### Petition for the Determination of Nonregulated Status for Herbicide-Tolerant 73496 Canola

We submit this petition under 7 CFR §340.6 to reque st that the Administrator, Animal and Plant Health Inspection Service, make a determination that the article should no longer be regulated under 7 CFR §340.

Submitting Company:

Pioneer Hi-Bred International, Inc. 7100 NW 62nd Avenue PO Box 1014 Johnston, IA 50131-1014

Submitted by:

Natalie Weber, Registration Manager

Pioneer Hi-Bred International, Inc. DuPont Agricultural Biotechnology DuPont Experimental Station, E353/305C PO Box 80353 Wilmington DE 19880-0353 Telephone: 302-695-8160 Fax: 302-695-3075

Prepared by:

John Larsen, Natalie Weber, Jennifer Tallman, Donald MacKenzie, Alejandra Pascual, Keri Carstens, Kate Hayter, Kara Califf, Kent Br ink, Theresa Sult, and Holly Hettinger

OECD Unique Identifier: DP-Ø73496-4

Submission date: February 25, 2011 Revised submission date: August 3, 2011Pioneer Hi-Bred International, Inc. Page 2 of 167 73496 Canola



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L IST OF T ABLES

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L IST OF F IGURES

.............................................................................................................................. ............... 7

R ELEASE OF I NFORMATION

.............................................................................................................................. 9

C ERTIFICATION

.............................................................................................................................. ................ 10

S UMMARY

.............................................................................................................................. ....................... 11

A BBREVIATIONS
, A CRONYMS
, AND D EFINITIONS .............................................................................................. 13

I. R ATIONALE FOR THE D EVELOPMENT OF 73496 C ANOLA ............................................................................. 15

I-A. Basis for the Request for a Determinati on of Nonregulated Status under 7 CFR §340.6 .................. 15 I-B. Benefits of 73496 Ca nola ................................................................................................ .................... 15 I-C. Submissions to Other Regulatory Agencies ........................................................................................ 15

II. T HE B IOLOGY OF C ANOLA ......................................................................................................................... 16

II-A. Canola as a Crop

............................................................................................................................... . 16 II-B. Description of the Non-Tr ansformed Recipien t Canola Line .............................................................. 16

III. M ETHOD OF D EVELOPMENT OF 73496 C ANOLA ........................................................................................ 16

III-A. Description of Transfor mation, Selecti on, and Breeding ................................................................. ... 16 III-B. Selection of Comp arators for 73496 Canola ............................................................................. ........ 18

IV. D ONOR G ENES AND R EGULATORY S EQUENCES ....................................................................................... 18

IV-A. Fragment PHP28181A Used in Transformation .............................................................................. . 18 IV-B. Identity and Source of the gat4621 Gene Cassette on Frag ment PHP28181A ............................... 20

V. G ENETIC C HARACTERIZATION OF 73496 C ANOLA ..................................................................................... 21

V-A. Molecular A nalysis Overview ............................................................................................. ................ 21 V-B. Results of Molecular Characterization of 73496 Canola by Souther n Blot Analysis ......................... 21 V-C. Inheritance and Genetic Stability of the Introduced Trait in 73496 Canola ....................................... 34 V-D. Conclusions on Molecular Characteriza tion and Genetic Stabilit y of 73496 Canola ........................ 35

VI. C HARACTERIZATION OF THE I NTRODUCED GAT4621 P ROTEIN ................................................................. 36

VI-A. The GA T4621 Protein .................................................................................................... ................... 36 VI-B. Physicochemica l Characterization of the GAT4621 Pr otein ............................................................. 38 VI-C. Concentrations of GAT4621 in 73496 Canola .............................................................................. .... 38 VI-D. Summary of the Food and Feed Safety Assessment for the GA T4621 Protein ............................... 40

VII. A GRONOMIC P ERFORMANCE AND E COLOGICAL O BSERVATIONS .............................................................. 42

VII-A. Germinat ion Evaluations ............................................................................................... ................... 42 VII-B. Field Tr ial Evaluations ............................................................................................... ....................... 43 VII-C. Ecological Observations ............................................................................................... ................... 52 VII-D. Conclusions on Agronomic Perf ormance and Ecologica l Observations ......................................... 53Pioneer Hi-Bred International, Inc. Page 3 of 167 73496 Canola



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VIII. C OMPOSITIONAL A SSESSMENT .............................................................................................................. 54

VIII-A. Proximate and Fiber A nalysis ......................................................................................... ................ 55 VIII-B. Fatty Acid Analysis .................................................................................................. ........................ 57 VIII-C. Amino Acid Analysis .................................................................................................. ..................... 60 VIII-D. Vitamin Analysis

............................................................................................................................... 63 VIII-E. Mineral Analysis ...................................................................................................... ......................... 65 VIII-F. Glucosi nolate Analysis ............................................................................................... ..................... 67 VIII-G. Secondary Metabolite and Anti-Nutri ent Analysis ....................................................................... .... 70 VIII-H. Acetylat ed Amino Acids ............................................................................................... ................... 72 VIII-I. Conclusions on the Composit ional Analysis of 73496 Ca nola ......................................................... 75

IX. A SSESSMENT OF P LANT P EST R ISK FOR 73496 C ANOLA ......................................................................... 77

IX-A. Environmental Assessment of the Transgenic Protein ..................................................................... 77 IX-B. Fate of Transgenic DNA in Humans and Animals ........................................................................... . 77 IX-C. Weediness Potential of 73496 Canola .............................................................................................. 77 IX-D. Gene Flow Assessment ................................................................................................... ................. 81

A PPENDIX 1. M ATERIALS AND M ETHODS FOR G ENETIC C HARACTERIZATION OF 73496 C ANOLA ..................... 92

1.1. Southern Blot Charac terization of 73496 Cano la .......................................................................... ..... 92 1.2. Mendelian Inheritance and Genetic St ability of the Trait in 73496 Canola ......................................... 95

A PPENDIX 2. D ESCRIPTION OF S TATISTICAL A NALYSES P ERFORMED FOR A GRONOMIC AND N UTRIENT C OMPOSITION D ATA

.............................................................................................................................. ........ 97

2.1. Statistical Analysis of Germinat ion Data ................................................................................ ............. 97 2.2. Statistical Analyses of Ag ronomic Characteristic, Yield, and Nutrient Composition Data .................. 97 2.3. Special Co nsiderations .................................................................................................. ................... 100 2.4. SAS Procedures

............................................................................................................................... . 101

A PPENDIX 3. M ATERIALS AND M ETHODS FOR D ETERMINATION OF GAT4621 P ROTEIN C ONCENTRATIONS ..... 102

3.1. Plant Material .......................................................................................................... .......................... 102 3.2. Storage and Processi ng of ELISA Samples ................................................................................. .... 102 3.3. Protein Extraction fr om Ground Canol a Tissues ........................................................................... ... 102 3.4. Determination of GAT 4621 Protein Conc entrations ......................................................................... 102

A PPENDIX 4. C HARACTERIZATION OF THE P LANT -E XPRESSED AND M ICROBIAL -E XPRESSED GAT4621 P ROTEINS

.............................................................................................................................. ..... 104

A PPENDIX 5. E COLOGICAL O BSERVATIONS FOR 73496 C ANOLA .................................................................. 111

A PPENDIX 6. USDA AND C ANADIAN F IELD T RIALS OF 73496 C ANOLA ......................................................... 115

A PPENDIX 7. S URVEY OF P OTENTIAL S UBSTRATES FOR GAT4621 .............................................................. 116Pioneer Hi-Bred International, Inc. Page 4 of 167 73496 Canola



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A PPENDIX 8. S AFETY AND H ISTORY OF C ONSUMPTION OF A CETYLATED A MINO A CIDS .................................. 118

8.1. Summary ................................................................................................................. .......................... 118 8.2. Function and Use of Acetylated Am ino Acids .............................................................................. ..... 118 8.3. History of Safe Use of Acetylated Amino Acids ........................................................................... ..... 118 8.4. Presence of NAA, NAG, NAT, N AS, and NAGly in Biol ogical Systems ........................................... 119 8.5. History of Safe Consumption of NAA, NAG, NAS, NAT, and NA Gly ................................................ 121 8.6 Toxicology Studies Conducted with NAA, NAG, NAS, NAT, and NAGly .......................................... 121

A PPENDIX 9. H ERBICIDE R ESISTANT W EEDS ............................................................................................... 122

9.1. Evolution of Herb icide Resistant Weeds .................................................................................. ......... 122 9.2. Characteristics of Glyphosate ........................................................................................... ................ 124 9.3. Evolution of Resi stance to Glyphosate ................................................................................... .......... 124 9.4. Stewardship of Herbic ide Tolerant 73496 Canola .......................................................................... .. 125

A PPENDIX 10. GAT4621 N EW P ROTEIN C ONSULTATION ............................................................................. 130

R EFERENCES

.............................................................................................................................. ................ 148Pioneer Hi-Bred International, Inc. Page 5 of 167 73496 Canola



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Table 1. Generations and Comparat ors Used for Analysis of 73496 Canola ........................................... 18

Table 2. Description of the Genetic Elem ents in Fragment PHP28181A .................................................. 20

Table 3. Description of DNA Probes Used for Southern Blot Hy bridization .............................................. 24

Table 4. Summary of Expected and Observed Hybridization Fragments on Southern Blots for 734 96 Canola ........................................................................................................ ....... 25

Table 5. Summary of Genotypic and Phenotyp ic Results for 7349 6 Canola ............................................ 35

Table 6. Comparison of Amino Acid Sequence Similarity Between Parental GAT Enzymes and GAT4621 ........................................................................................................... ... 38

Table 7. Concentrations of GAT4621 Protein in 73496 Canola Plant Tissues ......................................... 39

Table 8. Description of Seed Ge rmination Condi tions .............................................................................. 42

Table 9. Summary of Germination Re sults for 73496 Canola ................................................................... 43

Table 10 . Site Locations for 2008 and 2009 Field Trial Ex periments ........................................................ 45

Table 11 . Experiment A: 2008 Field Trial Agro nomic Characteristic s Measured ..................................... 47

Table 12. Experiment A: Summary of Agronomic Characteristics of 73496 Canola Across Seven Locations ........................................................................................................ .... 48

Table 13. Experiment B: 2009 Field Trial Agrono mic Characteristic s Measured ..................................... 49

Table 14. Experiment B: Summary of Agronomic Characteristics of 73496 Canola Across Three Locations ........................................................................................................ .... 51

Table 15. Summary Analysis of Proximate and Fiber Results in Canola Seed ........................................ 56

Table 16. Summary Analysis of Fatty Acid Composition in Canola Seed ................................................. 58

Table 17. Summary Analysis of Amino Acid Co mposition in Cano la Seed ............................................... 61

Table 18. Summary Analysis of Vitamin Comp osition in Canola Seed ..................................................... 64

Table 19. Summary Analysis of Mineral Comp osition in Canola Seed ..................................................... 66

Table 20. Summary Analysis of Glucosinolate Composition in Ca nola Seed ........................................... 68

Table 21. Summary Analysis of Secondary Metabolite and Anti-Nutrient Composition in Canola Seed ................................................................................................................ .......... 71

Table 22. Concentrations of Acetylated Am ino Acids in Cano la Seed ...................................................... 73

Table 23. Concentrations of Acetylated Amino Ac ids in Canola Whole Plant Samples ........................... 74Pioneer Hi-Bred International, Inc. Page 6 of 167 73496 Canola



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Table 24. Concentrations of Acetylated Amino Acids in Processed Fractions Produced from 73496 and Co ntrol Canola ................................................................................................ 75

Table 25. Common Characteristics of Weeds ........................................................................................... 7 8

Table 26. List of Species with Reports of Hand -Pollinated or Spontaneous Hybridization with B. napus ......................................................................................................................

....... 84

Table 5.1. United States: Insect Stressor Comparis on between 73496 Canola and Controls ............... 111

Table 5.2. United States: Disease Stressor Compar ison between 73496 Canol a and Controls ........... 112

Table 5.3. Canada: Insect Stressor Comparison between 73496 Canola and Controls ........................ 113

Table 5.4. Canada: Disease Stressor Comparison between 73496 Canola and Controls .................... 114

Table 6.1. USDA Field Trials of 73496 Canola........................................................................................ 115

Table 6.2. Canada Field Trials of 73496 Canola ..................................................................................... 115

Table 7.1. k cat / K M for the GAT4621 Enzyme on Glyphos ate and Selected Am ino Acids ........................ 116

Table 8.1. Full list of Studies Conducted with N AA, NAG, NAS, NAT, and NAGly ................................. 121

Table 9.1. Herbicide Resistant Weeds Summary Table (Heap, 2010b) ................................................. 123Pioneer Hi-Bred International, Inc. Page 7 of 167 73496 Canola



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Figure 1. Schematic Diagram of the Deve lopment of 7349 6 Canola ........................................................ 17

Figure 2. Breeding Diagram for 73496 Canola and Generations Used fo r Analyses ............................... 17

Figure 3. Schematic Diagram of Fragment PHP28181A .......................................................................... 19

Figure 4. Schematic Diagram of Plasmid PHP28181 ............................................................................... 19

Figure 5. Restriction Enzyme Map of PHP28181A DNA Fr agment .......................................................... 25

Figure 6. Restriction Enzyme Map of Plasmid PHP28181 ........................................................................ 26

Figure 7. Physical Map of the Inse rtion in 73496 Canola ......................................................................... 26

Figure 8. Southern Blot Analysis of 73496 Canola: Nco I Digestion and UBQ10 Promoter Probe ................................................................................................................ ......... 27

Figure 9. Southern Blot Analysis of 73496 Canola: Nco I Digestion and gat4621 Probe ......................... 28

Figure 10. Southern Blot Analysis of 73496 Canola: Nco I Digestion and pin II Terminator Probe ......................................................................................................................... .............. 29

Figure 11. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and UBQ10 Promoter Probe ................................................................................................................ ....... 30

Figure 12. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and gat4621 Probe ....................... 31

Figure 13. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and pin II Terminator Probe .............................................................................................................. ....... 32

Figure 14. Southern Blot Analysis of 73496 Canola: Nco I Digestion and Plasmid Backbone Probe ............................................................................................................... ...... 33

Figure 15. Deduced Amino Acid Sequence of the GAT4621 Protein ....................................................... 36

Figure 16. Enzymatic Activity of the GAT4621 Pr otein ............................................................................. 37

Figure 17. Map of Locations for Agronomic Data Collecti on for 73496 Canola ........................................ 45

Figure 18. Map Indicating Zones with Similar Growing Conditions for Field Trials ................................... 46

Figure 19. Production Climate Zones for Spring , Biennial, and Wint er Canola ........................................ 82

Figure 20. Genome Relationships Among Cultivated Bras sicaceae ........................................................ 83

Figure 4.1. SDS-PAGE Analysis of the Plant -Expressed GAT462 1 Protein .......................................... 104

Figure 4.2. Western Immunoblot Analysis of the Plant-Expressed and Microbial-Expressed GAT4621 Proteins .............................................................................. 105

Figure 4.3. N-Terminal Amino Acid Sequence Analysis of the Plant-Expressed and Microbial-Expressed GAT4621 Proteins ....................................................................... 106Pioneer Hi-Bred International, Inc. Page 8 of 167 73496 Canola



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Figure 4.4. Deduced GAT4621 Amino Acid Sequence Showing Matching Peptides from MALD I-MS ................................................................................................................. .. 106

Figure 4.5. Glycosylation Analysis of the Plant-Expressed GAT4621 Protein ........................................ 107

Figure 9.1. Number of Resistant Biotypes of Weeds by Herbicide Class and Year (Heap, 2010d) ....... 124

Figure 9.2. Resistant Weed Management Label ..................................................................................... 127Pioneer Hi-Bred International, Inc. Page 9 of 167 73496 Canola



### Release of Information

Pioneer Hi-Bred International, Inc. (Pioneer) is submitti ng the information in this assessment for review by USDA as part of the regulatory process. By submitti ng this information, Pioneer does not authorize its release to any third party except to the extent it is requested under the Freedom of Information Act (FOIA), 5 U.S.C., Section 552; USDA complies with the provisions of FOIA and USDA’s implementation regulations (7 CFR Part 1.4); and this informaiton is responsive to the specific request. Except in accordance with the Freedom of Information Act, Pioneer does not authorize the release, publication or other distribution of this information (including webs ite posting) without Pioneer’s prior notice or consent.Pioneer Hi-Bred International, Inc. Page 11 of 167 73496 Canola



### Summary

Pioneer Hi-Bred International, Inc. (Pioneer) is subm itting this Petition for Determination of Nonregulated Status for herbicide-tolerant canola event DP-Ø73 496-4, hereafter referred to as 73496 canola. Canola line 73496 was developed by Pioneer Hi-Bred, a DuPont Business. The data in this petition support the conclusion that 73496 canola is not likely to pose an increased plant pest potential. Therefore, Pioneer requests a determination from USDA - Animal and Plant Health Inspection Service (APHIS) that 73496 canola and any crosses of this line with other nonregulated Brassica napus no longer be considered regulated articles under 7 CFR §340.

73496 canola is a transgenic plant line that is tolerant to the herbicidal active ingredient glyphosate. The availability of 73496 canola will provide an alternative to currently available glyphosate-tolerant canola lines. Herbicide-tolerant 73496 canola will provide t he same benefits as currently available glyphosatetolerant canola lines, in that growers will be able to proactively manage weed populations and delay the development of adverse populat ions of troublesome weeds.

73496 canola has been genetically modified to expres s the GAT4621 (glyphosate acetyltransferase) protein. The gat4621 gene is a variant of three gat genes from the common soil bacterium Bacillus licheniformis . The GAT4621 protein is equivalent to t he protein expressed in 98140 maize deregulated by USDA in 2009 and reviewed by FDA in 2008, and is encoded by the gat4621 gene which confers tolerance to glyphosate-containing herbicides by ac etylating glyphosate and thereby rendering it nonphytotoxic. In 73496 canola, the expression of the gat4621 gene is driven by the Arabidopsis polyubiquitin constitutive promoter.

73496 canola was generated using biolistic transformati on of canola microspores with a gel-purified DNA fragment isolated from plasmid PHP28181 containing the gat4621 gene cassette. Molecular characterization of 73496 canola by Southern blot anal ysis confirmed that a single, intact PHP28181A DNA fragment has been inserted into the genome wi th no plasmid backbone DNA. Segregation analysis of 73496 canola confirmed Mendelian inheritance of the gat4621 gene.

The potential for allergenicity and toxicity of 73496 ca nola was evaluated by examining the allergenic potential of canola as a crop and by as sessing the allergenic and toxic pot ential of the GAT4621 protein. Canola is not a common allergenic food and the modification in 73496 canola is not expected to alter the allergenic potential of canola. The allergenic pot ential of the GAT4621 protein was assessed using a weight-of-evidence approach using guidance from th e Codex Alimentarius Commission. Bioinformatic analyses revealed no biologically significant identities to known or putative protein allergens or toxins for the GAT4621 protein sequences. The GAT4621 protein is not glycosylated and is rapidly digested (within 30 seconds) in simulated gastric fluid. In simulated intestinal fluid, the GAT4621 protein hydrolyzed within 5 minutes. There was no evidence of acute toxicity in mice for GAT4621 at a dose of 1640 mg protein per kg of body weight. Based on the GAT4621 prot ein levels in 73496, exposure levels would be exponentially lower than the tested doses. These data support the conclusion that the GAT4621 protein is unlikely to cause an allergic reaction in humans or be a toxin in humans or animals and therefore support the food and feed safety of GAT4621. A Ne w Protein Consultation for the GAT4621 protein was submitted to FDA on January 31, 2007 and completed on October 7, 2009.

73496 canola has been field tested since 2007 in the major canola-growing regions of Canada and the United States. All field tests that have occurred in the United States were under field permits and notifications granted by USDA - APHIS. Comprehen sive agronomic performance for 73496 canola were conducted in replicated field studies at a total of 10 locations across Canada and the United States. Characteristics such as early growth , days to flower, days to maturity , plant height, yield, seedling vigor, flowering duration, lodging, shattering, disease incidence and insect damage were assessed. Seed germination and dormancy data were also collected in laboratory experiments. All field trials of 73496 canola were observed for naturally occurring disease or insect biotic stressors. Analysis of agronomic and ecological data showed no biologically meaning ful differences between 73496 canola and control canola lines, indicating the similarity of 73496 canola to conventional canola and indicating no plant pestPioneer Hi-Bred International, Inc. Page 12 of 167 73496 Canola

characteristics or selective advant age in natural habitats. These data support the conclusion of agronomic comparability of 73496 canola to commercially available canola with respect to the lack of increased weediness and plant pest potential.

Extensive nutrient composition analysis of seed was conducted to compare the composition of 73496 canola to that of a control line and five commercial canola varieties. Compositional analysis of 73496 canola was used to evaluate any changes in the leve ls of key nutrients, anti- nutrients, and secondary metabolites in accordance with the OECD consensus document for new varieties of canola. Based on the results of the compositional evaluation, the seed of 73496 canola are comparable to commercially available canola. Along with the agronomic data inclu ded in this petition, compositional comparability is a general indicator that 73496 canola will not exhibi t unintended effects due to the inserted DNA.

In addition to glyphosate, the GAT4621 protein is known to acetylate certain free amino acids (Laspartate, L-glutamate, glyci ne, L-serine, and L-threonine) re sulting in the production of N -acetylaspartate (NAA), N -acetylglutamate (NAG), N -acetylglycine (NAGly), N -acetylserine (NAS), and N -acetylthreonine (NAT). The efficiency of acetylation of free amino ac ids by GAT proteins is co nsiderably lower than the activity displayed toward glyphosate. Because of t he potential for these five acetylated amino acids to be increased in 73496 canola, concentrations were me asured in seed, whole plant, and processed product samples. An increase in concentrations of NAA, NAG, and, in some instances, NAGly, NAS, and NAT, was confirmed through the analysis of seed, whol e plant, and processed product samples. Low but quantifiable concentrations of each N -acetylated amino acid were found in each sample type except refined, bleached, deodorized (RBD) oil, where levels were either not detectable or below the limit of quantification. These five acetylated amino acids ar e not novel substances as they are present in conventional canola as well as in other plants.

In conclusion, based on the data contained herein t hat support the conclusion that 73496 canola is not likely to pose an increased plant pest potential, Pi oneer requests that APHIS grant the request for a determination of nonregulated status for 73496 ca nola and any crosses of this line with other nonregulated Brassica napus

.Pioneer Hi-Bred International, Inc. Page 13 of 167 73496 Canola



### Abbreviations, Acronyms, and Definitions

~ approximately 1822B canola donor line used for transformation 1822R non-transgenic canola line used in breeding 5300B non-transgenic canola line used in breeding 5536F non-transgenic canola line used in breeding 6393B non-transgenic canola line used in breeding 6395B non-transgenic canola line used in breeding 73496 canola canola lines containing the DP-Ø73496-4 event ACY1 Aminoacylase I ADF acid detergent fiber ALS Acetylactate synthase AOSA Association of Official Seed Analysis APHIS Animal and Plant Health Inspection Service of USDA ATCC American Type Culture Collection Bam H I Restriction enzyme from Bacillus amyloliquefaciens BAR phosphinothricin acetyltransferase BBCH Bundesanstalt, Bundessortenamt and Chemical industry bla (Ap R ) Ampicillin resistance gene B. licheniformis Bacillus licheniformis B. napus Brassica napus L. bp base pair CAC Codex Alimentarius Commission CCA Certified Crop Adviser CFIA Canadian Food Inspection Agency CFR Code of Federal Regulations CNS Central nervous system CPSI Carbamyl phosphate synthetase I C T threshold cycle Da Dalton df degrees of freedom DIG digoxygenin DP-Ø73496-4 OECD identifier for herbicide-tolerant canola event
DP-Ø9814Ø-6 OECD identifier for approved herbicide-tolerant maize event DNA deoxyribonucleic acid E. coli Escherichia coli E

score expectation score ELISA enzyme linked immunosorbent assay EPA Environmental Protection Agency EPSPS enolpyruvylshikimate-3-phosphate synthase EU European Union FARRP Food Allergy Research and Resource Program FDA Food and Drug Administration FDR false discovery rate FOIA Freedom of Information Act GAT glyphosate acetyltransferase GAT4621 specific GAT protein gat4621 specific gat gene GLMM Generalized Linear Mixed Model GNAT GCN 5-related N -acetyltransferases Hae III Restriction enzyme from Haemophilus aegyptius Hin d III Restriction enzyme from Haemophilus influenzaePioneer Hi-Bred International, Inc. Page 14 of 167 73496 Canola



### Abbreviations, Acronyms, and Definitions (continued)

HRAC Herbicide Resistance Action Committee HRP horseradish peroxidase IgG immunoglobulin G ISAAA International Service for the Acquisition of Agri-biotech Applications kb kilobase pair kDa kilodalton LLOQ lower limit of quantitation LS-Mean Least Squares Mean MALDI-MS matrix assisted laser desorption ionization mass spectrometry mRNA messenger ribonucleic acid NAA N -acetylaspartate NAG N -acetylglutamate NAGly N -acetylglycine NAGS N -acetylglutama te synthase NAS N -acetylserine NAT N acetylthreonine NCBI National Center for Biotechnology Information Nco I Restriction enzyme from Nocardia corallina NDF neutral detergent fiber Not I Restriction enzyme from Nocardia otitidis-caviarum NRCS Natural Resources Conservation Service OD optical density OECD Organisation for Economic Co-operation and Development OGTR Office of the Gene Technology Regulator PAT phosphinothricin acetyltransferase PCR polymerase chain reaction PEP phosphoenolpyruvate pin II proteinase inhibitor II PMRA Pest Management Regulatory Agency (Canada) ppm parts per million REML Residual Ma ximum Likelihood SAS Statistical Analysis Software SDS-PAGE sodium dodecyl sulfate po lyacrylamide gel electrophoresis Ssp I Restriction enzyme from Sphaerotilus species UBQ10 polyubiquitin gene from Arabidopsis thaliana USDA United States Depa rtment of Agriculture USDA-ERS Economic Research Service of the U.S. Department of Agriculture USDA-NASS National Agricultural Statistics Se rvice of the U.S. Depar tment of Agriculture WSSA Weed Science Society of America

*Abbreviations of units of measurem ent and of physical and chemical quantities are used according to the standard format described in Instructions to Authors in the Journal of Biological Chemistry (http://www.jbc.org/ ).Pioneer Hi-Bred International, Inc. Page 15 of 167 73496 Canola



### I. Rationale for the Development of 73496 Canola

I-A. Basis for the Request for a Determination of Nonregulated Status under 7 CFR § 340.6

The Animal and Plant Health Inspection Service (APH IS) of the U.S. Department of Agriculture (USDA) has responsibility, under the Plant Protection Act (7 U.S.C. 7701-7772) and the Plant Quarantine Act (7 U.S.C. 151-167), to prevent the introduction or dissem ination of plant pests into or within the United States. Part 340 regulates introduction of organi sms altered or produced through genetic engineering which are plant pests or for which there is a reason to believe are plant pests. The APHIS regulations at 7 CFR §430.6 provide that an applicant may petition APH IS to evaluate submitted data on the genetically engineered crop to determine that a regulated article does not present a plant pest risk and therefore should no longer be regulated.

Pioneer Hi-Bred International, Inc. is submitting dat a for genetically engineered herbicide tolerant 73496 canola and requests a determination from USDA - An imal and Plant Health Inspection Service (APHIS) that event DP-Ø73496-4 and any crosses with other nonregulated Brassica napus no longer be considered regulated articles under 7 CFR §340.

I-B. Benefits of 73496 Canola

Herbicide-tolerant canola varieties have provided gr owers with a very useful tool to help manage their canola crops. Herbicide-tolerant canola varieties ha ve helped to increase the adoption of low- and no-till practices which are important in the minimization of soil erosion and also have helped to reduce the volume of herbicides applied to canola crops to control weeds (Brookes and Barfoot, 2010; Duke and Powles, 2009; Smyth et al. , 2010). Additionally, the yield potentia l of canola can be optimized by the application of herbicides that remove weeds competing for soil nutrients and moisture.

In particular, glyphosate has become a popular post -emergence herbicide for canola to control weeds that reduce yields. As a broad-spectrum herbicide, it is effective in controlling both grasses and annual broadleaf weeds, while possessing an excellent environmental profile and low mammalian toxicity.

73496 canola was developed with glyphosate-tolerance to provide an alternative to existing herbicidetolerant canola products on the market. The comme rcialization of 73496 canola is not expected to have an impact on existing weed control practices and coul d replace the use of ot her glyphosate-tolerant canola products already commercialized. The ava ilability of 73496 canola will provide growers with an additional market choice for herbicide-tolerant canola.

I-C. Submissions to Other Regulatory Agencies

A New Protein Consultation for the GAT4621 prot ein was submitted to FDA on January 31, 2007 and completed on October 7, 2009. A safety and nut ritional assessment for feed and food derived from 73496 canola will be submitted to FDA in the first quarter of 2011.

Submission of a tolerance petition and supporting residue data to the U.S. Environmental Protection Agency (EPA) to amend the glyphosate tolerance to include N -acetylglyphosate for canola was submitted on February 18, 2011.

Submissions for food, feed, and env ironmental approval were made to Canada in August 2010. Submissions will also be made in Mexico, Japan, S outh Korea, China, EU, and other countries as appropriate. Pioneer is committed to robust product stew ardship prior to and continuing after all relevant authorizations are granted. A full commercial launch of 73496 canola will not occur until import regulatory approvals have been obtained in key canola import ma rkets with functioning regulatory systems.Pioneer Hi-Bred International, Inc. Page 16 of 167 73496 Canola



### II. The Biology of Canola

II-A. Canola as a Crop

Biology documents on the unmodifi ed plant species, canola ( Brassica napus L.), have been published by the Canadian Food Inspection Agency (CFIA, 1994) and by the Organization for Economic Co-operation and Development (OECD, 1997). These documents provide background on the biology of B. napus including:

 information on use of canola as a crop plant

 taxonomic status of Brassica

 identification methods

 reproductive biology

 centers of origin and diversity

 crosses, including intra- and inter-specific/genus crosses and gene flow

 agro-ecology, including information about cultivat ion, volunteers and weediness, soil ecology, and canola-insect interactions

II-B. Description of the Non-Transformed Recipient Canola Line

A doubled-haploid form of the Pioneer proprietary li ne, 1822B, was used as the recipient line for the production of 73496 canola. Line 1822B was chosen becau se it is receptive to transformation and is also an elite line ( i.e. , Pioneer proprietary line used for commercial products). The use of this doubled-haploid line ensured that the recipient li ne was homozygous at all genetic loci, which aided in the breeding and testing of the transformed events.



### III. Method of Development of 73496 Canola

III-A. Description of Transforma tion, Selection, and Breeding

A gel-purified DNA fragment isolated from plasmid PHP28181 (containing the gat4621 gene cassette) was used to generate 73496 canola. Refer to Sectio n 3.1 for a detailed description of the gel-purified Hin d III/ Not I DNA fragment, PHP28181A, used for transformation.

Microspores were prepared from donor line 1822B an d transformed essentially as described (Chen and Tulsieram, 2007). Gold particles coated with t he PHP28181A DNA fragment were used for biolistic transformation carried out as described (Klein et al. , 1987). Transformed embryogenic microspores were cultured in fresh medium in dark conditions for 10 to 12 days, then under dim light for one to three weeks. Green embryos were transferred to fresh medium and cultured for two weeks at 4°C and then for four weeks at 25°C in the presence of glyphosate (0.1 mM) to select for glyphosate-t olerant transformants. Germinated shoots or plants were transferred to gr owth medium supplemented with glyphosate for selection.

Plants that were regenerated from transformation and tissue culture (designated T0 plants) were selected for further characterization by molecular analyses, he rbicide efficacy, and agronomic evaluations. Refer to Figure 1 for a schematic overview of the transformation and event development process for 73496 canola.

The subsequent breeding of 73496 canola proceeded as indicated in Figure 2 to produce specific generations for the characterization and assessment s conducted. Table 1 indicates the breeding generations used for each of the analyses described in this submission. During the breeding and product development of 73496 canola, seed was produced for multiple purposes, including product development, research testing, and regulatory testing. Becaus e there was not enough seed from any one generation for all of the regulatory studies listed in Table 1, seed was sourced from multiple generations of 73496 canola. Where applicable, studies contained the appr opriate near-isoline and/or commercial comparator. Each generation is equally representative of 73496 canola.Pioneer Hi-Bred International, Inc. Page 17 of 167 73496 Canola

Assembly and isolation of DNA fragment PHP28181A containing gat4621 gene cassette ↓ Transformation of microspores from 1822B line using particle bombardment ↓ Selection of transformation events based on tolerance to glyphosate

Regeneration of T0 canola plants ↓ Molecular characterization and evaluation of T0 plants ↓ Selfing and molecular analysis to select homozygous plants ↓ Nursery evaluation of agronomic performance and herbicide efficacy of subsequent generations ↓ Multiple location herbicide efficacy and agronomic trials ↓ Selection of event DP-Ø73496-4 as the commercial candidate ↓ Continued field and laboratory studies to support product registration

Continued breeding and testing of 73496 canola for product development

Figure 1. Schematic Diagram of the Development of 73496 Canola

1822B T0

Self

T1

Self

T2

Self T3

T4 X 1822R

T3F1 Self

T3F2

T3F3

T3F4 X 5536F F1 *4

F1 *5 Self

X 5300B

F1 *1

Self BC1F1 *1

BC2F1 *1

BC3F1 *1 X 5300B

X 5300B

X 5300B BC2F1 *3 X 6393B

X 6393B

X 6393B BC1F1 *3

X 6393B

BC3F1 *3 X 6395B

X 5536F Self F1 *3 F1 *2 Self

T5

Figure 2. Breeding Diagram for 73496 Canola and Generations Used for AnalysesPioneer Hi-Bred International, Inc. Page 18 of 167 73496 Canola

Table 1. Generations and Comparators Used for Analysis of 73496 Canola

Analysis Generation Comparators and Commercial Reference Lines
Genetic Characterization (Section V) T2, T3, F1 *2 , T3F2, T3F3 1822B, 1822R, and 6395B

Inheritance (Section V-E) F1 *1, *3 , BC1F1 *1, *3 , BC2F1 *1, *3

, BC3F1 *1, *3 , T3F2 Not applicable

Concentrations of GAT4621 (Section V-B) F1 *4 5536F x 1822R (near isoline)

Compositional Assessment (Section VIII) F1 *4 5536F x 1822R (near isoline) and Pioneer commercial lines 46A65, 45H72, 45H73, 46H02, and 44A89 Germination and Dormancy (Agronomic Performance) (Section VII-A) F1 *5 5536F x 1822R (near isoline) and Pioneer commercial lines 45H72 and 45H73 Field Trial Evaluations (Agronomic Performance) (Section VII-B) T3 (7 locations) T5 (3 locations) 1822B 1822B

III-B. Selection of Comparators for 73496 Canola

To ensure an accurate evaluation of the effect of t he transgene, a proper selection of comparator plants is important for the analysis of a transgenic plant. Cont rol canola lines were used as comparators for 73496 canola (Table 1). For all analyses, the near-isoline c ontrol plants had a genetic bac kground similar to that of the 73496 canola generation used ( i.e., >95% genetic similarity), but did not go through the transformation process.

In addition, non-transgenic commercial canola lines (Table 1) were used to obtain tolerance intervals for the nutrient compositional assessment. These Pion eer commercial canola products were chosen to represent the full range of non-genetically modified vari eties that would normally be planted commercially. The tolerance intervals were used to establish the ra nge of natural variation of current commercial canola products with respect to key nutrients and anti-nutrients, and to determine the possible biological significance of any observed statistical differences between 73496 canola and commercial canola lines.



### IV. Donor Genes and Regulatory Sequences

IV-A. Fragment PHP28181A Used in Transformation

73496 canola was produced by biolistic transformation with the Hin d III/ Not I fragment, PHP28181A, from plasmid PHP28181. The PHP28181A fragment containing the UBQ10 promoter, the gat4621 gene, and the pin II terminator is shown in Figure 3, and the entir e PHP28181 plasmid is shown in Figure 4.Pioneer Hi-Bred International, Inc. Page 19 of 167 73496 Canola



# PHP28181A
2112 bp 

### gat4621 UBQ10 Promoter pin II Terminator

Figure 3. Schematic Diagram of Fragment PHP28181A

Schematic diagram of transformation fragment PHP28181A with the gat4621 gene and its regulatory elements indicated. The size of the fragment is 2112 base pairs (bp).



# PHP28181
4770 bp



## bla (Ap R 

## ) gat4621 UBQ10 Promoter



## pin II Terminator

Not I (2113) Hin d III (1)



## colE1 ori

Figure 4. Schematic Diagram of Plasmid PHP28181

Schematic diagram of plasmid PHP28181 indicating the genetic elements. Hin d III and Not I restriction enzyme sites flank the transformation fragment PHP28181A. The size of the plasmid is 4770 bp.Pioneer Hi-Bred International, Inc. Page 20 of 167 73496 Canola

IV-B. Identity and Source of the gat4621 Gene Cassette on Fragment PHP28181A

The genetic elements present in the transformation fragment PHP28181A are listed in Table 2. The gat4621 gene was optimized by a gene shuffling process of glyphosate acetyltransferase genes from Bacillus licheniformis

. The GAT4621 protein, encoded by the gat4621 gene, confers tolerance to glyphosate-containing herbicides by acetylating glyphosate, thereby rendering it non-phytotoxic (Castle et al ., 2004).

B. licheniformis , the source organism for the gat4621 gene, is used for the production of a number of enzymes such as proteases and amylases that hav e wide application in the detergent industry. B. licheniformis has been used in the United States, Canada, and Europe in the fermentation industry for production of food enzymes ( e.g., alpha-amylase, cyclodextrin glycosyltransferase, hemicellulase, proteases, and pullulanase; Rey et al., 2004). All B. licheniformis cultures available from the American Type Culture Collection (ATCC) are classified as Bios afety Level 1. Items that the ATCC classifies at Biosafety Level 1 have no known history of causing disease in humans or animals based on their assessment of potential risk using U.S. Public Health Service guidelines, with assistance provided by ATCC scientific advisory committees.

