Supplemental Information for USDA Petition for Nonregulated Status of DAS-68416-4 Soybeans

Dow AgroSciences LLC

Supplemental Information for Petition for Determination of Nonregulated Status 

for Herbicide Tolerant DAS-68416-4 Soybeans

Economic and Agronomic Impacts of the Introduction of DAS-68416-4 soybeans on 

Glyphosate Resistant Weeds in the U.S. Cropping System

The undersigned submits this information under 7 CFR 340.6 to support the 

determination that the article should not be regulated under 7 CFR 340.

Submitting Company:

Dow AgroSciences LLC

Submitted by:

__________________________________

Mark Krieger, Ph.D.

Regulatory Leader

Regulatory Sciences & Government Affairs

Dow AgroSciences LLC

9330 Zionsville Road

Indianapolis, IN 46268

Telephone: (317) 337- 3458

FAX: (317) 337-4649

Mkrieger2@dow.com

June 27, 2011
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Summary

Dow AgroSciences (DAS) has submitted a petition to the United States Department of 

Agriculture (USDA)’s Animal and Plant Health Inspection Service (APHIS) for the 

determination of nonregulated status for DAS-68416-4 soybeans, which provides 

tolerance to the herbicides 2,4-dichlorophenoxy acetic acid (2,4-D) and glufosinate.

This document provides information pertaining to the economic and agronomic impact of 

DAS-68416-4 soybeans. This information includes: 

o Benefits of Glyphosate Tolerant Crops

o Weed Management in Glyphosate Tolerant Corn and Soybeans

o Long-term Weed Resistance Management through Use of Herbicide Tolerant 

DAS-68416-4 soybeans

o Economic Benefits of Dow AgroSciences Herbicide Tolerant Technology

o Impact of 2,4-D on Herbicide Tolerant DAS-68416-4 Soybeans and DAS40278-9 Corn on the Cost and Environmental Load of Herbicides Applied on 

Glyphosate Tolerant Corn and Soybeans 
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Economic and Agronomic Impacts of the 

Introduction of DAS-68416-4 Soybeans on Glyphosate 

Resistant Weeds in the U.S. Cropping System
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TABLE OF CONTENTS

1.1 Introduction_____________________________________________________________ 8

1.2 Glyphosate tolerant crop Technology Adoption ______________________________ 9

1.3 Factors Influencing Glyphosate tolerant crop Techology Adoption _____________ 10

2 Benefits of Glyphosate Tolerant Crops _______________________________________ 12

2.1 Environmental Benefits_________________________________________________ 12

2.1.1 Enables conversvation tillage with Glyphosate tolerant crops ________________ 12

2.1.2 Reduces soil erosion __________________________________________________ 13

2.1.3 Reduces greenhouse gas emission _______________________________________ 13

2.2 Economic Benefits _____________________________________________________ 14

2.2.1 Reduces chemical costs________________________________________________ 14

2.2.2 Reduces fuel costs ____________________________________________________ 14

2.2.3 Reduces labor costs___________________________________________________ 15

2.2.4 Reduces management costs ____________________________________________ 15

2.2.5 Global economic benefits ______________________________________________ 16

2.3 Yield Enhancement ____________________________________________________ 16

2.4 Convenience __________________________________________________________ 17

3 Weed Management in Glyphosate Tolerant Corn and Soybeans __________________ 19

3.1 Herbicide resistance____________________________________________________ 20

3.2 Other shifts in weed communities_________________________________________ 22

3.3 Potential for future spread of glyphosate resistant and hard-to-control weeds in 

glyphosate tolerant crops __________________________________________________ 23

3.4 Growers’ response to glyphosate resistant and hard-to-control weeds __________ 28

3.5 Weed management strategies to sustain glyphosate resistant cropping systems in 

corn and soybeans ________________________________________________________ 34

3.6 New tools for weed resistance managmenet ________________________________ 35

4 Long-term Weed Resistance Management through Use of Herbicide Tolerant DAS68416-4 ___________________________________________________________________ 36

4.1 DAS-68416-4 soybeans enables use of alternative modes of action to glyphosate __ 36

4.2 Management of glyphosate resistance and hard-to-control weeds using herbicide 

tolerant DAS-68416-4 soybeans _____________________________________________ 37

4.3 Proposed Use Pattern and Compatibility with Glyphosate Cropping System_____ 39

4.4 Proactive resistance management for 2,4-D through integration with glyphosate _ 40

5 Economic Benefits of Dow AgroSciences herbicide tolerant technology___________42
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6 Impact of 2,4-D on Herbicide Tolerant DAS-68416-4 Soybeans and DAS-40278-9

Corn on the Cost and Environmental Load of Herbicides Applied on Glyphosate 

Tolerant Corn and Soybeans to Control Glyphosate Resistant and Glyphosate Tolerant 

Weed Biotypes___________________________________________________________ 43

 Conclusions_____________________________________________________________ 44

Appendix A: Economic Impacts of Glyphosate Resistant Weeds and the Benefits of DHT 

Technology_______________________________________________________________ 51

Appendix B: Analysis to Determine the Impact of the Use of 2,4-D on Herbicide Tolerant 

DAS-40278-9 Corn and DAS-68416-4 Soybeans on the Cost and Environmental Load of 

Herbicides Applied on Glyphosate Tolerant Corn and Soybeans to Control Glyphosate 

Resistant and Hard-to-Control Weeds________________________________________ 120

Appendix C: Survey of University Weed Specialists to Determine Glyphosate-Resistant 

and Hard-to-Control Weed Prevalence and Management Practices Used in Corn and 

Soybeans________________________________________________________________ 142
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FIGURES

Figure 1.1 Adoption rates of herbicides tolerant corn and soybean in the United States__ 9

Figure 1.2 U.S. glyphosate prices______________________________________________ 11

Figure 2.1 Corn and soybean fuel consumption by tillage type, Central Corn Belt _____ 15

Figure 2.2 Benefits of glyphosate tolerant crops _________________________________ 18

Figure 3.1 Global reports of herbicide resistance weeds ___________________________ 20

Figure 3.2 Adoption of glyphosate tolerant crops and development of glyphosate resistant 

weeds in the United States ___________________________________________________ 21

Figure 3.3 Glyphosate Resistant Weeds ________________________________________ 24

Figure 3.4 Projected corn and soybean acres infested with glyphosate resistant broadleaf 

and grass weeds in the United States (excluding volunteer glyphosate resistant corn). __ 27

Figure 3.5 Average postemergence glyphosate use rates on corn and soybeans in the 

United States ______________________________________________________________ 28

Figure 3.6 Average number of glyphosate applications on corn and soybeans in the United 

States (includes burndown uses) ______________________________________________ 29

Figure 3.7 Total pounds of glyphosate applied on corn and soybeans in the United States

(includes bourndown uses) ___________________________________________________ 29

Figure 3.8 Preemergence non-glyphosate herbicide usage on glyphosate tolerant corn _ 31

Figure 3.9 Preemergence non-glyphosate herbicide usage on glyphosate tolerant soybeans

__________________________________________________________________________ 31

Figure 3.10 Post-emergence non-glyphosate herbicide usage on glyphosate tolerant corn32

Figure 3.11 Post-emergence non-glyphosate herbicide usage on glyphosate tolerant 

soybeans (excludes products typically used to control volunteer corn) _______________ 32

Figure 4.1 2,4-D and glyphosate applications schedules for DAS-68416-4 soybeans ____ 40
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TABLES

Table 1.1 Year of deregulation for glyphosate tolerant crops_______________________ 10

Table 1.2 Percent of all soybeans planted to herbicide tolerant varieties by state ______ 12

Table 3.1 Weeds that evolved resistance to glyphosate in glyphosate tolerant crops in the 

United States ______________________________________________________________ 22

Table 3.2 Weeds reported to have increased in abundance in glyphosate tolerant crops 25

Table 3.3 Future assumptions for glyphosate resistant weeds in corn and soybeans in the 

United States ______________________________________________________________ 26

Table 3.4 Future assumptions for glyphosate resistant weeds in corn and soybeans in the 

United States, Syngenta Corporation __________________________________________ 27

Table 3.5 Assessment of resistance risk by evaluation of the cropping system _________ 35

Table 4.1 Glyphosate resistant, ALS resistant weeds, and hard-to-control weeds that are 

controlled by 2,4-D _________________________________________________________ 38
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1 Economic and Agronomic Impacts of the Introduction of DAS-68416-4 

soybeanson Glyphosate Resistant Weeds in the U.S. Cropping System

1.1 Introduction

Glyphosate tolerant cropAtechnology has driven dramatic changes in agricultural 

production processes while generating important economic and environmental benefits. 

But as some agronomists warned, the benefits of glyphosate tolerant crops are beginning 

to be eroded by increasing weed resistance as well as weed population shifts to hard-tocontrol weeds. Growers have begun to alter production practices to adjust for weed 

resistance and shifts to hard-to-control weeds. Unfortunately, some of these practices, 

particularly tillage, reverse some of the benefits gained from glyphosate tolerant crop

technology. In order to preserve the benefits of glyphosate tolerant crop technology, 

Dow AgroSciences' herbicide tolerant DAS-68416-4 soybeans complement glyphosate 

tolerant crop technology by controlling glyphosate resistant and hard-to-control weeds 

without additional tillage. In addition, DAS-68416-4 soybeans provide another mode of 

action which is strongly suggested by agronomists as a best management practice in 

dealing with glyphosate resistant and hard-to-control weeds. 

The purpose of this paper is to demonstrate the importance of glyphosate tolerant crop

technology, briefly summarize the benefits of glyphosate resistant crop technology, 

describe the developing weed resistance and weed shift problem, discuss current 

solutions to weed resistance, provide an overview of Dow AgroSciences’ herbicide 

tolerant DAS-68416-4 soybeans, and finally document how this technology 

complements glyphosate tolerant crop technology and provides a durable, long-term 

solution to the development of weed resistance.

 

A

The following definitions are applied throughout this document:

Herbicide Tolerant Crop: A crop plant that has been developed (using techniques such as genetic 

engineering or selection of variants produced by tissue culture or mutagenesis) to survive and reproduce 

after treatment with a specific herbicide or herbicides that would normally damage an unmodified crop.

Herbicide Resistant Weed: A herbicide-resistant weed is a member of a population within a species that 

has an inherited ability to survive and reproduce following exposure to a dose of a herbicide normally lethal 

to susceptible populations of the species. Through repeated herbicide selection, the resistant population 

becomes dominant in a given area. 

Hard-to-Control Weed: A weed species that is inherently able to withstand treatment with a herbicide as 

a result of natural factors not involving herbicide selection or genetic mutation. 
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1.2 Glyphosate tolerant crop Technology Adoption

There are few technologies that have been as widely and universally adopted as 

glyphosate tolerant crops. USDA estimates that 91 percent of the soybeans planted in 

2009 were glyphosate tolerant varieties (see Figure 1.1).

1

 At least one other source, 

which surveys approximately 5,000 large U.S. farms, suggests similar results.2 In the 

case of corn, there is some discrepancy in the data on the percent of corn acres that were 

planted with glyphosate tolerant seed in 2009. USDA estimates that total herbicide 

resistant hybrids planted represented 68 percent of the corn acres planted in 2009.

1

 

Estimates from proprietary surveys and Monsanto (based on seed sales) are higher, 

exceeding 80% of total planted area.2,3 In any case, the prevalence of glyphosate tolerant 

seed use in both corn and soybeans is very high, underscoring the importance of

glyphosate tolerant technology.

Figure 1.1 Adoption rates of herbicide tolerant corn and soybeans in the United 

States

Sources: USDA's June "Acreage" Report, various issues, 2000-20091, Fernandez-Cornejo & McBride 

soybeans 1996-19994, Duke and Powles corn 1998-19995.

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

19961997199819992000200120022003200420052006200720082009

Percent of Planted Acres

Soybeans Corn
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1.3 Factors Influencing Glyphosate tolerant crop Technology Adoption 

The historical data on glyphosate tolerant technology releases and the rate of adoption 

provides informative clues about the perceptions of benefits, the ease of adoption, and the 

general availability of the technology. Adoption of most new technologies starts off 

slowly. Early adopters usually figure out if the technology lives up to claims made about 

it as well as how difficult the technology is to implement in the production process. In 

addition, availability of the technology can limit initial growth. Beyond this point the 

factors influencing adoption become more crop specific. It is also important to note that 

glyphosate tolerant crop technology was not simultaneously introduced for all crops in 

the same year and subsequently adoption curves start at different points (see Table 1.1). 

The literature from the late 1990's casts glyphosate tolerant technology mostly as a tool to 

enable easier management of crops: some early studies even documented yield drag in 

soybeans. 6 Yet in these early studies, the yield results were based on strip trials made in 

weed free fields which were not necessarily representative of actual farm conditions.6In 

addition, glyphosate tolerant technology was not available in the highest yielding soybean 

varieties at the time. USDA noted that analysts expected yield drags to disappear when 

the glyphosate tolerant trait was backcrossed into higher yielding parent lines.6 Despite 

the early concerns of a yield drag, the rapid adoption of glyphosate resistant crops 

indicates the value farmers associated with the new technology.

Table 1.1 Year of deregulation for glyphosate tolerant crops

Source: Duke and Powles, 2008.5

By 1998, adoption of glyphosate tolerant technology in soybeans had increased, jumping 

from 17 to 44 percent of total soybean acreage in the United States in just one year from 

1997 to 1998 (see Figure 1.1). This rapid jump in adoption suggests that growers 

perceived substantial benefits from adopting the technology. Studies document that 

glyphosate tolerant technology provided "better, simpler, cheaper, and more flexible 

weed management than the conventional alternatives."5, 7, 8, 9 There appears to be a 

reversal in tolerant technology adoption in 2000 for corn and soybeans (see Figure 1.1). 

However, this is probably more attributable to a shift in data sources on adoption rates 

rather than a reversal in adoptions rates for glyphosate tolerant technology (see citations 

in Figure 1.1).

Crop Year

Soybeans 1996

Canola 1996

Cotton 1997

Corn 1998
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In 2000, glyphosate came off patent and prices slowly began to fall as generic glyphosate 

producers increased production. Falling glyphosate prices provided further incentives to 

adopt glyphosate tolerant technology (see Figure 1.2 and Table 1.2). Supply issues from 

generic glyphosate producers in 2008 drove prices back up, but this price increase was

temporary (see Figure 1.2). 

By 2004, Marra et al., noted that glyphosate tolerant technology continued to be adopted 

for soybeans despite the fact that prices of herbicides used for conventional soybeans had 

fallen to the point where the cost of these herbicide bundles were competitive with 

glyphosate tolerant soybeans.10 Note that the adoption growth rate in soybeans slowed 

after 2004, but still increased. New studies have shown that profitability is not the only 

driver of adoption rates. Other factors such as compatibility with the use of other 

herbicides, ease of use, observable in-field results, and flexibility in application timing

can drive the adoption of a new technology, and have done so here.

11, 12 ,13, 14, 15, 16, 17 The 

results and convenience associated with glyphosate tolerant crops are discussed below in 

section 2.

Figure 1.2 U.S. glyphosate prices

Source: Proprietary data source, 2009.

2

Adoption of glyphosate tolerant corn has occurred more slowly than adoption of 

glyphosate tolerant soybeans. For corn there were already several effective pre- and post 

emergent weed control herbicides in place that could be effectively used for 

preemergence weed control.18 In addition, glyphosate tolerant corn was not approved for 

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010

Dollars Per Pound of Acid 

Equivalent

$16.00
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import into the EU until late 2003, thereby limiting the export market for glyphosate 

tolerant grain. 

Table 1.2 Percent of all soybeans planted to herbicide tolerant varieties by state

Source: USDA's June "Acreage" Report, various issues, 2000-20091

2 Benefits of Glyphosate Tolerant Crops

As discussed below, the use of glyphosate tolerant crops has been shown to promote the 

use of conservation tillage practices. “Conservation tillage” refers to the use of 

herbicides to control weeds before, at, or after planting, rather than tilling the soil and 

“plowing up the weeds” to control them. By reducing soil erosion, conservation tillage 

preserves topsoil, soil structure, improved water infiltration and holding capacity as well 

as improved water quality by reducing soil, pesticide and fertilizer run-off. Additionally, 

greenhouse gas emissions are decreased by reducing tractor trips across fields, and 

allowing the soil to sequester carbon through increased soil organic matter.

2.1 Environmental Benefits

2.1.1 Enables conservation tillage with glyphosate tolerant crops

Many studies have noted a linkage between the rapid adoption of glyphosate tolerant 

crops and conservation tillage practices.4, 10, 19, 20, 21, 22 The literature varies somewhat in 

its conclusions on causality, but there is consensus that glyphosate tolerant crops enabled

greater adoption of conservation tillage including minimum and no-till practices. If 

herbicides are used to control weeds before, at, or after planting, the need for tillage 

before and after planting is eliminated. The National Academy of Sciences concludes in 

their 2010 report, "Given that agriculture is the largest source of surface water pollution, 

improvements in water quality resulting from the complementary nature of herbicideState 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

Percent of all soybeans planted

Arkansas 43 60 68 84 92 92 92 92 94 94

Illinois 44 64 71 77 81 81 87 88 87 90

Indiana 63 78 83 88 87 89 92 94 96 94

Iowa 59 73 75 84 89 91 91 94 95 94

Kansas 66 80 83 87 87 90 85 92 95 94

Michigan 50 59 72 73 75 76 81 87 84 83

Minnesota 46 63 71 79 82 83 88 92 91 92

Mississippi 48 63 80 89 93 96 96 96 97 94

Missouri 62 69 72 83 87 89 93 91 92 89

Nebraska 72 76 85 86 92 91 90 96 97 96

North Dakota 22 49 61 74 82 89 90 92 94 94

Ohio 48 64 73 74 76 77 82 87 89 83

South Dakota 68 80 89 91 95 95 93 97 97 98

Wisconsin 51 63 78 84 82 84 85 88 90 85

Other States 54 64 70 76 82 84 86 86 87 87

U.S. 54 68 75 81 85 87 89 91 92 91
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resistance technology and conservation tillage may represent the largest single 

environmental benefit of GE [Genetically Engineered] crops." 18

The American Soybean Association conducted a survey of famers in 2001 asking what 

factors had the greatest impact on their adoption of reduced tillage or no-till soybeans. 

Fifty four percent of the survey respondents indicated that the release of glyphosate 

tolerant soybeans had the greatest impact.23 The next largest factor, with 15 percent of 

the respondents, was improvements in reduced till or no-till planters. Another 

comparison that is a bit more striking was made by Dill, et al. in 2008.24 The percent of 

glyphosate tolerant soybeans planted via no-till was nearly 50 percent compared with 

conventional soybeans at 32 percent. Conventional tillage was used on about 32 percent 

of glyphosate tolerant soybeans, but nearly 50 percent of conventional soybeans.24 

Unfortunately the development of glyphosate resistant weeds and weed population shifts 

to hard-to-control weeds is jeopardizing the gains in conservation tillage. As noted 

below, in section 3.4, increased tillage is identified as a primary grower means to control 

glyphosate resistant weeds.5, 25, 26

2.1.2 Reduces soil erosion

When adoption of glyphosate tolerant soybeans and corn encourages parallel adoption of 

conservation and reduced tillage practices, improved soil and water conservation can be 

obtained. Conservation and reduced tillage can increase the availability of organic matter 

and minerals in the soil leading to enhanced soil structure and fertility. Soil erosion and 

water runoff are also reduced, sustaining the productive capacity of land and minimizing 

surface and groundwater contamination.20, 27 Due to improved soil moisture content and 

retention capacity, efficiencies in water use may also be achieved.28, 21, 29 

2.1.3 Reduces greenhouse gas emission

Increased no till cultivation enabled by glyphosate tolerant crop technology has two air 

quality impacts: reduction in fuel consumption and increased carbon sequestration within 

the soil.29, 20, 21 Reduction in fuel use through less tillage as well as less intensive tillage 

is well documented for conventional versus conservation tillage (see Section 2.2.2

below). In addition, by leaving the soil profile intact, a greater amount of organic carbon 

in the form of crop residue is sequestered in the soil. Sequestering more carbon in the 

soil leads to a reduction in green house gas (GHG) emissions. Brookes and Barfoot 

partitioned these GHG impacts from herbicide resistant soybeans and canola into carbon 

emission reductions from reduced fuel consumption and increased carbon sequestration.30 

Relative to conventional tillage, they increased carbon sequestration by a rate of 300 kg 

carbon/hectare-1for no-till and 100 kg carbon/hectare-1for reduced tillage. They describe 

these rates as conservative relative to the range of 50 kg/hectare-1to 1,300 kg 

carbon/hectare-1suggested by the International Panel on Climate Change. Using these 
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carbon sequestration rates, Brookes and Barfoot estimated that the fuel savings amounted 

to 1,117 million kg of carbon dioxide savings and additional carbon sequestration 

amounted to 13,548 million kg of carbon dioxide savings in 2006. This is equivalent to 

removing roughly 6.5 million cars from the road.30

2.2 Economic Benefits

One of the primary reasons glyphosate tolerant crop technology has been so popular with 

growers is the strong economic incentive. The incentives are primarily driven by lower 

costs of production including lower costs for chemicals, fuel, labor, and management.

2.2.1 Reduces chemical costs

Studies indicate that chemical costs for growers of glyphosate tolerant crops are 

substantially lower in part because those growers have been able to control weeds 

through glyphosate alone without the assistance of other herbicides until recently.9 In 

1997, USDA found that soybean herbicide costs were reduced 11 percent by glyphosate 

tolerant crop technology in the primary growing area of the United States6. In addition, 

when glyphosate came off patent in 2000, its price declined by 40 percent (Figure 1.2). 

In 2003, Sankula and Blumenthal found that soybean herbicide costs were reduced 53 

percent by glyphosate tolerant crop technology. 31, 28 Slightly lower soybean herbicide 

cost reduction estimates of 46 percent were found by Sankula for 2005.28, 32 In summary, 

overall, the introduction of glyphosate tolerant soybean resulted in a reduction in weed 

control costs.

2.2.2 Reduces fuel costs

Energy costs are also reduced through glyphosate tolerant crop technology. As discussed 

above, the expansion of conservation tillage practices and glyphosate tolerant crop

technology have been found to complement each other. NAS states that glyphosate can 

be used to "supplement or replace tillage" in controlling most weeds, reducing fuel and 

labor inputs.18 In USDA's fuel simulator, fuel consumption is reduced by 44 percent in 

corn and 60 percent in soybeans by switching from conventional tillage to no-till methods 

(see Figure 2.1).33 In 2006, Mitchell et al. found that reduced tillage systems in 

California cotton reduced fuel use by 42 to 62 percent.34 Sanders found similar results,

with conservation tillage reducing fuel costs as much as 50 percent.

35

 Another source of 

fuel savings referenced in the literature is a reduction in herbicide applications.5, 25

Reduction in tillage and spraying also results in lower farm machinery expenses. Shortterm machinery repairs are lower and less usage extends the life of farm machinery,

thereby reducing the long run cost of equipment.18
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Figure 2.1 Corn and soybean fuel consumption by tillage type, Central Corn Belt

Source: USDA-NRCS, May 2010. 33

2.2.3 Reduces labor costs

Labor savings result in part from reduced tillage and also fewer herbicide applications. 

Sanders estimates a 40 percent reduction in labor costs through conversion to 

conservation tillage practices.35 Jasa reports that labor was reduced from 1.22 hours per 

acre to 0.49 hours per acre with a shift from moldboard plow tillage to no-till.36

2.2.4 Reduces management costs

Management costs (time and effort expended to control of weeds) are also reduced with 

glyphosate tolerant technology allowing growers to farm more land or increase their 

hours at an off-farm job. Recent studies have found a positive relationship between off 

farm income and the adoption of glyphosate tolerant soybeans.37, 38 These studies 

concluded that a 15.9 percent increase in off-farm household income is associated with a 

ten percent increase in the probability of adopting glyphosate tolerant soybeans. Other 

studies have found that adopting glyphosate tolerant soybeans reduces farm labor 

requirements by 23 percent.39

0.0

1.0

2.0

3.0

4.0

5.0

6.0

Conventional

Till

Mulch Till Ridge Till No-Till Conventional

Till

Mulch Till Ridge Till No-Till Gallons of Fuel Per Acre

Corn Soybeans

-26%

-33%

-44% -38%

-33%

-60%
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2.2.5 Global economic benefits

The reduction in costs of production at the farm level translates directly into an aggregate 

reduction in costs, enabling growers to obtain the same level of production at lower costs. 

In economics, this corresponds to a rightward shift in the supply curve which, assuming 

other factors remain constant, promotes a drop in the price of soybeans and an 

improvement in consumer welfare. These positive economic impacts extend to the 

grower through lower production costs, to the company supplying the technology through 

product sales, to other co-product sales such as seed (the carrier of the technology in this 

case), and to global consumers through lower commodity prices.28

Many studies have estimated the economic benefits of glyphosate tolerant crop

technology, focusing on one or more of the areas realizing the economic benefits. While 

studies looking at the global welfare for all sectors provide the most complete picture of 

economic benefits, not all studies are this broad. In any case, the literature documents 

economic benefits, particularly for growers and global consumers. Brooks and Barfoot 

focused on the farm income benefits of glyphosate tolerant technology. They reported 

global economic benefits to farm income from glyphosate tolerant soybeans over the 

1996-2004 period of $9.3 billion.29 Falck-Zepeda estimated the total increase in global 

welfare from glyphosate resistant soybeans for one year, 1997/98, at $1.06 billion.40 

Moschini et al. estimated the total global welfare from glyphosate tolerant soybeans for 

the year 2001 at $1.2 billion.41 In 2002, Qaim and Traxler estimated the global welfare 

effects of glyphosate tolerant soybeans for 2001 at $1.2 billion.42 In a study by Trigo and 

Cap of the Argentine soybean industry, accumulated savings in global consumer 

spending over the 1996-2005 from growers in Argentina adopting glyphosate tolerant 

soybeans was $26 billion.43 Finally, in 2008, Konduru et al. estimated a total global 

welfare increase for all glyphosate resistant soybean adoption, including losses from a 

shift away from the minor oilseeds, of $31.4 billion over the 1996 to 2006 period.28

2.3 Yield Enhancement

The opportunity for glyphosate tolerant crops to boost crop yields is driven by the ability 

of glyphosate to better control weeds. Empirical evidence of yield enhancement through 

use of glyphosate tolerant crop technology is somewhat conflicting. Many of the early 

studies show yield drag in soybeans, particularly in areas outside the primary soybean 

growing area. 42, 44, 45, 46, 47 In 2002, Marra, et al. suggested that yield drags in the early 

years of adoption disappeared over time as glyphosate tolerance was introduced into 

more elite soybean varieties.28, 48 Other studies have shown an increase in yields with 

glyphosate tolerant technology, particularly in the main growing region of the United 

States.2, 40, 49 In 2010, Carpenter summarized the results from 49 peer reviewed studies 

that reported comparisons of yields for non-glyphosate tolerant and glyphosate tolerant 

crops

50. Of the 14 studies reporting specific results for glyphosate tolerant soybeans in 
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developed countries, none of the studies showed a yield decrease and the average 

increase in soybean yields was seven percent. Only three studies reported specific 

results for glyphosate tolerant soybean in developing countries, but again none of the 

studies showed a yield decrease and the average increase in soybean yields was 21 

percent. While the sample size is too small to draw specific conclusions, these results 

could be representative of different weed pressures in developing versus developed 

countries. Growers in developed countries can more easily access alternative options for 

effective weed control compared to developing countries where effective weed control 

options may be more limited.50 Therefore, the potential for yield enhancement may be 

greater in environments with higher weed pressures.51 To the extent that existing weed 

control programs prior to glyphosate tolerant crop technology controlled weeds, the yield 

impact from adopting glyphosate tolerant crops may be smaller.

In Section 3 of this report, a detailed discussion of weeds that have developed resistance 

to glyphosate is presented. Weed resistance and shifts in weak populations suggest the 

importance of complementary systems which control hard-to-control weeds while 

allowing continued use of glyphosate in controlling the broad spectrum of weeds still 

susceptible. 

2.4 Results and Convenience

Throughout the literature, the simplicity and flexibility of glyphosate tolerant crops is 

mentioned repeatedly as one of the major benefits of this technology.20, 52 But what 

exactly does that mean? First, and foremost, is the manner in which glyphosate tolerant 

crop technology works. As a non-selective broad spectrum herbicide, glyphosate will 

control virtually all susceptible weed species with one or two appropriately applied post 

emergent applications to the glyphosate tolerant crop (i.e. applied after the crop has 

emerged). Contrast this simplicity with conventional herbicide alternatives that can 

involve hiring a crop consultant to prescribe a combination of herbicides appropriate to 

the crop with the right selectivity for the weed spectrum for each field on the farm. 

Second, simplicity also extends to the "over-the-top" application of glyphosate on 

glyphosate tolerant crops, allowing greater ground speed and much wider coverage in a 

single spraying pass in contrast to more directed spray applications for other herbicides.

11

Third, glyphosate tolerant crops offer considerable flexibility at planting time. Typically, 

growers in the U.S. Corn Belt will plant corn before soybeans due to its longer growing 

season and its yield sensitivity to weather conditions at the silking stage. However, 

weather delays can play havoc with the planting season and make the planting window 

very narrow for optimal yields. Glyphosate tolerant corn and soybeans allow growers a 

longer window for weed control since they can return to the field and spray the crop at a 

later date rather than be limited to only applying weed control at planting or early post 

emergence as is the case with many other herbicides. In addition, glyphosate will control 
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larger weeds (up to 10 cm are controllable in most circumstances), compared to other 

postemergent herbicides, further expanding the window for weed control.27 Glyphosate 

also has no residual soil herbicidal activity allowing maximum cropping flexibility.26 

Finally, flexibility also encompasses the enabling of conservation tillage practices. 

Glyphosate tolerant crops allow weed control without tillage. By reducing the amount of 

tillage, labor requirements fall, allowing growers more time to complete planting in a 

timely manner for optimal crop yields and/or expand their farming operation thereby 

reducing their fixed cost per bushel produced.26 Brookes and Barfoot concluded in their 

study that glyphosate tolerant soybeans have enabled an expansion in second crop 

soybeans in Argentina due to the time savings alone from reduced tillage. They estimate 

the net value over variable costs of the additional second crop soybeans at $699 million 

in 2006.30

Figure 2.2 Benefits of glyphosate tolerant crops 

Glyphosate

Tolerant

Crops

Complementary with

reduced tillage

• Reduces soil loss

• Lowers energy usage

• Improves carbon

sequestration

• Lowers greenhouse gas

emissions

Convenience

•Simplifies herbicide

application

• Accelerates speed of

application

• Saves management time

• Increases flexibility

• Enhances production

process simplicity

Cost reduction

• Lowers energy costs from

fewer tillage passes and

less intensive tillage

• Reduces herbicide cost

• Reduces labor costs

• Lowers machinery costs

Yield enhancement

• Improves yields on 

farms in developing

regions

• Potentially enhances

yields in developed

countries depending on

weed pressure
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3 Weed Management in Glyphosate Tolerant Corn and Soybeans

Proper weed control has always been a critical challenge for crop growers because weeds 

compete with crops for light, water and nutrients. Herbicides used in modern agricultural 

systems enable growers to manage most weeds across vast acreages. However, weed 

changes can occur in response to herbicide use as it can for other types of agricultural 

management decisions. Changes in weed populations begin when a subset of plants 

within a weed species, called a “biotype,” have a distinct genetic makeup that allows 

them to resist and survive a particular herbicide application. As a grower continues to 

use a particular herbicide without any other herbicide modes of action that are active 

against the resistant biotype, or doesn’t use any other weed control practices, the resistant 

biotype continues to survive and produce seed while susceptible biotype(s) of that weed 

are controlled. Subsequent populations of the resistant biotype will continue to increase 

until they are the dominant weed in the field.

As detailed in the previous sections, the introduction of glyphosate tolerance into crops 

through genetic engineering has revolutionized crop protection. Glyphosate is a broadspectrum herbicide with favorable environmental characteristics and effective broadspectrum weed control that has greatly improved crop protection efficiency. The 

widespread adoption of glyphosate tolerant crops, and subsequent glyphosate use, on a 

large portion of the available agronomic cropland has resulted in a strong selection 

pressure for weed biotypes that are not controlled by glyphosate; glyphosate resistant

weeds and hard-to-control weeds. After a little more than a decade of use, the utility of 

this technology is threatened by the occurrence of glyphosate resistant and hard-tocontrol biotypes of certain weed species.

Glyphosate resistant weed species such as marestail, ragweed, waterhemp and Palmer 

amaranth and hard-to-control species such as lambsquarters and morning glory species 

are quickly spreading through corn and soybean producing states (Figure 3.3). The 

potential magnitude of the problem affects an estimated 15 to 20 million acres of corn 

and soybeans and presents important agronomic and economic challenges to growers and 

the agricultural industry (Table 3.1). University weed scientists from across the country 

have warned of the impact of glyphosate resistant weeds on the profitability and 

sustainability of current cropping systems and believe that a higher level of stewardship 

is required to sustain the benefits of glyphosate and glyphosate tolerant crops into the 

future.53 Management of the spread of hard-to-control and herbicide-resistant weeds will 

likely guide the direction of crop production in the future.54 Growers clearly need more 

effective and diverse tools to manage glyphosate resistant and hard-to-control weeds in 

order to sustain the long-term viability of the glyphosate tolerant cropping system and 

preserve the benefits it provides to growers, the agricultural industry, and society.
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3.1 Herbicide resistance

The evolution of herbicide-resistant weeds is not unique to glyphosate. Currently, 195 

species (115 dicots and 80 monocots) have evolved resistance to at least one of 19 

herbicide modes of action (the means by which a herbicide achieves the intended effect 

on the plant) in at least 347 herbicide-resistant weed biotypes distributed over 340,000 

fields (Figure 3.1).55

Figure 3.1 Global reports of herbicide resistant weeds

As discussed above in Section 1.2, corn and soybean production in the United States was 

drastically altered with the introduction of glyphosate tolerant technology in 1996 and 

1998. By 2009, producers grew glyphosate tolerant varieties and used glyphosate for 

weed control on approximately 95 percent and 82 percent of the soybean and corn acres, 

respectively.56 The growers on these acres were generally not using other weed control 

practices, and the situation outlined above occurred – weed biotypes that were not killed 

by glyphosate survived and reproduced.57 In response to the selection pressure (i.e. a 

reduction in the reproductive success of the glyphosate susceptible weed biotypes as a 

result of glyphosate treatment) imposed by these practices, the composition and structure 

of weed communities in agricultural fields have been altered.57 A total of eleven weed 

species have developed resistance to glyphosate in the United States. Nine of these 
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species have evolved resistance to glyphosate in GT crops since their introduction 13 

years ago.55 The nearly exclusive reliance on glyphosate for weed control on glyphosate 

tolerant crop varieties has caused substantial changes in weed communities. Figure 3.2 

shows this relationship of the adoption of glyphosate tolerant corn and soybeans to the 

development of glyphosate resistant weeds.

Figure 3.2 Adoption of glyphosate tolerant crops and development of glyphosate 

resistant weeds in the United States

Sources: Third party proprietary data and Ian Heap http://www.weedscience.org.

The first report in the United States of glyphosate resistance in weeds associated with a 

glyphosate tolerant crop involved horseweed in Delaware.58 Growers found it difficult to 

control this weed in no-till glyphosate tolerant soybeans once resistance evolved since 

tillage was not used to “plow under” any resistant biotypes. Since the initial report in 

2000, glyphosate resistant populations of horseweed have been documented in 16 states 

throughout the Mid-Atlantic, Mid-South, Mississippi Delta, and Midwest states.55 Since 

the discovery of glyphosate resistant horseweed in 2000, eight other weed species have 

evolved resistance to glyphosate in glyphosate tolerant crops in the United States 

including Palmer amaranth, waterhemp, Johnsongrass, common ragweed, giant ragweed, 

kochia, Italian ryegrass and Johnsongrass (Table 3.1).

110%

19961997199819992000200120022003

200420052006200720082009

11

# of Confirmed Gly-Res Weeds in U.S.

GT Soybean GT Cotton GT Corn

% of Acres with GT Crop
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Table 3.1 Weeds that evolved resistance to glyphosate in glyphosate tolerant crops 

in the United States

Species Crop State Acreage*

Amaranthus palmeri 

(Palmer amaranth)

Corn, cotton, soybean Georgia, North Carolina, 

Arkansas, Tennessee, 

Mississippi

200,000–2,000,000

Amaranthus tuberculatus 

(waterhemp)

Corn, soybean Iowa, Missouri, Illinois, 

Kansas, Minnesota

1,200–11,000

Ambrosia artemisiifolia 

(common ragweed)

Soybean Arkansas, Missouri, 

Kansas

<150

Ambrosia trifida (giant 

ragweed)

Cotton, soybean Ohio, Arkansas, Indiana, 

Kansas,

Minnesota, Tennessee

2,000–12,000

Erigeron canadensis

(horseweed)

Corn, cotton, soybean Arkansas, California, 

Delaware, Illinois, 

Indiana, Kansas, 

Kentucky, Maryland, 

Michigan, Mississippi, 

Missouri, New Jersey, 

North Carolina, Ohio, 

Pennsylvania, Tennessee

> 2,000,000

Kochia scoparia (kochia) Corn, soybean Kansas 51-100

Lolium multiflorum 

(Italian ryegrass)

Cotton, soybean Mississippi 1000–10,000

Sorghum halepense 

(Johnsongrass)

Soybean Arkansas Unknown

* Minimum and maximum acreages are based on expert judgments provided for each state. The estimates 

were summed and rounded to provide an assessment of the minimum and maximum acreages in the United 

States. These values indicate orders of magnitudes but do not provide precise information on abundance of 

resistant weeds and likely underestimate actual acreage because the estimates were made when the 

resistance was first identified.

Source: Data from Heap, 2010.

3.2 Other shifts in weed communities (hard-to-control species)

The makeup of weed communities in agronomic fields is influenced by many factors in 

addition to herbicide use including tillage, crop rotation, soil characteristics, 

environmental factors, and management practices. Weeds that naturally tolerate 

glyphosate tolerant crop weed management practices are referred to as “hard-to-control” 
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weeds. As described above, the adoption of glyphosate tolerant cropping systems has 

contributed to large increases in the percentage of growers using no-till and reduced-till 

systems.59 In response to these tillage practice changes, winter annual and perennial 

weed species have become more prevalent after the widespread adoption of glyphosate 

tolerant crops because they are not “plowed under” and can survive to reproduce and 

spread. For example, horseweed, which behaves primarily as a winter annual weed, was 

rarely an economic problem in conventionally tilled fields, but has become a problem in 

no-till and reduced till fields. Weeds, like waterhemp, that continue to germinate after

the last glyphosate application, escape control, and have an advantage in glyphosate 

tolerant crops.60 Some weeds are naturally more tolerant of glyphosate, such as 

lambsquarters, wild buckwheat and morning glory species and have become more 

prevalent (Table 3.2). Table 3.2 lists weed species that have been found to become more 

abundant after the widespread adoption of glyphosate tolerant crops excluding resistant 

biotypes discussed above in Section 3.1.

