USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

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Petition for Determination of Nonregulated Status for Herbicide Tolerant DAS - 8191 Ø - 7 Cotton OECD Unique Identifier: DAS - 8191Ø
- 7 The undersigned submits this petition under 7 CFR 340.6 to request that the Administrator, Animal and Plant Health Inspection Service, make a determination that the article should not be regulated under 7 CFR 340 Submitting Compan y : Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, In 46268 Submitted by:
Gary Rudgers , Ph.D. U . S . Regulatory Manager Regulatory Sciences & Government Affairs Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268 Telephone: (317) 337 - 3 581 FAX: (317) 337 - 4649 gwrudgers @dow.com September 1 7 , 201 3 Revised November 2 5 , 2013USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Release of Information Dow AgroSciences LLC (DAS) is submitting the information in this petition for deregulation to USDA - APHIS as part of the regulatory process. By submitting this information, DAS does not authorize its release to any third party . If USDA receives a Freedom of Information Act request pursuant to 5 U.S.C., § 552 and 7 CFR Part 1 regarding this information, DAS expects that USDA will provide DAS with a copy of the material proposed to be released and the opportunity to object to the release of any information bas ed on appropriate legal grounds ( e.g. , responsiveness, confidentiality, and/or competitive concerns). DAS understands that a copy of this information may be made available to the public in a reading room and upon individual request as part of a public comm ent period. Except in accordance with the foregoing, DAS does not authorize the release, publication or other distribution of this information (including website posting) without prior notice and consent from DAS.

© 201 3 Dow AgroSciences LLC. All Rights R eserved. This document is property of Dow AgroSciences LLC and is for use by the regulatory authority to which it has been submitted, and only in support of actions requested by Dow AgroSciences . All data and information herein must not be used, reproduced or disclosed to third parties for any other purpose without the written consent of Dow AgroSciences.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Certification The undersigned certifies that, to the best knowledge and belief of the undersigned, this petition includes all information and views on which to base a determination and that it includes all relevant data and information known to the petitioner , unfavorable as well as favorable, associated with DAS - 8191Ø
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Gary Rudgers , Ph.D. U . S . Regulatory Manager Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, Indiana 46268 Telephone: (317) 337 - 3581 Fax: (317) 337 - 4649 gwrudgers @dow.comUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Summary Dow AgroSciences LLC (herein referred to as “DAS”) is submitting a Petition for Determination of Nonregulated Status for DAS - 8191Ø
- 7 cotton . DAS requests from USDA Animal and Plant Health Inspection Service (APHIS) that cotton transformation event DAS 8191Ø
- 7 and any cotton lines derived from crosses between DAS - 8191Ø
- 7 cotton and conventional cotton or biotechnology - derived cotton granted n onregulated status by APHIS , no longer be considered regulated articles under 7 CFR Part 340. DAS has developed transgenic cotton plants containing aad - 12 and pat , which confer toleran ce to the herbicides 2,4 - dichlorophenoxyacetic acid (2,4 - D ) and glufosinate . DAS 8191Ø
- 7 cotton will provide growers with greater flexibility in selection of herbicides for the improved control of economically important weeds; allow an increased application window for effective weed control; and provide an effective weed resistance management solution to the growing incidence of glyphosate resistant weeds. DAS - 8191Ø
- 7 cotton plants have been genetically modified to express aryloxyalkanoate dioxygenase - 12 (AAD - 12) . AAD - 12 is an enzyme with an alpha ketoglutarate - dependent dioxygenase activity which results in metabolic inactivation of the herbicides o f the aryloxyalkanoate family. The aad - 12 gene, which expresses the AAD - 12 protein, was derived from Delftia acidovorans, a gram - negative soil bacterium . In addition to AAD - 12, DAS - 8191Ø
- 7 cotton plants have b een genetically modified to express the phosphinothricin ace tyltransferase (PAT) protein . The PAT enzyme acetylates the primary amino group of the herbicide phosphino thricin , rendering the herbicide inactive. The pat gene expressing the PAT protein was der ived from Streptomyces viridochromogenes and provides tolerance to the herbicide glufosinate in DAS - 8191Ø
- 7 cotton plants. The pat gene has been extensively reviewed by regulatory authorities in over eleven countries and has a long history of safe use, being used in over eight crop species representing over twenty two biotechnology plant events. The aad - 12 and pat expression cassettes in troduced into DAS - 8191Ø
- 7 cotton are the same as those intr oduced into DAS - 68416 - 4 soybean, currently under review by USDA - APHIS (USDA petition number 09 - 349 - 01p) . In addition, the aad - 12 and pat expression cassettes are the same as those introduced into D AS - 444Ø6
- 6 soybean , also currently under USDA APHIS review (USDA petition number 11 - 234 - 01p) . Plant Pest Assessment of DAS - 8191Ø - 7 C otton Data and information presented in this petition to USDA - APHIS confirm the la ck of p lant pest p otential of DAS - 8191Ø
- 7 cotton compared to non - transgen ic cotton. The data demonstrate that DAS - 8191Ø
- 7 cotton is agronomically, phenotypically, and compositionally comparable to non - transgenic cotton, with the exception of the presence of the aad - 12 and pat genes. DAS - 8191Ø
- 7 cotton is unlikely to pose an increased plant pest risk, weediness potential or an adverse environmental impact compared to non - transgenic cotton . These conclusions are based on the outcome of extensive data and evaluation including :USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC  Cotton is a familiar crop that does not possess any of the attributes commonly associated with weeds and has a long history of safe use.  D etailed molecular characterization of the inserted DNA demonstrated a single, intact copy of the T - DNA insert within the cotton genome .  D etailed biochemical characterization of the expressed AAD - 12 and PAT proteins confirmed they are unlikely to be allergens or toxins . In addition, PAT has been commercially available in crops including cotton, corn, rice, canola, soybean and several other c rops previously reviewed by USDA.  C ompositional assessment of cottonseed confirmed the DAS - 8191 Ø
- 7 cotton is compositionally equivalent to non - transgenic cotton.  P henotypic, agronomic and ecological characterization assessments of DAS - 8191Ø
- 7 cotton demonstrated no increased plant pest or weediness potential compared to non transgenic cotton.  A ssessment on the potential impact on non - target and endangered species indicated that DAS - 8191Ø
- 7 cotton is unlikely to have adverse eff ects on these organisms compared to non - transgenic cotton.  Current agronomic management practices for cotton conclude that DAS - 8191Ø
- 7 cotton is not likely to impact cotton agronomic practices or l and use, with the exception of 2,4 - D application on DAS - 81 91Ø
- 7 cotton varieties . Cotton is a Familiar Crop U.S. cotton is grown across 17 states in the southern region of the country. Cotton is the world’s most widely grown fiber crop, accounting for over 35% of the total world fiber use . The United States is t he top exporter of raw cotton, and third in world production behind China and Ind ia. In 2012, 9 .4 million acres of cotton were harvested in the US ; with production value estimated at just under $ 6 billion . Cotton is a slow - growing plant that competes poorly with weeds . The commercial cotton species grown in the U.S. do not exhibit weedy characteristics, do not outcross to weedy relatives and are not invasive . Cotton is not listed as a weed and is not listed on the list of noxious weeds by USDA (7 CFR P art 360) . Volunteers that may appear in subsequent rotational crops are easily controlled through traditional tillage practices or the use of appropriate herbicides. Although feral populations of cultivated variants of cotton exist in the U.S., these popu lations do not occur in cotton growing areas. In addition, DAS - 8191Ø
- 7 cotton would not be expected to confer a selective advantage or result in a plant pest or weediness potential if crossing with feral populations were to occur . Such unlikely outcomes co uld be controlled by current agronomic practices.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Molecular Characterization of DAS - 8191Ø - 7 C otton The aad - 12 and pat genes were introduced into DAS - 8191Ø
- 7 cotton using Agrobacterium mediated transformation. Molecular characterization by Southern blot analyses of DAS 8191Ø
- 7 cotton confirmed that a single, intact DNA insert containing the aad - 12 and pat gene expression cassettes was stably integrated into the cotton genome. Southern bl ot analyses also confirmed the absence of the plasmid backbone DNA in DAS - 8191Ø
- 7 cotton . The integrity of the inserted DNA was demonstrated in five different breeding generations. Data from segregating generations confirmed the predicted Mende lian inheritance pattern. These data confirmed the stability of DAS - 8191Ø
- 7 cotton during traditional breeding procedures. Biochemical Characterization of DAS - 8191Ø - 7 C otton Microbial - derived AAD - 12 and PAT have been extensively assessed to establish the safety of the protein. DAS - 8191Ø
- 7 cotton - derived AAD - 12 and PAT proteins were determined to be biochemically equivalent to the corresponding protein s from microbial expression host organism s . A step - wise, weight - of - evidence approach was used to assess th e potential for toxic or allergenic ef

fects from the AAD - 12 and PAT protein s . Bioinformatic analyses revealed no meaningful homologies with known or putative allergens or toxins for t he AAD 12 or PAT amino acid sequence s . Both proteins hydrolyze d rapidly i n simulated gastric fluid . There was no evidence of acute toxicity in mice at a dose of 2000 mg/kg b ody weight of AAD - 12 protein and 5000 mg/kg body weight of PAT protein . AAD - 12 and PAT expression levels in DAS - 8191Ø
- 7 cotton w ere measured using a protein specific enzyme - linked immunosorb ent assay (ELISA). Protein expression wa s analyzed in multiple tissues collected throughout the growing season from DAS - 8191Ø
- 7 cotton plants both non - sprayed and sprayed with 2,4 - D plus g lufosinate . Glycosylation analysis revealed no detectable covalently linked carbohydrates in either AAD - 12 or PAT protein s expressed in DAS - 8191Ø
- 7 cotton plants. T he low level expression of the se protein s presents a low exposure risk to humans and animals, and the results of the overall safety assessment of AAD - 12 and PAT indicate that DAS - 8191Ø
- 7 cotton is unlikely to cause allergenic or toxic effects in humans or animals. Composition al Assessment of DAS - 8191Ø - 7 C otton A composition al assessment was conducted in which levels of key nutrients and anti nutrients of DAS - 8191Ø
- 7 cottonseed were compared with the appropriate non - transgenic near isogenic control and non - transgenic reference line s . Samples were analyzed for proximates, fiber, minerals, amino acids, fatty acids, vitamins, and anti - nutrients. Fifty - nine cotton analytes were assayed and the analyses conclude that DAS - 8191Ø
- 7 cotton is compositionally equival ent to non - transgenic cotto n . Phenotypic, A gronomic and E cological C haracterization of DAS - 8191Ø - 7 C otton Evaluations of nine ph e notypic, agronomic and ecological characteristics (early population, seedling vigor, flower initiation, nodes above white flower , plant height, percent o pen bolls, lint yield, disease incidence and insect damage) were conducted to investigate the equivalency of DAS - 8191Ø
- 7 ( non - sprayed and sprayed with 2,4 - D plus glufosinate) cotton to non - transgenic cotton . Phenotypic, agronomic and ecological analysis of DAS - 8191Ø
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Dow AgroSciences LLC cotton revealed no statistically significant differences between non - sprayed DAS - 8191Ø
- 7 cotton and the isoline (control) . It was also determined that the phenotypic, agronomic and ecological characteristics of DAS - 8191Ø
- 7 cotton sprayed with 2,4 - D plus glufosinate are equivalent to non - sprayed DAS - 8191Ø
- 7 cotton. In addition, germination and dormancy studies conducted under warm and cool conditions did not differ significantly from the non transgenic cotton, near isogenic comparator. The dat a support the conclusion that DAS - 8191Ø
- 7 cotton is substantially equivalent to non transgenic cotton with the exception of the introduced and expression of aad - 12 and pat genes and therefore no more likely to pose a plant pest risk or have a significant environmental impact compared to non - transgenic cotton. Assessment on the P otential I mpact on N on - T arget and E ndangered S pecies A review of potential environmental impacts indicates that DAS - 8191Ø
- 7 cotton is unlikely to have adverse effects o n non - target organisms including threatened or endangered species under normal agricultural practices. This conclusion is based on several lines of evidence .  T he aad - 12 gene and expressed protein are present in nature in the soil bacterium Delftia acidovo rans . The pat gene and the expressed protein are present in other crops grown in the United States with no effects on non - target organisms or endangered species .  AAD - 12 and PAT are not potential food allergens or toxins .  DAS - 8191Ø
- 7 cotton has been shown to be substantially equivalent to non - transgenic cotton based on the compositional analysis of cottonseed.  O bservations made during field testing of DAS - 8191Ø
- 7 cotton revealed no effects on invertebrate populations .  A gron omic characteristics were found to be equivalent to non - transgenic cotton. Impact on Current A gronomic M anagement P ractices Because DAS - 8191Ø
- 7 cotton is agronomically and compositionally s imilar to conventional cotton, no significant impact is expected on current crop production practices, non - target or endangered species, crop rotation, volunteer management, or commodity food and feed cotton products . The availability of DAS - 8191Ø
- 7 cotton is expected to have a beneficial impact on weed control practic es by providing growers with an advanced tool to address their weed control needs. The availability of DAS - 8191Ø
- 7 cotton will allow growers to proactively manage weed populations while avoiding adverse population shifts of troublesome weeds or the develop ment of resistance, particularly glyphosate resistance in weeds. Conclusion Informatio n collected during field trials and laboratory analyses presented herein conclude that DAS - 8191Ø
- 7 cotton is not likely to be a plant pest or result in weediness potenti al . DAS therefore requests a determination from USDA - APHIS that herbicide tolerant DAS 8191Ø
- 7 cotton and all progeny derived from crosses between DAS - 8191Ø
- 7 cotton and non - transgenic cotton or biotechnology derived cotton be granted nonregulated status u nder 7 CFR Part 340.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table of Contents RELEASE OF INFORMATI ON ................................ ................................ ................................ ................................ ... 2 CERTIFICATION ................................ ................................ ................................ ................................ ...................... 3 SUMMARY ................................ ................................ ................................ ................................ ............................. 4 TABLE OF CONTENTS ................................ ................................ ................................ ................................ .............. 8 LIST OF FIGURES ................................ ................................ ................................ ................................ ................... 11 LIST OF TABLES ................................ ................................ ................................ ................................ .................... 13 LIST OF ACRONYMS AND SCIENTIFIC TERMS ................................ ................................ ................................ ........ 14 1. RATIONALE FOR THE DE VELOPMENT OF DAS - 8191Ø - 7 COTTON ................................ ................................ . 17 1.1. B ASIS FOR THE R EQUEST FOR N ONREGULATED S TATUS ................................ ................................ ......................... 17 1.2. B ENEFITS OF DAS - 8191Ø - 7 C OTTON ................................ ................................ ................................ .............. 17 1.3. S UBMISSION TO O THER R EGULATORY A GENCIES ................................ ................................ ................................ .. 19 2. THE BIOLOGY OF COTTO N AND DAS - 8191Ø - 7 RECIPIENT COTTON C ULTIVAR ................................ ............. 20 2.1. O VERVIEW OF C OTTON B IOLOGY ................................ ................................ ................................ ...................... 20 2.2. C HARACTERIZATION OF T HE R ECIPIENT C OTTON C ULTIVAR ................................ ................................ ..................... 20 3. METHOD OF DEVELOPMEN T OF DAS - 8191Ø - 7 COTTON ................................ ................................ .............. 21 3.1. P DAB4468 ................................ ................................ ................................ ................................ ................. 21 3.2. D ESCRIPTION OF THE T RANSFORMATION S YSTEM ................................ ................................ ................................ . 21 3.3. S ELECTION OF THE C OMPARATORS FOR DAS - 8191Ø - 7 C OTTON ................................ ................................ ........... 25 3.4. D ONOR G ENES AND R EGULATORY S EQUENCES IN DAS - 8191Ø - 7 C OTTON ................................ .............................. 25 3.4.1. aad - 12 expression cassette ................................ ................................ ................................ .................. 25 3.4.2. pat expression cassette ................................ ................................ ................................ ........................ 25 3.4.3. RB7 MAR ................................ ................................ ................................ ................................ .............. 28 4. GENETIC CHARACTERIZA TION OF DAS - 8191Ø - 7 COTTON ................................ ................................ ............ 29 4.1. O VERVIEW OF G ENETIC C HARACTERIZATION ................................ ................................ ................................ ....... 29 4.1.1. Analysis of the Insert and Its Genetic Elements ................................ ................................ ................... 37 4.1.2. Absence of Plasmid Backbone Sequences ................................ ................................ ............................ 38 4.2. S TABILITY OF THE I NSERT A CROSS G ENERATIONS ................................ ................................ ................................ . 39 4.3. S OUTHERN B LOT A NALYSIS C ONCLUSIONS ................................ ................................ ................................ .......... 39 4.4. S EGREGATION A NALYSIS ................................ ................................ ................................ ................................ . 67 4.4.1. Genetic and Molecular Analysis of a Segregating Generation ................................ ............................ 67 4.4.2. Segregation Analysis of Breeding Generations ................................ ................................ .................... 67 4.5. S UMMARY OF THE G ENETIC C HARACTERIZATION ................................ ................................ ................................ .. 68 5. CHARACTERIZATION OF THE DAS - 8191Ø - 7 AAD - 12 AND PAT PROTEINS ................................ ..................... 69 5.1. AAD - 12 ................................ ................................ ................................ ................................ ...................... 69 5.1.1. Identity of the AAD - 12 Protein ................................ ................................ ................................ ............. 69 5.1.2. Mode of Action of the AAD - 12 Protein ................................ ................................ ................................ 70 5.1.3. Biochemical Characterization of the AAD - 12 Protein ................................ ................................ .......... 71 5.1.4. Expression of the AAD - 12 Protei n in Plant Tissues ................................ ................................ ............... 72 5.1.5. Food and Feed Safety Assessment of AAD - 12 ................................ ................................ ...................... 73 5.1.6. Summary of AAD - 12 Protein Characterization ................................ ................................ .................... 77 5.2. PAT ................................ ................................ ................................ ................................ ............................ 78 5.2.1. Identity of the PAT Protein ................................ ................................ ................................ ................... 78 5.2.2. Mode of Action of the PAT Protein ................................ ................................ ................................ ...... 78USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 5.2.3. Biochemical Characterization of the PAT Protein ................................ ................................ ................ 79 5.2.4. Expression of the PAT Protein in Plant Tissues ................................ ................................ ..................... 79 5.2.5. Food and Feed Safety Assessment of PAT ................................ ................................ ............................ 81 5.2.6. Summary of PAT Protein Characterization ................................ ................................ ........................... 82 6. COMPOSITION ASSESSME NT OF DAS - 8191Ø - 7 COTTON ................................ ................................ ............. 83 6.1. DAS - 8191Ø - 7 C OTTONSEED C OMPOSITION ................................ ................................ ................................ ..... 83 6.1.1. Field Study Design ................................ ................................ ................................ ................................ 83 6.1.2. Compositional Analysis ................................ ................................ ................................ ........................ 84 6.2. S TATISTICAL A NALYSIS ................................ ................................ ................................ ................................ .... 84 6.3. C OMPOSITION A NALYSIS R ESULTS ................................ ................................ ................................ ..................... 86 6.3.1. Sub - experiment One - Proximate and Fiber Analysis of Seed ................................ .............................. 86 6.3.2. Sub - experiment One - Mineral Analysis of Seed ................................ ................................ .................. 90 6.3.3. Sub - experiment One - Amino Acid Analysis of Seed ................................ ................................ ............. 94 6.3.4. Sub - experiment One - Fatty Acid Analysis of Seed ................................ ................................ ............. 100 6.3.5. Sub - Experiment One - Vitamin Analysis of Seed ................................ ................................ ................ 105 6.3.6. Sub - Experiment One - Anti - Nutrient Analysis of Seed ................................ ................................ ....... 107 6.3.7. Sub - Experiment Two - Composition Results ................................ ................................ ....................... 110 6.4. C OMPOSITION S UMMARY ................................ ................................ ................................ ............................. 110 6.5. C ONCLUSIONS ................................ ................................ ................................ ................................ ............. 111 7. PHENOTY PIC, AGRONOMIC AND E COLOGICAL CHARACTERI STICS ................................ ............................ 112 7.1. S TUDY D ESIGN ................................ ................................ ................................ ................................ ............ 112 7.2. D ATA C OLLECTION AND S TATISTICAL A NALYSIS ................................ ................................ ................................ .. 113 7.2.1. Phenotypic and Agronomic Results ................................ ................................ ................................ .... 115 7.2.2. Ecological Evaluations ................................ ................................ ................................ ........................ 116 7.2.3. Cottonseed Germination and Dormancy Evaluation ................................ ................................ ......... 117 7.3. S UMMARY OF P HENOTYPIC , A GRONOMIC AND E COLOGIC C HARACTERISTICS ................................ ........................... 119 7.4. F IELD E FFICACY ................................ ................................ ................................ ................................ ........... 119 8. IMPACT ON ENVIRONMEN TAL AND AGRONOMIC PR ACTICES ................................ ................................ .. 121 8.1. C URRENT U.S. A GRONOMIC P RACTICES FOR C OTTON ................................ ................................ ......................... 121 8.1.1. Cotton Production ................................ ................................ ................................ .............................. 121 8.1.2. Cotton Seed Production ................................ ................................ ................................ ..................... 124 8.1.3. Planting and Cotton Development ................................ ................................ ................................ ..... 125 8.1.4. Weeds in Cotton ................................ ................................ ................................ ................................ . 126 8.1.5. Weed Management in Cotton ................................ ................................ ................................ ........... 127 8.1.6. Crop Rotation and Tillage Practices ................................ ................................ ................................ ... 128 8.2. P OTENTIAL I MPACTS OF DAS - 8191Ø - 7 ................................ ................................ ................................ .......... 128 8.2.1. Environment – Weediness Potential, Gene Flow and Non - Target / Endangered Species .................. 129 8.2.2. Agronomic Practices – cultivation/management, weed control and volunteer management .......... 133 8.3. H ERBICIDE R ESISTANCE M ANAGEMENT ................................ ................................ ................................ ............ 135 8.3.1. Herbicide Resistance ................................ ................................ ................................ .......................... 135 8.3.2. Factors Impacting Herbicide Resistance ................................ ................................ ............................ 136 8.3.3. Herbicide Resistance Management ................................ ................................ ................................ ... 138 8.4. S UMMARY OF E NVIRONMENTAL C ONSEQUENCES AND I MPACT ON A GRONOMIC P RACTICES ................................ ....... 140 9. ADVERSE CONSEQU ENCES OF INTRODUCTIO N ................................ ................................ ......................... 141 10. APPENDICES ................................ ................................ ................................ ................................ ............. 141 A PPENDIX 1. M ETHODS FOR M OLECULAR C HARACTERIZATION OF DAS - 8191Ø - 7 C OTTON ................................ .................... 142 A PPENDIX 2. M ETHODS AND R ESULTS FOR C HARACTERIZATION OF AAD - 12 P ROTEIN ................................ ............................ 144 A PPENDIX 3. M ETHODS AND R ESULTS FOR C HARACTERIZATION OF PAT P ROTEIN ................................ ................................ .. 159USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC A PPENDIX 4. M ETHODS FOR AAD - 12 & PAT P ROTEIN E XPRESSION A NALYSIS ................................ ................................ ...... 173 A PPENDIX 5. M ETHODS FOR C OMPOSITIONAL A NALYSIS ................................ ................................ ................................ ... 177 A PPENDIX 6. C OMPOSITIONAL L ITERATURE R ANGES FOR N ON - T RANSGENIC C OTTONSEED ................................ ....................... 185 A PPENDIX 7. E VOLUTION OF H ERBICIDE R ESISTANT W EEDS IN T RANSGENIC C ROPS ................................ ................................ 187 A PPENDIX 8. S TEWARDSHIP OF H ERBICIDE T OLERANT T RAIT T ECHNOLOGY FOR DAS - 8191Ø - 7 C OTTON ................................ ... 196 A PPENDIX 9. USDA N OTIFICATIONS FOR DAS - 8191Ø - 7 C OTTON ................................ ................................ ..................... 202 A PPENDIX 10. R EFERENCES ................................ ................................ ................................ ................................ ......... 203USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC List of Figures FIGURE 1. PLASMID M AP OF PDAB4468 ................................ ................................ ................................ ..................... 22 FIGURE 2. DIAGRAM O F T - DNA REGION IN PLASMI D PDAB4468 ................................ ................................ ............... 22 FIGURE 3. SCHEMATIC OF THE DEVELOPMENT O F DAS - 8191Ø - 7 COTTON ................................ ............................... 23 FIGURE 4. BREEDING DIAGRAM OF DAS - 819 1Ø - 7 COTTON ................................ ................................ ....................... 24 FIGURE 5. DIAGRAM O F SEQUENCED TRANSGEN E INSERT IN DAS - 8191Ø - 7 COTTON ................................ .............. 29 FIGURE 6. PROBE LOC ATIONS ON PDAB4468 U SED IN SOUTHERN BLOT ANALYSIS ................................ .................. 32 FIGURE 7. PDAB4468 SHOWING LOCATION OF RESTRICTION ENZYMES USED FOR SOUTHERN AN ALYSIS ............... 36 FIGURE 8. T - DNA INSERT RESTRICTI ON ENZYME MAP OF DAS - 8191Ø - 7 COTTON ................................ ..................... 36 FIGURE 9. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH NCO I; AAD - 12 PROBE ........................ 40 FIGURE 10. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; AAD - 12 PROBE ........................ 41 FIGURE 11. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH NCO I; PAT PROBE ............................. 42 FIGURE 12. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; PAT PROBE .............................. 43 FIGURE 13. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH MSC I; ATUBI10 PROBE ...................... 44 FIGURE 14. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; ATUBI10 PROBE ...................... 45 FIGURE 15. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH NCO I; ATUORF23 3′ UTR P ROBE ....... 46 FIGURE 16. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; ATUORF23 3′ UTR P ROBE ........ 47 FIGURE 17. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH NCO I; CSVMV PROBE ........................ 48 FIGURE 18. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WITH SPH I; CSVMV PROBE ......................... 49 FIGURE 19. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH NCO I; ATUORF1 3′ UTR PR OBE ......... 50 FIGURE 20. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; ATUORF1 3′ UTR PR OBE .......... 51 FIGURE 21. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I TO RELEASE AAD - 12 EXPRESSION CASSETTE; AAD - 12 PROBE ................................ ................................ ................................ ................................ .. 52 FIGURE22. SOUTHERN A NALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I TO RELEASE AAD - 12 EXPRESSION CASSETTE; ATUBI10 PR OBE ................................ ................................ ................................ ................................ 53 FIGURE 23. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I TO RELEASE AAD - 12 EXPRESSION CASSETTE; ATUORF23 3 ′ UTR PROBE ................................ ................................ ................................ ................. 54 FIGURE 24. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I/ XHO I TO RELEASE PAT EXPRESSION CASSETTE; PAT PROBE ................................ ................................ ................................ ................... 55 FIGURE 25. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I/ XHO I TO RELEASE PAT EXPRESSION CASSETTE; CSVMV PROBE ................................ ................................ ................................ ............. 56 FIGURE 26. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I/ XHO I TO RELEASE PAT EXPRESSION CASSETTE; ATUORF1 3′ UTR PROBE ................................ ................................ .............................. 57 FIGURE 27. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH SPH I; RB7 PROBE .............................. 58 FIGURE 28. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH MSC I; ORI PROBE .............................. 59 FIGURE 29. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I; ORI PROBE ............................... 60 FIGURE 30. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH MSC I; BACKBONE2 PROBE ................ 61 FIGURE 31. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I; BACKBONE2 PROBE ................. 62 FIGURE 32. SOUTHERN ANALYSIS OF DAS - 8191 Ø - 7 COTTON DIGESTED WI TH MSC I; BACKBONE1 PROBE ................ 63 FIGURE 33. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I; BACKBONE1 PROBE ................. 64 FIGURE 34. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH MSC I; SPEC R PROBE ......................... 65 FIGURE 35. SOUTHERN ANALYSIS OF DAS - 8191Ø - 7 COTTON DIGESTED WI TH PST I; SPEC R PROBE ........................... 66 FIGURE 36. AMINO ACI D SEQUENCE OF EXPRES SED AAD - 12 IN DAS - 8191Ø - 7 ................................ .......................... 69 FIGURE 37. DEGRADATION REAC TION OF 2,4 - D CATALYZED BY AAD - 12 ................................ ................................ .... 70 FIGURE 38. GENERAL R EACTION CATALYZED BY AAD - 12 (R=H OR CH 3 ) ................................ ................................ ...... 71 FIGURE 39. AMINO ACI D SEQUENCE OF PAT ................................ ................................ ................................ ............... 78 FIGURE 40. MODE OF A CTION OF THE PAT PRO TEIN ................................ ................................ ................................ .. 79 FIGURE 41. PROXIMATE S & FIBER IN ISOLINE , DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ..................... 88 FIGURE 42. MINERALS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ................................ ....... 92 FIGURE 43. PERCENT T OTAL AMINO ACIDS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ...... 97 FIGURE 44. PERCENT T OTAL FATTY ACIDS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ...... 103USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC FIGURE 45. VITAMINS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ................................ ..... 106 FIGURE 46. ANTI - NUTRIENTS IN ISOLINE , DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED ......................... 109 FIGURE 47. PLANTED UPLAND COTTON ACRES BY COUNTY IN THE U.S . IN 2012 (USDA NASS , 2012B) .................. 1 23 FIGURE 48. PLANTED PIMA COTTON ACRES BY COUNTY IN THE U .S. IN 2012 ................................ ......................... 124 FIGURE 49. 2,4 - D USE IN DAS - 8191Ø - 7 COTTON ................................ ................................ ................................ ...... 134 FIGURE 50. ADOPTION OF GE CROPS IN THE U .S. ................................ ................................ ................................ .... 139 FIGURE 51. SDS - PAGE AND WESTERN BLOT ANA LYSIS OF MICROBE - & DAS - 8191Ø - 7 COTTON - DERIVED AAD - 12 PROTEINS ................................ ................................ ................................ ................................ ......................... 150 FIGURE 52. SDS - PAGE ANALYSIS OF IMMUNOAFFINITY PURIF IED DAS - 8191Ø - 7 COTTON DERIVED AAD - 12 ......... 151 FIGURE 53. GLYCOPRO TEIN ANALYSIS OF PUR IFIED DAS - 8191Ø - 7 COTTON AAD - 12 ................................ .............. 152 FIGURE 54. IN SILICO TRYPSIN CLEAVAGE OF DAS - 8191Ø - 7 COTTON AAD - 12 ................................ ......................... 153 FIGURE 55. IN SILICO CHYMOTRYPSIN CLEAVAG E OF DAS - 8191Ø - 7 COTTON AAD - 12 ................................ ............ 154 FIGURE 56. IN SILICO ASP - N CLEAVAGE OF DAS - 8191Ø - 7 COTTON AAD - 12 ................................ ............................ 154 FIGURE 57. COMPREHE NSIVE MS AND MS/MS SEQUENCE C OVERAGE MAP FOR TRYP SIN, CHYMOTRYPSIN AN D ASP - N DIGEST OF DAS - 8191Ø - 7 COTTON - DERIVED AAD - 12 ................................ ................................ ............ 155 FIGURE 58. KINETIC ANALYSIS OF MICROBE AND DAS - 8191Ø - 7 COTTON DERIVED AAD - 12 PROTEINS WITH S DICHLOROPROP SUBSTRA TE ................................ ................................ ................................ ............................ 158 FIGURE 59. SDS - PAGE AND WESTERN BLOT ANA LYSIS OF MICROBE - AND DAS - 8191Ø - 7 COTTON - DERIVED PAT PROTEINS ................................ ................................ ................................ ................................ ......................... 166 FIGURE 60. SDS - PAGE ANALYSIS OF THE IMMUNOAFFINITY PURIF IED DAS - 8191Ø - 7 COTTON DERIVED PAT ........ 167 FIGURE 61. GLYCOPRO TEIN ANALYSIS OF IMM UNOPURIFIED DAS - 8191Ø - 7 DERIVE D PAT ................................ .... 168 FIGURE 62. IN SILICO TRYPSIN CLEAVAGE OF DAS - 8191Ø - 7 COTTON PAT ................................ ............................... 169 FIGURE 63. IN SILICO ASP - N CLEAVAGE OF DAS - 8191Ø - 7 COTTON PAT ................................ ................................ .. 170 FIGURE 64. COMPREHE NSIVE MS AND MS/MS S EQUENCE COVERAGE MAP FOR TRYPSIN AND ASP - N DIGESTS OF DAS - 8191Ø - 7 COTTON - DERIVED PAT ................................ ................................ ................................ .............. 171 FIGURE 65. KINETIC ANALYSIS OF MICROBE - AND DAS - 8191Ø - 7 COTTON - DERIVED PAT PROTEINS ...................... 172 FIGURE 66. ADOPTION OF GE COTTO N IN THE U.S. (USDA ERS, 2013B) ................................ ................................ .. 188USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC List of Tables TABLE 1. GENETIC ELEMENTS FROM PLASMID PDAB446 8 ................................ ................................ .......................... 26 TABLE 2. GENETIC ELE MENTS IN DAS - 8191Ø - 7 COTTON ................................ ................................ ............................ 30 TABLE 3. LIST OF PRO BES AND THEIR POSITI ONS IN PLASMID PDAB4 468 ................................ ................................ .. 31 TABLE 4. PREDICTED & OBSERVED SIZES OF HY BRIDIZING FRAGMENTS IN SOUTHERN BLOT ANA LYSES .................. 33 TABLE 5. SEGREGATING GENERATI ON RESULTS OF BC 1 F 2 INDIVIDUAL PLANTS ................................ .......................... 67 TABLE 6. SEGREGATING BREEDING GENERATION RESULTS OF DAS - 8191Ø - 7 COTT ON PLANTS ................................ 68 TABLE 7. DAS - 8191Ø - 7 COTTON AAD - 12 EXPRESSION ANALYS IS TISSUE SAMPLES ................................ .................... 72 TABLE 8. SUMMARY OF AAD - 12 PROTEIN EXPRESSIO N ................................ ................................ .............................. 73 TABLE 9. DAS - 8191Ø - 7 COTTON PAT EXPRESS ION ANALYSIS TISSUE SAMPLES ................................ .......................... 80 TABLE 10. SUMMARY OF PAT PROTEIN EXPRESSI ON IN DAS - 8191Ø - 7 COTTON ................................ ........................ 80 TABLE 11. COTTONSEED COMPOSITION ANALYTES ................................ ................................ ................................ .... 85 TABLE 12. COMBINED S ITE ANALYSIS RESULTS FOR P ROXIMATES & FIBER IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARIETY CO TTONSEED AND LITERAT URE RANGES ................................ ................................ ......... 87 TABLE 13. COMBINED S ITE ANALYS IS RESULTS FOR MINER ALS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED AND LITER ATURE RANGES ................................ ................................ ................................ ........... 91 TABLE 14. COMBINED S ITE ANALYSIS RESULTS FOR AMINO ACIDS IN ISOLI NE, DAS - 8191Ø - 7 AND REFERENCE VARIETY COTTONSEED A ND LITERATURE RANGES ................................ ................................ ............................ 95 TABLE 15. COMB INED SITE ANALYSIS R ESULTS FOR FATTY ACI DS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARIETY COTTONSEED A ND LITERATURE RANGES ................................ ................................ .......................... 101 TABL E 16. COMBINED SITE ANALYSIS RESULTS FOR VITAMINS IN ISOLINE, DAS - 8191Ø - 7 AND REFERENCE VARI ETY COTTONSEED AND LITER ATURE RANGES ................................ ................................ ................................ ......... 105 TABLE 17. COMBINED S ITE ANALYSIS RESULTS FOR ANTI - NUTRIENTS IN ISOLINE , DAS - 8191Ø - 7 AND REFERENCE VARIETY COTTONSEED A ND LITERATURE RANGES ................................ ................................ .......................... 108 TABLE 18. MEASURED AGRONOMIC CHARACTERI STICS AND SAMPLE COL LECTION DETAILS ................................ . 114 TABLE 19. COMBINED SITE ANALYSIS RESULT S FOR AGRONOMIC CHAR ACTERISTICS ................................ ............. 115 TABLE 20. INSECTS A ND DISEASES PRESENT AT FIELD TESTING SIT ES ................................ ................................ ...... 117 TABLE 21. GERMINA TION PERCENTAGES FOR DAS - 8191Ø - 7 AND CONTROL COTTON SEED ................................ ... 119 TABLE 22. DAS - 8191Ø - 7 COTTON TOLERANCE T O APPLICATION OF HER BICIDES ................................ ................... 120 TABLE 23. TOTAL U.S . COTTON GROWING REG IONS, STATES AND 201 0 – 2012 HARVEST, YIELD & PRODUCTION 122 TABLE 24. COTTON PR ODUCTION IN THE U.S. , 2002 - 2013 1,2 ................................ ................................ ................. 123 TABLE 25. MAJOR WEE DS TREATED IN COTTON BY REGION IN 2011 (D ESCENDING ORDER) 1 ................................ 127 TABLE 26. N UMBER OF HERBICIDE R ESISTANT WEEDS REPOR TED GLOBALLY BY HERB ICIDE GROUP AND MODE OF ACTION 1 ................................ ................................ ................................ ................................ ............................ 137 TABLE 27. ASSESSMEN T OF RESISTANCE RISK BY E VALUATION OF CROPPIN G SYSTEMS 1 ................................ ....... 138 TABLE 28. GLYPHOSAT E AND ALS RESISTANT WEEDS CONTROLLED BY 2,4 - D 1 ................................ ........................ 139 TABLE 29. TEST MATE RIAL FOR AAD - 12 CHARACTERIZATION ................................ ................................ .................. 144 TABLE 30. COMMERCIA LLY AVAILABLE REFERE NCE SUBSTANCES FOR A AD - 12 CHARACTERIZATION ..................... 145 TABLE 31. SUMMARY O F N - TERMINAL SEQUENCES O F AAD - 12 DERIVED PROTEINS ................................ .............. 156 TABLE 32. SUMMARY O F C - TERMINAL SEQUENCES O F AAD - 12 DERIVED PROTEINS ................................ .............. 157 TABLE 33. TEST MATE RIAL FOR PAT CHARACT ERIZATION ................................ ................................ ........................ 159 TABLE 34. COMMERCIA LLY AVAILABLE REFERE NCE SUBSTANCES FOR P AT CHARACTERIZATION ........................... 160 TABLE 35. SUMMARY O F N - TERMINAL SEQUENCES O F PAT DERIVED PROTEI NS ................................ .................... 170 TABLE 36. SUMMARY O F C - TERMINAL SEQUENCES O F PAT DERIVED PROTEI NS ................................ .................... 170 TABLE 37. WEED SPEC IES WITH REPORTED GL YPHOSATE RESISTANT B IOTYPES 1 ................................ .................... 189 TABLE 38. GLOBA L REPORTS OF GLYPHOS ATE RESISTANT WEED B IOTYPES WITH RESISTA NCE TO OTHER HERBICI DE MODES OF ACTION 5 ................................ ................................ ................................ ................................ ......... 190 TABLE 39. POTENTIAL WEED SHIFTS WITH USE OF G LYPHOSATE ................................ ................................ ............ 191 TABLE 40. WEED SPEC IES WITH REPORTED 2, 4 - D RESISTANT BIOTYPES ................................ ................................ .. 193 TABLE 41. U.S. GLYP HOSATE RESISTANT WEE DS IN COTTON GROWING STATES 1 ................................ ................... 194USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC List of Acronyms and Scientific Terms Symbol or Abbreviation Definition °C Degree Celsius 2,4 - D 2,4 - Dichlorophenoxyacetic acid AA Amino Acid aad - 12 Gene encoding the AAD - 12 protein AAD - 12 Aryloxyalkanoate dioxygenase - 12 protein ACCase Acetyl CoA carboxylase ADF Acid detergent fiber Adj. P False Discovery Rate Adjusted P - value ae Acid equivalent ae/ha Acid equivalent per hectare ai Active ingredient ai/ha Active ingredient per hectare AL Alabama ALS Acetolactate synthase ANOVA Analysis of variance AOSA Association of Official Seed Analysis APHIS Animal and Plant Health Inspection Service, USDA AtUbi10 Ubiquitin promoter from Arabidopsis thaliana AtuORF1 3′ untranslated region from Agrobacterium tumefaciens AtuORF23 3′ untranslated region from Agrobacterium tumefaciens BLASTp Basic Local Alignment Search Tool protein bp Base pair BSA Bovine Serum Albumin CFR Code of Federal Regulations CFSAN Center for Food Safety and Nutrition, U.S. FDA cm centimeter CsVMV Promoter from cassava vein mosaic virus DAS Dow AgroSciences LLC DAS - 8191Ø
- 7 OECD identifier for the cotton event expressing the AAD - 12 and PAT

proteins DCP 2,4 - Dichlorophenol DIG Digoxigenin DNA Deoxyribonucleic acid ELISA Enzyme - linked immunosorbent assay EPA Environmental Protection Agency (US) ESA Endangered Species Act ESI - LC/MS Electrospray ionization - liquid chromatography mass spectrometryUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Symbol or Abbreviation Definition FAO Food and Agriculture Organization of the United Nations FARRP Food Allergy Research and Resource Program FDA Food and Drug Administration (US) FDR False Discovery Rate FIFRA Federal Insecticide, Fungicide and Rodenticide Act ft feet FWS U.S Fish & Wildlife Service g gram GA Georgia GS Glutamine synthetase ha Hectare IAA Indole acetic acid ILSI International Life Sciences Institute Kb Kilobase pair kDa Kilodalton kPa Kilopascals L Liter LA Louisiana LFS Lateral Flow Strip LOD Limit of Detection LOQ Limit of Quantitation m meter M Molar MALDI - TOF MS Matrix assisted laser desorption/ionization time - of - flight mass spectrometry MARC Metabolism Assessment Review Committee - U.S. EPA MCPA ((4 - chlro - 2 - methyphenoxy) acetic acid) MO Missouri MOA Mode of Action MS Mississippi μg microgram μL microliter μM micromolar mg Milligrams min minute mL Milliliter mM millimolar MOE Margin of exposure MW Molecular WeightUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Symbol or Abbreviation Definition NA Not Applicable NC North Caroline ng/mg Nanogram / milligram NOAEL No observed adverse effect level NOEL No observed effect level OD Optical Density OECD Organisation for Economic Co - operation and Development Ori Rep replication Origin Sequence pat Gene from Streptomyces viridochromogenes which encodes the PAT protein PAT Phosphinothricin N - acetyltransferase protein PBN US FDA Pre - market Biotechnology Notice PCR Polymerase chain reaction pDAB4468 DNA vector carrying the aad - 12 and pat expression cassettes ppb Parts Per Billion ppm Parts Per Million PPO Protoporphyrinogen oxidase PPT Phosphinothricin PSI Pounds per Square Inch RB7 MAR Matrix attachment region (MAR) from Nicotiana tabacum RCB Randomized complete block SDS Sodium dodecyl sulfate SDS - PAGE Sodium dodecyl sulfate polyacrylamide gel electrophoresis SE Standard Error sec second SGF Simulated gastric fluid SpecR Spectinomycin Resistance STI Short Term I ntake T - DNA Transfer DNA TX Texas USDA United States Department of Agriculture V volt w/v weight / volume w/w w eight / w eight WHO World Health OrganizationUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 1. Rationale for the Development of DAS - 8191 Ø - 7 Cotton 1.1. Basis for the Request for Nonregulated Status The Animal and Plant Health Inspection Service (APHIS) of the U.S. Department of Agriculture (USDA) has responsibility under the Plant Protection Act (7 U.S.C. 7701 - 7772) to pr event the introduction or dissemination of plant pests into or within the United States. The APHIS regulations at 7 CFR 340.6 provide that an applicant may petition APHIS to evaluate submitted data on the genetically engineered crop to determine that a reg ulated article does not present a plant pest risk and therefore should no longer be regulated. Dow AgroSciences LLC (herein referred to as ”DAS”) is submitting data for herbicide tolerant DAS - 8191Ø
- 7 cotton and requests a determination from APHIS that DA S - 8191Ø
- 7 cotton no longer be considered regulated articles under 7 CFR 340. 1.2. Benefits of DAS - 8191 Ø - 7 Cotton DAS has developed transgenic cotton plants containing aad - 12 and pat , which confers toleran ce to the herbicides 2,4 - D and glufosinate . The unique identifier for these plants, in accordance with the Organisation for Economic Co - operation and Development’s (OECD) “Guidance for the Designation of a Unique Identifier for Transgenic Plants” ( OECD, 2004 ) , is DAS - 8191 Ø
- 7. DAS - 8191Ø
- 7 cotton was developed using Agrobacterium - mediated transformation to stably incorporate the aad - 12 gene from Delftia acidovorans and the pat gene from Streptomyces viridochromogenes into cotton . The aad - 12 gene encodes the aryloxyalkanoate dioxygenase - 12 (AAD - 12) enzyme which, when expressed in plants, degrades 2,4 - D to herbicidally - inactive 2,4 - dichlorophenol (DCP). The pat gene encodes the en zyme phosphinothricin acetyltransferase that inactivates glufosinate. With the introduction of genetically engineered, glyphosate tolerant crops in the mid - 1990’s, growers were enabled with a simple, convenient, flexible, and inexpensive tool for control ling a wide spectrum of broadleaf and grass weeds that was unparalleled in agriculture. Consequently, producers were quick to adopt glyphosate tolerant crops, and in many instances, abandon many of the accepted best agronomic practices such as crop rotatio n, herbicide mode of action rotation, tank mixing, and incorporation of mechanical with chemical and cultural weed control. Currently glyphosate tolerant soybean, cotton, corn, alfalfa, sugar beets, and canola are commercially available in the United State s and elsewhere in the Western Hemisphere . More glyphosate tolerant crops ( e.g., wheat, rice, turf, etc. ) are poised for introduction pending global market acceptance. Many other glyphosate tolerant species are in experimental or development stages ( e.g. , sugar cane, sunflower, beets, peas, carrot, cucumber, lettuce, onion, strawberry, tomato, and tobacco; forestry species like poplar and sweetgum; and horticultural species like marigold, petunia, and begonias) ( Information Systems for Biotechnology, 2011 ) . Additionally, the cost of glyphosate has dropped dramatically in recent years to the point that few conventional weed control programs can effectively compete on price and performance with glyphosate tolerant crop systems.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Extensi ve use of glyphosate - only weed control programs has resulted in the selection of glyphosate resistant weeds, and continues to select for the propagation of weed species that are inherently more tolerant to glyphosate than most target species ( i.e. , weed sh ifts). Although glyphosate has been widely used globally for more than 30 years, the vast majority of resistant weeds have been identified in the past 5 - 8 years. Resistant weeds in the U.S. include both grass and broadleaf species

— Lolium rigidum (Rigid r yegrass), Lolium multiflorum (Italian ryegrass), Sorghum halepense (Johnsongrass), Amaranthus palmeri (Palmer amaranth), Amaranthus rudis (Common waterhemp), Ambrosia artemisiifolia (Common ragweed), Ambrosia trifida (Giant ragweed), Conyza canadensis (Hor seweed), and Conyza bonariensis (Hairy fleabane) . Additionally, weeds that had previously not been an agronomic problem prior to the wide use of glyphosate tolerant crops are now becoming more prevalent and difficult to control in the context of glyphosate tolerant crops . According to a 2012 survey across 31 states in the U.S., 49% of growers reported the presence of glyphosate resistant weed on their farms ( Pucci, 2013 ) . In 2011, the number was 34% . The problem is more pronounced in the South, with 92% of growers reporting glyphosate resistant weeds . These weed shifts are occurring predominantly, but not exclusively, with difficult - to - control broadleaf weeds . Some examples include Ipomoea, Amaranthus, Chenopodium, Taraxacum, and Commelina species. In areas where growers are faced with glyphosate resistant weed s or a shift to more difficult to - control weed species, growers can compensate by tank mixing or alternating with other herbicides that will control the surviving weeds. One popular and efficacious tank mix active ingredient for controlling broadleaf escap es has been 2,4 - diclorophenoxyacetic acid (2,4 - D). 2,4 - D has been used agronomically and in non - crop situations for broad spectrum, broadleaf weed control for more than 7 0 years. Individual cases of more tolerant weed species have been reported, but 2,4 - D remains one of the most widely used herbicides globally. The development of 2,4 - D - tolerant cotton provides an excellent option for controlling glyphosate resistant (or highly tolerant and shifted) broadleaf weed species for in - crop applications, allowing t he grower to focus applications at the critical weed control stages and extending the application window . The availability of DAS - 8191Ø
- 7 cotton is expected to have a beneficial impact on weed control practices by providing growers with an advanced tool to address their weed control needs. The availability of DAS - 8191Ø
- 7 cotton will allow growers to proactively manage weed populations while avoiding adverse population shifts of troublesome weeds or the development of resistance, particularly glyphosate re sistance in weeds. DAS - 8191Ø
- 7 cotton will be commercialized in combination with other herbicide tolerant ( e.g . glyphosate) and insect resistance cotton events. Stacked varieties provide growers with built - in, sustainable resistance management tools to address glyphosate resistant and hard to control weeds, as well as incorporate the recognized environmental benefits of insect resistant traits. The combination of herbicide tolerance traits will allow the use of multiple herbicides in an integrated weed management program to control a broad spectrum of grass and broadleaf weed species in cotton. These herbicides will provide distinct modes of actions for use in con

junction with other herbicide active ingredients and mode s of action for anUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC effective weed management program in cotton . 2,4 - D will provide improved in - crop post emergence control of hard to control glyphosate resistant broad - leaf weeds, such as pigweed, w aterhemp, horseweed, and morning g lory. 1.3. Submission to O ther Regulatory Agencies DAS - 8191Ø
- 7 cotton falls within the scope of the FDA policy statement, published in the Federal Register on May 29, 1992, concerning regulation of products deriv ed from new plant varieties, including those developed via biotechnology. DAS submitted a pre - market biotechnology notification (PBN ) to FDA in June 2013 , BNF 000142 with anticipated review completed in late 2014 . The regulation and use of herbicides on D AS - 8191Ø
- 7 cotton is governed by the U.S. EPA under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA ) , which prohibits the sale and distribution of any pesticide that is not registered by EPA . In order to register a pesticide or a new use of a previously registered pesticide EPA must find that it will not pose an unreasonable risk to humans or the environment. Once registered, it is a violation of FIFRA to use a pesticide in a manner inconsistent with its EPA - approved label. The use of herbicid es on DAS - 8191Ø
- 7 cotton will be consistent with either currently authorized herbicide uses on cotton or uses that are currently in review by U.S. EPA . Pesticides produced in planta , known as plant - incorporated protectants (PIPs), are also subject to regulation by the U.S. EPA under FIFRA ( e.g. Cry proteins) . Since AAD - 12 and PAT are neither a herbicide or PIP, AAD - 12 and PAT fall outside the scope of EPA regulations . DAS intends to submit dossiers beginning in 2013 to the regulatory authorities of trade partners for import clearance and production approval which may include Canada, Japan, Korea, European Union, Australia / New Zealand, South Africa, Brazil and Mexi co .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 2. The Biology of Cotton and DAS - 8191 Ø - 7 Recipient Cotton Cultivar 2.1. Overview of Cotton Biology Refer to The OECD Consensus Document on t he Biology of Cotton ( Gossypium , spp.) ( OECD, 2008 ) , for information related to the following aspects of cotton biology:

 G eneral description and morphology of cotton (p 11

– 12 )  Uses of cotton as a crop plant (p 13 )  Taxonomy (p 14

– 15 )  Centers of origin, diversity and domestication (p 15

– 18 )  A gronomic practices (p 1 9

– 2 3 ) o Biotic Environment (pest, diseases, weeds) (p 21

– 23 ) o Harvest, processing and crop rotation (p 23 )  R eproductive biology (p 2 4

– 2 7) o Seed dormancy and germination (p 26 ) o Weediness and naturalization (p 26 - 27 )  Genetics & Hybridization ( p 28

– 29 ) o A bility to cross intra and inter - species/genus (p 29 )  Toxin and Allergen potential (p 34

– 35 ) o Gossypol (p 34 - 35 ) o Cyclopropenoid fatty acids (p 35) o Allergens (p 35 ) 2.2. Characterization of the Recipient Cotton Cultivar The publically available cotton variety Coker 310 ( G. hirsutum ) was used as the recipient lines for the generation of event DAS - 8191 Ø
- 7 . The variety Coker 310 was developed by the cotton division of Coker’s Pedigreed Seed Company and is an older commercial variety of upland cotton generated from a cross of Coker 100 Staple and Deltapine 15 and selected through successive generations of line selection ( Smith et al. , 1 999 ; Bowman et al. , 2006 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 3. Method of Development of DAS - 8191Ø - 7 C otton DAS - 8191Ø
- 7 cotton was generated by Agrobacterium mediated transform ation of cotton tissues from Coker 310 variety using plasmid pDAB4468 ( Figure 1 ). This section describes the plasmid vector (pDAB4468), the transformation method, the donor genes ( aad - 12 and pat ), and the regulatory elements used in the development of DAS - 8191 Ø
- 7 cotton. The transfer DNA (T - DNA) refers to DNA that is transferred to the plant during transformation. The T - DNA insert in pDAB4468 ( Figure 2 ) contains two synthetic genes, aad - 12 from Delftia acidovorans and pat from Streptomyces viridochromogenes . 3.1. pDAB4468 The plasmid vector, pDAB4468, was used in the transformation of cotton to generate DAS 8191Ø
- 7. A vector map and the summary of the genetic elements in pDAB4468 are provided in Figure 1 and Table 1 , respectively. pDAB4468 is approximately 12 - kb and contains one T DNA that is delineated by T - DNA borde rs B and A ( Figure 2 ). The T - DNA contains the aad 12 and pat expression cassettes along with the RB7 - MAR sequence. A gene expression cassette is compr ised of sequences to be transcribed (the gene coding sequence) and the regulatory elements necessary for the expression of those sequences ( e.g. promoter, terminator). Details of the expression cassettes and RB7 - MAR in pDAB4468 are described below in secti ons 3.4.1 , 3.4.2 , 3.4.3 and in Table 1 . The backbone region of pDAB4468, located outside the T - DNA region, contains two origins of replication (OriRep and Trf A) for the maintenance of the plasmid vector in bacteria and a bacterial selectable marker gene ( SpecR ). Details of the genetic elements are in Table 1 . 3.2. Description of the Transformation System Cotton ( Gossypium hirsutum L.) event DAS - 8191Ø
- 7 was developed through Agrobacterium - mediated transformation of pDAB4468. The disarmed A. tumefa ciens strain LBA4404 ( Ooms et al. , 1982 ) , carrying the binary vector, pDAB4468, was used to initiate transformation of cotton hypocotyl segments. Agrobacterium - mediated transformation was carried out using a modified procedure based on Umbeck et al. ( Umbeck, 1991 ) . Briefly, cotton seeds (cv. Coker 310) were germinated on basal media and hypocotyl segments were isolated and infected with Agrobacterium strain LBA4404 carrying pDAB4468. Following infection, the hypocotyl segments were cult ured on a sequence of media containing carbenicillin and glufosinate to inhibit the growth of Agrobacterium and untransformed cells, respectively. Gene - specific PCR analyses were performed on embryogenic callus to identify transgenic lines containing the target genes ( aad - 12 and pat ). Selected calli were transferred to culture medium containing plant growth regulators to stimulate root regeneration. Rooted plants (T 0 ) were transferred to soil mixtures under high humidity in growth chambers for 2 - 4 weeks. The hardened plants were then transferred to greenhouse facilities. Following the transfer to the greenhouse, young leaves of T 0 plants were painted with glufosinate (1.5% w/v) to screen for putative transformants. Those glufosinate tolerant plants were sampled and analyzed at a molecular level to confirm the presence of the target genesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC and the absence of the vector backbone. Specifically, for T 0 plants, PCR analyses were performed to verify the absence of the bacterial selectable marker sequence, specti nomycin, in the vector backbone of pDAB4468 as well as the presence of the aad - 12 and pat genes. PCR and Invader assays ( Kwiatkowski et al. , 1999 ) , were carried out to determine the copy number of the pat and aad - 12 genes. T 0 plants conferring the desirable copy number were self - pollinated to produce T 1 seed. For T 1 plants, Invader assay and Sou thern blot analyses were performed to identify plants containing a single pat and aad - 12 gene insertion. DAS 8191Ø
- 7 cotton was selected as the lead event based on molecular and phenotypic characteristics. Genetic characterization studies on DAS - 8191Ø
- 7 cotton were initiated to further characterize the transgenic insert and the expressed proteins (Section 4 ). The major steps described in the development of DAS - 819 1Ø
- 7 cotton are described in Figure 3 with the breeding diagram for DAS - 8191Ø
- 7 cotton in Figure 4 .