The expression of the gat4621 gene is controlled by the Arabidopsis thaliana polyubiquitin promoter ( UBQ10 ) (Norris et al. , 1993). The terminator for the gat4621 gene is the 3’ terminator sequence from the proteinase inhibitor II gene of Solanum tuberosum ( pin II terminator) (An et al. , 1989; Keil et al. , 1986).

Table 2. Description of the Geneti c Elements in Fragment PHP28181A

Location on

Fragment (bp position) Genetic Element Size (base pairs) Description

1 to 7 Polylinker Region 7 Region required for cloning genetic elements

8 to 1312 UBQ10 Promoter 1305 Version of the promoter region from Arabidopsis thaliana UBQ10 polyubiquitin gene (Norris et al. , 1993) developed by E. I. duPont de Nemours and Company

1313 to 1335 Polylinker Region 23 Region required for cloning genetic elements

1336 to 1779 gat4621 Gene 444 Synthetic glyphosate N -acetyltransferase gene (Castle et al. , 2004; Siehl et al. , 2007)

1780 to 1796 Polylinker Region 17 Region required for cloning genetic elements

1797 to 2106 pin II Terminator 310 Terminator region from Solanum tuberosum proteinase inhibitor II gene (An et al. , 1989; Keil et al. , 1986)

2107 to 2112 Polylinker Region 6 Region required for cloning genetic elementsPioneer Hi-Bred International, Inc. Page 21 of 167 73496 Canola



### V. Genetic Characterization of 73496 Canola

V-A. Molecular Analysis Overview

Molecular characterization of the inserted DNA eval uates the integrity of the introduced cassette and provides a confirmation that the elements of the expr ession cassette are intact. Genetic stability is evaluated to confirm the in heritance of the inserti on and confirms the stabilit y of the introduced trait through traditional breeding methods.

The inserted DNA in 73496 canola was characterized by Southern blot analysis to evaluate the integrity and stability of the inserted gat4621 cassette. As described earlier in Section III-A, 73496 canola was produced by biolistic transformation with fragm ent PHP28181A. Fragment PHP28181A contains the gat4621 cassette containing the UBQ10 promoter, gat4621 gene, and pin II terminator. All probes used for the analysis are indicated on the schematic ma ps of PHP28181A and PHP28181 (Figures 5 and 6, respectively) and outlined in Table 3. Plasmid PHP28181 was used as a positive control for probe hybridization and to verify fragment sizes internal to PHP28181A. Individual plants of the T2, T3, T3F2, T3F3, and F1* 2 generations (refer to Figure 2 for the bree ding diagram) were analyzed to determine the copy number of each of the genetic elements inserted in to 73496 canola and to verify that the integrity of the PHP28181A fragment was maintained upon integration.

The analyses confirmed that a single, intact PHP281 81A DNA fragment was inserted into the genome of 73496 canola (Section V-B1 and B2). In addition, these analyses also verified that the inserted DNA remained intact and stably integrated in 73496 ca nola. All five generations demonstrated identical hybridization patterns. These results confirmed t he stability of the inserted DNA in 73496 canola across these five breeding generations. Based on these analyses, schematic maps of the inserted DNA in 73496 canola were determined and are provided in Figure 7.

All five generations were also analyzed to c onfirm the absence of plasmid backbone sequence, i.e. the plasmid region outside of isolated fragment PHP28 181A. The results verified the absence of these backbone sequences in both 73496 canola (Section V-B3).

To confirm inheritance of the insertion through tr aditional breeding, segregation analysis using genotypic and phenotypic assays were conducted (Section V-C). These results indicated that the inserted DNA and the herbicide-tolerance phenotype in 73496 canola segregate according to Mendel’s laws of segregation and are consistent with the fi nding of a single locus of insertion of the gat4621 cassette. The stability of the insertion and of the herbicide-tolera nce phenotype was demonstrat ed in these generations of self- and cross-pollinations.

Materials and methods for the molecular and genetic characterization of 73496 canola are described in Appendix 1.

V-B. Results of Molecular Characterization of 73496 Canola by Southern Blot Analysis

The integration pattern of the insertion in 73496 cano la was investigated using Southern blot analysis with Nco I digested genomic DNA to determine copy number and with Ssp I digested genomic DNA to determine insertion integrity. Copy number and integr ity of each genetic element were determined in five generations of 73496 canola using probes specific to the UBQ10 promoter, gat4621 gene, and pin II terminator (Table 3, Figure 5). These analyses also verified that the inserted DNA remained intact and stably integrated. In addition, probes to the plasmi d backbone region of PHP28181 located outside of the PHP28181A DNA fragment (Table 3, Figure 6) were used to show that these regions were not transferred to 73496 canola.

Based on the Southern blot analyses described below, it was determined that a si ngle, intact PHP28181A DNA fragment was inserted into the genome of 73496 canola as diagramed in the insertion map (Figure 7) and that no region from the backbone of plasmi d PHP28181 was inserted. In addition, these results confirmed the stability of the inserted DNA in 73496 canola across five breeding generations.Pioneer Hi-Bred International, Inc. Page 22 of 167 73496 Canola

B1. Copy Number

The Nco I digestion provides information about the nu mber of copies of the PHP28181A DNA fragment that have been integrated into the genome of 73496 ca nola. The PHP28181A DNA fragment contains a single Nco I restriction enzyme site at bp position 1335 (Figure 5) and any additional sites would fall in the canola genome outside the fragment sequence. Th erefore, hybridization with probes from the gat4621 cassette would indicate the number of copies of each element found in 73496 canola based on the number of hybridizing bands ( e.g. one hybridizing band indicates one copy of the element). As the Nco I restriction site is located between the UBQ10 promoter and gat4621 gene, the promoter probe is expected to hybridize to a single band of greater than 1300 bp, and the gat4621 and pin II terminator probes are expected to hybridize to a single ban d of greater than 800 bp (Figure 5). Predicted and observed fragment sizes for 73496 canola with Nco I digestion are provided in Table 4.

The UBQ10 promoter probe was hybridized to Nco I-digested genomic DNA from individual 73496 canola plants of the T2, T3, T3F2, T3F3, and F1* 2 generations (Table 4, Figure 8). A single fragment of greater than 8600 bp was detected in each 73496 canola plant sample (Table 4, Figure 8), indicating a single copy insertion of the promoter element. The gat4621 and pin II terminator probes were hybridized to the

same Nco I-digested genomic DNA. Both probes hybrid ized to the same single band of approximately 7000 bp in each 73496 canola plant sample (Table 4, Figures 9 and 10).

The presence of single bands for each probe in this Southern blot analysis demonstrated the presence of a single copy of the PHP28181A DNA fragment in 73496 canola. The presence of identical hybridization patterns for each probe in all 73496 canola plants of the five generations analyzed demonstrated the stability of the DNA insertion during traditional breeding.

B2. Insertion Integrity

Ssp I digestion was used to verify that the inserted PHP28181A DNA fragment containing the gat4621 cassette was complete and intact in 73496 canola. Two Ssp I sites are present within the PHP28181A DNA fragment (bp positions 157 and 2043; Figure 5). Hybridization with the probes of the gat4621 cassette confirmed that all the elements were found on the expected internal 1886 bp fragment. Expected and observed fragment sizes for 73496 canola with Ssp I are provided in Table 4. All three probes are expected to hybridize to an internal fr agment of 1886 bp (Table 4, Figure 5). Due to the locations of the Ssp I restriction sites within the UBQ10 promoter and pin II terminator elements (Figure 5), these two probes are also expected to hybridize to additional border fragments (Table 4).

The UBQ10 promoter, gat4621 , and pin II terminator probes all hybridized to a single insert-derived band of 1886 bp that matched the plasmid control band in each 73496 canola plant sample (Table 4, Figures 11, 12, and 13). The UBQ10 promoter probe was expected to hybridize to a border band due to the Ssp I site within the UBQ10 promoter element. A faint border band of approximately 2200 bp was detected with the UBQ10 promoter probe (Table 4, Figure 11). A w eakly hybridizing border band of approximately 1100 bp was also detected with the pin II terminator probe (Table 4, Figure 13). The weak band resulted from a border fragment including the portion of the pin II terminator located 3’ to the Ssp I site at bp 2043 of PHP28181A (Figure 5) and a second Ssp I site for this fragment located in the canola genome. These hybridizing border bands with the UBQ10 promoter and pin II terminator probes were observed in each 73496 canola plant sample (Figures 11 and 13).

The presence of the 1886 bp internal band with all probes and the border bands with the UBQ10 promoter and pin II terminator probes indicate that the PH P28181A fragment was inserted intact into 73496 canola. Furthermore, the same hybridization pattern with each probe in the five generations confirmed the stability of the insertion in 73496 canola during traditional breeding.

B3. Plasmid Backbone DNA Analysis

Five generations of 73496 canola were analyzed by Southern blot analysis for the presence of DNA sequences from the PHP28181 plasmid backbone. Probes for sequences from the PHP28181 plasmidPioneer Hi-Bred International, Inc. Page 23 of 167 73496 Canola

backbone located outside the PHP28181A DNA fragm ent were used to determine if any plasmid backbone was inserted in 73496 canola during transforma tion. Three probes covered the entire plasmid backbone region and were used in a single hybridizat ion solution. These probes would confirm if any region of the backbone outside the PHP28181A DNA fragment was transferred into 73496 canola.

Genomic DNA from the T2, T3, T3F2, T3F3, and F1* 2 generations were digested with Nco I and hybridized to the backbone probes described above. No bands were observed in the 73496 canola or control canola samples, while the expected band of 4770 bp was seen in the plasmid positive control lanes (Figure 14). This confirms that no sequence from the PHP28181 plasmid backbone was inserted into 73496 canola during transformation.

B4. Physical Map of the Inserted DNA in 73496 Canola

Based on the Southern blot analysis, it was determi ned that a single, intact PHP28181A DNA fragment was inserted into the genome of 73496 canola. Using these data, a physical map of the inserted DNA in 73496 canola showing the applicable restriction enzy mes was developed and is provided in Figure 7.

B5. Summary and Conclusions

Southern blot analysis was conducted to characterize the DNA insertion in 73496 canola. The analysis confirmed that a single, intact PHP28181A DNA fr agment had been inserted into the canola genome to produce 73496 canola. A single copy of each of the UBQ10 promoter, gat4621 gene, and pin II terminator genetic elements was present and the integrity of the PHP28181A DNA fragment was maintained upon integration. Identical hybridization patterns were observed across the T2, T3, T3F2, T3F3, and F1* 2 generations, thus demonstrating stab ility of inheritance of the insertion in 73496 canola during traditional breeding procedures. In addition, Southern blot analysis verified the absence of plasmid backbone sequences in 73496 canola.Pioneer Hi-Bred International, Inc. Page 24 of 167 73496 Canola

Table 3. Description of DNA Probes Used for Southern Blot Hybridization

Probe Name Genetic Element Figure
Probe Position on PHP28181A DNA Fragment (bp to bp) Position on PHP28181

Plasmid (bp to bp) Probe Length

(bp)

UBQ10 promoter a UBQ10 promoter Figure 5 probe A 26 to 699
720 to 1286 26 to 699
720 to 1286 674
567

gat4621 gat4621 gene Figure 5 probe B 1336 to 1770 1336 to 1770 435

pin II terminator pin II terminator Figure 5 probe C 1849 to 2082 1849 to 2082 234

Backbone 1 Plasmid between Not I and bla Figure 6 probe 1 N/A 2120 to 2762 643

bla (Ap R ) Ampicillin resistance gene Figure 6 probe 2 N/A 2736 to 3566 831

Backbone 2 Plasmid between bla and Hin d III Figure 6 probe 3 N/A 3503 to 4770 1268

N/A-Not Applicable, these are not pr esent on the PHP28181A DNA fragment.

a Two non-overlapping segments were generated for this probe and were combined for hybridization. The bp

positions provided are the positi ons of each different segment.Pioneer Hi-Bred International, Inc. Page 25 of 167 73496 Canola

Table 4. Summary of Expected and Observed Hybridization Fragments on Southern Blots for 73496 Canola

Probe Enzyme Digestion Figure Expected Fragment

Size in 73496 Canola (bp) a Expected Fragment Size in Plasmid PHP28181 (bp) b Observed Fragment Size in

73496 Canola (bp) c

UBQ10 Promoter Nco I 8 >1300 (border) 4770 >8600
Ssp I 11 >200 (border) 1886 2208 1886 ~2200 1886 d

gat4621 Nco I 9 >800 (border) 4770 ~7000 Ssp I 12 1886 1886 1886 d

pin II Terminator Nco I 10 >800 (border) 4770 ~7000
Ssp I 13 1886 >100 (border) 1886 676 1886 d
~1100 Plasmid Backbone e Nco I 14 none 4770 none

a Size based on map of fragment PHP28181A in Figure 5. Border fragment size rounded to nearest 100 bp.
b Size based on plasmid map of PHP28181 in Figure 6.

c Observed fragment sizes are approximated from the di goxigenin (DIG)-labeled DNA Molecular Weight Marker

VII fragments on the Southern blots. Due to the inability to determine exact sizes on the blot, all approximated values are rounded to the nearest 100 bp. d Size is same as expected because of equivale nt migration with plasmid positive control.

e The plasmid backbone probe includes three fragments covering the entire plasmid backbone sequence in a

single hybridization solution.



### gat4621 UBQ10 Promoter pin II Terminator Nco I (1335)
Ssp I (157) Ssp I (2043)



# A C B

Figure 5. Restriction Enzyme Map of PHP28181A DNA Fragment

Schematic map of fragment PHP28181A from plasmid PH P28181 used for transformation of canola. Location of genetic elements and Ssp I and Nco I restriction enzyme sites are indicated. Fragment size is 2112 bp. The locations of the probes used are shown as boxes in the lo wer part of the map and are identified as follows: A = UBQ10 promoter probe, B = gat4621 probe

, and C = pin II terminator probe.Pioneer Hi-Bred International, Inc. Page 26 of 167 73496 Canola



### Figure 6. Restriction Enzyme Map of Plasmid PHP28181

Schematic map of plasmid PHP28181 indicating the location of genetic elements and Not I, Ssp I, Nco I, and Hin d III restriction enzyme sites. Hin d III and Not I sites flank the fragment PHP28181A (Figure 5) used for transformation of canola. The black arcs inside the plasmi d map indicate the locations of the three probes used to confirm the absence of plasmid backbone sequences and are identified as follows: 1 = Backbone 1 probe, 2 = bla (Ap R ) probe, and 3 = Backbone 2 probe.

PHP28181A

Nco I ~7000 bp >8600 bp 1886 bp Ssp I ~2200 bp ~1100 bp Nco I Nco I Ssp I gat4621 UBQ10 Promoter pin II Terminator Nco I
Ssp I Ssp I Ssp I

Figure 7. Physical Map of the Insertion in 73496 Canola

Schematic map of the insertion in 73496 canola based on Southern blot analysis. The flanking canola genome is represented by the horizontal dotted li ne. A single, intact copy of the PH P28181A DNA fragment integrated into the canola genome. Nco I and Ssp I restriction enzyme sites are indicate d with the sizes of observed fragments on Southern blots shown below the map in bp. The loca tions of restriction enzyme sites outside the PHP28181A DNA fragment are not shown to scale.Pioneer Hi-Bred International, Inc. Page 27 of 167 73496 Canola

Figure 8. Southern Blot Analysis of 73496 Canola: Nco I Digestion and UBQ10 Promoter Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Nco I and hybridized to the UBQ10 promoter probe. A pproximately 4 μg of genomic DNA was digested and loaded per lane. Positi ve control lanes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight markers are indicated adjacent to the blot image in kilobases (kb).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 1822B control 14 73496 canola / plant 14 (T3F3 generation) 5 1822R control 15 73496 canola / plant 15 (T3F3 generation) 6 6395B control 16 73496 canola / plant 19 (F1* 2 generation) 7 Blank 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

kb

8.6 7.4

6.1

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Figure 9. Southern Blot Analysis of 73496 Canola: Nco I Digestion and gat4621 Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Nco I and hybridized to the gat4621 probe. Approximately 4 μg of genomic DNA was digested and loaded per lane. Positive control l anes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight markers are in dicated adjacent to the blot image in kilobases (kb).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 1822B control 14 73496 canola / plant 14 (T3F3 generation) 5 1822R control 15 73496 canola / plant 15 (T3F3 generation) 6 6395B control 16 73496 canola / plant 19 (F1* 2 generation) 7 Blank 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

kb

8.6 7.4

6.1

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0.72Pioneer Hi-Bred International, Inc. Page 29 of 167 73496 Canola

Figure 10. Southern Blot Analysis of 73496 Canola: Nco I Digestion and pin II Terminator Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Nco I and hybridized to the pin II terminator probe. Approximately 4 μg of genomic DNA was digested and loaded per lane. Positive cont rol lanes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight marker s are indicated adjacent to the blot image in kilobases (kb).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 1822B control 14 73496 canola / plant 14 (T3F3 generation) 5 1822R control 15 73496 canola / plant 15 (T3F3 generation) 6 6395B control 16 73496 canola / plant 19 (F1* 2 generation) 7 Blank 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

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0.72Pioneer Hi-Bred International, Inc. Page 30 of 167 73496 Canola

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

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Figure 11. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and UBQ10 Promoter Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Ssp I and hybridized to the UBQ10 promoter probe. A pproximately 4 μg of genomic DNA was digested and loaded per lane. Positi ve control lanes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight markers are indicated adjacent to the blot image in kilobases (kb). Note: A faint band is visible on the X-ray film at about 2. 2 kb in lanes 8 through 17 (may not appear on printed copy).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 Blank 14 73496 canola / plant 14 (T3F3 generation) 5 1822B control 15 73496 canola / plant 15 (T3F3 generation) 6 1822R control 16 73496 canola / plant 19 (F1* 2 generation) 7 6395B control 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B controlPioneer Hi-Bred International, Inc. Page 31 of 167 73496 Canola

Figure 12. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and gat4621 Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Ssp I and hybridized to the gat4621 probe. Approximately 4 μg of genomic DNA was digested and loaded per lane. Positive control l anes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight markers are in dicated adjacent to the blot image in kilobases (kb).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 Blank 14 73496 canola / plant 14 (T3F3 generation) 5 1822B control 15 73496 canola / plant 15 (T3F3 generation) 6 1822R control 16 73496 canola / plant 19 (F1* 2 generation) 7 6395B control 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control kb

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Figure 13. Southern Blot Analysis of 73496 Canola: Ssp I Digestion and pin II Terminator Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Ssp I and hybridized to the pin II terminator probe. Approximately 4 μg of genomic DNA was digested and loaded per lane. Positive cont rol lanes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecular weight marker s are indicated adjacent to the blot image in kilobases (kb). Note: A faint band is visible on the x-ray film at about 1. 1 kb in lanes 8 through 17 (may not appear on printed copy).

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 Blank 14 73496 canola / plant 14 (T3F3 generation) 5 1822B control 15 73496 canola / plant 15 (T3F3 generation) 6 1822R control 16 73496 canola / plant 19 (F1* 2 generation) 7 6395B control 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 1

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0.72Pioneer Hi-Bred International, Inc. Page 33 of 167 73496 Canola

Figure 14. Southern Blot Analysis of 73496 Canola: Nco I Digestion and Plasmid Backbone Probe

Genomic DNA isolated from leaf tissue from individual plants from five generations of 73496 canola and control canola lines was digested with Nco I and hybridized to the combined plasmid backbone probe. Approximately 4 μg of genomic DNA was digested and loaded per lane. Positive control lanes include plasmid PHP28181 and 4 μg of control canola DNA. Sizes of the DIG VII molecu lar weight markers are indicated adjacent to the blot image in kilobases (kb). Note: Extra bands in Lane 3 near and below the 0.72 kb band are due to hybridization of the probe to the Φ X174 RF DNA/ Hae III fragments used to monitor gel electrophoresis progress.

Lane Sample Lane Sample

1 3 copy PHP28181 + 1822R control 11 73496 canola / plant 8 (T3 generation) 2 1 copy PHP28181 + 1822R control 12 73496 canola / plant 9 (T3F2 generation) 3 DIG VII molecular weight marker 13 73496 canola / plant 10 (T3F2 generation) 4 1822B control 14 73496 canola / plant 14 (T3F3 generation) 5 1822R control 15 73496 canola / plant 15 (T3F3 generation) 6 6395B control 16 73496 canola / plant 19 (F1* 2 generation) 7 Blank 17 73496 canola / plant 20 (F1* 2 generation) 8 73496 canola / plant 1 (T2 generation) 18 DIG VII molecular weight marker 9 73496 canola / plant 3 (T2 generation) 19 1 copy PHP28181 + 6395B control 10 73496 canola / plant 7 (T3 generation) 20 3 copy PHP28181 + 6395B control 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

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0.72Pioneer Hi-Bred International, Inc. Page 34 of 167 73496 Canola

V-C. Inheritance and Genetic Stability of the Introduced Trait in 73496 Canola

Inheritance of the inserted DNA and the herbicide-t olerance phenotype in 73496 canola was evaluated to ensure stability of the trait during the plant breeding process and to confirm the trait was at a single genetic locus. Segregating generations of 73496 canola (T3F2, BC1F1 *1,*3 , BC2F1 *1,*3 , and BC3F1 *1,*3 ) and one non-segregating generation (F1 *1,*3 ) were evaluated. The breeding history of these five generations is shown in the breeding diagram (Section III-A, Fi gure 2). Those populations with the superscript “*1” or “*3” designation were populations from two different genetic backgrounds (Figure 2). Chi-square analysis was conducted on the four se gregating generations to determine if the observed segregation ratios were consistent with the expect ed ratios. The assay methods and statistical analysis for the trait inheritance data are described in Appendix 1.

The presence of the 73496 event insert ion was determined by event-specific and gat4621 gene-specific endpoint PCR analyses performed on leaf punches from seedlings of each generation. The herbicide tolerance phenotype was determined by treating the pl ants with herbicide and by visually evaluating each plant for the presence of herbicide injury. A posit ive plant exhibited no herbi cidal injury and a negative plant exhibited severe herbicide injury.

Results from the segregation analysis are provided in Table 5. For one of the plants, PCR analyses were inconclusive and were unable to be repeated, and ther efore were excluded from the statistical analyses. However, this excluded plant was evaluated for the herbicide-tolerance phenotype and this information was reported and analyzed. For those plants wher e both PCR and herbicide-tolerance phenotype data were obtained, all analyses correlated ( e.g. , plants that were positive by PCR analyses were also tolerant to the herbicide). To confirm that the inserted DNA and the herbicide-tolerance phenotype segregate according to Mendel’s laws of genetics, chi-square analysis was performed separately for the PCR and the herbicide-tolerance phenotype data. All P-values were greater than 0.05, wi th the exception of the BC1F1 *1,*3 generation of 73496 canola, indicating that the observed segregation ratio was consistent with the expected ratio (Table 5).

In the case of the BC1F1 *1 and BC1F1 *3 populations, the observed segregation ratios were not consistent with the expected 1:1 (positive: negat ive) ratio (Table 5) and this was attributed to the hand pollinations that were performed to generate the populations. The BC1F1 *1 and BC1F1 *3 populations were crosspollinated by hand with a control canola plant in or der to generate a population segregating 1:1. This process required removal of pollen-producing anthers from several fertile flower buds of a hemizygous 73496 canola plant. It is likely that some of the fl ower buds were self-pollinated inadvertently, generating a 3:1 segregating population, prior to the cross-pollin ation step and resulted in a pool of seed that was a mixture of 3:1 and 1:1 segregating populations. Each of the other 73496 canola generations that were analyzed were either derived from the same progenito r as the BC1F1 generation (T3F2), a parent of the BC1F1 generation (F1 *1,*3 ), or derived directly from this BC1F1 generation (BC2F1 *1,*3 and BC3F1 *1,*3 ) (Figure 2). The fact that results from these othe r four generations were consistent with expectations indicate that the BC1F1 *1 and BC1F1 *3 populations were not representative of the segregation of the trait and that the insertion is segregating as expected.

These results indicate that the inserted DNA and the herbicide-tolerance phenotype in 73496 canola segregate according to Mendel’s laws of segregatio n and were consistent with the finding of a single locus of insertion of the gat4621 cassette. The stability of the in sertion and of the herbicide-tolerance phenotype was demonstrated in these generat ions of self- and cross-pollinations.Pioneer Hi-Bred International, Inc. Page 35 of 167 73496 Canola

Table 5. Summary of Genotypic and Phenotypic Results for 73496 Canola

73496 Canola Generation Expected Segregation Ratio Seed Source Analysis Observed Values (n = 100 a ) Statistical Analysis

Positive Negative ChiSquare b Pvalue

T3F2 3:1 T3F2 PCR 69 30 1.4848 0.2230 Herbicide tolerance assay 69 31 1.9200 0.1659

F1 NonSegregating F1 *1 PCR 49 1

NA c F1 *3 50 0

F1 *1 Herbicide tolerance assay 49 1
F1 *3 50 0

BC1F1 1:1 BC1F1 *1 PCR 32 18 3.9200 0.0477 d

BC1F1 *3 32 18 3.9200 0.0477 d

BC1F1 *1 Herbicide tolerance assay 32 18 3.9200 0.0477 d

BC1F1 *3 32 18 3.9200 0.0477 d

BC2F1 1:1 BC2F1 *1 PCR 29 21 1.2800 0.2579
BC2F1 *3 26 24 0.0800 0.7773
BC2F1 *1 Herbicide tolerance assay 29 21 1.2800 0.2579
BC2F1 *3 26 24 0.0800 0.7773

BC3F1 1:1 BC3F1 *1 PCR 24 26 0.0800 0.7773
BC3F1 *3 27 23 0.3200 0.5716
BC3F1 *1 Herbicide tolerance assay 24 26 0.0800 0.7773
BC3F1 *3 27 23 0.3200 0.5716

a n = 99 for statistical analysis of T3F2 PCR results (PCR results for one T3F2 plant were inconclusive and were therefore excluded).
b Degrees of freedom = 1

c Chi-square test is not applicable (NA) fo r testing a non-segregating population ( i.e . a nominal proportion of 1.0).

d Statistically significant difference, P-value <0.05

V-D. Conclusions on Molecular Characteri zation and Genetic Stability of 73496 Canola

Southern blot analysis was conducted to characterize the DNA insertion in 73496 canola. The analysis confirmed that a single, intact PHP28181A DNA fragm ent was inserted into the canola genome. A single copy of each of the UBQ10 promoter, gat4621 gene, and pin II terminator genetic elements was present and the integrity of the PHP28181A DNA fragment wa s maintained. Southern blot analysis on five generations confirmed the stability of inheritance of the DNA insertion during traditional breeding procedures. In addition, Southern blot analysis ve rified the absence of plasmid backbone sequences in 73496 canola.

The inheritance and genetic stability of the inserted DNA in 73496 canola was examined in additional generations by event-specific and gene- specific PCR assays and by eval uation of herbicide-tolerance in the population. Four segregating generations and one non-segregating generat ion were evaluated for consistency with the expected segregation ratio of t he population. The results of this analysis were consistent with the finding of a single locus of insertion of the gat4621 cassette in 73496 canola that segregated according to Mendelian rules of inheritance. The stability of the insertion and of the herbicidetolerance phenotype was demonstrated in these populations.

Together, these analyses confirmed the stability ofthe inserted DNA and its corresponding herbicidetolerance trait during traditional breeding of 73496 canola.Pioneer Hi-Bred International, Inc. Page 36 of 167 73496 Canola



### VI. Characterization of the Introduced GAT4621 Protein

73496 canola was modified to express the GAT4621 protei n to confer glyphosate-tolerance. The identity, deduced amino acid sequence, enzymatic activity , derivation, protein characterization, and concentrations of the GAT4621 protein in 7349 6 canola tissues are described below.

VI-A. The GAT4621 Protein

A1. Identity of the GAT4621 Protein

The GAT4621 protein is a variant of N -acetyltransferase protein sequences derived from Bacillus licheniformis , a gram positive saprophytic bacterium t hat is widespread in nature and thought to contribute substantially to nutrient cycling due to t he diversity of enzymes produced by members of its species. GAT4621 is 147 amino acids in length and has a molecular weight of 16.5 kDa (Figure 15).

Figure 15. Deduced Amino Acid Sequence of the GAT4621 Protein

The introduced gat4621 coding sequence in 73496 canola is identical to the gat4621 coding sequence present in the previously approved maize event DP-Ø9814Ø-6 (FDA, 2008; Rood, 2007b; USDA, 2009).

As discussed in Section VI-B, the GAT4621 pr otein produced in 73496 canola demonstrated physicochemical equivalence to the microbial-produ ced GAT4621 protein that was used in the protein safety studies that were conducted for maize event DP-Ø9814Ø-6. These bridging data also support the conclusion that the GAT4621 protein expressed in 73496 canola and in maize event DP-Ø9814Ø-6 are equivalent.

A2. Characteristics and Enzymatic Activity of GAT Proteins

Glyphosate acetyltransferase (GAT) proteins are members of the GCN 5-related family of N

-acetyltransferases (also known as the GNAT superfam ily). The GNAT superfamily is one of the largest enzyme superfamilies recognized to date with over 10,000 representatives fr om plants, animals and microbes. Members of the GNAT superfamily all c ontain highly conserved GNAT motifs but have high sequence diversity (Vetting et al ., 2005). The GNAT proteins are known to have a number of metabolic functions including detoxification (Dyda et al ., 2000). In particular, and as described below, GAT proteins can confer herbicide tolerance by detoxificat ion of the broad-spectrum herbicide glyphosate.

The enzyme 5-enolpyruvylshikim ate-3-phosphate synthase (EPSPS; 3-phophoshikimate 1-carboxyvinyltransferase; EC2.5.1.19) (Steinrücken and Amrhein, 1980) is the sixth enzyme of the shikimic acid pathway, which is essential for the biosynthesis of aromatic amino acids (L-phenylalanine, L-tyrosine and L-tryptophan) and chorismate-derived secondary metabo lites in algae, higher plants, bacteria, and fungi (Kishore and Shah, 1988). EPSPS has been identified as the primar y target of glyphosate [ N

- (phosphonomethyl) glycine], which is a nonselec tive, broad-spectrum, foliar-applied herbicide first commercialized in 1974 and widely used for t he management of annual, perennial, and biennial herbaceous species of grasses, s edges, and broadleaf weeds, as well as woody brush and tree species (Baylis, 2000; Bradshaw et al ., 1997). Mechanisms for conferring tole rance to glyphosate herbicide in genetically engineered plan ts have included the introduction of microbial variants of EPSPS that are insensitive to glyphosate ( e.g ., CP4 EPSPS from Agrobacterium tumefaciens ) or mutated forms of endogenous plant EPSP synthases ( e.g ., modified EPSPS from Zea mays ).Pioneer Hi-Bred International, Inc. Page 37 of 167 73496 Canola

GAT proteins provide an alternative mechanism of tolerance to glyphosate by detoxifying glyphosate to the non-phytotoxic form, N -acetylglyphosate (Figure 16). This deto xification mechanism is similar to that of the phosphinothricin acetyltransfe rase (PAT or BAR) enzymes from Streptomyces , which detoxify glufosinate ammonium herbicides by adding an acetyl group (De Block et al ., 1987). As shown in Figure 16, GAT enzymes acetylate the secondary amine of glyphosate using acetyl coenzyme A as an acetyl donor (Castle et al ., 2004). Transgenic expression of GAT pr oteins was shown to confer glyphosate tolerance in several plant species (Castle et al ., 2004) and is also the basis for previously approved maize (DP-Ø9814Ø-6) (FDA, 2008; Rood, 2007b; USDA, 2009) and soybean (DP-356Ø43-5) events (FDA, 2007; Rood, 2006; USDA, 2008).

Figure 16. Enzymatic Activity of the GAT4621 Protein

A3. Derivation of the GAT4621 Protein

The derivation of the GAT4621 enzyme was discuss ed in submissions to the USDA and FDA for maize event DP-Ø9814Ø-6 (FDA, 2008; Rood, 2007b; USDA, 2009) and was discussed in the New Protein Consultation that was provided to FDA (FDA, 2009; Rood, 2007a; Appendix 10). In summary, the gat4621 gene was produced using a DNA shuffling process employing three native gat genes from Bacillus licheniformis as pa rental templates (Castle et al. , 2004). The gat4621 gene variant was the result of 11 rounds of gene shuffling and the encoded GAT4621 enzyme exhibited a 7000-fold increase in catalytic activity relative to the native enzy mes, using glyphosate as a substrate (Siehl et al. , 2005). The gat4621 gene was further optimized for plant expressi on by conservative codon substitutions and a codon addition to improve protein production in plants (a GCT codon for alanine was inserted at amino acid position 2).

The GAT4621 protein, encoded by the gat4621 gene, is 75–78% identical and 90–91% similar at the amino acid level to each of the three native GAT enz ymes from which it was derived, compared to 94% identity of each of the native enzymes to each other (T able 6). Amino acid similarity is defined as the percentage of identical amino acids plus the percentage of “conservativ e” changes from one amino acid to another with the same functional side chain group ( e.g., alanine to valine, or lysine to arginine) between two proteins. Therefore, the percent similari ty is always equal to or greater than the percent identity between two proteins. There are 32 to 36 amino acid changes (22 to 23 of which are conservative) between the shuffled GAT4621 protei n and any one of the original three native GAT proteins.Pioneer Hi-Bred International, Inc. Page 38 of 167 73496 Canola

Table 6. Comparison of Amino Acid Sequence Similarity Between Parental GAT Enzymes and GAT4621

Percent Identity or Similarity of Amino Acid Sequences GAT (strain 401) GAT (strain B6) GAT (strain DS3) GAT4621

GAT (strain 401) 100% 94% Identica l 94% Identical 78% Identical
91% Similar

GAT (strain B6) 100% 94% Identical 76% Identical
91% Similar

GAT (strain DS3) 100% 75% Identical
90% Similar

GAT4621 100%

VI-B. Physicochemical Characterization of the GAT4621 Protein

The safety of GAT4621 protein was evaluated and wa s assessed previously by FDA as part of New Protein Consultation 005 (FDA, 2009; Rood, 2007a; A ppendix 10). That assessment considered the allergenicity and toxicity of the GAT4621 protein, which used a microbial-expressed GAT4621 protein as a means to evaluate protein safety in certain studi es. The microbial-expressed GAT4621 protein was characterized for maize event DP-Ø9814Ø-6 and was used to make relevant comparisons to the GAT4621 protein in 73496 canola to demonstrate equiva lence and to confirm suitability of bridging to the previous GAT4621 safety assessments.

In order to verify the equivalence of the in planta GAT4621 to the microbial-produced protein and confirm the microbial-produced protein was appropriate for t he safety assessment stud ies, a physicochemical characterization of the GAT4621 protein in 73496 canola was conducted. This characterization of the in planta GAT4621 protein included the following analyses:

 Molecular weight and immunochemical cross-reacti vity by sodium dodecyl sulfate polyacrylamide gel electrophoresis (SDS-PAGE) and western immunoblot analysis

 N-terminal amino acid sequencing to confirm protein identity

 Mass determination and protein identity using tr yptic peptide mapping by matrix assisted laser desportion ionization mass spectrometry (MALDI-MS)

 Glycoprotein staining to determine potential post-translational modification (glycosylation)

A detailed description of the methods used in the equi valency studies and the resulting data are included in Appendix 4.

Utilizing the above analyses, the equival ency of GAT4621 protein expressed in E. coli to the protein expressed in 73496 canola was demonstrated. T herefore, the GAT4621 pr otein derived from the microbial expression system was app ropriate for utilization in safety assessment studies as a proxy for the GAT4621 protein expressed in 73496 cano la. Microbial GAT4621 protein was used for in vitro digestion and acute toxicology safety assessment studies summarized in Section VI-D.

VI-C. Concentrations of GAT4621 in 73496 Canola

In order to understand the level expression of t he GAT4621 protein in 73496 canola and the potential exposure, the concentration of the protein was measur ed in relevant plant tissues. Expression of the GAT4621 protein is driven by the constitutive UBQ10 promoter from Arabidopsis thaliana and would be expected to be measurable in all tissues tested from 73496 canola.Pioneer Hi-Bred International, Inc. Page 39 of 167 73496 Canola

The range of expression of the GAT4621 protein in 73496 canola was determined by quantitative enzyme linked immunosorbent assay (ELISA) of samples of seed, roots, and whole plants ( i.e. , the entire above-ground portion of the plant) obtained from up to si x field trial locations in Canada and the United States in 2009 (Appendix 3 for ELISA materials and methods). Near-isoline canola plants were grown and sampled as controls.

As indicated below, tissue samples were collected at various developmental stages described by Lancashire et al. (1991):

 BBCH15 – five true leaves unfolded (whole plant sample)

 BBCH33 – three visibly extended internodes (whole plant sample)

 BBCH65 – full flowering; 50% of flowers open on main raceme, older petals falling (whole plant and root samples)

 BBCH90 – senescence (seed sample)

As expected, quantifiable amounts of GAT4621 protein were detected in each plant tissue tested from 73496 canola (Table 7). The range of mean concentrations in whole plant samples across growth stages was 5.2-6.9 ng/mg dry weight. The mean concentra tion of the GAT4621 protein measured in 73496 root was 6.6 ng/mg dry weight. The mean concentration in seed was 6.2 ng/mg dry weight.

Table 7. Concentration of GAT4621 Protein in 73496 Canola Plant Tissues

Tissue GAT4621 Concentration [ng/mg dry weight ± SD (range)] a Plant Growth Stage b

BBCH15 BBCH33 BBCH65 BBCH90
Whole Plant n=24 6.9 ± 1.3 (3.9–10) 5.3 ± 1.2 (3.1–8.4) 5.2 ± 0.88 (3.9–7.6) NC

Root n=24 NC c NC 6.6 ± 2.4 (3.9–13) NC

Seed n=20 NC NC NC 6.2 ± 0.94 (4.8–8.4)

a Values are expressed as the mean of f our replicate tissue samples collected fr om each of six locations except seed samples, which were only collected from five locations. SD = standard deviation; range, in parentheses, denotes the lowest and highest indivi dual value across sites.
b Plant growth stages: BBCH15 – five true leaves unfolded; BBCH33 – three visibly extended internodes; BBCH65 – full flowering; BBCH90 – senescence (Lancashire et al. , 1991).

c NC = Not collected.Pioneer Hi-Bred International, Inc. Page 40 of 167 73496 Canola

VI-D. Summary of the Food and Feed Safety Assessment for the GAT4621 Protein

A food and feed safety assessment was conducted to as sess the allergenicity and toxicity potential of the GAT4621 protein. A detailed assessment of t he food and feed safety of the GAT4621 protein was submitted to FDA on January 31, 2007 as part of New Protein Consultation (NPC) 005 and was completed on October 7, 2009 (FDA, 2009; Rood, 20 07a). A summary of the information in NPC 005, along with recently updated bioinformatic analyses on GAT4621 are described below. Additional information on 73496 canola, including human and lives tock exposure assessments, will be submitted to FDA as part of the consultation process for bioengineered foods.