3.3 Potential for future spread of glyphosate resistant and hard-to-control weeds in 

glyphosate tolerant crops

Glyphosate resistant and hard-to-control weeds are rapidly increasing in agricultural 

fields both in the number of species with resistant biotypes and the acreage infested 

(Figure 3.3). Tables 3.3-3.4 and Figure 3.3 present future assumptions for glyphosate 

resistant weed development in corn and soybeans in the United States. Several common 

annual grass and broadleaf weeds are expected to develop resistance to glyphosate during 

the next five years including lambsquarters, velvetleaf, barnyardgrass and foxtail. Dow 

AgroSciences projects that approximately 30 million acres (20 percent of the 160 million 

total corn and soybean acres) will become infested with glyphosate resistant weeds by 

2020 (Table 3.3 and Figure 3.4), while Syngenta projects that glyphosate resistant weeds 

will infest 38 million acres by 2013 (Table 3.4 and Figure 3.4). As a result, glyphosate 

resistant and hard-to-control weeds are projected to impact management decisions on 

nearly half of the corn and soybean acres in the United States within ten years.
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2001

✔ Marestail

2005

✔ Marestail

✔ Common Ragweed

✔ Giant Ragweed

✔ Palmer Amaranth

✔ Common Waterhemp

✔ Italian Ryegrass

2009

✔ Johnson Grass

✔ Kochia

✔ Marestail

✔ Common Ragweed

✔ Giant Ragweed

✔ Palmer Amaranth

✔ Common Waterhemp

✔ Italian Ryegrass

Figure 3.3 Glyphosate Resistant Weeds

Change in Prevalence: 2001, 2005, 2009

Source: http://www.weedscience.org
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Table 3.2 Weeds reported to have increased in abundance in glyphosate tolerant 

crops

Species Crop

Acalypha spp. (copperleaf) Soybean

Amaranthus tuberculatus (waterhemp) Soybean

Amaranthus palmeri (Palmer amaranth) Cotton

Annual grasses Cotton

Chenopodium album (common 

lambsquarters)

Soybean Iowa

Commelina communis (Asiatic dayflower) Cotton, soybean Midwest, Midsouth, Southeast

Commelina benghalensis (tropical 

spiderwort)

Cotton Southeast, Georgia

Cyperus spp. (nutsedge) Cotton

Equisetum arvense (field horsetail) Herbicide-resistant crops

Oenothera biennis (evening primrose) Herbicide-resistant crops Iowa

Oenothera laciniata (cutleaf evening 

primrose)

Soybean

Pastinaca sativa (wild parsnip) Herbicide-resistant crops Iowa

Phytolacca americana (pokeweed) Herbicide-resistant crops

Ipomoea spp. (annual morning glory) Cotton

Source: Ervin, D. E. et.al. 2010. Impact of Genetically Engineered Crops on Farm Sustainability in the 

United States. Committee on the Impact of Biotechnology on Farm-Level Economics and Sustainability; 

National Research Council. ISBN: 0-309-14709-3, 240 pages, 6 x 9. 

http://www.nap.edu/catalog/12804.html. Accessed: April 28, 2010.
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Table 3.3 Future assumptions for glyphosate resistant weeds in corn and soybeans 

in the United States*

Corn and Soybean Acres Today (2010) By 2015 By 2020

Glyphosate resistant weed 

species present or predicted

Marestail 

Common ragweed

Giant ragweed

Palmer amaranth

Waterhemp 

Kochia 

Rigid ryegrass

Johnsongrass 

All 2010 weeds, 

plus

Lambsquarters

Velvetleaf

Barnyardgrass

Giant foxtail

Goosegrass

All weeds listed 

in 2010 and 2015

Estimated acres infested with 

glyphosate resistant weeds 7.5 M acres 15 M acres 30 M acres

% infested with glyphosate 

resistant weeds 5% 10% 20%

Estimated % of acres on which 

weed management decisions 

are impacted by glyphosate 

resistant weeds

10% 20% 40%

Source: Dow AgroSciences LLC.
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Table 3.4 Future assumptions for glyphosate resistant weeds in corn and soybeans 

in the United States, Syngenta Corporation

Category Species

Key weeds developing resistance in corn and 

soybean fields over a broad area of the corn 

belt

Waterhemp

Pigweed species

Horseweed

Probable resistant weeds by 2010-2015 Foxtail

Barnyardgrass

Johnsongrass

Source: Syngenta Resistance FighterTM Message Board. http://www.resistancefighter.com/about/weeddetail.aspx?Id=91163; 

Figure 3.4 Projected corn and soybean acres infested with glyphosate resistant 

broadleaf and grass weeds in the United States (excluding volunteer glyphosate 

resistant corn).

Sources: 

 Foresman, C. 2009. Syngenta Resistance FighterTM Message Board. http://blog.syngentaus.com/blogs/ask_the_expert/archive/2009/04.aspx Accessed January 16, 2011. 

 Dow AgroSciences LLC.

0

5

10

15

20

25

30

35

40

Millions of Aces

Syngenta Dow
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3.4 Growers’ response to glyphosate resistant and hard-to-control weeds

Glyphosate resistance and other weed shifts can reduce the effectiveness and economic 

benefits of glyphosate tolerant crop systems. However, growers are reluctant to stop 

using glyphosate tolerant crops and glyphosate when faced with hard-to-control weed 

species. Despite reduced weed control, growers have constructed their farming 

enterprises around glyphosate and glyphosate tolerant crops, and they prefer the 

convenience, broad spectrum control and economic benefits of using glyphosate.57 So 

they prefer to increase glyphosate application rates, increase the number of glyphosate 

applications, use other herbicides in addition to glyphosate, and/or increase tillage to 

control problem weeds. Figures 3.5 and 3.6 show how glyphosate rates and the number 

of glyphosate applications applied on corn and soybeans have steadily increased with the 

widespread adoption of glyphosate tolerant crop systems and evolution of glyphosate 

resistant and hard-to-control weeds. Figure 3.7 shows the impact of increasing 

glyphosate rates and application frequency, and the increase in glyphosate tolerant corn

acres on total glyphosate use on corn and soybeans. (Please note that the glyphosate 

tolerant soybean acreage was flat from 2006-2009, so the increase in pounds of 

glyphosate used during this time period resulted from higher glyphosate application rates 

and frequency. Corn acres, however, grew during this time period and account for much 

of the glyphosate increase.)

Figure 3.5 Average postemergence glyphosate use rates on corn and soybeans in the 

United States.

Source: Third party proprietary data Lb. ai/Acre

Corn Soybeans

0.9
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Figure 3.6 Average number of glyphosate applications on corn and soybeans in the 

United States (includes burndown uses)

Source: Third party proprietary data

Figure 3.7 Total pounds of glyphosate applied on corn and soybeans in the United 

States (includes burndown uses)

Source: Third party proprietary data No. of Glyphosate Applications 

Corn Soybeans

1.75 Lb Glyphosate Applied

Corn Soybeans

120,000,000
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In addition to higher rates and application frequency of glyphosate, growers have 

increased their use of non-glyphosate herbicides in glyphosate tolerant crop systems in 

order to introduce additional herbicide modes of action for control glyphosate resistant

and hard-to-control weeds. The use of preemergence residual herbicides nearly doubled, 

increasing from approximately 40 percent to 75 percent of the glyphosate tolerant corn

acreage and from 20 percent to 34 percent of the glyphosate tolerant soybean acreage 

from 2000 to 2009 (Figures 3.8 and 3.9). During this same timeframe, the use of 

postemergent non-glyphosate herbicides on glyphosate tolerant corn more than doubled 

from approximately 15 percent of the glyphosate tolerant corn acreage in 2000 to 39

percent in 2009 (Figure 3.10). Postemergent use of non-glyphosate herbicides on 

soybeans followed a slightly different pattern (Figure 3.11). Use of these herbicides on 

glyphosate tolerant soybeans was approximately eight percent of the glyphosate tolerant 

soybean acres in 2000 and 2001, then dipped to five percent in 2004-2006, and increased 

to 11 percent in 2009.

Unfortunately, the use of non-glyphosate herbicides does not always address weed 

resistance issues. Growers do not always use broad-spectrum herbicides to supplement 

glyphosate, so even when utilizing these alternative modes of action, glyphosate still 

provides the control of certain weeds while the supplemental herbicide has no effect on 

those weeds.61 In addition, growers often apply reduced rates of non-glyphosate 

herbicides, resulting in a reduced spectrum of control and frequent weed escapes.62,63 

Glyphosate still provides control of certain weeds when used in combination with 

reduced rates of non-glyphosate herbicides. 
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Figure 3.8 Preemergence non-glyphosate herbicide usage on glyphosate tolerant corn

Source: Third party proprietary data

Figure 3.9 Preemergence non-glyphosate herbicide usage on glyphosate tolerant soybeans

Source: Third party proprietary data

80,000,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

40%

RR Soybean Acres Non Glyphosate Herbicide Acres % of RR Soybeans with Non Gly Herbicide

80,000,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

80%

RR Corn Acres Non Glyphosate Herbicide Acres % of RR Corn with Non Gly Herbicide
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Figure 3.10 Post-emergence non-glyphosate herbicide usage on glyphosate tolerant corn

Source: Third party proprietary data

Source: Third party proprietary data

80,000,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

12%

RR Soybean Acres Non Glyphosate Herbicide Acres % of RR Soybeans with Non Gly Herbicide

80,000,000

1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

45%

RR Corn Acres Non Glyphosate Herbicide Acres % of RR Corn with Non Gly Herbicide

Figure 3.11 Post-emergence non-glyphosate herbicide usage on glyphosate tolerant soybeans (excludes products 

typically used to control volunteer corn)
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Several peer-reviewed journal articles have been published on grower response to 

glyphosate resistant and hard-to-control weeds in glyphosate resistant crops. The 

following literature review is summarized from the National Research Council report 

entitled “Impact of Genetically Engineered Crops on Farm Sustainability in the United 

States.18

 “Soybean growers in Delaware continued planting glyphosate-resistant soybean 

even in the presence of widespread glyphosate resistance in horseweed. Most 

producers addressed the problem by applying a herbicide with a different mode of 

action, increasing the frequency of glyphosate applications, or using tillage before 

planting. Some 76 percent of growers estimated that resistance in horseweed 

increased their management costs by more than $2.02/acre, and 28 percent 

reported cost increases of over $8.09/acre.” 

 “A survey of 400 corn, soybean, and cotton producers in 17 states found that most 

would not limit the use of glyphosate-resistant crops when facing problematic 

glyphosate-resistant weeds. Instead, producers planned to increase the rotation of 

herbicides, the use of tank-mixes, or the amount of tillage. They expected that 

additional measures for the control of glyphosate-resistant weeds would cost 

$13.90–16.30/acre.”

 “In an economic analysis of weed-management costs with a hypothetical 

reduction of control with glyphosate in three regions of the United States, the 

projected cost of new resistance-management practices for horseweed was 

$12.33/acre in a cotton–soybean–corn rotation in western Tennessee. Additional 

costs were due to a shift from no-till to conventional tillage for cotton and the 

need for new preplant herbicides for soybean.”

 “The projected cost of new herbicide resistance-management practices for 

waterhemp was $17.91/acre in a corn–soybean rotation in southern Illinois; this 

cost resulted from use of different preemergence and postemergence herbicides 

for soybean.”

 “For cotton grown in Georgia, the extra cost of controlling shifts in tropical 

spiderwort (Commelina benghalensis), a weed that is naturally tolerant to 

glyphosate, was predicted to be $14.91/acre; an additional herbicide application 

after cotton emergence explained this cost.”

The authors of the National Research Council report concluded from these studies that 

the evolution of glyphosate resistance and weed shifts could lead to two important 

changes in practices: increased use of herbicides generally and reductions in 

conservation tillage. The preceding literature review indicates that these changes will 

increase weed-management costs, reduce growers’ profits, and produce environmental 
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consequences. If widely adopted by growers, increased use of herbicides and tillage will 

negate the environmental benefits achieved through glyphosate tolerant crop systems. 

3.5 Weed management strategies to sustain glyphosate tolerant cropping systems in 

corn and soybeans

The key to controlling existing resistant weeds and slowing the development of new 

resistant weeds is to reduce and diversify selection pressure on the weed population while 

still maintaining economic levels of control.64 This requires a planned and integrated 

weed management approach combining: 

 Rotation of crops -- to allow a more varied weed control program 

 Rotation of cultural practices -- to reduce reliance on herbicides 

 Rotation of sequences and mixtures of herbicidal modes of action and chemistry -

- to reduce the pressure on a specific herbicide group. 

Diversification of weed-management strategies can be accomplished by integrating 

several weed-control tactics including the following:65

 Scout fields before and after herbicide application. 

 Start with a clean field, using either a burn-down herbicide application or tillage. 

 Control weeds early when they are relatively small. 

 Rotate herbicides that have different modes of action.

 Use residual herbicides that have different modes of action.

 Use tank-mixes of herbicides that have different modes of action.

 Incorporate other herbicides and cultural practices as part of glyphosate tolerant 

cropping systems where appropriate. 

 Use the right herbicide product at the right rate and the right time. 

 Control weed escapes and prevent weeds from setting seeds.

 Clean equipment before moving from field to field to minimize spread of weed 

seed. 

 Use new commercial seed as free from weed seed as possible. 

 Report any incidence of repeated non-performance on a particular weed to the 

local crop protection chemical company representative, retailer, or county 

extension agent.

The Herbicide Resistance Action Committee (HRAC, www.hracglobal.com) prepared the 

tool presented in Table 3.5 to help growers assess the value of weed resistance 

management practices and create an effective integrated weed management program. 

HRAC recommends that the number of applications of a single mode of action be limited 

in a single growing season. Where possible, HRAC recommends use of herbicide 

mixtures or sequential application of herbicides of different modes of action that are 

active on the same target weeds. In cases of confirmed herbicide resistance, HRAC 

advises farmers to avoid using the herbicide to which resistance has been confirmed 

unless used in conjunction with herbicides with a different mode of action active on the 

resistant weed population. 
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Resistance management through use of herbicide mixtures and rotation of herbicides is 

most effective if the partner herbicides are highly effective against the same weeds. A 

partner herbicide which is only marginally effective at controlling a weed or is used at a 

reduced application rate (to reduce crop damage), is not expected to effectively delay 

resistance.

62

Table 3.5 Assessment of resistance risk by evaluation of the cropping system

Management Option

Risk of Resistance

Low Moderate High

Herbicide mix or rotation in 

cropping system >2 modes of action 2 modes of action 1 mode of action

Weed control in cropping 

system

Cultural, mechanical 

and chemical

Cultural* and 

chemical Chemical only

Use of same MOA per 

season

Once More than once Many times

Cropping system Full rotation Limited rotation No rotation

Resistance status to MOA Unknown Limited Common

Weed infestation Low Moderate High

Control in last 3 years Good Declining Poor

* Cultural control can be by using cultivation, stubble burning, competitive crops, stale seedbeds, etc. See 

HRAC guidelines for more details. 

Source: Herbicide Resistant Action Committee. http://www.hracglobal.com

3.6 New tools for weed resistance management 

Without changes in production practices, increased weed resistance to glyphosate will 

likely increase weed-management expenses for growers. Given the rapid increase in, and 

expansion of, glyphosate resistant weeds in glyphosate tolerant crops, herbicide-
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resistance management needs national attention and requires the development and use of 

new, more effective weed-management strategies and tactics. New herbicide tools are 

critical to management of weeds with resistance to multiple modes of action.

Herbicide tolerant DAS-68416-4 soybeans allows the use of a new herbicide mode of 

action on soybean. It confers robust tolerance to 2,4-D as well as tolerance to 

glufosinate. This technology enables the use of a new mode of action on soybeans for 

control of broadleaves, and efficacious application rates and flexible application timing 

for 2,4-D. 

Most university recommendations for control of glyphosate resistant and hard-to-control 

broadleaf weeds include 2,4-D as a control option for preplant burndown in soybeanB. 

2,4-D’s wide spectrum of broadleaf weed control complements glyphosate because it 

controls most glyphosate resistant and hard-to-control broadleaf weed species (Table 4.1

and Section 4.4). 2,4-D will control broadleaf weeds that are resistant to other modes of 

action such as ALS-enzyme inhibitor and PPO inhibitor herbicides, including weeds with 

multiple resistance. Weed researchers are hopeful that new technologies, such as DAS68416-4, will become useful tools to help manage glyphosate resistant and hard-tocontrol weeds in order to sustain the long-term viability of the glyphosate tolerant 

cropping system and preserve the benefits it provides to growers, the agricultural 

industry, and society.

4 Long-term Weed Resistance Management through Use of Herbicide Tolerant 

DAS-68416-4 soybeans

4.1 DAS-68416-4 soybeans enable use of alternative modes of action to glyphosate

DAS-68416-4 soybean plants have been genetically engineered to express the 

aryloxyalkanoate dioxygenase-12 (AAD-12) and phosphinothricin acetyltransferase 

(PAT) proteins. The AAD-12 protein provide tolerance to 2,4-dichlorophenoxyacetic 

acid (2,4-D)Cand the PAT provides tolerance to glufosinate-ammonium herbicides.

2,4-D and glufosinate represent two distinct herbicidal modes of action that are different 

from glyphosate. 2,4-D is a broadleaf herbicide that acts as a synthetic auxin causing 

uncontrolled growth and plant death. 2,4-D is classified by HRAC as a Group O 

 

B

For example: http://www.btny.purdue.edu/Pubs/ws/ws-16/

C

Dow AgroSciences is seeking EPA registration of a new 2,4-dichlorophenoxyacetic acid (2,4-D) product to 

be utilized with DAS-68416-4 soybeans. This proprietary choline salt of 2,4-D has ultra low volatility, 

improved stability at low temperatures and improved, lower odor. In addition, Dow AgroSciences is 

developing technology to significantly reduce the potential for off-target movement via spray droplet drift.
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Dow AgroSciences LLC

herbicide (a synthetic auxin, acts like indole acetic acid) and Group 4 in the Weed 

Science Society of America (WSSA) mode of action classification scheme (a synthetic 

auxin, specific site(s) unknown). Each Group designation reflects a specific mode of 

action or how it affects the sensitive species.66 Glufosinate-ammonium inhibits the 

glutamine synthetase enzyme resulting in a decrease of several amino acids, which 

eventually leads to cell membrane disruption and death of the cell. Glufosinateammonium is classified by HRAC as a Group H herbicide (and Group 10 in the Weed 

Science Society of America (WSSA) mode of action classification scheme). Glyphosate 

is a non-selective herbicide that acts by inhibition of 5-enolpyruvylshikimate-3-phosphate 

synthase (EPSPS), a key enzyme in the shikimate biosynthetic pathway. Glyphosate is 

classified by HRAC as a Group G herbicide (Group 9 in the WSSA scheme). 

4.2 Management of glyphosate resistant and hard-to-control weeds using herbicide 

tolerant DAS-68416-4 soybeans

DAS-68416-4 soybeans will be stacked (the process of combining traits through 

traditional breeding) with glyphosate tolerance so that farmers will be able to use 2,4-D

and glyphosate together, providing two different but complementary modes of action for 

both broadleaf weed control. 2,4-D is an ideal complement to glyphosate to provide an

exceptional pre and postemergent weed management program that is not available today

and is readily adaptable to use with foundation herbicide programs. 2,4-D controls 

several key broadleaf weed species that are resistant to, or difficult to control with, 

glyphosate and ALS herbicides (Table 4.1). Mixtures of 2,4-D with glyphosate can 

provide control of glyphosate resistant biotypes and hard to control weeds that is superior 

to glyphosate alone.

Weed control in soybeans using 2,4-D can play an important role in managing glyphosate 

resistant weed biotypes. DAS-68416-4 soybeans provide an opportunity to preserve the 

economic, environmental, and convenience benefits of glyphosate-tolerance technology 

even in the presence of glyphosate resistance. DAS-68416-4 soybeans can enable 

farmers to manage glyphosate resistant weeds without returning to environmentally 

damaging weed management practices such as tillage.
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Table 4.1 Glyphosate resistant, ALS resistant weeds, and hard-to-control weeds 

that are controlled by 2,4-D

Weed Species

Glyphosate Resistance /

Hard-to-Control

Resistant to ALS 

Herbicides

Controlled by 

2,4-D

Common Lambsquarters Hard-to-control (2004)  (2001) 

Common Ragweed Confirmed Resistant (2004)  (1998) 

Eastern Black Nightshade Hard-to-control (2004)  (1999) 

Giant Ragweed Confirmed Resistant (2004)  (1998) 

Marestail (horseweed) Confirmed Resistant (2000)  (2000) 

Palmer Amaranth* Confirmed Resistant (2005)  (1991) 

Waterhemp Confirmed Resistant (2005)  (1993) 

Prickly Sida Hard-to-control (2004)  (1993) 

* Requires an integrated weed management plan, including additional weed control technology, for 

acceptable control.

DAS-68416-4 soybeans will enable farmers to better manage glyphosate resistant weeds 

by enabling an effective alternative mode of action that will provide the opportunity to 

reduce the selection pressure for resistance to glyphosate and prevent or delay the onset 

of new cases of resistance. Farmers will be able to apply mixtures of herbicides with two 

or more distinct modes of action. Such mixtures will prevent or severely limit the 

survival and reproduction of susceptible weeds which are developing resistance to one of 

the herbicidal modes of action because these weeds will be susceptible to the other 

herbicide(s) in the mixture.

67

 

For mixtures to be most effective at delaying resistance, each component alone should be 

highly efficacious on that weed species.68 Both 2,4-D and glyphosate individually 

provide very high levels of control of important susceptible weed species when applied 

alone, and show the expected additivity when applied together. This means that when 

used together, any susceptible weed plants that may be developing resistance to one of 
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the components is expected to be eliminated from the population by the other component, 

curtailing the increase and spread of the resistance. 

As an alternative to mixtures of herbicides, temporally separated spray applications to 

provide a rotation among modes of action within a growing season can be effective as 

part of a pre-emptive resistance management strategy.68 As with mixtures, a rotation 

approach to herbicide management is expected to prevent or delay the emergence of new 

weed management challenges due to resistance. Through these practices, the projected 

trajectory of new glyphosate resistant and hard-to-control weed issues, such as new 

resistant biotypes or expanded range of resistant and hard-to-control weed populations, 

can be slowed through the use of 2,4-D with herbicide tolerant DAS-68416-4 soybeans.

4.3 Proposed Use Pattern and Compatibility with Glyphosate Cropping System

To encourage a system that incorporates multiple modes of action, Dow AgroSciences 

has designed the technology to be compatible with the current glyphosate cropping 

system.

The proposed use pattern of 2,4-D on DAS-68416-4 soybeans will allow applications of 

2,4-D at 0.5-1.0 lb ae/ac at burndown and preemergence timings with no planting 

restrictions. The proposed use pattern will also allow application of 2,4-D at 0.5-1.0 lb 

ae/ac postemergence from VC to R2 growth stage. The proposed maximum seasonal use 

of 2,4-D is 3.0 lbs ae/ac. 

This application window will provide optimal flexibility for growers to manage their 

weed control program around cultural operations or climatic conditions. This application 

window is aligned with the application window for glyphosate on soybeans, which will 

maintain flexibility for farmers when stacked with a glyphosate tolerance trait. The 

combination of 2,4-D and glyphosate provides a superior weed control system with 

maximum flexibility and efficiency for the grower. The proposed use pattern for 2,4-D on 

DAS-68416-4 soybeans is shown pictorially in Figure 4.1.
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Dow AgroSciences LLC

Figure 4.1 2,4-D, and glyphosate applications schedules for DAS-68416-4 soybeans

*ae/ac, Pre = pre-emergence, Post = post-emergence

The compatibility of the windows for application of all soybean herbicides allows 

growers to easily incorporate DAS-68416-4 soybeans into their cropping system and 

increases the ease of delivering multiple modes of action to control weeds and mitigate 

the development of weed resistance.

4.4 Proactive resistance management for 2,4-D through integration with glyphosate

Herbicide tolerant DAS-68416-4 soybeans provide a new tool for managing and delaying 

glyphosate resistance, managing hard-to-control weeds, and preserving the benefits of the 

herbicide tolerant technologies. However, sustainable use of DAS-68416-4 soybeans will 

require long-term management of resistance to 2,4-D, glufosinate as well as to 

glyphosate. A thorough discussion of weed resistance, how it develops, and its 

management can be found at the Herbicide Resistance Action Committee (HRAC) 

website.67 

2,4-D has been used since 1945 with relatively few weed resistance issues. Globally, 16 

weed species have documented reports of 2,4-D resistant biotypes, with only three in the 

continental United States (wild carrot, field bindweed, prickly lettuce).69 None of these 

are of substantial economic importance and none has shown a large degree of spread 

from their point of origin. The rarity of resistance to 2,4-D or other auxinic herbicides 

has been attributed to:70, 71, 72, 73,74

 multiple sites of action for these auxin herbicides in the plant,

 redundancy in receptors and other components of the auxin signal response,

 frequent use in mixtures with other herbicides,

Post 0.5-1 lb

(up to 2 applications 12 days apart)

Burndown/Pre 1 lb

R2

Full flower

Glyphosate All units = lbs ae/A.

Post-emergence

Glyphosate 

Pre-emergence

Post 0.5-1 lb

(up to 2 applications 12 days apart)

Burndown/Pre 1 lb

R2

Full flower

Glyphosate All units = lbs ae/A.

Post-emergence

Glyphosate 

Pre-emergence
Supplemental Information for USDA Petition for Nonregulated Status of DAS-68416-4 Soybeans Page 41 of 202

Dow AgroSciences LLC

 a fitness penalty associated with auxin resistance mechanisms in weeds, and

 quantitative inheritance of the trait

 short soil half-life (residual)

The same principles of weed resistance management discussed above (see Section 3.5) 

for glyphosate apply directly to 2,4-D and the glufosinate herbicides. Farmers will be 

encouraged to use multiple herbicide modes of action with DAS-68416-4 soybean to 

control their weed problems. DAS-68416-4 will be stacked with glyphosate resistance so 

that farmers may be able to select among 2,4-D, glyphosate, and a mixture of the two for 

their postemergence broadleaf weed control. Selection pressure for 2,4-D resistant weed 

biotypes will be mitigated by the ability to use glyphosate concurrently. Since glyphosate 

still effectively controls most weed species in most fields, and controls all weed biotypes 

that have developed resistance to 2,4-D, use of glyphosate will prevent or delay selection 

for 2,4-D resistance.

Formal herbicide stewardship programs being developed for use with DAS-68416-4 

soybeans will provide farmers with the knowledge and tools to optimally manage 

resistance to 2,4-D and glyphosate, to ensure that the benefits of herbicide-tolerant 

cropping systems can be continued for the long term. Dow AgroSciences’ stewardship 

program will include substantial grower education on cost-effective integrated weed 

management. An extensive network of sales representatives, field scientists, and 

agronomists will play an important role in educating and training applicators and growers 

on the proper use of the technology. Dow AgroSciences field personnel will work with 

growers to select the seed and herbicide products appropriate to their needs.

Dow AgroSciences will recommend a program approach for broad-spectrum weed 

control. Pre-plant and pre-emergence herbicides will be recommended to provide early 

season control of a range of broadleaf and grass herbicides. For example, Sonic®(a 

premixture of cloransulam-methyl and sulfentrazone)Dis a soil herbicide that can be 

applied prior to or at planting in soybeans to control broadleaf weeds. These herbicide 

programs provide additional modes of action and they control several weeds that are 

increasingly problematic in glyphosate-tolerant crops, such as horseweed (marestail), 

waterhemp, common lambsquarters, velvetleaf, common and giant ragweed, pigweed, 

morning glory, kochia, and Palmer amaranth.

Dow AgroSciences is voluntarily adopting mode of action labeling for its herbicides that 

can be used with DAS-68416-4 soybeans, following the WSSA mode of action 

classification. These labels will include clear weed resistance management language 

promoting agronomic practices that reduce the likelihood that resistant weed populations 

will develop and can be used to manage weed resistance if it occurs. These 

 

D

SONIC is a registered trademark of Dow AgroSciences LLC
Supplemental Information for USDA Petition for Nonregulated Status of DAS-68416-4 Soybeans Page 42 of 202

Dow AgroSciences LLC

recommendations will be product specific, but generally include the use of appropriate 

herbicide mixtures, rotation of herbicides from different mode of action groups, use of 

burndown and residual applications of herbicides at or prior to planting, use of full 

labeled rates when applied, use of alternative weed control practices such as delayed 

planting and use of weed-free crop seeds, and scouting of fields after applications for any 

weeds that may have escaped treatment or show evidence of less-than-expected control. 

Growers will also be asked to report to Dow AgroSciences any incidents of repeated nonperformance of these herbicides with DAS-68416-4 soybeans.

In addition to labeling on Dow AgroSciences herbicides, weed resistance management 

practices will be recommended in documentation that accompanies the DAS-68416-4

seed. As with Dow AgroSciences’ other genetically engineered seed products 

(Herculex®family of insect protection in corn, WideStrike®insect protection in cotton, 

and REFUGE ADVANCEDTM powered by SmartStax®in corn)Egrowers who purchase 

and plant soybean seed containing DAS-68416-4 will be required to have a signed 

Grower Agreement in place. The Grower Agreement is a legal and contractual obligation 

that includes a provision requiring them to follow the relevant Product Use Guide. 

Product Use Guides are being developed and will be provided to all growers using the 

technology. These Guides will describe appropriate trait stewardship guidelines 

including effective weed resistance management based around sound agronomic practices 

and integrated approaches to weed control.

The diversity of herbicide modes of action that can be applied to DAS-68416-4 soybeans, 

coupled with cultural approaches to weed management, provide the opportunity for

robust resistance management and help insure long term viability of each of the 

components. Therefore, Dow AgroSciences’ DAS-68416-4 herbicide tolerant soybeans 

will promote the sustainable use and benefits of herbicide tolerant crops.

5 Economic Benefits of Dow AgroSciences Herbicide Tolerant Technology

The introduction of glyphosate tolerant soybeans and corn enabled adoption of 

conservation tillage practices because weeds could be successfully controlled without 

additional tillage. Over the last few years, weed resistance to glyphosate has developed 

and continues to spread. Some weeds can be controlled with other herbicides at an 

additional cost. In some situations, farmers have reverted back from no-till systems to 

 

E

SmartStax® multi-event technology developed by Dow AgroSciences and Monsanto. 

TMREFUGE ADVANCED is a trademark of Dow AgroSciences LLC. 

®

SmartStax is a registered trademark of Monsanto Technology LLC.

®TMHERCULEX and the HERCULEX Shield Logo are registered trademarks of Dow AgroSciences LLC

REFUGE ADVANCED is not registered for sale or use in all states.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-68416-4 Soybeans Page 43 of 202

Dow AgroSciences LLC

conventional tillage or minimum tillage systems in order to control weeds such as 

marestail, giant ragweed and Palmer amaranth incurring not only the cost of additional 

tillage but also losing the positive environmental benefits associated with reduced tillage.

A study was conducted to evaluate the economic impacts of glyphosate resistant weeds 

and herbicide tolerant DAS-68416-4 soybeans and DAS-40278-9 corn at the farm level 

through individual case study analysis and to determine the aggregate economic effects at 

the national level using the IHS partial equilibrium models for US crops and farm 

income. The study is presented in Appendix A. Both the case study analysis and 

national analysis utilized scenario analysis to contrast a baseline situation of no weed 

resistance with situations of weed resistance without DAS-68416-4 and DAS-40278-9

technology and weed resistance with DAS-68416-4 and DAS-40278-9 technology.

Glyphosate resistant weed infestations significantly reduce farm income, erode net worth, 

and have significant environmental consequences from tillage changes. On average 

across all five soybean case studies, growers with DAS-68416-4 technology were able to 

recover 34 percent of their income lost from glyphosate resistant weeds. Those cases 

with tillage impacts recovered 45 percent of their lost income and those cases without 

tillage impacts recovered 18 percent.Similar to the case studies, on a national basis 

herbicide tolerant DAS-68416-4 soybeans and DAS-40278-9 corn were found in the 

study to offset over 18 percent of the net farm income impacts and eliminate environment 

impacts saving the equivalent of emissions from over 19,000 cars per year and reducing 

soil erosion by 2.6 million tons per year in the United States. Over the 2011 to 2020 

period, with DAS herbicide tolerant technology, growers would save $4 billion in net 

farm income and consumers would save $563 million.

6 Impact of 2,4-D on Herbicide Tolerant DAS-68416-4 Soybeans and DAS-40278-9

Corn on the Cost and Environmental Load of Herbicides Applied on Glyphosate 

Tolerant Corn and Soybeans to Control Glyphosate Resistant and Glyphosate 

Tolerant Weed Biotypes

An analysis was conducted to determine the impact of the use of 2,4-D on herbicide 

tolerant DAS-68416-4 soybeans and DAS-40278-9 corn on the environmental load of 

herbicides applied on glyphosate tolerant corn and soybeans to control glyphosate 

resistant and hard-to-control weed biotypes. Third party proprietary data for corn and 

soybeans and a survey of university weed specialists were used to create assumptions for 

how growers would change herbicide use on glyphosate tolerant corn and soybeans to 

manage glyphosate resistant and hard-to-control weed biotypes. The full analysis is 

presented in Appendix B and the university weed specialist survey is presented in 

Appendix C. Analyses were completed for corn in five states and for soybeans in five 
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Dow AgroSciences LLC

states targeting control of a glyphosate resistant weed species that are present in each 

state

In DAS-68416-4 soybeans, the analysis indicated that the use of 2,4-D on herbicide 

tolerant DAS-68416-4 soybeans will vary from a reduction in one scenario of 0.10 lbs 

ai/ac to an increase in others of up to 0.65 lbs ai/ac, with an average increase across all 

scenarios of only 0.3 lbs, compared to the use of currently registered alternative nonglyphosate herbicides. The results in soybeans differ from those in corn because many of 

the non-glyphosate herbicide alternatives for control of broadleaf weeds in soybeans are 

very low rate products (examples: carfentrazone, flumioxazin, fomesafen, sulfentrazone). 

Conclusions

Herbicide tolerant crops have played, and continue to play, a central role in improving 

U.S. agricultural productivity and protecting the agricultural environment. Herbicide 

tolerant crops have enabled the widespread adoption of conservation tillage practices that 

preserve soil health, can improve water quality, and improve efficiency of utilization of 

agricultural inputs, while improving weed management and increasing farm income. 

U.S. farmers have enjoyed the benefits of an easy-to-use, flexible, and cost-effective 

weed management technology based around glyphosate. This success has resulted in a 

recent rise in glyphosate resistant weeds and hard-to-control weeds as a consequence of 

over-reliance on a single herbicide mode of action. Alternatives to the glyphosate system 

that share the same benefits but enable use of alternative modes of action are necessary to 

preserve the benefits of herbicide tolerant crops for the long-term.

Dow AgroSciences has developed an alternative herbicide tolerant technology for 

soybeans using the aryloxyalkanoate dioxygenase-12 (AAD-12) and phosphinothricin 

acetyltransferase (PAT) proteins. Dow AgroSciences’ herbicide tolerant DAS-68416-4 

soybeans provides an important alternative to glyphosate-only herbicide tolerance and is 

a powerful tool that can help solve the challenges of weeds that are resistant to, or hardto-control with, glyphosate. By enabling the use of 2,4-D and glufosinate herbicides in 

addition to glyphosate, DAS-68416-4 soybeans will allow the use of one more tool to 

control glyphosate resistance. In addition, Dow AgroSciences’ herbicide tolerant trait 

will enable easy implementation of effective weed resistance management programs 

based on pre-mixes, tank mixes, and/or herbicide rotation programs that use multiple 

modes of action to control weed populations. Specific stewardship programs to be 

implemented alongside DAS-68416-4 soybeans will help to preserve glyphosate efficacy 

and promote 2,4-D resistance management.

DAS-68416-4 soybeansDAS-68416-4 soybeansDAS-68416-4 soybeansBy offering a 

simple, effective, and flexible alternative to glyphosate-only herbicide tolerant crops, 
Supplemental Information for USDA Petition for Nonregulated Status of DAS-68416-4 Soybeans Page 45 of 202

Dow AgroSciences LLC

Dow AgroSciences’ herbicide tolerant DAS-68416-4 soybeans will create the 

opportunity to preserve and extend the many environmental and economic benefits 

farmers have realized from using glyphosate tolerant crops and provide U.S. farmers with 

a cutting edge technology to enhance global competitiveness.

 

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40 Falck–Zepeda, Jose B., G. Traxler, R.G. Nelson “Rent Creation and Distribution From 

Biotechnology Innovations: The Case of Bt Cotton and Herbicide-Tolerant Soybeans in 

1997,” Agribusiness, Vol. 16, 1, 21–32. 2000.

41 Moschini, Giancarlo, H. Lapan, and A. Sobolevsky “Roundup Ready Soybeans and 

Welfare Effects in the Soybean Complex,” Agribusiness, 16 (1): 33-55. 2000.
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42 Qaim, Matin, and G. Traxler (2002). “Roundup Ready Soybeans in Argentina: Farm 

Level, Environmental, and Welfare Effects,” 6

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Ravello, Italy, July 11-14

43 Trigo, E.J., and Cap, E.J. (2006). “Ten Years of Genetically Modified Crops in 

Argentine Agriculture,” Research Report, Argentine Council for Information and 

Development of Biotechnology – ArgenBio.

44 Benbrook, Charles (1999). “Evidence of the magnitude and consequences of the 

Roundup Ready Soybean Yield Drag from University-Based Variety Tests in 1998, Ag 

BioTech Info Net Technical Paper 1, www.biotech-info.net/RR_yield_drag_98.pdf

45 Duffy, Michael, and M. Ernst. (1999). Does Planting GMO Seed Boost 

Farmers'Profits? Iowa State University, Leopold Center for Sustainable Agriculture, 

Leopold Letter, Vol. 11, No. 3.

46 Elmore, R.W., Roeth, F.W., Nelson, L. A., Shapiro, C. A., Klein, R. N., Knezevic, S. 

Z.,Martin, A. “Glyphosate-Resistant Soybean Cultivar Yields Compared with Sister 

Lines,” Agronomy Journal, 93: 408–412. 2001.

47 Oplinger, E.S., M. J. Martinka, J. M. Gaska, K. A. Schmitz and C. R. Grau. Wisconsin 

soybean variety test results, A3654, Department of Agronomy and Plant Pathology, 

University of Wisconsin-Madison, 1998. 

http://www.uwex.edu/ces/soybean/research/98soyvar/98soyvar.pdf.

48 Marra, M., Pardey, P., & Alston, J. (2002). The payoffs to transgenic field crops: an 

assessment of the evidence. AgBioForum, 5(2), 43–50.

49 Gianessi, L.P., and J. E. Carpenter (2000). “Agricultural Biotechnology: Benefits of 

Transgenic Soybeans,” A Report by National Center for Food and Agricultural Policy, 

Washington DC.

50 Carpenter, J. C. Peer-reviewed surveys indicate positive impact of commercialized 

GM crops. Nature Biotechnology, 28 (4), 319-321. 2010.

51 Bertram, M. G., & Pedersen, P. (2004). Soybean: Adjusting Management Practices 

Using Glyphosate-Resistant Soybean Cultivars. Agronomy Journal, 96, 462-468.

52 Frisvold, G. B., Hurley, T. M., & Mitchell, P. D. (2009). Overview: Herbicide 

Resistant Crops - Diffusion, Benefits, Pricing, and Resistance Management. 

AgBioForum, 12 (3 & 4), 244-248.

