### Capital Reporting Company

US Department of Agriculture - Animal and Plant Health Inspection 11-17-2011

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U.S. DEPARTMENT OF AGRICULTURE ANIMAL AND PLANT HEALTH INSPECTION (APHIS)

Event H7-1, Roundup Ready Sugar Beet Draft Environmental Impact Statement Public Meetings

Thursday, November 17, 2011 4:00 p.m. - 7:00 p.m. Oregon State University LaSells Stewart Center Construction and Engineering Hall 875 Southwest 26th Street Corvallis, Oregon

Taken by: Kimberly McLain

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1 P R O C E E D I N G S 2 MR. GEORGE: If we could get started, please. 3 Thank you all for being here today. As part of a 4 public participation process, we are holding this 5 public meeting to solicit your comments on the draft 6 environmental impact statement for H7-1 sugar beets, 7 also known as Roundup Ready sugar beets. 8 My name is Dick George and I'm Communications 9 Branch Chief at Biotechnology Regulatory Services, a 10 part of APHIS, the Animal, Plant and Health Inspection 11 Service, which in turn is a part of the U.S.D.A. 12 Soliciting public comments is a very important part of 13 our process. We value your input and we are very glad 14 and grateful that you've taken the trouble to come here 15 today and be a part of our process. 16 Also with me are Rebecca Stankiewicz-Gabel, 17 Senior Environmental Protection Specialist. Rebecca's 18 been working on the microphone over on the side. And 19 Neil Hoffman, Science Advisor to the Office of the 20 Deputy Administrator. Neil is the person who signed 21 you in at the table outside and I think he's still out 22 there. Neil worked with our project managers on this 23 environmental impact statement on Roundup Ready sugar 24 beets. Information Officer Larry Hawkins is also with 25 us. 4

1 enforce the five minute time limit per speaker. 2 Unfortunately, even if you are not finished within that 3 time, we'll have to move on to the next speaker. We 4 appreciate your understanding. We will end our meeting 5 by 7:00 p.m. 6 When your name is called, please come to the 7 microphone on the side. Please begin by stating and 8 spelling your name for our court reporter and stating 9 your organization if you are representing one. Your 10 five minutes will begin after you've introduced 11 yourself. If you haven't done so already, please 12 provide Rebecca with a written version of your 13 statement at the end of your five minute time period if 14 you have it written out. You can also put written 15 comments in the comment box which is on the round table 16 in the back of the room. 17 If we have time after our speakers have 18 finished with their remarks, we'll have an informal 19 session in the back of the room. The purpose of this 20 session is to answer clarifying questions about our 21 process, not to discuss or debate the issues or 22 analyses of the draft. It's important to remember any 23 comment provided during this informal session are not 24 on the record. To be on the record, your comments must 25 be provided either during the listening session or as a

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1 Larry, are you in the room? 2 I think he's outside as well. Our court 3 reporter is Kim McLain. 4 Our purpose today is to take your comments 5 and to make them part of the public record. You can 6 also enter comments into the public record by going to 7 regulations.gov on the web and entering H7-1 sugar 8 beets in the search box. Public comment period ends on 9 December the 13th. All public comments will be 10 considered before a determination is made on the 11 regulatory status of Roundup Ready sugar beets. 12 On the table in the back of the room as you 13 entered, we have placed some handouts including an 14 Executive Summary Draft, EIS, fact sheets and other 15 information. There are also CDs of the Draft EIS. 16 Please feel free to take any of these materials. The 17 Draft EIS is also available on our website. 18 We are providing speakers five minutes to 19 present their comments. If you forgot to note at sign20 in that you wish to present your comment, please do so 21 now at the sign-in table. Rebecca will be our timer 22 and will let you know when your five minutes are up. 23 We appreciate everyone being polite and offering 24 comments in a civil way. In order to give everyone an 25 equal opportunity to speak, it's necessary for us to 5

1 written comment. 2 This concludes our introduction. We'll now 3 begin to take your comments. 4 Our first commentor is Charles Melberg. 5 MR. MELBERG: My name is Charles Melberg. 6 That's C-h-a-r-l-e-s, Melberg, M-e-l-b-e-r-g. 7 I'm from Hector, Minnesota. I'm a life-long 8 sugar beet grower and a major shareholder at our 9 Southern Minnesota Sugar Beet Cooperative. I'm 10 currently on the board of directors and sit on the seed 11 committee of the co-op. I'm a second generation sugar 12 beet grower. I have a farming partnership with my wife 13 and two sons and their families. We have grown Roundup 14 Ready sugar beets since they were made available to us. 15 I am currently in line for a quality yield that's 16 steadily increased than in the past when we planted 17 conventional seeds. We fully support Alternative 2 in 18 EIS which is a full deregulation of Roundup Ready sugar 19 beets. 20 We continue to need scientific research to 21 produce the highest yielding of quality sugar with the 22 least harm to the environment. It is important to be 23 able to produce sugar at a cost that makes it 24 competitive in the world market for generations to come 25 to our family farm. If we are forced to use only

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1 conventional seed in 2011, the family farms in our 2 cooperative would not have been able to harvest about 3 60 percent of our sugar beets which is approximately 4 69,000 acres. Because of the cool, wet weather in the 5 spring and the hot summers, with conventional seeds we 6 would not have been able to control the weeds and 7 diseases because of cool wet springs. There were not 8 enough dry days to spray industrial herbicide at the 9 correct timing. 10 The application time frame for industrial 11 herbicides is very tight and in order to kill the weeds 12 and we certainly do not want to apply herbicides before 13 a threatening rain storm. The yields on our farm since 14 the advent of Roundup Ready sugar beets are 15 to 20 15 percent greater. So we need fewer acres to produce our 16 crops which means there are less sugar beet acres being 17 covered by herbicides and the extra acres are being 18 freed up from Roundup Ready sugar beets that can be 19 used to plant other crops to feed the world. 20 I'm on the seed committee of the Southern 21 Minnesota Sugar Beet Cooperative and we have very 22 strict standards for both seed qualities and because we 23 have no other source of sugar beets to operate our 24 factories. We closely evaluate varieties through a 25 number of factors such as disease, resistance, sugar 8

1 technology and science to be able to compete in the 2 world sugar production and assure that my three 3 grandsons will be able to continue the practices we 4 have established in the past. On behalf of my family 5 and my fellow producers, please choose Alternative 2 in 6 the EIS and deregulate Roundup Ready sugar beets. 7 Thank you. 8 MR. GEORGE: Thank you. 9 Paul Stieber. 10 MR. STIEBER: Hello, my name is Paul Stieber, 11 P-a-u-l, S-t-i-e-b-e-r. I'm a third generation farmer 12 in Big Horn County, Montana. I have grown sugar beets 13 for 32 years, ten of those being for the farmer owned 14 Western Sugar Cooperative. I have been a director on a 15 local grower association for eight years, presently 16 serving as president. I also serve on the seed 17 committee. My 20-year-old son and I grow sugar beets, 18 winter wheat, and malt barley to maintain the three19 year rotation in our sugar beets. This rotation 20 prevents Roundup Ready resistant weeds. I have grown 21 100 percent Roundup Ready sugar beets since they were 22 first available in 2008. We currently grow Roundup 23 Ready sugar beets under a compliance agreement between 24 APHIS and the Western Sugar Cooperative. 25 There are many benefits to Roundup Ready

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1 content yield. It takes several years for us to find a 2 variety with the desired traits and make commercial 3 quantities available to our growers. We need the seed 4 company each year to evaluate if we are not making our 5 goals. We have not had any issues of red beets, Swiss 6 chard in our commercial seeds, even with isolation 7 distances in the Willamette Valley at 1.5 miles. This 8 is a strict standard in isolation distances of three or 9 four miles is totally well beyond whatever is needed 10 for or employed by other seed producers. 11 With respect to weed resistant issues, our 12 co-op and all of our members have gone through the 13 training for the compliance agreement. In our crop 14 rotation, we have different chemicals, for example, so 15 we do not have weed resistance in that crop. In the 16 area where we live in central Minnesota, we have very 17 harsh winters with temperatures at minus 40 degrees 18 below 0. There is no chance of any seed or sugar beet 19 surviving that winter. Sometimes it's hard for man to 20 survive the winters. You do not have any potential to 21 see a wild beet in Minnesota and no cross pollination 22 of sugar beets. 23 We very much appreciate all the time people 24 have spent to keep this excellent technology of Roundup 25 Ready sugar beets available to us. We need this 9

1 sugar beets and these are major benefits to the 2 environment, growers along with their employees, the 3 crop and the consumer. Roundup is a very safe 4 herbicide to the environment, the handler and the crop. 5 In the past with conventional sugar beets, we tank 6 mixed as many as four different herbicides that were 7 more toxic with less weed control and a lot of 8 situations requiring expensive hand labor that was hard 9 to acquire. Roundup has a flexible application window 10 with superior weed control resulting in increased 11 yields and does not require cultivation, so we are 12 creating fewer emissions. 13 The partial deregulation and compliance 14 agreements did not change the way we farm because good 15 stewardship practices like crop rotation and weed 16 control have always contributed to higher yields. My 17 technology use agreement with Monsanto also requires 18 certain stewardship requirements like the removal of 19 bolters and correct application rates of Roundup 20 herbicide. If we were to lose this technology, it 21 would increase our operating costs and make us less 22 competitive in the global market where some countries 23 are heavily subsidized. We would also lose young 24 producers who would move to other professions because 25 of the complicated, ineffective practice of

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1 conventional sugar beets. 2 As a seed committee member, we have always 3 required quality seed with disease and pest resistance 4 with high yield levels, also, variety purity without 5 the presence of bolters is a strict requirement. All 6 of these rules and requirements were around long before 7 Roundup Ready sugar beets were ever developed. 8 To address seed production in the Willamette 9 Valley, seed production for sugar beets Swiss chard and 10 table beets have been grown successfully for years in 11 the Willamette Valley because of field separation 12 guidelines. There are no risks of cross pollination 13 for Roundup Ready sugar beets in my growing area 14 because table beets and Swiss chard are not grown 15 there. 16 This decision affects over 940 Western Sugar 17 Cooperative growers producing 128,000 acres of sugar 18 beets. With these facts, we fully support Alternative 19 2, full deregulation of Roundup Ready sugar beets. 20 Thank you. 21 MR. GEORGE: Thank you. 22 Clay Crumbaugh. 23 MR. CRUMBAUGH: Good afternoon, ladies and 24 gentleman. My name is Clay Crumbaugh, C-l-a-y, C-r-u25 m-b-a-u-g-h. I am the Chairman of the Michigan Sugar 12

1 characteristics in terms of tons per acre, sugar per 2 ton, sugar per acre, emergence and disease and pest 3 resistance. Seed suppliers have already done 4 significant testing of their own prior to submitting 5 varieties to Michigan Sugar Company for evaluation. 6 Only varieties that meet or exceed Michigan Sugar 7 Company seed committee variety approval standards 8 become fully approved for planting by our growers. 9 Sugar beet seed production is a lengthy and 10 sensitive process. It can take many years to recover 11 from disruptive legal or policy changes. These changes 12 can cause productive varieties to be unnecessarily 13 eliminated and other desirable varieties to be in short 14 supply. Under my leadership, the seed committee has 15 open dialogue with our seed suppliers so that we don't 16 inadvertently cause a shortage in the supply of seed to 17 our market. The seed committee reviews the variety 18 approval standards annually and communicates closely 19 with our seed suppliers as we consider any changes. 20 Our suppliers host members of our seed committee at 21 their processing facilities from time to time to review 22 their seed growing, handling, processing, preparation 23 and packaging practices. 24 Losing Roundup Ready sugar beets would have 25 damaging effects to Michigan Sugar Company and its

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1 Company Seed Committee. I'm the Treasurer of the 2 Michigan Sugar Company West District Board. I have 3 been on the seed committee in Michigan since 1996 and 4 have been chairman of the committee since 2005. My 5 family and I have a cash crop farm in the geographic 6 center of the lower peninsula of Michigan where we 7 annually raise 900 acres of sugar beets along with 8 other crops. I have raised Roundup Ready sugar beets 9 on my farm since 2008 and have had no issues using the 10 technology. 11 In 2011, I raised my sugar beets under 12 compliance agreements between Michigan Sugar Company 13 and USDA APHIS. Michigan Sugar Company is comprised of 14 1,000 grower-owners who raise 160,000 acres of sugar 15 beets annually and employ 2,000 seasonal and full-time 16 employees. Michigan Sugar Company has a one-half 17 billion dollar direct economic impact on our economy in 18 Michigan. 19 High quality seed is very important to 20 Michigan Sugar Company and the grower-owners. We have 21 always received high quality seed from the Willamette 22 Valley. This is measured in Michigan by subjecting 23 varieties submitted by suppliers to testing standards 24 set by the Michigan Sugar Company seed committee. 25 These standards measure a variety's production 13