Canola seed is not commonly consumed without proc essing and its fractions have different uses for humans and livestock. Canola seed is processed into refined oil which is then used as a human food and livestock feed. The by-product meal fraction from proc essing is used as livestock feed. Refined oil is the only canola product that is consumed by humans. The oil is free from any protein and considered nonallergenic (Gylling, 2006; Hefle and Taylor, 1999; Moneret-Vautrin and Kanny, 2004) , and therefore would not be expected to contain the GAT4621 protein.

Human or livestock consumption of the GAT4621 protein in o il derived from 73496 canola will be negligible. Livestock will consume the GAT4621 protein in meal derived from 73496 canola seed after oil extraction. Any human exposure to GAT4621 prot ein would be limited to potential occupational exposure to canola seed meal and flour in feed processi ng facilities, grain mills or on farm. Due to the very low exposure and low risk, the GAT4621 protein in 73496 canola is safe.

Although there will be consumption of the GAT4621 protein by livestock and also human occupational exposure from meal derived from 73496 canola, the GA T4621 protein is unlikely to cause an allergic reaction in humans or be a toxin in humans or animals, and therefore is safe for human exposure and animal consumption.

1) The donor organism, B. licheniformis , is a common soil bacterium widely distributed in the environment. Due to its ubiquitous presence as spores in soil and dust, B. licheniformis is widely known as a contaminant of food but is not associated with any adverse effects. 2) B. licheniformis has a history of safe use for t he production of food enzymes in the United States, Canada, and Europe (e.g., alpha-amylase, cyclod extrin glycosyltransferase, hemicellulase, proteases, pullulanase), biocontrol agents (EU Commission, 2000; FDA, 2001) and as a probiotic (Alexopoulos et al. , 2004a; Alexopoulos et al. , 2004b; Kritas et al. , 2006). B. licheniformis was determined by EPA to present low risk of adverse effects to human health and the environment and was subsequently granted an exemptio n for use in certain industrial fermentation processes (Federal Register, 1997). 3) The amino acid sequence of the GAT4621 protei n was compared to a database of allergens from the Food Allergy Research and Resource Program (FARRP ), University of Nebraska, Allergen Database (FARRP, 2010; Version 10.0, January 2010; http://www.allergenonline.org/ ), which contains the amino acid sequences of 1471 known and putative aller genic proteins. Potential identities between the GAT4621 protein and proteins in the allergen dat abase were evaluated using the FASTA34 sequence alignment program (Pearson and Lipman, 1988) set to t he default parameters (ktup = 2, scoring matrix = BLOSUM50, gap creation penalty = -1 0, gap extension penalty = -2, E score cutoff = 10). The top 20 high scoring alignments were reviewed for sequence identities greater than or equal to 35% over 80 or greater amino acid residues. None of the ali gnments met or exceeded the 35% over 80 or greater amino acid threshold. The GAT4621 amino acid se quence was also evaluated for any eight or greater contiguous identical amino acid matches to the sa me database of allergens noted above. There were no eight or greater contiguous identical amino ac id matches observed with the GAT4621 amino acid sequence. These data indicate the lack of both amino acid identity and immunologically relevant similarities between the GAT4621 protein and known protein allergens. 4) Additional experimental assays were conducted to assess the allergenic potential of the GAT4621 protein. The GAT4621 protein was assayed for dige stibility in simulated gastric fluid and in simulated intestinal fluids and also assayed for the presence of glycosylation. The GAT4621 protein is rapidly hydrolyzed in both simulated gastric and intestinal fluids (less than 30 seconds in simulated gastricPioneer Hi-Bred International, Inc. Page 41 of 167 73496 Canola

fluid containing pepsin at pH 1.2 as demonstrat ed by SDS-PAGE analysis, and less than 5 minutes in simulated intestinal fluid containing pancreatin at pH 7.5 as demonstrated by SDS-PAGE analysis). In addition, the GAT4621 protein in 73496 canola is not glycosylated (Appendix 4). Taken together with the similarity search results, these data i ndicate that the GAT4621 protein is unlikely to be allergenic to animals or humans. 5) Bioinformatic analyses demonstrated that the GAT46 21 protein retains the characteristics found in other N-acetyltransferases that are ubiquitous in plants and microorganisms (Neuwald and Landsman, 1997). GAT4621 contains the definit ive motif for the GNAT family ofN-acetyltransferases (MarchlerBauer et al., 2005). This superfamily of enzymes is present in all organisms, including plants, mammals, fungi, algae, and bacteria (Dyda et al ., 2000). 6) An updated sequence similarity search of the GAT 4621 protein sequence against the National Center for Biotechnology Information (NCBI) Entrez Pr otein dataset was conducted using the BLASTP 2.2.13 algorithm against Release 176.0 (02/15/10) of the NCBI Entrez Protein dataset. A cutoff E score of 1.0 was used to generate biologically meaningful similarity between the GAT4621 protein and proteins in the NCBI database, which allowed for identi fication of proteins with limited similarity in the search. Low complexity filtering was turned off and the maximum number of alignments returned was set to 2000. The GAT4621 similarity search identifie d 577 proteins that were within these criteria. None of the similar proteins returned by the search were identified as toxins, demonstrating that the GAT4621 protein is unlikely to share relevant sequen ce similarities with known protein toxins and is therefore unlikely to be a toxin itself. 7) There was no evidence of acut e toxicity in mice at a target dose of 2000 mg purified protein preparation per kg of body weight (equivalent to approximately 1640 mg of the full-length GAT4621 protein per kg of body weight). Based on expr ession levels of GAT4621 protein in 73496 canola toasted meal, the highest calculated exposure to GAT4621 protein was for poultry livestock based on a hypothetical total replacement scenario. The marg in of exposure for poultry to GAT4621 is greater than 50,000-fold the no observed adverse effect leve l of 1640 mg/ kg of body weight in mice. Based on these calculations, there is a wide ma rgin of safety for the GAT4621 protein.Pioneer Hi-Bred International, Inc. Page 42 of 167 73496 Canola



### VII. Agronomic Performance and Ecological Observations

Agronomic and ecological evaluations were conducted to assess the comparability of 73496 canola to conventional canola. These evaluations form the basis to determine whether 73496 canola is comparable to conventional canola and is therefore no more likely to pose a plant pest risk than conventional canola.

The agronomic evaluations were based on both labora tory experiments and replicated, multi-site field trials conducted by agronomists and scientists who are considered experts in the production and evaluation of canola. To evaluate the agronomic c haracteristics of 73496 canola, data were collected on representative characteristics that influence reproducti on, crop survival, and potential weediness. In each of these assessments, 73496 canola was compared to a near-isoline control that was >95% genetically similar to 73496 canola but did not carry any recombinant DNA, and, in some experiments, was compared to non-transgenic commercial canola lines se lected from current Pioneer conventional canola products. In each experiment, 73496 canola was comparab le to the control or commercial comparators.

The ecological evaluations included observed respon ses to insect and disease stressors during multiyear and multi-site field trials. These observat ions were made on 73496 canola and control canola and tracked the presence of insect and disease stressors in the field and the plant responses. In each case, 73496 canola responded similarly to the control plants in these trials.

Based on the analyses described below, 73496 canola is comparable to conventional canola and would not pose a greater plant pest risk or incr eased weed potential than conventional canola.

VII-A. Germination Evaluations

In order to test germination, seeds from the F1 *5 generation (Section III-A, Figure 2) of 73496 canola were tested for germination under warm, cold, and diurnal conditions (Table 8). A near-isoline control was used for comparison. In addition, two commercial ca nola lines were evaluated to establish a reference range for germination. This range provided a cont ext to determine the biological significance of any statistical differences observed.

Each germination test contained eight replicat es of 73496 canola, near-isoline control, and two commercial lines: one 60-seed replicate was count ed and weighed for each canola line, with seven additional replicates weighed out based on the we ight of the corresponding 60-seed replicate. The “Rules for Testing Seeds”, published by the Associ ation of Official Seed Analysis, were used as guidelines for the germination methods and interpreta tion of results (AOSA, 2007). Each replicate was placed between sheets of moist germination toweling, rolled up, and placed in a growth chamber set to the appropriate test conditions as specified below.

Table 8. Description of Seed Germination Conditions

Warm germination test  Continuous setting of 25°C and 90% relative humidity for 10 days

 Germinated seed counted after 10 days

Cold germination test  Continuous setting of 10°C and 90% relative humidity for 10 days, followed by three days at a continuous setting of 25°C and 90% relative humidity

 Germinated seed counted after 13 days

Diurnal germination test  Simulates daily weather conditions

 Cyclical setting of 10°C and 90% relative humidity for 16 hours and then 25°C and 90% relative humidity for 8 hours, repeated daily for 10 days

 Germinated seed counted after 10 daysPioneer Hi-Bred International, Inc. Page 43 of 167 73496 Canola

A statistically significant (P-value = 0.0460) diffe rence in mean germination rate was observed between 73496 canola and the control canola in the warm germi nation test, with a lower mean germination rate in 73496 canola compared to the control canola (Table 9). However, for 73496 canola and the control canola, the range of germination rate values was within the reference range of commercial canola values. In the cold germination test, no statistically significant differences in mean germination rate were observed between 73496 canola and the control canola (Table 9). In the diurnal germination test, no statistically significant differences in mean ger mination rate were observed between 73496 canola and the control canola (Table 9).

Table 9. Summary of Germination Results for 73496 Canola

Statistic 73496 Canola Control Canola Reference Range a
Warm n=525 n=469
Mean b 96.4% 98.7%

84% - 100% Range c 93% - 100% 96% - 100% SEM d 0.00891 0.00535 P-value 0.0460 e
Cold n=518 n=466
Mean 98.8% 98.4%

88% - 100% Range 93% - 100% 97% - 100% SEM 0.00613 0.00745 P-value 0.7127 Diurnal n=514 n=453

Mean 98.9% 99.8%

92% - 100% Range 95% - 100% 98% - 100% SEM 0.00527 0.00224 P-value 0.1635

a Reference range denotes the lowest and highest germination rates across reference canola lines
b Mean percentage

c Range denotes the lowest and highest germination rates d Standard error of the mean

e Statistically significant difference; P-value <0.05

Germination rates in 73496 canola under warm, cold and diurnal growing conditions were comparable to those of the control canola. A s lightly lower germination rate was observed for 73496 canola seed under warm growing conditions that was statistically signi ficant. However, this difference was small and the entire range of germination rate values for 7349 6 canola and the control canola under warm growing conditions were within the corresponding range of reference for commercial canola germination rates.

The data provided here support the conclusion that 7 3496 canola is comparable to conventional canola with respect to germination.

VII-B. Field Trial Evaluations

73496 canola has been field tested in the United States since 2007 as authoriz ed by USDA notification applications listed in Appendix 6. The list compiles a number of test sites in diverse regions of the U.S. including the major canola-growing areas. Agronomic data were collected to assess agronomic comparability as it relates to plant pest potential. In addition, extensive testing has also been conducted in Canada in major canola-growing areas, primarily because Pioneer’s canola breeding facilities are located in Canada and Canada is the primary market. A table of testing under authorized Canadian permits is also provided in Appendix 6.Pioneer Hi-Bred International, Inc. Page 44 of 167 73496 Canola

Throughout the development process, 73496 canol a was observed for unexpected differences in responses to abiotic stress ( e.g , drought, excess moisture, temperature extremes, etc .). Monthly observations for response to naturally occurring abi otic stressors indicated that 73496 canola and nearisoline control were similar with respect to their response to abiotic stress.

Agronomic data were collected from 73496 canola and control canola in two experiments (denoted A and B) that were conducted at 10 total field locations in 2008 and 2009 (Table 10; Figure 17). The trial locations were selected in order to provide data repres entative of the major canola growing regions in the U.S. and Canada, where commercial sales of 73496 ca nola are expected. Where sites were common between both experiments, the data from these sites were analyzed independently of each other. In addition, different characteristics were measured in each experiment because of the stage at which the data were collected. Experiment A was conduct ed earlier in the development of 73496 canola and was collected at Pioneer field sites, therefore the data were used as part of product advancement decisions. Experiment B was conducted at a later stage of developm ent and at contractor si tes, therefore the data were used to fully characterize the agronomic charac teristics of 73496 canola. Agronomic practices used to prepare and maintain each field site were characteristic of each respective region. The genetic backgrounds selected for these trials are adapted for cu ltivation both in northern U.S. and in Canada. In addition, insect pests and diseases at the Canada locati ons are typical of those found in the U.S. While the majority of the sites were from Canadian field trial sites, these Canadian locations are considered representative of suitable canola growing areas wi thin the U.S. Zone maps have been created by the U.S. EPA (EPA, 1996) and Canada Pest Management Regulatory A gency (PMRA, 1998) that divide North America into regions where climate conditions are similar (Figure 18, Panels A and B). These zone maps are used to determine where field trials s hould be placed when conducting studies for establishing tolerances ( e.g. maximum pesticide residue levels) associated with domestic pesticide registrations. Thus, field trials conducted within the same zone are considered interchangeable. The zones for each of the field trials conducted are provided in Table 10 and show that the zone designations for trials conducted in Canada are representative of U.S. zones.

A statistical analysis of agronomic data was conducted to test for differences in the mean values between the 73496 canola and the near-isoline control (Appendix 2 for statistical model). When numerous comparisons are being made, it is important to contro l the rate of false positive results. Since the introduction of the false discovery rate (FDR) ap proach in the mid-1990’s, it has been widely employed across a number of scientific disciplines, including genomics, ecology, medicine, plant breeding, epidemiology, dairy science and signal/image processing ( e.g ., Pawitan et al ., 2005; Spelman and Bovenhuis, 1998). A false positive result occurs wh en two means are deemed significantly different when, in fact, they are not. If one uses a 5% type I error rate for each agronomic characteristic measured, then the number of false po sitives increases as the number of characteristics increase. In order to help manage the false positive rate, the FDR method of Benjamini and Hochberg was applied to account for making multiple comparisons (Benjamini and Hochberg, 1995; Westfall et al ., 1999). P-values were adjusted accordingly. This resulted in the false positive rate being held to 5%. Both adjusted and unadjusted P-values are provided for the agronomic data

.Pioneer Hi-Bred International, Inc. Page 45 of 167 73496 Canola



### 1 2 3, 9, 10 4 5 6

7 8 

# Canada

United States

Figure 17. Map of Locations for Agronomic Data Collection for 73496 Canola

Table 10. Site Locations for 2008 and 2009 Field Trial Experiments

Map Site Number Country Location Zone
Experiment A: 2008 Field Trials 1

Canada Riviere Qui Barre, AB 14 2 Nisku, AB 14 3 Saskatoon, SK 7/14 4 Crystal City, MB 5/14 5 Rosebank, MB 5/14 6 Morden, MB 5/14 7 Georgetown, ON 5 Experiment B: 2009 Field Trials 8 U.S. Ephrata, WA 11 9 Canada Saskatoon, SK 7/14 10 Saskatoon, SK 7/14Pioneer Hi-Bred International, Inc. Page 46 of 167 73496 Canola

A. Canada PMRA Zones

B. U.S. EPA Zones

Figure 18. Maps Indicating Zones with Similar Growing Conditions for Field Trials

Panel A : Zones established by PMRA in Canada with similar climate conditions for residue field trials (PMRA, 1998). Panel B : Zones established by the U.S. EPA with similar climate conditions for residue field trials (EPA, 1996).Pioneer Hi-Bred International, Inc. Page 47 of 167 73496 Canola

Experiment A contains data from seven locations planted in Canada during the 2008 growing season (Table 10, Figure 17). The purpose of Experiment A was to evaluate the agronomic characteristics and yield of 73496 canola. Seed of the T3 generation of 73496 canola was used (Section III-A, Figure 2). The control plants were near-isoline control canola.

The following characteristics were measured: early growth, plant height, days to flower, days to maturity, and yield. Descriptions of the characterist ics and their measurement are found in Table 11.

Each site included a randomized complete block de sign containing three blocks, with each block containing one plot of 73496 canola and one plot of t he control canola. Proced ures employed to control the introduction of experimental bias in this study were as follows: non-systematic selection of trial areas and plot areas within each site, randomization of the canola entries within each block, and uniform maintenance treatments across each plot area.

Results of Experiment A are summarized in Table 12.

For characteristics early growth, plant height, days to maturity, and yield, no statistically significant differences were observed between the mean values of 73496 canola and the control. One statistical difference was observed between 73496 canola and the control in days to flower (adjusted P-value < 0.05). The mean flowering time was one day longe r for 73496 canola; however, the range of individual values for days to flower in 73496 canola was within the range of the control data. Furthermore, this statistical difference was not replicated in the trial co nducted in 2009. Because the time to flowering for 73496 canola is still within the normal range of canola flowering, this statistical difference is not biologically meaningful to the deter mination of plant pest potential.

The results from Experiment A indicate that 73496 ca nola is agronomically comparable to the near-isoline control.

Table 11. Experiment A: 2008 Field Trial Agronomic Characteristics Measured

General Characteristic Characteristic Measured Number of Sites Data Description Scale

Vegetative Parameter Early Growth 3 of 7 Overall plant health and amount of soil surface area covered by leaves at the 4-leaf to 6-leaf stages 1-9 Scale where 1=Unhealthy/weak looking plants with small leaf coverage; 9=healthy/strong-looking plants with large leaf coverage

Plant Height 7 of 7 10 plants per plot at physiological maturity. Height was measured from the soil surface to the tip of the highest pod. Centimeters

Reproductive

Parameter Days to Flower 7 of 7 Number of days from the planting date to the date when approximately 50% of plants had produced flowers. Days

Days to Maturity 6 of 7 Number of days from the planting date to the date when approximately 50% of plants had reached physiological maturity. Days

Yield 7 of 7 Weight (corrected for moisture content of seed) harvested from all plants in a given plot kg/haPioneer Hi-Bred International, Inc. Page 48 of 167 73496 Canola

Table 12. Experiment A: Summary of Agronomic Characteristics of 73496 Canola Across Seven Locations

Agronomic Characteristic a (unit of measurement) Control Canola 73496 Canola

Early Growth

(1-9 scale) n=9 Mean b 6.50 7.37 Range c 6 - 7 6 - 8 Standard Error 0.445 0.445 P-Value d 0.0395 Adjusted P-Value e 0.0790

Days to Flower (days) n=21 Mean 44.6 45.7 Range 40 - 50 42 - 49 Standard Error 1.09 1.09 P-Value 0.000218 Adjusted P-Value 0.00131 f

Days to Maturity (days) n=18 Mean 93.0 92.8 Range 87 - 106 89 - 105 Standard Error 2.35 2.35 P-Value 0.468 Adjusted P-Value 0.562

Plant Height (centimeters) n=21 Mean 89.5 91.6 Range 65 - 115 60 - 118 Standard Error 5.10 5.10 P-Value 0.355 Adjusted P-Value 0.532

Yield (kg/ha) n=21 Mean 2310 2140 Range 1020-3500 1140-2910 Standard Error 199 199 P-Value 0.0311 Adjusted P-Value 0.0790

a Refer to Table 11 for descriptions of each agronomic characteristic measured.
b Least squares mean

c Range denotes the lowest and highest individual value across sites.
d Non-adjusted P-value

e False Discovery Rate (FDR) adjusted P-value f Statistically significant diffe rence, adjusted P-value <0.05Pioneer Hi-Bred International, Inc. Page 49 of 167 73496 Canola

Experiment B contains data from three locations planted in the U.S. and Canada during the 2009 growing season (Table 10, Figure 17). The purpos e of Experiment B was to evaluate the agronomic characteristics and yield of 73496 canola. Seed from the T5 generation was used (Section III-A, Figure 2). The control plants were near-isoline control canola

The following agronomic characteristics were measur ed in each block: early population, seedling vigor, days for flowering, plant height, disease incidence, in sect damage, lodging, days to maturity, shattering, final population, and yield data. Descriptions of t he characteristics and their measurement are found in Table 13.

Each site included a randomized complete block design containing four blocks, with each block containing 73496 canola and control canola.

Results of Experiment B are summarized in Table 14.

No statistically significant differences were ob served between 73496 canola and control canola mean values for early population, final population, seedling vi gor, days to flowering, flowering duration, disease incidence, insect damage, lodging, days to maturity, shattering, yield, or plant height.

The results from Experiment B indicate that 73496 ca nola is agronomically comparable to the near-isoline control.

Table 13. Experiment B: 2009 Field Trial Agronomic Characteristics Measured

General Characteristic Characteristic Measured Evaluation timing a Data Description Scale

Germination /

Emergence Early Population BBCH 11-13 Number of plants emerged per plot (two 1 square meter quadrants) during true leaf (rosette) development Actual count per plot

Seedling Vigor BBCH 11-13 Visual estimate of average vigor of emerged plants per plot during true leaf (rosette) development From 1 to 9, where 1=short plants with small thin leaves, and 9=tall plants with large robust leaves

Vegetative Parameters Plant Height BBCH 79 Height from the soil surface to the tip of the highest pod when nearly all pods on the plants are at full size Height in cm

Lodging BBCH 87-89 Visual estimate of lodging severity when >70% of pods are fully ripe From 1 to 9, where 1=plants lying flat, and 9=plants standing straight

Shattering BBCH 87-89 Visual estimate of seed shattering when >70% of pods are fully ripe From 1 to 9, where 1=high seed shattering, and 9=no seed shattering

Final Population Harvest Total number of plants per plot Actual count per plot

a Based on Lancashire et al. (1991) for canola growth stages.Pioneer Hi-Bred International, Inc. Page 50 of 167 73496 Canola

Table 13. Experiment B: 2009 Field Trial Agronomic Characteristics Measured (continued)

General Characteristic Characteristic Measured Evaluation timing a Data Description Scale

Reproductive Parameters Days to flowering BBCH 57-62 From the time of planting to the first open flowers. Days

Flowering duration BBCH 69 Number of days from the date when the first flowers were open to the date when flowering ended on approximately 50% of the plants. Days

Days to Maturity BBCH 86-87 Number of days from planting to the date when between 60-70% of pods are ripe. Days

Yield At harvest Weight (corrected for moisture content of seed) harvested from all plants in a given plot kg/ha

Ecological Interactions Disease Incidence BBCH 71-79 Visual estimate of foliar disease incidence during plant pod elongation. Ranging from 1-9 where 1 = poor disease resistance or high infection; 9 = best disease resistance or low infection.

Insect Damage BBCH 71-79 Visual estimate of insect damage during plant pod elongation. Ranging from 1-9 where 1 = poor insect resistance or high damage; 9 = best insect resistance or low damage.

a Based on Lancashire et al. (1991) for canola growth stages.Pioneer Hi-Bred International, Inc. Page 51 of 167 73496 Canola

Table 14. Experiment B: Summary of Agronomic Characteristics of 73496 Canola Across Three Locations

Agronomic Characteristic a (unit of measurement) Control Canola 73496 Canola Early Population (number of plants)

73496 Canola n=11 Control Canola n=12 Mean b 108 116 Range c 50 - 184 41 - 207

CI d , e (24) - 239 (16) - 247 P-Value f 0.496 Adjusted P-Value g 0.661
Final Population (number of plants)

73496 Canola n=11 Control Canola n=12 Mean 87 82 Range 29 - 158 23 - 164

CI (9) - 183 (14) - 177 P-Value 0.691 Adjusted P-Value 0.691
Seedling Vigor

(1-9 scale)

73496 Canola n=11 Control Canola n=12 Mean 5 5 Range 3 - 8 3 - 8

CI 0 - 11 0 - 11 P-Value 0.422 Adjusted P-Value 0.632
Days to Flowering (number of days)

73496 Canola n=11 Control Canola n=12 Mean 47 47 Range 35 - 60 35 - 59

CI 17 - 76 18 - 77 P-Value 0.327 Adjusted P-Value 0.561
Flowering Duration (number of days)

73496 Canola n=11 Control Canola n=12 Mean 27 28 Range 22 - 37 22 - 38

CI 8 - 47 8 - 48 P-Value 0.116 Adjusted P-Value 0.279

Disease Incidence (1-9 scale)

73496 Canola n=11 Control Canola n=12 Mean 7 7 Range 6 - 9 6 - 8

CI 5 - 10 5 - 9 P-Value 0.0851 Adjusted P-Value 0.279
Insect Damage

(1-9 scale)

73496 Canola n=11 Control Canola n=12 Mean 6 7 Range 3 - 9 3 - 9

CI (1) - 14 (1) - 14 P-Value 0.165 Adjusted P-Value 0.329
Lodging (1-9 scale)

73496 Canola n=11 Control Canola n=12 Mean 8 8 Range 7 - 9 6 - 9

CI 6 - 10 6 - 10 P-Value 0.624 Adjusted P-Value 0.691

a Refer to Table 13 for descriptions of each agronomic characteristic measured.
b Least squares mean

c Range denotes the lowest and highest individual value across sites for 73496 canola and near-isoline control.
d Confidence interval

e Confidence intervals within parentheses indicate a negative value.
f Non-adjusted P-value
g False Discovery Rate (FDR) adjusted P-valuePioneer Hi-Bred International, Inc. Page 52 of 167 73496 Canola

Table 14. Experiment B: Summary of Agronomic Characteristics of 73496 Canola Across Three Locations (continued)

Agronomic Characteristic a (unit of measurement) Control Canola 73496 Canola Days to Maturity (numbers of days)

73496 Canola n=11 Control Canola n=12 Mean b 113 114 Range c 103 - 132 104 - 133

CI d ,e 73 - 152 74 - 153 P-Value f 0.102 Adjusted P-Value g 0.279 Shattering (1-9 scale)

73496 Canola n=11 Control Canola n=12 Mean 8 7 Range 5 - 9 4 – 9

CI 5 - 10 5 - 10 P-Value 0.646 Adjusted P-Value 0.691

Yield h (kg/ha at 8% moisture)

73496 Canola n=8 Control Canola n=8 Mean 3500 2900 Range 2600 - 4680 1550 - 4280

CI 1620 - 5380 1030 - 4780 P-Value 0.0395 Adjusted P-Value 0.279
Plant Height (centimeters)

73496 Canola n=110 Control Canola n=120 Mean 118 113 Range 100 - 143 94 - 134

CI 81 - 155 76 - 150 P-Value 0.0563 Adjusted P-Value 0.279

a Refer to Table 13 for descriptions of each agronomic characteristic measured.
b Least squares mean

c Range denotes the lowest and highest individual value across sites for 73496 canola and near-isoline control.
d Confidence interval

e Confidence intervals within parentheses indicate a negative value.
f Non-adjusted P-value
g False Discovery Rate (FDR) adjusted P-value
h Yield data from one of the three sites was not included due to an early killing frost that affected seed harvest at maturity.

VII-C. Ecological Observations

Ecological observations ( i.e. , plant interactions with pest insects and diseases) were recorded for all USDA-APHIS permitted field trials of 73496 canol a during the 2007, 2008, 2009, and 2010 growing seasons. In addition, trials were conducted in Canada in 2007, 2008, and 2009 and the ecological observations were recorded. Plant breeders and fiel d staff familiar with plant pathology and entomology observed 73496 canola and control lines at least ever y four weeks for pest insect and disease pressure and recorded the severity of any stressor seen. Any unexpected differences in response between 73496 canola and various control lines (near-isolines and/or conventional canola lines) were recorded.

The following scale was used when recording observations:

 mild – very little disease or insect injury (<10%) visible

 moderate – noticeable plant tissue damage (10% to 30%)

 severe – significant plant tissue damage (>30%)

A summary of the insect and disease ecological obs ervations for both U.S. and Canada field trials is provided in Appendix 5. In every case, the severity of insect or disease stress on 73496 canola was not qualitatively different from various control lines grow ing at the same location. These results support the conclusion that the ecological interactions for 73496 canola were comparable to control canola lines with similar genetics or to conventional canola lines.Pioneer Hi-Bred International, Inc. Page 53 of 167 73496 Canola

VII-D. Conclusions on Agronomic Performance and Ecological Observations

73496 canola was observed in laboratory experiments and at 10 field locations in the U.S. and Canada to measure agronomic parameters. Data generated from these studies represent observations that are typically recorded by plant breeders and agronomists to evaluate the characteristics of canola over a broad range of environmental conditions that re present where 73496 canola may be grown. The agronomic characteristics measured are represent ative of reproduction, survival, and potential weediness. The measured characteristics provide data useful in establishing a basis to assess agronomic comparability and familiarity of 73496 canola compared to conventional canola in the context of ecological risk assessment.

The agronomic data showed no statistical differences between 73496 canola and control canola (untransformed near-isoline controls and/or commercial canola lines) except for days to flower in Experiment A. The range of individual values for days to flower in 73496 canola was within the range of the control data and the statistical difference was not replicated in Experiment B. These data support the conclusion that 73496 canola is comparable in agronomic characteristics to conventional canola.

Ecological observations of U.S. and Canadian field tr ials for responses of 73496 canola to naturally occurring insect and disease stressors showed no u nexpected differences from control canola. The assessment of the ecological data detected no biolog ically significant differences between 73496 canola and control canola lines indicative of a selective adv antage that would result in increased weed potential or plant pest risk.

Based on these analyses, 73496 canola is compar able to conventional canola and would not pose a greater plant pest risk or increased weed potential than conventional canola.Pioneer Hi-Bred International, Inc. Page 54 of 167 73496 Canola



### VIII. Compositional Assessment

Compositional comparisons between transgenic crops and conventional varieties are a key part of a nutritional and safety assessment and provide assura nce of the food safety of transgenic crops. Compositional assessments are performed in acco rdance with the principles outlined in the OECD consensus document on compositional considerati ons for canola (OECD, 2001). This document emphasizes quantitative measur ements of essential nutrients, and kn own anti-nutrients and toxicants. These analyses will effectively highlight any compositi onal changes that may indicate potential safety and anti-nutritional concerns.

For 73496 canola, the following analytes were meas ured for the comparative assessment: proximates, fiber, fatty acids, amino acids, vitamins, minerals, glucosinolates, secondary metabolites, phytosterols, and anti-nutrients. Levels of the analytes were measured in the seed of the F1 *4 generation (Section III-A; Table 1, Figure 2) of 73496 canola and were comp ared to corresponding levels in the near-isoline control and were also compared to statistical tolerance in tervals generated from non-modified conventional commercial varieties. These comparisons formed the basis for determining compositional comparability of 73496 canola to conventional canola. Canola se ed was chosen as the test material for the compositional analysis of 73496 canola because oil fractions are derived fr om seed. Compositional evaluation of seed would be represent ative of these derived materials.

Seed samples were collected from five separate si tes in Canada and the United States during the 2009 growing season (three sites in Manitoba, Canada: Elm Creek, Minto, and Portage la Prairie; two sites in the United States: Velva, ND and Ephrata, WA). Ea ch site utilized a randomized complete block design with four blocks and each block containing 73496 ca nola and the control canola. Each plot of 73496 canola was treated with glyphosate at a rate of 0.367-0.414 pounds acid equivalent per acre (411-464 grams acid equivalent per hectare) consistent with typical agronomic practices, and each plot of the control canola was left untreated. Seed samples collected from 73496 canola and the control canola were analyzed for key nutritional components in accordance with the OECD consensus document on compositional considerations for new varieties of canola (OECD, 2001), which included analysis of proximates, fiber, fatty acids, amino acids, vitami ns, minerals, glucosinolates, secondary metabolites, phytosterols, and anti-nutrients.

In a separate experiment for the statistical tolera nce intervals, seed was also collected from five conventional ( i.e ., non-modified) commercial canola lines grown at five field locations in canola-growing areas of U.S. and Canada in 2008 and 2009. Plantin g, harvesting, processing, and compositional analysis procedures for the reference hybrid trials were similar to those employed for the trials containing near-isoline control and 73496 canola. Compositiona l analyses of the reference lines were used to determine the statistical tolerance intervals, whic h established the normal variation for the measured analytes in canola.

Statistical analysis of nutrient composition data was co nducted to test for differences in the analyte mean values between 73496 canola and the near-isoline contro l. For details of the statistical methodology, refer to Appendix 2. When numerous analytes ar e being evaluated on the same samples, controlling false positive outcomes is important. A false positive outcome occurs when an analyte mean of the transgenic line is deemed significantly different from t he analyte mean of the control line, when in fact the two means are not different. If one uses a 5% type I e rror rate for each analyte, then the number of false positives increases as the number of analytes increase . In order to help manage the false positive rate, the false discovery rate (FDR) method of Benjam ini and Hochberg was applied to account for making multiple comparisons (Benjamini and Hochberg, 1995; Westfall et al ., 1999). P-values were adjusted accordingly, resulting in the false positive rate being held to 5%. Both adjusted and non-adjusted P-values are provided in this su bmission. In the discussion of t hese data, a significant difference between the mean of 73496 canola and that of the near isoline was established with an FDR-adjusted Pvalue <0.05.

Using the data obtained from the commercial lines, a statistical tolerance interval was calculated to contain, with 95% confidence, 99% of the values c ontained in the population of commercial canola. AnyPioneer Hi-Bred International, Inc. Page 55 of 167 73496 Canola

negative limits were set to zero. This statistica l tolerance interval provided further context for interpretation of the composition results for 73496 canola.

VIII-A. Proximate and Fiber Analysis

Analysis of the major constituents of canola seed, or proximates, was used to determine the nutritional properties of seed from 73496 and control canola. No statistically significant differences were observed between 73496 canola and the control canola mean va lues for any of the proximate and fiber analytes (Table 15).

In conclusion, proximate and fiber analysis of cano la seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 56 of 167 73496 Canola

Table 15. Summary Analysis of Proximate and Fiber Results in Canola Seed

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance Interval a

% Dry Weight

Crude Protein Mean b 26.6 25.9

11.3 - 54.4 Range c 23.4 - 31.9 22.4 - 31.6

CI d 23.4 - 30.3 22.8 - 29.5
P-Value e 0.0275 Adjusted P-Value f 0.0974

Crude Fat Mean 43.6 43.9

30.6 - 65.8 Range 37.4 - 51.5 37.0 - 49.6

CI 40.1 - 47.3 40.3 - 47.7
P-Value 0.608 Adjusted P-Value 0.737

ADF g Mean 32.4 32.3

14.5 - 63.4 Range 27.1 - 38.6 26.6 - 39.5

CI 28.8 - 36.5 28.7 - 36.4
P-Value 0.929 Adjusted P-Value 0.957

Crude Fiber Mean 28.4 28.5

12.9 - 55.5 Range 24.3 - 35.1 22.8 - 35.5

CI 25.1 - 32.1 25.2 - 32.2
P-Value 0.889 Adjusted P-Value 0.935

NDF h Mean 33.4 33.3

15.5 - 67.7 Range 28.8 - 40.3 28.0 - 38.9

CI 30.4 - 36.8 30.2 - 36.7
P-Value 0.844 Adjusted P-Value 0.911

Ash Mean 4.08 3.92

2.01 - 7.63 Range 2.98 - 5.10 3.00 - 5.06

CI 3.29 - 5.07 3.16 - 4.87
P-Value 0.0549 Adjusted P-Value 0.141

Carbohydrates Mean 25.3 26.0

19.6 - 33.5 Range 16.9 - 29.1 23.7 - 28.8

CI 24.0 - 26.7 24.6 - 27.4 P-Value 0.320 Adjusted P-Value 0.468

a The statistical tolerance interval was calculated from comm ercial canola varieties and calculated to contain with 95

percent confidence, 99 percent of the population of canola, negative limits set to zero b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Acid Detergent Fiber
h Neutral Detergent FiberPioneer Hi-Bred International, Inc. Page 57 of 167 73496 Canola

VIII-B. Fatty Acid Analysis

Five fatty acids account for more than 96 percent of the total fatty acids in canola seed, with the most abundant being oleic (C18:1 Δ 9; ~ 60%) and linoleic (C18:2 Δ 9,12; ~ 20%) acids. Less abundant, but occurring at measurable concentrations ar e palmitic (C16:0), stearic (C18:0) and α -linolenic (C18:3 Δ 9,12,15) acids. The desaturation of oleic acid to form linoleic acid, and its subsequent desaturation to form α -linolenic acid, occurs only in plants, hence both linoleic and α -linolenic acids are essential fatty acids for mammals. For this reason, it was important to analyze any unintended changes in the concentrations of linoleic and α -linolenic acids, and their key precursors palmitic, stearic, and oleic acids, in seed from 73496 canola.

Other polyunsaturated fatty acids, such as γ -linolenic (C18:3 Δ 6,9,12), eicosatrienoic (C20:3 Δ 8,11,14) and arachidonic (C20:4 Δ 5,8,11,14) acids can all be synthesized by mammals from dietary sources of

α -linolenic and linoleic acid. Hence, small changes in the concentrations of these trace fatty acids in 73496 canola seed would have little or no biological significance to either humans or animals consuming derived products. Similarly, the synthesis of palmitoleic (C16:1 Δ 9) and saturated fatty acids with chain lengths greater than 18 ( e.g ., C20:0, C22:0, C24:0), can be accomplished in mammals through de novo fatty acid synthesis without dietary requirement s for palmitic and stearic acids, respectively.

The fatty acids reported in Table 16 were identif ied by OECD as those that should be measured for compositional comparisons in canola (OECD, 2001). Based on consultation with the Codex Alimentarius Commission definition of canola oil (CODEX, 2005), si x additional fatty acids were reported in this analysis. Non-detectable fatty acids are defined as <0.05% of total fatty acids (CODEX, 2005). Heptadecanoic acid (C17:0), γ -linolenic acid (C18:3), and erucic acid (C22:1) were below this threshold and were not included in Table 16. As expected per the canola definition, erucic acid (C22:1) was not detected in the analysis.