53 Boerboom C.M. 2007. The stewardship continuum. 32–36 in Boerboom C.M., Owen 

M.D.K. National Glyphosate Stewardship Forum II: A Call to Action. St. Louis, MO: 

North Central IPM Center. http://www.weeds.iastate.edu/mgmt/2007/NGSFII_final.pdf. 

Accessed: April 28, 2010.

54 Culpepper A.S. 2006. Glyphosate-induced weed shifts. Weed Technol. 20: 277–281.

55 Heap, I. 2010. The international survey of herbicide resistant weeds. from 

WeedScience.org, http://www.weedscience.org/. Accessed March 31, 2010.

56 Third Party Proprietary Data, 2009.
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57 Ervin, D.E. et.al. Impact of Genetically Engineered Crops on Farm Sustainability in the 

United States. Committee on the Impact of Biotechnology on Farm-Level Economics 

and Sustainability. National Research Council. Prepublication Copy. ISBN: 0-309-

14709-3. 2010.

58 VanGessel, M.J. 2001. Glyphosate-resistant horseweed from Delaware. Weed Science 

49:703–705.

59 Givens, W. A. 2010. Shifts in Herbicide Use, Tillage Practices, and Perceptions of 

Glyphosate-resistant Weeds Following Adoption of Glyphosate-resistant Crops. Miss. 

State Univ. Dissertation. http://sun.library.msstate.edu/ETD-db/theses/available/etd03312010-103616/. Accessed: April 28, 2010.

60 Owen, MDK. 2008. Weed species shifts in glyphosate-resistant crops. Pest 

Management Science 64(4):377-387.

61 Vindrine, P.R., J.L. Griffin and D.C. Blouin. 2002. Evaluation of reduced rates of 

glyphosate and chlorimuron in glyphosate-resistant soybean (Glycine max). Weed 

Technology 16:731-736.

62 Golden Harvest. 2007. Weed management strategies for herbicide tolerant corn. 

http://www.ghcommunications.com/Uploads/Agronomy_Studies/HerbicideTolerantCorn.

pdf. Accessed May 5, 2011.

63 Third party proprietary data.

64 Herbicide Resistance Action Committee. 

http://www.hracglobal.com/Publications/HRACManagementandWeedResistance/tabid/2

28/Default.aspx. Accessed April 28, 2010.

65 Weed Resistance Management Guidelines. 

http://www.weedresistancemanagement.com/guidelines.html. Accessed April 28, 2010.

66 HRAC. Classification of Herbicides According to Site of Action. 

http://www.hracglobal.com/Publications/ClassificationofHerbicideSiteofAction/tabid/222

/Default.aspx. Accessed May 5, 2011.

67 HRAC. Guidelines to the Management of Herbicide Resistance. 

http://www.hracglobal.com/Publications/ManagementofHerbicideResistance/tabid/225/D

efault.aspx. Accessed May 5, 2011.

68 Neve, P. 2008. Simulation modeling to understand the evolution and management of 

glyphosate resistance in weeds. Pest Management Science 64:392–401

69 Heap, I. 2009. The International Survey of Herbicide Resistant Weeds. 

http://www.weedscience.com

70 Jasieniuk, M., Brule-Babel, A.L. and Morrison, I.N. 1996. The evolution and genetics 

of herbicide resistance in weeds. Weed Science 44:176-193.

71 Walsh, T.A., Neal, R., Merlo, A.O., Honma, M., Hicks, G.R., Wolff, K., Matsumura, 

W. and Davies, J.P. 2006. Mutations in an auxin receptor homolog AFB5 and in SGT1b 
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confer resistance to synthetic picolinate auxins and not to 2,4-Dichlorophenoxyacetic 

acid or indole-3-acetic acid in Arabidopsis. Plant Physiology 142:542-552.

72 Kern, A.J., Chaverra, M.E. and Dyer, W.E. 2005. Dicamba-responsive genes in 

herbicide-resistant and susceptible bioytpes of kochia (Kochia scoparia). Weed Science 

53:139-145.

73 Bourdot, G.W., Saville, D.J., and Hurrell, G.A. 1996. Ecological fitness and the 

decline of resistance to the herbicide MCPA in a population of Ranunculus acris. Journal 

of Applied Ecology 33:151-160.

74 Cranston, H.J., Kern, A.J., Hackett, J.L., Miller, E.K., Maxwell, B.D., and Dyer, W.E. 

2001. Dicamba resistance in kochia. Weed Science 49:164-170.
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Economic Impacts of Glyphosate Resistant Weeds and the Benefits 

of DHT Technology

Appendix A:
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Table of Contents

1. Introduction _____________________________________________________55

2. Case Study Analysis _______________________________________________55

2.1 Case Study Design______________________________________________56

2.1.1 Case Studies and Farm Selection _____________________________56

2.1.2 State Weed Specialist Interviews _____________________________57

2.1.3 Cost of Controlling GR Weeds_______________________________58

2.1.4 Convenience Benefits Lost in Controlling GR Weeds Without DHT _59

2.1.5 The Cost of Controlling GR Weeds With Tillage ________________60

2.2 Case Study Scenario Definitions __________________________________64

2.3 Environmental Impact Analysis in the Case Studies__________________68

2.3.1 Simulation of the Environmental Impacts ______________________69

2.3.2 Data____________________________________________________70

2.3.3 Model outputs ____________________________________________71

3. Case study results_________________________________________________71

3.1 Economic Impacts______________________________________________71

3.1.1 Soybean Results __________________________________________72

3.1.2 Corn Results _____________________________________________73

3.1.3 Comparison of Soybean and Corn Results ______________________73

3.2 Environmental Impacts _________________________________________75

4. National Analysis _________________________________________________77

4.1 National Scenario Assumptions___________________________________77

4.1.1 GR Weed Infestation Levels_________________________________77

4.1.2 Cost of Controlling GR Weeds_______________________________79

4.1.3 Convenience Benefits ______________________________________80

4.1.4 Assumptions on the Use of Tillage to Control GR Weeds __________80

4.1.5 Costs of Changing Tillage Systems ___________________________82

4.1.6 Adoption Rate Assumptions for GT Seed ______________________83

4.2 Conservative Bias in the National Analysis Assumptions______________84

5. National Analysis Results __________________________________________85

5.1 National Analysis Economic Impacts ______________________________85

5.2 National Analysis Environmental Impacts__________________________88

6. Economic and Environmental Impact Conclusions______________________91

7. Supplemental Tables ______________________________________________93

8. End Notes ______________________________________________________118
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Tables

Table 1. Case Study Farm Coverage................................................................................. 56

Table 2. Average Harvested Cropland By Farm, Acres .................................................. 57

Table 3. Resistant Weeds By County .............................................................................. 58

Table 4. Cost of Recommended Herbicide Program to Control Resistant Weeds .......... 59

Table 5. Illinois Soybean Tillage Costs By System.......................................................... 62

Table 6. Input Cost Reduction For Selected Reduced Tillage Systems Compared with 

Conventional tillage ........................................................................................... 63

Table 7. Summary of Case Study Farm Impacts, 2011-2020 Average of Annual Impacts 

(Change from Scenario 1, No Weed Resistance)............................................... 74

Table 8. Environmental Impacts: Factors Contributing to Water Quality....................... 75

Table 9. Environmental Impacts: Average Annual Carbon Sequestration ...................... 76

Table 10. Summary of Soybean Case Study Environmental Impacts............................. 76

Table 11. Soybean Glyphosate Resistant Weed Infestation Estimates (Weighted Average 

Based on State Acreages)................................................................................... 78

Table 12. Corn Glyphosate Resistant Weed Infestation Estimates (Weighted Average 

Based on State Acreages)................................................................................... 78

Table 13. Additional Herbicide Cost to Control GR Weeds Without DHT in Soybeans 79

Table 14. Additional Herbicide Cost to Control GR Weeds Without DHT in Corn....... 80

Table 15. Convenience Benefits Lost from GR Weed Control ....................................... 80

Table 16. No-Till Soybean Acres in Reported States...................................................... 81

Table 17. Share of Soybean Acres Using Tillage to Control GR Weeds Weighted 

Average Based on State Acreages ..................................................................... 81

Table 18. Cost of Switching from No-Till to Conventional Tillage Systems in Soybeans 

(Unadjusted for No-Till and the Share of Growers Using Tillage for GR Weed 

Control).............................................................................................................. 82

Table 19. Cost of Switching from No-Till to Conventional Tillage Systems in Soybeans 

(Adjusted for No-Till and the Share of Growers Using Tillage for GR Weed 

Control).............................................................................................................. 82

Table 20. Total Soybean Cost of Production Change to Control GR Weeds (Scaled for 

GR Weed Infestations and GT Soybean Seed Adoption).................................. 83

Table 21. Adoption Rate of GT Seed............................................................................... 84

Table 22. Total Corn Cost of Production Change to Control GR Weeds (Scaled for GR 

Weed Infestations and GT Corn Seed Adoption) .............................................. 84

Table 23. Farm Income Impacts of GR Weeds Without and With DHT Technology .... 86

Table 24. Changes in Consumer Welfare, Million Dollars ............................................. 88

Table 25. Change in No-Till Soybean Acres With GR Weeds Without DHT Technology

............................................................................................................................ 89

Table 26. Increase in Soil Loss from Switching from No-Till to Conventional Tillage 

(With GR Weeds But Without DHT Technology) ............................................ 89

Table 27. Increase in Carbon Emissions from Increased Fuel Use (With GR Weeds But 

Without DHT Technology)................................................................................ 90

Table 28. Increase in Carbon Emissions from Loss of Soil Carbon Sequestration (With 

GR Weeds But Without DHT Technology)....................................................... 90
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Table 29. Total Increase in Carbon Emissions from All Sources (With GR Weeds But 

Without DHT Technology)................................................................................ 90

Table 30. Arkansas Soybean Herbicide Programs............................................................ 93

Table 31. Georgia Soybean Herbicide Programs.............................................................. 94

Table 32. Illinois Soybean Herbicide Programs............................................................... 95

Table 33. Iowa Soybean Herbicide Programs................................................................... 96

Table 34. Minnesota Soybean Herbicide Programs.......................................................... 97

Table 35. Illinois Corn Herbicide Programs..................................................................... 98

Table 36. Iowa Corn Herbicide Programs ........................................................................ 99

Table 37. Minnesota Corn Herbicide Programs ............................................................. 100

Table 38. Ohio Corn Herbicide Programs ...................................................................... 101

Table 39. Georgia Corn Herbicide Programs ................................................................. 102

Table 40. Cultivated Soils and Soil Texture ................................................................... 103

Table 41. Factors Contributing to Water Quality in Phillips County, Arkansas ........... 104

Table 42. Factors Contributing to Water Quality in Dooly/Macon County, Georgia ... 104

Table 43. Factors Contributing to Water Quality in Dooly/Macon County, Georgia ... 105

Table 44. Factors Contributing to GHGs and Carbon Sequestration in Phillips County, 

Arkansas........................................................................................................... 106

Table 45. Factors Contributing to GHGs and Carbon Sequestration in Dooly/Macon 

County, Georgia............................................................................................... 106

Table 46. Factors Contributing to GHGs and Carbon Sequestration in Fayette County, 

Illinois.............................................................................................................. 107

Table 47. Phillips County, Arkansas Case Study Results, 936 Acre Soybean Farm..... 108

Table 48. Dooly County, Georgia Case Study Results, 320 Acre Soybean Farm......... 109

Table 49. Fayette County, Illinois Case Study Results, 250 Acre Soybean Farm......... 110

Table 50. Story County, Iowa Case Study Results, 215 Acre Soybean Farm............... 111

Table 51. Renville County, Minnesota Case Study Results, 260 Acre Soybean Farm . 111

Table 52. Fayette County, Illinois Case Study Results, 245 Acre Corn Farm .............. 112

Table 53. Story County, Iowa Case Study Results, 320 Acre Corn Farm..................... 112

Table 54. Renville County, Minnesota Case Study Results, 390 Acre Corn Farm....... 113

Table 55. Darke County, Ohio Case Study Results, 135 Acre Corn Farm.................... 113

Table 56. U.S. Corn Supply and Demand Impacts........................................................ 114

Table 57. U.S. Soybean Supply and Demand Impacts.................................................. 115

Table 58. U.S. Corn Acreage Impacts By Region ......................................................... 116

Table 59. U.S. Soybean Acreage Impacts By Region ................................................... 117
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1. Introduction

The introduction of glyphosate-tolerant (GT) crop technology has had a revolutionary 

impact on corn and soybean farming in the US. The rapid wide scale adoption of GT 

soybeans and corn enabled adoption of conservation tillage practices because weeds 

could be successfully controlled without additional tillage. Over the last few years, 

however, weed resistance to glyphosate has developed and continues to spread. Some 

weeds can be controlled with other herbicides at an additional cost. In some situations, 

growers have reverted back from no-till systems to conventional tillage or minimum 

tillage systems in order to control weeds such as marestail, incurring not only the cost of 

additional tillage but also losing the positive environmental benefits associated with 

reduced tillage. The analysis described in this report takes a look forward at the value 

and benefits that could be offered by Dow AgroSciences’ herbicide tolerant trait 

technology (DS-40278-9 or DHT) that is part of the EnlistTM Weed Control System1

versus other projected herbicide and tillage options.

This study evaluates the economic impacts of glyphosate resistant (GR) weeds and the 

benefits of DHT technology by two means - at the farm level through individual case 

study analysis and at the national level using the IHS partial equilibrium models for U.S. 

crops and farm income to determine aggregate economic effects. Both the case studies

and the national analysis utilize scenario analysis to contrast a baseline situation of no 

weed resistance with situations of glyphosate-weed resistance without DHT technology 

and weed resistance with DHT technology. Certainly weed resistance is already an 

issue, but by assuming no weed resistance as the base case, one can first determine the 

economic impact of weed resistance and then determine how much of that impact can be 

offset with DHT technology.

The case studies enable the evaluation of a particular, realistic farm situation specific to a 

given location providing measures of impacts on farm expenses, farm income, and net 

worth. Then to examine the impacts beyond just the particular single farm case to that of 

US growers more broadly, a national analysis was constructed using representative 

measures of the critical factors driving economic impacts such as the types of GR weeds 

by region, methods of control by region, tillage impacts by region, and ultimately the cost 

of GR weed control by region. 

2. Case Study Analysis

The development of glyphosate resistance in weeds has had significant financial and 

production impacts on growers. In order to provide perspective on the farm level 

economic impacts, nine case studies were constructed. These case studies included five 

average soybean farms and four average corn farms scattered among six counties with 

known weed resistance issues. These case studies were selected to give a broad-base and 

realistic representation of situation across the corn and soybean production areas (see 

 1 Enlist is a trademark of Dow AgroSciences LLC. Components of the Enlist Weed Control System have 

not yet received regulatory approvals.
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Table 1). These farms are not specific farming entities but rather represent average farms 

for the county using USDA and Ag Census data2

Table 1. Case Study Farm Coverage

. Environmental impacts for those farms 

affected by tillage changes were also calculated and those results are reported following 

the economic impacts. 

2.1 Case Study Design

Each of the case studies included at least three scenarios and two additional scenarios 

where tillage is used as a method of controlling resistant weeds. In each scenario, the 

economic impact on the cost of producing the crop and resulting farm income, cash flow, 

and net worth was estimated for the 2010 through 2020 period. For those scenarios 

including tillage impacts, environmental impacts were also calculated. 

2.1.1 Case Studies and Farm Selection

Although farms usually grow more than one type of crop, we have included only the crop 

of interest in each case study. And although a single farm may have problems with 

multiple resistant weeds which would further complicate the management options, only a 

single resistant weed was used in each scenario. The size of the farm selected is based on 

the 2007 Agricultural Census for each crop in each county (see Table 2). Net farm 

income is estimated in each year over the 2011 – 2020 period using data specific to each 

county and/or state as available and the IHS global agricultural forecast8. The IHS global

agricultural forecast provides the baseline forecast for crop prices, yields, government 

payments, cost of production, average indebtedness, land values, and farm machinery 

depreciation. This baseline forecast provides a basis for comparison and the starting 

point from which changes in assumptions can be made for each of the specific scenarios. 

The emphasis of this analysis is on the changes from the IHS baseline forecast rather than 

on the specific forecasted levels. Scenario impacts are generated through the changes in 

the baseline projections of cost of production. Despite the additional complexity of 

 2 USDA-NASS (U.S. Department of Agriculture – National Agricultural Statistics Service) 2007 Census of 

Agriculture. Available online at: http://www.agcensus.usda.gov/Publications/2007/index.asp

Location Soybeans Corn

Darke County, Ohio No Yes

Story County, Iowa Yes Yes

Renville County, Minnesota Yes Yes

Fayette County, Illinois Yes Yes

Dooly County, Georgia Yes No

Phillips County, Arkansas Yes No
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handling additional herbicides for the control of resistant weeds, the scenarios do not 

assume crop yields are affected.

Table 2. Average Harvested Cropland By Farm, Acres

Source: USDA-NASS (U.S. Department of Agriculture – National Agricultural Statistics Service) 2007 

Census of Agriculture. Available online at: http://www.agcensus.usda.gov/Publications/2007/index.asp

2.1.2 State Weed Specialist Interviews

The herbicides selected to control the GR weeds are those reported in a third party 

proprietary survey which captures the top herbicide programs actually used from a 

sample of approximately 5000 large farms. In order to establish the GR weeds of greatest 

concern and methods of their control, independent, recognized University weed 

specialists in a number of states were interviewed. The experts included Ken Smith, 

professor of weed science at the University of Arkansas; Stanley Culpepper, associate 

professor of weed science at the University of Georgia; Mike Owen, associate chair of 

the agronomy department at Iowa State University; Bill Johnson, associate professor of 

weed science at the Purdue University in Indiana; Jim Martin, extension professor 

specializing in weed science at the University of Kentucky; Dallas Peterson, professor of 

agronomy at the Kansas State University; Kevin Bradley, assistant professor and state 

extension weed specialist at the University of Missouri-Columbia; Jeff Gunsolus, 

professor and extension weed scientist at the University of Minnesota; and Tom Eubank, 

assistant professor and weed scientist at Mississippi State University. The process 

included a written survey in combination with phone interviews. The sample size is 

small since only one expert from each state was contacted. The experts were not 

compensated to participate in the survey.

Tillage was found to be an option growers are returning to in some situations. Interviews 

with the University weed specialists in each state indicated tillage has been used by some 

soybean growers to control marestail in Missouri and Arkansas and palmer amaranth in 

Georgia, both recognized as GR weeds. Marestail is found throughout the northern 

United States. Marestail can be controlled in more intensive tillage systems. Therefore 

it is only a problem in crops in states where no-till is employed such as southern Illinois, 

Arkansas, Mississippi, Missouri, Kentucky, Indiana, and Ohio. Marestail is not a 

problem where more intensive tillage systems are dominantly used such as Iowa and 

Minnesota. The University weed specialists reported that corn growers do not use tillage 

Location Soybeans Corn

Darke County, Ohio 135

Story County, Iowa 215 320

Renville County, Minnesota 260 390

Fayette County, Illinois 250 245

Dooly County, Georgia 320

Phillips County, Arkansas 935
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as an alternative to control glyphosate resistant weeds because of the effectiveness of 

alternative herbicides in controlling GR weeds. It should be pointed out that the 

University weed specialists stated that no-till growers use tillage reluctantly. Not only is 

tillage expensive, it is also time intensive and accelerates soil erosion.

Table 3. Resistant Weeds By County

2.1.3 Cost of Controlling GR Weeds

The cost of controlling GR weeds is significant. The details of the alternative herbicide 

programs are presented in Table 30 through Table 39 in the Supplemental Tables in 

Section 7 at the end of this report. These Supplemental Tables document the most 

popular herbicide programs in use for the specific locations based on data from a 2009 

third party proprietary survey as well as DHT herbicide programs. These current popular 

programs include GT programs, conventional programs, and modification of current 

herbicide programs to address GR weeds. Although some growers may elect herbicide 

options not listed, these represent the most likely options from herbicides currently 

registered for these uses based on third party proprietary data.

Table 4 presents a summary of the average cost per acre of the various herbicide 

programs currently used with and without GR weeds. The second column of Table 4

below presents the average herbicide costs across currently used programs according to 

the third party proprietary survey. The third column represents the continued cost of 

using a glyphosate plus the additional cost of non-glyphosate herbicides to control the 

GR weeds listed in Table 3 (based on label recommendations from currently available 

herbicides). The third column does not include any costs of additional tillage if that is 

also a method of control for resistant weeds.

Location Soybeans Corn

Darke County, Ohio Giant Ragweed

Story County, Iowa Giant Ragweed Waterhemp

Renville County, Minnesota Waterhemp Giant Ragweed

Fayette County, Illinois Marestail Waterhemp

Dooly County, Georgia Palmer Amaranth

Phillips County, Arkansas Palmer Amaranth
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Table 4. Cost of Recommended Herbicide Program to Control Resistant Weeds

Source: 2009 third party proprietary survey data, average cost per acre of top herbicide programs used (see 

supplemental tables 30-39).

* DHT program cost excludes the seed technology premium and utilizes 2009 2,4-D prices because the 

herbicide and technology fee price structures have not been established.

2.1.4 Convenience Benefits Lost in Controlling GR Weeds Without DHT

Not only do growers incur the additional herbicide costs for controlling GR weeds, they 

also lose the convenience benefits associated with using only glyphosate. In the 

economic literature, convenience benefits are often referred to as non-pecuniary aspects. 

There are a few studies which have quantified these benefits through grower surveys. 

1,2,3

3

However, a 2006 article by Marra and Piggott suggests that these benefits are overstated 

due to part-whole bias. Part-whole bias occurs when the individual values of each nonpecuniary benefit sum to a much greater level than the grower's assessment of the total 

non-pecuniary benefits. Their conclusion on the issue of part-whole bias is that the 

individual values of each non-pecuniary benefit are overstated by 60 percent. This 

analysis uses the levels of non-pecuniary benefits associated with GT crops quantified in 

journal articles adjusted down by the 60 percent overstatement. 

Marra and Piggott specifically re-analyzed their 2004 data from the national soybean 

survey.

1

 Their unadjusted estimate of the value of the convenience aspect for GT 

soybeans was $10 per acre. After applying their methodology to remove the part-whole 

bias, they estimated the convenience benefit at $3.33 per acre. 

Location Top GT 

herbicide 

programs 

with no 

resistant 

weeds

Likely GT 

herbicide 

programs 

with resistant 

weeds

DHT 

program with 

resistant 

weeds*

$/Acre $/Acre $/Acre

Soybeans

 Story County, Iowa 16.05 31.49 15.23

 Renville County, Minnesota 16.36 31.49 17.40

 Fayette County, Illinois 19.21 31.49 16.52

 Dooly County, Georgia 18.92 28.64 19.84

 Phillips County, Arkansas 16.29 44.34 19.60

Corn

 Darke County, Ohio 18.84 33.58 19.88

 Story County, Iowa 19.23 32.10 15.43

 Renville County, Minnesota 17.91 31.80 14.12

 Fayette County, Illinois 17.57 33.40 18.61
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The convenience benefit for corn is not as explicitly reported. In a 2009 journal article 

by Brookes and Barfoot, they report that a 2003 survey suggested total non-pecuniary 

benefits for GT corn was $14.44 per acre.4

 They also report that the convenience share 

of the total non-pecuniary benefits ranges between 50 and 66 percent. Assuming an 

average of 58 percent and adjusting for the part-whole bias (60 percent overstatement) 

yields, the convenience benefit for corn is $3.00 per acre, approximately 10 percent lower 

than soybeans. Based on economic literature discussed above, in Scenario 3 described 

below in Section 2.2, convenience benefits of the use of GT soybeans and corn are 

assumed to be $3.33 and $3.00 per acre respectively. The values used for the 

convenience factors are realistic and even conservative compared to some of the literature 

estimates

2.1.5 The Cost of Controlling GR Weeds With Tillage

Some of the University weed specialists reported that some growers used tillage as an 

option for controlling GR weeds, serving as a substitute for a pre-plant herbicide burn 

down of weeds. This means that herbicide cost of $9.55 per acre for a pre-plant 

application of glyphosate (average price of glyphosate × average application rate) can be 

subtracted from the total herbicide cost where pre-plant tillage is used. However, the 

additional cost of additional tillage (fuel, machinery overhead, and repair expenses) must 

be added back to the total production costs.

Tillage cost impacts are based on the reversion from no-till back to conventional till or 

"minimum till" systems. Minimum tillage in the case studies is defined as the same 

tillage operations as no-till systems with an additional pre-plant pass with horizontal disk, 

drag, and rolling basket. Tillage is primarily used as a control option for GR marestail 

and palmer amaranth. In the case studies, the soybean farms in Georgia, Arkansas and 

Illinois include tillage effects. The change in tillage has specific cost implications 

affecting fuel, labor, machinery, and fertilizer as well as environmental impacts such as

soil loss, carbon emissions, and nutrient loss. 

In April 2006, the University of Illinois published a bulletin documenting the cost of 

alternative tillage systems. This bulletin provides the basis for the machinery operations 

used in conventional, no-till, and no-till plus disking operations.5

 The machinery 

operations used to prepare for planting included chisel plowing, disking, and field 

cultivation. Since 2006 growers have collapsed the disking operation and field 

cultivation operation into one operation using a combination tool that includes a field 

cultivator, drag, and rolling basket reducing costs. The University of Illinois has not 

specifically published an update of the 2006 bulletin comparing the costs of alternative 

tillage systems however they have updated the costs of the various components used in 

that analysis. In April 2010, the University of Illinois published updated estimates of the 

cost of fuel, labor, and equipment overhead expenses required for various tillage 

operations.6, 7

 The University of Illinois used fuel cost of $2.90 per gallon and labor 

costs of $16 per hour. 
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Since 2006, the distribution of costs has changed with less fuel use per acre, but a 

significant increase in tractor and implement overhead per acre for conventional tillage 

systems. In the 2006 data, University of Illinois estimated total soybean no-till costs at 

$49.06 per acre compared with $46.07 per acre using updated 2010 cost estimates (see

Table 5). However, in the case of soybean conventional tillage systems, University of 

Illinois estimated a cost of $62.36 per acre in 2006 compared with $64.47 using updated 

2010 cost estimates (see Table 5). The total machinery implement costs for no-till 

systems in 2006 was $35.23 compared to 37.87 in the 2010 estimates. However, total 

machinery implement costs for conventional tillage systems in 2006 was $43.63 

compared with $50.37 in the 2010 estimates. Machinery implement costs increased less 

in no-till operations because the implement overhead costs for no-till planters actually 

declined since 2006. Fuel use in conventional tillage systems declined from 3.7 gallons 

per acre in the 2006 estimates to 2.7 gallons per acre in the 2010 estimates while no-till 

fuel use decreased from 2.4 gallons per acre in the 2006 estimates to 1.5 gallons per in 

the 2010 estimates. The data also suggests that the equipment cost for no till planting has 

declined. 
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Table 5. Illinois Soybean Tillage Costs By System

Sources: University of Illinois, Farm Management6,7

The 2010 Illinois soybean tillage cost estimates serve as a basis for determining the cost 

difference between conventional, no-till and "minimum till" are presented in Table 6

where minimum till is defined as no-till plus the disking operation discussed above. The 

overhead and labor expenses used in Table 6 are the same as the Illinois estimates, but 

the fuel prices were updated to reflect the IHS estimates of the 2010 average retail diesel 

prices adjusted for the federal excise tax exemption for farm use.8

 In addition, for 

Georgia the diesel fuel use was adjusted using USDA's Energy Estimator program which 

estimates the fuel use for various types of tillage systems specific to a growing region.

9

Fuel Use Fuel Labor

Implement 

Overhead

Tractor 

Overhead Total

Gal/Acre --------------------------- Dollars Per Acre --------------------------

Conventional Tillage

Dry Fertilizer 0.20 0.64 0.06 0.80 0.50 2.00

Chisel Plow 0.70 2.20 1.00 4.10 4.60 11.90

Field cultivator, drag, rolling basket 0.60 2.00 1.00 4.20 4.30 11.50

Plant 0.50 1.60 1.30 5.40 2.80 11.10

Spray 0.03 0.10 0.20 3.50 0.00 3.80

Spray (1/3) 0.01 0.03 0.07 1.17 0.00 1.27

Combine 0.66 2.10 1.80 3.80 15.20 22.90

Total 2.70 8.67 5.43 22.97 27.40 64.47

No Till

Dry Fertilizer 0.20 0.64 0.06 0.80 0.50 2.00

Spray 0.03 0.10 0.20 3.50 0.00 3.80

No Till Drill 0.50 1.60 1.30 6.60 2.80 12.30

Spray 0.03 0.10 0.20 3.50 0.00 3.80

Spray (1/3) 0.01 0.03 0.07 1.17 0.00 1.27

Combine 0.72 2.10 1.80 3.80 15.20 22.90

Total 1.50 4.57 3.63 19.37 18.50 46.07

No Till with one tillage pass preplant

Dry Fertilizer 0.20 0.64 0.06 0.80 0.50 2.00

Horizontal disk, drag, rolling basket 0.80 2.50 1.70 4.70 4.60 13.50

No Till Drill 0.50 1.60 1.30 6.60 2.80 12.30

Spray 0.03 0.10 0.20 3.50 0.00 3.80

Spray (1/3) 0.01 0.03 0.07 1.17 0.00 1.27

Combine 0.72 2.10 1.80 3.80 15.20 22.90

Total 2.27 6.97 5.13 20.57 23.10 55.77

 

The exact values from the energy estimator are not used because the University of Illinois 

data suggest that machinery has become more fuel efficient. Instead Georgia energy 

costs are adjusted relative to the Illinois estimates using Georgia's fuel use for the various 

tillage operations relative to Illinois fuel use for various tillage systems as reported by 
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USDA's Energy Estimator program. Arkansas diesel fuel use by tillage type was 

reported by USDA's Energy Estimator to be the same as Illinois.

Table 6. Input Cost Reduction For Selected Reduced Tillage Systems Compared 

with Conventional tillage

Input Use Differences Input Cost Reduction

Conventional No-Till

No-Till Plus 

Disking 

Operation*

Conventional - 

No Till

Conventional - 

No Till Plus 

Disking 

Operation

Farm Input 

Prices

Conventional - 

No Till

Conventional - 

No Till Plus 

Disking 

Operation

Soybean Diesel Fuel Use - Gallons/Acre**

gallons per acre $/Gallon $/Acre

Illinois 2.70 1.50 2.27 1.20 0.43 2.62 3.14 1.13

Georgia 4.12 2.69 3.49 1.43 0.63 2.62 3.74 1.65

Arkansas 2.70 1.50 2.27 1.20 0.43 2.62 3.14 1.13

Equipment Overhead Expenses

dollars per acre $/Acre

Illinois 50.37 37.87 43.67 12.5 6.70 12.50 6.70

Georgia 50.37 37.87 43.67 12.5 6.70 12.50 6.70

Arkansas 50.37 37.87 43.67 12.5 6.70 12.50 6.70

Labor

dollars per acre $/Hour $/Acre

Illinois 0.34 0.23 0.32 0.11 0.02 16 1.82 0.32

Georgia 0.34 0.23 0.32 0.11 0.02 16 1.82 0.32

Arkansas 0.34 0.23 0.32 0.11 0.02 16 1.82 0.32

Fertilizer***

pounds per acre $/pound $/Acre

Nitrogen Loss

 Illinois 6.01 4.46 4.73 1.54 1.28 0.45 0.69 0.57

 Georgia 0.44 0.30 0.45 0.14 -0.01 0.45 0.06 0.00

 Arkansas 8.50 6.58 7.58 1.92 0.92 0.45 0.86 0.41

Phosphorous Loss

 Illinois 0.18 0.14 0.15 0.03 0.03 0.52 0.02 0.01

 Georgia 0.02 0.01 0.01 0.01 0.01 0.52 0.00 0.00

 Arkansas 0.36 0.33 0.34 0.03 0.02 0.52 0.02 0.01

Total Savings

$/Acre

 Illinois 18.18 8.74

 Georgia 18.13 8.67

 Arkansas 18.35 8.57

* Source: Disking operation added to No-Till System for one preplant tillage operation to control GR weeds. 

 Based on costs from University of Illinois - Machinery Cost Estimates: Field Operations 

 for horizontal disks, drag, rolling basket, 17 feet wide, April 2010. 

 Web address: http://www.farmdoc.illinois.edu/manage/index.asp 7

** Source: University of Illinois Extension, Farm Economics FEFO 06-07 April 2006. 

 Web address: http://www.farmdoc.illinois.edu/manage/newsletters/fefo06_07/fefo06_07.html 6

 Fuel consumption rates for Georgia adjusted based on USDA's fuel consumption calculator. 

 Web address: http://ecat.sc.egov.usda.gov/Fuel.aspx 10

*** Source: Fertilizer retention rates are based on estimates from the EPIC model.
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2.2 Case Study Scenario Definitions

Scenario 1: No Weed Resistance

The first scenario estimates farm receipts, expenses, net farm income, and real net worth 

for each farm using a GT crop production system and experiencing no glyphosate weed 

resistance issues. The primary purpose of this scenario is that it provides a basis for 

comparison. 

Scenario 2: Weed Resistance with No DHT Technology

The second scenario assumes the use of a GT crop production system experiencing 

significant weed resistance to glyphosate across the entire farm in each case study. The 

GR weeds are specific to each crop and county. In this scenario growers are assumed to 

control those GR weeds no impact on yields using additional conventional herbicides and

tillage (where indicated). Because of the use of conventional herbicides and, in some 

cases tillage, growers lose the convenience benefits of GT technology and in some cases 

incur additional tillage costs along with incurring environmental costs. In three of the 

case study states, Illinois, Georgia, and Arkansas, the University weed specialists 

reported that growers were using tillage to control the GR weeds. In this scenario, it is 

assumed that growers in these three case studies where tillage is used, switch from no-till 

systems to conventional tillage systems. The pre-plant weed burn down of $9.55 per acre 

is subtracted from the additional herbicide costs. Scenario 4 considers the alternative 

assumption that growers switch from no-till systems to minimum tillage systems. 

Scenario 3: Weed Resistance with DHT Technology

Table 4 also includes a fourth column which assumes the use of a GT crop production 

system experiencing significant weed resistance to glyphosate, but using DHT 

technology to meet the need for control of GR weeds. The estimated cost of nonglyphosate herbicides assumes that 2,4-D used as part of the DHT technology is priced at 

2009 levels and does not include any technology fees associated with a seed technology 

premium because the cost structures have not been established. Since this cost estimate 

does not include technology fees and the cost structure for 2,4-D as part of the DHT 

system has not been established this column does not provide a basis for the cost of the 

DHT system. In this analysis, a more conservative approach is taken potentially 

understating the economic value of DHT. The cost of the DHT system is price at the best 

alternative herbicide program for controlling GR weeds which is column three of Table 4. 

Arguably this makes sound economic sense because any new technology cannot be 

priced above the next best alternative (including cost and benefits) otherwise it would not 

be adopted. This assumption narrows the economic benefits to focus on convenience 

as well as any tillage impacts. Therefore, Scenario 3 is essentially Scenario 2 with the 

same herbicide costs but with the convenience and tillage benefits added back in that are 

preserved with DHT technology 
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Scenario 4: Weed Resistance with No DHT Technology, Minimum tillage 

Scenario 4 is the same as Scenario 2, assuming the use of a GT crop production system 

experiencing significant weed resistance to glyphosate across the entire farm and using 

alternative herbicides and tillage to control GR weeds, except that the growers switch 

from no till to "minimum till" instead of conventional till. Scenario 4 only applies to 

Illinois, Georgia, and Arkansas since those are the case study states with tillage impacts. 

Minimum till in this scenario is defined as the same tillage operations as no-till systems 

with an additional pre-plant pass with horizontal disk, drag, and rolling basket. As in 

Scenario 2, the pre-plant weed burn down of $9.55 per acre is subtracted from the 

additional herbicide costs.

Scenario 5: Weed Resistance with DHT Technology without Tillage Impacts

Scenario 5 is essentially the same as Scenario 3 assuming the use of a GT crop 

production system experiencing significant weed resistance to glyphosate across the 

entire farm, but all references to tillage impacts are removed. Scenario 5 only applies to 

Illinois, Georgia, and Arkansas since those are the case study states with tillage impacts. 
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In order to provide additional clarity, an outline of the scenarios considered in each of the 

nine case studies is given below.

Individual farm case 

studies (location and size) 

GR weed Management scenarios compared

A representative corn farm 

in:

1. Darke County, Ohio 

(135 acres)

Giant 

Ragweed

1. Base case: no GR weed problem, 

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used

2. Story County, Iowa (215 

acres)

Waterhemp 1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used

3. Renville Country, 

Minnesota (260 acres)

Giant 

Ragweed

1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used

4. Fayette Country, 

Illinois (250 acres)

Waterhemp 1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used
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Individual farm case 

studies (location and size) 

GR weed Management scenarios compared

A representative soybean 

farm in:

5. Story County, Iowa 

(215 acres)

Giant 

Ragweed

1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used

6. Renville County, 

Minnesota (260 acres)

Waterhemp 1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options

3. GR weed problem: DHT available and 

used

7. Fayette County, Illinois 

(250 acres)

Marestail 1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to conventional tillage

3. GR weed problem: DHT available and 

used

4. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to minimum tillage

5. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options but with no tillage 

change from no-till
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Individual farm case 

studies (location and size) 

GR weed Management scenarios compared

A representative soybean 

farm in:

8. Dooly County, Georgia 

(320 acres)

Palmer 

Amaranth

1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to conventional tillage

3. GR weed problem: DHT available and 

used

4. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to minimum tillage

5. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options but with no tillage 

change from no-till

9. Phillips County, 

Arkansas (935 acres)

Palmer 

Amaranth

1. Base case: no GR weed problem,

standard glyphosate-alone system 

2. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to conventional tillage

3. GR weed problem: DHT available and 

used

4. GR weed problem: No DHT and 

instead top projected alternative 

herbicide options + switch from no-till 

to minimum tillage

5. GR weed problem: No DHT and 

instead top projected herbicide 

alternative herbicide options but with 

no tillage change from no-till

2.3 Environmental Impact Analysis in the Case Studies

In addition to analyzing the economic impacts of the use of different herbicide systems 

on GT fields experiencing GR weed infestations, the soybean case studies also analyze 

the environmental impacts of shifting tillage practices from no-till to minimum tillage 

and conventional tillage. The potential environmental impacts considered in the case 

study analysis are soil erosion, water quality, and changes in soil organic carbon. A brief 

background on these type of impacts is presented in the following paragraphs.
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Soil erosion is a gradual process caused by water and wind, and occurs when a soil 

particle is detached, transported, and then deposited. Rainfall that does not infiltrate the 

soil will flow and may move soil directly. The on-site impact includes decreased soil 

quality due to loss of nutrients with sediment loss, and reduced water-absorbing capacity. 

The off-site impact occurs when water runoff carries sediment which if deposited in 

watercourses, could result in water quality impairment, aquatic ecosystem disruption, 

etc.

10

The deposit of sediment-attached nutrients could contribute to water quality degradation. 

