Dose (RfD), or chronic 

Population Adjusted Dose (cPAD). Following a comprehensive review of the results of 

toxicological studies conducted on the pesticide, the RfD is set by applying appropriate 

uncertainty factors to the most appropriate No-Observed-Adverse-Effect-Level (NOAEL). 

In 1999, EPA conducted a dietary exposure risk assessment and concluded that the 

incremental dietary exposure associated with the use of glyphosate on glyphosate tolerant 

sugar beet did not pose a concern to human health (64 FR 18360, 1999). 

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Table 4-1 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on Freshwater Fish 

Fish LC60 (a.i.)' Fish Risk Quotient' 

Active Ingredient Max. Ib/acre EEC' Range Range Classification 1 Label 

(single appl.) (ppm) (ppm) Warnings 

. low high worst best 

Glyphosate 1.125 0.038 45 140 0.0008 0.0003 

.Clethodim 0.09 0.003 19 >33 0.0002 <0.0001 

Clopyralid 0.25 0.008 104 125 0.0001 0.0001 

Cycloate 4.0 0.135 4.5 7 0.03 0.02 

Desmedipham 1.2 0.040 1.7 6 0.024 0.007 Toxic to fish. I 

EPTC 4.2 0.142 11.5 27 0.012 0.005 

Ethofumesate 3.6 0.121 0.75 >320 0.16 <0.0004 

Phenmedipham 0.6 0.020 1.41 3.98 0.014 0.005 

Pyrazon 7.3 0.246 NA NA NA NA 

Quizalofop-p-ethyl 0.17 0.006 0.17 10.72 0.034 0.00 

Sethoxydim 0.47 0.016 170 265 0.0001 0.0001 Toxic to aquatic organisms. 

h-rifluralin4 0.72 0.024 0.0084 0.210 2.9 0.12 Extremely toxic to freshwater, 

marine and estuarine fish. 

h-riflusulfuron 0.08 0.0027 <640 <760 >0.000004 >0.000004 

NA = information not available 

1 EEC refers to the Estimated Environmental Concentrationl which assumes that a one-acre pond, six feet deep receives 5% drift from a aneacre field and 5% runoff from a 10-acre field. 

2 Aquatic LCso values obtained from the 2010 EPA Ecotoxicology One-Liner Database. 

3 Risk Quotient is EEC/LCso. Risk Quotient Balded if > 0.5 = Level of Concern [criteria from EPA Ecological Effects, Rejection Analysis]. Risk 

Quotients >0.1 result in classification for Restricted Use (http://www.epa.gov/oppefed1/ecorisk_ders/toera_risk.htm#Deterministic). 

4 Toxicity values are from the Trifluralin Reregistration Eligibility Document, United States Environmental Protection Agency, April 1996. 

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Table 4-2 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on Freshwater Aquatic Invertebrates 

Max. Iblacre EEC' 

Invertebrate EC" (a.i.)2 Invertebrate Risk Classification I Label 

Range Quotient' Warnings Active Ingredient (single appl,) (ppm) (ppm) Range 

low high worst best 

Glyphosate 1.125 0.038 134 780 0.0003 0.00005 

Clethodim4 0.09 0.003 20.2 NA 0.0002 NA 

Clopyralid 0.25 0.008 225 NA 0.00004 NA 

Cycloate 4.0 0.135 2.6 24 0.052 0.006 

Desmedipham 1.2 0.040 1.88 NA 0.021 NA 

EPTC 4.2 0.142 3.5 66 0.040 0.002 

Ethofumesate 3.6 0.121 64 294 0.002 0.0004 

Phenmedipham 0.6 0.020 3.2 14 0.006 0.001 Toxic to fish and aquaticorganisms. 

Pyrazon 7.3 0.246 NA NA NA NA 

Quizalofop-p-ethyl 0.17 0.006 2.12 6.4 0.003 0.001 

Sethoxydim 0.47 0.016 78 NA 0.0002 NA Toxic to aquatic organisms. 

Irrifluralin' 0.72 0.024 0.56 2.2 0.043 0.011 Ex1remely toxic to aquati 

invertebrates. 

Triflusulfuron 0.08 0.0027 960 NA 0.000003 NA I 

NA = information not available or not applicable 

1 EEC refers to the Estimated Environmental Concentration, which assumes that a one-acre pond, six feet deep receives 5% drift from a one-acre field and 5% 

runoff from a 10-acre field. 

2 Aquatic Invertebrate ECso values obtained from the 2010 EPA Ecotoxicology One-Liner Database. 

3 Risk Quotient is EECIECso. Risk Quotient Balded if> 0.5 = Level of Concern [criteria from EPA Ecological Effects, Rejection Analysis] 

4 EC50 value is from a study using a 25.6% ai concentration. 

s Toxicity values are from the Trinuralin Reregistration Eligibility Document. United States Environmental Protection Agency, April 1996. 

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Table 4-3 Comparison of Potential Effects of Glyphosate and Sugar Beet Herbicides on Aquatic Plants 

(Algae and Duckweed) 

Max. Iblacre EEC' 

Aquatic Plant EC50 (a. i.)' Aquatic Plant Risk Classification 1 Label 

Range Quotient' Warnings Active Ingredient (single appl.) (ppm) (ppm) Range 

low high worst best 

Glyphosate 1.125 0.038 0.8 38.6 0.047 0.001 

Clethodim 0.09 0.003 1.34 >11.4 0.0023 <0.0003 May pose hazard to federally 

listed endangered plants. 

Clopyralid 0.25 0.008 6.9 NA 0.001 NA 

Cycloate 4.0 0.134 NA NA NA NA 

Desmedipham 1.2 0.040 0.044 >0.33 0.909 <0.123 

EPTC 4.2 0.141 1.36 41 0.104 0.003 

Etholumesate 3.6 0.121 >2.76 >39 <0.044 <0.003 

Phenmedipham 0.6 0.020 0.19 >0.32 0.106 <0.064 Toxic to aquatic organisms. 

Pyrazon 7.3 0.245 0.17 >4.6 1.441 <0.053 

Quizalolop-p-ethyl 0.17 0.006 >0.082 >1.77 <0.069 <0.004 

Sethoxydim 0.47 0.016 >0.27 >5.6 <0.059 <0.003 Toxic to aquatic organisms. 

Trifluralin 0.72 0.024 0.015 5.0 1.60 0.005 Extremely toxic to aquatic 

invertebrates. 

Irrillusulfuron4 0.08 0.0027 0.0028 0.123 0.96 , . 0.022 - J 

NA = information not available or not applicable. 

1 EEC refers to the Estimated Environmental Concentration, which that a one-acre pond, six feet deep receives 5% drift from a one-acre field and 5% runoff from 

a 10-acre field. 

2 Aquatic EC5G values obtained from the 2010 EPA Ecotoxicology One-Liner Database except for the values for phenmedipham which are from the Reregistraflon 

Eligibility Decision lor Phenmedipham .. 

3 Risk Quotient is EEC/EC50. Risk Quotient Balded if> 1.0 = Level of Concern [criteria from EPA Ecological Effects. Rejection Analysis]. 

4 Toxicity values are from the Regulatory Note REG99-03 from the Pest Management Regulatory Agency of Canada. 

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In a recent risk assessment supporting establishment of certain new food crop tolerances for 

glyphosate, EPA estimated that chronic (daily dietary) exposure to glyphosate from all food and 

water sources would use only 2 percent of the glyphosate RfD (1.75 mg/kg/day) for the general 

US population and 7 percent of the RfD for the highest potentially exposed subgroup population 

(71 FR 76180, 2006). 

The cumulative impacts from use of glyphosate on sugar beets was considered. , 

Biomonitoring of pesticide applicators conducted by independent investigators has shown that 

bodily adsorption of glyphosate as the result of routine, labeled applications of registered 

glyphosate-based agricultural herbicides to crops, including to glyphosate tolerant sugar beet, 

was thousands of times less than the allowable daily intake level established for glyphosate 

(Acquavella et aI., 2004). Given similarity to current use pattern, herbicide label rates, and the 

percentage of cultivate acres for sugar beets, the continued use of event H7-1 sugar beet 

through partial deregulation will not significantly increase the exposure risk to pesticide 

applicators. Furthermore, EPA, the European Commission, the WHO, and independent 

scientists have concluded that glyphosate is not mutagenic or carcinogenic, not a teratogen nor 

a reproductive toxicant, and that there is no evidence of neurotoxicity associated with 

glyphosate (EPA, 1993; EC, 2002; WHO, 2004, and Williams et aI., 2000). 

Bystander exposure to glyphosate as a result of pesticide application to event H7-1 sugar beet 

would be negligible, since such applications would occur in an agricultural setting in relatively 

rural sugar beet fields, not in an urban setting. 

Presented below is an brief, comparative analysis of the hazard/risk characteristics of 

glyphosate, the active ingredient in Roundup WeatherMAX@ herbicide (EPA Registration No. 

524-537), to the most commonly used herbicides applied in conventional sugar beet production, 

based on total pounds of active ingredient applied (USDA-NASS, 2001). A detailed assessment 

of the potential chronic human health risks compared to traditional products will not be 

presented in this comparison. The assessment is based on information obtained from various 

sources, including product-specific labeling, EPA Reregistration Eligibility Documents (RED, 

EPA, 1993), EPA RED Fact Sheets, product-specific Federal Register publications, the EPA 

® Roundup UltraMAX is a registered trademark of Monsanto Technology LLC 

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Ecotoxicology One-Liner database42, the USDA Pesticide Properties database43, and other 

public sources of product-specific toxicological and environmental profile information. The 

assessment shows that in the majority of cases, weed control with glyphosate, formulated and 

sold as Roundup WeatherMAX herbicide, in the event H7 -1 sugar beet system offers the benefit 

of less risk from potential exposure for applicators and handlers of concentrated product and a 

reduced potential to impact non-target species and water quality. 

Table 4-4 provides a comparison of product-specific labeling for herbicides commonly used for 

weed control in sugar beet production, including required precautionary statements associated 

with acute exposure hazards and environmental risk concerns. Although most alternative 

products carry the same signal word as Roundup WeatherMAX herbicide (CAUTION), the 

associated precautionary statements of each of the alternative herbicide products are indicative 

of toxicity findings that represent a greater acute exposure risk than Roundup WeatherMAX. 

Nearly every sugar beet herbicide product evaluated has more restrictive requirements for the 

use of Personal Protective Equipment (PPE) than those required for Roundup WeatherMAX 

herbicide, indicating a greater need to reduce the risk of acute exposure, and, in some cases, 

the risk of longer-term or chronic exposure, for applicators and handlers of these other products. 

The comparative analyses provided in this section are summarized in Table 4-5 and show those 

areas for which glyphosate (designated with a checkmark v'), using Roundup WeatherMAX 

herbicide in the comparison, offers the benefit of potential risk reduction compared to the most 

commonly used sugar beet herbicides in sugar beet production. In this cumulative comparison, 

glyphosate offers potential benefits over all the traditional sugar beet herbicides in at least one 

and up to four risk assessment categories. These comparisons demonstrate the benefits to 

applicators, mixers and non-target organisms from the use of glyphosate in the event H7-1 

sugar beet system. 

4.4.5 Summary of Potential Cumulative Impacts from Increased Use of Glyphosate 

When conSidering the impact that the use of glyphosate in the event H7-1 sugar beet system 

could have on the human environment in conjunction with the use of glyphosate in other 

glyphosate tolerant crops already being cultivated in the same affected environments, the facts 

suggest that this use will have little or noadditive effect Additionally, use of glyphosate. 

42 EPA Ecotoxicology One-Liner database: http://www.ipmcenters.org/Ecotoxlindex.cfm 

43 USDA Pesticide Properties database: ttp:/Iwww.ars.usda.gov/Services/docs.htm?docid=14199 

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Alternatively, this has the potential to reduce risks to the affected environment from the use of 

other, more harmful, herbicides. This is supported by the assessment of the environmental and 

worker safety hazards associated with glyphosate when compared to other available herbicides 

used for weed control in sugar beet production. Based on such an assessment, EPA granted 

reduced risk status for this use of glyphosate, and expedited the review of supporting residue 

data. Therefore, there is no reasonably anticipated adverse cumulative impact on human health 

or the environment from the use of glyphosate associated specifically with the deregulation of 

event H7 -1 sugar beets 

For a discussion of coexistence of H7-1 and conventional beta species crops, see Sections 1.6 

and 2.4.. 

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Active 

Ingredient(s) 

Glyphosate 

Clethodim' 

Clopyralid 

Event H7-1 

Draft ER 

Table 44 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison / Exposure Mitigation 

Max. Ib 

Label Sugar Beet ai/acre Max. lb. 

Product Signal PHI' (single ai/acre 

Brand Word (days) appl.) (season) 

Roundup Caution 30 1.125 6 

WeatherM 

AX 

Select 2 Warning 40 0.09 0.25 

EC or 

Prisim 

Stinger Caution 45 0.25 0.25 

162 

Label Precautionary Statements 

/ Special Directions / Other 

Information 

Causes moderate eye irritation. 

Harmful if inhaled. Do not store in 

steel. Four resistant weed 

biotypes confirmed to date. 

Causes substantial, but temporary, 

eye injury. Harmful if swallowed or 

inhaled. Potential skin sensitizer. 

Warnings and precautions for 

runoff and drift. Use of the product 

may pose hazard to federally listed 

endangered plant species. 

Warnings for repeated use leading 

to selection of resistant weed 

biotypes. Crop injury warnings. 

Causes eye injury. Harmful if 

inhaled or absorbed through skin. 

Warning for leaching to 

groundwater under certain 

conditions. Crop injury warnings 

for 1) use of treated plant material 

or manure from animals grazed in 

treated areas, as mulch or 

compost; and 2) spreading of 

treated soil. Up to 18-month 

rotation restrictions to many crops 

due to risk of injury; field bioassay 

recommended. -_ .. 

Applicator and Handler PPEb 

Required to Mitigate Exposure 

Risks 

Long-sleeved shirt, long pants, 

shoes plus socks. When handling 

this concentrated product or its 

application solutions of 30% or 

greater, must also wear chemicalresistant gloves. 

Long-sleeved shirt, long pants, 

shoes plus socks, chemicalresistant gloves, protective 

eyewear. Do not reuse heavily 

contaminated clothing. 

Long-sleeved shirt, long pants, 

waterproof gloves, shoes plus 

socks. 

-

Cumulative Impacts 

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Table 44 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison / Exposure Mitigation 

Active 

Ingredient(s) 

Cycloate 

Desmediphamd 

L. __ 

Event H7-1 

Draft ER 

-

Product 

Brand 

Ro-neet 

Betanex 

'--- - , 

Max. Ib 

Label Sugar Beet ai/acre 

Signal PHI' (single 

Word (days) appl.) 

Caution NA; preplant 4 

incorporation 

Caution 75 1.2 

-

Max. lb. Label Precautionary Statements 

ai/acre / Special Directions / Other 

(season) Information 

4 Harmful if swallowed. Avoid 

contamination of food orfeed. Soil 

incorporation or soil injection 

required. Crop injury concerns 

dependent on soil type. 

1.92 Harmful if swallowed. Causes 

moderate eye irritation. Prolonged 

or frequent repeated skin contact 

may cause allergic reaction. This 

product contains the toxic inert 

ingredient isophorone. This 

product is toxic to fish. Do not 

apply where runoff is likely to 

occur. Sugar beet injury possible 

under many situations. 

163 

Applicator and Handler PPEb 

Required to Mitigate Exposure 

Risks 

Long-sleeved shirt. long pants. 

chemical-resistant gloves, shoes 

plus socks. Added PPE in 

California for a non-closed system; 

for mixers/loaders: chemical 

resistant clothing, full face 

respirator; for applicators: 

coveralls, plus half-face respirator, 

93 gallon limit for 21-day period. 

Long-sleeved shirt, long pants, 

chemical-resistant gloves, shoes 

plus socks, protective eyewear. 

I 

Cumulative Impacts 

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Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison I Exposure Mitigation 

Active 

Ingredient(s) 

Desmediphaml 

phenmedipham 

EPTC' 

Ethofumesate 

Event H7-1 

Draft ER 

Product 

Brand 

Betamix 

Eptam 

Nortron 

Label 

Signal 

Word 

Warning 

Caution 

Caution 

Max. Ib 

Sugar Beet ailacre 

PHI' (single 

(days) appl.) 

75 1.2 

NA; preplant 4.2 

incorporation 

or very early 

postemergen 

ce 

90 3.6 

Max. lb. Label Precautionary Statements 

ailacre I Special Directions I Other 

(season) Information 

1.92 Causes substantial, but temporary, 

eye injury. Harmful if swallowed or 

absorbed through skin. This 

product contains the toxic inert 

ingredient isophorone. This 

product is toxic to fish and aquatic 

organisms. Drift and runoff ... may 

be hazardous to fish and aquatic 

organisms. Physical hazard: 

Combustible. Sugar beet injury 

possible under many situations; 

evening applications 

recommended. Rotation restriction 

of 120 days for cereals. 

5.6 Harmful if swallowed. Avoid 

breathing spray mist. 

Incorporation or soil injection 

required unless applied through 

irrigation. 

4 Harmful if swallowed, inhaled or 

absorbed through skin. Rotation 

restrictions of 6 to 12 months for 

crops other than sugar beets or 

ryegrass. Do not graze livestock 

on treated crops. 

164 

Applicator and Handler PPEb 

Required to Mitigate Exposure 

Risks 

Long-sleeved shirt, long pants, 

chemical-resistant gloves, shoes 

plus socks, protective eyewear. 

Long-sleeved shirt, long pants, 

chemical-resistant gloves, shoes 

plus socks. 

Long-sleeved shirt, long pants, 

waterproof gloves, shoes plus 

socks. 

Cumulative Impacts 

7/28/2010 
Active 

Ingredient(s) 

Pyrazon 

Quizalofop-pethyl 

Sethoxydim' 

Event H7-1 

Draft ER 

Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison 1 Exposure Mitigation 

Max.lb 

Label Sugar Beet ai/acre .. Max. lb. 

Product Signal PHI' (single ai/acre 

Brand Word (days) appl.) (season) 

pyramix DF Caution 0 7.3 7.3 

Assure II Danger 45 days, 0.17 0.17 

except 60 

days for 

feeding of 

tops 

Poast Warning 60 0.40 0.8 

165 

Label Precautionary Statements 

1 Special Directions 1 Other 

Information 

Harmful if swallowed, inhaled or 

absorbed through skin. Avoid 

breathing dust or spray mist. 

Causes moderate eye irritation. 

Significant crop injury warning 

statements, depending on soil 

moisture level, soil type (organic 

matter content, loam, sandy, etc.), 

and temperature at time of 

application, application method, 

and tank mix products. 

Causes severe eye irritation. May 

irritate skin, nose and throat. May 

be harmful if absorbed through 

skin, swallowed or inhaled. This 

product contains petroleum-based 

distallates. Rotation restriction of 

120 days for crops not labeled. 

Need spray adjuvant added. 

Causes substantial, but temporary, 

eye injury. Harmful if swallowed. 

This product is toxic to aquatic 

organisms. Crop injury warnings. 

Multiple confirmed resistant weed 

biotypes. 

Applicator and Handler PPEb 

Required to Mitigate Exposure 

Risks 

Long-sleeved shirt, long pants, 

chemical-resistant gloves, shoes 

plus socks. Do not reuse clothing 

heavily contaminated with this 

product's concentrate. 

Long-sleeved shirt, long pants, 

chemical-resistant gloves, shoes 

plus sock, protective eyewear. Do 

not reuse clothing heavily 

contaminated with this product's 

concentrate. 

Coveralls over short-sleeved shirt 

and short pants, chemical-resistant! 

gloves, chemical-resistant I 

footwear, protective eyewear, 

chemical-resistant headgear for 

overhead exposure, chemicalresistant apron for cleaning, 

mixing, loading. 

Cumulative Impacts 

7/28/2010 
Table 4-4 Alternative Herbicides for Weed Control in Sugar Beets - Label Comparison 1 Exposure Mitigation 

Max.lb 

Label Sugar Beet ai/acre Max. lb. Label Precautionary Statements Applicator and Handler PPEb 

Active Product Signal PHI' (single ai/acre 1 Special Directions 1 Other Required to Mitigate Exposure 

Ingredient(s) Brand Word (days) appl.) (season) Information Risks 

h"rifluralin9 Treflan Caution NA; one 0,72 4.0 Causes moderate eye irritation, Long-sleeved shirt, long pants, 

HFP application harmful if swallowed, potential skin shoes plus socks, chemicalbetween first sensitizer. This product contains resistant gloves, protective 

true leaf and aromatic hydrocarbon and can be eyewear, Do not reuse clothing 

6 inch stage extremely toxic if swallowed, This heavily contaminated with this 

pesticide is extremely toxic to product's concentrate, 

freshwater marine and estuarine 

fish and aquatic invertebrates, Soil 

incorporation required within 24 

hrs of application, Crop injury 

warnings. Crop rotation 

restrictions ranging from 5 to 21 

months, Confirmed multiple 

resistant weed biotypes, 

~riflusulfuron Upbeet Caution 60 0,008 0,08 Resistant weed biotypes; multiple Long-sleeved shirt, long pants, 

MOA resistance, Need spray chemical-resistant gloves, shoes I 

adjuvant added. plus socks, 

NA indicates not applicable, 

, PHI- Post Harvest Interval. 

PPE - Personal Protective Equipment. 

, Based on recent clethodim tolerance action (67 FR 46893, Final Rule, July 17, 2002) percent-crap-treated market data necessary to refine chronic dietary 

exposure estimates; per label statement: concern for risks to endangered plant species. 

d 1996 desmedipham RED: concern for Margins of Exposure (MOE) for dermal exposure to miXers and loaders; additional concern for applicator inhalation 

exposure to wettable-powder formulations requiring limits on application rate per acre and number of acres treated per day; low to moderate chronic risk to birds. 

, 1999 EPTC RED; 10x FOPA UF retained due to neurotoxic effects; developmental neurotoxicity study required; reversible Cholinesterase inhibitor; Tier 3 

refinements using average residues and percent crop treated data for chranic dietary assessment; concern for risk to applicators and handlers fram dermal and 

inhalation exposure; concern for risks to small mammals and non-target plants, including endangered species from run-off and spray drift. 

f Based on recent sethoxydim tolerance actions (66 FR 51587, Final Rule, Oct.10, 2001), aPAD includes additional 3x FOPA UF for acute exposure to females 

13+ yrs of age, due to fetal effects seen in rat developmental tox study; antiCipated residues and percent-crap-treated data necessary to refine chronic exposure 

assessment. 

9 1995 Trifluralin RED: concern for cancer risk to applicators, handlers and field workers; moderately to highly toxic to fish and aquatic invertebrates; chronic risk 

concern for birds due to evidence of egg cracking in avian study. 

Event H7-1 

Draft ER 166 

Cumulative Impacts 

7/28/2010 
Table 4·5 Potential Reduction in Risk from Use of Glyphosate Compared to Traditional Herbicides Used in US Sugar Beet Production 

Active Human Health Risk Non·Target Species Risks Groundwater 

Ingredients 1 Contamination Aquatic Aquatic Acute Chronic Mammals Fish Invertebrates Plants Avian 

Clethodim or or or 

Clopyralid or or 

Cycloate or or or or 

Desmedipham or or or 

EPTC or or or or 

Ethofumesate or or or 

Phenmedipham or 

Pyrazon or or or or or 

Quizalofop·p· or or or 

ethyl 

Sethoxydim '" '" or 

Trifluralin '" '" '" or '" or 

Triflusulfuron '" 1 Traditional herbicides are compared to glyphosate, using the label from Roundup WeatherMAX herbicide . 

./ Indicates there is a potential for reduction in risk category by using Roundup agricultural herbicides. 

Event H7·1 

Draft ER 167 

Total Number of Areas I 

for Potential Risk 

Reduction 

3 

2 

4 

3 

4 

3 

1 

5 

3 

3 

6 

1 

Cumulative Impacts 

7/28/2010 
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Appendix A 

Willametle Valley Specialty Seed Association (WVSSA) specialty seed production 

isolation guidelines and Columbia basin vegetable seed field isolation standards 

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Appendix A 

7/28/2010 
WVSSA Specialty Seed Production Isolation Guidelines 

Beta species (Beets and Swiss chard) 

Must be pinned at the Beta species maps 

Four Separate Groups: Sugar beets, Table beets, Fodder beets, Swiss chard 

Between one O.P. and another of the same color and group 

Between Hybrid of the same color and group 

Between Hybrid and O.P. of the same color and group 

Between different colors within a group 

Between stock-seed and a Hybrid within a group 

Between stock-seed and O.P. within a group 

Between Hybrids of different groups 

Between Hybrid and O.P. of different groups 

Between GMO's and any other Beta species no closer than 

(And is excluded from exception to lessen this distance) 

Brassica species (Fall types - 9 chromosomes) 

Includes: Cabbage, Kale, Kohlrabi, Brussel Sprouts, etc. 

Between O.P. of the same color and group 

Between O. P. of different color 

Between O.P. cabbage and non-heading cultivars 

(Savoy, Kale, Brussel Sprouts, Collards and Cauliflower) 

Between Hybrids and Hybrids and O.P. of the same color and group 

Between Hybrids and O.P. of different colors or group 

Between Hybrid cabbage and non-heading cultivars 

Brassica species (Spring types - 6 groups) 

1 mile 

1 mile 

2 mile 

3 mile 

2 mile 

3 mile 

3 mile 

4 mile 

3 mile 

1 mile 

2 mile 

2 mile 

2 mile 

3 mile 

3 mile 

1 Turnip types - 10 chromosomes (Japanese type, purple top, strap leaf, Shogoin) 

2 Chinese Mustard types - 10 chromosomes (komatsuna, mizuna, mibuna, tatsoi) 

3 Chinese Cabbage types -10 chromosomes (heading, semi-heading, non-heading) 

4 Pak Choi types - 10 chromosomes 

5 Choi Sum types - 10 chromosomes 

6 Indian Mustard types - 18 chromosomes (Florida broadleaf, southern giant curled, 

red mustard, Chinese mustard, leaf mustard) 

SPECIAL ATIENTION MUST BE PAID TO THESE CROPS AS THERE IS A VERY WIDE 

RANGE OF PHENOTYPES THAT CAN CROSS. IF THERE IS ANY DOUBT, CHECK 

WITH THE OTHER COMPANY REP. BEFORE PINNING & PLANTING. 

Between any 10 chromosome and any 18 chromosome types 

Between O.P. of the same group 

Between O.P. of different groups 

Between Hybrids or Hybrids and O.P. of same group and phenotype 

Event H7-1 

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Physical separation 

1 mile 

1.5 mile 

2 mile 

Appendix A 

7/28/2010 
Between Hybrids of different groups or phenotype 

Between Hybrids and O.P. of different groups or phenotype 

Brassica species Canola 

Must be grown under permit from Oregon Department of Agriculture. 

GMO type CanDia or Rapeseed is not allowed to be grown 

2.5 mile 

3 mile 

between any other specialty seed crops. 3 mile 

Allium cepa (Onion) 

Male parent used to pin hybrids 

Onion Hybrid 

Between Hybrid and O. P. of different color 

Between Hybrid and O.P. of same color, different shape 

Between Hybrid and O.P. of same color, shape and type 

Between Hybrid of same color, shape and type 

Onions Open Pollinated 

Between Hybrid and O.P. of different color or shape 

Between O. P. of different color 

Between O.P. of same color, but different shape 

Between Hybrid of same color and shape 

Between O.P. of same color, type and shape 

Allium fistulosum (Bunching Onions) 

Between another variety of fistulosum 

Allium porrum or Allium ampleoprasum (Leek) 

Between another variety of Leek 

Allium other species (Chives) 

Umbelliferous other species (Parsley, Dill, Parsnips, etc.) 

Between same types 

Between Hybrid and O.P. of similar types 

Between different types 

Rhaphanus sativus (Radish) 

Between O. P. varieties of same color and or shape 

Between Hybrids or Hybrid and O.P. type 

Between Hybrid and O.P. of different colors and or shape 

Between Red globes or from White tip type 

Between Long Red from any other Red type 

Between Any Red from any other White type 

Spinacit used to pin hybrids 

Between O. P. of the same leaf shape type 

Between O.P. of different leaf shape type 

Between Hybrid and O.P. type 

Event H7-1 

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2 mile 

2 mile 

1 mile 

3 mile 

3 mile 

2 mile 

2 mile 

1 mile 

1 mile 

2 mile 

3 mile 

no distance 

1 mile 

2 mile 

3 mile 

1 mile 

2 mile 

1 mile 

2 mile 

3 mile 

1 mile 

3 mile 

3 mile 

3 mile 

Appendix A 

7/28/2010 
Cichorium intvbus (Chicory) 

Includes: raddichio, chicory, witloof, fodder root 

Between O. P. type or endiva species 

Between Hybrids or Hybrid and O. P. type 

Cichorium endiva (Endive) 

Includes: endive, escarole, frizze 

Between D.P. type Dr intybus species 

Cucumis sativus (Cucumber) 

Types: Slicer, Pickle, White spine, Black spine, Beta alpha. 

Between O.P. of the same type 

Between O.P. of different type or spine color 

Between Hybrid and O. P. type 

Between Hybrid of different type or spine color 

Cucurbita species (Squash) 

Includes: pepo, moshchata, mixta, maxima 

Between Similar types, shape and color 

Between Same or Different species 

Between another Hybrid of similar variety 

Between Hybrid and O.P. of similar type and shape 

Between O. P. or Hybrid of different type, shape or color 

Flowers 

All Flowers need to be pinned 

1 mile 

2 mile 

1 mile 

1 mile 

2 mile 

3 mile 

3 mile 

1 mile 

1 mile 

1 mile 

1.5 mile 

2 mile 

Between ones that cross pollinate 1 mile 

Includes: Chrysanthemums, Sunflowers, Helianthus, Poppies, etc. 

Multiple non-crossing flowers at one location can be pinned with one pin denoting flowers 

Consult company representatives on general pinned flower locations 

All other seed crops need to be pinned. 

For isolation distances consult company representatives 

WVSSA 

Specialty Seed Production 

Pinning Rules 

To facilitate communication and protect the specialty seed industry in the Willamette and 

Tualatin Valleys of Oregon, isolation mapping procedures have been drafted and agreed upon 

Event H7-1 

Draft ER 196 

Appendix A 

7/28/2010 
by the Willamette Valley Specialty Seed Association (WVSSA). The procedures and isolation 

distances as outlined below have been set up to ensure quality seed production of all 

vegetable and other specialty seed in the designated areas from potential cross pollination. 