1 growers. Many growers would abandon sugar beet 2 production entirely. Yields would drop and weed 3 control would be hampered. Conventional herbicides 4 provide less effective weed control, are more subject 5 to weather problems and are toxic to the sugar beets 6 themselves. Conventional herbicides require precise 7 timing of application despite the weather for maximum 8 efficacy and reduced damage to the sugar beets. A wet 9 spring, like Michigan sugar growers experienced this 10 spring, with the old conventional herbicides would have 11 been devastating. Sugar beet acres would have been 12 replanted to another crop. Michigan Sugar Company 13 would have had less sugar beets to process this winter 14 resulting in less sugar produced for sale lowering the 15 payment to growers. This could have put our co-op in 16 jeopardy. Roundup Ready technology offers much greater 17 flexibility of timing, near perfect weed control and 18 causes no damage to the sugar beet crop. Going back to 19 the old method would be more labor intensive, would use 20 more fuel, would require more tillage of the soil, 21 result in less efficient sugar production, lower sugar 22 yield and less control of weeds. 23 Growers in Michigan are committed to good 24 stewardship of Roundup Ready technology and good 25 stewardship of the environment. Farmers in Michigan

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1 grew up on family farms just like I did. We have 2 received training in weed resistance management. We 3 are certified pesticide applicators and Michigan Sugar 4 Company growers have received training from Michigan 5 Sugar Company to ensure compliance with USDA-APHIS 6 requirements for producing Roundup Ready sugar beets. 7 Partial deregulation would not cause a significant 8 change in farming operations, only more reporting to 9 Michigan Sugar Company. 10 Sustainable agriculture is important to me. 11 Like most farmers, I take a long-term view of all 12 issues affecting agriculture. I am making a career of 13 farming as did my forefathers and my two sons are 14 planning to return to the family farm after college 15 graduation. 16 Cross pollination is not an issue in Michigan 17 because while sugar beets are a biennial seed crop, 18 they are an annual sugar crop. There is no chance of 19 survival of the root crop through a Michigan winter. 20 If a root did survive through the winter and did not 21 produce seed stalk the following summer, there is no 22 chance of cross pollination because there are no 23 compatible crops grown in the region for cross 24 pollination to occur. 25 I urge USDA-APHIS to restore deregulated 16

1 harvest weather, and a world class process makes the 2 area desirable for growing seed. Our growers have 3 always demanded and received pure and high quality 4 sugar beet varieties from the Willamette Valley even 5 while Swiss chard and table beet production has 6 occurred in the valley. 7 Prior to the production of Roundup Ready 8 seed, conventional seed was grown for decades in 9 isolation distance here in the Willamette Valley of 1.5 10 miles, which was very adequate to maintain high quality 11 seed for the buyers of that seed which is our growers. 12 When Roundup Ready sugar beet seed production was 13 introduced, those isolation distances at least doubled 14 to proactively -- to proactive -- in those isolation 15 distances. We believe that action was successful. We 16 also believe the final EIS should better reflect the 17 proactive stewardship measures taken by our seed 18 industry to double the isolation distances to make sure 19 producers of grade of seed species produce pure, high 20 quality seeds for all their customers. 21 Planting of sugar beet seed with the Roundup 22 Ready trait began in Southern Minnesota Beet Sugar 23 Cooperative in 2008. As more seed became available in 24 2009, over 90 percent of our crop was planted to 25 Roundup Ready seed. For the crop years of 2010 and

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1 status to Roundup Ready sugar beets. I appreciate the 2 arduous task of preparing the Environmental Impact 3 Statement and I thank you for the efforts that you have 4 put forth. I support proposed Alternative 2 granting 5 full deregulation of Roundup Ready sugar beets. 6 MR. GEORGE: Mark Arnold. 7 MR. ARNOLD: Good afternoon, my name is Mark 8 Arnold, M-a-r-k, A-r-n-o-l-d. I'm the Chairman of the 9 Board of Directors Southern Minnesota Beet Sugar 10 Cooperative. Our cooperative is in full support of 11 proposed Alternative 2, full deregulation of Roundup 12 Ready sugar beets. Southern Minnesota Beet Sugar 13 Cooperative was formed in 1972 after a processing plant 14 in Chaska, Minnesota ceased operation. Approximately 15 300 growers invested in the cooperative and built a new 16 factory in Renville, Minnesota. Today, the cooperative 17 has 509 growers, shareholders and plants 120,000 acres 18 of sugar beets each year. Each year our growers 19 purchase approximately 69,000 units of sugar beet seed 20 worth 18 million dollars which directly benefits 21 growers in the Willamette Valley. 22 Ever since the planting of the first sugar 23 beet crop for our cooperative in 1975, the primary 24 source of sugar beets seed has been the Willamette 25 Valley. Mild winters, low disease pressure, dry 17

1 2011, over 88 percent of the seed planted was Roundup 2 Ready. Weed control has always been a major challenge 3 for the production of sugar beets. With the use of 4 Roundup Ready trait, our growers have experienced much 5 better weed control, reduced cost of production, 6 increased yields and reduced weed production for future 7 years. 8 The use of Roundup Ready sugar beet seed has 9 given our cooperative growers a tool to be good 10 stewards to our environment. Growers now apply fewer 11 and much less toxic herbicides. Make fewer passes 12 through the fields with their tractors, thereby using 13 less fuel and lowering emissions. Without the use of 14 Roundup Ready sugar beets, our cooperative faces the 15 challenge of growers reducing acreage because of the 16 lack of weed control higher cost of production and the 17 option to grow other crops with Roundup Ready traits. 18 With the use of Roundup Ready sugar beets, the growers 19 of Southern Minnesota Beet Sugar Cooperative and all 20 American sugar beet growers, will be able to continue 21 to provide American consumers with a consistent and 22 safe supply of sugar. 23 On behalf of the Southern Minnesota Beet 24 Sugar Cooperative Board of Directors and all of its 25 growers and shareholders, I would like to express our

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1 appreciation for the hard work reflecting in the Draft 2 Environmental Impact Statement prepared by APHIS. 3 Again, Southern Minnesota Sugar Beet Cooperative is in 4 support of proposed Alternative 2, full deregulation of 5 Roundup Ready sugar beets. Thank you. 6 MR. GEORGE: Thank you. 7 Greg Loberg. 8 MR. LOBERG: Hello everyone. My name is 9 Greg, G-r-e-g, Loberg, L-o-b-e-r-g. I'm the Manager of 10 West Coast Beet Seed Company in Salem, Oregon. We 11 represent a diverse selection of seed growers in the 12 Willamette Valley. Member companies that initiate seed 13 production at West Coast Beet Seed include American 14 Crystal Sugar, Syngenta, Holly Seed and SES VanderHave. 15 West Coast Beet Seed has developed explicit 16 standard operating procedures and grower guidelines 17 intended to minimize or eliminate a movement of pollen 18 among seed fields and inadvertent seed mixing. West 19 Coast Beet Seed has strict protocols to minimize the 20 possibility of accidental mixing of our seed with any 21 other seed. We track seed from the time members 22 provide stock seed continuing through all phases of 23 seed production in field, including delivery of 24 multiple seed to our dedicated seed processing 25 facility. And finally, concluding in shipping 20

1 is to maintain a mapping system where fields are 2 recorded or pinned to ensure adequate isolation 3 distances between genetically compatible crops. The 4 pinning process is not unique to sugar beets or other 5 specialty seeds, having been used in such crops as 6 sunflowers for many years. 7 Isolation distances are agreed to by the 8 members of the Willamette Valley Seed Association. That 9 group provides an opportunity for seed savers to pin 10 crops with the assistance of Willamette Valley 11 Specialty Seed Association member. The Association 12 creates an environment of cooperation by promoting 13 coexistence among farmers growing competitive crops, 14 including those growing biotech sugar beets and those 15 growing non-biotech crops. 16 I know our growers, their businesses, and 17 often their family members. West Coast Beet Seed has 18 worked with them as partners and enjoys relationships 19 with some who are now in their third or even fourth 20 generation of producing seeds for West Coast Beet Seed. 21 Many of our growers are members of the recently formed 22 grower association to promote and preserve specialty 23 seed production and they pay dues to the Specialty Seed 24 Growers of Western Oregon. 25 West Coast Beet Seed Company supports full

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1 processed seed to members. These procedures include 2 scheduled and ongoing grower and staff training, 3 careful monitoring of seed production during growing 4 season. Prohibiting seed growers from growing other 5 Beta species, cleaning equipment before and after 6 harvest of a sugar beet variety, and monitoring for and 7 eliminating volunteer sugar beets after harvest. 8 I have been in my position since 2007 and 9 have been in the industry for over 31 years. I have 10 worked closely with Willamette Valley Speciality Seed 11 and have been an officer since 2008. Including time in 12 the more distant past, I have worked with the 13 Willamette Valley Specialty Seed Association for about 14 12 years. West Coast Beet Seed is a member of the Seed 15 Association. It was formed in 1980 by companies 16 involved in vegetable, sugar beet and other specialty 17 seeds. With the assistance of Oregon State University, 18 this group was created to promote quality seed 19 production. 20 All commercial companies producing seed in 21 the Willamette Valley are members of the Willamette 22 Valley Specialty Seed Association. New memberships are 23 encouraged and pursued in order to maintain full 24 representation of specialty seed production. One of 25 the major activities of Willamette Valley Association 21

1 deregulation of Roundup Ready sugar beets. Thank you. 2 MR. GEORGE: Thank you. 3 Rodney Hightower. 4 MR. HIGHTOWER: My name is Rodney Hightower, 5 R-o-d-n-e-y, Hi-g-h-t-o-w-e-r. 6 I'm the Vice President of Strome Farms 7 located in Junction City, Oregon. I have served a term 8 as president of both the Oregon Seed Growers League and 9 the Oregon Seed Council. Our farm has been growing 10 various seed crops for more than 70 years on about 750 11 acres. Sugar beet seed has been in our crop rotation 12 for more than 35 years. It is one of our higher-value 13 crops and provides a very good return to us. They are 14 a significant and stable part of our yearly income. If 15 we were not able to grow sugar beet seeds, it would 16 have a strong financial impact on our business. We in 17 the seed production industry understand the roles of 18 cropping history, crop rotations, isolations and field 19 and machinery sanitation plays in producing a 20 genetically pure, clean and quality seed product. Our 21 contract with the beet company requires that we follow 22 very strict production standards. We spend a 23 tremendous amount of time and effort to grow the best 24 crop possible because the market demands that we meet 25 these quality standards.

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1 There is no market for genetically inferior 2 or contaminated seed. Isolation distances are 3 important to avoid cross pollination. Every seed crop 4 grown in this valley has to deal with this issue and 5 make sure both the growers and seed companies have 6 extensive experience dealing with the various systems 7 that are in place to ensure the Willamette Valley keeps 8 its reputation as a premier seed growing region. 9 Because we also produce other seed crops that 10 have to be free of contamination from weeds and other 11 crops, we go to great effort to control volunteers from 12 previous crops and crops that are currently growing in 13 a given field. This past year was the fourth year that 14 we have grown sugar beet seed with the Roundup Ready 15 gene. In our experience, we have not had any problems 16 controlling volunteer plants. Roundup Ready sugar beet 17 volunteers are easily controlled with tillage in our 18 crop rotation. There are also crops highly susceptible 19 to other herbicide chemistries that we may use if the 20 need arises. I feel that there is very little chance 21 that this crop becoming a weed could not be controlled 22 because it is an annual plant and there are several 23 control measures. 24 I urge the USDA to fully deregulate Roundup 25 Ready sugar beets so that the sugar industry can 24

1 and Hearing chairman for the Junction City Lion's Club 2 but most of all a father to one son and six daughters. 3 We have been growing sugar beets on our farm 4 since 1986. Two years ago we raised 120 acres of sugar 5 beets from seed which accounted for 25 percent of our 6 income on only six percent of our land. These numbers 7 share the value of what raising sugar beet seed has 8 offered our farm. This past year, we were limited to 9 only 28 acres due to the regulations of the industry 10 and the lack of good roots available for the same 11 reason. This over-regulation of the sugar beet 12 industry is a burden carried by the growers. We hope 13 this can be relieved through deregulation of the sugar 14 beet industry. 15 I believe the integrated pest management 16 activities undertaken by growers already, along with 17 strict rules imposed by our contracting company, 18 ensures the protection that the regulations duplicate. 19 We are contracted by the Beta-Seed Inc. 20 which has strict, significant stewardship 21 measures that we must adhere to. There are isolation 22 distances imposed. Volunteer control methods either 23 physical or chemical that growers employ within crop 24 rotations. There is also strict limitations between 25 sugar beet seed crops and on seed producers land and a

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1 continue to produce profitable sugar without the 2 uncertainty that has been hovering over this crop. 3 Thank you. 4 MR. GEORGE: Thank you. 5 John Reerslev. 6 MR. REERSLEV: Good afternoon. My name is 7 John, J-o-h-n, Reerslev, R-e-e-r-s-l-e-v. And I am one 8 of the Beta-Seed's sugar beet growers from Junction 9 City located in the southern part of the Willamette 10 Valley. I farm with my two brothers providing our 11 family income through sustainable farming operation as 12 the economic, social and environmental conditions 13 allow. Our family has farmed in the Junction City area 14 since my grandparents immigrated from Denmark around 15 1910. Over time, our farm has evolved into a 2,000 acre 16 operation producing peppermint oil, perennial rye grass 17 and tall fescue for turn markets, wheat and hybrid 18 sugar beet seed. 19 I graduated from Oregon State University in 20 Agronomic Crop Science. I have been actively involved 21 in numerous agricultural associations such as the 22 Oregon Essential Oil Growers Association, Oregon Mint 23 Commission, Mint Industry Research Council and Eugene 24 Farmer's Supply Co-op as well as several other civic 25 groups within my community. Including being the Sight 25