Nitrogen and phosphorus are the two most common polluting nutrients. Increased levels 

of nitrogen- and phosphorus-enriched sediments could cause eutrophication. The 

eutrophication process occurs when a watercourse acquires a high concentration of 

nutrients, which stimulates excessive growth of algae and other aquatic plants. When this 

organic matter dies and decomposes, it depletes the dissolved oxygen levels resulting in 

negative impacts on other aquatic species.11, 12, 13

Carbon sequestration has a significant role in reducing atmospheric carbon dioxide. 

According to the U.S. Environmental Protection Agency (EPA), the largest source of 

U.S. greenhouse gas emissions is carbon dioxide and carbon dioxide from fossil fuel 

combustion accounted for approximately 80 percent of global warming potential (GWP) 

weighted emissions in 2008, increasing at an average annual rate of one percent from 

1990 to 2008. 14

Through the carbon sequestration process, plants remove carbon dioxide from the 

atmosphere and incorporate it into plants and soil structural components. Soil organic 

carbon is composed of a mixture of decomposing plant and animal tissue, the living 

biomass of microbes, and humus. Carbon can either remain stored in soils for a very long 

time, or be quickly released back into the atmosphere. Soil organic carbon can be 

enhanced by management practices including incorporating biomass into the soils, 

minimizing soil disturbance, conserving soil and water, and enhancing fauna activity. 

Less soil disturbance allows soil carbon to accumulate. Conservation tillage systems such 

as no-till are effective ways to enhance soil organic carbon accumulation. 15, 16, 17

2.3.1 Simulation of the Environmental Impacts

The Environmental Policy Integrated Climate (EPIC) model is the biophysical modeling 

tool used in this study to analyze the environmental impacts of no till versus conventional 

tillage farming practices.18 The EPIC model is capable of analyzing the impacts of crop 

management on soil, water, nutrient, and pesticide movement and in turn the effects on 

soil loss, water quality, and crop yields. 19

A number of water-erosion equations are used for soil erosion simulation. The main 

difference among them is the emphasis either on rainfall or runoff energy. The erosion 

equation used in this study is the Modified Universal Soil Loss Equation (MUSLE). The 

MUSLE focuses on runoff energy to estimate soil erosion and provides the amount of soil 
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transported to edge of field without the need to specify a delivery ratio. This allows 

analysis of relatively small time step events such as single storms.20

20

 In some soils the 

MUSLE estimates could exceed the Universal Soil Loss Equation's (USLE) estimates 

because the MUSLE estimates reflect larger scale erosion processes than USLE.

However, the MUSLE estimates can be lower than the USLE estimates for other soils 

where the residence time of water is longer for the larger observational plot, allowing soil 

and nutrients to redeposit back on the field rather than exit via runoff.

In each scenario, field conditions including slope, elevation, soil composition, soil water 

content, nutrient content, and residue cover for various tillage practices are held constant 

over the simulation processes. The EPIC model is calibrated using the soil type, 

topography, nutrient levels, and cultivation techniques to representative crop yields for 

the area. Simulations of the impact of other tillage systems such as no till and 

conservation tillage are then conducted.

Precipitation is one of the significant factors that influences runoff and off-site transport 

of sediment and nutrients. Weather generated data including precipitation, temperature 

and solar radiation information on weather from over 300 weather stations across the 

United States are obtained from EPIC weather database. The sequences of weather 

variables used in EPIC are generated by a precipitation model developed by Nicks (1974)

and a temperature and solar radiation model developed by Richardson (1981). 21, 22

2.3.2 Data

The three counties where tillage was identified as a management option were developed 

into representative farms for EPIC simulation. To model the interrelationships between 

the factors affecting the environmental impacts of no till and conventional tillage 

scenarios, data on soils, weather and cropping practices were obtained from various 

sources.

Three scenarios of farming practices were evaluated for each of the case studies. These 

scenarios included no till systems, minimum till systems, and conventional tillage 

systems. Chemical input data were limited to phosphorus fertilizer applications. Data on 

soil types, topography, and weather are specific to each case study location (More detail 

is presented in Tables 40 through Table 46 in the Supplemental Tables in Section 7 at the 

end of this report.)

Soil data from these three locations were obtained from Natural Resources Conservation 

Services, U.S. Department of Agriculture (NRCS-USDA). Major soil types which 

indicated the suitability for cultivation were selected. Soil characteristics for 26 soil 

types, comprising of 10 from Phillips County-Arkansas, six from Dooly/Macon CountiesGeorgia, and 10 from Fayette County-Illinois were based on NRCS and soil EPIC 

database. Dooly and Macon Counties are considered as one study area because soil 

reports from the NRCS group soil types of these two counties were reported as 

Dooly/Macon County. 23
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Weather parameters and statistics were obtained from EPIC database. The key parameters 

are monthly precipitation, minimum and maximum temperature, radiation, relative 

humidity, and wind velocity and direction. For this study, nearby weather stations for 

each location were selected in order to obtain data that closely represented the weather of 

the study areas. Jonesboro, Macon, and Pana weather stations in Arkansas, Georgia, and 

Illinois were used for the three sample farms which were Phillips, Dooly/Macon, and 

Fayette Counties. 

2.3.3 Model outputs

Environmental benefits from no-till practices are reflected through reduced soil erosion

and reduced levels of nitrogen and phosphorus leaving the field attached to sediment 

through reduced runoff to surface water and reduced leaching to ground water. 

Improvement in the amount of soil organic carbon is the key parameter for GHG 

reduction and is also included as an environmental benefit. 

The EPIC model results reported in this study included soil erosion, nitrogen and 

phosphorus leaving the fields, and the change in soil organic carbon. All annual estimates 

of nutrient and sediment runoff are edge-of-field, except for soil organic carbon, which 

was an on-the-field estimation. Total nitrogen loss considered in this study was a 

combination of dissolved nitrate lost in runoff and nitrogen lost with sediment. 

Phosphorus loss with sediment was also considered in this study. A change in the total 

amount of soil organic carbon in the field including carbon in standing biomass, root 

structures, plant residues and in soil was also reported. 

3. Case study results

3.1 Economic Impacts

Table 7 presents an overall summary of the case study results for the various soybean and 

corn farms. (More detail is presented in Table 47 through Table 55 in the Supplemental 

Tables in Section 7 at the end of this report.) Table 7 reports the average changes from 

the base case (no weed resistance) for farm expenses, net farm income, and real net worth 

in nominal dollars as well as percent change for each case study. Note that the Arkansas, 

Georgia, and Illinois farms also considered tillage impacts because the University weed 

specialists indicated that tillage was used as an option to control GR weeds in those 

states. 

Cursory inspection of Table 7 reveals that the expense impact and farm income impacts, 

when measured in dollars, are exactly the same within each scenario. This is expected 

because no yield impacts are assumed in any of the scenarios and we did not assume that 

individual growers could influence overall commodity prices. (This assumption 

regarding price impacts changes in the national scenarios presented in section 4 where the 

aggregate impact on commodity prices of changes on all farms is considered.) The 

percentage change in expenses and farm income are different because of the base levels 

of expenses and income. For example, in the Arkansas soybean farm under Scenario 1 
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with no GR weeds, the average of farm expenses and net farm income over the 2011 to 

2020 period (Table 47) are $301,419 and $199,574, respectively. Comparing Scenario 2 

that includes GR weeds with Scenario 1, the percentage change in expenses and net farm 

income are 15.4 percent and 23.3 percent, respectively. 

Cash flow and accumulated net worth are also presented for each case study in Tables 47 

through 55. These calculations began using 2010 as a basis and proceed through 2020. 

The accumulated net worth measures the accumulation of farm income through time. 

Since accumulated net worth is measured over the 2010 through 2020 it technically 

reflects eleven years of impact in the various scenarios. 

3.1.1 Soybean Results

As expected, under Scenario 2 those farms with tillage impacts had larger impacts on 

farm expenses and subsequently larger impacts on net farm income than the Iowa and 

Minnesota soybean farm case studies which did not include tillage impacts. In Scenario 

3, the use of DHT technology as part of the GT crop production system preserves the 

convenience and minimum tillage benefits of the GT system. Preserving these benefits 

reduces the impact of GR weeds on farm expenses. In the case of Arkansas, comparing 

Scenario 3 with Scenario 2 farm expenses increase an average of 10.8 percent using DHT

compared to 15.4 percent using other herbicides to complement glyphosate (seeTable 7). 

On average over the 2011 to 2020 period, this puts another $14,008 per year back in the 

grower’s pockets (calculated from Table 7: $46,426-$32,418). Through the next eleven 

years (counting 2010) this additional income accumulates adding $152,026 back to the 

Arkansas soybean grower's net worth (calculated from Table 7: $503,868-$351,842). 

Comparing Scenario 3 (assuming weed resistance, use of DHT) with Scenario 2

(assuming weed resistance, use of other supplemental herbicides and conversion to 

conventional tillage) in states with tillage impacts, DHT technology reduced the impact 

of GR on farm income by over 30 percent in Arkansas (calculated from Table 7: [1-

$32,418/$46,426]), and 50 percent in Georgia and Illinois (calculated from Table 7: [1-

$3,480/$8,541] and [1-$3,778/$7,683], respectively). Scenario 4 is similar to Scenario 2 

except that soybean growers switch from no-till to minimum till instead of conventional 

tillage. The impacts are reduced because minimum tillage is not as expensive as 

conventional tillage. However, comparing Scenario 4 with Scenario 3 shows that, even 

switching to minimum till, Arkansas soybean growers with DHT technology reduced the

overall change in their expenses caused by GR weeds by nearly 7.7 percent (calculated 

from Table 7: [1-$32,418/$35,134]). Georgia and Illinois soybean growers using DHT 

technology reduced the change in their expenses by 19.4 and 17.0 percent, respectively

(calculated from Table 7: [1-$3,840/$4,764] and [1-$3,778/$4,551], respectively). 

Scenario 5 presents the situation with no tillage impacts for Arkansas, Georgia and 

Illinois. Although this is not representative of reality as reported by the University weed 

specialists it does facilitate direct comparison with scenario 2 for the Iowa and Minnesota 

case studies. The levels of net farm income impacts ranging from -6.0 to -18.2 percent 

are similar to the -6.5 percent and -9.4 percent for Iowa and Minnesota, respectively (see 

Table 7).
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3.1.2 Corn Results

The corn case studies do not consider tillage impacts, eliminating the need for Scenarios 

4 and 5. The University weed specialists consulted for this analysis did not report tillage

as a control method for GR weeds in corn. The impact of GR weeds in Scenario 2 results 

in an average decline in annual net farm income between 5.7 percent and 8.8 percent over 

the 2011 to 2020 period (see Table 7). In Scenario 3, 15.9 to 18.9 percent of the loss in 

farm income from GR weeds is offset with DHT technology (calculated from Table 7: 

[Illinois 1-$5,127/$6,099], [Iowa 1-$5,472/$6,747], [Minnesota 1-$6,352/$7,724], and 

[Ohio 1-$2,642/$3,180]). 

3.1.3 Comparison of Soybean and Corn Results

Overall, the impact of GR weeds in a GT production system appears to be smaller for 

corn than soybeans, but much of the difference is due to the impacts of tillage used in 

some of the states for GR weed control in soybeans. The remaining difference is 

explained by the cost of the alternative herbicide programs used in corn versus soybeans. 

Soybean herbicide programs used to control GR weeds are modestly more expensive than 

the corresponding corn herbicide programs. 
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Table 7. Summary of Case Study Farm Impacts, 2011-2020 Average of Annual Impacts (Change from Scenario 1, No Weed 

Resistance)

Arkansas Case Georgia Case Illinois Case Iowa Case Minnesota Case Ohio Case

935 Acre Farm 320 Acre Farm 250 Acre Farm 215 Acre Farm 260 Acre Farm 135 Acre Farn

Dollars Percent Dollars Percent Dollars Percent Dollars Percent Dollars Percent Dollars Percent

Soybean Case Studies

Scenario 2: Weed Resistance - No DHT

 Change in Farm Expenses 46,426 15.4% 8,541 10.0% 7,683 12.3% 4,965 8.1% 5,949 7.5%

 Change in Net Farm Income -46,426 -23.3% -8,541 -10.0% -7,683 -18.3% -4,965 -6.5% -5,949 -9.4%

 Change in Accumulated Net Worth* -503,868 -11.8% -92,699 -5.7% -83,383 -5.9% -53,884 -3.0% -64,564 -4.0%

Scenario 3: Weed Resistance - DHT Techology Available

 Change in Farm Expenses 32,418 10.8% 3,840 4.5% 3,778 6.1% 4,084 6.7% 4,876 6.1%

 Change in Net Farm Income -32,418 -16.2% -3,840 -4.5% -3,778 -9.0% -4,084 -5.3% -4,876 -7.7%

 Change in Accumulated Net Worth* -351,842 -8.2% -41,676 -2.5% -41,007 -2.9% -44,320 -2.4% -52,917 -3.3%

Scenario 4: Weed Resistance - No DHT, Addition of Preplant Disking to No-Till

 Change in Farm Expenses 35,134 11.7% 4,764 5.6% 4,551 7.3%

 Change in Net Farm Income -35,134 -17.6% -4,764 -5.6% -4,551 -10.8%

 Change in Accumulated Net Worth* -381,319 -8.9% -51,709 -3.2% -49,389 -3.5%

Scenario 5: Weed Resistance - No DHT without Tillage Impacts

 Change in Farm Expenses 36,267 12.0% 5,156 6.0% 4,803 7.7%

 Change in Net Farm Income -36,267 -18.2% -5,156 -6.0% -4,803 -11.4%

 Change in Accumulated Net Worth* -393,612 -9.2% -55,954 -3.4% -52,127 -3.7%

Corn Case Studies

Scenario 2: Weed Resistance - No DHT

 Change in Farm Expenses 6,099 5.5% 6,747 4.2% 7,724 3.7% 3,180 4.9%

 Change in Net Farm Income -6,099 -8.8% -6,747 -5.7% -7,724 -7.5% -3,180 -6.0%

 Change in Accumulated Net Worth* -65,770 -3.8% -72,764 -2.6% -83,303 -3.3% -34,295 -2.7%

Scenario 3: Weed Resistance - DHT Techology Available

 Change in Farm Expenses 5,127 4.6% 5,472 3.4% 6,352 3.0% 2,642 4.1%

 Change in Net Farm Income -5,127 -7.4% -5,472 -4.6% -6,352 -6.2% -2,642 -5.0%

 Change in Accumulated Net Worth* -55,291 -3.2% -59,009 -2.1% -68,507 -2.7% -28,495 -2.2%

* Change in Accumulated Net Worth is measured based on the level of net worth in 2020 that was accumulated over the 2010 - 2020 period.
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3.2 Environmental Impacts

The MUSLE estimates of soil erosion, nitrogen (N) loss, and phosphorous (P) loss are 

given in Table 8. As expected, the result show lower environmental impacts with less 

soil disturbance under the minimum till and no-till operations. Soil erosion under no-till 

compared with conventional tillage is less than half with some variance for soil, 

topography, precipitation, and other factors. Nitrogen losses in no-till are roughly 75 

percent of the levels in conventional tillage. Phosphorous loss differences are generally 

smaller across the various tillage systems.

Table 8. Environmental Impacts: Factors Contributing to Water Quality 

Historically, no-till and minimum tillage practices have helped either improve soil 

organic carbon or alleviate a reduction of soil organic carbon from the farming process. 

In the Arkansas and Georgia counties, 159 percent and 33 percent more soil organic 

carbon was released into the atmosphere, respectively, with conventional tillage 

compared to no-till systems (see Table 9). Only 1/5th of the carbon was sequestered in 

Fayette County, Illinois in the conventional tillage system compared with the no-till 

system. In the case of minimal tillage (no till with an extra pre-plant disking) the 

increase in soil organic carbon released into the atmosphere was 49 percent and 14 

percent for Arkansas and Georgia, respectively. In Illinois, minimum tillage systems 

sequester only about half of the carbon of no-till systems.

Conventional 

Tillage

Minimum 

Till NoTill

AR, Phillips County

Soil-Water Erosion (tons/acre) 2.19 1.27 0.97

N Loss (lbs/acre) 8.50 7.87 6.58

P Loss (lb/acre) 0.36 0.34 0.33

GA, Dooly/Macon County

Soil-Water Erosion (tons/acre) 0.07 0.07 0.03

N Loss (lbs/acre) 0.44 0.45 0.3

P Loss (lb/acre) 0.02 0.01 0.01

IL, Fayette County

Soil-Water Erosion (tons/acre) 0.74 0.43 0.30

N Loss (lbs/acre) 6.01 4.73 4.46

P Loss (lb/acre) 0.18 0.15 0.14
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Table 9. Environmental Impacts: Average Annual Carbon Sequestration

The farm level impacts of tillage changes in the various scenarios are presented in Table 

10. These results are based on the per acre estimates from the EPIC model. These 

impacts can be avoided with DHT technology preserving the benefits of GT crops by 

preventing reversion to more intensive tillage methods.

Table 10. Summary of Soybean Case Study Environmental Impacts

Conventional 

Tillage

Minimum 

Till No till

tons/acre

Soil Carbon Lost into the Atmosphere

 Phillips County, Arkansas -0.96 -0.55 -0.37

 Dooly/Macon County, Georgia -1.45 -1.24 -1.09

Soil Carbon Sequestered in the Soil

 Fayette County, Illinois 0.20 0.47 1.03

Arkansas Case Georgia Case Illinois Case

935 Acre Farm 320 Acre Farm 250 Acre Farm

Quantity Percent Quantity Percent Quantity Percent

Scenario 2: Weed Resistance - No DHT, Switch from No-Till to Conventional Till

 Soil Loss (tons) 1,141 125.8% 13 133.3% 110 146.7%

 Nitrogen Loss (pounds) 1,795 29.2% 45 46.7% 388 134.8%

 Phosphorous Loss (pounds) 28 9.1% 3 100.0% 10 28.6%

 Soil Carbon Loss (tons) 551.65 159.5% 115.2 33.0% 207.5 415%

Scenario 4: Weed Resistance - No DHT, Switch from No-Till to Minimum Till

 Soil Loss (tons) 281 30.9% 13 133.3% 33 43.3%

 Nitrogen Loss (pounds) 1,206 19.6% 48 50.0% 68 6.1%

 Phosphorous Loss (pounds) 9 3.0% 0 0.0% 3 7.1%

 Soil Carbon Loss (tons) 168.3 48.6% 48 13.8% 140 119%
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4. National Analysis

While the case studies look at specific farms, the national analysis is designed to provide 

an aggregate measure for the United States. The state level differences in GR weeds 

outlined in the case studies and by the University weed specialists provide insight into 

regional differences in GR weed pressures. As discussed below, there is a particular 

difference between the northern states and southern states. While the economic and 

environmental impacts are presented at the national level, the regional differences in GR 

weeds and the methods used for GR weed control are included in the analysis.

The national analysis aspect of this study quantifies the economic impacts of current GR 

weed conditions and provides an estimate of future impacts assuming the strong 

likelihood that weed resistance will continue to spread in the future. This is 

accomplished through the use of three scenarios similar to the case studies discussed 

above including:

1. a reference scenario assuming the use of a GT crop production system with no GR 

weeds, 

2. a scenario assuming the use of a GT crop production system with GR weeds, in 

which only currently available technologies are used for GR weed control, 

including both non glyphosate herbicides and increased tillage as they are 

currently used, and

3. a scenario assuming the use of a GT crop production system with GR weeds, in 

which DHT technology is available to growers. As in the case studies, the 

assumption is made that DHT technology prices will be set at levels similar to the 

increased costs of using additional non-glyphosate herbicides to control GR 

weeds. This assumption narrows the economic benefits to focus on convenience.

as well as any tillage impacts.

4.1 National Scenario Assumptions

4.1.1 GR Weed Infestation Levels

One important difference from the case studies is that the national analysis is scaled by 

the overall prevalence of GR weeds across the United States rather than assuming that all 

acres in the United States are infested with GR weeds. Reliable data on the percent of 

acres across the United States affected by GR weeds is generally not yet available 

although there is considerable documentation of the types of resistant weeds that have 

been discovered by state. In order to approximate the prevalence of GR weeds by weed 

type, the national analysis used the results from the interviews and surveys conducted 

with the University weed specialists in each state. There was some clustering in the 

survey responses with consistent weed type and infestation issues reported for the 

northern states of Iowa, Indiana, Missouri, Ohio, Minnesota, Kansas, and Kentucky in 

contrast with the responses from the southern states of Arkansas, Georgia, and 

Mississippi. Given this clustering in responses, the data was aggregated into two regions 

for the United States weighting each state's response by the 2010 planted acreage in that 

state. 
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In the surveys, each state weed scientist expert was asked to provide an estimate of the 

current infestation of GR weeds by type of weed individually for corn and soybeans as 

well as his impression of projected infestation levels in 2015 (see Table 11and Table 12). 

In general, weed scientist experts from the northern states suggested that for soybeans the 

most significant resistant weeds were marestail, giant ragweed, and waterhemp with 

infestations expected to increase 30 to 50% from current levels over the next five years. 

In the southern states, marestail and palmer amaranth were highlighted as the most 

significant GR weed problems. GR palmer amaranth and marestail infestations were 

expected to increase by over 50% by 2015. Estimates of weed infestations between 2010 

and 2015 were estimated using linear interpolation. Estimates beyond 2015 were trended 

based on growth over the 2000 to 2015 period topping out at 100% infestation. 

Infestation rates for GR weeds in corn start off a bit lower. The pattern of GR weeds in 

corn by region is similar to that found in soybeans. 

Table 11. Soybean Glyphosate Resistant Weed Infestation Estimates (Weighted 

Average Based on State Acreages)

Table 12. Corn Glyphosate Resistant Weed Infestation Estimates (Weighted 

Average Based on State Acreages)

As Table 11 and Table 12 suggest, over the next few years multiple GR weeds are 

predicted to infest the same acreage increasing the complexity of controlling GR weeds. 

For simplicity this analysis assumes that only one type of GR weed will infest any 

specific farm over the next 10 years. 

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(percent of total acres)

Northern Region

 Marestail 26.5% 29.0% 31.4% 33.8% 36.3% 38.7% 41.1% 43.5% 46.0% 48.4% 50.8%

 Giant Ragweed 9.5% 12.2% 14.9% 17.6% 20.3% 22.9% 25.6% 28.3% 31.0% 33.7% 36.3%

 Waterhemp 18.4% 21.0% 23.7% 26.3% 28.9% 31.6% 34.2% 36.8% 39.5% 42.1% 44.8%

 Palmer Amaranth 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Southern Region

 Marestail 43.8% 48.2% 52.6% 57.0% 61.4% 65.8% 70.2% 74.6% 79.0% 83.3% 87.7%

 Giant Ragweed 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Waterhemp 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Palmer Amaranth 44.3% 54.0% 63.6% 73.3% 83.0% 92.7% 100.0% 100.0% 100.0% 100.0% 100.0%

* Northern Region survey states include IA, IN, MO, OH, KY, MN, and KS.

** Southern Region survey states include AR, GA, and MS.

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(percent of total acres)

Northern Region

 Marestail 19.4% 21.7% 24.0% 26.3% 28.6% 30.9% 33.1% 35.4% 37.7% 40.0% 42.3%

 Giant Ragweed 9.0% 11.3% 13.6% 15.8% 18.1% 20.4% 22.6% 24.9% 27.2% 29.5% 31.7%

 Waterhemp 16.6% 19.5% 22.5% 25.4% 28.4% 31.4% 34.3% 37.3% 40.3% 43.2% 46.2%

 Palmer Amaranth 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Southern Region

 Marestail 34.4% 40.6% 46.9% 53.1% 59.4% 65.6% 71.9% 78.1% 84.4% 90.6% 96.9%

 Giant Ragweed 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Waterhemp 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Palmer Amaranth 34.5% 39.3% 44.0% 48.8% 53.6% 58.3% 100.0% 100.0% 100.0% 100.0% 100.0%

* Northern Region survey states include IA, IN, MO, OH, KY, MN, and KS.

** Southern Region survey states include AR, GA, and MS.
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4.1.2 Cost of Controlling GR Weeds

The cost of controlling specific GR weed species varies by type of weed. Note that GR 

weed infestation estimates from the University scientists in Tables 11 and 12 sum to more 

than 100% in the regions in some of the later years as GR weeds spread. It was necessary 

to rescale these estimates in Tables 11 and 12 to sum to 100% and use the rescaled 

percentages to weight the average costs of controlling the weeds. This ignores the 

additional cost of other herbicides that might be needed to control multiple species. This 

is another advantage of DHT technology because 2,4-D controls a broad spectrum of GR 

weeds and thus eliminates the cost and inconvenience of adding another herbicide. 

Table 13. Additional Herbicide Cost to Control GR Weeds Without DHT in 

Soybeans

The estimated costs of additional herbicides versus glyphosate alone used to control GR 

weeds are based on the alternative programs developed in the case studies for 2010. 

For soybeans, the case studies did not develop programs for controlling marestail in the 

southern regions, thus the northern region cost is used as an approximation. The state 

weed specialists identified marestail as a problem in the southern regions so it is included 

in the national analysis. 

Herbicide programs to control GR palmer amaranth were developed both for Georgia and 

Arkansas soybeans in the southern region. The level of additional herbicide cost used in 

the southern region is the planted area weighted average of the two case study estimates. 

In the case of additional herbicide costs for corn, no southern states were included in the 

original case studies. The additional cost of marestail control is assumed to be the same 

as the northern region. The cost of controlling palmer amaranth in Georgia is developed 

in the same way as the case study costs (see Table 39 in the Supplemental Tables in 

Section 7 at the end of this report). Estimates for 2011 through 2020 are based on IHS 

projections of herbicide price inflation.8

 These estimates in Tables 13 and 14 are not yet

scaled by GR weed infestations.

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Marestail 12.28 12.57 13.06 13.40 13.72 14.05 14.32 14.59 14.88 15.17 15.44

 Giant Ragweed 15.43 15.80 16.41 16.84 17.24 17.65 17.99 18.33 18.70 19.06 19.41

 Waterhemp 15.13 15.49 16.09 16.51 16.90 17.31 17.64 17.98 18.33 18.69 19.03

 Palmer Amaranth 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Southern Region

 Marestail 12.28 12.57 13.06 13.40 13.72 14.05 14.32 14.59 14.88 15.17 15.44

 Giant Ragweed 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Waterhemp 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Palmer Amaranth 26.60 27.23 28.29 29.03 29.71 30.43 31.01 31.60 32.23 32.86 33.45
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Table 14. Additional Herbicide Cost to Control GR Weeds Without DHT in Corn

4.1.3 Convenience Benefits

The use of current available herbicide programs to control GR weeds involves the 

additional management, labor, fuel, and overhead costs to utilize multiple herbicides with 

more restrictive windows for application. As discussed in the case studies, there are 

convenience costs associated with the loss of the simpler GT system. The convenience 

values identified in the literature were taken as the 2010 values. The per acre cost 

estimates for 2011 through 2020 are summarized in Table 15 based on IHS projections of 

each farm input price inflation category.8

Table 15. Convenience Benefits Lost from GR Weed Control

Sources: Marra and Piggott, 2006.3

 Brookes and Barfoot, 2009.4

4.1.4 Assumptions on the Use of Tillage to Control GR Weeds

In soybeans some growers also use tillage as an alternative to herbicides for GR weed 

control. The impact of conversion from no-till to conventional or minimum tillage is 

limited by the number of acres that are actually under no-till systems. Using 2006 data 

from the USDA-ERS website24

Table 16

the average share of no-till acreage was 45.4 percent in 

the northern region and 27.9 percent in the southern region. Tillage impacts would affect 

only these percentages (see ). 

Based on the survey of University weed specialists in each state and weighting by state 

acreages, tillage was found to be mostly used for marestail and palmer amaranth control 

in the southern region states (see Table 17). There was some use in the northern states as 

well. Interestingly, the University weed specialists did not see tillage becoming an 

increasing option for weed control and thus the rates are held flat in the national 

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Marestail 14.23 14.57 15.14 15.53 15.89 16.28 16.59 16.91 17.24 17.58 17.90

 Giant Ragweed 14.16 14.49 15.06 15.45 15.81 16.19 16.50 16.82 17.15 17.49 17.80

 Waterhemp 14.30 14.65 15.22 15.61 15.98 16.36 16.68 16.99 17.33 17.67 17.99

 Palmer Amaranth 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Southern Region

 Marestail 14.23 14.57 15.14 15.53 15.89 16.28 16.59 16.91 17.24 17.58 17.90

 Giant Ragweed 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Waterhemp 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Palmer Amaranth 8.94 9.15 9.29 9.17 9.15 9.16 9.11 9.11 9.12 9.11 9.10

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Soybeans

 Fuel 0.70 0.72 0.74 0.75 0.77 0.79 0.82 0.84 0.87 0.89 0.92

 Repairs 0.70 0.72 0.74 0.75 0.77 0.79 0.82 0.84 0.87 0.89 0.92

 Labor 1.93 1.99 2.03 2.08 2.13 2.19 2.26 2.32 2.39 2.47 2.54

 Total 3.33 3.43 3.50 3.58 3.68 3.78 3.89 4.01 4.13 4.25 4.38

Corn

 Fuel 0.63 0.65 0.67 0.69 0.70 0.72 0.73 0.75 0.76 0.78 0.79

 Repairs 0.63 0.65 0.67 0.69 0.70 0.72 0.73 0.75 0.76 0.78 0.79

 Labor 1.74 1.78 1.85 1.90 1.94 1.99 2.03 2.07 2.11 2.15 2.19

 Total 3.00 3.07 3.19 3.27 3.35 3.43 3.50 3.56 3.64 3.71 3.77
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scenarios. These rates are used to further scale the cost of conversion of no-till to 

conventional or minimum till acres. 

Table 16. No-Till Soybean Acres in Reported States

Table 17. Share of Soybean Acres Using Tillage to Control GR Weeds Weighted 

Average Based on State Acreages

Total No Till

Percent 

No Till

1000 acres

Northern States

 Illinois 10,100 5,285 52.3%

 Indiana 5,700 3,958 69.4%

 Iowa 10,150 4,111 40.5%

 Kansas 3,150 1,729 54.9%

 Kentucky 1,380 1,055 76.4%

 Tennessee 1,160 833 71.8%

 Michigan 2,000 930 46.5%

 Minnesota 7,350 778 10.6%

 Missouri 5,150 2,342 45.5%

 Nebraska 5,050 2,506 49.6%

 North Dakota 3,900 354 9.1%

 Ohio 4,650 3,573 76.8%

 South Dakota 3,950 1,359 34.4%

 Virginia 520 417 80.2%

 Wisconsin 1,650 696 42.2%

 Subtotal 65,860 29,924 45.4%

Southern States

 Arkansas 3,110 410 13.2%

 Louisiana 870 217 25.0%

 Mississippi 1,670 578 34.6%

 North Carolina 1,370 752 54.9%

 Subtotal 7,020 1,957 27.9%

National 72,880 31,882 43.7%

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(percent of total acres)

Northern Region*

 Marestail 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0%

 Giant Ragweed 0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2% 0.2%

 Waterhemp 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Palmer Amaranth 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

Southern Region*

 Marestail 11.7% 11.7% 11.7% 11.7% 11.7% 11.7% 11.7% 11.7% 11.7% 11.7% 11.7%

 Giant Ragweed 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Waterhemp 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

 Palmer Amaranth 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5% 2.5%

* Northern Region survey states include IA, IN, MO, OH, KY, MN, and KS.

** Southern Region survey states include AR, GA, and MS.
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4.1.5 Costs of Changing Tillage Systems

The cost of switching from no-till to conventional tillage is made up of the additional 

fuel, labor, and equipment costs as well as the small amount of additional fertilizer costs 

associated with more soil loss in conventional tillage systems (see Table 18). Offsetting 

a portion of these additional costs is the savings from eliminating a pre-plant weed burn 

down. The 2010 cost levels correspond to the case study estimates. Estimates for 2011 

through 2020 are based on IHS projections of each farm input price inflation category.8

 

These estimates are scaled by the percentage of acres using no-till and the share of 

grower's actually using tillage as GR weed control. Applying the scaling factors, 

significantly reduces the average increase in the cost of production changes due to tillage 

across the regions (see Table 19).

Table 18. Cost of Switching from No-Till to Conventional Tillage Systems in 

Soybeans (Unadjusted for No-Till and the Share of Growers Using Tillage for GR Weed Control)

Table 19. Cost of Switching from No-Till to Conventional Tillage Systems in 

Soybeans (Adjusted for No-Till and the Share of Growers Using Tillage for GR Weed Control)

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Herbicide Savings (No Burndown) -9.55 -9.78 -10.16 -10.42 -10.67 -10.93 -11.14 -11.35 -11.57 -11.80 -12.01

 Fuel Use 3.14 3.14 3.36 3.50 3.62 3.77 3.93 4.03 4.12 4.13 4.12

 Equipment Overhead 12.50 12.79 13.27 13.73 14.23 14.76 15.26 15.78 16.34 16.93 17.51

 Labor 1.82 1.88 1.91 1.96 2.01 2.07 2.13 2.19 2.26 2.32 2.39

 Fertilizer 0.71 0.81 0.79 0.80 0.80 0.81 0.82 0.84 0.85 0.87 0.89

 Subtotal 8.62 8.84 9.17 9.57 9.99 10.48 11.00 11.49 12.00 12.46 12.90

Southern Region

 Herbicide Savings (No Burndown) -9.55 -9.78 -10.16 -10.42 -10.67 -10.93 -11.14 -11.35 -11.57 -11.80 -12.01

 Fuel Use 3.19 3.19 3.41 3.55 3.68 3.83 3.99 4.09 4.18 4.20 4.18

 Equipment Overhead 12.50 12.79 13.27 13.73 14.23 14.76 15.26 15.78 16.34 16.93 17.51

 Labor 1.82 1.88 1.91 1.96 2.01 2.07 2.13 2.19 2.26 2.32 2.39

 Fertilizer 0.82 0.94 0.91 0.92 0.92 0.94 0.95 0.96 0.98 1.01 1.03

 Subtotal 8.78 9.02 9.35 9.75 10.17 10.67 11.19 11.68 12.20 12.66 13.10

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Herbicide Savings (No Burndown) -0.13 -0.13 -0.14 -0.14 -0.14 -0.15 -0.15 -0.15 -0.16 -0.16 -0.16

 Fuel Use 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.06 0.06 0.06

 Equipment Overhead 0.17 0.17 0.18 0.19 0.19 0.20 0.21 0.21 0.22 0.23 0.24

 Labor 0.02 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03

 Fertilizer 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

 Subtotal 0.12 0.12 0.12 0.13 0.13 0.14 0.15 0.15 0.16 0.17 0.17

Southern Region

 Herbicide Savings (No Burndown) -0.38 -0.39 -0.40 -0.41 -0.42 -0.43 -0.44 -0.45 -0.46 -0.47 -0.48

 Fuel Use 0.13 0.13 0.13 0.14 0.15 0.15 0.16 0.16 0.17 0.17 0.17

 Equipment Overhead 0.49 0.51 0.53 0.54 0.56 0.58 0.60 0.62 0.65 0.67 0.69

 Labor 0.07 0.07 0.08 0.08 0.08 0.08 0.08 0.09 0.09 0.09 0.09

 Fertilizer 0.03 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04 0.04

 Subtotal 0.35 0.36 0.37 0.39 0.40 0.42 0.44 0.46 0.48 0.50 0.52
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4.1.6 Adoption Rate Assumptions for GT Seed

In the case of soybeans, combining the scaled estimates of the conversion of no-till to 

conventional till costs with the additional herbicide costs and the loss of convenience 

benefits provides a measure of the total per acre cost of weed resistance. If at least one 

type of GR weed was found on every crop acre and GT soybeans were used by all 

growers, this would be the final step. However, GR weeds are not reported on every 

soybean acre at present and not every grower uses GT soybeans. In the southern region, 

by 2011 at least one type of GR weed is estimated on every acre, but the University weed 

specialists in each state suggest that it will take until 2016 before this happens in the 

northern region. In addition GT soybeans are only reported to be used on 91 percent of 

total soybean acres. The implication is that the overall impacts of weed resistance must 

be scaled by 91 percent reflecting the growers using GT technology and the impacts are 

smaller in the first few years of the analysis, particularly in the northern region, due to the 

currently limited spread of GR weeds in the north. Finally, 91 percent GT adoption in 

soybeans is held constant over the 2011 through 2020 period. Combining these factors, 

the total soybean cost of production change calculated for Scenario 2 is presented in 

Table 20. 

Table 20. Total Soybean Cost of Production Change to Control GR Weeds (Scaled 

for GR Weed Infestations and GT Soybean Seed Adoption)

For corn the total per acre cost of GR weed control is less complicated because there are 

no tillage impacts. The combination of additional herbicide costs and loss of 

convenience benefits is scaled by the weed infestation rates and adoption rate of GT corn. 

Unlike the case of soybeans, the adoption rate of GT corn is expected to continue to 

increase from its current level of 70 percent reaching a level of 91 percent by 2015 (see

Table 21). Note that estimates from the third party proprietary surveys and Monsanto 

(based on seed sales) are significantly higher, exceeding 80% of total planted area in 

2009.

3,25

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Herbicides 6.84 8.03 9.42 10.77 12.15 13.60 14.76 15.06 15.38 15.70 16.00

 Fuel Use 0.37 0.43 0.50 0.57 0.64 0.72 0.79 0.82 0.84 0.86 0.89

 Equipment Overhead 0.43 0.51 0.58 0.66 0.75 0.84 0.93 0.96 0.99 1.02 1.05

 Labor 0.97 1.14 1.31 1.49 1.68 1.88 2.08 2.14 2.21 2.27 2.34

 Fertilizer 0.00 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

 Subtotal 8.61 10.12 11.82 13.49 15.23 17.05 18.57 18.99 19.43 19.87 20.29

Southern Region

 Herbicides 15.62 18.13 19.11 19.82 20.46 21.11 21.55 21.73 21.95 22.16 22.35

 Fuel Use 0.66 0.77 0.79 0.81 0.84 0.86 0.89 0.91 0.94 0.96 0.99

 Equipment Overhead 0.96 1.12 1.15 1.18 1.22 1.25 1.29 1.33 1.38 1.42 1.47

 Labor 1.61 1.88 1.92 1.96 2.01 2.07 2.13 2.19 2.26 2.33 2.40

 Fertilizer 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.03 0.04 0.04 0.04

 Subtotal 18.87 21.93 22.99 23.81 24.56 25.32 25.90 26.21 26.56 26.91 27.24
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Table 21. Adoption Rate of GT Seed 

As in the case of soybeans, the corn cost of production changes increase over time. The 

increase is more dramatic for corn than soybeans because of the increase in GT corn seed 

adoption and because the level of GR weed infestations grows from a lower starting level 

to full infestation (see Table 12 and Table 22). In the case of corn, 100 percent GR weed 

infestations are expected to be reached in the northern region by 2018 and by 2013 in the 

southern region. 

Table 22. Total Corn Cost of Production Change to Control GR Weeds (Scaled for 

GR Weed Infestations and GT Corn Seed Adoption)

In scenario 3, DHT technology is assumed to be available preserving the convenience 

benefits of both GT corn and soybeans and eliminating the tillage impacts in soybeans. 

This reduces preserved the reduced costs from the convenience benefits of GT crops and 

eliminates the additional cost of tillage and negative environmental benefits associated 

with increased tillage in soybeans.