Small but statistically significant differences were observed using the adjusted P-value in concentrations of oleic and linoleic acid between 73496 and contro l canola (Table 16). However, these fatty acid concentrations were within the respective tolerance intervals derived for commercial canola varieties. Therefore, the small, statistically significant differences observed for certain fatty acids are unlikely to be biologically meaningful.

In conclusion, fatty acid analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 58 of 167 73496 Canola

Table 16. Summary Analysis of Fatty Acid Composition in Canola Seed

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance

Interval a

% Total Fatty Acids

Lauric Acid (C12:0) Mean b 0.0816 0.0811

0 - 0.216 Range c 0.0568 - 0.105 0.0563 - 0.113

CI d 0.0639 - 0.104 0.0634 - 0.104
P-Value e 0.863 Adjusted P-Value f 0.919

Myristic Acid (C14:0) Mean 0.053 0.0546

0.0239 - 0.112 Range 0.0470 - 0.0749 0.0484 - 0.0670

CI 0.0466 - 0.0603 0.0480 - 0.0621
P-Value 0.212 Adjusted P-Value 0.355

Palmitic Acid (C16:0) Mean 4.08 4.19

3.10 - 5.60 Range 3.72 - 4.40 3.85 - 4.45

CI 3.87 - 4.31 3.97 - 4.42
P-Value 0.0111 Adjusted P-Value 0.0605

Palmitoleic Acid (C16:1) Mean 0.262 0.272

0.154 - 0.378 Range 0.225 - 0.306 0.224 - 0.317

CI 0.232 - 0.295 0.241 - 0.307 P-Value 0.0173 Adjusted P-Value 0.079

Heptadecenoic Acid (C17:1) Mean 0.108 0.105

0 - 0.264 Range 0.0675 - 0.140 0.0666 - 0.137

CI 0.0802 - 0.146 0.0776 - 0.141
P-Value 0.058 Adjusted P-Value 0.144

Stearic Acid (C18:0) Mean 1.71 1.61

1.17 - 3.47 Range 1.47 - 1.89 1.44 - 1.93

CI 1.57 - 1.86 1.48 - 1.76
P-Value 0.00577 Adjusted P-Value 0.0507

Oleic Acid (C18:1) Mean 61.6 60.1

53.1 - 74.4 Range 58.6 - 64.1 56.8 - 63.3

CI 58.9 - 64.4 57.5 - 62.9
P-Value <0.0001 Adjusted P-Value 0.00216 g

Linoleic Acid (C18:2) Mean 20.1 21.3

13.1 - 27.1 Range 18.5 - 22.5 19.5 - 23.4

CI 18.5 - 21.8 19.5 - 23.1
P-Value 0.000107 Adjusted P-Value 0.00220 g

(9,15) Isomer of Linoleic Acid (C18:2) Mean 0.0986 0.0924

0 - 0.524 h Range 0.0626 - 1.45 0.0611 - 0.496

CI 0.0697 - 0.139 0.0653 - 0.131
P-Value 0.764 Adjusted P-Value 0.868Pioneer Hi-Bred International, Inc. Page 59 of 167 73496 Canola

Table 16. Summary Analysis of Fatty Acid Comp osition in Canola Seed (continued)

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance

Interval
% Total Fatty Acids

Linolenic Acid (C18:3) Mean 8.92 9.29

4.23 - 16.8 Range 7.46 - 10.0 8.08 - 10.5

CI 8.04 - 9.89 8.38 - 10.3
P-Value 0.00884 Adjusted P-Value 0.0525

Arachidic Acid (C20:0) Mean 0.615 0.586

0.496 - 1.01 Range 0.585 - 0.645 0.552 - 0.640

CI 0.598 - 0.632 0.570 - 0.602
P-Value 0.00618 Adjusted P-Value 0.0507

Eicosenoic Acid (C20:1) Mean 1.38 1.36

0.999 - 1.88 Range 1.19 - 1.54 1.24 - 1.45

CI 1.27 - 1.51 1.25 - 1.48
P-Value 0.128 Adjusted P-Value 0.269

Eicosadienoic Acid (C20:2) Mean 0.069 0.0713

0.0308 - 0.107 Range 0.0565 - 0.0805 0.0563 - 0.0831

CI 0.0583 - 0.0817 0.0602 - 0.0844
P-Value 0.0256 Adjusted P-Value 0.0974

Behenic Acid (C22:0) Mean 0.328 0.319

0.241 - 0.465 Range 0.290 - 0.365 0.286 - 0.359

CI 0.300 - 0.358 0.292 - 0.348
P-Value 0.0182 Adjusted P-Value 0.079

Lignoceric Acid (C24:0) Mean 0.178 0.17

0.0601 - 0.657 Range 0.160 - 0.208 0.151 - 0.206

CI 0.160 - 0.198 0.153 - 0.189
P-Value 0.0183 Adjusted P-Value 0.079

Nervonic Acid (C24:1) Mean 0.191 0.194

0.0295 - 0.542 Range 0.121 - 0.257 0.120 - 0.254

CI 0.141 - 0.259 0.143 - 0.263 P-Value 0.303 Adjusted P-Value 0.458

a The statistical tolerance interval was calculated from comm ercial canola varieties and calculated to contain with 95

percent confidence, 99 percent of the population of canola, negative limits set to zero b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Statistically significant differe nce; FDR Adjusted P-Value <0.05
h Tolerance interval could not be calculated (NC) due to all sample values below the assay LLOQ.Pioneer Hi-Bred International, Inc. Page 60 of 167 73496 Canola

VIII-C. Amino Acid Analysis

Canola seed is generally a good source of essential and non-essential amino acids for most domestic animal species. Total levels of 18 amino acids and 26 free amino acids were measured in 73496 and control seed.

Results are shown in Table 17 for the 18 total amino acids. No statistically significant differences between the 73496 canola and control were noted for any amino acids measured (adjusted P-value).

The levels of 26 free amino acids were also measured (Pioneer data not shown). For each analyte, the measured values for 73496 canola were within stat istical tolerance intervals defined by commercial conventional varieties even when a statistically significant difference was observed between 73496 canola and control.

In conclusion, total and free amino acid analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 61 of 167 73496 Canola

Table 17. Summary Analysis of Amino Acid Composition in Canola Seed

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance Interval a

% Dry Weight

Alanine Mean b 1.14 1.12

0.588 - 1.90 Range c 1.01 - 1.37 0.970 - 1.32

CI d 1.02 - 1.28 0.996 - 1.25
P-Value e 0.0446 Adjusted P-Value f 0.133

Arginine Mean 1.62 1.57

0.741 - 3.07 Range 1.30 - 1.98 1.32 - 1.92

CI 1.42 - 1.85 1.37 - 1.79
P-Value 0.0502 Adjusted P-Value 0.133

Aspartic Acid Mean 2.00 2.06

0.980 - 3.52 Range 1.26 - 2.54 1.77 - 2.50

CI 1.71 - 2.33 1.77 - 2.40
P-Value 0.152 Adjusted P-Value 0.312

Cystine Mean 0.606 0.618

0.311 - 1.24 Range 0.505 - 0.751 0.523 - 0.722

CI 0.516 - 0.712 0.526 - 0.726
P-Value 0.592 Adjusted P-Value 0.737

Glycine Mean 1.38 1.35

0.688 - 2.52 Range 1.09 - 1.61 1.17 - 1.54

CI 1.25 - 1.52 1.22 - 1.49
P-Value 0.162 Adjusted P-Value 0.317

Glutamic Acid Mean 5.05 5.01

1.99 - 11.9 Range 2.48 - 6.68 4.30 - 6.40

CI 4.23 - 6.02 4.20 - 5.97
P-Value 0.783 Adjusted P-Value 0.868

Histidine Mean 0.800 0.801

0.342 - 1.72 Range 0.644 - 0.966 0.667 - 0.939

CI 0.712 - 0.899 0.713 - 0.900
P-Value 0.945 Adjusted P-Value 0.957

Isoleucine Mean 1.08 1.06

0.533 - 1.95 Range 0.869 - 1.30 0.922 - 1.25

CI 0.958 - 1.22 0.935 - 1.19
P-Value 0.113 Adjusted P-Value 0.250

Leucine Mean 1.88 1.83

0.910 - 3.42 Range 1.52 - 2.26 1.59 - 2.19

CI 1.66 - 2.12 1.62 - 2.07 P-Value 0.0498 Adjusted P-Value 0.133Pioneer Hi-Bred International, Inc. Page 62 of 167 73496 Canola

Table 17. Summary Analysis of Amino Acid Composition in Canola Seed (continued)

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance Interval

% Dry Weight

Lysine Mean 1.65 1.64

0.729 - 3.16 Range 1.25 - 2.02 1.48 - 1.97

CI 1.45 - 1.87 1.45 - 1.86
P-Value 0.669 Adjusted P-Value 0.793

Methionine Mean 0.464 0.472

0.258 - 0.857 Range 0.383 - 0.546 0.402 - 0.546

CI 0.408 - 0.529 0.415 - 0.538
P-Value 0.596 Adjusted P-Value 0.737

Phenylalanine Mean 1.12 1.10

0.545 - 2.12 Range 0.901 - 1.35 0.927 - 1.28

CI 1.01 - 1.26 0.985 - 1.23
P-Value 0.167 Adjusted P-Value 0.319

Proline Mean 1.63 1.59

0.717 - 3.36 Range 1.46 - 1.98 1.38 - 1.95

CI 1.43 - 1.87 1.39 - 1.83
P-Value 0.123 Adjusted P-Value 0.265

Serine Mean 1.12 1.12

0.576 - 2.08 Range 0.719 - 1.34 0.985 - 1.31

CI 1.01 - 1.25 1.00 - 1.25
P-Value 0.971 Adjusted P-Value 0.971

Threonine Mean 1.11 1.11

0.619 - 1.95 Range 0.847 - 1.29 0.997 - 1.26

CI 1.02 - 1.22 1.01 - 1.21
P-Value 0.687 Adjusted P-Value 0.793

Tryptophan Mean 0.325 0.312

0.153 - 0.537 Range 0.242 - 0.429 0.236 - 0.427

CI 0.256 - 0.382 0.239 - 0.371
P-Value 0.212 Adjusted P-Value 0.355

Tyrosine Mean 0.635 0.620

0.337 - 1.20 Range 0.552 - 0.757 0.508 - 0.737

CI 0.573 - 0.704 0.560 - 0.688
P-Value 0.205 Adjusted P-Value 0.355

Valine Mean 1.39 1.36

0.682 - 2.49 Range 1.04 - 1.66 1.20 - 1.59

CI 1.23 - 1.57 1.20 - 1.54
P-Value 0.159 Adjusted P-Value 0.317

a The statistical tolerance interval was calculated from co mmercial canola varieties and calculated to contain with 95 percent

confidence, 99 percent of the population of canola, negative limits set to zero
b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites
d Confidence Interval

e Non-adjusted P-value
f False Discovery Rate (FDR) adjusted P-valuePioneer Hi-Bred International, Inc. Page 63 of 167 73496 Canola

VIII-D. Vitamin Analysis

Although not specifically mentioned in the OECD consensus document, a standard B vitamin analysis was conducted. No statistically significant diffe rences were observed between 73496 and the control canola mean values for vitamin B1 (thiamine), vita min B2 (riboflavin), vitamin B3 (niacin), vitamin B5 (pantothenic acid), vitamin B6 (pyridoxine), and vitamin B9 (folic acid; Table 18). These results indicate 73496 canola is comparable to conventional canola with respect to key vitamins.

Tocopherols are listed in the OECD consensus docum ent as additional important components of canola oil as natural antioxidants (OECD, 2001). Concentrations of δ -tocopherol and total tocopherols were statistically significantly different between 7349 6 canola and control canola seed samples using the adjusted P-value (Table 18). However, the differences were small in magnitude and, in every case, the range of values was within the respective tole rance interval determined using commercial canola varieties. The small, statistically significant differ ences observed for certain tocopherols are unlikely to be biologically meaningful



### .
In conclusion, vitamin analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 64 of 167 73496 Canola

Table 18. Summary Analysis of Vitamin Composition in Canola Seed

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance Interval a

mg/kg Dry Weight

Vitamin B1 (Thiamine) Mean b 14.2 14.8

4.92 - 33.1 Range c 9.65 - 21.1 10.6 - 25.8

CI d 11.8 - 17.2 12.2 - 17.8
P-Value e 0.611Adjusted PValue f 0.737

Vitamin B2 (Riboflavin) Mean 2.70 3.14

1.45 - 7.33 Range 2.04 - 3.98 2.27 - 5.88

CI 2.29 - 3.19 2.66 - 3.71
P-Value 0.00531 Adjusted P-Value 0.0507

Vitamin B3

(Niacin) Mean 188 180

61.0 - 444 Range 156 - 245 154 - 208

CI 179 - 197 171 - 189
P-Value 0.188 Adjusted P-Value 0.338

Vitamin B5 (Pantothenic Acid) Mean 4.74 4.56

3.52 - 9.88 Range 4.08 - 5.77 3.94 - 5.05

CI 4.31 - 5.21 4.15 - 5.01
P-Value 0.0273 Adjusted P-Value 0.0974

Vitamin B6 (Pyridoxine) Mean 3.69 3.39

1.17 - 20.9 Range 2.58 - 6.01 2.54 - 5.25

CI 2.94 - 4.64 2.70 - 4.26
P-Value 0.0670 Adjusted P-Value 0.162

Vitamin B9 (Folic Acid) Mean 2.89 2.63

0.769 - 5.27 Range 1.57 - 7.88 1.12 - 5.68

CI 2.05 - 4.06 1.87 - 3.69
P-Value 0.307 Adjusted P-Value 0.458

α -Tocopherol Mean 109 114

54.7 - 189 Range 96.5 - 130 101 - 129

CI 98.8 - 120 103 - 125
P-Value 0.0179 Adjusted P-Value 0.0790

β -Tocopherol Mean <1.25 g <1.25 g

0 - 1.67 i Range <1.25 g <1.25 g

CI NA h NA
P-Value NA Adjusted P-Value NA

δ -Tocopherol Mean 3.23 3.65

1.93 - 11.9 Range 2.80 - 4.04 3.25 - 3.99

CI 3.11 - 3.35 3.51 - 3.78 P-Value <0.0001 Adjusted P-Value 0.00216 jPioneer Hi-Bred International, Inc. Page 65 of 167 73496 Canola

Table 18. Summary Analysis of Vitamin Composition in Canola Seed (continued)

Analyte Control Canola

n=20 73496 Canola

n=20 Tolerance Interval

mg/kg Dry Weight

γ -Tocopherol Mean 170 177

106 - 378 Range 143 - 196 146 - 205

CI 155 - 187 161 - 195
P-Value 0.00770 Adjusted P-Value 0.0525

Total Tocopherols Mean 283 295

191 - 499 Range 243 - 313 250 - 332

CI 262 - 305 273 - 318 P-Value 0.00397 Adjusted P-Value 0.0465 j

a The statistical tolerance interval was calculated from co mmercial canola varieties and calculated to contain with 95

percent confidence, 99 percent of the population of canola, negative limits set to zero b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Analyte values were below the assay LLOQ. Sample re sults below the LLOQ were as signed a value equal to the

LLOQ.
h Statistical analysis was not available (NA).
i Tolerance interval was not ava ilable due to insufficient sample values being detected abov e the assay LLOQ. Minimum and maximum values are used in place of a tolerance interval. j Statistically significant differenc e, FDR adjusted P-Value <0.05.

VIII-E. Mineral Analysis

Several mineral ions are recognized as essential plant nutrients and are required by the plant in significant quantities. These ma cronutrients include calcium, phos phorus, magnesium, potassium and sodium. The micronutrient minerals, iron, copper, ma nganese and zinc are incorporated in plant tissues in only trace amounts. Both macro- and micro-nutrie nt minerals were analyzed in seed samples from 73496 canola and compared with corresponding values fr om samples of near-isoline control canola seed.

A statistically significant difference was observed in magnesium concentration between 73496 and control canola using the adjusted P-value (Table 19). The magnitude of the difference was small and the range of individual values was within the tolerance interval determined for seed magnesium concentrations using commercial canola varieties.

In conclusion, mineral analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 66 of 167 73496 Canola

Table 19. Summary Analysis of Mineral Composition in Canola Seed

Analyte Control Canola n=20 73496 Canola n=20 Tolerance Interval a % Dry Weight

Calcium Mean b 0.465 0.474

0.172 - 0.939 Range c 0.365 - 0.576 0.397 - 0.572

CI d 0.406 - 0.532 0.414 - 0.542
P-Value e 0.457 Adjusted P-Value f 0.625

Phosphorus Mean 0.788 0.756

0.299 - 1.58 Range 0.543 - 1.13 0.567 - 1.14

CI 0.608 - 1.02 0.583 - 0.980
P-Value 0.0285 Adjusted P-Value 0.0974

Magnesium Mean 0.357 0.325

0.219 - 0.538 Range 0.308 - 0.410 0.277 - 0.385

CI 0.327 - 0.390 0.298 - 0.356
P-Value <0.0001 Adjusted P-Value 0.00216 g

Manganese Mean 0.00381 0.00351

0.00174 - 0.00769 Range 0.00275 - 0.00463 0.00278 - 0.00418

CI 0.00318 - 0.00458 0.00292 - 0.00422
P-Value 0.0334 Adjusted P-Value 0.110

Copper Mean 0.000175 0.000185

0 - 0.000772 Range <0.000125 h - 0.000251 <0.000125 h - 0.000276

CI 0.000129 - 0.000236 0.000137 - 0.000250
P-Value 0.0972 Adjusted P-Value 0.221

Iron Mean 0.00677 0.00634

0.00163 - 0.0259 Range 0.00452 - 0.0200 0.00412 - 0.0116

CI 0.00427 - 0.0107 0.00400 - 0.0100
P-Value 0.288 Adjusted P-Value 0.454

Potassium Mean 0.649 0.659

0.284 - 1.79 Range 0.489 - 0.866 0.487 - 0.898

CI 0.525 - 0.803 0.533 - 0.816
P-Value 0.401 Adjusted P-Value 0.567

Sodium Mean 0.00168 0.00179

0.0000886 - 0.0270 Range 0.000568 - 0.00599 0.000849 - 0.00505

CI 0.000790 - 0.00358 0.000840 - 0.00381
P-Value 0.507 Adjusted P-Value 0.671

Zinc Mean 0.00398 0.00384

0.00163 - 0.0101 Range 0.00277 - 0.00548 0.00233 - 0.00594

CI 0.00317 - 0.00498 0.00306 - 0.00481
P-Value 0.288 Adjusted P-Value 0.454

a The statistical tolerance interval was calculated from co mmercial canola varieties and calcul ated to contain with 95 percent

confidence, 99 percent of the population of canola, negative limits set to zero
b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites
d Confidence Interval

e Non-adjusted P-value
f False Discovery Rate (FDR) adjusted P-value

g Statistically significant diffe rence, FDR adjusted P-Value <0.05.
h Analyte values were below the assay LLOQ. Sample results below the LLOQ were assigned a value equal to the LLOQ.Pioneer Hi-Bred International, Inc. Page 67 of 167 73496 Canola

VIII-F. Glucosinolate Analysis

Glucosinolates are considered key toxicants of canola (OECD, 2001). The major glucosinolates in canola are 3-butenyl glucosinolate (gluconapin), 4-penteny l glucosinolate (glucobrassicanapin), 2- hydroxy-3- butenyl glucosinolate (progoitrin) and 2-hydro xy-4-pentenyl glucosinolate (napoleiferin).

Glucosinolates themselves are generally considered to be innocuous; however the hydrolysis products have negative effects on animal production. The low palatability and t he adverse effects of glucosinolates due to their antithyroid activity led to the developm ent of varieties of rapeseed which have combined low concentrations of both glucosinolates and erucic ac id (also known as “double low” varieties). The total glucosinolate concentration for 73496 canola was 5.66 μ moles/g dry weight, which is within the acceptable definition for canola (maximum 30 μ moles/g dry weight; OECD, 2001).

A statistically significant difference was observed in progoitrin concentration between 73496 canola and control canola samples based on the adjusted P-value. The range of concentrations of progoitrin in 73496 canola was within the tolerance intervals establis hed using commercial canola varieties (Table 20).

In conclusion, glucosinolate analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 68 of 167 73496 Canola

Table 20. Summary Analysis of Glucosinolate Composition in Canola Seed

Analyte Control Canola n=20 73496 Canola n=20 Tolerance Interval a

μ mol/g Dry Weight

Glucoiberin Mean b <0.176 g <0.176 g

NC i Range c <0.176 g <0.176 g

CI d NA h NA
P-Value e NAAdjusted PValue f NA

Progoitrin Mean 0.524 0.412

0.130 - 11.6 Range 0.224 - 1.29 0.181 - 1.37

CI 0.233 - 1.18 0.183 - 0.928
P-Value 0.00174 Adjusted P-Value 0.0238 j

Epi-Progoitrin Mean 0.0717 <0.0708 g

0 - 0.159 k Range <0.0708 g - 0.0883 <0.0708 g

CI NA NA
P-Value NA Adjusted P-Value NA

Glucoraphanin Mean 0.0847 0.0789

0 - 0.565 Range <0.0488 g - 0.217 <0.0488 g - 0.143

CI 0.0655 - 0.110 0.0610 - 0.102
P-Value 0.401 Adjusted P-Value 0.567

Gluconapoleiferin Mean 0.0339 0.0330

0 - 0.372 Range <0.0299 g - 0.0618 <0.0299 g - 0.0544

CI 0.0280 - 0.0411 0.0272 - 0.0400
P-Value 0.272 Adjusted P-Value 0.446

Gluconapin Mean 0.759 0.773

0.197 - 10.0 Range 0.286 - 2.01 0.304 - 2.66

CI 0.328 - 1.75 0.335 - 1.79
P-Value 0.777 Adjusted P-Value 0.868

Glucoalyssin Mean 0.0753 0.0897

0 - 0.663 Range <0.0676 g - 0.125 <0.0676 g - 0.223

CI 0.0508 - 0.111 0.0606 - 0.133
P-Value 0.0496 Adjusted P-Value 0.133

4-Hydroxyglucobrassicin Mean 3.36 3.41

1.28 - 11.3 Range 1.53 - 6.06 1.78 - 8.33

CI 2.40 - 4.71 2.44 - 4.76
P-Value 0.836 Adjusted P-Value 0.911

Glucobrassicin Mean 0.404 0.383

0.0376 - 5.25 Range 0.215 - 0.787 0.206 - 1.14

CI 0.271 - 0.600 0.257 - 0.569
P-Value 0.189 Adjusted P-Value 0.338Pioneer Hi-Bred International, Inc. Page 69 of 167 73496 Canola

Table 20. Summary Analysis of Glucosinolat e Composition in Canola Seed (continued)

Analyte Control Canola n=20 73496 Canola n=20 Tolerance Interval

μ mol/g Dry Weight

Glucobrassicinapin Mean 0.401 0.395

0 - 1.80 Range <0.390 g - 0.475 <0.390 g - 0.441

CI NA NA
P-Value NA Adjusted P-Value NA

Gluconasturtiin Mean 0.255 0.286

0 - 5.39 Range 0.133 - 0.991 0.139 - 0.610

CI 0.166 - 0.391 0.186 - 0.439
P-Value 0.302 Adjusted P-Value 0.458

4-Methoxyglucobrassicin Mean <0.0774 g <0.0774 g

NC Range <0.0774 g <0.0774 g

CI NA NA
P-Value NA Adjusted P-Value NA

Neoglucobrassicin Mean 0.0466 0.0641

0 - 0.192 Range <0.0198 g - 0.0903 0.0230 - 0.162

CI 0.0266 - 0.0815 0.0366 - 0.112
P-Value 0.00897 Adjusted P-Value 0.0525

Total Glucosinolates Mean 5.77 5.66

2.17 - 30.0 Range 2.61 - 10.5 2.77 - 13.5

CI 3.72 - 8.94 3.65 - 8.77 P-Value 0.686 Adjusted P-Value 0.793

a The statistical tolerance interval was calculated from co mmercial canola varieties and calculated to contain with 95 percent confidence, 99 percent of the population of canola, negative limits set to zero
b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Theoretical LLOQ values were calculated by mathemat ically proportioning a known or measured canola seed

glucosinolate concentration per measured signal-to-noise (S :N) ratio to a theoretical glucosinolate concentration per S:N of 10. Sample results below the theoretical LLOQ were designated < [LLOQ].
h Statistical analysis was not available (NA).
i Tolerance interval could not be calculated (NC) due to all sample values below the assay LLOQ. j Statistically significant differenc e, FDR adjusted P-Value <0.05.
k Tolerance interval was not available due to insufficient samp le values being detecte d above the assay LLOQ.

Minimum and maximum values are used in place of a tolerance interval.Pioneer Hi-Bred International, Inc. Page 70 of 167 73496 Canola

VIII-G. Secondary Metabolite and Anti-Nutrient Analysis

Tannins, sinapine, and phytic acid are considered to be anti-nutrients in canola meal (OECD, 2001). A major phenolic compound in canola, sinapine imparts a bitter taste to canola meal (OECD, 2001). Phytic acid is the major form of phosphorus in plants; howeve r, it is unavailable as a nutrient source for animals (OECD, 2001).

Phytosterols are cholesterol-like molecules found in all plant foods, with the highest concentrations occurring in vegetable oils. They are absorbed only in trace amounts but have the beneficial effect of inhibiting the absorption of dietary cholesterol (Ostlund, 2002). Phytosterols are not endogenously synthesized in the body but are derived solely from the diet (Rao and Koratkar, 1997).

The only statistically significant difference found between 73496 compared with control canola was for cholesterol based on the adjusted P-value. However, the range of values for cholesterol was within the established tolerance interval and is unlikely to be biologically meaningful (Table 21).
In conclusion, secondary metabolite and anti-nutrient analysis of canola seed demonstrates that 73496 canola is comparable to conventional canola.Pioneer Hi-Bred International, Inc. Page 71 of 167 73496 Canola

Table 21. Summary Analysis of Secondary Meta bolite and Anti-Nutrient Composition in Canola Seed

Analyte Control Canola n=20 73496 Canola n=20 Tolerance Interval a % Dry Weight

Tannins-Soluble Mean b 0.113 0.109

0.0521 - 0.297 Range c 0.0768 - 0.180 0.0777 - 0.176

CI d 0.0840 - 0.152 0.0812 - 0.147
P-Value e 0.415 Adjusted P-Value f 0.577

Tannins-Insoluble Mean 0.330 0.237

0.0731 - 2.32 Range 0.155 - 0.824 0.142 - 0.492

CI 0.218 - 0.499 0.157 - 0.359
P-Value 0.00874 Adjusted P-Value 0.0525

Phytic Acid Mean 1.84 1.73

0.684 - 6.06 Range 1.04 - 2.86 1.01 - 3.00

CI 1.27 - 2.68 1.19 - 2.52
P-Value 0.0401 Adjusted P-Value 0.126

Sinapine Mean 0.928 0.937

0.538 - 1.33 Range 0.763 - 1.12 0.804 - 1.09

CI 0.852 - 1.01 0.861 - 1.02
P-Value 0.558 Adjusted P-Value 0.727

Cholesterol Mean 0.000866 0.00110

0 - 0.00238 Range 0.000685 - 0.00121 0.000850 - 0.00135

CI 0.000801 - 0.000938 0.00101 - 0.00119
P-Value 0.000281 Adjusted P-Value 0.00461 g

Brassicasterol Mean 0.0147 0.0160

0.00830 - 0.108 Range 0.0106 - 0.0190 0.0124 - 0.0200

CI 0.0129 - 0.0168 0.0141 - 0.0183
P-Value 0.0230 Adjusted P-Value 0.0945

Campesterol Mean 0.0921 0.0990

0.0249 - 0.257 Range 0.0738 - 0.111 0.0707 - 0.125

CI 0.0775 - 0.109 0.0833 - 0.118
P-Value 0.0492 Adjusted P-Value 0.133

Stigmasterol Mean 0.00269 0.00268

0.000832 - 0.0113 Range 0.00234 - 0.00316 0.00228 - 0.00335

CI 0.00248 - 0.00292 0.00247 - 0.00291
P-Value 0.942 Adjusted P-Value 0.957

β -Sitosterol Mean 0.132 0.137

0.0428 - 0.387 Range 0.0967 - 0.158 0.103 - 0.174

CI 0.115 - 0.151 0.120 - 0.157 P-Value 0.176 Adjusted P-Value 0.328Pioneer Hi-Bred International, Inc. Page 72 of 167 73496 Canola

Table 21. Summary Analysis of Secondary Meta bolite and Anti-Nutrient Composition in Canola Seed (continued)

Analyte Control Canola n=20 73496 Canola n=20 Tolerance Interval % Dry Weight

Total Sterols Mean 0.242 0.257

0.0801 - 0.741 Range 0.189 - 0.287 0.206 - 0.323

CI 0.215 - 0.274 0.228 - 0.290 P-Value 0.0846 Adjusted P-Value 0.198

a The statistical tolerance interval was calculated from co mmercial canola varieties and calculated to contain with 95

percent confidence, 99 percent of the population of canola, negative limits set to zero b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Statistically significant differ ence, FDR adjusted P-Value <0.05.

VIII-H. Acetylated Amino Acids

The GAT4621 enzyme exhibits measureable activity wi th five amino acid substrates (L-aspartate, L-glutamate, L-serine, glycine and L-threonine) in addi tion to glyphosate (Appendix 7). In studies using microbial-produced GAT4621, the level of catalytic efficiency of GA T4621 on aspartate, glutamate, serine, and threonine was 1%, 0.8%, 0.05%, and 0.06%, re spectively, of that observed for glyphosate (Pioneer data not shown). The affinity of the GAT 4621 enzyme for glycine was too low to estimate the level of catalytic efficiency. Levels of activity with other tested substrates, including a wide range of other amino acids and antibiotics, were below the limit of quantification (Pioneer data not shown).

Based on the activity of the GAT4621 enzyme, the concentrations of N -acetylaspartate (NAA), N

-acetylglutamate (NAG), N -acetylserine (NAS), N -acetylthreonine (NAT), and N -acetylglycine (NAGly) were measured in samples of seed, whole plant, and processed fractions derived from 73496 canola and control canola.

H1. Acetylated Amino Acids in Seed and Whole Plant Samples

Concentrations of the five acetylated amino acids we re measured in seed samples of 73496 canola and control canola. Results are provided in Table 22 belo w. As expected based on catalytic efficiency, NAA and NAG were the two most abundant in 73496 canola. Mean concentrations of NAA and NAG were 1480 μg/g dry weight and 32.8 μg/g dry weight, respectively, for 73496 canola seed samples (Table 22). Although the mean concentrations of NAT and NAS were elevated (statistically significant) in 73496 canola seed, relative to the near-isoline control li ne, the range of individual values for both these acetylated amino acids were within the tolerance interval established using commercial canola varieties (Table 22). There was no statistically significant difference in NAGly concentration measured in 73496 canola seed samples relative to the control line.Pioneer Hi-Bred International, Inc. Page 73 of 167 73496 Canola

Table 22. Concentrations of Acetylated Amino Acids in Canola Seed

Analyte Control Canola n=20 73496 Canola Treated

n=20 Tolerance Interval a
μg/g Dry Weight

NAA Mean b 1.24 1480

0.00861 - 4.43 Range c 0.377 - 5.39 1200 - 1770

CI d 0 g - 9.38 1340 - 1640 P-value e <0.0001 Adjusted P-value f <0.0001 g

NAG Mean 0.628 32.8

0.0968 - 5.37 Range 0.428 - 1.46 20.3 - 61.1

CI 0.00000752 - 2.50 24.4 - 42.5 P-value <0.0001 Adjusted P-value <0.0001 h

NAGly Mean 0.0751 0.0825

0.0240 - 0.338 Range 0.0481 - 0.125 0.0424 - 0.182

CI 0.0540 - 0.105 0.0592 - 0.115 P-value 0.454 Adjusted P-value 0.454

NAS Mean 0.843 1.04

0.0524 - 27.2 Range 0.389 - 3.05 0.491 - 3.55

CI 0.437 - 1.63 0.542 - 2.01 P-value 0.0035 Adjusted P-value 0.00528 h

NAT Mean 0.110 0.546

0.0140 - 1.74 Range 0.0531 - 0.212 0.260 - 1.64

CI 0.0665 - 0.181 0.331 - 0.902 P-value <0.0001 Adjusted P-value <0.0001 h

a The statistical tolerance interval was calculated from co mmercial canola varieties and calculated to contain with 95

percent confidence, 99 percent of the population of canola, negative limits set to zero b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g The lower limit of the confidence interval was negative on the transformed scale and wa s set to zero.prior to backtransformation
h Statistically significant differ ence, FDR adjusted P-Value <0.05.Pioneer Hi-Bred International, Inc. Page 74 of 167 73496 Canola

Concentrations of the five acetylated amino acids we re measured in whole plant samples derived from greenhouse-grown 73496 canola and control canola. Concentrations of all measured acetylated amino acids except NAS were elevated in whole plant samples of 73496 canola plants compared to control (Table 23). Consistent with results obtained for seed samples obtained from 73496 canola, NAA and NAG were the two most abundant with mean concentrations of 4560 μg/g and 26 μg/g, in whole plant samples, respectively.

Table 23. Concentrations of Acetylated Amino Acids in Canola Whole Plant Samples

Analyte Control Canola

n=15 73496 Canola

n=15

μg/g a

NAA Mean b 0.705 4560 Range c 0.404 - 1.23 3730 - 5340

CI d 0.649 - 0.766 4190 - 4950 P-value e <0.0001 Adjusted P-value f <0.0001 g

NAG Mean 2.04 26.0 Range 1.45 - 3.27 21.0 - 35.9

CI 1.87 - 2.22 23.8 - 28.3 P-value <0.0001 Adjusted P-value <0.0001 g

NAGly Mean 0.152 0.344 Range 0.122 - 0.193 0.247 - 0.445

CI 0.139 - 0.166 0.316 - 0.376 P-value <0.0001 Adjusted P-value <0.0001 g

NAS Mean 14.0 13.0 Range 10.2 - 21.9 9.17 - 22.0

CI 12.3 - 15.9 11.5 - 14.7 P-value 0.406 Adjusted P-value 0.406

NAT Mean 1.92 7.67 Range 1.60 - 2.50 5.43 - 11.8

CI 1.76 - 2.11 7.00 - 8.39 P-value <0.0001 Adjusted P-value <0.0001 g

a Results reported as-is after lyophili zation without adjusting for moisture
b Least squares mean were generated from a mixed model analysis

c Range denotes the lowest and highest individual value across sites.
d Confidence Interval

e Non-adjusted P-value f False Discovery Rate (FDR) adjusted P-value
g Statistically significant differe nce, FDR adjusted P-Value <0.05.Pioneer Hi-Bred International, Inc. Page 75 of 167 73496 Canola

H2. Acetylated Amino Acids in Processed Fractions

Whole canola seed is not commonly consumed. Be cause the typical processed canola products consumed by animals and humans are meal and oil, respectively, the concentrations of the five acetylated amino acids were measured in proces sed fractions of 73496 canola and control canola.

As expected, based on data from whole seed sa mples, NAA and NAG were the two most abundant acetylated amino acids in 73496 canola meal. Mean concentrations of NAA and NAG were 2872 μg/g and 62.3 μg/g, respectively, for 73496 canola toasted meal from seed with hulls ( i.e. , seed coats) (Table 24). The corresponding concentrations from toasted meal produced from canola seed without hulls of each event were similar at 3013 and 66.0 μg/g, respec tively for NAA and NAG. The concentrations of each of the remaining acetylated amino acids, NAT, NAS and NAGly, were approximately 30–100 fold less than the concentration of NAG measured in to asted meal produced from 73496 canola seed either with or without hulls.

On an equivalent weight basis, the elevated concentra tions of acetylated amino acids in toasted meal, relative to concentrations measured in whole seed samp les, reflect removal of the oil component, which is not expected to contain these compounds. This wa s confirmed through analysis of oil samples, where the concentrations of each acetylated amino acid were either not detectable or below the limit of quantification in all samples of refined, bleached, deodorized oil (Table 24).

Table 24. Concentrations of Acetylated Amino Acids in Processed Fractions Produced from 73496 Canola and Control Canola

Fraction Canola Line Concentration (Range)

n=2 a
NAA b NAG NAT NAS NAGly μg/g c

Toasted Meal

(with hulls) 73496 2872 (2822 - 2921) 62.3 (57.7 - 66.8) 0.585 (0.558 - 0.612) 1.20 (1.11 - 1.29) 0.151 (0.145 - 0.157)

Control 2.31 (2.15 - 2.47) 1.36 (1.31 - 1.41) 0.161 (0.146 - 0.175) 1.46 (1.39 - 1.53) 0.129 (0.114 - 0.144)

Toasted Meal (without hulls) 73496 3013 (3002 - 3024) 66.0 (62.6 - 69.3) 0.788 (0.535 - 1.04) 2.27 (1.98 - 2.55) 0.224 (0.184 - 0.265)

Control 2.58 (2.00 - 3.16) 1.71 (1.63 - 1.80) 0.226 (0.195 - 0.258) 1.76 (1.51 - 2.01) 0.180 0.163 - 0.197)

RBD Oil (with hulls) 73496 ND d ND - <LLOQ ND - <LLOQ ND ND - <LLOQ

Control ND ND <LLOQ ND ND - <LLOQ

RBD Oil (without hulls) 73496 ND - <LLOQ e <LLOQ ND ND ND -<LLOQ

Control ND ND ND ND ND

a Statistics are not provided due to small sample size.
b NAA = N -acetylaspartate; NAG = N -acetylglutamate; NAT = N -acetylthreonine; NAS = N -acetylserine; NAGly = N

acetylglycine

c Values are not corrected for moisture content.
d ND = Not detected

e LLOQ = Lower limit of quantification, which was 0.01 μg/g for a 100 mg sample

VIII-I. Conclusions on the Compositional Analysis of 73496 Canola

The analytes for compositional assessment were selected considering the OECD consensus document on compositional considerations for new varietie s of canola (OECD, 2001). Among the numerousPioneer Hi-Bred International, Inc. Page 76 of 167 73496 Canola

compositional analyses that were carried out, concent rations of most analytes were not significantly different between 73946 canola and control canola. Stat istically significant differences were noted for concentrations of oleic and linoleic fatty acids; del ta- and total tocopherols; magnesium; the glucosinolate progoitrin; and cholesterol. However, the magnitudes of the differences were small and in every case the ranges of values was all within the respective to lerance interval established using commercial canola varieties. Overall, no consistent patterns emerged to suggest that biologically significant changes in composition or nutritive value of the seed had occu rred as an unexpected result of the transformation
process.