The isolation control area of interest referred to as the Wrllamette and Tualatin Valleys 

includes the counties of; Multnomah, Washington, Clackamas, Yamhill, Polk, Marion, Benton, 

Linn, and Lane. 

Maps 

The association has four separate maps for the purpose of pinning and maintaining 

appropriate isolation distances. There are two for non-Beta species, and two for Beta 

species. The maps are then divided by the North and South valley isolation areas. They are 

established at four different locations as follows: 

Non-Beta Species Locations 

Map1 - North Valley Pinning 

OSU Extension Service Marion County Phone: 503-588-5301 

At: 3180 Center NE, Salem, Oregon 97301 Room 1361 

Map 2 - South Valley Pinning 

OSU Extension Service Linn County Phone: 541-967-3871 

At: 104 4th Ave SW, Albany, Oregon 97321 Room 102 

Beta Species Locations 

Map 3 - North Valley Pinning 

West Coast Beet Seed Phone: 503-393-4600 

At: 2380 Claxter Rd NE, Salem, Oregon 97303. 

Map 4 - South Valley Pinning 

Betaseed, Inc. Phone: 541-926-0161 

At: 34303 Hwy 99 E, Tangent, Oregon 97389 

The non-Beta types are to be pinned at the non-Beta locations in respect to their valley area. 

The North map is for pinning isolations: Including and North of Township 9 South. 

The South map is for pinning isolations: Including and South of Township 9 South. 

Fields located within Township 9 S. must be pinned on both North and South maps. 

The Beta types are to be pinned at the Beta locations in respect to their valley area. 

The North map is for pinning isolations: Including and North of Township 11 South. 

The South map is for pinning isolations: Including and South of Township 12 South. 

Pinning Procedures 

To identify production fields for location on the map, pins and flags will be used to mark the 

isolation. On the non-Beta maps, different color flags are used to separate the major crop 

types. 

1. Must have approved pinning rights and abide by the guidelines of the WVSSA. 

2. Observe the dates covered under the priority pinning. 

3. Check for acceptable isolation distance on the maps. 

4. Use proper flag to pin the field. 

Written on each flag will be: Party name, Crop type, Hybrid or O.P., Legal location. 

5. Fill out pinning card at time of pinning. 

Event H7-1 

Draft ER 197 

Appendix A 

7/28/2010 
6. At non-Beta maps, have Extension personal date stamp card and place in lock 

box. 

7. At Beta maps, pin as set up at each location, date stamp card and place in lock 

box. 

8. Contact any companies involved if isolation guidelines are in question. 

Pins will be placed as close to the center of the field to be planted as possible. This will be done 

to facilitate proper isolation distances to other fields. The isolation is not valid if that isolation is 

pinned incorrectly. 

The map cannot be pinned until an established agreement has been made with the grower for 

planting the crop. The map cannot be pinned on a speculative basis in order to reserve 

isolation. Upon cancellation of an intended production prior to planting the pin must be removed 

within 5 days. Upon abandonment of an established production, the pin must be marked failed. 

A penalty may be assessed of $50.00 if in violation and payment is required to remain a 

member in good standing. 

Pinning Priority 

The WVSSA allows the grower to hold the right to the isolation in his perspective farming area 

for the following year, to produce the same crop within a one-mile radius to the prior year's 

isolation. The grower maintains the right to elect the contracting company. The isolation right, 

known as a prior year's priority can only be held for the specific grower until the dates specified 

below. 

A prior year's priority is only valid until the following dates: 

For non-Beta species: Annuals - March 1st Biennials - August 1st 

For Beta species: Transplants - February 1st Direct seeded - August 1st 

After these dates, all isolations are available on a first come basis. 

Pinning Rights: 

The contracting company or responsible seed representative, who is a member of the WVSSA, 

may do the pinning. The intent is for the contracting company or responsible seed 

representative to do the pinning. The representative appointed by a company may also do the 

pinning if the company is a member of the WVSSA. Oregon State University is considered here 

as a non-due paying member that has pinning privileges. 

The contracting company or responsible seed representative with a grower agreement acts as 

the grower's appointed representative in establishing the isolation. Individual growers are to 

allow their contracting company or responsible seed representative who is a member of the 

WVSSA, to establish the isolation. Growers are allowed to be members of the WVSSA 

and would be considered as a responsible seed representative and as a member would be 

allowed to pin isolations for their farms under their own agreements. The contracting company 

or responsible seed representative agrees to abide by the pinning and isolation guidelines of the 

WVSSA. 

New pinning parties need to contact an officer of the WVSSA for eligibility approval a 

membership is required prior to pinning. The responsible party may be required to have 

membership approval by the association. The association may elect to appoint a representative 

to meet with the new parties at the appropriate isolation map to clarify pinning practices. 

Event H7-1 

Draft ER 198 

Appendix A 

7/28/2010 
Membership and Pinning Fees: 

The member or responsible party for the seed is subject to fees as established by the WVSSA. 

Fees are inclusive of the WVSSA annual membership dues of $150.00 per year, or a 

Homestead membership fee of $5.00 per year. The pinning fees are; $10.00 per OP crop, 

$25.00 per Hybrid crop, and $25.00 Multi-crop fee. Annual dues for the current year and 

pinning fees for the prior year's pinning are assessed at the beginning of each year. If dues and 

pinning fees are not received, pinning rights may be revoked. 

A multi-crop fee may apply when producing multiple crop species of an OP in one location, and 

one acre or less. Only one per member is allowed and is intended for research farms, and 

small commercial farms used for seed production. The multi-crop fee is not a pin, crop pins 

must be used to pin different species, and multi-crop must be designated on each card turned 

in. 

A Homestead membership fee and no pinning fees may apply for a Homestead non-voting 

member when producing in one location non commercial OP seed crops. Intended for the seed 

saver this member is not eligible for the pinning priority and is required to follow WVSSA rules 

and to be accompanied by a designated appointee when pinning the map. Crop pins must be 

used to pin different species, and Homestead must be designated on each card turned in. 

Exceptions Agreements 

There are two exception agreements, the Isolation Distance Encroachment, and the One Year 

Isolation Deferral. The Encroachment exception applies to an established crop isolation where 

one company agrees to allow another company to produce a like crop under less than the set 

isolation distance. The deferral applies to an established crop isolation where one grower and 

company agrees to allow another grower and company to produce a like crop for one year, and 

the established grower retains the isolation priority. 

The parties involved prior to planting a specific crop must agree upon any exception to the 

established isolation for the specific crop year. The exception agreement needs to be in writing 

annually and to include the right to the isolation the following year. There are exception 

agreement forms available for this use. All parties must agree and all other WVSSA isolation 

rules must be followed. 

Securing Isolations 

At all maps a system of cards and a lock box will be used and parties using the maps must 

follow the WVSSA rules. Fields must be currently identified for both the past and present crop 

year. Failure to pull pins will result in a penalty under the WVSSA. 

At the non-Beta maps, at the time of opening the lock box, a representative from two different 

companies of the WVSSA, in addition to an Extension Agent, are required to be present. The 

lock box will be emptied annually when the prior crop year's map is cleared. 

At the Beta maps, the procedures for pinning must be followed at each location. The cards will 

be date stamped, except not by an Extension Agent, and placed in lock box. The lock box can 

only be opened and will be emptied annually by two members of the WVSSA. 

The purpose of the lock box is: 1.To use as the archive and formal record of posting of pins. 2. 

To review established pinning priority rights. 3. To be used for pinning dispute resolutions. Any 

discrepancies over pinning locations will be solved through the cards. The cards will be used 

for accuracy of pinning and in case of arbitration. Pinning cards will be archived indefinitely. 

Event H7-1 

Draft ER 199 

Appendix A 

7/28/2010 
Arbitration 

Should all precautions fail in preventing potential cross-pollination problems between seed 

companies or responsible seed representative, and or growers, the WVSSA suggests the 

following system or arbitration: Fields not pinned will be considered at fault in event of 

arbitration. If the parties agree to arbitration by the three-person committee, they agree to abide 

by the committee's recommendation. The two contesting seed companies or responsible seed 

representative, in consultation with their growers, each chooses an outside field representative 

from the WVSSA. The arbitrators, A and B, are suggested to a neutral facilitator who notifies 

them of their. role. They do not know whom they represent and together choose a third 

committeeman. Arbitrators A, Band C agree to hear the facts of each seed company. 

Maximum would be two representatives on each side of the issue. After both parties present 

the facts, only the arbitration committee, A, Band C, remain in the room to discuss the facts 

fully. They agree to a solution before leaving the room and the chairman will deliver the 

recommendation immediately to both parties. 

Columbia Basin Vegetable Seed Field Isolation Dates 1 

With a valid "release"', vegetable seed company representatives may reserve fields for 

vegetable seed production as follows: 

Annuals and carryover onions' 

Onion and other biennials 

(except carrots) 

Carrots and fall planted annuals 

February 1 or closest weekday 

thereafter 

March 1 or closest weekday 

thereafter 

June 1 or closest weekday 

thereafter 

1 These dates for crops are as per agreement at the January 21, 2005 meeting of the Columbia 

Basin Vegetable Seed Field Representatives Association. 

, A release must include the production company, crop, and crop year for placement in 

Columbia Basin production and either the number of fields or number of acres. 

, Carryover onion crops may be repined with priority between February 1 and March 1, after 

which priority is lost. 

Columbia Basin Vegetable Seed Field Isolation Standards' 

Event H7-1 

Draft ER 200 

Appendix A 

7/28/2010 
All genetically modified crops will be designated as GMO. 

CARROT FAMILY (Ap;aceae) 

CARROT (Pinned by Group and Type) 

Groups: Hybrid and Open Pollinated 

Types: Chantenay (Danvers, Red Cored, Royal, etc.) 

American Market (Imperator, etc.) 

Early (Amsterdam, Baby Carrot, etc.) 

Medium (Nantes, etc.) 

Late (Flakkee, Berticum, etc.) 

Round and Odd Shapes (Paris Forcing, etc.) 

Oriental (Usually short Chantenay shape) 

Distance: Between Hybrids ......................................................................... 2 miles 

Between Hybrids and Open Pollinated ................................. 2 miles + 

Between Types within Groups .............................................. 1 mile 

Between Varieties of same Type .......................................... '/;, mile 

Between same Varieties for different companies ................. Y; mile 

Off-color carrots shOUld be grown outside main production area and pinned by color with a 

minimum isolation distance of 5 miles from other colors. 

• Note: A 3 mile isolation will be permitted between Hybrid and Open Pollinated carrots where 

requested. 

PARSLEY Between all Types and Varieties .......................................... 1 mile 

CORIANDER (cilantro or Chinese parsley) Between all Types and Varieties 1 mile 

MUSTARD FAMILY (Cruciferae) 

RADISH (Pinned by Group and/or Type ... Understood to be O.P. unless otherwise noted) 

Groups: 

Types: 

Event H7-1 

Draft ER 

Hybrid and Open Pollinated 

Round Red 

Round Red Forcing 

Crimson Giant 

Round Red White Tip 

Half Long White Tip 

Long Red 

Icicle (and related forms) 

Round White 

Purple 

Black 

Other 

201 

Appendix A 

7/28/2010 
• Standards as of March 1, 2006 as agreed upon by the Columbia Basin Seed Field 

Representatives Association. Revised 03/06. 

RADISH Cont'd. 

Daikon (assumed to be white rooting type unless specified) 

Daikon Sprouting 

Daikon, Red 

Daikon, Green 

Distance: ............................................................................................. Between Hybrid and 

Open Pollinated ............................................................................. 2 miles 

Between any red Type and any white type ........................... 2 miles 

Between any round white, icicle Type, purple, black, or any 

Daikon Types and any other radish ...................................... 2 miles 

Between Round Red, Crimson Giant, Long Red, round White Tip, 

and Half Long White Tip ....................................................... 1 mile 

Between Daikon, Sprouting, and any other Daikon of same color 1 mile 

Between Round Red and Round Red Forcing ..................... y" mile 

Between Round Red Varieties (unless negotiated between companies) y" mile 

RAPESEED 

Canola and other Oilseed Types .............................................................. 3 miles 

Genetically modified Canola and other Oilseed Types will be designated as GMO 

OTHER CRUCIFERS (Pinned by crop name and chromosome number) 

All Groups or Types ................................. _ ................................................... 2 miles 

ONION FAMILY (Alliaceae) 

ONION (Pinned by Group and Type) 

(Allium cepa) 

Groups: Hybrid and Open Pollinated 

Hybrid: (Should be posted as male parent) 

From Hybrid or O.P. of different color ......................................................... 3 miles 

From Hybrid or O.P. of same color, but different shape (Le. Globe vs. Flat) 2 miles 

From O.P. of same color and shape ........................................................... 2 miles 

From Hybrid of same color, but different shape ........................................... 2 miles 

From Hybrid of same color, shape, and Type (Le. Yellow Spanish vs. Yellow Spanish) 1 mile 

From Allium fistulosum, Chives, or Leek ...................................................... None 

Open Pollinated: 

From Hybrid or O.P. of different color or shape .......................................... 3 miles 

From O.P. of same color, but different shape (Le. Yellow Globe vs. Yellow Ebenezer) 2 miles 

From Hybrid of same color and shape ......................................................... 2 miles 

Event H7-1 

Draft ER 202 

Appendix A 

7/28/2010 
From O.P. of same color, but different Type (i.e. Yellow Spanish vs. Yellow Globe) 

miles 

1 Yz 

From O.P. of same color, Type, and shape (i.e. Yellow Spanish vs. Yellow Spanish) 1 mile 

From Allium fistulosum, Chives, or Leek ...................................................... None 

(Allium fistulosum) 

Open Pollinated: 

From Allium cepa, Chives, or Leek .............................................................. None 

From another variety of Allium fistulosum (i.e. Tokyo Long White vs. He-Shi-Ko) 1 mile 

ONION Cont'd. 

Hybrid: 

From any O.P. or Hybrid A. fistulosum ...................................................... 2 miles 

(Allium cepa-fistulosum cross) CFC 

tetraploid double chromosome 

Open Pollinated: 

From Allium cepa or Allium fistulosum of the same color ............................ None 

From Allium cepa or Allium fistulosum of a different color ........................... None 

From another Variety of CFC of the same color .......................................... 1 mile 

From another Variety of CFC of a different color ......................................... 3 miles 

CHIVES 

From Allium cepa, Allium fistulosum, or Leek .............................................. None 

From another Variety of chives .................................................................... 1 mile 

LEEK 

From Allium cepa, Allium fistulosum, Chives ............................................... None 

From another Variety of Leek ...................................................................... 1 mile 

GOOSEFOOT FAMILY (Chenopodiaceae) 

BEETS 

Between all Beets, Swiss Chard, and Mangels ........................................... 3 miles 

Sugar Beet Types: 

Diploid 

Tetraploid 

From Sugar Beets of the same or different Type ......................................... 2 miles 

Genetically modified Sugar Beets will be designated as GMO 

Even! H7-1 

Draft ER 203 

Appendix A 

7/28/2010 
Appendix B 

West Coast Beet Seed Company protocol for genetically modified (GM) seed production 

and GM grower guidelines 

Event H7-1 

Draft ER 204 

Appendix B 

7/28/2010 
PROTOCOL FOR GENETICALLY MODIFIED (GM) SEED PRODUCTION 

(Direct-Seeded, Transplants, Nurseries, Plots) 

DETECTION 

1. West Coast Beet Seed Company will request the help of Members to set up assay for 

QC (detection) of Roundup Ready (RR) gene in sugar beet seed lots. 

2. West Coast Beet Seed Company will, from time-to-time, add additional assay of QC 

(detection) for other events as needed. 

3. West Coast Beet Seed Company will conduct the assay for QC of RR on all RR seed 

lots. For the protection of West Coast Beet Seed Company and to learn if the processes 

are meeting the desirable criteria, random testing of non-GMO seed lots will be 

conducted. West Coast Beet Seed Company may consider using zones, based on 

distances from the GM source, for determining this random testing. Members have the 

option of requesting all of their lots be tested. Members have the option of requesting 

this information in written form. 

4. The shipping document will indicate that the shipment contains GM seed. 

5. West Coast Beet Seed Company assigns a lot number to the potential seed lot prior to 

the item being planted. This number stays with the seed lot and becomes a permanent 

record for this lot. 

6. West Coast Beet Seed Company will inform members of all past events grown so 

members can test their seed lots. 

ISOLATION 

1. West Coast Beet Seed Company's goal is to develop an agreement with sugar beet, 

chard, and red beet seed companies to avoid cross contamination and to develop a 

program to inform each other as to the locations of present and past GM and non-GM 

seed productions. 

2. Within a three mile radius of any RR field, West Coast Beet Seed Company will monitor 

for any volunteers in any fields used for sugar beet production, over a minimum of the 

past five years or until no volunteers are observed. 

3. West Coast Beet Seed Company will monitor GM fields for a minimum of five years or 

until no volunteers are present. This will protect chard, red beet, and sugar beet seed 

production in the area. The removal of the volunteers will be done under the supervision 

of West Coast Beet Seed Company representatives and recorded in a log book. The 

costs will be shared between West Coast Beet Seed Company and the grower. 

4. West Coast Beet Seed Company will maintain a minimum three-mile isolation between 

GM and non-GM sugar beet production. The isolation between GM 

pollinators/productions where the same event is present will be a minimum of one mile. 

Event H7-1 

Draft ER 205 

Appendix B 

7/28/2010 
The isolation between sugar beet, chard, and red beet will be a minimum of three miles 

until an agreement can be reached with the other companies. 

STOCK SEED/STECKLINGS/SEED TAGS 

1. West Coast Beet Seed Company has adopted an orange color tagging system to 

visually identify GM material (GM stock seed, GM stecklings, GM seed in tote boxes, 

cotton or burlap bags, GM seed samples, and member's shipping containers). The 

orange colored tags identify the product as GM and it is to be treated according to the 

protocol. In respect to each Member company's policies, GM material going to or 

coming from West Coast Beet Seed Company will be tagged with the preferred 

identification of that member company. 

Member Requirements: 

1. Prior to GM stock seed being shipped to West Coast Beet Seed Company, the members 

will send a document (Movement Traceability Form) identifying the stock seed items (I. 

D. code number, etc.) that will be GM. 

2. Each GM stock seed bag arriving from members will already contain an orange tag 

marked in writing, stating it is GM seed. The stock seed bags can also contain the 

Member company's GM identifying colored tag, code, symbol, etc. 

A. If stock seed arrives and there are any inconsistencies in the paperwork, orange 

tagging, non-orange tagging, or any other inconsistency of labeling, the 

warehouse personnel will notify the Manager and the seed will be put on hold 

until the member clears the issue and backs it up with the proper documents. 

The seed will be stored on a separate pallet in the GM portion of the warehouse. 

The pallet will be marked clearly in a manner to prevent it from being prepared 

for planting. 

West Coast Beet Seed Company's Requirements: 

1. The GM stock seed will be stored separately from the conventional stock seed. The 

area will be in the main building, along the east wall, near the Warehouse Manager's 

office and will be identified in a clear manner. 

A. Non-GM seed will be stored in the northwest warehouse, of the main building, by 

the main dock. 

2. The GM stock seed will be prepared for grower disbursement in the main building, along 

the east wall, near the Warehouse Manager's office. 

A. A sample of the GM stock seed will be held in a separate area of the warehouse 

for five years. This sample will be labeled with the orange colored tag and the 

preferred identification of the member company. 

3. Once the GM stock seed is prepared for the grower, it will be labeled with an orange tag 

indicating to the grower that they have in their possession GM seed. 

Event H7-1 

Draft ER 206 

Appendix B 

7/28/2010 
4. Accompanying the GM stock seed will be a written document declaring that the seed is 

GM. 

5. The stock seed for GM and non-GM productions will not be transported to the growers in 

the same vehicle at the same time. The field staff will be trained properly at least once a 

year in the handling of GM seed and all seed movement will be documented. 

6. The field supervisors are responsible for collecting the remaining stock seed from the 

growers immediately after planting. The Warehouse Manager will log in the stock seed. 

When GM stock seed is returned from the growers after planting, sealed bags will be 

returned to the member. Opened bags will be incinerated at the County garbage 

burning facility to prevent use of potentially grower-contaminated seed. 

The Member will be informed, in writing, of the amount, location, and date destroyed. 

The Member also will be informed, in writing, as to amount being returned to them. 

GM NURSERY 

1. The GM nursery will be kept separate from the conventional nursery. 

A. The owner of the nursery ground will have given West Coast Beet Seed 

Company written permission to plant GM stock seed. 

2. The GM stock seed for the nursery will be handled the same as any other GM stock 

seed (Information from member, orange tag, stored in separate area, etc.) (see above 

"STOCK_SEED/STECKLINGS/SEED TAGS"). 

3. The digging eqUipment will be completely clean of any stecklings before entering or 

leaving the GM nursery. West Coast supervisors will sign a document stating they have 

personally inspected the equipment after cleaning and found it to be free from any 

stecklings. 

4. All GM stecklings will be stored in sacks that are marked with a GM orange tag. The 

stecklings will be stored in a cooler or warehouse separate from non-GM stecklings. 

5. There will be a separate GM observation nursery and it will be isolated in the area where 

GM productions of the same event(s) are being grown. 

GROWING THE CROP 

(Planters, tillers/fiail, sprayers, separators, male removal, 

swathers, combines, tote boxes, hauling, tarpsllids) 

Any equipment (planter, transplanter, sprayer, flail, tiller, tractor, irrigation equipment, vehicle, 

separator, clipper, swather, combine, tote box, post-harvest tilling equipment, seed cleaning 

equipment, or any other equipment) must be monitored, treated,., cleaned, and the process 

documented, according to West Coast Beet Seed Company's policies. 

Event H7-1 

Draft ER 207 

Appendix B 

7/28/2010 
The intent is to prevent seed, pollen, or stecklings from being transferred out of the area of 

control or transferred to where they could contaminate other Beta species productions (details 

of the methods are found in other parts of this protocol), 

1, West Coast Beet Seed Company will use only designated totes for GM seed harvest by 

growers, Phase one will be metal totes only, Phase two will be metal totes and 

designated wood totes, 

A. During transportation, the totes will be covered with a West Coast Beet Seed 

Company approved high-quality tarp or high-quality lid, 

2, Trucks transporting commercial GM seed will not carry non-GM seed on the same load, 

3, Growers will not be allowed to transfer bulk seed to totes at third party locations 

(Le, grain elevators) unless, in the opinion of West Coast Beet Seed Company 

and upon approval of the member company(ies), the seed can be transferred in a 

manner that would allow complete and easy transfer without contamination of 

equipment or surrounding area, To avoid spillage, growers must not transfer 

seed from one tote to another. 

4, Any pesticide application made during the flowering period needs to be done by aerial 

applications, If aerial application is not possible, then West Coast Beet Seed Company 

will use its operator and modified equipment to spray, If the grower has high clearance 

spray equipment that does not leave his farm, then we can consider using this 

eqUipment 

The Member will be notified in advance as to which productions West Coast Beet Seed 

Company will use its equipment for spraying after flowering begins, 

5, When the GM production is in bloom, any person who enters the field (grower or their 

workers if they would be going to any other Beta species production, West Coast Beet 

Company staff or temporary workers, Member or their representatives), will wear 

disposable coveralls, They are to be removed and disposed of after each use, The 

disposable clothing will be stored in a separate, closed container so that live pollen 

cannot escape the area or be transferred into another field, 

A. Clean, disposable, coveralls will be kept in a closed container prior to use, 

These coveralls will be furnished at West Coast Beet Seed Company's expense, 

West Coast Beet Seed Company's field supervisor is responsible for the 

disbursement of the disposable clothes, for having people wear them, for training 

people how to dispose of them, and finally to control the good use of them, 

SEED CLEANING, STORAGE, SHIPPING CONTAINERS, 

AND SCREENINGS DISPOSAL 

1, GM seed will be delivered in designated totes, The totes will be affixed with all 

appropriate tags, including a GM orange tag which will designate it as containing GM 

seed, 

Event H7-1 

Draft ER 208 

Appendix B 

7/28/2010 
A. These totes will be stored in a designated portion of the warehouse(s) physically 

separated from non-GM seed. The seed will also be unloaded in a separate area 

and only GM designated and marked equipment (brooms, conveyors, etc.) will be 

used for GM seed. 

B. The field-run samples also will be affixed with a GM orange tag and these 

samples will be stored separately from non-GM samples. This requirement will 

be added to the scale house procedures and policies. Scale house personnel 

will be trained in these procedures, each year, prior to seed delivery. 

2. West Coast Beet Seed Company will, in the beginning years, utilize one or two of the 

cleaning lines to process GM seed. The GM seed will be cleaned at the end of the 

processing period to avoid potential problems. 

A. The Company shall not clean conventional and GM seed simultaneously, except 

in an emergency. In the event of an emergency and the Company must clean 

conventional and GM seed simultaneously, a physical barrier, such as a plastic 

wall, shall be put in place to avoid contamination. 

B. All cleaning equipment will be thoroughly cleaned prior to and after cleaning GM 

seed. This will ensure that all GM seed has been removed from equipment prior 

to any non-GM seed being introduced after that point. (Detailed instructions of 

cleaning the equipment are already in place). 

C. A permanent log is kept for the cleaning sequence. 

3. West Coast Beet Seed Company will draw a representative clean seed sample and tag it 

with a GM orange tag. 

A. Part of this sample will be tagged with a GM orange tag and sent to Agri Seed 

Testing for germination and purity testing. Agri Seed Testing will be informed 

that the seed is GM. Agri Seed Testing holds their samples for three (3) years 

and then will destroy them by incineration in the County garbage burning facility. 

B. Part of the sample will be tested via the QC assay method for the event(s). (This 

will be expanded to include how this information will be disseminated). See 

DETECTION category number 3, paragraph 1 above. 

C. A minimum of one (1) pound will be stored in a separate area for five years 

labeled with an orange tag and the preferred identification of the member 

company. 

D. Members at their request will be sent their requested amount of properly labeled, 

clean seed samples. 

4. Screenings from GM production will be delivered to either the pellet mill or composting 

facility. 

Event H7-1 

Draft ER 209 

Appendix B 

7/28/2010 
A. West Coast Beet Seed Company will check yearly with the pellet mill company to 

see if the feed pellets will be sold where GM is presently not allowed (Europe)44. 

West Coast Beet Seed Company will keep members informed on the result of 

this discussion. 

B. In the future, regulated screenings can be delivered to a landfill if required. 

5. Shipping of GM seed to members will be in new containers (boxes, poly tote bags, etc.). 

The containers will be affixed with a GM orange tag and the preferred identification of 

the member company. Shipping containers (cardboard boxes and poly bags), because 

they are known to hold some seed in crevices, will not be allowed to be reused at this 

time. Therefore, West Coast Beet Seed Company would prohibit GM shipping 

containers from being returned for reuse. 

A. The paperwork that goes with the seed will indicate seed in truck contains GM 

seed. 

B. For the protection of West Coast Beet Seed Company and its members, GM and 

non-GM seed will not be shipped on the same truckload to the Members' 

facilities. 

GM GROWER GUIDELINES 

The policy for the grower guidelines will include the following revised reqUirements: 

1. The policy will be a part of the Grower Contract. 

2. The grower will have only a GM production (of one event) or a non-GM production; not 

both in a given year. This applies to growers who grow only for West Coast Beet Seed 

Company and to those growers who grow for both West Coast Beet Seed Company and 

another sugar beet seed company. 

A. The grower will not raise a GM crop and a chard or red beet seed production in 

the same year. 

3. The grower will use precaution in the field to eliminate seed from remaining loose on the 

transport deck prior to leaving the field. 

A. Clean off deck of loose seed prior to leaving field. This is part of the protocol that 

will be reviewed with the Grower. 

B. (West Coast Beet Seed Company will work on designing a method to prevent 

seed from falling between boxes. We may also promote bulk hauling to the plant 

and transfer to boxes). 

4. Grower cannot use/share any equipment that might be used in a non-GM sugar beet, 

chard, or red beet seed production in the same growing year. 

44 Import of food and feed products derived from Roundup Ready sugar beet event H7-l 

was approved by the European Union in October, 2007. 

Event H7-1 

Draft ER 210 

Appendix B 

7/28/2010 
5. Grower cannot use same combine to combine GM sugar beet, non-GM sugar beet, 

chard, or red beet seed in same year. 

A. The grower will combine 200 acres of another crop between combining any beta 

species. 

6. We want a rotation of five crop plantings since the last beta species was grown on the 

field for seed. 

7. Grower training on all aspects of GM growing handling will be conducted by 

management and field staff. 

RECORD KEEPING 

1. West Coast Beet Seed Company will continue to maintain a permanent GPS 

computerized mapping system to record all productions including year, item number, 

and lot number. 

2. West Coast Beet Seed Company maintains a yearly and ongoing computerized log 

where all important activities of the production are recorded (Crop Tracker). The Grower 

may collect information, but the final responsibility for this data collection is the field 

supervisor. 

3. Crop histories of herbicide and crop are collected each year prior to planting. 

4. West Coast Beet Seed Company will develop a method for tracking all movement of GM 

seed from the time West Coast Beet Seed Company receives the stock seed, to 

the final processing and shipment to the member. This information will be 

communicated to the members upon request. The members may also request 

additional information when necessary for stewardship of the GM crops. 

INSPECTION 

New disposable clothing will be used by West Coast personnel, grower, custom contractor, and 

member company personnel when entering the field when pollen is present. After each use, the 

clothing will be discarded into a sealed container and then disposed of in customary container 

(garbage can, dump box). 

RISK ANALYSIS 

The protocol needs to be continually reviewed. During the review and handling of the crop, new 

areas of concern may become evident. When this occurs, the concern must be addressed and 

solutions implemented. Final approval of any changes to the contracts must be approved by the 

Contract Committee and recommended by the committee to the Board of Directors in a timely 

fashion. 

Event H7-1 

Draft ER 

TRAINING 

211 

Appendix B 

7/28/2010 
1. All West Coast Beet Seed Company employees will be trained in all areas of the 

protocol. Date, time, personnel attending, type of training and instructor should be 

recorded for all training sessions and appropriately filed. 

A. West Coast will train personnel on these policies and procedures. Written 

training documents will be reviewed and approved by the board. 

2. West Coast Beet Seed Company employees that deal with specific areas will have 

extensive and continual training in the specific area. 

3. Both West Coast Beet Seed Company growers and personnel will be trained in the 

relevant areas of the protocol. Date, time, attendees, type of training and instruction 

should be recorded for all training sessions and appropriately filed. 