4.2 Conservative Bias in the National Analysis Assumptions

The assumptions used in the national analysis were deliberately constructed to 

conservatively estimate the economic benefits of DHT. Specifically, these conservative 

assumptions included:

1. Convenience and tillage benefits only: The analysis considers the economic value 

of preserving the convenience benefits of the GT system and tillage benefits. No 

benefits were assigned to DHT technology through lower costs than other 

herbicide programs. The technology fee and fees for 2,4-D may be lower than 

other herbicide program alternatives.

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Soybeans 91% 91% 91% 91% 91% 91% 91% 91% 91% 91% 91%

Corn 70% 74% 78% 83% 87% 91% 91% 91% 91% 91% 91%

2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

(dollars per acre)

Northern Region

 Herbicides 4.49 5.68 7.13 8.68 10.37 12.25 13.62 15.03 15.70 16.00 16.29

 Fuel 0.20 0.25 0.32 0.38 0.46 0.54 0.60 0.67 0.69 0.71 0.72

 Repairs 0.20 0.25 0.32 0.38 0.46 0.54 0.60 0.67 0.69 0.71 0.72

 Labor 0.55 0.70 0.87 1.06 1.27 1.50 1.66 1.84 1.92 1.96 1.99

 Total 5.44 6.88 8.64 10.50 12.55 14.83 16.49 18.20 19.00 19.38 19.73

Southern Region

 Herbicides 5.58 7.06 8.77 10.31 11.02 11.76 11.14 11.40 11.68 11.96 12.22

 Fuel 0.30 0.38 0.48 0.57 0.61 0.66 0.67 0.68 0.69 0.71 0.72

 Repairs 0.30 0.38 0.48 0.57 0.61 0.66 0.67 0.68 0.69 0.71 0.72

 Labor 0.84 1.06 1.32 1.57 1.69 1.81 1.85 1.88 1.92 1.96 1.99

 Total 7.03 8.88 11.04 13.02 13.93 14.89 14.32 14.64 14.99 15.33 15.65
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2. Value of convenience benefits: The analysis uses the most conservative estimates 

of the convenience benefits as suggested by Marra.3 The value of convenience 

benefits are significantly reduced by using their adjustment for the part-whole 

bias inherent in grower surveys.

3. Single weed resistance: This analysis assumes that only one type of weed in any 

farm is glyphosate resistant. DHT technology offers additional cost savings in 

situations where multiple GR weeds infest a farm because growers would only 

pay one technology fee and DHT controls a broad spectrum of GR weeds. 

Prescriptive herbicide program alternatives are potentially more expensive and are 

more difficult to manage. 

4. Tillage impacts: The analysis results are scaled by the adoption rate of no-till as 

well as the percent of growers using tillage as a method of control. Due to the 

relatively small percentage of no-till acres, this significantly reduces the impact of 

tillage changes. The University weed specialists did not report any tillage 

changes in corn and limited tillage impacts in soybeans due to the presence of GR 

weeds. The impacts in soybeans were focused mostly in the southern states. 

These assumptions may be conservative as GR weed infestations spread to the 

northern states. In addition, the University weed specialists project that tillage use 

for GR weed control remains flat. This assumption suggests that they assume that 

new technologies will limit any further increase in tillage.

5. GT seed adoption: This analysis assumes that GT soybean cultivation has 

reached it full adoption level at 91 percent. In addition GT corn seed adoption 

uses the conservative adoption rates reported by USDA instead of other sources 

showing much higher GT corn adoption rates. 

6. No yield impacts: This analysis assumes that managing multiple alternative 

herbicides currently available to address GR weeds has no yield impacts or 

additional cost impacts from the efficacy rates for alternative herbicide systems. 

5. National Analysis Results

5.1 National Analysis Economic Impacts

The adjustments to cost outlined above form the basis for Scenarios 2 and 3 in the 

national analysis. As in the analysis of the case studies, there are two sets of impacts: 

economic and environmental. There is also the added dimension of measuring the impact 

on overall commodity prices from the cumulative effect of grower responsiveness to 

increased cost estimated by the IHS U.S. agricultural model. In the national analysis, 

commodity prices, acreage, and demand all respond to the increases in cost of production. 

Table 57 and Table 58 in the Supplemental Tables in Section 7 at the end of this report

present the impacts on price, supply, and demand for corn and soybeans. The results 

suggest small increases in per bushel commodity prices for corn and soybeans that do not 

offset the increase in costs of production. From a grower perspective the impact on net 
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farm income is most important. Note that unlike the specific results for corn and 

soybeans reported in the case studies, corn and soybean impacts are combined in the 

results for U.S. farm income. In Table 23, the results from Scenario 2 show the impact 

on farm income in GT crop production systems with GR weeds in the absence of DHT 

technology. The impacts increase from 2011 through 2017 as weed infestations reach 

100 percent and GT corn becomes more widely adopted. GR weeds in GT corn and 

soybeans reduce net farm income by $1.9 billion in 2011 and this impact increases to 

$2.5 billion by 2017. The impact on gross farm income is small because prices and 

production are modestly affected and yields are assumed to be unaffected by the 

additional complications of managing multiple herbicide programs. 

DHT technology in Scenario 3 reduces the loss in farm income by preserving the GT 

crop production system convenience benefits while eliminating the need for tillage 

changes. When GR weed infestations reach 100 percent for soybeans in all areas in 

2016, the addition of DHT technology can save growers $460 million per year. Over the 

entire period of 2011 to 2020, including the smaller impacts prior to 2016, growers are 

able to retain an additional $4 billion dollars. With all soybean acres estimated to be

infested with GR weeds, the benefits over a ten year would be even higher at $4.6 billion. 

The impact of DHT technology on U.S. farm income is similar to the results from the 

case studies. In the national scenarios, DHT technology offset 18 percent of the overall 

net farm income loss posed by GR weeds. The case study results for soybeans with 

tillage impacts did show significantly higher offsets from DHT technology, but the 

scaling factors in the national analysis significantly reduces these impacts.

Consumers of soybeans and corn are also impacted by higher commodity prices resulting 

from the slight reduction in production as growers respond to higher costs of production. 

Overall, consumers lose $3.32 billion dollars of consumer welfare over the 2011 to 2020 

period with GR weeds and no DHT technology. This loss is reduced to $2.75 billion in 

the presence of DHT technology. Over the 10 year period, DHT adds $562 million back 

to consumer welfare by reducing the impact on costs of production (see Table 24). 

(Producer surplus changes were measured as the change in net farm income.)

Table 23. Farm Income Impacts of GR Weeds Without and With DHT Technology

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Gross Farm Income (Billion Dollars)

 Scenario 1: Without Weed Resistance 395.34 395.01 391.81 398.96 398.23 406.38 410.50 417.13 422.53 427.56

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.08 -0.03 0.00 -0.04 -0.03 -0.06 -0.06 -0.09 -0.12 -0.26

 Scenario 3: With Weed Resistance and DHT -0.06 -0.03 0.00 -0.04 -0.03 -0.04 -0.04 -0.07 -0.10 -0.22

Production Expenses (Billion Dollars)

 Scenario 1: Without Weed Resistance 303.74 305.50 308.36 312.46 315.05 320.72 324.96 330.49 334.81 338.48

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 1.82 1.87 2.02 2.14 2.30 2.36 2.41 2.36 2.29 2.19

 Scenario 3: With Weed Resistance and DHT 1.55 1.58 1.69 1.77 1.89 1.92 1.96 1.92 1.86 1.77

Net Farm Income (Billion Dollars)

 Scenario 1: Without Weed Resistance 91.60 89.50 83.44 86.50 83.18 85.66 85.54 86.64 87.72 89.09

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -1.89 -1.90 -2.02 -2.18 -2.34 -2.42 -2.47 -2.45 -2.41 -2.45

 Scenario 3: With Weed Resistance and DHT -1.61 -1.61 -1.69 -1.81 -1.91 -1.96 -2.01 -1.99 -1.95 -1.99
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Table 24. Changes in Consumer Welfare, Million Dollars

5.2 National Analysis Environmental Impacts

For the national analysis, environmental impacts are calculated using the switch from notill systems to conventional till systems. The IHS global agricultural model produces 

acreage impacts for nine U.S. regions (see Table 25). Table 58 and Table 59 in the 

Supplemental Tables in Section 7.0 at the end of this report present more details on 

regional acreage impacts. Using the regional acreages levels from Scenario 2, and 

adjusting for the percent of acres using no-till, percent of acres using tillage to control GR 

weeds, percent of acres using GT soybeans seed, and percent of soybean acres with at 

least one type of GR weed, produces the impact on the switch to conventional tillage 

from no-till soybean acres for the nine regions.

2011-2020

Corn Change in Consumer Surplus from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 2,164.5

 Scenario 3: With Weed Resistance and DHT 1,836.4

 Consumer Surplus Saved with DHT 328.1

Soybean Change in Consumer Surplus from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 1,151.5

 Scenario 3: With Weed Resistance and DHT 916.7

 Consumer Surplus Saved with DHT 234.8

Total Change in Consumer Surplus from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 3,316.0

 Scenario 3: With Weed Resistance and DHT 2,753.2

 Consumer Surplus Saved with DHT 562.9
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Table 25. Change in No-Till Soybean Acres With GR Weeds Without DHT 

Technology

The switch from no-till to conventional till affects 1.2 million acres creating impacts on 

soil loss, carbon emissions as well as water quality and fertilizer implications. In the 

national scenarios we focus on the soil loss and carbon emission because water quality 

and fertilizer implication are very spatially specific requiring more precision in 

measuring where the impact exactly occurs (as in the case studies). Soil losses increase 

to 2.6 million tons per year by 2016 and represent an addition 24.9 million tons of soil 

loss over the 2011 to 2020 period (see Table 26).

Table 26. Increase in Soil Loss from Switching from No-Till to Conventional Tillage

(With GR Weeds But Without DHT Technology)

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Percent of Planted Area No Tilled without resistant weeds

Northern Regions 45.4% 45.4% 45.4% 45.4% 45.4% 45.4% 45.4% 45.4% 45.4% 45.4%

Southern Regions 27.9% 27.9% 27.9% 27.9% 27.9% 27.9% 27.9% 27.9% 27.9% 27.9%

Percent of Soybean Acres Using Tillage to Control Resistant Weeds

Northern Regions 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0% 3.0%

Southern Regions 14.2% 14.2% 14.2% 14.2% 14.2% 14.2% 14.2% 14.2% 14.2% 14.2%

Percent of Soybean Acres Using GT Seed 91.0% 91.0% 91.0% 91.0% 91.0% 91.0% 91.0% 91.0% 91.0% 91.0%

Percent of Soybean Acres Infested With Resistant Weeds

Northern Regions 62.2% 70.0% 77.7% 85.5% 93.2% 100.0% 100.0% 100.0% 100.0% 100.0%

Southern Regions 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0% 100.0%

Regional Changes in No-Till Acres With Resistant Weeds and No DHT, Million Acres

 Corn Belt -0.25 -0.28 -0.32 -0.34 -0.37 -0.39 -0.39 -0.40 -0.41 -0.41

 Central Plains -0.07 -0.08 -0.09 -0.09 -0.10 -0.11 -0.11 -0.11 -0.11 -0.11

 Delta States -0.23 -0.24 -0.24 -0.23 -0.23 -0.22 -0.22 -0.22 -0.22 -0.22

 Far West 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Lake States -0.08 -0.09 -0.10 -0.11 -0.12 -0.13 -0.13 -0.13 -0.13 -0.13

 Northeast -0.01 -0.01 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02

 Northern Plains -0.07 -0.07 -0.08 -0.09 -0.09 -0.10 -0.10 -0.10 -0.10 -0.09

 Southeast -0.23 -0.23 -0.23 -0.22 -0.22 -0.21 -0.22 -0.21 -0.22 -0.21

 Southern Plains -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02

 US Total -0.97 -1.02 -1.10 -1.11 -1.17 -1.18 -1.20 -1.20 -1.21 -1.20

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Regional Soil Loss (Million tons of soil errosion per year)

Northern Regions 0.84 0.93 1.06 1.12 1.23 1.28 1.30 1.30 1.32 1.31

Southern Regions 1.38 1.37 1.40 1.34 1.33 1.28 1.30 1.29 1.29 1.27

Regional Soil Loss Weed Control (Million tons of soil errosion per year)

 Corn Belt 0.43 0.48 0.54 0.57 0.63 0.66 0.67 0.68 0.69 0.69

 Central Plains 0.13 0.14 0.16 0.17 0.19 0.19 0.20 0.20 0.20 0.20

 Delta States 0.82 0.82 0.83 0.80 0.79 0.75 0.77 0.76 0.76 0.75

 Far West 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Lake States 0.09 0.10 0.11 0.12 0.13 0.14 0.14 0.14 0.14 0.14

 Northeast 0.01 0.01 0.02 0.02 0.02 0.02 0.02 0.02 0.02 0.02

 Northern Plains 0.18 0.20 0.23 0.24 0.26 0.26 0.27 0.27 0.27 0.26

 Southeast 0.55 0.54 0.55 0.53 0.53 0.51 0.52 0.52 0.52 0.51

 Southern Plains 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01 0.01

 US Total 2.22 2.31 2.46 2.46 2.55 2.55 2.60 2.59 2.61 2.58
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Table 27. Increase in Carbon Emissions from Increased Fuel Use (With GR Weeds 

But Without DHT Technology)

Table 28. Increase in Carbon Emissions from Loss of Soil Carbon Sequestration

(With GR Weeds But Without DHT Technology)

Table 29. Total Increase in Carbon Emissions from All Sources (With GR Weeds 

But Without DHT Technology)

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Million Pounds CO2 equivalent

Change in Soybean GHG Emissions

Northern Regions 32.44 36.01 40.80 43.17 47.37 49.41 50.34 50.49 51.18 50.86

Southern Regions 34.64 34.47 34.97 33.60 33.28 32.12 32.53 32.28 32.37 31.82

Regional Changes in Soybean GHG Emissions 

 Corn Belt 16.95 18.69 21.07 22.40 24.60 25.89 26.26 26.50 27.01 27.07

 Central Plains 4.68 5.28 5.98 6.31 6.99 7.19 7.40 7.37 7.45 7.34

 Delta States 14.57 14.61 14.89 14.23 14.04 13.45 13.68 13.56 13.62 13.37

 Far West 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Lake States 5.40 6.01 6.83 7.24 7.94 8.37 8.51 8.53 8.60 8.52

 Northeast 1.02 1.12 1.30 1.33 1.52 1.56 1.62 1.63 1.66 1.65

 Northern Plains 4.39 4.90 5.62 5.89 6.32 6.40 6.55 6.45 6.46 6.28

 Southeast 18.79 18.59 18.79 18.16 18.07 17.57 17.75 17.64 17.67 17.42

 Southern Plains 1.28 1.27 1.28 1.21 1.17 1.09 1.11 1.08 1.08 1.04

 US Total 67.07 70.48 75.77 76.77 80.65 81.53 82.88 82.77 83.55 82.68

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Million Pounds CO2 equivalent

Change in Soybean Soil Carbon

Northern Regions 57.34 63.63 72.02 76.27 83.74 87.43 89.05 89.39 90.70 90.24

Southern Regions 63.09 62.84 63.79 61.25 60.65 58.48 59.27 58.81 58.98 57.97

Regional Changes in Soybean Soil Carbon 

 Corn Belt 33.68 37.13 41.85 44.50 48.87 51.43 52.16 52.65 53.65 53.78

 Central Plains 9.29 10.50 11.89 12.53 13.88 14.27 14.70 14.65 14.80 14.58

 Delta States 31.01 31.10 31.70 30.28 29.88 28.63 29.11 28.87 28.99 28.45

 Far West 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Lake States 7.14 7.97 9.05 9.59 10.52 11.08 11.28 11.30 11.39 11.28

 Northeast 1.41 1.55 1.80 1.84 2.11 2.17 2.25 2.26 2.30 2.28

 Northern Plains 5.82 6.49 7.44 7.80 8.37 8.48 8.67 8.54 8.56 8.32

 Southeast 30.27 29.94 30.27 29.26 29.10 28.31 28.59 28.41 28.45 28.05

 Southern Plains 1.81 1.80 1.82 1.72 1.66 1.55 1.57 1.54 1.53 1.47

 US Total 120.43 126.47 135.81 137.52 144.39 145.92 148.33 148.21 149.68 148.22

Assumes 10% of No-till was continuous No-Till (5 yrs or more)

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Million Pounds CO2 equivalent

Change in Soybean Soil Carbon

Northern Regions 89.78 99.64 112.82 119.44 131.11 136.84 139.40 139.88 141.88 141.10

Southern Regions 97.72 97.30 98.75 94.85 93.93 90.60 91.81 91.10 91.34 89.79

Regional Changes in Soybean Soil Carbon 

 Corn Belt 50.63 55.82 62.92 66.91 73.46 77.32 78.42 79.16 80.66 80.86

 Central Plains 13.97 15.78 17.87 18.84 20.87 21.46 22.10 22.02 22.26 21.92

 Delta States 45.58 45.71 46.59 44.50 43.92 42.08 42.79 42.44 42.61 41.82

 Far West 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Lake States 12.54 13.98 15.88 16.83 18.46 19.45 19.79 19.82 19.98 19.81

 Northeast 2.42 2.67 3.09 3.17 3.64 3.73 3.87 3.88 3.96 3.93

 Northern Plains 10.21 11.39 13.06 13.69 14.68 14.89 15.22 14.99 15.02 14.60

 Southeast 49.06 48.53 49.06 47.42 47.17 45.88 46.33 46.04 46.12 45.47

 Southern Plains 3.09 3.06 3.10 2.92 2.83 2.64 2.68 2.62 2.61 2.51

 US Total 187.50 196.95 211.58 214.29 225.04 227.44 231.20 230.98 233.22 230.90

Total Change in Annual Automobile Equivalents 15,464 16,243 17,450 17,674 18,561 18,758 19,069 19,050 19,235 19,043
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With additional tillage, green house gas emissions (measured in carbon equivalents) also 

increase significantly through increased fuel use as well as reduced carbon sequestration 

(see Table 27 and Table 28). The fuel use change is based on USDA's Energy Estimator 

tool and used 22.2 pounds of CO2 emissions per gallon of diesel fuel.9 Reduced carbon 

sequestration is based on estimates from the former Chicago Climate Exchange.26 For 

most regions this is equivalent to 1,323 pounds of CO2 emissions per year. The 

exceptions are the Northern and Southern Plains regions which are equivalent to 882 

pounds of CO2 emissions per year. These CO2 emissions apply only to continuous no till 

situations. The amount of continuous no-till acres is unknown so we have assumed 10 

percent of no-till acres are continuous in calculating soil carbon sequestration impacts.

The total impact on carbon emissions is large; reaching 230 million pounds of CO2

emissions by 2017. This is equivalent to the annual emissions from over 19,000 cars (see

Table 29). 

6. Economic and Environmental Impact Conclusions

The introduction of GT soybeans and corn enabled adoption of conservation tillage 

practices because weeds could be successfully controlled without additional tillage. Over 

the last few years, weed resistance to glyphosate has developed and continues to spread. 

Some weeds can be controlled with other herbicides at an additional cost. In some 

situations, growers have reverted back from no-till systems to conventional tillage or 

minimum tillage systems in order to control weeds such as marestail incurring not only 

the cost of additional tillage but also losing reduced tillage’s positive environmental 

benefits.

This study evaluated the economic impacts at the farm level through individual case 

study analysis and determined the aggregate economic effects at the national level using 

the IHS partial equilibrium models for U.S. crops and farm income. Both the case study 

analysis and the national analysis utilized scenario analysis to contrast a baseline situation 

of a GT crop production system with no weed resistance with situations of the same GT 

crop production system suffering from GR weeds without DHT technology and with 

DHT technology.

GR weed infestations significantly reduce farm income, erode net worth, and have 

significant environmental consequences from tillage changes. Of the five soybean case 

studies, three included tillage impacts. On the three farms with tillage impacts, growers 

without DHT technology experienced 30 to 50 percent higher expenses in controlling GR 

weeds than growers using DHT technology. In the two soybean case studies without 

tillage impacts, growers without DHT technology experienced 18 percent higher 

expenses. On average farm income in the three case studies with GR weeds and tillage 

impacts, decreased 17.2 percent without DHT technology. With DHT technology on 

these farms, the impact of GR weeds on farm income limited was limited to a decline of 

9.9 percent on average. In the two case studies with GR weeds but without tillage 

impacts, DHT technology limited the decline in farm income to 6.5 percent compared 

with 7.9 percent without DHT technology. On average across all five soybean case 
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studies, growers with DHT technology were able to recover 34 percent of their income 

lost from GR weeds. Those cases with tillage impacts recovered 45 percent of their lost 

income and those cases without tillage impacts recovered 18 percent.

The corn case studies did not include tillage impacts for any of the cases. On average 

growers without DHT technology experienced 16 to 19 percent higher expenses than 

those growers with DHT technology available. On average across all four corn case 

studies, growers with DHT technology were able to recover 17 percent of their income 

lost from GR weeds. 

Similar to the case studies, on a national basis DHT technology was found to offset over 

18 percent of the net farm income impacts and eliminate environment impacts associated 

with conventional tillage saving the equivalent of emissions from over 19,000 cars per 

year and reducing soil erosion by 2.6 million tons per year. Over the 2011 to 2020 

period, with DHT technology, growers saved $4 billion in net farm income and 

consumers saved $563 million.
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7. Supplemental Tables

Table 30. Arkansas Soybean Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.55 $ 14.70 30%

Glyphosate POST 0.94 $ 9.14 21%

(Glyphosate + Growth Regulator) f/b Glyphosate BURN f/b POST 1.99 $ 11.47 10%

Glyphosate f/b Glyphosate f/b (Broadleaf + 

Glyphosate)

BURN f/b POST f/b 

POST 2.59 $ 30.67 7%

Broadleaf f/b Glyphosate PRE f/b POST 0.87 $ 15.48 6%

Average 1.59 $ 16.29

Broadleaf or Acetamide f/b (Glyphosate + 2,4-D) PRE f/d POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply 0.75 Lb ae/A 

glyphosate ($7.62/A) + 0.71 Lb ae/A of 

2,4-D ($2.59/A) postemerence as 

needed. Calculations are based on 

one postemergence application. 

1.87 $ 19.60

Average 1.87 $ 19.60

Broadleaf f/b (Broadleaf + Glyphosate) PRE f/b POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply glyphosate as 

needed to control grasses and other 

broadleaf weeds. Apply Flexstar or 

Ultra Blazer postemergence as 

needed at full label rates to 3-inch tall 

or less Palmer amaranth (may be tank 

mixed with glyphosate). Calculations 

are based on one postemergence 

application. 

1.58 $ 28.10

Broadleaf f/b (Liberty + Acetamide) f/b Liberty

PRE f/b EPOST f/b 

POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply Liberty + Dual 

Magnum over-the-top when Palmer 

amaranth are less than 3-inches tall. 

Apply Liberty postemergence as 

needed when Palmer amaranth are 

less than 3-inches tall and before row 

closure. Calculations are based on 

one postemergence application,

2.36 $ 60.58

Average 1.97 $ 44.34

0.28 $ 3.31

0.38 $ 28.05

-0.10 $ (24.74)

*** Bond, J., T. Eubank, K. Smith, and B. Scott. 2010. Glyphosate-resistant Palmer Amaranth and Ryegrass Management. Mississippi Agricultural and 

Forestry Experiment Station. University of Arkansas Division of Agriculture. Infomration Sheet 1351. March 2010. 

http://msucares.com/pubs/infosheets_research/i1351.pdf

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Soybeans With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for C minus A

Projected Rate and Cost Increase (Decrease) for B Minus C
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Table 31. Georgia Soybean Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.75 $ 7.21 75%

(Broadleaf + Glyphosate) PRE f/b POST 0.91 $ 16.99 18%

(Glyphosate + DNA) f/b (Broadleaf + Glyphosate) BURN PRE f/b POST 2.70 $ 32.56 8%

Average 1.45 $ 18.92

Broadleaf or Acetamide f/b (Glyphosate + 2,4-D) PRE f/d POST

Apply Sencor or Canopy or Boundry or 

Authority MTZ or Dual Magnum or 

Intrro premergence. Apply 0.75 Lb 

ae/A glyphosate ($7.62) + 0.71 Lb 

ae/A of 2,4-D ($2.59/A) postemerence 

as needed. Calculations are based on 

one postemergence application. 

2.17 $ 19.84

Average 2.17 $ 19.84

Broadleaf or Acetamide f/b (Broadleaf + 

Glyphosate) PRE f/b POST

GT Soybeans : Apply Sencor or 

Canopy or Boundry or Authority MTZ 

or Dual Magnum or Intrro 

premergence. Apply glyphosate + 

Reflex or glyphosate + Ultra Blazer or 

glyphosate + Cobra or glyphosate + 

Prefix or postemergence as needed. 

Calculations are based on one 

postemergence application. 2.04 $ 28.37

Broadleaf or Acetamide f/b Liberty PRE f/b POST

Liberty Link Soybeans: Apply Dual 

Magnum or Intrro or Valor or Envive or 

Prefix or Valor XLT premergence. 

Apply Liberty postemergence as 

needed. Calculations are based on 

one postemergence application. 1.01 $ 28.90

Average 1.53 $ 28.64

0.72 $ 0.92

0.07 $ 9.72

0.65 $ (8.80)

Projected Rate and Cost Increase (Decrease) for C minus A

 A. Top Herbicide Programs in GT Soybeans

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Soybeans With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

*** Prostko, E. P. 2010. Managing Herbicide Resistant Palmer Amananty (Pigweed) in Field Corn, Peanut, and Soybean - 2010. University of Georgia. 

http://mulch.cropsoil.uga.edu/weedsci/resistance-10-tables.pdf 

Projected Rate and Cost Increase (Decrease) for B Minus C

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.
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Table 32. Illinois Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.91 $ 10.18 30%

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.75 $ 17.69 23%

(Glyphosate + Growth Regulator) f/b Glyphosate BURN f/b POST 2.17 $ 19.38 7%

(Broadleaf + Glyphosate + Growth Regulators) f/b 

Glyphosate+A22+A36 BURN f/b POST 2.35 $ 29.11 6%

Broadleaf f/b Glyphosate PRE f/b POST 1.02 $ 19.67 4%

Average 1.64 $ 19.21

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.49 $ 11.22

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.33 $ 18.73

(Glyphosate + Growth Regulator) f/b (Glyphosate + 

2,4-D) BURN f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 2.75 $ 20.42

(Glyphosate + Growth Regulators) f/b (Glyphosate 

+ 2,4-D) BURN f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A), 

subtract 0.13 Lb ae/A of Glyphosate 

($1.55/A) and subtract 0.11 lb ai/A of 

Broadleaf ($9.32/A). 2.93 $ 20.83

(Glyphosate + 2,4-D) POST Same as above 1.60 $ 11.39

Average 2.22 $ 16.52

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.58 $ (2.69)

0.04 $ 12.28

Projected Rate and Cost Increase (Decrease) for B Minus D 0.54 $ (14.97)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

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Table 33. Iowa Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.91 $ 9.67 31%

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.73 $ 18.39 25%

DNAs f/b Glyphosate PRE f/b POST 1.94 $ 16.50 10%

Broadleaf f/b Glyphosate POST 0.99 $ 22.48 7%

(Glyphosate + Post Grass) POST 0.85 $ 13.22 4%

Average 1.28 $ 16.05

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.49 $ 10.71

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.31 $ 19.43

DNAs f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A), 

subtract 0.13 Lb ae/A of Glyphosate 

($1.55/A) and subtract 0.11 lb ai/A of 

Broadleaf ($9.32/A). 2.52 $ 17.54

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.46 $ 14.20

(Glyphosate + Post Grass + 2,4-D) POST Same as above 1.43 $ 14.26

Average 1.84 $ 15.23

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Growth Regulator) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.56 $ (0.82)

0.39 15.43

0.17 $ (16.26)

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A

Projected Rate and Cost Increase (Decrease) for B Minus D

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.
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Table 34. Minnesota Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.60 $ 16.21 37%

Glyphosate POST 0.86 $ 9.09 35%

(Glyphosate + Post Grass) POST 0.88 $ 13.79 6%

(Glyphosate + Post Grass) f/b Glyphosate POST f/b POST 1.72 $ 22.17 4%

Glyphosate f/b (Glyphosate + Post Grass) POST f/b POST 1.55 $ 20.53 3%

Average 1.32 $ 16.36

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.18 $ 17.25

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.44 $ 10.13

(Glyphosate + Post Grass + 2,4-D) POST Same as above 1.46 $ 14.83

(Glyphosate + Post Grass) f/b (Glyphosate + 2,4-D) 

or (Glyphosate + Post Grass + 2,4-D) f/b 

(Glyphosate + 2,4-D) POST f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.30 $ 23.21

(Glyphosate) f/b (Glyphosate + Post Grass + 2,4-D) 

or (Glyphosate + 2,4-D) f/b (Glyphosate + Post 

Grass + 2,4-D) POST f/b POST Same as above 2.13 $ 21.57

Average 1.90 $ 17.40

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.58 $ 1.04

0.35 $ 15.13

Projected Rate and Cost Increase (Decrease) for B Minus D 0.23 $ (14.09)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 98 of 202

Table 35. Illinois Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST 2.64 $ 23.62 32%

Glyphosate POST 0.90 $ 9.50 15%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.52 $ 15.61 7%

(Acetamide Pre-Mix + Glyphosate) POST 3.02 $ 27.15 5%

(Triazine + Glyphosate) POST 1.99 $ 11.96 4%

Average 2.02 $ 17.57

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) or 

(Acetamide Pre-Mix + Glyphosate + 2,4-D) PRE f/b POST or POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.22 $ 24.66

(Glyphosate + 2,4-D) POST Same as above 1.48 $ 10.54

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.10 $ 16.65

(Acetamide Pre-Mix + Glyphosate + 2,4-D) POST Same as above 3.60 $ 28.19

(Triazine + Glyphosate + 2,4-D) POST Same as above 2.57 $ 13.00

Average 2.59 $ 18.61

Acetamide Pre-Mix PRE or POST 2.33 $ 19.13 40%

(Acetamide Pre-Mix + Triazine) PRE or POST 3.16 $ 24.43 9%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide 

Pre-Mix + Broadleaf) PRE f/b POST or POST 2.38 $ 29.13 7%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 3.14 $ 31.86 5%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.61 $ 26.09

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 3.23 $ 28.27

Acetamide Pre-Mix f/b (Triazine + Glyphsate) or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 4.06 $ 33.57

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.28 $ 38.27

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) 

or (Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 4.04 $ 41.00

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 3.33 $ 33.40

0.58 $ 1.04

1.32 $ 15.83

Projected Rate and Cost Increase (Decrease) for B Minus D -0.74 $ (14.79)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 99 of 202

Table 36. Iowa Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 2.44 $ 21.93 34%

Glyphosate POST 0.85 $ 8.53 20%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.76 $ 18.95 8%

(Broadleaf + Glyphosate) POST 0.93 $ 19.63 5%

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) PRE f/b POST 2.33 $ 27.09 5%

Average 1.66 $ 19.23

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.02 $ 22.97

(Glyphosate + 2,4-D) POST Same as above 1.43 $ 9.57

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.34 $ 19.99

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) and 0.24 Lb 

ai/A of Broadleaf 

($12.08/A) 1.27 $ 8.59

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST Same as above 2.67 $ 16.05

Average 2.15 $ 15.43

Acetamide Pre-Mix PRE or POST 2.03 $ 19.24 24%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide 

Pre-Mix + Broadleaf) PRE f/b POST or POST 2.67 $ 34.62 14%

(Acetamide Pre-Mix + Triazine) PRE or POST 2.70 $ 25.11 12%

(Broadleaf + Triazine) PRE or POST 0.96 $ 19.07 9%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.08 $ 24.78

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 2.93 $ 28.38

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.57 $ 43.76

(Acetamide Pre-Mix + Triazine) f/b Glyphosate or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 3.60 $ 34.25

(Broadleaf + Triazine) + Glyphosate or (Broadleaf 

+ Triazine + Glyphosate) PRE f/b POST or POST Same as above 1.86 $ 28.21

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 2.80 $ 32.10

0.48 $ (3.79)

1.14 $ 12.87

Projected Rate and Cost Increase (Decrease) for B Minus D -0.66 $ (16.66)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 100 of 202

Table 37. Minnesota Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 2.22 $ 21.32 31%

Glyphosate POST 0.84 $ 8.48 21%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.58 $ 14.97 12%

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST 2.04 $ 28.54 8%

(Broadleaf + Glyphosate) POST 0.92 $ 16.23 6%

Average 1.52 $ 17.91

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 2.80 $ 22.36

(Glyphosate + 2,4-D) POST Same as above 1.42 $ 9.52

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.16 $ 16.01

Acetamide f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) and 0.24 Lb 

ai/A of Broadleaf 

($12.08/A). 2.38 $ 17.50

(Glyphosate + 2,4-D) POST Same as above 1.26 $ 5.19

Average 2.00 $ 14.12

Acetamide Pre-Mix PRE or POST 1.71 $ 18.55 34%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide PreMix + Broadleaf) PRE f/b POST or POST 1.88 $ 24.81 17%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 2.22 $ 26.94 10%

Acetamide Pre-Mix f/b (Broadleaf + Triazine) PRE f/b POST 2.02 $ 26.24 6%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 1.98 $ 24.48

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 2.61 $ 27.69

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 2.78 $ 33.95

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE or POST Same as above 3.12 $ 36.08

Acetamide Pre-Mix f/b (Broadleaf + Triazine + 

Glyphosate) PRE f/b POST Same as above 2.92 $ 35.38

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 2.70 $ 31.80

0.48 $ (3.79)

1.18 $ 13.89

Projected Rate and Cost Increase (Decrease) for B Minus D -0.69 $ (17.68)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 101 of 202

Table 38. Ohio Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program*

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 3.22 $ 27.48 32%

Glyphosate POST 0.96 $ 10.01 14%

(Acetamide Pre-Mix + Glyphosate) BURN/PRE or POST 3.11 $ 29.62 10%

Glyphosate f/b Glyphosate

BURN f/b POST or 

POST f/b POST 1.40 $ 15.02 9%

(Triazine + Glyphosate) BURN/PRE or POST 2.71 $ 12.09 5%

Average 2.28 $ 18.84

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.80 $ 28.52

(Glyphosate + 2,4-D) POST Same as above 1.54 $ 11.05

(Acetamide Pre-Mix + Glyphosate + 2,4-D) BURN/PRE or POST Same as above 3.69 $ 30.66

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or 

POST f/b POST Same as above 1.98 $ 16.06

(Triazine + Glyphosate) BURN/PRE or POST Same as above 3.29 $ 13.13

Average 2.86 $ 19.88

Acetamide Pre-Mix PRE or POST 2.27 $ 15.38 49%

(Acetamide Pre-Mix + Triazine) PRE or POST 3.24 $ 25.32 14%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 2.54 $ 28.68 7%

(Broadleaf + Post Grass + Triazine) POST 2.44 $ 36.10 2%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.51 $ 26.27

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST 

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 3.17 $ 24.52

(Acetamide Pre-Mix + Triazine) f/b Glyphosate or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 4.14 $ 34.46

(Acetamide Pre-Mix + Broadleaf) f/b Glyphosate 

or (Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.44 $ 37.82

(Broadleaf + Triazine + Glyphosate) POST Same as above 3.34 $ 45.24

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 3.23 $ 33.58

0.58 $ 1.04

0.95 $ 14.74

-0.37 $ (13.70)

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% 

of Base Treated Acres to insure its inclusion as an alternative.

D. Projected Herbicide Programs in GT Corn Without DHT

C. Top Five Herbicide Herbicide Programs in Conventional Corn

B. Projected Herbicide Programs in GT Corn With DHT 

Projected Rate and Cost Increase (Decrease) for B Minus D

 A. Top Five Herbicide Programs in GT Corn

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 102 of 202

Table 39. Georgia Corn Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)*

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.77 $ 8.90 22%

Triazine f/b Glyphosate PRE f/b POST 2.86 $ 13.26 12%

Glyphosate f/b (Glyphosate + Triazine) BURN f/b POST 3.68 $ 20.61 5%

(Glyphosate + Synthetic Auxin) + (Glyphosate + 

Synthetic Auxin) BURN f/b POST 2.75 $ 31.20 3%

Glyphosate f/b Triazine f/b Glyphosate BURN f/b PRE f/b POST 3.50 $ 21.25 3%

Average 2.71 $ 19.04

Atrazine f/b (Glyphosate + 2,4-D) + (2,4-D or 

Banvel/Clarity/Status)

PRE f/b POST f/b LAYBY 

(as needed)

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.85 Lb ai/A of nonglyphosate broadleaf herbicides 

($7.54/A) applied postemergence in C 

below. Calculations are based on one 

layby application.

3.07 $ 19.39

(Bicep II Magnum/Bullet/ Guardsman/Lariat/Lexar 

at 66% normal rate) + (Glyphosate + 2,4-D) + (2,4-

D or Banvel/Clarity/Status) 

PRE f/b POST f/b LAYBY 

(as needed)

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.85 Lb ai/A of nonglyphosate broadleaf herbicides 

($7.54/A) applied postemergence in C 

below. Calculations are based on one 

layby application.

3.42 $ 26.67

Average 3.24 $ 23.03

Atrazine f/b (Glyphosate + 

Atrazine/Banvel/Clarity/Status or 

Expert/Sequence/Halex GT) + (2,4-D or 

Banvel/Clarity/Status)

PRE f/b POST f/b LAYBY 

(as needed)

Calculations are based on one layby 

application.

3.21 $ 24.34

(Bicep II Magnum/Bullet/ Guardsman/Lariat/Lexar 

at 66% normal rate) + (Glyphosate + 

Atrazine/Banvel/Clarity/Status or 

Expert/Sequence/Halex GT) + (2,4-D or 

Banvel/Clarity/Status) 

PRE f/b POST f/b LAYBY 

(as needed)

Calculations are based on one layby 

application.