1 zero volunteer policy in new plantings in sugar beets 2 for seed for the production of high quality hybrids the 3 sugar industry demands for disease and sugar content. 4 The future of producing Roundup Ready sugar 5 beet seed depends on the root grower's success to 6 continue to grow our seeds. Fewer root growers mean 7 less of a need for my farm to continue to grow sugar 8 beet seed. If the industry does not deregulate or 9 totally ban the use of the genetically modified sugar 10 beet plants, many current sugar beet growers will not 11 return to growing conventionally propagated beets 12 because some have said they will no longer be able to 13 grow a quality product economically. This is because 14 the costs and the lack of the available chemical 15 control methods to control their current weed problems 16 associated with the production of sugar. The 17 production of sugar beet seed on our farm is 18 financially and economically very important to our 19 business. It is important as a rotation crop for our 20 sustainability. 21 I encourage the USDA to fully deregulate 22 Roundup Ready sugar beets so we can continue to produce 23 a high quality, pure sugar beet seed to support our 24 country's domestic sugar production. Let's work toward 25 making our own country sustainable in producing more

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1 sugar ourselves versus to have it imported. At the 2 same time, we can further support the thousands of 3 family farms that grow sugar beets as well as the 4 infrastructure that supports the industry. Thank you. 5 MR. GEORGE: Thank you. 6 Harry MacCormack. 7 MR. MACCORMACK: My name is Harry, H-a-r-r-y, 8 MacCormack, M-a-c-c-o-r-m-a-c-k. I'm a small, organic 9 -- certified organic grower here in the Willamette 10 Valley and I would urge that the sugar beet industry be 11 regulated as all biotechnical seeds should regulated. 12 One of the things that the USDA has to look 13 at when we are certified through USDA, we cannot have 14 any GMO contamination in our products and I do grow 15 beets and I grow chard and there is some evidence here 16 on the valley floor that there has already been 17 crossing. And I think other people will speak to that 18 that know more about that than I do. This is just one 19 of the biotech tools and I'm not particularly against 20 biotechnology. I just think that we need to regulate it 21 and the fact that there was a court case in 1980 that 22 allowed all this seed to be privately owned and 23 therefore impact our personal farms as a result and has 24 throughout court cases. It's not a technology that is 25 -- the impact of it is not a technology that we have 28

1 through fallen seeds. The placement of the transgene 2 in only the female parent will certainly reduce 3 movement via pollen. There must be an agreed upon 4 level of admonitious presence in transgene and non5 transgenic crops. I also believe that if managed 6 correctly, Roundup Ready sugar beets offer benefits for 7 weed control for sugar beets growers. 8 My other comments will address statements 9 related to the Alternatives presented in the EIS which 10 I consider to be inaccurate or potentially misleading 11 to persons not well informed about herbicide use and 12 herbicide resistance in weed populations. 13 Alternative 1 has what I would consider to be 14 a misleading statement that there would be an increase 15 in the usage of the 12 herbicides registered for use in 16 sugar beets. The usage would return to a level that 17 was used before the introduction of Roundup Ready sugar 18 beets. There is no evidence that the usage of those 19 would increase. Although an argument can be made that 20 the herbicides have more environmental impact than 21 glyphosate, if herbicides are currently registered and 22 labeled and used both by the Environmental Protection 23 Agency and State Departments of Agriculture. I would 24 request that the APHIS provide data to support the 25 statement that there are many weeds present in sugar

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1 had any choice over. It's come to us and been laid on 2 us and it threatens the whole organic industry. The 3 deregulation of alfalfa is the first thing. Sugar 4 beets are going to be the second, and there's some of 5 us here today that are quite worried about the coming 6 of biotech wheat into the valley. So I would say that 7 the regulations need to stand and that's it. Thank 8 you. 9 MR. GEORGE: Thank you. 10 Carol Mallory-Smith. After Carol we have 11 Camille Hall would be next. 12 MS. MALLORY-SMITH: I'm Carol Mallory-Smith. 13 C-a-r-o-l, M-a-l-l-o-r-y, hyphen, S-m-i-t-h. Some of 14 you in the room know that I'm a professor of Wheat 15 Science at Oregon State University and I want to make 16 it clear that my comments do not represent any opinion 17 but my own and not those of Oregon State University. 18 I'm not here to endorse any of the Alternatives that 19 are being suggested. I would also like to make it 20 clear, in my opinion, that I don't believe that the 21 transgenic sugar beets in question, H7-1, present human 22 health risks. 23 I also believe that transgenic and non24 transgenic crops can coexist in the Willamette Valley 25 but that gene movement will occur at some point either 29

1 beet fields. 2 Resistance has rarely been reported to have 3 evolved in sugar beet production fields. In fact, the 4 strongest recommendation for preventing resistance is 5 the rotation of herbicides with different sites of 6 action along with alternative methods of weed control 7 such as killers. Conventional sugar beet production is 8 at a lower risk for selection of resistant weeds than 9 will be a system that is relied upon by only one 10 herbicide. 11 The assertion that there would be more aerial 12 application of herbicides under Alternative 1 needs to 13 be substantiated. Herbicides now registered for use in 14 sugar beets are often soil applied and require 15 incorporation or are applied in advance. It's more 16 likely that applications applied the same would be 17 applied by air especially if the applications are 18 needed late in the growing season. And this would be 19 done to prevent crop damage from spray equipment. 20 Under Alternative 2, there's a statement 21 providing that APHIS would expect that there would be 22 stewardship by the companies but it has no authority to 23 require monitoring or any compliance for action with 24 full deregulation. APHIS -- under Alternatives 2 and 25 3, APHIS should also include any data to support the

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1 statement as related to glyphosate resistant weeds that 2 industry and growers are aware of the situation and 3 will likely take proactive measures aimed to reduce and 4 delay the development as glyphosate resistant weeds. 5 This has not occurred in other Roundup Ready products 6 where, for example, glyphosate resistant weeds are now 7 a major issue in, "soybean and cotton Roundup Ready 8 production systems." 9 And in fact, the resistance management 10 strategy provided by one Monsanto data sheet for the 11 ingenuity of Roundup Ready sugar beets, the first three 12 recommendations are an application of glyphosate. 13 Roundup WeatherMax can be applied in a single season up 14 to 5.3 quarts are allowed and the pattern of use will 15 apply tremendous selection pressure to the evolution of 16 resistant weeds and is modifiable resistance management 17 strategy. Glyphosate resistant weeds are an ongoing and 18 increasing production problem. 19 MR. GEORGE: Thank you. Camille Hall, 20 please. Next will be Doug Zielinksi. 21 MS. HALL: I'm Camille Hall. C-a-m-i-l-l-e, 22 H-a-l-l. I'm here to speak in support of Alternative 23 1. The Willamette Valley is the heart of an important 24 movement to reduce our independence on fossil fuels and 25 to rebuild an effort for food security which would 32

1 sugar beet industry has succeeded and will continue to 2 do so without the use of Roundup Ready seed. There is 3 no compelling reason to approve this petition. 4 Alternatives 2 and 3 will clearly have a significant 5 adverse effect on organic farms and the organic seed 6 industry in Oregon and other areas that grow and rely 7 on organic seeds for crops. 8 MR. GEORGE: Thank you. 9 Doug Zielinski. Next up would be Kerry 10 Bowen. 11 MR. ZIELINSKI: Good evening or afternoon. 12 Doug Zielinksi, Z-i-e-l-i-n-s-k-i. I'm the owner of 13 Alpha Nursery in Salem. It's a nursery and farming 14 operation. We are a family business and I am the 15 fourth generation and I have my two sons which are the 16 fifth. Our farm began growing sugar beets in -- back 17 as far as 1949 and have continued to be in production 18 since. Sugar beets are one of the crops that fits in 19 our diverse farming operation. We also produce row 20 crops and corn, beans, onions, wheat and other seeds 21 such as grass and radish. 22 This crop plays an important role in 23 contributing towards the bottom line of our company. 24 Sugar beets when planted during the fall and winter 25 months fit our labor force and equipment crop rotation

31

1 minimize the need to transport food necessary to 2 support our population centers. Much of this effort 3 centers around the organic farm movement. 4 MR. GEORGE: Can you get a little closer to 5 the microphone, please. 6 MS. HALL: Organic seeds are an essential 7 part of organic farming. And table beets, Swiss chard 8 and like products play an essential role in crop 9 production and seasonally available food crops to this 10 state and nationwide. What's at stake are farms' 11 livelihoods. Not only commercial organic seed 12 producers, but also the small organic farmer who relies 13 on producing and saving their own seeds. This is a 14 historic moment where Monsanto, with corporate tax 15 breaks, lobbyists and employees working for USDA, are 16 pressing its advantage to expand its market for Roundup 17 Ready -- Roundup herbicides. 18 Approval will lead to the expanded use of 19 their trademarked herbicide, industry relied on, 20 patented Roundup Ready seed. It will also shut down 21 the seed production of organic beets and related greens 22 because many of the best places to grow sugar beet seed 23 are also the best places to grow these organic 24 products. 25 I urge the USDA to adopt Alternative 1. The 33

1 very well. They also contribute to the soil quality of 2 our farm. Not only does sugar beet seed work well on 3 our farm, it is very important for the Willamette 4 Valley. Because of the unique climate, characterized 5 by the mild winter temperatures and long dry summers 6 for harvest, it's the most ideal place to grow sugar 7 beets in the U.S. For this reason, the vast majority of 8 our seeds that is sold to beet growers throughout the 9 U.S. is grown here -- everything is grown here. 10 The crop has proven to be a very viable one 11 for our future and is bright and the demand for seed 12 continues to grow, due to the fact that refineries for 13 sugar production relies increasingly on sugar from 14 sugar beets. Because of this demand and the fact that 15 the seed is only grown here, beet seed has huge 16 financial impacts on the valley. If we were to abandon 17 this specialty crop, the trickle down effect would be 18 massive. If would affect not only the farmers, the 19 seed producers, but the allied industries ranging from 20 the banks, ag chem, equipment, accountants, insurance 21 providers and most importantly, our employees. 22 I believe that West Coast Beet and the WVSSA 23 have done a very thorough job in providing growers with 24 all the necessary growing procedures as well as the 25 mapping that you've heard about, our crop rotations and

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1 recognizing our isolation distances. For decades now, 2 we have -- have the responsibility to work together and 3 seem to work just fine protecting all species. Farms 4 like mine in the Willamette Valley need to be to able 5 to continue to provide the market with the demands 6 including -- which includes sugar beet seed. While 7 many commodity types in crops are inconsistent as far 8 as the supply and demand over the years, specialty 9 crops such as sugar beet seed have been more than 10 consistent in providing our farms with a steady income. 11 I would hate to have this phased out in our family 12 business because of some burdensome and unnecessary 13 regulations Thank you. 14 MR. GEORGE: Thank you. 15 Kerry Bowen and then next up will be Matt 16 Croker. 17 MR. BOWEN: Good afternoon. Kerry Bowen, K18 e-r-r-y, B-o-w-e-n. I'm a third generation beet 19 grower. I got my start with the FFA project in the 20 '70s. I currently grow 500 acres of beets, originally 21 for the Amalgamated Sugar Company. Now I grow for the 22 Snake River Sugar Company when the grower bought the 23 company. I also raise wheat, dry beans and alfalfa. 24 I've raised 100 percent of my beets with 25 Roundup technology since 2008. And I still grow them 36

1 ineffective and very costly for growers. 2 Right now, we are operating under the 3 Monsanto agreement which already Monsanto requires 4 certain protocols to be followed and also removes 5 bolters out of our field. For this reason I urge -- 6 strongly urge for a full deregulation. 7 I'm also Chairman of the Snake River Seed 8 Committee, a position I've held for 12 years. As that 9 chairman of that committee, I'm responsible to oversee 10 our official trials, review the data provided by our 11 research committee and to make recommendations to that 12 committee so they can make an informed decisions about 13 the product we are approving. With rhizomania becoming 14 the responsibility of the seed committee to approve 15 varieties that are no longer in the area. As with 16 rhizomania, the seed quality is paramount to the end 17 growers. These requirements include rhizomania 18 resistance, curly top resistance, quality of pounds of 19 sugar per acre and pounds per ton. 20 It's also our responsibility to monitor the 21 beet seeds that come into the area and removes market 22 status from varieties which do not or we don't like, 23 such as bolters and/or chard. Currently, we have 24 varieties of market status this year is poor quality or 25 poor rhizomania existence. For a variety to become