4. Part of the training will include the following West Coast Beet Seed Company policy: 

Operators discovering evidence of spillage or GM seed out of place immediately will 

inform their supervisor, the head of department, and the West Coast Beet Seed 

Company Manager. At first evidence of the problem, appropriate action will be taken to 

halt the release of any additional seed, pollen, or plant material. The problem will be 

evaluated immediately to prevent a reoccurrence. Appropriate individuals or companies 

will be informed of the situation. 

GM Grower Guidelines 

I. The following are guidelines to which all West Coast Beet Seed Company commercial 

growers are required to adhere in the contract production of genetically modified (GM) 

sugar beet seed. If questions arise with this production, contact West Coast Beet Seed 

Company's field men for clarification or explanation. 

Direct seeded and transplant productions will adhere to the guidelines, except with 

reference to transplanting. West Coast Beet Seed Company will perform the 

transplanting in winter/spring. 

A. Field Selection: Genetic purity is of the utmost concern with this type of seed 

production. Field selection encompasses many characteristics, but the main 

features that are necessary include fields with required isolation of at least three 

miles from non-GM productions and one mile between GM 

pollinators/productions, the least chance of having volunteer beets from previous 

productions, good fertility, favorable location (not likely to flood), available for 

timely plantings into pre-irrigated conditions, good irrigation systems, and good 

water availability. At a minimum, a rotation of five crops since the last beta 

species were grown for seed is required. 

B. Planting: Stock seed will carry an orange tag to indicate GM. The goal is to 

plant into fertilized, pH adjusted as necessary, and pre-irrigated fields to ensure 

timely establishment of desired stands. It is desirable to have a population of 4-5 

beets per foot of row in all lines for direct-seeded production. 

Event H7-1 

Draft ER 212 

Appendix B 

7/28/2010 
Stock seed normally is limited in supply, so close monitoring of seed drop is 

essential to establishing uniform stands across the entire planting. Stock seed 

will be stored safely to ensure no seed is lost inadvertently or released into the 

environment inadvertently. All unused stock seed will be returned to company 

personnel in a timely manner. 

Planters must be monitored both before and after planting to ensure that the 

proper seed is being planted. After planting, the planter and the tractor need to 

be cleaned in the field to remove 100% of the seed prior to moving the planter to 

another location. The intent is to prevent seed from being transferred out of the 

area of control or transferred to where it could contaminate other beta species 

productions. 

C. Irrigation: Fall irrigation of direct-seeded production should start after planting, 

as necessary, and continue through emergence and stand establishment. 

Spring irrigation of direct seeded and transplant production should begin as the 

soil moisture drops and crop growth requires supplemental moisture. Spring 

irrigation should continue as the crop grows and matures to the point that 

additional moisture is no longer beneficial to production of a quality crop. 

West Coast Beet Seed Company personnel will determine the timing of the last 

irrigation. 

Irrigation equipment will be cleaned of any live GM pollen before leaving the field. 

If this is not possible, then irrigation equipment should be left by the field for 24 

hours before moving to another location. 

D. Disposable Clothing Requirements: When the GM production is in bloom, any 

person who enters the field, and who may enter another Beta species production 

that same day, will wear disposable coveralls. These will be furnished at West 

Coast's expense and they are to be removed and disposed of after each use. 

This will prevent live pollen from being transferred to another field. 

E. Care of the Crop: The crop will be cared for in the best interest of obtaining a 

high quality and high-yielding production. Management practices of individual 

fields vary and shall be approved by West Coast Beet Seed Company's field 

staff. Recommendations by Company representatives will be carried out in a 

timely and efficient manner. 

1. Any pesticide application made during the fiowering period needs to be 

done by aerial applications. If aerial application is not possible, then West 

Coast Beet Seed Company will use its operator and modified equipment 

to spray. If the grower has high clearance spray equipment that does not 

leave his farm, then we can consider using this equipment. 

F. Pollinator Removal: Removal of pollinator in a timely manner is very important 

to production of high quality seed. Pollinator destruction will be completed within 

the time frame agreed upon with West Coast Beet Seed Company 

representatives. West Coast Beet Seed Company representatives will approve 

destruction methods and equipment. Equipment will not be used in another 

Event H7-1 

Draft ER 213 

Appendix B 

7/28/2010 
beet field until thoroughly cleaned of pollen andlor seed and inspected by West 

Coast Beet Seed Company field supervisor or his representative. 

1. Any equipment (flail, tiller, separator, tractor, vehicle) must be cleaned to 

kill all live pollen before leaving the field according to West Coast Beet 

Seed Company's policies. 

The intent is to prevent pollen from being transferred out of the area of 

control or transferred to where it could contaminate other Beta species 

productions. 

G. Swathing: Swathing will be done in a timely manner as directed by West Coast 

Beet Seed Company representatives. Swathers will be inspected by West Coast 

Beet Seed Company's field supervisor for cleanliness prior to and after cutting. 

Swathers will be cleaned in the field after swathing to ensure that no seed is 

released into any adjacent field or area. 

H. Combining: West Coast Beet Seed Company will approve the cleanliness of 

the growers combine. Before use, the combine must have threshed at least 200 

acres of another crop since it was used last to combine any other Beta species. 

Approval for grower combine usage will be determined on a case-by-case basis 

and will depend on previous crops combined and acreage. 

Combines must be cleaned before they leave the field to ensure no seed is 

moved into adjacent areas. Combined seed will be placed in designated tote 

boxes within the confines of the existing field. Grower will clean off the truck 

deck in the field to ensure seed is not spilled during transport. West Coast Beet 

Seed Company's supervisor will approve the cleanliness of the grower's combine 

before leaving the field. 

I. Bulk Seed: Growers will not be allowed to transfer bulk seed to totes at third 

party locations (i.e. grain elevators) unless, upon approval of West Coast Beet 

Seed Company, the seed can be transferred in a manner that would allow 

complete and easy transfer without contamination of equipment or surrounding 

area. To avoid spillage, growers must not transfer seed from one tote to 

another. 

J. Hauling Seed: All loads of seed shall be covered with West Coast Beet Seed 

Company approved, high-quality tarps andlor sealed with lids so no seed can be 

lost during transport. GM and non-GM seed will not be hauled 

simultaneously on the same truck. 

K. Post-Harvest Field Management: Fields will be shallow tilled after harvest to a 

depth of not more than 3". To promote sprouting of the shattered seed, full 

irrigation is required, unless a West Coast Beet Seed Company representative 

determines adequate rainfall has occurred to promote the required sprouting. 

Fields will not be fall plowed for any reason. Control of sprouted seed is 

essential to prevent any pollen release and seed formation in future crops. 

Event H7-1 

Draft ER 

All tractors and tillage equipment must be monitored and cleaned according to 

West Coast Beet Seed Company's policies before leaving the field. 

214 

Appendix B 

7/28/2010 
The intent is to prevent seed from being transferred out of the area of 

control or transferred to where it could contaminate other Beta species 

productions. 

L. Fields will be inspected by West Coast Beet Seed Company for a minimum of 

five years or until no volunteers are noted. 

M. All of these actions will be recorded at West Coast Beet Seed Company in order 

to establish a record of adherence to GM policy, whether the actions were taken 

by the grower, the company, or by both in a shared responsibility. 

Event H7-1 

Draft ER 215 

Appendix B 

7/28/2010 
Event H7-1 

Draft ER 

Appendix C 

International Seed Federation Code of Conduct 

216 

Appendix C 

7/28/2010 
Summary 

SEED IS LIFE 

_SF 

lnternationul Seed Feder iltion 

CODE OF CONDUCT 

(adopted by the ISF Sugar and Fodder Beet Commission) 

Principles of quality assurance in beet seed production. 

(Final version of 22 October 2007) 

The principles and measures highlighted in this paper aims to the adventitious presence of 

GM45 beet seed in conventional sugar beet and fodder beet, as well as the adventitious 

presence of other GMOs46 in GM sugar beet and fodder beet seed. The adventitious presence 

of GMOs can only be minimized but not totally excluded because seed production occurs in 

open fields under natural conditions. There is a strong necessity for practicable rules and 

regulations governing a high level of purity for seed of conventional varieties relating to 

adventitious presence of GMOs and for seed of GM varieties relating to adventitious presence 

of other GMOs. 

1. Objective 

The objective of this industry position paper for the quality assurance of sugar beet and fodder 

beet (hereinafter referred to as "beet seed") is to describe the measures the seed industry has 

taken to minimize the likelihood of adventitious presence of GM beet seed in conventional seed 

or adventitious presence of different GMOs in GM beet seed. The Industry recommends to 

apply the same measures to table beet and/or Swiss chard seed production'. 

This objective is accomplished by implementing guidelines and operating procedures 

(preventive measures) covering every step from the stage of R&D activities up to delivery of 

commercial beet seed to the customer. In addition to these measures, actions are undertaken 

to control the various steps of this process. 

2. Deregulation of GM beet events 

The status of deregulation of GM sugar beet events varies according to territories. Similarly, 

requirements set up by regulators may vary by country. Therefore prinCiples adopted by the 

industry must reflect these regional differences. 

45 GM: Genetically modified 

46 GMO: Genetically modified organism 

This code of conduct has up to now been agreed upon by the following companies: Danisco Seed, 

Dieckmann GmbH & Co. KG, Fr. Strube Saatzucht GmbH & Co. KG, Maison Florimond Desprez S.A.S., 

KWS SAAT AG, SESVanderHave, Syngenta Seeds and their affiliated companies. It is open for adoption 

by other seed companies producing sugar and/or fodder beet seeds. 

Event H7-1 

Draft ER 217 

Appendix C 

7/28/2010 
2.1. USA 

There are three GM sugar beet events which have been deregulated in the USA. One of the 

three events is commercialized since 2007. 

2.2. Europe 

No GM beet events are deregulated at this moment in Europe. As of today no 

commercialization of GM beet seed can take place in Europe. There is one sugar beet event 

undergoing the European deregulation process. This process has not been finalized. Similarly 

there is one fodder beet event undergoing deregulation but the process is still in progress. 

2.3. Other territories in the world 

There is one sugar beet event undergoing a deregulation process in certain countries. 

3. Adventitious presence of GM beet seed 

3.1. Adventitious presence in conventional seed 

Adventitious presence of GM sugar beet seed in conventional beet seed cannot be totally 

excluded. As of today, there are no official thresholds governing the adventitious presence of 

GM seed in conventional seed in Europe. There is an urgent need for such a threshold to be in 

place in Europe due to the rnarket introduction of the first GM sugar beet in the US. Thresholds 

will vary and some territories or countries may not regulate adventitious presence. 

Adventitious presence of GM seed in conventional seed would result from the presence of GM 

seed or GM plants in other beet seed production at some stage of seed production or 

processing. 

Three possible main sources of adventitious presence of GM seed in conventional seed 

productions are identified: 

• Spread of GM pollen to multiplications of conventional seed. 

• Unintentional mixing-up of plants during transplanting. 

• Unintended traces of GM seed during harvest, transport, processing or storage. 

Quality assurance systems have been implemented to address the issues posed by the 

adventitious presence. These consist in preventive measures and testing procedures for 

adventitious presence. They are presented in section 5. 

3.2. Adventitious presence in GM seed 

Adventitious presence of unintended GM seed in GM seed production would result from the 

presence of GM seed of another event in a production of a given event at some stage of seed 

production or processing of GM seed. 

Similar measures as above in point (3.1) are addressing this case. 

Event H7-1 

Draft ER 218 

Appendix C 

7/28/2010 
4. Pre-commercial and commercial production of GM beet seed 

4.1. Europe 

There are currently no pre-commercial or commercial productions of GM beet seed in Europe. 

Until now, production of GM beet seed in Europe is limited to R&D47 activities only. 

Quality assurance measures that would be taken in the future for commercial seed production in 

Europe will be focused on the separation of GM seed and conventional seed during the whole 

production procedure (e.g. multiplication and processing steps). 

In addition to this, tests for adventitious presence and traces of GM beet seed in commercial 

beet seed lots are performed. 

4.2. USA 

There are commercial productions of GM beet seed of one deregulated event in the USA. 

Quality assurance systems to prevent adventitious presence and traces of GM seed as 

presented in the data sheet of the Annex have been implemented by the seed industry. 

These measures are focused on the separation of GM seed and conventional seed during the 

whole production procedure (e.g. multiplication and processing steps). 

In addition to this, tests for adventitious presence of GM seed in the GM commercial seed lots 

were implemented (this refers to traces of another event in a GM seed production based on an 

intended event). 

5. Principles for preventive measures and testing procedures for adventitious presence 

in R&D, in conventional and in GM beet seed production 

This section describes main measures (preventive measures and testing procedures) to ensure 

a high level of purity for beet seed regarding Ap48 of GM. Three base cases cover all situations 

encountered either as producer of conventional seed or as producer of GM seed. 

The guidelines for preventive and control measures have thus been divided into three parts: 

1. R&D activities related to GM seed (all stages of the seed development up to the basic 

seed production) - Data sheet in Annex 1 

2. Production of conventional seed for commercialization - Data sheet in Annex 2 

3. Production of GM seed for commercialization - Data sheet in Annex 3 

The following sections outline general preventive and control measures to ensure a high level of 

purity regarding AP for conventional seed and/or GM seed. 

5.1 Preventive measures 

47 R&D: Research and development 

48 AP: adventitious presence 

Event H7-1 

Draft ER 219 

Appendix C 

7/28/2010 
Several principles are implemented in all types of activities and operations by each company: 

o A quality assurance system is implemented, whereby every GM plant material is recorded 

and can therefore be traced. 

o SOPS49 are written for all aspects of the handling of GM beet plants and GM beet seed and 

the staff is trained and briefed on their use and application. 

o Conventional and GM seed are handled separately, and specific labels or the unique 

identifier will be used for all GM material. 

o The above mentioned breeding companies have agreed in sharing information on the 

locations and traits of their respective GM seed production worldwide. 

5.2 Testing procedures 

o Testing for adventitious presence of GM in conventional seed lots and for unintended events 

in GM seed lots. 

o Exchange information on detection methods of such traits which are shortly before 

production. 

More detailed information can be found in the Annexes. 

Annex 1 

Data sheet for "R&D activities for GM and Non-GM (all stages of seed development up to the 

basic seed production of regulated and deregulated GM beet)". 

Preventive measures 

• All activities involving GM beet plants and GM beet seed are subject of national and 

international regulations which are adhered to by the breeding companies. 

• By sharing information between breeding companies about the locations and traits of their 

respective GM seed production, companies will have the opportunity to redefine their 

location of seed production in case it is located close to a conventional seed or another GM 

event production area. 

• Minimum of four years of rotation between GM beet seed-crop and conventional beet rootcrop. 

o Isolation distance of at least 1.5 miles between GM and conventional or other GM event 

seed production. 

• Bolting plants of Beta species are removed within a radius of at least 1000 m around GM 

multiplications before flowering. 

• SOPs are written for all aspects of the handling of GM beet plants and GM beet seed and 

the staff is trained and briefed on their use and application. 

• Transport of GM seed only in closed containers or bags. 

o Storage of GM seed in dedicated areas separated from conventional seed. 

• Careful cleaning of all machinery is carried out before and after each step in the production 

process of a GM seed lot or separate production lines (different GM, Non-GM) are used in 

the production process. 

o Monitoring for volunteer beets is done at fields or locations used for GM seed production 

• Shallow post harvest tillage 

49 SOP: standard operating procedure 

Event H7-1 

Draft ER 220 

Appendix C 

7/28/2010 
Testing procedures 

• Seed lots are tested for the adventitious presence of GM and GM seed lots for unintended 

GMO before shipment to third parties, for example: 

o Testing of conventional seed lots used for variety trials. 

o Testing of GM seed lots used for variety trials. 

o Testing of conventional seed lots used in field trials by research institutes and/or 

industry. 

o Testing of GM seed lots used in field trials by research institutes and/or industry. 

• Basic seed lots used for commercial production are tested by either PCR or immunological 

tests and/or herbicide application in case of herbicide tolerance traits. 

• Seeds are sampled after harvesting or before pelleting according to internationally accepted 

sampling techniques. 

Annex 2 

Data sheet for "Production of conventional beet seed for commercialization" 

Preventive measures 

• The above mentioned breeding companies have agreed in sharing information on the 

locations and traits of their respective GM seed multiplications worldwide. 

• In addition, as part of the information sharing, breeding companies will exchange information 

on detection methods of such traits which are shortly before production. 

• Isolation distance of at least 1.5 miles between GM and conventional seed production. 

• Bolting plants of Beta species are removed before flowering within a radius of 1000 m 

around GM multiplications. 

• Minimum of four years crop rotation in seed production. 

• Separation of conventional and GM seed during processing 

• The order of lots processed and pelleted is thoroughly recorded. 

• Careful cleaning of all machinery is carried out before and after each step in the production 

process or use of separate production lines (GM, Non-GM) in the production process 

Testing procedures 

• Conventional seed lots are tested for adventitious presence of GM seed by either PCR or 

immunological tests and/or herbicide application. 

• Seeds are sampled after harvesting or before pelleting according to internationally accepted 

sampling techniques. 

Event H7-1 

Draft ER 221 

Appendix C 

7/28/2010 
Annex 3 

Data sheet for "Production of GM seed for commercialization" 

Preventive measures 

• All activities involving GM beet plants and GM beet seed are subject of national and 

international regulations which are adhered to by the breeding companies. 

• SOPs are written for all aspects of the handling of GM beet plants and GM beet seed and 

the staff is trained and briefed on their use and application. 

• The above mentioned breeding companies have agreed in sharing information on the 

locations and traits of their respective GM seed multiplications worldwide. 

• In addition, as part of the information sharing, breeding companies will exchange information 

on the appropriate detection method for GM traits. 

• A quality assurance system is implemented, whereby every GM plant material is recorded 

and can therefore be traced. 

o Isolation distance of at least 1.5 miles between GM and conventional seed production. 

• Bolting plants of Beta species are removed before flowering within a radius of 1000 m around 

GM multiplications. 

o The order of lots processed and pelleted is thoroughly recorded. 

• Careful cleaning of all machinery is carried out before and after each step in the production 

process or use of separate production lines (GM, Non-GM) in the production process 

Testing procedures 

o GM seed is tested by either PCR or immunological tests andlor herbicide application in case 

of herbicide tolerance traits. 

Seeds are sampled after harvesting or before pelleting according to internationally accepted 

sampling techniques. 

Event H7-1 

Draft ER 222 

Appendix C 

7/28/2010 
Event H7-1 

Draft ER 

Appendix D 

Sugar Beet Production by County and State 

223 

Appendix D 

7/28/2010 
Corrm:d:-:y Year Plii"Tied All Purposes HaNEsted y,<:ld ?rnduc:iD:t 1_~uC"C'5e. 

!Th~Jsards cf Ac:.;s) l""7hous3nds of A.cF-s) jTlJns) (7hcusands rnTons) '" : 

mE~.ifcm: ~=i~: ~i~~I' ID51J'''""~.'~' ~~ . ' 

2.:,roo, 

I 

, , ICo:,roo, 

I " 

I 

~ ho 

Event H7-1 

Draft ER 

2C 

20 

20 

""n 

, 

"oan 

IW,'d lOON,,,h,,,' 

.. I 

I i 

"."" 

~"I 

10 

224 

25, 

',gOO 

12,000 

111. 

,20 

lB,'O 2' 

3, 

;,0001 

27 

;>7, ' 

29,0 

31 

30, 

&'3,' 1 • 

16,00 

O},ODD 18.: 

177, 

17," 

3,1 ',31 

..!l: 

',S[ 

U 

I30,1 • 29,200 23,0 ''''200 

Appendix D 

7/28/2010 
Corrmcdiy Year Courrly Pliirl1e::l All ?urposes HaNE512d Y~d Frcduc:iccr Suc:-ose 

{Th:rJ'5an:::i5 d Ac:esj (Thou5an:::i: of ;'.cF-:5) lTor.;;) f7hou.sand5 of Ton5) {?el"Oln;;) 

~beets 

~~ 

Event H7-1 

Draft ER 

.. I 

" 

I. 

. h' ,~ 

25,400 

1,000 

~ 100 

1: 100 

50 BOD 

27.' 15. I 

25.. _1 15. 

~==~ 

,~ 

',BOD 

CD,IDO 20. 50 ,DOD 

eDO 33.: ,DOD 

2'. 

l' 

lB.3: 

17.1: 

17. 

l' 

~, , 

:~1B' 16, . 

, . 

"osg I ISh". Total 137,000 13G,.QQ11~~2B'I-__ ""3U,~"'0~OD----;1B*,,, ~ 

2G~ ?==€16~~, ~'~========+=======~"~00======:#'~~~=42,,~ .. ======~'~~iD~0'~~1i~ 2v,", I""'''" ",ODD ,700 25J 51 ,iOD 1 S, 

11.1,,,,,,11 41.500 , •. 

I"'onroo 39,100 ,DOD 24, 

IRed Lake 1200,100 25. 

11 0 N"J",~Sl " 

225 

Appendix D 

7/28/2010 
CorrmD:i::y Year Stale 

.. I ~ '0"" ~'''EIs 20:\3 

2008 

"00 O,'or.do 

"':\3 O,'orodo 

lor.'" 

lor.. 

IQ@: 

I 

I 

I , I 

20 I 

I 

~~ I j,ho 

"',. Id,ho 

'ho 

~ ii'I,,,,,, .. ,,,O 

•. '"" ' 

Event H7-1 

Draft ER 

1""""3 

,""dlaod 

County 

050 'em,,1 

;" ,"roo 

, " 

I,omn 

Pla:'11ed All rurpD!:2S 

iTh::r.lsan:::ls af Ac:-es) 

Haf'iES1Ed Yiad 

[Thousan:::ls cf,!..cres) lTDns) 

11 

OB .. 

'4.1 

.100 !OD 

, I-- , . I r------: 

I,D' 

, ''<1 

25'~'~~~====='~D,~;.!D~~DDII=4.""M.e·t===~~~. 17.' 

226 

15 

1: 

45 

21. 

115,5DD 

lDD 

DOD 

3DD 

lOD 

45, 

115i .1 

000 

.300 3D. 

300 ". 

3D.! 

-" . 2B: 

23' 

24. 

26. 

!OD 25.: 

'9.I'DD 23.0 

37,600 

Appendix D 

7/28/2010 
CorrroD:i:ty 

~beels 

Event H7-1 

Draft ER 

Year Siaie 

I I 

IiIi ' i 

" :aJiFcm 

, Ii· 

Ii. 

I 

I 

~"Ig~i:~: 

'. I 

1&'" m"d, 

,oa I 

I 

I 

orod 

'''' Ildaho 

,I " 

~, ' 

1051 Ean J"ox~ Va"ey 

I",~al 

,Total 

'acemoe 

~ 

i I 

1050 CO",," 

;01/ 

I, I:c'!'oan 

, . ~ 

, I, i::~.:: t=~-I~ : E>stCeol",1 

, ';000 GE"~ee 

I 

, . 

,;cl; 

20'" , 

I 

I 

, 

II 

II'io",""n 

~ 

PIa::1ted All ?Urp05ES 

lTh::rJ52nd::; cf Ac:-es) 

H,3r.~s\.ed '''Ed 

G'hol1san:5; of .!..c8S) lTor.s) 

227 

7,600 ", 

20.100 

,8OD 

I 

.100 

i 

ID,: 

ill 

eoo 

I 

f====ml", 

15,ID , 15, 

=~22674·,==~.~ '1 :::: 

24 54, 15," 

, 17: 

310 '," 

,DO 

1,3001 1,10 3D ,',-, 17 

2B" 

57, ",S[ 

37, 

b2;4'=~~54"'OI 17,10 

25. 2U 

Appendix D 

7/28/2010 
Corrm:>:l:::y Year S~ate COlJnt'j 

Pla:"e::l All rtJrpose:s 

{Thws;;ifids of At::1!s) 

~ 

4.400 

MOO 

Wilkin 45.100 

'\ i 

~H ... I,:,:nne"" 

HarvestEd 

(ihou5an:is 01 ,o!<..cEi) 

3,100 

I 

_25, 

Y'-Sd 

{Toru<) 

23, 

25.! 

25.' 

25.' 

, 1720 

00 17.40 

15.30 

.. 

i " 

i .i' 

2"'" II.l'n~n' 

2C'''''I.l'n~'' 

2C}J8II.l'n~n' 

~ ;-~"."n~n' 

, , 

2i)J8 ' 

2C''''!H,,,,, , 

20'" I"""" ~ ~J""fl'", ! 

~"'" 

~~ 

~~t~:=-: 

~~~ 

Even! H7-1 

Draft ER 

Ii . I 

" J 

s~ 

"." P",,'n; 

Stat. Tota' 

Ie 

~ , 

~ '~, 

.'~ , 

, 

, 

228 

it ! ' §I§ ~ 4,"0 SO.5OO 

3,7DDI ~ 15,80 

44 •. 000 -'~]I 2d 17.25 

~ 1&.3: 

lB,91 

17,: 

, iDO 

5,70 " .OOD 

AD ,100 

41, 34,300 ,5DO 

~r-______ ~"ao~iDO~~25~.I.~ ____ -7,~:.0~01D0r-'~17~ ~ eoo :M." TODI 17 

4~~==~~~~ll~'==~~~!~.~16~" 100 

, !DO 

12.5 17.5C 

26,: 17. 

15.", 

Appendix 0 

7/28/2010 
Corrm::.:jy 

Even! H7-1 

Draft ER 

Year $ia!a 

~ i 

2c.'L'8 ' 

2'{)8 , 

2~'" I"',b", <a 

2C{)8 , 

=I ,b""IG 

22 

22 

County 

11.10,"11 

IShe',,,,,n 

10 

;h''"' 

'''"' in; 

; 

1 N'nheas, 

II 

2~ 

P!a,:,::e:i PJI ~urpo=es 

{Tn:rJ,S,3I105 of Ac1:!s) 

229 

"I lE,goD 

,ODD 

I 

41 

28,1100 

20: 

, iOD 

, 'DO 

BOD 

, iDD 

iOD 

HarvestEd 

(Thou:ands of ;'..cEi) 

YcEd !=rcduc~iY1- I.~uc:cse. lTons) f7housands of Tons) IO:',e,,,,,,,:',1 

:;t '. 

2DS.5',fu: 

5' , !DD 

3,' 22 

~ 

3D,: • 

" ,",,51 I-- ----;;~ ___ ~3' • I--

, 4,1001 

~ 21 

'eoDI 24,' 

~I 23, 

41" 

'i 

'" 

" ~ 15.: 

14,70 

7( 

,," 

Appendix D 

7/28/2010 
CorrmD::>ry 

~b,e1s 

Event H7-1 

Draft ER 

Ye;;,r S:ate County 

I ' 

D3D 

61, Hem 

'0,3uo, 

~!I 

. ),kes G,,,,d Fmks 

: ~ w"s: 

~;;~~ C"h' 

ill 

, 

'on 

~ 

PJ;':;""t,e::! All ~rpo!:es Han"Ested Yad Prcduc;i:n SUc:<.:'SE 

jThD"Jsand5 of Ac1:s) (Thousands of ~.cr=sJ lions) fThlJl.lsands afTon:;) {?err81t) 

230 

4. 

440. 

5,' 

" 

E ~~ln~J lDO.'" " 

25.61 10} DO 17 

21,70 

20.1 23.: 

2<.4 

553 !DO 15 

! ., 17.15 

2 15.60 

15,7[ 

2~'1===2~:' ~2M=5,==~, gl!J.L ":" 

18,' 

, ' 

45,: 

27200 

40 

5,,'"0 

'I 

~~~Im' 

37,300 

,000 

2~ 26, 

41\4lili 2e, 

5,: 24. 

-", . "I 24., 

IQI. .30.1 

43.oOD 

m,OOO 

~'DDD 16, , 

16.18 

18.16 

15.7: 

17.3: 

16," 

15.30 

17.3: 

1{,3: 

15.09 

15.5' 

, 15.5' 

I~~, 17.45 

Appendix D 

7/28/2010 
~ 

lTD 

1098 

~ 

~ 

~=I 

Event H7-1 

Draft ER 

)3" , 

~ 

'''''=:'''''':=----t:'f' 

~ ill 

IPe;iins 

lTD 

" I 

231 

5.400 

5.OD' 

11·. 

'" i.'" 

• 

I 

I.'" 

4. 

'.1" 1:i 22.-

;;~:f----*; ;: 

~ ,. ;;a.......---,ii' 

15.' 

"'D' " 17. 

17.DD 

2. ' 

i 15.3: 

15.3: 

, 10.B4 

" 

14. 

702'.' 

. , 

1-, 

17.48 

, '.30 

Appendix D 

7/28/2010 
COlTmo:f.1y 

~be,ts 

Year Stale 

forni' 

, 

~']7 Colo"" 

'-007 Colo"" 

~." ~ ~': . r 

, I 

I 

Event H7-1 

Draft ER 

,I 10 

I 

I 

, I 

, . '",n i ' :gan 

i ':gan 

COUnt'! PI;;:",ea All PurpO!:-=5 HanrestEd Y'4d 

jTh::rJ5;:;!';::!5 cf Avas) (7housands of ,.;e;f:-5i iTo!';s} 

232 

'I 

05" .DDD 15." 

1 •. 

15. 

5.' :i ~: j~ OS. ~OD 

11~==~_. ~264l==_=:~::~,~: 

I, ~3.=tID§~4i""'ODD~'i:D: ~ . """.DDD 15.: . , , 15.4' , 

. 'DD 16.50 

, 16A8 

::i 15;1t~2D'C7'-' f----";""': 

5211t=~ ::.~¢==;:: 

2D.millt--_----;7, 

20000 

250 

750 

3.500 

'-'. 

25 .. 

20.01 

15.71 

1,ODD 

5001 

1,0001 20.0 

151LOOOI 

70 

Appendix D 

7/28/2010 
Corrmoi::y 

Event H7-1 

Draft ER 

Year S'ta!.e 

; 

20Cil I,,,,"" "" , I 

20, 

LV , Celorodo 

~, 

'C·07 Celorad, 

2~J7 Celor.d, 

Celorodo 

Colo",do 

~ ~ I 

, I 

11 

,c~ 

,., ' 

20 I 

I 

I 

County 

,I 

'tate '0'" 

I e~ 

Ie", 

tat. Total 

I ~ 

IPam" 

233 

;.1 

zs. 

3,2DD 

2200 

100 

2/. 2'.'1 

3, 

~ 20,11 

1~~+-__ '-,-"611i,, 

5 " 

17. 

1{, 

15.: . 

=l15~. 15.DE 

, 15-" 

, , 

15." 

15,5[ 

'~ 

,Ir,: 

Appendix D 

7/28/2010 
Year 

1( " 

d, 

2Ge"\,! " 

2~:e " 

20.' 