3.56 $ 31.62

Average 3.39 $ 27.98

0.53 $ 3.99

0.68 $ 8.94

-0.14 $ (4.95)

Cost estimates for DHT Technology is based on 2009 pricing for 

2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 2,4-D that will be used registered for use on crops containing DHT 

technology, and technology fees had not been established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

*** Prostko, E. P. 2011. Managing Herbicide Resistant Palmer Amananty (Pigweed) in Field Corn, Peanut, and Soybean - 2011. University of Georgia. 

http://mulch.cropsoil.uga.edu/weedsci/resistance-2011-tables.pdf 

A. Top Herbicide Programs in GT Corn

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Corn With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Corn Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for C minus A

Projected Rate and Cost Increase (Decrease) for B Minus C
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Table 40. Cultivated Soils and Soil Texture

Soil Acres % of Total 

Cultivated Soils

Soil Type

AR, Phillips County Alligator 11,830 4.2% Silty Clay

Dubbs 8330 3.0% Silt Loam

Dundee 10300 3.6% Silt Loam

Falaya 5820 2.1% Silt Loam

Foley 38990 13.8% Silt Loam

Henry 36980 13.1% Silt Loam

Jeanerette 9620 3.4% Silt Loam

Loring 28280 10.0% Silt Loam

Newellton 38250 13.6% Silty Clay

Sharkey 93800 33.2% Silty Clay

Total 282,200 100.0%

GA, Dooly/Macon County Chewacla 19895 9.4% Fine Sandy Loam

Cowarts 14880 7.1% Sandy Loam

Dothan 79010 37.4% Loamy Sand

Fuquay 23905 11.3% Loamy Sand

Lucy 25990 12.3% Loamy Sand

Orangeburg 47375 22.4% Loamy Sand

Total 211055 100.0%

IL, Fayette County Atlas 15100 5.8% Silt Loam

Beaucoup 11831 4.5% Silty Clay Loam

Bluford 83798 32.1% Silt Loam

Cisne 50899 19.5% Silt Loam

Darmstadt 26205 10.0% Silt Loam

Ebbert 4942 1.9% Silt Loam

Hoyleton 39328 15.1% Silt Loam

Parke 13526 5.2% Silt Loam

Titus 6808 2.6% Silty Clay Loam

Wynoose 8327 3.2% Silt Loam

Total 260764 100.0%

Source: Natural Resources Conservation Service23
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Table 41. Factors Contributing to Water Quality in Phillips County, Arkansas

AR, Phillips County Soil Soil Erosion

(tons/acre)

N Loss

(lbs/acre)

P loss

(lbs/acre)

Conventional Tillage Alligator 3.81 19.16 0.71

Dubbs 0.65 2.77 0.12

Dundee 2.48 5.39 0.38

Falaya 2.34 11.37 0.44

Foley 1.73 6.88 0.30

Henry 3.23 13.11 0.53

Jeanerette 1.18 7.80 0.24

Loring 1.90 7.79 0.33

Newellton 1.47 8.15 0.32

Sharkey 2.33 10.44 0.46

No till Alligator 1.61 13.96 0.69

Dubbs 0.30 2.10 0.12

Dundee 1.21 4.26 0.34

Falaya 0.90 8.53 0.39

Foley 0.79 5.85 0.28

Henry 1.20 9.94 0.44

Jeanerette 0.47 6.15 0.23

Loring 0.78 5.91 0.30

Newellton 0.79 7.09 0.30

Sharkey 1.08 8.08 0.42

Table 42. Factors Contributing to Water Quality in Dooly/Macon County, Georgia

GA, Dooly/Macon Soil Soil Erosion

(tons/acre)

Total N Loss

(lbs/acre)

Total P losses

(lbs/acre)

Conventional Tillage Chewacla 0.14 1.40 0.04

Cowarts 0.48 1.72 0.07

Dothan 0.02 0.14 0.01

Fuquay 0.03 0.39 0.01

Lucy 0.02 0.24 0.01

Orangeburg 0.03 0.27 0.01

No till Chewacla 0.06 1.05 0.04

Cowarts 0.22 1.30 0.06

Dothan 0.01 0.10 0.00

Fuquay 0.01 0.21 0.01

Lucy 0.01 0.12 0.00

Orangeburg 0.01 0.17 0.00
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Table 43. Factors Contributing to Water Quality in Dooly/Macon County, Georgia

IL, Fayette Soil Soil Erosion

(tons/acre)

Total N Loss

(lbs/acre) 

Total P losses

(lbs/acre)

Conventional Tillage Atlas 3.65 17.76 0.74

Beaucoup 0.18 3.19 0.10

Bluford 0.33 3.59 0.10

Cisne 0.99 9.04 0.23

Darmstadt 0.90 6.88 0.17

Ebbert 0.52 5.42 0.16

Hoyleton 0.33 3.59 0.10

Parke 0.61 3.68 0.13

Titus 0.76 8.27 0.26

Wynoose 0.66 5.48 0.16

No till Atlas 1.66 14.02 0.63

Beaucoup 0.07 1.97 0.06

Bluford 0.14 2.51 0.08

Cisne 0.35 6.79 0.17

Darmstadt 0.35 5.35 0.17

Ebbert 0.20 4.04 0.12

Hoyleton 0.13 2.49 0.07

Parke 0.26 2.51 0.10

Titus 0.32 6.57 0.21

Wynoose 0.27 4.36 0.12
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Table 44. Factors Contributing to GHGs and Carbon Sequestration in Phillips 

County, Arkansas

AR, Phillips County Soil

Carbon 

Sequestration

(tons/acre)

Conventional Tillage Alligator 2.36

Dubbs 2.01

Dundee 0.45

Falaya -4.29

Foley 0.10

Henry 1.54

Jeanerette 0.41

Loring 1.74

Newellton NA

Sharkey 0.82

No till Alligator 3.21

Dubbs 2.91

Dundee 1.06

Falaya -2.77

Foley 1.10

Henry 2.84

Jeanerette 1.42

Loring 2.81

Newellton NA

Sharkey 1.45

Table 45. Factors Contributing to GHGs and Carbon Sequestration in 

Dooly/Macon County, Georgia

GA, Dooly/Macon Soil

Carbon 

Sequestration

(tons/acre)

Conventional Tillage Chewacla -4.98

Cowarts -2.07

Dothan -0.13

Fuquay -4.02

Lucy -2.03

Orange -0.37

No till Chewacla -4.38

Cowarts -1.64

Dothan 0.12

Fuquay -3.70

Lucy -1.74

Orange 0.10
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Table 46. Factors Contributing to GHGs and Carbon Sequestration in Fayette 

County, Illinois

IL, Fayette Soil

Carbon 

Sequestration

(tons/acre)

Conventional Tillage Atlas -1.18

Beaucoup -4.54

Bluford 0.31

Cisne 0.67

Darmstadt 1.09

Ebbert 0.02

Hoyleton 0.69

Parke 0.69

Titus -1.39

Wynoose 0.83

No till Atlas 0.12

Beaucoup -3.88

Bluford 1.03

Cisne 1.68

Darmstadt 1.89

Ebbert 0.79

Hoyleton 1.48

Parke 1.43

Titus -0.56

Wynoose 1.63
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Table 47. Phillips County, Arkansas Case Study Results, 936 Acre Soybean Farm 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 535,534 519,552 515,543 501,103 483,106 488,764 482,342 495,385 491,798 496,808

 Total Farm Expenses 299,719 298,804 299,922 299,776 299,992 298,643 296,474 302,083 307,089 311,690

 Net Farm Income 235,815 220,748 215,622 201,327 183,114 190,121 185,867 193,302 184,709 185,118

 Cash Flow 461,498 617,537 757,428 870,237 949,805 1,018,435 1,192,454 1,373,347 1,545,060 1,716,567

 Net Worth 2,259,068 2,599,339 2,868,732 3,095,439 3,289,323 3,478,485 3,665,475 3,867,063 4,067,753 4,275,349

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 535,534 519,552 515,543 501,103 483,106 488,764 482,342 495,385 491,798 496,808

 Total Farm Expenses 340,222 340,381 343,062 344,279 346,019 345,953 344,994 351,861 358,007 363,671

 Net Farm Income 195,312 179,171 172,481 156,824 137,087 142,811 137,348 143,524 133,791 133,137

 Cash Flow 381,383 495,845 592,596 660,902 694,443 715,763 841,262 972,378 1,093,173 1,212,699

 Net Worth 2,178,953 2,477,647 2,703,899 2,886,104 3,033,961 3,175,813 3,314,283 3,466,094 3,615,867 3,771,481

Scenario 3: Weed Resistance - DHT Techology Available

 Total Farm Receipts Including Government Payments 535,534 519,552 515,543 501,103 483,106 488,764 482,342 495,385 491,798 496,808

 Total Farm Expenses 328,001 327,837 330,046 330,852 332,132 331,679 330,354 336,842 342,644 347,988

 Net Farm Income 207,532 191,715 185,498 170,252 150,974 157,085 151,987 158,543 149,154 148,821

 Cash Flow 405,555 532,562 642,329 724,062 771,490 807,084 947,223 1,093,357 1,229,515 1,364,725

 Net Worth 2,203,125 2,514,363 2,753,632 2,949,264 3,111,008 3,267,135 3,420,244 3,587,073 3,752,209 3,923,507

Scenario 4: Weed Resistance - No DHT, Addition of Preplant Disking to No-Till

 Total Farm Receipts Including Government Payments 535,534 519,552 515,543 501,103 483,106 488,764 482,342 495,385 491,798 496,808

 Total Farm Expenses 330,371 330,269 332,570 333,455 334,825 334,446 333,193 339,754 345,623 351,029

 Net Farm Income 205,163 189,283 182,974 167,648 148,281 154,317 149,149 155,631 146,175 145,780

 Cash Flow 400,869 525,443 632,686 711,815 756,551 789,377 926,678 1,069,900 1,203,079 1,335,248

 Net Worth 2,198,439 2,507,244 2,743,989 2,937,018 3,096,069 3,249,428 3,399,699 3,563,616 3,725,773 3,894,030

Scenario 5: Weed Resistance - No DHT without Tillage Impacts

 Total Farm Receipts Including Government Payments 535,534 519,552 515,543 501,103 483,106 488,764 482,342 495,385 491,798 496,808

 Total Farm Expenses 331,359 331,283 333,622 334,541 335,948 335,600 334,377 340,968 346,865 352,297

 Net Farm Income 204,175 188,269 181,921 166,562 147,158 153,163 147,965 154,417 144,933 144,512

 Cash Flow 398,914 522,474 628,664 706,708 750,321 781,993 918,110 1,060,118 1,192,055 1,322,956

 Net Worth 2,196,484 2,504,275 2,739,968 2,931,911 3,089,839 3,242,044 3,391,131 3,553,834 3,714,748 3,881,737

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 40,503 41,577 43,140 44,503 46,027 47,310 48,519 49,777 50,918 51,981

 Net Farm Income -40,503 -41,577 -43,140 -44,503 -46,027 -47,310 -48,519 -49,777 -50,918 -51,981

 Cash Flow -80,115 -121,692 -164,832 -209,335 -255,362 -302,672 -351,192 -400,969 -451,887 -503,868

 Net Worth -80,115 -121,692 -164,832 -209,335 -255,362 -302,672 -351,192 -400,969 -451,887 -503,868

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -12,221 -12,544 -13,016 -13,427 -13,887 -14,274 -14,639 -15,019 -15,363 -15,684

 Net Farm Income 12,221 12,544 13,016 13,427 13,887 14,274 14,639 15,019 15,363 15,684

 Cash Flow 24,172 36,717 49,733 63,160 77,047 91,322 105,961 120,979 136,342 152,026

 Net Worth 24,172 36,717 49,733 63,160 77,047 91,322 105,961 120,979 136,342 152,026

Change: Scenario 3 - Scenario 4

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -2,369 -2,432 -2,524 -2,603 -2,693 -2,768 -2,838 -2,912 -2,979 -3,041

 Net Farm Income 2,369 2,432 2,524 2,603 2,693 2,768 2,838 2,912 2,979 3,041

 Cash Flow 4,687 7,119 9,643 12,246 14,939 17,707 20,545 23,457 26,436 29,477

 Net Worth 4,687 7,119 9,643 12,246 14,939 17,707 20,545 23,457 26,436 29,477

Change: Scenario 3 - Scenario 5

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -3,358 -3,447 -3,576 -3,689 -3,816 -3,922 -4,022 -4,126 -4,221 -4,309

 Net Farm Income 3,358 3,447 3,576 3,689 3,816 3,922 4,022 4,126 4,221 4,309

 Cash Flow 6,641 10,088 13,664 17,353 21,169 25,091 29,113 33,239 37,460 41,769

 Net Worth 6,641 10,088 13,664 17,353 21,169 25,091 29,113 33,239 37,460 41,769
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Table 48. Dooly County, Georgia Case Study Results, 320 Acre Soybean Farm 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 181,256 176,435 175,309 170,980 165,566 167,429 165,583 169,715 168,745 170,414

 Total Farm Expenses 83,663 83,652 84,255 84,506 84,881 84,815 84,527 86,228 87,755 89,164

 Net Farm Income 97,593 92,783 91,054 86,473 80,685 82,614 81,056 83,487 80,991 81,249

 Cash Flow 198,575 275,342 347,598 412,042 466,897 519,141 597,747 678,668 756,971 835,405

 Net Worth 793,163 923,931 1,032,075 1,126,614 1,210,722 1,293,031 1,374,444 1,460,564 1,546,634 1,635,027

Scenario 2: Weed Resistance - No DHT, Switch from No-Till to Conventional Till

 Total Farm Receipts Including Government Payments 181,256 176,435 175,309 170,980 165,566 167,429 165,583 169,715 168,745 170,414

 Total Farm Expenses 91,115 91,301 92,192 92,694 93,349 93,519 93,453 95,386 97,122 98,728

 Net Farm Income 90,142 85,134 83,118 78,286 72,217 73,910 72,130 74,329 71,623 71,686

 Cash Flow 183,835 252,954 317,273 373,530 419,917 463,457 533,137 604,899 673,835 742,706

 Net Worth 778,424 901,543 1,001,750 1,088,102 1,163,742 1,237,347 1,309,833 1,386,796 1,463,498 1,542,328

Scenario 3: Weed Resistance - DHT Techology Available

 Total Farm Receipts Including Government Payments 181,256 176,435 175,309 170,980 165,566 167,429 165,583 169,715 168,745 170,414

 Total Farm Expenses 87,013 87,091 87,823 88,187 88,688 88,728 88,540 90,346 91,966 93,464

 Net Farm Income 94,243 89,344 87,486 82,792 76,878 78,701 77,043 79,370 76,779 76,950

 Cash Flow 191,948 265,277 333,965 394,728 445,776 494,106 568,699 645,503 719,594 793,729

 Net Worth 786,536 913,866 1,018,441 1,109,300 1,189,600 1,267,996 1,345,396 1,427,399 1,509,257 1,593,351

Scenario 4: Weed Resistance - No DHT, Addition of Preplant Disking to No-Till

 Total Farm Receipts Including Government Payments 181,256 176,435 175,309 170,980 165,566 167,429 165,583 169,715 168,745 170,414

 Total Farm Expenses 87,820 87,919 88,682 89,073 89,604 89,670 89,506 91,337 92,980 94,499

 Net Farm Income 93,437 88,516 86,627 81,906 75,961 77,759 76,077 78,378 75,765 75,915

 Cash Flow 190,353 262,853 330,682 390,559 440,691 488,079 561,706 637,518 710,596 783,696

 Net Worth 784,941 911,443 1,015,159 1,105,131 1,184,515 1,261,969 1,338,403 1,419,415 1,500,259 1,583,318

Scenario 5: Weed Resistance - No DHT without Tillage Impacts

 Total Farm Receipts Including Government Payments 181,256 176,435 175,309 170,980 165,566 167,429 165,583 169,715 168,745 170,414

 Total Farm Expenses 88,161 88,269 89,046 89,448 89,992 90,068 89,915 91,756 93,409 94,937

 Net Farm Income 93,095 88,166 86,264 81,531 75,573 77,360 75,668 77,959 75,336 75,477

 Cash Flow 189,678 261,828 329,294 388,796 438,540 485,530 558,748 634,140 706,789 779,451

 Net Worth 784,266 910,417 1,013,770 1,103,368 1,182,364 1,259,420 1,335,445 1,416,037 1,496,452 1,579,073

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 7,452 7,649 7,937 8,187 8,468 8,704 8,926 9,158 9,368 9,563

 Net Farm Income -7,452 -7,649 -7,937 -8,187 -8,468 -8,704 -8,926 -9,158 -9,368 -9,563

 Cash Flow -14,739 -22,388 -30,325 -38,512 -46,980 -55,684 -64,610 -73,768 -83,136 -92,699

 Net Worth -14,739 -22,388 -30,325 -38,512 -46,980 -55,684 -64,610 -73,768 -83,136 -92,699

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -4,101 -4,210 -4,369 -4,506 -4,661 -4,791 -4,913 -5,041 -5,156 -5,264

 Net Farm Income 4,101 4,210 4,369 4,506 4,661 4,791 4,913 5,041 5,156 5,264

 Cash Flow 8,113 12,323 16,691 21,198 25,859 30,649 35,563 40,603 45,759 51,023

 Net Worth 8,113 12,323 16,691 21,198 25,859 30,649 35,563 40,603 45,759 51,023

Change: Scenario 3 - Scenario 4

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -807 -828 -859 -886 -917 -942 -966 -991 -1,014 -1,035

 Net Farm Income 807 828 859 886 917 942 966 991 1,014 1,035

 Cash Flow 1,595 2,423 3,282 4,168 5,085 6,027 6,993 7,984 8,998 10,033

 Net Worth 1,595 2,423 3,282 4,168 5,085 6,027 6,993 7,984 8,998 10,033

Change: Scenario 3 - Scenario 5

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -1,148 -1,178 -1,222 -1,261 -1,304 -1,341 -1,375 -1,411 -1,443 -1,473

 Net Farm Income 1,148 1,178 1,222 1,261 1,304 1,341 1,375 1,411 1,443 1,473

 Cash Flow 2,270 3,448 4,671 5,932 7,236 8,577 9,952 11,362 12,805 14,278

 Net Worth 2,270 3,448 4,671 5,932 7,236 8,577 9,952 11,362 12,805 14,278
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Table 49. Fayette County, Illinois Case Study Results, 250 Acre Soybean Farm 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 113,579 109,849 108,481 105,149 101,192 101,757 100,058 102,017 100,879 101,346

 Total Farm Expenses 62,912 62,529 62,538 62,299 62,116 61,616 60,939 62,018 62,976 63,852

 Net Farm Income 50,667 47,320 45,943 42,850 39,076 40,141 39,120 39,999 37,903 37,495

 Cash Flow 96,089 128,395 156,808 179,212 194,416 206,598 242,602 279,339 313,825 347,741

 Net Worth 937,497 1,038,786 1,109,009 1,163,319 1,207,258 1,246,967 1,286,593 1,330,334 1,375,453 1,423,097

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 113,579 109,849 108,481 105,149 101,192 101,757 100,058 102,017 100,879 101,346

 Total Farm Expenses 69,615 69,410 69,677 69,664 69,733 69,445 68,968 70,256 71,402 72,454

 Net Farm Income 43,964 40,439 38,804 35,485 31,459 32,312 31,090 31,762 29,477 28,892

 Cash Flow 82,831 108,257 129,531 144,570 152,157 156,510 184,485 212,984 239,044 264,357

 Net Worth 924,239 1,018,647 1,081,732 1,128,677 1,164,999 1,196,879 1,228,476 1,263,979 1,300,672 1,339,713

Scenario 3: Weed Resistance - DHT Techology Available

 Total Farm Receipts Including Government Payments 113,579 109,849 108,481 105,149 101,192 101,757 100,058 102,017 100,879 101,346

 Total Farm Expenses 66,208 65,913 66,049 65,921 65,862 65,466 64,888 66,069 67,120 68,082

 Net Farm Income 47,370 43,936 42,432 39,228 35,330 36,291 35,171 35,948 33,759 33,264

 Cash Flow 89,569 118,491 143,394 162,175 173,634 181,965 214,021 246,706 277,048 306,734

 Net Worth 930,977 1,028,882 1,095,594 1,146,282 1,186,476 1,222,334 1,258,011 1,297,701 1,338,676 1,382,090

Scenario 4: Weed Resistance - No DHT, Addition of Preplant Disking to No-Till

 Total Farm Receipts Including Government Payments 113,579 109,849 108,481 105,149 101,192 101,757 100,058 102,017 100,879 101,346

 Total Farm Expenses 66,882 66,605 66,767 66,661 66,627 66,253 65,695 66,897 67,967 68,947

 Net Farm Income 46,697 43,244 41,715 38,487 34,565 35,504 34,364 35,120 32,912 32,399

 Cash Flow 88,236 116,467 140,652 158,693 169,386 176,930 208,179 240,036 269,531 298,352

 Net Worth 929,644 1,026,858 1,092,852 1,142,800 1,182,228 1,217,299 1,252,169 1,291,031 1,331,159 1,373,708

Scenario 5: Weed Resistance - No DHT without Tillage Impacts

 Total Farm Receipts Including Government Payments 113,579 109,849 108,481 105,149 101,192 101,757 100,058 102,017 100,879 101,346

 Total Farm Expenses 67,102 66,830 67,001 66,903 66,878 66,510 65,958 67,168 68,244 69,229

 Net Farm Income 46,477 43,018 41,480 38,246 34,315 35,247 34,100 34,849 32,635 32,117

 Cash Flow 87,801 115,805 139,756 157,555 167,998 175,285 206,270 237,857 267,075 295,614

 Net Worth 929,208 1,026,196 1,091,956 1,141,663 1,180,840 1,215,654 1,250,261 1,288,852 1,328,703 1,370,970

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 6,703 6,880 7,139 7,365 7,617 7,829 8,029 8,237 8,426 8,602

 Net Farm Income -6,703 -6,880 -7,139 -7,365 -7,617 -7,829 -8,029 -8,237 -8,426 -8,602

 Cash Flow -13,258 -20,138 -27,277 -34,642 -42,259 -50,088 -58,117 -66,355 -74,781 -83,383

 Net Worth -13,258 -20,138 -27,277 -34,642 -42,259 -50,088 -58,117 -66,355 -74,781 -83,383

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -3,406 -3,497 -3,628 -3,743 -3,871 -3,979 -4,081 -4,186 -4,282 -4,372

 Net Farm Income 3,406 3,497 3,628 3,743 3,871 3,979 4,081 4,186 4,282 4,372

 Cash Flow 6,738 10,234 13,863 17,605 21,476 25,455 29,536 33,722 38,005 42,376

 Net Worth 6,738 10,234 13,863 17,605 21,476 25,455 29,536 33,722 38,005 42,376

Change: Scenario 3 - Scenario 4

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -674 -692 -718 -740 -766 -787 -807 -828 -847 -865

 Net Farm Income 674 692 718 740 766 787 807 828 847 865

 Cash Flow 1,333 2,024 2,742 3,482 4,248 5,035 5,842 6,670 7,517 8,382

 Net Worth 1,333 2,024 2,742 3,482 4,248 5,035 5,842 6,670 7,517 8,382

Change: Scenario 3 - Scenario 5

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -894 -918 -952 -982 -1,016 -1,044 -1,071 -1,099 -1,124 -1,147

 Net Farm Income 894 918 952 982 1,016 1,044 1,071 1,099 1,124 1,147

 Cash Flow 1,768 2,686 3,638 4,620 5,636 6,680 7,751 8,849 9,973 11,120

 Net Worth 1,768 2,686 3,638 4,620 5,636 6,680 7,751 8,849 9,973 11,120
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Table 50. Story County, Iowa Case Study Results, 215 Acre Soybean Farm

Table 51. Renville County, Minnesota Case Study Results, 260 Acre Soybean Farm

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 149,085 144,361 142,776 138,548 133,464 134,437 132,362 135,209 133,877 134,710

 Total Farm Expenses 61,291 61,008 61,116 60,982 60,912 60,536 59,995 60,966 61,812 62,574

 Net Farm Income 87,793 83,353 81,661 77,565 72,551 73,901 72,366 74,243 72,065 72,137

 Cash Flow 176,393 245,046 309,757 367,777 417,743 465,447 532,880 601,957 668,611 735,081

 Net Worth 1,010,653 1,150,105 1,257,003 1,346,481 1,424,087 1,497,538 1,570,431 1,648,563 1,728,129 1,810,816

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 149,085 144,361 142,776 138,548 133,464 134,437 132,362 135,209 133,877 134,710

 Total Farm Expenses 65,623 65,454 65,729 65,742 65,834 65,596 65,184 66,289 67,257 68,133

 Net Farm Income 83,462 78,907 77,047 72,806 67,629 68,841 67,177 68,920 66,620 66,578

 Cash Flow 167,826 232,032 292,130 345,390 390,435 433,078 495,323 559,077 620,286 681,196

 Net Worth 1,002,086 1,137,091 1,239,376 1,324,094 1,396,778 1,465,170 1,532,874 1,605,683 1,679,804 1,756,932

Scenario 3: Weed Resistance - DHT Techology Available

 Total Farm Receipts Including Government Payments 149,085 144,361 142,776 138,548 133,464 134,437 132,362 135,209 133,877 134,710

 Total Farm Expenses 64,854 64,665 64,910 64,897 64,961 64,698 64,263 65,344 66,291 67,146

 Net Farm Income 84,231 79,696 77,866 73,651 68,503 69,740 68,098 69,865 67,587 67,564

 Cash Flow 169,346 234,342 295,259 349,364 395,282 438,824 501,989 566,688 628,864 690,761

 Net Worth 1,003,606 1,139,401 1,242,504 1,328,068 1,401,626 1,470,915 1,539,540 1,613,295 1,688,382 1,766,496

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 4,331 4,446 4,613 4,759 4,922 5,059 5,189 5,323 5,445 5,559

 Net Farm Income -4,331 -4,446 -4,613 -4,759 -4,922 -5,059 -5,189 -5,323 -5,445 -5,559

 Cash Flow -8,568 -13,014 -17,627 -22,387 -27,309 -32,368 -37,557 -42,880 -48,325 -53,884

 Net Worth -8,568 -13,014 -17,627 -22,387 -27,309 -32,368 -37,557 -42,880 -48,325 -53,884

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -769 -789 -819 -845 -874 -898 -921 -945 -967 -987

 Net Farm Income 769 789 819 845 874 898 921 945 967 987

 Cash Flow 1,521 2,310 3,129 3,974 4,847 5,746 6,667 7,611 8,578 9,565

 Net Worth 1,521 2,310 3,129 3,974 4,847 5,746 6,667 7,611 8,578 9,565

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 155,032 149,859 148,011 143,383 137,866 138,734 136,397 139,237 137,689 138,415

 Total Farm Expenses 77,774 77,775 78,343 78,605 78,980 78,960 78,740 80,192 81,477 82,649

 Net Farm Income 77,258 72,084 69,669 64,779 58,886 59,774 57,657 59,045 56,212 55,766

 Cash Flow 156,048 212,617 264,335 308,347 343,168 374,950 427,949 482,115 533,218 583,633

 Net Worth 934,315 1,058,644 1,151,817 1,227,690 1,291,283 1,350,638 1,408,785 1,471,452 1,534,650 1,600,241

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 155,032 149,859 148,011 143,383 137,866 138,734 136,397 139,237 137,689 138,415

 Total Farm Expenses 82,963 83,102 83,870 84,307 84,877 85,022 84,958 86,570 88,001 89,309

 Net Farm Income 72,068 66,757 64,141 59,076 52,988 53,712 51,440 52,667 49,688 49,105

 Cash Flow 145,782 197,024 243,214 281,524 310,447 336,167 382,949 430,737 475,315 519,069

 Net Worth 924,049 1,043,051 1,130,696 1,200,866 1,258,562 1,311,855 1,363,785 1,420,074 1,476,747 1,535,678

Scenario 3: Weed Resistance - DHT Techology Available

 Total Farm Receipts Including Government Payments 155,032 149,859 148,011 143,383 137,866 138,734 136,397 139,237 137,689 138,415

 Total Farm Expenses 82,027 82,141 82,873 83,278 83,813 83,929 83,836 85,420 86,824 88,108

 Net Farm Income 73,004 67,718 65,138 60,105 54,052 54,805 52,561 53,817 50,865 50,307

 Cash Flow 147,634 199,837 247,024 286,363 316,350 343,163 391,066 440,005 485,760 530,716

 Net Worth 925,901 1,045,864 1,134,506 1,205,705 1,264,465 1,318,851 1,371,903 1,429,342 1,487,192 1,547,324

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 5,190 5,327 5,528 5,702 5,898 6,062 6,217 6,378 6,524 6,661

 Net Farm Income -5,190 -5,327 -5,528 -5,702 -5,898 -6,062 -6,217 -6,378 -6,524 -6,661

 Cash Flow -10,266 -15,593 -21,121 -26,823 -32,721 -38,783 -45,000 -51,379 -57,903 -64,564

 Net Worth -10,266 -15,593 -21,121 -26,823 -32,721 -38,783 -45,000 -51,379 -57,903 -64,564

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -936 -961 -997 -1,029 -1,064 -1,094 -1,121 -1,151 -1,177 -1,202

 Net Farm Income 936 961 997 1,029 1,064 1,094 1,121 1,151 1,177 1,202

 Cash Flow 1,852 2,813 3,810 4,839 5,903 6,996 8,118 9,268 10,445 11,647

 Net Worth 1,852 2,813 3,810 4,839 5,903 6,996 8,118 9,268 10,445 11,647
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Table 52. Fayette County, Illinois Case Study Results, 245 Acre Corn Farm

Table 53. Story County, Iowa Case Study Results, 320 Acre Corn Farm

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 190,855 182,650 183,859 174,393 176,503 176,130 177,326 178,673 179,685 178,803

 Total Farm Expenses 102,623 103,664 105,856 107,022 109,249 110,587 112,154 115,764 119,325 122,681

 Net Farm Income 88,232 78,986 78,003 67,371 67,253 65,543 65,172 62,908 60,361 56,122

 Cash Flow 181,912 245,283 305,033 351,092 393,440 429,788 491,907 551,618 608,630 661,245

 Net Worth 1,007,863 1,139,739 1,241,536 1,320,139 1,392,158 1,457,277 1,522,945 1,589,520 1,656,953 1,723,021

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 190,855 182,650 183,859 174,393 176,503 176,130 177,326 178,673 179,685 178,803

 Total Farm Expenses 107,748 108,955 111,395 112,744 115,232 116,777 118,574 122,430 126,234 129,820

 Net Farm Income 83,106 73,694 72,464 61,649 61,271 59,353 58,752 56,242 53,451 48,983

 Cash Flow 172,002 230,082 284,293 324,630 360,996 391,153 446,852 499,897 550,000 595,476

 Net Worth 997,954 1,124,538 1,220,797 1,293,677 1,359,713 1,418,642 1,477,890 1,537,799 1,598,322 1,657,252

Scenario 3: Weed Resistance - DHT Techology Available*

 Total Farm Receipts Including Government Payments 190,855 182,650 183,859 174,393 176,503 176,130 177,326 178,673 179,685 178,803

 Total Farm Expenses 106,932 108,112 110,513 111,832 114,279 115,791 117,552 121,368 125,133 128,683

 Net Farm Income 83,923 74,537 73,347 62,560 62,224 60,339 59,775 57,304 54,552 50,120

 Cash Flow 173,581 232,503 287,597 328,846 366,165 397,308 454,030 508,137 559,341 605,954

 Net Worth 999,533 1,126,960 1,224,101 1,297,893 1,364,882 1,424,797 1,485,068 1,546,039 1,607,663 1,667,730

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 5,126 5,292 5,539 5,722 5,983 6,190 6,420 6,666 6,909 7,139

 Net Farm Income -5,126 -5,292 -5,539 -5,722 -5,983 -6,190 -6,420 -6,666 -6,909 -7,139

 Cash Flow -9,910 -15,201 -20,740 -26,462 -32,445 -38,635 -45,055 -51,721 -58,630 -65,770

 Net Worth -9,910 -15,201 -20,740 -26,462 -32,445 -38,635 -45,055 -51,721 -58,630 -65,770

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -817 -843 -882 -912 -953 -986 -1,023 -1,062 -1,101 -1,137

 Net Farm Income 817 843 882 912 953 986 1,023 1,062 1,101 1,137

 Cash Flow 1,579 2,422 3,304 4,216 5,169 6,155 7,178 8,240 9,341 10,478

 Net Worth 1,579 2,422 3,304 4,216 5,169 6,155 7,178 8,240 9,341 10,478

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 293,508 281,966 284,556 270,986 274,886 275,013 277,509 280,227 282,430 281,722

 Total Farm Expenses 148,778 150,378 153,654 155,444 158,783 160,837 163,233 168,325 173,339 178,050

 Net Farm Income 144,730 131,588 130,901 115,542 116,104 114,176 114,276 111,902 109,090 103,672

 Cash Flow 296,435 404,965 509,238 594,025 674,540 747,380 854,313 958,526 1,059,563 1,154,800

 Net Worth 1,539,917 1,755,000 1,923,464 2,056,737 2,180,364 2,293,870 2,408,929 2,526,620 2,646,874 2,766,248

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 293,508 281,966 284,556 270,986 274,886 275,013 277,509 280,227 282,430 281,722

 Total Farm Expenses 154,449 156,233 159,782 161,775 165,401 167,686 170,336 175,700 180,983 185,948

 Net Farm Income 139,059 125,733 124,774 109,211 109,485 107,327 107,173 104,527 101,446 95,773

 Cash Flow 285,472 388,148 486,293 564,748 638,645 704,636 804,466 901,304 994,697 1,082,036

 Net Worth 1,528,954 1,738,182 1,900,519 2,027,460 2,144,468 2,251,126 2,359,082 2,469,398 2,582,008 2,693,484

Scenario 3: Weed Resistance - DHT Techology Available*

 Total Farm Receipts Including Government Payments 293,508 281,966 284,556 270,986 274,886 275,013 277,509 280,227 282,430 281,722

 Total Farm Expenses 153,377 155,126 158,624 160,578 164,150 166,391 168,993 174,306 179,538 184,455

 Net Farm Income 140,131 126,840 125,932 110,408 110,736 108,622 108,515 105,921 102,891 97,267

 Cash Flow 287,544 391,327 490,630 570,282 645,430 712,716 813,889 912,121 1,006,959 1,095,791

 Net Worth 1,531,026 1,741,361 1,904,856 2,032,994 2,151,254 2,259,206 2,368,505 2,480,215 2,594,270 2,707,239

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 5,671 5,854 6,128 6,331 6,619 6,849 7,103 7,375 7,644 7,899

 Net Farm Income -5,671 -5,854 -6,128 -6,331 -6,619 -6,849 -7,103 -7,375 -7,644 -7,899

 Cash Flow -10,963 -16,818 -22,946 -29,276 -35,895 -42,744 -49,847 -57,222 -64,866 -72,764

 Net Worth -10,963 -16,818 -22,946 -29,276 -35,895 -42,744 -49,847 -57,222 -64,866 -72,764

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -1,072 -1,107 -1,158 -1,197 -1,251 -1,295 -1,343 -1,394 -1,445 -1,493

 Net Farm Income 1,072 1,107 1,158 1,197 1,251 1,295 1,343 1,394 1,445 1,493

 Cash Flow 2,072 3,179 4,338 5,534 6,786 8,080 9,423 10,817 12,262 13,755

 Net Worth 2,072 3,179 4,338 5,534 6,786 8,080 9,423 10,817 12,262 13,755
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 113 of 202

Table 54. Renville County, Minnesota Case Study Results, 390 Acre Corn Farm

Table 55. Darke County, Ohio Case Study Results, 135 Acre Corn Farm

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 329,290 315,773 318,598 302,736 307,077 307,054 309,770 312,744 315,122 314,134

 Total Farm Expenses 192,816 195,241 199,922 202,653 207,469 210,599 214,207 221,151 227,997 234,444

 Net Farm Income 136,474 120,532 118,676 100,084 99,608 96,455 95,564 91,594 87,125 79,690

 Cash Flow 283,060 377,016 464,830 529,091 587,059 634,943 723,520 807,796 887,256 958,919

 Net Worth 1,455,494 1,654,394 1,808,326 1,925,051 2,031,720 2,127,546 2,223,845 2,320,872 2,418,475 2,512,903

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 329,290 315,773 318,598 302,736 307,077 307,054 309,770 312,744 315,122 314,134

 Total Farm Expenses 199,308 201,943 206,937 209,901 215,047 218,439 222,338 229,594 236,748 243,487

 Net Farm Income 129,982 113,830 111,661 92,836 92,030 88,614 87,432 83,150 78,373 70,647

 Cash Flow 270,509 357,762 438,561 495,574 545,965 586,009 666,453 742,286 812,995 875,616

 Net Worth 1,442,942 1,635,140 1,782,057 1,891,534 1,990,626 2,078,611 2,166,779 2,255,362 2,344,214 2,429,599

Scenario 3: Weed Resistance - DHT Techology Available*

 Total Farm Receipts Including Government Payments 329,290 315,773 318,598 302,736 307,077 307,054 309,770 312,744 315,122 314,134

 Total Farm Expenses 198,155 200,753 205,691 208,613 213,701 217,047 220,894 228,094 235,194 241,881

 Net Farm Income 131,135 115,020 112,907 94,123 93,376 90,007 88,876 84,650 79,928 72,253

 Cash Flow 272,738 361,182 443,227 501,527 553,264 594,700 676,589 753,922 826,186 890,412

 Net Worth 1,445,172 1,638,560 1,786,723 1,897,487 1,997,925 2,087,303 2,176,915 2,266,998 2,357,405 2,444,395

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 6,492 6,702 7,015 7,248 7,577 7,840 8,132 8,443 8,751 9,043

 Net Farm Income -6,492 -6,702 -7,015 -7,248 -7,577 -7,840 -8,132 -8,443 -8,751 -9,043

 Cash Flow -12,551 -19,254 -26,269 -33,517 -41,094 -48,935 -57,066 -65,510 -74,261 -83,303

 Net Worth -12,551 -19,254 -26,269 -33,517 -41,094 -48,935 -57,066 -65,510 -74,261 -83,303

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -1,153 -1,190 -1,246 -1,287 -1,346 -1,393 -1,444 -1,500 -1,554 -1,606

 Net Farm Income 1,153 1,190 1,246 1,287 1,346 1,393 1,444 1,500 1,554 1,606

 Cash Flow 2,229 3,420 4,666 5,953 7,299 8,692 10,136 11,636 13,190 14,796

 Net Worth 2,229 3,420 4,666 5,953 7,299 8,692 10,136 11,636 13,190 14,796

2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Scenario 1: No Weed Resistance

 Total Farm Receipts Including Government Payments 126,483 120,878 121,360 115,014 116,101 115,609 116,123 116,736 117,141 116,358

 Total Farm Expenses 59,873 60,525 61,857 62,585 63,942 64,778 65,752 67,860 69,938 71,895

 Net Farm Income 66,610 60,353 59,503 52,428 52,159 50,831 50,371 48,876 47,204 44,463

 Cash Flow 138,654 190,072 239,171 279,493 317,548 351,893 400,165 446,842 491,743 533,795

 Net Worth 727,727 825,896 902,412 962,871 1,018,437 1,068,964 1,119,690 1,171,188 1,223,448 1,275,023

Scenario 2: Weed Resistance - No DHT

 Total Farm Receipts Including Government Payments 126,483 120,878 121,360 115,014 116,101 115,609 116,123 116,736 117,141 116,358

 Total Farm Expenses 62,546 63,284 64,745 65,569 67,062 68,006 69,100 71,336 73,540 75,617

 Net Farm Income 63,937 57,594 56,615 49,445 49,039 47,603 47,023 45,400 43,601 40,741

 Cash Flow 133,487 182,145 228,356 265,695 300,630 331,748 376,671 419,873 461,171 499,500

 Net Worth 722,560 817,969 891,597 949,072 1,001,519 1,048,819 1,096,197 1,144,219 1,192,876 1,240,728

Scenario 3: Weed Resistance - DHT Techology Available*

 Total Farm Receipts Including Government Payments 126,483 120,878 121,360 115,014 116,101 115,609 116,123 116,736 117,141 116,358

 Total Farm Expenses 62,094 62,818 64,256 65,065 66,534 67,460 68,534 70,748 72,931 74,988

 Net Farm Income 64,389 58,060 57,104 49,949 49,567 48,149 47,589 45,988 44,210 41,370

 Cash Flow 134,361 183,486 230,185 268,028 303,491 335,154 380,644 424,433 466,341 505,300

 Net Worth 723,434 819,310 893,426 951,406 1,004,380 1,052,226 1,100,170 1,148,779 1,198,046 1,246,528