In addition to the compositional analytes per OECD guidelines, the concentrations of NAA, NAG, NAS, NAT, and NAGly were measured in samples of seed , whole plant, and processed fractions derived from 73496 canola. As described earlier, these analyses were conducted because the GAT4621 protein is known to acetylate certain free amino acids (L-asparta te, L-glutamate, glycine, L-serine, and L-threonine) resulting in the production of NAA, NAG, NAGly, NAS, and NAT, respectively. As expected, NAA and NAG were the most abundant in seed, whole plant, and processed meal fractions. Refined, bleached, deodorized oil fractions did not contain measurable leve ls of these five acetylated amino acids. These acetylated amino acids are normal components of food and feed, have a safe history of food and feed use, and are not novel substances (Appendix 8). The safety of these substances has also been evaluated in published studies as described in Appendix 8; therefore, it is not ex pected that the increase in these acetylated amino acids would adversely a ffect the safety of processed products from 73496 canola.

Based on the OECD guidelines for compositional equivalence, we have concluded that 73496 canola was compositionally comparable to conventional canola. The increases in certain acetylated amino acids do not negatively impact the safety of 73496 canola and will not have an adverse impact on processed commodity products from 73496 canola.Pioneer Hi-Bred International, Inc. Page 77 of 167 73496 Canola



### IX. Assessment of Plant Pest Risk for 73496 Canola

In this section, the plant pest risk of 73496 canola is discussed with respect to the potential environmental impact of the presence of the GAT4621 pr otein in 73496 canola, the fate of the gat4621 gene in humans and animals, the weediness potential of 73496 canola, and the impact of gene flow from 73496 canola to crop relatives or wild relatives of canola.

IX-A. Environmental Impact of the Transgenic Protein

The GAT4621 protein present in 73496 canola is iden tical to the GAT4621 protein present in previously authorized maize event DP-Ø9184Ø-6 (FDA, 2008; USDA, 2009). The GAT4621 protein was reviewed by FDA in a New Protein Consultation submitt ed to US FDA on January 31, 2007 and completed on October 7, 2009.

The GAT4621 protein is unlikely to pose a hazard to the environment. The GAT4621 protein sequence is derived from N -acetyltransferase protein sequences from Bacillus licheniformis , a gram positive saprophytic bacterium that is ubiquitous in soil. The GAT4621 protein is a member of the GNAT acetyltransferase superfamily that contains more than 10,000 representatives from plants, animals, bacteria, and fungi, all of which share a highly conserved GNAT motif (Section VI) (Vetting et al., 2005). GAT4621 is 75-78% identical and 90-91% similar at the amino acid level to the translated protein sequences of each of the three original gat genes from Bacillus licheniformis from which the gat4621 gene was derived. GAT4621 retains the acetyltransferas e enzyme function of the native proteins. In addition, the GAT4621 protein is highly unlikely to be a toxin (Section VI).

Based on the facts above, there are not likely to be any adverse environmental effects due to the presence of the GAT4621 protein in 73496 canola.

IX-B. Fate of Transgenic DNA in Humans and Animals

Transgenic DNA is no different from other DNA cons umed as part of the normal diet. Genetically engineered organisms have been used in drug production (Thayer, 2005) and microbial fermentation (cheese) since the late 1970’s (Maryanski, 1995; Na tional Centre for Biotechnology Education, 2006). More than 2.47 billion cumulative acres (1 billion hectares) of engineered food and feed crops have been grown and consumed worldwide fr om 1996 to 2010 (ISAAA, 2010). The FDA has not reported any significant concerns with bioengineered food and f eed currently on the market. The EPA has exempted from a tolerance DNA that encodes currently register ed plant incorporated protec tants because of a lack of toxicity (Federal Register, 2001).

Studies in humans and animals following the fate of DNA once consumed have show n that the majority of DNA is degraded in the gastrointestinal tract. There is evidence that DNA can move from the gastrointestinal tract lumen to other areas of the body , but this is considered to be a normal occurrence and no risks have been identified as a result of absorption (Duggan et al. , 2003; Einspanier et al. , 2001).

In conclusion, there are not likely to be any adverse effects due to the presence of the gat4621 gene and associated transgenic DNA in 73496 canola.

IX-C. Weediness Potential of 73496 Canola

Canola is not considered a noxious or invasive weed in the United States (USDA-NRCS, 2010). Weed species typically spread easily in disturbed areas or wi thin crops and generally have a range of life history characteristics in common that enables them to rapidl y colonize and persist in an ecosystem. Several characteristics of weeds have been described by Bake r (1974) and are indicated in Table 25. In general, these characteristics do not apply to cultivated canola varieties.Pioneer Hi-Bred International, Inc. Page 78 of 167 73496 Canola

Table 25. Common Characteristics of Weeds

Characteristic Example Applies to canola varieties? Dissemination of seed Long continuous seed production No. As a cultivated crop, canola has been selectively bred to ensure seed production is timely to allow for efficient harvest. Additionally, canola is an early successional ruderal ( i.e.

, capable of growing in disturbed habitats) which is incapable of regenerating in undisturbed habitats (Crawley et al. , 1993). Populations were observed to be seed limited in a study conducted on motorway verges by Crawley and Brown (1995). Special adaptations for short and long-distance dispersal Possible. However, the small size of canola seeds and their high numbers on post-harvest fields may facilitate some wind dispersal (Lutman, 1993). The dispersal distance will depend on wind strength, the amount of debris on the ground and the moisture content of the material. It is reasonable to expect that seeds and pods of low moisture content may be transported within the field to adjacent fields, or outside agricultural areas. High seed output under favorable conditions Yes. However due to selective breeding, crop plants only functional optimally under managed agricultural conditions, such as high soil fertility or low plant competition. These conditions rarely occur in natural habitats, resulting in poor fitness of canola plants ( i.e. reduced recruitment, low survivorship, poor competitive ability, low seed production) (OGTR, 2002). Dormancy of seed Continuous germination and long-lived seeds Yes. Studies in the Northern Hemisphere have reported viable seeds of canola persisting in disturbed soils for at least 5 years and possibly up to 10 years or more in undisturbed soil (Chadoeuf et al

., 1998; Madsen 1962; Pekrun et al

., 1997; Vaughan et al ., 1976).Pioneer Hi-Bred International, Inc. Page 79 of 167 73496 Canola

Table 25. Common Characteristics of Weeds (continued)

Characteristic Example Applies to canola varieties? Germination of seed/seed survival Germination and seed production under a wide range of environmental conditions Possible. The persistence of canola seeds in a seed bank depends both on seed dormancy and their vertical distribution in the soil, as seeds are more likely to persist at deep rather than shallow depths (Pekrun et al.

, 1998; Simard et al. , 2002). As with many annual weeds, feral canola plants usually are not capable of surviving outside of cultivation and without human intervention for more than a few generations (Andersson and de Vicente, 2010). Still, some old canola cultivars can persist outside of cultivation for up to eight or nine years after they were last cultivated, albeit at low densities (Gulden et al

., 2003; Légère et al ., 2001; Simard et al ., 2002; Squire et al ., 1999). Competitiveness Choking growth or production of allelochemicals No. Canola is not known to produce allelochemicals or otherwise strongly compete with other plants. Canola is known to be strongly affected by weed competition during crop establishment (Berglund et al.

, 2007) and is unable to invade established natural habitats (OGTR, 2002). Ability to regenerate from severed rootstock No. Canola is not known to regenerate from severed rootstock. Rapid seedling growth No. Young canola seedlings are very sensitive to early weed competition (Berglund et al. , 2007). Canola is a poor competitor and not regarded as an environmentally hazardous colonizing species. Unless the habitat is regularly disturbed, or seed replenished from outside, canola will be displaced by other plants (OGTR, 2002). Rapid growth to reproductive stage No. As a crop, canola has been selectively bred to develop to maturity for the purpose full yield potential. This is in contrast to rapid growth to reproductive stage for the purpose of dispersing pollen, as with weed species.Pioneer Hi-Bred International, Inc. Page 80 of 167 73496 Canola

Table 25. Common Characteristics of Weeds (continued)

Characteristic Example Applies to canola varieties? Self-compatible, but not obligatorily self-pollinated or apomictic Yes. Fertilization of ovules usually results from self pollination, although out-crossing rates of 20- 30% have been reported (Rakow and Woods, 1987). The floral biology of canola is such that it is suited to cross pollination by insect vectors, but can be pollinated by wind (Cresswell et al ., 2004; Hayter and Cresswell, 2006; Hoyle et al

., 2007). Stress tolerance High tolerance or plasticity of climatic and edaphic variation Possible. Canola grows well in dry environments and can tolerate moderately saline soil conditions (Bañuelos et al ., 1997; Stricker et al ., 1997). However, although tolerant of some drought stress, seed yields of Brassica napus are known to decrease due to drought stress (Jensen et al ., 1996; Kumar and Singh, 1998) and are most susceptible to heat and drought stress during flowering (Berglund et al. , 2007).

It is generally accepted that most crop plants, incl uding canola, have undergone many years of selective breeding and domestication and therefore, they function optimally only under managed agricultural conditions. Similar conditions rarely occur in natural habitats, resulting in poor fitness of canola plants outside of a managed field (OGTR, 2002). Although c anola has a number of life history traits in common with those usually associated with weeds (Table 25), it is a poor co mpetitor and is not regarded as a colonizing species (Salisbury, 2002). Unless the habi tat is regularly disturbed or seeds are replenished from outside, canola will be displace d by other plants (Salisbury, 2002).

The agronomic characteristics and germination data (S ection VII) provide evidence that the genetic modification resulting in 73496 canola did not alter any major characteristics of t he plant that would allow for development of weedy characteristics different from other canola varieties. Furthermore, the herbicide-tolerance trait conferred by gat4621 gene does not provide a selective advantage in unmanaged ecosystems, but rather only in settings wher e glyphosate is being applied for weed control. 73496 canola is susceptible to other herbicides, so co ntrol of volunteers could be achieved by use of alternative herbicides, or by non-chemical met hods that may be part of the weed management best practices.

There is no evidence that herbicide-tol erant varieties of canola are more invasive or more persistent in disturbed habitats than their unmodified counterparts, nor does canola survive well in the wild (Crawley et al ., 1993; Crawley et al ., 2001), therefore it is highly unlikely to invade other habitats (Salisbury, 2002). Additionally, because there are many different traits that lead to weediness in plants ( e.g. , those described in Table 25), one can assume that these ar e likely to be polygenic traits and changes to these traits would not be easily conferred by a dding a single herbicide tolerance gene.

Herbicide-tolerant canola, including varieties tole rant to glyphosate, has been cultivated since the mid-90’s (Devine, 2005). To our knowledge, there is no record of herbicide-tolerant canola varietiesPioneer Hi-Bred International, Inc. Page 81 of 167 73496 Canola

demonstrating weedy characteristics as a result of their herbicide tolerance characteristics. Based on Pioneer’s detailed characterization, we expect 73496 canola to be similar to other herbicide-tolerant canola with regard to weediness characteristics.

IX-D. Gene Flow Assessment

Gene flow is the movement of genes via pollen flow or seed dispersal; pollen- mediated gene flow could be a potential route for transfer of traits from canola to other related crops or to wild relatives. The introgression of a gene ( e.g ., the introduced gat4621 gene) into another species is limited by several variables including pollen viability and dispersal, synchr ony of flowering or pollen production, wind speed and direction, topography and surroun ding vegetation, temperature, hum idity, relative density of donor and receptor plant populations, sexual incompatibilit y, and genetic instability (Eastham and Sweet, 2002; Gliddon et al ., 1999; Ingram, 2000; Thompson et al ., 1999; Warwick et al ., 2009). In order to evaluate the potential for gene flow from 73496 canola, the geographic areas of canola production, the crop relatives of canola, the wild relatives of canola, and the barrier s to gene flow are discussed further below. In order to be conservative in the analysis of possible gene flow, crop or wild relative species were considered for further examination if the spec ies had geographical prevalence in canola production areas and hybridization with B. napus was possible.

D1. Geographic Areas of Canola Production

Canola is grown in the U.S. and the primary states of cultivation include North Dakota (approximately 90% of total production), Minnesota, Idaho, Wash ington, Montana, Oklahoma, and Oregon (USDA-ERS, 2010; USDA-NASS, 2009; USDA-NASS, 2010). Spring and wint er canola are generally grown in different regions of the U.S. based on climate zones most suitable for the varieties (Mills, 1996; Figure 19). Spring canola (typically planted in March and harvested around September to October) in the U.S. is primarily grown in areas of North Dakota (90% of production acreage), Minnesota, and the Pacific Northwest ( e.g

. Idaho, Washington, and Montana), due to spring cano la’s poor performance in warm temperatures. Winter canola (typically planted in September and harv ested around June to July) in the U.S. is grown on fewer acres than spring canola but can be grown in a broader range of environment s if winters are mild. In recent years, winter canola variety trial prog rams are run in the Southeast (Alabama, Arkansas, Virginia, Georgia), the Midwest (Illinois, Kentucky, Michigan, Ohio, Pennsylvania), and the Great Plains (Wyoming, Colorado, Nebraska, Kans as, Oklahoma, Texas, Missouri); these states also have reported canola production (Brown et al. , 2008; USDA-NASS, 2009). Winter ca nola is often planted in rotation with wheat, so weed control practices are applied to some extent ahead of the canola planting ( e.g ., Brown et al. , 2008), which could limit the likelihood for presence of wild relatives in and around prospective winter canola fields.Pioneer Hi-Bred International, Inc. Page 82 of 167 73496 Canola

Figure 19. Production Climate Zones for Spring, Biennial, and Winter Canola Map of climatic zones suitable fo r the production of different canola varieties (adapted from Mills, 1996)

D2. Crop Relatives of Brassica napus

The genus Brassica contains several important crop species t hat are used for a variety of purposes. Brassica napus and B. rapa are the most important for their use as oilseed crops (Ellstrand, 2003a). Brassica and the related genus Raphanus include vegetables for human consumption, e.g ., swede ( B.
napus ), turnip and Chinese cabbage ( B. rapa ), and cauliflower, cab bage, broccoli, and others ( B. oleracea ), Indian mustard ( B. juncea ), and radish ( R. sativus ). Three Brassica species and one species in the related genus Sinapis are ‘mustards’: B. carinata (Ethiopian mustard), B. juncea (Indian mustard), B. nigra (black mustard) and Sinapis alba (white mustard) (FitzJohn et al. , 2007). Cultivation of B. carinata as an oilseed and vegetable crop is largely re stricted to Ethiopia and India (Hemingway, 1995; Stewart, 2002). Some forms of B. napus

, B. oleracea

, B. rapa and R. sativus are also grown as fodder crops (FitzJohn et al. , 2007).

The three Brassica species forming the foundation of the Triangle of U (Nagaharu, 1935) are B. rapa, B. nigra, and B. oleracea . These three species are diploid, and their respective genomes have been distinguished from one another and are described as A, B, and C ( 

### Ø stergaard and King, 2008). They can be hybridized sexually with varying degrees of di fficulty. Figure 20 describes the likelihood for B. napus crossing successfully with ot her cultivated species. As B. napus and B. rapa may easily cross, other crosses with B. napus are difficult to nearly impossible based on genome characteristics (Myers, 2006; Nagaharu, 1935; OGTR, 2002). The resulting amphidiploid hybrids, B. juncea

, B. napus , and B. carinata contain AB, AC, and BC genomes, respectively. Research has shown that B. napus and B. rapa outcross readily with each other; these species can also outcro ss, albeit more rarely, with a wide range of wild and cultivated species including B. oleracea

, B. nigra , and R. sativus (summarized in OGTR, 2002). Brassica
napus and B. juncea share a common set of chromosomes, enhancing the likelihood of interspecific hybridization and gene flow (Myers, 2006).

Brassica napus and B. juncea can self-fertilize (Rakow and Woods, 1987), but B. rapa is selfincompatible (Warwick et al. , 2003). The A genome is common to the three major oilseed Brassica species, explaining the success of interspecific crossing, and the ability to transfer genes among these species (Figure 20). Canola Production Zone Spring Annual Biennial Winter AnnualPioneer Hi-Bred International, Inc. Page 83 of 167 73496 Canola

Figure 20. Genome Relationships Among Cultivated Brassicaceae

A modified “Triangle of U” showing genome relationshi ps among cultivated Brassicaceae adapted from Nagaharu (1935) and Myers (2006). Genomes are represented by letters, and haploid genome chromosome numbers are described in parentheses. The three diploid species posse ss three basic genomes, A, B, and C. Lines represent ease with which species can be crossed. These genomes are combined in the three tetraploid species in pair-wise combinations, i.e. AB, AC, and BC.

D3. Wild Relatives of Brassica napus

Hybridization between crops and their wild relatives (eit her the same or different species) has occurred in agricultural history (Ellstrand and Schierenbeck, 2000; Raybould and Wilkinson, 2005). The majority of important crops have wild relatives (CAST, 2007; Ellstrand et al. , 1999), and gene flow to wild species from crops occurs at higher frequen cy than might be expected (Ellstrand et al. , 1999). However, the probability of gene flow from crops to related weed species is habitat-dependent and variable between populations (Cureton et al. , 2006).

The Brassicaceae family contains a number of major weeds, including those in the genera Sinapis, Capsella, Thlaspi, Erucastrium, Raphanus , and others (OECD, 1997). Concerns have been raised about the potential for the transfer of tr ansgenes from the cultivated oilseed Brassica species to their weedy relatives in Europe and North America where Brassica crop species are widely grown. Some Brassica crops and their wild relatives will hybridize only under artificial conditions in laboratories or highly contrived field conditions; others will hybridize at very low rates under natural conditions (Table 26; Barton and Dracup, 2000; Raybould, 1999). However, major barriers to introgression exist, including spatial and temporal isolation, sexual incompatibility, or lack of fertile progeny, thereby reducing the likelihood of gene flow.

Table 26 describes crop and wild relative species that occur in the U.S. to some extent, and the likelihood for hybridizations with canola. In order to be conser vative in the analysis of possible gene flow, species were considered for further examination if the spec ies had geographical prevalence in canola production areas and at least one re ported successful hybridiz ation (hand pollination or in the field) with B. napus . IfPioneer Hi-Bred International, Inc. Page 84 of 167 73496 Canola

information was not known about hybridization, the species was also examined further if present in primary canola-growing areas. The species that met these criteria are highlighted in Table 26 and discussed individually in section D5.

Table 26. List of Species with Reports of Hand -Pollinated or Spontaneous Hybridization with B. napus

Species Name a Crop Weed Classification b Hand Pollination (successes:failures) c Spontaneous and Natural Hybridization c Presence in Winter Canola Growing Areas d Presence in Spring Canola Growing Areas d B.napus as Male B.napus

as Female B.napus as Male B.napus

as Female
Brassica carinata  X 4:1 7:0

 Brassica elongata   
Brassica fruticulosa  0:1 1:1  X



Brassica juncea   25:1 13:4   Brassica nigra   2:2 4:2 X X  

Brassica oleracea  X 3:11 9:17  X  

Brassica rapa   55:8 84:0    
Brassica tournefortii  0:1 1:1  X



Camelina sativa  X 0:1 0:1  Capsella bursapastoris  0:1 0:1  
Coincya monensis    Conringia orientalis  0:1 0:1   Diplotaxis erucoides X 1:1  

Diplotaxis muralis  3:0 1:1   Diplotaxis siifolia X 0:3 0:1 X X

 Diplotaxis tenuifolia  0:3 1:1  

Eruca vesicaria (E.sativa)  2:0  

Erucastrum gallicum  0:1 1:0 X  
Hirschfeldia incana  1:2 1:2    X

 Moricandia arvensis X 0:2 0:2 X X

 Myagrum perfoliatum X 0:1 0:1  X

 Raphanus raphanistrum  0:4 3:2    
Raphanus sativus   1:5 1:2   Rapistrum rugosum  1:0  

Rorippa islandica  1:0 X X



Sinapis alba   0:6 1:2 X   Sinapis arvensis  1:10 5:8 X    Sisymbrium irio  0:1 0:1  X

 Sisymbrium orientale   

 = Yes, to some degree X = No

a Species highlighted in purple have at least one report of successful hybridization with B. napus b Weed Science Society of America or USDA NRCS list of noxious weeds

c Andersson and de Vicente, 2010; FitzJohn et al ., 2007 d USDA PLANTS Database; Criteria to distinguish growing areas for winter and spring canola were obtained from Brown et al. (2008) and are summarized in the following section. Blank cells = no data availablePioneer Hi-Bred International, Inc. Page 85 of 167 73496 Canola

D4. Gene Flow Assessment Considerations

In general, it is difficult for a transgene to become estab lished in a wild relative or recipient population. In order for successful introgression of a transgene in a recipient population, several conditions must exist and several steps must take place before this would occur (Devos et al. , 2009). These are as follows:

1. There must at least be a partial overlap in flowering periods between the transgenic canola and the relative. 2. The relative must grow within the physical range of viable pollen dispersal of the transgenic canola, and viable pollen grains must reach the recipient stigma. 3. Viable and fertile interspecific F 1 hybrids must be produced, and the transgene successfully integrated into the recipient plant genome. 4. The transgene must be transmitted through successive backcross generations. 5. The transgene must be stabilized in the genome of the relative through backcrossing over multiple generations. 6. The introgressed transgene must be either neut ral or provide a fitness advantage such that it persists in the relative’s populations.

In order to evaluate the likelihood of gene flow of 73496 canola to the species highlighted in Table 26, additional information related to canola flowering sync hrony and flowering characte ristics, pollen dispersal mechanisms and pollinator biology ar e discussed below in order to provide context for the gene flow assessment.

Flowering synchrony and flower characteristics

Winter canola can grow in a broader geographic range than spring canola, thereby increasing the number of wild relative species with which geographic overlap is possible (Table 26). However, the flowering period may not overlap. Planting of winter canola o ccurs in the fall, and the plants overwinter in the rosette stage (Boyles et al. , 2009; Boyles, 2010; Wysocki et al. , 2005). Rosettes resume growth in the spring as temperatures increase, and (Boyles et al. , 2009; Boyles, 2010; Wysocki et al. , 2005) Depending on location, flowering for winter canola generally occurs in April to May, with harvest in June to July (Boyles et al. , 2009; Boyles, 2010; Wysocki et al. , 2005). As an example, Brassica tournefortii generally flowers from February to May in Arizona, in December to January in California, and January to March in Texas (summarized by Halvorson, 2003), thereby lim iting the likelihood for flowering synchrony with winter canola.

In self-compatible species ( e.g

. B. napus

, B. juncea ) (Rakow and Woods, 1987), pollination typically occurs prior to flower opening, thus limiting exposure of the recipient stigma to pollen from another flower or species. Finally, canola crops produce 5x10 12 pollen grains per hectare (Chèvre et al. , 1999). Therefore, due to a general lack of mobility of poll en, any pollen coming from outside the immediate field would be competing with this large volume of po llen (Salisbury, 2002), thereby decreasing the likelihood for successful pollination by pollen from outside the immediate field.

Pollen dispersal mechanisms

B. napus is primarily a self-pollinating cr op, and the majority of large-scal e outcrossing studies with fertile canola indicate outcrossing rates of <2% (Salis bury, 2002). However, worst-case estimates of outcrossing suggest levels between 12 to 47% (Becker et al. , 1992; Kapteijns, 1993; Rakow and Woods, 1987). The pollen, which is heavy and sticky, can also be transferred from plant to plant through physical contact with neighboring plants, via pollinator insect s and, to a smaller extent, by wind (Cresswell, 1994; Cresswell et al. , 2002; Williams, 1984). In general, windborne pollen may make little to no contribution to long distance pollination (OGTR, 2002).

Approximately half of canola pollen travels less than th ree meters from the source; the vast majority of pollen travels less than 10 meters, with the amount of pollen decreasing as the distance from the pollen source increases (Scheffler et al. , 1993; Thompson et al. , 1999). Pollinating insects, in particularPioneer Hi-Bred International, Inc. Page 86 of 167 73496 Canola

honeybees and bumblebees, play a major role in B. napus pollination and are believed to be involved in the transfer of pollen over long di stances (OGTR, 2002; Salisbury, 2002).

Pollinator biology

Insects are the primary pollen vectors (Hayter and Cr esswell, 2003), and insect foraging behavior is complex. The dynamics of bee-mediated pollen movement depend on a number of factors including spatial arrangement of plants, envir onmental conditions, plant density, av ailability of pollen, and the size and location of the receiving populations (Ellstrand et al. , 1989; Klinger et al. , 1992; Levin and Kerster, 1969; Rieger et al. , 2002).

In situations with abundant flowers, such as in a cultivated field, individual honey bees generally collect nectar and pollen from flowers in the same or i mmediately adjacent plants (Cresswell, 1999; OGTR, 2002; Pierre, 2001; Ramsay et al. , 1999). Occasionally, bees may travel much further and some pollen transfer may occur over longer distances, for example a maximum flight distance of four kilometers has been reported in the literature (Ramsay et al. , 1999; Thompson et al. , 1999). However, the majority of bee flights are less than one meter, thereby limiting the lik elihood of long distance pollen dispersal via insect pollinators (summarized by OGTR, 2002).

Honeybees forage during daylight and are unlikely to carry viable pollen grains to impact fertilization beyond 12 hours (Kraai, 1962). Honeybees are sens itive to weather events and barometric pressure, and respond to these events by decreasing foraging di stances (APHIS, 1998). The distance and success of pollen-mediated gene flow is dependent on its disper sal in space by either wind or insects, and on the length of time the pollen grain remains viable (OGT R, 2002). Canola pollen viability gradually decreases after four to five days in natural circumstances depending on environmental conditions, particularly temperature and humidity (Andersson and de Vicente, 2010; Rantio-Lehtimäki, 1995).

Likelihood of hybridization

Reproductive compatibility among Brassica crops is complex. Because experimental hybridization studies are designed to optimize the likelihood of su ccessful hybridization, they create bias toward positive reports of hybridization bet ween species that may be unlikely to cross in natural conditions (FitzJohn et al. , 2007). The ease with which a crop and its wild relatives can hybridize through manual cross-pollination reveals little about the potential infl uence of pre-pollination and other ecological barriers (Arnold, 1997; FitzJohn et al. , 2007; Grant, 1994).

Many studies have been conducted to ga ther experimental data to infe r the likelihood of hybridization using a variety of techniques: experimental cr osses (manual hand pollination), spontaneous crosses (non-assisted crosses under field conditions), and in vitro methods ( e.g ., embryo rescue). Crosscompatibility varies with the particular genoty pe used and with the polarity of the cross ( i.e. , dependent upon which species was the maternal parent; Arnold, 1997). Most combinations are unsuccessful and where crosses are successful, rates of hybrid pr oduction are typically very low (Table 26; FitzJohn et al.

, 2007; Warwick and Black, 1993).

Hybridization of B. napus with cultivated and wild Brassica species such as B. carinata

, B.elongata, B.fruticulosa, B. incana, B.nigra, B. tournefortii , have been attempted and in most cases the production of hybrids requires considerable human intervention and is only successful if artificial hybridization techniques are used ( e.g ., embryo rescue) (Andersson and de Vicente, 2010). All resulting F1 hybrids are sterile (Andersson and de Vicente, 2010). Brassica carinata

, B.nigra , and B

. tournefortii are able to form hybrids with B. napus after hand pollination however, they hav e significant barriers to introgression such as pollen dehiscense prior to the flower opening , sexual incompatibility, reduced hybrid fertility, or sterility, making gene exchange with B. napus extremely unlikely (Andersson and de Vicente, 2010). Even among the closely related Brassica species (Nagaharu, 1935), hybridization with B. napus is highly unlikely. For example, although B. napus and B. rapa share the A genome, Scott and Wilkinson (1998) reported only 7% of B. rapa populations had any hybrids, indicating that 93% of B. rapa populations had no hybrids, and hybridization rates were low (0.4-1.5%) in field situations; further, less than 2% of hybridPioneer Hi-Bred International, Inc. Page 87 of 167 73496 Canola

seedlings survived (Scott and Wilkinson, 1998). Othe r published hybridization rates are equally low, e.g

. <3% for B. juncea (Bing et al. , 1991; Jørgensen et al. , 1996), <0.003% for R. raphanistrum (Chèvre et al.

, 1999; Chèvre et al., 2000), <0.000034% for S. arvensis (Lefol et al. , 1996). In many cases of attempted hybridizations with B. napus as male donor, no hybrids were produced (Salisbury, 2002).

D5. Assessment of Gene Flow Potential from 73496 Canola to Relevant Species

Gene flow assessments were conducted for those sp ecies highlighted in Table 26 on the basis of overlapping geographic ranges with canola production and reports of at least one successful hybridization (by hand pollination or in the field) with B. napus . If information was not known about hybridization, the species was also examined further if present in primary canola growing-areas.

Crop Species:

Brassica carinata (Ethiopian mustard)

Although some reports of successful hand pollinations are reported for B. napus and B. carinata , no hybridizations in the field have been reported (A ndersson and de Vicente 2010), and no distribution information is available for B. carinata in the U.S. (USDA Plants Database, 2010). Several barriers to introgression exist, e.g . reduced hybrid fertility or sterility (Andersson and de Vicente, 2010).

Brassica juncea (Indian or brown mustard )

B. juncea can occur throughout the U.S. (USDA Plants Database, 2010) and is both a crop and a weed. B. juncea (AABB genome) has a common set of chromosomes with B. napus (AACC genome), which enhances the likelihood of interspecific hybridizat ion and gene flow (Andersson and de Vicente, 2010). Spontaneous hybridization has been reported at <3% for B. juncea (Bing et al. , 1991; Jørgensen et al.

, 1996), although hybridization is less successful when B. napus is the female parent (Jørgensen et al.

, 1998). In general, F1 hybrids are rarely more fi t than highly selected and well adapted counterparts, and low initial frequencies, reduced fitness and viability, and competitive disadvantage with respect to parents can lead to hybrid extinction (Wolf et al. , 2001). The pollen and seed fertility of the F1 hybrids is typically less than 30% (Bajaj et al. , 1986; Choudhary and Joshi, 1999; Frello et al. , 1995; GhoshDastidar and Varma, 1999; Prakash and Chopra, 1988; Roy, 1980; Sacristán and Gerdemann, 1986), however spontaneous backcrossing progeny with im proved fertility have been documented (Bing et al. , 1991; Bing et al. , 1996; Jørgensen, 1999). Backcrossing and subsequent gene introgression from B. napus to B. juncea could be expected, although infrequently (Andersson and de Vicente, 2010).

Brassica nigra (Black mustard)

B. nigra can grow throughout regions of the U.S. (USD A Plants Database, 2010) and is classified as both crop and weed. Hybrids between Brassica nigra and B. napus have been reported to occur at a low frequency when produced under controlled conditions (Bing et al. , 1991; Heyn, 1977). However, under field conditions no hybrids resulted from co-cultivation of B. nigra and B. napus (Bing et al. , 1996).

Brassica oleracea ( e.g. cauliflower, cabbage, broccoli)

B. oleracea has a more limited distribution than other Brassica spp. ( i.e. CA, CT, DC, GA, IA, IL, KY, LA, MA, MO, ME, MI, MD, MT, NM, NY, OH, OR, PA, RI, TX, VA, WA) (USDA Plants Database, 2010). Hybridization of B. napus with B. oleracea can be achieved by hand pollination (Eastham and Sweet, 2002; Scheffler and Dale, 1994). Although B. oleracea and B. napus share a common set of chromosomes (Figure 19), the frequency of successful crosses is very low, and embryos often abort at early stages of development (Chiang et al. , 1977; Honma and Summers, 1976; Mattsson, 1988). Thus far, no viable hybrid seeds have bee n obtained from crosses between B. napus and B. oleracea without the assistance of embryo rescue or ovule culture (Ayotte et al. , 1987; Myers, 2006; Quazi, 1988; Takeshita et al. , 1980). Spontaneous hybrids have been reported in wild B. oleracea populations in thePioneer Hi-Bred International, Inc. Page 88 of 167 73496 Canola

UK (Ford et al. , 2006). No information is available thus far on the fertility of the natural hybrids reported (Andersson and de Vicente, 2010).

Brassica rapa (Turnip, Chinese cabbage)

B. rapa is a closely related species of canola (amphidiploi d), which has a similar life history to canola, but with a shorter growing season. B. napus (AACC) and B. rapa (AA) have a common set of chromosomes, making interspecific outcrossing more common ( e.g . Bing et al. , 1991). Gene flow measurements by Scott and Wilkinson (1998) reported only 7% of B. rapa populations had any hybrids, indicating that 93% of B.
rapa populations had no hybrids, and hybridization rates were low (0.4-1.5%) in field situations. Importantly, less than 2% of hybrid seedlin gs survived (Scott and Wilkinson, 1998).

Hybridization frequencies are higher when B. rapa occurs as a weed within canola crops, but varies significantly with experimental design. Where natural interspecific hybrids occur, hybrids have reduced fertility and low seed set (average 2-5 per pod) comp ared with the parents (Jørgensen and Andersen, 1994). Reduced dormancy of B. rapa x canola hybrids relative to the persistent wild B. rapa (Jørgensen et al. , 1999), coupled with the reduced fertility of the inter-specific hybrid (Jørgensen et al. , 1999) makes it very unlikely that populations of these hybrids will persist.

Raphanus sativus (radish)

R. sativus can be found throughout the U.S. (USDA Plant s Database, 2010). Spontaneous hybridization between a male sterile B.napus line and a cultivated variety of R. sativus line has been reported (Ammitzboll and Jørgensen, 2006). However, all F1 offspring were found to be hybrids with low pollen fertility (0%-15%) (Ammitzboll and Jørgensen, 2006) . Although hybridization can be achieved by hand pollination or through sophisticated methods, such as ovule culture and embryo rescue (Gupta, 1997; Huang et al. , 2002; Metz et al. , 1995; Rhee et al. , 1997; Sundberg and Glimelius, 1991) all artificially produced F1 hybrids have shown to be male sterile (Andersson and de Vicente, 2010).

Sinapis alba (See Other Highlighted Species section below).

Weed Species:

Brassica fruticulosa

This species only occurs in California (USDA Plants Database, 2010), therefore risk is limited to canola production in California. Additionally, only one r eport of successful hand po llination has occurred, and no reports of hybridization in the field are described (Andersson and de Vicente, 2010).

Brassica tournefortii

B. tournefortii grows in the southwestern U.S. ( e.g . NV, NM, AZ, TX, CA) (USDA Plants Database, 2010), therefore geographic overlap is limited to winter ca nola production, however as previously discussed, asynchrony of flowering is probable in this case (Boyles et al. , 2009; Boyles, 2010; Halvorson, 2003; Wysocki et al. , 2005).

Hybridization of B. napus has been attempted with B. tournefortii . In most cases, the production of F1 hybrids requires considerable human intervention and is only successful if artificial hybridization techniques are used. B. tournefortii is able to form hybrids with B.napus after hand pollination. However, they have significant barriers to introgression such as pollen dehiscence prior to the flower opening, sexual incompatibility, reduced hybrid fert ility, or sterility making gene exchange with B.napus extremely unlikely (Andersson and de Vicente, 2010)Pioneer Hi-Bred International, Inc. Page 89 of 167 73496 Canola

Diplotaxis muralis

D. muralis occurs throughout regions of the U. S. (USDA Plants Database, 2010). Ringdahl et al. (1987) examined the crosssability of D. muralis and B. napus using conventional crossing techniques, using B.
napus as the male parent. They were able to produce viable F1 hybrids after hundreds of hand pollinations conducted (Ringdahl et al. , 1987). On the other hand, Fan et al. 1985 investigated male sterility in backcross populations from hybrids between D. muralis and B.napus , using D. muralis as the female parent. Male sterility of the F1 populations was caused by an extra chromosome derived from D.muralis (Fan et al. , 1985).

Erucastrum gallicum

E. gallicum can be found throughout regions of the U.S. (USDA Plants Database, 2010), however studies conducted by Warwick et al. (2003) indicated that gene flow from commercial fields of B. napus to E. gallicum has very low probab ility of occurrence.

Hirschfeldia incana

H. incana can be found in CA, HI, NV, OR (USDA Plant s Database, 2010). Spontaneous hybridization between male-sterile B. napus and H. incana in field has been reported in both directions (Chèvre et al.

, 1996; Eber et al. , 1994; Lefol et al. , 1995). The resulting triploid F1 hybrids are often vigorous and at least as competitive as their wild parent (Eber et al. , 1994; Lefol et al. , 1996). However, they are usually male sterile and produce very little seed (1 seed per plant) under controlled conditions (Lefol et al. , 1996). Hybridization between these two species is easy and re current, but introgression rarely occurs (Darmency and Fleury, 2000).

Raphanus raphanistrum

R. raphanistrum occurs throughout regions of the U.S. (USDA Plants Database, 2010), and there is a possibility for successful hybridizat ion; however, the frequency of such hybridization is very low ( e.g

. <0.003%; Ammitzboll and Jørgensen, 2006; Baranger et al. , 1995; Chèvre et al. , 1996; Chèvre et al.

, 1999; Chèvre et al. , 2000; Darmency et al. , 1995; Eber et al. , 1994; Rieger et al. , 2001;), and hybrids show very low fertility (Ander sson and de Vicente, 2010).

Spontaneous hybridization between B. napus and R. raphanistrum may occur in the wild. Low frequencies of F1 hybrids have been reported and they are allotriploids, which show very low fertility (Baranger et al. , 1995; Chèvre et al. , 1996; Chèvre et al. , 1998; Darmency et al , 1998; Kerlan et al ., 1992; Pinder et al. , 1999; Thalmann et al. , 2001; Warwick, 2009). F1 hybrids also commonly show decreased fitness in terms of reduced seedling emergence, a significant emergence delay, and lower survival rate than both parents. (Guéritaine et al. , 2003).