Stale 

, 

; 

.• i 

, c,r;,,,";, 

; 

~~~'& 

Even! H7-1 

Draft ER 

i' . 

; ,goo 

; , 

IP'" 

IDIO 

L",m;e 

IPI~te 

COlJnty 

I'WeTout 

ID70 ; 

I 

It,H,;d,', 

loaD 

i. 1m 

PJii'l'!ed AU rUrpoS€5 

{Tt1~.rsan:is of Ac<es} 

500 

200 

",7001 

1.000 

11,80 

Haniesled 

I::hDu5<1nds cf A.c8s) 

Y:$d 

iTo!',!;) 

g,goO 25, 

25,000 24. 

300 '0. 

'0.' 

21,100 2'. 

3,700 

200 ". 

OS, 

",-,DO 17." 

, , 

;.1: 

14.60' '-" 

15." 

15 

, --------,i ~ 

234 

12700 

42.30'1 

1, !ilr-' 

""mmr- ~r-~~" r-__ ~4~5; .. ~'0ID'~'_~',5 .. ' 

',600 ~., 16.' 

41,900 33.: 

10 

Appendix D 

7/28/2010 
Corrmro::y 

Even! H7-1 

Draft ER 

Year 

" 1 I 

I 

I 

" , 

, ; 

-State 

, 

, 

ST, 

I 

:,. 

11,11",-;;;0 

10(~ 

""'5iY~ 

Oil:, 11,11""0'"' 

10(, 

~ I~!ichia;;n " , 

Ccurrt'/ 

= IM,cc=d 

I~ 

= 

IDaii .. I 

sw. Total 

~ 

I 

I 

IG",,;, 

If.lidiaiid 

~ 

I. 

IA,ce." 

IHlliDii 

= 17u>o01, 

lOaD Soui'", C,nbl 

1D§O i 

l~ 

Ist,t, Total 

235 

n ' 

40.000 

t,,=It 

t •• : 

:>:,900 41, 

39.100 37, 

5: 

11 

2?, 

34. 

34. 

35, 

, mo '" 

3D. 

34, 

, ,2e[ 

:=rcdu~lo.-, SUc:"QS2 

[Thousands: of Tons) i?efC8l:) 

14', , 

,7[" l' 

,'DO 

44~ 17, 

17.5. 

t. 

j 

37,20' 

12.70' 

, . 

1521 

15, 

4 "DC i-

!,DDD 

, , 

"'1.000 

~ 

~ • n[ 

),0001 18,0[ 

H,B[ 

, , 

1I'15.ii 

" i5:ii 

18.1< 

'.S[ 

Appendix D 

7/28/2010 
CorrmD:::(:Y 

~ ~~ 

~ ~ 

~ ~o--

Year State 

i ,",,;0'" 

20J; Heb""",, 

"GOY Heb""",, 

'027 "'eb",18 

,. 

2C'}7 '~eb",18 

'D'OY Neb","" 

. fl; ",b",18 

. bra,,,, 

f-; ,. 

,. 

,. 

f-;' 

,. 

, 

Event H7-1 

Draft ER 

I 

I 

1020 

'u,"" 

"0 C 

Count'l 

Ocuo's 

P!iit1ed AU FurpoS€s 

.;ThD'Jsan::!s c; AC'Es) 

46 100 

'DO 

! 

144DO 

100 

I 

. 

9CD 

20 "'.' 

2T. "0 r 

25.: .DDD lB." 

27.1 .m; 15.0[ 

l=:lHl 

, ___ ----';'''''.31 25.: 15." 

1.0: =~'4.,==~ 15.6E 

50. 

236 

".2 -±. . 17. IE 

10.: 

Appendix D 

7/28/2010 
COIT'mDi:!ry Year State Count; 

Event H7-1 

Draft ER 

"",'50 

.=t.' 

""7~ 

"~ , '" inne:;cG 

"' i 'eo,,"'" 1096 ' ;, 

'nne,ola 'st,t. Tolal 

20 ,J ! 

DOc} 

"Xl, ' 

o CEn"" 

~'I , I, " I 

Pla1ied AJI ?urposes 

I.Th:).1san::S af Ac-"Es) 

237 

I 

15.1OD 

jj]j'O 

,., 

4, 

Han.;esled 

(7hoLJ:an::!s cf ;!,cr=s) 

I 

'8, , 

30,aoo 

1511 

10,400 

23,800 

2B, 

0, 

~ 

on 

;,70D 

0 

0 

17. 

15.E[ 

15.9[ 

15.37 

16.00 

15.c15.07 

15,68 

16,67 

; I I 

Appendix D 

7/28/2010 
Corrm~1y 

Event H7-1 

Draft ER 

Yeaf StrtE Countj 

'I 

i i 

I . Ita IMoL",d 

2D''' 1 

2W' 

onta03 

,"lana DaD CoMbined Counf", 

Cu"el 

]90 CDmbl"ed C''''5 

)90 Scu~e,,, 

leu 

I 11 

I 

PI~1ed All Furposes Har;ested Yi4d rrcduG':im SuC;'"cse 

{Th:rJ'san:is cf Ac.--es} (11ousands of ;'.c:r-:s) iTor.s) (Thousand~ ofTDrrsj ;?efC81tj 

238 

15'OOot ~===~l4t==~c::iiiii 3f eoo 20, 'AW 15.9[ 

5.9' 

, 

::18* , ,7001 , 

, 

41 , 

_4' 

i.I 

24. 

1" 

OM, 

21. 

'~~ .;t 00 ,",", f-----';""'""*I-"~"".--_"* ,300 27. 

§' ~~",~, ~,8001 , 

, , 

,I 

7. 7,<30 

a50 i 

,go 

,,920 

100 

22. 

3' . 

25. 

25: 

24.' 

23" 

19. 

-'t5 

! 

"'.000 

5,700 

;,~ 

15. 

15. 

21 

15.5' 

le, 

IE, , I--

'I--

I--

Appendix 0 

7/28/2010 
2C'}7 

~"- =Ii 

~=Ii 

Even! H7-1 

Draft ER 

.... ~ 

; 

~ 

I ' 

1020; i. 

lOaD Scuth I 

,pro,. 

; 

1090 &u~."i 

1St". Total 

KImball 

~" 

,; 

10 Combine' Ccunt"" 

239 

52.200 

5.500 

~ 

, 

i 

3.: 

24,3001 

1,78D 

4,920 

47.500 

,200 21 

3,320 

120 

24,1301 

24. 

05,' 

,720 ".1 

4,74D 24., 

24: 

'==~ "" 

25,: 

22, 

PI 

'----" 

, 

,~ 17.' 

17.7E 

-'h , 

, , 

'r 

, ' r-" 

, , , , 2. '200 

',OOD 

'·.BOD , 

"e 5,7001 ~ 515.'001 iKTIl 

--" 

1001 ; , 15K " . , 15,5< 

.'k! , 

, 

r---

Appendix D 

7/28/2010 
Corrm1»:,Y Ye5:r Stale 

20' 

~=ilo",oon 

~o, 

":~~i ~, 

~' . . 

2"J~ , 

i 

I 

. :::alifcmia 

C,lifoml, 

I 

:,Iifeml' 

I 

I 

y",,, 

ISt,t.' 

Ie,""." 

IElmo," 

I 

" F,"s 

County 

,~ 

Even! H7-1 

Draft ER 

ho 

i '"'" I' 

i ~~:Q .. n 

" 

P!;;nied AI! FurpoS€s Harvested Yf-:!d 

i!h;,;.rsan:G cf Ac:;:;s) (Thousan:!s of . .;cr:s) \Tons) 

Frcdur.':kn l~uC:'cse. (ThousandsofT~:m!i), . 

240 

'~ ~ 

2~ti , , 24: 

,ODD 

, 

=m'IS,,'-~ 

: ,1---, 

, f--, 

f--, 

2~r-______ ~''<~OO~2g~,~ _____ ~m"ID~'Dr-~~ 

500 ,GO 3D, " IDD 

, :00 40, 

~i~' ==:=::tir 

I====~~I ;;, 

33, 

33, 

31, 

LDOJ ' 

g 

"',DOD 

7S ,DOD 17: 

Appendix 0 

7/28/2010 
Corrm~:i;:y 

Event H7-1 

Draft ER 

Yeiir Courrty 

Il 

20J , 

2eG7 "yemlo; 

Stat •. 

I 

F"rrDno 

Pac, 

"/0,,1,., ~ i 

~11':fl:;!. JE!, ~ 

'yomln, 

~califum:' 

~ 

~ ~ Im:-=rial 

I 

~~ Stat. Total 

E·Jil Lo,a, 

22·" 3:::~;~ =l!: 

20]6 'do",', 

m:~;~ ~~ 

1o"", 

I 1)0 

I 

1080 

15irc~m 

PI;nied AJI PurpC9:S 

\Th~-,san::!;; cf Ac::-es) 

Han.'l:sted 

('hDusan:l5 c.f ;'.cI?.5) 

241 

17.Of 

., 

1'1=~2~1~·====~~~:.~0'D~DD=;~;l.:~a; 0' 21 .DDD 15." 

.BOD 

26~ 

23, ' 

I 

, , 

2: .. 

I~~~II' ::: 

Ji43, .,~ 

~ 000 

O~, .r_---.~,90~O-~~ .. ,r----~~.3D~'Dr-7.C15 .. ' i,1OD _'.' ,;DD 10.: 

600 24.1 . IDD 15.4' , 15.70 ,Hi 

" 'I 

21011= ;.O'D . , 

Appendix D 

7/28/2010 
Stale Count! 

~: 

~r- , 

~r-~ ,Ii I::::::: 

20C 'y",n;", 

20 ' '",""i", ,~ ~ ",,,,,in, 

~~~ , 

i 

. Ca!ifcmi 

~: , 

~ 

20:0 C,'orado 

~ ~~ ~ C,'orud, 

~ ~ ~ Colorodo 

, 'd"" 

, 

, , 

, 

, 

, 

, 

SuI. Toul 

:", 

Lin,,', 

i 

~w~ F,II, 

, , 

D20 Conbi,.d Coon'". 

4, 

,DOD 

15,100 

13,: 

11,0001 

,~ i]OOf 42, 

'AOO 

600 

13,eDO 

" 

43,1001 36, 

20 

",200 33, 

",DE 

~ ~ 

2E4,"OOI 

34, ' 

~ 15 

~ 

lB,3'. 

1721 

16.81 

1-' 

" . 

", 

4:,3D0 

267,000 

,~ 

15,70 

15," 

'RHl 

, ' 

, :i:@O~:'"~:=3~E;~;;'~~:~::~;~~'U~~"'''=====t======J'~~,,:en:D'I======='~ill;::I~;~:~ ____ ~~'; . :[C: 

2.,o,n '@: 1= 18:' 3" ' 

Event H7-1 

Draft ER 

~ l.y ~;~:;: 14,eool ;~, 2[>5,: , 

242 

Appendix D 

7/28/2010 
Corrmo.:!.1Y 

~ ~ 

ii 

~ 

~ 

~" 

'fear S!ale 

22" II'"'''' I 

.-

~ , 

" 

2<': 1(,. 1 

I" i 

Ji~ 

Ii. 

ii 

Ii· 

Worr 

.. 

::' ~ Ii· 

21], I 

I 

~I 

2"'6 Colo"" , I 

2"'" Colo",,,, 

m I , . 

, 

I ~ 

~" ~' 

2D'~ 

~r 

Event H7-1 

Draft ER 

2}2u 

.' nd 

I I 

St,t, 

o-::c"IIi:k 

eid 

ll.",; 

i I 

20~ 

IE.'n,-am 

1000 

ISt,t 

1050 em",1 

IE~I 

I"ornn 

PI;;;17ed All FUrp05€5 

{Th:r.rsan:!s cf Ac:-es) 

2" , 

HJn;esled 

l;nousan:!s of AcGos) 

11.eDOI 

26.1001 

10.' 

23. 

17. 

17.07 

~ "96 , 

. , 

, , , m 

25. ' 

5iD, mo 

. ~1---i7 ;;;;j--;~ ___ ~:;;;;'~::'+--f::C;:t'81O\ '] 15.DB , 

~ 43. 

, 

4. 4. 

.000 1.900 

15. 100 12.700 

600 BOO 

~ 

. 5OD 

'. 

18 . 

3.! 

243 

Hi;] 

CT. 

""-

25 . 

110.'0', 15.: 

34~ 

ST:~ 

I I .. 15]i 

I 

lI--

I-

,--

lI- '. I--

Appendix D 

7/28/2010 
CorrmD:i:iy Year S':au: 

gao 

, oao i . gan 

i 

2~ 

~ , 

~~o-+-: · I :0",,,° . ,"' I 

Event H7-1 

Draft ER 

\ inne;;c 

" 0"," 

I 

,I ~ 

Count'! 

:C"O'S 

Stat. To",' 

~, 1 

il,! 

."," 1 

I 

i Hem 

PI;;L'~ed AJI furpcs€!s Han."estE:d ''!':-;:jd frcduc::i:::n SUC:-:::'SE '""-":i ~-":J'-' ,"-'. ::::,-,: 

H 

244 

2,1 

51., 

Si 

uo 

0' 

1,3001 

2,100 

65,000 " 

2' 

,000 "Tal 

.. 0001 

15.' 

p 

,~ 

~ , 

I-

, , 

57.100 

Appendix D 

7/28/2010 
~ 

~ 

Event H7-1 

Draft ER 

Cowr.r; 

III ,"· ' 

. ill 

CQ • ,J C'~b;'~:' I 

. 0,,,,,-.3 R,o"", 

'y,,,, ,,' 

051 

I I 

I Ii 

I 

. d'ho Elno," 

PI;;:"1~e::l All fUtp05€5 

{Th~:Ganrls of AC"Es) 

31,¥ot 

lAODI 

245 

H3J"\1\:;Sted Y'ad ;:rcdu~i::L"1 I ~uC"i:se_ [Thousands of .~.cf2SJ Fnn;j (Thousands of Tons) 11?~~~) 

10, 

9,100 

1 

,5OD 15,91 

, ----; 

-

,-

78', 

. , , 

, 'A: 

, , 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

Year 

= 

, 

, . 

~ 

2( 

20w 

1 

1 

I, 

, 

t; 

I,j 

~I' 2'''' 1 

1 

Ii 

'DO 

1 

1 

1 

1 

Count! 

1 

''''on 

I,,,-'all 

10ttC',,;, 

& 

i, 

in 

t.t. Totat 

246 

= ;.5001 

1", 

55200 

5,.. 

27.BaD 

.16D 

1.9OD 

.'001 

,.,. 

50,' 

6' 

7.' 

2: 

41 

0: 

23.5 

24. 

'~ 16. 

" ' 

lII5' 

I' 

',700 

7,+D· 1·n 

~ 15. 

, . 

, ' 

4'.70D 

Appendix D 

7/28/2010 
Corrmx,"y 

.~ 

~ ~ 

Event H7-1 

Draft ER 

Year State Count/ 

~ , ~ ~ 

, Illi 

" . 

IH,m '.~ 

'. 

=I " IOOJ' 

~ 

.~ :,n",m 

~ i , 

~ I g~ '""cn 

II 

II·

, '."" = = 

, ;;;;-

~ h' 

~iID 

~ 

~ I 

I 

& 

= I 

,I ,i 

'~ 

i 

, 

Pia.~je:j AU ?Urp05€S 

\Th~:l;ands cf Al7Es) 

cooo 

WIT 

, 

Tori 

.. 

247 

101 

~ :,3001 

2[, ' 

23,' 

,3m 

1. iF 

, 

~ 

, 

l .. 

, '. 

I .. 

. , 

.0.· .. 15.4: " 

, . 

, " 

I---

I---

so • 

4 

Appendix D 

7/28/2010 
CorrmDi.:ty 

Event H7-1 

Draft ER 

rear Count! 

2~:~ i· I 

'.I§I" .". lEa" , I' I 

,. i 

. : ~. 

1 

1 

I, 

1 

I, 

~ 

Ie lC . ; 

-.lI' 

1 

""'on 

1 

~ 

~' 

lOaD Sou'" Ce""" 

=!!TOW ; 

10 

1,400 

5, 

248 

, " 

4, 

, . ,DOD 

4: ,ODD 

, , 

,5D 

, , 17, 

, , 

~ .til,: jgh~==='~'~'~~ --'" 52t ,7DD I 

3,C 

51 , I ' , 

, , 

15.40 , 

45,7DOI 15.40 

Appendix D 

7/28/2010 
Corrm:.:i'-:Y Year Siaie 

~~H~ 

= 

, i 

i. , i 

=j;;;-

~ 

~ Ii , 

Ii 

Ii· 

Ii 

Ii I 

Ii 

1 , 

1 

~. 

1 

1 

~II: "I" 

" I 

~ " = , 

,mr 

I 

" I 

Count; 

, , 

~3DAmDl~"~DD'DI , 

J,8D 

== ~ ~ ~ "~ .. 7;~ '. 

" " 1 

I 

i 

NO "I 

'"" Elnoo; 

~ 30, 

1070 'I-------->i: m 15, ' 

;~±~~:~~. 'i:I:d'~II" t==IT:],1~lii'"ii]di'k ~'" ===I:===:J~.~,~~~~~'Jt ~j"i,Ot~,,=~=~=~=~~i![]j" ~:~~i"i8 j\jd,jID 

~ 

Even! H7-1 

Draft ER 249 

Appendix D 

7/28/2010 
Corr.mtl:fty Year Slate 

, gan 

I 

I 

I' 

I' 

I 

Count'l 

.. I 

~:;"'~: : ' 1020 So"1i; C,nt"al 

LC'" I' CoMbl,,; Cc"nls , " 

, ., i 

10: I I" 

20 

:~ ""on , , I 

I 

I 

I 

I """ 

,I 

~~I , , 1 W~5! Cent73J 

~==,~ Central 

I, 

PI~!ed AIl r:urpo!>!Os Han.rEsted 

jTkr.Isan:::is cf Acres) [Thousands of A.cr-:-.s} Ig 

1,: " 

',200 

".g" b,,1s Icn~na C'n"" 27, 23, 652,70[ 

Ilcn~", IPro'fee 60' 2: 14,30[ 

I 

~i:~ ~: KImball !,BOD 

~ I bca, ka Memll 

I 

~~~II===!Eb""l<a I€JN,rth~"I"" ~5:i~' §I II 

1,3D 

;,10 

Event H7-1 

Draft ER 250 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

Year Staie 

, 

Count'J 

ISt,t. Tota' 

Illi 

I

. ,. 

"·' " 

., _ 

.". F ,_ 

20]5 I 

lC·]5 Ca"fomla 

I 

ikmia 

Ii'. 

: , 

., 

., , 

., 

., , ~]"" , :C-] , '0 

I'u,", 

Ist,t. Tou' 

" 

I 

Uernc.e 

L 

1.I101do'a 

I 

" I 

251 

.700 

31, 

woo 

',000 

" .. 

100 

" . 

37.01 

37.01 

,<00 

00 31. 

20,7001 35. 

1. 

13, 

4~' .+-1 --""'i~~.Hm 

;:rcduai:x:; 8lJc:cse 

(ThDusands ofT-on:;;) {Perc=n:) 

16." 

75, ' 

17. 

'i:m 

-----; 

---; 

!,OOO 

1.000 

I 

csool 15. 

•. 1G·t, 

274,1 ' 

17.S1 

Appendix D 

7/28/2010 
CCrrmDJ~'Y Ye" I 

I 

I 

I 

I 

I 

'gan 

20}5 I.1''''"an 

2}}5 """,'gan ",g" beets 2G-}5 i."~" ""n 

, 

~ .. , .. , .. , 

, , , " , 

CCLJntoj 

'30 

IDeo S;s: ee"",1 

Ii 

I i 

Planted All :=tJrp05eS 

(TnY.l'5and; cf At:.<es) 

ODD 

3,20' 

'.20' 

,500 

Har.1::s1ed ,(~!d 

[Thousan::!s of J..cr;:s) {T:ms} 

I 

3,: 

,,ODD 

PrcduC';iD1 SUC'C5B 

(Thou5ands ,:::dTOI'5j {P'::fC'mt) 

~~!~:~~~~~5~e'==+====::g,1 ~n Sl Ca', ,3001~==:::j! 

.. , 

, 

~ , , 

, 

, 

~-

Icnlana 

~~H~I: i, 

I 

Event H7-1 

Draft ER 

. ~ ona 

;'a'e Total 154,~+-___ ~ 15< I 21, ",9' I"''''' '~:lQQ ,;iDDI 20. 20 ,600 ,,, 

I 

I II 

1040 

1M",,, 

I 

ISibE' 

l'lE,me 

IR,d","" 

i ' 

i 

)70 

ID" :O~bi"d Ci>Ui~3 

IRco""., 

)30 N"heast , 

;: 'C,"nto 

252 

'.'001 

3,700 

2.700 

4,200 

~ 

700 

.g90 

140 

eB50 

,J_ "ODD 15.51 

.~ 24, 

2 .. )3.: 

3,200 

4,100 2B.' 

eoo 27, 

230 20.: 

2,100 19.' 

20,e: 21 

4,120 "-: 

.24 .. 

3D. 

1.3701 19. 

, 

, , 

, 

, 

" 

, 

~ 

46~ 15.01 

10; , 

41~ 15,5' 

",70' ;, . , 

2De,DDO 

6.000 ,0,4' 

:?;ADO 15.54 

Appendix 0 

7/28/2010 
COITIDc-ifiy 

~ 

Yeiir 

"'-"\."" 11, 

I 

20]5 I 

·1 

2O{J5lldaho 

·I!.lle'·gan 

I 

, 

Count'l 

1080 5co", Cent2l 

'o",la 

JaO s,,, Cer.",1 

Ii 

I i.nia. 

' :~II lao 

i' 

hlO' 

I 

'0 , 

Ccoot'=<; 

, I 

'. i i 

I 

51 ~~ ·1 

.. = 

~ •. :iji:' 

Event H7-1 

Draft ER 

. ""' 

Pia-rted All ?urposP-s 

{Th:r.l:san:is cf AC'Es) 

253 

'= gOO 

3.200 

I.OOD 

"I 13.200 

.9OD 

3J:QO 2'"' 

1.39D 

Har."E:sied 

mOllsands cf f..cre.s) 

Yi;:!d frcduC':iD.'1 I ~uCfc5e 

{Tons) (Thousands ofTor'.s), I 

15 

,I 24.' 

B.100 14. 

,.700 

11~ 20. 

:war 25 

'F lE.OOO 16. 

',Z.ODD 15: 

21 100 17 

1S.5< 

=~~=:I~ :~'~~.:6D~DI--~ 

4. 

61.BOD 

.'~ 15.0 

4t'ToD~1'~ .,,']liD lS.'{ 

~ K.<DD ~ 

B. ;E3Ii~~~2~~~OiIDOD~~'~5.' 5.003 10.' 

, ' 

20.4001 15 .. 

Appendix D 

7/28/2010 
~-'m , 

~: h. 

~ ~n 

lG'" 

20'" 11.1i&.9,n 

20'" IMi"':gan 

lv:Jii '.lio;pan 

.~ 

i 

iii 

" , 

COUrrt'f 

, 

I 

&-

~,,1s i""" 

Event H7-1 

Draft ER 

" 

20 2~ 

~~~ , , 

2C~ 

""'" " 

2eGO 

~ l!.Ionbn, 

~~r 'n~n' 

I ,nbna 

IM'n~na ~ , 

PJa?!,ed AJJ Purposes Harves1ed Y~d Prcduc:ia'1 I ,~ue:;c'5e. (Th::r.1sands cf A~5) (Thousan:!s of A..cp-s) {Trms} (:'hDUS<lm!s Di"TOn5l~'~' ~~ 

~ 'f254 

1,10' 

000 

" ' 

43,; 

BDD 

4,20D 

18" 

32,000 2'. 

161,000 21. 

eoo l1.' 

10" 

,I 

34,: 

aoo 25. 

11 5,200 2D. ' 

,'"0 OS .. 

25. 

3,eoo 24.9 

, ' 

55,00' 1520 

'DIU .s." 15,0[ 

" ~ 

19 24. 

lD" 15, 

11. 

Appendix D 

7/28/2010 
Ccrrm:df:y 

Event H7-1 

Draft ER 

Clintoo 

I , 

G"''';5 •• """'g,n ,-=* 

'''';pan 

County 

, Lotal 

, 

Pla1~erl AJI furpcses Hani-esf:!d 

iTh::r,[sand.s c~ Ac-esj [Thcus:m:::!5 of .,!.cl?:i) 

V:",!d ~rcduc:!oo I ,~UC\:Se. 

:Ton'J ,"""u"nd, ofT'"'J I: 

-'" , , " 

, 

11 167. 

, . 

11.0001 23: ,. I 

fi .ODD 100 '" , 

" 

~8-, ---,7 17..20 

15.50 

15.SO 

'E 

. 1--" 

, ' 

15~~~~:::~:==~:~:~:~:~:~ 

~==~~~2'.~. ==~~:'~D,'=~'5. :.50D 17.n 

.1 . 1.400 17." 

inn esc ChjppE'~'j"a 

'~~~~~~~~~~~~~ ,. , 

2C 

20, IS,·,1h , 

, ,"Him 

~an' 

lana 

255 

4. 

119, 

'.610 "' , 

25,56D 

::1 " 

2001 '4.· 

4,100 ". 

-,GO, 20. 

~ 21. 

19.' 

,790 '5. 

,., , 

109,5OD 

1,3"~ 

':7.~ 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

YEW- S:ate Gaunt! 

)!~n IL i 

PIa"1~e::! All PUrpOSES 

;Thrus<:in::E of AG-'"Es) 

770 , 

ADD 

256 

Han .. es!:ed 

(Thousand: cf Acr=E) 

1,530 15. 

4, !20 20. 

49,900 22., 

2, 19., 

",900 22.: 

",300 , 

, , 

i, 

i5.34 

17.55 

r." 

lB: 

, . 

18. 

15.40 

".Of 

Appendix D 

7/28/2010 
Even! H7-1 

Draft ER 

Year State 

'00 SD"Ii","~ 

20.' lontan, tat. Total 

EM I".b",,"" IE.", "". 

til(" 1·1,,,,, D,k"" !P...,b'" 

::>""0 I·J,,,-' 0,,",,,, W,I,' 

I· t·,,,, . MeK",=<: 

I· 

2"':~ "J,,", 0""" 0", . :.,:., ,.""" D",.:o;S1<;.I. 

,. 

t· i' 

~J<:5 . ,"" De "0;' 

~ 

j j 

, 'I,lte 

~TO"t 

Pk.."l,ed AI! ?urp05€:S 

{Th:tJsandE cf Ac-"es) 

1.770 

Hallo'e:stEd 

f:hollsan:!.5 of ,l..cl?:;;) 

1.530 

:~ i.3GDI 

". ~ 8-1-----''"~·: I ~~. -" 

_ tDD 15. 

7;.CDDI 

4'.1001 

, ' 

1.70D 40.' 

'. 

, . 

. , 

, I--

1--, 

'f= 

'f= , I--

, . 

, . 

fr8j[i 

".DOOI 16.75 

3. 

12. -*22 

22. 

.. :*-. -~~""' ~ .. 

17." 

17.70 

257 

3: .200 

700 

210D 

".200 

Appendix D 

7/28/2010 
COITn1X,,¥ Year 

Event H7-1 

Draft ER 

Stale 

,I,. 

County 

~TOUI 

5" 

0,,,1 

I 

,10"'" 

I",,, ",," 

'10 Combln,d C,"nt~ 

,",,,, 

Pl",i-~e:::l All t=urposes Han .. e:s1Ed Y,~d Prnduc:i!rl I SUC'"CSe 

Ftm:rsiin:::l:s of A1::"es) (Thollsands of .~~s) {TOlE) {7hollsands DfT-:.nsj:, ,I 

258 

4.30 

BOO 

iADO 

1,100 

53.' 

3i. 

251 

2.000 

. 800 

,BOO 

. 700 

3,~ 

6.7illi 

60 

3,00 '3J 

1.00 23., 

101 20.01 

:b "'I 

.700 

i 

33 .. 

32. 

40 . 

l' . 

10.700 I 

J'J.BDD !. 

2'. IDO 

,. 

,. 15.1 

1 •. , 

10.1' 

, .. 

17. 

17. 

'.J! 