35

1 under a compliance agreement between the Snake River 2 Sugar and the APHIS. I support proposal 2 and really 3 appreciate APHIS for working so hard to continue to 4 allow me to use this tool. I used to have a witches 5 brew of six different chemicals in order to control the 6 weeds in my beet crop. Some of them within 48 hours 7 had retrainables. I called it chemotherapy because I 8 took my crop to the brink of death and then revive it. 9 This is the physical evidence. 10 The Roundup allows me to reduce my tillage 11 and right now I'm heavy into rototilling which leaves a 12 smaller carbon footprint. All these are available to 13 me because of Roundup. When I grow silage corn, I stay 14 away from Roundup on my corn because of a plethora of 15 other chemicals available for weed control, thus, I 16 have less of a chance of Roundup resistant weeds. As 17 with growers, we do our best to be good stewards to the 18 resources we have control over. I was the grower 19 representative at the time rhizomania was found in our 20 valley. I was the third grower to be diagnosed with 21 this virus which led me down the path that brought me 22 here today. When rhizomania was diagnosed in Idaho, 23 the Idaho Department of Ag implemented protocols for 24 weed growers to follow. In a couple years those 25 protocols were abandoned and they were found to be 37

1 official in our trial, it took two years to get a 2 status and our growers are clamoring for better and 3 newer varieties. And to help with being profitable, 4 Roundup makes a tool to assist us in this. Right now, 5 we have over 50 different varieties and because of the 6 competition for better varieties, they don't hang 7 around very long. Five or six years is an old variety 8 and the ones that have been around ten years, that's a 9 grandfather. Compared to wheat, which I've been 10 growing the same variety over 20 years, beets evolve a 11 lot quicker. 12 Thank you for your support and listening to 13 me. 14 MR. GEORGE: Thank you. 15 Matt Croker followed by Bruce Ruddenklau. 16 Matt Croker, please. No? Okay. Then we go to Bruce 17 Ruddenklau. 18 MR. RUDDENKLAU: Bruce Ruddenklau, B-r-u-c-e, 19 R-u-d-d-e-n-k-l-a-u. Good afternoon. My wife Helen 20 and I farm at the Amity area, 50 miles north of here on 21 the west side of the Willamette Valley. We farm around 22 1,000 acres on which we grow grass seed, wheat for 23 certified seed, clover seed, radish seed, metaphone 24 seed, dried peas, sweet corn, and bush beans. We also 25 raise sugar beet seed on contract with West Coast Beet

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1 Seed. It was a very lucky break for us to get five 2 acres of beet seed production in 1994, our third year 3 of farming. Since then, we've expanded our operation 4 and so has our beet seed acres and so now we annually 5 raise about 40 to 50 acres of beets. The Willamette 6 Valley is well known for a high quality, consistent 7 production of many seed crops. The purity of these 8 crops is guaranteed by the Oregon State University 9 certification system. We have to adhere to standards 10 of crop rotation, isolation distances and weed 11 tolerances. This is common practice with seed growers 12 in the Willamette Valley. 13 For crops not covered by this system, there 14 is stringent protocol in place to decide how -- which 15 crops to be grown where. This protocol has worked well 16 for a number of years and resulted in uncontaminated 17 seed crops of similar types and species being produced 18 within one geographic area. We follow guidelines of 19 isolation distances, rotation schedules, cultivation 20 practices and herbicide use, all for the specific 21 purpose of avoiding cross contamination. This is all 22 especially true for sugar beet seed. In many ways, 23 much of our cropping rotation revolves around the 24 placement of this crop. We plan four to five years out 25 in order to have fields and meet isolation requirements 40

1 moving into a valuable crop. 2 Finally, I'd like to say a word about West 3 Coast Beet Seed. I raise seed crops for many different 4 seed companies but few in my experience offer the 5 honesty and integrity that characterizes West Coast 6 Beet Seed. I'm proud to raise the sugar beet seed that 7 in turn another farmer uses to grow his livelihood 8 which provides tremendous value to the whole continent. 9 Under the watchful eye of the reputable beet seed 10 companies in the Willamette Valley, I believe we have 11 proven we can produce this crop in a responsible 12 manner. Thank you. 13 MR. GEORGE: Thank you. 14 Clint Lindsey is next. He will be followed 15 by John Brice. 16 MR. LINDSEY: Good afternoon. My name is 17 Clint Lindsey and I'm with A2R Farms Alliant Seed and 18 Grain. My family has been farming in the valley since 19 the '60s. We grow grass seed, oats, beans, wheat, 20 flax, various other seed crops. Also part of a group 21 of farms that is basically set up to increase the 22 availability of staple foods, most of those grown 23 organically. 24 My chief concern is that by allowing the full 25 deregulation GMO quality sugar beets it will lead to a

39

1 as well as crop history and herbicide history. 2 During the growing season we are careful not 3 to accidentally transfer any pollen or mature seeds out 4 of the field. At harvest time, we have to load our 5 seed into boxes within the field boundary, again, not 6 to let any viable seeds escape. A whole load is 7 thoroughly topped before transport. After harvest, the 8 seeds and husks fall on the ground and are allowed to 9 sprout and then killed before a new crop is planted. 10 We do not plow under any viable seeds which could then 11 sprout later on. The fields are scouted for a few 12 years after beets have been produced to make sure there 13 are no volunteer plants, and if so, they are removed. 14 Meeting this requirement is not easy, but the 15 rewards of doing so make it well worth the effort. 16 Sugar beet seed are one of the highest returning crop 17 and in many cases, worth twice as much as wheat, corn 18 or grass seed. It is a very unique crop and the value 19 of it remains consistent regardless of the falling in 20 Wall Street or the fluctuations in the market. Beet 21 seed remains a stable, high-value crop and as husbandry 22 and harvest are done with minimal additional equipment 23 over and above what a typical seed producer would have 24 on hand. There's also a great rotation for grass seed. 25 By allowing us a chance to control the grass we grow by 41

1 slippery slope to allow other GMO crops in the valley. 2 I think sugar beets are just the first step. I find it 3 somewhat ironic that six years ago when we applied for 4 a permit to grow canola, we said many of the same 5 things that some of my fine colleagues are saying now, 6 which is we would cover our loads. We would kill 7 volunteers. We would make all provisions for cleaning 8 our equipment. We met and exceeded the ODA's 9 requirements for approving that permit but were still 10 denied because of the perceived threat to the vegetable 11 seed industry and I respect that decision. I think it 12 was ultimately the right decision. So now, we're 13 hearing the same arguments from seed growers who are 14 saying we've been doing this responsibly for awhile but 15 we can control these risks. 16 We've also heard statements that are saying 17 that it's almost inevitable that you will eventually 18 see GE traits in the non-GE varieties. Well, that's an 19 unacceptable risk to us. Why risk a whole industry, 20 you know. We have a very unique position here in the 21 Willamette Valley. We have a burgeoning organic seed 22 industry that is under direct threat from genetically 23 modified crops and I don't want to mortgage the future 24 of our ability to provide organic food so that Monsanto 25 can line their pockets. Thank you.

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1 MR. GEORGE: John Brice will be followed by 2 Bud Laurent. 3 MR. BRICE: Good afternoon. My name is John 4 Brice, J-o-h-n, B-r-i-c-e. I've been a member of 5 several supply cooperatives and grower cooperatives and 6 the processes over the last 43 years of my professional 7 life. I have -- 8 MR. GEORGE: John, can you just get a little 9 closer to the microphone, please. That's great. 10 Thanks so much. 11 MR. BRICE: I have served on boards of 12 directors for Eugene Farmers Supply Co-op and Agropac. 13 I have grown crops for numerous processors including 14 Beta-Seed. I am a second generation farmer in a family 15 that has operated here for over 60 years. We farm 16 approximately 700 acres and raise wheat, green beans, 17 sweet corn, peppermint, radish seed as well as sugar 18 beet seed. We have been raising sugar beets for at 19 least 35 years. Our operation employs five full-time 20 persons and many seasonal workers. Most of our 21 rotational crops require us to follow up with thorough 22 measures to minimize volunteers going forward and 23 eradicate what few survive these efforts before they 24 mature. Most of our companion crops -- companion crop 25 customers don't want sugar beets growing in their 44

1 about what your agency is about to decide. 2 Because of my background, I appreciate and 3 respect the American tradition of family farming and 4 the strength of this tradition was a large reason of 5 my wife and I choosing to settle here. It takes guts to 6 be a small farmer and there are many examples of gutsy 7 people here in the Willamette Valley. Striving 8 successfully to compete with corporate agriculture by 9 using the tools made at the bedrock of American 10 farmers. Intelligence, commitment, innovation, market 11 demand and sheer hard work. However, the tradition has 12 been under attack for decades now and these family 13 farms are consistently replaced with corporate 14 agribusinesses besides something viable and valuable is 15 being lost to the fabric of America. The impending 16 decision at the heart of this hearing may have little 17 to do to impede that trend should you forbid the use of 18 wholesale Roundup sugar beets in the Willamette Valley, 19 but should you find in favor of further corporatization 20 of the sugar beet industry, you will constitute another 21 nail in the coffin of the American small farmer. 22 I'd like to briefly list a few things that I 23 think we should all be concerned about. First, the 24 affects of imposed isolation zones. In order to 25 protect against genetic cross fertilization caused by

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1 fields. If we are not allowed to continue to grow 2 sugar beets, Roundup Ready sugar beets, it would have a 3 significant negative financial impact as well as 4 seriously complicating our rotations with other crops. 5 It seems to us that not being able to grow 6 Roundup Ready sugar beets would greatly hinder 7 production of the crop as many of the other chemistries 8 are either unavailable or have lost efficacy. It also 9 seems that permanent regulation is not needed as it is 10 not seem to be -- there does not seem to be any 11 evidence of cross pollination having really been shown 12 to be a problem. Therefore, we support full 13 deregulation of sugar beets. 14 MR. GEORGE: Thank you. 15 Bud Laurent. He will be followed by Katy 16 Stokes. 17 MR. LAURENT: Thank you. My name is Bud 18 Laurent, B-u-d, L-a-u-r-e-n-t. I'm a resident of the 19 Willamette Valley just a few miles from here, about 20 three miles to the east of the Willamette River. My 21 neighborhood is surrounded by, at the moment, grass 22 seed farms which we greatly enjoy. While I was raised 23 in an agricultural family, I am not a farmer. I have 24 no direct economic connection to agriculture. So I 25 appear here today as just an American citizen concerned 45

1 winds, is up to six miles isolation zone, if I'm 2 understanding it correctly, has been recommended under 3 one scenario to provide adequate protection to non-GMO 4 crops from contamination by GMO crops. The corporate 5 sugar beet industry has apparently complained about the 6 size of the zone and it has proposed a reduction to at 7 least a three-mile radius and not farther, thereby 8 further reducing the statistical protection assumed the 9 surrounding agriculture. 10 My questions of you are, is this zone placed 11 only on the sugar beet land in question, and if so, 12 what will the non-sugar beet zone be used for? Have 13 you counted the total isolation zones for the 14 Willamette Valley and what the impact on agriculture 15 in the regional economy will be? Or will some or all 16 of this zone be in place on neighboring properties 17 thereby leading to loss of use by farmers operating 18 under or relying on organic guidelines. If the latter 19 is true to any extent, are you not concerned about the 20 impact of the unrelying, unAmericanism of this 21 monopolicy practice and the defamation of life, liberty 22 and the pursuit of happiness to every farmer? 23 Another concern, the right of consumers to 24 know what kind of food they're eating. America's sugar 25 beets are strictly grown, as I understand, for the U.S.