Rorippa islandica

Although intergeneric hybridization between R. islandica and B. napus is possible (Bijral and Sharma, 1995), the distribution of this species in the U.S. is restricted to Washington D.C. (USDA Plants Database, 2010) therefore the potential for gene flow and hybridization is negligible.

Sinapis arvensis

S. arvensis occurs throughout the U.S. (USDA Plants Data base, 2010) and is a weed frequently found in canola fields in weed surveys (Zollinger et al. , 2003). However, greenhouse studies conducted by Moyes et al. (2002) have confirmed the low pr obability of hybridization between B. napus and S. arvensis. Low frequencies (<0.00003%) of hybrids were obtained when S. arvensis was the receptor (female) (Lefol et al. , 1996). Although a low level of inters pecific crosses could occur (Leckie et al. , 1993), the likelihood of gene flow between B. napus and S. arvensis is extremely remote, and there is general agreement that no gene introgression will occur (Bing et al. , 1991; Downey, 1999; Eber et al. , 1994). Hybrids obtainedPioneer Hi-Bred International, Inc. Page 90 of 167 73496 Canola

between S.arvensis and B. napus (Moyes et al. , 2002) had greatly reduced fertility or were completely sterile (Andersson and de Vicente, 2010).

Other Highlighted Species

Of the remaining highlighted species (Table 26), C. monesis occurs in CA and the eastern U.S. in states with very limited canola production (USDA Plants Database, 2010). B. elongata is present in CO, NV, and OR, and S. orientale occurs in the southwestern U.S. (USDA Plants Database, 2010). Crosses between B. napus and a number of species belonging to other genera have been attempted using artificial hybridization methods, but the cros ses either failed or resulted in pa rtially or completely sterile F1 progeny. Among those species are: Diplotaxis erucoides, Diplotaxis t enuifolia, Eruca vesicaria (E. sativa), Erucastrum gallicum, Rapistrum rugosum, Sinapis alba, Sisymbrium orientale (Andersson and de Vicente, 2010).

Related Weeds Frequently Found in Agricultural Fields

In addition to examination of geographic range and likeli hood of hybridization, it is important that abundance of weed species in agricultural fields is considered in the risk assessment. Weed abundance in agricultural fields is partially determined by cr op production practices, an d weed species prominence can be significantly impacted by cropping systems and cultivation practices (CFIA, 1994). In North Dakota weed surveys, some Brassicaceae we ed species that are frequently found include Thlaspi

arvense , Descurainia sophia, and Descurainia pinnata (Zollinger et al. , 2003)

. The probability of hybridization and gene flow to these species is unknown.

D6. Conclusions on the Potential Plant Pest Risk of 73496 Canola

73496 canola does not pose a plant pest risk. The GAT4621 protein and its source organism, B. licheniformis , are familiar and have a history of safe use. The transgenic DNA in 73496 canola is as safe for consumption as any other DNA. B. napus is not considered a noxious or invasive weed in the U.S. Although it does demonstrate some weedy characteristics, canola has undergone many years of selective breeding and domestication and is a poor competitor wi th other species. In addition, the agronomic characteristics and germination data for 73496 canol a demonstrated no change that would allow for development of weedy characteristics differ ent from other canola varieties. The gat4621 gene does not provide a selective advantage in unmanaged ecosystems, rather only in settings where glyphosate is being applied for weed control. Other commercially available herbicides, such as glufosinate or imidazolinones, as well as mechanical means can be used in crop settings for volunteer control.

Gene flow from 73496 canola was evaluated thoroughly with respect to plant pest risk. Although crops and certain wild/weedy relatives have exchanged genes for centuries, the concern with genetically modified crops is that the acquisition of transgenes may increase the fitness of recipient plants (Ellstrand et al. , 1999; Ellstrand, 2003b) and the potential weediness or invasiveness in the crop itself or in its wild or weedy relatives as a result of transgene movement (Warwick et al. , 2009). Successful hybridization of B. napus and a wild/weedy relative is hi ghly unlikely. However, should su ch unlikely events of successful hybridization and stable introgression of the gat 4621 gene from 73496 canola into wild/weedy relative populations occur, the herbicide-tolerance trait woul d only provide selective advantage in situations in which the weedy hybrid was in contact with the herbicide ( i.e. , in an agricultural field).

The introduced gat4621 gene in 73496 canola did not change the ab ility of the plant to interbreed with other plant species. Furthermor e, the evaluation of agronomic and phenotypic properties of 73496 canola, including those characteri stics associated with reproducti ve biology, indicated no unintended changes likely to affect the potential for gene flow from 73496 canola to sexually compatible species.

The consequences of gene flow and introgression of the glyphosate-tolerant trait from 73496 canola to the same or sexually compatible species is antic ipated to be the same as for existing commercial glyphosate-tolerant canola varieties. If glyphosate-tolerant individuals arise through interspecific or intergeneric hybridization, the to lerance will not confer any competitive advantage to these plants unlessPioneer Hi-Bred International, Inc. Page 91 of 167 73496 Canola

selected by glyphosate herbicide. This would only occur in managed ecosystems where glyphosatecontaining herbicides are applied for broad-spectrum weed control, or in plant varieties developed to exhibit glyphosate tolerance and in which glyphosate is used to control weeds. As with glyphosatetolerant canola volunteers, these in dividuals, should they arise, woul d be controlled using other available chemical or mechanical means.

Although gene flow from 73496 canola to relatives is pos sible, it will not result in increased weediness or invasiveness of these relatives based on the agronomic and ecological assessments (Section VII; Appendix 5). Large-scale cultivation of herbicide-t olerant canola has occurred for nearly 15 years in Canada and the United States. To date, there are no reports of problems with interspecific crosses and introgression of herbicide-tolerant genes into cultiv ated or wild relatives of canola (Andersson and de Vicente, 2010).Pioneer Hi-Bred International, Inc. Page 92 of 167 73496 Canola

Appendix 1. Materials and Methods for Genetic Characterization of 73496 Canola

1.1. Southern Blot Characterization of 73496 Canola

Southern blot analysis was conducted to characterize the DNA insertions in 73496 canola. Individual plants of the T2, T3, T3F2, T3F3, and F1 *2 generation were analyzed by Southern blot to determine the number of each of the genetic elemen ts of the expression cassette that were inserted and to verify that the integrity of the PHP28181A fragment was maintain ed upon integration. The integration patterns of the insertion in 73496 canola was investigated with Nco I and Ssp I restriction enzymes. Southern blot analysis was conducted on individual plants of the fi ve generations to confirm stability of the insertion across generations and to verify the absence of backbone sequences from plasmid PHP28181.

1.1.1. Test Material

Seeds from the T2, T3, T3F2, T3F3, and F1 *2 generations of 73496 canola were planted and leaf tissue harvested from individual plants was used for genomic DNA extraction.

1.1.2. Control Material

Seeds from the unmodified canola varieties 18 22B, 1822R, and 6395B were planted and leaf tissue harvested from individual plants was used for genomic DNA extraction.

1.1.3. Reference Material

Plasmid DNA from PHP28181 was prepared from E. coli (Invitrogen, Carlsbad, CA) and was used as a positive control for Southern blot anal ysis to verify probe hybridization and to verify sizes of fragments internal to the plasmid. The plasmid stock was a copy of the plasmid used for transformation to produce 73496 canola and was digested with restriction enzymes to confirm the plasmid map. The probes used in this study were derived from plasmid PHP28181 or from a plasmid containing equivalent genetic elements.

DNA molecular weight markers for gel electrophoresi s and Southern blot analysis were used to determine approximate molecular weights. Fo r Southern analysis, DNA Molecula r Weight Marker VII, digoxigenin (DIG) labeled (Roche, Indianapolis, IN), was used as a size standard for hybridizing fragments. Φ X174 RF DNA/ Hae III Fragments (Invitrogen, Carl sbad, CA) was used as a mole cular weight standard to determine sufficient migration and sepa ration of the fragments on the gel.

1.1.4. Genomic DNA Extraction

Genomic DNA was extracted from leaf tissue harvested from individual plants as described above. The tissue was pulverized in tubes containing grinding beads using a Geno/GrinderTM (SPEX CertiPrep, Inc., Metuchen, NJ) instrument and the genomic DNA was isolated using a urea-based procedure (modification from Chen and Dellaporta, 1994). Approximately 1 gram of ground tissue per sample was extracted with 5 ml Urea Extraction Buffer (7 M urea, 0.34 M NaCl, 0.05 M Tris-HCl, pH 8.0, 0.02 M EDTA, 1% N-lauroylsarcosine) for 15-18 minutes at 37  C, followed by two extractions with phenol/chloroform/isoamyl alcohol (25:24:1) and one extraction with water saturated chloroform. The DNA was precipitated from the aqueous phase by the addition of 1/10 volume of 3 M NaOAc (pH 5.2) and 1 volume of isopropyl alcohol, followed by centrifugati on to pellet the DNA. After washing the pellet twice with 70% ethanol, the DNA was dissolved in 0.5 ml distilled water and treated with 10  g ribonuclease A for 15 minutes at 37  C. The sample was then washed with 70% ethanol. After drying, the DNA was redissolved with 0.5 ml distilled water and stored at 4  C.Pioneer Hi-Bred International, Inc. Page 93 of 167 73496 Canola

1.1.5. Quantitation of Genomic DNA

Following extraction, the DNA samples were quantified on a spectrofluorometer using PicoGreen® reagent (Molecular Probes, Inc., Eugene, OR) fo llowing a standard procedure. The DNA was also visualized on an agarose gel to confirm quantitation values from the PicoGreen® analysis and to determine DNA quality.

1.1.6. Identification of the 73496 Canola Plants Used for Southern Blot Analysis

Phenotypic analysis of 73496 canola plants and control plants was carried out by the use of lateral flow devices able to detect the GAT4621 protein to confir m the absence or presence of the GAT4621 protein in material used for Southern blot analysis.

Leaf extract were prepared by gri nding leaf punches to homogeneity in 400 μl of SEB6 extraction buffer (Agdia, Inc., Elkhart, IN). Lateral flow devices (Agdia) were placed in the homogenate and allowed to develop. After incubation, the result s were read from the lateral flow devices. A single stripe indicated a negative result and a double stripe indicated the samp le was positive for the GAT4621 protein.

Genotypic analysis of the 73496 canola and cont rol canola plants was carried out by real-time polymerase chain reaction (PCR) using assays specific for the DNA insertion. A leaf sample was taken from each test and control plants for event-specific PCR analysis. DNA was extracted from each leaf sample using the Extract-N-AmpTM Plant PCR kit using the described procedure (Sigma-Aldrich, St. Louis, MO).

Real-time PCR was performed on each DNA samp le utilizing an ABI PRISM  7500 Fast Real-Time PCR System (Applied Biosystems, Inc., Foster City, CA). TaqMan ® probe (Applied Biosystems, Inc.) and primer sets (Integrated DNA Technologies, Coralville , IA) were designed to detect target sequences from the insertion in 73496 canola. In addition, a second TaqMan ® probe and primer set for a reference canola endogenous gene was used to confirm the presence of amplifiable DNA in each reaction. The assay analysis consisted of real-time PCR determination of qualitative positive/negative calls. The extracted DNA was assayed using TaqMan ® Universal PCR Master Mix, No AmpErase ® UNG (Applied Biosystems, Inc.). Initial incubation was at 95  C for 10 minutes followed by 40 cycles as follows: 95  C for 15 seconds, 60  C for one minute.

Positive or negative determination for each plant was based on comparison of the threshold cycle (C T ) of the insertion target PCR to that of the canola endogenous reference target. If the event-specific and endogenous PCR targets amplified above C T , then the plant was scored as positive for the DP-Ø73496-4 event. If the endogenous target amplified and the ev ent target did not, then the plant was scored as negative. For all assays, if neither target amplifi ed for a particular sample, it was determined to be a poor quality sample or failed run and the assay was repeated.

A subset of 73496 canola plants that were identified as containing the inserted DNA and expressing the GAT4621 protein from the five generations described pr eviously were selected for Southern blot analysis.

1.1.7. Digestion of DNA for Southern Blot Analyses

Genomic DNA samples extracted from selected 73496 canola and control canola plants were digested with restriction enzymes following a standard procedure. Approximately 4  g of genomic DNA was digested using 20-50 units of enzyme according to manufacturer’s recommendations. The digestions were carried out at 37  C for approximately three hours, followed by ethanol precipitation with 1/10 volume of 3 M NaOAc (pH 5.2) and 2 volumes of 100% ethanol. After incubation at ≤ -5  C and centrifugation, the DNA was allowed to dry and then re-dissolved in TE buffer (10mM Tris, 1 mM EDTA, pH 7.5). The reference plasmid, PHP28181, was spiked into a control plant DNA sample in an amount equivalent to approximately one or three gene copies per canola genome and digested with the same enzyme to servePioneer Hi-Bred International, Inc. Page 94 of 167 73496 Canola

as a positive control for probe hybridization and to veri fy sizes of fragments internal to the plasmid on the Southern blot.

1.1.8. Electrophoretic Separation and Southern Transfer

Following restriction enzyme digestion, the resultant DNA fragments were electrophoretically separated by size through an agarose gel. A molecular weight standard [ Φ X174 RF DNA/ Hae III Fragments (Invitrogen)] was used to determine sufficient migration and separation of the fragments on the gel. DIG labeled DNA Molecular Weight Marker VII (Roche), which is visible after DIG detection as described below, was used to determine hybridizing fragment size on the Southern blots.

Agarose gels containing the separated DNA fragme nts were depurinated, den atured, and neutralized in situ , and transferred to a nylon membrane in 20x SSC bu ffer (3M NaCl, 0.3 M sodium citrate) using the method as described for the TURBOBLOTTERTM Rapi d Downward Transfer System (Whatman, Inc., Piscataway, NJ). The DNA was then bound to t he membrane by UV cross linking (Stratalinker, Stratagene, La Jolla, CA).

1.1.9. DNA Probe Labeling for Southern Blot Hybridization

Probes for the UBQ10 promoter, gat4621 , and pin II terminator were used to detect genes and elements within the insertion. Probes covering the backbone region of plasmid PHP28181 were used to verify absence of plasmid backbone DNA in 73496 canola. DNA fragments of the probe elements were generated by PCR from plasmid PHP28181 or a plasmid with equivalent elements using specific primers. PCR fragments were electrophoretically separated on an agarose gel, excised and purified using a gel purification kit (Qiagen, Valencia, CA). DNA prob es were generated from these fragments by PCR that incorporated a DIG labeled nucleotide, [DIG-11]-d UTP, into the fragment. PCR labeling of isolated fragments was carried out according to the proced ures supplied in the PCR DIG Probe Synthesis Kit (Roche).

1.1.10. Probe Hybridization and Visualization

Labeled probes were hybridized to the target DNA on the nylon membranes for detection of the specific fragments using the procedures essentially as described for DIG Easy Hyb solution (Roche). After stringent washes, the hybridized DIG-labeled probes and DIG-labeled DNA standards were visualized using CDP-Star Chemiluminescent Nucleic Acid Dete ction System with DIG Wash and Block Buffer Set (Roche). Blots were exposed to X-ray film for one or more time points to detect hybridizing fragments and to visualize molecular weight standards bound to the nylon membrane. Images were digitally captured by detection with the Luminescent Image Analyzer LAS- 3000 (Fujifilm Medical Systems, Stamford, CT). Digital images were compared to original X-ray film ex posures as verification for use in this submission. The sizes of detected bands were documented for each digest and each probe.

1.1.11. Stripping of Probes and Subsequent Hybridizations

Following hybridization and detection, membranes were stripped of DIG-labeled probe to prepare the blotfor subsequent re-hybridization to additional probes. Membranes were rinsed briefly in distilled, deionized water and then stripped in a solution of 0. 2 M NaOH and 0.1% SDS at 37°C with constant shaking. The membranes were then rinsed in 2x SSC and used directly for subsequent hybridizations. The alkali-based stripping procedure effectively re moves probes labeled with the alkali-labile DIG.Pioneer Hi-Bred International, Inc. Page 95 of 167 73496 Canola

1.2. Mendelian Inheritance and Genetic Stability of the Trait in 73496 Canola

Inheritance of the inserted DNA and the herbicide-t olerance phenotype in 73496 canola was evaluated to ensure stability of the trait during the plant breeding process and to confirm the trait was at a singlegenetic locus. A phenotypic and genotypic analysis of individual plants of segregating and nonsegregating generations was conducted. The pr esence of the DP-Ø73496- 4 event insertion was determined by event- and gat4621 gene-specific endpoint PCR analysi s performed on leaf punches from seedlings of each generation. Plant phenotypic anal ysis was conducted by treating the plants with herbicide and determining the level of herbicide injury to the plants.

1.2.1. Test Material

One-hundred plants from segregating gener ations of 73496 canola (T3F2, BC1F1 *1,*3 , BC2F1 *1,*3 , and BC3F1 *1,*3 ) and one non-segregating generation (F1 *1,*3 ) were evaluated. The breeding history of these five generations is shown in the bree ding diagram in Section III-A, Figure 2. Those populations with the superscript “*1,*3” designation were pooled populatio ns from two different genetic backgrounds (Section III-A, Figure 2). The plants from the T3F2 generati on were expected to segr egate 3:1 (positive:negative for the presence of the inserted DNA and the herbi cide-tolerance phenotype), and the plants from the BC1F1, BC2F1, and BC3F1 generations were expected to segregate 1:1 (posit ive:negative). Leaf tissue samples were collected for conducting the genotypic analysis described below.

1.2.2. Genotypic Analysis

Leaf punch samples collected from 73496 canola plan ts were analyzed using qualitative endpoint PCR analysis to confirm the presence or absence of the DP-Ø73496-4 event insertion and the gat 4621 gene.

The PCR results for one 73496 canola plant (generation T3F2) were inconclusive and the plant had already been discarded so no plant material was available for retesting; therefore, the PCR results for this plant was not included in subsequent statistical analysis.

1.2.3. Phenotypic Analysis

After sample collection, all plants were treated wi th a mixture containing the herbicide Touchdown HiTech a (Syngenta Crop Protection, Inc., Greensboro, NC), non-ionic surfac tant, and ammonium sulfate. Glyphosate constitutes 52.3% (by weight) of Touchd own HiTech in the form of a monopotassium salt, equivalent to 5 pounds glyphosate acid equivalents per gallon (0.6 kilograms glyphosate acid equivalents per liter). The spray mixture was applied at an approxim ate rate of 16 fluid ounces per acre (1.2 liters per hectare) of Touchdown HiTech, 3.5 pounds per acre (3 .9 kilograms per hectare) of ammonium sulfate, and 0.25% (by volume) of non-ionic surfactant per volume of spray solution. Spray volume was approximately 23 gallons per acre (215 liters per hectare).

Each plant was visually evaluated 9 days after herb icide application for the presence of herbicide injury, and was identified as presenting an herbicide-tolerant phenotype (plant exhibited no herbicidal injury) or an herbicide-susceptible phenotype (pla nt exhibited severe herbicide injury). After herbicide injury evaluation, all plants were discarded.

1.2.4. Statistical Analysis of Trait Inheritance Data

Statistical analyses were conducted using SAS software, Version 9. 2 (SAS Institute, Inc., Cary, NC). A Pearson’s chi-square ( χ 2 test at 95% confidence) was conduc ted for each segregating generation of 73496 canola to determine the goodness-of-fit of the observed segregation ratio to the expected segregation ratio. This value was not calculated fo r the non-segregating populat ions. The Pearson test statistic was conducted separately for both the genotypic ( i.e. , PCR) results and phenotypic ( i.e.

, herbicide tolerance) results, and was computed using the following equation:

a Registered trademark of a Syngenta Group CompanyPioneer Hi-Bred International, Inc. Page 96 of 167 73496 Canola

2 2
2 

### ( )( ) pos pos neg neg

pos neg 

### OE OE

E E     

Where O pos denotes the total observed positive frequencies, E pos denotes the total expected positive frequencies, O neg denotes the total observed negative frequencies, E neg denotes the total expected negative frequencies, and χ 2 follows a chi-square distribution with one degree of freedom (df).

A chi-square value >3.84 ( χ 2 (df=1)) has a P-value <0.05 and indica tes a significant difference between the observed and expected frequencies. A chi-square value ≤ 3.84 ( χ 2 (df=1)) has a P-value ≥ 0.05 and indicates that the observed data can be interpre ted as consistent with the expected ratio.Pioneer Hi-Bred International, Inc. Page 97 of 167 73496 Canola



### Appendix 2. Description of Statistical Analyses Performed for Agronomic and Nutrient Composition Data

2.1. Statistical Analysis of Germination Data

Statistical analyses were conducted to evaluate and compare germination rates of 73496 canola and a near-isoline control canola using version 9.1 of SAS b software (SAS Institute, Inc., 100 SAS Campus Drive, Cary, NC 27513, USA). Statistical analyses were conducted separately for each of three germination tests (warm, cold, and diurnal).

2.1.1. Mixed Model for Statistical Analysis

For a given germination test, data were analyzed us ing a Generalized Linear Mixed Model (GLMM), assuming Binomial distribution with the “logit” link function:

GLMM model on the linear predictor scale:  ij =  i + r j(i) Model 1

r j(i) iid ~ N(0,  2 R )

where μ i denotes the mean response for the i th entry (fixed effect) and r j(i) denotes the effect of the j th replication within the i th entry (random effect nested within fixed effect), and iid denotes independently and i dentically distributed.

Binomial Distribution: y ij | r

j(i) ~ Binomial ( n ij ,  ij )

where y ij denotes the number of germinated seed in the j th replication of the i th entry, j = 1, 2, ..., 8 (each replication contained a total of 46~72 seed), n ij denotes the total number of seed in the j th replication of the i th entry, and 

###  ij denotes the probability of a seed being germinated in the j th replication of the i th entry.

“Logit” link function: 

### logit( ) log 1 ij ij ij ij 

###      

     

  

which transformed the parameter  ij into a linear predictor, denoted as n ij . Logit link is default for Binomial data.

2.1.2. Least Squares Mean (LS-Mean) Calculations

For a given germination test, the mean (i.e. least squares mean, also referred to as LS-Mean) value and standard error was estimated from Model 1 fo r each of 73496 canola and the control canola.

2.1.3. Statistical Comparisons and Interpretations

To test for differences in LS-Mean values between 73496 canola and the control canola, a p-value was calculated for each germination test. For a given comparison, a p-value of < 0.05 was considered to indicate a significant difference.

2.2. Statistical Analyses of Agronomic Characte ristic, Yield, and Nutrient Composition Data

Statistical analyses were conducted to evaluate and compare agronomic characteristics and yield of 73496 canola and near-isoline control canola across seven sites during the 2008 growing season (referred to as Experiment A), and across three site s during the 2009 growing season (referred to as Experiment B). Statistical analyses were also conduc ted to evaluate and compare nutrient composition of seed derived from 73496 canola and near-isoline control canola across six sites during the 2009 growing

season.

b Registered trademark of the SAS Institute, Inc.Pioneer Hi-Bred International, Inc. Page 98 of 167 73496 Canola

Analysis was conducted separately for each study using SAS software (version 9.1 of SAS was used for analysis of Experiment A, and version 9.2 was used for Experiement B and the nutrient composition data). Days to maturity data were not collected at one site and early growth data were not collected at four sites for Experiment A. Yield data collected at one site were not included in the respective analysis for Experiment B.

2.2.1. Mixed Models for Across Sites Analysis

Default Model

For a given agronomic characteristic or composit ion analyte, data were analyzed using the following linear mixed model:

y

ijk

= μ i + l j + r k(j) + ( μl

) ij

+ ε ijk Model 2

l j ~ iid N(0, σ 2 Site ), r k(j) ~ iid N(0, σ 2 Rep ), ( μl

) ij

~ iid N(0, σ 2 Ent×Site ), and ε ijk

~ iid N(0, σ 2 Error )

where μ i denotes the mean of the i th entry (fixed effect), l j denotes the effect of the j th site (random effect), r k(j) denotes the effect of the k th block within the j th site (random effect), ( μl

) ij denotes the interaction between the entries and sites (random effect) and ε ijk denotes the effect of the plot assigned the i th entry in the k th block of the j th site (random effect or residual). Notation ~ iid N(0, σ 2
a

) indicates random variables that are identically independently distributed ( iid ) as normal with zero mean and variance σ 2
a . Residual maximum likelihood (REML) estimation procedure was used to generate estimates of variance components, and entry means (i.e. LS-Means) across sites were then estimated with standard errors.

Model Allowing Negative Covariance

When the REML estimate for the entry by site variance component σ 2 Entry×Site from Model 2 was zero, the random part of the mixed model was changed to a compound symmetry (CS) model that allows for negative covariance (Littell et al ., 2006).

y

ijk

= μ i + l j + r k(j) + ε ijk Model 3

l j ~ iid N(0, σ 2 Site ), r k(j) ~ iid N(0, σ 2 Rep )

In the CS model, the residual variance structure for the ij th entry by site combination is defined as:



###    

 

   

 



1 ...

... ... ... ...

... 1

... 1

) ( 2 

###  

 

    CS

ij 

### V

where ε ij = [ ε ij1 ε ij2 ... ε ijK ] is defined as the vector of residuals for the i th entry at the j th site, σ 2 CS denotes the residual variance in the CS structure and 

 denotes the correlation between residuals for the same entry at the same site,  = Cov( ε ijk , ε ijk’ )/ σ 2 CS.
REML estimation procedure was used to generate es timates of variance and covariance components, and entry means (i.e. LS-Means) across sites were then estimated with standard errors.Pioneer Hi-Bred International, Inc. Page 99 of 167 73496 Canola

Model Considering Lower Limit of Quantification (LLOQ)

For the analytes copper, glucoalyssin, gluconapolei ferin, glucoraphanin, and neoglucobrassicin, somesample values were below the assay LLOQ. Sample results below the LLOQ were treated as leftcensored observations at the respective assay LLOQ value. Data were analyzed using the following linear mixed model:

y

ijk

= μ i + l j + r k(j) + ( μl

) ij

+ ε ijk Model 4

l j ~ iid N(0, σ 2 Site ), r k(j) ~ iid N(0, σ 2 Rep ), ( μl

) ij

~ iid N(0, σ 2 Entry×Site ), ε ijk

~ iid N(0, σ 2 Error )

Where μ i denotes the mean of the i th entry (fixed effect), l j denotes the effect of the j th site (random effect), r k(j) denotes the effect of the k th block within the j th site (random effect), ( μl

) ij denotes the interaction between the entries and sites (random effect) and ε ijk denotes the residual for the observation ob tained from the plot assigned to the i th entry in the k th block of the j th site.

The conditional likelihood for each observation, giv en the random effects, was formulated according to the status of the observation (i.e. observed or left-censored) (Thiébaut and Jacqmin-Gadda, 2004):



###       

     

 


censored left c c y P observed y y y P

y f

ijk ijk ijk ijk ijk ijk

ijk 

### ) ( ) ( ) ( ) ( ) | ( *

*



###      

Where  denotes the vector of all random effects,  ijk denotes the mean of y ijk ,  denotes the standard normal density function,  denotes the standard normal cumu lative distribution function, y * ijk

denotes the observed sample value of
y

ijk , and c denotes the assay LLOQ value.

The conditional likelihood function is a product of all individual conditional likelihoods, and the marginal likelihood function is formed when the conditional likeli hood function is integrated over all random effects. Maximum likelihood (ML) procedure was then used to generate estimates of variance components and entry means (i.e. LS-Means) across sites.

2.2.2. Least Squares Mean (LS-Mean) and Confidence Interval (CI) Calculations

For each agronomic characteristic or composition an alyte, the LS-mean value across sites was estimated from the corresponding statistical model for herbicide-tr eated 73496 canola and the control canola. The 95% CI for each of the entry means was formed by:

LS-Mean ± t 0.975, v × standard error of LS-Mean

where t 0.975 , v denotes the upper 0.025 percentage point of a t-distribution with v degrees of freedom. The degrees of freedom were determined by Kenward-Roger method (Kenward and Roger, 1997).

2.2.3. Statistical Comparisons and Interpretations

The first step in the evaluation was to test for di fferences in LS-Mean values between herbicide-treated 73496 canola and the control canola. The FDR method of Benjamini and Hochberg (Benjamini and Hochberg, 1995; Westfall et al. , 1999) was applied as a post-hoc procedure to account for multiple comparisons due to multiple endpoints (i.e. agrono mic characteristics or composition analytes) and p-values were adjusted accordingly. Significant differences were established if an adjusted p-value <0.05.

For nutrient composition analytes where a statisticall y significant difference (adjusted p-value <0.05) was identified in the across sites analysis, the respecti ve range of individual values was compared to aPioneer Hi-Bred International, Inc. Page 100 of 167 73496 Canola

tolerance interval. Tolerance intervals containing 99% of the values for corresponding analytes of the conventional canola population with 95% confiden ce level (Graybill, 1976) were derived from data collected from seven conventional (i.e. non-modified) comm ercial canola lines grown at five field locations in canola-growing areas of the U.S. and Canada over two growing seasons. The selected canola lines represent non-modified canola population with a histor y of safe use, and the selected environments (i.e. site and year combinations) represent canola growth under a wide range of environmental conditions (i.e. soil type, temperature, precipitation, and i rrigation) and canola maturity group zones.

2.3. Special Considerations

2.3.1. Agronomic Data Considerations

Plant Height

Plant height was measured on 10 plants per plot. Pl ot average (i.e. average of 10 plants) was treated as the response for the across sites analysis.

2.3.2. Nutrient Composition Data Considerations

Transformation

A natural logarithmic “ln(y)” transformation was perf ormed for the raw data of all nutrient composition analytes before statistical analyses. For each analyte, residuals from the across sites analysis were examined for validation of the normality and constant variance assumptions. The assumptions were reasonably satisfied for most analytes after “ln(y)” transformation.

For the analyte tryptophan, residual distribution sk ewed to the left and therefore, a square “(y) 2 ” transformation was performed to the raw data instead. The model assumptions were reasonably satisfied for this analyte after “(y) 2 ” transformation.

The statistical comparisons were conducted based on the transformed data. The estimated mean values and the confidence limits were then ba ck-transformed to the original data scale for reporting purposes.

Fatty Acids

For some fatty acids analytes, absolute sample values were detected below the assay LLOQ. When sample values were converted from absolute values to relative propor tions (i.e. percent of total fatty acids), sample results that were below the LLOQ were assigned a zero value to reflect a negligible proportion. However, these zeros were not “true” zeros, but were some unknown small positive values. Even though the origination of these zero values was the LLOQ values, it was not straight-forward to determine an LLOQ value on the relative proportion scal e for each analyte. Therefore, Model 4 was not used to analyze fatty acids analytes with zero values ; instead it was deemed appropriate to treat these zero sample values as missing values and analyze the non-missing data using Model 2 or Model 3.

Partial LLOQ Sample Values

For a given analyte (including non-fatty acids and fatty acid analytes), the number of samples below the assay LLOQ value determined whether a statistical analysis was conducted. The following rules were implemented.



###  If < 80% of samples for each entry were below t he LLOQ, then statistical analysis was conducted using the appropriate mixed model.

 If ≥ 80% of samples for a single entry within t he study were below the LLOQ, then mixed model across sites analysis was not conducted. Howe ver, if the numbers of samples below the LLOQ were not even between the control canola and herbicide-treated 73496 canola, such observationPioneer Hi-Bred International, Inc. Page 101 of 167 73496 Canola

would be discussed. Descriptive statistics (i.e. arithmetic means and ranges) were calculated for analytes that were not statistically analyzed using mixed model analysis.

2.4. SAS Procedures

SAS PROC GLIMMIX was used to fit Model 1, SAS PROC MIXED was used to fit Model 2 and Model 3, and SAS PROC NLMIXED was used to fit Model 4. A ll three procedures gene rated LS-Means and 95% confidence interval s, and provided statistical comparisons (i .e. p-values). SAS PROC MULTTEST was used to provide adjusted p-values.Pioneer Hi-Bred International, Inc. Page 102 of 167 73496 Canola



### Appendix 3. Materials and Methods for Determination of GAT4621 Protein Concentrations

Plant tissue concentrations of the GAT4621 pr otein were determined using enzyme-linked immunosorbent assays (ELISA) developed at Pioneer Hi-Bred International, Inc., Johnston, IA, USA.

3.1. Plant Material

73496 canola plants of the F1 *4 generation (refer to Section III-A, Figure 2), plus near-isoline control canola plants, were grown concurrently at six field trial locations near: Portage la Prairie, MB; Saskatoon, SK (grain samples not included from this site); Mint o, MB; Elm Creek, MB; Ephrata, WA; and Velva, ND. Trials were planted in a randomized complete block de sign containing four blocks per treatment and were managed according to standard local agronomic prac tices, with the exception that the 73496 canola plants were treated with two applicat ions of glyphosate herbicide (Touchdown HiTech®), at the first true leaf stage and the five-leaf stage, respectively. Pl ant tissue samples were collected from impartially selected, healthy individual plants from each block at the following growth stages:

 BBCH15 – five true leaves unfolded (whole plant sample)

 BBCH33 – three visibly extended internodes (whole plant sample)

 BBCH65 – full flowering; 50% of flowers open on main raceme, older petals falling (whole plant and root samples)

 BBCH90 – senescence (seed sample)

3.2. Storage and Processing of ELISA samples

After collection, tissue samples were shipped overnigh t on dry ice to Pioneer Hi-Bred International, Inc. Whole plant samples, which comprised the entire ab ove-ground portion of the plant, were coarsely homogenized and all samples (whole plant, root, and seed) were lyophilized, and then finely homogenized and stored frozen ( ≤ -10oC).

3.3. Protein Extraction from Ground Canola Tissues

Lyophilized, ground tissue samples were weighed into 1. 2-ml tubes at the following target weights: 15 mg for whole plant, and 20 mg for root and seed. Each sample was extracted with 0.6 ml of chilled H5 buffer solution (90 mM HEPES pH 7.6, 140 mM NaCl, 1% PVP- 40, 0.3% Tween-20, 1% bovine serum albumin, 1% polyethylene glycol, and 0.007% Thimerosal), centri fuged, and the supernatants removed, diluted, and analyzed.

3.4. Determination of GAT4621 Protein Concentrations

Sample extracts were quantitatively analyzed fo r GAT4621 by sequential dou ble-antibody sandwich ELISA using antibodies specific for the GAT protein. Standards (analyzed in triplicate wells) and diluted sample extracts (analyzed in duplicate wells) were incubated in a plate pre-coated with GAT-specific antibody. Following incubation, unbound substances were washed from the plate. A different GATspecific antibody conjugated to the enzyme horsera dish peroxidase (HRP) was added to the plate and incubated. Unbound substances were washed from the plate leaving the bound GAT4621 protein “sandwiched” between the antibody coated on the pl ate and the antibody-HRP co njugate. Detection of the bound GAT4621-antibody complex was accomplished by the addition of substrate, which generated a colored product in the presence of HRP. The reacti on was stopped with an acid solution and the optical density (OD) of each well was determined using a plat e reader. An average of the results from duplicate wells was used to determine the concentration of the GAT4621 protein in ng/mg sample weight.Pioneer Hi-Bred International, Inc. Page 103 of 167 73496 Canola

SoftMax c Pro software (Molecular Devices Corporation, Sunnyvale, CA) was used to perform the calculations required to convert the OD values obta ined by the microtiter plat e reader to tissue protein concentrations. A standard curve was included on ea ch ELISA plate. The equat ion for the standard curve was generated by the software, which used a quadratic fit to relate the mean OD values to the respective standard concentrations (ng/ml).

Lower limits of quantification (LLOQ) by ELISA were established with each sample matrix and were 0.29 ng/mg dry weight for whole plant samples, and 0.22 ng /mg dry weight for root and seed samples. For each plant tissue type and growth stage, levels of GAT4621 protein in samples from control plants were below the LLOQ.

c Registered trademark of Molecular Devices CorporationPioneer Hi-Bred International, Inc. Page 104 of 167 73496 Canola



### Appendix 4. Characterization of the Plant-Expressed and Microbial-Expressed GAT4621 Proteins

4.1. Characterization of the Plant-Expressed GAT4621 Protein

Physicochemical characterization of the GAT4621 pr otein isolated from 73496 canola was conducted in order to demonstrate equivalence to the microbial-expre ssed form of the protein used in acute toxicity testing and digestibility studies previously c onducted for maize event DP-Ø9814Ø-6. This characterization of in planta expressed GAT4621 protein from 73496 canola included: molecular weight and immunochemical cross-reactivity by SDS-PAGE a nd western immunoblot analysis; N-terminal amino acid sequencing; and tryptic peptide mapping by MA LDI-MS. In addition, the GAT4621 protein from 73496 canola was analyzed for glycosylation as part of the weight of evidence for assessing the potential allergenicity.

In the case of the N-terminal amino acid sequ encing and tryptic peptide mapping by MALDI-MS, data obtained previously for the microbial-expressed GAT4621 were used for comparison to the characterization of the GAT4621 protein from 73496 canola.

Utilizing these analyses, the equivalency of GAT4621 protein expressed in E. coli to the protein expressed in 73496 canola was demonstrated. T herefore, the GAT4621 pr otein derived from the microbial expression system was app ropriate for utilization in safety assessment studies as a proxy for the GAT4621 protein expressed in 73496 canola. In addition, the GAT4621 protein produced in 73496 canola is not glycosylated and supports the weight of evidence assessment that the GAT4621 protein is unlikely to be an allergen.

4.2. SDS-PAGE Analysis of the Plant-Expressed GAT4621 Protein

Analysis of GAT4621 protein isolated from 73496 cano la by SDS-PAGE followed by staining revealed a prominent band with a relative mobility consistent with the GAT4621 molecular weight of 16.5 kDa (Figure 4.1).

Based on this analysis, the approximate size of the pl ant-expressed GAT4621 protein was consistent with the expected theoretical size of the GAT4621 protein.

Figure 4.1. SDS-PAGE Analysis of the Plant-Expressed GAT4621 Protein

A sample of the purified GAT4621 protein (~ 1 μg total pr otein) from 73496 canola (lane 2) was analyzed by SDS-PAGE on 10–20% gradient gels followed by staining with GelCode Coomassie Blue reagent. Molecular weight markers (PageRuler Prestained Protein Ladder) we re included in lane 1. The major band corresponding to the intact size of the GAT4621 protein is indicated.Pioneer Hi-Bred International, Inc. Page 105 of 167 73496 Canola

4.3. Western Immunoblot Analysis of th e Plant-Expressed and Microbial-Expressed GAT4621 Proteins

Western blot analysis of the GAT4621 protein pr epared from 73496 canola revealed a predominant immunoreactive band that co-migrated with the microbial-expressed GAT4621 and corresponded to the molecular weight of 16.5 kDa for the GAT4621 protein (Figure 4.2).