Appendix D 

7/28/2010 
Corrrn:.,:i;iy Year 

2005 

State 

ient", 

iont,n, 

LOUro!'; 

~] ~~ COC" 

&'0 11'le"" O,'e:o ;,,.'i,, 

~m~~~:~::, 

~~~iI 

~ 

~ 

~rn"~ 

~.,,, 

Even! H7-1 

Draft ER 

, 

~J .. , 

'~ ~. , 

.. , IBe'.l 

IShrt. T, 

IP .. , 

""'or.h"B;1 

ILa"mi. 

IPI~l= 

ISIat. Tot,] 

PI""le::l All i=urpO£-ES 

.:Th::l'Js;;mi5 of Ac:-e.s) 

7'-'00 

4' 100 

,OJ 

Han.-ested 

(Thot.!Eands c,f . .;c~5) 

,"0 

74, '00 15.: 

4',100 20. 

'" 

10.' fi: 20.0 

'~fi 

SO.: 

>S.: 

259 

32,O( 

" 

35,900 

I. 

15.00 

15.10 

, '.00 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

FlantEd All ?Urpc5£:Ei 

260 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

?2nted All Purp:5=:i 

lThY~'S3I1ds -of Ac.--esl 

261 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

?;anted All Purp::se.s 

(TroJs:nds of Acres:} 

262 

.. , 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 263 

Appendix D 

7/28/2010 
Event H7-1 

Draft ER 

Appendix E 

2010 Technology Use Guide 

264 

Appendix E 

7/28/2010 
TECHNOLOGY USE GUIDE 

THE SOURCE FOR MONSANTO'S PORTFOLIO 

OF TECHNOLOGY PRODUCTS, STEWARDSHIP 

REQUIREMENTS AND GUIDELINES FOR USE. 

2010 
Since 1996, biotech crops have delivered environmental and economic 

benefits to both farmers and consumers. 

1--------------------------
Source: www.biotech-gmo.com 

fro 'r. .•..... /~ 44 Increased iff; Billion 

farmers' net income 

475 fvWllion 

gallons of diesel fuel through 

reduced tillaq,~ or plowln(j 

~ 13 3 Grownby 

i~O farmer:worldwi~illion 

o 

Decreased 

reliably documented 

human or animal 

safety Issues 

;; ff 359,000 

......,-IJ •. lI' ••• : .....,...,. metric tons* 

of pesticide applications 

Decreased 

10 MTi'iion 

metric tons 

of greenhouse gas emissions 

through fuel savings 

environmental impact quotient by 1 I 2 % (EIQ) 

Have been Ingredients In an estimated 

1,000,000,000,000 

meals consumed 

'"Pesticides regIstered by the U.S. EPA will not cause unreasonable adverse effects to man or the environment when used in accordance with label directions. 
YOUR ABILITY TO ENHANC 

YOUR CROPS TODAY! 

It's time to ReNEW your license 

If you haven't renewed your Monsanto 

Technology/Stewardship Agreement (MTSA) 

in the past nine months, take care of it today! 

Signing the MTSA ensures you'll have access 

to current and next-wave technologies. These 

innovations will enhance plant drought tolerance, 

cold tolerance, nitrogen use efficiency, yield and 

much more! 

1-800-768-6387, Option 3 

You'll then have the option to complete the process 

online or through conventional mail. 

Paper MTSA's will continue to be accepted. 
Introduction 

This 2010 Technology Use Guide (TUG) provides 

a concise source of technical information about 

Monsanto's current portfolio of technology products 

and sets forth requirements and guidelines for 

the use of these products. As a user of Monsanto 

Technology, it is important that you are familiar 

with and follow certain management practices. 

Please read all of the information pertaining to the 

technology you will be using, including stewardship 

and related information. Growers must read the 

Insect Resistance Management (IRM)/Grower 

GUide prior to planting for important information 

on planting and IRM. 

This technical guide is not a pesticide product label. 

It is intended to provide additional information and 

to highlight approved uses from the product 

labeling. Read and follow all precautions and use 

instructions in the label booklet and separately 

published supplemental labeling for the Roundup® 

agricultural herbicide product you are using. 

Included in this guide is information on the following: 

Stewardship Overview 

Introducing Genuity'" 

Insect Resistance Management 

Weed Management 

Coexistence and Identity Preserved Production 

Corn Technologies 

YieldGard® and Genuity'· Corn Technologies Product Descriptions 

Roundup Ready® Technology in Corn 

Cotton Technologies 

Genuity'" Bollgard II@and Boilgard21 Cotton 

Roundup Ready Technologies in Cotton 

Genuity·· Roundup Ready 2 Yield@ and Roundup Ready Soybeans ----,,-,,-.-----"'----.-"-----~-------'''---------------'"'--------------""----- " 

Genuity'" Roundup Ready· Alfalfa 

Genuitl" Roundup Ready® Spring CanDia 

Genuity!~ Roundup Ready@ Winter CanDia 

Genuity'" Roundup Ready® Sugarbeets 

If you have any questions, contact your Authorized Retailer or Monsanto at 1-800-768-6387. 

4 

6 

8 

10 

12 

15 

21 

31 

3S 

38 

39 

40 

2010 TECHNOLOGY USE GUIOE 
A Message About Stewardship - SEED AND TRAITS 

Monsanto Company is committed to enhancing farmer productivity 

and profitability through the introduction of new agricultural 

biotechnology traits. These new technologies bring enhanced value 

and benefits to farmers, and farmers assume new responsibilities 

for proper management of these traits. Farmers planting seed with 

biotech traits agree to implement good stewardship practices, 

including, but not limited to: 

• Reading, signing and complying with the Monsanto 

Technology/Stewardship Agreement (MTSA) and 

reading all annual license terms updates before 

purchase or use of any seed containing a trait. 

• Reading and following the directions for use on all 

product labels. 

• Following applicable stewardship practices as 

outlined in this TUG. 

• Reading and following the IRM/Grower Guide prior 

to planting. 

• Observing regional planting restrictions mandated 

by the U.S. Environmental Protection Agency (EPA). 

• Complying with any additional stewardship 

requirements, such as grain or feed use agreements 

or geographical planting restrictions, that Monsanto 

deems appropriate or necessary to implement for 

proper stewardship or regulatory compliance. 

MONSANTO 

• Following the Weed Resistance Management 

Guidelines to minimize the risk of resistance 

development. 

• Complying with the applicable IRM practices for 

specific biotech traits as mandated by the EPA and 

set forth in this TUG. 

• Utilizing all seed with biotech traits only for planting 

a single crop. 

• Selling crops or material containing biotech traits 

only to grain handlers that confirm their acceptance, 

or using those products on farm. 

• Not moving material containing biotech traits across 

boundaries into nations where import is not permitted. 

• Not selling, promoting and/or distributing within 

a state where the product is not yet registered. 
CROP OR MATERIAL HANDLING STEWARDSHIP STATEMENT 

WHY IS STEWARDSHIP IMPORTANT? 

Each component of stewardship offers benefits to farmers: 

• Signing the MTSA provides farmers access to Monsanto's biotech 

trait seed technology. 

• Following IRM guidelines guards against insect resistance to 

Bacillus thuringiensis (B.t.) technology and therefore enables 

the long-term viability of this technology. and meets EPA 

requirements. 

• Proper weed management maintains the long-term effectiveness 

of glyphosate'based weed control solutions. 

• Utilizing biotech seed only for planting a single-commercial 

crop helps preserve the effectiveness of biotech traits, 

while allowing investment for future biotech innovations 

which further improves farming technology and productivity. 

Practicing these stewardship activities will enable biotechnology's 

positive agricultural contributions to continue. 

Farmers' attitudes and adoption of sound stewardship principles, 

coupled with biotechnology benefits, provide for the sustainability 

of our land resources, biotechnology and farming as a preferred 

way of life. 

SEED PATENT INFRINGEMENT 

If Monsanto reasonably believes that a farmer has planted 

saved seed containing a Monsanto biotech trait, Monsanto 

will request invoices and records to confirm that fields in 

question have been planted with newly purchased seed, If this 

information is not provided within 30 days, Monsanto may 

inspect and test all of the farmer's fields to determine if saved 

seed has been planted. Any inspections will be coordinated 

with the farmer and performed at a reasonable time to best 

accommodate the farmer's schedule. 

If you have questions about seed stewardship or become aware of 

individuals utilizing biotech traits in a manner other than as noted 

above, please call 1-800-768-6387. Letters reporting unacceptable 

or unauthorized use of biotech traits may be sent to: 

Monsanto Trait Stewardship 

800 N. Lindbergh Boulevard NC3C 

st. Louis, MO 63167 

For more information on Monsanto's practices related to seed 

patent infringement, please visit: 

www.monsanto.com/seedpatentprotection. 

Provide Anonymous or Confidential reports as follows: 

"Anonymous" reporting results when a person reports information to Monsanto in such a way that the identity of the person 

reporting the information cannot be identified. This kind of 

reporting includes telephone calls requesting anonymity and 

unsigned letters. 

"Confidential" reporting results when a person reports information to Monsanto in such a way that the reporting person's 

identity is known to Monsanto. Every effort will be made to 

protect a person's identity, but it is important to understand that 

a court may order Monsanto to reveal the identity of people who 

are "known" to have supplied relevant information. 

"Q,<II.-

"b!!yond" .-______ 4trBS!!!!d 6-

You'rebuyingmoreUmIl _,~El 

juslseed. You're getting value today 

and innovation for tomorrow. 

The Beyond the Seed Program 

was launched by the American 

Seed Trade Association (ASTA) 

to raise awareness and 

understanding of the value 

that goes beyond the seed. 

The future success of U.S. agriculture depends upon quality 

seed delivered by an industry commitment to bring innovation 

and performance through continued investment. For more 

information about seed technology, visit ASTA's Beyond the 

Seed Program at www.beyondtheseed.org. 

2010 TECHNOLOGY USE GUIDE 
Genuity'" Unites the Best Traits' 

As a purchaser of Monsanto biotech trait products, your investment 

helps fuel the research and development engine that leads to the 

discovery and delivery of new technologies for agriculture. Current 

and future Genuity'" traits are designed to deliver high yield potential, 

maximize return on seed investments and consistently deliver future 

trait innovations. 

CORN 

Higher yields come from quality grain. Genuity'" VT Triple PRO"· 

was the next generation of corn technology available for the 

2009 growing season. Genuity'" VT Triple PRO'" provides dual 

modes of action against above-ground pests such as corn 

earworm, European and southwestern corn borers, sugarcane 

borer, southern cornstalk borer and fall armyworm. Reduced 

kernel damage from corn earworm means the potential for 

reduced Aflatoxin contamination. Genuity'" VT Triple PRO'· dual 

modes-of-action also allows for a reduction in refuge acres 

required In southern [otton~growing regions while providing 

long-term effectiveness and consistency. 

'" GENUITY'" SMARTSTAX'" 

Scheduled for launch in 2010, Genuity'" 

SmartStax'" is the mostwadvanced, 

ailwin-one corn trait system that 

controls the broadest spectrum of 

above- and below-ground insects and 

weeds. Genuity'" Smartstax'" provides 

control of corn earworm, European 

corn barer, southwestern corn borer; sugarcane borer, fall 

armyworm, western bean cutworm, black cutworm, western corn 

rootworm, northern corn rootworm and Mexican corn rootworm. 

Genuity'" SmartStax'" contains Roundup Ready~ 2 Technology 

and UbertyLink® herbicide tolerance. Genuity'" Smartstax'" also 

allows for a reduction in refuge acres in the corn belt from 20% 

down to 5% for above- and below-ground refuge. Genuity'" 

SmartStai" is also approved for a 20% refuge in the cotton belt. 

·See pages 16 and 17 for additional traits. 

SOYBEAN 

Genuity'" Roundup Ready 2 YieldlRl soybeans are taking yield 

to a higher level. They were developed to provide farmers with 

the same simple, dependable and flexible weed control and crop 

safety they've come to rely on with the first-generation Roundup 

Ready® soybean system, but with higher yield potential. This is 

possible because of advanced insertion and selection technologies. 

COTTON 

Genuity"" Roundup Ready® Flex and Genuity-" Bollgard II® offer 

the ultimate combination of peace of mind and flexibility. 

They contain unrivaled built-in worm control to stop the most 

leaf- and bolHeeding worm species, including bollworms, 

budworms, armyworms, loopers, saltmarsh caterpillars and 

cotton leaf perforators. Protecting just one additional boll 

per plant can result in significantly higher lint yield. The 

convenience and savings from fewer or no sprays for worms 

can make a big difference when it comes to the bottom line. 

SPECIALTY 

Genuity'" Roundup Ready® alfalfa: Bred from an innovative 

germplasm pool, it offers outstanding weed control, excellent 

crop safety and preservation of forage quality potential. 

Genuity'" Roundup Ready® canola: Offers excellent control 

of broadleaf weeds and grasses, even in tough weather 

conditions. Also features excellent crop safety and broad 

application flexibility. 

Genuitym Roundup Ready® sugarbeets: Excellent in-plant 

tolerance to over-the-top applications of labeled Roundup 

agricultural herbicides. Offers outstanding weed control, 

excellent crop safety and preservation of yield potential. 

NOTE: Farmers must read the IRM/Grower Guide prior to planting for information on planting and Insect Resistance Management. 

MONSANTO 
Monsanto's New Generation of Technologies 

As Monsanto continues to develop new generations of technologies, 

several of our newer technologies are migrating to the Genuity"" brand. 

These products and their new logos are presented below. 

Vll!ldlillrd VI>' wlip> 

Triple PRO VTTrlplcPRO 

CORN 

BOI~U withg 

Roundup Ready- Cotton 

COTTON 

SPECIALTY 

Bollgard II 

Roundup Ready Flex 

Grow the Feedl 

Nol the WeedL" 

SOYBEANS 

BoUgard 11 

BolI~U withg t:7:::;;D>' 

Roundup Ready. flex Rcu~dup Dollg.nlil 

Rully Flo 

Roundup Ready 

2010 TECHNOLOGY USE GUIDE II 
An EFFECTIVE IRM program is a vital part of 

responsible product stewardship for insectP/anlingR./ugB5,P",.rv/ngTechn%gy protected biotech products. Monsanto is committed 

to implementing an effective IRM program for all of its insectprotected B.t. technologies In ali countries where they are 

commercialized, including promoting farmer awareness of these 

IRM programs. Monsanto works to develop and implement IRM 

programs that strike a balance between available knowledge and 

practicality, with farmer acceptance and implementation of the plan 

as critical components. 

The U.S. EPA requires that Monsanto implement, and farmers 

who purchase insect-protected products follow, an IRM plan.* 

IRM programs for B.t. traits are based upon an assessment of the 

biology of the major target pests, farmer needs and practices, 

and appropriate pest management practices. These mandatory 

regulatory programs have been developed and updated through 

broad cooperation with farmer and consultant organizations, 

including the National Corn Growers Association and the National 

cotton Council, extension specialists, academic scientists, and 

regulatory agencies. 

*In some areas, a natural refuge option is available for BoligarElIi. See the current IRM!Grower Guide for details. 

II MONSANTO 
The IRM programs for planting seeds containing at traits contain 

several important elements. One key component of an IRM 

plan is a refuge. A refuge is simply a portion of the relevant 

crop (corn or cotton) that does not contain a B.t. technology 

for the control of the insect pests which are controlled by the 

planted technology(ies). The lack of exposure to the B.t. proteins 

means that there will be susceptible insects nearby to mate 

with any rare resistant insects that may emerge from B.t. 

products. Susceptibility to B.t. products is then passed on 

to offspring, preserving the long-term effectiveness of 

the technology. 

Farmers who purchase seeds containing B.t. traits must plant an 

appropriately designed refuge. Refuge size, configuration, and 

management is described in detail in the sections on those 

products in the 2010 IRM/Grower Guide. 

FailUre to follow IRM requirements and to plant a proper 

refuge may result in the loss of a farmer's access to Monsanto 

technologies. Monsanto is committed to the preservation of 

B.t. technologies. Please do your part to preserve B.t. technologies 

by implementing the correct IRM plan on your farm. 

MONITORING PROGRAM 

The U.S. EPA requires Monsanto to take corrective measures in 

response to a finding of IRM non-compliance. Monsanto or an 

approved agent of Monsanto must monitor refuge management 

practices. The MTSA signed by a farmer requires that upon 

request by Monsanto or its approved agent, a farmer must 

provide the location of all fields planted with Monsanto 

technologies and the locations of all associated refuge areas 

as required, to cooperate fully with any field inspections. and 

allow Monsanto to inspect all fields and refuge areas to ensure 

an approved insect resistance program has been followed. All 

inspections will be performed at a reasonable time and arranged 

in advance with the farmer so that the farmer can be present 

if desired. 

Farmers must read the current IRM/Grower Guide prior to planting for information on 

planting and IRM. If you do not have a copy of the current IRM/Grower Guide, you may 

downloaded it at www.monsanto.com. or you may call 1-800-768-6387 to request a copy 

by mail. 

2010 TECHNOLOGY USE GUIDE 
Monsanto considers product stewardship to be a fundamental 

component of customer service and responsible business practices. 

As leaders In the development and stewardship of Roundup" 

agricultural herbicides and other products, Monsanto invests 

significantly in research to continuously improve the proper uses 

and stewardship of our proprietary herbicide brands. 

This research, done in conjunction with academic scientists, 

extension specialists and crop consultants, includes an evaluation 

of the factors that can contribute to the development of weed 

resistance and how to properly manage weeds to delay the 

selection for weed resistance. Visit www.weedtool.com for 

practical, best practices-based information on reducing the risk 

for development of glyphosate-resistant weeds. Developed 

in cooperation with academic experts, the website provides 

options for managing the risk on a field-by-field basis. 

Glyphosate is a Group 9 herbicide based on the mode of action 

classification system of the Weed Science Society of America. 

Any weed population may contain plants naturally resistant to 

Group 9 herbicides. The following general recommendations 

help manage the risk of weed resistance occurring. 

WEED RESISTANCE MANAGEMENT PRACTICES: 

• Scout your fields before and after herbicide application 

• Start with a clean field, using either a burndown herbicide 

application or tillage 

• Control weeds early when they are small 

• Add other herbicides (e.g. a selective in~crop and/or a residual 

herbicide) and cultural practices (e.g. tillage or crop rotation) as 

part of your Roundup Ready® cropping system where appropriate 

• Rotation to other Roundup Ready crops will add opportunities for 

introduction of other modes of action 

· Use the right herbicide product at the right rate and the right time 

• Control weed escapes and prevent weeds from setting seeds 

• Clean equipment before moving from field to field to minimize 

spread of weed seed 

• Use new commercial seed that Is as free from weed seed 

as possible 

Note: Always read and follow all pesticide label requirements. 

II MONSANTO 

Monsanto is committed to the proper use and long~term 

effectiveness of its proprietary herbicide brands through a 

four~part stewardship program: developing appropriate weed 

control recommendations, continuing research to refine and update 

recommendations, education on the importance of good weed 

management practices and responding to repeated weed control 

inquiries through a product performance evaluation program. 

GLVPHOSATE-RESISTANT WEEDS 

Monsanto actively investigates and studies weed control 

complaints and claims of weed resistance. When glyphosate~ 

resistant weed biotypes have been confirmed, Monsanto alerts 

farmers and develops and provides farmers with recommended 

control measures, which may include additional herbicides, 

tank~mixes or cultural practices. Monsanto actively communicates 

all of this information to farmers through multiple channels, 

including the herbicide label, www.weedscience.org, supplemental 

labeling, this TUG, media and written communications, 

Monsanto's website, www.weedresistancemanagement.com. 

and farmer meetings. 

Farmers must be aware of, and proactively manage for, 

glyphosate~resistant weeds in planning their weed control 

program. When a weed is known to be resistant to glyphosate, 

then a resistant population of that weed is by definition no 

longer controlled with labeled rates of glyphosate. Roundup® 

agricultural herbicide warranties will not cover the failure to 

control glyphosate~resistant weed populations. 

Report any incidence of repeated non-performance on a 

particular weed to your local Monsanto representative, retailer 

or county extension agent. 
ROUNDUP BRAND AGRICULTURAL OVER-THE-TOP HERBICIDE PRODUCTS 

MONSANTO BRANDS OF SELECTIVE OVER-THE-TOP 

HERBICIDE PRODUCTS 

Herbicide products sold by Monsanto for use over the top of 

Roundup Ready crops for the 2010 crop season are as follows: 

Roundup WeatherMAX® Roundup PowerMAKID 

Read and follow all product labeling before using Roundup 

agricultural herbicides over the top of Roundup Ready traits. 

To learn more about applicable supplemental labels or fact 

sheets, call 1-800-768-6387. 

Tank-mixtures of Roundup agricultural herbicides with insecticides, fungicides, micronutrients or foliar fertilizers are not 

recommended as they may result in reduced weed control. 

crop injury, reduced pest control or antagonism. Refer to the 

Roundup agricultural herbicide product label, supplementa! 

labeling or fact sheets published separately by Monsanto for 

tank-mix recommendations. 

Do not add additional surfactants and/or products containing 

surfactants to these Roundup agricultural herbicides unless 

otherwise directed by the label. Other glyphosate products 

labeled for use in Roundup Ready technologies may require 

the addition of surfactants, or other additives to optimize 

performance, that may increase the potential for crop injury. 

Monsanto will label and promote only fully tested brands that 

do not require surfactants and other additives for over-the-top 

applications to Roundup Ready Crops. 

GLYPHOSATE ENDANGERED SPECIES INITIATIVE 

Before making applications of glyphosate-based herbicide 

products, licensed farmers of crops containing Roundup Ready 

technology must access the website www.pre-serve.org to 

determine whether any mitigation requirements apply to the 

planned application to those crops, and must follow all applicable 

requirements. The mitigation measures described on the website 

are appropriate for all applications of glyphosate-based 

herbicides to all crop lands. 

Farmers making only ground applications to crop land with 

a use rate of less than 3.5 Ibs of glyphosate a.e./A are not 

required to access the website. If a farmer does not have web 

access, the seed dealer can access the website on behalf of 

the farmer to determine the applicable requirements, or the 

farmer can call 1-800-332-3111 for assistance. 

In certain areas, populations of ryegrass, johnsongrass, marestail, common ragweed, giant ragweed, Palmer Amaranth and waterhemp are known to be resistant to 

glyphosate. For control recommendations for resistant biotypes of these weeds, refer to www.weedresistancemanagement.comor call 1,800-768,6387. When approved, 

supplemental labeling for specific herbicide products can also be viewed on www.cdms.netorwww.greenbook.netorobtained by calling 1'800-768-6387. 

2010 TECHNOLOGY USE GUIDE III 
Coexistence in agricultural production systems and supply 

chains is not new. Different agricultural systems have coexisted 

successfully for many years around the world. Standards 

and best practices were established decades ago and have 

continually evolved to deliver high purity seed and grain to 

support production, distribution and trade of products from 

different agricultural systems. For example, production of similar 

commodities such as field corn, sweet corn and popcorn has 

occurred successfully and in close proximity for many years. 

Another example is the successful coexistence of oilseed rape 

varieties with low erucic acid content for food use and high 

erucic acid content for industrial uses. 

The introduction of biotech crops generated renewed discussion 

of coexistence focused on biotech production systems with 

conventional cropping systems and organic production. These 

discussions have primarily focused on the potential economic 

impact of the introduction of biotech products on other systems. 

The health and safety of biotech products are not an issue 

because their food, feed and environmental safety must be 

demonstrated before they enter the agricultural production 

system and supply chain. 

The coexistence of conventional, organic and biotech crops has 

been the subject of several studies and reports. These reports 

conclude that coexistence among biotech and non~biotech 

crops is not only possible but is occurring. They recommend 

that coexistence strategies be developed on a case~by~case basis 

considering the diversity of products currently in the market and 

under development, the agronomic and biological differences in 

the crops themselves and variations in regional farming practices 

and infrastructures. Furthermore, coexistence strategies are 

driven by market needs and should be developed using current 

science~based industry standards and management practices. 

The strategies must be flexible, facilitating options and choice for 

the farmer and the food/feed supply chain, and must be capable 

of being modified as changes in markets and products warrant. 

Successful coexistence of all agricultural systems is achievable 

and depends on cooperation, flexibility and mutual respect for 

each system. Agriculture has a history of innovation and change, 

and farmers have always adapted to new approaches or chal~ 

lenges by utilizing appropriate strategies, farm management 

practices and new technologies. 

II MONSANTO 

The responsibility for implementing practices to satisfy specific 

marketing standards or certification lies with that farmer who 

is growing a crop to satisfy a particular market. Only that farmer 

is instructed to employ the practices appropriate to assure the 

integrity of his/her crop. This is true whether the goal is high~oil 

corn, white/sweet corn or organically produced yellow corn for 

animal feed. In each case, the farmer is seeking to produce a 

crop that is supported by a market price and consequently that 

farmer assumes responsibility for satisfying reasonable market 

specifications. That said, the farmer needs to be aware of the 

planting intentions of his/her neighbor in order to gauge the 

need for management practices. 

IDENTITY PRESERVED PRODUCTION 

Some farmers may choose to preserve the identity of their crops 

to meet specific markets. Examples of Identity Preserved (I.P.) 

corn crops include production of seed corn, white, waxy or sweet 

corn, specialty oil or protein crops, food grade crops and any 

other crop that meets specialty needs, including organic and 

non~genetically enhanced specifications. Farmers of these crops 

assume the responsibility and receive the benefit for ensuring 

that their crop meets mutually agreed contract specifications. 

Based on historical experience with a broad range of I.P. crops, 

the industry has developed generally accepted J.P. agricultural 

practices. These practices are Intended to manage I.P. production 

to meet quality specifications, and are established for a broad 

range of I. P. needs. The accepted practice with I.P. crops is that 

each I.P. farmer has the responsibility to implement any neces~ 

sary processes. These processes may include sourcing seed 

appropriate for I.P. specifications, field management practices 

such as adequate isolation distances, buffers between crops, 

border rows, planned differences in maturity between adjacent 

fields that might cross-pollinate and harvest and handling 

practices designed to prevent mixing and to maintain product 

quality. These extra steps associated with I.P. crop production 

are generally accompanied by incremental increases in cost 

of production and consequently of the goods sold. 
General Instructions for Management 

of Pollen Flow and Mechanical Mixing 

For all crop hybrids or varieties that they wish to identity 

preserve, or otherwise keep separated, farmers should take steps 

to prevent mechanical mixing. Farmers should make sure all seed 

storage areas, transportation vehicles and planter boxes are 

cleaned thoroughly both prior to and subsequent to the storage, 

transportation or planting of the crop. Farmers should also make 

sure all combines, harvesters and transportation vehicles used at 

harvest are cleaned thoroughly both prior to and subsequent to 

their use in connection with the harvest of the grain produced 

from the crop. Farmers should also make sure all harvested grain 

is stared in clean storage areas where the identity of the grain 

can be preserved. 

Self-pollinated crops, such as soybeans, do not present a risk 

of mixing by cross-pollination. If the intent is to use or market 

the product of a self-pollinated crop separately from general 

commodity use, farmers should plant fields a sufficient distance 

away from other crops to prevent mechanical mixture. 

Farmers planting cross-pollinated crops, such as corn or alfalfa, 

who desire to preserve the identity of these crops, or to minimize 

the potential for these crops to outcross with adjacent fields 

of the same crop kind, should use the same generally accepted 

practices to manage mixing that are used in any of the currently 

grown I.P. crops of similar crop kind. 

It is generally recognized in the industry that a certain amount 

of incidental, trace level pollen movement occurs, and it is not 

possible to achieve 100% purity of seed or grain in any corn 

production system. A number of factors can influence the 

occurrence and extent of pollen movement. As stewards of 

technology, farmers are expected to consider these factors and 

talk with their neighbors about their cropping intentions. 

Farmers should take into account the following factors that can 

affect the occurrence and extent of cross-pollination to or from 

other fields. Information that is more specific to the crop and 

region may be available from state extension offices. 

• Cross-pollination Is limited. Some plants, such as potatoes, are 

incapable of cross-pollinating, while others, like alfalfa, require 

cross-pollination to produce seed. Importantly, cross-pollination 

only occurs within the same crop kind, like corn to corn. 

• The amount of pollen produced within the field can vary. The 

pollen produced by the crop within a given field, known as pollen 

load, is typically high enough to pollinate all of the plants in the 

field. Therefore, most of the pollen that may enter from other 

fields falls on plants that have already been pollinated with pollen 

that originated from plants within the field. In crops such as alfalfa, 

the hay cutting management schedule significantly limits or 

eliminates bloom, and thereby restricts the potential for pollen 

and/or viable seed formation. 

• The existence and/or degree of overlap In the pollination period 

of crops in adjacent fields varies. This will vary depending on the 

maturity of crops, planting dates and the weather. For corn, the 

typical pollen shed period lasts from 5 to 10 days for a particular 

field. Therefore, viable pollen from neighboring fields must be 

present when silks are receptive in the recipient field during this 

brief period to produce any grain with traits introduced by the 

out-of-field pollen. 

• Distance between fields of different varieties or hybrids of the 

same crop: The greater the distance between fields the less likely 

their pollen will remain viable and have an opportunity to mix 

and produce an outcross. For wind-pollinated crops, most crosspollination occurs within the outermost few rows of the field. 