Figure 1 . Plasmid map of pDAB4468

Figure 2 . Diagram of T - DNA R egion in P lasmid pDAB4468USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 3 . Schematic of the Devel opment of DAS - 8191Ø - 7 Cotton Assembled Agrobacterium binary vector pDAB4468 and transformed into disarmed

Agrobacterium tumefaciens strain LBA4404 Transformed Coker 310 hypocotyl segments with pDAB4468 using Agrobacterium

tumefaciens - mediated transformation R egenerated calli on media containing glufosinate and carbenicillin to select for transformed calli expressing PAT and to inhibit Agrobacterium growth, respectively Performed gene specific PCR analysis ( aad - 12, pat ) on selected transformants Generated roo ted shoots from transformed tissues positive for both genes Performed preliminary evaluation on transformed T 0 plants for the absence of vector backbone and copy number of the genes of interest. Allowed self pollination to produce T 1 plants Evaluated T 1 plants and subsequent generations resulting from self pollination Evaluated transgenic plants via molecular characterization, protein expression,

agronomic performance, and herbicide resistance Selected homozygous plants and carried out crossing and backcrossing into DAS proprietary cotton strain 98M - 2983 to identify the lead candidate, DAS - 8191Ø
- 7. Further evaluated progeny to evaluate and assess insert integrity, copy number,

herbicide tolerance and agr onomic performanceUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Analysis Petition

Section(s) DAS - 8191Ø - 7

Cotton Generations Control Molecular Analysis 4 , 4.2 T 2 , T 3 , T 4 , T 5 , BC 1 F 2 Coker 310 Segregation Analysis (single generation) 4.4.1 BC 1 F 2 None Segregation Analysis (breeding generations) 4.4.2 T 1 , BC 1 F 2 None Protein Characterization 5.1.3 , 5.2.3 T 3 Coker 310 Protein Expression 5.1.4 , 5.2.4 BC 1 F 3 98M - 2983 Composition 6.1 BC 1 F 3 98M - 2983 Agronomics 7.1 BC 1 F 3 98M - 2983 Germination & Dormancy 7.2.3 BC 1 F 4 98M - 2983 X Coker 310

Figure 4 . Breeding Diagram of DAS - 8191Ø - 7 CottonUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 3.3. Selection of the Comparators for DAS - 8191Ø - 7 Cotton P roper selection of comparator (control) plants is important t o ensure the accurate assessment of the impact of transgene insertion on various characteristics of DAS - 8191Ø
- 7 cotton . The control plants should have a genetic background similar to that of DAS - 8191Ø
- 7 cotton but lack the transgenic insert. In all cases, a genotypically similar non - transgenic near isogenic control was used as a comparator (see Figure 4 ) . 3.4. Donor Genes and Regulatory Sequences in DAS - 8191 Ø - 7 Cotton The transgenic insert in DAS - 8191Ø
- 7 cotton contains two expression cassettes, aad - 12 and pat in addition to a matrix attachment region (MAR) of RB7 from Nicotiana tobacum ( Figure 2 ) . This section describes the details of each expression cassette including the source organism, history of safe use , the expressed traits and the genetic organization of each expression cassette . I n addition, details of the RB7 - MAR sequence are described. 3.4.1. aad

- 12 expression cassette The aad - 12 expression cassette consists of the AtUbi10 promoter, aad - 12 gene and AtuORF23 3′ UTR terminator ( Figure 2 , Table 1 ) and is identical to the aad - 12 expression cassette in DAS - 68416 - 4 soybean and DAS - 444Ø6
- 6 so ybean ( c urrently under USDA APHIS review , petition numbers 09 - 349 - 01p, 11 - 234 - 01p respectively ) . The aad - 12 gene was isolated from Delftia acidovorans and the synthetic version of the gene was optimized for plant expression by modify ing the G+C content bia s to the plant system . The native and plant - optimized DNA sequences of aad - 12 are 80 % identical. The aad - 12 gene i s designed to express the A ryloxyalkanoate D ioxygenase - 12 ( AAD - 12 ) protein , which consists of 293 amino acids with a molecular weight of approximately 32 kDa. Expression of AAD - 12 protein in plants confers tolerance to herbicides such as 2,4 - D . D . acidovorans , which w as previously described as Pseudomonas acidovorans and Comamonas acidovorans , is a non glucose - fermenting, gram - negative, non spore - forming rod - shaped bacterium present in soil, fresh water, activated sludge, and clinical specimens ( Von Graevenitz, 1985 ; Tamaoka et al. , 1987 ; Wen et al. , 1999 ) . Strains of D. acidovorans can be used to transform ferulic acid into vanillin and related flavor metabolites ( Toms and Wood, 1970 ; Labuda et al. , 1992 ; Rao and Ravishankar, 2000 ; Shetty et al. , 2006 ) . aad - 12 expression is controlled by the AtUbi10 promoter from Arabidopsis thaliana , which is known to drive constitutive expression of the genes that it controls ( Norris et al. , 1993 ) . The terminator sequence , AtuORF23 3′ UTR, is derived from Agrobacterium tumefaciens plasmid pTi15955 ( Barker et al. , 1983 ) . 3.4.2. pat e xpression cassette The pat expression cassette consists of the CsVMV promoter, pat gene and AtuORF1 3′ UTR terminator ( Figure 2 ) and is identical to the pat expression cassette in DAS - 68416 - 4 soybean and DAS - 444Ø6
- 6 soybean (c urrently under USDA - APHIS review , petition numbers 09 - 349 - 01p, 11 - 234 - 01p respectively) . The pat expression cassette is designed to express the PAT protein . The pat gene was isolated from the common soil bacterium Streptomyces viridochromogenes ( Wohlleben et al. , 1988 ) and the synthetic version of the ge ne was optimized for plant expression by modify ing the G+C content bias to the plant system.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 1 . Genetic E lements from P lasmid pDAB4468 Feature Name Feature

Start Feature

Stop Feature

Size Description T - DNA Region T - DNA Border B 1 24 24 Transferring DNA sequences Intervening sequence 25 160 136 Sequence from Ti plasmid pTi15955 ( Barker et al. , 1983 ) RB7 - MAR 161 1326 1166 Matrix attachment region (MAR) from Nicotiana tobacum ( Hall et al., 1991 ) Intervening sequence 1327 1421 95 Sequence from plasmid pENTR/D - TOPO (Invitrogen Cat. No. A10465) and multiple cloning sites AtUbi10 1422 2743 1322 Arabidopsis thaliana polyubiquitin UBQ10 gene comprising the promoter, 5′ untranslated region and intron ( Norris et al. , 1993 ) Intervening sequence 2744 2751 8 Sequence used for DNA cloning aad - 12 2752 3633 882 Synthetic, plant - optimized version of an aryloxyalkanoate dioxygenase from Delftia acidovorans ( Wright et al. , 2009 ) Intervening sequence 3634 3735 102 Sequence used for DNA cloning AtuORF23 3736 4192 457 3′ untranslated region (UTR) comprising the transcriptional terminator and polyadenylation site of open reading frame 23 (ORF23) of Agrobacterium tumefaciens pTi15955 ( Barker et al. , 1983 ) Intervening sequence 4193 4306 114 Sequence from plasmid pENTR/D - TOPO (Invitrogen Cat. No. A10465) and multiple cloning sites CsVMV 4307 4823 517 Promoter and 5′ untranslated region derived from the cassava vein mosaic virus ( Verdaguer et al. , 1996 ) Intervening sequence 4824 4830 7 Sequence used for DNA cloning pat 4831 5382 552 Selectable marker. Synthetic, plant - optimized version of phosphinothricin N

- acetyl transferase gene, isolated from Streptomyces viridochromogenes ( Wohlleben et al. , 1988 ) Intervening sequence 5383 5484 102 Sequence from plasmid pCRI2.1(Invitrogen Cat. No. K205001) and multiple cloning sites AtuORF1 5485 6188 704 3′ untranslated region (UTR) comprising the transcriptional terminator and polyadenylation site of open reading frame 1 (ORF1) of Agrobacterium tumefaciens pTi15955 ( Barker et al. , 1983 ) Intervening sequence 6189 6416 228 Sequence from Ti plasmid C58 ( Zambryski et al. , 1982 ; Wood et al. , 2001 )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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The presence of PAT protein in plants confers tolerance to glufosinate . The pat gene encodes a protein of 183 amino acids that has a molecular weight of approximately 2 0 kDa . The pat gene was used both as a selectable marker and herbicide tolerance trait in previously deregulated products ( USDA, 1996 ; FDA, 1998 , 2001 ; USDA, 2001 ; FDA, 2003 , 2004a , 2004b , 2004c ; USDA, 2004 , 2005 ; FDA, 2011 ) . Expression of the pat gene is controlled by the cassava vein mosaic virus CsVMV promoter and the AtuORF1 3′ UTR sequence from A . tumefaciens plasmid pTi15955 . The CsVMV is a double stranded DNA virus which infects cassava plants ( Manihot esculenta Crantz) and has been characterized as a plant pararetrovirus belonging to the caulimovi rus subgroup . The CsVMV promoter is known to drive constitutive expression of the g enes that it controls ( Verdaguer et al. , 1996 ) . Feature Name Feature

Start Feature

Stop Feature

Size Description T - DNA border A 6417 6440 24 Transferring DNA sequences intervening sequence 6441 6459 19 Sequence from Ti plasmid C58 ( Zambryski et al. , 1982 ; Wood et al. , 2001 ) T - DNA border A 6460 6483 24 Transferring DNA sequences intervening sequence 6484 6770 287 Sequence from Ti plasmid pTi15955 ( Barker et al. , 1983 ) T - DNA border A 6771 6794 24 Transferring DNA sequences Plasmid Backbone Region Plasmid backbone sequences 6795 7173 379 Plasmid backbone sequences from RK2 plasmid ( Stalker et al. , 1981 ) Ori Rep 7174 8193 1020 Replication origin sequences from RK2 plasmid ( Stalker et al. , 1981 ) Plasmid backbone sequences 8194 8738 545 Plasmid backbone sequences from RK2 plasmid ( Stalk er et al. , 1981 ) Trf A 8739 9887 1149 Plasmid replication sequences for Trf A protein from RK2 plasmid ( Stalker et al. , 1981 ) Plasmid backbone sequences 9888 11091 1204 Plasmid backbone sequences from RK2 plasmid ( Stalker et al. , 1981 ) Spec R 11092 11880 789 Sequences for Spectinomycin resistance gene ( Fling et al. , 1985 ) Plasmid backbone sequences 11881 12154 274 Plasmid backbone sequences for cloningUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 3.4.3. RB7 MAR In addition to the two expression cassettes, a matrix attachment region (MAR) of RB7 from Nicotiana tabacum was included at the 5 ′ end of the T - DNA . Matrix attachments regions are natural and abundant regions found in genomic DNA that are thought to attach to the matrix or scaffold of the nucleus . When positioned on the flanking ends of gene cassettes, some MARs have been shown to increase expression of transgenes and to reduce t he incidence of gene silencing ( Han et al. , 1997 ; Abranches et al. , 2005 ; Verma et al. , 2005 ) . It is hypothesi zed that MARs may act as a buffer to protect transgenes from neighboring chromosomal sequences that could destabilize their expression ( Allen et al. , 1993 ; Allen et al. , 2000 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 4. Genetic Characterization of DAS - 8191 Ø - 7 Cotton 4.1. Overview of Genetic Characterization Characterization of DAS - 8191Ø
- 7 cotton was conducted by Southern blot and DNA sequence analys e s . The sequence of the insert in DAS - 8191 Ø
- 7 cotton was confirmed ( Figure 5 ) and the genetic elements identified in DAS - 8191Ø
- 7 cotton are provided in Table 2 . Results demonstrate that the transgene insert in DAS - 8191Ø
- 7 cotton occurred as a single integration of the respective T - DNA regions from plasmid pDAB4468 , including a single, intact copy of each of the aad - 12 and pat gene expression cassettes along with a RB7 - MAR element . The transgene insert is stably integrated and inherited across breeding generations, and no plasmid backbone sequences are present in DAS - 8191Ø
- 7 cotton .

Figure 5 . Diagram of Sequenced Transgene Insert in DAS - 8191Ø - 7 Cotton Southern blot analyse s were used to determine the copy and insertion number of the integrated DNA as well as the presence or absence of plasmid vector backbone sequences . The Southern analysis was designed to ensure that all potential transgenic segments from pDAB4468 would be identified in DAS - 8191Ø
- 7 cotton . Locations of each probe on plasmid pDAB4468 are described in Figure 6 and Table 3 respectively . Restriction enzymes were specifically chosen to fully characterize the transgene insert and detect any potential fragments of the T - DNA and backbone sequences in DAS - 8191Ø
- 7 cotton . The expected and observed fragment sizes for DAS - 8191Ø
- 7 cotton genomic DNA, generated by specific restriction enzyme and probe combinations, based on the known restriction enzyme sites of plasmid pDAB4468 and the intended T - DNA insert from pDAB4468 , are shown in Figure 7 and Figure 8 , respectively. The Southern blot analyses described here consist of two types of DNA restriction fragments: a) internal fragments generated by known restriction enzyme recognition sites locate d within the T - DNA insert of pDAB4468, and b) border fragments generated by one known restriction enzyme recognition site located within the T - DNA insert and a nother site located in the cotton genome flanking the insert ( Figure 8 ) . Border fragment sizes vary by event because they rely on the location of the restriction enzyme recognition sites with in the DNA sequence flanking the transgene insert . Since integration si tes are unique for each event, border fragments provide a mean s to determine the number of transgene insertions and to specifically identify the event.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 2 . Genetic E lements in DAS - 8191Ø - 7 C otton Feature Name Feature

Start Feature

Stop Feature Length Description 5′ Flanking border 1 1373 1373 Cotton genomic DNA flanking the 5′ end of the transgene insert in DAS - 8191Ø
- 7 cotton Transgene Insert Partial T DNA Border B 1374 1375 2 Partial sequence from T - DNA Border Bs Intervening sequence 1376 1511 136 Sequence from Ti plasmid pTi15955 ( Barker et al. , 1983 ) RB7 - MAR 1512 2677 1166 Matrix attachment region (MAR) from Nicotiana tobacum ( Ha ll et al., 1991 ) Intervening sequence 2678 2772 95 Sequence from plasmid pENTR/D - TOPO (Invitrogen Cat. No. A10465) and multiple cloning sites AtUbi10 2773 4094 1322 Arabidopsis thaliana polyubiquitin UBQ10 gene comprising the promoter, 5′ untranslated region and intron ( Norris et al. , 1993 ) Intervening sequence 4095 4102 8 Sequence used for DNA cloning aad - 12 4103 4984 882 Synthetic, plant - optimized version of an aryloxyalkanoate dioxygenase from Delftia acidovorans ( Wright et al. , 2010 ) Intervening sequence 4985 5086 102 Sequence used for DNA cloning AtuORF23 5087 5543 457 3′ untranslated region (UTR) comprising the transcriptional terminator and polyadenylation site of open reading frame 23 (ORF23) of Agrobacterium tumefaciens pTi15955 ( Barker et al. , 1983 ) Intervening sequence 5544 5657 114 Sequence from plasmid pENTR/D - TOPO (Invitrogen Cat. No. A10465) and multiple cloning sites CsVMV 5658 6174 517 Promoter and 5′ untranslated region derived from the cassava vein mosaic virus ( Verdaguer et al. , 1996 ) Intervening sequence 6175 6181 7 Sequence used for DNA cloning pat 6182 6733 552 Synthetic, plant - optimized version of phosphinothricin N - acetyl transferase (PAT) gene, isolated from Streptomyces viridochromogenes ( Wohlleben et al. , 1988 ) Intervening sequence 6734 6835 102 Sequence from plasmid pCRI2.1 (Invitrogen Cat. No. K205001) and multiple cloning sitesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Genomic DNA for Southern blot analysis was prepared from leaf material of individual DAS - 8191 Ø
- 7 cotton plants from five distinct breeding generations ( Figure 4 ) . Gen omic DNA from leaves of non - transgenic variety Coker 310 was used as a control material . Plasmid DNA of pDAB4468 added to genomic DNA from the non - transgenic variety Coker 310 served as the positive control for Southern blot analysis . Materials and methods used for Southern analyses are further described in Appendix 1 . The expected restriction fragments of the inserted DNA are shown in Table 4 and Figure 8 . Southern blot analysis results are shown in Figure 9 through Figure 35 .

Table 3 . List of P robes and their P ositions in P lasmid pDAB4468 Probe Name Position in pDAB4468 Length (bp) RB7 25 - 1432 1408 AtUbi10 1433 - 2750 1318 aad - 12 2752 - 3633 88 2 AtuORF23 3′ UTR 3607 - 4300 694 CsVMV 4301 - 4871 571 pat 4831 - 5382 552 AtuORF1 3′ UTR 5361 - 6411 1051 Ori 6412 - 8193 1782 Backbone2 8160 - 9887 1728 Backbone1 9857 - 11110 1254 SpecR 11092 - 24 1087 Feature Name Feature

Start Feature

Stop Feature Length Description AtuORF1 6836 7539 704 3′ untranslated region (UTR) comprising the transcriptional terminator and polyadenylation site of open reading frame 1 (ORF1) of Agrobacterium tumefaciens pTi15955 ( Barker et al. , 1983 ) Intervening sequence 7540 7763 224 Sequence from Ti plasmid C58 ( Zambryski et al. , 1982 ; Wood et al. , 2001 ) Cotton Ge nomic DNA 3′ Flanking border 7764 8834 1071 Cotton genomic DNA flanking the 3′ end of the transgene insert in DAS - 8191Ø
- 7 cottonUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 6 . Probe L ocations on pDAB4468 used i n Southern B lot A nalysis

The eleven p robe s described in Table 3 are shown as hashed boxes i n the inner circle of the pDAB4468 plasmid map (outer circle) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 4 . Predicted & O bserve d S izes of H ybridizing F ragments in Southern B lot A nalyses Probe Restriction

enzyme Sample Lane Expected fragment sizes (bp) 1 Observed

fragment sizes (bp) 2 Fig ure

aad - 12 Nco I pDAB4468 2 7429 ~7400 Figure 9 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >4043 ~9500 Sph I pDAB4468 2 12154 ~12200 Figure 10

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000
pat Nco I pDAB4468 2 7429 ~7400 Figure 11 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >4043 ~9500 Sph I pDAB4468 2 12154 ~12200 Figure 12

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000
AtUbi10 Msc I pDAB4468 2 6225 ~6200 Figure 13 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >5464 ~15000 Sph I pDAB4468 2 12154 ~12200 Figure 14

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000 AtuORF23 3′ UTR Nco I pDAB4468 2 7429 ~7400 Figure 15 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >4043 ~9500 Sph I pDAB4468 2 12154 ~12200 Figure 16

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000
CsVMV Nco I pDAB4468 2 7429 ~7400 Figure 17 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >4043 ~9500 Sph I pDAB4468 2 12154 ~12200 Figure 18

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000 AtuORF1 3′ UTR Nco I pDAB4468 2 7429 ~7400 Figure 19 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >4043 ~9500USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Probe Restriction

enzyme Sample Lane Expected fragment sizes (bp) 1 Observed

fragment sizes (bp) 2 Fig ure Sph I pDAB4468 2 12154 ~12200 Figure 20

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000 aad - 12 Pst I

Release aad - 12 expression cassette pDAB4468 2 2868 ~2900 Figure 21

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 2868 ~2900 AtUbi10 pDAB4468 2 2868 ~2900 Figure 22 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 2868 ~2900 AtORF23 3′ UTR pDAB4468 2 2868 ~2900 Figure 23 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 2868 ~2900 pat Pst I/

Xho I Release pat expression cassette pDAB4468 2 1928 ~1900 Figure 24

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 1928 ~1900 CsVMV pDAB4468 2 1928 ~1900 Figure 25 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 1928 ~1900 AtuORF1 3′ UTR pDAB4468 2 1928 ~1900 Figure 26 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 1928 ~1900 RB7 Sph I pDAB4468 2 12154 ~12200 Figure 27 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 >6245 ~7000
Ori Msc I pDAB4468 2 5929, 6225 ~5900, ~6200 Figure 28 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none Pst I pDAB4468 2 9286 ~9300 Figure 29

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none Backbone 2 Msc I pDAB4468 2 5929 ~5900 Figure 30 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none noneUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Probe Restriction

enzyme Sample Lane Expected fragment sizes (bp) 1 Observed

fragment sizes (bp) 2 Fig ure Backbone 2 Pst I pDAB4468 2 9286 ~9300 Figure 31 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none
Backbone 1 Msc I pDAB4468 2 5929 ~5900 Figure 32 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none Pst I pDAB4468 2 9286 ~9300 Figure 33

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none SpecR Msc I pDAB4468 2 5929 ~5900 Figure 34 Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none Pst I pDAB4468 2 9286 ~9300 Figure 35

Coker 310 3 none none DAS - 8191Ø
- 7 4 - 18 none none 1 Expected fragment sizes are based on the plasmid map of pDAB4468 ( Figure 7 ) and the intended T - DNA insert in DAS - 8191Ø
- 7 cotton ( Figure 8 ) . 2 Observed fragment sizes are considered approximately from these analyses and are based on the indicated sizes of the DIG - labeled DNA Molecular Weight Marker fragments . Due to the incorporation of DIG molecules for visualization, the Marker fragments typically run approximat ely 5 - 10% larger than their actual indicated molecular weight.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 7 . pDAB4468 S howing L ocation of R estriction E nzyme s used for Southern A nalysis

Figure 8 . T - DNA I nsert R estriction E nzyme M ap of DAS - 8191Ø - 7 Cotton Top: Intended T - DNA insert map of DAS - 8191Ø
- 7 cotton showing restriction enzymes used for DNA digestion . Dashed blue lines on either end of insert represent cotton genomic DNA flanking T - DNA insert . Bottom: table of restriction enz ymes (left) showing expected Southern blot hybridization band sizes for each restriction enzyme (right) . A great er than symbol (>) denotes border fragments in which the hybridization band size is expected to be greater than the indicted size shown.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 4.1.1. Anal ysis of the Insert and Its Genetic Elements 4.1.1.1. Number of Transgenic Insertion Sites & Copy Number To determine the number of pDAB4468 transgenic insertion sites as well as the copy numbers of the transgenes in DAS - 8191 Ø
- 7 cotton, d etailed Southern blot analysis was conducted on genomic DNA from five distinct breeding generations of DAS - 8191 Ø
- 7 cotton ( Figure 4 ) . Restric tion enzymes Nco I , Sph I , and Msc I were chosen to determine the number of inserts in DAS - 8191 Ø
- 7 cotton since each restriction enzyme cut s only once in the T DNA insert ( Figure 8 ) and at an undefined location in the cotton genome to generate a border fragment . Since integration sites are unique for each event, border fragments provide a mean s to determine the insertion and copy numbers to specifically identify the event . To determine insertion and copy number , p robes specific to the T - DNA insert ( aad - 12 , pat , AtUbi10 promoter, AtuORF23 3  UTR, CsVMV promoter, AtuORF1 3  UTR, and RB7 MAR ) were used to screen Southern blots containing digested DAS - 8191 Ø
- 7 cotton genomic DN A . When genomic DNA from DAS - 8191 Ø
- 7 cotton was digested with Nco I and hybridized with the aad - 12 , pat, ORF23, CsVMV, and AtuORF1 3  UTR probes a single hybridization band of >4043 bp was expected ( Figure 8 ). As anticipated, all DAS - 8191 Ø
- 7 cotton sam ples displayed a single band of ~9500 bp, consistent with the expected result of >4043 bp ( Figure 8 , Figure 9 , Figure 11 , Figure 15 , Figure 17 , Figure 19 ). When digested with Msc I and hybridized with the At Ubi10 promoter probe , all DAS - 8191 Ø
7 cotton samples d isplayed a single band of ~1 50 0 0 bp, consistent with the expected result of > 5464 bp ( Figure 8 , Figure 13 ). When digested with Sph I and hybridized with aad - 12 , pat , AtUbi10, ORF23 3  UTR, CsVMV, a nd AtuORF1 3  UTR and RB7 probes, all DAS - 8191 Ø
- 7 cotton samples displayed a single band of ~7000 bp, consistent with the expected result of >6245 bp ( Figure 8 , Figure 10 , Figure 12 , Figure 14 , Figure 16 , Figure 18 , Figure 20 and Figure 27 ). In addition to DAS - 8191 Ø
- 7 cotton DNA, g enomic DNA from leaves of non - transgenic variety Coker 310 was used as a negative control material ( Appendix 1 ) . Plasmid DNA of pDAB4468 added to genomic DNA from the non - transgenic variety Coker 310 served as the positive control for Southern blot analysis . As expected, s pecific hybridization bands w ere detected in all of the positive control samples at the expected sizes for each restriction enzyme and probe combinations tested ( Figure 9 - Figure 20 and Figure 27 ). For negative control plants, in which genomic DNA from non - transgenic var iety Coker 310 was used, no hybridization bands were detected, as expected ( Figure 9 - Figure 20 and Figure 27 ). These data confirm that DAS - 8191 Ø
- 7 cotton contain a single integration and a single copy of the respective T - DNA sequence from pDAB4468 plasmid ( including the AtUbi10 promoter, add - 12 , AtuORF23 3′ UTR, CsVMV promoter, pat , AtuORF1 3′ UTR along with the RB7 MAR element ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 4.1.1.2. Structure of the Insert and Genetic Elemen ts To further characterize the structure of transgene insert and confirm that DAS - 8191 Ø
- 7 cotton contains a single intact cop y of the aad - 12 expression cassette (AtUbi10 promoter, add - 12 , AtuORF23 3′ UTR) and pat expression cassette (CsVMV promoter, pat , A tuORF1 3′ UTR), DAS - 8191 Ø
- 7 cotton genomic DNA was digested with Pst I and Pst I/ Xho I restriction enzymes and hybridized with the cassette element - based probes . As shown in Figure 7 and Figure 8 , Pst I allows for the release of the full length aad - 12 expression cassette , while Pst I/

Xh o I allows for the release of the full length pat expression cassette . Southern blot analysis was conducted on genomic DNA from five distinct breeding generations of DAS - 8191 Ø
- 7 cotton ( Figure 4 ) . When digested with Pst I and separately hybridized with the aad - 12 , AtUbi10, and AtuORF23 3′ UTR probes, all DAS - 8191 Ø
- 7 cotton samples along with the positive control displayed a single ban d of ~2900 bp, consistent with the predicted size of 2868 bp for the aad - 12 expression cassette ( Figure 8 , Figure 21 , Figure 22 , Figure 23 ). These data indicate that an intact aad - 12 expression cassette is present in all tested generations of DAS - 8191 Ø
- 7 cotton . When digested with PstI/XhoI and separately hybridized with the p at probe, CsVMV, and AtuORF1 3  UTR probes, all DAS - 8191 Ø
- 7 cotton samples along with the positive control displayed a single band of ~1900 bp, consistent with the predicted size of 1928 bp for pat expression cassette ( Figure 8 , Figure 24 , Figure 25 , Figure 26 ). These data indicate that an intact pat expression cassette is present in all tested generations of DAS - 8191 Ø
- 7 cotton . Hybridization bands of the expected sizes were detected in all posit ive samples , while no specific hybridization band was detected in the non - transgenic cotton samples ; as expected ( Figure 21 - Figure 26 ). The hybridization pattern is consistent across all generations with all the tested restriction enzyme and probe combinations . Taken together, the Southern blot analyses reveal that DAS - 8191 Ø
- 7 cotton contains a single intact insert of aad - 12 expression cassette and the pat expression cassette . 4.1.2. Absence of Plasmid Backbone Sequences To verify that no plasmid vector backbone sequences were inserted in DAS - 8191 Ø
- 7 cotton, four probes (Backbone 1, Backbone 2, Ori , and Spec R) covering the entire backbone region of pDAB4468 plasmid DNA were generated and hybridized to Msc I and Pst I digested DAS 8191 Ø
- 7 cotton DNA samples . When digested with Msc I and independently hybr idized with Backbone 1, Backbone 2, and Spec R probes, it would be anticipated that the positive control samples would have a band of ~5900 bp , while in t he absence of plasmid backbone, DAS - 8191 Ø
- 7 cotton samples and the negative control would be expected t o have no hybridization bands ( Figure 8 ). When digested with Msc I and hybridized with Backbone 1, Backbone 2, and Spec R probes, no specific hybridization bands were detected in any DAS - 8191 Ø
- 7 cotton samples, except for the positive controls . A single band of ~5900 bp was detected in the positive controlUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC sample, which was consistent with the predicted size of 5929 bp ( Figure 30 , Figure 32 and Figure 34 ). When blots containing the same digested genomic DNA and hybridized with Ori probe, two expected bands at ~5900 and ~6200 bp were detected only in the positive control sample and not in the DAS - 8191 Ø
- 7 cotton samples ( Figure 28 ) . This is consistent with the expected fragment sizes of 5929 and 6225 bp , since the Ori probe binds to DNA sequences on both sides of MscI digested pDAB4468 plasmid DNA ( Figure 6 ) . When digested with Pst I and hybridized with Backbone 1, Backbone 2, Ori , and Spec R probes, no specific hybridization bands were detected in any DAS - 8191 Ø
- 7 cotton samples, except for the positive controls . A single band of ~9300 bp was detected in positive control sample, consistent with the predicted size of 9286 bp ( Figure 6 , Figure 29 , Figure 31 , Figure 33 and Figure 35 ). These Southern analys i s data , along with the positive and negative control results confirm that no backbone sequences from pDAB4468 are incorporated into DAS - 8191Ø
- 7 cotton . 4.2. Stability of the Insert Across Generations All DAS - 8191Ø
- 7 cotton Southern hybridization samples, across all five generations (T2, T3, T4, T5, and BC1F2 see Figure 4 ) revealed an intact, single copy aad - 12 expression cassette , pat expression cassette and RB7 MAR insertion . These data clearly show stable integration and inheritance of the intact, single copy transgene insert across multiple generations of DAS - 8191Ø
- 7 cotton. 4.3. Southern Blot A nalysis C onclusions Southern blot analys i s confirms that DAS - 8191Ø
- 7 cotton contains a single copy of the transgene insert from pDA B4468 , gene expression cassettes aad - 12 and pat , and a RB7 - MAR element ( Section 4.1.1 ). No plasmid backbone sequences were detected in DAS 8191Ø
- 7 cotton (Section 4.1.2 ) . The hybridization patterns across five generations of DAS 8191 Ø
- 7 cotton (T2, T3, T4, T5, and BC1 F2) were identical, indicating that the insert is stably integrated and inherited in the DAS - 8191Ø
- 7 cotton genome (Section 4.2 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 9 . Southern A nalysis of DAS - 8191 Ø - 7 C otton D igested with Nco I ; aad - 12 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II a nd VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 03 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 03 6 DAS - 8191Ø
- 7 - T2 - 03 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 06 9 DAS - 8191Ø
- 7 - T3 - 03 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 10 . Southern A nalysis o f DAS - 8191 Ø - 7 C otton D igested with Sph I ; aad - 12 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marke r II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 42 of 214

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Figure 11 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Nco I ; pat Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marke r II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 03 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 03 6 DAS - 8191Ø
- 7 - T2 - 03 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 06 9 DAS - 8191Ø
- 7 - T3 - 03 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 43 of 214

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Figure 12 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Sph I ; pat Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marke r II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs. Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 44 of 214

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Figure 13 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Msc I ; AtUbi10 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marke r II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs. Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 45 of 214

Dow AgroSciences LLC

Figure 14 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Sph I ; AtUbi10 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DN A Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs.
Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 46 of 214

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Figure 15 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Nco I ; AtuORF23 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fra gment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs. ( Note: Differential migration of hybridization bands in lanes 1 0 and 12 are attribut able to minor impurities in DNA samples.) Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 03 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 03 6 DAS - 8191Ø
- 7 - T2 - 03 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 06 9 DAS - 8191Ø
- 7 - T3 - 03 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 16 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Sph I ; AtuORF23 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II a nd VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . ( Note: D ifferent ial migration of hybridization bands in lanes 10 and 12 are attribut able to minor impurities in DNA samples ) Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 06 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 17 . Southern A nalysis o f DAS - 8191Ø - 7 C otton Di gested with Nco I ; CsVMV Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual s ample IDs . ( Note: Differential migration of hybridization bands in lane 10 and 12 are attribut able to minor impurities in DNA samples.) Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 03 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 18 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Sph I ; CsVMV Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fra gment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs. Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 19 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Nco I ; AtuORF1 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 03 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 03 6 DAS - 8191Ø
- 7 - T2 - 03 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 06 9 DAS - 8191Ø
- 7 - T3 - 03 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 20 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Sph I ; AtuORF1 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted fr om non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs. Lane Sample Lane Sa mple 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 21 . Southern A n alysis o f DAS - 8191Ø - 7 C otton D igested with Pst I to R e lease aad - 12 E xpression cassette ; aad - 12 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II a nd VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 22 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Pst I to R e lease aad - 12 E xpression C assette ; AtUbi10 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of th e DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 23 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Pst I to R e lease aad - 12 E xpression C assette ; AtuORF23 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - tr ansgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 24 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Pst I/ Xho I to R e lease pat E xpression C assette ; pat Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indi cate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 25 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Pst I/ Xho I to R e lease pat E xpression C assette ; CsVMV Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II a nd VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 26 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Pst I/ Xho I to R e lease pat E xpression C assette ; AtuORF1 3′ UTR Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . (Note: Differential migration of hybridization bands in lanes 10 and 12 are attri but able to minor impurities in DNA samples.) Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 27 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Sph I ; RB7 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 28 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested w ith Msc I ; Ori Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecul ar Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 29 . Southern A nalysis of DAS - 8191Ø - 7 C otton D igested with Pst I; Ori Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 30 . Southern Analysis of DAS - 8191Ø - 7 C otton D igested with Msc I; Backbone2 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fra gment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 31 . Southern A nalysis of DAS - 8191Ø - 7 C otton D igested with Pst I; Backbone2 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic contro l Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 32 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Msc I ; Backbone1 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from no n - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 33 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Pst I ; Backbone1 Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 34 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Msc I ; Spec R Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marker II a nd VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 03 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 03 5 DAS - 8191Ø
- 7 - T2 - 03 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 05 7 DAS - 8191Ø
- 7 - T3 - 02 17 DAS - 8191Ø
- 7 - BC1F2 - 06 8 DAS - 8191Ø
- 7 - T3 - 03 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 35 . Southern A nalysis o f DAS - 8191Ø - 7 C otton D igested with Pst I ; Spec R Probe Approximately 10  g of genomic DNA was digested and loaded per lane . The positive control included plasmid pDAB4468 at approximately one copy of plasmid pDAB4468 per cotton genome in 10  g of genomic DNA extracted from non - transgenic control Coker 310 . Fragment sizes in bp of the DIG - labeled DNA Molecular Weight Marke r II and VII were indicated adjacent to membrane image . The last two digits in Sample Description indicate individual sample IDs . Lane Sample Lane Sample 1 DIG Molecular Weight Marker II 11 DAS - 8191Ø
- 7 - T4 - 02 2 Coker 310 + pDAB4468 12 DAS - 8191Ø
- 7 - T4 - 05 3 Coker 310 13 DAS - 8191Ø
- 7 - T5 - 01 4 DAS - 8191Ø
- 7 - T2 - 01 14 DAS - 8191Ø
- 7 - T5 - 02 5 DAS - 8191Ø
- 7 - T2 - 02 15 DAS - 8191Ø
- 7 - T5 - 04 6 DAS - 8191Ø
- 7 - T2 - 04 16 DAS - 8191Ø
- 7 - BC1F2 - 04 7 DAS - 8191Ø
- 7 - T3 - 01 17 DAS - 8191Ø
- 7 - BC1F2 - 05 8 DAS - 8191Ø
- 7 - T3 - 02 18 DAS - 8191Ø
- 7 - BC1F2 - 07 9 DAS - 8191Ø
- 7 - T3 - 04 19 DIG Molecular Weight Marker VII 10 DAS - 8191Ø
- 7 - T4 - 01USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 4.4. Segregation Analysis 4.4.1. Genetic and Molecular Analysis of a Segregating Generation DAS - 8191Ø
- 7 cotton transgene insert resides at a single locus within the cotton genome and is inherited according to Mendelian inheritance principles . Chi - square goodness of fit analyses of trait inheritance data within a segregating generation was conducted to confirm the Mendelian inherit ance of the transgene insert in DAS - 8191Ø
- 7 cotton . The inheritance pattern of the transgene insert within a segregating generation was demonstrated with Lateral Flow Strip (LFS) and event specific PCR analyses of individual plants within a BC 1 F 2 generat ion of DAS - 8191Ø
- 7 cotton ( Figure 4 ) . A total of 136 plants from the BC 1 F 2 generation of DAS - 8191Ø
- 7 cotton were tested for AAD - 12 protein expression by LFS assay . O f the 136 BC 1 F 2 plants tested, 104 plants were positive and 32 were negative (segregated nulls) for AAD - 12 protein expression . Genomic DNA was extracted from all these samples and followed by event - specific PCR analysis to determine the presence or absence of the DAS - 8191Ø
- 7 transgene insert . Similarly, of the 136 plants tested by event - specific PCR, 104 plants were positive for the presence of DAS 8191Ø
- 7 transgene insert and the remaining 32 plants were negative (segregated null) . All plants that tested positi ve for AAD - 12 protein expression by LFS were also positive for the DAS - 8191Ø
- 7 transgene insert by event - specific PCR analysis , and all plants that tested negative for AAD - 12 protein expression were also negative for the presence of the DAS 8191Ø
- 7 t ransgene insert by event - specific PCR ( Table 5 ) . This result confirm ed that the phenotypic segregation matched the genotypic makeup of the tested plants in the BC1 F 2 generation . Statistical analysis using a chi - square g oodness of fit test indicated that the ratio of 104 positive to 32 null segregants did not significantly differ from the expected Mendelian 3:1 segregation pattern for a single indepe ndent locus. Table 5 . Segregating Generation Results of BC 1 F 2 Individual Plants Tested Method Total plants

tested Positive Negative Expected ratio P - value 1 AAD - 12 LFS 136 104 32 3:1 0.6921 Event - Specific PCR 136 104 32 3:1 0.6921 1 Based on a chi - squared goodness of fit test 4.4.2. Segregation Analysis of Breeding Generations Chi - square goodness of fit analyse s o f trait inheritance data from a population of T 1 and BC 1 F 2 breeding generation s was also conducted to determine the Mendelian inheritance of the transgene insert in DAS - 8191Ø
- 7 cotton ( Figure 4 ) . The presence or absence of t he trans gene insert was determi ned using a PAT protein assay , a pat gene zygosity assay, or an aad - 12 gene zygosity assay for DAS - 8191 Ø
- 7 cotton . Gene zygosity assays were conducted using Ta q Man real time PCR with primers and probes specific to either pat or aad - 12 sequence to determine gene copy number of each assayed sample. DNA samples were extracted from 2571 BC 1 F 2 and 196 T 1 plants and assayed for aad - 12 and pat , respectively. Quantitative analysis of the PCR results revealed t he expected segregation ratio of 3:1 for plants containing the transgene insert versus plants that do not contain the transgene insert (segregated nulls) ( Table 6 ) . The observed segregation ratio does not significa ntly differ fromUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC the expected Mendelian 3:1 segregation pattern for a single independent locus. These results support the conclusion that DAS - 8191 Ø
- 7 transgene insert resides at a single locus within the cotton genome and is inherited according to Mendelia n principles . Table 6 . Segregating Breeding Generation Results of DAS - 8191 Ø - 7 C otton Plants Generation Total

Plants Tested Tested Method Positive Null Expected Ratio P - value 1 T1 191 PAT LFS 146 45 3:1 0.65 T1 196 pat gene zygosity 153 43 3:1 0.32 BC1F2 2571 aad - 12 gene zygosity 1916 655 3:1 0.58 1 Based on a chi - square goodness of fit test 4.5. Summary of the Genetic Characterization Molecular characterization of DAS - 8191 Ø
- 7 cotton by Southern blot analysis confirmed that a single transgene insert containing each of the intact expression cassette s for aad - 12 and pat , along with the RB7 MAR element at the 5  end , were integrated into DAS - 8191 Ø
- 7 cotton . No transformation plasmid back bone sequence was found in DAS - 8191 Ø
- 7 cotton as demonstrated by Southern blot analysis using probes covering the entire region of the plasmid flanking the T - DNA insert . Southern blot analysis of five generation s (T 2 , T 3 , T 4 , T 5 , and BC 1 F 2 ) demonstrated the inserted DNA wa s stably inherited through multiple generations . Moreover, the transgene insert displayed the expected Mendelian inheritance pattern for a single independent insert/locus in segregating generation s ( T 1 and BC 1 F 2 ) , confirmi ng that the transgene insert in DAS - 8191Ø
- 7 cotton occurs at a single chromosomal locus with expected inheritance patterns .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 69 of 214

Dow AgroSciences LLC 5. Characterization of the DAS - 8191Ø - 7 AAD - 12 and PAT Proteins As described in Section 3.4 , DAS - 8191Ø
- 7 cotton contains the aad - 12 and pat expression cassettes that, when transcribed and translated, result in the expression of the AAD - 12 and PAT prot eins, respectively . This section summarizes: 1) the identity and mode of action of the AAD - 12 and PAT proteins expressed in DAS - 8191Ø
- 7 cotton ; 2) demonstration of equivalence between the plant - produced and microbially - produced AAD - 12 and PAT proteins , whi ch were used in various protein safety studies ; 3) the expression levels of AAD 12 and PAT proteins in DAS - 8191Ø
- 7 plant tissue s ; 4) the assessment of the potential allergenicity and toxicity of AAD - 12 and PAT proteins; 5) the food and feed safety assessm ent of AAD - 12 and PAT proteins . Based on several lines of evidence described below, t he data support a conclusion that these two proteins produced in DAS - 8191Ø
- 7 cotton are safe for the environment and safe for human and animal consumption. These data were supplied to FDA for their evaluation in consultation BNF No. 000142 on the food and feed safety and compositional assessment of DAS - 8191Ø
- 7 cotton . 5.1. AAD - 12 5.1.1. Identity of the AAD - 12 Protein The expressed DAS - 8191Ø
- 7 cotton AAD - 12 protein is comprised of 293 amino acids and has a molecular weight of 32 kDa ( Figure 36 ). The wild - type aryloxyalkanoate dioxygenase (AAD - 12) p rotein coding sequence was derived from Delftia acidovorans , a gram - negative soil bacterium ( Wright et al. , 2010 ) . The wild - type AAD - 12 amino acid sequence and the DAS - 8191Ø
- 7 cotton AAD - 12 amino acid sequence (encoded by the plant - optimized aad - 1 gene (see section 3.4.1 )) are greater than 99% identical, differing only by a single amino acid addition , alanine (A), at position number two ( Figure 36 ) . The additional alanine codon encodes part of an Nco I restriction enzyme recognition site (CC ATG G) spanning the ATG translational start codon of aad - 12 . This additional codon serves the dual purpose of facilitating subsequent cl oning operations and improving the sequence context surrounding the ATG start codon to optimize translation initiation. The AAD - 12 protein produced in DAS - 8191Ø
- 7 cotton is expressed from the identical genetic aad - 12 sequence present in DAS - 68416 - 4 soybean and DAS - 444Ø6
- 6 soybean (c urrently under USDA - APHIS review , petition numbers 09 - 349 - 01p, 11 - 234 - 01p respectively) . 001 M A QTTLQITPTGATLGATVTGVHLATLDDAGFAALHAAWLQHALLIFPGQ 051 HLSNDQQITFAKRFGAIERIGGGDIVAISNVKADGTVRQHSPAEWDDMMK 101 VIVGNMAWHADSTYMPVMAQGAVFSAEVVPAVGGRTCFADMRAAYDALDE 151 ATRALVHQRSARHSLVYSQSKLGHVQQAGSAYIGYGMDTTATPLRPLVKV 201 HPETGRPSLLIGRHAHAIPGMDAAESERFLEGLVDWACQAPRVHAHQWAA 251 GDVVVWDNRCLLHRAEPWDFKLPRVMWHSRLAGRPETEGAALV Figure 36 . Amino A cid Sequence of E xpressed AAD - 12 in DAS - 8191Ø - 7 DAS - 819 1 Ø
- 7 cotton AAD - 12 amino acid sequence was designed to have a single amino acid addition, alanine, at position number two (underlined in figure above) as compared to the native D. acidovorans AAD - 12 amino acid sequence . See text for details .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 5.1.2. Mode of Action of the AAD - 12 Protein Expression of the AAD - 12 protein in transgenic crops has been shown to provide tolerance to the herbicide 2,4 - D by c atalyzing the conversion of 2,4 - D to 2,4 - dichlorophenol (DCP) , a herbicidally inactive compound , through an Fe(II)/α - keto acid - dependent dioxygenase reaction ( Figure 37 and Figure 38 ) ( Müller et al . , 1999 ; Westendorf et al. , 2002 ; Westendorf et al. , 2003 ; Wright et al. , 2009 ; Wright et al. , 2010 ) .

Figure 37 . Degradation R eaction of 2,4 - D C atalyzed by AAD - 12 5.1.2.1. DCP DCP (2,4 - dichlorophenol) is a known primary degradate of 2,4 - D in plants ( Roberts, 1998 ) . DCP has been observed as a degradate of 2,4 - D in environmental matrices and is also observed in animal metabolism studies ( Roberts, 1998 ; Barnekow et al. , 2001 ) . The U.S. EPA tolerance expression for 2,4 - D does not include DCP in the plant residue definition, but DCP was at one point included in the livestock meat and milk tolerance expression. In 2004 the U.S. EPA’s Health Effects Division, Metabolism Assessment Review Committee (MARC) recommended th at DCP be deleted from the livestock tolerance expression for 2,4 - D. The MARC committee stated DCP is “not of concern for either the tolerance expression or for risk assessment at the levels expected in livestock tissues and considering the likely lower to xicity of 2,4 - DCP compared to 2,4 - D” ( EPA, 2003 ) . This decision was included in the 2005 Registr ation Eligibility Decision document ( EPA, 2005 ) and posted in the 2007 Federal Register ( EPA, 2007 ) . This action harmonizes U.S. tolerances with Codex, Japanese and European residue defi nitions which do not include DCP in any tolerance expression. DAS will be submitting information to the U.S. EPA on the Nature of Residue and Magnitude of Residue resulting from the use of 2,4 - D on cotton that express es the AAD - 12 protein . The U.S. EPA w ill evaluate this information as a component of their review of the use of 2,4 - D on cotton that express es the AAD - 12 protein .

5.1.2.2. Enzyme Specificity AAD - 12 is able to degrade related achiral phenoxyacetate herbicides such as MCPA ((4 - chloro - 2 - methylphenoxy) acetic acid) and pyridyloxyacetate herbicides such as triclopyr and fluroxypyr to their corresponding inactive phenols and pyridinols, respectively ( Figure 38 ) . AAD - 1 2 has enantiomeric selectivity for the (S) - enantiomers of the chiral phenoxy acid herbicides ( e.g. , dichlorprop and mecoprop), but does not catalyze degradation of the (R) - enantiomers. It is the R - enantiomers in this class of chemistry that are herbicidall y active;USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC therefore AAD - 12 does not provide tolerance to commercially - available chiral phenoxy acid herbicides ( Wright et al. , 2010 ) .