Based on this analysis, the microbial- and the plant -expressed GAT4621 proteins were determined to be equivalent in size and immunoreactivity.

Figure 4.2. Western Immunoblot Analysis of the Plant-Expressed and Microbial-Expressed GAT4621 Proteins

A sample of the GAT4621 protein (~ 10 ng protein estima ted) from 73496 canola (lane 2) and a sample of the microbial-expressed GAT4621 protein (Lot: PCF-0005; ~ 15 ng of purified GAT4621; lane 3) were analyzed by SDSPAGE followed by electroblotting onto polyvinylidene difluoride (PVDF) membrane. The blots were probed sequentially with mouse anti-GAT monoclonal antibody and horseradish peroxidase-conjugated anti-mouse IgG. Blots were then incubated in the presence of a chemilum inescent substrate and the signa l was detected with Fujifilm Luminescent Image Analyzer. Molecular weight markers (PageRuler Prestained Protein Ladder) were included in lane 1. Note: The total protein extract from 73496 canola was loade d in lane 2 and ~ 15 ng of the purified microbialexpressed GAT4621 protein was loaded in lane 3; therefore, t he amounts of the GAT4621 protein in lanes 2 and 3 were not equivalent and the amount of plant-expres sed protein was estimated from the blot image.

4.4. N-Terminal Amino Acid Sequence An alysis of the Plant-Expressed and Microbial- Expressed GAT4621 Proteins

The N-terminal sequence analysis of the GAT4621 pr otein derived from 73496 canola indicated that the primary sequences matched residues 2–14 of the deduced N-terminal sequence of GAT4621 and also matched residues 2-11 of the microbial-expressed protei n (Figure 4.3). In the plant-expressed GAT4621, the lysine signal at position 6 and the aspartic acid signal at position 12, relative to the predicted sequence, were low. The N-terminal methionine residue was not detected, which was consistent with results from MALDI-MS (Applied Biosystems/M DS SCIEX 4800 MALDI-TOF/TOF) tryptic peptide mapping.

Edman sequencing analysis confirmed that the N- terminal sequences of the 73496 canola-derived GAT4621 protein matched both the theoretical protei n sequence as well as the microbial-expressed sequences. These results provided additional eviden ce that the plant- and microbial-expressed GAT4621 proteins are equivalent.Pioneer Hi-Bred International, Inc. Page 106 of 167 73496 Canola

Figure 4.3. N-Terminal Amino Acid Sequence Analysis of the Plant-Expressed and MicrobialExpressed GAT4621 Proteins

A sample of purified GAT4621 protein from 7349 6 canola was analyzed by SDS-PAGE followed by electroblotting onto PVDF membrane. The band corresponding to the GAT4621 protein was excised and subjected to Edman N-terminal sequencing. For the 73496 canola-derived GAT4621 protein, the aspartic acid residue in parentheses at position 12 was assigned based on a low signal. As indicated by X a , position 6 was not assigned due to a low signal. The theoretical and previously determined N-terminal amino acid sequence for microbial-expressed GAT4621 protein are shown for comparison.

4.5. MALDI-MS Identifica tion of Tryptic Peptides

MALDI-MS analysis of the tryptic peptides for GA T4621 isolated from 73496 canola identified 25 unique peptides. Some of the identified peptides had overlapping sequences and several peptides had a cysteine residue modified by propionamide or a methi onine residue modified by oxidation. Overall, the identified peptides accounted for 88.4% (130/147) of the deduced protein sequence for the GAT4621 protein derived from 73496 canola (Figure 4.4). In comparison, 76% of the theoretical protein sequence was represented by uniquely identified tryptic pept ides derived from the microbial-expressed GAT4621 protein. The N-terminal methionine residue was not identified in matching tryptic peptides derived from either plant- or microbial-expressed GAT4621, consist ent with the results from N-terminal amino acid sequencing.

As with the N-terminal sequencing, the analysis of tryptic peptides provides additional evidence of equivalency between the plant- and microbial-expressed GAT4621 proteins.

Figure 4.4. Deduced GAT4621 Amino Acid Sequence Showing Matching Peptides from MALDI-MS

Sequence shown in red correspond to matching tryptic pe ptides identified for the GA T4621 protein isolated from 73496 canola. Sequence shown in red with shading corre spond to matching tryptic peptides identified for the microbial-expressed GAT4621 protein.

4.6. Protein Glycosylation Analysis of the Plant-Expressed GAT4621 Proteins

In order to analyze glycosylation of the plant-expre ssed GAT4621 protein as part of the weight of evidence for protein allergenicity, the GAT4621 prot ein isolated from 73496 canola was analyzed using a glycoprotein staining procedure. Plant-expressed GA T4621 protein did not exhibit positive staining with the glycoprotein staining reagent (Figure 4.5, lane 4, Glycoprotein staining panel), while the positive control horseradish peroxidase was st ained and clearly visible (Figure 4.5., lane 3, Total protein staining panel).Pioneer Hi-Bred International, Inc. Page 107 of 167 73496 Canola

Based on this analysis, the 73496 canola-deri ved GAT4621 protein was determined not to be glycosylated and provided support to the weight of evidence assessment that the GAT4621 protein is unlikely to be an allergen.

Figure 4.5. Glycosylation Analysis of the Plant-Expressed GAT4621 Protein

Samples containing soybean trypsin inhibitor ( ~ 1 μg) as a negative control (lane 2), horseradish peroxidase (~ 1 μg) as a positive control (lane 3), and GAT4621 protein ( ~ 1 μg) isolated from 73496 canola (lane 4) were subjected to SDS-PAGE and analyzed for the presence of carbohydrates using a periodate-acid-Schiff glycoprotein staining reagent (Glycoprotein staining pane l). Following image capture, the same gel was stained with Coomassie Blue to visual all proteins (Total protei n staining panel). Molecular weight markers (PageRuler Prestained Protein Ladder) were included in lane 1.

4.7. Methods for Isolation and Purification of the GAT4621 Protein from Canola Leaf Tissue

The GAT4621 protein was isolated from leaf tissue of greenhouse-grown 73496 canola plants. Each plant was tested to confirm the presence of the in troduced trait by event-specific PCR. Leaves were harvested from plants at the five- to six-leaf stage [ BBCH 15-16] and stored frozen (-80oC) until use.

Approximately 80 g of leaf tissue derived from 734 96 canola was extracted by homogenizing with a Waring blender in 300 ml Buffer A (50 mM HEPES, pH 7.8, 50 mM NaCl, 1 mM EDTA, 5% glycerol, 0.007% thimerosal) containing Complete Protease Inhibi tors (Roche Applied Science, Indianapolis, IN). The homogenate was filtered through four layers of cheese cloth and then centrifuged for 20 minutes at approximately 30,500 g . The clarified extract was subjected to 85% saturated ammonium sulfate precipitation. The precipitated protei ns were resuspended in approximately 60 ml of Buffer A. This sample was then desalted with 10DG columns (Bio-Rad Labo ratories, Hercules, CA) and pre-equilibrated with Buffer B (50 mM MES, pH 7.2, 5% glycerol, 1 mM EDTA). The desalted sample was loaded to an SP Sepharose Fast Flow (GE Healthcare Biosciences, Piscataway, NJ) column (10 ml) equilibrated with Buffer B. The column was washed with the sa me buffer (approximately 50 ml) and then the bound proteins were eluted with a salt gradient (approxi mately 100 ml 0-0.5 M NaCl). The GAT4621 fractions were collected, pooled and diluted (1:1) with Buffer A. GAT4621 protein was further purified with an immuno-affinity column (approximately 3 ml) prepar ed with GAT-specific mouse monoclonal antibody (12C9). The column was sequentially washed with 50 ml each of Buffer A, Buffer C (Buffer A containing100 mM NaCl and 0.2% Triton X-100) and Buffer D (Buffer A containing 100 mM NaCl and 0.4% Triton X100). The bound GAT4621 protein was eluted using I mmunoPure IgG Elution Buffer (Thermo Scientific Inc., Rockford, IL). Fractions we re collected and the protein concentration was estimated by a modified Bradford assay (Coomassie Plus Protein Assay Reagent, Thermo Scientific, Inc.). The collected fractions were analyzed by SDS-PAGE and western blotting with a GAT-specific antibody (18F9) to confirm thePioneer Hi-Bred International, Inc. Page 108 of 167 73496 Canola

presence of the GAT4621 protein. The fraction s containing GAT4621 were pooled and concentrated using Nanosep 3K concentrators (Pall Corporation, Ann Arbor, MI).

4.8. Methods for Isolation and Purification of the Microbial-Expressed GAT4621 Protein

The GAT4621 protein was expressed in E. coli strain BL21(DE3) as a sol uble protein and was purified at Aldveron, LLC (Fargo, ND) using cation exchange chromatography, anion exchange chromatography and hydrophobic interaction chromatography, followed by diafiltration into 0.1 M ammonium bicarbonate, pH 7.8. The purified protein was then lyophilized. Fo r characterization, the GAT4621 protein was used in the following form: 1 mg of the lyophilized powder was dissolved in 1 ml of 100 mM KCl, 10% methanol, and 25 mM HEPES, pH 7.2.

4.9. Methods for SDS-PAGE Analysis

SDS-PAGE was performed by first mixing GAT4621 protein samples with Laemmli sample buffer (NuSep Limited, Frenchs Forest, Australia) containing 100 mM dithiothreitol and heating at 100°C for approximately five minutes. The prepared protein sa mples were loaded into a 10-20% gradient Ready Gel Tris-HCl gel (Bio-Rad Laboratories, Inc., He rcules, CA). PageRuler Prestained Protein Ladder (Fermentas, Inc., Vilnius, Lithuania) molecular weight markers were loaded into the gel to provide a visual estimate of molecular weight. Electrophoresis wa s conducted using the Ready Gel Cell system (Bio-Rad Laboratories, Inc.) with Tris-glycine running buffe r (Fermentas, Inc.) at 150 volts for 60 minutes.

Upon completion of electrophoresis, the gel was re moved from the gel cassette and washed three times with deionized water for five to 15 minutes each. T he gel was then stained for approximately 60 minutes with GelCode Coomassie Blue stain reagent (Thermo Scientific Inc., Rockford, IL), and washed with deionized water at least four times for approximately ten minutes each or until the background of the gel was clear.

4.10. Methods for Western Immunoblot Analysis

GAT4621 protein samples were run by SDS-PAGE as desc ribed in the previous section. The resulting gel was soaked in cathode buffer (60 mM Tris, 40 mM CAPS, 0.1% SDS, pH 9.6) for 10-20 minutes. A polyvinylidene difluoride (PVDF) membrane (Bio-Rad Laboratories, Inc.) was briefly placed in 100% methanol followed by immersion in anode buffer (60 mM Tris, 40 mM CAPS, 15% methanol, pH 9.6) for 10-15 minutes. A Trans-Blot SD Semi-Dry Electropho retic Transfer Cell system (Bio-Rad Laboratories, Inc.) was used to transfer proteins from the gel to the membrane at approximately 120 mA for 30-60 minutes.

Following protein transfer, the membrane was washed f our times for five to ten minutes each in Classic Buffer (50 mM Tris-HCl, pH 7.0, 500 mM NaCl, 0. 5% Tween-20) and then blocked by incubation in phosphate-buffered saline solution with Tween-20 (P BST solution: 8.1 mM phosphate buffer, pH 7.4, 137 mM NaCl, 2.7 mM KCl, and 0.05% Tween-20) containi ng 5% non-fat dry milk for 30-60 minutes. The blocked membrane was washed four times for 5-10 mi nutes each in Classic Buffer and then incubated for approximately 60 minutes with a GA T-specific mouse monoclonal anti body (18F9) diluted 1:8,000 in PBST containing 5% non-fat dry milk . The unbound antibody was removed from the membrane with four washes of Classic Buffer for 5-10 minutes each. T he membrane was then incubated for approximately 60 minutes with a secondary antibody (anti-mouse Ig G HRP conjugate, Promega, Madison, WI) diluted 1:10,000 in PBST containing 5% non-fat dry milk, follo wed by four washes with Classic Buffer for 5-10 minutes each. The washed blot was immersed in phosphate-buffere d saline (PBS: 8.1 mM phosphate buffer, pH 7.4, 137 mM NaCl, and 2.7 mM KCl) or PBST solution for at least 5 minutes and then incubated with SuperSignal West Dura Chemiluminescent Substrate (Thermo Scientific Inc.) according to the manufacturer’s instructions. The signal was det ected with Fujifilm Luminescent Image Analyzer (LAS3000, Fujifilm, Hanover Park, IL).Pioneer Hi-Bred International, Inc. Page 109 of 167 73496 Canola

4.11. Methods for N-Terminal Amino Acid Sequence Analysis

Following SDS-PAGE of the 73496 canola-derived GA T4621 protein sample, the resulting gel was soaked in cathode buffer (60 mM Tris, 40 mM CAPS, 0.1% SDS, pH 9.6) for approx imately 20 minutes. A PVDF membrane (Millipore Corp., Bedford, MA) was briefly wetted with 100% methanol, followed by immersion in anode buffer (60 mM Tris, 40 mM CAPS, 15% methanol, pH 9.6) for 10-15 minutes. A Trans-Blot SD Semi-Dry Electropho retic Transfer Cell system (Bio-Rad Laboratories, Inc.) was used to transfer proteins from the gel to the membrane at 120 mA for approximately 60 minutes. Following protein transfer, the membrane was then stained with GelCode Coomassie Blue stain reagent (Thermo Scientific Inc.) to visualize the GAT4621 protein band. The re sulting GAT4621 band was excised and shipped to the Keck Biotechnology Resource Laboratory (Yale University, New Haven, CT ) for Edman N-terminal amino acid sequencing using the Procise 494 cLC analy zer (Applied Biosystems, Inc., Foster City, CA) equipped with an online high performance liquid chromatography system.

The microbial-expressed GAT4621 protein sample was sent to Crop Genetics (E. I. du Pont de Nemours and Company, Wilmington, DE) in 25mM HEPES, pH 7. 2, 100mM KCl, 10% methanol. The protein was transferred to PVDF membrane using ProSorb Inserts (Applied Biosystems, Foster City, CA) and washedwith 200 μl 0.1% trifluoroacetic acid in water. The membrane was removed and used for Edman Nterminal amino acid sequencing with the Procise 494 LC analyzer (Applied Biosystems) equipped with an online high performance liquid chromatography system.

4.12. Methods for MALDI-MS Identification of Tryptic Peptides

Following SDS-PAGE, the 73496 canola-derived GAT 4621 protein band was visualized by staining with Coomassie Blue and the band was then excised from t he gel. The gel slice containing the protein was placed in a labeled tube and shipped on dry ice via overnight delivery to the Keck Biotechnology Resource Laboratory (Yale University ). The protein in the gel slice wa s digested with trypsin for 18 hours at 37°C. An aliquot of the digest was analyzed by matrix assisted laser desorption ionization mass spectrometry (MALDI-MS) on an Applied Biosystems /MDS SCIEX 4800 MALDI TOF/TOF Analyzer in the reflectron mode of operation. Detected peptide peaks were considered a match if the observed experimental mass was within 50 parts per million (ppm ) of the theoretical mass of peptides determined via in silico trypsin cleavage of the protein sequence. T he peptide mass matching was performed using GPMAW 7.1.

Allowances were made for the following potential modi fications to the peptides: oxidation of methionine (observed value is 15.995 Da greater than the theoretical value) and m odification of cysteine residues by propionamide adduct during SDS-PAGE (observed value is 71.037 Da greater than the theoretical value).

For the microbial-expressed GAT4621, the procedures for excising the protein and trypsin digestion were similar to those described for the 73496 canola-de rived protein. The analysis was conducted on an Applied Biosystems/MDS SCIEX 4700 MALDI-Tof-Tof inst rument (Applied Biosystems) in the reflectron mode of operation. Detected peptide peaks were considered a match if they were within 100 parts per million (ppm) of the theoretical mass of peptides determined via in silico trypsin cleavage of the protein
sequence.

Allowances were made for the following potential modifi cations to the peptides: oxidation of methionine or tryptophan residues (observed value is 15.995 Da grea ter than the theoretical value) and modification of cysteine residues by acrylamide free radicals dur ing SDS-PAGE (observed value is 71.037 Da greater than the theoretical value).Pioneer Hi-Bred International, Inc. Page 110 of 167 73496 Canola

4.13. Methods for Protein Glycosylation Analysis

A GelCode glycoprotein staining kit (Thermo Scientif ic Inc.) was used according to the manufacturer’s instructions to determine whether the GAT4621 protein was glycosylated. The 73496 canola-derived GAT4621 protein, a positive contro l protein (horseradish peroxidase) and a negative control protein (soybean trypsin inhibitor) were run by SDS-PAGE as described in the SDS-PAGE analysis section. Following electrophoresis, the gel was fixed with 50% methanol for 30 minutes and washed with 3% acetic acid. The gel was then incubated with the GelCode oxidizing solution for 15 minutes and washed three times with 3% acetic acid. The gel was next incubated with the GelCode glycoprotein staining reagent (Thermo Scientific Inc.) for 15 minutes a nd then treated with the GelCode reducing reagent, followed by extensive washing with 3% acetic acid and deionized water. Glycoproteins were detected as magenta colored bands on the gel. Following glycopro tein detection, the gel was scanned and the image was captured electronically. The same gel was then st ained with Coomassie Blue as described previously to visualize the total protein content of all pr otein bands, and an image of the gel was captured electronically.Pioneer Hi-Bred International, Inc. Page 111 of 167 73496 Canola



### Appendix 5. Ecological Observations for 73496 Canola

Key to “Range of severity” in Tables 5.1 through 5.4: mild – very little disease or insect injury (<10%) visible; moderate – noticeable plant tissue damage (10% to 30%); severe – significant plant tissue damage (>30%).

Table 5.1. United States: Insect Stressor Comparison between 73496 Canola and Controls

Year Permit Number State County Insect Stressor Range of Severity a Difference with Control?

2007 07-255-103n CA Imperial Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild to Moderate No

Green peach aphid ( Myzus persicae ) Mild to Moderate No

2008 08-261-103n CA Imperial Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Green peach aphid ( Myzus persicae ) Mild No

Aphid ( Brevicoryne brassicae ) Mild No

2009 09-016-106n ND McHenry Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

WA Grant Imported cabbage moth ( Pieris brassicae ) Mild No

2009 09-245-104n CA Imperial Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Green peach aphid ( Myzus persicae ) Mild to Moderate No

2010 10-020-103n ND Cass Grasshopper ( Melanoplus sanguinipes) Mild to Moderate No

Aphid ( Brevicoryne brassicae ) Moderate No

Diamond back moth ( Plutella xylostella) Moderate No

White cabbage butterflies ( Pieris rapae) Mild to Moderate No

White cabbage moths ( Mamestra brassicae ) Mild No

White cabbage butterflies ( Pieris rapae) Mild NoPioneer Hi-Bred International, Inc. Page 112 of 167 73496 Canola

Table 5.1. United States: Insect Stressor Comparison between 73496 Canola and Controls (continued)

Year Permit Number State County Insect Stressor Range of Severity a Difference with Control?

2010 10-020-103n ND Ward Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Grand Forks Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Diamond back moth ( Plutella xylostella) Mild No
Aphid ( Brevicoryne brassicae ) Mild No
McHenry Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

WA Grant Green peach aphid ( Myzus persicae ) Mild No

a Range of severity scores are as follows: Mild – very little insect injury (<10%) visible; Moderate – noticeable plant tissue damage (10% to 30%); Severe – significant plant tissue damage (>30%)

Table 5.2. United States: Disease Stressor Comparison between 73496 Canola and Controls

Year Permit Number State County Disease Stressor Range of Severity a Difference with Control?

2007 07-255-103n CA Imperial None reported N/A N/A

2008 08-261-103n CA Imperial Downey mildew ( Peronospora parasitica ) Mild No

2009 09-016-106n ND McHenry None reported N/A N/A

WA Grant Powdery mildew ( Erysiphe polygoni ) Mild No

2009 09-245-104n CA Imperial None reported N/A N/A

2010 10-020-103n ND Cass White mold/Sclerotinia ( Sclerotinia sclerotiorum) Mild to Moderate No

Ward None reported N/A N/A

Grand Forks White mold/Sclerotinia ( Sclerotinia sclerotiorum) Mild No

Fusarium wilt ( Fusarium oxysporum ) Mild No

Alternaria ( Alternaria brassicae) Mild No
McHenry None reported N/A N/A

WA Grant Powdery mildew ( Erysiphe polygoni ) Mild No

a Range of severity scores are as follows: Mild – very little disease injury (<10%) visible; Moderate – noticeable plant tissue damage (10% to 30%); Severe – significant plant tissue damage (>30%)Pioneer Hi-Bred International, Inc. Page 113 of 167 73496 Canola

Table 5.3. Canada: Insect Stressor Comparison between 73496 Canola and Controls

Year a Province Nearest City Insect Stressors Range of Severity b Difference with Control?

2008 MB Morden Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Lygus bug ( Lygus sp. ) Mild No

Rosebank Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Lygus bug ( Lygus sp. ) Mild No
Crystal City Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Carman Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

ON Georgetown Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Imported cabbage moth ( Pieris brassicae ) Mild No Lygus bug ( Lygus sp. ) Mild No

2009 AB Fort Saskatchewan Grasshopper ( Melanoplus sanguinipes) Mild to Severe No

Cutworm ( Euxoa ochrogaster) Mild to Severe No

Gibbons Grasshopper ( Melanoplus sanguinipes) Mild to Severe No

Cutworm ( Euxoa ochrogaster) Mild to Severe No

Riviere Qui Barre Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Thrips ( Thrips tabaci) Mild No Cutworm ( Euxoa ochrogaster) Mild No

MB Minto Imported cabbage moth ( Pieris brassicae ) Mild No Aphid ( Brevicoryne brassicae ) Mild No Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Thrips ( Thrips tabaci) Mild No

Rosebank Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Portage la

Prairie Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Wellwood Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No

Franklin Flea beetle ( Phyllothreta cruciferae or Phyllothreta striolata ) Mild No
SK Dundurn Alfalfa looper ( Autographa californica) Mild No

a Canadian permits: 2008: 08-PHI-294-CAN01, 2009: 09-PHI1-294-CAN01
b Range of severity scores are as follows: Mild – very little insect injury (<10%) visible; Moderate – noticeable plant tissue damage (10% to 30%); Severe – significant plant tissue damage (>30%)Pioneer Hi-Bred International, Inc. Page 114 of 167 73496 Canola

Table 5.4. Canada: Disease Stressor Comparison between 73496 Canola and Controls

Year a Province Nearest City Disease Stressor Range of Severity b Difference with Control?

2008 MB Morden Sclerotinia ( Sclerotinia sclerotiorum) Moderate No Rosebank Sclerotinia ( Sclerotinia sclerotiorum) Mild to Moderate No ON Georgetown Sclerotinia ( Sclerotinia sclerotiorum) Mild No

2009 MB Minto Sclerotinia ( Sclerotinia sclerotiorum) Mild No Franklin Sclerotinia ( Sclerotinia sclerotiorum) Mild to Moderate No SK Dundurn Sclerotinia ( Sclerotinia sclerotiorum) Mild No

a Canadian permits: 2008: 08-PHI-294-CAN01, 2009: 09-PHI1-294-CAN01
b Range of severity scores are as follows: Mild – very little disease injury (<10%) visible; Moderate – noticeable plant tissue damage (10% to 30%); Severe – significant plant tissue damage (>30%)Pioneer Hi-Bred International, Inc. Page 115 of 167 73496 Canola



### Appendix 6. USDA and Canadian Field Trials of 73496 Canola

Table 6.1. USDA Field Trials of 73496 Canola a,b

Year Permit Name Permit Valid Date State Number of Counties Where Planted Acreage

2007 07-255-103n 10/1/2007 California 1 0.00594 2008 08-261-103n 10/28/2008 California 1 0.07128

2009 09-016-106n 2/20/2009 Idaho 1 0.05 Minnesota 1 0.035 New Jersey 1 0.01 North Dakota 4 0.19264 Washington 5 0.15535 2009 09-245-104n c 9/21/2009 California 1 0.55556

2010 10-020-103n c 3/2/2010 North Dakota 4 0.50327 Washington 1 0.304 2010 10-253-111n c 10/5/2010 California 1 0.3

a Plantings through Oct ober 19, 2010 are listed. b In USDA final reports, 73496 canola (event DP-Ø73496-4) is called DP-073496-4 or DP-73496-4.

c Final field test report not yet due to USDA.

Table 6.2. Canada Field Trials of 73496 Canola a

Year Permit Name Permit Valid Date Province Number of Locations

Planted Acreage

2008 08-PHI-294-CAN 4/29/2008 Alberta 2 0.28038 Manitoba 2 0.70093 Ontario 1 0.22664 Saskatchewan 1 0.14019

2009 09-PHI1-294-CAN01 4/30/2009 Alberta 4 0.33685 Manitoba 9 0.85154 Ontario 2 0.24223 Saskatchewan 7 0.2479

2010 10-PHI1-294-CAN 4/29/2010 Alberta 5 2.44817 Manitoba 1 0.15381 Ontario 2 0.40707 Saskatchewan 1 0.87204

a Plantings through Oct ober 19, 2010 are listed.Pioneer Hi-Bred International, Inc. Page 116 of 167 73496 Canola



### Appendix 7. Survey of Potential Substrates for GAT4621

In enzyme kinetics, k cat is a measure of the turnover rate or speed of the reaction. The higher the k cat , the faster the enzyme reaction. K M is the affinity of the enzyme for a su bstrate or tightness of binding of the substrate to the enzyme. The lower the K M , the greater the affinity of the enzyme for the substrate. A k

cat / K M ratio is the common way to express the catalyti c efficiency of the enzyme. The greater the k cat / K M ratio, the greater the catalytic efficiency of the enzym e for a given substrate. Specificity of an enzyme can be judged by comparing the values of k cat / K M for various enzyme substrates.

In order to examine the specific catalytic efficien cy of the GAT4621 enzyme expressed in 73496 canola, a substrate specificity study was done with the mi crobial GAT4621 protein that had previously been determined to be equivalent to plant-derived GAT 4621 protein from 73496 canola (Section VI-D and Appendix 4).

A dithiobis-2-nitrobenzoate enzymatic end-point assay wa s used to detect any enzyme activity in a survey of various substrates (Siehl et al ., 2005) using assay buffer containing 100 mM KCl to represent physiological conditions in the plant cytosol and chloroplast (Cuin et al ., 2003; Sanders and Bethke, 2000). Twenty agrochemicals, 21 amino acids and 11 antib iotics were tested as potential substrates for the GAT4621 protein. As expected from a previous survey (Siehl et al ., 2005) with a Round 11 GAT protein that only differed from GAT4621 in 73496 ca nola by the absence of an alanine residue in the second position of the protein sequence, no significa nt activity was seen with the majority of the substrates.

Of the substrates surveyed for activity with GAT4621 , only five amino acid substrates indicated low but measurable enzyme activity (suffi ciently above the limit of quantitati on of the assay): L-aspartate, L-glutamate, L-serine, glycine and L-threonine. T he remaining amino acids and substrates surveyed (other than glyphosate) produced levels of end produc t near or below the limit of quantitation of the endpoint assay.

GAT4621 activity on the five amino acids wa s further characterized using a continuous spectrophotometric assay (Siehl et al ., 2005) for characterization of kinetic properties (Table 1). The affinity of the GAT4621 enzyme for glycine was so low that K M values could not be accurately estimated. Therefore, a k cat / K M ratio could not be calculated.

Table 7.1. k cat / K M for the GAT4621 Enzyme on Glyphosate and Selected Amino Acids

Substrate k cat / K M (+/- standard deviation) min -1 mM -1 % k cat / K M of glyphosate

Glyphosate 1063 (+/- 31.8) 100 Aspartate 12.1 (+/- 1.57) 1.14 Glutamate 8.32 (+/- 0.46) 0.78

Serine 0.57 (+/- 0.05) 0.05 Threonine 0.60 (+/- 0.01) 0.06

Glycine ND a ND 1

a ND – Not able to determine because the K M was too high to estimate.

The results of the GAT4621 substrate survey conf irmed the results of the earlier published substrate survey for the GAT enzyme. The GAT4621 enzyme was able to use five amino acids as substrates (aspartate, glutamate, serine, threonine and glycine), although inefficiently (~0.05 - 1% of that of GAT4621 on glyphosate). Further kineti c characterization indicated that the K M of GAT4621 for glycine was too high to estimate (low affinity of the GAT4 621 enzyme for glycine as substrate). The level ofPioneer Hi-Bred International, Inc. Page 117 of 167 73496 Canola

catalytic efficiency of GAT4621 on aspartate, glutamat e, serine, and threonine was about 1%, 0.8%, 0.05 and 0.06%, respectively, of the activity on glyphosate.

Due to the low levels of GAT4621 enzyme activity on five amino acids as substrates, the concentrations of NAA, NAG, NAS, NAT and NAGly in 73496 and co ntrol canola seed was measured in the nutrient composition studies (Section VIII).Pioneer Hi-Bred International, Inc. Page 118 of 167 73496 Canola



### Appendix 8. Safety and History of Consumption of Acetylated Amino Acids

8.1 Summary

In addition to glyphosate, the GAT4621 enzyme is kn own to acetylate five amino acids: aspartate, glutamate, threonine, serine, and glycine. Acetylat ed amino acids are ubiquitous in nature, and are part of many biological systems in plants and animals. In addition, acetylated amino acids can be used in animal feed applications and industrial applicatio ns. A large amount of data has been developed on the safety of consumption of NAA, NAG, NAT, NAS, and NAGly. Collectively, these data indicate that acetylated amino acids have a history of safe use and are as safe for consumption as table salt.

8.2 Function and Use of Acetylated Amino Acids

Acetylated amino acids are naturally occurring subst ances that have been identified in many biological systems. Acetylation of N -terminal amino acids is the most commonly observed posttranslational modification of cytoso lic proteins (Persson et al., 1985; Polevoda and Sherman, 2002). It has been estimated that up to 80% of all cytosolic proteins in mammalian systems are N -acetylated (Brown and Roberts, 1976; Driessen et al ., 1985). Enzymatic acetylation of am ino acids using acetyl-CoA as the acetyl donor group can occur either cotranslationally or posttranslationally depending on the biological system (Polevoda and Sherman, 2000). Enzymes responsi ble for intracellular acetylation of amino acids ( N -acetyltransferases) have been identified in rat, yeast, and other eukaryotic organisms (Lee et al

., 1988; Lee et al ., 1989; Mullen et al ., 1989; Yamada and Bradshaw, 1991a; Yamada and Bradshaw, 1991b). The biological role of acetylation of N -terminal amino acids of cytosolic proteins has been investigated and evidence indicates that this modi fication protects proteins from proteolysis by intracellular aminopeptidases (Berger et al ., 1981; Brown, 1979; Jörnvall, 1975). A variety of additional roles for N -acetylation of amino acids in biological systems have been established (Polevoda and Sherman, 2002).

Taking into account the wide distribution and biological roles of acetylation, it is not surprising that a number of enzymes responsible for deace tylation of acetylated amino acids ( i.e ., acylases) have also been described. It has long been speculated that enzymat ic deacetylation of amino acids is a “general” phenomenon in mammals because this reaction has been observed in numerous organs (Neuberger and Sanger, 1943). It was later hypothesized that this enzymatic reaction plays a role in the salvage of acetylated amino acids formed during the metabolic degradation of N-terminal ac etylated proteins (Endo, 1980; Gade and Brown, 1981). To date, four clas ses of acylases (Types I – IV) that mediate deacetylation of acetylated amino acids have been described in mammalian systems that differ with regard to distribution and specificity.

8.3 History of Safe Use of Acetylated Amino Acids

Acetylation of proteins is commonly employed in the f ood industry to alter the solubility, water absorption capacity and emulsifying propertie s of protein concentrates ( e.g ., El-Adawy, 2000; Ramos and Bora, 2004). Another well-characterized use of acetylated am ino acids is in the livestock industry in cases when it is unsuitable to use free amino acids in feed. For example, the quality of soy protein fractions can be limited by the concentrations of the essential amino acid L-methionine. This deficiency can be overcome by supplementation of diets with free L- methionine; however this can lead to development of objectionable odors and flavors from conversion of L-me thionine to methional by Strecker degradation (Ballance, 1961). Therefore, feed may be supplemented with N -acetyl-L-methionine. In rats fed diets produced with soy protein isolates, growth and weight gains were similar regardless of whether they were supplemented with L-methionine or N -acetyl-L-methionine (Amos et al ., 1975; Boggs et al ., 1975).

Metabolism studies have demonstrated that N -acetyl- 14 C-L-methionine is readily metabolized to L-methionine in rats and in human infants (Boggs, 1978; Stegink et al., 1980; Stegink et al., 1982). Similarly, metabolic deacetylation of N- acetyl-L-methionine has been reported in in vitro studies using rabbit intestinal epithelial cells (Brachet et al. , 1991). While these reports demonstrate that this enzymaticPioneer Hi-Bred International, Inc. Page 119 of 167 73496 Canola

deacetylation occurs within the digestive system, there is also evidence that N -acetyl amino acids are deacetylated in other tissues (Yoshida and Lin, 1972). Nutritional and metabolic studies with the N -acetyl forms of some amino acids have been conducted in humans, rats, and pigs. In most cases, these studies have reported that the N -acetyl form of amino acids substitute for the constituent amino acid via metabo lic deacetylation. Such re sults have been reported for glutamate (Arnaud et al ., 2004; Magnusson et al ., 1989; Neuhäuser and Bässler, 1986), phenylalanine and tryptophan (du Vigneaud et al., 1934) and threonine (Boggs, 1978). Although specific information is not available for aspartate, threonine, serine, or glyc ine, there is no reason to believe these amino acids would not also be biologically available when acetylated.

8.4 Presence of NAA, NAG, NAT, NAS, and NAGly in Biological Systems

Plants expressing the GAT4621 enzyme are known to contain increase d concentrations of some or all of the following five acetylated amino acids: NAA, NA G, NAT, NAS, and NAGly. As described earlier, acetylated amino acids are known to be widely pr esent in biological systems and some additional information about the cellular location and possible function of these five acetylated amino acids are described further below.

8.4.1 NAA

NAA is a component of the mammalian central nervou s system (CNS). It was first isolated from the brains of cats in 1956 (Tallan et al ., 1956). Since that report NAA has been found to be a common constituent of the CNS of all mammals (reviewed in Moffett et al ., 2007) where it is located almost entirely within the neurons and produced at high concentrat ions. It has been reported that NAA is the second most abundant free amino acid in the mammalian CNS – second only to the concentrations of free glutamate (Miyake et al ., 1981; Simmons et al ., 1991; Tsai and Coyle, 1995; Urenjak et al ., 1993).

The metabolic pathway by which NAA is synthesized in the mammalian CNS has also been determined. It is produced enzymatically by acetylation of L-aspa rtate using acetyl-CoA as a cofactor. The enzyme responsible for this reaction is aspartate- N -acetyltransferase (E.C. 2.3.1.17) . It is expressed exclusively in neuron mitochondria (Demougeot et al ., 2004; Truckenmiller et al ., 1985).

Within the mammalian CNS, NAA is readily metabo lized to L-aspartate and free acetate by the enzyme N

-acetyl-L-aspartate amidohydro lase (EC 3.5.1.15; D’Adamo et al ., 1973; Goldstein, 1976). This enzyme has also been called acylase II and aspartoacylase in published literature and will hereafter be referred to as aspartoacylase. Recent studies have demon strated that aspartoacylase is expressed by oligodendrocytes (the cells responsible for synthesi s of myelin in the CNS) but not by neurons or astrocytes (Baslow et al ., 1999; Madhavarao et al ., 2004).

NAA is the primary source of acetate required for lipid synthesis used for axonal myelination during development of the mammalian CNS (D’Adamo et al ., 1968; Patel and Clark, 1979). Aspartoacylase liberates acetate from NAA which is then used in t he biosynthesis of lipids used for myelination of the axons of the developing CNS. In fac t, it has been reported that the activi ty of aspartoacylase in the brains of developing rats correlates with the time course of myelination of the brain (Bhakoo et al ., 2001; Kirmani et al ., 2002; Kirmani et al ., 2003); therefore NAA is critical for proper development of the mammalian CNS.

8.4.2 NAG

NAG has been identified as a component of a number of organs (liver, small inte stine, brain, kidneys, spleen and heart) in numerous animal species (rats, mice and other animals) using different analytical methods (Alonso et al ., 1991; Reichelt and Kvamme, 1967; Shigesada and Tatibana, 1971a), and serves as the first intermediate in the biosynthesis of ar ginine in prokaryotes, lower eukaryotes and plants (Caldovic and Tuchman, 2003). Glutamate is the most abundant amino acid in the mammalian brain and it is a principal neurotransmitter in the central ne rvous system (CNS; Al-Sarraf and Philip, 2003; reviewed by Meldrum, 2000).Pioneer Hi-Bred International, Inc. Page 120 of 167 73496 Canola

Biochemical studies have demonstrated that NAG in mammals is produced enzymatically by Nacetylglutamate synthase (NAGS; E.C. 2.3.1.1), which acetylates glutamate using acetyl-CoA as a cofactor (Caldovic and Tuchman, 2003). This occurs in mitochondria of parenchymal cells from most tissues, as high levels of NAGS activity and NAGS specific mRNA have been identified in liver and small intestinal mucosal cells of rats and humans thou gh neither NAGS protein nor mRNA have been detected in brain tissue (Caldovic et al ., 2002a; Caldovic et al ., 2002b; Uchiyama et al ., 1981).