Change: Scenario 2 - Scenario 1

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses 2,673 2,759 2,888 2,984 3,120 3,228 3,348 3,476 3,603 3,723

 Net Farm Income -2,673 -2,759 -2,888 -2,984 -3,120 -3,228 -3,348 -3,476 -3,603 -3,723

 Cash Flow -5,167 -7,926 -10,815 -13,798 -16,918 -20,146 -23,493 -26,969 -30,572 -34,295

 Net Worth -5,167 -7,926 -10,815 -13,798 -16,918 -20,146 -23,493 -26,969 -30,572 -34,295

Change: Scenario 3 - Scenario 2

 Total Farm Receipts Including Government Payments 0 0 0 0 0 0 0 0 0 0

 Total Farm Expenses -452 -467 -488 -505 -528 -546 -566 -588 -609 -630

 Net Farm Income 452 467 488 505 528 546 566 588 609 630

 Cash Flow 874 1,340 1,829 2,333 2,861 3,407 3,973 4,561 5,170 5,800

 Net Worth 874 1,340 1,829 2,333 2,861 3,407 3,973 4,561 5,170 5,800
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 114 of 202

Table 56. U.S. Corn Supply and Demand Impacts

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Variable Cost of Production (Dollars Per Acre)

 Scenario 1: Without Weed Resistance 323.12 331.33 344.40 355.33 370.56 383.42 397.66 412.89 427.95 442.21

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 7.08 8.88 10.76 12.69 14.83 16.27 17.84 18.60 18.97 19.31

 Scenario 3: With Weed Resistance and DHT 5.82 7.30 8.84 10.43 12.20 13.37 14.67 15.29 15.59 15.88

Season Average Farm Price (Dollars Per Bushel)

 Scenario 1: Without Weed Resistance 4.48 4.22 4.19 3.91 3.90 3.84 3.81 3.79 3.76 3.69

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.01 0.01 0.01 0.02 0.02 0.02 0.02 0.02 0.02 0.02

 Scenario 3: With Weed Resistance and DHT 0.00 0.01 0.01 0.01 0.02 0.02 0.02 0.02 0.02 0.01

Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 90.54 91.65 89.49 92.34 89.18 89.99 88.64 87.81 86.49 85.91

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.12 -0.22 -0.23 -0.34 -0.36 -0.42 -0.48 -0.50 -0.51 -0.52

 Scenario 3: With Weed Resistance and DHT -0.08 -0.18 -0.18 -0.28 -0.30 -0.37 -0.40 -0.43 -0.43 -0.44

Yield (Bushels Per Acre)

 Scenario 1: Without Weed Resistance 164.5 169.2 172.7 176.7 181.0 184.5 188.0 190.4 192.7 195.1

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

 Scenario 3: With Weed Resistance and DHT 0.0 0.0 0.1 0.1 0.1 0.1 0.1 0.1 0.1 0.1

Production (Million Bushels)

 Scenario 1: Without Weed Resistance 13,722 14,296 14,246 15,058 14,902 15,339 15,396 15,442 15,392 15,480

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -13 -28 -29 -47 -51 -64 -74 -80 -83 -86

 Scenario 3: With Weed Resistance and DHT -7 -24 -23 -40 -44 -57 -64 -69 -71 -74

Domestic Disappearance (Million Bushels)

 Scenario 1: Without Weed Resistance 11,489 12,068 12,094 12,423 12,495 12,784 12,869 12,860 12,820 12,795

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -6 -15 -18 -27 -32 -40 -48 -54 -57 -52

 Scenario 3: With Weed Resistance and DHT -4 -12 -14 -23 -28 -35 -41 -46 -49 -45

Exports (Million Bushels)

 Scenario 1: Without Weed Resistance 1,991 2,052 2,243 2,404 2,461 2,489 2,514 2,567 2,585 2,627

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -5 -9 -12 -15 -18 -21 -24 -25 -25 -21

 Scenario 3: With Weed Resistance and DHT -3 -7 -10 -13 -16 -18 -21 -22 -22 -18
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 115 of 202

Table 57. U.S. Soybean Supply and Demand Impacts

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Variable Cost of Production (Dollars Per Acre)

 Scenario 1: Without Weed Resistance 138.49 141.21 145.51 149.90 154.64 158.95 163.02 167.24 171.07 174.65

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 12.10 13.70 15.23 16.80 18.44 19.80 20.20 20.63 21.05 21.46

 Scenario 3: With Weed Resistance and DHT 10.51 11.78 12.94 14.08 15.23 16.08 16.37 16.68 16.98 17.26

Season Average Farm Price (Dollars Per Bushel)

 Scenario 1: Without Weed Resistance 9.99 9.57 9.37 9.00 8.58 8.57 8.35 8.46 8.30 8.29

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.05 0.05 0.05 0.06 0.07 0.07 0.06 0.06 0.06 0.06

 Scenario 3: With Weed Resistance and DHT 0.04 0.04 0.05 0.05 0.05 0.05 0.05 0.05 0.05 0.04

Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 77.35 76.39 77.94 75.02 75.32 73.16 74.42 74.48 75.35 74.74

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.70 -0.59 -0.70 -0.70 -0.79 -0.79 -0.76 -0.74 -0.74 -0.74

 Scenario 3: With Weed Resistance and DHT -0.61 -0.50 -0.59 -0.57 -0.63 -0.61 -0.59 -0.57 -0.57 -0.57

Yield (Bushels Per Acre)

 Scenario 1: Without Weed Resistance 44.2 45.4 46.6 47.8 48.6 49.4 49.8 50.2 50.6 51.0

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.1

 Scenario 3: With Weed Resistance and DHT 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0 0.0

Production (Million Bushels)

 Scenario 1: Without Weed Resistance 3,377 3,423 3,584 3,540 3,616 3,572 3,662 3,695 3,769 3,770

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -28 -24 -29 -30 -34 -35 -34 -33 -33 -33

 Scenario 3: With Weed Resistance and DHT -24 -20 -25 -24 -27 -27 -26 -25 -25 -25

Domestic Disappearance (Million Bushels)

 Scenario 1: Without Weed Resistance 1,828 1,885 1,929 1,911 1,954 1,988 2,010 2,030 2,059 2,046

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -7 -8 -9 -10 -11 -11 -11 -11 -11 -9

 Scenario 3: With Weed Resistance and DHT -6 -7 -8 -8 -9 -9 -9 -8 -8 -6

Exports (Million Bushels)

 Scenario 1: Without Weed Resistance 1,526 1,589 1,653 1,610 1,633 1,606 1,657 1,687 1,714 1,745

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -18 -16 -20 -20 -23 -23 -22 -22 -22 -18

 Scenario 3: With Weed Resistance and DHT -16 -14 -16 -16 -18 -18 -17 -17 -17 -14
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 116 of 202

Table 58. U.S. Corn Acreage Impacts By Region

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Corn Belt Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 39.39 40.08 39.51 40.57 39.97 40.41 39.97 39.58 38.91 38.69

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.07 0.03 0.03 0.02 0.01 0.00 -0.03 -0.03 -0.04 -0.05

 Scenario 3: With Weed Resistance and DHT 0.07 0.03 0.02 0.01 0.00 -0.02 -0.04 -0.04 -0.05 -0.05

Central Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 15.19 15.36 14.62 15.22 14.42 14.56 14.26 14.13 13.93 13.84

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.05 -0.07 -0.08 -0.10 -0.12 -0.13 -0.15 -0.15 -0.15 -0.15

 Scenario 3: With Weed Resistance and DHT -0.04 -0.06 -0.06 -0.08 -0.10 -0.11 -0.12 -0.12 -0.12 -0.12

Delta States Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 1.73 1.75 1.72 1.76 1.70 1.72 1.69 1.68 1.66 1.66

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Scenario 3: With Weed Resistance and DHT 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Far West Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 1.31 1.34 1.32 1.36 1.29 1.29 1.28 1.26 1.25 1.23

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01

 Scenario 3: With Weed Resistance and DHT -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01

Lake States Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 14.34 14.40 14.08 14.50 14.09 14.17 13.94 13.86 13.71 13.67

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.01 -0.02 0.01 -0.03 0.00 -0.03 -0.03 -0.05 -0.05 -0.05

 Scenario 3: With Weed Resistance and DHT -0.01 -0.02 0.01 -0.03 0.00 -0.03 -0.03 -0.05 -0.05 -0.05

Northeast Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 3.57 3.56 3.44 3.56 3.39 3.42 3.34 3.31 3.25 3.23

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.01 -0.01 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02 -0.02 -0.02

 Scenario 3: With Weed Resistance and DHT 0.00 -0.01 -0.01 -0.01 -0.01 -0.02 -0.02 -0.02 -0.02 -0.02

Northern Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 7.71 7.80 7.58 7.98 7.32 7.40 7.24 7.15 7.04 6.93

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.08 -0.09 -0.11 -0.13 -0.15 -0.17 -0.18 -0.18 -0.18 -0.18

 Scenario 3: With Weed Resistance and DHT -0.06 -0.08 -0.09 -0.11 -0.12 -0.14 -0.15 -0.15 -0.15 -0.15

Southeast Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 4.46 4.47 4.39 4.48 4.29 4.31 4.25 4.21 4.16 4.13

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.01 -0.02 -0.02 -0.03 -0.03 -0.02 -0.02 -0.02 -0.02 -0.02

 Scenario 3: With Weed Resistance and DHT -0.01 -0.01 -0.02 -0.02 -0.02 -0.01 -0.01 -0.01 -0.01 -0.01

Southern Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 2.84 2.90 2.82 2.90 2.72 2.71 2.66 2.62 2.58 2.54

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.03 -0.04 -0.04 -0.05 -0.05 -0.04 -0.04 -0.04 -0.04 -0.04

 Scenario 3: With Weed Resistance and DHT -0.03 -0.03 -0.04 -0.04 -0.04 -0.03 -0.03 -0.03 -0.03 -0.03
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

Dow AgroSciences LLC

Page 117 of 202

Table 59. U.S. Soybean Acreage Impacts By Region

11/12 12/13 13/14 14/15 15/16 16/17 17/18 18/19 19/20 20/21

Corn Belt Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 33.50 32.80 33.30 32.21 32.44 31.83 32.26 32.56 33.17 33.24

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.14 -0.09 -0.11 -0.11 -0.12 -0.12 -0.09 -0.09 -0.09 -0.08

 Scenario 3: With Weed Resistance and DHT -0.13 -0.08 -0.09 -0.08 -0.08 -0.07 -0.06 -0.06 -0.05 -0.05

Central Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 9.27 9.30 9.49 9.11 9.26 8.89 9.14 9.11 9.21 9.07

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.07 -0.05 -0.06 -0.07 -0.08 -0.08 -0.08 -0.08 -0.08 -0.08

 Scenario 3: With Weed Resistance and DHT -0.06 -0.04 -0.05 -0.06 -0.06 -0.06 -0.06 -0.06 -0.06 -0.06

Delta States Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 6.68 6.68 6.81 6.51 6.43 6.17 6.27 6.21 6.24 6.12

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.17 -0.15 -0.16 -0.16 -0.16 -0.16 -0.16 -0.16 -0.16 -0.16

 Scenario 3: With Weed Resistance and DHT -0.14 -0.13 -0.13 -0.13 -0.14 -0.14 -0.14 -0.13 -0.13 -0.13

Far West Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

 Scenario 3: With Weed Resistance and DHT 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00

Lake States Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 10.67 10.56 10.85 10.43 10.53 10.32 10.51 10.50 10.59 10.50

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.05 -0.04 -0.08 -0.05 -0.09 -0.07 -0.08 -0.06 -0.06 -0.06

 Scenario 3: With Weed Resistance and DHT -0.04 -0.03 -0.07 -0.04 -0.07 -0.05 -0.06 -0.04 -0.04 -0.04

Northeast Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 1.40 1.37 1.43 1.34 1.41 1.34 1.39 1.40 1.43 1.41

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01

 Scenario 3: With Weed Resistance and DHT -0.01 0.00 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01 -0.01

Northern Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 8.78 8.70 9.01 8.62 8.50 8.06 8.23 8.12 8.14 7.91

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.13 -0.12 -0.15 -0.17 -0.20 -0.21 -0.21 -0.22 -0.22 -0.22

 Scenario 3: With Weed Resistance and DHT -0.12 -0.11 -0.13 -0.14 -0.16 -0.17 -0.17 -0.17 -0.17 -0.17

Southeast Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 6.46 6.38 6.45 6.24 6.21 6.04 6.10 6.06 6.07 5.98

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.11 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10 -0.10

 Scenario 3: With Weed Resistance and DHT -0.09 -0.08 -0.08 -0.09 -0.09 -0.09 -0.09 -0.09 -0.09 -0.08

Southern Plains Planted Acreage (Million Acres)

 Scenario 1: Without Weed Resistance 0.60 0.59 0.60 0.57 0.55 0.52 0.53 0.51 0.51 0.49

 Change from Scenario 1

 Scenario 2: With Weed Resistance, No DHT -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03

 Scenario 3: With Weed Resistance and DHT -0.03 -0.02 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.03 -0.02
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8. End Notes

 1 Marra, M. C., Piggott, N. E., & Carlson, G. A. (2004). The Net Benefits, Including Convenience, of 

Roundup Ready Soybeans: Results from a National Survey. National Science Foundation. Raleigh: NSF 

center for IPM.

2 Piggott, N. E., & Marra, M. C. (2008). Biotechnology Adoption Over Time in the Presence of NonPecuniary Characteristics that Directly Affect Utility: A Derived Demand Approach. AgBioForum, 11 (1), 

58-70.

3 Marra, M., & Piggottt, N. (2006) The value of non pecuniary characteristics of crop biotechnologies: A 

new look at the evidence. In Just, j. Alston, & D. Zilbermann (Eds.) Regulating agricultural biotechnology: 

Economics and Policy, pp. 145-178. New York: Springer-Verlag.

 

4 Brookes, G., & Barfoot, P. (2009). Global impacts of Biotech Crops: Income and Production Effects, 

1996-2007. AgBioForum, 12 (2), 184-208.

5 University of Illinois Extension, Farm Economics Facts & Opinions, "Costs and Fuel Use for Alternative 

Tillage Systems" FEFO 06-07 April 17, 2006.

http://www.farmdoc.illinois.edu/manage/newsletters/fefo06_07/fefo06_07.html

6 University of Illinois Extension, Farm Business Management, Machinery Cost Estimates: Field 

Operations. April 2010. http://www.farmdoc.illinois.edu/manage/index.asp

7 University of Illinois Extension, Farm Economics Facts & Opinions, "Machinery Cost Estimates: 

Harvesting." April 2010. http://www.farmdoc.illinois.edu/manage/index.asp

8 IHS Global Insight. November 2010. Global Agricultural Forecast. Proprietary Data.

9 United States Department of Agriculture, Natural Resources Conservation Service. Energy Estimator. 

Retrieved December 2010. http://ecat.sc.egov.usda.gov/

10 Soil Erosion Site. Retrieved October 2010 http://soilerosion.net/doc/water_erosion.html

11 USGS, 2010.Eutrophication, Retrieved October 2010. 

http://toxics.usgs.gov/definitions/eutrophication.html

12 Daniel, T. C., A. N. Sharpley, and J. L. Lemunyon. 1995. Agricultural Phosphorus and Eutrophication: 

A Symposium Overview. J. of Environ. Qual., 27: 251-257.

13 Correll. D.L. 1998. The Role of Phosphorus in the Eutrophicaton of Receiving Waters: A Review. J. 

Environ. Qual. 27: 261-266.

14 USEPA, 2010. Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2008. 

http://www.epa.gov/climatechange/emissions/downloads10/US-GHG-Inventory-2010_Report.pdf

15 Sundermeier, Alan, Randall Reeder, and Rattan Lal. Soil Carbon Sequestration-Fundamentals. Ohio 

State University Extension Fact Sheet AEX-510-05. http://ohioline.osu.edu/aex-fact/pdf/0510.pdf

16 West, O. Tristram O. and Wilfred M. Post. 2002. Soil Organic Carbon Sequestration Rates by Tillage 

and Crop Rotation: A Global Data Analysis. Soil Sci. Soc. Am. J. 66:1930–1946.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn 

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17 USEPA, 2010. Carbon Sequestration in Agriculture and Forestry, Retrieved October 2010 

http://www.epa.gov/sequestration/index.html

18 Texas A&M Blackland Research Center. 2006. Researcher's Guide for WinEPIC: Version 3.0. BRC 

Report No. 05-01 (revised), Temple, Texas. 

19 Gassman, P.W., J.R. Williams, V.W. Benson, R.C. Izaurralde, L.M. Hauck, C.A. Flowers. 2005. 

Historical Development and Applications of the EPIC and APEC models. Eorking Paper 05-WP-397, 

Center for Agricultural and Rural Development, Iowa State University, Ames.

20 Food and Agricultural Policy Research Institute (FAPRI). 2007. Estimating Water Quality, Air Quality, 

and Soil Carbon Benefits of the Conservation Program, FAPRI-UMC Report #01-07.University of 

Missouri, Columbia.

21 Nicks, A.D. 1974. "Stochastic Generation of the Occurrence, Pattern, Location of Maximum Amount of 

Daily rainfall." In Proceedings symposium on statistical hydrology: USDA Misc. Pub. N. 1275.

22 Richardson, C.W. 1981. Stochastic Simulation of Daily Precipitation, Temperature, and Solar Radiation. 

Water Resources Res. 17(10: 182-90.

23 USDA, National Resources Conservation Service. 2010. County Soil Data, Retrieved October 2010 

http://soildatamart.nrcs.usda.gov/State.aspx

24 USDA-ERS . 2006. http://www.ers.usda.gov/Data/ARMS/app/default.aspx?survey=CROP

25 Supplemental Toolkit For Investors. Monsanto. February 2010.

26 Chicago Climate Exchange. Agricultural Best Management Practices. Referenced December 2010. 

http://www.chicagoclimatex.com/docs/offsets/CCX_Conservation_Tillage_and_Grassland_Conversion_Pr

otocol_Final.pdf
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Appendix B

Analysis to Determine the Impact of the Use of 2,4-D on Herbicide 

Tolerant DAS-40278-9 Corn and DAS-68416-4 Soybeans on the 

Cost and Environmental Load of Herbicides Applied on 

Glyphosate Tolerant Corn and Soybeans to Control Glyphosate 

Resistant and Hard-to-Control Weeds

:
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Table of Contents

1. Introduction ____________________________________________________123

2. Case Study Process_______________________________________________123

3. Analysis Results _________________________________________________129

4. End Notes ______________________________________________________141
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Tables

Table 1. State, crop and weed species combinations targeted in the herbicide load 

analysis............................................................................................................. 123

Table 2. Year on Year Changes in Average Glyphosate Rates Applied Postemergence on 

Glyphosate Tolerant Corn and Soybeans......................................................... 125

Table 3. Corn and Soybean herbicide categories used to subdivide the third party 

proprietary data data. ....................................................................................... 126

Table 4. Application Sequence Categories Used to Subdivide the Third Party Proprietary 

Data.................................................................................................................. 127

Table 5. Arkansas Soybean Herbicide Programs............................................................ 130

Table 6. Georgia Soybean Herbicide Programs.............................................................. 131

Table 7. Illinois Soybean Herbicide Programs............................................................... 132

Table 8. Iowa Soybean Herbicide Programs................................................................... 133

Table 9. Minnesota Soybean Herbicide Programs.......................................................... 134

Table 10. Illinois Corn Herbicide Programs................................................................... 135

Table 11. Iowa Corn Herbicide Programs ...................................................................... 136

Table 12. Minnesota Corn Herbicide Programs ............................................................. 137

Table 13. Ohio Corn Herbicide Programs ...................................................................... 138

Table 14. Georgia Corn Herbicide Programs ................................................................. 139

Table 15. Summary of the impact of incorporating 2,4-D and other non-glyphosate 

herbicides into GT crop herbicide programs to control GR and GT weeds on per 

acre herbicide load. .......................................................................................... 140
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1. Introduction

An analysis was conducted to determine the impact of the use of 2,4-D on herbicide 

tolerant DAS-40278-9 corn and DAS-68416-4 soybeans on the cost and environmental 

load of herbicides applied on glyphosate tolerant (GT) corn and soybeans to control 

glyphosate resistant (GR) and hard-to-control (HTC) weeds. 2009 third party proprietary 

data (hereafter referred to as data) for corn and soybeans and a survey of university weed 

specialists were used to create assumptions about how growers would change herbicide 

use on GT corn and soybeans to manage GR and HTC weeds. The university weed 

specialist survey is presented in Appendix C.

2. Case Study Process

Analyses were completed for corn in five states and for soybeans in five states, targeting 

growers’ approaches to control a GR resistant weed species that is present in each state 

(Table 1). The weed species chosen for each case study is common and widely 

distributed throughout each respective case study state, although GR biotypes may not 

yet be widespread.

Table 1. State, crop and weed species combinations targeted in the herbicide load 

analysis.

State Crop Target Weed Species

Arkansas Soybeans Palmer amaranth

Georgia Corn Palmer amaranth

Soybeans Palmer amaranth

Illinois Corn Waterhemp

Soybeans Marestail

Iowa Corn Waterhemp

Soybeans Giant ragweed

Minnesota Corn Giant ragweed

Soybean Waterhemp

Ohio Corn Giant ragweed

The following approach was used to objectively identify potential herbicide programs for 

use in GT corn and soybeans to control GR weeds both with and without Dow 

AgroSciences herbicide tolerant (DHT) trait technology found in DAS-40278-9 corn and 

DAS-68416-4 soybeans that is part of the EnlistTM Weed Control System1 .

 1 Enlist is a trademark of Dow AgroSciences LLC. Components of the Enlist Weed Control System have 

not yet received regulatory approvals; approvals are pending. The information provided here is not an offer 

for sale. ©2011 Dow AgroSciences LLC
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2009 market research data was used to identify the most commonly used herbicide 

programs on GT and conventional corn and soybeans in each case study state. The third 

party proprietary data source is one of the most trusted sources of market information for 

many of the world’s leading manufacturers and suppliers of agricultural products and 

services. This source has created and maintains a large respondent database consisting of 

products and quantities used, field acres treated with products, and dollar expenditures. 

Market research surveys are sent out to a randomly selected population of participants 

(growers and distribution/retailers). Based on the responses, survey data compiled are 

extrapolated to estimate the market size and value for crop protection solutions in major 

crops. Dow AgroSciences has purchased licenses to access the proprietary databases for 

marketing and business analysis purposes.

Step 1: Identify the most commonly used GT and conventional herbicide programs 

in corn and soybeans. 

The 2009 market data for corn herbicides shows that glyphosate is predominantly used in 

combination with non-glyphosate herbicides on corn (53% of corn acres) and is only used 

alone on approximately 20% of corn acres. This contrasts with glyphosate use on 

soybeans where glyphosate is used alone on approximately 56% of the acres and in 

combination with non-glyphosate herbicides on approximately 39% of the acres. 

Conventional herbicides were used on approximately 23% and 5% of corn and soybean 

acres, respectively, while glufosinate was used on approximately 4% and 0.2% of corn 

and soybean acres, respectively, in 2009. 

The market data shows that the average use rate for glyphosate applied on GT corn and 

soybeans has increased an average of 0.014 lb ae/ac/yr from 1998 to 2010 (Table 2). The 

steady increase in average glyphosate application rates coincides with the widespread 

adoption of GT crop systems and evolution of GR and HTC weeds. Based on this 

assessment, it was assumed that average glyphosate use rates would increase 0.01 lb 

ae/ac/yr from 2011 forward.
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Table 2. Year on Year Changes in Average Glyphosate Rates Applied 

Postemergence on Glyphosate Tolerant Corn and Soybeans.

Year

Year on Year Glyphosate 

Rate Increase (Decrease) 

(Lb ae/Ac)

1999 0.018

2000 0.006

2001 (0.003)

2002 0.013

2003 0.020

2004 0.019

2005 0.016

2006 0.010

2007 0.019

2008 0.017

2009 0.003

2010 0.031

Avg 0.014

Source: Third party proprietary data .

The 2009 data for corn and soybeans was grouped into similar herbicide (Table 3) and 

application sequence categories (Table 4). Grouping the individual herbicide programs 

into these categories enabled the identification of the most commonly used herbicide 

programs on GT and conventional crops in each state. 
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Table 3. Corn and Soybean herbicide categories used to subdivide the third party 

proprietary data data.

Herbicide Categories

Corn Soybeans

ACETAMIDE PRE-MIX ACETAMID

Lumax (S-metolachlor + atrazine + mesotrione) Lasso (alachlor)

Lexar (S-metolachlor + atrazine + mesotrione) Axiom, Define (flufenacet)

Harness Xtra, Keystone (acetochlor + atrazine) Cinch, Dual Magnum, Medal, Parallel (Smetolachlor)

Bicep II Magnum (S-metolachlor + atrazine) Prefix (S-metolachlor + fomesafen)

Guardsman (dimethenamid + atrazine) Boundary (S-metolachlor + metribuzin)

SureStart (acetochlor + flumetsulam + 

clopyralid)

BROADLEAF

Balance (isoxaflutole) Blazer (acifluorfen)

Impact (topramezone) Galaxy, Storm (acifluorfen + bentazone)

Marksman (dicamba + atrazine) Basagran (bentazone)

Corvus (isoxaflutole + thiencarbazone-methyl) Aim (carfentrazone)

Callisto (mesotrione) Classic (chlorimuron)

Hornet (flumetsulam + clopyralid) Canopy (chlorimuron + metribuzin)

Synchrony (chlorimuron + thifensulfuron)

Enlite, Envive (chlorimuron + thifensulfuron + 

flumioxazim)

FirstRate (chloransulam)

Resource (flumiclorac)

Encompass, Valor (flumioxazin)

Ganster Co-Pak (flumioxazin + cloransulam)

Cadet (fluthiacet)

Flexstar, Reflex (fomesafen)

Raptor (imazamox)

Scepter (imazaquin)

Pursuit (imazethapyr)

Cobra (lactofen)

Authority, Blanket (sulfentrazone)

Authority First, Sonic (sulfentrazone + 

cloransulam)

Harmony (thifensulfuron + tribenuron)

DNA

Prowl (pendimethalin) Pendant, Prowl (pendimethalin)

Pursuit Plus (pendimethalin + imazethapyr)

Treflan, Trifluralin, Triflurex (trifluralin)

GLYPHOSATE
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Herbicide Categories

Corn Soybeans

Buccaneer, Cornerstone, Clearout, Credit, 

Durango, Gly Star, Honcho, Mad Dog, Roundup

Weathermax, Touchdown, several (glyphosate)

Buccaneer, Cornerstone, Clearout, Credit, 

Durango, Gly Star, Honcho, Mad Dog, Roundup

Weathermax, Touchdown, several (glyphosate)

SYNTHETIC AUXIN

2,4-D, several (2,4-D) 2,4-D, several (2,4-D)

Clarity, Distinct, Oracle, Status (dicamba)

POST GRASS

Steadfast (nicosulfuron + rimsulfuron) Select (clethodim)

Option Corn (foramsulfuron) Fusilade (fluazifop)

Celebrity (nicosulfuron + dicamba + 

diflufenzopyr) Assure (quizalofop)

Lightning (imazethapyr) Poast (sethoxydim)

TRIAZINE

Aatrex, Atrazine (atrazine) Sencor, Metribuzin, several (metribuzin)

Princep, Simazine (simazine)

Table 4. Application Sequence Categories Used to Subdivide the Third Party 

Proprietary Data.

Herbicide Sequence Category Definition

BURN Herbicides applied to burndown vegetation before, 

during or after planting but before crop emergence

PRE Herbicides applied premergence (before crop 

emergence)

POST Herbicides applied postemergence (after crop 

emergence)

(_____ + _____) Tank-mixed products

_____ f/b _____ Sequential application

University Extension weed control recommendations were consulted to identify 

recommended solutions for control of GR weeds. Specific recommendations were found 

for the control of GR Palmer amaranth in soybeans and corn from the University of 

Georgia and the University of Arkansas.

Step 2: Identify University Extension weed control recommendations for control of 

each GR weed species.

1,2

 The majority of the GR Palmer amaranth 

present in Georgia and Arkansas is also resistant to ALS-inhibitor herbicides and this was 

reflected in the university recommendations. Only general recommendations were found 

for the control of the other GR weed species. An objective, non-biased approach was 

developed to estimate the most likely herbicide programs growers would use in GT crops 

to control GR weed species other than Palmer amaranth (see Steps 3 and 4). 
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The five most widely used GT herbicide programs (greatest number of base treated acres) 

were identified and selected to represent the “current state” weed control programs for 

GT corn and soybeans. In each case study, the top five GT programs identified using this 

approach accounted for 60% or more of the total base treated acres of GT corn and 

soybeans.

Step 3: Identify likely herbicide programs for control of GR weeds in GT/DHT corn 

and soybeans

It was assumed that DHT trait technology would be stacked with GT technology in both 

corn and soybeans, allowing the use of 2,4-D + glyphosate tank mixtures to control GR 

weed biotypes. DHT programs were created by adding 0.71 lb ae/ac of 2,4-D to the top 

GT programs identified in each state. Each program was evaluated and adjusted to 

eliminate redundant herbicides. For example, it was assumed that 2,4-D would replace 

any “Broadleaf” category herbicides that were applied tank mixed with glyphosate in a 

given program. Finally, it was assumed that glyphosate rates would return to 0.75 lb 

ae/ac of glyphosate in DHT programs because of the high level of control demonstrated 

in field trials with the 0.75 lb ae/ac glyphosate + 0.71 lb ae/ac 2,4-D tank mixture.

The market data was determined to be the best non-biased source for identification of 

non-glyphosate herbicides and rates for use in combination with glyphosate on GT crops. 

The 2009 market data show that the average rate of non-glyphosate herbicides applied on 

GT corn in combination with glyphosate was 1.41 lb ai/ac while the average rate of nonglyphosate herbicides applied on conventional corn was 2.34 lb ai/ac. The difference in 

these two amounts (0.93 lb ai/ac of non-glyphosate herbicides) is the reduction in 

environmental load of non-glyphosate herbicides achieved from the use of 

glyphosate. 

Step 4: Identify likely herbicide programs for control of GR weeds in GT corn and 

soybeans without DHT technology

Growers, however, will no longer be able to use reduced rates of nonglyphosate herbicides in combination with glyphosate if their objective is to control 

GR resistant weeds. As a result, it was assumed that growers must return to using 

full rates of non-glyphosate herbicides in combination with glyphosate in order to 

continue to realize the benefits of the GT cropping system and effectively control 

GR weeds. Non-DHT alternative programs were created by adding full use rates of 

glyphosate to full use rates of the top conventional herbicide programs in corn and 

soybeans. This approach would insure that the herbicide and rate choices were nonbiased and would mirror the non-glyphosate herbicides and use rates growers are using 

today and most likely would use in the future.

The five most widely used herbicide programs in “conventional” corn and soybeans were 

identified as outlined in Step 3. The top five conventional programs identified using this 

approach accounted for 60% or more of the total base treated acres of conventional corn 

in each state. However, the five most widely used programs in conventional soybeans 

were identified on a national basis because there were too few conventional soybean 

acres for accurate identification at the state level. The top five conventional programs in 

soybeans identified using this approach accounted for approximately 50% of the total 

base treated acres of conventional soybeans nationally.
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The average use rate for postemergence applied glyphosate on GT corn and soybeans in 

2010 was 0.88 lb ae/ac. Dow AgroSciences is striving for a 2012 and 2014 launch for 

corn and soybeans, respectively. By the time DHT is launched, it was assumed that the 

average application rate of glyphosate would increase 0.01 lb ae/ac/yr to 0.9 lb ae/ac GT 

corn and to 0.94 lb ae/ac on GT soybeans. Similar to the GT/DHT programs, all 

redundant herbicides were eliminated from the herbicide program. For example, it was 

assumed that glyphosate would replace any “POST GRASS” herbicides that were applied 

in a given program. All ALS-inhibitor herbicides were eliminated from the “Broadleaf” 

herbicide category in the soybean analysis because of widespread ALS resistance and the 

increasing occurrence of biotypes that are resistant to both glyphosate and ALS 

herbicides. The most commonly used glufosinate program was also included as one of 

the top five programs in each case study despite low current use. The glufosinate 

treatment was assumed to be 2% of base treated acres in each case study to insure its 

inclusion as an alternative.

The 2009 market data was used to provide the herbicide cost and application rate 

information used in the analysis. In this step, the “current” state GT and conventional 

programs were compared to the “future state” GT/DHT and GT/non-glyphosate herbicide

programs to determine the impact of the different programs on cost, complexity and 

environmental load of herbicide active ingredients.

Step 5: Analysis

3. Analysis Results

Analysis results for the ten case studies are presented in Table 5 through Table 14 and 

summarized in Table 15.
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Table 5. Arkansas Soybean Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.55 $ 14.70 30%

Glyphosate POST 0.94 $ 9.14 21%

(Glyphosate + Growth Regulator) f/b Glyphosate BURN f/b POST 1.99 $ 11.47 10%

Glyphosate f/b Glyphosate f/b (Broadleaf + 

Glyphosate)

BURN f/b POST f/b 

POST 2.59 $ 30.67 7%

Broadleaf f/b Glyphosate PRE f/b POST 0.87 $ 15.48 6%

Average 1.59 $ 16.29

Broadleaf or Acetamide f/b (Glyphosate + 2,4-D) PRE f/d POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply 0.75 Lb ae/A 

glyphosate ($7.62/A) + 0.71 Lb ae/A of 

2,4-D ($2.59/A) postemerence as 

needed. Calculations are based on 

one postemergence application. 

1.87 $ 19.60

Average 1.87 $ 19.60

Broadleaf f/b (Broadleaf + Glyphosate) PRE f/b POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply glyphosate as 

needed to control grasses and other 

broadleaf weeds. Apply Flexstar or 

Ultra Blazer postemergence as 

needed at full label rates to 3-inch tall 

or less Palmer amaranth (may be tank 

mixed with glyphosate). Calculations 

are based on one postemergence 

application. 

1.58 $ 28.10

Broadleaf f/b (Liberty + Acetamide) f/b Liberty

PRE f/b EPOST f/b 

POST

Apply Valor or Prefix or Authority MTZ 

premergence. Apply Liberty + Dual 

Magnum over-the-top when Palmer 

amaranth are less than 3-inches tall. 

Apply Liberty postemergence as 

needed when Palmer amaranth are 

less than 3-inches tall and before row 

closure. Calculations are based on 

one postemergence application,

2.36 $ 60.58

Average 1.97 $ 44.34

0.28 $ 3.31

0.38 $ 28.05

-0.10 $ (24.74)

*** Bond, J., T. Eubank, K. Smith, and B. Scott. 2010. Glyphosate-resistant Palmer Amaranth and Ryegrass Management. Mississippi Agricultural and 

Forestry Experiment Station. University of Arkansas Division of Agriculture. Infomration Sheet 1351. March 2010. 

http://msucares.com/pubs/infosheets_research/i1351.pdf

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Soybeans With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for C minus A

Projected Rate and Cost Increase (Decrease) for B Minus C
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 131 of 202

Table 6. Georgia Soybean Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.75 $ 7.21 75%

(Broadleaf + Glyphosate) PRE f/b POST 0.91 $ 16.99 18%

(Glyphosate + DNA) f/b (Broadleaf + Glyphosate) BURN PRE f/b POST 2.70 $ 32.56 8%

Average 1.45 $ 18.92

Broadleaf or Acetamide f/b (Glyphosate + 2,4-D) PRE f/d POST

Apply Sencor or Canopy or Boundry or 

Authority MTZ or Dual Magnum or 

Intrro premergence. Apply 0.75 Lb 

ae/A glyphosate ($7.62) + 0.71 Lb 

ae/A of 2,4-D ($2.59/A) postemerence 

as needed. Calculations are based on 

one postemergence application. 

2.17 $ 19.84

Average 2.17 $ 19.84

Broadleaf or Acetamide f/b (Broadleaf + 

Glyphosate) PRE f/b POST

GT Soybeans : Apply Sencor or 

Canopy or Boundry or Authority MTZ 

or Dual Magnum or Intrro 

premergence. Apply glyphosate + 

Reflex or glyphosate + Ultra Blazer or 

glyphosate + Cobra or glyphosate + 

Prefix or postemergence as needed. 

Calculations are based on one 

postemergence application. 2.04 $ 28.37

Broadleaf or Acetamide f/b Liberty PRE f/b POST

Liberty Link Soybeans: Apply Dual 

Magnum or Intrro or Valor or Envive or 

Prefix or Valor XLT premergence. 

Apply Liberty postemergence as 

needed. Calculations are based on 

one postemergence application. 1.01 $ 28.90

Average 1.53 $ 28.64

0.72 $ 0.92

0.07 $ 9.72

0.65 $ (8.80)

Projected Rate and Cost Increase (Decrease) for C minus A

 A. Top Herbicide Programs in GT Soybeans

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Soybeans With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

*** Prostko, E. P. 2010. Managing Herbicide Resistant Palmer Amananty (Pigweed) in Field Corn, Peanut, and Soybean - 2010. University of Georgia. 

http://mulch.cropsoil.uga.edu/weedsci/resistance-10-tables.pdf 

Projected Rate and Cost Increase (Decrease) for B Minus C

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 132 of 202

Table 7. Illinois Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.91 $ 10.18 30%

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.75 $ 17.69 23%

(Glyphosate + Growth Regulator) f/b Glyphosate BURN f/b POST 2.17 $ 19.38 7%

(Broadleaf + Glyphosate + Growth Regulators) f/b 

Glyphosate+A22+A36 BURN f/b POST 2.35 $ 29.11 6%

Broadleaf f/b Glyphosate PRE f/b POST 1.02 $ 19.67 4%

Average 1.64 $ 19.21

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.49 $ 11.22

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.33 $ 18.73

(Glyphosate + Growth Regulator) f/b (Glyphosate + 

2,4-D) BURN f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 2.75 $ 20.42

(Glyphosate + Growth Regulators) f/b (Glyphosate 

+ 2,4-D) BURN f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A), 

subtract 0.13 Lb ae/A of Glyphosate 

($1.55/A) and subtract 0.11 lb ai/A of 

Broadleaf ($9.32/A). 2.93 $ 20.83

(Glyphosate + 2,4-D) POST Same as above 1.60 $ 11.39

Average 2.22 $ 16.52

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.58 $ (2.69)

0.04 $ 12.28

Projected Rate and Cost Increase (Decrease) for B Minus D 0.54 $ (14.97)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 133 of 202

Table 8. Iowa Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.91 $ 9.67 31%

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.73 $ 18.39 25%

DNAs f/b Glyphosate PRE f/b POST 1.94 $ 16.50 10%

Broadleaf f/b Glyphosate POST 0.99 $ 22.48 7%

(Glyphosate + Post Grass) POST 0.85 $ 13.22 4%

Average 1.28 $ 16.05

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.49 $ 10.71

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.31 $ 19.43

DNAs f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A), 

subtract 0.13 Lb ae/A of Glyphosate 

($1.55/A) and subtract 0.11 lb ai/A of 

Broadleaf ($9.32/A). 2.52 $ 17.54

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.46 $ 14.20

(Glyphosate + Post Grass + 2,4-D) POST Same as above 1.43 $ 14.26

Average 1.84 $ 15.23

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Growth Regulator) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.56 $ (0.82)

0.39 15.43

0.17 $ (16.26)

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A

Projected Rate and Cost Increase (Decrease) for B Minus D

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 134 of 202

Table 9. Minnesota Soybean Herbicide Programs

Herbicide Program Sequence

Description of Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate f/b Glyphosate

BURN f/b POST, POST 

f/b POST 1.60 $ 16.21 37%

Glyphosate POST 0.86 $ 9.09 35%

(Glyphosate + Post Grass) POST 0.88 $ 13.79 6%

(Glyphosate + Post Grass) f/b Glyphosate POST f/b POST 1.72 $ 22.17 4%

Glyphosate f/b (Glyphosate + Post Grass) POST f/b POST 1.55 $ 20.53 3%

Average 1.32 $ 16.36

Glyphosate f/b (Glyphosate + 2,4-D) or 

(Glyphosate + 2,4-D) f/b (Glyphosate + 2,4-D) 

BURN f/b POST, POST 

f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.18 $ 17.25

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.13 Lb ae/A of 

Glyphosate ($1.55/A). 1.44 $ 10.13

(Glyphosate + Post Grass + 2,4-D) POST Same as above 1.46 $ 14.83

(Glyphosate + Post Grass) f/b (Glyphosate + 2,4-D) 

or (Glyphosate + Post Grass + 2,4-D) f/b 

(Glyphosate + 2,4-D) POST f/b POST

Add one or two applications of 0.71 Lb 

ae/A of 2,4-D ($2.59/A) and subtract 

one or two applications of 0.13 Lb 

ae/A of Glyphosate ($1.55/A). 