Figure 38 . General R eaction C atalyzed by AAD - 12 (R=H or CH 3 ) The AAD - 12 enzyme was screened for the ability to utilize endogenous plant substrates using a sensitive coupled in vitro enzyme assay ( Luo et al. , 2006 ) . Potential plant substrates were determined based on chemical structure, similar physiological function to known AAD 12 substrates, and abundance within primary/secondary metabolic pathways of plants. The substrates tested were separated into three groups; natural plant hormones (ind ole acetic acid, abscisic acid, gibberellin, and aminocyclopropane - 1 - carboxylate), phenylpropanoid intermediates (cinnamate, coumarate, and sinapate), and L - amino acids. 2,4 - dichlorphenoxyacetic acid (2,4 - D), the positive control substrate, showed a high l evel of activity in the enzyme assay. Under the same reaction conditions, the plant compounds identified and tested were not oxidized upon incubation with AAD - 12, resulting in values at or below the background limit of detection (<3% positive control rate) . Based on this survey of potential substrates, there is no indication that AAD - 12 has activity on endogenous plant substrates ( Griffin et al. , 2013 ) . 5.1.3. Bioch emical Characterization of the AAD - 12 Protein Large quantities of purified AAD - 12 protein are required to perf orm safety assessment studies. Because it is technically infeasible to extract and purify sufficient amounts of recombinant protein fro m transgen ic plants ( Evans, 2004 ; Raybould et al. , 2012 ) , large quantities of AAD - 12 protein was produced in Pseudomonas fluorescens . Characterization studies were performed to confirm the equivalency of the AAD - 12 protein produced in P. fluorescens with the AAD - 12 protein produced in planta in DAS - 8191Ø
- 7 cotton. Sodium dodecyl sulfate polyacrylamide gel electrophoresis (SDS - PAGE), western blot, glycoprotein detection, enzymatic assay, and protein sequence analysis by matrix assisted laser desorption/ionization t ime - of - flight mass s pectrometry/ mass spectrometry (MALDI - TOF MS /MS ) were used to characterize the biochemical properties of the protein s . Using these methods, the AAD - 12 protein isolated from P. fluorescens and DAS - 8191Ø
- 7 cotton were shown to be biochemically and biologicall y equivalent, thereby supporting the use of the microbe - derived protein in safety assessment studies. The methods and results of the biochemical characterization of the DAS - 8191Ø
- 7 cotton and microbe - derived AAD - 12 proteins are described in detail in Appendix 2 . B oth the plant andUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 72 of 214

Dow AgroSciences LLC P. fluorescens - derived AAD - 12 proteins were observed at the expected molecular weight of 32 kDa by SDS - PAGE and were i mmunoreactive to AAD - 12 protein - specific antibo dies by western blot analysis. There was no evidence of glycosylation of either the DAS - 8191Ø
- 7 cotton or P. fluorescens - derived AAD - 12 proteins. Cotton - and P. fluorescens - derived AAD 12 were equally active u sing S - dichloroprop as a substrate and displayed similar kinetic parameters, indicating that the proteins are enzymatically equivalent. In addition, greater than 88% of the cotton - derived protein a mino acid sequence was confirmed by either enzymatic peptid e mass fingerprinting or MS/MS sequence analysis by MALDI - TOF MS /MS. The N terminal methionine was found to be cleaved from both protein sources and the N - terminal peptide of the plant - derived AAD - 12 was determined to be acetylated after the N - terminal met hionine was cleaved . These two post - translational processes, cleavage of the N - terminal methionine residue and N - terminal acetylation, are common modifications that have been found to occur on the vast majority (~85%) of eukaryotic proteins ( Polevoda and Sherman, 2003 ) . The C - terminal peptides from DAS - 8191Ø
- 7 cotton and P. fluorescens were intact and empirically determined to be identical. 5.1.4. Expression of the AAD - 12 Protein in Plant Tissues A field expression study was conducted in the U.S. during 20 12. Six sites (Alabama, Georgia, Louisiana, Missouri, North Carol ina, and Texas) were planted with DAS - 8191Ø
- 7 cotton and the non - transgenic control (98M - 2983) . The test sites represented regions of diverse agronomic practices and environmental conditions for cotton in North America. Two treatments of DAS - 8191Ø
- 7 cotton ( non - sprayed or sprayed with 2,4 - D and glufosinate) were tested and plant tissue was collected from l eaf, squares, bolls, pollen, flower, whole plan t, root, and seed ( Table 7 ) . Table 7 . DAS - 8191Ø - 7 Cotton AAD - 12 Expression Analysis Tissue Samples Expression Tissue Growth

Stage 1 Sample Size No. of Samples per

Entry/Site Bolls Peak Bloom 10 - 14 Bolls 4 Flower Peak Bloom 14 - 18 Flowers 4 Leaf 4 - Leaf 10 - 14 Leaves 4 Leaf 1 st White Bloom 10 - 14 Leaves 4 Leaf 1 st Open Boll 10 - 14 Leaves 4 Pollen Early Bloom 0.2 - 0.5 mL 4 Root Maturity 1 - 2 Plants 4 Seed Maturity 175 - 250 grams 4 Squares 1 st White Bloom 10 - 14 Squares 4 Whole Plant Maturity 1 - 2 Plants 4 1 Approximate growth stage AAD - 12 protein was extracted from DAS - 8191Ø
- 7 cotton tissue and t he soluble, extractable AAD - 1 2 protein from each tissue was measured using a draft enzyme - linked immunosorbent assay (ELISA) method . AA D - 12 protein levels for all tissue types were calcula ted on ng/mg dry weight basis. The details of the materials and methods are described in Appendix 4 .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 73 of 214

Dow AgroSciences LLC A summary of the AAD - 12 protein concentrations (averaged across sites) in the various cotton matrices is shown i n Table 8 . The mean AAD - 12 protein levels were highest in the leaf at 71.17 ng/mg followed by pollen at 70.71 ng/mg, squares at 38.33 ng/mg, flower at 30.63 ng/mg, seed at 18.75 ng/mg, bolls at 17.17 ng/mg, whole plant at 16.42 ng/mg, and root at 10.74 ng/mg. AAD - 12 e xpression levels were comparable for both sprayed and non sprayed treatments. No AAD - 12 protein was detected in the control tissues . Table 8 . Summary of AAD - 12 Protein Expression Expression Tissue Growth

Stage AAD - 12 ng/mg Tissue Dry Weight 1,2

Overall Mean Std. Dev. 3

(n = 48) Min/Max Range 4 Bolls Peak Bloom 17.17 7.91 4.36 - 33.39 Flower Peak Bloom 30.63 8.36 18.76 - 52.28 Leaf 4 - Leaf 71.17 46.63 7.78 - 180.72 Leaf 1 st white Bloom 17.53 8.6 1.45 - 40.56 Leaf 1 st Open Boll 51.26 19.63 17.38 - 89.23 Pollen Early Bloom 70.71 19.58 35.15 - 107.1 Root Maturity 10.74 5.27 ND e
- 22.89 Seed Maturity 18.75 4.81 6.75 - 27.77 Squares 1 st White Bloom 38.33 12.21 16.42 - 66.72 Whole Plant Maturity 16.42 12.18 ND 5

- 46.98 1 Calculated from AAD - 12 expression raw data. 2 Table represents overall results for non - sprayed and sprayed cotton tissue across all sites. 3 Standard deviation of individual cotton samples across all sites. 4 Represents the min and max for individual cotton samples across all sites. 5 ND = Not Detected, expression level below LOD (Limit of Detection). A zero value was used for ND results for mean calculation . 5.1.5. Food and Feed Safety Assessment of AAD - 12 The primary food source from cotton is r efined cottonseed oil, which contains undetectable amounts of protein ( Re eves III and Weihrauch, 1979 ) . T herefore, assessing the allergenicity and toxicity to humans of the expressed proteins in cotton is less relevant compared with other crops such as soybean, since little to no protein is present in consumed cotton product s. Regardless, a detailed safety assessment of AAD - 12 was conducted to assess any potential adverse effects to humans or animals resulting from the environmental release of crops containing AAD - 12 ( Codex Alimentarius Commission, 2009 ) . The food and feed safety assessment of AAD - 12 expressed in DAS - 8191Ø
- 7 cotton considers several factors including safety of the donor organism, history of safe use, allergenic potential, toxicity potential and dietary ris k assessment based on consumption patterns . The conclusion from the assessment is that AAD - 12 is unlikely to cause allergic reaction in humans or be a toxin to humans or animals. 5.1.5.1. Safety of Donor Organism and history of safe use The donor organism, Delft ia acidovorans (formerly designated as Pseudomonas acidovorans and Comamonas acidovorans) is a non glucose - fermenting, gram - negative, non spore forming rod , bacterium present in soil, fresh water, activated sludge, and clinical specimens ( Von Graevenitz, 1985 ; Tamaoka et al. , 1987 ; Wen et al. , 1999 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Strains of Delftia acidovorans can be used to transform ferulic acid into vanillin and related flavor metabolites ( Toms and Wood, 1970 ; Labuda et al. , 1992 ; Rao and Ravishankar, 2000 ; Shetty et al. , 2006 ) .

5.1.5.2. Assessment of Allergenicity Potential Studies were conducted to ascertain the potential allergenicity of AAD - 12 and conclusions were as follows: 1) DAS - 8191Ø
- 7 cotton AAD - 12 originates from Delftia acidovoran s , an organism that has not been reported as a source of allergens ( 5.1.5.1 ) . 2) Bioinformatics ana lyses demonstrated that DAS - 8191Ø
- 7 cotton AAD - 12 does not share amino acid sequence similarities with known allergens and is highly u nlikely to contain immunologically cross - reactive allergenic epitopes. 3) In vitro digestive fate experiments conducted with AAD - 12 demonstrate that the protein is rapidly digested in simulated gastric fluid (SGF). 4) AAD - 12 is heat labile, in which enzyme activity is rapidly eliminated at temperatures as low as 50 °C in less than thirty minutes . Due to the harsh processing conditions of cottonseed oil and the lack of detectable proteins in processed cottonseed oil, AAD 12 is most likely absent in the oil an d linters used in food products. Taken together, these data conclude that DAS - 8191Ø
- 7 cotton AAD - 12 does not pose a significant allergenic risk. Amino Acid Sequence Comparison to Known Allergens The step - wise, weight - of

- evidence approach ( Codex Alimentarius Commission, 2009 ) was used to assess the allergenic potential of the AAD - 12 protein. The AAD - 12 protein does not share meaningful amino acid sequence similarities with known allergens. No signific ant sequence homology was identified when the AAD - 12 protein sequence was compared with known allergens in the FARRP (Food Allergy Research and Resource Program) version 13 .00 allergen data base (Released in February, 2013 ), using the search criteria of eit her a match of eight or more contiguous identical amino acids, or >35% identity over 80 or longer amino acid residues . Lability in Simulated Gastric Fluid The digestibility of the P. fluorescens - derived AAD - 12 protein was tested in vitro using simulated g astric fluid (SGF) . The AAD - 12 protein was incubated in SGF (0.32% w/v pepsin at pH 1.2; ( The United States Pharmacopeia, 1995 ) for various periods of time. The samples were then ana lyzed via SD S - PAGE and western blot analysis using a polyclonal antibody specific to AAD - 12 . The results demonstrated the AAD - 12 pr otein was readily digested in less than thirty seconds in SGF , indicating that the proteins are unlikely to elicit allergenic reactions when consumed .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Heat Lability The thermal stability of the P. fluorescens - derived AAD - 12 protein was evaluated by heating protein solutions for 30 min at 50, 70 and 95 °C ; and 20 min in an autoclave (120 °C at ~117 kPa (~17 PSI)) in a phosphate - based buffer. The AAD - 12 protein activity was measured by a modified enzyme assay based on the procedure described in Fukumori and Hausinger ( Fukumori and Hausinger, 1993 ) . In the presence of Fe(II), the AAD - 12 protein catalyzes the conversion of dichlorphenoxyacetate to 2,4 - dichlorophenol and glyoxylate concomitant with the decomposition of α - ketoglutarate to form succinate and carbon dioxide. The result ing phenol is measured with an AAPPC assay or the Emerson reaction ( Emerson, 1943 ) . All heating conditions eliminated the enzymatic activity of the AA D - 12 prote in .

5.1.5.3. Assessment of Toxicity Potentia l Amino Acid Sequence Comparison to Known Toxins The AAD - 12 protein does not share meaningful amino acid sequence similarities with known toxins. Sequence homologies between the AAD - 12 protein and known protein toxins were evaluated using BLASTp search algorithm against the GenBank non - redundant protein sequenc es (up date d February 18, 2012). By their annotations, the proteins returned by BLASTp search can be grouped in to the following 10 categories: 2,4 - D/alpha - ketoglutarate dioxygenase, putative alkylsulfatase, alpha - ketoglutarate (dependent) dioxygenase, alpha ketoglutarate - dependent sulfonate dioxygenase, taurine catabolism dioxygenase, taurine dioxygenase, dioxygena se, oxidoreductase, pyoverdine biosynthesis protein, and hypothetical (putative) or unnamed proteins. AAD - 12 (aryloxyalkanoate dioxygenase - 12) itself is an alpha - ketoglutarate dependent dioxygenase. Hypothetical and unnamed proteins are derived from concep tual translation of DNA sequences generated from massive genome sequencing projects of various fungi and bacteria. Those proteins have functional annotations such as “probable taurine catabolism dioxygenase”, “ clavaminic acid synthetase - like”, and “putativ e alpha - ketoglutarate dependent dioxygenase”. None of those proteins are associated with protein toxins that are harmful to humans or animals . Acute Oral Toxicity An acute oral toxicity study with the P. fluorescens - derived AAD - 12 protein was conducted in mice administered 2000 mg AAD - 12/kg body weight after adjustment for purity (5666 mg/kg of test substance at 35.3% purity). The study was conducted following OECD guideline 423 and used a total of 10 mice (5 male and 5 female) ( OECD, 2001 ) . There were no treatment - related gross pathological observations. Therefore, the acute oral LD 50 and no observed effect level (NOEL) of AAD - 12 in mice was greater than 2000 mg/kg based on fact that no mortality was observed and there were no observable effects (adverse or non - adverse effects) with the AAD - 12 - treated animals. AAD - 12 pro tein displays very low acute toxicity potential. 5.1.5.4. Human Dietary Risk Assessment for AAD - 12 For the human diet, only the cottonseed of cotton plants is useful for food. Cottonseed is not directly consumed by humans because the majority of commerc ial cotton varieties contain the anti - nutrients gossypol and cyclopropenoid fatty acids. For the human diet, cottonseed is used in food applications in which the seeds are mainly used to obtain refined edible oil ,USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC which contains undetectable amounts of pro tein ( Reeves III and Weihrauch, 1979 ; OECD, 2009 ) ; therefore, oil produced from DAS - 8191Ø
- 7 will contain extremely low levels to no detectable levels of AAD - 12 protein . This assessment assumes that 100% of consumed cotton products are derived from DAS - 8191Ø
- 7 cottonseed. This is a highly conservative estimate for exposure to the AAD 12 protein from DAS - 8191Ø
- 7 cotton. The actual dietary exposure of the protein from DAS - 81 91Ø
- 7 cotton will be lower because: 1) there may be protein degradation during transport and storage ; 2) cottonseed containing AAD - 12 will be mixed with non - AAD - 12 cottonseed; 3) human consumption of cotton products is primarily in food forms which are coo ked and heat is known to denature th e AAD - 12 protein and 4) the majority of consumer dietary exposure to cotton is via edible cottonseed oil, which according to USDA National Nutrient Database for Standard Reference, Release 25 ( USDA ARS, 2012 ) does not contain any protein . Therefore, no human dietary exposure to the AAD - 12 protein is expected from consumption of oils derived from DAS - 8191Ø
- 7 cotton based on USDA Nutrient Database. Potential dietary risk to humans and livestock from the consumption of AAD - 12 protein in food and feed derived from DAS - 8191Ø
- 7 cotton was evaluated by determining margins of exposure (MOE). MOE is the ratio of the No Ob servable Effect Level (NOEL) of AAD - 12 determined by a mouse acute oral toxicity study (2000 mg/kg body weight) to estimated dietary intake of AAD 12. To evaluate dietary risk for human food consumption, MOEs were determined for the U.S. population based o n mean protein expression levels in cottonseed . For a U.S. assessment, the MOE values were calculated using the DEEM dietary exposure model program, DEEM FCID version 3.15 ( EPA, 2013 ) . The only cotton commodity included in the dietary model in DEEM is cottonseed oil. There is no protein in cottonseed oil; therefore, estimated exposure to AAD - 12 based on this model is 0 mg/kg bw/day. The U.S. assessment is incongruent with an assessment performed based on the WHO maximum global consumption data for acute exposures, which indicated that the U.S. was the top global consumer for both cottonseed and cottonseed oil. The 97.5 t h percentile exposure estimates from WHO for cottonseed were 0.05 g/kg bw/day, indicating very low consumption levels. When the WHO “SO 691 Cottonseed” acute consumption information is coupled to the protein average field expression level for cottonseed ( Table 8 ) , t he dietary risk assessments revealed that the calculated MOE values for the AAD - 12 protein in cottonseed for both adults and infants are very large with bot h great than 2 , 000 ,000. For chemicals, MOE s greater than 100 are typically considered acceptable. Based on the available safety threshold information , all MOEs for AAD - 12 protein indicate negligible concern for adverse effects from DAS - 8191Ø
- 7 cotton . Acco rdingly, there is negligible risk to human health when DAS - 8191Ø
- 7 AAD - 12 is present in the human diet.

5.1.5.5. Livestock Dietary Risk Assessment for AAD - 12 Expression levels of the AAD - 12 protein in DAS - 8191Ø
- 7 cotton were used with conservative (i.e. protective) livestock dietary assumptions for cotton commodities to estimate livestock dietary exposure. In addition, the relevance of the exposure estimate is placed into context based on the known mammalian toxicity inf ormation. A dietary exposure assessment reveals large margin of exposure (MOE) values for the AAD - 12 protein inUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC DAS - 8191Ø
- 7 cotton , indicating negligible concern for adverse effects from acute dietary exposure . AAD - 12 Livestock Dietary Risk Assessment Ana lysis The cotton commodity forms that are considered potential animal feeds are derived primarily from the cottonseed, which can be fed whole or processed into meal and hulls; cotton gin byproduct s are also sometimes used as a supplemental cattle feed. Cot ton gin byproducts (also called cotton gin trash) consist of the plant residues remaining from ginning cotton and can contain several parts of the cotton plant including stems, leaves, seed, burr, and lint . Gin byproducts are not a high value feed commodit y and so are not processed for removal of the anti - nutrient, gossypol; as such, they are only a relevant feed commodity for ruminants. This assessment has assumed that 100% of cotton consumed is derived from DAS - 8191Ø
- 7 cotton . Actual dietary exposure to AAD - 12 protein will be lower because: 1) co tton is a blended commodity; cotton - derived food and feed will contain cotton from a mixture of sources, 2) d egradation of the protein will occur during transport and storage , and 3) h eat applied during preparation of cotton derived foods and feeds may lessen exposure to AAD 12, as AAD - 12 is functionally unstable when heated (Section 5.1.5.2 ) . A U.S. livestock assessment was conducted based on the Maximum Reasonably Balanced Diet (MRBD) animal burden procedures ( EPA, 2008 ) . This U.S. assessment includes several cotton commodity forms as potential animal feeds: seed, meal, hulls and gin byproduct s . The U.S. MRBD guidance is used to construct a maximum cotton feed contribution for swine, poultry and cattle. No guidance on sheep diets is offered in the MRBD guidance, so all possible commodities were included as a conservative approach . Th e highest estimated exposed U.S. animal is the sheep with 0.27 mg AAD - 12/kg - bw . Lower estimates for beef cattle, dairy cattle, swine and poultry were < 0.23 mg AAD - 12/kg - bw . When these values are compared to the acute mammalian NOAEL of >2000 mg/kg - bw (see section 5.1.5.3 ) , there is a high margin of safety for livestock because the MOEs are large (>7200). This dietary exposure assessment for AAD - 12 in DAS - 8191Ø
- 7 cot ton supports the conclusion that there is negligible risk to animal health when AAD - 12 is present in their diets . 5.1.6. Summary of AAD - 12 Protein Characterization Detailed biochemical characterization of the AAD - 12 protein derived from DAS - 8191Ø
- 7 cotton was conducted . SDS - PAGE , western blot, glycoprotein detection, enzymatic assay, and protein sequence analysis by MALDI - TOF MS /MS were used to characterize the biochemical properties of the protein s . Using these methods, the AAD - 12 protein isolated from P. fluo rescens and DAS - 8191Ø
- 7 cotton were shown to be biochemically and biologically equivalent. A step - wise, weight - of

- evidence approach was used to assess the potential for toxic or allergenic effects from the AAD - 12 protein. Bioinformatic analyses revealed n o meaningful homologies to known or putative allergens or toxins for the AAD - 12 amino acid sequence. AAD - 12 protein is rapidly degraded in simulated gastric fluid and is readily denatured byUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC heat. There is no evidence of acute toxicity of the AAD - 12 protei n in mice at a dose of 2000 mg/kg body weight of AAD - 12. T he se results indicate that AAD - 12 is unlikely to cause allergenic or adverse effects in humans or animals. AAD - 12 protein expression analysis was conducted using DAS - 8191Ø
- 7 cotton tissue samples c ollected over the growing season. T he low level expression of the AAD - 12 protein in the various assayed tissue samples in DAS - 8191Ø
- 7 cotton presents a low exposure risk to humans and animals . T he overall safety assessment of the AAD - 12 protein supports th e conclusion that DAS - 8191Ø
- 7 cotton is as safe as non - transgenic cotton currently on the market and unlikely to cause allergenic or toxic effects to humans or animals . 5.2. PAT 5.2.1. Identity of the PAT Protein The expressed DAS - 8191Ø
- 7 cotton PAT protein is comprised of 18 3 amino acids and has a molecular weight of ~ 2 0 kDa ( Figure 39 ). The PAT protein was derived from Streptomyces viridochromogenes , a gram - pos itive soil bacterium ( Strauch et al. , 1988 ; OECD, 1999 ) . The pat transgene in DAS - 8191Ø
- 7 encodes a protein sequence that is identical to the native S . viridochromogenes PAT protein ( UniProt Accession N umber : Q57146 ) and is identical to that produced in DAS - 68416 - 4 soybean and DAS - 444Ø6
- 6 soybean (c urrently under USDA APHIS review , petition numbers 09 - 349 - 01p, 11 - 234 - 01p respectively). 001 MSPERRPVEIRPATAADMAAVCDIVNHYIETSTVNFRTEPQTPQEWIDDL 051 ERLQDRYPWLVAEVEGVVAGIAYAGPWKARNAYDWTVESTVYVSHRHQRL 101 GLGSTLYTHLLKSMEAQGFKSVVAVIGLPNDPSVRLHEALGYTARGTLRA 151 AGYKHGGWHDVGFWQRDFELPAPPRPVRPVTQI Figure 39 . Amino A cid S equence of PAT 5.2.2. Mode of Action of the PAT Protein The L - isomer of phosphinothricin (PPT) is a potent inhibitor of glutamine synthetase (GS) in plants and is used as a non - selective herbicide ( OECD, 1999 ) . Inhibition of GS by PPT causes rapid accumulation of intracellular ammonia which leads to cessation of photorespiration and results in the death of the plant cell ( Duan et al. , 2009 ) . PAT acetylate s the free NH 2 (amine) group of PPT ( in the presence of acetyl coenzyme A) . The acetylated NH 2 does not bind GS , thus prevent ing autotoxicity ( Figure 40 , ( Duke, 1996 ) ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 40 . Mode of A ction of the PAT P rotein 5.2.3. Biochemical Characterization of the PAT Protein Large quantities of purified PAT p rotein are required to perf orm safety assessment studies. Because it is technically infeasible to extract and purify sufficient amounts of recombinant protein fro m transgenic plants ( Evans, 2004 ; Raybould et al. , 2012 ) , the PAT protein was hete rologously - expressed in Pseudomonas fluorescens . Characterization studies were performed to confirm the equivalency of the PAT protein produced in P. fluorescens with the PAT protein produced in planta in DAS - 8191Ø
- 7 cotton. Sodium dodecyl sulfate polyacry lamide gel electrophoresis (SDS - PAGE), western blot, glycoprotein detection, enzymatic assay, and protein sequence analysis by matrix assisted laser desorption / ionization t ime - of

- flight mass spectrometry/ mass spectrometry (MALDI - TOF MS /MS ) were used to c haracterize the biochemical properties of the protein s . Using these methods, the PAT protein isolated from P. fluorescens and DAS - 8191Ø
- 7 cotton were shown to be biochemically and biologically equivalent, thereby supporting the use of the microbe - derived protein in safety assessment studies. The methods and results of the biochemical characterization of the DAS - 8191Ø
- 7 cotton and microbe - derived PAT proteins are described in detail in Appendix 3 . B oth the DAS 8191Ø
- 7 cotton and P. fluorescens - derived PAT proteins were observed at the expected molecular weight of ~ 20 kDa by SDS - PAGE and were i mmunoreactive to PAT protein specific antibo dies by western blot analysis. T here was no evidence of glycosylation of either the DAS - 8191Ø
- 7 cott on or P. fluorescens - derived PAT proteins. Cotton and P. fluorescens derived PAT were equally active using glufosinate as a substrate and displayed similar kinetic parameters, indicating that the proteins are enzymatically equivalent. In addition, greater than 90% of the cotton - derived protein a mino acid sequence was confirmed by enzymatic peptide mass fingerprinting and MS/MS sequence analysis by MALDI - TOF MS /MS. The N - terminal methionine was found to be cleaved from both protein sources which is a common modification that has been found to o ccur on many proteins ( Li and Chang, 1995 ) . The C - terminal peptides from DAS - 8191Ø
- 7 cotton and P. fluorescens were intact and empirically determined to be i dentical. 5.2.4. Expression of the PAT Protein in Plant Tissue s A field expression study was conducted in the U.S. during 20 12. Six sites (Alabama, Georgia, Louisiana, Missouri, North Carolina, and Texas) were planted with DAS - 8191Ø
- 7 cotton and the non - transgenic control. The test sites represented regions of diverse agronomic practices and environmental conditions for cotton in North America. Two treatments of theUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC DAS - 8191Ø
- 7 cotton ( non - s prayed or sprayed with 2,4 - D and glufosinate) were tested with PAT protein levels being determined in nine tissue types including l eaf, squares, bolls, pollen, flower, whole plan t, root, and seed ( Table 9 ) . Table 9 . DAS - 8191Ø - 7 Cotton PAT Expression Analysis Tissue Samples

Expression Tissue Growth Stage 1 Sample Size No. of Samples per

Entry/Site Bolls Peak Bloom 10 - 14 Bolls 4 Flower Peak Bloom 14 - 18 Flowers 4 Leaf 4 - Leaf 10 - 14 Leaves 4 Leaf 1 st White Bloom 10 - 14 Leaves 4 Leaf 1 st Open Boll 10 - 14 Leaves 4 Pollen Early Bloom 0.2 - 0.5 mL 4 Root Maturity 1 - 2 Plants 4 Seed Maturity 175 - 250 grams 4 Squares 1 st White Bloom 10 - 14 Squares 4 Whole Plant Maturity 1 - 2 Plants 4 1 Approximate growth stage PAT protein was extracted from DAS - 8191Ø
- 7 cotton tissue and t he soluble, extractable PAT protein was measured using an enzyme - linked immunosorbent assay (ELISA) method . PAT protein levels for all tissue types were calcula ted on ng/mg dry weight bas is. The details of the materials and methods are described in Appendix 4 . Table 10 . Summary of PAT Protein Expression in DAS - 8191Ø - 7 Cotton Expression Tissue Growth

Stage PAT ng/mg Tissue Dry Weight 1,2

Overall Mean Std. Dev 3

(n = 48) Min/Max Range 4 Bolls Peak Bloom 3.16 1.11 1.62 - 6.27 Flower Peak Bloom 5.3 1.09 2.92 - 8.20 Leaf 4 - Leaf 13.29 4.76 1.11 - 20.06 Leaf 1 st W hite Bloom 8.18 2.57 1.64 - 14.34 Leaf 1 st Open Boll 9.14 3.92 4.11 - 18.56 Pollen Early Bloom 0.11 0.22 ND e
- 0.99 Root Maturity 1.63 0.7 ND e
- 3.11 Seed Maturity 3.85 0.79 2.37 - 5.71 Squares 1 st White Bloom 7.91 2.39 4.38 - 14.48 Whole Plant Maturity 0.97 1.02 ND 5

- 3.97 1 Calculated from PAT expression raw data. 2 Table represents overall results for non - sprayed and sprayed cotton tissue across all sites. 3 Standard deviation of individual cotton samples across all sites. 4 Represents the min and max for individual cotton samples across all sites. 5 ND = N ot Detected, expression level below LOD (Limit of Detection). A zero value was used for ND results for mean calculation. A summary of the PAT protein concentrations (averaged across sites) in the various cotton matrices is shown i n Table 10 . The mean PAT protein levels were highest in the leaf at 13.29 ng/mg, followed by squares at 7.91 ng/mg, flower at 5.30 ng/mg, seed at 3.85 ng/mg, bolls atUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 3.16 ng/mg, root at 1.6 7 ng/mg, whole plant at 0.97 ng/mg and pollen at 0.11 ng/mg . PAT e xpression levels were comparable for both sprayed and non - sprayed treatments. No PAT protein was detected in the control tissue above the limit of quantitation (0.06 ng/mg) with the exceptio n of a single seed sample . This was most likely attributed to sampling error and/or contamination. 5.2.5. Food and Feed Safety Assessment of PAT Safety evaluation of the PAT protein was conducted to assess any potential adverse effects to humans or animals resulting from the environmental release of crops containing the PAT protein ( Codex Alimenta rius Commission, 2009 ) . The conclusion from the assessment is that the PAT protein is unlikely to cause allergic reactions in humans or to be toxic to humans or animals. The safety of phosphinothricin acetyltransferase (PAT) in biotech crops has been e xtensively studied and environmental release of biotech crops containing PAT have been issued by regulatory agencies in eleven different countries involving over thirty eight events in eight plant species including cotton, maize and soybean, among other cr ops ( CERA - ILSI Research Foundation, 2011 ) . Numerous transgenic crops expressing PAT have been reviewed by USDA and FDA with no concerns identified ( USDA, 1996 ; FDA, 1998 , 2001 ; USDA, 2001 ; FDA, 2004a , 2004b , 2004c ; USDA, 2004 , 2005 ) Amino Acid Sequence Comp arison to Known Allergens The PAT protein has no biologically meaningful sequence similarities to known allergens using a sequence evaluation program based on that formulated by the joint FAO/WHO Expert Consultation (2001 ) and by the Codex Alimentarius ( Codex Alimentarius Commission, 2001 ) . This search looks for a match of at least eight contiguous amino acids or greater than 35% identity over 80 or longer amino - acid stretches using an allergen database ( FARRP, 2013 ) and no such matches were found . Amino Acid Sequence C omparison to Known Toxins T he PAT protein does not share any amino acid sequence similarities with known protein toxins that would present any safety concerns. Amino acid sequence similarities with known proteins were evaluated using BLASTp search algorithm against the GenBank non - redundant protein sequences ( updated February 23, 2012). By their annotations, the majority proteins returned by BLASTp with statistically signif icant alignments are phosphinothricin acetyltransferase, other acetyltransferases, and hypothetical proteins without assigned function. Furthermore, most of the non - significant alignments are related with phosphinothricin N

- acetyltransferase or GCN5 relate d N - acetyltransf

erase. None of these proteins are associated with known protein toxins that ar e harmful to humans or animals . Lability in Simulated Gastric Fluid and Heat Lability The PAT protein is rapidly degraded in simulated gastric fluid ( EPA, 1997 ; OECD, 1999 ; Herouet et al. , 2005 ) and is readily denatured by heat ( EPA, 1997 ; OECD, 1999 ) . Numerous glufosinat e tolerant products including those in canola, soybean, corn and cotton have been reviewed by USDA with no concerns identified .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC There is no evidence available indicating that the PAT protein is toxic to either humans or animals. In acute toxicity studies mice gavaged with high levels of PAT protein showed no treatment - related significant toxic effects ( EPA, 1997 ; OECD, 1999 ) . The U.S. EPA has concluded, after reviewing data on the acute toxicity and digestibility of the PAT protein, that there is a reasonable certainty that no harm will result from aggregate exposure to the U.S. population, including infants and child ren, to the PAT protein and the genetic material necessary for its introduction ( EPA, 1997 ) . U.S. EPA has consequently established an exemption from tolerance requirements pursuant to FFDCA section 408(j)(3) for PAT and the ge netic material necessary for its production in all plants , which would include DAS 8191 Ø
- 7 cotton (40 CFR §174.522) . 5.2.6. Summary of PAT Protein Characterization Detailed biochemical characterization of the PAT protein derived from DAS - 8191Ø
- 7 cotton was conducted . SDS - PAGE , western blot, glycoprotein detection, enzymatic assay, and protein sequence analysis by MALDI - TOF MS /MS were used to characterize the biochemical properties of the protein s . Using these methods, the PAT protein isolated from P. fluores cens and DAS - 8191Ø
- 7 cotton were shown to be biochemically and biologically equivalent with no glycosylation. A step - wise, weight - of

- evidence approach was used to assess the potential for toxic or allergenic effects from the PAT protein. Bioinformatic analyses revealed no meaningful homologies to known or putative allergens or toxins for the PAT amino acid sequence. PAT protein is rapidly degraded in simulated gastric fluid and is readily denatured by heat. There is no evidence of acute to xicity of the PAT protein in mice . PAT protein expression analysis was conducted using DAS - 8191Ø
- 7 cotton tissue samples collected over the growing season. T he low level expression of the PAT protein in the various assayed tissue samples in DAS - 8191Ø
- 7 c otton presents a low exposure risk to humans and animals, and the results of the overall safety assessment of the PAT protein indicate that it is unlikely to cause allergenic or adverse effects in humans or animals. T he overall safety assessment of PAT supports the conclusion that food and feed products containing DAS - 8191Ø
- 7 cotton or derived from DAS - 8191Ø
- 7 cotton are as safe as non transgenic cotton currently on the market for human and animal consumption.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 83 of 214

Dow AgroSciences LLC 6. Composition Assessment of DAS - 8 191 Ø - 7 Cotton 6.1. DAS - 8191 Ø - 7 Cottonseed Composition Composition assessment of DAS - 8191Ø
- 7 cotton was conducted to examine key nutrient and anti - nutrient levels . In one experiment, non - sprayed DAS - 8191Ø
- 7 cottonseed were compared with the appropriate non - tra nsgenic near isogenic isoline (control) ( Figure 4 ) and non - transgenic reference lines . In another experiment, non - sprayed DAS - 8191Ø
- 7 cottonseed were compared with herbicide - treated DAS - 8191Ø
- 7 cottonseed and non - sprayed DAS 8191Ø
- 7 cottonseed . The assessment was conducted using the principles and analytes in the OECD consensus document for cotton composition ( OECD, 2009 ) . S amples were analyzed for proximates, fiber, minerals, amino acids, fatty acids, vitamins, and anti - nutrients. Levels of the analytes in DAS - 8191 Ø
- 7 cottonseed were compared with : 1) corresponding levels in cottonseed from a non - transgenic, near isogenic control ( Figure 4 ) , grown concurrently, unde r the same fi eld conditions; 2) natural ranges generated from an evaluation of six commercial non transgenic cotton reference lines (ALL - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271, and Speed) grown concurrently, under the same field conditions ; and 3) data published in the scientific literature for non - transgenic cotton. Comparison with data published in the literature places any potential differences between the assessed crop and its comparators in the context of the documented variations in th e concentrations of crop nutrients and anti - nutrients . Of the 73 cotton analytes assayed, 59 analytes had sufficient quantitative data for inclusion in the combined site statistical analysis . Although a limited number of statistically significant differences occurred between DAS - 8191Ø
- 7 cotton and the control , the se differen ces were not biologically relevant because the results were within ranges found for non - transgenic cotton reference lines included i n this study and/or within available literature ranges for non transgenic cotton . Based on these results, it is concluded that DAS - 8191Ø
- 7 cotton is compositionally equivalent to non - transgenic cotton. 6.1.1. Field Study Design Field trials were conducted at eig ht U.S. sites ( one site each in Tallassee, Alabama; Sycamore, Georgia ; Washington, Louisiana ; Stoneville, Mississippi; Fisk, Missouri ; Mebane, North Carolina ; Groom, Texas ; and East Bernard, Texas ) in 2012 to produce cottonseed samples of DAS - 8191Ø
- 7 cotto n ( non - sprayed and sprayed with 2,4 - D plus glufosinate), near isogenic non - transgen ic isoline (control) and non - transgenic cotton varieties, referred to as reference line s, for nutrient composition analysis . For the reference lines, six unique reference lines were included across all sites of the field production with three varieties per site to provide data on natural variability of each composition analyte analyzed. Because non - transgenic cotton plants ( e.g. isoline and reference lines) are sensitive to 2,4 - D, two sub - experiments were conducted at each site to spatially separate the non - transgenic entries from the entries where 2,4 - D was applied . Sub - experiment one was not sprayed and contained t he isoline , reference varieties and one entry of DAS - 8191Ø
- 7 cotton . Sub experiment two contained two entries of only DAS - 8191Ø
- 7 cotton; one not sprayed and one sprayed with 2,4 - D plus glufosinate .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 84 of 214

Dow AgroSciences LLC The entries were arranged in a randomized complete bloc k de sign within each sub experiment. The sub - experiments were separated by 100 ft (30 m) to prevent isoline and reference entries in sub - experiment one from potential injury by 2,4 - D drift from applications in sub - experiment two . Both sub - experiment one an d two were present at all field testing sites . Randomization of entries within blocks was unique at each field testing site . Test, isoline , and reference variety cotton was planted at a seeding rate of approximately 100 seeds per 25 ft (7.62 m) of row (one seed per 3 in or 7.6 cm) . Four replicate plots of each entry were established at each site for each sub - experiment , with each plot consisting of four rows that were 25 ft (7.62 m) long with a row spacing of approximately 30 in (76 cm) . E ach four row plot was bordered b y two rows of a non - transgenic cotton cultivar. Herbicides were applied in a spray volume of approximately 20 gallons per acre (187 L/ha), and all h erbicide applications included 2% v/v ammonium sulfate . In sub - experiment two, 2,4 - D (GF - 2654) and glufosinate (Ignite 280 SL) were applied in a tank mixture as two broadcast applications to one entry of DAS - 8191Ø
- 7 cotton . Application timings were at the 3 node and 6 node growth stages . The target application rates for both applica tion timings were 1120 g ae/ha 2,4 - D and 596 g ai/ha glufosinate . Actual application rates ranged from 1108

– 1142 g ae/ha 2,4 - D and 589

– 622 g ai/ha glufosinate for the 3 node application and 1061

– 1141 g ae/ha 2,4 - D and 564

– 621 g ai/ha glufosinate for the 6 node application . 6.1.2. Compositional Analysis Samples of acid delinted cottonseed were analyzed at Covance Laboratories Inc. for 73 cotton analytes ( Table 11 ) . Methods for compositional analysis are described in A ppendix 5 . Data from the composition analysis was statistically analyzed for ea ch sub - experiment comparing 1) non - sprayed DAS - 8191Ø
- 7 cotton in sub - experiment one to the appropriate non - sprayed non - transgenic near isogenic isoline and non - transgenic reference lines in sub experiment one and 2) non - sprayed DAS - 8191Ø
- 7 cotton in sub - experiment one to the non sprayed DAS - 8191Ø
- 7 cotton and to herbicide - treated DAS - 8191Ø
- 7 cotton in sub experiment two . The results were then placed into context with reported scientific literature values . 6.2. Statistical Analysis Analysis of variance was conduct ed for each sub - experiment separately across field testing sites for composition data using a mixed model ( SAS Institute Inc., 2009 ) . E ntry was conside red a fixed effect; location, block within location, and locatio n - by - entry were designated as random eff ec ts . Paired contrasts were conducted using t - tests, and the significance of overall treatment effects was estimated using an F - test . Significant differences were declared at the 95% confidence level (α = 0.05) . Of the 73 analytes evaluated in this study , 59 produced sufficient data (>50% of data points above the limited of quantitation (LOQ)) for inclusion in the combined site statistical analysis. Therefore, 59 comparisons were made in each sub - experiment . I nclusion of analytes in the statistical analys is where a predominance of the data are less than the LOQ violates the assumptions of ANOVA due to non - normal data distributions and artifici ally reduced variance estimates .USDA - APHIS Determination of Non - Regulation Status for DAS - 8191Ø
- 7 Cotton Page 85 of 214

Dow AgroSciences LLC I n the 59 comparisons in the statistical analysis , the probability of declaring one or more false differences based on unadjusted P - values was very high due to a multiplicity effect in each sub - experiment. Multiplicity occurs when a large number of comparisons are made in a single study to look for unexp ected effects. As a result, the probability of falsely declaring differences based on comparison - wise P - values is very high at 95.151% (1 - 0.95 59 ) (1 - 0.95 number of comparisons ). Table 11 . Cottonseed C omposition A nalytes Proximates a nd Fiber (9) Protein Moisture Neutral Detergent Fiber ( NDF ) Fat Carbohydrates Total Dietary Fiber Ash Acid Detergent Fiber (ADF) Crude Fiber Minerals (12) Calcium Manganese 2 Selenium Copper Molybdenum Sodium Iron Phosphorus Sulfur Magnesium Potassium Zinc Amino Acids (18) Alanine Histidine Proline Arginine Isoleucine Serine Aspartic Acid Leucine Threonine Cystine Lysine Tryptophan Glutamic Acid Methionine Tyrosine Glycine Phenylalanine Valine Fatty Acids (22) 8:0 Caprylic 1 16:1 Palmitoleic 2 20:0 Arachidic 10:0 Capric 1 17:0 Heptadecanoic 1 20:1 Eicosenoic 1 12:0 Lauric 1 17:1 Heptadecenoic 1 20:2 Eicosadienoic 1 14:0 Myristic 2 18:0 Stearic 20:3 Eicosatrienoic 1 14:1 Myristoleic 1 18:1 Oleic 2 20:4 Arachidonic 1 15:0 Pentadecanoic 1 18:2 Linoleic 2 22:0 Behenic 15:1 Pentadecenoic 1 18:3 Linolenic 16:0 Palmitic 18:3 γ - Linolenic 1 Vitamins (7) Vitamin A (Beta Carotene) 1 Vitamin B3 (Niacin) α - tocopherol (Vitamin E) Vitamin B1 (Thiamine HCl) Vitamin B6 (Pyridoxine HCl) Vitamin B2 (Riboflavin) Vitamin B9 (Folic Acid) Anti - Nutrients (5) Dihydrosterculic Acid Sterculic Acid Total Gossypol 2 Malvalic Acid 2 Free Gossypol 1 A nalytes excluded from combined site and analysis due to more than 50% of samples < LOQ 2 A nalytes with statistically significant adjusted FDR differences in the combined site analysis. One method that has been used to handle multiplicity is to adjust P - values to control the experiment - wise error rate. However, the power for detecting specific effects can be reduced significantly when many comparisons are made. An alternative approach with much greater power is to adjust P - values to control the probability that each declared difference is significant ( Curran - Everett, 2000 ) . This can be accomplished using a False Discovery Rate (FDR) control procedure ( Benjamini and Hochberg, 1995 ) , which is a commonly used approach in studies ex amining transgenic crops ( Herman et al. , 2007 ; Coll et al. , 2008 ; Huls et al. , 2008 ; Jacobs et al. , 2008 ; Stein et al. , 2009 ; Herman et al. , 2010 ) .USDA - APHIS Determination of Non - Regulation Status for DAS - 8191Ø
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Dow AgroSciences LLC Therefore, the P - values from the composition analysis were each adjusted using the FDR method to improve discrimination of true differences among treatments from random effects (false positives) . In this study differences were considered significant if the FDR - adjusted P value was less than 0.05. 6.3. Composition Analysis Results Combined summary and statistical analysis of composition data from the non - transgenic , near isogenic isoline (control) and DAS - 8191 Ø
- 7 cotton is found in Table 12 through Table 17 and Figure 41 through Figure 46 for both sub - experiment one and two . For each analyte and entry, the least - square mean, standard error, and minimum and maximum sample value s are reported . Also, for comparison, the minimum a nd maximum values for the reference lines and literature ranges are reported. Arithmetic means from each field site are plotted in figures and literature ranges are shaded. L iterature ranges reported as not detectable or <LOD are plotted as zeros . The fo llowing sections discuss results first for sub - experiment one ( non - sprayed DAS 8191Ø
- 7, isoline , and reference lines), followed by a discussion of results for sub - experiment two (sprayed and non - sprayed DAS - 8191Ø
- 7) . Sub - experiment one was used to evaluate if the composition of non - sprayed DAS - 8191Ø
- 7 cotton is equivalent to reference and isoline lines, and sub - experiment two was used to evaluate if applying 2,4 - D plus glufosinate impacts the composition of DAS - 8191Ø
- 7 cotton. 6.3.1. Sub - experiment One - Proximat e and Fiber Analysis of Seed Results from the combined site analysis of the proximate and fiber composition for the non transgenic isoline (control) and DAS - 8191Ø
- 7 cottonseed are provided in Table 12 and Figure 41 . Nine analytes were analyzed including ash, carbohydrates, crude fat, protein, moisture, a cid d etergent f iber (ADF), crude fiber, n eutral d etergent f iber (NDF) and dietary fiber . No significant FDR - adjusted P - values were observed for DAS - 8191Ø
- 7 non - sprayed for all nine analytes . In addition, mean results for all nine DAS - 8191Ø
- 7 non - sprayed proximate and fiber analytes fell within the reference variety ranges and literature ranges . S tatistical analyses found no differences between the levels of nutrient components in cottonseed from DAS - 8191Ø
- 7 and the non - transgenic isoline , support ing the findings of composition equivalence of DAS - 8191 Ø
- 7 to non - transgenic cotton .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 87 of 214

Dow AgroSciences LLC Table 12 . Combined Site Analysis Results for Proximates & Fiber in Isoline , DAS - 8191Ø - 7 and

Reference Variety Cottonseed and Literature Ranges Analytical Component (Units) Isoline

(control) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Ex periment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Ash (% Dry Weight) 4.29 ± 0.11

3.67 - 5.14 4.17 ± 0.11

3.62 - 4.76 ( 0.047 , 0.185) 3.53 - 5.21 4.31 ± 0.13 3.69 - 5.08 4.28 ± 0.13

3.79 - 5.02 (0.411, 0.945) 3.7 - 5.342 Carbohydrates (% Dry Weight) 47.5 ± 0.9

44.5 - 53.6 49.1 ± 0.9

44.7 - 57.9 ( 0.007 , 0.050) 42.3 - 54.2 50.2 ± 1.1 46.9 - 56.6 50.5 ± 1.1

45.7 - 58.6 (0.485, 0.945) 39.0 - 53.62 Crude Fat (% Dry Weight) 21.7 ± 0.7

18.3 - 25.2 21.3 ± 0.7

15.6 - 26.2 (0.368, 0.642) 15.8 - 27.9 20.9 ± 0.9 17.3 - 25.9 20.5 ± 0.9

15.1 - 26.6 (0.319, 0.945) 14.4 - 27.292 Protein (% Dry Weight) 26.4 ± 0.9

22.3 - 31.5 25.4 ± 0.9

22.2 - 31.1 ( 0.008 , 0.055) 21.5 - 32.3 24.6 ± 1.0 19.2 - 29.7 24.7 ± 1.0

19.2 - 29.7 (0.669, 0.945) 12 - 32.97 Moisture (% Fresh Weight) 8.2 ± 0.2

6.64 - 9.74 8.0 ± 0.2

6.56 - 9.39 (0.663, 0.815) 6.37 - 10.2 8.2 ± 0.2 6.95 - 9.20 8.2 ± 0.2

6.92 - 9.13 (0.985, 0.998) 2.25 - 15.9 ADF 3 (% Dry Weight) 25.9 ± 0.5

23.0 - 28.6 25.3 ± 0.5

21.3 - 28.6 (0.381, 0.642) 20.4 - 29.4 26.0 ± 0.5 22.1 - 29.8 25.7 ± 0.5

22.4 - 30.0 (0.405, 0.945) 19.74 - 40.5 Crude Fiber (% Dry Weight) 18.1 ± 0.3

16.0 - 21.3 17.9 ± 0.3

14.8 - 22.7 (0.677, 0.815) 15.1 - 23.5 18.6 ± 0.3 13.7 - 23.6 17.8 ± 0.3

15.6 - 19.8 (0.060, 0.945) 13.45 - 23.10 NDF 4 (% Dry Weight) 34.0 ± 0.6

30.7 - 40.3 33.8 ± 0.6

28.3 - 39.7 (0.667, 0.815) 27.2 - 38.2 35.2 ± 0.6 30.6 - 39.3 34.8 ± 0.6

31.3 - 39.3 (0.557, 0.945) 25.56 - 53.6 Dietary Fiber (% Dry Weight) 44.8 ± 1.0

40.3 - 53.5 45.7 ± 1.0

40.7 - 56.5 (0.283, 0.591) 37.6 - 51.3 46.6 ± 1.1 40.0 - 54.0 47.2 ± 1.1

41.7 - 54.1 (0.309, 0.945) 33.69 - 47.55 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - values 3 Acid detergent fiber 4 Neutral detergent fiberUSDA - APHIS Petition for Nonregulated Status of DAS - 8191 Ø
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Figure 41 . Proximates & F iber in Isoline , DAS - 8191Ø - 7 and R eference V ariety C ottonseed Y axis: Moisture = % fresh weight, all others = % dry weight . Reference Variety cottonseed: All - TEX 1203, ALL TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed. 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Uns prayed 2 = DAS - 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191 Ø
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Dow AgroSciences LLC

Figure 41 . Proximates & Fiber in Isoline , DAS - 8191Ø - 7 and Reference Variety Cottonseed (continued) Y axis: Moisture = % fresh weight, all others = % dry weight. Reference Variety cottonseed: All - TEX 1203, ALL TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed.191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosi nate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191 Ø
- 7 Cotton Page 90 of 214

Dow AgroSciences LLC 6.3.2. Sub - experiment One - Mineral Analysis of Seed Results from the combined site analysis of the mineral composition for the non - transgenic isoline (control) and DAS - 8191Ø
- 7 cottonseed are provided in Table 13 and Figure 42 . Twelve analytes were measured including calcium, copper, iron, magnesium, mangan ese, molybdenum, phosphorus, potassium, selenium, sodium, sulfur and zinc. Mean results for all minerals tested in DAS - 8191Ø
- 7 non - sprayed fell within the reference variety ranges and literature ranges where available (no values were reported in the litera ture for selenium and sulfur) . No significant FDR - adjusted P - values were observed for DAS - 8191Ø
- 7 non - sprayed except for manganese . Manganese showed no significant differences for FDR - adjusted P - values among the eight individual field sites. Significant FDR - adjusted P - values were only identified in the combined site analysis. The relative magnitude of the difference for manganese between the mean values for DAS - 8191Ø
- 7 non - sprayed and the non - transgenic isoline for the combined site analysis was a decreas e of 15.0%, which was less than the variability observed for the control sample for manganese (range 1.17

– 2. 36 , a relative difference of 10 1. 7 %). The observed differences in manganese between DAS - 8191Ø
- 7 and the non - transgenic isoline were not considered to be meaningful from a food , nutritional or safety perspective because they were small, less than the variability seen in the isoline , statistically insignificant when compared at each individual field site and the mean DAS 891Ø
- 7 val ue for manganese was within both reference variety and literature ranges. For the remaining mineral analytes, mean results for DAS - 8191Ø
- 7 non - sprayed fell within the reference variety ranges and literature ranges . S tatistical analyses found no difference s between the levels of nutrient components in cottonseed from DAS - 8191Ø
- 7 and the non transgenic isoline , supporting the findings of composition equivalence of DAS - 8191 Ø
- 7 to non - transgenic cotton .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 91 of 214

Dow AgroSciences LLC Table 13 . Combined Site Analysis Results for Minerals in Isoline , DAS - 8191Ø - 7 and Reference

Variety Cottonseed and Literature Ranges Analytical Component (mg/100 g Dry Weight ) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Calcium 124 ± 7