Mammalian metabolism of NAG is also well characte rized. NAG is hydrolyzed enzymatically by aminoacylase I (EC 3.5.1.14) to glutamate and acetat e within the cytosol of kidney and liver parenchymal cells (Reglero et al ., 1977; Shigesada and Tatibana, 1971b). The primary biological activity of NAG is the allosteric regulation of carbamyl phosphate synthetase I (CPSI; E.C. 6.3. 4.16) activity; the first enzymatic step in the urea cycle which is responsible for elim ination of excess ammonia from metabolic processes (Caldovic and Tuchman, 2003). CPSI is an intr amitochondrial enzyme that converts ammonia and bicarbonate into carbamyl phosphate which is su bsequently combined with ornithine via ornithine transcarbamylase (EC 2.1.3.3) to form citrulline which is then exported from the mitochondria. The activity of CPSI is so dependent on NAG that the activity of this enzyme is virtually undetectable in the absence of NAG (Caldovic and Tuchman, 2003; Hall et al ., 1958). This dependence has clinical relevance for humans and other mammals because deficiency of NA G can arrest urea cycle metabolism and lead to hyperammonemia (Caldovic et al ., 2002a).

8.4.3 NAT

NAT is a derivative of the amino acid L-threonine bearing an acetyl group covalently linked to the amine nitrogen. It has been identified as the N-terminal am ino acid of a number of dietary proteins though the biological function is unknown (Polevoda and Sherman, 2003).

Acetylation of proteins has been reported to protect proteins from degradation (Persson et al ., 1985), assist in the export of soluble proteins from the cell (Chang et al. , 2008), and block activation of signaling pathways by antagonizing phosphorylati on of threonine residues (Mukherjee et al. , 2007).

8.4.4 NAS

NAS is an acetylated derivative of the amino acid L-serine and has been identified on the N-terminus of proteins as a commonly occurring post-translational modification of proteins in eukaryotes (Brown and Roberts, 1976; Polevoda and Sherman, 2003). Acetyl ation of proteins has been reported to protect proteins from degradation (Persson et al. , 1985), assist in the export of soluble proteins from the cell (Chang et al ., 2008), and block activation of signaling pathw ays by antagonizing phosphorylation of serine residues (Mukherjee et al. , 2007).

Within nature, NAS is one of the most commonly acetyl ated amino acids of proteins. In fact, it has been estimated that approximately 90% of proteins with N-terminal serine residues are acetylated (Driessen et al. , 1985). Accordingly, proteins containing NAS are like ly to be routinely consumed in the diet from a wide variety of plant and animal sour ces (Brown and Roberts, 1976; Persson et al ., 1985).

Plants and microorganisms are able to reduce inorgani c sulfur resulting in L-cysteine biosynthesis. A pathway for this has been described in microorganisms involving free NAS. Through a feedback inhibition mechanism, L-cysteine inhibits the biosynthesis of O- acetyl-L-serine, which is the precursor for NAS, an inducer of the cysteine regulon. (Kredich, 1996).

8.4.5 NAGly

A number of naturally occurring proteins from eukaryot ic cells contain NAGly, including; cytochrome c, hemoglobin and ovalbumin (Brown and Roberts, 1976). S pecific activity for the hydrolysis of NAGly has been observed in liver, kidney and brain tissue (Bray et al ., 1949; Bray et al ., 1950; Giardina et al ., 2000; Goldstein, 1976; Mounter et al ., 1958; Reglero et al ., 1977).Pioneer Hi-Bred International, Inc. Page 121 of 167 73496 Canola

Aminoacylase I (ACY1; EC 3.5.1.14) is an enzym e involved in the cytoplasmic degradation of Nacetylated derivatives of serine, gl utamic acid, alanine, methionine, glycine, leucine, and valine. When aminoacylase activity is compromised, as in the ca se of ACY1 deficiency, there is marked increase in urinary excretion of acetylated amino acids including NAGly (Gerlo et al ., 2006; Sass et al ., 2006).

8.5 History of Safe Consumption of NAA, NAG, NAS, NAT, and NAGly

NAA, NAG, NAS, NAT, and NAGly are normal compo nents of food and feedstuffs . As demonstrated by the compositional analysis described in Section VIII and more extensivel y in submissions for previously approved 98140 maize ( FDA, 2008; USDA, 2009 ), these compounds are found in plant species including canola, are not novel, and are normal components of animal diets.

8.6 Toxicology Studies Conducted with NAA, NAG, NAS, NAT, and NAGly

A substantial number of toxicology studies have been conducted with NAA, NAG, NAS, NAT, and NAGly. There was no evidence of mutagenicity in individual in vitro and in vivo studies with NAA, NAG, NAS, NAT and NAGly (Harper et al. 2009; Harper et al. 2010; Karaman et al ., 2009; van de Mortel et al. 2010a; van de Mortel et al. 2010b). In addition, no adverse effects were observed in rats following acute oral exposure to NAA, NAG, NAS, NAT and NAGly indivi dually at 2000 mg/kg of body weight or following repeated dose dietary exposure to approxi mately 1000 mg/kg of body weight (Delaney et al ., 2008; Harper et al. 2009; Harper et al. 2010; van de Mortel et al. 2010a; van de Mortel et al. 2010b). Mortalities and clinical signs of toxicity were observed in rats that were orally dosed with NAA at 5000 mg/kg of body weight in an acute toxicity study, indi cating that the acute toxicity of this particular substance is similar to that reported for table salt (Delaney, 2010). In addi tion, there was no evidence of adverse effects in longer term (i.e., 90 day) NAA feeding studies at doses of approximately 500 mg/kg of body weight in which brain myelination was evaluated (Karaman et al ., 2011). A two generation reproductive toxicity study with NAA that included evaluation of brain lip id myelination and tissue concentrations of NAA in which no evidence of adverse effects were observed was also conducted, however, this study has not yet been published. The full list of toxicology studies conducted by Pioneer is listed in Table 8.1.

Table 8.1. Full List of Studies Conducte d with NAA, NAG, NAS, NAT, and NAGly

Acetylated Amino Acid Publication Study

NAA Karaman et al ., 2009 Ames in vitro mutagenicity Bone marrow micronucleus in vivo mutagenicity Delaney et al ., 2008 and Delaney, 2010 Acute oral toxicity

Delaney et al ., 2008 28-Day repeated dose oral toxicity

Karaman et al ., 2011 90-Day repeated dose oral toxicity

Not yet published 2-Generation reproduction toxicity

NAG Harper et al. , 2009 Ames in vitro mutagenicity Bone marrow micronucleus in vivo mutagenicity Acute oral toxicity 28-Day repeated dose oral toxicity

NAT van de Mortel et al ., 2010a Ames in vitro mutagenicity Bone marrow micronucleus in vivo mutagenicity Acute oral toxicity 28-Day repeated dose oral toxicity

NAS van de Mortel et al ., 2010b Ames in vitro mutagenicity Bone marrow micronucleus in vivo mutagenicity Acute oral toxicity 28-Day repeated dose oral toxicity

NAGly Harper et al. , 2010 Ames in vitro mutagenicity Bone marrow micronucleus in vivo mutagenicity Acute oral toxicity 28-Day repeated dose oral toxicityPioneer Hi-Bred International, Inc. Page 122 of 167 73496 Canola



### Appendix 9. Herbicide Resistant Weeds

9.1. Evolution of Herbicide Resistant Weeds

Weeds will tend to adapt and circumvent any single cont rol mechanism. Instances of herbicide resistant weeds have occurred for many herbicide classes in cluding acetyl-CoA carboxylase and acetolactate synthase (ALS) inhibitors, glyphosate, hormone, tria zines and other photosystem II inhibitors (Table 9.1; Heap, 2010b).

Herbicide resistance usually evolves in only one or two weed species in an area, even though a much larger number of weeds are exposed to the same herb icide selection intensity. Nonetheless, weed resistance to herbicides currently affects hundreds of thousands of fields and the most widely used herbicides (Heap, 2010a). According to a recent survey, more than 348 herbicide resistant weed biotypes (representing 194 species) are confirmed to be present in agricultural fields around the world (Table 9.1; Heap, 2010b). In this survey, several criteria are used to confirm resistance. Among these criteria, a resistant weed must meet certain spec ific definitions, is confirmed through unbiased experimentation, is able to pass t he phenotype to subsequent generations, and has a practical economic impact to growers (Heap, 2005). Resi stant weeds often increase the cost of crop production and limit the effectiveness of herbicides that can be used and the crops that can be grown. Growers use a variety of approaches to limit the impact of resi stant weeds on crop productivity.

A graph of the number of confirmed herbicide resistant weeds by herbicide class and by year is provided in Figure 9.1. Globally, confirmed glyphosate resi stant weeds do not represent the largest class of herbicide resistant weeds (Figure 9.1). One hundred thirty-two herbicide resistant weed biotypes are confirmed in the United States, with 12 of these resi stant to the glyphosate (glycine) class of herbicides (Heap, 2010c).

When growers indicate that their "weeds have become re sistant," they really me an that the population of resistant weed biotypes has increased to an unaccept able level. The spread of a resistance phenotype depends primarily upon the exposure or selection applied by the herbicide. When an herbicide is applied, most of the susceptible weeds die while the resist ant weeds survive, mature, and produce seed. Although the resistant population may be small, repeat ed application of the same herbicide continues to increase the proportion of resistant weeds in the population.

Not all weed shifts are driven by a genetically bas ed biochemical capacity to survive exposure. For example, weeds with delayed emergence and slower dev elopment are also able to avoid exposure to the herbicide (Hilgenfeld et al ., 2004).

Herbicide resistance can become an ecological problem if the resistant weed biotype replaces the nonresistant biotype in the weed popul ation. Even then, the shift to an herbicide resistant population of weeds has ecological consequence only if the resi stant population cannot be controlled with other herbicides or other control practices. This is genera lly not the case. Many hundr eds of cases of resistant weeds have been documented worldwide, but resistan ce is usually not a limiting factor for crop production.

In spite of the evolution of herbici de resistance in weed populations, US growers continue to have many herbicides and management options for weed control. Even so, growers must always be concerned about herbicide sustainability and the economic conseque nces of losing any herbicide technology due to the evolution of resistant weeds.Pioneer Hi-Bred International, Inc. Page 123 of 167 73496 Canola

Table 9.1. Herbicide Resistant Weeds Summary Table (Heap, 2010b)

Herbicide Group Si te of Action Example Herbicide Total Number of Biotypes

ALS inhibitors Inhibition of acetolactate synthase ALS (acetohydroxyacid synthase AHAS) Chlorsulfuron 107

Photosystem II inhibitors Inhibition of photosynthesis at photosystem II Atrazine 68

ACCase inhibitors Inhibition of acetyl CoA carboxylase (ACCase) Diclofop-methyl 37

Synthetic Auxins Synthetic auxins (action like indoleacetic acid) 2,4-D 28
Bipyridiliums Photosystem-I-electron diversion Paraquat 25

Ureas and amides Inhibition of photosynthesis at photosystem II Chlorotoluron 21
Glycines Inhibition of EPSP synthase Glyphosate 20 Dinitroanilines and others Microtubule assembly inhibition Trifluralin 10

Thiocarbamates and others Inhibition of lipid synthesis - not ACCase inhibition Triallate 8

PPO inhibitors Inhibition of protoporphyrinogen oxidase (PPO) Oxyfluorfen 4
Triazoles, ureas, isoxazolidiones Bleaching: Inhibition of carotenoid biosynthesis (unknown target) Amitrole 4

Chloroacetamides and others Inhibition of cell division (Inhibition of very long chai n fatty acids) Butachlor 4

Nitriles and others Inhibition of photosynthesis at photosystem II Bromoxynil 3

Carotenoid biosynthesis inhibitors Bleaching: Inhibition of carotenoid biosynthesis at the phytoene desaturase step (PDS) Flurtamone 2

Arylaminopropionic acids Unknown Flamprop-methyl 2

4-HPPD inhibitors Bleaching: Inhibition of 4- hydroxyphenyl-pyruvate-dioxygenase (4-HPPD) Isoxaflutole 1

Mitosis inhibitors Inhibition of mitosis / microtubule polymerization inhibitor Propham 1

Cellulose inhibitors Inhibition of cell wall (cellulose) synthesis Dichlobenil 1
Organoarsenicals Unknown MSMA 1 Total number of resistant biotypes 348Pioneer Hi-Bred International, Inc. Page 124 of 167 73496 Canola

Figure 9.1. Number of Resistant Biotypes of Weeds by Herbicide Class and Year (Heap, 2010d)

9.2. Characteristics of Glyphosate

Glyphosate is a broad spectrum herbicide that was introduced in the 1970s for management of annual, perennial and biennial herbaceous grasses, sedges, and broadleaves, as well as woody brush and trees (Franz et al ., 1997).

Glyphosate controls plants by inhibiting the enzyme EPSPS (5-enolpyruvyl shikimate-3-phosphate synthase). EPSPS is an essential en zyme in the shikimate pathway that ultimately leads to the production of aromatic amino acids (tryptophan, tyro sine, and phenyIalanine). The shikimate pathway for synthesizing aromatic amino acids, and therefore the enzyme EPSPS, is found in plants, bacteria and fungi, but not animals.

The structure of glyphosate resembles the st ructure of the substrate for EPSPS, which is phosphoenolpyruvate (PEP). Theref ore, glyphosate competes with PEP for the enzyme’s active site and prevents conversion of PEP to the prec ursor that is required in the synt hesis of aromatic amino acids. Aromatic amino acids are essential for many plant processes such as protein synthesis, cell wall formation, pathogen defense and hormone production. At high rates, glyphosate is toxic to virtually all plants.

9.3. Evolution of Resistance to Glyphosate

For more than two decades, the evolution of gly phosate resistance was not perceived as a problem (Bradshaw et al ., 1997). This opinion was based on the difficu lty of discovering a fully functional 5- enolpyruvylshikimate-3-phosphate synt hase (EPSPS) that was insensitive to glyphosate, the inability of plant species to enzymatically deactivate glyphosate, t he lack of soil activity of glyphosate (thus reducing the selection pressure due to exposure), and the em pirical observation that no resistant weeds had appeared after at least 20 years of use.Pioneer Hi-Bred International, Inc. Page 125 of 167 73496 Canola

Known theoretical ways for weeds to develop herbi cide resistance did not seem likely for glyphosate (Jasieniuk, 1995). Over-p roduction of the EPSPS target site di d not increase resistance enough for plants to survive glyphosate amount s used in agricultural settings (K ishore and Shah, 1988). The EPSPS modifications that conferred glyphosate resistance in bacteria were inside the enzyme’s active site, which reduced its catalytic efficiency and thus w ould probably reduce plant fitness (Padgette et al ., 1995). No higher plants could be found metabolically inactivate glyphosate (Dyer, 1994).

However, the views about the ability of weeds to ev olve glyphosate resistance changed in 1996 when glyphosate-resistant Lolium rigidum , was discovered in Australia (Powles et al ., 1998; Pratley et al

., 1999). Since then, glyphosate-resistant biotypes in at least 19 other weed species have been confirmed globally (Heap, 2010a), and it is estimated that more than several million acres are now affected by glyphosate resistant weeds (Owen, 2010).

Another economically significant glypho sate-resistant weed is horseweed ( Conyza canadensis ); it was confirmed in 2000 as the first annual broadleaf sp ecies with glyphosate resistance (Heap, 2010a; VanGessel, 2001). Currently, glyphos ate-resistant horseweed is estimated to be infesting over several million acres in the U.S. across 17 states (Heap, 2010a).

The molecular basis for weed resistance to glyphos ate is not understood for all weeds that have been identified, though some mechanisms have been elucidat ed. Initial studies of various weed species revealed EPSPS target site insensitivity (Baerson et al ., 2002). Target site-based resistance has been identified for some weed species, including Eleusine indica

, Lolium multiflorum , and Lolium rigidum (Powles and Preston, 2006). Differences in tran slocation and transport to the chloroplast are also important in some weeds, such as horseweed ( Conzya canadensis ) and Lolium rigidum (Feng et al

., 2004; Lorraine-Colwill et al ., 2003; Powles and Preston, 2006). Because weed populations can be diverse genetically, any particular weed species may ev olve different mechanisms of resistance, as is the case for Lolium rigidum (Powles and Preston, 2006). Most recently, EPSPS gene duplication and increased gene expression has been hypothesiz ed to explain glyphosate resistance in Amaranthus palmeri (Gaines et al. , 2010).

The effectiveness, economic benefit s, and ease of using glyphosate have led to repeated applications, year after year, in areas where glyphosate tolerant bi otech crops are grown. The practice of continuously planted glyphosate-resistant soybean was implicat ed in the development of glyphosate-resistant horseweed in Delaware (VanGessel, 2001). This intensive use has resulted in a high selection pressure for weeds that inherently are difficult to control with glyphosate (Culpepper, 2004). Eventually, this selection pressure can lead the spectrum of weeds in the fields to a shift to those weeds that inherently can tolerate glyphosate.

As predicted, spectrum shifts to weed populations with endogenous glyphosate resistance have occurred more rapidly than evolved resistance in response to glyphosate exposure (Shane r, 2000). For example, in Iowa, common waterhemp ( Amaranthus rudis ) and velvetleaf ( Abutilon theophrasti ) became a concern in glyphosate-resistant soybean soon after crop commercialization (Owen, 1997).

9.4. Stewardship of Herbicide Tolerant 73496 Canola

In order to best manage their weed populations, growers understandably need to know where to obtain information on whether herbicide resistant weed biotypes have been reported in their area. It is important to understand that when weeds dev elop resistance to an herbicide, they do so under specific circumstances (heavy reliance on a single herbicide mode of action) at a specific location. Weeds that develop resistance to herbicides are referred to as “biotypes” to indicate that only a sub-type of the species has developed resistance. If the resistant we ed biotypes are controlled effectively by mechanical means or use of alternative mode-of -action herbicides, the problem may be limited to a specific locality in a specific year.

Growers can obtain information about resistant weed bi otypes reported in their area from many sources, including their local crop protection chemical dealers, crop protection chemical company representatives,Pioneer Hi-Bred International, Inc. Page 126 of 167 73496 Canola

their state Department of Agricultur e, University Extension Services , and local crop consultants. The most timely and location specific information can lik ely be provided by their county extension agent, as well as their local seed and/or chemistry providers. The USDA Cooperative Extension System offices are staffed by one or more experts who provide prac tical, research-based information to agricultural producers and others in rural areas and communities of all sizes. Some of this information is also available to growers from the university extensio n services, such as the University of Minnesota Extension (Gunsolus, 2002) and North Dakota State University (http://www.ag.ndsu.edu/weeds/herbicideresistant-weeds).

The Glyphosate, Weeds, and Crops Website (http://www.glyph osateweedscrops.org/ ), a website devoted to glyphosate stewardship, also develops and comp iles member publications and news reports on managing glyphosate-resistant weeds. DuPont is one member of this website and membership also includes major universities and agricultural institutions.

The weed science community is also a valuable source of information about resi stant weed biotypes that have been reported (International Survey of Herbicid e Resistant Weeds, www.w eedscience.org). They also monitor the evolution of herbicide resistant we eds. However, because the information posted on their website relies on extension agents and weed scient ists to self-report, it may not be completely updated with information for the grower's local area.

DuPont’s Pioneer Hi-Bred International, Inc. and Crop Protection Chemical s businesses both have long histories of product stewar dship. Examples of these efforts are detailed below.

9.4a. Local Weed Management

In collaboration with university investigators, priv ate consultants, other ma nufacturers, and growers, DuPont Crop Protection field development personnel conduct hundreds of field trials annually to refine existing recommendations and to investigate potential new active ingredients and herbicide combinations deployed in an Integrated Weed Management cont ext to improve solutions for existing and emerging weed problems. Within Pioneer, field agronomists give presentations to local audiences about resistant weeds and best management practices. In addition, they assist customers in making crop management decisions, including options for managing weeds.

9.4b. Product Labeling

For at least 20 years, all DuPont herbicide labels hav e carried voluntary statements regarding resistant weed management (Figure 9.2). These labels acti vely promote an integrated weed management philosophy as seen in the second paragraph:Pioneer Hi-Bred International, Inc. Page 127 of 167 73496 Canola

Figure 9.2. Resistant Weed Management LabelPioneer Hi-Bred International, Inc. Page 128 of 167 73496 Canola

9.4c. Training and Education of Sa les Representatives and Agronomists

DuPont Crop Protection: In addition to the formal academic training of technical, marketing, and sales professionals, DuPont Crop Protection has a mandator y on-line interactive training course with intensive and comprehensive coverage of product stewardship genera lly and herbicide resistance specifically. This training is administered globally to all employees involved in weed management recommendations and is also provided to other interested parties as a co mmunity education contribution. The technical, marketing, and sales professionals ar e required to be certified in this training by receiving a passing grade of 90% or higher in each of the eight modules . A person unfamiliar with this topic is expected to take about twelve hours to complete the internal version of the training. This is the first training of its kind to be awarded Certified Crop Adviser (CCA) credits by the American Society of Agronomy. The CCA standard allows growers, employers, and other organ izations to help manage risk by enabling them to have assurance that a person has the ap propriate professional qualifications.

Pioneer: The Pioneer sales force, made up of agronomists, account managers and sales representatives, and customers receive ongoing ma ndatory and voluntary stewardship training throughout the sales season through a variety of tact ics. These include stewardship training sessions administered in person or communicated electronica lly by Pioneer Stewardship personnel. The Pioneer sales force also utilizes a propriet ary computer software system to ac cess information about products, traits, crop management practices, sales transactio ns and required stewardship documentation. This formal training is in addition to the practical experi ence of the Pioneer sales force working with growers on the positioning and use of products containing biot ech traits, including herbicide resistant traits.

9.4d. Technical Bulletins Provided to Seed Customers and the Public

Direct Mail

Pioneer’s Growing Point magazine is mailed to all Pioneer customers, prospects and employees. This magazine contains information abo ut products, marketing programs, production and management practices and advice on agronomic application of traits and technologies.

Information on Websites

 Pioneer’s “Growing Point” site (https://www.pioneer.com/growingpoint/login/login.jsp) has an extensive agronomy section, with access to in formation about many different crops and crop management practices. Technical bulletins such as “Crop Insights” have been published for the past 15 years, and are a good example of how Pioneer make s the latest information available to growers.

 The DuPont Biotechnology website (http://www2. dupont.com/Biotechnology/en_US/) contains an indepth “Science Knowledge” section addressing “Herbicide Resistant Crops and Weed Management: Scientific Summary and the DuPont Perspective” , with a section devoted to Integrated Weed Management, as well as an FAQ section that addresses weed control and Integrated Weed Management. There is also a Scientific Summa ry on Integrated Weed Management and Herbicide Resistance: (http://www2.dupont.com/Biotechnolo gy/en_US/science_knowledge/her bicide_resistance/moreinfo8.h tml).

9.4e. Involvement in Industry Groups

DuPont Crop Protection is a long-standing participa nt in the Herbicide Resistance Action Committee (HRAC), an industry-based group su pported by Croplife International. Their stated mission is to “Facilitate the effective management of herbicide resist ance by fostering communication and co-operation between industry, government and farmers.” They work towards fostering responsible attitudes towards herbicide use, communicating herbicide resistan ce management strategies and support their implementation through practical guidelines, and they seek active collaboration with public and privatePioneer Hi-Bred International, Inc. Page 129 of 167 73496 Canola

researchers, especially in the areas of problem identification and devising and implementing management strategies.

9.4f. Involvement with Academic Groups

Pioneer and DuPont personnel interact with academic we ed scientists in conducti ng trials at university sites as well as seeking input from them regarding weed management strategies.

9.4g. Customer Satisfaction and Weed Resistance Management Plan

Pioneer and DuPont Crop Protection are committed to active market presence wherever we sell our products. Consistent with our stewardship principles , all of our business teams are required to maintain an active contact with customers and awareness of end-user practices and a capability to respond rapidly to issues arising. DuPont Crop Protection main tains a customer satisfaction database to track and address any complaints, including for resistant weeds. Field employees are trained and provided tools and processes for responding to inquiries regarding product performance (or any potential impacts on human health or environment).Pioneer Hi-Bred International, Inc. Page 130 of 167 73496 Canola



### Appendix 10. GAT4621 New Protein ConsultationPioneer Hi-Bred International, Inc. Page 131 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 132 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 133 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 134 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 135 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 136 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 137 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 138 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 139 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 140 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 141 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 142 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 143 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 144 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 145 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 146 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 147 of 167 73496 CanolaPioneer Hi-Bred International, Inc. Page 148 of 167 73496 Canola



### References

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Smyth S, Gusta M, Phillips P, Castle D (2010) As sessing the Economic an d Ecological Impacts of Herbicide Tolerant Canola in Western Canad a. Alberta Canola Producers Commission, http://canola.ab.ca/assessi ng_the_economic_and _ecological_impacts_of_he rbicide_tolerant_canola_in_ western_canada.aspx

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Rey MW, Ramaiya P, Nelson BA, Br ody-Karpin SD, Zaretsky EJ, Tang M, Lopez de Leon A, Xiang H, Gusti V, Groth Clausen I, Olsen PB, Rasmussen MD, Andersen JT, Jørgensen PL, Larsen TS, Sorokin A, Bolotin A, Lapidus A, Galleron N, Ehrlich SD, Berka RM (2004) Complete genome sequence of the industrial bacterium Bacillus licheniformis and comparisons with closely related Bacillus species. Genome Biology 5: R77

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VIII. Compositional Assessment

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IX. Assessment of Plant Pest Risk for 73496 Canola

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Appendix 9. Herbicide Resistant Weeds

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Gaines TA, Zhang W, Wang D, Bukun B, Chisholm ST, Shaner DL, Nissen SJ, Patzoldt WL, Tranel PJ, Culpepper AS, Grey TL, Webster TM, Vencill WK, Sammons RD, Jiang J, Preston C, Leach JE, Westra P (2010) Gene amplification confers glyphosate resistance in Amaranthus palmeri . Proceedings of the National Academy of Sciences USA 107: 1029-1034

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Heap I (2010b) Herbicide Resistant Weeds Summary Table. The International Survey of Herbicide Resistant Weeds, Weed Science, http://www .weedscience.org/summ ary/MOASummary.asp

Heap I (2010c) Herbicide resistant weeds by countr y and site ofaction. The International Survey of Herbicide Resistant Weeds, Weed Science, http://w ww.weedscience.org/summa ry/CountrySummary.asp

Heap I (2010d) The International Survey of Herbicide Resistant Weeds. Weed Science, http://www.weedscience.org/ChronMOA.GIF

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Padgette SR, Kolacz KH, Delannay X, Re DB, LaVall ee BJ, Tinius CN, Rhodes WK, Otero YI, Barry GF, Eichholtz DA, Peschke VM, Nida DL, Taylor NB, Kishore GM (1995) Development, Identification and Characterization of a Glyphosate-Tolerant Soybean Line. Crop Science 35: 1451-1461

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Powles SB, Preston C (2006) Evolved Glyphosate Resi stance in Plants: Biochemical and Genetic Basis of Resistance. Weed Technology 20: 282-289

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Shaner DL (2000) The impact of glyphosate-tolerant crops on the use of other herbicides and on resistance management. Pest Management Science 56: 320-326

VanGessel MJ (2001) Glyphosate-resistant horseweed from Delaware. Weed Science 49: 703-705

### Addendum to Petition for the Determination of Nonregulated Status for

Herbicide Tolerant 73496 Canola

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COMPREHENSIVE REVIEW OF FERAL CANOLA

Submitting Company:

Pioneer Hi

- Bred International, Inc. 7100 NW 62nd Avenue PO Box 1014 Johns ton, IA 50131

- 1014

Submitted by:

Natalie Weber , Registration Manager Pioneer Hi

- Bred International, Inc. DuPont Agricultural Biotechnology DuPont Experimental Station, E353/305C

PO Box 80353 Wilmington DE 19880

- 0353 Telephone: 302

- 695

- 8160 Fax: 30 2

- 695

- 3075

Prepared by:

Aimee Hyten, Don MacKenzie, and Tracy Rood

OECD Unique Identifier: DP

- Ø73496

- 4

September 2 , 2011

NO CBIAddendum to 73496 Canola petition Page 2 of 7

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### BRS has requested additional information and a sound justification for why weedy traits of 73496 canola are neithe r plant pest nor “issues of concern”. This topic is touched on briefly in Section IX

- C (“Weediness Potential of 73496 Canola” of the petition, and this addendum provides additional comprehensive information on the potential for and plant pest risk of

esta blishment of 73496 feral canola populations. The text in this addendum is copied from the Environmental Report that Pioneer is submitting to the BRS NEPA team.



## Feral Canola

Feral canola plants are crop

- derived plants occurring outside of cultivated ar eas, most commonly in ruderal ( i.e ., non

- cropped, disturbed) habitats such as field margins, along transportation corridors ( e.g., roadsides, paths, railway lines), near seed/grain handling facilities ( e.g ., ports, storage facilities), and wastelands where they can survive and reproduce without human intervention ( ( Bagavathiannan and Van Acker, 2008 )

. There are a number of ways by which feral canola populations can originate including from spillage of seed during its transport to and from the field, r edistribution of seed by field equipment, seed dispersal by birds and mammals, or as a result of bulk seed handling operations.

Canola is a plant of disturbed habitats in that it takes advantage of disturbed sites due to its early germination potential an d capacity to capture resources quickly. However, canola is a poor competitor and lacks the ability to establish stable populations in undisturbed natural habitats ( Crawley et al. , 2001 ; Crawley et al. , 1993 ; Warwick et al. , 2008 )

. Unless the habitat is regularly disturbed, or seed replenished from outside, canola will be displaced over time by other plants.

As reviewed by Devos et al. (2011a )

, while many feral canola populations have been found to be transient at a local scale, persisting from one to four years ( e.g ., ( Crawley and Brown, 1995 ; Crawley and Brown, 2004 ) this is likely counterbalanced at a landscape scale by repeated seed addition and redistribution. The contribution of seed derived from resident feral plants to the persistence of feral canola populations is still a matter of some discussion. A survey conducted in central France indicated that local seed input from resident feral plants accounted for less than 10 percent of subsequent feral populations ( ( Pivard et al. , 2008 )

, while a four

- year field survey and assessment of genetic variation in feral canola pop ulations in northwest Germany indicated that the percentage of feral plants setting seeds ranged between 30−48 % ( Elling et al. , 2009 )

. Thus, feral canola may be considered long

- lived at a landscape scale, where the high rate of local population extinctions is compensated by the esta blishment of new populations founded by repeated fresh seed spills from agricultural fields and transport, with some proportion of populations resulting from seed emerging from the feral soil seedbank.

Because of concerns that transgenic herbicide

- toleran t canola might be more weedy or invasive, or that the introduced genes would be transferred by pollen to wild relatives, whose hybrid offspring might be more weedy or invasive, there have been numerous monitoring surveys conducted to assess the presence of transgenes in feral canola populations (Table 11). Not surprisingly, in regions where there has been widespread adoption of transgenic herbicide

-Addendum to 73496 Canola petition Page 3 of 7

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### tolerant canola over a number of years, such as western Canada and some states in the U.S

. , the prevalence of transgenes in feral canola populations is similar to the proportion of cultivated canola that is GE ( Knispel et al. , 2008 ; Yoshimura et al. , 2006 ) . For example, in a survey of feral canola plants conducted in North Dakota, approximately 86% of the feral plants collected tested positive for either the glyphosate

- or the glufosinate

- tolerance trait, and there were two instances where these two traits were found combined within single plants ( Schafer et al. , 2010 )

.
Likewise in countries that import si gnificant quantities of canola, but where transgenic herbicide

tolerant canola is not commercially cultivated, surveys of feral canola populations occurring around transportation routes and port areas have confirmed the presence of glyphosate

- and glufosin ate

- tolerance traits ( Aono et al. , 2006 ; Kawata et al. , 2009 ; Nishizawa et al. , 2009 ; Saji et al. , 2005 ) . In Japan, which imports more than 2 million tonnes of canola annually for crushing, the frequency of herbicide

- tolerant traits in feral canola populations has been found to vary significantly over time and across sampling sites, ranging from 0.2 to 100% ( Kawata et al.

, 2009 ; Nishizawa et al. , 2009 ) . The occurrence of herbicide

- tolerance traits in feral canola populations in Japan is attributed to accidental loss and spillage of imported viable canola seed, of which approximately 90% is sourced from Canada, whe re up to 95% of the canola crop is comprised of transgenic HT varieties. Plants containing multiple herbicide

- tolerant (a.k.a. stacked) traits ( i.e. , glyphosate

- plus glufosinate

- tolerant) have never been commercialized, but have been reported in feral ca nola populations ( Aono et al. , 2006 ; Kawata, 2010 ) as has the occurrence of herbicide

- tolerance traits in interspecific ( e.g ., B. oleracea ) and intergeneric ( e.g ., Sisymbrium altissimum ; a Brassicaceae weed) hybrids with B. napus collected from roadsides in Japan ( Kawata et al. , 2009 ; Saji et al. , 2005 )

. However, it was noted that most hybrids with Sis ymbrium sp . were sterile and did not produce seed ( Kawata, 2010 ) . Other surveys conducted in Japan have failed to detect th e presence of herbicide

- tolerance traits in seed collected from wild relatives of B. napus ( e.g. , B. rapa and B. juncea ) sampled from ruderal habitats ( Aono et al. , 20 06 ; Saji et al. , 2005 )

. At least in these two studies, the theoretical possibility of spilled feral transgenic herbicide

- tolerant canola germinating, surviving, hybridizing with sexually compatible wild relatives and the hybrids surviving, reproducing and containing the transgene was below the level of detection.Addendum to 73496 Canola petition Page 4 of 7

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### Table 11. Surveys to Monitor Transgene Presence in Feral Canola Populations

Country Surveyed area Period Transgene detection Sampled
mater ial

Belgium Roadsides nearby and field

margins of cropped fields in Wallonia 2007

– 2008 DNA analysis Leaf

Port areas (Antwerpen, Gent, Izegem and Kluisbergen) Not specified DNA analysis Leaf

Canada* Roadsides nearby and field

margins of cropped fields i n southern Manitoba (central Canada) 2004

– 2006 Herbicide screening, biochemical (protein) analysis Seed,

Leaf

Roadsides and railway lines in Saskatchewan and at the port of Vancouver 2005 Biochemical (protein) analysis Leaf

Japan Port areas (Kashima, Ch iba

and Yokohama), roadsides and riverbanks in the Kanto district 2004 Herbicide screening, biochemical (protein) analysis, DNA analysis Seed

Port areas, roadsides and riverbanks in western Japan (Shimizu, Yokkaichi, Sakai

Senboku, Uno, Mizushima, Kita

- K yusyu and Hakata) 2005 Herbicide screening, biochemical (protein) analysis, DNA analysis Seed

Port areas and roadsides in the area of Yokkaichi 2004

– 2007 Biochemical (protein) analysis Leaf

Roadside (Route 51) in eastern

Japan 2005

– 2007 Biochemical (pr otein) analysis, DNA analysis Leaf

USA * Roadsides (interstate, state and

country roads) in North Dakota 2010 Biochemical (protein) analysis Leaf

* Country where GE herbicide

- tolerant canola is grown commercially Source: adapted from Devos et al. (2011b )

Canola itself is not considered a noxious or invasive weed in the U.S., although it does demonstrate some of the common characteristics of weeds as described by Baker (1974 ) ; highAddendum to 73496 Canola petition Page 5 of 7

11

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- 01p September 1, 2011



### seed output under favorable conditions, continuous germination combined wit h long

- lived seeds and self

- compatibility, but not obligatorily self

- pollinated or apomictic

. However, canola has undergone many years of selective breeding and domestication and is a poor competitor with other species. Feral canola populations, even if genetically engineered, do not grow well outside of agricultural production.

Herbicide

- tolerant canola is no more likely to form feral populations than unmodified canola, nor is it more likely to be more invasive or competitive or persistent in habitats w here the target herbicide is not applied ( Andersson and de Vicente, 2010 ; Warwick et al. , 2009 )

. Field st udies in which both conventional and transgenic glufosinate

- tolerant canola varieties were repeatedly introduced into 12 different habitats in the U.K. between 1990 and 1992, followed by monitoring over a period of up to ten years, failed to find any evide nce that canola is invasive of natural habitats or that transgenic herbicide

- tolerant canola is more invasive of, or more persistent in, disturbed habitats than unmodified canola ( Crawley et al. , 2001 )

. As reported by Hall et al. (2005 ) , grower survey data from western Canada, where transgenic herbicide

- tolerant canola has been grown extensively over man y years, did not indicate any evidence of altered weediness or invasiveness potential.

The small size of canola seeds, their abundance and the tendency of canola seed pods to shatter means that canola is likely to appear as a volunteer in following crop s and must be removed to preserve yield and crop quality. Control of volunteer canola plants can be accomplished with appropriate herbicides, taking into account the tolerance of the current crop and any tolerance of the previously planted canola variety. Failure to adequately control volunteers can lead to stacking of multiple herbicide

- tolerance traits through cross pollinations, as has been observed in canola volunteers ( Beckie et al. , 2004 ; Hall et al. , 2000 ) However, multiple herbicide

- tolerant does not significantly alter plant fitness in the absence of herbicide pressure ( Simard et al.

, 2005 )

.
Based on the lack of any alterations in survival and reproductive biology characteristics of currently commercialized transgenic herbicide

- tolerant canola, Devos et al. (2011b ) conc luded that the likelihood of unintended environmental effects due to the establishment and spread of such plants will be no different than from conventional unmodified canola. The ability of transgenic herbicide

- tolerant canola to successfully establish f eral populations in disturbed habitats is limited by the availability of competition

- free seed germination sites, just as for unmodified non

- herbicide

- tolerant canola.

The comparison of phenotypic characteristics between 73496 and non

- transgenic canola demonstrated an absence of any biologically meaningful differences with respect to early population, vegetative growth, reproductive parameters, yield and ecological interactions. The 73496 canola does not have an increased weediness potential and unconfi ned cultivation should not lead to increased weediness.

In unmanaged environments, herbicide

- tolerant crops have no advantage over non

- herbicide

tolerant crops since no herbicide is applied. Based on this characterization, 73496 canola is no more likely to establish feral populations than either existing transgenic herbicide

- tolerant canolaAddendum to 73496 Canola petition Page 6 of 7

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### varieties or unmodified non

- herbicide

- tolerant canola, and these populations would not be more likely to be persistent or invasive.

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Baker HG (1974) The Evolution of Weeds. Annual Review of Ecology and Systematics 5 : 1

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### Hall L, Topinka K, Huffman J, Davis L, Good A (2000) Pollen flow between herbicide

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