In fact, many white and waxy corn production contracts ask the 

farmer to remove the outer 12 rows (30 ft.) of the field in order 

to remove most of the impurities that could result from cross' 

pollination with nearby yellow dent corn. Furthermore, research 

has also shown that as fields become further separated, the 

incidence of wind-modulated cross-pollination drops rapidly. 

Essentially, the in-field pollen has an advantage over the pollen 

coming from other fields for receptive silks because of its volume 

and proximity to silks. 

• The distance pollen moves. How far pollen can travel depends on 

many environmental factors, including Weather during pollination, 

especially wind direction and velocity, temperature and humidity. 

For bee-pollinated crops, the farmer's choice of pollinator species 

and apiary management practice may reduce field-to-field 

pollination potential. All these factors will vary from season to 

season, and some factors from day to day and from location 

to location. 

• For wind-pollinated crops, the orientation and width of the 

adjacent field in relation to the dominant wind direction. Fields 

oriented upwind during pollination will show dramatically lower 

cross-pollination for wind-pollinated crops, like corn, compared 

to fields located downwind. 

2010 TECHNOLOGY USE GUIDE III 

Advanced breeding and biotechnology have had a major impact on 

farming production. From 1971 to 1995, average corn yields were 

increasing at a rate of 1.5 bushels per acre, per year. Since the advent 

of biotech in 1996, corn yields have increased at a rate of 2.6 bushels 

per acre, per year, for a total increase of 32 bushels per acre." 

Excellence Through Stewardship 

Monsanto Company is a member of Excellence Through 

Stewardship® (ETS). Monsanto products are commercialized 

in accordance with ETS Product Launch Stewardship Guidance, 

and in compliance with Monsanto's Policy for Commercialization 

of BiotechnolQgy~Derived Plant Products in Commodity Crops. 

This product has been approved for import into key export 

markets with functioning regulatory systems. Any crop or 

material produced from this product can only be exported to, 

or used. processed or sold in countries whe.re all necessary 

regulatory approvals have been granted. It is a violation of 

national and international law to move material containing 

biotech traits across boundaries into nations where import 

is not permitted. Growers should talk to their grain handler 

or product purchaser to confirm their buying position for this 

product. Excellence Through Stewardship@ is a registered 

trademark of Biotechnology Industry Organization. 

For specific refuge requirements for 

B.t. corn and cotton, see the current 

IRM/Grower Guide, sent with this TUG. 

If you have not received a copy of 

this Guide, it can be downloaded at 

www.monsanto.com. or call1~800~768~6387 

to request a copy be mailed to you. 

Before opening a bag of seed, be sure to read and understand the stewardship requirements, including 

applicable refuge requirements for insect resistance management. for the biotechnology traits expressed in 

the seed as set forth in the Monsanto Technology Agreement that you sign. By opening and using a bag of seed, 

you are reaffirming your obligation to comply with those stewardship requirements. 

• USDA Yields were calculated using 3 year rolling a~erages (32 Yield is 2.6 bu/ac *12 years). 2008 Yield is from Doane Ag Services forecast In April 8, 2008 Quarterly Crop Outlook. 

2010 TECHNOLOGY USE GUIDE II 
Genuity'" Trait Products and YieldGard® Corn Technologies Product Descriptions 

GENUITY'" SMARTSTAX'" 

Scheduled to launch in 2010, Genuity'W SmartStax'" is the most 

advanced, all-in"one corn trait system that controls the broadest 

spectrum of above- and below-ground insects and weeds. Genuity"" 

SmartStax'" hybrids will contain B.t. proteins that represent three 

separate modes of action for control of lepidopteran, aboveground insect pests, as well as combined modes of action for 

control of coleopteran, below-ground insect pests. Providing 

multiple B.t. proteins for control will dramatically decrease the 

probability that insects will become resistant to the traits, 

resulting in enhanced durability of transgenic insect control via 

B.t. genes. Based on this multiple gene approach, Genuityt" 

SmartStax·" is approved for reduced refuge in the corn belt from 

20% down to 5% for both above- and below-ground pests. The 

cotton belt refuge for Genuity SmartStax'" is also reduced, from 

50% down to 20%. 

VTTrip!~ PRO 

GENUITY'" VT TRIPLE PRO'" 

(Formerly YieldGard VT Triple PRO") - Genuity' VT Triple PRO" 

is available in selected southern corn- and cotton-growing areas. 

It includes broad-spectrum insect control against corn earworm, 

European and southwestern corn borers, sugarcane borer, 

southern cornstalk borer, fall armyworm, western corn rootworm, 

northern corn rootworm and Mexican corn rootworm. Its 

advanced control of ear pests can result in higher grain quality 

and higher-yielding crop potential. The dual mode-of-action of 

Genuity'" VT Triple PRO .... allows for lower corn borer refuge acres 

in southern cotton-growing areas compared to other registered 

B.t.-traited products. It includes the same Roundup Ready® 2 

Technology as Monsanto's previous product, YieldGard VT Triple. 

Seed containing Genuity'" VT Triple PRO .... technology is treated 

with seed-applied insecticide.* 

MONSANTO 

V,eldlillrd I(f> 

Tripie 

YIELDGARD VT TRIPLE@ 

YieldGard VT Triple technology combines YieldGard Corn Borer 

and YieldGard VT RootwormiRR2® technology into a single plant. 

YieldGard VT Triple corn hybrids control European and southwestern corn borer, sugarcane borer, southern cornstalk borer, 

western corn rootworm, northern corn rootworm and Mexican 

corn rootworm. YieldGard VT Triple technology suppresses corn 

earworm, fall armyworm and stalk borer. By providing in-plant 

protection against the above insect pests, the genetic yield 

potential of YieldGard VT Triple corn hybrids is preserved. 

YieldGard VT Triple corn hybrids also include Roundup Ready 2 

Technology. This trait allows a farmer to experience the benefits 

of utilizing Roundup agricultural herbicides in a weed control 

system that provides the broadest weed control spectrum 

available. better application flexibility, and superior crop safety. 

Seed containing YieldGard VT Triple technology is treated with 

seed-applied insecticide.* 

VT Ooublll PRO 

GENUITY'" VT DOUBLE PRO'" 

Genuity'" VT Double PRO'" is a new corn technology scheduled 

for launch in 2010. It includes broad-spectrum insect control 

against corn earworm. European and southwestern corn borers, 

sugarcane borer, southern cornstalk borer and fall armyworm. 

The dual mode-of-action of Genuity'" VT Double PRO'" allows for 

lower corn borer refuge acres compared to other registered 

B.t. -traited products. Seed containing Genuity'" VT Double PRO·" 

technology is treated with seed-applied insecticide.* 

*A seed·applied insecticide Ciln protect seed. roots and seedlings from insects such as black 

cutworm, wireworm, white grubs, seed corn maggots, chinch bug and early flea beetles. 
flllI!ldlillrd W--::p 1F1@@1E'i&!'@If'IlifUIIF1IF1~ 

YIELDGARD VT ROOTWORM/RR2'" 

YieldGard VT Rootworm/RR2 technology is the current VietdGard stacked-trait product for control of western corn rootworm, 

northern corn rootworm and Mexican corn rootworm. Protecting the root of the corn plant from feeding by corn rootworm larvae 

decreases lodging and protects the genetic yield potential of YieldGard VT Rootworm/RR2 corn hybrids. The Roundup Ready 2 

Technology allows a farmer to experience the benefits of utilizing Roundup agricultural herbicides in a weed control system that 

provides the broadest weed control spectrum, better application flexibility and superior crop safety. Seed containing YieldGard VT 

Rootworm/RR2 technology is treated with seed-applied insecticide.* 

YIELDGARD'" CORN BORER 

YieldGard Corn Borer corn hybrids contain an insecticidal 

protein from B.t. that protects corn plants from European 

corn borer. southwestern corn borer; sugarcane borer and 

southern cornstalk borer resulting in full yield potential. 

Maxlmom 

IlISect ProlDcUOD 

YIELDGARD PLUS 

YieldGard Plus corn technology combines YieldGard 

Corn Borer and YieldGard Rootworm technology 

into a single plan. 

YIELDGARD ROOTWORM 

YieldGard Rootworm corn hybrids contain an insecticidal 

protein from B.t. that protects corn roots from larval 

feeding by western, northern and Mexican corn rootworm. 

YIELDGARD" CORN BORER WITH 

ROUNDUP READY'" CORN 2 

YieldGard Corn Borer with Roundup Ready Corn 2 offers 

farmers all the benefits of both traits combined in one crop. 

These hybrids exhibit the same insect protection qualities as 

YieldGard Corn Borer and, like Roundup Ready Corn 2, are tolerant 

to over-the-top applications of Roundup@ agricultural herbicides. 

YIELDGARD PLUS WITH ROUNDUP READY CORN 2 

YieldGard Plus with Roundup Ready Corn 2 offers farmers all the 

benefits of all three traits combined in one crop. These hybrids 

exhibit the same insect protection qualities of YieldGard Corn 

Borer and YieldGard Rootworm and, like Roundup Ready Corn 2, 

are tolerant to over-the-top applications of Roundupf!'! agricultural 

herbicides. Seed containing YieldGard Plus technology is treated 

with seedvapplied insecticide.* 

YIELDGARD ROOTWORM WITH 

ROUNDUP READY CORN 2 

YieldGard Rootworm with Roundup Ready Corn 2 offers farmers 

all the same insect protection qualities as YieldGard Rootworm 

and, like Roundup Ready Corn 2, is tolerant to over-the-top 

applications of Roundup agricultural herbiCides. 

*A seed'applied insecticide can protect seed, roots and seedlings from Insects such as blad 

cutworm, wireworm. white grubs. seed corn maggots, chinch bug and early Ilea beetles. 

2010 TECHNOLOGY USE GUIDE 
ROUNDUP READY® Technology in Corn 

WEED CONTROL RECOMMENDATIONS 

Roundup Ready® Corn 2 (RR2) and corn with Roundup Ready® 

2 Technology are equivalent in their tolerance to Roundup 

agricultural herbicides. Products with Roundup Ready Technology 

contain in-plant tolerance to Roundup agricultural herbicides. 

The Roundup Ready® Technology system's flexibility, broadspectrum weed control and proven crop safety offer farmers 

weed control programs that allow them to use the system in the 

way that provides the greatest benefit. Farmers can select the 

program that best fits the way they farm. Options include the use 

PROGRAM 

For use where residual 

herbicides are 

typically used for 

early-season weed 

control: 

Residual Herbicide 

Plus Roundup 

WeatherMAX® 

For use where total 

postemergence 

programs are effective 

and sustainable: 

Roundup Weather MAX 

Sequential 

Maximum Use Rates 

For Roundup 

We,therMAX 

of a residual herbicide with 

a Roundup® agricultural 

herbicide, tank-mixing other 

herbicides with Roundup 

agricultural herbicides where 

appropriate and a total 

postemergence program. 

INSTRUCTIONS AND USE RATES' 

Use the proper Roundup Ready RATE'" of BulietO, 

Degree®, Degree xtra®, Harness®)iarness Xtra, Harness 

Xtra 5.6l, Micro'Tech"', or lariat!l (no post) as defined in 

the table below and the individual product labels, either 

pre or postemergence to the crop."" 

follow with Roundup We,lherMAX at 16 to 11 ozfA 

post sequentially after preemergence application or 

tank-mixed in-crop with the residual. Applications 

should be made before weeds exceed 411 in height. 

Roundup Ready RATEs*** 

Harness 1.5 Pints 

Degree 3.0 Pints 

Harness Xtra I.Z Duarts 

Harness X!ra 5.6l 1.5 Quarts 

Degree Xtra Z.O Quarts 

Micro-Tech Z.O Quarts 

lariat 2.0 Quarts 

Bullet 2.0 Quarts 

Apply Roundup WeatherMAX ,116 to 11 ozfA before 

weeds exceed 411 in height and follow with a second 

application at 16 to 22 oz/A for an additionaillush of 

weeds before they exceed 4" in height. 

Products with Roundup Ready 2 Technology In-crop: 

" 32 oz/A per single application 

"Total: 64 oz/A from emergence through 4811 height of 

corn, drop nozzles must be used from 3011 to 48!! corn. 

AGRONOMIC PRINCIPLES 

Corn yield is very sensitive to early-season weed competition. 

Weed control systems must provide farmers the opportunity to 

control weeds before they become competitive. The Roundup 

Ready Technology system provides a mechanism to control 

weeds at planting and once they emerge. Farmers are provided 

excellent crop safety and full yield potential, with applications 

made from planting through 4811 of corn height. Drop nozzles 

must be used between 30" and 48" of corn height. Failure to 

control weeds with the right rate, at the right time and with 

the right product, can lead to increased weed competition, 

weed escapes and the potential for decreased yields. Use 

other approved herbicide products with Roundup agricultural 

herbicides if appropriate for the weed spectrum. 

ADDITiONAL INFORMATION 

Use full labeled rate of residual when application is 14 days or more prior to 

planting or when tough grasses are present. e.g., barnyardgrass, shattercane, 

seedling johnsongrass, sandbur. 

Use a minimum of 2.5 pt/A of Harness on woolly cupgrass and wild proso millet. 

Products containing atrazine will provide improved control of cocklebur, giant 

ragweed, Palmer Amaranth and morningglory, 

Tank'mix products such as 2,4'0, dicamba or Status® herbicide with Roundup 

WeatherMAX for control of glyphosate'resistant marestail (horseweed), Palmer 

Amaranth and other difficulHo-control weeds. 

Use 22 to 32 oz/A 01 Roundup WeatherMAX" when morningglory or perennial weeds 

are present or when broad leaf weeds are 411 in height or taller. 

Use 22 to 32 oz/A of Roundup WeatherMAX when morningglory or perennial 

weeds are present. 

Tank"mix products such as 2,4-0, dicamba or Status herbicide with Roundup 

WeatherMAX for control of glyphosate'resistant marestail (horseweed), Palmer 

Amaranth and other dilficulHo-control weeds. 

Products with Roundup Ready 2 Technology Total Season: 

The combined total of pre plant. in-crop and preharvest applications 

of Roundup WeatherMAX can not exceed 5.3 qt/A, The combined total 

of in'crop and preharvest applications can not exceed 66 oz/A. 

"If using another Roundup ilgriculturill herbicide. you must refer 10 Ihe labE'l booklet or Roundup Ready Corn 2 Technology supplemenlallabcl for lliat brand to delermine appropriate use rales.lf using Roundup PawerMAX', applicJlion 

rales oJre Ihe same as tor Roundup WedtherMAX,n using anolher residual herbicide, follow the labeled use rate instructions applicable to Roundup Reildy Com Z. follow all pesticide label requirements . 

.. Atrazine may also be used as a residual herbicide in the Roundup Readv Corn 2 System. 

'''Yau may apply up 10 Ihe full residual herbicide labeled rale lor corn. 

MONSANTO 
WEED RESISTANCE MANAGEMENT FOR CORN 

WITH ROUNDUP READY TECHNOLOGY 

• Or apply a pre-emergence residual herbicide at the recommended 

rate tank-mixed with Roundup WeatherMAX" at a minimum of 

Follow all pesticide label requirements and the guidelines below 

to minimize the risk of developing glyphasate-resistant weed 

populations in a Roundup Ready Technology system. 

22 az/A in-crop before weeds exceed 4" in height. 

• Follow with a postemergence in-crop application of Roundup 

WeatherMAX at a minimum of 22 az/A for additional weed 

flushes before they exceed 4" in height. 

• Start clean with a burndown herbicide or tillage. Early-season 

weed control Is critical to yield. 

• Roundup WeatherMAX may be tank-mixed with other herbicides 

for postemergence weed control. 

• Apply pre-emergence residual herbicides such as Harness Xtra, 

Degree xtra or other residual herbicides at the recommended rate. 

• Report repeated non-performance to Monsanto or your 

local retailer. 

RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS IN PRODUCTS 

WITH ROUNDUP READY TECHNOLOGY 

Glyphosate-Resistant 

Marestail (Horseweed) 

Glyphosate-Resistant 

Amaranthu5 Species 

- Palmer Amaranth 

- Waterhemp 

G Iyphasa te-Resistant 

Ambrosia Species 

- Giant Ragweed 

- Common Ragweed 

Glyphosate-Resistant 

Johnsongrass 

start clean with a burndown program or tillage. 

-Tank-mix Roundup agricultural herbicides with 2,4-0, or dieamba, according to the label directions, 

In-crop, tank-mix 22 ounces per acre of Roundup WeatherMAX with Clarity· (B 10 16 fluid ounces per acrel or 2,4-0 

10.5 to 1.0 Ib active ingredient per acre) from corn emergence to the 5·leal stage of corn grawlh (approximalely B" talil. 

Or tank'mix 22 ounces per acre of Roundup WeatherMAX with 5 ounces per acre of Status® herbicide when the corn is 

4" to 36" tall (V2 to VIO). 

Marestail should not exceed 611 in height at the time of in-crop application. -~~ 

Slarl clean with a burndawn program or tillage. 

Use a residual herbicide such as Harness Xtra, Harness Xtra 5.6L. Degree Xtra or other residual herbicide either 

preemergence or in-crop for control of Amaranthus species. 

In'crap, tank-mix Roundup WeatherMAX with other herbicides such as 2,4-0, dieamba (Clarity or Banvel®) or status 

herbicide 10 control emerged weeds. Applications of status herbicide should be made when the corn is between 

4" and 36" tall (V21a VlO), follow all label directions. 

Amaranthus species should not exceed 311 in height at the time of in-crop application. 

Starl clean with a burndawn program or tillage. 

Use a residual herbicide such as Harness Xtra, Harness Xtra 5.6l, Degree Xtra or other residual herbicide either 

preemergence or in-crop for control of Ambrosia species. 

In'crop, tank-mix Roundup WeatherMAX wilh alher herbieides such as 2,4-0, dieamba (Clarity or Banvel) or Slatus 

herbicide 10 canlral emerged weeds. Applications of Status herbieide should be made when the corn is between 

4" and 36" lall (V210 V10). follow all label directions. 

Ambrosia species should not exceed 3" in heighl at the time of in-crop application. 

start clean with a burndown program or tillage. 

Use a residual herbicide such as Harness Xtra, Harness Xtra 5.6L, Degree Xtra or other residual herbicide containing 

atrazine preemergence to reduce the competition from seedling johnsongrass prior to the emergence of corn. 

In-crop, tank-mix Roundup WeatherMAX wilh a herbicide such as Accent", Equip" or Option· lor control of emerged 

weeds including seedling and rhizome johnsangrass. follow all label directions of tank-mix partners, especially Ihase 

related to weed size. 

In certain areas, Italian ryegrass is known to be resistant to glyphosate. For control recommendations, refer to www.weedreslstancemanagement.com 

or call1-800-768-6387. When approved, supplemental labeling for specific herbicide products can also be viewed on www.cdms.netorwww.greenbook.net. 

'Follow all pesticid~ label requirements2010 TECHNOLOGY USE GUIDE II 

Genuity'" Bollgard II' and Boligard'"' Cotton Descriptions 

Bcllgardll 

GENUITY'" BOLLGARD II' COTTON 

Genuity·· Boligard [F" cotton contains two distinct insecticidal 

proteins from Bacillus thuringiensis (B.t.) that increase the efficacy 

and spectrum of control and reduce the chance that resistance 

will develop to the B.t. insecticidal proteins, relative to 8ollgardl'! 

cotton. Genuity'" Bollgard [!~ cotton normally provides excellent, 

season-long control of tobacco budworm, pink bollworm and 

cotton bollworm. Genuity'" Bollgard W' cotton provides good 

protection against fall armyworm, beet armyworm, cabbage 

and soybean loopers and other secondary leaf- or fruiHeeding 

caterpillar pests of cotton. Applications of insecticides to 

control these insects are substantially reduced with Genuity'" 

Bollgard Ir~ cotton. 

The U.S. Environmental Protection Agency has mandated 

the following terms and conditions:* 

• Bollgard"cotton may be sold through September 30,2009. After that 

date. all sales of Bollgard cotton are prohibited. 

• All Bollgard cotton seed must be planted by midnight of July 1, 2010 

(the expiration date of the Bollgard cotton registration). After July 1. 

2010, planting of Boligard cotton seed is prohibited. Any Bollgard cotton 

seed not planted on or before July 1, 2010, must be returned to either 

the retailer or to Monsanto. No refunds are to be issued on Bollgard 

cotton seeds bought for planting in 2010 and returned by growers. 

• An adequate amount of refuge seed must be purchased for planting 

an appropriate refuge for Bollgard cotton. Purchase of refuge seed 

with the Bollgard cotton seed is mandatory, and such seed must be 

purchased by growers In advance of theIr receipt of Bollgard cotton 

"-It is a violation of federal law to sell or distribute an unregistered pesticide. 

NOTE: Sale or commercial planting of Bollgard'''cotton is prohibited in 

certain states, Including: Arizona, California, Colorado, Kansas, New Mexico 

and Oklahoma. 

Sale or planting of Bongard Is prohibited in the Texas counties of: Carson, 

Dallam, Hansford, Hartley, Hutchison, LIpscomb, Moore, Ochlltree, Roberts, 

and Sherman. 

Sale or commercial planting of both Genuity"' Bollgard II" and Bollgard 

Is prohIbIted In Hawaii, Puerto Rico, the U.S. VIrgIn Islands, and In Florida 

south of Route 60 (near Tampa). 

BOI~ td 

BOLLGARD' COTTON 

Bollgard cotton contains a single insecticidal protein from 

B.t. that provides good control against three major lepidopteran 

insect pests of cotton. Specifically, Bollgard cotton provides 

excellent, season~long control of tobacco budworm and pink 

bollworm, and suppression of cotton bollworm. When the 

above~mentioned insect larvae feed on Bollgard cotton plants, 

the B.t. protein protects the plants from damage by reducing 

larval survival. Under high infestation, application of insecticides 

may be necessary to protect 80llgard cotton. 

seed. Any seed purchased for use as a refuge is non'refundable, 

unless the proportional amount of Bollgard cotton seed that the 

refuge seed would have supported is returned at the same time. 

• Any order for replacement or additional Bollgard cotton seed for 

the 2010 planting season, that does not conform to the requirements 

stated above must be filled with Genuity'" Bollgard 11 10 cotton seed 

(or other products with current registrations). 

• On-farm IRM assessments will be conducted during the planting season. 

• In 2010, Bollgard cotton may only be planted in: Alabama, Arkansas, 

Florida (North of florida Route 60), Georgia. Kentucky, Louisiana, 

Maryland, Missouri, Mississippi, North Carolina, South Carolina, 

Tennessee, Texas (excluding the ten prohibited Texas panhandle counties 

of: Dallam, Sherman, Hansford, Ochiltree, Lipscomb, Hartley, Moore, 

Hutchinson, Roberts, and Carson) and Virginia. 

The B.t. delta endotoxin protein expressed in this cotton targets certain cotton 

Insect pests. Routine applicatIons of insecticIdes to control certain Insects are 

usually unnecessary when cotton contaInIng the B.t. delta endotoxin protein Is 

planted. However, Jf Insecticide appl1cations are necessary to control certaIn 

cotton Insect pests, follow all label requirements. 

2010 TECHNOLOGY USE GUIDE 
Genuity" Boligard II" and Boligard" Cotton 

GolF 

ncllgardl! 

INSECT RESISTANCE MANAGEMENT (IRM) 

Lepidopteran cotton pests have demonstrated the ability 

to develop resistance to many chemical insecticides. As a pre~ 

emptive measure, Genuity'" BoHgard II':!> and Bollgard''' cotton must 

be managed in ways that will retard insect resistance development. 

These practices are designed to ensure that some lepidopteran 

populations are not exposed to the B.t. proteins so they can 

maintain susceptibility in select populations. In order to achieve 

this, refuge cotton that does not contain B.t. proteins must 

be planted. 

GENUITY'" BOLLGARD II - DUAL EFFECTIVE DOSE 

Resistance management is critical to the long-term viability 

of our technology and the benefits realized by our farmer 

customers. 2010 is a transition year for Monsanto B.t. cotton 

products as we shift all U.S. cotton acres toward the two-gene 

insect control product, Genuity'" BoHgard 11'" cotton. The move 

to multiple-gene products, including Genuity'· Bollgard II'''', offers 

dua! effective modes of action against target insect pests, 

increasing the longevity of the technology. 

INTEGRATED PEST MANAGEMENT (lPM) 

Integrated Pest Management (IPM) is an effective and environmentally sensitive approach to pest management that relies 

on a combination of cammon-sense practices. IPM programs use 

current, comprehensive information on the life cycles of pests 

and their interaction with the environment. This information 

is used to manage pests in a manner that is least harmful 

to people, property and the environment. 

Prevention 

Using the best agronomic management practices in conjunction 

with the appropriate cotton varieties will yield the greatest benefits. 

Use varieties, seeding rates and planting technologies 

appropriate for each specific geographical area. As much 

as possible, manage the crop to avoid plant stress. 

• Employ appropriate scouting techniques and treatment decisions 

to preserve beneficial insects that can provide additional insect 

pest control. 

MONSANTO 

. Manage for appropriate maturity and harvest schedules. destroy 

stalks immediately after harvest to avoid regrowth and minimize 

selection for resistance in late-season Infestations . 

• Use soli management practices that encourage destruction 

of over-wintering pupae. 

Monitor and Identify 

Fields should be carefully monitored for all pests, including cotton 

bollworms, to determine the need for remedial insecticide treatments. For target pests, scouting techniques and supplemental 

treatment decisions should take into account the fact that larvae 

must hatch and feed before they can be affected by the B.t. 

protein(s) in either Genuitym Bollgard I[:l' or Bollgard cotton. Fields 

should be scouted regularly, following periods of heavy or sustained 

egg lay, especially during bloom, to determine if significant larval 

survival has occurred. Scouting should include a modified wholeplant inspection, including terminals, squares, blooms, bloom tags 

and small bolls. Larvae larger than 1/4 inch (3- to 4-days old) are 

generally recognized as survivors that may not be controlled 

by Genuity' Bollgard II' or Bollgard cotton. 

Read the lRM/Grower Guide prior to planting for information on planting and Insect Resistance Management. 

If you do not have a copy of this Guide, you may download 

it at www.monsanto.com. or cal! 1-800-768~6387 to 

request a copy by mail. 

Control 

Monsanto recommends the use of appropriate remedial 

insecticide treatments to ensure desired levels of control 

if any cotton insect pest reaches locally established thresholds 

in Genuity'" Bollgard II'" or Bollgard cotton. 

Although Genuityt. Bollgard II" and Bollgard cotton will sustain 

less damage from some of the most troublesome lepidopteran 

pests, they will not provide protection against non-lepidopteran 

species. These insects should be monitored and treated with 

insecticides when necessary, using recommended thresholds. 

Whenever possible, select insecticides that are least harmful 

to beneficial insects. 

NOTE: In 2010, sale or commercial planting of Boligard' cation Is prohibited In the following 

states: Arizona, California, Colorado, Kansas, New Mexico aml Oklahoma . 

In 2010, sale or planting of 8ollgard' is prohibited in the Texas counties of: Carson. Dallam. 

Hansford. Hartley. Hutchison, Lipscomb, Moore. Ochiltree. Roberts, and Sherman. 

In 2010, sale or commercia! planting of both Genuity~ 80llganl II' and 8ol!gard~ is prohibited in 

Hawaii. Puerto Rico, and the U,S, Virgin Islands, or in Florida south of Route 60 (near Tampa). 
Roundup Ready<'> Cotton, Genuity'" Boligard II" with Roundup Ready@ 

Cotton and Bollgard with Roundup Ready Cotton 

ROUNDUP READY COTTON 

Roundup Ready'" cotton varieties contain in~plant tolerance 

to Roundup'!!) agricultural herbicides, enabling farmers to 

make in-crop applications of Roundup WeatherMAX'E' or 

Roundup PowerMAX'~ according to label requirements. 

MARKET OPTIONS 

Gin by-products of cotton containing Monsanto's biotech traits, 

including cottonseed for feed uses, are fully approved for export 

to Canada, Japan, Mexico and South Korea. Cottonseed containing 

Monsanto traits may not be exported for the purpose of 

planting without a license from Monsanto. 

It is a violation of national and international law to move 

material containing biotech traits across boundaries into 

nations where Import is not permitted. 

RECOMMENDED MANAGEMENT PRACTICES 

Managing Roundup Ready cotton, Bollgard with Roundup Ready 

cotton and Genuity''' Bollgard I(:ll with Roundup Ready@cotton 

requires that a farmer follow the recommended management 

practices associated with cotton containing each individual trait. 

Farmers of Bollgard with Roundup Ready cotton and Genuity'" 

Bollgard II'" with Roundup Ready'"' cotton varieties must follow 

the same guidelines for establishing required refuge options, 

practicing IRM and managing target and non-target pests as 

described for Bollgard and Genuity'" Bollgard IP cotton in the 

IRM/Grower Guide. 

APPLICATION OF ROUNDUP WEATHERMAX" 

AND ROUNDUP POWER MAX" 

Roundup Ready cotton is genetically 

improved to provide tolerance to 

glyphosate, the active ingredient in 

Roundup agricultural herbicides. 

Roundup Ready cotton can receive 

over-the-top applications of Roundup 

agricultural herbicides only through the 

four-leaf stage. With the Introduction mACK"- t:DUTn"- Mora than Four, Poat·DlraC'!. 

BoUganili 

GENUITY'" BOLLGARD II WITH ROUNDUP READY 

COTTON AND BOLLGARD WITH ROUNDUP READY 

COTTON 

Genuity·~ Bollgard II'" with Roundup Ready:fO cotton and Boligard 

with Roundup Ready varieties offer farmers the benefits of both 

insect protection and glyphasate tolerance combined in one 

crop. These varieties exhibit the same insect protection qualities 

as Genuity"" Boligard W' and Boligard cotton and enable farmers 

to make in-crop applications of Roundup WeatherMAX or 

Roundup PawerMAX according to label requirements. 

of Genuity''' Roundup Ready'" Flex cotton, there is the potential 

for both Roundup Ready cotton and Genuity·· Roundup Readyf) 

Flex cotton to be used on a farmer's farm. This creates concern 

for the crop safety of Roundup Ready cotton. Monsanto 

recommends that farmers: 

• Maintain accurate records of which technologies have been planted 

and where they have been planted. 

• Communicate the field plan with other members of their work 

force to ensure proper applications for each technology. 

• Clearly mark fields to indicate which technology has been planted. 

WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow all pesticide label requirements and these guidelines 

to minimize the risk of developing glyphosate-resistant weed 

populations in a Roundup Ready cotton system: 

• Scout fields before and after each burndown and in-crop application. 

• Start clean with a burndown herbicide program or tillage. 

• Use the right herbicide product at the right rate and right time. 

• Add soil residual herbicide{s) and cultural practices as part 

of a Roundup Ready weed control program. 

• In-crop, apply Roundup WeatherMAX at a minimum of 22 ozlA 

when weeds are less than 6" in height. 

• Tank-mix other approved herbicides with Roundup WeatherMAX 

if necessary for postemergence weed control. 

• Clean equipment before moving from field to field to minimize 

the spread of weed seed (as well as nematodes, insects and other 

cotton pests). 

• Should repeated non-performance occur, report to Monsanto 

or your local retailer. 

2010 TECHNOLOGY USE GUIDE 
WEED CONTROL RECOMMENDATIONS 

Weed control in cotton is essential to help maximize both fiber 

yield and quality potential. Cotton is very sensitive to early~ 

season weed competition, which can result in unacceptable 

stands and/or reduced yield potential. The Roundup Ready"" 

cotton system provides farmers with the right tools to control 

weeds before they become competitive. 

PROGRAM 

Preplant Burndown 

Residual Herbicides 

Over-The-Top 

through 

Fourth Leaf 

Selective Equipment 

Preharvest 

Over-The-Top 

Applications 

INSTRUCTIONS AND USE RATES' 

Always start clean by planting into a weed-free field using 

either tillage or a burndown application. 

In no-till and reduced-till systems, apply a preplant burndown 

application of Roundup WeatherMAX··· at 11 to 44 oz/A in a 