88.1 - 164 133 ± 7

98.0 - 172 ( 0.011 , 0.059) 78.9 - 204 136 ± 7 113 - 178 136 ± 7

114 - 178 (0.960, 0.998) 100 - 330 Coppe r 0.90 ± 0.07

0.525 - 1.37 0.86 ± 0.07

0.532 - 1.30 ( 0.021 , 0.096) 0.466 - 1.44 0.86 ± 0.08 0.446 - 1.32 0.86 ± 0.08

0.426 - 1.41 (0.944, 0.998) 0.313 - 2.457 Iron 4.20 ± 0.24

3.24 - 6.26 4.25 ± 0.24

3.45 - 5.76 (0.546, 0.747) 3.43 - 6.45 4.25 ± 0.21 3.28 - 5.71 4.30 ± 0.21

3.43 - 5.57 (0.353, 0.945) 3.671 - 31.838 Magnesium 387 ± 18

291 - 487 384 ± 18

282 - 488 (0.420, 0.679) 285 - 470 391 ± 19 250 - 494 388 ± 19

283 - 498 (0.278, 0.945) 340 - 493.12 Manganese 1.59 ± 0.10

1.17 - 2.36 1.35 ± 0.10

0.968 - 2.20 ( 0.002 , 0.021 ) 0.983 - 2.28 1.31 ± 0.08 0.985 - 1.93 1.31 ± 0.08

1.01 - 2.04 (0.789, 0.990) 1.069 - 2.216 Molybdenum 0.039 ± 0.012

0.00412 - 0.107 0.036 ± 0.012

0.00427 - 0.106 (0.460, 0.702) 0.00326 -

0.122 0.036 ± 0.011

0.00557 - 0.0980 0.034 ± 0.011

0.00539 - 0.0999 (0.331, 0.945) NR Phosphorus 652 ± 42

491 - 924 633 ± 42

469 - 921 (0.079, 0.259) 460 - 901 655 ± 45 412 - 936 649 ± 45

472 - 933 (0.378, 0.945) 482.54 - 991.57 Potassium 1078 ± 23

958 - 1230 1055 ± 23

937 - 1190 (0.106, 0.331) 938 - 1290 1074 ± 23 939 - 1200 1070 ± 23

934 - 1190 (0.613, 0.945) 960 - 1448.35 Selenium (ppb Dry Weight) 110 ± 30

<LOQ - 382 122 ± 30

<LOQ - 378 (0.379, 0.642) <LOQ - 676 194 ± 95 <LOQ - 2010 180 ± 95

<LOQ - 1070 (0.670, 0.945) NR Sodium 123 ± 8

77.5 - 178 111 ± 8

64.7 - 188 (0.249, 0.577) 73.9 - 192 128 ± 9 78.7 - 207 136 ± 9

75.3 - 192 (0.187, 0.945) 5 .4 - 740 Sulfur 495 ± 67

305 - 952 535 ± 67

311 - 1850 (0.541, 0.747) 331 - 847 520 ± 74 279 - 1430 499 ± 74

303 - 1180 (0.734, 0.945) NR Zinc 3.36 ± 0.13

2.63 - 3.93 3.47 ± 0.13

2.47 - 5.29 (0.290, 0.591) 2.77 - 4.26 3.51 ± 0.21 2.33 - 5.53 3.48 ± 0.21

2.23 - 5.94 (0.821, 0.998) 2.70 - 5.95 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 42 . Minerals in Isoline , DAS - 8191Ø - 7 and R eference V ariety C ottonseed Y axis: selenium = ppb dry weight, al l others = mg/100 g dry weight . Reference Variety cottonseed: All - TEX 1203, ALL TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed. 191Ø Unsprayed 1 = DAS - 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range (where available).USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 42 . Minerals in Isoline , DAS - 8191Ø - 7, and R eference V ariety C ottonseed (continued) Y axis: selenium = ppb dry weight, al l others = mg/100 g dry weight . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band repres ents the literature range (where available).USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 94 of 214

Dow AgroSciences LLC 6.3.3. Sub - experiment One - Amino Acid Analysis of Seed Results from the combined site analysis of the amino acid composition for non - transgenic isoline ( control ) and DAS - 8191Ø
- 7 cottonseed are provided in Table 14 and Figure 43 . Eighteen analytes were measured incl uding alanine, arginine, aspartic acid, cystine, glutamic acid, glycine, histidine, isoleucine, leucine, lysine, methionine, phenylalanine, proline, serine, threonine, tryptophan, tyrosine and valine. Mean results for all eighteen of the amino acids tested in DAS - 8191Ø
- 7 non - sprayed fell within the reference variety ranges and/or literature ranges . For all amino acid ana lytes measured, no significant FDR - adjusted P - values were observed for DAS - 8191Ø
- 7 non - sprayed . In addition, mean results for all eighteen DAS - 8191Ø
- 7 non sprayed analytes fell within the reference variety ranges and literature ranges . Based on these data, statistical analyses found no differences between the levels of nutrient components in cottonseed from DAS - 8191Ø
- 7 and the non - transgenic isoline , supporting the findings of composition equivalence of DAS - 8191 Ø
- 7 cotton to non - transgenic cotton .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 95 of 214

Dow AgroSciences LLC Table 14 . Combined Site Analysis Results for Amino Acids in Isoline , DAS - 8191Ø - 7 and

Reference Variety Cottonseed and Literature Ranges Analytical Component (% Total Amino Acids) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Alanine 4.44 ± 0.03

4.29 - 4.598 4.45 ± 0.03

4.22 - 4.741 (0.705, 0.815) 4.18 - 4.656 4.48 ± 0.05 4.265 - 4.734 4.49 ± 0.05

4.25 - 4.746 (0.549, 0.945) 4.08 - 5.30 A rginine 12.64 ± 0.16

11.87 - 13.73 12.49 ± 0.16

11.50 - 13.67 ( 0.020 , 0.096) 11.57 - 13.67 12.41 ± 0.20 11.27 - 13.47 12.39 ± 0.20

11.31 - 13.77 (0.677, 0.945) 10.83 - 15.18 Aspartic Acid 10.09 ± 0.15

9.67 - 11.03 10.25 ± 0.15

9.75 - 12.03 (0.349, 0.642) 9.59 - 11.42 10.32 ± 0.22 9.69 - 11.74 10.56 ± 0.22

9.70 - 12.33 (0.182, 0.945) 9.00 - 12.37 Cystine 1.785 ± 0.040

1.563 - 2.126 1.833 ± 0.040

1.529 - 2.214 (0.145, 0.427) 1.593 - 2.339 1.799 ± 0.029 1.559 - 2.235 1.786 ± 0.029

1.542 - 2.165 (0.701, 0.945) 1.53 - 2.35 Glutamic Acid 20.11 ± 0.13

19.17 - 20.73 20.07 ± 0.13

18.58 - 20.72 (0.701, 0.815) 19.44 - 21.23 19.92 ± 0.20 18.91 - 20.69 19.83 ± 0.20

18.33 - 20.65 (0.437, 0.945) 20.24 - 22.90 Glycine 4.42 ± 0.04

4.14 - 4.61 4.41 ± 0.04

4.081 - 4.546 (0.949, 0.969) 4.10 - 4.594 4.45 ± 0.05 4.053 - 4.633 4.44 ± 0.05

4.070 - 4.738 (0.382, 0.945) 4.29 - 5.72 Histidine 2.841 ± 0.016

2.695 - 3.048 2.868 ± 0.016

2.604 - 3.001 (0.267, 0.583) 2.651 - 3.077 2.840 ± 0.019 2.685 - 2.999 2.829 ± 0.019

2.606 - 2.978 (0.652, 0.945) 2.91 - 3.88 Isoleucine 3.62 ± 0.02

3.284 - 3.790 3.61 ± 0.02

3.391 - 3.799 (0.746, 0.847) 3.180 - 3.817 3.63 ± 0.03 3.268 - 3.880 3.62 ± 0.03

3.329 - 3.876 (0.737, 0.945) 3.10 - 4.46 Leucine 6.30 ± 0.02

6.15 - 6.49 6.31 ± 0.02

6.18 - 6.45 (0.702, 0.815) 6.04 - 6.54 6.34 ± 0.04 6.15 - 6.60 6.32 ± 0.04

6.14 - 6.60 (0.153, 0.945) 6.03 - 8.11 Lysine 4.69 ± 0.06

4.36 - 5.09 4.73 ± 0.06

4.44 - 5.107 (0.254, 0.577) 4.27 - 5.03 4.72 ± 0.07 4.40 - 5.209 4.74 ± 0.07

4.39 - 5.149 (0.727, 0.945) 4.62 - 6.60 Methionine 1.640 ± 0.023

1.406 - 1.801 1.625 ± 0.023

1.460 - 1.774 (0.464, 0.702) 1.339 - 1.785 1.651 ± 0.033 1.434 - 1.988 1.645 ± 0.033

1.449 - 1.908 (0.728, 0.945) 1.27 - 2.28 Phenylalanine 5.70 ± 0.06

5.49 - 6.12 5.68 ± 0.06

5.201 - 6.01 (0.504, 0.726) 5.44 - 6.02 5.68 ± 0.06 5.35 - 5.88 5.63 ± 0.06

5.223 - 5.97 (0.137, 0.945) 5.44 - 7.23 Proline 4.04 ± 0.01

3.908 - 4.116 4.04 ± 0.01

3.895 - 4.187 (0.983, 0.983) 3.780 - 4.192 4.04 ± 0.02 3.903 - 4.200 4.05 ± 0.02

3.92 - 4.160 (0.897, 0.998) 3.81 - 5.30 Serine 4.63 ± 0.04

4.352 - 4.88 4.63 ± 0.04

4.32 - 4.875 (0.878, 0.925) 4.26 - 5.05 4.63 ± 0.03 4.354 - 4.915 4.63 ± 0.03

4.291 - 4.928 (0.897, 0.998) 4.15 - 5.87 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 96 of 214

Dow AgroSciences LLC Table 14 . Combined Site Analysis Results for Amino Acids in Isoline , DAS - 8191Ø - 7 and

Reference Variety Cottonseed and Literature Ranges (continued) Analytical Component (% Total Amino Acids) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Threonine 3.54 ± 0.03

3.312 - 3.705 3.54 ± 0.03

3.291 - 3.684 (0.849, 0.911) 3.186 - 3.756 3.57 ± 0.04 3.261 - 3.800 3.58 ± 0.04

3.338 - 3.799 (0.705, 0.945) 2.67 - 4.26 Tryptophan 1.433 ± 0.019

1.240 - 1.592 1.422 ± 0.019

1.267 - 1.651 (0.557, 0.747) 1.295 - 1.677 1.422 ± 0.018 1.254 - 1.595 1.420 ± 0.018

1.199 - 1.652 (0.927, 0.998) 0.91 - 1.40 Tyrosine 3.335 ± 0.015

3.201 - 3.457 3.313 ± 0.015

3.180 - 3.422 (0.155, 0.436) 3.190 - 3.459 3.331 ± 0.020 3.192 - 3.490 3.320 ± 0.020

3.157 - 3.468 (0.507, 0.945) 2.63 - 3.46 Valine 4.75 ± 0.02

4.43 - 4.96 4.74 ± 0.02

4.50 - 4.92 (0.426, 0.679) 4.36 - 5.02 4.76 ± 0.04 4.36 - 5.023 4.74 ± 0.04

4.45 - 5.059 (0.610, 0.945) 4.49 - 6.24 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 97 of 214

Dow AgroSciences LLC

Figure 43 . Percent T otal Amino Acids in Isoline , DAS - 8191Ø - 7 and Reference Variety Cottonseed Y axis: % Total Amino Acid . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL TEX LA122, Paymaster HS 200, Raider 271 and Speed. 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled c ircle = TX1, filled triangle = TX2 . The shaded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 98 of 214

Dow AgroSciences LLC

Figure 43 . Percent T otal Amino Acids in Isoline , DAS - 8191Ø - 7 and Reference Variety Cottonseed (continued) Y axis: % Total Amino Acid. Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangl e = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature rangeUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 99 of 214

Dow AgroSciences LLC

Figure 43 . Percent T otal Amino Acids in Isoline , DAS - 8191Ø - 7 and Reference Variety Cottonseed ( c ontinued) Y axis: % Total Amino Acid . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open cir cle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range

F FUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 100 of 214

Dow AgroSciences LLC 6.3.4. Sub - experiment One - Fatty Acid Analysis of Seed Results from the combined site analysis of the fatty acid composition (22 analytes) for non transgenic isoline (c ontrol ) and DAS - 8191Ø
- 7 cottonseed are provided in Table 15 and Figure 44 . Of the 22 fatty acids analyzed ( Table 15 ) , thirteen were excluded from the analysis because the majority of the results were less than the LOQ ( Table 11 and Table 15 ) . Mean results in DAS - 8191Ø
- 7 non - sprayed for the remaining nine fatty acids including 14 :0 myristic, 16:0 palmitic, 16:1 palmitoleic, 18:1 oleic, 18:2 linoleic, 18:0 stearic, 18:3 linolenic, 20:0 arachidic, and 22:0 behenic, fell within the reference variety ranges and/or literature ranges . T he FDR - adjusted P - values for 14:0 myristic, 16:1 palmitoleic, 18:1 oleic, and 18:2 linoleic were significant . Statistical differences for 16:1 palmitoleic and 18:1 oleic were not consistently observed among individual sites, in which 16:1 palmitoleic decreased at one of the eight sites by a mean differen ce of - 2.3% , while 18:1 oleic acid decreased at one of the eight sites by a mean difference of - 5.3 % . In addition, the relative magnitudes of the difference between the mean values for non - sprayed DAS - 8191Ø
- 7 and the non - transgenic control for the combined site analysis were a decrease of 6.9% for 16:1 palmitoleic and a decrease of 5.9% for 18:1 oleic acid. This was less than the variability observed for the control sample for 16:1 palmitoleic (range 0.4105

– 0.639, a relative difference of 55.7%) and 18:1 oleic (range 13.74

– 17.16 a relative difference of 24.9%) . The o bserved differences in 16:1 palmitoleic and 18:1 oleic between DAS - 8191Ø
- 7 and the non - transgenic isoline were not consider ed to be meaningful from a food, nutritional or safety perspective b ecause they were small, not consistently reproducible across the individual sites and the mean DAS 8 1 91Ø
- 7 values for 16:1 palmitoleic and 18:1 oleic were within both reference variety and literature ranges. For 14:0 myristic and 18:2 linoleic , no significant differences for FDR - adjusted P - values were observed among the individual sites. Significant FDR - adjusted P - values were only identified in the combined site analysis . The relative magnitudes of the differences between the mean values for DAS - 8191Ø
- 7 non - sprayed and the non - transgenic isoline for the combined site analysis were a decrease of 8.75% for 14:0 myristic and an increase of 2 .0 5 % for 18:2 linoleic . T his was less than the variability observed for the control sample for 14:0 myristic ( r ange 0. 545

– 0 .907 , a relative difference of 6 6 .4 %) and 18:2 linoleic (range 54. 4

– 6 1 . 1 , a relative difference of 12.3 %) . The observed differences in 14:0 myristic and 18:2 linoleic between DAS - 8191Ø
- 7 and the non - transgenic isoline were not considered to be meaningful from a food , nutritional or safety perspective because they were small and the mean DAS - 891Ø
- 7 values for 14:0 myristic and 18:2 linoleic were within both reference variety and literature ranges. For 16:0 palmitic, 18:0 stearic, 18:3 linole nic, 20:0 arachidic, and 22:0 behenic, mean results for DAS - 8191Ø
- 7 non - sprayed fell within the reference variety ranges and literature ranges . Statistical analyses found no FDR - adjusted differences between the levels of these nutrient components in cotton seed from DAS - 8191Ø
- 7 and the non - transgenic isoline , supporting the findings of composition equivalence of DAS - 8191Ø
- 7 to non - transgenic cotton .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 101 of 214

Dow AgroSciences LLC Table 15 . Combined S ite A nalysis R esults for F atty Acids in Isoline , DAS - 8191Ø - 7 and

R eference V ariety C ottonseed and L iterature R anges Analytical Component (% Total Fatty Acid ) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experim e nt 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) 8:0 Caprylic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 10:0 Capric NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 12:0 Lauric NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 14:0 Myristic 0.720 ± 0.041

0.545 - 0.907 0.657 ± 0.041

0.489 - 0.872 ( <0.001 , 0.002 ) 0.4324 - 1.046 0.651 ± 0.041 0.508 - 0.871 0.648 ± 0.041

0.506 - 0.866 (0.541, 0.945) 0.455 - 2.40 14:1 Myristoleic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 15:0 Pentadecanoic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ 0.050 - 0.481 15:1 Pentadecenoic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 16:0 Palmitic 22.55 ± 0.58

20.37 - 25.67 22.26 ± 0.58

20.04 - 26.12 ( 0.027 , 0.114) 18.76 - 26.07 22.26 ± 0.66 19.71 - 26.14 22.16 ± 0.66

19.53 - 25.99 (0.216, 0.945) 15.11 - 28.10 16:1 Palmitoleic 0.494 ± 0.022

0.4105 - 0.639 0.460 ± 0.022

0.3917 - 0.588 ( <0.001 , 0.003 ) 0.3787 - 0.636 0.454 ± 0.023 0.3776 - 0.587 0.451 ± 0.023

0.3728 - 0.592 (0.203, 0.945) 0.464 - 1.190 17:0 Heptadecanoic NA

<LOQ - 0.0990 NA

<LOQ - 0.1046 <LOQ - 0.1085 NA <LOQ - 0.1044 NA

<LOQ - 0.1030 0.092 - 0.119 17:1 Heptadecenoic NA

< LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 18:0 Stearic 2.311 ± 0.068

1.951 - 2.685 2.334 ± 0.068

1.943 - 2.645 (0.373, 0.642) 1.801 - 2.962 2.341 ± 0.073 1.959 - 2.628 2.313 ± 0.073

1.875 - 2.612 (0.124, 0.945) 0.20 - 3.11 18:1 Oleic 14.84 ± 0.35

13.74 - 17.16 13.95 ± 0.35

12.76 - 16.50 ( <0.001 , 0.001 ) 12.93 - 17.09 13.82 ± 0.34 12.54 - 16.50 13.80 ± 0.34

12.64 - 16.08 (0.698, 0.945) 12.8 - 25.3 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 102 of 214

Dow AgroSciences LLC Table 15 . Combined S ite A nalysis R esults for F atty Acids in Isoline , DAS - 8191Ø - 7 and

R eference V ariety C ottonseed and L iterature R anges (continued) Ana lytical Component (% Total Fatty Acid ) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 ( No Herbicide) Sub - Experiment 2 (Herbicide Applied) 18:2 Linoleic 58.5 ± 0.8

54.4 - 61.1 59.7 ± 0.8

54.9 - 62.5 ( <0.001 , 0.003 ) 52.36 - 63.9 59.9 ± 0.9 54.45 - 62.9 60.0 ± 0.9

54.7 - 62.91 (0.247, 0.945) 46.00 - 59.4 18:3 Linolenic 0.2032 ± 0.0083

0.1733 - 0.2412 0.2117 ± 0.0083

0.1782 - 0.2991 (0.249, 0.577) 0.1460 -

0.2567 0.2126 ±

0.0090 0.1829 - 0.2761 0.2150 ± 0.0090

0.1828 - 0.2688 (0.617, 0.945) 0.11 - 0.35 18:3 γ Linolenic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ 0.097 - 0.232 20:0 Arachidic 0.2509 ± 0.0105

0.2088 - 0.2949 0.2492 ± 0.0105

0.2029 - 0.3063 (0.489, 0.722) 0.1855 -

0.3242 0.2530 ±

0.0111 0.2010 - 0.3113 0.2521 ± 0.0111

0.2067 - 0.2991 (0.660, 0.945) 0.186 - 0.414 20:1 Eicosenoic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ 0.095 - 0.098 20:2 Eicosadienoic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 20:3 Eicosatrienoic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 20:4 Arachidonic NA

<LOQ NA

<LOQ <LOQ NA <LOQ NA

<LOQ NR 22:0 Behenic 0.1373 ± 0.0060

0.1119 - 0.1692 0.1341 ± 0.0060

0.1057 - 0.1693 (0.181, 0.464) 0.1035 -

0.1749 0.1358 ±

0.0071 0.1101 - 0.1757 0.1386 ± 0.0071

0.1092 - 0.1726 (0.373, 0.945) 0.104 - 0.295
1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 103 of 214

Dow AgroSciences LLC

Figure 44 . Percent Total F atty A cids in Isoline , DAS - 8191Ø - 7 and R eference V ariety C ottonseed Y axis: % Total Fatty Acid . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 1 91Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The s haded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 104 of 214

Dow AgroSciences LLC

Figure 44 . Percent Total F atty A cids in Isoline , DAS - 8191Ø - 7 and R eference V ariety C ottonseed (continued) Y axis: % Total Fatty Acid . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unspray ed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 105 of 214

Dow AgroSciences LLC 6.3.5. Sub - E xperiment One - Vitamin Analysis of Seed Results from the combined site analysis of the vitamin composition from non - transgenic isoline ( control ) and DAS - 8191Ø
- 7 cottonseed are provided in Table 16 and Figure 45 . Seven vitamin analytes were measured including v itamin E, A, B1, B2, B3, B6, and B9 ( Table 16 ). Vitamin A (beta carotene) was excluded from the analysis because the majority of the results were less than the LOQ . Mean results in DAS - 8191Ø
- 7 non - sprayed for the remaining six vitamins fell within the reference variety ranges and the literature ranges ( only available for vitamin E ) . No significant FDR - adjusted P - values were observed for DAS - 8191Ø
- 7 non - sprayed in the six vitamins that were included in the statistical analysis , supporting the findings of composition equivalence of DAS - 8191Ø
- 7 to non - transgenic cotton . Table 16 . Combined Site Analysis Results for V i tamins in Isoline , DAS - 8191Ø - 7 and Reference

Variety Cottonseed and Literature Ranges Analytical Component (mg/kg Dry Weight) Isoline

( Control ) DAS - 8191Ø - 7

non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Alpha Tocopherol (Vitamin E) 90 ± 11

30.3 - 134 88 ± 11

26.7 - 136 (0.612, 0.803) 31.1 - 151 90 ± 10 20.4 - 135 89 ± 10

27.6 - 129 (0.360, 0.945) 70.825 - 197.243 Vitamin A (Beta Carotene) NA

<LOQ - 0.264 NA

< LOQ - 0.323 <LOQ -

0.267 NA

<LOQ - 0.249 NA

<LOQ - 0.238 NR Vitamin B1 (Thiamine HCl) 10.3 ± 0.4

7.52 - 12.6 10.3 ± 0.4

8.28 - 13.2 (0.953, 0.969) 5.54 - 14.7 10.4 ± 0.5 6.14 - 13.4 10.4 ± 0.5

7.42 - 15.4 (0.912, 0.998) NR Vitamin B2 (Riboflavin) 6.2 ± 0.5

3.52 - 9.95 6.3 ± 0.5

3.82 - 9.82 (0.813, 0.888) 3.44 - 9.52 6.6 ± 0.5 3.69 - 12.5 6.6 ± 0.5

3.97 - 10.0 (0.998, 0.998) NR Vitamin B3 (Niacin) 27.8 ± 1.2

21.7 - 35.6 28.5 ± 1.2

22.7 - 35.3 (0.315, 0.620) 20.4 - 36.8 28.2 ± 1.1 21.3 - 37.7 28.1 ± 1.1

23.5 - 34.3 (0.905, 0.998) NR Vitamin B6 (Pyridoxine HCl) 3.83 ± 0.09

3.15 - 4.49 3.72 ± 0.09

3.10 - 4.54 (0.176, 0.464) 2.84 - 5.12 3.70 ± 0.13 3.18 - 4.72 3.77 ± 0.13

3.08 - 5.28 (0.535, 0.945) NR Vitamin B9 (Folic Acid) 1.66 ± 0.07

1.14 - 2.38 1.67 ± 0.07

1.17 - 2.26 (0.806, 0.888) 1.10 - 2.40 1.56 ± 0.09 0.872 - 2.31 1.64 ± 0.09

1.15 - 2.29 (0.160, 0.945) NR
1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of D AS - 8191Ø
- 7 Cotton Page 106 of 214

Dow AgroSciences LLC

Figure 45 . Vitamins in Isoline, DAS - 8191Ø - 7 and R eference V ariety C ottonseed Y axis: mg/kg Dry Weight . Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represe nts the literature range.USDA - APHIS Petition for Nonregulated Status of D AS - 8191Ø
- 7 Cotton Page 107 of 214

Dow AgroSciences LLC 6.3.6. Sub - E xperiment One - Anti - N utrient Analysis of Seed Results from the combined site analysis of the five anti - nutrient analytes including dihydrosterculic acid, malvalic acid, sterculic acid, free gossypol and total gossypol from non - transgenic isoline ( control ) and DAS - 8191Ø
- 7 cottonseed are provided in Table 17 and Figure 46 . Mean results in DAS - 8191Ø
- 7 non - sprayed for the five anti - nutrients analyzed fell with in the reference variety ranges and the literature ranges . The FDR - adjusted P - values were significant in DAS - 8191Ø
- 7 non - sprayed for malvalic acid and total gossypol. For both analytes, no significant differences for FDR - adjusted P - values were observed a mong the individual sites. Significant FDR - adjusted P - values were only identified in the combined site analysis. The relative magnitudes of the differences between the mean values for DAS - 8191Ø
- 7 non - sprayed and the non - t ransgenic isoline for the combined site analysis were an increase of 10.1% for malvalic acid and a decrease of 12 % for total gossypol . This was less than the variability observed for the control sample for both malvalic acid (range 0.4 0 3

– .6 45 , a relative difference of 60 . 0 %) and total gos sypol (range 0.8 29

– 1. 44 , a relative difference of 73.7 %). The observed differences in malvalic acid and total gossypol between DAS - 8191Ø
- 7 and the non - transgenic isoline were not considered to be meaningful from a food , nutritional or safety perspective : differences were 1) small , 2) less than the variability seen in the isoline , and 3) the mean DAS - 891Ø
- 7 values for malvalic acid and total gossypol were within both reference variety and literature ranges. For dihydrosterculic acid, sterculic acid and free gossypol mean results for DAS - 8191Ø
- 7 non - sprayed fell within the reference variety ranges and literature ran ges. St atistical analyses found no FDR - adjusted differences between the levels of nutrient components in cottonseed from DAS - 8191Ø
- 7 and the non - transgenic isoline , supporting the findings of composition equivalence of DAS - 8191Ø
- 7 to non - transgenic cotton.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 108 of 214

Dow AgroSciences LLC Table 17 . Combined Site Analysis Results for Anti - Nutrients in Isoline , DAS - 8191Ø - 7 and Reference

Variety Cottonseed and Literature Ranges Analytical Component (Units) Isoline

( Control ) DAS - 8191Ø - 7

Non - sprayed Reference

Variety Range DAS - 8191Ø - 7

Non - sprayed DAS - 8191Ø - 7

Sprayed 1 Literature

Range Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Mean ± SE Min - Max Mean ± SE

Min - Max (P - Val., Adj. P) 2 Min - Max Sub - Experiment 1 (No Herbicide) Sub - Experiment 2 (Herbicide Applied) Dihydrosterculic Acid (% Total Fatty Acid) 0.205 ± 0.007

0.150 - 0.247 0.214 ± 0.007

0.174 - 0.261 (0.074, 0.259) 0.153 -

0.325 0.216 ± 0.006

0.175 - 0.269 0.214 ± 0.006

0.181 - 0.254 (0.578, 0.945) 0.075 - 0.310 Malvalic Acid (% Total Fatty Acid) 0.524 ± 0.023

0.403 - 0.645 0.577 ± 0.023

0.426 - 0.762 ( 0.003 , 0.029 ) 0.402 -

0.854 0.591 ± 0.026

0.474 - 0.722 0.612 ± 0.026

0.450 - 0.806 (0.174, 0.945) 0.17 - 0.759 Sterculic Acid (% Total Fatty Acid) 0.275 ± 0.011

0.173 - 0.447 0.297 ± 0.011

0.209 - 0.358 (0.077, 0.259) 0.196 -

0.440 0.301 ± 0.011

0.215 - 0.366 0.301 ± 0.011

0.196 - 0.391 (0.964, 0.998) 0.13 - 0.56 Free Gossypol (% Dry Weight) 0.96 ± 0.06

0.593 - 1.36 0.83 ± 0.06

0.556 - 1.17 ( 0.010 , 0.059) 0.492 - 1.28 0.82 ± 0.06 0.479 - 1.20 0.81 ± 0.06

0.498 - 1.13 (0.624, 0.945) 0.454 - 1.399 Total Gossypol (% Dry Weight) 1.08 ± 0.05

0.829 - 1.44 0.95 ± 0.05

0.719 - 1.19 ( 0.001 , 0.010 ) 0.551 - 1.41 0.92 ± 0.05 0.519 - 1.31 0.93 ± 0.05

0.624 - 1.32 (0.867, 0.998) 0.547 - 1.522 1 Sprayed with 2,4 - D and glufosinate 2 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - valuesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 109 of 214

Dow AgroSciences LLC

Figure 46 . Anti - N utrients in Isoline, DAS - 8191Ø - 7 and R eference V ariety C ottonseed Y axis : see Table 17 for specific values. Reference Variety cottonseed: All - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, Raider 271 and Speed . 191Ø Unsprayed 1 = DAS
- 8191Ø
- 7 unsprayed in sub - experimen t 1, 191Ø Unsprayed 2 = DAS
- 8191Ø
- 7 unsprayed in sub - experiment 2, 191Ø Sprayed = DAS
- 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate in sub - experiment 2 . Symbols for each location shown: open circle = AL,  = GA, + = LA, open triangle = MO, open square = MS, open diamond = NC, filled circle = TX1, filled triangle = TX2 . The shaded band represents the literature range.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 110 of 214

Dow AgroSciences LLC 6.3.7. Sub - E xperiment Two - Composition Results The comparison s between sprayed and no n - sprayed entries of DAS - 8191Ø
- 7 cotton in sub experiment two indicated no statistically significant differences for all 59 analytes included in the combined site analysis ( Table 12 - Table 17 and Figure 41 - Figure 46 ) . In addition, comparisons of non - sprayed DAS - 8191Ø
- 7 cotton in sub - experiment two with non - sprayed DAS - 8191Ø
- 7 cotton in sub - experiment one indicated no statistically significant differences for all 59 analytes . Based on these comparisons , sprayed DAS - 8191Ø
- 7 cotton in sub experiment two is compositionally equivalent to non - sprayed DAS - 8191Ø
- 7 cotton in sub experiment one and indicates that spraying DAS - 8191Ø
- 7 with 2,4 - D plus glufosinate has no significant effect on cottonseed composition. Based on the se results, it is concluded that DAS - 8191Ø
- 7 ( non - sprayed or sprayed with 2,4 - D plus glufosinate) cottonseed is compositionally equivalent to non - transgenic cottonseed. 6.4. Composition Summary Field trials were conducted at eight U.S. field sites in 2012 to pr oduce cottonseed samples of DAS - 8191Ø
- 7 cotton ( non - sprayed and sprayed with 2,4 - D plus glufosinate), non - transgenic isoline ( control ) and non - transgenic cotton lines for nutrient composition analysis . Cottonseed s amples were analyzed for 73 analytes including proximates, fiber, minerals, amino acids, fatty acids, vitamins, and anti - nutrients, which include d analytes that are deemed important for the assessment of new cotton varieties for use in food and feed ( OECD, 2009 ) . Of the 73 analytes tested, 14 were excluded from the combined site analysis because more than 50% of the results for those analytes were less than the limit of quantitation (<LOQ) ( Table 11 ) . Statistical analyses found no FDR - adjusted P - value differences in cottonseed from DAS - 8191Ø
- 7 and the non - transgenic control for proximate, fiber, amino acid or vitamin analytes . In addition, mean values for these analytes all fell within reference variety ranges and /or literature ranges supporting the findings of composition equivalence of DAS - 8191Ø
- 7 to non - transgenic cotton. For mineral, fatty acid and anti - nutrient composition analysis, all but seven analytes showed no statistical differences in FDR - adjusted P - values in combined site analysis of DAS - 8191Ø
7 non - sprayed cotton and the non - transgenic isoline . The mean values for mineral, fatty acid and anti - nutrient analytes with no statistical difference also fell within reference variety ranges and/or literature ranges . Seven analytes including manganese, 14:0 myristic, 16:1 palmitoleic, 18:1 oleic, 18:2 linoleic, malvalic acid and total gossypol all showed statistical differences in FDR - adjusted P - values between the isoline and DAS - 8191Ø
- 7 non - sprayed and the non - transgenic control . However, the observed differences between the seven analytes in DAS - 8191Ø
- 7 and the non transgenic isoline were not considered to be meaningful from a food , nutritional or safety perspective because the differences between DAS - 8191Ø
- 7 and the non - transgenic isoline were small, were less than the variability seen in the non - transgenic isoline and the mean values for the seven analytes were all within reference variety and/or literature ranges. Additionally, no statistically significa nt differences were detected between DAS - 8191Ø
- 7 non - sprayed and DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate, which indicates thatUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 111 of 214

Dow AgroSciences LLC spraying DAS - 8191Ø
- 7 with 2,4 - D plus glufosinate has no significant effect on cottonseed composition . Based on these resu lts, it is concluded that DAS - 8191Ø
- 7 ( non - sprayed or sprayed with 2,4 - D plus glufosinate) cotton is compositionally equivalent to non - transgenic cotton. 6.5. Conclusions Overall, for DAS - 8191Ø
- 7 , mean analyte values observed to be significantly different from those of the non - transgenic isoline ( control ) were generally shown to be of small relative magnitudes . All combined - site mean values and individual site mean values of DAS - 8191Ø
- 7 for all analytes measured were within the context of the natural variabilit y of reference cotton line composition data and/or published in the scientific literature. Additionally, no statistically significant differences were detected between DAS - 8191Ø
- 7 non - sprayed and DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate, which indicates that spraying DAS - 8191Ø
- 7 with 2,4 - D plus glufosinate has no significant effect on cottonseed composition . Based on the results of this composition analysis, it is concluded that cottonseed from DAS - 8191Ø
- 7 is compositionally equivalent to non - tr ansgenic cotton seed and therefore the food and feed safety and nutritional quality of this product is comparable to that of commercially cultivated cotton.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 112 of 214

Dow AgroSciences LLC 7. Phenotypic, Agronomic and Ecological Characteristics This section provides a comparative assessment of the phenotypic, agronomic and ecological characteristics of DAS - 8191Ø
- 7 cotton compared to non - transgenic isoline (control) . As part of 7 CFR § 340.6, a detailed description of the regulated article phenotype is requested as part of the petition for determination of nonregulated status to substantiate that the regulated article is unlikely to pose a greater pl ant pest risk than the unmodified organism from which it was derived. A list of all DAS - 8191Ø
- 7 cotton field evaluations conducted under USDA permit or notification is provided in Appendix 9 . The characterization of DAS - 8191Ø
- 7 cotton encompasses 1) vegetative growth, 2) ecological (insect and disease) and 3) seed germination, dormancy, and emergence. The data were evaluated by individuals familiar with the production and evaluation of cotton . In each assessment, DAS - 8191Ø
- 7 cotton was compared to an appropriate, near isogenic isoline (control) that does not contain the add - 12 or pat genes. The data collected here support a conclusion that DAS - 8191Ø
- 7 cotton is substan tially equivalent to non - transgenic cotton with the exception of the introduced and expression of aad - 12 and pat genes and therefore no more likely to pose a plant pest risk or have a significant environmental impact compared to non - transgenic cotton. 7.1. Study Design Agronomic studies used the same field studies and plots as those for composition assessment of DAS - 8191Ø
- 7 cotton , as described in detail in section 6.1.1 . Briefly, f ield trials were conducted at eight U.S. sites in 2012 to evaluate phenotypic, agronomic and ecological characteristics of DAS - 8191Ø
- 7 cotton (non - sprayed and sprayed with 2,4 - D plus glufosinate), near isogenic non - transgenic isoline (contr ol) ( Figure 4 ) and reference variety cotton plants. For the reference lines, six unique reference lines (ALL - TEX 1203, ALL - TEX A102, ALL - TEX LA122, Paymaster HS 200, R aider 271, and Speed) were included across all sites of the field production with three varieties per site. Because non - transgenic cotton plants ( e.g. , isoline and reference lines) are sensitive to 2,4 - D, two sub - experiments were conducted at each site to spatially separate the non - transgenic entries from the entries in which 2,4 - D was applied . Sub - experiment one was not sprayed and contained the isoline, reference varieties and one entry of DAS - 8191Ø
- 7 cotton . Sub experiment two contained two entries of only DAS - 8191Ø
- 7 cotton; one not sprayed and one sprayed with 2,4 - D plus glufosinate. The objective of sub - experiment one was to determine if non - sprayed DAS - 8191Ø
- 7 cotton is agronomically equivalent to non - transgenic cotton, and the objective of sub - experiment two was to determine if applying 2,4 - D plus glufosinate impacts the agronomic characteristics of DAS - 8191Ø
- 7 cotton. The entries were arranged in a randomized complete block design w ithin each sub experiment. T he sub - experiments were se parated by 100 ft (30 m) to prevent isoline and reference entries in sub - experiment one from potential injury by 2,4 - D drift from applications in sub - experiment two . Both sub - experiments were prese nt at all field testing sites. Randomization of entries within blocks was uniq ue at each field testing site. Test, isoline, and reference variety cotton was planted at a seeding rate of approximately 100 seeds per 25 ft (7.62 m) of row (one seed per 3 in or 7.6 cm). Four replicate plots of each entry wereUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 113 of 214

Dow AgroSciences LLC estab lished at each site for each sub - experiment , with each plot consisting of four rows that were 25 ft (7.62 m) long with a row spacing of approxima tely 30 in (76 cm). E ach four row plot was bordered b y two rows cotton . Herbicides were applied in a spray vol ume of approximately 20 gallons per acre (187 L/ha), and all h erbicide applications included 2% v/v ammonium sulfate. 2,4 - D (GF - 2654) and glufosinate (Ignite 280 SL) were applied in a tank mixture as two broadcast applications to one entry of DAS - 8191Ø
- 7 c otton in sub - experiment two. Application timings were at the 3 node and 6 node growth stages. The target application rates for both application timings were 1120 g ae /ha 2,4 - D and 596 g ai/ha glufosinate . Actual application rates ranged from 1108

– 1142 g ae/ha 2,4 - D and 589

– 622 g ai/ha glufosinate for the 3 node appli cation and 1061

– 1141 g ae/ha 2,4 - D and 564

– 621 g ai/ha glufosinate for the 6 node application . 7.2. Data Collection and Statistical Analysis Evaluations of nine ph e notypic, agronomic and e cological characteristics (early population, seedling vigor, flower initiation, nodes above white flower , plant height, percent open bolls, lint yield, disease incidence and insect damage) were conducted to investigate the equivalency of DAS - 8191Ø
- 7 ( non - s prayed and sprayed with 2,4 - D plus glufosinate) cotton to non - transgenic cotton . In all cases, the agronomic data was collected and evaluated by individuals familiar with the production and evaluation of cotton . Details regarding the agronomic data collect ion of the nine agronomic characteristics measured are described in Table 18 . Analysis of variance was conducted across field testing sites for agronomic data using a mixed model ( SAS Institute Inc., 2011 ) . Entry was considered a fixed effect ; location, block within location, and locatio n - by - entry were designated as random effec ts. Paired contrasts were conducted using t - tests, and the sign ificance of overall treatment effects was estimated using an F - test. Significant differences were declared at the 95% confidence level (α = 0.05). Multiplicity occurs when a number of comparisons are made in a single study t o look for unexpected effects. U nder these conditions, the probability of falsely declaring differences based on comparison - wise P - values can be high (1 - 0.95 number of comparisons ). There were nine analytes included in the combined site statistical analysis; therefore, nine comparisons we re made in each sub - experiment in this study (DAS - 8191Ø
- 7 non - sprayed compared with the control in sub - experiment one and DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate compared with DAS - 8191Ø
- 7 non - s prayed in sub - experiment two). As a result , the probability of declaring one or more false differences ba sed on unadjusted P - values was 36.975% (1 - 0.95 9 ) due to multiplicity in each sub - experiment (or >60% across both sub experiments). One method to account for multiplicity is to adjust P - val u es to cont rol the experiment - wise error rate ; however, the power for detecting specific effects can be reduced significantly when many co mparisons are made in a study. An alternative with much greater power is to adjust P - values to control the probability that each declared difference is significant ( Curran Everett, 2000 ) . This can be accomplished using a False Discovery Rate (FDR) control procedure ( Benjamini and Hochberg, 1995 ) , which is a commonly used approach in studies examining transgenic crops ( Herman et al. , 2007 ; Coll et al. , 2008 ; Huls et al. , 2008 ; JacobsUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 114 of 214

Dow AgroSciences LLC et al. , 2008 ; Stein et al. , 2009 ; Herman et al. , 2010 ) . Therefore, the P - values from the contrasts were each adjusted using the FDR method to improve discrimination of true differences among treatments from ra ndom effects (false positives). Differences were considered significant if the FDR - adjusted P - value was less than 0.05. Table 18 . Measured Agronomic Characteristics and Sa mple Collection Details Evaluation Category Evaluation

Timing Description of Data Evaluation Description (scale/measurements) Early Population (Stand Count) 28 days after

planting Total number of emerged plants in

the center two rows of each plot Plants we re considered emerged when the cotyledons ha d assumed an erect posture and we re completely unrolled. Seedling Vigor 28 days after

planting Visual estimate of the plant vigor

in each plot 0 - 100% rati ng scale; 0 = all plants we re dead, 10 = short plants with small, thin leaves, 100 = all plants we re tall with robus t leaves . Evaluation w as not base d on growth of control entries and did not consider germination/ emergence (stand count) . Flower Initiation First white

flower 1) Dat e when approximately 50%

of plants in plot produced at least one white flower 2) Number of days from planting and the date when 50% of plants in plot have reach ed first white flower Visual approximation of when 50% of the plants in each plot ha d produced one open white flower .
Nodes A bove First White Flower 28 days after

first white flower Number of nodes above the

uppermost node containing a first position white flower on six plants per plot . Record ed the number of the uppermost node and the total number of nodes on six cotton plants that contain ed a first position white flower . The number of nodes above first white flower were c alculated by subtracting the number of the uppermost node that contain ed a first - position white flower from the total number of nodes . Plant Height 28 days after

first white flower Plant height from soil surface to

terminal bud on six plants per plot Recorded the height each plant in centimeters . Percent Open Bolls Maturity but

prior to defoliation 1 . T otal number of bolls and the

number of open bolls on six plants from each plot. 2 . Calculate d percent open bolls 1 . Record ed the total number of bolls on six represen tative plants from each plot . Record ed the number of open bolls (bolls greater than 1 in.) on the same six plants . Cracked bolls we re considered to be open. 2 . Calculate d percent open bolls: (Number of open bolls / t otal number of bolls)*100 . Lint Yield Maturity Weight of cotton lint from the center two rows of each plot. Seedcotton from rows 2 and 3 of each plot was harvested and a sub - sample of the seedcotton yield was ginned. Gin turnout (lint/seedcotton) was multiplied by the seedcotton yield of each plot to determine lint yield p er plot . Disease Incidence Peak bloom Visual estimate of disease incidence 0 - 100%; Estimate d % plant tissue/leaf area diseased over all plants in plot; d id not record % of plants in plot that ha d detectable disease; 100% = all plant tissues in plot we re diseased . R ecord ed type of disease . Insect Damage Peak bloom Visual estimate of insect damage 0 - 100%; Estimate d % plant tissue/leaf area damaged over all plants in plot; did not record % of plants in plot that ha d detectable damage; 100% = all plant tissu es ha d feeding damage; r ecord ed type of damage and type of insects if present.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 115 of 214

Dow AgroSciences LLC 7.2.1. Phenotypic and Agronomic Results Seven agronomic characteristics were evaluated in this study: early population, seedling vigor, flower initiation, nodes above first white flower, plant height , percent open bolls and lint yield. A statistical analysis of agronomic data from the control and DAS - 8191Ø
- 7 cotton entries across field testing sites was conducted . For each agronomic characteristic and entry, the least squares mean, standard error, and minimum and maximum values we re reported ( Table 19 ) . Table 19 . Combined Site Analysis Results for Agronomic Characteris tics Agronomic Characteristic (Units) Isoline

(Control) DAS - 8191Ø - 7

Non - Sprayed Reference

Range DAS - 8191Ø - 7

Non - Sprayed DAS - 8191Ø - 7

Sprayed 1 Mean ± SE Min - Max 2 Mean ± SE

Min

– Max 2 (P - Val., Adj. P) 3 Min

– Max 2 Mean ± SE Min

– Max 2 (P - Val., Adj. P) 3 Mean ± SE

Min

– Max 2 (P - Val., Adj. P) 3 Sub - Experiment 1 ( No Herbicide) Sub - Experiment 2 (Herbicide Applied) 1 Early Population ( Emerged Plants per Plot) 142 ± 10 91

– 194 129 ± 10

62 - 179 (0.050, 0.450) 4 - 209 137 ± 10 87 - 185 137 ± 10

84 - 179 (0.856, 0.963) Seedling Vigor (0 - 100% scale: 0% = short, thin plants, 100% = tall, robust plants) 85 ± 3 40

– 100 82 ± 3

62 - 100 (0.288, 0.555) 10 - 100 87 ± 3 60 - 100 84 ± 3

40 - 100 ( 0.037 , 0.335) Flower Initiation (Days from Planting to First White

Bloom) 62 ± 2 51

– 69 62 ± 2

51 - 76 (0.915, 0.995) 51 - 70 62 ± 2 51 - 70 62 ± 2

51 - 69 (0.642, 0.931) Nodes Above First White Flower (Number of Nodes) 8 ± 2 0

– 18 7 ± 2

0 - 17 (0.161, 0.555) 0 - 19 8 ± 2 0 - 17 8 ± 2

1 - 19 (0.625, 0.931) Plant Height (cm) 99 ± 9 48

– 158 99 ± 9

49 - 147 (0.774, 0.995) 45 - 164 103 ± 9 55 - 161 102 ± 9

60 - 163 (0.624, 0.931) Percent Open Bolls (Percent of Total Bolls) 65 ± 8 0

– 100 68 ± 8

17 - 100 (0.199, 0.555) 11 - 100 68 ± 8 15 - 100 68 ± 8

14 - 100 (0.989, 0.989) Lint Yield (kilograms per hectare) 762 ± 191 146

– 1991 762 ± 191

78 - 1891 (0.995, 0.995) 74 - 2225 745 ± 193 208 - 2187 687 ± 193

144 - 1585 (0.423, 0.931) Ecological Eval. Disease Incidence 4 (0 - 100%: 0% = no damage, 100% = all plants diseased) 0 ± 0 0

– 7 0 ± 0

0 - 5 (0.855, 0.995) 0 - 7 0 ± 0 0 - 3 0 ± 0

0 - 3 (0.724, 0.931) Insect Damage 4 (0 - 100%: 0% = no damage, 100% = all plants damaged) 1 ± 1 0

– 10 1 ± 1

0 - 5 (0.308, 0.555) 0 - 10 1 ± 1 0 - 5 1 ± 1

0 - 10 (0.270, 0.931) 1 Sprayed with 2,4 - D and glufosinate 2 Min, Max value is an individual data point reported for a single test plot 3 P - Val

– unadjusted P - value, Adj. P

– FDR Adjusted P - values 4 Evaluation conducted at peak bloom

7.2.1.1. Comparison of the Isoline (C ontrol ) and Non - S prayed DAS - 8191Ø
- 7 For the assessment of the nine phenotypic, agronomic and environmental characteristics measured t here were no statistically significant differences ( Adj. P<0.05) observed between the control and non - sprayed DAS - 8191Ø
- 7 entries (sub experiment 1) ; moreover, meanUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 116 of 214

Dow AgroSciences LLC results for non - sprayed DAS - 8191Ø
- 7 entries fell within the reference variety ranges ( Table 19 ) . Therefore, non - sprayed DAS - 8191Ø
- 7 was found to be agronomically equivalent to the isoline (control) .

7.2.1.2. Comparison of Non - Sprayed and Sprayed DAS - 8191Ø
- 7 Cotton Comparisons between DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate and non - sprayed DAS - 8191Ø
- 7 cotton (sub experiment 2) were not statistically significant ( Adj. P<0.05) for the nine agronomic characteristics included in the combined site analysis based on FDR adjusted P - values ( Table 18 ) . The unadjusted P - value for seedling vigor in DAS - 8191Ø
- 7 sprayed with 2,4 - D plus glufosinate was significant . Significant P - values for seedling vigor were identified at only one of the eig ht field locations . T he relative magnitudes of the differences between the mean values for non - sprayed DAS - 8191Ø
- 7 cotton vs. sprayed DAS - 8191Ø
- 7 cotton for the combined s ite analysis were small ( - 3.45% ). M ean results for DAS - 8191Ø
- 7 sprayed with 2,4 - D plu s glufosinate fell within the reference variety ranges , and the FDR - adjusted P - value w as insignificant ; therefore, the statistically significant difference for seedling vigor based on the unadjusted P - value is not considered biologically meaningful . T he ag ronomic characteristics of DAS - 8191Ø
- 7 cotton sprayed with 2,4 - D plus glufosinate are equivalent to non - sprayed DAS - 8191Ø
- 7 .

7.2.1.3. Phenotypic and Agronomics Conclusions Phenotypic and agronomic analysis of DAS - 8191Ø
- 7 cotton revealed no statistically significan t differences between non - sprayed DAS - 8191Ø
- 7 cotton and the isoline (control) . In addition, all mean results from the isoline and DAS - 8191Ø
- 7 entries were within the ranges observed in the non - transgenic cotton reference varieties included in the study . It was also determined that the agronomic characteristics of DAS - 8191Ø
- 7 cotton sprayed with 2,4 - D plus glufosinate are equivalent to non - sprayed DAS - 8191Ø
- 7 cotton . The data collected here support a conclusion that DAS - 8191Ø
- 7 cotton is substantially equ ivalent to non - transgenic cotton with the exception of the introduced and expression of aad - 12 and pat genes and therefore no more likely to pose a plant pest risk , increase in weediness, or have an altered environmental impact compared to non - transgenic c otton. 7.2.2. Ecological Evaluations As part of the plant characterization for DAS - 8191Ø
- 7 cotton, e valuations of disease incidence and insect damage were conducted to determine the potential for increase in plant pest characteristics compared to non - t ransgenic cotton. The same field trials and plots as described for the phenotypic and agronomic analyses for DAS - 8191Ø
- 7 cotton were monitored for both insect damage and disease incidenc e at peak bloom . Monitoring was performed and observed by personnel fa miliar with cotton cultivation practices (field station managers, field agronomists, field associates) . The personnel conducting the field tests visually monitored the incidence of plant disease and pests on DAS - 8191Ø
- 7 cotton and non - transgenic cotton v arieties included in the same trials . Disease and insect damage was rated at peak bloom on a numerical scale of 0 - 100%, with 0% representing no damage due to disease incidence or insect pests ( Table 19 ) . Table 20 summarizes the insects and diseases that caused the insect damage and disease incidence at each field site.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 117 of 214

Dow AgroSciences LLC Insect damage or disease was limited, and where present, was found in both test an d control plots ( Table 19 ) . The insect and disease pressure observed in these trials was typical of the growing locations . There were no statist ically significant diff erences between non - sprayed DAS - 8191Ø
- 7 cotton and the isoline (control) in susceptibility to and interactions with diseases and insects ( Table 19 ) . Likewise, sp r ayin g 2,4 - D and glufosinate on DAS - 8191Ø
- 7 cotton did not statistically significantly affect the occurrence of insect damage or disease incidence. All plots were uniformly treated with pest control measures at each location based on pressure in the non - transgenic plots such that low incidence of these pests was expected . This design mimics commercial practice and allows comparison to typical cultivation conditions for non - transgenic cotton . The se data support the conclusion that DAS - 8191Ø
- 7 cotton is substantially equivalent to non - transgenic cotton and is no more likely to be susceptible or resistant to insects or disease s typical to U.S. cotton growing regions. The data collected here support a conclusion that , with the exception of the introduced and expression of aad - 12 and pat genes DAS 8191Ø
- 7 cotton is no more likely to pose a plant pest risk, increase in weediness or have an altered environmental impact compared to non - transgenic cotton. Table 20 . Insects and Diseases Present at Field Testing Sites Site 1 Insects Present Type of Insect Damage Diseases

Present AL Whitefly Stippling Leaf spot GA Bollworm/Tobacco Budworm Chewing None LA None None None MO None None None MS Plant bug Square Feeding None NC None None None TX1 None None None TX2 None None Alternaria 1 Site location listed by U.S. state abbreviation with two locations shown for Texas (TX1, TX2) 7.2.3. Cottonseed Germination and Dormancy Evaluation Seed dormancy is a characteristic that is often associated with plants that are considered weeds. Cotton, however , has had this characteristic removed through selection and breeding. Since USDA - APHIS considers weediness as a factor in the plant pest deter mination, an assessment of seed dormancy and germination was conducted on DAS - 8191Ø
- 7 cottonseed. The germination and dormancy of DAS - 8191Ø
- 7 cottonseed compared with non - transgenic isoline (control) (98M - 2983XCoker 310) cottonseed under warm and cool conditions was evaluated to determine any impact of AAD - 12 and PAT expression on seed germination and dormancy characteristics .