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1 market and mainly purchased by the Processed Food Can 2 Administration. They are not exported because most 3 foreign markets restrict importation of engineered food 4 products. The American sugar beet lobbyists have 5 vigorously opposed labeling legislation that would 6 require identification of GMO ingredients. All less 7 corporate controlled countries are adopting such 8 legislation. 9 This industry resistance can only succeed for 10 so long before American consumers prevail in 11 establishing the right to know what they are putting in 12 their mouths and bodies. When that happens, products 13 made with the American GMO sugar beets will be at a 14 decided competitive disadvantage with the intended 15 destructive consequences to the Willamette Valley 16 agricultural economy. Had you included this in your 17 deliberated thinking? Are you fully prepared to let 18 the genie out of the bottle? 19 Third, the impacts of the increased use of 20 Roundup. There's increasing evidence that the use of 21 Roundup has undesirable side effects on wildlife, 22 positive in the surfactant carriers rather than the 23 glyphosate itself. There is also growing body of 24 research on the adaptability of target wheat species 25 and developing resistance to Roundup. It's not 48

1 chooses to eat. 2 I can only hope and pray that this agency 3 will prove the skeptics wrong by coming to the decision 4 that favor small farmers over corporations and a long 5 view over the short term. Thank you. 6 MR. GEORGE: Katy Stokes is next. She'll be 7 followed by Sabrina Siegel. 8 MS. STOKES: Hello, I'm Katy Stokes. K-a-t-y, 9 S-t-o-k-e-s. Okay. It's unusual for me to come and 10 speak in public and I'm here to say that I encourage 11 stronger regulations in the sugar beet industry. I 12 think that everyone here is sincere in believing that 13 they will do the best job they can. Accidents happen 14 and this is such a wonderful growing area. I've lived 15 in Benton County for 40 years. I'm a small farmer and 16 a seed grower myself. If the accident happens, it can't 17 be turned around. To have contamination of the GMO's 18 that this valley is already producing is very, very 19 dangerous and I feel very nervous about it. 20 It's also a historic time not just for 21 agriculture but also in our country, economically, 22 people are saying no to big corporations and saying 23 that money is not the most important thing. The 24 economy is not the most important thing and the bigger 25 corporations set a lot of rules. Monsanto has not been

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1 difficult to imagine what the result of an increasing 2 reliance on herbicides like Roundup will be to the 3 development of Frankenweeds as an unintended 4 consequence. If you want corollary evidence in another 5 arena, look no further than the overuse of antibiotics 6 in whole human and agricultural applications. 7 My final concern, for now, is that this 8 hearing has been advertised as being already decided. 9 A slam dunk for the sugar beet industry and that the 10 decision from this hearing will be a decision made 11 years ago except for the convenience of the U.S. 12 District Court decision calling on the 13 Department of Agriculture to reconsider its 14 approval of GMO products. Your agency should know as 15 well as anybody in this room, we all read the same 16 papers after all, that the trust of the American public 17 in its government is at an all-time low. One of the 18 primary reasons for this is that Americans, from tea 19 partiers to occupiers, feel as though their basic 20 efforts have been abandoned by those who represent them 21 and that mega-corporations are taking over the basic 22 decisions of daily life: Earning a livelihood, 23 protecting one's family, enjoying basic health and 24 having the right to make one of the most personal, 25 intimate and fundamental decisions of all, what one 49

1 very generous in testing whether this food is harmful 2 for us so I think it's also not very democratic. 3 Herbicides even in the nutritious crop, people are 4 saying they can't grow genetically modified sugar 5 beets. They might grow other things. Maybe they would 6 grow local food for Benton County for Oregon. I feel 7 like that would be a much more healthy and wonderful 8 use of our beautiful valley. Thank you. 9 MR. GEORGE: Sabrina Siegel followed by Teri 10 Burns. 11 MS. SIEGEL: Hello, Sabrina Siegel, S-a-b-r12 i-n-a, S-i-e-g-e-l, from GMO-Free Eugene. First of all, 13 I'd just like -- I just want to say what about growing 14 organically and without chemicals and hearing all these 15 chemical nightmare stories, anyway. 16 We reject the deregulation of GM sugar beets 17 as well as partial deregulation in the U.S. We don't 18 want GMO sugar beets or any GMO crops. The Willamette 19 Valley is recognized as a major center for seed 20 production around the world and is one of the most 21 agriculturally productive areas in the country. GMO 22 crops threaten this distinction as well as the 23 livelihood of those who work within our agriculture 24 industry. Pollen from GM crops cannot be contained. 25 As such, the farmers of our valley live in constant

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1 fear that their livelihoods will be stripped of them by 2 genetic contamination. These farmers support 3 themselves and their families and the local community 4 by producing non-transgenic seeds and crops for a 5 diverse range of customers. Their products become -- if 6 their products become contaminated, they lose those 7 clients who will search elsewhere for -- for these 8 products. 9 These farmers were once freely able to 10 provide. Since sugar beets are wind pollinated and 11 easily crossed with vegetable relatives, the prospect 12 of coexistence between GM crops and the conventional 13 crops is a total impossibility. The pollen from beets 14 has been shown to travel upward of 12 miles. Given 15 there is no relative distance that can isolate these 16 crops from conventional crops in the open environment. 17 With the highly concentrated seed and vegetable 18 production found in the Willamette Valley, this becomes 19 even more unrealistic. Due to this, the current USDA 20 requirements of the four or six mile isolation distance 21 between transgenic and conventional beets is not only 22 insufficient, but callow and irresponsible. 23 The proposed deregulation is not only a 24 direct threat to the livelihoods of Oregon farmers, but 25 it spells inevitable end of our illustrious 52

1 they can't even produce as much food as convention and 2 organic farming methods. They're a step back in 3 agriculture masked within this misleading rhetoric of 4 the industry sales pitch of presupposed advancement 5 which is based upon no credible scientific data. They 6 are of a financial benefit to these corporations only, 7 to the biotech corporations. While the farmer, the 8 environment, the consumer and all else suffer great 9 loss. 10 Every independent explanation of the 11 purported benefits of these products have found them to 12 be lacking in every way. This technology is in the 13 infant stages of development. Its safety has not been 14 tested. Once it is released, it cannot be mitigated. 15 It places a direct threat upon our pre-existing 16 agricultural infrastructure and it presents not a 17 single, independently verified gain for our economic -- 18 for our economy or food security. In addition, it has 19 been shown in -- 20 MS. STANKIEWICZ-GABEL: Your time is up. 21 MS. SIEGEL -- several peer-viewed studies to 22 be a danger to human and animal health. 23 MR. GEORGE: I'm sorry. Time's up. 24 MS. SIEGEL: It is time that the USDA join 25 the many concerned countries of the world in taking

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1 livelihoods, illustrious and vibrant commercial and 2 organic farming industry. After all, many of the 3 countries that our state exports food crops to simply 4 do not accept GMO crops, you know, like the Asian 5 countries that we export to. 6 In addition to the issue of the threat to our 7 food is -- in addition to the issue of the threat to 8 our food sovereignty, safety and security through this 9 reckless deregulation of GM crops, our concerns raised 10 by the use of glyphosate that is associated with 11 Roundup Ready sugar beets and other GM crops. 12 According to the UDSA's own data, glyphosate usage has 13 increased since the introduction of GM crops in the 14 United States. Its overuse of glyphosate is not only - 15 - not only degrades the quality of our soils and 16 threatens public health in the form of lymphoma and 17 other health dangers, but aids in the creation of 18 highly, herbicide-resistant weeds that are becoming an 19 agricultural epidemic here. These thicker weeds force 20 farmers to pull them by hand or use toxic cocktails of 21 multiple chemicals to eradicate them. 22 Deregulation as well as partial deregulation 23 threatens our land and crops for absolutely no 24 reasonable gain. GM crops have not only failed to 25 reach the yields promised by biotechonolgy firms, but 53

1 responsible and legally accountable action -- 2 MR. GEORGE: Ms. Siegel, your time is up. 3 MS. SIEGEL: -- and apply the precautionary 4 principle -- 5 MR. GEORGE: Ms. Siegel, excuse me. 6 MS. SIEGEL: -- to GM products in the U.S. 7 Thank you. I'm sorry. 8 MR. GEORGE: Thank you. 9 MS. SIEGEL: Forgive me. 10 MR. GEORGE: We have to enforce this five11 minute rule so that everyone will have an opportunity 12 to speak. We're here to take your public comments as 13 well as show respect for everyone's point of view and 14 we want to make sure that everyone has a chance to make 15 their point. 16 Next up is Teri Burns and she'll be followed 17 by John Perdue. 18 MS. BURNS: Hello, Teri Burns, T-e-r-i, B-u19 r-n-s. I'm with GMO-Free Eugene. And we greatly 20 oppose the deregulation of genetically modified Roundup 21 Ready sugar beets in the U.S. and specifically, here, 22 in our state of Oregon. 23 The Willamette Valley is recognized as the 24 center of seed production and is known for its organic 25 seed production for the world. GM sugar beets would

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1 greatly destroy that recognition for Oregon. 2 Genetically modified sugar beets would threaten 3 Oregon's conventional and organic sugar beets, organic 4 chard and table beet crop as GM sugar beets cross 5 pollinate with related crops. Because GM sugar beets 6 are wind pollinated, contamination of these crops would 7 be inevitable as coexistence between genetically 8 modified crops and natural crops is virtually 9 impossible and we're seeing that already, here, in the 10 Willamette Valley. 11 This would threaten Oregon's 27 million 12 dollar speciality seed industry, specifically our 13 organic seed industry. In addition to the grave 14 economic impact of our market loss on farmers and 15 ultimately our state, as many countries in the world 16 including major importers of sugar beets, require 17 labeling or have bans on genetically modified 18 organisms. 19 In addition to this is the environmental 20 concern of added and excessive chemical spraying 21 associated with genetically modified crops. Again, 22 according to the USDA's own data, glyphosate usage, the 23 main ingredient in Roundup has increased, not decreased 24 since the introduction of GM crops in our country. And 25 with that, has come the creation of super weeds which 56

1 food and we also raise sugar beets. We've been raising 2 sugar beets for 27 years and we've raised sugar beets 3 in the same farm as we raise table beets. One is a 4 weed to the other. We control them. We make sure that 5 they're not in the crops that they're not supposed to 6 be because they become weed to the other crops. 7 Canneries would not accept a sugar beet seed in their 8 crop. Neither would the sugar beet industry want table 9 beet seed in their crop. Sometimes our fears of the 10 unknown are our biggest problems. And we've been 11 genetically modifying seeds for probably 50 years or 12 better. They're called hybrids and because it's done in 13 a test tube and we fear that, we are afraid of it but 14 the truth of the matter is, is that when I was young, 15 by the turn of the century, they told us there wasn't 16 going to be enough food to go around. And because of 17 research from great universities like Oregon State, we 18 have increased our food production and have safer food 19 supply than we've had ever. 20 And so, you know, I urge the USDA to 21 deregulate the regulations they have on GMO products 22 right now, because we've raised sugar beets all these 23 years and never had cross pollination problems. These 24 gentlemen that have talked about the seed qualities and 25 stuff, if they had cross pollinated sugar beets they

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1 is a growing epidemic here in America. The weeds, with 2 nature's help, have developed a resistance to 3 glyphosate and many GM crop farmers have resulted to 4 pulling these super weeds by hand or having to use 5 cocktails of multiple chemicals. 6 Next, the biotech industry will be 7 introducing even deadlier and more hazardous chemicals 8 to be used with their genetically modified crops such 9 as diconda and 2, 4-D a major ingredient in Agent 10 Orange. The affects of being exposed to these 11 chemicals include birth defects, an increase in certain 12 cancers, including non-Hodgkins lymphoma and even 13 death. Genetically modified sugar beets or any GM 14 crops are not right for Oregon. They represent, and if 15 allowed, will definitely present negative economic 16 impact, a loss in market share and a direct hit to our 17 farmers and their choice of what they want to grow, our 18 state's resources, our food sovereignty and security, 19 and our basic right to choose what we eat. Thank you. 20 MR. GEORGE: John Perdue and the next speaker 21 will be Bill Mansour. 22 MR. PERDUE: Good afternoon. My name is John 23 Perdue, J-o-h-n, P-e-r-d-u-e. I farm 700 acres here in 24 the Willamette Valley. We raise bush beans, sweet 25 corn, table beets, pumpkin seeds, pumpkins for baby 57

1 would not accept that seed. They have very high and 2 strict standards and as growers we adhere to those 3 strict standards and we keep our equipment clean and we 4 keep our fields clean and I just encourage 5 understanding here that we can all work together in 6 this valley. Thank you. 7 MR. GEORGE: Thank you. 8 Bill Mansour who will be followed by Kristie 9 Steele. 10 MR. MANSOUR: Good afternoon. My name is 11 Bill Mansour. It's spelled like man sour, M-a-n-s-o-u12 r. The comments that I'm going to make this afternoon 13 are mine because I'm an emeritus professor, I don't 14 speak for Oregon State University. I believe that the 15 production of 16 Roundup Ready sugar beets for seed should be 17 allowed in the Willamette Valley as the instance of 18 deregulation by the U.S. Department of Agriculture in 19 2005. I provide the following comments: 20 Regarding production aspects of Roundup Ready 21 sugar beet seed as related to the safety from 22 contamination of organically produced seed crops 23 although the question of human safety comes in, 24 genetically modified crops is not an issue in these 25 comments. There's no credible evidence of biological

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1 harm to people from genetically altered sugar beet 2 seed. From August 1970 to November of '99, I served as 3 the Oregon State University vegetable crop extension 4 specialist. My duties were primarily as a resource 5 person for the county extension staff and producers of 6 processing crops, fresh market crops, vegetable seed 7 crops, primarily in Oregon but I also worked 8 cooperatively with extension staff in the Pacific 9 Northwest. 10 For most of these 29 years, I, together with 11 colleagues of the Benton County Extension Office and 12 from the North Willamette Experiment Station, we are 13 representatives to a committee from about 20 different 14 seed companies called the Willamette Valley Specialty 15 Seed Crops Committee. As the university 16 representatives, our duties were to be as neutral 17 facilitators to the committee for the educational 18 research efforts and benefits -- to the benefit of the 19 companies and to their growers. A major thrust of work 20 of this committee was to establish isolation maps for 21 numerous types vegetable crops grown in the Willamette 22 Valley and river valleys. Large, detailed wall maps 23 were posted at county extension offices in Linn and 24 Marion County where a great majority of these crops are 25 grown. Postings of plantings and intentional plantings 60

1 the years. This same protection from genetic 2 contamination has been afforded to small acreage crops 3 as is afforded to the predominantly, growing large 4 acreage commercial crops. Production of organic chard 5 or organic table beets or any other seed crops in the 6 organic market, consumer relief can be easily resolved 7 among the willing co-operators so long as historically 8 established isolation procedures are adhered to. 9 Willamette Valley is a large production area and can 10 easily accommodate various types of production. 11 Seed companies in the Willamette Valley are 12 proud of the quality of specialty seeds being produced 13 and have published a pamphlet advertising the 14 attributes of the Willamette Valley and list producers 15 as a quality seed production area. 16 As a result, among the review of Japanese 17 seed companies, produce specialty seed in the 18 Willamette Valley through local seed companies. Genetic 19 modified Roundup Ready sugar beets have been produced 20 without problems, to my knowledge, since they were 21 introduced by the U.S. Department of Agriculture. 22 There have been no known incidents of contamination of 23 conventional table beets with chard organically 24 produced table beets or chard other crops in the 25 organic specialty crop market.