tank-mix with dicamba or 1,4-D, 

See the dicamba and 1,4-D product label for rates and time 

intervals required between application and cotton planting. 

State restrictions may apply. 

Apply residual herbicide(s) as part of a Roundup Ready cotton 

weed control program. Use the recommended label rate and 

timing of the residual herbicide applied. Refer to individual 

product labels for list of residual herbicides that may be used. 

Apply Roundup WeatherMAX over the top from crop emergence 

through the fourth true-leaf (node) stage (until the fifth true 

leaf reaches the size of a quarter). 

Two applications can be made during this period at a maximum 

rate of 11 aliA per application, 

Refer to the "Annual Weeds Rate Table" in the Roundup 

WeatherMAX label for rate recommendations for specific 

annual weeds. 

After the fourth true-leaf stage through layby, Roundup 

WeatherMAX may be applied using precision post-directed 

or hooded sprayers which direct the spray to the base of 

the cotton plant. 

Two post-directed applications can be made during this period 

at a maximum rate of 12 aliA per application. 

Before harvest and after cotton reaches 10% boll-crack, if 

needed, apply up to 44 aliA of Roundup WeatherMAX. 

This treatment is effective in controlling late-season perennial 

weeds and can improve harvest efficiency. 

ADDITIONAL INFORMATION 

Early-season weed competition can result in unacceptable 

stands andlor reduced yield potential. 

This tank-mix is recommended for control and management 

of glyphosate-resistant marestail (Conyza sp.) or other 

tough-to-control weeds. 

Burndown application should be made far enough 

in advance of planting to control existing weeds. 

The residual herbicide(s) may be applied as either a 

preemergence (including preplant incorporated), 

postemergence, andlor layby application as allowed 

on the label of the specific product being used. 

In-crop over-the-top applications must be at least ID days apart 

and the cotton must have at least two nodes of incremental 

growth between applications. Care should be taken to record 

growth stage at first application. 

In situations where the potential for weed infestations is high 

(including perennial weeds), make the first application early 

enough to allow a second application before cotton exceeds the 

fourth true-leaf stage. Over-the-top applications after the fourth 

true-leaf stage can result in boll loss, delayed maturity, andlor 

yield loss. 

Place nozzles in a low horizontal position to permit spray 

pattern to overlap in the row while contact of spray solution 

with cotton leaves should be avoided to the maximum extent 

possible. Excessive foliar contact can result in boll loss, delayed 

maturity, andlor yield loss. 

There must be two nodes of growth and at least 10 days between 

applications. 

Applications must be made at least 7 days prior to harvest. 

Roundup agricultural herbicides are not effective for 

preharvest cotton regrowth in Roundup Ready cotton. 

Do not apply Roundup agricultural herbicides preharvest 

to crops grown for seed under contract at an authorized cotton 

seed company. 

Roundup Ready cotton has excellent vegetative tolerance to Roundup WeatherMAX allowing early-season over-the-top applications. Incomplete 

reproductive tolerance requires that applications after the 4-leaf (node) stage be properly post-directed. 

ATTENTION: Use of Roundup agricultural herbicides in accordance with label directions is expected to result in normal growth of Roundup Ready cotton, 

however, various environmental conditions, agronomic practices, and other factors make it impossible to eliminate all risks associated with the product, 

even when applications are made in conformance with the label specifications. In some cases, these factors can result in boll loss, delayed maturity, 

andlor yield loss. 

-Follow all pesticide label requirements. 

*-If using another Roundup agricultural herbicide, you must refer to the label booklet or Roundup Ready cotton supplemental label for that brand to determine appropriate use rates. If using 

Roundup PowerMAX", application rates are the same as for Roundup WeatherMAX. 

MONSANTO 
IIcllg.rdll 

-

B~~!9Qfd Roundup Ready Catton 

RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS 

Glyphosate-Reslstant 

Marestail (Horseweed) 

Glyphosate-Reslstant 

Amaranthus Species 

~ Palmer Amaranth 

- Waterhemp 

Glyphosate-Resistant 

Ambrosia Species 

- Giant Ragweed 

~ Common Ragweed 

Glyphosate-Reslstant 

Johnsongrass 

Start clean with a burndown herbicide program or tillage. 

-Tank-mix Roundup agricultural herbicides with dicamba or 2,4-D (consult label for plant back timing). 

If you have dense stands of marestail, use a preplant residual herbicide at the recommended rate and 

timing, such as diuron (Direx®) or flumioxazin (Valor®). 

Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oliA to control other weeds. 

In-crop, if applying post-directed to glyphosate-resistant marestail, Roundup WeatherMAX can be tank-mixed 

with other herbicides, such as diuron or MSMA. 

Marestail should be less than 6" in height at the time of in-crop application. 

Start clean with a burndown herbicide program or tillage. 

Apply a preemergence residual herbicide such as pendimethalin (Prowl®) plus fluometuron or fomesafen 

(Reflex®) or flumioxazin (Valor) for control of Amaranthus species. 

In-crop, tank'mix Roundup WeatherMAX at 22 oz/A with metolachlor or other labeled chloracetamide herbicide 

before Amaranthu5 species emerges. 

Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oliA to control other weeds. 

A post-directed application of Roundup WeatherMAX tank-mixed with MSMA and a residual such as diuron 

(Direx) or flumioxazin (Valor) should be made to control Amaranthus spedes 3" or smaller in height and 

prevent additional flushes. --_ .... _--_. __ .•. _-

Start clean with a burndown herbicide program or tillage. 

Apply a preemergence residual herbicide such as pendimethalin (Prowl) plus fluometuron or fomesafen 

(Reflex)for control of Ambrosia species. 

In-crop, tank'mix Roundup WeatherMAX at 22 oliA with metolachlor before Ambrosia species emerges. 

Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oliA to control other weeds. 

A post-directed application of Roundup WeatherMAX tank-mixed with MSMA and a residual such as diuron (Direx) or 

flumioxazin (Valor) should be made to control Ambrosia speCies 3" or smaller in height and prevent additional flushes. 

Start clean with a burndown herbicide or tillage. 

Pre plant incorporate a residual herbicide such as pendimethalin or trifluralin for control or suppression of seedling 

johnsongrass. 

Apply Roundup WeatherMAX in a tank-mix with herbicides such as SelectMAX®, Assure® II or Poast Plus for the control of 

emerged weeds including seedling and rhizome johnsonqrass. Follow all label directions of tank-mix partners, especially 

those related to weed size. ---_.--_ .. _._ ............ _._ ... _--_ .. - ---_ ..... . 

In certain areas, Italian ryegrass is known to be resistant to glyphosate. For control recommendations, refer to www.weedresistancemanagement.com 

or call 1-800-768-6387. When approved, supplemental labeling for specific herbicide products can also be viewed on www.cdms.netorwww.greenbook.net. 

-Follow all pesticide label requirements. 

2010 TECHNOLOGY USE GUIDE 
Genuity" Roundup Ready® Flex Cotton and 

Genuity'" Boligard II" with Roundup Ready" Flex Cotton 

Roundup Ready Flex 

GENUITY'" ROUNDUP READY' FLEX COTTON 

Genuity'~ Roundup Ready" Flex cotton varieties possess improved 

reproductive tolerance to Roundup® agricultural herbicides. This 

technology gives farmers the opportunity to make Dver-the-top 

broadcast applications of labeled Roundup agricultural herbicides 

from crop emergence up to seven (7) days prior to harvest. 

MARKET OPTIONS 

Genuity'" Roundup Ready!i Flex cotton and Genuity'" Bollgard II® 

with Roundup Ready Flex cotton have regulatory clearance 

in the United states, but do not have import approval in all 

export markets. Processed fractions from these products, 

including linters, oil, meal, cottonseed and gin trash, must not 

be exported without all necessary approvals in the importing 

country. It is a violation of national and international law to 

move material containing biotech traits across boundaries 

into nations where import is not permitted. 

RECOMMENDED MANAGEMENT PRACTICES 

Managing Genuity'" Roundup Readye Flex cotton and Genuity'" 

Bollgard II;' with Roundup Ready'" Flex cotton requires a farmer 

to follow the recommended management practices associated 

with cotton containing each individual trait. Farmers of Genuity'" 

Bollgard Jr" with Roundup Ready']O Flex cotton must follow 

the same guidelines for establishing required refuge options, 

practicing IRM and managing target and non·target pests as 

described for Genuity'" Bollgard IF' cotton in the IRM/Grower Guide. 

WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow all label requirements and the guidelines below to 

minimize the risk of developing weed resistance in a Genuity .... 

Roundup Ready'" Flex cotton system: 

o Scout fields before and after each burndown and 

in-crop application. 

o Start clean with a burndown herbicide program or tillage. 

• Use the right herbicide product at the right rate and right time. 

MONSANTO 

ADundup BaUg:mlll 

Ready Flllx 

GENUITY'" BOLLGARD II' WITH ROUNDUP READY' 

FLEX COTTON 

Genuity'" Boligard W' with Roundup Ready~ Flex varieties offer 

farmers the benefits of both insect protection and glyphosate 

tolerance combined in one crop. These varieties exhibit the 

same insect protection qualities as Genuity!~ Bollgard 11'" and are 

tolerant to Dver-the-top applications of Roundup WeatherMAX'" 

and Roundup PowerMAX®. 

o Add soil residual herbicide(s) and cultural practices as part of 

a Genuity'" Roundup Ready® Flex cotton weed control program. 

• In-crop, apply Roundup WeatherMAX at a minimum of 22 oz/A 

when weeds are 31t to 61t in height. 

o Tank-mix other approved herbicides with Roundup WeatherMAX 

If necessary for paste mergence weed control. 

• Should repeated non-performance occur, report to Monsanto or 

your local retailer. 

o Clean equipment before moving from field to field to minimize the 

spread of weed seed (as well as nematodes, insects and other 

cotton pests). 

APPLICATION OF ROUNDUP WEATHERMAX' AND 

ROUNDUP POWERMAX' 

• May be applied over-the-top and/or in-crop, from crop emergence 

up to 7 days pr'lor to harvest. 

o A maximum rate of 32 oz/A per application may be applied using 

ground application equipment while the maximum is 22 ozlA per 

application by air. 

o There are no growth or timing restrictions for sequential 

applications. 

• Four (4) quarts/A is the total in-crop volume allowed from 

emergence to 60% open bolls. 

• A maximum total volume of 44 oz/A may be applied between 

layby and 60% open bolls. 

• Post-directed equipment may be used to achieve more thorough 

spray coverage of weeds or if herbicides not labeled for overthe-top application will be tank-mixed with Roundup WeatherMAX 

or Roundup PowerMAX . 
PREHARVEST APPLICATIONS 

• up to 44 az/A may be applied after cotton reaches 60% open bolls 

and before harvest, jf needed . 

• Applications must be made at least 7 days prior to harvest. 

Over-The-Top (example) 

22-32 az/A In any single application 

Preharvest 

440zfA 

128 az/A total In-crop application (emergence to preharvest) 

CROP SAFETY OF OVER-THE-TOP GLYPHOSATE 

APPLICATIONS 

Monsanto has determined that a combination of components in 

glyphosate formulations have the potential to cause leaf injury 

when applied during later stages of crop growth. Roundup 

WeatherMAX and Roundup PowerMAX are the only Roundup 

agricultural herbicides labeled and approved for new labeled 

uses over the top of Genuity'~ Roundup Ready~ Flex cotton. 

Leaf injury may occur if the products are not used according 

to the product label. used at higher than recommended rates 

or if overlap of spray occurs in the field. Farmers must confirm 

that any glyphosate formulation to be used on GenultyT~ 

Roundup Ready<!l Flex cotton has been labeled for use on 

GenuityT~ Roundup Ready® Flex cotton and should confirm 

that it has been tested to demonstrate crop safety. 

2010 TECHNOLOGY USE GUIDE 
WEED CONTROL RECOMMENDATIONS 

Weed control in cotton is essential to maximize both fiber yield 

and quality potential. Cotton is very sensitive to early-season 

weed competition, which can result in unacceptable stands and! 

or reduced yield potential. The Genuity'" Roundup Ready~ Flex 

cotton system, with improved reproductive tolerance to 

Roundup® agricultural herbicides, provides farmers with the 

right tools to control weeds, 

PROGRAM 

Preplant Burndown 

Residual Herbicides 

INSTRU~TIONS AND USE RATES' 

Always start clean by planting into a weed-free field 

using either tillage or a burndown application. 

In no-till and reduced-till systems, apply a preplant 

burndown application of Roundup WeatherMAX®" 

at 22 to 44 oz/A in a tank'mix with dicamba or 2,4-D. 

See the dicamba and 2,4-D produd label for rates 

and time intervals required between application 

and cotton planting. State restridions may apply • 

ADDITIONAL INFORMATION 

Early-season weed competition can result in unacceptable stands 

andlor reduced yield potential. 

This tank-mix is recommended for control and management 

of glyphosate-resistant marestail (Conyza sp.) or other toughto-control weeds. 

Burndown application should be made far enough 

in advance of planting to control existing weeds. 

. -------~--.--.---- ---. --------~-----.---

Apply approved residual herbicide(s) as part of a 

Genuity'" Roundup Ready® Flex cotton weed control 

program, Use the recommended label rate and timing 

of the residual herbicide applied. Refer to individual 

product labels for list of residual herbicides that may 

be used . 

The residual herbicide(s) may be applied as either 

a preemergence (including preplant incorporated), 

paste mergence, andlor layby application as allowed 

on the label of the specific product being used. 

. _-----------_._-_.- -- _._--------_._-_. 

In-Crop Weed Control Target the first application of Roundup WeatherMAX 

on 1-2 leaf cotton when weeds are small. 

Applya minimum of 22 oz/A of Roundup WeatherMAX 

in-crop. 

The need for sequential applications of Roundup 

Weather MAX will depend upon the occurrence of 

subsequent weed flushes. 

Reier to the "Annual Weeds Rate Table" in the 

Roundup WeatherMAX label booklet for rate 

recommendations for specific annual weeds. 

Early-season weed competition can reduce yield potential 

in cotton. 

Seled timing of application based on the most difficult 

to control weed species in your field. 

Post-direct or hooded sprayers can be used to achieve 

more thorough spray coverage on weeds. 

---_._-----_._-- ~~-----------"----~-------"'---

Preharvest Over-The-Top 

Applications 

*Follow all pesticide label requirements. 

Before harvest and after cotton reaches 60% 

open bolls, if needed, apply up to 44 oz/A of 

Roundup WeatherMAX. 

This treatment is effective in controlling late-season 

perennial weeds. 

Applications must be made at least 7 days prior to harvest. 

Roundup agricultural herbicides are not effedive for pre harvest 

cotton regrowth in Genuity" Roundup Ready® Flex cotton. 

-*The maximum volume of Roundup WeatherMAX and Roundup PowerMAX~ that may be used in a single season 155.3 quarls per acre. 

MONSANTO 
Roundup Ball~,rd!l 

Roundup Ready Flex Re~dy Rex 

RECOMMENDATIONS FOR MANAGING GLYPHOSATE-RESISTANT WEEDS 

Glyp hosate-Res istan t 

Marestail (Horseweed) 

Glyphosate-Resistant 

Amaranthus Species 

~ Palmer Amaranth 

- Waterhemp 

Glyphosate-Reslstant 

Ambrosia SpeCies 

- Giant Ragweed 

- Common Ragweed 

G Iyp hosa te-Reslsta nt 

Jahnsangrass 

start clean with a burndown herbicide program or tillage. 

-Tank-mix Roundup agricultural herbicides with dicamba or 2,4-0 (consult label for plant back timing). 

If you have dense stands of marestail, use a pre plant residual herbicide at the recommended rate and 

timing, such as diuron (Direx@) or flumioxazin (Valo("'). 

Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oi/A to control other weeds, 

In-crop, if applying post-directed to glyphosate-resistant mares tail. Roundup WeatherMAX can be tank-mixed 

with other herbicides, such as diuron or MSMA. 

Marestail should not exceed 6" in height at the time of in-crop application. 

Start clean with a burndown herbicide program or tillage, 

Apply a preemergence residual herbicide such as pendimethalin (Prowl®) plus fluometuron or fomesafen 

(Reflex®) or flumioxazin (Valor) for control of Amaranthus species. 

In'crop, tank'mix Roundup WeatherMAX at 22 oi/A with metolachlor or other labeled chloracetamide herbicide 

before Amaranthu5 species emerges. 

Use Roundup WeatherMAX in-crop, as needed, at a minimum of 22 oi/A to control other weeds. 

A post-directed application of Roundup WeatherMAX tank-mixed with MSMA and a residual such as diuron 

(Direx) or flumioxazin (Valor) should be made to control Amaranthus species 3" or smaller in height and 

prevent additional flushes. 

start clean with a burndown herbicide program or Iillage. 

Apply a preemergence residual herbicide such as pendimethalin (Prowl) plus fluometuron or fomesafen (Reflex) 

for control of Ambrosia species. 

In-crop, tank-mix Roundup WeatherMAX at 22 oz/A with metolachlor before Ambrosia species emerges. 

Use Roundup WeatherMAX in'crop, as needed, at a minimum of 22 oi/A to control other weeds. 

A post-directed application of Roundup WeatherMAX lank-mixed with MSMA and a residual such as diuron 

(Direx) or flumioxazin (Valor) should be made to control Ambrosia species 311 or smaller in height and prevent 

additional flushes. 

start clean with a burndown herbicide or tillage. 

Preplant incorporate a residual herbicide such as pendimethalin or trifluralin for control or suppression of seedling 

johnsongrass. 

Apply Roundup WeatherMAX in a tank-mix with herbicides such as SelectMAX"', Assure' II or Poast Plus for the control of 

emerged weeds including seedling and rhizome johnsongrass. Follow all label directions of tank-mix partners, especially 

those related to weed size. 

In certain areas, Italian ryegrass is known to be resistant to glyphosate. For control recommendations, refer to www.weedresistancemanagement.com 

or calil-BOO·768-63B7. When approved, supplemental labeling for specific herbicide products can also be viewed on www.cdms.netorwww.greenbook.net. 

'Follow all pesticide label requirements. 

2010 TECHNOLOGY USE GUIDE II 

FWundup Ready Z Yield 

GenuityW Roundup Ready 2 Yield® and Roundup Ready® soybean 

varieties contain in-plant tolerance to Roundup® agricultural 

herbicides. This means you can spray Roundup agricultural 

herbicides in-crop from emergence through flowering. 

Spray labeled Roundup agricultural herbicides over the top from 

emergence (cracking) through flowering (R2 stage soybeans) 

WEED CONTROL RECOMMENDATIONS 

Starting clean with a weed~free field, and making timely post~ 

emergence in~crop applications, is critical to obtaining excellent 

weed control and maximum yield potential. The Roundup Ready 

soybean system provides the flexibility to use the herbicide tools 

necessary to control weeds at planting and in-crop. Failure to 

control weeds with the right rate, at the right time and with the 

right product, can lead to increased weed competition and the 

potential for decreased yield. 

for unsurpassed weed control, proven crop safety and maximum 

yield potential. R2 stage soybeans end when a pod 5 millimeters 

(3/1611 ) long at one of the four uppermost nodes appears on the 

main stem along with a fully developed leaf (R3 stage). 

PROGRAM 

Preplant Burndown 

Residual Herbicide 

Plus Roundup 

WealherMAX 

INSTRUCTIONS AND USE RATES' 

To start clean in no-till systems. apply a burndown application 

of Roundup WeatherMAX®" at 22 to 44 oziA before planting. 

See the label for appropriate rates by weed species. For control 

and management of glyphosate-resistant marestail (Conyza sp.) 

or other difficult-to-control weeds present at burn down. apply 

22 oziA of Roundup WeatherMAX in a tank-mix with I to 2 ptiA 

2,4-0. Make applications 7 to 3D days before planting and before 

marestail reaches 611 in height. 

Use the recommended label rate of a soil-applied residual 

herbicide applied preemergence to soybeans as defined in 

the individual product's labeling. The residual product may be 

tank-mixed with Roundup WeatherMAX at burndown. Refer to 

individual product labels for list of residual herbicides that 

may be used, 

Follow with 22 oziA Roundup WeatherMAX in-crop when weeds 

are 2" to 8" tall. Refer to the "Annual Weeds Rate Table" in the 

Roundup WeatherMAX label for rate recommendations for 

specific annual weeds. 

Crop rotation following Genuity" Roundup Ready 2 Yield® and 

Roundup Ready soybeans is strongly encouraged. Use of a 

residual herbicide is encouraged especially if the cropping 

system is a continuous Roundup Ready system, 

ADDITIONAL INFORMATION 

Always start with a weed-free field_In no-till and reduced-till 

systems, apply a Roundup WeatherMAX' burndown application 

to control existing weeds before planting. 

Adding 2,4-0 in the burndown can significantly reduce 

broad leaf weed pressure at post-emergence timing. 

Read the 2,4-0 product label for time intervals required 

between application and soybean planting. 

-------- ----

A residual program is encouraged when agronomic conditions 

favor the practice. 

Reducing Roundup WeatherMAX rate when tank-mixing with 

a residual or use of premixes utilizing a reduced rate of 

glyphosate (such as Extreme·) is not recommended. If the 

in-crop application is delayed and weeds are larger, apply a 

higher rate of Roundup WeatherMAX. 

----------_ .. _-------

Roundup WealherMAX Apply a minimum of 22 oziA of Roundup WeatherMAX" In-crop application of Roundup WeatherMAX provides control 

in-crop when weeds are 21( to 811 tall. of labeled weeds. 

Refer to the "Annual Weeds Rate Table" in the Roundup For best results, apply 3 to 4 weeks after planting or 

WeatherMAX label for rate recommendations for specific when weeds are less than 8" tall. 

annual weeds. Choose the rate to control the most difficult- If initial application is delayed and weeds are larger, 

to-control weed in your field. apply a higher labeled rate of Roundup WeatherMAX. 

A sequential application of this product may be required 

to control new flushes of weeds in the Roundup Ready 

soybean crop. 

If a sequential application is necessary, apply 16 to 22 oziA of 

Roundup WeatherMAX'" when weeds are 311 to 611 tall. 

·Follow all pesticide label requirements. 

._--_._----

Hlfusing another Roundup agricultural herbicide. you must refer to the label booklet or Genuity~ Roundup Ready 2 Yield~ soybean or Roundup Ready soybean supplemental label for that 

brand to determine appropriate use rates, If using Roundup PowerMAX, application rales are the same as for Roundup WeatherMAX. 

2010 TECHNOLOGY USE GUIDE 
PROGRAM 

Glyphosate-Tolerant 

Volunteer COfn 

Maximum Use Rates 

for Roundup 

WeatherMAX 

INSTRUCTIONS AND .USE RATES· 

Tank-mix Roundup WealherMAX· with 6 to 12 oz/A of 

Select Max' and apply 10 4" to 36" glyphosale-Ioleranl 

volunteer corn. 

In-Crop: 

• 44 oz/A per single application 

• 44 oz/A during flowering 

• 64 oz/A emergence through flowering (R2 slage soybeans) 

Preharvest: 

• 22 oz/A application 

-Follow all pesticide label requirements. 

ADDITIONAL INFORMATION 

Choose your Roundup WealherMAX rale based on the 

weed species and size lisled in Ihe "Annual Weeds Rale Table" 

of the Roundup WealherMAX Label. ------

Total Season: 

The combined lolal of preplanl, in'crop and preharvesl 

applications of Roundup WeatherMAX can nol exceed 

5.3 ql/A. The combined lolal of in-crop and preharvesl 

applications can not exceed 64 oz/A. 

Herbicide products sold by Monsanto for use over the top of soybeans with Genuity'" Roundup Ready 2 Yield'!) Technology for the 2010 crop 

season are as follows: 

• Roundup WeatherMAX 

• Roundup PowerMAX 

WEED CONTROL RECOMMENDATIONS 

Weeds that Tend 

to Have Multiple 

Emergence Events 

Where dense stands of weed species such as common 

lambsquarlers, lall and common walerhemp, Paimer 

Amaranth, redrool pigweed, common ragweed, and giant 

ragweed are expected, the following agronomic practices 

are recommended: 

• Start clean wilh tillage or burndown in no-Ii II and reduced 

till syslems, Include 2,4'D in the burndown. 

• Plant soybeans in narrow rows «20"). 

• Use a pre'planl residual herbicide, 

• Use Ihe righl rale of Roundup WealherMAX al Ihe righl 

time (proper weed size). 

Weeds such as lambsquarters, waterhemp, pigweed, and giant 

ragweed lend 10 emerge throughout Ihe season. Sequential 

Roundup WeatherMAX applicalions or Ihe addition of a soil 

residual herbicide may be required for control of subsequent 

weed flushes. 

---._---_ .. _--_._--

Difficult-toControl Weeds Black nightshade, velvetleaf, walerhemp, morningglory, 

lambsquarters, Florida pus ley, giant ragweed, Pennsylvania 

smartweed, groundcherry, hemp sesbania and spurred 

anoda are difficult'lo'conlrol weeds. Please refer to the 

Roundup agricultural herbicide label for specific rates and 

weed sizes for control of these weeds. 

------------------

Perennial Weeds An in'crop application of 22 10 44 oz/A of Roundup 

WeatherMAX" will provide suppression and/or conlrol of 

nutsedge and perennial weeds like Canada Ihistle, field 

bindweed, hemp dogbane, horsenetile, johnsongrass, 

milkweed, quackgrass, etc. 

These weed species require speCial attention be paid 

10 Roundup WealherMAX rale and application timing 

(proper weed size) 10 oblain excellenl weed conlrol. 

A sequential application may be required if a new 

weed flush occurs, especially in soybeans planled 

in wide rows (>20"). 

For additional information on perennial weeds, see the 

"Perennial Weeds Rate Table" in the label booklet for Roundup 

WealherMAX_ 

For besl control. allow perennials 10 achieve al leasl 

6" or more of growth before spraying. ---

*Follow all pesticide label requirements. 

**11 usinQ another Roundup agricu!lural herbicide, you must refer to the label booklat or Roundup Ready Soybean or Genulty~ Roundup Ready 2 Yiald~ Soybean supplemental label for that brand 

to determine appropriate use rates. If using Roundup PowerMAX, application rates are the same as for Roundup WealherMAX. 

WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow all pesticide label requirements and the guidelines below 

to minimize the risk of developing glyphosate-resistant weed 

MONSANTO 

populations in a Roundup Ready Soybean System: 

• Crop rotation is strongly encouraged. 

• Scout fields before and after each burndown and in-crop application. 
RaU!JlupRe:adyZYield 

· Start clean with a burndown herbicide or tillage. • If an additional flush of weeds occurs, a sequential application of 

Roundup WeatherMAX at 22 ozlA may be needed before weeds 

exceed 6" in height. 

- Tank-mix with 2,4-D to control glyphosate-resistant marestail or 

other tough-to-control broad leaf weeds. 

• Use the recommended label rate of a soil-applied residual herbicide 

such as INTRRO®, Valor~'. Valor XLP' or Gangster"'. 

· Refer to individual product labels for a list of recommended 

tank-mix partners. 

• In-crop, apply Roundup WeatherMAX at a minimum of 22 ozlA 

before weeds exceed 811 in height. 

• Clean equipment before moving from field to field to minimize 

the spread of weed seed. 

• Report repeated non-performance to Monsanto or your local retailer. 

RECOMMENDATIONS FOR MANAGING GLVPHOSATE-RESISTANT WEEDS 

Glyphosate-Resistant 

Marestail (Horseweed) 

Glyphosate-Resistant 

Amaranthus Species 

- Palmer Amaranth 

- Waterhemp 

Preplant: 

Applya tank-mixture of 22 o,IA Roundup WeatherMAX® with 1 pI/A 2,4-0 before mares tail exceeds 6" in height. 

See the 2,4-0 product label for time intervals required between application and planting_ 

In-crop: 

It is strongly encouraged that marestailshould be controlled prior to planting using recommended preplant burndown treatments. 

In-crop, apply a tank'mixture of 22 o,IA Roundup WeatherMAX with OJ o,IA FirstRate®. This treatment should be used as a salvage 

treatment only for a marestail infestation that was not controlled preplant. Application should be made between full emergence of 

the first trifoliate leaf and 50% flowering stage of soybeans. At the time of treatment, marestail should not exceed 6" in height. 

.~~~- ------~~ .. 

Preplant: 

Apply a tank-mix of 22 o,IA Roundup WeatherMAX with a pre emergence residual herbicide such as alochlor (lNTRRO®), 

flumioxa,in (Valor®) or another residual herbicide for preemergence control of Amaranthus species. 2,4-0 may be added to 

the tank-mix to help control emerged Amaranthus species and other broad leaf weeds preplant only. Follow label instructions 

regarding application timing relative to soybean planting. 

In-crop: 

It is strongly encouraged that a preemergence residual product be used to control Amaranthus species prior to emergence. 

If there is emerged Amaranfhus in-crop, apply a tank-mixture of 22 o,IA Roundup WeatherMAX with a postemergence product 

with activity on Amaranthus such as lactofen (Cobra®), fomesafen (Flexstar®) or cloransulam (FirstRate). Applications 

should be made on emerged Amaranthus that does not exceed 3" in height. Read and follow all product label instructions. 

It is likely that visual soybean injury will occur with these tank-mixtures. 

----_ ... _ ..... ~~~~-.---.--..... ~~ .---.. -... --~-~.-----... -~~~ 

Glyphosate-Resistant 

Ambrosia SpeCies 

- Giant Ragweed 

- Common Ragweed 

Preplant: 

Apply a tank-mix of 22 o,IA Roundup WeatherMAX with a preemergence residual herbicide such as cloransulam (FirstRate) 

or cloransulam + flumioxazin (Ganster®) or another residual herbicide for preemergence control of Ambrosia species. 2kD 

may be added to the tank·mix to help control emerged Ambrosia species and other broad leaf weeds preplant only. Follow label 

instructions regarding application timing relative to soybean planting. 

In-crop: 

It is strongly encouraged that a preemergence residual product be used to control Ambrosia species prior to emergence. 

If there is emerged Ambrosia in·crop, apply a tank·mixture of 22 o,IA Roundup WeatherMAX with a postemergence product 

with activity on Ambrosia such as lactofen (Cobra) or fomesafen (Flmtar), Applications should be made on emerged 

Ambrosia that does not exceed 3" in height. Read and follow all product label instructions. It is likely that visual soybean 

injury will occur with these tank-mixtures, 

----~---.-.~~~ -~~ .-••. -----~-~~-.---.------

Glyphosate-Resistant 

Johnsongrass 

Start clean with a burndown herbicide or tillage. 

Preplant incorporate a residual herbicide such as pendimethalin or trifluralin for control or suppression of seedling 

johnsongrass. 

Apply Roundup WeatherMAX in a tank· mix with herbicides such as SelectMAX®, Assure" II or Poast Plus for the control of 

emerged weeds including seedling and rhizome johnsongrass. Follow all label directions of tank·mix partners, especially those 

related to weed size. 

-.~--.----.-.. ~~- ~~~-.~ .. ~-.--. ~~~".-.... ---~~~----~~-

In certain areas, Italian ryegrass is known to be resistant to glyphosate. For control recommendations, refer to www.weedreslstancemanagement.com 

or call 1-800-168-6387. When approved, supplemental labeling for specific herbicide products can also be viewed on www.cdms.netorwww.greenbook.net. 

'Follow all pesticide label requirements, 

2010 TECHNOLOGY USE GUIDE 

Roundup Ready 

Genuity'" Roundup Ready® alfalfa varieties have in-plant tolerance to Roundup® agricultural 

herbicides, enabling farmers to apply labeled Roundup agricultural herbicides up to 5 days 

before cutting for unsurpassed weed control, excellent crop safety and preservation of 

forage quality potential. 

Hay and Forage Management Practices 

Genuity'" Roundup Ready!!> alfalfa must be managed for high 

quality hay/forage production, including timely cutting to 

promote high forage quality (i.e. before 10% bloom) and to 

prevent seed development. In geographies where conventional 

alfalfa seed production is intermingled with forage production 

and the agronomic conditions (climate and water/irrigation 

availability) are such that forage alfalfa is allowed to stand and 

flower late in the season, Genuity'" Roundup Ready" alfalfa must 