7.2.3.1. Study Design The warm and cool germination tests consisted of four replications of each cotton entry with 100 seeds per replica tion in a completely randomized design.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Warm Germination Methods : One hundred acid delinted cotton seeds were evenly distributed onto two water saturated sheets of non - toxic, germination paper towels . A third water saturated towel was used to cover the s eeds and all three towels were loosely rolled and placed u pright in a plastic container. This process was repeated for each of four replications . The rolled towels were placed in an incubator set at 30° C. Sufficient water was added throughout the experime nt to maintain a moist substrate while ensuring that a film of excess water did no t accumulate around the seeds. On day four and day eight, seeds were observed for germination. This method is adapted from the AOSA Rules for Testing Seeds ( AOSA, 2010a ) . Seedlings were evaluated in accordance with the AOSA Seedling Evaluation guidelines ( AOSA, 2010b ) . Cool Germination Methods: One hundred acid delinted cotton seeds were evenly distributed onto two water saturated sheets of germination non - toxic paper towels . A third water saturated towel was used to cover the seeds and all three towels were loosely rolled and placed upright in a plastic co ntainer. Prior to use all towels had been kept at 18 ° C for at least 16 hours . Each container was covered to reta in moisture and then kept at 18 ° C for 7 days in the dark . On day seven, the germination was recorded . For cool germination, n ormal seedling s were defined as “normal seedlings having a combined hypocotyl and root length of 4 cm (1 and 10/16 in) or longer ( AOSA, 2009 ) .” All other germinated seedlings that did not meet these criteri a were classified as abnormal. This method is adapted from the AOSA Seed Vigor Testing Handbook ( AOSA, 2009 ) . Data were transformed using the arcsine of the square root of the decimal fraction of cotton seeds normally germinated per replicate and then subjected to analysis of variance based on a completely randomized design ( SAS Institute Inc., 2011 ) .

7.2.3.2. Germination and Dormancy Results Percentages of normally germinated cotton seedlings and P - values for the signif icance of the effect of entry on germination are provided in Table 21 . Germination of event DAS - 819 1Ø
- 7 cotton did not differ significantly (α = 0.05) from that of the non - transgenic cotton comparator under warm ( P = 0. 1189 ) or co ol ( P = 0.0717 ) conditions , indicating that the presence of the transgenic insert in DAS - 8191Ø
- 7 cotton did not alter cottonseed germination. These data support the conclusion that DAS - 8191Ø
- 7 cottonseed is substantially equivalent to non - transgenic cottonseed in its germination characteristics. The data support a conclusion that with the exception of the introduced and expression of aad - 12 and pat genes DAS - 8191Ø
- 7 cottonseed is no more likely to pose a plant pest risk or increase in weediness compared to non - transgenic cotton.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 21 . Germination Percentages for DAS - 8191Ø - 7 and Control Cottonseed Temperature Entry Cotton Germination (%) 1 PValue 2 Rep 1 Rep 2 Rep 3 Rep 4 Mean (±SE) Warm 30 °C DAS - 8191Ø
- 7 93 95 95 99 95 .5 (±1. 3 ) 0. 1189 30 °C Control 89 93 91 95 9 2 . 0 (± 1 . 3 ) Cool 18 °C DAS - 8191Ø
- 7 60 73 48 50 57 . 8 (± 5 . 7 ) 0. 0717 18 °C Control 85 81 76 59 75 . 3 (±5 .7 ) 1 F our replications of each cotton sample at the indicated temperature with 100 seeds per replication in a completely randomized design 2 Differences were considered significant if the P - value was less than 0.05. 7.3. Summary of Phenotypic, Agronomic and Ecologic Characteristics A comparative assessment of the phenotypic, agronomic and ecological characteristics of DAS - 8191Ø
- 7 cotton compared to non - transgenic isoline (control) was conducted. The characterization of DAS - 8191Ø
- 7 cotton encompasse d 1) vegetative growth, 2) ecologica l (insect and disease) and 3) seed germination and dormancy. The data were evaluated by individuals familiar with the production and evaluation of cotton . In each assessment, DAS - 8191Ø
- 7 cotton was compared to an appropriate, near isogenic isoline (contr ol) that does not contain the add - 12 or pat genes ( Figure 4 ) . Phenotypic, agronomic and ecological analysis of DAS - 8191Ø
- 7 cotton revealed no statistically significant differences between non - sprayed DAS - 8191Ø
- 7 cotton and the isoline (control) . It was also determined that the phenotypic, agronomic and ecological characteristics of DAS - 8191Ø
- 7 cotton sprayed with 2,4 - D plus glufosinate are equivalent to non - sprayed DAS - 8191Ø
- 7 cotton. In addition, studies conducted under warm and cool conditions revealed that the germination and dormancy of DAS - 8191Ø
- 7 cotton did not differ significantly from its non - transgenic cotton, near isogenic comparator. The data collected here support a conclusion that DAS - 8191Ø
- 7 cotton is substantially equivalent to non - transgenic cotton with the exception of the introduced and expression of aad - 12 and pat genes and therefore no more likely to pose a plant pest risk or have a significant environmental impact compared to non - transgenic cotton. 7.4. F iel d Efficacy As part of the phenotypic, agronomic and ecologic field studies, herbicide injury ratings were also collected from DAS - 8191Ø
- 7 cotton entries ( non sprayed and sprayed with 2,4 - D plus glufosinate) . Field trial designs and herbicide application ratings are described in section 7.1 . Herbicide applications were applied at the 3 node and 6 node stage and p lants were evaluated 14 days after application on a scale of 0

– 100% where 0 represents no injury and 100 represents complete plant death . Results of the herbicide injury data are shown in Table 22 . DAS - 8191Ø
- 7 cotton displayed minimal herbicide injury for applications at both the 3 node and 6 node stages . These data support the excellen t tolerance of DAS - 8191Ø
- 7 cotton at the proposed maximum herbicide use rate.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 22 . DAS - 8191Ø - 7 Cotton Tolerance to Application of Herbicides Herbicide 1 Application Rate 2 Application Stage Percent Plant Injury 3

(Mean ± SE) DAS - 8191Ø
- 7 No Herbicide DAS - 8191Ø
- 7

Sprayed 2,4 - D plus glufosinate 1120 g ae/ha (2,4 - D)

596 g ai/ha (glufosinate) 3 node 0 ± 0 4 ± 2 6 node 0 ± 0 4 ± 2 1 2,4 - D and glufosinate were applied in combination as a tank mixture 2 g ae/ha = grams acid equivalent per hectare, g ai/ha = grams active ingredient per hectare 3 Means for no herbicide treatment (No Herbicide ) and sprayed were not statistically compared since the data contained insufficient variability to enable ANOVA . Dat a from the Louisiana field testing site were excluded from this analysis since data was not collected on non sprayed plants.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 8. Impact on Environmental and Agronomic Practices As part of the plant pest assessment required by 7 CFR § 340.6(c)(4), impacts to agricultural and cultivation practices must be considered. This section provides a summary of current agronomic practices in the U.S. for producing cotton and describes potential impacts regarding the introduction of DAS - 8191Ø
- 7 cot ton into the environment, including gene flow and on non - target organisms and endangered species. In addition, this section provides an evaluation of the potential impact of DAS - 8191Ø
- 7 cotton on current agronomic practices including cultivation, weed cont rol, volunteer management and herbicide resistance management. With the exception of the presence of the AAD - 12 and PAT proteins, DAS - 8191Ø
- 7 cotton is phenotypically equivalent to commercially cultivated cotton and is no more susceptible to diseases or pests than commercially cultivated cotton. Therefore, there are no likely impacts of DAS - 8191Ø
- 7 cotton to the majority of the agronomic practices currently employed in cotton production and b ased on substrate specificity of AAD - 12 and PAT , no effect on non target organisms or endangered species is anticipated for DAS - 8191Ø
- 7 cotton . 8.1. Current U.S. Agronomic Practices for Cotton 8.1.1. Cotton Production Only the cotton boll (consisting of fibers and seeds) is useful for fiber, food and feed wit h the primary use of cotton in the U.S. being fibers which are mainly used in the manufacturing of a large number of textiles. Approximately 85% of cotton value is derived from the fiber. The boll is processed to remove the fiber for textile use; the remai ning fuzzy seed is processed into four major food and feed products: oil, meal, hulls and linters. Cottonseed currently results in approximately 10% of the world’s oilseed production. Cotton is the world’s most widely grown fiber crop, accounting for over 35% of the total world fiber use ( USDA ERS, 2013a ) . The United States is the top exporter of raw cotton, and third in world production behind China and India ( USDA ERS, 2013a ) . U.S. cotton producti on alone accounts for more than $25 billion in products and services annually and generat es approximately 200,000 U.S. jobs ( USDA ERS, 2013a ) . Upland c otton, Gossypium hirsutum , accounts for approximately 97% of U.S. annual cotton crop production, with Pima (Egyptian) cotton, G. barbadense , accounting for the remaining 3% of cotton acreage ( USDA NASS, 2013c, p.42 ) . In the U.S., cotton is grown across the southern sta tes in four major cotton growing regions which include the Southeast, Midsouth, Southwest and West regions ( Table 23 , Figure 47 & Figure 48 ). Over the past 10 years, harvested cotton acres have v aried from around 7.5 to 13.8 million acres harvested with the lowest harvested acres recorded in 2009 and the highest in 2005 ( Table 24 ). Texas devotes more area to cotton production and produces more cotton than any other state, producing over five million bales in 2012 accounting for nearly 30% of all cotton productionUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC in the U.S. ( Table 23 ) . Other states producing over one million bales in 2012 included Georgia, North Carolina, Arkansas, and California ( Table 23 ) . In 2012, 9 .4 million acres of cotton were harvested in the US ; with production value estimated at just under $ 6 billion ( USDA NASS, 2013a , 2013b ) . Current estimates of all cotton planted in the U.S. for 2013 are 10. 2 million acres, with 10.0 million acres estimated for u pland cotton and the remaining U.S. acreage dedicated to pima cotton which is mainly grown and limited to the Sou thwestern U.S. due to the longer required growing season compared to upland cotton ( Figure 48 ).

Table 23 . Total U.S. Cotton Growing Regions, States and 2010 – 2012 Harvest, Yield & ProductionUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Table 24 . Cotton Production in the U.S., 2002 - 2013 1,2

Figure 47 . Planted Upland Cotton Acres by County in the U.S. in 2012 ( USDA NASS, 2012b )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 48 . Planted Pima Cotton Acres by County in the U . S . in 2012 ( USDA NASS, 2012a ) 8.1.2. Cotton See d Production Seed quality, including genetic purity, vigor, and presence of weed seed, seed - borne diseases, and inert materials, is a major factor affecting crop yield. Genetic purity in commercial seed production is generally regulated through a system of seed certification which is intended to ensure that the desired traits in the seed are maintained throughout all stages in cultivation. The U.S. Federal Seed Act, enacted in 1939, recognizes seed certif ication and official certifying agencies. Implement ing regulations further recognize land history, field isolation, and varietal purity standards for seed. States have developed laws to regulate the quality of seed available to farmers ( Bradford, 2006 ) . Most of the laws are similar in natur e and have general guidelines for providing information on the label for the followin g: 1) c ommonly accepted name of agricultural seed, 2) a pproximate total percentage by weight of purity, 3) a pproximate total percentage of weight of weed seeds, 4) n ame and approximate number per pound of each kind of noxious weed seeds, 5) a pproximate percentage of germination of the seed, and 6) m onth and year the seed was tested. The Association of Official Seed Certifying Agencies (AOSCA, 2012) defines the classe s of cottonseed as follows: 1) breeder seed, 2) foundation seed, 3) registered seed, and 4) certified seed. Breeder seed is seed directly controlled by the originating or sponsoring plant breeding organization. Foundation seed is the progeny of Breeder see d or Foundation seed that is handled to maintain specific genetic identity and purity. Registered seed is the progeny of Breede r or Foundation seed that is handled to maintain satisfactory genetic identity andUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC purity. Certified seed is the progeny of Breed er, Foundation, or Registered seed that is handled to maintain satisfactory genetic identity and purity . Commercial cotton seed sold and planted for typical cotton production is produced predominately to meet or exceed certified seed standards. Production of all classes of certified seed requires that 1) each certifying agency shall determine that genetic purity and identity are maintained at all stages of certification including seeding, harvesting, processing, and labeling of the seed; 2) the unit of cer tification shall be a clearly defined field or fields; 3) one or more field inspection shall be made prior to harvest and when genetic purity and identity can best be determined; and 4) a certification sample shall be drawn in a manner approved by the cert ifying agency from each cleaned lot of seed eligible for certification ( USDA, 2012a ) . Federal regulation 7 CFR §201 .76 specifies minimum land, isolation, field, and seed standards required for cotton Foundation, Registered and Certified seed. To qualify as Certified seed, only one plant of another variety in 10 00 cotton plants or 0. 1 % of seed of other varieties or off

- types are permitted ( USDA, 2012b ) . To qualify as Registered seed, only one plant of another variety in 500 0 cotton plants and 0. 05 % of seed of other variety or off types are permitted. To be certified as Foundation seed, only one plant of another variety in 1 0 ,000 cotton plants and 0. 03 % of seed of other variety or off - types are permitted . Agronomic practices for producing cottonseed are similar to commercial production with enhanced management practices to ensure high quality, genetically pure seeds. Commercial certified cotton seed must meet state and federal seed standards and labeling requirements. State seed certification standards vary from state to state, but can be more restrictive than standards set forth by AOSCA. DAS - 8191Ø
- 7 cotton does not differ from conventional cotton in agronomic characteristics (Section 7 ) and thus is not expected to impact U.S. cotton or seed production. Once deregulated, DAS - 8191Ø
- 7 cottonseed will be produced in the same manner as commercially certified cottonse ed, such that it will meet all state and federal seed standards and labeling requirements. 8.1.3. Planting and Cotton Development Soil temperatures have a strong influence on the rate of germination and seedling development in cotton, which responds most favorably to soil temperatures around 64°C or greater at the appropriate seedling planting depth ( Smith et al. , 1999 ) . Pla n ting c otton in soil conditions with temperatures less than 55°C will generally result in poor vigor and seedling disease problems. Under favorable conditions, germination generally occurs with five to fifteen days after planting. O ptimal cotton yield is highly dependent on achieving a satisfactory cotton stand which is dependent on location, soil conditions, environment conditions, row - spacing and the cultivar. Soil conditions can be optimized and cotton has the ability to compensate in response to row spacing a nd plant populations. However, cotton plants in thick stands tend to grow taller,USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC develop more ve getative growth and often cause delays in fruiting; this may alter the reproductive/vegetative balance of the plant ( Smith et al. , 1999 ) . L ow plant populatio ns can contribute to weed problems and produce inadequate fruit and impact overall yield. The first cotton squares become visible normally five to eight weeks after planting, depending on growing conditions. The majority of cotton bolls harvested tend to come from squares which set during the first month of squaring, emphasizing the importance of proper crop management during this period including water, weed, nutrient and pest management which all have the potential to dramatically decrease crop yield if not managed properly. Once cotton develops into the later stages of the season, management of the crop is typically orientated to harvest. Effective defoliation is an essential step in the overall process of harvesting high quality lint. Quick, efficient defoliation is accomplished by chemical means and is dependent on the plant - water status, nitrogen fertility status, insect damage, weather conditions and the chemical defoliant ( Smith et al. , 1999 ) . Once defoliated, the cotton is harvested mechanically. 8.1.4. Weeds in Cotton Cotton is a slow - growing plant early in the season and competes poorly with weeds . This is especially true in the northern cotton - growing areas, when cotton is planted into cooler soils . Studies show that control of weeds during the first four to eight weeks after planting is critical to prevent weeds for competing for water, light, nutrients and other resources essential for cotton germination and growth ( Smith et al. , 1999 ) . Weeds that are most common are not necessarily the most troublesome. The degree of importance depends on the expense of control, interference to cotton growth and yield, and reduction in lint quality. The type, severity, and impact of weeds in cotton vary between geographical regions . In addition, weed populations do not remain static and change over time due to reproductive ability, control methods, herbicide regimes, herbicide resistance, climate changes and other environmental factors ( Smith et al. , 1999 ) . It is important for proper identification of invading weed species to help develop an effective weed management program. Major weeds in cotton include broadleaf species such as pigweeds, horseweed, and common cocklebur, as well as grass species such as Johnsongrass ( sorghum halepense ) and goosegrass ( Heap, 2013b ) . Palmer a maranth, morning g lory spp., and nutsedge species are reported as both common and tr oublesome ( Webster and Sosnoskie, 2010 ) . Table 25 provides a list of top weeds in cotton as reported by growers in specific cotton - growing regions, with glyphosate resis tant biotypes being the most pervasive and problematic in the Southeast and parts of the Midsouth.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 25 . Major Weeds Treated in Cotton by Region in 2011 (Descending Order) 1

8.1.5. Weed Management in Cotton Weed control in cotton uses a combination of cultural, mechanical and chemical methods ( University of California Agriculture & Natural Resources, 2013c ) . With herbicide tolerant cotton planted on 82% of U.S. acres ( USDA NASS, 2013c ) , herbicides are the primary basis o f weed management programs . These regimens incorporate h erbicide s pre - emergence, during planting, post - emergence , or a combination ( Burgos et al. , 2006 ) . Mechanical cultivation remains common, particularly in areas of herbicide resistant weeds ( University of Western Australia, 2010 ) . A 2010 USDA survey reports that herbicides wer e applied to 99% of upland cotton, with glyphosate being the most widely and heavily used ( USDA NASS, 2011 ) . O ther commonly used herbicides include diuron, pendimethalin, metalochlor, pyrithriobac, and trifluralin ( University of California Agriculture & Natural Resources, 2013c ) . The widespread adoption of glyphosate tolerant crops and su bsequent glyphosate use on a large portion of cropland has created strong selection pressur e for glyphosate resistant weed s . In 1996, no weed species were known to be resistant to glyphosate; currently there are 24 confirmed glyphosate resistant weed speci es globally. Fourteen are confirmed in the U.S ., and all occur in cotton growing states ( Hurley et al. , 2009 ; Heap, 2013d ) . For m ore detail s see Appendix 7 .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Heavy reliance on glyphosate and the resulting emergence of persistent, resistant weeds has resulted in increasing emphasis on integrated management app roaches . These approaches include tillage, hand - weeding, crop rotation, and alternate herbicidal chemistries (WSSA, 2013). Few herbicides have been developed for use on cotton as compared to corn and soybean ( Kendig et al. , 1994 ) . DAS - 8191 Ø
- 7 cotton and the herbicide systems it enables, provide growers needed tool s for use in an integrated weed management strategy . Weed management decisions are difficult for growers because a single tool cannot effectively control all possible weed problems . Effective weed control requires grower implementation of management practices that limit the introduction and spread of weeds, help the crop to compete with weeds, and prevent weeds from adapt ing . The combination of weed control practices that a grower cho oses depends upon the weed spectrum, level of infestation, soil type, cropping system, weather, and time and labor available for the treatment option. 8.1.6. Crop Rotation and Tillage Practices Cotton is commonly rotated with other crops, including corn, soybean s, sorghum, peanut and wheat ( USDA APHIS, 2011 ) . Market dynamics, g eography and grower needs influence the choice of rotation crop; crop rotation is used to manage weeds, pests, diseases, erosion, and improve soil health ( University of California Agriculture & N atural Resources, 2013b ) . While some of the cotton belt still operates under continuous cotton monoculture practice, there is evidence that rotation practice is becoming more common due to the benefits it provides ( Cotton Incorporated, 2013 ) . Types of tillage currently used in cotton include conventional, reduced, and conservation tillage ( Albers and Reinbott, 1 994 ) . Data demonstrates that new technologies, such as herbicides to control early season weeds, allowed growers to shift away from conventional tillage ( University of California Agriculture & Natural Resources, 2013c ) . A Cotton Incorporated g rower survey found a “signific ant increase” in conservation tillage from 1990 - 2004 ( Smith, 2009 ) . However, high weed pressure in recent years has resulted in a reduction i n conservation tillage practice ( Sh aw et al. , 2012 ; Robinson, 2013 ) . 8.2. Potential Impacts of DAS - 8191Ø - 7 Dow AgroSciences has developed DAS - 8191Ø
- 7 cotton, tolerant to the herbicides 2,4 - D and glufosinate. DAS - 8191Ø
- 7 cotton will pro vide growers with greater flexibility in selection of herbicides for the improved control of economically important weeds; allow an increased application window for effective weed control; and provide an effective weed resistance management solution to gly phosate resistant weeds . DAS - 8191Ø
- 7 cotton will be combined with glyphosate tolerant cotton utilizing traditional breeding techniques. The combination of herbicide tolerant traits will allow the use of multiple herbicides in an integrated weed managemen t program to control a broad spectrum of grass and broadleaf weed species in cotton. These herbicides will provide distinct modes of actions for use in conjunction with other herbicide active ingredients and mode s of actionUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC for an effective weed management program in cotton. 2,4 - D will provide improved in - crop post - emergence control of hard to con trol glyphosate resistant broad leaf weeds, such as pigweed, waterhemp, horseweed, and morning g lory. 8.2.1. Environment – Weediness Potential, Gene Flow and Non - Target / Endangered Species 8.2.1.1. Weediness Potential Cotton is not considered to have weedy characteristics in the U.S. and USDA - APHIS has determined that cotton ( Gossypium hirsutum ) is not a plant pest in the United States ( USDA APHIS, 2011 ) . In addition, cotton is no t present on the lists of noxious weed species distributed by the federal government (7 CFR Part 360) nor does cotton possess attributes commonly associated with weeds; it is relatively slow - growing and does not compete effectively with other cultivated pl ants or primary colonizers ( OECD, 2010 ) . In addition, c ommercial varieties of cotton in the U.S. are not effective in invading established ecosystems . Cultivated cotton rarely displays any dormancy characteristics and may grow as a volunteer o nly under specific conditions. V o lunteers are easily controlled by herbicides or mechanical means ( Morgan et al. , 2011a ; Morgan et al. , 2011b ) . The introduction of 2,4 - D , glufosinate, and glyphosate tolerance into cotton will not alter its weediness characteristics . Agronomic properties of DAS - 8191Ø
- 7 cotton related to weediness, such as germination, emergence, seedling vigor and respo nse to environmental stressors have been shown to be identical to conventional cotton (Section 7 ) . If individual DAS - 8191Ø
- 7 cotton plants were to overwinter, they can still be effectively controlled mechanically or with other herbicide modes of action such as paraquat in burndown, atrazine to con trol 2,4 - D cotton volunteers in corn fields, and flumioxazin to control 2,4 - D tolerant cotton volunteers in soybean fields ( Morgan et al. , 2011a ) . Collectively, these findings support the conclusion that DAS - 8191Ø
- 7 cotton has no increase d weediness compared to commercially cultivated cotton .

8.2.1.2. Gene Flow Assessment 8.2.1.2.1. Vertical Gene Flow Cotton is considered self - pollinating; pollen grains are large, heavy and somewhat sticky; thus dissemination by wind is absent or negligible . Pollen - mediat ed gene flow declines steepl y, typically below 1% beyond 10 m eters from the source ( Van Deynze et al. , 2005 ) . Thus, the potential for gene flow from DAS - 8191 Ø
- 7 cotton to cultivated, wild or feral cotton is highly unlikely . Cotton is generally self

- pollinating but some cross - pollination can occur, albeit at relatively low incidence through activity of pollinating insects ( Hutmacher et al. , 2006 ) . In the presence of pollinators, cross pollination may occur at low lev els, with decreasing frequency as distance from t he source increases ( OECD, 2010 ) . In farm scale studies using traditional Upland cotton in California, it was found that the outcrossing distance was strongly dependent on the presence of bee colonies. When only native pollinat ors were present in the field, 1% out - crossing was detectable over a distance of 1 meter (approximately 3 f ee t) and 9USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC meters (29.5 f

ee t) when there was high pollinator activity ( Van Deynze et al. , 2005 ) . Out crossing declined exponentially with increasing distance from the source plot ( Van Deynze et al. , 2005 ) . In addition, DAS - 8191Ø
- 7 cotton would not be expected to confer a selective advantage to, or enhance the pest potential of, progeny resulting from such crosses if they were to occur. Therefore, the environmental consequences of gene flow from DAS - 8191Ø
- 7 cotton to other cotton species is considered to be negligible. The potential for outcrossing and gene introgression from DAS - 8191Ø
- 7 to cultivated cotton in the U.S. ( G. hirsutum and G. barbadense ) is low since cotton pollen movement by wind is limited due t o its large and sticky nature. In addition, studies have shown that even in the presence of pollinator activity, cross - pollination is limited by distance ( Van Deynze et al. , 2005 ) . Only two ‘wild’ Gossypium species are known to persist in the U.S. including G. thurberi found in Arizona and feral populations of G. hirsutum known to occur in South Florida and Puerto Rico. In addition, G. thurber i is a diploid (2x) cott on species while DAS - 8191Ø
- 7 cotton (present in G. hirsutum ) is allotetraploid (4x) species, if pollen or gene exchange did occur, it would result in a triploid (3X) sterile plant. Such sterile plants have not been reported in the wild. Although DAS - 8191Ø
- 7 cotton is capable of crossing with wild G. hirsutum , wild species of G. hirsutum are not commonly present in cotton growing areas of the U . S. G. tomentosum is en demic to the Hawaiian Islands. Cultivated cotton is not grown commercially in Hawaii ( USDA NASS, 2012c ) , but ma y occur in counter - season breeding nurseries. In such cases of counter - season nurseries, appropriate isolation distances and practices are required for seed productions ( Federal regulation 7 CFR §201.76 ) and growing regulated cotton (660 feet physical iso lation from non - transgenic cotton fields; or minim of 40 feet of continuous and uninterrupted non - regulated cotton border, plus 10 feet separation between the border and adjacent field; or destruction of material prior to flowering), significantly limiting any potential for gene flow between domesticated cotton and G. tomentosum . Overall, the potential for DAS - 8191Ø
- 7 cotton for crossing to cultivated, wild or feral cotton populations is low due to cotton’s self - pollination nature, geographic isolation barriers and or geneti c make - up. In addition, DAS - 8191Ø
- 7 cotton would not be ex pected to confer a selective advantage to, or enhance the pest potential of, progeny resulting from such crosses if they were to occur. Therefore, the environmental consequences of gene flow from DAS 8191Ø
- 7 cotton to other cotton species is considered to be negligible.

8.2.1.2.2. Horizontal Gene Flow DAS is unaware of any reports regarding the unintended transfer of genetic material from cotton to other sexually - incompatible species. In the unlikely event that such a transfer were to take place, the aad - 1 2 and/ or pat genes from DAS - 8191Ø
- 7 cotton would not present a human health or plant pest risk; this conclusion is based on the safety data presented in this petition. Therefore, in the highly unlikely event that horizontal gene flow were to occur, theUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC presence of aad - 1 2 and/ or pat traits would not be expected to increase pest or weed potential in the recipient species.

8.2.1.3. Non - Target Organisms and Endangered Species Based on substrate specificity of the AAD - 12 enzyme activity, no effect on non - target organisms or enda ngered species is anticipated for DAS - 8191Ø
- 7 cotton . The aad - 12 gene and expressed protein are present in nature in the soil bacterium Delftia acidovorans . The pat gene and the expressed protein are present in other crops grown in the United States with n o effect s on non - target organisms or endangered species . AAD - 12, and PAT are not potential food allergens or toxins ( Section 5.1.5.2 , 5.1.5.3 and 5.2.5 ) and DAS - 8191Ø
- 7 cotton has been shown to be substantially equivalent to non - tr ansgenic cotton based on the compositional analysis of cottonseed ( Section 6 ) . Observations made during field testing of DAS - 8191Ø
- 7 cotton revealed no effects on i nvertebrate populations ( Section 7.2.2 ) and agronomic characteristics were found to be equivalent to non - transgenic cotton ( Section 7 ). The Endangered Species Act (ESA) (16 USC 1531) is administered by the U.S. Fish & Wildlife Service (FWS) . Under ESA, Section 6 requires federal agencies who conduct activities which may aff

ect listed species to consult with the FWS to ensure that listed species are protected should there be a potential impact . It is not anticipated that DAS 8191Ø
- 7 cotton will impact any currently listed species of concern since it is not anticipated that DA S - 8191Ø
- 7 cotton will cause new cotton acres to be planted in areas that are not already in agricultural use . Habitat disruption within DAS - 8191Ø
- 7 cotton fields would be comparable to other herbicide tolerant cropping systems. Cultivated cotton is not invasive or weedy, and these properties are not anticipated to be altered by the insertion of the genes conferring tolerance to herbicides . Based on the data, i t is reasonable to conclude that DAS - 8191Ø
- 7 cotton will not affect threatened or endangered spe cies or adversely affect or change designated critical habitats as compared to current commercial agricultural practices. 2,4 - D is not currently registered for use s specific to cotton production . The environmental fate and ecological effects on non - targe t organisms for the use of 2,4 - D in cotton will be a ddressed by the EPA as part of its review process under FIFRA . Glufosinate is currently registered for use in cotton production as a post - emergent herbicide treatment . The environmental fate and ecologi cal effects of these herbicides on non - target organisms and endangered species ha ve been addressed by the EPA as part of its review process. 8.2.1.4. Potential Impacts on Boll Weevil Eradication Program The National Boll Weevil Eradication Program (BWEP) was laun ched in the late 1970’s by USDA's Animal and Plant Health Inspection Service (APHIS) to eradicate the boll weevil in the cotton - growing areas of the U.S. Prior to implementation of the program, boll weevils were found throughout southern cotton growing sta tes, including California, Arizona, and New Mexico. By 2009, eradication was completed in all U.S. cotton growing regions exceptUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC for a small region in Texas ( National Cotton Council of America, 2013 ) . In 2012, boll weevils were captured in only three of the sixteen Texas eradicated zones, with a substantially reduced number of boll weevil s in two of the three zones ( Texas Boll Weevil Eradication Foundation Inc., 2012 ) . Eradication continues today for a small region of Texas. The BWEP and the Texas Boll Weevil Eradication Foundation (TBWEF) have developed comprehensive eradication programs over the past several decades to monitor, trap and treat infected boll weevil zones in the U . S . and northern Mexico ( Texa s Boll Weevil Eradication Foundation Inc., 2012 ; National Cotton Council of America, 2013 ) . Eradication and control of boll weevil is primary based on the use of the insec ticide malathion. This product has been highly efficacious in the control and eradication of boll weevil across the southern US. In addition to chemical control, the boll weevil eradication programs rely on and promotes farmers to use cultural controls suc h as planting during the most advantageous periods of time, harvesting early and thoroughly, and destroying crop residues and failed plantings in a timely manner ( Texas Boll Weevil Eradica tion Foundation Inc., 2012 ) . Because of the warm climate and rainfall in parts of south Texas, cotton stalks left in the field after harvest can regrow. This provides hostable cotton structure (squares and bolls) that boll weevils can use as both food and reproductive harbors, potentially increasing overwintering survivability. Methods available for the management of cotton stalks include mechanical destruction or removal (shredding, tillage, and stalk pullers), flood irrigati on, and herbicide app lication. Applied herbicides may include 2,4 - D, dicamba, thifensulf uron - methyl + tribenuronmethyl and others. Based on the cotton growing zones in Texas, The Texas Department of Agriculture has provided guidelines on appropriate cotton stalk destruction met hods ( Texas Department of Agriculture, 2013 ) . In order for destruction of cotton plants to be deemed complete, both plant s re - growing from stalks and those growing from seed must be eliminated. To ensure compliance of cotton crop destruction, the BWEP has extensive quality control measures in place to monitor and enforce the destruction of cotton plants post - harvest ( National Cotton Council of America, 2013 ) . Herbicides are typically the management option of choice , largely due to efficacy, convenience and cost. Among the herbicides labeled for the management of cotton stalks, sequential applicatio ns of 2,4 - D are most commonly used. Although methods other than 2,4 - D are currently available for the management of cotton stalks, Dow AgroSciences recognizes the utility of 2,4 - D in the BWEP and is committed to identifying other herbicides that can be used for cotton stalk control. Since 2010, Dow AgroSciences has been actively engaged in research focused on identifying alternative herbicides that meet the BWEP performance criteria of no hostable cotton structures during the prescribed period for the pe s t management zones of interest. Effective treatments which result in no hostable structure have been identified including dicamba and dichlorprop and combinations of dicamba plus dichlorprop. Additional testing will be conducted over the next several ye ars to further improve efficacy of these alternative treatments for controlling hostable structures.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC The introduction of DAS - 8191Ø
- 7 cotton in Texas is not anticipated to significantly impact the BWEP or TBWEF in the U.S or Mexico . With the exception of fields where DAS - 8191Ø
- 7 cotton is planted, the standard management practices of the BWEP and TBWEF remain unaffected. In fields planted with DAS - 8191Ø
- 7 cotton, identical, effective boll weevil control measures (mapping, trapping, in secticide control and framing practices) set forth by BWEP, TBWEF and Texas Department of Agriculture will remain effective measures for control and eradication of boll weevil populations. The only potential impact could be the need to use a herbicide stal k destruct method other than 2,4 - D that meets the BWEP performance criteria. Collaborative research by Dow AgroSciences and public - sector scientists have identified herbicides other than 2,4 - D that effectively meet the BWEP performance criteria, to mitigat e this potential impact. Dow AgroSciences is committed to the long - term success of BWEP, and will continue its efforts to identify effective herbicide alternatives and management plans for cultivation of cotton in boll weevil regions of the US . 8.2.2. Agronomic Practices – cultivation/management, weed control and volunteer management 8.2.2.1. Potential Impacts on Cultivation and Management Practices Transgenic varieties of cotton have been rapidly adopted . USDA estimates 10.3 million acres for all U.S. cotton planted in 2 013 , with 10 million of these acres being upland cotton ( USDA NASS, 2013c ) . Of those acres, 90% have been planted to transgenic varieties : 8 % are ins ect resistant varieties only, 15 % are herbicide tolerant varieties only, and 67 % are stacked varieties (herbicide resistance plus insect resistance) ( USDA NASS, 2013c ) . Current cotton cultivation and management practices incorporate the management of herbicide tolerant traits . DAS - 8191Ø
- 7 cotton is phenotypically and agronomically comparable to conventional cotton ( Section 7 ) . Ecological observations during field testing have shown no changes in ins ect susceptibility ( Section 7.2.2 ); therefore no impacts are expected on insect control practices for DAS - 8191Ø
- 7 cotton . It is anticipated that the same managemen t practices for today for herbicide tolerant cotton will also be appropriate for DAS - 8191Ø
- 7 cotton.

8.2.2.2. Potential Impact on Weed Control Practices DAS - 8191Ø
- 7 cotton will provide expanded weed management options in cotton . Post emergence applications of 2,4 - D control a broad spectrum of broadleaf weeds . 2,4 - D also has some short - lived soil residual activity ( approximately three weeks ) which provides limited residual control of l ater germinating broadleaf weeds ( Lajeunesse, 1997 ) . Thus, DAS - 8191Ø
- 7 cotton will provide greater flexibility to farmers compared to glyphosate alone in weed management systems . Inclusion of 2,4 - D would contribute to the control of glyphosate resistant and hard to control broadleaf weeds, plus slow down the selection for more glyphosate resistant broadleaf weeds ( Powles, 2008a ) . 2,4 - D is not currently registered for use on cotton; however , 2,4 - D is used for weed control in burndown programs in no - ti l l fields, due to 2,4 - D’s efficacy against broadleaf weeds, including glyphosate resistant biotype s ( University of Delaware College of Agriculture & Natural Resources, 2008 )

. 2,4 - D has app roximately three weeks of residual soil activity. F orUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC growers who choose to use 2,4 - D in a burndown regimen, a 30 day waiting interval is typically required prior to planting . T his time period may fluctuate slightly depending on the individual label. In DAS - 8191Ø
- 7 cotton, the proposed use pattern will allow application of 2,4 - D at burndown or pre - emergence (1 lb ae/A or 1120 g ae/ha) without plant back restrictions, followed by one or two post - emergence (0.5

– 1.0 lb ae/A or 560 - 1120 g ae/ha) application s at least 12 days apart , over - the - top of the cotton , up to the mid - bloom stage of development ( Figure 49 ). Thus the proposed maximum seasonal rate of 2,4 - D on cotton is estimated to be 3.0 lbs ae/ha . DAS - 8191Ø
- 7 cotton will allow growers to apply 2,4 - D from burndown or pre emergence up through t he mid - bloom stage without risk of crop injury. This will provide new options for improved weed control during the cotton development period when weeds have the greatest potential yield impact.

Figure 49 . 2,4 - D Use in DAS - 8191 Ø - 7 Cotton While 2,4 - D is currently registered as a pesticide, supporting information on proposed label changes for its use with DAS - 8191Ø
- 7 c otton is being provided by Dow AgroSciences to U.S. EPA for review . Application for Dow AgroSciences’ 2,4 - D formulation (Enlist Duo) registration on DAS - 8191Ø
- 7 cotton and tolerance petition is scheduled for submission to U . S . EPA in early 2014 with anticipated approval in mid - 2015 based on set PRIA timelines. Dow AgroSciences is also developing an extensive ste wardship program that will include technological advancements in application to reduce potential for off - target movement, as well as utilizing several media venues to educate and facilitate adoption of the technology and decision management tools to ensure the proper use and stewardship of both the trait and the associated chemical technologies . DAS’ stewardship program is detailed further in Appendix 8 .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC When combined with additional herbicide mode of actions through traditional breeding methods, DAS - 8191Ø
- 7 cotton varieties will improve weed control by allowing use of herbicide combinations or mixtures which can provide more consistent performance in post emergence weed control programs . They counteract glyphosate rate - creep (steady increase in the amount of glyphosate herbicide rates to effectively control weeds) needed over time to obtain effective weed control on hard to control weeds ( Jaehnig, 2005 ) . DAS - 8191Ø
- 7 cotton will allow use of a low cost, high performance solution to reduce the es calation of glyphosate and ALS resistance in weed populations.

8.2.2.3. Volunteer Management Commercial varieties of cotton in the U.S. are not considered weeds and are not effective in invading established ecos ystems ( USDA APHIS, 2011 ) . Cultivated cotton rarely displays any dormancy characteristics and may grow as a volunteer only under specific conditions . Any volunteers are easily controlled by herbicides or mechanical means ( Morgan et al. , 2011a ; Morgan et al. , 2011b ) . Cotton is a slow grower, and does not compete effectively with other cultivated plants or primary colonizers ( OECD, 2010 ) . Cultivated cotton is considere d self - pollinating ( OECD, 2010 ) and is not classified as a weed either in the scienti fic literature or by USDA ( USDA APHIS, 2011 ) . If DAS - 8191Ø
- 7 cotton were to cross with cotton varieties expressing tolerance to herbicides with different modes of action and produce cotton volunteers with multiple herbicide tolerance , volunteers can still be effectively controlled mechanically or with other herbicide modes of action. Additionally, agronomic practices such as appropriate variety selections, crop rotation, and rotation of herbicides with different modes of action can be used to avoid or manage volunteer cotton toleran ce to one or a few herbicides. 8.3. Herbicide Resistance Management 8.3.1. Herbicide Resistance Herbicides have revolutionized weed control in most countries around the world . Herbicides are often the most reliable and least expensive method of weed control available, but reliance upon herbicides as the primary method of weed control can have unintended consequences ( Appendix 7 ). The widespread use of herbicides can lead to weed populations that are no longer susceptible to the herbicide being used. The Weed Science Society of America defines herbicide resistance as "the inherited ability of a plant to survive and reproduce followi ng exposure to a dose of herbicide normally lethal to the wild type” ( WSSA, 2013a ) . Target plants with genes conferring resistance to a given herbicide can occur naturally within a population, but in extremely small numbers . Such pl ants remain reproductively compatible with the wild - type and can pass resistance genes on to their progeny ( Mallory - Smith, 2010 ) . Repeated use of the herbicide may allow these resistant plants to survive and repro duce . The number of resistant plants then increases in the population until the herbicide no longer effectively controls the weed . Thus, this is an evolutionary process ( Moss, 2002 ) , whereby a population changes from being susceptible to being resistant . Individual plants do not change from being susceptible to being resistant; rather, the prop ortion of resistant individuals within the population increases over time.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Herbicide resistant weeds have been a problem for growers for decades. During the 1970s, up to 30 different weed species were reported to be resistant to the triazine herbicides ( Bandeen et al. , 1982 ) . Today, there a re 403 unique cases of herbicide resistant we eds globally, with 217 species: 129 dicots and 88 monocots ( Heap, 2013c ) . A weed biotype is a sub - type or sub - population of a weed species; in this case one that has developed resistance to one or more herbicides . Report of a resistant biotype for a given weed species does not mean that weed resistance is common, widespread, or persistent in that species. There are generally many other options available to control these resistant biotypes . Table 26 shows a tabular summary of the total number of resistant species for each he rbicide mode of action as of August 2013. Two different classification systems have been developed independently by Herbicide Resistance Action Committee ( HRAC ) and the Weed Scien ce Society of America ( WSSA ) to communicate the mode of action of herbicides ; both are included in Table 26 . Weeds which have developed resistance to one herbicide may also be resistant to other herbicides which have the same mode of action. Additional information on glyphosate, the evolution of herbicide resistant weeds , and 2,4 - D can be found in Appendix 7 . 8.3.2. Factors Impacting Herbicide Resistance There are several factors to consider when assessing the risk for herbicide resistance in a weed species. Some of these relate to the biology of the weed species in question, others relate to particular farming practices . The key factors influencing a plant’s potential to develop resistance have been outlined by the HRAC , an industry initiative that fosters cooperation between plant protection manufacturers, government, researchers, advisor s and farmers . These key factors include the number or density of weeds, natural frequency of resistant plants in the population, seed soil dormancy potential, frequent use of herbicides with a similar mode of action, cropping rotations with reliance prima rily on herbicides for weed control, and lack of non - chemical weed control practices ( HRAC, 1998 ) . A matrix that can be used to evaluate the risk of selection for herbicide resistant weeds based on cropping system practices in shown in Table 27 . This table assesses the risk of herbicide resistance development for each management practice as either “low”, “medium”, or “high” . There is a high risk of resistance when limited ma nagement tools are used

– for example, sole reliance on a chemical, such as glyphosate. When additional methods are used, the risk of weed resistance decreases. Cultural controls are an effective tool in battling weed resistance; these include practices su ch as delayed planting, cultivation or plowing prior to sowing, using certified crop seed free of weeds, and others ( HRAC, 2013b ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 26 . Number of H erbicide R esistant W eeds R eported G lobally by H erbicide G roup

and M ode of A ction 1 Herbicide Group Mode of Action HRAC Group WSSA Group Example Herbicide

Total Count ALS Inhibitors Inhibition of acetolactate synthase ALS (acetohydroxyacid synthase AHAS) B 2 Chlorsulfuron 132 Photosystem II Inhibitors Inhibition of photosynthesis at photosystem II C1 5 Atrazine 71 ACCase Inhibitors Inhibition of acetyl CoA carboxylase (ACCase) A 1 Diclofop - methyl 43 Synthetic Auxins Synthetic auxins (action like indoleacetic acid) O 4 2,4 - D 30 Bipyridiliums Photosystem - I - electron diversion D 24 Paraquat 28 Ureas and Amides Inhibition of photosynthesis at photosystem II C2 7 Chlorotoluron 23 Glycines Inhibition of EPSP synthase G 9 Glyphosate 24 Dinitroanilines and others Microtubule assembly inhibition K1 10 Trifluralin 11 Thiocarbamates and others Inhibition of lipid synthesis

– not ACCase inhibition N 8 Triallate 8 Chloroacetamides and others Inhibition of cell division (inhibition of very long chain fatty acids) K3 15 Butachlor 4 Triazoles, Ureas, Isoxazolidiones Bleaching: Inhibition of carotenoids biosynthesis (unknown target) F3 11 Amitrole 5 4 - HPPD Inhibitors Bleaching: Inhibition of 4 - hydroxyphenyl pyruvate - dioxygenase (4 - HPPD) F2 27 Isoxaflutole 2 PPO Inhibitors Inhibition of protoporphyrinogen oxidase (PPO) E 14 Oxyfluorfen 6 Glutamine Synthase Inhibitors Inhibition of glutamine synthetase H 10 Glufosinate ammonium 2 Nitriles and others Inhibition of photosynthesis at photosystem II C3 6 Bromoxynil 4 Carotenoid Biosynthesis Inhibitors Bleaching: Inhibition of carotenoids biosynthesis at the phytoene desaturase step F1 12 Flurtamone 3 Arylaminopropionic Acids Unknown Z 25 Flamprop - methyl 2 Unknown Unknown Z 26 (chloro)

– flurenol 2 Mitosis Inhibitors Inhibition of mitosis / microtubule polymerization inhibitor K2 23 Propham 1 Cellulose Inhibitors Inhibition of cell wall (cellulose) synthesis L 27 Dichlobenil 1 Organoarsenicals Unknown Z 17 MSMA 1 Total herbicide resistant weeds 403 1 ( Heap, 2013a )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 27 . Assessment of R esistance R isk by E valuation of C ropping S ystems 1 Management Option Risk of Resistance Low Moderate High Herbicide mix or rotation in cropping system >2 modes of action 2 modes of action 1 mode of action Weed control in cropping system Cultural, mechanical and chemical Cultural and chemical Chemical only Use of same MOA per season Once More than once Many times Cropping system Full rotation Limited rotation No rotation Resistance status to MOA Unknown Limited Common Weed infestation Low Moderate High Control in last 3 years Good Declining Poor 1 ( Nevill et al. , 1998 ; HRAC, 2013a ) Development of herbicide resistance is often thought of as a problem caused by the herbicide itself . However, it is well documented that resistance results from management practices that have relied too heavily on a particular herbicide as the sole method of weed control . Under these conditi ons, the risk of weeds developing herbicide resistance is greatest: the best defense is diversity in weed management practices. 8.3.3. Herbicide Resistance Management Although no cases of glyphosate resistant weeds were documented for 20 years after the launch of glyphosate ( Dyer, 1994 ) , glyphosate resistant biotypes of several weed species have now been reported in the United States ( Powles, 2008b ) . This may be attributed to increased reliance on glyphosate for weed control after the launch of glyphosate tolerant soybeans (1996), cotton (1997), and corn (1998) . The adoption of genetically engineered ( GE ) technology from 1996 onwards, primarily glypho sate tolerant crops, is illustrated in Figure 50 : herbicide tolerant (HT) cotton is shown in dark blue; insect resistant (Bt) cotton is shown in green ( USDA ERS, 2013b ) . The resulting evolution of glyphosate resistant weed populations threatens the ongoing sustainability of glyphosate and its contributions to world food production ( Duke and Powles, 2008a ) . As the number of glyphosate resistant weed species increases, it becomes increasingly important for growers to introduce greater diversity into their weed management programs ( Powles, 2008a ) . Thi s diversity could be achieved with herbicide rotations/sequences, mixtures of robust herbicides with different modes of action, and use of non - herbicide weed control tools. Glyphosate is increasingly being mixed with effective doses of other herbicides to manage these hard to control and resistant weed species . New herbicide tolerant traits that allow selective use of additional herbicides with a wider weed control spectrum compared to conventional herbicides can be used to control glyphosate resistant weed populations and reduce selection pressure for additional glyphosate resistant weed species . Table 28 shows that several common weeds in U.S. agriculture which are res istant to or difficult to control with glyphosate or ALS herbicides can be effectively controlled with 2,4 - D.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 50 . Adoption of GE Crops in the U.S. Introduction of DAS - 8191Ø
- 7 cotton will give farmers one more tool for use in their weed management programs and help e nsure the long term sustainability of weed management programs, including the use of glyphosate . DAS - 8191Ø
- 7 cotton will be combined with glyphosate tolerant cotton utilizing traditional breeding techniques. The combination of herbicide tolerance traits will allow the use of multiple herbicides in an integrated weed management program to control a broad spectrum of grass and broadleaf weed species in cotton. DAS - 819 1Ø
- 7 cotton will allow use of 2,4 - D to control glyphosate resistant weeds and significantly delay the selection for glyphosate resistance in other weed species . The same benefits of DAS - 8191Ø
- 7 cotton can be extended to other herbicide tolerant cropping sy stems, such as those with tolerance to glufosinate or ALS - inhibiting herbicides. Table 28 . Glyphosate and ALS Resistant Weeds C ontrolled by 2,4 - D 1 Weed Species Glyphosate (year) 2 ALS Herbicides (year) 2 2,4 - D Common lambsquarters Difficult: Suspected Resistant (2004) Resistant (2001) Susceptible Common ragweed Confirmed Resistant (2004) Resistant (1998) Susceptible Eastern black nightshade Difficult (2004) Resistant (1999) Susceptible Giant ragweed Confirmed Resistant (2004) Resistant (1998) Susceptible Marestail (horseweed) Confirmed Resistant (2000) Resistant (2000) Susceptible Palmer amaranth Confirmed Resistant (2005) Resistant (1991) Susceptible Waterhemp spp. Confirmed Resistant (2005) Resistant (1993) Susceptible Prickly sida Difficult (2004) Resistant (1993) Susceptible 1 ( Heap, 2013c ) 2 Year first reportedUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC DAS - 8191 Ø
- 7 cotton will expand the range of herbicides that can be used in herbicide tolerant cotton production systems, improving the ease and effectiveness of managing resistant and hard to control weeds and delaying the evolution of resistance to glyphosate and other herbicides. 8.4. Summary of Environmental Consequences and Impact on Agronomic Practices Field testi ng results confirm that AAD - 12 and PAT proteins expressed in DAS - 8191Ø
- 7 cotton pro vid e robust tolerance to 2,4 - D and glufosinate respectively . There are no new phenotypic characteristics in DAS - 8191Ø
- 7 cotton to indicate it is any different from conventional cotton in weediness potential, and like conventional cotton , the risk of gene flow from DAS - 8191Ø
- 7 cotton to wild relatives in the U.S. is negligible. No significant impact is expected on current crop management practices, non - target or endangered species, crop rotation, or volunteer management from the introduction of DAS 8191Ø
- 7 cot ton . The availability of DAS - 8191Ø
- 7 cotton will have a beneficial impact on weed control practices by providing growers with another tool to address their weed control needs . The availability of DAS - 8191Ø
- 7 cotton will allow growers to proactively manage weed populations while avoiding adverse population shifts of troublesome weeds or the development of resistance. With the exception of the presence of the AAD - 12 and PAT proteins, DAS - 8191Ø
- 7 cotton is phenotypically equivalent to commercially cultivated cotton and is no more susceptible to diseases or pests than commercially cultivated cotton. Based on the data presented throughout this petition, DAS submits that DAS - 8191Ø
- 7 cotton is unlikely to pose a plant pest risk.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC 9. Adverse C onsequences of Introduction Field and laboratory testing of DAS - 8191Ø
- 7 cotton demonstrated that the transgenic cotton is substantially equivalent to non - transgenic cotton apart from the intended change of herbicide tolerance. DAS knows of no study results or other observations indicating that there would be adverse consequences from the introduction of DAS - 8191Ø
- 7 cotton.