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1 followed along the established procedures adopted by 2 the fieldman's group were made twice a year, spring and 3 fall, by certain deadlines. This provided an orderly 4 method of preventing contamination by insects or weeds 5 or wind cross pollination. 6 Actually, it served, also, as a method of 7 preventing the spread of certain diseases. The 8 committee also established an arbitration procedure by 9 which disputes could be resolved if intended plantings 10 were established or plantings were discovered which 11 might have resulted in contamination and if the seed 12 companies involved were not able to resolve the 13 disputes among themselves. 14 The committee was also involved in providing 15 educational needs for their growers about seed 16 production, dealing with issues about pollination, 17 weed, insect and disease control, good practices 18 regarding transportation of seed crops and the disposal 19 of seed cleaning waste so as not to create 20 contamination problems. They conducted research that 21 developed pesticide registrations for weed control in 22 some crops. 23 Isolation issues in the production of sugar 24 beets, table beets, red and yellow beets, various types 25 of chard as well as heirlooms have been worked out over 61

1 There's no reason to believe that this would 2 change provided producers of these crops work 3 cooperatively in the production. In the future, we can 4 maintain the Willamette Valley as a unique, quality 5 production area. Thank you 6 MR. GEORGE: Thank you. 7 Next is Kristie Steele and following her is 8 Chris Peterson, you put a question mark under the oral 9 comment. Chris, if you're here, and you would like to 10 speak you will be next. But if not, that's fine too. 11 MS. STEELE: Hello, my name is Kristie 12 Steele, K-r-i-s-t-i-e, S-t-e-e-l-e. I work at 13 Hummingbird Wholesale an organic distributor in Eugene. 14 I volunteer at the Willamette Valley Sustainable Food 15 Alliance Business Association with over 50 natural food 16 businesses in the Lane County area. I'm also a member 17 of the Provender Alliance which is a similar 18 association for the Pacific Northwest. The natural 19 foods industry is really strong in this area. It's one 20 of the few industries that has grown throughout 21 economic recession. My company has grown over 20 22 percent over the year for the past five years while 23 other companies are going out of business. 24 Natural food is not a trend. The people want 25 it. And the people don't believe that GMOs are

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1 natural. You'd be hearing from a lot more of us today 2 if this hearing weren't planned the week before 3 Thanksgiving. It's our busiest week the whole year. 4 There are lots of people in the association I mentioned 5 earlier who would be here if they didn't have loads of 6 work to do today. 7 The buzz in this industry is that GMO 8 technology is still really new and the truth is that we 9 don't know what the long-term implications are. We 10 can't say for sure which, you know, despite all the 11 great skills that our farmers have, I know you guys are 12 specialists at your job, but like somebody said 13 earlier, accidents happen. We're not perfect. It's my 14 hope today that we can make decisions based on ethics 15 until we have enough information to make a truly 16 informed decision, rather than making a decision based 17 on money and risking our own health, the health of our 18 land, and the livelihood of the small organic farmers. 19 I'd like to ask the farmers here today who 20 have given success stories about Roundup Ready beets 21 could consider the bigger picture; the long-term health 22 of the land and prosperity for all farmers. There are 23 companies out there like mine looking for farmers to 24 partner with and grow natural foods and use natural 25 practices and we want to help you make more money doing 64

1 published, then realized ways which the application of 2 science, especially in the interest of large 3 corporations has failings. Now, I'm an advocate for 4 family farmers, community food security and public 5 health. 6 I'm here this evening because after decades 7 of federal policies that have helped large corporations 8 at the extreme detriment of family farmers, GMO crops 9 really would be the final death nail for our local food 10 security. 11 The proposed action to deregulate is a 12 handout to the few and unacceptable and unconscionable 13 risk to family farmers and public health. Do not 14 deregulate Roundup Ready sugar beets and stop allowing 15 genetically modified sugar beets. Do not allow any 16 genetically modified crops in Oregon or the U.S. 17 Genetically modified crops have irreversible 18 and likely -- irreversible consequences in likely 19 individual and community fatality in the long term due 20 to increased pesticide poisoning, defective genetically 21 modified crops themselves, and production in crop 22 genetic diversity. The USDA recognizes that 23 genetically modified sugar beet pollen travels further 24 than the current buffer mentioned and the glyphosate 25 usage has increased upon genetically modified crops.

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1 it. 2 Also consider what somebody said earlier 3 about labeling. Studies have shown that the American 4 public will not buy food that's labeled GMO. So what 5 if that law changes? How is that going to affect your 6 farms and your livelihood? And I also want to urge you 7 to learn more about Monsanto because this company is 8 not on your side. It's done horrible things to farmers 9 and any company that's developed something called a 10 terminator gene so that farmers cannot save their seed 11 is not on your side. They are all about making money. 12 I ask the USDA to do the right thing and do not 13 deregulate GMO, Roundup Ready sugar beets. Thank you. 14 MR. GEORGE: Thank you. 15 Chris, are you here? Do you care to speak? 16 CHRIS: No. 17 MR. GEORGE: Samantha Surrillo, Charillo, 18 perhaps? She will be followed by Leda Hermecz. 19 MS. CHIRILLO: Hi, my name is Samantha 20 Chirillo, spelled C-h-i-r-i-l-l-o. I reside in Eugene, 21 Oregon. I have a bachelor's degree in microbiology and 22 a minor in biochemistry and molecular biology from Penn 23 State University. A master's degree in biology and 24 public administration from the University of Oregon. I 25 worked in biomedical research for eight years and 65

1 Clean water and food are basic human needs. 2 Deregulation as proposed violates basic human rights. 3 Deregulation also violates fair business practices 4 because of the presence of genetically modified crops 5 violates the ability of family farmers to grow what 6 they choose and to be able to compete. It forces 7 extreme risks in cost to them that they cannot afford. 8 And what will be the affect of reduction in exports to 9 a country that has stricter policies than ours? 10 It seems to me that this proposal is really 11 at the benefit of a few at the expense of the many. If 12 I followed my career path I would be a USDA official 13 but I do not want to put my community survival at risk 14 or public health at risk. So I ask the decision15 makers; whose interest are you looking out for, the 99 16 percent or the one percent? Who are are you? 17 Regulators in the public interest or Monsanto's 18 minions? 19 MR. GEORGE: Leda Hermecz and she will be 20 followed by Andrew Still. 21 MS. HERMECZ: Hello, my name is Leda Hermecz, 22 that's L-e-d-a, H-e-r-m-e-c-z. I am a food consultant 23 in Eugene, Oregon, as well as the sustainability 24 coordinator for Sweet Life Patisserie in Eugene, 25 Oregon. I sit on the board of the Willamette Valley

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1 Sustainable Food Alliance with Sweet Life Patisserie. 2 We employ about 60 people and we are very proud, very 3 proud to be a member of the alliance. 4 Over the past year, we have phased out the 5 use of all GMO ingredients at our bakery including 6 switching over from sugar beet sugar to cane sugar to 7 avoid the contamination of GMOs. We use about 25,000 8 pounds of sugar a year. So I'm here to say that I am 9 representing one business in the Willamette Valley. I 10 own a consulting business and I do plan to continue to 11 urge my clients to consider using alternatives to RSBs 12 because of the potential health dangers especially when 13 glyphosates are concerned. We oppose the deregulation 14 of RSBs. Thank you. 15 MR. GEORGE: Thank you. Andrew Still who 16 will be followed by Sara Kleeger. 17 MR. STILL: Okay. Hello, my name is Andrew 18 Still, S-t-i-l-l. Owner and operator of Adaptive Seeds 19 with my wife near Sweet Home, Oregon. We have grown a 20 wide variety of GM-free vegetable, herb, grain, and 21 legume seed and which include beta vulgaris, beets and 22 chard. We currently cannot grow beets or chard due to 23 the -- I guess I would say the pestilence problem of GM 24 pollen. Roundup Ready beets are a pest to me and my 25 thousands of customers. The Environmental Impact 68

1 free chard or beets as a vegetable producing farmer. 2 Thank you. 3 MR. GEORGE: Next is Sara Kleeger and she 4 will be followed by Frank Morton. 5 MS. KLEEGER: My name is Sara Kleeger and 6 it's K-l-e-e-g-e-r. In the fall of 2009, my husband 7 and I signed a lease for land near Sweet Home, Oregon, 8 with the intention to produce organic vegetable, beet, 9 grain and specialty seed crops. We knew that Beta seed 10 crops had been grown on one acre of the 30 acre 11 property under a subcontract from the previous owners. 12 After two growing seasons, we have discovered hundreds 13 of sugar beets volunteers. Andrew just showed one of 14 them to you. Many of them are turning up in land that 15 has not, to our knowledge, been used to grow Beta seed 16 crops. So the seeds have either persisted in the soil 17 for many years or they somehow managed to move. 18 Under the partial deregulation of GE sugar 19 beets that has been in effect since 2010, Roundup Ready 20 sugar beet fields are supposed to be policed frequently 21 for volunteers. Several people providing testimony 22 here today have said that that happens. But on our 23 farm, we have not had one Beta seed representative walk 24 our fields, not even one time. Instead we are left to 25 be responsible to control this plant pest in our crops.

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1 Statement does not adequately address the pollen 2 trespass. Knowing that three miles is not satisfactory 3 isolation, that seed requires zero contamination. The 4 inevitable gene flow that will happen with a non-GMC 5 will cause irreparable harm and will prevent me from 6 growing GM-free beets and chard for seed. 7 Coexistence is a great idea but this 8 Environmental Impact Statement does not make it seem 9 plausible. The Environmental Impact Statement does not 10 adequately address the active problem of sugar beets, 11 beta vulgaris, volunteering for years and crops where 12 they have been grown in the past. For example, in my 13 hand, these plants do have the ability in the 14 Willamette Valley to produce GM pollen and contaminate 15 non-GM beets and chard seed. We have seen these 16 volunteers in fields which have not grown GM beet seed 17 for two years as well as in places for three to four 18 years in past fields. This is a pest for me. 19 Although, sugar beets are grown as an annual for 20 vegetable production or whatever you want to call it, 21 seed production is different. I have observed beta 22 vulgaris as an annual, biennial, and as a perennial. 23 This increases the chance of pollen contamination. If 24 GM beets are deregulated, I will not be able to grow 25 GM-free seed and I will likely not be able to grow GM69

1 On my farm, GE sugar beets have proven themselves to be 2 a plant pest. Because of this, my ability as a grower 3 to produce certain varieties of chard and table beets 4 has been limited as I cannot risk the possibility of GE 5 sugar beets showing up in related food crops. 6 My ability to grow chard and table beet seed 7 has also been limited because of the presence of 8 volunteer GE beets on my farm. The regulations 9 currently in effect are not being enforced. As a 10 farmer and a seed producer, I encourage the USDA to 11 fully regulate and enforce current regulations for the 12 H7-1 sugar beets. Thank you. 13 MR. GEORGE: Thank you. Frank Morton 14 followed by Leah Rodgers. 15 MR. MORTON: Hi, my name is Frank Morton and 16 I'm an organic seed grower -- 17 MR. GEORGE: You want to spell that for us, 18 Frank, just in case. 19 MR. MORTON: M-o-r-t-o-n. 20 MR. GEORGE: Thank you. 21 MR. MORTON: I'm an organic seed grower here 22 in the Willamette Valley. I'm a member of the 23 Willamette Valley Specialty Seed Association. I have 24 sat on the rule making committee of the Willamette 25 Valley Specialty Seed Association. And in fact, I was

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1 sitting on the seed -- the isolation committee when it 2 was first announced that Roundup Ready beets were going 3 to be grown in Oregon. I had only been a member of the 4 WVSSA for one month when the announcement came to the 5 whole organization's surprise that Roundup Ready beets 6 were not only going to be grown here, they had already 7 been planted and we were not informed. 8 At the time that we were informed, 30 percent 9 of the ground in the valley for sugar beets had already 10 been planted and nobody had been alerted to that. So 11 I'm glad you guys or finally here except you should 12 have been here before you deregulated this crop the 13 first time because there was no EIS. And because the 14 environmental assessment which the court described as 15 cursory at best, because that assessment did not even 16 take into account the seed growing phase of the sugar 17 beet lifestyle, nobody in this valley was asked whether 18 we would feel the impact. 19 Then we were told, "Oh, yeah. We've already 20 planted and we want extra isolation because we are 21 afraid that the current five mile limit is not enough." 22 This is what a member of the sugar beet seed industry 23 said to our group. "We think we need six miles," that 24 representative said. And the rule committee that I sat 25 on discussed this, and weirdly, decided to make the 72