be harvested at or before 10% bloom to minimize potential 

pollen flow from hay to common or conventional alfalfa seed 

production. Farmers who are unwill1ng to or who can not make 

this commitment to stewardship should not continue to grow 

Genuity'" Roundup ReadylO alfalfa. 

Genuity'" Roundup Ready~ alfalfa varieties have excellent 

tolerance to over-the-top applications of labeled Roundup 

agricultural herbicides. An in-crop weed control program using 

Roundup WeatherMAXs or Roundup PowerMAX~ will provide 

excellent weed control in most situations. A residual herbicide 

labeled for use in alfalfa may also be applied postemergence in 

alfalfa. Contact a Monsanto Representative, local crop advisor or 

extension specialist to determine the best option for your situation. 

Stand Takeout and Volunteer Management 

Crop rotations can be divided into two main groups, alfalfa 

rotated to: 1) grass crops (e.g. corn and cereal crops); and 

2) broadleaf crops. More herbicide alternatives exist for management of volunteer alfalfa in grass crops. The recommended steps 

for controlling volunteer Genuity'" Roundup Ready'" alfalfa are: 

• Diligent Stand Takeout • Plan for Success 

• Start Clean • Timely Execution 

DILIGENT STAND TAKEOUT 

Use appropriate, commercially available herbicide treatments 

alone for reduced tillage systems or in combination with tillage 

to terminate the Genuity'" Roundup Ready/; alfalfa stand. Refer to 

your regional technical bulletin for specific stand takeout recommendations. NOTE: Roundup'" agricultural herbicides are not 

effective for terminating Genuity'· Roundup Ready);) alfalfa stands. 

START CLEAN 

If necessary, utilize tillage and/or additional herbicide 

application(s) after stand takeout, and before planting of 

the subsequent rotational crop to manage any newly 

emerged or surviving alfalfa. 

PLAN FOR SUCCESS 

Rotate the crops with known and available mechanical or 

herbicidal methods for managing volunteer alfalfa, keeping 

in mind that Roundup agricultural herbicides will not terminate 

Genuity'" Roundup Ready~ alfalfa stands. 

• Rotations to certain broadleaf crops are not advisable if 

the farmer is not willing to Implement recommended stand 

termination practices. 

• In the event that no known mechanical or herbicidal methods 

are available to manage volunteer alfalfa in the desired rotational 

crop, it is suggested that a crop with established volunteer 

alfalfa management practices be introduced into the rotation. 

TIMELY EXECUTION 

Implement in-crop mechanical or herbicide treatments for 

managing alfalfa volunteers in a timely manner; that is, before 

the volunteers become too large to control or begin to compete 

with the rotational crop . 

2010 TECHNOLOGY USE GUIDE 
Planting Requirements 

GenuityT>< Roundup Ready'~ alfalfa is not permitted to be planted 

in any wildlife feed plots. 

Stewardship 

All Genuity'" Roundup Ready!> alfalfa farmers shall sign the 

Monsanto Technology/Stewardship Agreement (MTSA) limiteduse license application which provides the terms and conditions 

for the authorized use of the product. Due to special circumstances, alfalfa farmers in the Imperial Valley of California will 

also sign an Imperial Valley Use Agreement (IVUA) with specific 

stewardship commitments. The MTSA Of IVUA must be completed 

before purchase or use of seed. 

Both the MTSA or IVUA explicitly prohibit all forms of commercia! 

seed harvest on the stand. Every alfalfa farmer producing seed 

of Genuity'" Roundup Ready'" alfalfa must possess an additional, 

separate and distinct seed farmer contract to produce Genuity'" 

Roundup Ready" alfalfa seed. Genuity'" Roundup Ready'" alfalfa 

seed may not be planted outside of the United States, or for 

the production of seed or sprouts. 

Any product produced from a Genuity"" Roundup Ready® alfalfa 

crop or seed, including hay and hay products, must be labeled 

and may only be used, exported to, processed or sold in countries 

where regulatory approvals have been granted. It is a violation 

of national and international laws to move material containing 

biotech traits across boundaries into nations where import is 

not permitted. 

Pursuant to a Court Order issued on May 3, 2007, Genuity"" 

Roundup ReadyiE' alfalfa farmers must adhere to the requirements 

set out in the December 18, 2007 USDA Administrative Order 

(http://www.aphis.usda.qov/brs/pdf/RRA_AB_final.pdi) until 

the USDA completes its regulatory process. 

These requirements include, but are not limited to: 

• Pollinators shall not be added to Genuity'" Roundup Ready1fi 

alfalfa fields grown only for hay production. 

• Farm equipment used in Genuity'" Roundup Ready'" alfalfa 

production shall be properly cleaned after use. 

• Genuity" Roundup Ready!! alfalfa shall be handled and clearly 

Identified to minimize commingling after harvest. 

For additional information visit the USDA website: 

http://www.aphls.usda.qov/blotechnoloqy/alfalfa_hlstory.shtml 

For more information and the latest updates on Genuity'" Roundup 

Ready" alfalfa, go to http://www.roundupreadyalfalfa.com 

To meet sales reporting requirements, the seed supplier is required to identify and list all Genuity'M Roundup Ready® alfalfa 

field locations. Therefore, all farmers MUST PROVIDE their seed supplier with the GPS coordinates of all their Genuity'M 

Roundup Ready® alfalfa fields. 

MONSANTO 
WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow all pesticide label requirements and the guidelines below 

to minimize the risk of developing glyphosate-resistant weed 

populations in a GenuityT~ Roundup Ready:;' alfalfa system: 

• Scout fields before and after each herbicide application. 

• Use the right herbicide product at the right rate and at 

the right time. 

WEED CDNTROL RECDMMENDATIONS 

In established stands, to preserve the quality potential of forage 

and hay, applications should be made after weeds have emerged 

PROGRAM 

Eslablished Siands 

Weeds Conlrolled 

Maximum Use Rales 

INSTRUCTIONS AND USE RATES' 

After the first harvest of a newly established stand, up 

to 44 oz/A of Roundup WeatherMAX®** herbicide 

per cutting may be applied up to 5 days before each 

subsequent cutting. The combined total per year for 

aU in-crop applications in established stands must not 

exceed 132 oz/A (4.1 qt/A) of Roundup WeatherMAX. 

For specific application rates and instructions for 

control of various annual and perennial weeds, refer to 

Ihe Roundup WealherMAX" herbicide label booklet. 

Some weeds with multiple germination times or 

suppressed (stunted) weeds may require a second 

application of Roundup WeatherMAX** herbicide for 

complete control. For some perennial weeds, repeated 

applications may be required to eliminate crop 

competition throughout the growing season. 

In-Crop: 

• 44 oz/A per single application. 

• Established Stand Tolal: 44 oz/A per cutting 

up to 5 days before harvest 

*Follow all pestlcide label requirements. 

RDundup Ready 

• To control flushes of weeds in established alfalfa, make 

applications of Roundup WeatherMAX'!J or Roundup 

PowerMAXZ, herbicide at 22 to 44 az/A before weeds 

exceed 6" in height. up to 5 days before cutting. 

• Use other approved herbicide products tank-mixed or in 

sequence with Roundup agricultural herbicide if appropriate 

for the weed spectrum present as part of a Genuity'" 

Roundup Ready~ alfalfa weed control program. 

• Report repeated non·performance to Monsanto or your 

local retailer. 

but before alfalfa re·growth interferes with application 

spray coverage of the target weeds. 

ADDITIONAL INFORMATION 

Applications between cuttings may be applied as a single application or 

in multiple applications (e.g. 2 applications of 22 oz/A). 

Sequential applications should be at least 7 days apart. 

In addition to those weeds listed in the Roundup WeatherMAX* label booklets, 

this product will suppress or control the parasitic weed, dodder (Cuscuta spp.) 

in Genuity'" Roundup Ready® alfalfa. Repeat applications may be necessary for 

complete control. 

For tough·to·control weeds or weeds not controlled by Roundup® agricultural 

herbicides use labeled rates of other approved herbicides, alone or in 

tank-mixtures, with Roundup agricultural herbicides. 

Tolal Per Year: 

The combined total per year for all in-crop applications in established stands 

must not exceed 132 oz/A (4.1 qt/A) 01 Roundup WealherMAX . 

"If using another Roundup agricultural herbicide, you must refer to the label booklet or separately published Genuity~ Roundup Ready~ alfalfa supplemental label 

for that brand to determine appropriate use rates. If usIng Roundup PowerMAX, appllcallon rates are the same as for Roundup WeatherMAX. 

2010 TECHNOLOGY USE GUIDE 
Roundup R~ady 

N Genuity'M Roundup Ready" spring canola hybrids contain 

in-plant tolerance to Roundup agricultural herbicides, 

enabling farmers to apply Round up0 agricultural herbicides 

over the top of GenuityTM Roundup Ready6 spring canola 

anytime from emergence through the 6-leaf stage of development. 

The introduction of the Roundup Ready'" trait into leading spring 

canola hybrids and varieties gives farmers the opportunity for 

unsurpassed weed control, proven crop safety and maximum 

profit potential. With Genuitv''' Roundup Ready® spring canola, 

farmers have the weed management tool necessary to improve 

spring canola profitability, while providing a viable rotational crop 

to help break pest and disease cycles in cereal-growing areas. 

WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow all pesticide label requirements and the guidelines below 

to minimize the risk of developing glyphosate-resistant weed 

populations in a Genuity'" Roundup Ready!> spring canola system: 

WEED CONTROL RECOMMENDATIONS (SPRING-SEEDED) 

PROGRAM 

Two·Pass ProgramFor Annual and 

Perennial Weed 

Control 

Single AppllcationFor Annual Weed 

Control 

Maximum Use 

Rate For Roundup 

WeatherMAX 

INSTRUCTIONS AND USE RATES' 

For broad'spectrum control of annual and perennial 

weeds, use an initial application 0111 oz/A of Roundup 

WeatherMAX", in 5 to 10 gallA water volume. 

No surfactant is required. 

Make a second application of 11 oz/A of Roundup 

WeatherMAX" no less than 10 days after initial 

application up to the 6-leaf stage (prebolting). 

Do not exceed 11 oz/A per application. 

For broad-spectrum control of annual and 

easy-to-control perennial weeds, make a single 

application of 16 oz/A of Roundup WeatherMAX." 

Two over-the-top applications: Do not exceed 

11 oz/A per application. 

Single over-the-top applications: Do not exceed 16 

oz/A_ No additional application can be made. 

"Follow all pesticide label requirements. 

• Scout fields before and after each burndown and in-crop 

application. 

• Start clean with a burndown herbicide or tillage. 

• In-crop, apply Roundup WeatherMAXn herbicide before 

weeds exceed 3" in height. 

• A sequential application of Roundup weatherMAX herbicide 

may be needed. 

• Clean equipment before moving from field to field to minimize 

the spread of weed seed. 

• Report repeated non-performance to Monsanto or your local 

retailer. 

ADDITIONAL INFORMATION 

Spray when canola is at the 0- to 6-leaf stage of growth. To maximize yield 

potential, spray Genuity' Roundup Ready· spring canola at the 1- to 3-leaf 

stage to eliminate competing weeds. Short-term yellowing may occur with 

later applications, with little eliee! on crop growth, maturity, or yield. 

Wait a minimum of 10 days between applications. Two applications 

of Roundup WeatherMAX will: 

• Control late flushes of annual weeds such as foxtail, pigweed, 

and wild mustard. 

• Provide season-long suppression of Canada thistle, quackgrass, and 

perennial sow thistle. 

• Provide better yields by eliminating competition from both annuals 

and hard-la-control perennials. 

For best results, spray Genuity' Roundup Ready® spring canola at the 2- to 

3-leaf stage_ Can be applied up to 6-leaf stage; yellowing may occur 

with later application with little effee! on crop growth, maturity, or yield, 

No additional over-the-top applications can be made, 

··If using another Roundup agricultural herbicide. you must refer to the label booklet or separately published Genuity'" Roundup Ready'" canola supplemental label for that brand to determine 

appropriate use rales. If using Roundup PowerMAX. applicat"lon rates are the same as for Roundup WeatherMAX. 

MONSANTO 
, GenuityTM Roundup Ready® winter canola varieties have 

been developed for seeding in the fall and harvesting the 

following spring/summer. 

Roundup Ready 

Genuity'" Roundup Readyfl winter canola varieties contain in-plant 

tolerance to Roundupnagricultural herbicides, enabling farmers 

to apply Roundup agricultural herbicides over the top of Genulty-" 

Roundup ReadyB winter canola from crop emergence to the 

pre-bolting stage. The introduction of the Roundup Ready trait 

into winter canola varieties gives farmers the opportunity of 

unsurpassed weed control, crop safety and maximum yield 

potentia!. Genuity'" Roundup Ready'!! winter canola offers farmers 

an important option as a rotational crop in traditional monoculture 

winter wheat production areas. Introducing crap rotation is an 

important factor in reducing pest cycles, including weed and 

disease problems. 

WEED RESISTANCE MANAGEMENT GUIDELINES 

Follow the same guidelines as stated for spring canola. 

WEED CONTROL RECOMMENDATIONS (WINTER-SEEDED) 

PROGRAM INSTRUCTIONS AND.USE RATES· 

Sequential Applications The two-pass program gives the greatest flexibility in 

controlling late emerging weeds. For broad'spectrum weed 

control, apply 11 to 22 oz/A of Roundup WeatherMAX" 

herbicide to 2-leaf or larger Genuity" Roundup Ready']) winter 

canola in the fall. Use 5 to 10 galionslA water volume, Do not 

add surfactants. 

Single Application 

Maximum Use Rate for 

Roundup Weather MAX 

Apply a second application of Roundup WeatherMAX** at 11 to 

22 oz/A at a minimum interval of 60 days after the first 

application and before bolting in the spring. 

Do not exceed 22 oz/A per application. 

For broad-spectrum control of annual and easy-to-control 

perennial weeds, make a single application of 16 to 22 oz/A 

of Roundup WeatherMAX", preferably in the fall. 

----------------------

Any single over-the-top application of Roundup 

WeatherMAX" should not exceed 22 oz/A_ No more than 

two over-thE-top applications may be made from crop 

emergence to canopy closure prior to bolting in the spring. 

ADDITIONAL INFORMATION 

Spray when Genuity' Roundup Ready· winter canola is at the 2-3 

leaf stage of growth, Early applications can eliminate competing 

weeds and improve yield potential. 

Two applicalions of Roundup WeatherMAX will provide control of 

early emerging annual weeds and winter emerging weeds such as 

downy brome, cheat and joinled goalgrass. 

For besl results, spray Genuitv' Roundup Ready· winter canola 

allhe 2-3 leaf stage and when weeds are small and actively 

growing_ Applicalions must be made prior to bolting_ Use the 

higher rale in the range when weed densities are high, when 

weeds have over wintered or when weeds become large and 

well established_ --_._---------------------------

Applications of grealer Ihan 16 fluid ounceslA prior 10 Ihe 6-leaf 

stage may resull in temporary yellowing andlor growth reduclion, 

-----------------

"Follow all pesticide label requirements. 

ulf using another Roundup brand herbicide, you must refer \0 the label booktet or Genuity'" Roundup Ready" winter canola supptemental label for that brand to determine 

appropriate use rates. If using Roundup PowerMAX. application rates are the same as for Roundup WeatherMAX. 

GRAZING 

It is recommended that Genuity'~ Roundup Ready!') winter canola 

not be grazed. While Genuity'" Roundup ReadyGl winter canola 

may provide farmers additional opportunity as a forage for 

grazing livestock, at the present time insufficient information 

exists to allow safe and proper grazing recommendations. 

Preliminary data suggest that excessive grazing can significantly 

reduce yield, and that careful nitrate management is critical 

in managing Genuity'" Roundup ReadylP winter canola as a forage 

to limit the risk of livestock nitrate poisoning. State universities 

are assessing the potential and the instructions for grazing 

Genuity'" Roundup Ready"" winter canola and they will provide 

grazing management guidelines when their research is completed. 

2010 TECHNOLOGY USE GUIDE I' 
Genuity'" Roundup Ready® sugarbeet varieties have 

Roundup Ready 

in-plant tolerance to Roundup" agricultural herbicides, 

enabling farmers to apply labeled Roundup agricultural 

herbicides from planting through 30 days prior to 

harvest for unsurpassed weed 

preservation of yield potential. 

MANAGEMENT PRACTICES 

Sugar beets are extremely sensitive to weed competition for light. 

nutrients and soil moisture. Research on sugarbeet weed control 

suggests that sugarbeets need to be kept weed-free for the first 

eight weeks of growth to protect yield potential. Therefore, 

weeds must be controlled when they are small and before they 

compete with Genuity"'Roundup Ready® sugar beets (exceed crop 

height), that is from less than 2" up to 411 in height, to preserve 

sugarbeet yield potential. More than one in-crop herbicide 

application will be required to control weed infestations to 

protect yield potential as Roundup agricultural herbicides have 

no soil residual activity. Bolting sugarbeets must be rogued 

or topped in Genuity'M Roundup Ready® sugarbeet fields. 

Genuity"" Roundup Ready® sugarbeet varieties have excellent 

tolerance to over-the-top applications of labeled Roundup 

agricultural herbicides. A postemergence weed control program 

using Roundup WeatherMAX,]l or Roundup PowerMAX'.ID will 

provide excellent weed control in most situations. A residual 

herbicide labeled for use in sugarbeets may also be applied 

preemergence, preplant or postemergence in Genuity"" Roundup 

Ready® sugarbeets. Contact a Monsanto Representative, local 

crop advisor or extension specialist to determine the best option 

for your situation. 

WEED RESISTANCE MANAGEMENT FOR GENUITY'" 

ROUNDUP READY® SUGARBEETS 

Follow all pesticide label requirements and the guidelines below 

to minimize the risk of developing glyphosate-resistant weed 

populations in a Genuity'" Roundup Ready® sugarbeet system: 

• Start clean with tillage and follow-up with a burndown 

herbicide, such as Roundup WeatherMAX, if needed 

prior to planting. 

• Early-season weed control is critical to protect sugarbeet 

yield potential. Apply the first In-crop application of Roundup 

WeatherMAX at a minimum of 22 ozlA while weeds are less 

than 21t in height. 

III MONSANTO 

control, excellent crop safety and 

• Follow with additional postemergence in-crop application of 

Roundup WeatherMAX at a minimum of 22 oz/A for additional 

weed flushes before weeds exceed 4" in height. 

• Add spray grade ammonium sulfate at a rate of 17 Ibs/100 gallons 

of spray solution with Roundup'!> agricultural herbicides to 

maximize product performance. 

• Use mechanical weed control/cultivation andlor residual 

herbicides where appropriate in your Genuity'" Roundup Ready® 

sugarbeets. 

• Use additional herbicide modes of action/residual herbicides 

and/or mechanical weed control In other Roundup Ready crops you 

rotate with Genuity'· Roundup Ready'!) sugarbeets. 

• Report repeated non-performance of Roundup agricultural 

herbicides to Monsanto or your local retailer. 

AGRONOMIC PRINCIPLES IN SUGARBEETS 

Sugarbeets are very sensitive to early-season weed competition. 

It is important to select the appropriate herbicide product, 

application rate and timing to minimize weed competition to 

protect yields. The Genuity'· Roundup Ready® sugarbeet system 

provides a mechanism to control weeds at planting and once 

Genuity·· Roundup Ready® sugarbeets emerge. Failure to control 

weeds with the right rate, at the right time and with the right 

product, can lead to increased weed competition, weed escapes 

and the potential for decreased yields. Tank-mixtures of Roundup 

agricultural herbicides with fungicides, insecticides, micronutrients or foliar fertilizers are not recommended as they may result 

in crop injury and reduced pest control or antagonism. 

PLANTING REQUIREMENTS 

Genuity'· Roundup Ready® sugarbeets are not permitted to be 

planted in any wildlife reed plots, 

STEWARDSHIP 

All Genuity'M Roundup Ready® sugarbeet farmers shall sign the 

Monsanto Technology/Stewardship Agreement (MTSA) limiteduse license application which provides the terms and conditions 

for the authorized use of the product. The MTSA must be signed 

and approved prior to purchase or use of seed. 
WEED CONTROL RECOMMENDATIONS 

PROGRAM 

Preplant Burndown 

Over-The-Top 

Applications up to 

eight-leaf Genuity" 

Roundup Ready· 

Sugarbeets 

Over-The-Top 

Applications to 

greater than 

eight-leaf Genuity' 

Roundup Ready· 

Sugarbeets 

Maximum 

Use Rates 

INSTRUCTIONS AND USE RATES' 

After preplant tillage or bedding operations have been completed, a 

preplant burndown application of Roundup WealherMAX®** at 22 to 

44 az/A may be applied to control weeds that have germinated after 

tillage and prior to planting. 

See the label for appropriate rates by weed species and weed size. 

Up to two applications of Roundup agricultural herbicides may be made 

prior to the S-Ieaf stage of Genuity'" Roundup Ready® sugarbeets. 

The first application of 22 to 32 az/A of Roundup WealherMAX** 

should be made when weeds are less than 211 in height to protect 

yield potential. 

Make an additional application of 22 to 32 oz/A of Roundup WeatherMAX 

before weeds exceed 411 in height. 

Maximum in-crop Roundup WeatherMAX prior to a-leaf stage must not 

exceed 56 oz/A. 

Up to two additional applications of 22 oz/A of Roundup 

WeatherMAX can be made after the eight-leaf stage up to 

30 days prior to harvest. 

Maximum in-crop Roundup WeatherMAX from a-leaf stage up 

until 30 days prior to harvest must not exceed 44 adA. 

In-Crop: 

" Two applications of Roundup WeatherMAX prior to the a-leaf stage 

of Genuity" Roundup Ready® sugarbeets 

- 32 oz/A per single application up to the a-leaf stage. 

- Combined maximum of 56 oz/A in-crop prior to the a-leaf stage 

" Two applications of Roundup WeatherMAX after the a-leaf stage 

up to 30 days prior to harvest 

- 22 oz/A per single application after the a-leaf stage. 

- Combined maximum of 44 az/A in-crop after the a-leaf stage 

until 30 days prior to harvest 

"Follow all pesticide label requirements. 

ADDITIONAL INFORMATION 

Always utilize tillage to start with a weed-free field. 

Sugarbeets are sensitive to weed competition and can 

lose yield rapidly if weeds are not controlled early. More than one 

in-crop Roundup WeatherMAX application will be required to 

control weed infestations to protect yield potential as Roundup 

agricultural herbicides have no soil residual activity. 

Add ammonium sulfate at a rate of 171bs/lOO gallons of spray 

solution with Roundup agricultural herbicides to maximize 

product performance. Tank-mixtures of Roundup agricultural 

herbicides with fungicides, insecticides, micronutrients or foliar 

fertilizers are not recommended. 

Sequential applications should be at least 10 days apart 

Add ammonium sulfate at a rate of 171bs/100 gallons 

of spray solution with Roundup agricultural herbicides to 

maximize product performance. Tank-mixtures of Roundup 

agricultural herbicides with fungicides, insecticides, 

micronutrients or foliar fertilizers are not recommended. 

Sequential applications should be at least 

10 days apart. 

Total Per Year: 

The combined total per year for all Roundup WeatherMAX 

applications including pre-plant must not exceed 5.3 qt/A. 

Total in-crop application must not exceed 3 qUA. 

Add ammonium sulfate at a rate of 171bs/iOO gallons of spray 

solution with Roundup agricultural herbicides to maximize 

product performance. Tank-mixtures of Roundup agricultural 

herbicides with fungicides, insecticides, micronutrients or foliar 

fertilizers are not recommended. 

**If using another Roundup agricultural herbicide, you must refer to the labe! booklet or separately published Genuity~ Roundup Ready~ 5ugarbeets supplemental label for 

that brand to determine appropriate use rates. If using Roundup PowerMAX, application rates are Ihe same as for Roundup WealherMAX. 

2010 TECHNOLOGY USE GUIDE 
This guide was printed using Utopia II XG Cover " Saves the equivalent of 585 mature trees 

Reduces solid waste by 35,308 pounds 

Reduces waste water by 213,390 gallons 

and Text which contains 30% post·consumer waste. 

Savings derived from using 30% post-consumer 

fiber in lieu of 100% virgin fibers: Reduces greenhouse gas emissions by 199,989.75 pounds 

Before opening a bag of seed, be sure to read, understand and accept the 

stewardship requirements, Including applicable refuge requirements for 

Insect resistance management, for the biotechnology tralts expressed in 

the seed as set forth In the Monsanto Technology Agreement that you sign. 

By opening and using a bag of seed, you are reaffirming your obligation to 

Plut16,lWQu, hrurrfll, rHbJ/ffl' comply with the most recent stewardship requirements. 

LIBERTY 

LlNK"1!7 

.................................. 

Roundup Ready" Alfalfa seed Is currently not for sale or dlstrlbutron. The movement and use of Roundup Ready" Alfa[fa forage [s subject to a USDA admlnlstrOltive Order available at 

http://www.aph[s.usda.govJbrsJpdIJRRA_AB_flnal.pdf. 

ThIs stewardship statement applies to all products listed herein except Genulty"" VT Double PROTM, GenultyTM VT TrIple PRO'" and Genulty"" SmartStax,.... See restrIctions related 

to Genulty"" Double PROTM, Genulty'" VT Triple PRO'" and Genulty'" SmartStax'" below: 

Monsanto Company is a m~mber of Exc~lIence Through Stewardship" lETS). Monsanto products are commercialized in accordance with ETS Product Launch Stewardship Guidance. 

and In compliance with Monsanto's Policy for Commercialization of Blotechnology'Derlved Plant Products in Commodity Crops. This product has been approved for Import Into key e~port 

markets with functioning regulatory systems. Any crop or material produced from this product can only be exported to, or used, processed or sold in countries where all necessary regulatory 

approvals have been granled.1I is a violalfon of national and internallonallaw to move material containing biotech traits across boundaries into nations where Import Is not permitted. 

Growers should talk to theIr grain handler or product purchaser to confirm theIr buying posilfon for this product. Excellence Through Stewardship~ is a registered trademark of Biotechnology 

Industry Organization. 

IMPORTANT: Grain Marketing and Seed Availability: Genulty"" VT Double PRO'" has received the necessary approvals in the United States, however, as of October 22, 2009, approvals 

have not been received in certain major corn export markets. Genulty~ VT Double PRO'" will not be launched and seed will not be available until afler import approvals are received In 

appropriate major corn e~port markets. B.t. products, including Genuity~ VT Double PRO'u may not yet be registered in all states. Check with your Monsanlo representative for the 

registration slatus in your state. 

IMPORT ANT: Grain Marketing and Se~d Availability: Genulty'" VT Triple PRO"" has received the necessary approvals In the United Stales however, as of October 22, 2009, approval has 

not been received in all major corn export markets. Monsanto anticipates that all such approvals will be in place for the 2010 growing season. If all approvals are not in place, Genulty'U VT 

Triple PRO'" seed will only be avallable as part of a commercial demonstration program that Includes grain markeling stewardship requirements. It is a violation 01 national and international 

law to move material containing biolech traits across boundaries into nations where import is not permitted. Consult with your seed representative for current regulatory and stewardship 

information status. 

IMPORT ANT: GraIn Marketrng and Seed AvaUabillty: Genulty'" SmartStax'" has received the necessary approvals in the United States, however, as of October 22, 2009, approvals have 

not been received in certain major corn export markets. Genulty'" Smartstax'" wlll not be launched and seed wilt not be available until after Import approvals are rece!ved in appropriate 

major corn export markets. B.t. products, includIng Genulty"" SmartStax'" may not yet be registered in all states, Check with your Monsanto representative for the registration slatus 

In your state. 

Cottonse~d contaIning Monsanto traits may not be export~d for th~ purpose of planting without a license from Monsanto. 

Indlvldua[ results may vary, and performance may vary from location to location and from year to year. This result may not be an indicator of results you may obtain as local growing, soil 

and weather condilions may vary. Growers should evaluate data from multiple locations and years whenever possible. 

Growers may utilize the natural refuge optron for varieties containing the Boligard II'" trait In the following states: AL. AR, FL, GA, KS, KY, LA, MD, MS, MO, NC, OK, SC, TN, VA, and 

most of Texas (excluding Ihe Texas counties of Brewster, Crane, Crockell, Culberson, EI Paso, Hudspeth, Jeff Davis, Loving, Pecos, Presidio, Reeves, Terrell. Val Verde, Ward and Winkler). 

The natural refuge option does not apply to Bollgard II callan grown In areas where pink bollworm is a pest, including CA. AZ, NM, and the above listed Texas counUes. It also remains the case 

Ihat BoUgard~ and Boligard II cotlon cannot be planled south of HIghway 60 in Florida, and that Boligard cotlon cannol be planted in certain other counties in the Texas panhandle. Refer to the 

Technology Use Guide and IRM/Grower Guide for additional information regarding Bongard II, Bollgard, natural refuge and EPA'mandated geographical restricHons on the planting of B.t. colton. 

ALWAYS READ AND FOLLOW PESTiCIDE LABEL DIRECTIONS. Roundup Ready'" crops contain genes thai confer tolerance to glyphosale, the acl!ve ingredient in Roundup" brand 

agricultural herbicides. Roundup? brand agricultural herbicides will kill crops that are not tolerant to glyphosate. Degree~ and Harness~ are 1'101 registered in all slates. Degree" and Harness'" 

may be subject to use restrictions in some states. Bullet\ Degree Xlra', Harness", INTRRO~, Larlat~, and Micro-Tech -. are reslricled use pesticides and are not registered in all states. The 

distribution, sale, or use of an unregistered pesticide is a violation of federal and/or state law and is strictly prohiblled, Check with your local Monsanlo dealer or representative for the product 

regIstration status In your Slate. 

Tank mIxtures: The applicable labeling lor each product must be in the possession of the user at the lime of application. Follow applicable use instructions, IncludIng application rates, 

precaullons and restrictions of each product used in the tank mixture, Monsanto has not tested all tank mix product formulations for compatibility or performance other than specifically 

listed by brand name. Always predetermine the compatibility of tank mIxtures by mixing small proportional quantities in advance. 

Boligard", Boligard II", Bullet" Degree~, Degree Xtra", Genuity~, Genuity and Design~, Genuity Icons, Harness~.INTRRO~, Laria!~, Micro'Tech~, Respect the Refuge and Cotton De5Ign~, 

Roundup~, Roundup PowerMAX~, Roundup Ready", Roundup Ready 2 Technology and Design~, Roundup Ready 2 Yieid~, Roundup Ready RATE~. Roundup WeatherMAX~, Roundup 

WeatherMAX and Design', SmartStax", SmartSlax and Design~, Slart Clean, Stay Clean."', Transorb and Design~, Vistlve"', Vistive and Design", VT Double PRO~. VT Triple PRO~, YieldGard~, 

YieldGard Corn Borer and Design", YieldGard Plus and Design", YieldGard Rootworm and Design~. YieldGard VP', YieldGard VT and Design", YleldGard VT Rootworm/RR2", YieldGard VT 

Triple", and Monsanto and Vine Design~ are trademarks of Monsanto Technology LLC.lgnite~ and UbertyUnkY and the Water Droplet Design" are registered trademarks of Bayer. Herculex 

Is a trademark of Dow AgroSciences LLC. Select Ma~'~ and Valor" are registered trademarks of Valent U.S.A. Corporation. Respecl the Refuge'" and Respect the Refuge and Corn Design" 

are registered trademarks of National Corn Growers Association. All other trademarks are the property of theIr respective owners. ©2009 Monsanto Company. {19282Apgd]SA-9Y-09-3B81