10. Appendices Appendix 1 . Methods for Molecular Characterization of DAS - 8191 Ø
- 7 Cotton Appendix 2 . Methods and Results for Characterization of AAD - 12 Protein Appendix 3 . Methods and Results for Characterization of PAT Protein Appendix 4 . Methods for AAD - 12 & PAT Protein Expression Analysis A ppendix 5 . Methods for Compositional Analysis Appendix 6 . Compositional Literature Ranges for Non - Transgenic Cottonseed Appendix 7 . Evolution of Herbicide Resistant Weeds in Transgenic Crops Appendix 8 . Stewardship of Herbicide Tolerant Trait Technology for DA S - 8191Ø
- 7 Cotton Appendix 9 . USDA Notifications for DAS - 8191Ø
- 7 Cotton Appendix 10 . ReferencesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 1 . Methods for Molecular Characterization of DAS - 8191 Ø - 7 Cotton DAS - 8191Ø
- 7 cotton Material Transgenic cotton seeds from five distinct generations of cotton containing event DAS 8191 Ø
- 7 were planted in the gree nhouse. After at least one week of growth for emerged seedlings , leaf punches were taken from each plant and were tested for PAT protein expression using a L ateral Flow S trip (LFS) test according to the manufacturer’s instructions ( Envirologix Inc.). Each plant was given a “+” or “ - ” for the presence or absence of the PAT protein . Control Cotton Material Seeds from the non - transgenic cotton variety Coker 310 were planted in the greenhouse . The Coker 310 seeds had a genetic background representative of the transgenic seeds but did not contain the aad - 12 or pat gene s . Reference Materials DNA of the plasmid pDAB4468 was added to samples of the non - transgenic control genomic DNA at a ratio approximately equivalent to 1 copy of the transgene per cotton genome with a cotton gen ome size of ~2.2 × 10 9 bp ( Arumuganathan and Earle, 1991 ) and used as the positive control for the Southern hybridization . DIG - labeled DNA Molecular Weight Marker II and DIG - labeled DNA Molecular Weight Marker VII (Roche Diagnostics), each containing a mixture of DNA fragments with different sizes, served as size standards for agarose gel electrophoresis and Sou thern blot analysis . DNA Probe Preparation DNA probes were generated by a PCR - based inco rporation of a digoxigenin ( DIG) labeled nucleotide, [DIG ] - dUTP, into fragments generated by primers specific to gene tic elements and backbone regions from plasmid pD AB4468 . Generation of DNA probes by PCR synthesis was carried out using a PCR DIG Probe Synthesis Kit (Roche Diagnostics) . Labeled probes were purified from agarose gels and were quantified by a PicoGreen reagent (Invitrogen). Sample Collection and DNA Ex traction L eaf samples were collected from greenhouse - grown plants for genomic DNA extrac tion . Genomic DNA was extracted following a modified CTAB method . Briefly, leaf samples were ground individually in liquid nitrogen, and then CTAB extraction buffer (10 0 mM Tris - HCl, pH 8.0, 20 mM EDTA, 1.4 M NaCl, 2% CTAB, 2% PVP - 10, 2%  - ME) was added to samples at a ratio of about 5:1 plus over 10 μL each of RNase - A (Qiag en) and proteinase K (Qiagen). After approximately 2 hours of incubation at ~65 °C with gentle shaking, samples were centrifuged and the supernatants were extracted with equal volume of chlorofor m : octanol = 24:1 three times. DNA was precipitated by mixing the supernatants with approximat ely 0.7 volume of isopropanol. The precipitated DNA was rinse d with 70% ethanol, air - dried, then dissolved in appropriate volume of 1  TE buffer (pH 8.0). The resultant genomic DNA was further purified with a Genomic - tip 500/G following the manufacturer’s instructions (Qiagen). The DNA was quantified with aUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC PicoGree n reagent (Invitrogen), and was visualized on an agarose gel to check for genomic DNA quality. DNA Digestion and Electrophoretic Separation of the DNA Fragments Genomic DNA extracted from the cotton leaf tissue was digested with restriction enzy mes by com bining approximately 10  g of ge nomic DNA with approximately 5 - 10 units of the selected restriction enzyme per  g of DNA in the corresponding reaction buffer. Each sample was incubated at 37 o C overnight for digestion . The digested DNA samples were precipit ated with Quick - Precip (Edge BioSystems) and re - suspended to achieve the desired volume for gel loading . The DNA samples and molecular size markers were then electrophoresed through 0.8% agarose gels with 1  TBE buffer at 3 5 - 65 V for 18 - 22 h r to achieve fr agment separation . The gels were stained with ethidium bromide and the DNA was visualized under UV light . A photographic record was made for each stained gel. Southern Transfer DNA fragments in t he agarose gels were depurinated, denatured, neutralized in situ , and transferred to nylon membrane s in 10  SSC buffer using a wicking system . After transfer to the membrane, the DNA was fixed to the membrane by crosslinking through UV treatment. Hybridization Labeled probes were hybridized to the target DNA on th e nylon membranes using the DIG Easy Hyb Solution according to manufacturer’s instructions (Roche Diagnostics) . DIG labeled DNA molecular weight marker II and VII were used to determine the hybridizing fragment size on the Southern blots. Detection DIG - labeled probes bound to the nylon m embranes after stringent wash were incubated with Alkaline Phosphatase (AP) - conjugated anti - Digoxigenin antibody for ~1 h r at room temperature . The anti - DIG antibody specifically bound to the probes was then visualize d using CDP - Star Chemiluminescent Nucleic Acid Detection System (Roche Diagnostics) . Blots were exposed to chemiluminescent film to detect the hybridizing fragments and to visualize the molecular weight markers . The images were then scanned and stored . The number and size of all the detected band were documented for each digest and probe combination . Once the data were recorded, membranes were rinsed with milli - Q water and then stripped of the bound probe in a solution containing 0.2 M NaOH and 1.0% SDS . T he alkali - based stripping procedure successfully removes the labeled probes from the membranes, allowing them to be re - hybridized with a different DNA probe.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 2 . Methods and Results for Characterization of AAD - 12 Protein Materials & Methods for Characterization of AAD - 12 Protein DAS - 8191Ø
- 7 transgenic c otton material The AAD - 12 protein was extracted from the leaf tissue of greenhouse grown transgenic cotton event DAS - 8191Ø
- 7 (T 3 generation see Figure 4 ) . Prior to harvest, the AAD - 12 protein expression was verified by lateral flow strip testing and the leaf tissue from DAS 8191Ø
- 7 cotton was harvested, frozen, lyophilized, ground, and stored at - 80  C . Test material used for characterization of DAS - 8191Ø
- 7 cotton AAD - 12 are listed in Table 29 . Control c otton material The control cotton line had a genetic background representative of DAS - 8191Ø
- 7 cott on plants, but did not contain aad - 12 . Seeds from this isogenic non - transgenic cotton line were planted and the resulting le af tissue was harvested and processed under the same conditions as DAS - 8191Ø
- 7 cotton. AAD - 12 Reference material R ecombinant AAD - 12 protein was produced and purified from the microbe Pseudomonas fluorescens and had a molecular weight of 32 kDa . The commercially available reference substances used in this study are listed in Table 30 . Table 29 . Test Material for AAD - 12 Characterization Test Substance Source Lot Number Assay Reference Cotton AAD - 12 Cotton

DAS - 8191Ø
- 7 TSN304178 SDS - PAGE, Glycosylation, MALDI - TOF, MALDI TOF/TOF MS/MS, Activity Assay NA

Control Cotton Line isogenic / non transgenic cotton TSN304177 SDS - PAGE, Western NA Cotton crude leaf extract Cotton

DAS - 8191Ø
- 7 NA SDS - PAGE, Western NA Microbe - derived AAD - 12 Pseudomonas

fluorescens TSN030732 - 003

(466 - 028B) SDS - PAGE, Western,

Glycosylation, Activity Assay Microbe - derived AAD - 12 Pseudomonas

fluorescens TSN030732 - 002

(466 - 028A) MALDI - TOF, MALDI TOF/TOF MS/MS or ESI - LC/MSUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC
Table 30 . Commercially available reference substances for AAD - 12 Characterization Reference Substance Product Name Lot Number Assay Reference Mass Spectrometry Mass Standards Kit Mass Standards Kit

for Calibration of AB SCIEX TOF/TOF Instruments A1068 Protein sequence analysis AB SCIEX Soybean Trypsin Inhibitor (STI) A component of the

GelCode glycoprotein staining kit NH175044 Glycosylation assay ThermoFisher Horseradish Peroxidase (HRP) A component of the

GelCode glycoprotein staining kit ND171686 Glycosylation assay ThermoFisher Bovine Serum Albumin (BSA) Pre - diluted BSA

protein assay standard set NH175569 SDS - PAGE & Glycosylation assay ThermoFisher Prestained Molecular Weight Markers Novex Sharp

prestained protein standards 1167391 SDS - PAGE, western blot & Glycosylation assay Invitrogen: Molecular

Weight Markers of 260, 160, 110, 80, 60, 50, 40, 30, 20, 10, and 3.5 kDa SDS - PAGE and western blot analysis of crude cotton leaf extracts SDS - PAGE and western blot analyses of the crude protein extracts prepared from the transgenic DAS - 8191Ø
- 7 and non - transgenic - cotton leaf were performed with Bio - Rad Criterion gels fitted in a Criterion Gel chamber with XT MES running buffer (Bio - Rad) . Extracts were prepared by bead - grinding (Geno - grinder ) ~40 mg of the ground cotton leaf tissue for 3 minutes in a mi cro - centrifuge tube containing ~1.0 mL PBST supplemented with 5 mM E DTA, 23 mM β - mercaptoethanol, and protease inhibitors . Supernatants were isolated by subjecting the homogenate to centrifugation at ~20,000 × g (4 °C), and 100  L of each extract was mixed with 100  L of 2× Laemmli sample buffer (Bio - Rad) containing freshl y added  - mercaptoethanol (Bio - Rad) and heated for ~10 minutes at ~95  C . After a brief centrifugation (2 min at 20,000 × g), 30 μL of each supernatant was loaded directly on the gel . The reference standards, microbe - derived AAD - 12 and BSA (ThermoScientifi c), were diluted to an appropriate concentration and combined with freshly prepared Laemmli sample buffer containing 5%  - mercaptoethanol . The electrophoresis was conducted at a constant voltage of 150 V for ~60 minutes .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 146 of 214

Dow AgroSciences LLC After separation, the gel was cut in half and one half was stained with ThermoScientific GelCode Blue protein stain and then scanned with a densitometer (GE Healthcare) to obtain a permanent record of the gel . The remaining half of the gel was electro - blotted to a nitrocellulose membrane (Bio - Rad) with a Criterion transfer cell (Bio - Rad) for 60 minutes under a constant voltage of 100 V . The transfer buffer contained 20% methanol and Tris/glycine buffer from Bio - Rad . After transfer, the membrane was probed with an AAD 12 specific polyclonal rabbit antibody (α - AAD - 12 PAb, DAS 1197 - 167 - 2, 4.3 mg/mL) for 60 minutes (1:5000 dilution) at room temperature . A 1:10,000 dilution of conjugated goat anti - rabbit IgG (H+L) with horseradish peroxidase (ThermoScientific) was used as the secondary antibody . GE Healthcare ECL chemiluminescent substrate was used for development and visualization of the immunoreactive protein bands . The membranes were exposed to detection film (ThermoScientific) for various time points and subsequently developed with an All - Pro 100 Plus film developer. Protein purification of AAD - 12 from DAS - 8191Ø
- 7 cotton plant tissue for structural analyses An AAD - 12 immunoaffinity resin was prepared by mixing 50 μL of a slurry of Protein A/G resin (ThermoScientific) with 200 μg α - AAD - 12 mono clonal antibody and incubating overnight at 4 ° C . The resin was washed with PBST and the bound IgG irreversibly coupled to the resin by incubating in 200 μ L PBST containing 1.8 mM DSS for 6 0 minutes at room temperature with mixing . Cross - linking was terminated by incubating for 5 minutes following the addition of 500 μL o f 1.0 M Tris - HCl pH 8.0 . The resin was then washed extensively with PBST and used immediately for immune - capture of the AAD - 12 protein. To generate a cotton leaf ex tract suitable for AAD - 12 isolation, 5 - 10 grams of ground, lyophilized DAS - 8191Ø
- 7 cotton leaf tissue was suspended by stirring in cold extraction buffer (50 mM HEPES pH 7.8 , 300 mM NaCl, 10 mM EDTA) at a ratio of ~15 mL of buffer per gram of dry tissue . A protease inhibitor tablet (Roche) and 10% (w/w) PVPP were added to the suspended tissue . The mixture was stirred at 4 °C for 30 minutes to fully hydrate and extract soluble proteins . The mixture was then filtered through a single layer of pre - wetted mirac loth (Calbiochem) and the extract then further clarified by centrifugation at 38,000 × g for 30 minutes . The resulting primary supernatant was removed and mixed with an equal volume of extraction buffer supplemented with 2 M U rea and 0.2% Tween - 20 for a fi nal concentration of 1 M and 0.1% Tween - 20 respectively . To isolate AAD - 12, typically 15 mL of th e leaf extract was incubated with 50 μL of freshly prepared AAD - 12 capture resin . Binding reactions were incubated in batch at 4 °C for 3 hours to overnight . T he resin was collected by centrifugation and then successively washed twice with 1.0 mL extraction buffer containing 1 M urea + 0.1% Tween - 20 and then washed one time each with 1.0 mL extraction buffer with 0.5 M Urea + 0.05% Tween - 20 followed by 1.0 mL ex traction buffer alone . Lastly, the resin was washed once with either 1.0 mL of 50 mM HEPES pH 7.8, 0.1 mM EDTA or 1.0 mL of PBST . The resin containing captured AAD - 12 was either stored at

- 80 oC or analyzed immediately.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Detection of post - translational gl ycosylation Glycosylation analysis was used to determine whether DAS - 8191Ø
- 7 cotton AAD - 12 was post - translationally modified with covalently bound carbohydrate moieties. The resin containing the immunoaffinity - captured, cotton - derived AAD - 12 protein was mi xed with 50

– 100 μ L Laemmli sample buffer (Bio - Rad) lacking  - mercaptoethanol and the sample was then incubated at ~95 °C for 10 minutes to solubilize AAD - 12 . The microbe - derived AAD 12, soybean trypsin inhibitor, bovine serum albumin, and horseradish per oxidase were similarly diluted with 2X SDS - PAGE sample buffer to the approximate concentration of the purified cotton AAD - 12 protein . As with AAD - 12, all control proteins were also incubated for 10 minutes at ~95  C . All samples were then centrifuged at 20,000 × g for 2 minutes to obtain a clarified supernatant . The resulting supernatants were applied directly to duplicate Mini - Protean TGX gels (Bio - Rad) and electrophoresed at 1 5 0 V for ~50 minutes . After electrophoresis, one gel was stained with GelCod e Blue stain (ThermoScientific) for total protein according to the manufacturers’ protocol . After the staining was complete, the gel was scanned with a densitometer to obtain a perma nent visual record of the gel. The second gel was stained with a GelCode G lycoprotein Staining Kit (ThermoScientific) according to the manufacturers’ protocol to visualize the glycoproteins . The procedure for glycoprotein staining is briefly described as follows: After electrophoresis, the gel was fixed in 50% methanol for 30 m inutes and rinsed with 3% acetic acid . This was followed by an incubation period with the oxidation solution from the staining kit for 15 minutes . The gel was once again rinsed with 3% acetic acid and incubated with GelCode glycoprotein staining reagent fo r 30 minutes . Finally, the gel was immersed in the reduction solution for 5 minutes, and rinsed with 3% acetic acid . Glycoproteins were visualized as magenta bands on a light pink background . After the glycoprotein staining was complete, the gel was scanne d with a GE Healthcare densitometer to obtain a permanent visual record of the gel. Mass spectrometry peptide mass fingerprinting and sequence analysis of plant and microbe derived AAD - 12 protein The immunoaffinity purified plant - deriv ed AAD - 12 protein wa s subjected to in - gel digestion by trypsin, chymotrypsin, and Asp - N followed by matrix assisted laser desorption/ionization time - of - flight mass spectrometry (MALDI - TOF MS) and MALDI TOF MS - MS . Prior to each enzyme digestion , purified AAD - 12 protein was res olved on a SDS - PAGE gel and bands corresponding to AAD - 12 protein ( one band was used per digest containing approximately 100 ng per lane ) were excised with a sterile scalpel and processed as follows ( a half lane section of the standard protein of the gel w as processed alongside with the protein sample, in a separate tube, using identical procedure). Gel pieces were crushed with a sterile micro - pestle in a siliconized microcentrifuge tube, and destained as follows: 0.4 mL of 50% ACN and 0.4 mL of ammonium bi carbonate buffer were added, the tube was sealed and shaken at room temperature for 30 min in a Thermomixer R at 1100 rpm; the tube was centrifuged to settle the gel pieces, and the supernatant was removed with a pipette tip and discarded; the destaining p rocedure was repeated 2 times . The proteins were reduced and alkylated in - gel as follows: (1) 0.2 mL of DTT solution was added to gel pieces, and the tube was incubated at room temperature for 30 min in aUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Thermomixer R; (2) the tube was centrifuged, and t he DTT solution was removed by a pipette tip; (3) the gel pieces were washed with 0.5 mL of 25 mM ammonium bicarbonate buffer, the tube was centrifuged, and the buffer was removed; (4) 0.2 mL of IAA solution was added to the gel pieces, and the tube was in cubated in darkness at ambient temperature for 1 hour; (5) the gel pieces were washed twice with 0.5 mL of 25 mM ammonium bicarbonate buffer (the tube was centrifuged, and the buffer was removed after each wash) . A fter the destaining/ reduction/ alkylation procedures , the gel pieces were shrunk in neat acetonitrile and then dried in a centrifugal evaporator for 30 min . The dried gel pieces were re - hydrated with a trypsin solution (25  g in 500  L of 25 mM ammonium bicarbonate buffer, pH 7.8; prepared fresh ), chymo trypsin solution (25  g in 500  L of 1 mM HCl; prepared fresh), or Asp - N solution (2  g in 50  L of 50 mM sodium phosphate buffer, pH 8.0; prepared fresh) and incubated in an incubator at 37 o C for approximately 16 hours (overnight). Afterwards, th e peptides were extracted from the gel slices sequentially with 0.4 mL of 50% ACN/ 0.1% TFA, then 0.4 mL of 50% ACN/ 5% FA, and finally 0.4 mL of 75% ACN/ 5% FA (30 min per extraction in a Thermomixer R at room temperature, shaking at 1100 rpm). The extrac ts for each sample were combined and dried in a centrifugal evaporator. Dried peptides were reconstituted in 30  L of 0.1% TFA in water and were purified for MALDI MS analysis using C18 Zip - Tips (Millipore), according to the manufacturer’s procedure. Puri fied peptides were eluted directly onto MALDI plate sequentially, with aqueous 10%, 25%, 50%, and 75 % ACN (buffered with 0.1% TFA) . The ZipTip C18 fractions were mixed with 4 μL of CHCA matrix (10 mg/mL CHCA in 50% ACN supplemented with 0.1% TFA), and 1 μL of the sample - matrix mixture was deposited on the MALDI target and allowed to air dry. The sample preparations were analyzed directly b y MALDI - TOF mass spectrometry. All mass spectra were acquired on an AB Sciex 4800 MALDI - TOF/TOF mass spectrometer . Mas s calibration was performed with a Mass Standards Kit for Calibration of AB SCIEX TOF/TOF Instruments, consisting of the calibration mixture (theoretical monoisotopic [M+H] + m/z values used): des - Arg 1

- Bradykinin, m/z 904.4681; Angiotensin I, m/z 1296.6853; Glu 1

- Fibrinopeptide B, m/z 1570.6774; ACTH (fragment 1 - 17), m/z 2093.0867; ACTH (fragment 18 - 39), m/z 2465.1989; ACTH (fragment 7 - 38) m/z 3657.9294 . The plate wide calibration model was used for MS calibration. The peptide fragments of the cotton - derived ADD - 12 protein (including the N - and C termini) were analyzed and compared with the sequence of the microb e - derived pr otein . Activity a ssay of the AAD - 12 protein derived from DAS - 8191Ø
- 7 cotton plant tissue To prepare a cotton - derived AAD - 12 frac tion suitable for enzymatic analysis, a primary leaf extract was prepared as previously described . Following the initial centrifugation at 38,000 × g, powdered ammonium sulfate was added to the primary supernatant to achieve a final concentration of 30% . T he mixture was incubated with stirring at 4 °C for 1 hour . The sample was subjected to centrifugation at 38,000 × g for 30 minutes at 4 °C . The 30%USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 14 9 of 214

Dow AgroSciences LLC ammonium sulfate pellet was discarded and additional ammonium sulfate was added to the 30% supernatant to ac hieve a final concentration of 55% . The sample was then incubated overnight at 4 °C with stirring . The sample was again subjected to centrifugation at 38,000 × g for 30 minutes at 4 °C . The resulting supernatant was discarded and the pellet containing the bulk of the AAD - 12 was dissolved in 50 mM HEPES pH 7.8, 1 mM EDTA . The 30

– 50% ammonium sulfate protein fraction was divided into 850 μ L aliquots, snap frozen in liquid nitrogen and stored at - 80 °C . A colorimetric assay was used to assess the activity of both the cotton leaf - and microbe derived enzymes . Assays were performed in 1.5 mL Eppendorf tubes at room temperature with a total assay volume of 150 μL as previously described ( Fukumori and Hausinger, 1993 ) . Typical assays contained 10 0 mM HEPE S pH 7. 0 , 1 m M Fe (II)( SO 4 ) 2 ( NH 4 ) 2 , 1 m M sodium asco rbate, S - Dichloroprop (in DMSO), and 0.05 μM AAD - 12 . All reactions were initiated by addition of α - ketoglutarate to a final concentration of 2 mM . Prior to assay, the AAD - 12 protein was serially diluted in 50 mM HEPES pH 7.0, 1 mM EDTA to match the concentration of the cott on - derived enzyme (0.0865 μM). After the appropriate incubation time, assays were terminated by addition of 10 μ L 100 mM sodium EDTA followed by 15 μ L of borate buffer pH ~10 ( 0.3 09 g boric acid + 0.3 73 g KCl + 4 . 4 m L 1 N KOH) . Phenol products were detected by the addition of 2 μ L 2 % 4 - aminoantipyrine and 2 μ L 8% potassium ferric yanide. Following centrifugation for 30 seconds at 10,000 × g, 150 μL of the supernatant was transferred to a 96 - well plate and the absorbance at 510 nm was recorded o n a SpectraMax ® M2 microplate reader. Authentic product standard curves were run in paral lel with 2,4 dichlorophenol in the range of 0

– 125 μM added in place of substrate . Control reactions contained all reagents except for substrates. Blanks lacking enzyme were analyzed to account for the contaminati ng phenols in the substrate formulation wh ich were found to be negligible (not shown) . Kinetic experiments were performed as described with S - dichloroprop varied over a concentration range from 0

– 125 μM. Results for Characterization of AAD - 12 Protein SDS - PAGE and western blot analysis of crude cotton leaf protein extracts SDS - PAGE and western analysis was conducted to confirm the identity DAS - 8191Ø
- 7 cotton - derived AAD - 12 and to show molecular weight and immunoreactive equivalence between the microbe - derived and DAS - 8191Ø
- 7 cotton - derived AAD - 12 proteins . Both the microbe - derived AAD - 12 protein and the transgenic DAS - 8191Ø
- 7 cotton leaf extract contained a positive signal at the expected molecular weight of 32 kDa by polyclonal antibody western blot analysis ( Figure 51 ). Importantly, the non - transgenic cotton extracts and the BSA control samples did not contain any immunoreacti ve protein bands, as expected. The results demonstrated that the anti - AAD - 12 antibodies recognized the DAS 8191Ø
- 7 cotton AAD - 12 protein and t he identical migration pattern for both transgenic cotton and microbe - derived AAD - 12 strongly suggests that DAS - 8191Ø
- 7 cotton AAD - 12 is not fragmented, glycosylated or otherwise post - transla tionally modified which would add or subtract from the overall protein molecular weight. Both SDS - PAGE and westernUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 150 of 214

Dow AgroSciences LLC analysis results demonstrate the microbe - derived AAD - 12 and DAS - 8191Ø
- 7 cotton derived proteins to be equivalent in both molecular weight and immunoreactive . Purification results of DAS - 8191Ø
- 7 c otton AAD - 12 To conduct additional equivalency analysis of DAS - 8191Ø
- 7 cotton AAD - 12 to that of microbe - derived AAD - 12, AAD - 12 i mmunoaffinity precipitation was conducted on an aqueous extract of 5

– 10 grams of ground DAS - 8191Ø
- 7 cotton lyophilized transgenic leaf tissue . Proteins bound to the anti - AAD - 12 monoclonal antibody column were examined by SDS - PAGE along with the microbe - d erived AAD - 12 . For the microbe - derived AAD - 12, a single major protein band of 32 kDa was visualized following Coomassie staining of the SDS - PAGE gel and as expected, the corresponding DAS - 8191Ø
- 7 cotton - derived AAD - 12 protein was identical in size to the m icrobe - derived AAD - 12 protein ( Figure 52 ).

Lane Sample Amount Loaded M Novex prestained MW markers 10 .0  L 1 DAS - 8191Ø
- 7 cotton crude leaf extract 30 .0 μL 2 Microbe - derived AAD - 12 1.0 0  g 3 Control cotton (non - transgenic) leaf extract 30 .0  L 4 BSA protein standard 1.0 0  g 5 DAS - 8191Ø
- 7 cotton crude leaf extract 30 .0 μL 6 Microbe - derived AAD - 12 standard 1.3 0 ng 7 Blank - 8 Control cotton (non - transgenic) leaf extract 30 .0  L 9 BSA protein standard 1.25 ng Figure 51 . SDS - PAGE and Western Blot Analysis of Microbe - & DAS - 8191Ø - 7

Cotton - Derived AAD - 12 ProteinsUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 151 of 214

Dow AgroSciences LLC Predictably, the plant purified fractions contained a minor amount of impurities in addition to the AAD - 12 protein . The co - eluted proteins were likely retained on the resin by weak interactions with the column matrix or antibody leaching off of the column under the elution conditions . Ot her researchers have also reported the non - specific adsorption of proteins, peptides, and amino acids on activated agarose immunoadsorbents ( Holroyde et al. , 1976 ; Kennedy and Barnes, 1983 ; Williams et al. , 2006 ) as well as antibody leaching from the column ( Goldberg et al. , 1991 ) .

Lane Sample Amount Loaded 1 Microbe - derived AAD - 12 Standard 0.34 μg 2 Novex prestained MW markers 10 μL 3 DAS - 8191Ø
- 7 purified AAD - 12 25 μL 4 DAS - 8191Ø
- 7 purified AAD - 12 25 μL 5 DAS - 8191Ø
- 7 purified AAD - 12 25 μL 6 DAS - 8191Ø
- 7 purified AAD - 12 25 μL Figure 52 . SDS - PAGE Analysis of Immunoaffinity Purified DAS - 8191Ø - 7

Cotton Derived AAD - 12 Glycosylation detection of DAS - 8191Ø
- 7 c otton AAD - 12 protein Detection of carbohydrates, possibly covalently linked to immunoaffinity - purified DAS 8191Ø
- 7 cotton - derived AAD - 12 protein, was assessed using the GelCode GlycoproteinUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 152 of 214

Dow AgroSciences LLC Staining Kit from ThermoScientific . The purified DAS - 8191Ø
- 7 cotton AAD - 12 was electrophoresed simultaneously with a set of control and reference protein standards . As seen in the Coomassie stained gel in Figure 53 , the glycoprotein, horseradish peroxidase, was loaded as a positive control indicator for glycosylation and two non - glycoproteins, soybean trypsin inhibitor and bovine serum albumin, were employed as negative controls . As e xpected, the glycoprotein stained gel shows a positive signal from the glycosylated horseradish peroxidase positive control, while the non - glycosylated negative controls, soybean trypsin inhibitor and bovine serum albumin, show no signal . Importantly, as w ith the negative control sample s , neither the microbe - derived or DAS - 8191Ø
- 7 purified AAD 12 exhibited detectable glycosylation following glycoprotein staining . These results confirm that microbe - derived and DAS - 8191Ø
- 7 cotton derived AAD - 12 contains no de tectable covalently linked carbohydrates.

Lane Sample Amount Loaded M Novex prestained MW markers 10  L 1 Horseradish peroxidase (+ control) 0.5  g 2 Horseradish peroxidase (+ control) 1.0  g 3 Soybean trypsin inhibitor ( - control) 0.5  g 4 Soybean trypsin inhibitor ( - control) 1.0  g 5 Bovine serum albumin ( - control) 0.5  g 6 Bovine serum albumin ( - control) 1.0  g 7 Microbe - derived AAD - 12 0.5  g 8 Microbe - derived AAD - 12 1.0  g 9 DAS - 8191Ø
- 7 immunopurified AAD - 12 20 μL Figure 53 . Glycoprotein A nalysis of P urified DAS - 8191 Ø - 7 Cotton AAD - 12 Coomassie (left) and glycoprotein (right) stained SDS - PAGE gels containing control proteins and microbe derived and cotton derived AAD - 12 protein.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Results of MALDI

- TOF MS and MALDI

- TOF MS/MS amino acid sequence analysis of DAS 8191Ø
- 7 cotton - derived AAD - 12 protein To confirm the amino acid sequence of the purified DAS - 8191Ø
- 7 cotton - derived AAD - 12 protein , the purified protein was resolved by SDS - PAGE ( Figure 52 ) and the respective bands were excised and subjected to in - gel digestion with trypsin, chymotrypsin, or Asp - N . The masses of the digested DAS - 8191Ø
- 7 cotton AAD - 12 p rotein were compared with those deduced from expected masses of trypsin, chymotrypsin, and ASP - N cleavage sites in AAD 12 using Protein Analysis Worksheet (PAWS) freeware from Proteometric LLC ( Figure 54 - Figure 56 ) . The masses of the DAS - 8191Ø
- 7 cotton detected peptides were compared with the expected in silico masses to confirm the identity of the purified AAD - 12 protein.

Figure 54 . In Silico Trypsin Cleavage of DAS - 8191Ø - 7 Cotton AAD - 12 Theoretical cleavage of the AAD - 12 protein with trypsin g enerated in silico u sing Protein Analysis Worksheet (PAWS) from Proteometrics LLC . Theoretical trypsin digest peptides are indicated by the continuum of upper (black) or lower (red) case letters.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 55 . In Silico Chymotrypsin Cleavage of DAS - 8191Ø - 7 Cotton AAD - 12 Theoretical c leavage of the AA D - 12 protein with chymotrypsin g enerated in silico u sing Protein Analysis Worksheet (PAWS) from Proteometrics LLC . Theoretical trypsin digest peptides are indicated by the continuum of upper (black) or lower (red) case letters.

Figure 56 . In Silico Asp - N Cleavage of DAS - 8191Ø - 7 Cotton AAD - 12 Theoretical cleavage of the AAD - 12 protein with Asp - N generated in silico u sing Protein Analysis Worksheet (PAWS) from Proteometrics LLC . Theoretical trypsin digest peptides are indicated by the continuum of upper (black) or lower (red) case letters Figure 57 is a comprehensive peptide coverage map illustrating the peptides ide ntified and sequence verified for each endoproteinase (trypsin, chymotrypsin, and Asp - N) digest . Observed sequence coverage for trypsin, chymotrypsin and Asp - N was 61.4%, 49.1%, and 36.5%, respectively . For DAS - 8191Ø
- 7 cotton - derived AAD - 12, overall sequen ce coverage analysis was excellent at 88.1% . Peptide sequence that was missed did not contain sequence motifs that are typically required for glycosylation (N - X - S or N - X - T where X is any amino acid) ( Hamby and Hirst, 2008 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

Figure 57 . Comprehensive MS and MS/MS Sequence Coverage Map for Trypsin, Chymotrypsin and Asp - N Digest of DAS - 8191Ø - 7 Cotton - Derived AAD - 12

AAD - 12 peptide mapping - Consensus Protocol 110819 Event DAS - 8191Ø - 7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 1 M A Q T T L Q I T P T G A T L G A T V T G V H L A T L D D A 30 Trypsin 0 0 Chymotrypsin 15 15 Asp - N 26 26 Consensus 29 29

31 G F A A L H A A W L Q H A L L I F P G Q H L S N D Q Q I T F 60 Trypsin 0 0 Chymotrypsin 18 18 Asp - N 6 6 Consensus 18 18

61 A K R F G A I E R I G G G D I V A I S N V K A D G T V R Q H 90 Trypsin 25 25 Chymotrypsin 4 4 Asp - N 30 30 Consensus 30 30

91 S P A E W D D M M K V I V G N M A W H A D S T Y M P V M A Q 120 Trypsin 0 0 Chymotrypsin 6 6 Asp - N 5 5 Consensus 11 11

121 G A V F S A E V V P A V G G R T C F A D M R A A Y D A L D E 150 Trypsin 15 15 Chymotrypsin 23 23 Asp - N 6 6 Consensus 30 30

151 A T R A L V H Q R S A R H S L V Y S Q S K L G H V Q Q A G S 180 Trypsin 27 27 Chymotrypsin 20 20 Asp - N 0 0 Consensus 27 27

181 A Y I G Y G M D T T A T P L R P L V K V H P E T G R P S L L 210 Trypsin 30 30 Chymotrypsin 30 30 Asp - N 0 0 Consensus 30 30

211 I G R H A H A I P G M D A A E S E R F L E G L V D W A C Q A 240 Trypsin 30 30 Chymotrypsin 0 0 Asp - N 6 6 Consensus 30 30

241 P R V H A H Q W A A G D V V V W D N R C L L H R A E P W D F 270 Trypsin 30 30 Chymotrypsin 12 12 Asp - N 28 28 Consensus 30 30

271 K L P R V M W H S R L A G R P E T E G A A L V 293 Trypsin 23 23 Chymotrypsin 16 16 Asp - N 0 0 Consensus 23 23

Identified in MS Analysis - Trypsin Trypsin Trypsin # of AA covered 180 180 Identified in MS and MS/MS Analysis - Trypsin Chymotrypsin Chymotrypsin # of AA covered 144 144 Identified in MS Analysis - Chymotrypsin Asp - N Asp - N # of AA covered 107 107 Identified in MS and MS/MS Analysis - Chymotrypsin Consensus Consensus # of AA covered 258 258 Identified in MS Analysis - Asp - N Identified in MS and MS/MS Analysis - Asp - N Trypsin Percent Coverage 61.4 61.4 Identified in MS Analysis - Consensus Chymotrypsin Percent Coverage 49.1 49.1 Identified in MS and MS/MS Analysis - Consensus Asp - N Percent Coverage 36.5 36.5 Consensus Percent Coverage 88.1 88.1 A.a. covered by MS A.a.

covered by MS - MSUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 156 of 214

Dow AgroSciences LLC The amino acid residues at the N - and C - termini of the cotton - derived AAD - 12 protein were measured and compared with the previou sly determined sequence of the microbe - derived protein. The protein sequences were measured by MALDI - TOF, MALDI - TOF/TOF MS/MS or ESI - LC/MS. Asp - N digestion revealed that both the microbe - and DAS - 8191Ø
- 7 cotton - derived AAD - 12 N - termini were identical with the N - terminal amino acid of the cotton - derived AAD - 12 containing an acetylated alanine (A) ( Table 31 ). Table 31 . Summary of N - terminal S equences of AAD - 12 D erived P roteins Expected M 1 A 2 Q T T L Q I T P T G A T L G ... DAS - 8191Ø
- 7 N - acetyl - A 2 Q T T L Q I T P T G A T L G ... Microbe - derived A 2 Q T T L Q I T P T G A T L G ... Based on the aad - 12 DNA sequence, the N - terminal DAS - 8191Ø
- 7 cotton and microbe derived AAD - 12 protein sequence s are expected to contain a methionine residue ( Table 31 ) . This result indicated that the N - terminal methionine of the microbe - derived and DAS 8191Ø
- 7 cotto n protein s had been removed . In addition, in DAS - 8191Ø
- 7 the second amino acid alanine was acetylated . This result is encountered frequently with eukaryotic (plant) expressed proteins since approximately 80 - 90% of the N - terminal protein residues are modifi ed in such a way ( Wellner et al. , 1990 ; Polevoda and Sherman, 20 03 ) . This result determined that during or after AAD - 12 translation in cotton and P. fluorescens , the N terminal methionine is cleaved by a methionine aminopeptidase (MAP) . MAPs cleave methionyl residues rapidly when the second residue on the protein is small, such as Gly, Ala, Ser, Cys, Thr, Pro, and Val ( Walsh, 2005 ) . Also, it has been shown that protein s with serine and alanine at the N - termini are frequently acetylated ( Polevoda and Sherman, 2003 ) . The two cotranslational processes, cleavage of N terminal methionine residue and N - terminal acetylation, are by far the most common modifications and occur on the vast majority (~85%) of eukaryotic proteins ( Polevoda and Sherman, 2003 ) . However, examples demonstrating that N - terminal protein ace tylation result in biological significance are rare ( Polevoda and Sherman, 2003 ) . The C - terminal sequence of the DAS - 8191Ø
- 7 cotton - and microbe - derived AAD - 12 proteins were determined essentially as described above for AAD - 12 N - terminal sequence . The resulting amino acid C - terminal sequences were compared to the expected translated aad - 12 DNA sequence ( Table 32 ). The results indicated that the measured DAS - 819 1Ø
- 7 cotton - and microbe - derived AAD - 12 C - terminal sequences were ide ntical to the expected protein sequence , and both the cotton - and microbe - derived AAD - 12 proteins were indistinguishable and unaltered at the C - terminus.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 157 of 214

Dow AgroSciences LLC Table 32 . Summary of C - terminal S equences of AAD - 12 D erived P roteins Expected R 284 P E T E G A A L V 293 DAS - 8191Ø
- 7 R 284 P E T E G A A L V 293 Microbe - derived R 284 P E T E G A A L V 293 Results of the activity assay of the AAD - 12 protein derived from DAS - 8191Ø
- 7 cotton plant tissue To evaluate AAD - 12 enzymatic activity, kinetic assays were performed with both microb e derived and DAS - 8191Ø
- 7 cotton - derived AAD - 12 . Assays were performed for 6 minutes at 28 °C with 0.05 μM enzyme . AAD - 12 isolated from bot h P. flourescens and DAS - 8191Ø
- 7 cotton displayed the expected hyperbolic activity profiles when evaluated over a range of S dichloroprop substrate concentrations ( Figure 58 ) . Michaelis - Menten curve fitting revealed apparent K

m values of 41.2 ± 4.8 μM and 29.8 ± 1.0 μM for microb e - derived and cotton derived AAD - 12 respectively . For these assays, the apparent V max values for microb e - derived and cotton - derived AAD - 12 were also similar at 6.8 ± 0.3 and 5.0 ± 0.1 μ M /min respectively . The relative agreement in the measured kinetic parameters for both microbe - and DAS 8191Ø
- 7 cotton - derived AAD - 12 indicates that the enzymes are functionally equiv alent. Conclusions This study demonstrated that the biochemical identity and biological function of P. fluorescens - produced AAD - 12 protein was equivalent to the protein purified from the leaf tissue of DAS - 8191Ø
- 7 cotton. Both the DAS - 8191Ø
- 7 co tton and microbe - derived AAD - 12 proteins had an apparent molecular weight of 32 kDa and were immunoreactive on western blots using an AAD - 12 specific polyclonal antibody. The observation that DAS - 8191Ø
- 7 cotton and microbe - derived AAD - 12 co - migrate on both SDS - PAGE and western blots strongly indicates a lack of posttranslational modifications apart from the N - terminal acetylation. Moreover, it was experimentally determined that both DAS - 8191Ø
- 7 cotton and microbe - derived AAD - 12 are not glycosylated as empir ically determined by MALDI - MS and glycoprotein stained gels. DAS - 8191Ø
- 7 cotton - and P. fluorescens - derived AAD - 12 were equally active using S - dichloroprop as a substrate and displayed similar kinetic parameters, indicating that the proteins are enzymatic ally equivalent. Finally, the amino acid sequence of cotton - derived AAD - 12 was directly confirmed using enzymatic peptide mass fingerprinting by MALDI - TOF MS and verified by MS/MS analysis. Collectively, these data support the conclusion that the AAD - 12 pr otein produced by P. fluorescens and transgenic cotton are biochemically and functionally equivalent.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 58 . Kinetic Analysis of Microbe and DAS - 8191Ø - 7 Cotton Derived AAD - 12 Proteins with S - Dichloroprop Substrate The Michaelis - Menten plots of microbe - derived AAD - 12 (black circles) and cotton - derived AAD - 12 (blue squares) using S - D ichloroprop as a substrate for AAD - 12 . The average of three independent experiments is shown and error bars indicate the standard deviati on of the analyses.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 159 of 214

Dow AgroSciences LLC Appendix 3 . Methods and Results for Characterization of PAT Protein Mater Ø ials & Methods for Characterization of PAT Protein DAS - 8191Ø
- 7 transgenic C otton material The PAT pro tein was extracted from the leaf tissue of greenhouse grown transgenic cotto n event DAS - 8191Ø
- 7 (T 3 generation see Figure 4 ) . Prior to harvest, the PAT protein expression was verified by western blot and the leaf tissue from DAS - 8191Ø
- 7 cotton was harvested, frozen, lyophilized, ground, and stored at - 80  C. Test material used for characterization of DAS - 8191Ø
- 7 cotton PAT are listed in Table 33 . Control C otton material The control cotton line had a genetic background representative of DAS - 8191Ø
- 7 cotton plants, but did not contain the pat gene . Seeds of the non - transgenic cotton li ne were planted, grown, tested, harvested, and processed under the same conditions as DAS - 8191Ø
- 7 cotton. Microbe - Derived PAT Recombinant microb e - derived PAT protein was produced and purified from P seudomonas fluorescens and has an apparent molecular weight of ~ 20 kDa. Reference materials The commercially available reference substances used in this study ar e listed in Table 34 . Table 33 . Test Material for PAT Characterization Test Substance Source Lot Number Assay Reference Cotton PAT Cotton

DAS - 8191Ø
- 7 TSN304178 SDS - PAGE, Western blot, Glycosylation, MALDI - TOF, MALDI TOF/TOF MS/MS, Activity Assay NA

Control Cotton Line isogenic / non transgenic cotton TSN304177 SDS - PAGE, Western blot, Glycosylation, MALDI - TOF, MALDI TOF/TOF MS/MS, Activity Assay NA

Cotton crude leaf extract Cotton

DAS - 8191Ø
- 7 NA SDS - PAGE, Western NA Microbe - derived PAT Pseudomonas

fluorescens TSN303589 (ENBK

132436 - 001) SDS - PAGE, Western,

Glycosylation, MALDI TOF, MALDI - TOF/TOF MS/MS, Activity AssayUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 34 . Commercially A vailable R eference S ubstances for PAT Characterization Reference Substance Product Name Lot Number Assay Reference Mass Spectrometry Mass Standards Kit Mass Standards Kit for Calibration of AB SCIEX TOF/TOF Instruments A1068 Protein sequence analysis AB SCIEX Soybean Trypsin Inhibitor (STI) A component of the GelCode glycoprotein staining kit NH175044 Glycosylation assay ThermoFisher Horseradish Peroxidase (HRP) A component of the GelCode glycoprotein staining kit ND171686 Glycosylation assay ThermoFisher Bovine Serum Albumin (BSA) Pre - diluted BSA protein assay standard set NH175569 SDS - PAGE, Glycosylation assay ThermoFisher Prestained Molecular Weight Markers Novex Sharp prestained protein standards 1167391 SDS - PAGE, western blot, Glycosylation assay Invitrogen: Molecular

Weight Markers of 260, 160, 110, 80, 60, 50, 40, 30, 20, 10, and 3.5 kDa SDS - PAGE and western blot analysis of crude cotton leaf extracts SDS - PAGE and western blot analysis of the crude protein extracts prepared from the transgenic DAS - 8191Ø
- 7 cotton tissue and non - transgenic isoline tissue were performed with Bio - Rad Criterion gels fitted in a Criterion Gel chamber with XT MES running buffe r (Bio Rad). Extracts were prepared by Geno - grinding the ground cotton tissue at 40 mg/ mL in PBST buffer containing 5 mM EDTA, 0.16% (v/v) β - mercaptoethanol, and 1 × protease inhibitor cocktail with 2 steel beads for 3 minutes at 1,500 strokes/min in a 2 mL micro centrifuge tube. The supernatants were clarified by centrifuging the samples at ~ 20,000 × g (4 °C) for 5 minutes, and 100  L of each extract was mixed with 100  L of 2 × Laemmli sample buffer (Bio - Rad) containing freshly added β - mercaptoethanol (Bio - Rad) and heated for 5 minutes at ~95  C. After a brief centrifugation (2 min at 20,000 × g, 4 °C), 20 μL of each supernatant was loaded directly on the gel. The reference standard s , microbe - derived PAT, and control standard, BSA (Thermo Scientific), were d iluted to an appropriate concentration and combined with Laemmli sample buffer containing β - mercaptoethanol. The electrophoresis was conducted at a constant voltage of 150 V for ~ 60 minutes. After separation, the gel was cut in half and one half was stai ned with Thermo Scientific GelCode Blue protein stain and scanned with a densitometer (GE Healthcare) to obtain a permanent record of the gel. The remaining half of the gel was electro - blotted to a nitrocellulose membrane (Bio - Rad) using a Criterion trans - blot electrophoretic transfer cell (Bio - Rad) with transfer buffer containing 20% met hanol, 10% Tris/glycine buffer under a constant voltage of 100 V for 60 minutes. After transfer, the membrane was probed with a PAT specific polyclonal rabbit antibody for 60 minutes (1:40,000 dilution) at roomUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC temperature. A 1:80,000 dilution of conjugated goat anti - rabbit IgG (H+L) with horseradish peroxidase ( Thermo ) was used as the secondary antibody. Thermo Pierce ECL chemiluminescent substrate was used for development and visualization of the immunoreactive protein bands. The membrane w as exposed to detection film (Thermo Scientific) for various time points and subsequently developed with an All - Pro 100 Plus film developer. Protein purification of PAT from DAS - 8191Ø
- 7 cotton plant tissue for structural analyses The PAT protein was extracted from the ground cotton tissue using 50 mM HEPES (pH 7.8), 300 mM NaCl, 10 mM EDTA (Extraction buffer) by weighing and transferring ground leaf tissue into a chilled glass beaker and adding Extraction buffer to 20 mL per 1 gram of tissue. The tissue was mixed briefly and PVPP (insoluble) was added to the mixture at 10% (w/w ). The mixture was stirred for 20 min and the solution was filtered through 1 layer of pre wetted miracloth (Calbi ochem) and clarified by centrifugation at ~ 30,000 × g, 4 °C for 30 minutes. The supernatant was removed and co mbined with an equal volume of E xtraction buffer supplemented with 2 M urea, 0.2% Tween - 20 to yield a final extract containing 1 M urea and 0.1% T ween - 20. The PAT protein was purified from the supernatant by immuno - precipitation using polyclonal antibodies cross - linked to Protein A/G Agarose resin (Thermo Scientific) at 4 mg of antibody per milliliter of resin. For each 15 mL of clarified supernat ant, 50 μL (200  g of antibody) of coupled resin was added and allowed to incubate on a rotating mixer for 3 hours at 4 °C. The resin was recovered by centrifugation at ~ 3,50 0 × g for 5 minutes at 4 °C and the resin was transferred to a 1.5 mL microcentrif uge tube using 1 mL of wash buffer. The resin was then washed sequentially for a total of 5 washes using different buffers ( vide infra ) . Each wash was accomplished by adding buffer to the tube containing resin, rotating the tube on a mixer for ~5 min at 4 °C, centrifugi ng the sample at ~ 500 x g for 1 min, and discarding the supernatant. The resin was first washed twice with 0.9 mL of Extraction buffer su p plemented with 1 M urea and 0.1% Tween - 20, once with 0.9 mL of Extraction buffer supplemented with 0.5 M urea and 0.05% Tween - 20, once with Extraction buffer, and once with 50 mM HEPES (pH 7.8) , 0.1 mM EDTA. After the final wash, spin, and decant, the resin was centrifuged for 1 min at 500 × g at 4 °C to pellet the resin and the supernatant was discarded. Fi nally, the resin was centrifuged for 10 sec at 20,000 × g at 4 °C to pellet the resin and supernatant was again discarded . The immuno - purified protein was stored bound to the resin at - 20 °C until used for SDS - PAGE followed by mass spectrometry analysis an d SDS - PAGE followed by glycosylation analysis. Detection of post - translational glycosylation For detection of potential post - translational glycosylation, cotton - derived PAT protein was immuno - purified as described above . The resin with bound PAT protein f rom a single immuno - precipitation preparation was combined with 60 μL of 2 × Laemmli sample buffer (no β - mercaptoethanol added) and was heated at 95 °C for 5 minutes. Protein standards and controls including microbe - derived PAT, soybean trypsin inhibitor, b ovine serum albumin, and horseradish peroxidase proteins were diluted with 2 × Laemmli sample buffer (Bio - Rad) to the approximate concentration of the purified cotton - derived PAT protein and heated at 95USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC  C for 5 minutes. All samples were centrifuged at 20,000 × g for 1 minute prior to loading on SDS - PAGE gel. The resulting sample supernatants were applied directly to a Bio - Rad Mini - Protean TGX gel and were electrophoresed at 150 V for ~50 minutes. Two id entical gels were r u n in parallel and a fter electrophoresis, one gel was stained with GelCode Blue stain (Thermo Scientific) for detection of total protein according to the manufacturers’ protocol. After the staining was complete, the gel was scanned with a densitometer to obtain a permanent visual record of the gel. The second gel was stained with a GelCode Glycoprotein Staining Kit (Thermo Scientific) according to the manufacturers’ protocol to visualize the glycoproteins. The procedure for glycoprotein staining is briefly described as follows: After electrophoresis, the gel was fixed in 50% methanol for 30 minutes and rinsed with 3% acetic acid. This was followed by an incubation period with the oxidation solution from the staining kit for 15 minutes. T he gel was once again rinsed with 3% acetic acid and incubated with GelCode glycoprotein staining reagent for 30 minutes. Finally, the gel was immersed in the reduction solution for 5 minutes, and rinsed with 3% acetic acid. The glycop roteins were visualiz ed as magenta bands on a light pink background. After the glycoprotein staining was complete, the gel was scanned with a GE Healthcare densitometer to obtain a permanent visual record of the gel. Mass spectrometry peptide mass fingerprinting and sequence analysis of cotton event DAS 8191Ø
- 7 - and microbe - derived PAT proteins I mmunoaffinity purified plant - deriv ed PAT protein was subjected to in - gel digestion by trypsin and Asp - N followed by matrix assisted laser desorption/ionization time - of - flight mass spec trometry (MALDI - TOF MS) and MALDI - TOF MS - MS . For each enzyme digestion , bands resolved on a SDS - PAGE gel at ~20 kDa corresponding to PAT protein (two bands were used per digest containing approximately 100 ng per lane, resulting in 200 ng total protein per digest reaction) were excised with a sterile scalpel and processed as follows ( a half lane section of the standard protein of the gel was processed alongside with the protein sample, in a separate tube, using identical procedure). Gel pieces were crushed with a sterile micro - pestle in a siliconized microcentrifuge tube, and destained as follows: 0.4 mL of 50% ACN and 0.4 mL of ammonium bicarbonate buffer were added, the tube was sealed and shaken at room temperature for 30 min in a Thermomixer R at 1100 rp m; the tube was centrifuged to settle the gel pieces, and the supernatant was removed with a pipette tip and discarded; the destaining procedure was repeated 2 times . The protein s were reduced in - gel as follows: (1) 0.2 mL of DTT solution was added to the gel pieces, and the tube was incubated at room temperature for 30 min in a Thermomixer R; (2) the tube was centrifuged, and the DTT solution was removed by a pipette tip; (3) the gel pieces were washed twice with 0.5 mL of 25 mM ammonium bicarbonate buffe r, the tube was centrifuged, and the buffer was removed . A fter the destaining/ reduction procedures, the gel pieces were shrunk in neat acetonitrile and then dried in a centrifugal evaporator for 30 min.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC The dried gel pieces were re - hydrated with a trypsi n solution (25  g in 500  L of 25 mM ammonium bicarbonate buffer, pH 7.8; prepared fresh) or Asp - N solution (2  g in 50  L of 50 mM sodium phosphate buffer, pH 8.0; prepared fresh) and incubated in an incubator at 37 o C for approximately 16 hours (overnight). Afterwards, the peptides were extracted from the gel slices sequentially with 0.4 mL of 50% ACN/ 0.1% TFA, then 0.4 mL of 50% ACN/ 5% FA, and finally 0.4 mL of 75% ACN/ 5% FA (30 min per extraction in a Thermomixer R at room temperature, shaki ng at 1100 rpm). The extracts for each sample were combined and dried in a centrifugal evaporator. Dried peptides were reconstituted in 30  L of 0.1% TFA in water and were purified for MALDI MS analysis using C18 Zip - Tips (Millipore), according to the man ufacturer’s procedure. Purified peptides were eluted directly onto MALDI plate sequentially, with aqueous 10%, 25%, 50%, and 75 % ACN (buffered with 0.1% TFA) . The ZipTip C18 fractions were mixed with 4 μL of CHCA matrix (10 mg/mL CHCA in 50% ACN supplement ed with 0.1% TFA), and 1 μL of the sample - matrix mixture was deposited on the MALDI target and allowed to air dry. The sample preparations were analyzed directly by MALDI - TOF mass spectrometry . All mass spectra were acquired on an AB Sciex 4800 MALDI - TOF/T OF mass spectrometer . Mass calibration was performed with an Mass Standards Kit for Calibration of AB SCIEX TOF/TOF Instruments, consisting of the calibration mixture (theoretical monoisotopic [M+H] + m/z values used): des - Arg 1