1 Willamette Valley, they can go to Washington State and 2 get chard and beet seed. They can go to California and 3 get chard seed. They don't have to buy it from us. In 4 2009, the sales of my beet and chard seed were at their 5 high. They had gone up like this. And in 2009, when 6 this issue came to the public attention, they went like 7 this. I have emails that have been forwarded to me by 8 my customers asking, "Where can we go find beet and 9 chard seed organic other than the Willamette Valley?" 10 Because you know why. 11 So I think my environment's been affected. I 12 think the pollen of these crops is a pest. And I think 13 that this product should be re-regulated. 14 MR. GEORGE: Thank you. Leah Rodgers and 15 she'll be followed by -- I'm sorry. I cannot read -- 16 P. Dantos? Anyway. 17 MR. ROGERS: Hi, I'm Leah Rodgers, L-e-a-h, 18 R-o-d-g-e-r-s. I'm the Field Director for Friends of 19 Family Farmers. On behalf of our board and socially 20 responsible family farmers in central Oregon, we would 21 like to thank you for this opportunity to provide 22 comments and feedback regarding the proposed 23 deregulation of genetically modified Roundup Ready 24 sugar beets. 25 Friends of Family Farmers is Oregon's largest

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1 isolation distance three miles. So I have never really 2 understood how the environmental impact statement that 3 you produced, which is just like the environmental 4 assessment that you produced a year ago, to get around 5 the court order that you cease and desist until the EIS 6 was done. We are not being protected. 7 If this product is not regulated, we will be 8 returning to the situation as it was in December 2006, 9 when out of the blue, somebody let the seed industry in 10 the valley know that we had been visited. It's going 11 to return us right to that same place except at that 12 time, five miles were required between Swiss chard and 13 conventional sugar beets. Weirdly, after they went 14 GMO, it became three miles between sugar beets with GMO 15 and non-GMO sugar beets. 16 Dr. Mallory-Smith studies gene flow. That's 17 what she does and she has said that in this valley, if 18 GMOs are deregulated, gene flow between GM crops and 19 non-GM crops will occur. Dr. Smith suggested that we 20 must come up with a tolerance level that organic 21 growing will tolerate because that's the reality of 22 what we're going to face. 23 Well, we don't want any GMOs in our seeds. 24 Our customers do not want them in the seeds that they 25 buy from us and if they can't buy pure seed in the 73

1 organization representing family scale agriculture. 2 Our mission is to protect sensible policies, programs 3 and regulations that protect and expand the ability of 4 Oregon family farmers in order to run a successful 5 land-based enterprise while providing safe and 6 nutritious food for all Oregonians. 7 We have over 2300 supporters spread across 8 every county of Oregon and our membership is diverse. 9 Representing family farmers and ranchers of all size 10 that share the common value of producing food in a way 11 that is socially and ecologically responsible. Our 12 membership is not only a membership of geographically 13 and skill diverse, it also represents farmers of all 14 age and production types and it spans political lines. 15 Agriculture is a vital component of the 16 Oregon economy. It fuels our state engines and 17 provides a valuable livelihood for families in our 18 state. Family farms has been fundamental to the 19 integrity of our land base, the make-up of our 20 communities and the richness of our culture. The 21 Willamette Valley is one of the most productive and 22 diverse agricultural geographic areas in the nation. It 23 is a world leader in seed and specialty crops. 24 The farmers that we represent have identified 25 genetically modified crops as a major threat to farm

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1 and land viability. They have identified GMO isolation 2 and restriction that is years of viability of seed and 3 crops by top priorities. It was our farmers' opinion 4 that there isn't sound science available today that can 5 adequately demonstrate the full impact of introducing 6 genetically modified crops without an extremely high 7 chance of cross contamination. The ruination of the 8 organic agriculture industry in the area is likely. 9 Friends of Family Farmers does not want genetically 10 modified Roundup Ready sugar beets introduced in 11 Oregon. Protecting these lands for purposes of local 12 agriculture guarantees jobs, not just for the farmers 13 and their families, but for the number of businesses 14 both rural and urban who rely on the businesses from 15 family farms for survival. 16 This decision will have significant impact on 17 the entire region. It is USDA's responsibility to 18 listen to us and protect all aspects of agriculture. 19 We should not allow one side of agriculture to 20 potentially ruin another industry in the name of 21 Roundup Ready. This isn't minimal impact. Please hear 22 the socially responsible organic and sustainable 23 section of agriculture as carefully as big industry. 24 We, as farmers, work the land, support the land and 25 know that conflict and potential financial devastation 76

1 might be GMO seed already. Even when we have those 2 maps and pin the little flags of the locations of the 3 seed crops, not all farmers follow that. There are 4 farms growing out there that are not on those maps that 5 are going sugar beets. The biggest issue for me is the 6 pollen drift and then policing. Lots of you probably 7 have seen on the side of the road or observed some 8 beans that have fallen off the truck. 9 The other issue is birds. I have lots of 10 weed crops that show up that are new to me because 11 there has been newer crops growing rather than just 12 grass seed, such as corn and other crops, bringing 13 other weeds and the birds drop those on my land. I 14 don't believe that it is even possible for us to truly 15 control it and we do not have a way to police it. 16 There is not policing going on now and I can't see it 17 in the future. It's cost prohibitive. So please do not 18 deregulate Roundup Ready. Please restrict it more for 19 the sake of all small farms, conventional and organic. 20 Thank you. 21 MR. GEORGE: Thank you. 22 Next is Aleyon Auchanbault. Auchanbault? Is 23 that anyone's name is this room? A-l-e-y-o-n it looks 24 like is the first name. Well 25

--

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1 will arise from the introduction of genetically 2 modified crops and, specifically, Roundup Ready sugar 3 beets in the Willamette Valley. 4 We implore you to push back against the 5 pressure of the green light of Roundup Ready sugar 6 beets and protect the family farmers of Oregon. Thank 7 you. 8 MR. GEORGE: Thank you. Okay. Next, this is 9 very hard to read, but it looks like B.D. Aude, A-u-d10 e, it looks like, citizen? Anyone here? No. Okay. In 11 that case we will move on to Cynthia Kapple. She will 12 be followed by Auchenbault, Aleyon Auchenbault. 13 MS. KAPPLE: Hello, I'm Cynthia Kapple, C-y14 n-t-h-i-a, K-a-p-p-l-e. I have a small farm, Midway 15 Farms, out on Highway 22 between Corvallis and Albany. 16 Our farm is organic. We also have many other farms 17 that sell through us. We also are running a community 18 table at the Albany Farmer's Market. 19 The problem with the GMO Roundup Ready crops 20 are that they not only contaminate farmers that are 21 organic but also conventional farmers that do not wish 22 to grow GMO. I not only grow the crops for selling 23 product, but also feed the fodder to my animals and 24 then also I save money on seed. I worry that because 25 there is seed growing down the road from us that there 77

1 AUDIENCE: Can you repeat the name. 2 MR. GEORGE: A-l-e-y-o-n looks like the first 3 name and A-u-c-h-a-n-b-a-u-l-t, perhaps for the last 4 name. No? Okay. We'll move on. Eric Lezynski, 5 please and that will be followed by Ted Hale, or Hake, 6 perhaps. 7 MR. LEZYNSKI: Hello, I'm Eric Lezynski, 8 that's L-e-z-y-n-s-k-i. And it's kind of hard to know 9 where to start. I have a lot of issues with this EIS, 10 but I'd like to focus on three main things here. 11 First of all, in the EIS it talks about 12 socioeconomic impacts to farmers due to limited 13 availability and uses and this is basically an argument 14 for continuing the deregulation in full deregulation. 15 And I would like to point out that these socioeconomic 16 impacts due to -- the socioeconomic impacts due to 17 limited availability of conventional beet seed and 18 limited availability of other herbicides, this is all 19 caused by original release of Roundup Ready sugar beets 20 before they should have been and getting them out in 21 the market before the EIS was made. So, you know, if 22 the EIS had been done in the first place, these 23 problems wouldn't be a factor and these wouldn't be, 24 you know, in the EIS now -- as they are now. 25 Secondly, on the issue of usage of

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1 glyphosate, in the EIS it's predicted that fewer 2 herbicides will be used but a greater quantity of the 3 one of glyphosate, greater quantity overall. And I 4 would like to point to the European Journal of Agronomy 5 and include in issue three that deals with glyphosate 6 interaction with physiology, nutrition and diseases of 7 plants. And specifically an article entitled, 8 Glyphosate-resistant Crop Interactions with Rhizosphere 9 Microorganisms. 10 In the EIS it says, "Glyphosate is not 11 expected to pose acute or chronic risk to birds, 12 reptiles and mammals, terrestrial and aquatic 13 invertebrates, fish amphibians and microorganisms." 14 However, there are numerous papers in this Journal that 15 finds, "Increases of fusarium after glyphosate 16 applications. Increase of antagonistic bacterial 17 interactions, reduction and inoculation of roots and 18 many other things." This is just one article. 19 So I challenge the notion that the increased 20 used of glyphosate is, you know, necessarily a good 21 thing here. And I'd like to end with the issue of 22 contamination, that contamination won't occur with the 23 restrictions that are currently in place or with any 24 restrictions. I have here a court document from the 25 sugar beet case. This paper is titled Opposition to 80

1 MR. GEORGE: Thank you. 2 Ted Hale. 3 MR. HAKE: Hake. 4 MR. GEORGE: Hake. Thank you. 5 MR. HAKE: I'm Ted Hake, H-a-k-e. Sorry 6 about my sloppy handwriting. I'm the Production 7 Manager for Universal Seed Company, a national seed 8 company located here in the Willamette Valley and we 9 would like to comment on the request for non-regulated 10 status of the glyphosate tolerant H7-1 sugar beets and 11 specifically the production of seed from sugar beets. 12 While Universal Seed as a company is not 13 taking an official position on GMO beets, our main 14 concern, and one of our customers and growers, is the 15 possibility of crop crossing with the H7-1, with our 16 hybrid table beet and hybrid Swiss chard seed here in 17 the valley. Our average annual acreage and value of 18 the aforementioned crops is not insignificant. In the 19 petitioner's request and other testimony that's been 20 given or will be given here, the OSCS and WVSSA, 21 isolation standards have been referenced. It mentions 22 the OSCS standards for seed certification as a maximum 23 of 1.9 miles for non-sugar beet Beta species, to sugar 24 beets produced for stock seed. 25 The Willamette Valley's Specialty Seed

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1 Client's -- Plaintiffs's Motion for Permanent Relief 2 just technical legal stuff. The name of this section 3 is Intervenors, which means Monsanto, concedes 4 transgenic contamination is unavoidable as an 5 acceptable part of producing Roundup Ready sugar beets. 6 In its order, the court found that irreparable harm 7 sufficiently likely. This is in a quote. "Discovery 8 has uncovered further conclusive evidence that 9 contamination is not only likely but a common and 10 continuing occurrence and that Intervenors containment 11 efforts are ineffective. Seed companies have not been 12 able to isolate the sources of contaminants entering 13 their own fields it is impossible to know how many 14 other farmers crops have been contaminated. 15 Stewardship techniques and USDA guidelines which 16 Intervenors tout APHIS espouses as proposed protective 17 measures, have repeatedly proven ineffective." 18 It then lists the instances of contamination 19 which have been redacted to protect the privacy of the 20 companies that -- but these are sugar beet 21 contamination events. And it ends by saying, 22 "Moreover, the whole history of GE crops is literally 23 one contamination event after another, just like the 24 assurances of their impossibility for this or that 25 reason." That's all. 81

1 Association has an isolation distance requirement of 2 four miles between H7-1 and non-sugar beet Beta 3 species. Both of these references are intended in the 4 request to show the possibility of these crops 5 coexisting here in the Willamette Valley under strict 6 supervision of seed companies. 7 Unfortunately, we have to disagree with this. 8 The seed certification isolation for Beta species, 9 while certainly not laughable, are not in use by any 10 vegetable seed companies that we're aware of. The 11 harsh reality is the testing of non-sugar beet Beta 12 species for the years 2009 and 2010, we found 20 13 percent of the field to be contaminated with the 14 Roundup Ready gene. This occurred even when stricter 15 WVSSA guidelines were followed. The testing of the 16 2011 crop is not yet completed. 17 This is a very serious matter for our 18 customers, our growers, and for Universal Seed as a 19 company. We feel that the USDA needs to further study 20 the possibilities about crossing and that this needs to 21 be taken into account before any further steps are 22 taken from deregulation. Thank you. 23 MR. GEORGE: Jean Oxley. Jean Oxley. Please. 24 Jean Oxley is not here? 25 MS. OXLEY: Hi, my name is Jean Oxley. That's

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1 O-x-l-e-y and -- 2 MR. GEORGE: Jean with a "j?" 3 MS. OXLEY: With a "j." Okay. I'm not used 4 to speaking public. I'm not a farmer. I am a 5 community member here in Corvallis. I'm a health care 6 provider in the Willamette Valley and I want you to 7 understand the community that you're addressing. 8 You're addressing a community that is very, very 9 involved in a local level. We have a thriving farmer's 10 market. People like to eat organic here. They care 11 about their health and for the number of people that 12 have presented, come up here statistically, and 13 presented their thoughts and not being for this 14 deregulation and not even allowing GMOs in Oregon, for 15 every one of those, there's 50 to 100 other people that 16 they represent that are not here. And statistically, 17 those that are up here wanting to deregulate the GMO 18 and allow them in Oregon, there's about -- 19 statistically, what we are seeing is what's represented 20 out there. We care about Oregon. We do not want GMOs 21 here. They are not well tested. The contamination has 22 taken effect like, in Mexico, in their ancient 23 varieties of corn which they tried to protect but are 24 now contaminated and once it's done, it's done. There 25 is not enough health lead studies that have been done 84

1 right by Monsanto. That's just the truth. GMOs have 2 not been effectively studied. We do not know their 3 long-term consequences. They are not part of God's 4 creation. We messed with them and we don't know long5 term effects and we are not willing to take that risk. 6 Our children are not worth that risk. That's all I 7 have to say. 8 MR. GEORGE: Is there anyone that has signed 9 up to speak that I have missed? You signed up? 10 AUDIENCE MEMBER: I was the last one in. 11 MR. GEORGE: Well, I think Neil just went to 12 get the sign-up sheet. I think we're going to solve 13 that right now. Jayne Miller? If there is anyone else 14 who wishes to speak, make your way to the microphone or 15 just see Neil and we will be sure to hear from you. 16 Go ahead, Jayne. 17 MS. MILLER: My name is Jayne Miller, J-a-y18 n-e, M-i-l-l-e-r. I'm Director for Marion Soil and 19 Water Conservation District 4. I'm a cattle rancher's 20 daughter. I grew up here in Oregon on our family's 21 7,000 acre cattle ranch and I became an organic farmer 22 by accident. I became an organic farmer because I 23 foolishly went to work for a pulp and paper industry 24 and got contaminated and could no longer eat foods that 25 were grown in herbicides or pesticides. I couldn't

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1 on GMOs. The long-term consequences for health care -- 2 we have an epidemic developing in Oregon. We have one 3 in 99 children with autism and that doesn't even 4 include all of the other nervous system disorders, 5 ADHD, and all the other types of disorders that are 6 taking place right now in pediatrics. 7 I also work in geriatrics. I know that we 8 have an epidemic starting of auto-immune diseases and 9 these are not only happening to old people, they're 10 happening to the young people. These are the 20-year 11 olds and 30-year olds. I bet everyone in this room can 12 say they know someone with Lupus or MS, not to mention 13 the health disorders like cancer. We have a problem. 14 GMOs have not been studied well enough. We are not 15 guinea pigs. Oregon does not want GMOs here and if 16 they do deregulate them, the fight for this will not 17 end here. It will go on and eventually we will win 18 because we do not want them here and they won't be 19 here. 20 Look at the farmer's in the corn state. They 21 live in fear. They are no longer saving their own 22 seeds because they're afraid to save their own seeds. 23 Conventional farmers, their farms are polluted because 24 a passing-by truck tips over and seeds are carried or 25 blown into their field. They're being sued left and 85

1 even go into a restaurant and eat because of the 2 bleach. I became so chemically sensitive that I 3 couldn't eat anymore of what we consider now only 4 traditional foods which are foods grown with chemicals 5 which is a blessing. 6 I met folks like Harry MacCormack, over 7 there, who taught me how to organic farm. And I 8 thought, "By golly, if I'm going to survive, I'm going 9 to have to start growing my own food and eat organic 10 and support the organic community." I could eat 11 organic food and I became well again, but to this day, 12 over 20 years later, I can't eat foods grown in 13 chemicals. There are chemical-sensitive people out 14 there that are not being addressed and who are not 15 going to survive unless there's a new type of food 16 form. 17 We are going to have generations of people 18 who will not remember what it's like to taste, really, 19 a naturally grown carrot. It will taste like Roundup 20 Ready because that's what will be available. We are 21 not addressing the land ethics. You own land, you take 22 care of it for the future. You don't introduce 23 chemicals that are going to pollute our waters, kill 24 the soil and the lifeforms in soil and call this good 25 for the future.

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1 I've had a lot of grants, signed a lot of 2 grants at Marion Soil and Water Conservation District 3 trying to deal with the herbicides and pesticides that 4 are entering our waterways. I mean, really, it's 5 almost pathetic, in my opinion, to try and clean up the 6 mess. We already know that herbicides and pesticides 7 were supposed to be the answer in the 1900s for our 8 food shortages. We already know they are not. We 9 already know that they polluted our soil and our 10 waters. They are making people sick. They are making 11 our children sick. They are making our children be 12 born sick. And now they're telling us that GMO is the 13 new answer for food shortage and it's not. 14 If you allow GMO sugar beets in, it will not 15 be the only GMO. It will open the door for more and I 16 know this because, well, my brother is the CEO of 17 United Grain. He has sold grain for decades out of 18 Oregon and he's changing the guidelines in Vancouver, 19 right now, with a mega grain bin to hold your future 20 GMO wheat. This is not the end. Don't let them fool 21 you. Don't let them pull the wool over your eyes by 22 making it awkward for you to be here tonight. You 23 know, why is this scheduled from 4:00 through the 24 dinner hour? There are a lot of people who wanted to 25 be here and represent themselves but you need to make 88

1 grower, someone who doesn't want to eat those things 2 and wants to know what they are eating, they're being 3 infringed upon. We have the right to know what we're 4 eating and we have the right to choose what we are 5 eating and there are people trying to take this away 6 from us and this is what deregulation will continue to 7 do. 8 The thought that there won't be contamination 9 is really ignorant. There has already been 10 contamination. This has already been documented since 11 the year 2000. There has been contamination in organic 12 food crops of GMO crops. There has been contamination 13 in the food supply that were not meant to contain GMO 14 foods. 15 So right now a lot -- the big concern of 16 people is significant financial impact. This is 17 something that can have significant, negative financial 18 impact in Oregon. In 2009, there were 11 Canada flax 19 shipments to Europe and some other countries were found 20 to contain GMO flax. That GMO flax had been created in 21 the 1990s and it was told -- Canada decided that it 22 didn't want it. So they told the growers of it they 23 were all supposed to turn it in and destroy it all. 24 So in the 1990s, this product of GMO flax was 25 supposed to have been destroyed and in 2009, it pops up

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1 it more amenable. 2 Why isn't Monsanto labeling their foods, 3 "Hey, this has GMO in it." Why are we being denied our 4 option? We should not be denied our option. Take care 5 of the land and the land will take care of you. That 6 is not GMO -- a GMO or Monsanto's motto. Land ethics, 7 that's what must come first if we are to survive as a 8 nation. If we kill our soil, we kill our water with 9 this GMO, we will kill ourselves and there is no 10 turning back. Thank you. 11 MR. GEORGE: If there is anyone who would 12 like to speak who has not signed up, please see Neil in 13 the back of the room, please. 14 MS. GOODWIN: Hi, I'm Kim Goodwin, G-o-o-d-w15 i-n. That was so well spoken. It's kind of hard to 16 follow after it, but we have a bully in the room. We 17 have someone who is essentially the smoker on the 18 airplane. To say there can be a non-smoking section 19 and a smoking section is akin -- on an airplane, is 20 akin to what we are saying with GMO crops and non-GMO 21 crops. 22 The only people not infringed on by these GMO 23 crops are people who are growing them. Anyone who does 24 not want to utilize them, be it the conventional 25 grower, a conventional seed grower, an organic seed 89

1 in flax shipments to Europe. Europe is testing for 2 these and Europe did not allow flax shipment with GMOs 3 in them. This is just one of numerous, numerous 4 consequences. This has a significant financial impact 5 in Canada and the flax industry. 6 A couple of things have been brought up that 7 I think should be looked at a little more closely. One 8 of which is comparison of hybrid seed and hybrid plants 9 and GMOs. Any single one of us can grow hybrid or we 10 can develop our own strain of hybrid plants. I do 11 that. That is something that I enjoy doing. I enjoy 12 hybridizing plants, finding new plant varieties, 13 developing plants that are new to our area. This is 14 something any one of us can do. I'd be willing to bet 15 that none of us can create a GMO in our backyard. So 16 this is a significantly different process. This is 17 something that we keep hearing that there are no 18 studies showing that GMO sugar beets could be dangerous 19 to you and your health. There aren't any studies 20 showing this. It hasn't been done. 21 Why not take the proactive standpoint of 22 investigating something thoroughly first before 23 releasing it on the public. We have a terrible history 24 of releasing poisonous or dangerous things on to the 25 public and discovering it from the government

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1 afterwards. I don't want to be one of those people who 2 end up being affected by that. I don't think anybody 3 in this room wants to be affected by that and it would 4 be good to look a little more closely before deciding 5 something is safe. 6 So obviously I'm against deregulation. I hope 7 that sugar beets will continue to be -- the GMO sugar 8 beets will continue to be deregulated. And I'm against 9 the deregulation of any GMO crops. Oregon has a very, 10 very diverse wonderful set of plants that it can grow. 11 We are one of the most diverse areas in the country. 12 This can significantly, financially impact everybody in 13 the produce and safe seed, every company that grows and 14 distributes seeds, every company that wants -- or 15 person that wants to start an organic farm. We don't 16 need GMO sugar beets in Oregon. Please do not 17 deregulate them. Thank you. 18 MR. GEORGE: Is there anyone else who would 19 like to speak that perhaps I have missed? 20 No. If not, then I would like to thank all 21 of our speakers today and all of you for coming out and 22 participating in this process. We value your opinions. 23 We would like to thank all of our speakers for their 24 conviction and eloquence and thank you for coming out. 25 We will not adjourn because we are here until 92

1 CERTIFICATE OF NOTARY PUBLIC 2 I, Kimberly R. McLain, the officer before whom the 3 foregoing deposition was taken, do hereby certify that 4 the witness whose testimony appears in the foregoing 5 deposition was duly sworn by me; that the testimony of 6 said witness was taken by me in stenotypy and 7 thereafter reduced to typewriting under my direction; 8 that said deposition is a true record of the testimony 9 given by said witness; that I am neither counsel for, 10 related to, nor employed by and of the parties to the 11 action in which this deposition was taken; and, 12 further, that I am not a relative or employee of any 13 counsel or attorney employed by the parties hereto, nor 14 financially or otherwise interested in the outcome of 15 this action. 16 17 18 19 20 21

_______________________________ 22 Kimberly R. McLain 23 Notary Public in and for the 24 State of Oregon 25

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1 7:00 for latecomers. We will take their comments for 2 public record. However, we will suspend this meeting 3 and thank you for coming. 4 I will remind you that if you have written 5 comments that you would like to give, perhaps you 6 didn't care to speak, you can put those in the comment 7 box in the back. 8 Thank you all for being a part of our 9 processes. 10 (Whereupon, APHIS meeting concluded at 11 7:00 p.m.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25

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© 2011 intensive 13:19 intention 68:8 intentional 58:25 interaction 78:6 interactions 78:8,17 interest64:2 65:15,17 interested 93:2 Intervenors 79:3,10,16 intimate 47:25 introduce 85:22 introduced 4:10 16:13 60:21 74:10 introducing 55:7 74:5 introduction 5:2 28:17 51:13 54:24 75:1 invertebrates 78:13 invested 15:15 investigating 89:22 involved 19:16 23:20 59:12,14 82:9 ironic 41:3 irreparable 67:5 79:6 irresponsible 50:22 irreversible 64:17,18 isn't 74:4,21 87:2 isolate 50:15 79:12 isolation 7:6,8 16:9,13,14,18 20:2,7 22:2 24:21 34:1 38:10,19,25 44:24 45:1,13 50:20 58:20 59:23 60:8 67:3 70:1,20 71:1 74:1 80:21 81:1,8 isolations 21:18 issue 14:16 22:4 30:7 51:6,7 57:24 72:6 76:5,9 77:25 78:5,21 issues 4:21 7:5,11 11:9 14:12 59:16,23 77:9 it's 3:25 4:22 7:19 26:24 27:1 29:15 32:13 33:6 36:20 41:17 46:25 48:9,20 49:2 56:12 57:11 61:19 62:3,13 63:8 68:6 71:10 76:17 77:8 78:1 82:24 85:18 86:4,13 87:15 I've 34:24 36:8 37:9 42:4 48:14 86:1

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© 2011 76:2,4 Marion 58:24 84:18 86:2 mark 15:6,7 61:8 M-a-r-k 15:8 market 5:24 9:22 12:17 21:24 22:1 31:16 34:5 36:21,24 39:20 44:10 46:1 54:14 55:16 58:6 60:6,25 75:18 77:21 82:10 markets 23:17 46:3 masked 52:3 massive 33:18 master's 63:23 materials 3:16 Matt34:15 37:15,16 matter 56:14 81:17 mature39:3 42:24 maximum13:7 80:22 may 22:19 44:16 Maybe 49:5 m-b-a-u-g-h 10:25 McLain 1:17 3:3 92:3 93:11

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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### Capital Reporting Company

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