- Bradykinin, m/z 904.4681; Ang iotensin I, m/z 1296.6853; Glu 1

- Fibrinopeptide B, m/z 1570.6774; ACTH (fragment 1 - 17), m/z 2093.0867; ACTH (fragment 18 - 39), m/z 2465.1989; ACTH (fragment 7 - 38) m/z 3657.9294 . The plate wide calibration model was used for MS calibration. The peptide fragme nts of the cotton - derived PAT protein (including the N - and C - termini) were analyzed and compared with the sequence of the microb e - derived pr otein . Protein purification of PAT from DAS - 8191Ø
- 7 cotton plant tissue for functional analyses The PAT protein was extracted with 350 mL of 50 mM Tris (pH 7.5), 150 mM NaCl, 1 mM EDTA, 1 mM TCEP, supplemented with 1% PVPP (polyvinylpolypyrrolidone, insoluble) and a protease inhibitor cocktail by blending ground cotton leaf tissue (15 g) using a stic k blender (~1 g of tissue per 20 mL of buffer). The blended material was strained through 2 layers of pre - wetted Miracloth (Calbiochem), and clarified by centrifuging at ~ 35,000 × g, 4 °C for 45 minutes to remove all particulates and PVPP. The supernatan t was transferred to a pre - chilled beaker and solution was stirred at 4 °C. Ammonium sulfate was slowly added to the extract over a 1 hr time - course until 40% ammonium sulfate saturation was achieved. The solution was stirred for an additional 2 hrs follow ing final addition of salt. The solution was centrifuged at 35,000 × g, 4 °C for 60 minutes to remove precipitated proteins. The supernatant, containing PAT, was collected and returned to the chille d beaker at 4 °C with stirring. Ammonium sulfate was add ed to the extract over 1 hr until a concentration of 70% sa t uration was reached. The solution was allowed to equilibrate overnight. TheUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 164 of 214

Dow AgroSciences LLC precipitated protein material was pelleted by centrifuging the mixture at ~ 35,000 × g, 4 °C for 60 minutes and the super natant was discarded. The pellet containing PAT was resuspended in 45 mL of chilled HIC Buffer A (HIC Buffer A = 50 mM Tris (pH 7.5), 5% glycerol with 1.25 M ammonium sulfate; HIC Buffer B = 50 mM Tris (pH 7.5), 5% glycerol). The resuspension was centrifug ed at ~ 35,000 × g, 4 °C for 60 minutes to remove any non - dissolved particulates prior to chromatography. The clarified supernatant was loaded onto a 10 mL Phenyl HP HiTrap column (two 5 mL columns connected in serial, GE Healthcare) equilibrated in HIC B uffer A. The column was washed with 15 column volumes (CV) of HIC Buffer A, followed by 5 CV of 5% HIC Buffer B. The bound proteins were eluted with a 50 CV linear elution gradient to 100% HIC Buffer B. Fractions (3.5 mL volume) were collected starting at 10% HIC Buffer B conditions and odd fractions were assayed for PAT content by Lateral Flow Strip Assay (Envirologix, Inc) and by the PAT Activity Assay. Fractions containing the PAT protein were pooled and concentrated using a 10 kDa MWCO filter device ( Amicon) from 122.5 mL to 4.2 mL. The salt content of the concentrated sample was adjusted to match the initial chromatographic conditions (100% HIC Buffer A) and was loaded onto a 9.4 mL Phenyl HP HiScreen column (two 4.7 mL columns connected in serial, GE Healthcare) equilibrated in HIC Buffer A. The column was washed with 6 column volumes (CV) of HIC Buffer A, and the bound proteins were eluted with a 20 CV linear elution gradient to 100% HIC Buffer B. Fractions (2.0 mL volume) were collected starting at 0% HIC Buffer B conditions and odd fractions were assayed for PAT content by Lateral Flow Strip Assay (Envirologix, Inc) and by the PAT a ctivity a ssay. Fractions containing the PAT protein were pooled and concentrated using a 10 kDa MWCO filter device (A micon) from 46 mL to 3.0 mL. The concentrated sample was then applied to a 120 mL HiLoad 16/600 Superdex 200 column (GE Healthcare) equilibrated with 50 mM Tris (pH 7.5), 150 mM NaCl, and 5% glycerol. One - milliliter fractions were collected and assayed for PAT content by Lateral Flow Strip (Envirologix, Inc) and by the PAT Activity Assay. Fractions containing the PAT protein were pooled and concentrated using a 10 kDa MWCO filter device (Amicon) from 8 mL to 0.8 mL. The final purification product was aliquo ted, flash frozen in liquid nitrogen, and stored at - 80 °C. Activity a ssay of the PAT protein derived from DAS - 8191Ø
- 7 cotton plant tissue Cotton - derived PAT was purified using traditional purification procedures as described above . The activity of both t he cotton - and microbe - derived enzymes was verified using an established spectrophotometric assay with minor modifications ( De Block et al. , 1987 ; Mahan et al. , 2006 ) . Assays were performed in 96 - well plates at room temperature in a total volume of 150 μL (a 150 μL total volume results in a 0.446 cm path length). Assays contained 50 mM HEPES (pH 7.0), 1 mM EDTA, 1 mM 5,5' - dithiobis - 2 - nitrobenzoic acid (DTNB), 500 μM of acetyl CoA, 25 nM PAT, and varied levels of DL - glufosinate (25 μM

– 2 mM). Reactions were initiated by the addition of acetyl - CoA and the absorbance at 412 nm was rec orded every 30USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC seconds for a total of 5 minutes o n a Molecular Devices SpectraMax ® M2 plate reader . Separate positive control reactions were assayed using microbe - derived PAT at the same concentration as the plant - derived protein (25 nM). Negative control reactions were assayed in the absence of DL - glufosinate to monitor non - specific acetyl - CoA consumption. All reactions were run in triplicate. PAT activity was quantified by measuring the liberation of the free CoA sulfhydryl group which forms concomitant ly with transfer of the acetyl group to glufosinate . The reaction of the sulfh ydryl group of free CoA with DTNB yields a molar equivalent of the chromophore 5 - thio - 2 - nitrobenzoic (ε = 14,150 M - 1 cm - 1 at 412 nm ). The initial rates were determined from the raw data, and were corrected for non - specific acetyl - CoA consumption (based upon control reactions lacking glufosinate) and converted to μM/min. A racemic mixture of glufosinate was used for the assays; therefo re the final values are presented as a function of L - glufosinate, the active enantiomer. These converted initial rates were plotted against L glufosinate concentrations and subsequently fitted to the Michaelis

– Menten equation allowing for the extrapolation of K m and V

max . The data were analyzed using KaleidaGraph software (v.4.03) . Results for Characterization of PAT Protein SDS - PAGE and western blot analysis of cotton leaf protein extracts SDS - PAGE and western analysis was conducted to confirm the identi ty DAS - 8191Ø
- 7 cotton - derived PAT and to show molecular weight and immunoreactive equivalence between the microbe - derived and DAS - 8191Ø
- 7 cotton derived PAT proteins . For the microbe derived PAT protein, the major pro tein band was approximately ~20 kDa ( Figure 59 ) as visualized on Coomassie stained SDS - PAGE gels. As expected, the corresponding DAS 8191Ø
- 7 cotton - derived PAT protein was visualized by immunospecific polyc lonal antibodies at an identical size to the microbe - expressed protein. In the PAT w estern blot analysis, no immunoreactive proteins, consistent with the PAT protein, were observed in the control isoline extract or the BSA lanes ( Figure 59 ) . The results demonstrated that the anti PAT antibodies recognized the DAS - 8191Ø
- 7 cotton PAT protein and the identical migration pattern for both transgenic cotton - and microbe - derived PAT s trongly suggests that the PAT protein expressed in cotton is not post - translationally glycosylated ( note: the PAT enzyme does not contain N - glycosylation sites ( Herouet et al. , 2005 ) ) or processed in such a manner which would have added to or subtracted from the overall protein molecular weight. Both SDS - PAGE and western analysis results demonstrate the microbe - derived PAT and DAS 8191Ø
- 7 cotton derived proteins to be equivalent in both mo lecular weight and immunoreactive . Purification results of DAS - 8191Ø
- 7 c otton PAT for structural analysis To conduct additional equivalency analysis of DAS - 8191Ø
- 7 cotton - derived PAT to that of microbe - derived PAT, i mmuno - precipitation was conducted on an aqueous extract of ~6 grams of ground DAS - 8191Ø
- 7 cotton leaf tissue to further purify the DAS - 8191Ø
- 7 cotton derived PAT protein . The total protein bound to the polyclonal antibody resin was examined by SDS - PAGE analysis which demonstrated that DAS - 819 1Ø
- 7 cotton - derived PAT protein from the tissue extract with an approximate molecular weight of ~20 kDa was capturedUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
- 7 Cotton Page 166 of 214

Dow AgroSciences LLC during the immuno - precipitation procedu re ( Figure 60 ) . Following immuno - precipitation, the DAS - 8191Ø
- 7 cotton - derived PAT was then compared with the microbe - derived protein. For the microbe - derived PAT protein, the major protein band was appro ximately 20 kDa ( Figure 60 ) as visualized on Coomassie stained SDS - PAGE gels.

Lane Sample Amount Loaded M Novex Sharp Pre - Stained MW marker 10 .0  L 1 Bovine Serum Albumin (BSA) 1.0 0 μg 2 Control cotton (non - transgenic) leaf extract 20 .0  L 3 Microbe - derived PAT 1.0 0  g 4 DAS - 8191Ø
- 7 cotton extract 20 .0  L 5 Bovine Serum Albumin 1.25 ng 6 Control cotton (non - transgenic) leaf extract 20 .0  L 7 No sample --- 8 Microbe - derived PAT 1.3 0 ng 9 DAS - 8191Ø
- 7 cotton crude leaf extract 20 .0  L Figure 59 . SDS - PAGE and W estern B lot A nalysis of M icrobe - and DAS - 8191Ø - 7 C otton - D erived PAT P roteinsUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Lane Sample Loaded 1 Microbe - derived PAT 0.5 0  g 2 No sample --- 3 Novex Sharp Pre - Stained MW marker 10 .0  L 4 No sample --- 5 DAS - 8191Ø
- 7 immunopurified PAT 25 .0  L 6 DAS - 8191Ø
- 7 immunopurified PAT 25 .0  L 7 DAS - 8191Ø
- 7 immunopurified PAT 25 .0  L 8 DAS - 8191Ø
- 7 immunopurified PAT 25 .0  L Figure 60 . SDS - PAGE A nalysis of the I mmuno affinity Purified DAS - 8191Ø - 7 Cotton Derived PAT As expected, the corresponding cotton - derived PAT protein was visualized by immunospecific polyclonal antibodies at an identical size to the microbe - expressed protein ( Figure 60 ) . The plant - derived immuno - precipitation samples contained a minor amount of impurities in addition to the full - length PAT protein. The co - bound proteins were likely retaine d to the resin by weak interactions with the matrix or antibody released during sample preparation for SDS - PAGE analysis. Other researchers have also reported the non - specific adsorption of proteins, peptides, and amino acids on activated agarose immuno - ad sorbents ( Holroyde et al. , 1976 ; Kennedy and Barnes, 1983 ; Williams et al. , 2006 ) as well as antibody leaching from the resin ( Goldberg et al. , 1991 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Results of detection of glycosylation of PAT protein Detection of carbohydrates, possibly covalently linked to DAS - 8191Ø
- 7 cotton - derived PAT protein, was assessed by resolving immuno - precipitated PAT using SDS - PAGE followed by visualization of the gel with a stain that specifically detects glycosylated proteins. The immunoaffinity - purified DAS - 8191Ø
- 7 cotton PAT protein was e lectrophoresed simultaneously with a set of control and reference protein standards. A glycoprotein, horseradish peroxidase, was loaded as a positive control indicator for glycosylation, and non glycoproteins including microbe - derived PAT, soybean trypsin inhibitor, and bovine serum albumin, were employed as negative controls.

Lane Sample Amount Loaded M Novex Sharp Pre - Stained MW marker 10 .0  L 1 Horseradish Peroxidase (+ control) 0.5 0  g 2 Horseradish Peroxidase (+ control) 1.0 0  g 3 Soybean Trypsin Inhibitor ( - control) 0.5 0  g 4 Soybean Trypsin Inhibitor ( - control) 1.0 0  g 5 Bovine Serum Albumin ( - control) 0.5 0  g 6 Bovine Serum Albumin ( - control) 1.0 0  g 7 Microbe - derived PAT 0.5 0  g 8 Microbe - derived PAT 1.0 0  g 9 DAS - 8191Ø
- 7 immunopurified PAT 25 .0  L Figure 61 . Glycoprotein Analysi s of Immunopurified DAS - 8191Ø - 7 D erived PAT SDS - PAGE gels containing microbe - and cotton - derived PAT protein and standards visualized for total protein and glycoprotein stains.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC As expected, the glycoprotein stained gel shows a positive signal from the glycosylated horseradish peroxidase positive control, while the non - glycosylated negative controls, soybean trypsin inhibitor and bovine serum albumin, shows no signal. As with the negative control sample, both the microbial - derived and DAS - 8191Ø
- 7 cotton purified PAT samples were not detected on the glycoprotein stained gel. This was anticipated as the PAT protein does not contain any sites predicted for N - glycosylation, the most common form of glycosylation found on proteins ( Herouet et al. , 2005 ) . The results showed that both the DAS - 8191Ø
- 7 cotton and microbe - derived PAT proteins had no detectable covalently linked carbohydrates ( Figure 61 ). Results of MALDI

- TOF MS and MALDI

- TOF MS/MS tryptic and Asp - N peptide sequencing of DAS - 8191Ø
- 7 cotton - deriv ed PAT protein The PAT protein derived from DAS - 8191 Ø
- 7 cotton tissue was separated by SDS - PAGE ( Figure 60 ) and the respective bands were excised and subjected to in - gel digestion by trypsin and Asp - N endoproteases . The resulting peptide mixture was analyzed by MALDI TOF MS and sequence verified by MS/MS to determine the pep tide sequences . The masses of the dete cted peptides were compared with the expected masses based on trypsin or Asp - N cleavage sites in the sequence of the cotton - derived PAT protein. Figure 62 and Figure 63 illustrate the theoretical cleavage of the PAT protein generated in silico using Protein Analysis Worksheet (PAWS) freeware from Proteometrics LLC. The PAT protein , once denatured, is readily digested by endoproteases to yield numerous peptides that are able to be detected using mass spectrometry.

Figure 62 . In Silico Trypsin Cleavage of DAS - 8191Ø - 7 Cotton PAT Theoretical cleavage of the PAT protein with trypsin generated in silico using Protein Analysis Worksheet (PAWS) from Proteometrics LLC. Trypsin endoprotease specifically hydrolyzes protein and peptide bonds C - terminally of lysine and arginine. Theoretical trypsin digest peptides are indicated by the continuum of upper (black) or lower (red) case letters.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 63 . In Silico Asp - N Cleavage of DAS - 8191Ø - 7 Cotton PAT Theoretical cleavage of the PAT protein with Asp - N generated in silico using Protein Analysis Worksheet (PAWS) from Proteometrics LLC. Asp - N endoprotease specifically hydrolyzes protein and peptide bonds N - terminally of aspartic acid. Theoretical Asp - N digest peptides are indicated by the continuum of upper (black) or lower (red) case letters . In the endoprotease digests of the transgeni c cotton - derived PAT protein, the peptide sequence coverage from peptide mass fingerprint (PMF) data was extensive at 91.3%. Of the 91.3% sequence coverage from PMF data, all peptide sequences were confirmed by tandem mass spectrometry sequencing. The dete cted peptide fragments covered nearly the entire protein sequence with only a few peptide fragments undetected ( Figure 64 ). This analysis confirmed the DAS - 8191Ø
- 7 cot ton - derived protein amino acid sequence matched that of the microbe - derived PAT protein at the N - and C - terminus as well as a major portion of the internal sequence . Table 35 . Summary of N - terminal S equences of PAT D erived P roteins Expected M 1 S 2 P E R R P V E I R P A T A A DAS - 8191Ø
- 7 S 2 P E R R P V E I R P A T A A Microbe - derived S 2 P E R R P V E I R P A T A A Table 36 . Summary of C - T erminal S equences of PAT D erived P roteins Expected P 173 P R P V R P V T Q I 183 DAS - 8191Ø
- 7 P 173 P R P V R P V T Q I 183 Microbe - derived P 173 P R P V R P V T Q I 183 Based on the described results, one post - translational modification was observed for the DAS - 8191 Ø
- 7 cotton - derived PAT protein which included the removal of the N - terminal methionine. The excision of Met at position 1 is a common modification found in plant expressed proteins ( Li and Chang, 1995 ) . No other post - translational modifications were observed. Collec tively, the mass spectrometry data, glycosylation staining, and SDS - PAGE western blot analyses all provide evidence for the lack of glycosylation of both the DAS 8191 Ø
- 7 cotton - derived PAT and the microbe - derived PAT proteins. The results of these analyses indicate that the amino acid sequence of the DAS - 8191 Ø
- 7 cotton - derived PAT protein was equivalent to the P. fluorescens - expressed protein previously characterized .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Figure 64 . Comprehensive MS and MS/MS S equence C overage Map f or T rypsin and Asp - N digests of DAS - 8191 Ø - 7 Cotton - Derived PAT Sequence coverage was 91.3% with PMF data and 91.3% by tandem MS. Results of the enrichment and activity assay of the PAT protein derived from DAS - 8191Ø
- 7 cotton plant tissue Microbe and DAS - 8191Ø
- 7 cotton - derived PAT proteins were assayed using an established spectrophotometric assay with minor modifications ( De Block et al. , 1987 ; Mahan et al. , 2006 ) . Both the DAS - 8191Ø
- 7 cotton and microbe - derived PAT displayed hyperbolic kinetic plots when evaluated over a range of glufosinate concentrations (Figure 9). Michaeli s Menten curve fitting revealed that microb e and DAS - 8191Ø
- 7 cotton - derived PAT have similar V

max values of 9.30 ± 0.10 and 7.19 ± 0.06 μM/min, respectively. The K m value for the microbe - derived PAT (150 ± 3 μM) was comparable to that of the cotton - derived enzyme (117 ± 4 μM). Both enzyme preparations also displayed similar k cat values of 6.20 s - 1 for microbe - derived and 4.80 s - 1 for cotton - derived PAT. The calculated catalytic efficienciesUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC ( k cat /K m ) were nearly i dentical at 4.13 x 10 4 and 4.11 x 10 4 M - 1 s - 1 for both the microbe - and DAS - 8191Ø
- 7 cotton - derived enzymes, respectively. These results demonstrate that PAT derived from DAS - 8191Ø
- 7 cotton leaf displays similar kinetic parameters to PAT purified from P. fl uorescens and are therefore functionally equivalent .

Figure 65 . Kinetic Analysis of Microbe - and DAS - 8191Ø - 7 Cotton - Derived PAT Proteins The Michaelis - Menten plots of microbe - derived PAT (black circles) and cotton - derived PAT (blue squares) using L - Glufosinate as a substrate for PAT . The average of three independent experiments is shown and error bars indicate the standard deviation of the analyses. Conclusions It was demonstrated that the biochemical identity and biological f unction of the microbe derived PAT protein was equivalent to the protein purified from leaf tissue of cotton event DAS - 8191 Ø
- 7. Both the cotton - and microbe - derived PAT proteins had an apparent molecular weight of ~ 20 kDa and were immunoreactive to a PAT p rotein - specific polyclonal antibody in western blot assays. Greater than 90% of the amino acid sequences were confirmed by enzymatic peptide mass fingerprinting by MALDI - TOF MS and verified by MS/MS. The lack of glycosylation of the cotton - derived PAT prot ein provided additional support that the PAT protein produced by P. fluorescens and transgenic cotton were equivalent. Enzymatic activity assays using glufosinate as a substrate were performed to evaluate the kinetic parameters of both enzymes. These resul ts demonstrate that PAT derived from DAS - 8191Ø
- 7 cotton leaf displays similar kinetic parameters to PAT purified from Pseudomonas fluorescens . Collectively, these biochemical tests indicate that the plant - and microbe - derived PAT proteins are biochemically and biologically equivalent and therefore the microbe - derived protein is acceptable for use in regulatory studies.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 4 . Methods for AAD - 12 & PAT Protein Expression Analysis Experimental Design Cotton samples were collected from a field study conducted in the U.S. in 2012 that included six (6) field sites; Alabama, Georgia, Louisiana, Missouri, North Carolina, and Texas. Each site consisted of one plot of each treatment per b lock, with 4 blocks per location. Plots were arranged in a randomized complete block (RCB) design, with a unique randomization at each site. Plot size was 4 rows by 25 feet with row spacing of approximately 30 - 40 inches. Each cotton plot was bordered by 2 rows of non - transgenic cotton of similar maturity. Blocks were separated from each other and outside border rows by an alley of at least 10 ft of bare soil or a non ‐ sexually compatible non ‐ crop buffer (e.g., turf g rass ) . At each location, all blocks were u sed for collection of samples for protein expression analysis. With the exception of seed, expression samples wer e collected from rows 1 and 4 of each four row plot. Seed expression samples were collected from rows 2 and 3 (the center two rows) of each fou r row plot. Herbicide treatments were designed to replicate maximum label rates . 2,4 - D plus glufosinate Treatment: 2,4 - D (GF - 2654) + Glufosinate (Ignite 280 SL) as a tank mixture was applied as two broadcast applications to DAS ‐ 8191Ø ‐ 7 cotton . Individual applications were at approximately 3 node and 6 node stages. Individual target application rates were 1.0 lb ae/A for GF - 2654, or 1120 g ae/ha. Individual target application rates were 0.53 lb ae/A for Ignite 280 SL, or 596 g ai/ha. Tissue Sam pling and Processing Tissue Sampling A total of ten tissue samples were collected for AAD - 12 and PAT protein expression analysis . Details of each tissue type are as described: a. Leaf (4 - leaf, first white bloom, and first open boll growth stages ) One leaf sample per plot (representing 10 - 14 leaves collected from separate plants) was collected for each test and control entry. Each leaf was collected from a different plant in the plot. Each leaf sample was the youngest set of fully expanded leaves. b. Squares (first white bloom growth stage) One square sample per plot (representing 10 - 14 squares) was collected for each test and control entry. Each square was collected from a different plant in the plot consisting of a flower bud and bracts, but not the stem. c. Pollen (early bloom growth stage) One pollen sample per plot (representing a volume of 0.2 - 0.5 mL of pollen) was collected from each plot for each test and control entry. Each pollen sample was collected across the plants within each plot from wh ite flowers just starting to open.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC d. Flower (peak bloom growth stage) One flower sample per plot (representing 14 - 18 flowers) was collected for each test and control entry. Each flower consisted of white flowers from a different plant in the plot. e. Bolls (peak bloom) One boll sample per plot (representing 10 - 14 bolls) was collected for each test and control entry. Each boll was collected from a different plant in the plot. Boll samples were either open or closed on the first position of fruiting bran ches. f. Root (Maturity) One root sample (representing 1 - 2 plants) per plot was collected for each test and control entry at the maturity stage by cutting a circle around the base of the plant. The root ball was removed and cleaned. g. Whole plant One forage sample (representing 3 plants) per plot, each consisting of the aerial portion (no roots) of 3 whole plants was collected from each test and control entry. h. Seed (Maturity) One individual sample was collected from each plot of each test and co ntrol entry. Each sample contained approximately 500 grams of grain. Tissue Processing Samples were shipped to Dow AgroSciences laboratories and maintained frozen until use. Samples of cotton tissues were prepared for expression analysis by coarse grindi ng, lyophilizing and/or fine - grinding with a Geno/Grinder (Certiprep, Metuchen, NJ). Determination of AAD - 12 Protein in Cotton Tissue Samples ELISA method DAS 120999 was used to determine AAD - 12 protein concentration in cotton tissue samples . AAD - 12 Pr

otein Extraction and Analysis The AAD - 12 protein was extracted from cotton tissues except grain and pollen with a phosphate buffered saline solution containing 0.05% (v/v) Tween - 20 (PBST), 0.75% ovalbumin (OVA) and 1.0% p olyvinylpyrrolidone ( PVP). For grain and pollen, the protein was extracted with a phosphate buffered saline solution containing 0.30% (v/v) Tween - 20 (PBST), 0.75% OVA and 1.0% PVP. The plant tissue and grain extracts were centrifuged; the aqueous supernatant was collected, diluted with appropriate buffer if necessary, and analyzed using an AAD - 12 ELISA kit. Briefly, an aliquot of the diluted sample and a horseradish peroxidase (HRP)/ anti - AAD - 12 monoclonal antibody conjugate were incubated in the wells of a microtiter plate coated with an immobilized anti - AAD - 12 polyclonal antibody. These antibodies bind with AAD - 12USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC protein in the wells and form a "sandwich" with AAD - 12 protein bound b etween soluble and the immobilized antibodies. The unbound samples and excess conjugate were then removed from the plate by washing with PBST. Subsequent addition of an enzyme substrate generated a colored product. The reaction was stopped by adding a dilu te acid solution. Since the AAD - 12 was bound in the antibody sandwich, the level of color development, determined by measuring the absorbance of the solution, was related to the concentration of AAD - 12 in the sample (i.e., lower protein concentrations re sult in lower color development). The absorbance at 450 nm with a background subtraction at 650 nm was measured using a Molecular Devices Spectra Max M2 plate reader or a Grifols Triturus Automated Immunoassay Analyzer. A calibration curve was generated an d the AAD - 12 concentration in unknown samples was calculated from the polynomial regression equation using Soft - MAX ProTM or Triturus Version 4.01B software which was compatible with the plate reader. Samples were analyzed in duplicate wells with the averag e concentration of the duplicate wells being reported. The Limit of Detection (LOD) and Limit of Quantitation (LOQ) of the AAD - 12 ELISA in the tissue matrices were as follows: Tissue AAD - 12 (ng/mg)

LOD LOQ Bolls 0.5 1 Flower Leaf Pollen Root Seed Squares Whole Plant Determination of PAT Protein in Cotton Tissue Samples ELISA method GRM07.26 was used to determine PAT protein concentration in cotton tissue samples . PAT Protein Extraction and Analysis The PAT protein was extracted from cotton tissues with a phosphate buffered saline solution with 0.05% Tween - 20 (PBST) and 1.0% polyvinylpyrrolidone (PVP). The extract was centrifuged; the aqueous supernatant was collected, diluted with PBST/1.0% PVP if ne cessary, and analyzed using a PAT ELISA kit. Briefly, an aliquot of the diluted sample was incubated with enzyme - conjugated anti - PAT monoclonal antibody and anti - PAT polyclonal antibodies coated in the wells of a 96 - well plate in a sandwich ELISA format. A t the end of the incubation period, the unbound reagents were removed from the plate by washing. Subsequent addition of an enzyme substrate generated a colored product. The reaction was stopped by adding a dilute acid solution.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Sinc e PAT was bound in the antibody sandwich, the level of color development, determined by measuring the absorbance of the solution, was related to the concentration of PAT in the sample ( i.e. , lower residue concentrations result in lower color development). The absorbance at 450 nm with a background subtraction at 650 nm was measured using a Molecular Devices Spectra Max M2 plate reader or a Grifols Triturus Automated Immunoassay Analyzer. A calibration curve was generated and the PAT concentration in unknown samples was calculate d from the polynomial regression equation using Soft - MAX ProTM or Triturus Version 4.01B software which was compatible with the plate reader. Samples were analyzed in duplicate wells with the average concentration of the duplicate wells being reported. The Limit of Detection (LOD) and Limit of Quantitation (LOQ) of the PAT ELISA in the tissue matrices were as follows: Tissue PAT (ng/mg) LOD LOQ Bolls 0.025 0.06 Flower Leaf Pollen Root Seed Squares Whole PlantUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC A ppendix 5 . Methods for Compositional Analysis S amples of DAS - 8191Ø
- 7 ( non - sprayed and sprayed with 2,4 - D + glufosinate), near isogenic non - transgen ic control (98M - 2983) , and reference variety cottonseed were analyzed at Covance Laboratories Inc. for 73 composition analytes . The following methods were used by Covance Laboratories to determine Proximates & Fiber (9), Minerals (12), Amino Acids (18), Fatty Acids (22), Vitam ins (7) and Anti - Nutrients (5) . See section 6.1 for composition analysis study design and results. 

### Proximates and Fiber  Protein The protein and other organic nitrogen in the samples were conv e rted to ammonia by digesting the sa mples with sulfuric acid con t aining a catalyst m i xture. T he acid digest was m ade alkaline. The ammonia was disti l led and then titrated with a previously standardized acid. Instru m entation was used to auto m ate the digestion, distillation and titration processes. The percent nitrogen w a s calculated and converted to equivalent protein using the factor 6.25.  Fat - by Soxhlet Extr a ction (FSOX) The sa mples were weig h ed into a cellulose thi m ble containing sodium sulfate and dried to re m ove excess m oisture. Pentane was dripped through the sa m ples to re m ove the fat. The extract was then evaporated, dried, and weighed.
 Ash All organic m atter was driven off when the sa mples were ignited at approxi m ately 550oC in a m uffle furnace for at least 5 hours. The re m aining in o rganic m aterial was deter m ined gravi m etrically and referred to as as h .  Moisture The sa m ples were dried in a vacuum oven at approxi m ately 10 0 °C. The moisture weight loss was deter m ined and converted to percent moisture.
 Carbohyd r ate s The total carbohydrate level was calculated by difference usi n g the fresh weight - derived data and the following equation: % carbohydrates = 100 % - (% protein + % fat + % m oisture + % ash)
 Acid Detergent Fiber (ADF) Sa m ple ali q uots were w eighed i n to pre - weig h ed f ilter b ags . The f

ats and pig m ents were then re m oved by an acetone wash . Due to the h i gh fat content of the samples, this was followed by an additional 12 - hour acetone soak with no agitation. The f ilter bags were placed in an ANKO M 20 0 0 Fiber analyzer where t h e protein, carbohydrate, and ash content wereUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC dissolved by boiling a cidic d et e r g ent sol u tion. After drying, the bags were reweighed a nd the a c id deter g ent f

i b er was dete r m ined gravi m etrically.  Neutral Detergent Fiber (NDF) Sa m ple ali q uots were w eighed i n to pre - weig h ed f ilter b ags . The f

ats and pig m ents were then re m oved by an acetone wash . Due to the h i gh fat content of the samples, this was followed by an additional 12 - hour acetone soak with no agitation. The f ilter bags were placed in an ANKO M 20 0 0 Fiber analyzer where t h e protein, carbohydrate, and ash content were dissolved by a bo i ling detergent solution at a neutral pH . H e m i cellulose, cellulose, lignin and insoluble p r ot e in f raction we r e le f

t in the f ilter bag and deter m ined gravi m etrically.
 Total Diet a ry Fiber Duplicate s a mples were gelatini z ed with α - a m ylase and digested with enzy m es to break down starch and protein. Eth a nol was added to each of t h e s a mples to pr e cipitate the soluble fiber. The sa m p l es were filtered, and the residue was rinsed with ethanol and acetone to remove starch and protein degradation products a n d m oisture. Protein content was deter m ined for one of the duplicates; ash content was deter m ined for the other. T he tot a l di e t ary f

i ber in t h e s a m

ples was calc u lated using protein and ash values and the weighed residue fractions.  Crude Fiber Crude fiber was quantitated as the loss on ignition of d r ied residue re m aining after digestion of the sa mples with 1.25% sulfuric acid and 1.25% sodium hyd r oxide solutions under specific conditions.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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### Minerals Mineral Analysis ( 12 Total ): ICP Emission Spectrometry The sa m ples were dried, precharred, and ashed o vernig h t in a m uffle furnace set to m aintain 500°C. The ashed sa m ples were re - ashed with nitric acid, tre a t e d with hydrochloric acid, taken to dryness, and put i n to a solution of 5% hydrochloric acid. T he a m ount of e ach ele m ent was deter m ined at appropriate wavelengths by comparing the e m ission of the unknown sa mples, m easu r ed on the inductively coupled plas m a spectro m et e r, with t h e e m ission of the stand a rd solutio n s. Mineral Reference Standards: Manufacturer Mineral Lot No. Concentration (μg/ml) Inorganic Ventures Calcium F2 - MEB453071MCA, 200, 1000 F2 - MEB453073 Inorganic Ventures Copper F2 - MEB453071MCA, 2.00, 10.0 F2 - MEB453072MCA Inorganic Ventures Iron F2 - MEB453071MCA, 10.0, 50.0 F2 - MEB453074 Inorganic Ventures Magnesium F2 - MEB453071MCA, 50.0, 250 F2 - MEB453072MCA Inorganic Ventures Manganese F2 - MEB453071MCA, 2.00, 10.0 F2 - MEB453072MCA Inorganic Ventures Phosphorus F2 - MEB453071MCA, 200, 1000 F2 - MEB453073 Inorganic Ventures Potassium F2 - MEB453071MCA, 200, 1000 F2 - MEB453073 Inorganic Ventures Sodium F2 - MEB453071MCA, 200, 1000 F2 - MEB453073 Inorganic Ventures Zinc F2 - MEB453071MCA, 10.0, 50.0 F2 - MEB453072MCA Molybdenum & Sulfur: ICP - Mass Spectrometry The sa m ples were wet - ashed with nitric acid using m icrowa v e digestion. Using inductively coupled plas m a mass spectr o m etry, the a m ount of each ele m ent was deter m ined by co mparing the counts generat e d by the unknowns to those generated by standard solutions of known concentrations. Molybdenum and Sulfur Reference Standards: Manufa c turer Mineral Lot No. Concentration ( μ g/ml) I n o r g a n i c V e n t u r es M o ly bd en u m F 2 - ME B 4 2 111 5 MCA 1 . 0 0 0 I n o r g a nic V e n t ures Sul f ur E2 - S 01 1 1 9 1 00 Selenium by Inductively Coupled Plasma - Mass Spectrometry (SEICPMS) The sa m ples were clo s e d - vessel m icro w ave dige s ted with n it r ic a c id (HNO 3 ) and water. After digestion, the solutions were brought to a final volu m e with water. To nor m alize the organic contribution between samples and standards, a dilution was prepared for analysis that contained m ethanol. The sel e nium concentration was deter m ined with S e 78 using an inductively coupled plas m a - m a ss spectro m eter (ICP - MS) with a dyna m ic reaction cell (DRC) by co mparing the counts generated by standard solutions. Selenium Reference Standar d : M a nu f a c turer Mineral Lot N o . C o ncen t r a t i o n ( m g/L) SPEX C er ti Pr e p. Se l en i um 1 8 - 29 S E 1 0 00USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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### Amino Acid Composition (TAALC/TRPLC)  Samples Analyzed (18 total) A l ani n e (total) Lysine (total) Arginine (total) M ethionine (total) As p artic acid (including asparagines) (total) Phenylalanine (total) Cystine (including cysteine) (total) Pr o li n e (total) Gluta m ic acid (including gluta m

ine) (total) S e rine (total) Gl y ci n e (total) T hreonine (total) Histi d ine (total) Tryptophan (total) Isoleucine (total) T y rosine Leuci n e (total) V a line (total) The samples were hydrolyzed in 6N hydrochloric acid for approximately 24 hours at approximately 106 - 118oC. Phenol was added to the 6N hydrochloric acid to prevent halogenation of tyrosine. Cystine and cysteine were converted to S - 2 - carboxyethylthiocysteine by the addition of dithiodipropionic acid. Tryptophan was hydrolyzed from proteins by heating at approximately 110oC in 4.2N sodium hydroxide for approximately 20 hours. The samples were analyzed by HPLC after pre - injection derivatization. The primary am ino acids were derivatized with o - phthalaldehyde (OPA) and the secondary amino acids were derivatized with fluorenylmethyl chloro formate (FMOC) before injection.

Amino Acid Reference Standards:

Component Manufacturer Lot No. Purity (%) L - Alanine Sigma - Aldrich BCBC5470 99.8 L - Arginine Monohydrochloride Sigma - Aldrich 1361811 100 L - Aspartic Acid Sigma - Aldrich BCBB9274 100.6 L - Cystine Sigma - Aldrich 1451329 100 L - Glutamic Acid Sigma - Aldrich 1423805 100.2 Glycine Sigma - Aldrich 1119375 100 L - Histidine Monohydrochloride Monohydrate Sigma - Aldrich BCBB1348 99.9 L - Isoleucine Sigma - Aldrich 1423806 100 L - Leucine Sigma - Aldrich BCBC6907 99.9 L - Lysine Monohydrochloride Sigma - Aldrich 1362380 100.2 L - Methionine Sigma - Aldrich 1423807 99.9 L - Phenylalanine Sigma - Aldrich BCBC5774 100 L - Proline Sigma - Aldrich 1414414 99.7 L - Serine Sigma - Aldrich 1336081 99.9 L - Threonine Sigma - Aldrich 1402329 100 L - Tryptophan Sigma - Aldrich BCBC1685 >99 BCBB1284 99.8 L - Tyrosine Sigma - Aldrich BCBC2417 100 L - Valine Sigma - Aldrich 1352709 100USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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### Fatty Acids ( FAPM) The lipid was extracted and saponified with 0.5N sodium hydroxide in methanol. The saponification mixture was methylated with 14% boron trifluoride in methanol. The resulting methyl esters were extracted with heptane containing an internal standard. The methyl esters of the fatty acids were analyzed by gas chromatography using external standards for quantitation. Fatty acid results were converted to their triglyceride equivalents. Fatty Acids An alyzed and Reference Standards ( 22 AA t otal ) M a nu f a c turer Lot N o . Co m p o ne n t Weig h t (%) Purity (%) JY - 10 MA7 - W N u - C h e k Pr e p GLC Refere n c e Stand ar d C ov a nce 1 C ov a nce 2 JY - 10

M A 7 - W M e t h y l Oc t a no a t e ( 8:0 Caprylic) 3 . 0 1 . 25 9 9 .7

Methyl Decanoate (10:0 Capric) 3.25 1.25 99.6 M et h y l Laura t e (12:0 Lauric) 3 . 25 1 . 25 9 9 .8 M et h y l My ristate ( 14:0 Myristic) 3 . 25 1 . 25 9 9 .8 M et h y l My ristoleate ( 14:1 Myristoleic) 1 . 0 1 . 25 9 9 .5 M et h y l Penta d ecanoate (15:0 Pentadecanoic) 1 . 0 1 . 25 9 9 .6 M et h y l Penta d ecenoate ( 15:1 Pentadecenoic) 1 . 0 1 . 25 9 9 .4 M et h y l Pal m i t ate ( 16:0 Palmitic) 1 0 .0 1 5 . 7 5 9 9 .8 M et h y l Pal m i t oleate ( 16:1 Palmitoleic) 3 . 0 1 . 25 9 9 .7 M et h y l Hept ad ecanoate ( 17:0 Heptadecanoic)) 1 . 0 1 . 25 9 9 .6 Met h yl 1 0 - Hept a d ecenoa t e (17:1 Heptadecenoic) 1 . 0 1 . 25 9 9 .5 Methyl Stearate ( 18:0 Stearic) 7.0 14.00 99.8 M et h y l O l eate ( 18:1 Oleic) 1 0 .0 1 5 . 7 5 9 9 .8 M e t h y l L i no le a t e ( 18:2 Linoleic) 1 0 .0 1 5 . 7 5 9 9 .8 Met h yl Gamma Linol e n ate ( 18:3 γ - Linolenic) 1 . 0 1 . 25 9 9 .4 M et h y l Linol e n ate ( 18:3 Linolenic) 3 . 0 1 . 25 9 9 .5 M e t h y l Ara c h i da t e ( 20:0 Arachidic) 2 . 0 1 . 25 9 9 .8 M e t h y l 1 1 - Ei c os e noate ( 20:1 Eicosenoic) 2 . 0 1 . 25 9 9 .6 M et h y l 1 1 - 1 4 Eicosadi e n oate ( 20:2 Eicosadienoic) 1 . 0 1 . 25 9 9 .5 Met h yl 1 1 - 14 - 1 7 Eicosatrienoa t e ( 20:3 Eicosatrienoic) 1 . 0 1 . 25 9 9 .5 M e t h y l Ara c h i d o nate ( 20:4 Arachidonic) 1 . 0 1 . 25 9 9 .4 M et h y l Be hen a te ( 22:0 Behenic) 1 . 0 1 . 25 9 9 .8USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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### Vitamins  Vitamin A (Beta Carotene) The sa mples were saponified and extracted with hexane. The sa m ples were then injected on a reverse phase high - perfor m ance liquid chr om atography system with ultraviolet light detection. Quantitation was achieved with a linear re g res s i o n analy s is Vitamin A Reference Standar d : Component Manufacturer Lot No. Purity (%) Beta - Carotene Sigma - Aldrich 091M1417V 98.4 (Lambda Maximum 450 to 451 nm in hexane)

 Vitamin B1 ( Thiamine H Cl) The sa m ples were subjected to acid hyd r olysis to denature m a trix and free bound thia m i ne analogs. The treated sa mple was brou g ht to volu m e, f ilte r ed and inje c t ed onto a reversed phase colu m n using a high - perf o r m ance liquid chro m atography system with a post - colu m n derivatization reaction coil and detected via a fluorescence detector. As thiamine monophosphate is not completely reacted, thiamine and thiamine monophosphate are both quantitated separately. Final results are the sum of the two components converted to thiamine hydrochloride form. Vitamin B1 Reference Standards:

Co m p o ne n t M a nu f a c ture r Lot N o . Purity ( % ) T h ia m i n e m ono ph o sp h ate c h l o r i d e d i h ydrate Si g m a - Al d rich BCBF 5 55 4 V 9 9 .3 T h ia m i n e h y d r o c h l or i d e USP P0K366 9 9 .7

 Vitamin B 2 (Riboflavin) The sa m ples were hydrolyzed with dilute hy d rochloric acid and the pH was adjusted to re m ove interferences. T he a m ount of riboflavin was deter m ined by comparing the growth response of the sa m

ples, using the bacteria Lactobacillus rhamnosus , with the growth response of m ultipoint riboflavin standards. The growth response was m easured turbi d i m etrically. Vitamin B 2 Reference Standards: Component Manufacturer Lot No. Purity (%) Riboflavin USP N1J079 99.7USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC  Vitamin B3 ( Niacin ) The sa m ples were hydrolyzed with sulfuric acid and the pH was adjusted to re m ove interferences. The a m ount of niacin was deter m ined by comparing the growth response of the sa mp l es, using the bacteria Lactobacillus plantarum, with the growth response of a niacin standard. This response was m easured turbidi m etrically. Vitamin B 3 Reference Standards: Co m p o ne n t M a nu f a c turer Lot N o . Purity ( % ) N iacin USP J 0 J 2 35 9 9.8  Vitamin B6 ( Pyridoxine Hydrochloride ) The sa m ples were hydrolyzed with dilute sul f uric acid in the autoclave and the pH was adjusted to re m ove interferences. The a m ount of pyridoxine was deter m ined by co mparing the growth response of the sa mples, using the yeast Sacchar om yces cerevisiae, with the growth response of a pyridoxine standard. The response was m easured turbidi m etrically. Results were reported as pyridoxine hydrochloride. Vitamin B 6 Reference Standards:

Co m p o ne n t M a nu f a c turer Lot N o . Purity ( % ) P y r id ox i ne h yd ro c h lo r i d e USP Q 0G 4 0 9 9 9 .8
 Vitamin B9 ( Fol ic Acid) The sa m ples were hydrolyzed in a p o tassium phosphate buffer with t h e a d dition of ascorbic acid to protect the folic acid during autoclaving. F o llowing hydrolysis by autoclaving, the sa m ples were t r eat e d with a chicken - pancreas enzy m e and incubated approxi m ately 18 hours to liberate the bound folic acid. The a m ount of folic acid was deter m ined by co mparing the growth response of the sa mples, using the bacteria Lactobacillus casei , with the growth response of a folic acid standard. This response was m easured turbidi m etri ca lly. Vitamin B 9 Reference Standards: Co m p o ne n t M a nu f a c turer Lot N o . Purity ( % ) Folic Ac i d USP Q 0G 1 5 1 9 8 .9
 α - Tocopherol ( Vitamin E ) The sa m ples were saponified to break down any fat and release vita m i n E. The saponified m i xtures were extracted with ethyl ether and then quantitated by high perfor m ance liquid chro m atography using a silica colu m n . Note: Alpha tocopherol is part of a m i

xed standard which also includes beta, delta, and gamma iso m ers. The reference standard m a terial for those iso m ers m ay contain s m all a m ounts of alpha tocopherol. All reference standards that contributed to the alpha tocopherol concentration are listed below. α - Tocopherol Reference Standards: Co m p o ne n t M a nu f a c turer Lot N o . Purity ( % ) Al p h a T o c o phe ro l USP O 0K 2 91 9 8.5 D - g a m m a - T o c o p h e ro l Ac r o s O r g a n ics A 00 8 35 3 4 9 9.3 (+ ) - δ - T o c o ph e r o l Si g m a - A l d ric h 0 9 0 M 191 6 V 92 .0USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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### Anti - Nutrients Sterculic Acid, Malv al ic Acid, Dihydrosterculic Acid The tot a l li p id f

r action was ext r acted f

r om t h e samples using chloroform and m ethanol. A portion of the lipid fraction w a s then saponified with a m ild alkaline hydrolysis. The free fatty acids were extracted with ethyl e t her and hexane. T he free fatty acids were then converted to their p henacyl derivatives with 2 - bro m oacetophenone. The derivatized extracts were injected on a high - perfor m ance liquid chro m atography system equipped with an ultr a viol e t det e ctor. The r e l a tive p e rce n t of total fatty acids for each peak was calc u lated from peak areas. Sterculic, Malvalic and Dihydrosterculic Acid Reference Standards: M a nu f a c turer Lot N o . Co m p o ne n t Weight (%) Purity (%) N u - Ch e k Pr e p N - 2 2A - A1 7 - Q Behenic ac i d NA >99 N u - Ch e k Pr e p N - 2 4A - A2 8 - Q Lig n oceric acid NA >99 Matreya LLC 2 29 9 0 D i h ydr o ster c u lic acid NA > 9 8

N u - C h e k Pr e p GLC Refere n c e Stand ar d P SA 1 A U1 9 - V Met h yl Myris t ate 2 . 2 9 9 .6 M e t h y l Pen t a d ecanoate 0 . 7 9 9 .5 Methyl Pal m

itate 47.0 99.5 M et h y l Pal m i t oleate 0 . 5 9 9 .4 M et h y l Hept ad ecanoate 2 . 0 9 9 .6 Methyl Stearate 36.0 99.7 Methyl Oleate 9.0 99.5 M e t h y l L i no le a t e 1 . 0 9 9 .4 M et h y l Linol e n ate 0 . 5 9 9 .5 M et h y l N o n ad ecanoate 0 . 6 9 9 .4 M et h y l Ara c hidate 0 . 5 9 9 .6 NA=N o t ap p lica b le Gossypol, F ree The sa m ples were extra c ted with an aqueous ac e tone sol u ti o n and f ilt e r e d. Duplicate aliqu o ts were m ade and the active aliquot was reacted with a n ili n e with heat applied in a water bath. Active and inactive aliquots were brought to volu m e with an aqueous isopropyl alcohol solution and read on a spec t rophoto m eter at 440 n m . The absorbance difference was then co mpared to a linear c u rve calculated fr o m standards that were aliquoted, reacted, and read in the sa m e fashion as the sa m ples. Gossypol, Free & Total Reference Standard :

Co m p o ne n t M a nu f a c turer Lot N o . Purity ( % ) G o ssyp ol f

r o m c o tto n see d s Si g m a - A l d r ich 0 4 1 M411 7V 9 9.64 Gossypol, T otal ( GOSS) Total gossypol defines gossypol and gos s ypol derivatives, both free and bound, in cottonseed p roducts that are ca p able of reacting with 3 - a m ino - 1 - propan o l in di m ethylfor m a m ide so l ution to form a dia m i n opropanol complex, which then reacts with aniline to f

o rm dianilin o gossypol u n der the con d itions of t h e m ethod. Gossypol, gossypol analogs, and gossypol derivatives h a ving an available aldehyde m oiety were m easured by the m ethod (see references above).USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 6 . Compositional Literature Ranges for Non - Transgenic Cottonseed Analyte Units ILSI 2010 Literature Literature Citations Min Max Min Max Min Max Proximates & Fiber (9 Total) Ash % DW 3.761 5.342 3.7 5.29 ( Nida et al. , 1996 ) ( Hamilton et al. , 2004 ) Carbohydrates % DW 39.0 53.6 41.0 53.62 ( Nida et al. , 1996 ) ( Hamilton et al. , 2004 ) Fat % DW 17.201 27.292 14.4 25.5 ( Bertrand et al. , 2005 ) ( Nida et al. , 1996 ) Protein % DW 21.48 32.97 12 32 ( Kohel et al. , 1985 ) ( Kohel et al. , 1985 ) Moisture % FW 2.3 9.9 2.25 15.9 (Hamilton et al., 2004) ( Berberich et al. , 1996 ) ADF % DW 19.74 38.95 21.10 40.5 (Hamilton et al., 2004) (Bertrand et al., 2005) Crude Fiber % DW 13.86 23.10 13.45 19.31 (Hamilton et al., 2004) (Hamilton et al., 2004) NDF % DW 25.56 51.87 32.92 53.6 (Hamilton et al., 2004) (Bertrand et al., 2005) Total Dietary Fiber % DW 33.69 47.55 NR NR NR NR Minerals (12 Total) Calcium mg/100g dry wt. 103.23 325.81 100 330 (Hamilton et al., 2004) (Hamilton et al., 2004) Copper mg/100g dry wt. 0.313 2.457 0.333 1.114 (Hamilton et al., 2004) (Hamilton et al., 2004) Iron mg/100g dry wt. 3.671 31.838 3.927 7.215 (Hamilton et al., 2004) (Hamilton et al., 2004) Magnesium mg/100g dry wt. 347.09 493.12 340 470 ( Belyea et al. , 1989 ) (Hamilton et al., 2004) Manganese mg/100g dry wt. 1.069 2.196 1.106 2.216 (Hamilton et al., 2004) (Hamilton et al., 2004) Molybdenum mg/100g dry wt. NR NR NR NR NR NR Phosphorus mg/100g dry wt. 482.54 991.57 560 860 (Hamilton et al., 2004) (Hamilton et al., 2004) Potassium mg/100g dry wt. 983.45 1448.35 960 1240 ( Belyea et al. , 1989 ) (Hamilton et al., 2004) Selenium ppb_DW NR NR NR NR NR NR Sodium mg/100g dry wt. 11.183 735.477 5.4 740 (Hamilton et al., 2004) (Hamilton et al., 2004) Sulfur mg/100g dry wt. NR NR NR NR NR NR Zinc mg/100g dry wt. 2.70 5.95 2.89 4.862 (Belyea et al., 1989) (Hamilton et al., 2004) Amino Acids (AA) (18 Total) Alanine % total amino acid 4.08 4.51 4.15 5.30 (Hamilton et al., 2004) (Hamilton et al., 2004) Arginine % total amino acid 10.85 12.77 10.83 15.18 (Hamilton et al., 2004) (Hamilton et al., 2004) Aspartic Acid % total amino acid 9.00 10.60 9.63 12.37 (Hamilton et al., 2004) (Hamilton et al., 2004) Cystine % total amino acid 1.53 2.35 1.60 2.32 (Hamilton et al., 2004) (Hamilton et al., 2004) Glutamic Acid % total amino acid 20.61 22.90 20.24 21.61 (Hamilton et al., 2004) (Hamilton et al., 2004) Glycine % total amino acid 4.29 4.68 4.44 5.72 (Hamilton et al., 2004) (Hamilton et al., 2004) Histidine % total amino acid 2.91 3.22 3.00 3.88 (Hamilton et al., 2004) (Hamilton et al., 2004) Isoleucine % total amino acid 3.10 3.71 3.10 4.46 (Hamilton et al., 2004) (Hamilton et al., 2004) Leucine % total amino acid 6.03 6.65 6.27 8.11 (Hamilton et al., 2004) (Hamilton et al., 2004) Lysine % total amino acid 4.62 5.46 4.85 6.60 (Hamilton et al., 2004) (Hamilton et al., 2004) Methionine % total amino acid 1.27 2.16 1.46 2.28 (Hamilton et al., 2004) (Hamilton et al., 2004) Phenylalanine % total amino acid 5.44 6.04 5.51 7.23 (Hamilton et al., 2004) (Hamilton et al., 2004) Proline % total amino acid 3.81 4.49 3.93 5.30 (Hamilton et al., 2004) (Hamilton et al., 2004) Serine % total amino acid 4.15 5.31 4.16 5.87 (Hamilton et al., 2004) (Hamilton et al., 2004) Threonine % total amino acid 2.67 3.59 3.26 4.26 (Hamilton et al., 2004) (Hamilton et al., 2004) Tryptophan % total amino acid 0.91 1.31 0.94 1.40 (Hamilton et al., 2004) (Hamilton et al., 2004) Tyrosine % total amino acid 2.63 2.93 2.65 3.46 (Hamilton et al., 2004) (Hamilton et al., 2004) Valine % total amino acid 4.49 5.31 4.72 6.24 (Hamilton et al., 2004) (Hamilton et al., 2004)USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 6 . Compositional Literature Ranges for Non - Transgenic Cottonseed (continued)

Analyte Units ILSI 2010 Literature Literature Citations Min Max Min Max Min Max Fatty Acids (22 Total) 8:0 Caprylic % total fatty acid ND ND NR NR NR NR 10:0 Capric % total fatty acid ND ND NR NR NR NR 12:0 Lauric % total fatty acid ND ND NR NR NR NR 14:0 Myristic % total fatty acid 0.455 2.400 0.55 2.40 (Hamilton et al., 2004) (Hamilton et al., 2004) 14:1 Myristoleic % total fatty acid ND ND NR NR NR NR 15:0 Pentadecanoic % total fatty acid 0.103 0.481 0.050 0.17 (Hamilton et al., 2004) (Hamilton et al., 2004) 15:1 Pentadecenoic % total fatty acid ND ND NR NR NR NR 16:0 Palmitic % total fatty acid 15.11 27.90 21.23 28.10 (Hamilton et al., 2004) (Hamilton et al., 2004) 16:1 Palmitoleic % total fatty acid 0.464 1.190 0.57 0.57 (Bertrand et al., 2005) (Bertrand et al., 2005) 17:0 Heptadecanoic % total fatty acid 0.092 0.119 NR NR NR NR 17:1 Heptadecenoic % total fatty acid ND ND NR NR NR NR 18:0 Stearic % total fatty acid 0.20 3.11 1.99 3.11 (Hamilton et al., 2004) (Hamilton et al., 2004) 18:1 Oleic % total fatty acid 12.8 25.3 12.90 20.10 (Hamilton et al., 2004) (Hamilton et al., 2004) 18:2 Linoleic % total fatty acid 46.0 59.4 46.00 57.10 (Hamilton et al., 2004) (Hamilton et al., 2004) 18:3 Linolenic % total fatty acid 0.11 0.35 0.18 0.18 (Bertrand et al., 2005) (Bertrand et al., 2005) 18:3 gamma Linolenic % total fatty acid 0.097 0.232 NR NR NR NR 20:0 Arachidic % total fatty acid 0.186 0.414 0.24 0.34 (Hamilton et al., 2004) (Hamilton et al., 2004) 20:1 Eicosenoic % total fatty acid 0.095 0.098 NR NR NR NR 20:2 Eicosadienoic % total fatty acid ND ND NR NR NR NR 20:3 Eicosatrienoic % total fatty acid ND ND NR NR NR NR 20:4 Arachidonic % total fatty acid ND ND NR NR NR NR 22:0 Behenic % total fatty acid 0.104 0.295 0.12 0.24 (Hamilton et al., 2004) (Hamilton et al., 2004) Vitamins (7 Total) Alpha Tocopherol (Vitamin E) mg/kg DW 70.825 197.243 NR NR NR NR Vitamin A (Beta Carotene) mg/kg DW NR NR NR NR NR NR Vitamin B1 (Thiamine HCl) mg/kg DW NR NR NR NR NR NR Vitamin B2 (Riboflavin) mg/kg DW NR NR NR NR NR NR Vitamin B3 (Niacin) mg/kg DW NR NR NR NR NR NR Vitamin B6 (Pyridoxine HCl) mg/kg DW NR NR NR NR NR NR Vitamin B9 (Folic Acid) mg/kg DW NR NR NR NR NR NR Anti - Nutrients (5 Total) Dihydrosterculic Acid % total fatty acid 0.075 0.310 0.12 0.24 (Hamilton et al., 2004) (Hamilton et al., 2004) Malvalic Acid % total fatty acid 0.229 0.759 0.17 0.61 (Hamilton et al., 2004) (Hamilton et al., 2004) Sterculic Acid % total fatty acid 0.190 0.556 0.13 0.56 (Hamilton et al., 2004) (Hamilton et al., 2004) Free Gossypol mg/kg DW 0.454 1.399 0.53 1.20 (Hamilton et al., 2004) (Hamilton et al., 2004) Total Gossypol % DW 0.547 1.522 0.55 1.46 (Bertrand et al., 2005) ( Nida et al. , 1996 )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 7 . Evolution of Herbicide Resistant Weeds in Transgenic Crops Herbicide Tolerant Crops Herbicide resistance in weeds has long driven the development of herbicide tolerant crops. Soon after the first weeds evolved resistance to herbicides, scientists began to consider altering crops to make them resistant to herbicides ( Duke, 2005 ) . Initially, non - transgenic methods were used until the early 1980s when the tools for producing transgenic crops were becoming available. The first transgenic herbicide tolerant crops in cluded bromoxynil resistant cotton and canola. However, transgenic crops with resistance to broad - spectrum, non - selective herbicides were perceived as a better approach for weed management . This was soon realized with the development of glyphosate a nd gluf osinate tolerant crops. S ince the transgenic crops would tolerate the application of those broad spectrum herbicides, they could survive and prosper while reducing the amount and number of applications of herbicides by the growers. Herbicide tolerance (of

ten called resistance) in plants employs one of two strategies (or a combination) to make the plant tolerant to the applied herbicide:  the plant produces a new protein which detoxifies the herbicide ( e.g. , glufosinate tolerance, 2,4 - D tolerance) , or  the p rotein in the plant which is normally the target of the herbicide’s action is replaced by a new protein which is unaffected by the herbicide ( e.g. , glyphosate tolerance) . Herbicide tolerant crops available to farmers since 1996 include corn, soybean, cotto n, sugar beet, alfalfa and canola among others. Initially, t ransgenes were only used to confer tolerance to bromoxynil , glufosinate, and glyphosate. The bromoxynil - tole rant crops are no longer sold. Until recently, this only left glyphosate and glufosinate tolerant transgenic crops, and of those, glyphosate has had the strongest impact on weed management ( Duke, 2005 ) . Growers choose glyphosate tolerant crops because they make weed control easier and more effective, increas e profit, require less tillage, and do not restrict crop rotations ( Green, 2009 ) . Thus, glyphosate tolerant corn, soybeans and cotton have experienced an unprecedented rapid adoption rate by U.S. farmers ( Figure 50 ). The p lanting of glyphosate tolerant crops has increased steadily since their introduction in 1996 : herbicide tolerant cotton is currently planted to 82% of U.S. acres; the vast majority is glyphosate tolerant ( University of California Agriculture & Natural Resources, 2013a ; USDA NASS, 2013c ) . Figure 66 illustrates the breakdown between herbicide tolerant (HT), insect tolerant (Bt), and stacked varieties of transgenic cotton planted in the U.S.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Evolution of Resistance to Glyphosate, 2,4 - D, and Glufosinate Glyphosate Resistance and Weed Shifts

Glyphosate Resistance It was initially thought that evolution of glyphosate resistant weeds would be slow and the lev els of resistance would be low ( Bradshaw et al. , 1997 ) . This was based on the amount of glyphosate applied over many years, the rep eated applications made to perennial crops, the high level of herbicidal activity that it had demonstrated, and the uniqueness of its m etabolic activity in the plant. More than twenty years after the launch of glyphosate, rigid ryegrass in Australia was reported as the first glyphosate resistant weed in 1996 ( Powles et al. , 1998 ) . About the same time, sales of glyphosate began to increase dramatically in the U.S. due to the launch of glyphosate tolerant transgenic soybeans (1996), c otton (1997), and corn (1998). Rapid adoption of this new technology drove dramatic increases in the use of gly phosate only weed control, which resulted in increased selection pressure for glyphosate resistant weeds.

Figure 66 . Adoption of GE Cotton in the U.S. ( USDA ERS, 2013b ) Table 37 shows a summary of the glyphosate resistant weed species that have been reported from 1996 to August 2013. The data clearly show s that glyphosate resistance in weeds is expanding around the globe. Two of these glyphosate resistant weed species have alreadyUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC become a significant problem for farmers a cross a large geographic area: Conyza canadensis (Horseweed) infests at least two million hectares of glyphosate tolerant crops in the U.S. ; and Amaranthus palmeri ( Palmer a maranth ) has heavily impacted cotton growers, particularly in the Southeast. Table 37 . Weed Species with Reported Glyphosate Resistant B iotypes 1 Common Name Species Name First Confirmed Report Later

Confirmed Reports Year Country Rigid ryegrass Lolium rigidum 1996 Australia USA, S. Africa, France, Spain Goosegrass Eleusine indica 1997 Malaysia Colombia, USA Horseweed/Marestail Conyza Canadensis 2000 USA Brazil, China, Spain, Czech Republic Italian ryegrass Lolium multiflorum 2001 Chile Brazil, USA, Spain, Argentina Hairy fleabane Conyza bonariensis 2003 S. Africa Spain, Brazil, Colombia, USA Buckhorn plantain Plantago lanceolata 2003 S. Africa Common ragweed Ambrosia artemisiifolia 2004 USA Giant ragweed Ambrosia trifida 2004 USA Ragweed parthenium Parthenium hysterophorus 2004 Colombia Palmer amaranth Amaranthus palmeri 2005 USA Common waterhemp Amaranthus rudis 2005 USA Canada Johnsongrass Sorghum halepenses 2005 Argentina USA Sourgrass Digitaria insularis 2006 Paraguay Brazil Junglerice Echinochloa colona 2007 Australia USA Kochia Kochia scoparia 2007 USA Liverseedgrass Urochloa panicoides 2008 Australia Perennial ryegrass Lolium perenne 2008 Argentina Gramilla mansa Cynodon hirsutus 2008 Argentina Sumatran fleabane Coryza sumatrensis 2009 Spain Australian fingergrass Chloris truncate 2010 Australia Annual bluegrass Poa annua 2010 USA Tropical Sprangletop Leptochloa virgate 2010 Mexico Ripgut Brome Bromus diandrus 2011 Australia Spiny Amaranth Amaranthus spinosus 2012 USA 1 ( Heap, 2013d )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 38 . Global Reports of Glyphosate Resistant Weed Biotypes with Resistance to Other

Herbicide Modes of Action 5 Common Name Species Name Year – Country (State /Providence ) Multiple Resistance to Other Herbicide M ode of Actions Kochia Kochia scoparia 2012

– CAN (Alberta) ALS 1 Sumatran Fleabane Conyza sumatrensis 2011

– Brazil ALS Palmer amaranth Amaranthus palmeri 2008

– U.S. (MS, GA) ALS 2009

– U.S. (TN) Common waterhemp Amaranthus rudis 2005

– U.S. (MO) ALS, PPO 2 2006

– U.S. (IL) ALS 2011

– U.S. (IA) ALS, HPPD 3 Common ragweed Ambrosia artemisiifolia 2006

– U.S. (OH) ALS 2012

– CAN (Ontario) Hairy fleabane Conyza bonariensis 2009

– U.S. (CA) Bipyridiliums Horseweed Conyza canadensis 2003

– U.S. (OH) ALS 2007

– U.S. (MS) Bipyridiliums 2010

– U.S. (DE) ALS 2011

– CAN (Ontario) ALS Giant ragweed Ambrosia trifida 2006

– U.S. (OH) ALS 2008

– U.S. (MN) ALS Goosegrass Eleusine indica 1997

– Malaysia ACCase 4 Italian ryegrass Lolium multiflorum 2002

– Chile ALS 2006

– Chile ACCase 2007

– Chile ACCase, ALS 2010 - Argentina ALS 2010

– Argentina ACCase 2010

– Brazil ACCase 2010

– U.S. (OR) Glutamine synthase Rigid ryegrass Lolium rigidum 1999 - Australia ACCase, ALS, Dinitroanilines 2003

– South Africa ACCase, Bipyridiliums 2007 - Israel ACCase, ALS 2008 - Australia Triazoles 2010 - Australia Bipyridiliums Acetolactase synthase inhibitors 2 Polyphenol oxidase inhibitors 3 Hydroxyphenyl - pyruvate - dioxygenase inhibitors 4 Acetyl CoA carboxylase inhibitors 5 ( Heap, 2013b ) In addition, researchers in Virginia have been testing a biotype of common lambsquarters that survived 1.0 lb ae/acre (1120 g ae/ha) glyphosate, and thus appears to have low level resistance to glyphosate ( Hite et al. , 2008 ) . Weed scientists in Ohio and Indiana have also identified a biotype of common lambsquarters in at least a dozen fields that appears to have low - level glyphosate resistance ( Curran et al. , 2007 ) . The increased reports of glyphosate resistant species, plus the geographic spread of their infestations, have caused some to raise concerns about the long term sustainability for glyphosate. Some researchers have stated thatUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC applying glyphosate alone over wide areas on highly variable and prolific weeds made the evolution of resistant weeds ine vitable ( Owen, 2001 ; Thill and Lemerle, 2001 ) . Researchers have reported that eleven individual biotypes of the twenty - four glyphosate resistant species are also resistant to herbicides with other modes of action ( Table 38 ) . In recent years, chemical costs have doubled, and many growers have returned to hand weeding, in - crop cultivation, tillage, and post - harvest deep - turning to control glyphosate resistant weeds ( Sosnoskie and Culpepper, 2013 ) . Although herbicide options to control these biotypes with multiple herbicide resistance will be more limited, 2,4 - D remains a viable control option for the broadleaf weeds.

Table 39 . Potential W ee d Shifts with Use of Glyphosate Common Name Species Name Asiatic dayflower Commelina communis Brazil callalily Richardia brasiliensis Broadleaf buttonweed Spermacoce latifolia Common waterhemp Amaranthus rudis Common lambsquarters Chenopodium album Eastern black nightshade Solanum ptycanthum Giant ragweed Ambrosia trifida Hemp sesbania Sesbania exaltata Kochia Kochia scoparia Marestail / Horseweed Conyza canadensis Morning glory spp. Ipomoea spp. Nutsedge spp. Cyperus spp. Prickly sida Sida spinosa Russian thistle Salsola iberica Tall waterhemp Amaranthus tuberculatus Tridax daisy Tridax procumbens Tropical spiderwort Commelina benghalensis Velvetleaf Abutilon theophrasti Palmer Amaranth Amaranthus Palmieri Weed Shifts When glyphosate tolerant crops are grown intensively with high reliance on glyphosate for weed control, species which possess some level of natural tolerance to glyphosate will become more p revalent. These “weed shifts” can occur more rapidly than selection for glyphosate resista nce ( Shaner, 2000 ) . Some common hard to control weed species that could become “weed shifts” in U.S. cotton are listed in Table 39 , with pigweed and morning glory most commonly reported by cotton growers ( Duke and Powles, 2008b ; Owen, 2008 ; Prince et al. , 2012 ) .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC

2,4 - D Resistance 2,4 - D has been used continually and widely for over 70 years, and reports of resistance have been rare ( Wright et al. , 2010 ; Greene and Reid, 2012 ) . The earliest documented reports of herbicide resistant weeds were for resistance to 2,4 - D in wild carrot ( Daucus carota ) (observed in 1952 but not reported until 1957) and spreading dayflower ( Commelina diffusa ) in 1957 ( Heap, 2011 ) . Today, a total of s eventeen weed species have documented reports of 2,4 - D resistant biotypes someplace aro und the globe ( Table 40 ) . Wild carrot, yellow bur head, wild radish, musk thistle, and corn poppy are the only 2,4 - D resistant weeds that have reported infestat ions in more than 1,000 acres. Some of these 2,4 - D resistan t biotypes have documented cross resistance to other auxin herbicides or multiple resistance to s ome ALS inhibiting herbicides. M ost of these resistant species do not appear to be spreading, as indicated by few reports of additional sites after the initial report. Few of these auxin resistant weeds have had a significant economic impact due to the wide array of alternatives that successfully control these resistant weeds ( Heap, 1997 ) . The overall incidence of auxinic herbicide resistance after more than seventy years of use is low , particularly when compared with other herbicide families in use over shorter time periods: ALS inhibitors (imidazolinones, sulfonylureas, and sulfonamides), triazines, and ACCase herbicides. It has been suggested by various researchers that the rarity of auxinic herbicide resistant biotypes in the field is due to: a) a commonly held belief that these herbicides have multiple sites of action in the plant ( Jasieniuk et al. , 1996 ) , b) redundancy in auxin receptors (AFBs) and other components of the auxin signal response ( Walsh et al. , 2006 ) , c) moderate selection pressure and their use in mixtures with other herbicides ( Kern et al. , 2005 ) , d) fitness penalties ( Bourdot et al. , 1996 ) , and e) quantitative inheritance of the resistance trait ( Cranston et al. , 2001 ) . The mechanism of resistance to auxinic herb icides has been investigated, in varying degrees for only a fe w of these resistant biotypes. Resistance mechanisms in these biotypes have proven to be difficult to elucidate. A lack of differences between biotypes in auxinic herbicide absorption, transloca tion, and metabolism has led to the hypothesis that auxinic herbicide resistance is most often likely due to differences at the target site or differences along the signal transduction pathway ( Van Eerd et al. , 2005 ) . Patterns and mechanisms of cross resistance in auxin herbici de resistant biotypes to other classes of auxin herbicide s are not yet well understood. Further research is needed across a range of resistant species and biotypes to identify the potentially numerous gene mu tations that cause resistance. It is also possib le, but less likely, that a biotype might be resistant to all of these auxin herbicides. Due to the diversity of chemistry representing the synthetic auxin mode of action, it is unlikely plants will derive a single metabolic mechanism for tolerance to this class of herbicides.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Table 40 . Weed Species with Reported 2,4 - D Resistant Biotypes Common Name Species Name Herbicide(s) Year Country / U . S . State Wild carrot Daucus carota 2,4 - D 1952 Ontario 2,4 - D 1993 Michigan 2,4 - D 1994 Ohio Dayflower Commelina diffusa 2,4 - D 1957 Hawaii Field bindweed Convolvulus arvensis 2,4 - D 1964 Kansas Musk thistle Carduus nutans 2,4 - D, MCPA 1981 New Zealand Scentless chamomile Matricaria perforate 2,4 - D 1975 France 2,4 - D 1975 United Kingdom Gooseweed Spenoclea zeylanica 2,4 - D 1983 Philippines 2,4 - D 1995 Malaysia 2,4 - D 2000 Thailand Canada thistle Cirsium arvense 2,4 - D, MCPA 1985 Hungary Globe fringerush Fimbristylis miliacea 2,4 - D 1989 Malaysia Wild mustard Sinapsi arvensis 2,4 - D, most other auxins 1990 Manitoba Corn poppy Papaver rhoeas 2,4 - D, tribenuron 1993 Spain Yellow bur - head Limnocharis flava 2,4 - D 1995 Indonesia 2,4 - D, bensulfuron - methyl 1998 Malaysia Italian thistle Carduus pycnocephalus 2,4 - D 1997 New Zealand Wild radish Raphanus raphanistrum 2,4 - D 1999 Australia Marshweed Limnophila erecta 2,4 - D, ALS 2002 Malaysia Indian hedge mustard Sisymbrium orientale 2,4 - D, metsulfuron - methyl 2005 Australia Prickly lettuce Lactuca serriola 2,4 - D, dicamba, MCPA 2007 Washington Common Waterhemp Amaranthus tuberculatus 2,4 - D 2009 Nebraska 1 ( Heap, 2013e ) To summarize, selecti on for auxin resistant weed bio t y pes after more than 7 0 years of use has been slow . Auxin resistant weeds have not show n significant spread from initial sites, nor have they demonstrated significant economic importance. Thus far, there have been no reports of auxin resistant weed biotypes in cotton fields. U se of 2,4 - D in DAS - 8191Ø
- 7 cotton should not result in 2,4 - D resis tant weeds becoming a significant issue in cotton. Additionally, 2,4 - D will likely be used in a mixture with one or more other herbicides. Other alternative herbicides which are effective on the same weeds can be used to control any 2,4 - D resistant weeds t hat might occur.

Glufosinate Resistance There are currently only two report ed weed biotype s that have developed resistance to glufosinate , Goosegrass ( Eleusine indica ) in Malaysia and Italian ryegrass (Oregon) ( Heap, 2013a ) . Italian Ryegrass is also resistant to glyphosate .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Weed Resistance Management Cotton growers in the U.S. are currently battling a number of glyphosate resistant weeds ( Table 41 ) due to years of exclusive use of glyphosate for weed control ( For esman and Glasgow, 2008 ; Gustafson, 2008 ) . As described above, overreliance on this single method of control has greatly increased selection pressure f or glyphosate resistant weeds . Table 41 . U.S. Glyphosate Resistant Weeds in Cotton Growing States 1 Number Species Common Name State

1 Amaranthus palmeri Palmer Amaranth Ge orgia North Carolina Arkansas Tennessee New Mexico Alabama Georgia Mississippi Missouri Tennessee Louisiana Kansas Arizona California 2 Amaranthus spinosus Spiny Amaranth Mississippi 3 Amaranthus tuberculatus (syn. rudis) Common Waterhemp Missouri Kansas Mississippi Oklahoma Tennessee 4 Ambrosia artemisiifolia Common Ragweed Arkansas Missouri Kansas 5 Ambrosia trifida Giant Ragweed Arkansas Kansas Tennessee Missouri Mississippi 6 Conyza bonariensis Hairy Fleabane California
7 Conyza canadensis Horseweed Kentucky Tennessee Missouri Arkansas Mississippi North Carolina California Kansas Mississippi Oklahoma 8 Echinochloa colona Junglerice California 9 Eleusine indica Goosegrass Mississippi Tennessee 10 Kochia scoparia Kochia Kansas 11 Lolium multiflorum Italian Ryegrass Mississippi Arkansas California 12 Lolium rigidum Rigid Ryegrass California 13 Poa annua Annual Bluegrass Missouri Tennessee 14 Sorghum halepense Johnsongrass Arkansas Mississippi Louisiana 1 ( Webster and Sosnoskie, 2010 )USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC The magnitude of current weed resistance challenges has prompted outreach efforts by industry and academics to educate growers on integrated weed management strategies . For example, the Weed Science Society of America has extensive resources on its website, including lesson modules for herbicide resistant weeds ( WSSA, 2013b ) . These modules explain the current status of resistance, how herbicides work, what herbicide resistance is, and principles of managing herbicide resistance ( WSSA, 2013c ) . Similarly, the Herbicide Resistance Action Committee, an international body found ed by the agrochemical industry, provides herbicide resistance management strategies and principles to teach growers an integrated approach to weed resistance management ( HRAC, 2013b ) . One cornerstone of integrated weed resistance management is the use of herbicides with multiple modes or sites of action. DAS - 8191Ø
- 7 cotton will be combined with glyphosate tolerant cotton utilizing traditional breeding techniques and fits into a recommended integrated weed resistance management program . Additionally, DAS - 8191Ø
- 7 cotton is a needed tool to mitigate the current selectio n pressure for glyphosate resistant weed species. Conclusions The adoption of herbicide tolerant crops, primarily glyphosate tolerant varieties, and resulting reliance on a single mode of action for weed control, has resulted in a rapidly growing populat ion of resistant and hard to control weed species. Growers now understand the need for an integrated weed management approach; DAS - 8191Ø
- 7 cotton offers an alternative chemistry for control of troublesome weeds, in accordance with rec ommended management pr actices. DAS - 8191Ø
- 7 cotton will be combined with glyphosate tolerant cotton utilizing traditional breeding techniques . The combination of herbicide tolerance traits will allow the use of multiple herbicides in an integrated weed management program to control a broad spectrum of grass and broadleaf weed species in cotton. These herbicides will provide distinct modes of actions for use in conjunction with other herbicide active ingredients and mode of action for an effective weed management program in co tton .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 8 . Stewardship of Herbicide Tolerant Trait Technology for DA S - 8191Ø - 7 Cotton Introduction DAS - 8191Ø
- 7 cotton is a transgenic cotton product that provides tolerance to 2,4 - dichlorophenoxyacetic acid (2,4 - D) and glufosinate . This herbicide tolerant cotton will provide growers with greater flexibility in selection of herbicides for the improved control of economically important weeds; allow an increased application window for effective weed control; and provide an effective resistance management prevention solution to the increased incidence of hard to control and gly phosate resistant weeds 1
. Dow AgroSciences is committed to promoting the responsible use and stewardship of this new herbicide tolerant trait technology and will implement a comprehensive stewardship program for DAS - 8191Ø
- 7 cotton and its associated herb icide technology containing a new 2,4 - D choline salt . The stewardship program will focus on educating and training retailers, growers and applicators on the appropriate use of this new technology as part of an integrated weed management program . This will be accomplished by using a multi - faceted approach, including use of a variety of tools and delivery methods, and working with customers, stakeholders and industry organizations to promote re sponsible use of the technology . The stewardship program is design ed to:

• Provide comprehensive guidance and education on responsible use • Promote compatibility with other crops and cropping systems • Minimize the potential for off - target movement • Pro mote Weed Resistance Management 2 • Promote responsible use and worker safety • Support compliance with applicable regulatory requirements Stewardship Program Components The comprehensive stewardship program is based on Dow AgroSciences’ ongoing commitment to stewardship and input from retailers, growers, applicators, regulators, and stakeholders. Key components of the stewardship program include:  A uthorized use of DAS - 8191Ø
- 7 cotton (and associated herbicide products) through a Technology Use Agreement (TUA)  Herbicide technology advan cements, including new 2,4 - D choline based herbicide technolog ies  Comprehensive product use information , including mandatory use requirements and restrictions  Education and training for distributors, retailers, growers, and applicators , and 1 As used in this document, a herbicide resistant weed is a member of a population within a species that has an inherited ability to survive and reproduce following exposure to a dose of a herbicide normally lethal to susceptible populations of the species. Through repeated herbicide selection, the resistant population becomes dominant in a given area. A hard - to - control weed is a weed species that is inherently able to withstand treatment with a herbicide as a result of natural factors not involving herbicide selection or genetic mutation. 2 Stewardship inf

ormation on insect resistance management will also be included, as applicable.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC  Compliance mon itoring. Authorized Use of DAS - 8191Ø
- 7 Cotton and Associated Herbicide Products Through a Technology Use Agreement Dow AgroSciences will authorize growers of DAS - 8191Ø
- 7 cotton through a Technology Use Agreement that requires growers to use the cotton trait technology responsibly and prohibits the use of unauthorized herbicides. The Technology Use Agreement is a legal and contractual obligation that will require all growers of DAS - 8191Ø
- 7 cotton to:  Use only EPA accepted and Dow AgroSciences’ authori zed herbicide products for post plant applications to DAS - 8191Ø
- 7 cotton;  Read and follow the Product Use Guide (PUG) requirements ;  Read and follow FIFRA pesticide product label directions, which will include requirements to use in a manner protective of the environment;  Read and follow seed packaging information; and  Provide access to information about use of the technology and allo w on - farm assessments. Herbicide Technology Advancements Dow AgroSciences has discovered and developed a novel (non - ester or non - amine) 2,4 - D choline 3
. E xceptionally low volatility of DAS’ 2,4 - D choline salt has been demonstrated in both laboratory and field studies . I n a laboratory study, wheat plants treated with rates ten times higher than specified on the label of 2,4 - D choline were placed in an enclosed chamber with grape and tomato plants ( Ouse et al. , 2010 ) . After 24 hours of exposure in the chamber at 104°F, neither sensitive crop showed any symptoms of injury. The lack of any symptoms on th e grape and tomato plants is a clear indication that there was no detectable volatility following application of 2,4 - D choline salt . F ield results are consistent with these laboratory findings ( Hillger et al. , 2010 ) . Comprehensive Product Use Information Product Use Guides Dow AgroSciences will provide DAS - 8191Ø
- 7 cotton growers a comprehensive Product Use Guide that is a material part of the Technology Use Agreement and details the requirements for responsible use. As a standard practice, Dow AgroSciences provides a Product Use Guide to users (e.g., retailers, dealers, g rowers, applicators) of its technology. The Product Use Guide provides growers comprehensive information including required and recommended management practices. The Product Use Guide for DAS - 8191Ø
- 7 cotton will include detailed requirements for responsibl e use of the cotton and associated herbicide products. It will include information on weed resistance management, application and management of 3 Applications for 2,4 - D choline and associated herbicides for use with DAS - 8191Ø
- 7 cotton will be submitted to EPA.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC off - target herbicide movement, as well as seed planting directions and cotton seed and by product stewardship. The Product Use Guide will require DAS - 8191Ø
- 7 cotton growers to:  Use only EPA accepted and Dow AgroSciences’ authorized herbicide products with DAS - 8191Ø
- 7 cotton  Read and follow FIFRA pesticide product label directions  Follow Weed Resistance Management guidelines, recommending utilization of herbicide products with additional modes of action  Read and follow marketing guidelines  Provide management practices to promote compatibility with other crops, which may include se tbacks, consulting sensitive crop registries, and communicating with neighbors . The Product Use Guide will promote appropriate cultural practices including diversified weed control strategies (e.g. herbicide use or crop rotation) to minimize selection fo r herbicide resistant weed populations. Responsible use of the cotton seed and herbicides in an integrated farming system promotes compatibility with other crops. Herbicide Application and Management of Off - Target Movement The new 2,4 - D choline - containin g herbicide products will minimize off target movement by reducing volatility and the number of driftable fines . To further minimize the potential for off - target movement with the new 2,4 - D choline - containing herbicide products , the Product Use Guide will include recommendations on application equipment and methods such as following proper equipment maintenance, calibration and use. A variety of factors including weather conditions ( e.g. , wind direction, wind speed, temperature, and relative humidity) and method of application can influence pesticide drift . The Product Use Guide will require a pplicators to evaluate factors and make appropriate adjustments when applying 2,4 - D choline salt for use with DAS - 8191Ø
- 7 cotton consistent with the final product lab el approved by EPA . Dow AgroSciences is conducting significant research on nozzles for spray application. The Product Use Guide will include instructions on using specific nozzles that mi nimize driftable spray droplets and specified environmental condition s such as wind speed and field temperature that minimize the potential for off - target movement due to particle or vapor drift . Product Labels, Seed Bags and Tags Product Labels Dow AgroSciences will submit a product label to EPA that includes comprehe nsive information and requirements for responsible use of 2,4 - D choline with DAS - 8191Ø
- 7 cotton . That label language will include detailed use directions and application requirements designed to minimize the potential for weed resistance development, minimize the potential for off - target movement, and promote worker safety . For example , the submitted label willUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC not allow herbicide application through any type of irrigation equipment and will prohibit aerial application . Seed Bags and Tags Packages of DAS - 8191Ø
- 7 cotton seed will have product stewardship information on the seed bags and seed tags, including use requirements and a customer information telephone number. Information will be included on seed packaging to communicate the presence of herbicide tolerant traits. This information will also be included in the Product Use Guide, training, and marketing materials. Education and Training for Retailers, Growers and Applicators Dow AgroSciences will provide comprehensive education and trai ning in multiple formats to distributors, retailers, growers, and applicators to reinforce the requirements for proper stewardship and responsible use. Dow AgroSciences provides comprehensive training on its portfolio of products through a variety of forma ts. Education and training, reinforced through product profiles, technical bulletins, sales literature, direct mailing and websites will also be presented in multiple formats to enhance learning and mastery of core concepts related to the stewardship progr am. A variety of educational formats will be used to promote concept learning. Training will be provided through face - to - face meetings, retailer visits, field visits, and self - paced learning modules on:  s tewardship requirements for responsible use of DA S - 8191Ø
- 7 cotton and associated herbicides, including  w eed resistance management. This training will reinforce the cotton grower’s obligation to adhere to product use guidelines, FIFRA Pesticide Product Labels, seed product information and all product st ewardship requirements for responsible use and proper stewardship. Training is an ongoing process, with interactive learning incorporated, where applicable, to promote responsible use and stewardship. Multiple resources and tools will be available to the growers and applicators to promote and communicate the importance of stewardship and responsible technology use. In addition to the Technology Use Agreement, Product Use Guide, and training, additional resources will be available, including:  Customer Service  Technical Bulletins  AdvanceFarming.com  On - line training library  In - field experts  Trait stewardship website 4
4 www.traitstewardship.comUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC  Stewardship tools An extensive network of Dow AgroSciences sales representatives, field scientists, and agronomists will play an important role in educating and training retailers, growers and applicators on the proper use of the technology and application guidelines . Dow AgroSciences field personnel, in addition to product suppliers, will work with growers to select the see d and herbicide products appropriate to their needs, growing conditions, and proper application equipment for field conditions . Compliance Monitoring Dow AgroSciences will monitor compliance with the Technology Use Agreement and Product Use Guide throug h surveys and on - farm assessments. Upon request by Dow AgroSciences, DAS - 8191Ø
- 7 cotton growers must provide information regarding the location of fields planted with DAS - 8191Ø
- 7 cotton, and the herbicides applied to these fields. Failure to follow the s tewardship requirements will result in:  Education and reinforcement of the stewardship requirements with growers, applicators and retailers,  Additional education and training, and/or  Loss of access to DAS - 8191Ø
- 7 cotton. Stakeholder Outreach and Industry Involvement In addition to managing the technology in accordance with the applicable requirements of federal and state government agencies, Dow AgroSciences is a member of the American Chemistry Council's Responsible Care ® initiative and Founding Member of the biotechnology industry’s Excellence Through Stewardship ® organization which encourages effective and comprehensive stewardship programs and quality management systems throughout a trait product’s life cycle. Dow AgroSciences participates in s everal organizations and associations globally to promote the safe research and development, production, distribution, and responsible use of agricultural chemical and biotechnology products. Dow AgroSciences is a participant in the Herbicide Resistance Action Committee (HRAC) 5 , an industry - based group supported by CropLife International 6 . HRAC focuses on encouraging responsible herbicide usage, communicating herbicide resistance management strategies and supporting their implementation through practical guidelines . HRAC engages in active collaboration with public and private researchers, especially in the areas of problem identification and devising and implementing herbicide management strategies . Dow AgroSciences’ personnel interact with academic weed scientists in addressing weed resistance management 7 issues. Dow AgroSciences conducts joint trials at university sites as 5 www.hracglobal.com 6 www.croplife.org/public/resistance_management 7 www.wssa.net/Weeds/ResistanceUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC well as seeks input from university researchers regarding weed management. Dow AgroSciences also participates in a wide range of pro fessional organizations including agronomy societies, seed trade groups, weed science societies, and crop commodity groups. Conclusion Dow AgroSciences is committed to promoting the responsible use and stewardship of DAS 8191Ø
- 7 cotton and associated herbicide products. The comprehensive stewardship program outlined here incorporates elements to:  Promote responsible use of DAS - 8191Ø
- 7 cotton and associated herbicide products,  Promote compatibility with other crops and cropping systems ,  Promote Weed Resistance Management, and  Support compliance with all relevant state and federal requirements. The stewardship program, focusing on education and management practices for proper use of the cotton and herbicides, coupled with the physical attributes of DAS’ 2,4 - D choline formulation (e.g., ultra - low volatility, minimized potential for drift, decreased odor and improved handling characteristics) enables coexistence with organic crops, crops traditionally sensitive to 2,4 - D, and non - genetical ly engineered cotton . Education and training efforts are also an integral part of the stewardship effort, promoting awareness and understanding of proper use of the cotton and herbicides. The combination of EPA mandated herbicide label requirements, Dow AgroSciences’ stewardship program, and associated proprietary herbicide technology will provide the grower of DAS - 8191Ø
- 7 cotton with the tools needed to mitigate potential risk to human health and the environment without compromising farm productivity.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 9 . USDA Notifications for DAS - 8191Ø - 7 Cotton USDA Notification Number Authorization

Date Expiration

Date State(s) Number of Trials Trial Report

Status 1 13 - 063 - 109n 4/17/2013 4/17/2014 TX 12 Pending 13 - 053 - 106n 4/1/2013 4/1/2014 TX 3 Pending 13 - 063 - 110n 3/25/2013 3/25/2014 AR, CA, GA, LA, MS, NC, OK, SC 27 Pending 12 - 089 - 109n 4/26/2012 4/26/2013 LA 1 Pending 12 - 089 - 106n 4/26/2012 4/26/2013 TX 2 Pending 12 - 089 - 109n 4/26/2012 4/26/2013 AL, AR, CA, FL, GA, MO, MS, NC 9 Pending 12 - 089 - 101n 4/15/2012 4/15/2013 TX 13 Pending 13 - 066 - 104n 4/12/2012 4/12/2013 AL, AR, CA, GA, LA, MO, MS, NC 10 Pending 12 - 081 - 113n 4/6/2012 4/6/2013 AR, CA, GA, MO, MS, NC 13 Pending 12 - 062 - 102n 4/5/2012 4/5/2013 AR, CA, GA, LA, MO, MS, NC, OK, SC, TN 50 Pending 12 - 081 - 114n 4/4/2012 4/4/2013 TX 8 Pending 11 - 249 - 101n 11/1/2011 11/1/2012 PR 1 Submitted (Apr 2013) 11 - 147 - 101n 6/10/2011 6/10/2012 IN 1 Submitted (Nov 2012) 11 - 087 - 112n 4/29/2011 4/29/2012 AR, CA, GA, LA, MS, NC, SC, TN, TX 24 Submitted (Oct 2012) 10 - 076 - 102n 4/19/2010 4/19/2011 AL, AR, CA, GA, LA, MS, NC, SC, TN 29 Submitted (Oct 2011)

1 Pending reports to be submitted within six months of the notification expiration dateUSDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Appendix 10 . References Abranches, R., Shultz, R.W., Thompson, W.F., Allen, G.C., 2005. Matrix attachment regions and regulated transcription increase and stabilize transgene expression. Plant Biotechnology Journal 3, 535 - 543. Albers, D.W., Reinbott, D.L., 1994. Cotton tillage and planting guidelines: Report g4270. http://extension.missouri.edu/p/G4270 . Allen, G.C., Hall, G.E., Childs, L.C. , Weissinger, A.K., Spiker, S., Thompson, W.F., 1993. Scaffold attachment regions increase reporter gene expression in stably transformed plant cells. The Plant Cell 5, 603 - 613. Allen, G.C., Spiker, S., Thompson, W.F., 2000. Use of matrix attachment regio ns (MARs) to minimize transgene silencing. Plant Molecular Biology 43, 361 - 376. AOSA, 2009. Seed vigor testing handbook contribution no. 32. In: Baalbaki, R.J., Marcos - Filho, J., Elias, S.G., McDonald, M. (Eds.). AOSA, 2010a. Aosa rules for testing seeds volume 1. Principles and procedures. Association of Official Seed Analysts Inc. AOSA, 2010b. Aosa rules for testing seeds volume 4. Seeding evaluation. Association of Official Seed Analysts Inc. Arumuganathan, K., Earle, E., 1991. Nuclear DNA content of s ome important plant species. Plant Molecular Biology Reporter 9, 208 - 218. Bandeen, J.D., Stephenson, G.R., Cowett, E.R., 1982. Discovery and distribution of herbicide resistance weeds in North America. In: LeBaron, H.M., Gressel, J. (Eds.), Herbicide resis tance in plants. John Wiley & Sons, Rehovot, Israel, pp. 9 - 30. Barker, R.F., Idler, K.B., Thompson, D.V., Kemp, J.D., 1983. Nucleotide - sequence of the T DNA region from the Agrobacterium tumefaciens octopine Ti plasmid pTi15955. Plant Molecular Biology 2, 335 - 350. Barnekow, D.E., Hamburg, A.W., Puvanesarajah, V., Guo, M., 2001. Metabolism of 2,4 - dichlorophenoxyacetic acid in laying hens and lactating goats. Journal of Agricultural and Food Chemistry 49, 156 - 163. Belyea, R.L., Steevens, B.J., Restrepo, R.J., Clubb, A.P., 1989. Variation in composition of by product feeds. Journal of Dairy Science 72, 2339 - 2345. Benjamini, Y., Hochberg, Y., 1995. Controlling the false discovery rate: A practical and powerful approach to multiple testing. Journal of the Royal Statistical Society. Series B (Methodological) 57, 289 - 300. Berberich, S.A., Ream, J.E., Jackson, T.L., Wood, R., Stipanovic, R., Harvey, P., Patzer, S., Fuchs, R., L, 1996. The composition of insect - protected cottonseed is equivalent to that of conventio nal cottonseed. Journal of Agricultural and Food Chemistry 44, 365 - 371. Bertrand, J.A., Sudduth, T.Q., Condon, A., Jenkins, T.C., Calhoun, M.C., 2005. Nutrient content of whole cottonseed. Journal of Dairy Science 88, 1470 - 1477. Bourdot, G.W., Saville , D.J., Hurrell, G.A., 1996. Ecological fitness and the decline of resistance to the herbicide MCPA in a population of ranunculus acris. Journal of Applied Ecology 33, 151 - 160.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Bowman, D.T., Gutierrez, O.A., Percy, R.G., Calhoun, D.S., May, O.L., 2006. Ped igrees of upland and pima cotton cultivars released between 1970 and 2005. Bulletin 1155 Mississippi State University - Mississippi Agricultural & Forestry Experiment Station. Bradford, K.J., 2006. Methods to maintain genetic purity of seed stocks. ANR Pu blication 8189, 5. Bradshaw, L.D., Padgette, S.R., Kimball, S.L., Wells, B.H., 1997. Perspectives on glyphosate resistance. Weed Technology 11, 189 - 198. Burgos, N.R., Culpepper, A.S., Dotray, P.A., Kendig, J.A., Wilcut, J.W., Nichols, R.L., 2006. Managing herbicide resistance in cotton cropping systems. http://www.cottoninc.com/fiber/AgriculturalDisciplines/Weed - Management/ . CERA - ILSI Research Foundation, 2011. A revie w of the environmental safety of the PAT protein. International Life Sciences Institute. http://ceragmc.org/docs/cera_publications/pub_05_2011.pdf . Codex Alimentarius Commission, 200 1. Codex standard for named vegetable oils. www.codexalimentarius.net/download/standards/336/CXS_210e.pdf . Codex Alimentarius Commission, 2009. Foods derived from modern b iotechnology. www.fao.org/docrep/011/a1554e/a1554e00.htm . Coll, A., Nadal, A., Palaudelmàs, M., Messeguer, J., Melé, E., Puigdomènech, P., Pla, M., 2008. Lack of repeatable differential expression patterns between MON810 and comparable commercial varieties of maize. Plant Molecular Biology 68, 105 - 117. Cotton Incorporated, 2013. Crop rotation. http://www.cottoninc.com/fiber/Agricultural Research/State - Support - Program/SoutheastRegionReviewReport/ExecutiveSummary/08 - CropRotation/ . Cranston, H.J., Kern, A.J., Hackett, J.L., Miller, E.K., Maxw ell, B.D., Dyer, W.E., 2001. Dicamba resistance in kochia. Weed Science 49, 164 - 170. Curran - Everett, D., 2000. Multiple comparisons: Philosophies and illustrations. American Journal of Physiology - Regulatory, Integrative and Comparative Physiology 279, R1 - R8. Curran, B., Sprague, C., Stachler, J., Loux, M., 2007. The glyphosate, weeds, and crops series: Biology and management of common lambsquarters (GWC - 11). http://www.glyphosateweedscrop s.org/Info/GWC - 11.pdf . De Block, M., Botterman, J., Vandewiele, M., Dockx, J., Thoen, C., Gossele, V., Movva, N.R., Thompson, C., Van Montagu, M., Leemans, J., 1987. Engineering herbicide resistance in plants by expression of a detoxifying enzyme. The EMBO Journal 6, 2513 - 2518. Duan, J.J., Lundgren, J.G., Naranjo, S., Marvier, M., 2009. Extrapolating non - target risk of Bt crops from laboratory to field. Biology Letters 6, 74 - 77. Duke, S.O., 1996. Herbicide - resistant crops: Agricultural, environmental, eco nomic, regulatory, and technical aspects. CRC Press, Inc., Boca Raton. Duke, S.O., 2005. Taking stock of herbicide - resistant crops ten years after introduction. Pest Management Science 61, 211 - 218. Duke, S.O., Powles, S.B., 2008a. Editorial: Glyphosate - res istant weeds and crops. Pest Management Science 64, 317 - 318. Duke, S.O., Powles, S.B., 2008b. Glyphosate: A once - in - a - century herbicide. Pest Management Science 64, 319 - 325.USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC Dyer, W.E., 1994. Resistance to glyphosate. In: Powles, S.B., Holtum, J.A.M. (Eds. ), Herbicide resistance in plants: Biology and biochemistry. CRC Lewis Publishers, New York, New York, pp. 229 - 241. Emerson, E., 1943. The condensation of aminoantipyrine. II. A new color test for phenolic compounds. The Journal of Organic Chemistry 8, 417 - 428. EPA, 1997. Phosphinothricin acetyltransferase and the genetic material necessary for its production in all plants; exemption from the requirement of a tolerance on all raw agricultural commodities. Federal Register 62 (70): 17717 - 17720. http://www.gpo.gov/fdsys/pkg/FR - 1997 - 04 - 11/html/97 - 9373.htm . EPA, 2003. 2,4 - D HED MARC decision document, DP barcodes D293119 and D293128, Chemical ID No 030001, Case No. 0073. Meeting date 0 9/03/2003. Memorandum TXR No. 0052264. EPA, 2005. Reregistration eligibility decision for 2,4 - D. EPA 738 - R - 05 - 002. www.epa.gov/oppsrrd1/REDs/24d_red.pdf . EPA, 2007. Captan, 2,4 - D, dodine, DCPA, endothall, fomesafen, propyzamide, ethofumesate, permethrin, dimethipin, and fenarimol; proposed tolerance actions. Federal Register 72 (108): 31221 - 31237. www.gpo.gov/fdsys/pkg/FR - 2007 - 06 - 06/pdf/E7 - 10863.pdf . EPA, 2008. Memorandum re: Revisions of feedstuffs in Table 1 of oppts test guideline 860.1000 and guidance on constructing maximum reasonably balanced diets (MRBD). http://cfpub.epa.gov/ols/catalog/catalog_display.cfm?&FIELD1=SUBJECT&INPUT1=E ggs&TYPE1=EXACT&item_count=1 . EPA, 2013. Deem - fcid version 3.15. http://www.epa.gov/pesticides/science/deem/ . Evans, S.L., 2004. Producing proteins derived from genetically modified organisms for toxicology and environmental fate assessment of biopesticides. In: Parekh, S.R. (Ed.), The GMO Handbook: Genetically m odified animals, microbes, and plants in biotechnology. Humana Press, Inc., Totowa, NJ, pp. 53 - 83. FARRP, 2013. Allergen database, version 13, released in February 2013. Food Allergy Research and Resource Program. http://www.allergenonline.org/ . FDA, 1998. Biotechnology consultation agency response letter BNF No. 000055. ht tp://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm161092.h tm . FDA, 2001. Biotechnology consultation agency response letter BNF No. 000073. http://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm155765.h tm . FDA, 2003. Biotechnology consultation agency response letter BNF No. 000086. http://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm155758.h tm . FDA, 2004a. Biotechnology consultation agency response letter BNF No. 000081. http://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm155591.h tm . FDA, 2004b. Biotechnology consultation agency response letter BNF No. 000085. http://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm155756.h tm .USDA - APHIS Petition for Nonregulated Status of DAS - 8191Ø
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Dow AgroSciences LLC FDA, 2004c. Biotechnology consultation agency response letter BNF No. 0000092. http://www.fda.gov/Food/foodscienceresearch/Biotechnology/Submissions/ucm155750.h tm . FDA, 2011. Biotechnology consultation agency response letter BNF No. 000124. http://www.fda.gov/Food/FoodScienceResearch/Biotechnology/Submissions/ucm283172 .htm . Fling, M.E., Kopf, J., Richards, C., 1985. Nucleotide sequence of the transposon tn7 gene encoding an aminoglycoside - modifying enzyme, 3"(9) - 0 - nucleotidyltransferase. Nucleic Acids Research 13, 7095 - 7106. Foresman, C., Glasgow, L., 2008. US grower perceptions and experiences with glyphosate resistant weeds. Pest Management Science 64, 388 - 391. Fukumori, F., Hausinger, R.P., 1993. Purification and characterization of 2,4 - dichlorophenoxyacetate/alpha - ketoglutarate dioxygenase. The Journal of Biological Chemistry 268, 24311 - 24317. Goldberg, M., Knudsen, K.L., Platt, D., Kohen, F., Bayer, E.A., Wilchek, M., 1991. Specific interchain crosslinking of antibodies using bismaleimides. Repression of ligand leakage in immunoaffinity chromatography. Bioconjugate Chemistry 2, 275 - 280. Green, J.M., 2009. Evolution of glyphosate - resistant crop technology. Weed Science 57, 108 - 117. Greene, S.E., Reid, A., 2012. Moving targets: Fighting the evolution of resistance in infections, pests, and cancer. American Academy of Microbiology. Washington, DC. Griffin, S.L., Godbey, J.A., Oman, T.J., Embrey, S.K., Karnoup, A., Kuppannan, K., Barnett, B.W., Lin, G., Harpham, N.V.J., Juba, A.J., Schafer, B.W., Cicchillo, R.M., 2013. Characterization of aryloxyalkanoate dioxygenase - 12, a nonheme fe(II)/α - ketoglutarate dependent dioxygenase, expressed in transgenic soybean and Pseudomonas fluorescens . Journal of Agri cultural and Food Chemistry 61, 6589 - 6596. Gustafson, D.I., 2008. Sustainable use of glyphosate in north american cropping systems. Pest Management Science 64, 409 - 416. Hall, G., Jr., Allen, G.C., Loer, D.S., Thompson, W.F., Spiker, S., 1991. Nuclear sca ffolds and scaffold - attachment regions in higher - plants. Proceedings of the National Academy of Sciences of the United States of America 88, 9320 - 9324. Hamby, S., Hirst, J., 2008. Prediction of glycosylation sites using random forests. BMC Bioinformatics 9 , 500 - 512. Hamilton, K.A., Pyla, P.D., Breeze, M., Olson, T., Li, M., Robinson, E., Gallagher, S.P., Sorbet, R., Chen, Y., 2004. Bollgard II cotton: Compositional analysis and feeding studies of cottonseed from insect - protected cotton (gossypium hirsutum L .) producing the Cry1Ac and Cry2Ab2 proteins. Journal of Agricultural and Food Chemistry 52, 6969 - 6976. Han, K.H., Ma, C., Strauss, S.H., 1997. Matrix attachment regions (MARs) enhance transformation frequency and transgene expression in poplar. Transgen ic Research 6, 415

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