Calculations are based on one 2,4-D 

application. 2.30 $ 23.21

(Glyphosate) f/b (Glyphosate + Post Grass + 2,4-D) 

or (Glyphosate + 2,4-D) f/b (Glyphosate + Post 

Grass + 2,4-D) POST f/b POST Same as above 2.13 $ 21.57

Average 1.90 $ 17.40

Broadleaf PRE or POST 0.10 $ 11.31 15%

(Glyphosate + Broadleaf) or Glyphosate f/b 

Broadleaf

BURN PRE or BURN f/b 

POST 0.61 $ 11.82 7%

(DNA + Broadleaf) or DNA f/b Broadleaf PRE or PRE f/b POST 1.20 $ 24.17 6%

(Broadleaf + Post Grass) POST 0.31 $ 18.03 5%

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass) BURN PRE f/b POST 0.91 $ 41.91 5%

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass) BURN PRE f/b POST 2.02 $ 46.28 4%

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass) BURN f/b POST 1.10 $ 22.72 3%

(Acetamide + Broadleaf) PRE 0.89 $ 18.82 3%

Liberty POST 0.43 $ 11.91 2%

Average 0.84 $ 23.00

Broadleaf f/b Glyphosate or (Broadleaf + 

Glyphosate) PRE f/b POST, POST 

Add 0.94 Lb ae/A Glyphosate 

($9.55/A) 1.04 $ 20.86

(Glyphosate + Broadleaf) f/b Glyphosate or 

Glyphosate f/b (Broadleaf + Glyphosate) BURN f/b POST Same as above 1.55 $ 21.37

(DNA + Broadleaf) f/b Glyphosate or DNA f/b 

(Broadleaf + Glyphosate) PRE f/b POST Same as above 2.14 $ 33.72

(Broadleaf + Post Grass + Glyphosate) POST Same as above 1.25 $ 27.58

(Broadleaf + Glyphosate) f/b (Broadleaf + Post 

Grass + Glyphosate) BURN PRE f/b POST Same as above 1.85 $ 51.46

(Broadleaf + DNA + Glyphosate) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN PRE f/b POST Same as above 2.96 $ 55.83

(Glyphosate + Synthetic Auxin) f/b (Broadleaf + 

Post Grass + Glyphosate) BURN f/b POST Same as above 2.04 $ 32.27

(Acetamide + Broadleaf) f/b Glyphosate or 

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST Same as above 1.83 $ 28.37

Liberty POST No change 0.43 $ 11.91

Average 1.68 $ 31.49

0.58 $ 1.04

0.35 $ 15.13

Projected Rate and Cost Increase (Decrease) for B Minus D 0.23 $ (14.09)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 

2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been established at the time this analysis 

was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Soybeans

B. Projected Herbicide Programs in GT Soybeans With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Soybeans

D. Projected Herbicide Programs in GT Soybeans Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 135 of 202

Table 10. Illinois Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST 2.64 $ 23.62 32%

Glyphosate POST 0.90 $ 9.50 15%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.52 $ 15.61 7%

(Acetamide Pre-Mix + Glyphosate) POST 3.02 $ 27.15 5%

(Triazine + Glyphosate) POST 1.99 $ 11.96 4%

Average 2.02 $ 17.57

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) or 

(Acetamide Pre-Mix + Glyphosate + 2,4-D) PRE f/b POST or POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.22 $ 24.66

(Glyphosate + 2,4-D) POST Same as above 1.48 $ 10.54

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.10 $ 16.65

(Acetamide Pre-Mix + Glyphosate + 2,4-D) POST Same as above 3.60 $ 28.19

(Triazine + Glyphosate + 2,4-D) POST Same as above 2.57 $ 13.00

Average 2.59 $ 18.61

Acetamide Pre-Mix PRE or POST 2.33 $ 19.13 40%

(Acetamide Pre-Mix + Triazine) PRE or POST 3.16 $ 24.43 9%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide 

Pre-Mix + Broadleaf) PRE f/b POST or POST 2.38 $ 29.13 7%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 3.14 $ 31.86 5%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.61 $ 26.09

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 3.23 $ 28.27

Acetamide Pre-Mix f/b (Triazine + Glyphsate) or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 4.06 $ 33.57

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.28 $ 38.27

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) 

or (Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 4.04 $ 41.00

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 3.33 $ 33.40

0.58 $ 1.04

1.32 $ 15.83

Projected Rate and Cost Increase (Decrease) for B Minus D -0.74 $ (14.79)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

Page 136 of 202

Table 11. Iowa Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 2.44 $ 21.93 34%

Glyphosate POST 0.85 $ 8.53 20%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.76 $ 18.95 8%

(Broadleaf + Glyphosate) POST 0.93 $ 19.63 5%

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) PRE f/b POST 2.33 $ 27.09 5%

Average 1.66 $ 19.23

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.02 $ 22.97

(Glyphosate + 2,4-D) POST Same as above 1.43 $ 9.57

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.34 $ 19.99

(Glyphosate + 2,4-D) POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) and 0.24 Lb 

ai/A of Broadleaf 

($12.08/A) 1.27 $ 8.59

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST Same as above 2.67 $ 16.05

Average 2.15 $ 15.43

Acetamide Pre-Mix PRE or POST 2.03 $ 19.24 24%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide 

Pre-Mix + Broadleaf) PRE f/b POST or POST 2.67 $ 34.62 14%

(Acetamide Pre-Mix + Triazine) PRE or POST 2.70 $ 25.11 12%

(Broadleaf + Triazine) PRE or POST 0.96 $ 19.07 9%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.08 $ 24.78

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 2.93 $ 28.38

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.57 $ 43.76

(Acetamide Pre-Mix + Triazine) f/b Glyphosate or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 3.60 $ 34.25

(Broadleaf + Triazine) + Glyphosate or (Broadleaf 

+ Triazine + Glyphosate) PRE f/b POST or POST Same as above 1.86 $ 28.21

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 2.80 $ 32.10

0.48 $ (3.79)

1.14 $ 12.87

Projected Rate and Cost Increase (Decrease) for B Minus D -0.66 $ (16.66)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
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Table 12. Minnesota Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 2.22 $ 21.32 31%

Glyphosate POST 0.84 $ 8.48 21%

Glyphosate f/b Glyphosate

BURN f/b POST or POST 

f/b POST 1.58 $ 14.97 12%

Acetamide f/b (Broadleaf + Glyphosate) PRE f/b POST 2.04 $ 28.54 8%

(Broadleaf + Glyphosate) POST 0.92 $ 16.23 6%

Average 1.52 $ 17.91

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 2.80 $ 22.36

(Glyphosate + 2,4-D) POST Same as above 1.42 $ 9.52

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or POST 

f/b POST Same as above 2.16 $ 16.01

Acetamide f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) and 0.24 Lb 

ai/A of Broadleaf 

($12.08/A). 2.38 $ 17.50

(Glyphosate + 2,4-D) POST Same as above 1.26 $ 5.19

Average 2.00 $ 14.12

Acetamide Pre-Mix PRE or POST 1.71 $ 18.55 34%

Acetamide Pre-Mix f/b Broadleaf or (Acetamide PreMix + Broadleaf) PRE f/b POST or POST 1.88 $ 24.81 17%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 2.22 $ 26.94 10%

Acetamide Pre-Mix f/b (Broadleaf + Triazine) PRE f/b POST 2.02 $ 26.24 6%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 1.98 $ 24.48

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 2.61 $ 27.69

Acetamide Pre-Mix f/b (Broadleaf + Glyphosate) or 

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 2.78 $ 33.95

(Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE or POST Same as above 3.12 $ 36.08

Acetamide Pre-Mix f/b (Broadleaf + Triazine + 

Glyphosate) PRE f/b POST Same as above 2.92 $ 35.38

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 2.70 $ 31.80

0.48 $ (3.79)

1.18 $ 13.89

Projected Rate and Cost Increase (Decrease) for B Minus D -0.69 $ (17.68)

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of 

Base Treated Acres to insure its inclusion as an alternative.

 A. Top Five Herbicide Programs in GT Corn

B. Projected Herbicide Programs in GT Corn With DHT 

C. Top Five Herbicide Herbicide Programs in Conventional Corn

D. Projected Herbicide Programs in GT Corn Without DHT

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A
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Table 13. Ohio Corn Herbicide Programs

Herbicide Program Sequence

Description of 

Changes to "Current 

State" Program*

Avg Rate 

(Lb ai/A)

Avg Cost 

($/A)

% of 

Acres 

Treated**

Acetamide Pre-Mix f/b Glyphosate PRE f/b POST 3.22 $ 27.48 32%

Glyphosate POST 0.96 $ 10.01 14%

(Acetamide Pre-Mix + Glyphosate) BURN/PRE or POST 3.11 $ 29.62 10%

Glyphosate f/b Glyphosate

BURN f/b POST or 

POST f/b POST 1.40 $ 15.02 9%

(Triazine + Glyphosate) BURN/PRE or POST 2.71 $ 12.09 5%

Average 2.28 $ 18.84

Acetamide Pre-Mix f/b (Glyphosate + 2,4-D) PRE f/b POST

Add 0.71 Lb ae/A of 

2,4-D ($2.59/A) and 

subtract 0.13 Lb ae/A 

of Glyphosate 

($1.55/A) 3.80 $ 28.52

(Glyphosate + 2,4-D) POST Same as above 1.54 $ 11.05

(Acetamide Pre-Mix + Glyphosate + 2,4-D) BURN/PRE or POST Same as above 3.69 $ 30.66

Glyphosate f/b (Glyphosate + 2,4-D)

BURN f/b POST or 

POST f/b POST Same as above 1.98 $ 16.06

(Triazine + Glyphosate) BURN/PRE or POST Same as above 3.29 $ 13.13

Average 2.86 $ 19.88

Acetamide Pre-Mix PRE or POST 2.27 $ 15.38 49%

(Acetamide Pre-Mix + Triazine) PRE or POST 3.24 $ 25.32 14%

(Acetamide Pre-Mix + Broadleaf) PRE or POST 2.54 $ 28.68 7%

(Broadleaf + Post Grass + Triazine) POST 2.44 $ 36.10 2%

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST 2.06 $ 25.88 2%

Average 2.51 $ 26.27

Acetamide Pre-Mix f/b Glyphosate or (Acetamide 

Pre-Mix + Glyphosate) PRE f/b POST or POST 

Add 0.90 Lb ae/A 

Glyphosate ($9.14/A) 3.17 $ 24.52

(Acetamide Pre-Mix + Triazine) f/b Glyphosate or 

(Acetamide Pre-Mix + Triazine + Glyphosate) PRE f/b POST or POST Same as above 4.14 $ 34.46

(Acetamide Pre-Mix + Broadleaf) f/b Glyphosate 

or (Acetamide Pre-Mix + Broadleaf + Glyphosate) PRE f/b POST or POST Same as above 3.44 $ 37.82

(Broadleaf + Triazine + Glyphosate) POST Same as above 3.34 $ 45.24

Acetamide Pre-Mix f/b Liberty or (Acetamide PreMix + Liberty) PRE f/b POST or POST No change 2.06 $ 25.88

Average 3.23 $ 33.58

0.58 $ 1.04

0.95 $ 14.74

-0.37 $ (13.70)

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total 

Base Treated Acres of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% 

of Base Treated Acres to insure its inclusion as an alternative.

D. Projected Herbicide Programs in GT Corn Without DHT

C. Top Five Herbicide Herbicide Programs in Conventional Corn

B. Projected Herbicide Programs in GT Corn With DHT 

Projected Rate and Cost Increase (Decrease) for B Minus D

 A. Top Five Herbicide Programs in GT Corn

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for D minus A

* Cost estimates for DHT Technology is based on 2009 pricing for 2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the 

specially formulated 2,4-D that will be used registered for use on crops containing DHT technology, and technology fees had not been 

established at the time this analysis was conducted.
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Table 14. Georgia Corn Herbicide Programs

Herbicide Program Sequence Program Description 

Avg Rate 

(Lb ai/A)*

Avg Cost 

($/A)*

% of 

Acres 

Treated**

Glyphosate POST 0.77 $ 8.90 22%

Triazine f/b Glyphosate PRE f/b POST 2.86 $ 13.26 12%

Glyphosate f/b (Glyphosate + Triazine) BURN f/b POST 3.68 $ 20.61 5%

(Glyphosate + Synthetic Auxin) + (Glyphosate + 

Synthetic Auxin) BURN f/b POST 2.75 $ 31.20 3%

Glyphosate f/b Triazine f/b Glyphosate BURN f/b PRE f/b POST 3.50 $ 21.25 3%

Average 2.71 $ 19.04

Atrazine f/b (Glyphosate + 2,4-D) + (2,4-D or 

Banvel/Clarity/Status)

PRE f/b POST f/b LAYBY 

(as needed)

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.85 Lb ai/A of nonglyphosate broadleaf herbicides 

($7.54/A) applied postemergence in C 

below. Calculations are based on one 

layby application.

3.07 $ 19.39

(Bicep II Magnum/Bullet/ Guardsman/Lariat/Lexar 

at 66% normal rate) + (Glyphosate + 2,4-D) + (2,4-

D or Banvel/Clarity/Status) 

PRE f/b POST f/b LAYBY 

(as needed)

Add 0.71 Lb ae/A of 2,4-D ($2.59/A) 

and subtract 0.85 Lb ai/A of nonglyphosate broadleaf herbicides 

($7.54/A) applied postemergence in C 

below. Calculations are based on one 

layby application.

3.42 $ 26.67

Average 3.24 $ 23.03

Atrazine f/b (Glyphosate + 

Atrazine/Banvel/Clarity/Status or 

Expert/Sequence/Halex GT) + (2,4-D or 

Banvel/Clarity/Status)

PRE f/b POST f/b LAYBY 

(as needed)

Calculations are based on one layby 

application.

3.21 $ 24.34

(Bicep II Magnum/Bullet/ Guardsman/Lariat/Lexar 

at 66% normal rate) + (Glyphosate + 

Atrazine/Banvel/Clarity/Status or 

Expert/Sequence/Halex GT) + (2,4-D or 

Banvel/Clarity/Status) 

PRE f/b POST f/b LAYBY 

(as needed)

Calculations are based on one layby 

application.

3.56 $ 31.62

Average 3.39 $ 27.98

0.53 $ 3.99

0.68 $ 8.94

-0.14 $ (4.95)

* Cost estimates for DHT Technology is based on 2009 pricing for 

2,4-D, where 0.71 Lb ae of 2,4-D cost $2.59. Retail cost of the specially formulated 2,4-D that will be used registered for use on crops containing DHT 

technology, and technology fees had not been established at the time this analysis was conducted.

** "Percent of Acres Treated" values were calculated dividing Base Treated Acres for each altnerative herbicide program by the total Base Treated Acres 

of glyphosate resistant crops or conventional crops, as appropriate. The Liberty treatment was assumed to be 2% of Base Treated Acres to insure its 

inclusion as an alternative.

*** Prostko, E. P. 2011. Managing Herbicide Resistant Palmer Amananty (Pigweed) in Field Corn, Peanut, and Soybean - 2011. University of Georgia. 

http://mulch.cropsoil.uga.edu/weedsci/resistance-2011-tables.pdf 

A. Top Herbicide Programs in GT Corn

B. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Corn With DHT

C. Recommended Herbicide Program to Control GR Palmer Amaranth in GT Corn Without DHT***

Projected Rate and Cost Increase (Decrease) for B Minus A

Projected Rate and Cost Increase (Decrease) for C minus A

Projected Rate and Cost Increase (Decrease) for B Minus C
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Table 15. Summary of the impact of incorporating 2,4-D and other non-glyphosate 

herbicides into GT crop herbicide programs to control GR and GT weeds on per 

acre herbicide load.

Herbicide Load (Lb ai/A)

Per Acre Herbicide Load in Corn Ohio Minnesota Iowa Illinois Georgia Avg

Average applied on GT corn in 2009 2.28 1.52 1.66 2.02 2.71 2.04

Average increase (decrease) when 0.71 lb 

ae/ac of 2,4-D is incorporated into existing 

GT crop herbicide programs to control GR 

and GT resistant weeds 0.58 0.48 0.48 0.58 0.53 0.42

Average increase (decrease) when other 

non-glyphosate herbicides are incorporated 

into GT crop herbicide programs to control 

GR and GT resistant weeds 0.95 1.18 1.14 1.32 0.68 0.92

Net increase (decrease) from 2,4-D versus 

other non-glyphosate herbicide alternatives (0.37) (0.69) (0.66) (0.74) (0.15) (0.49)

Per Acre Herbicide Load in Soybeans Minnesota Iowa Illinois Arkansas Georgia Avg

Average applied on GT soybeans in 2009 1.32 1.28 1.64 1.59 1.45 1.46

Average increase (decrease) when 0.71 lb 

ae/ac of 2,4-D is incorporated into existing 

GT crop herbicide programs to control GR 

and GT resistant weeds 0.58 0.56 0.58 0.28 0.72 0.54

Average increase (decrease) when other 

non-glyphosate herbicides are incorporated 

into GT crop herbicide programs to control 

GR and GT resistant weeds 0.35 0.39 0.04 0.38 0.07 0.25

Net increase (decrease) from 2,4-D versus 

other non-glyphosate herbicide alternatives 0.23 0.17 0.54 (0.10) 0.65 0.30
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4. End Notes

 1 Prostko, E. P. 2010. Managing Herbicide Resistant Palmer Amaranth (Pigweed) in Field Corn, Peanut, 

and Soybean - 2010. University of Georgia. http://mulch.cropsoil.uga.edu/weedsci/resistance-10-

tables.pdf. Accessed January 16, 2011.

2 Bond, J., T. Eubank, K. Smith, and B. Scott. 2010. Glyphosate-resistant Palmer Amaranth and Ryegrass 

Management. Mississippi Agricultural and Forestry Experiment Station. University of Arkansas Division 

of Agriculture. Infomration Sheet 1351. March 2010. 

http://msucares.com/pubs/infosheets_research/i1351.pdf. Accessed January 16, 2011.
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Survey of University Weed Specialists to Determine GlyphosateResistant and Hard-to-Control Weed Prevalence and Management 

Practices Used in Corn and Soybeans

Appendix C:
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Table of Contents

1. Survey Participants ______________________________________________144

2. Survey Form____________________________________________________145

3. Survey Results __________________________________________________154

3.1 Question 1 ___________________________________________________154

3.2 Question 2 ___________________________________________________155

3.3 Question 3 ___________________________________________________156

3.4 Question 4 ___________________________________________________158

3.5 Question 5 ___________________________________________________167

3.6 Question 6: Glyphosate Resistant Marestail Control in Soybeans _____173

3.7 Question 6: Glyphosate Resistant Waterhemp Control in Soybeans ___177

3.8 Question 6: Glyphosate Resistant Giant Ragweed Control in Soybeans 180

3.9 Question 6: Glyphosate Resistant Kochia Control in Soybeans _______183

3.10 Question 6: Glyphosate Resistant Palmer Amaranth Control in Soybeans184

3.11 Question 6: Glyphosate Tolerant Common Lambsquarters Control in Soybeans

____________________________________________________________186

3.12 Question 6: Glyphosate Resistant Italian Ryegrass Control in Soybeans188

3.13 Question 6: Glyphosate Resistant Marestail Control in Corn_________189

3.14 Question 6: Glyphosate Resistant Waterhemp Control in Corn_______190

3.15 Question 6: Glyphosate Resistant Kochia Control in Corn___________192

3.16 Question 6: Glyphosate Resistant Giant Ragweed Control in Corn____193

3.17 Question 6: Glyphosate Tolerant Common Lambsquarters Control in Corn

____________________________________________________________194

3.18 Question 7 ___________________________________________________196

3.19 Question 8 ___________________________________________________197

3.20 Question 9 ___________________________________________________198

3.21 Question 10 __________________________________________________200

3.22 Question 11 __________________________________________________202
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1. Survey Participants

State Weed Specialist Affiliation

AR Ken Smith University of Arkansas

GA Stanley Culpepper University of Georgia

IA Mike Owen Iowa State University

IN Bill Johnson Purdue

KY Jim Martin University of Kentucky

KS Dallas Peterson Kansas State University

MO Kevin Bradley University of Missouri

MN Jeff Gunsolus University of Minnesota

MS Tom Eubank Mississippi State University

OH Mark Loux Ohio State University
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2. Survey Form

Survey of University Weed Specialists to Determine GlyphosateResistant and Hard-to-Control Weed Prevalence and Management 

Practices Used in Corn and Soybeans

Date: _____________________________

Name:____________________________ Address:___________________________

Title:______________________________ ____________________________

Phone:____________________________ ____________________________

Email:_____________________________

Survey Purpose: This survey is being conducted on behalf of Dow AgroSciences in support of 

the deregulation of DHT herbicide tolerant trait technology on corn and soybeans. Dow 

AgroSciences is required to provide USDA and EPA with an assessment of the economic 

benefits DHT technology will provide once registered. The information generated by this survey 

will be used to fulfill this requirement and provide useful and accurate information to both 

USDA and EPA. Thank you for your help and continued support of Dow AgroSciences and 

DHT herbicide tolerant trait technology.

Questions

1. How would you describe the glyphosate-resistant (GR) weed problem in your state 

today?

a. Declining

b. Static

c. Slowly increasing

d. Increasing at a moderate rate

e. Increasing rapidly

f. Increasing very rapidly

2. How would you describe the hard-to-control (HTC) weed problems in your state today?

a. Declining

b. Static

c. Slowly increasing

d. Increasing at a moderate rate

e. Increasing rapidly

f. Increasing very rapidly
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3. As a way to manage potential GR weed development, how effective do you consider 

each of the following practices? Rate using a 1-10 scale where 1 = ineffective and 10 =

very effective.

___ a. Rotate herbicide chemistries from one year to the next

___ b. Tillage

___ c. Rotate crops and aggressively manage GR weeds in the rotational crop

___ d. Use correct label herbicides rates (for the size and type of weeds present)

___ e. Apply burndown and postemergence herbicides at the proper weed size

___ f. Use more than one chemistry in a given year, such as glyphosate and a 

 residual herbicide(s)

___ g. Use more than one chemistry in a given year, such as glyphosate and 

 another foliar-applied herbicide(s)

___ h. Scout fields after a glyphosate application to determine treatment 

 effectiveness and if treatment is necessary, apply a postemergence 

 herbicide with a different mode of action

___ i. Clean equipment before moving from field to field to minimize spread of seed

___ j. Other ________________________________________________________

4. What are the major obstacles/challenges to implementing each practice in a resistant 

weed management system?

a. Rotate herbicide chemistries from one year to the next.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

b. Tillage.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

c. Rotate crops and aggressively manage GR weeds in the rotational crop.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________
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d. Use correct label herbicides rates (for the size and type of weeds present).

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

e. Apply burndown and postemergence herbicides at the proper weed size.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

f. Use more than one chemistry in a given year, such as glyphosate and a residual 

herbicide(s).

______________________________________________________________________

______________________________________________________________________

g. Use more than one chemistry in a given year, such as glyphosate and another 

foliar-applied herbicide(s).

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

h. Scouting fields after a glyphosate application to determine treatment 

effectiveness and if treatment is necessary, apply a postemergence herbicide 

with a different mode of action.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

i. Clean equipment before moving from field to field to minimize spread of seed 

seed.

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________
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5. What specific GR and HTC weeds are the biggest problems in your state, what 

percentage of each crop in your state is currently infested with each GR and HTC 

species, and what would you project the percent infested acreage to increase to over the 

next 3-5 years (by 2015)?

Estimated 2010 Infested 

Acreage (% of Crop)

Estimated 2015 Infested 

Acreage (% of Crop)

Weed

GR 

or 

HTC Soybean Corn Other Soybean Corn Other
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6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative is at 

managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three species).

a. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences

b. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences
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c. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences

d. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences
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e. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences

f. Weed:______________________ Crop:__________________(corn or soybeans)

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/

Benefits

Weaknesses/

Consequences
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7. How significant of a problem are GR weeds that are also resistant other 

herbicides (resistant to multiple modes of action) in your state?

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

8. Do you expect the acreage infested with multiple herbicide resistance weeds to 

continue to increase in your state?

_____________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

9. In your opinion, what needs to be done to sustain the longevity of the GR system 

and continue to reap the economic, soil conservation and environmental benefits 

the GR cropping system offers?

Corn:________________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

Soybeans_____________________________________________________________

_____________________________________________________________________

_____________________________________________________________________

10. In your opinion, how significant of a contribution will DHT herbicide tolerant 

technology contribute to preserving the utility and benefits of GR crops?

a. No benefit

b. Small benefit

c. Moderate benefit

d. Substantial benefit

Why (strengths and weaknesses)?

Corn:_____________________________________________________________

__________________________________________________________________

__________________________________________________________________

Soybeans__________________________________________________________
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__________________________________________________________________

__________________________________________________________________

11. What would be your recommendations for building a resistance weed 

management program that would include DHT herbicide trait technology in corn 

and soybeans?

Corn:_____________________________________________________________

__________________________________________________________________

__________________________________________________________________

Soybeans__________________________________________________________

__________________________________________________________________

__________________________________________________________________

12. Are you aware of any research studies you or other researchers have completed 

comparing the effectiveness of alternatives for the control of GR and HTC 

weeds?

__________________________________________________________________

__________________________________________________________________

__________________________________________________________________

THANK YOU
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3. Survey Results

3.1 Question 1

1. How would you describe the glyphosate-resistant 

(GR) weed problem in your state today?

a. Declining

b. Static

c. Slowly increasing

d. Increasing at a moderate rate

e. Increasing rapidly

f. Increasing very rapidly

State Responses

AR f

GA e

IA Did not ask

IN d

KY d

KS d

MO d

MN c

MS f

OH C

Summary

Average d to e

Range c-f
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3.2 Question 2

2. How would you describe the hard-to-control (HTC) 

weed problems in your state today?

a. Declining

b. Static

c. Slowly increasing

d. Increasing at a moderate rate

e. Increasing rapidly

f. Increasing very rapidly

State Response

AR E

GA A

IA Did not ask

IN C

KY B

KS D

MO C

MN C

MS F

OH B

Summary

Average C

Range A-F
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3.3 Question 3

3. As a way to manage potential GR weed development, how effective do you consider each of the following practices? 

Rate using a 1-10 scale where 1 = ineffective and 10 = very effective.

___ a. Rotate herbicide chemistries from one year to the next

___ b. Tillage

___ c. Rotate crops and aggressively manage GR weeds in the rotational crop

___ d. Use correct label herbicides rates (for the size and type of weeds present)

___ e. Apply burndown and postemergence herbicides at the proper weed size

___ f. Use more than one chemistry in a given year, such as glyphosate and a residual herbicide(s)

___ g. Use more than one chemistry in a given year, such as glyphosate and another foliar-applied herbicide(s)

___ h. Scout fields after a glyphosate application to determine treatment effectiveness and if treatment is 

necessary, apply a postemergence herbicide with a different mode of action

___ i. Clean equipment before moving from field to field to minimize spread of seed

___ j. Other ________________________________________________________

Resistance Management Practice Effectiveness

State a. b. c. d. e. f. g. h. i. j.

AR 7 7 10 3 7 8 7 7 4 n/a

GA 7 8 8 8 8 9 7 8 5 10

IA Did not ask

IN 10 6 1 6 7 7 7 4 6.5 n/a

KY 8 8 8 5 3 8 5 8 8 n/a

KS 7 5 9 5 3 8 8 5 3 n/a

MO 9 5 7 4 5 8 7 7 3 n/a

MN 6 6 9 7 8 9 8 9 7 n/a

MS 10 7 8 8 8 9 7 10 9 n/a

OH 5 5 5 2 4 10 7 5 4 n/a
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Summary

Average 7.7 6.3 7.2 5.3 5.9 8.4 7.0 7.0 5.5

Range 5 to10 5 to 8 1 to 10 2 to 8 3 to 8 7 to 10 7 to 8 4 to 10 3 to 9
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3.4 Question 4

4. What are the major obstacles/challenges to implementing each practice in a resistant weed management system?

a. Rotate herbicide chemistries from one year to the next.

AR Rotating crops may not be an option due to soil suitability, farming practices, and markets. If the crop is not 

rotated, the most economical weed control program may be the same as used in previous years. Many are 

reluctant to change if the program worked last year.

GA Many of the acres are not rotated out of cotton thus this tool is challenging. Often one product is more effective an 

more economical thus growers continue to use the most effective option

IA Did not ask

IN Cost and simplicity. 

KY Cost of alternative herbicides. Where you grow the same crop continuously can be a challenge to find alternatives 

for the resistant species we have.

KS Cost and effectiveness.

MO No challenges. Have a lot of continuous soybean acres that get back to using the same thing year after year 

because they like to use the cheapest thing out there which is glyphosate. There is less pushback on this than for 

the other practices.

MN Low cost and ease of application of glyphosate is an obstacle. Recent literature out of Canada has shown this 

approach to be less viable then using more than one chemistries in a given year.

MS Rotation of herbicide modes of action is a viable means of resistant weed management in that it limits exposure of 

weeds to a herbicide chemistry within a growing cycle. The biggest challenge I could envision is educating 

producers to the strengths and weaknesses of different herbicide modes of action as compared to the historical 

ease of a glyphosate only program. 

OH prevalence of glyphosate-resistant crops
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b. Tillage.

AR Time and money.

GA erosion, high costs, slow 

IA Did not ask

IN Time managmenet and cost factor

KY Tillage requires additional time and expense toward fuel and labor, as well as soil erosion. We don’t do a lot of 

tillage. Growers are reluctant to use tillage. No till is a religion for many of our growers.

KS Counteracts benefits of no-till production systems

MO Not very effective anyway. Not really a challenge to implement, however, we are going more and more to notill.

MN Although not a big no-till state those involved in no- and reduced- tillage would be reluctant to change. Also, many 

growers do not want to take the time to do inter-row cultivation.

MS Tillage is an effective means of controlling emerged weeds; however, it could also lead to the increased 

emergence of other weeds previously buried in the soil, increased production costs, and the increased likelihood 

of sediment loss. 

OH cost, time and soil erosion
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c. Rotate crops and aggressively manage GR weeds in the rotational crop.

AR Market, soil capabilities, and farm structure. Some farmers do not have the equipment, labor, or capacity to grow 

rice or cotton.

GA Sometimes growers cant rotate crops because of economics. Sometimes growers cant control the pest in a 

rotational crops easily, some rotational crops are of low value thus growers will not spend the money to control the 

pest even if options do exist. An example would be soybean in Georgia as growers will not spend the money in 

this crop even though options exist.

IA Did not ask

IN Profitability of the rotational crop.

KY Cost. Another would be the grain prices dictate what crop the grower will plant.

KS None

MO The challenge is that growers believe they have to grow soybeans on the ground which is reflected in our soybean 

acreage. We are 2:1 soybeans to corn. Liberty Link soybeans have not taken off in Missouri. We really no 

options to clean up resistant weeds if growers produce soybeans.

MN Low cost and ease of application of glyphosate is an obstacle. However, growers that have experienced GR 

weeds are making strategic choices as to which crop they want to keep viable for glyphosate (generally this would 

be sugar beets or soybeans) 

MS As with rotating herbicides knowing which chemistries control GR weeds in alternative cropping systems. In some 

situations the advantages of crop rotation may worsen the problem. Such as rotating wheat and soybeans with GR 

Italian ryegrass.

OH can’t rotate to crop this is different enough in gowth habit or herbicide used, or in area where corn does not grow 

well
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d. Use correct label herbicides rates (for the size and type of weeds present).

AR Not a major problem.

GA No good reason other than trying to save money

IA Did not ask

IN Used to preach that this was not a factor. And it is not a factor for target site resistance. But with glyphosate, 

where we are spraying big weeds, I feel it is a major factor causing resistance.

KY Cost. Don’t see a lot of obstacles. More and more growers are using full rates. It depends on the cost of 

glyphosate.

KS By itself, will not help that much.

MO There are no challenges. When we do surveys of custom applicators, we see they are often using over the label 

rate. We don’t encounter many people that use less than label rates.

MN Low cost of glyphosate has helped to improve label use rates but for established GR weeds this tactic won’t be 

enough.

MS The practice of cutting rates will always be a problem depending on the producers in the area.

OH time, too many acres to cover, weather, stupidity
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e. Apply burndown and postemergence herbicides at the proper weed size.

AR Mainly weather. Some may wait on financing to be approved prior to spending money on burndown.

GA Growers are handling too many acres thus there is no way to be timely everywhere. Rainfall events often delay 

our ability to be timely

IA Did not ask

IN Same as d

KY Growers have room for improvement. One of the issues is marestail and they are not timely with their burndown. 

Timeliness is important for burndown and post applications. Just a few inches and you are out of luck (with 

marestail). 

KS Same as above. Extra applications, cost.

MO The three years of torrential downpours we have in the spring have created problems with proper application 

timing. There are no challenges other than environment. Most spraying done in MO is by a custom applicator.

MN Timing to proper weed size to me is critical and links to rate and use of residual chemistries. Residual chemistries 

are needed to create a more uniform size cohort of emerged weeds for the POST glyphosate application.

MS One of the biggest issues I have seen with burndown/postemergence herbicides is applications being made in 

high winds, poor growing conditions, and improper nozzle selection. Proper weed size is imperative to getting 

adequate control; however, most will wait until the maximum label recommendation is reached to “get more bang 

for their buck” and as farming operations increase in acreage the longer it takes to cover those acres and the 

weeds are subsequently off label by the time they reach the back forty. 

OH time, too many acres to cover, weather, stupidity
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f. Use more than one chemistry in a given year, such as glyphosate and a residual herbicide(s).

AR Time and convenience. Accustomed to good performance with glyphosate and old habits are hard to break. Most 

have not started thinking about weed control from a whole farm, multiple year approach.

GA If growers see one chemistry as being the most effective and economical option then this is the one they use thus 

the limitation is convincing them of the value of that extra chemistry.

IA Did not ask

IN Cost and simplicity.

KY Cost. To a lesser degree some guys have been using glyphosate for so long that they are not knowledgeable 

about the available herbicide alternatives. We have some ALS resistance weeds in Kentucky but not a lot so ALS 

herbicides control glyphsate resistant weeds.

KS Did not ask

MO Goes back to cost. The cost of the residual herbicide. We are gaining more acceptance of this practice in the 

past year or two.

MN Residual chemistries are needed to create a more uniform size cohort of emerged weeds for the POST glyphosate 

application and increase the critical period of weed control window to reduce yield loss due to weed competition 

and allows more time for effective postemergence weed control. Residual chemistries also introduce new MOA’s

MS The biggest hurdle will be overcoming the expense of a residual herbicide. In Mississippi we have come to the 

point, with 5 GR weed species, that you cannot make a crop without multiple residual herbicides. 

OH cost, failure to recognize other benefits of residual
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g. Use more than one chemistry in a given year, such as glyphosate and another foliar-applied herbicide(s).

AR Not a major problem.

GA Having a tank mix partner that is effective on the pest in question. Additional costs

IA Did not ask

IN Same as f.

KY Timeliness and compatibility. Non-glyphosate products require more precise timing than glyphosate. 

KS Cost, antagonism.

MO Cost. There is less challenges than using residual herbicides. However, I see them using the wrong product for 

the weed they are targeting in order to control cost. I find 

MN Multiple chemistries that are effective on a GR weed can be effective but often, due to staggered weed flushes 

and time management issues the tank mix partner with glyphosate may be very weed and size specific plus the 

partner with glyphosate may be limited by crop size. This is not as robust of an approach as option (g).

MS These have value and merit but should not be used as standalone weed control programs. I would rather utilize a 

foliar as a clean up for what was missed by the residual program. 

OH cost, crop injury risk, lack or POST herbicides that do what is needed (soybeans)
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h. Scouting fields after a glyphosate application to determine treatment effectiveness and if treatment is necessary, apply a

postemergence herbicide with a different mode of action.

AR Most scouts are entomologists. They have been trained to look for insects with a hand lens, but cannot see a 

weed until it is 3 ft. tall.

GA Too many acres. Having a different mode of action to treat the pest. A second application would likely occur only 

on large weeds that are tough to kill following the first application.

IA Did not ask

IN What can you apply that late in the season? Most growers apply glyphosate late. You would be trying to control a 

weed that has been treated with and injured by glyphosate with a herbicide applied much later than it should be 

(for optimum performance

KY We preach all the time but guys miss the boat.

KS Often too late for alternative herbicide to be effective.

MO Hope they do more of that. The obstacle is time. 

MN This is an effective and highly desirable approach but is limited by time to adequately scout for weeds that are still 

small enough to be adequately controlled by a different mode of action and still within the window of application to 

the crop without inducing crop injury or off-target injury concerns.

MS Absolutely imperative in managing GR weeds whereas in many situations the weeds will become too large to 

control if the fields are not scouted soon after application. 

OH too late to control large resistant weeds by the time there is the recognition that glyphosate has failed, multipleresistant weed populations
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i. Clean equipment before moving from field to field to minimize spread of weed seed.

AR Time, Time, Time, If it slows the operation of planting or harvesting, it won’t happen. 

GA Not possible to clean all parts of the equipment, especially a cotton picker, bean harvestor, etc.

IA Did not ask

IN Its time. People won’t do it. Also this does not prevent the major mode with which the gene moves around. 

Marestail seed is blowing around. Common ragweed moves with the pollen. So cleaning equipment will have a 

less than complete effect.

KY Growers just don’t do it. If you do it you need to be thorough. They will miss something.

KS May help prevent spread, but not development. Time.

MO Time, Not an answer for many resistant weeds because waterhemp spreads through he pollen and marestail 

seed spreads by wind.

MN This is effective in reducing seed spread but narrow harvest windows often create time limitations.

MS A well advised practice but most farmers will not take the time to clean harvest equipment as time is of the 

essence and will subsequently spread weeds across their farms but the practice is definitely warranted. 

OH time
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3.5 Question 5

5. What specific GR and HTC weeds are the biggest problems in your state, what percentage of 

each crop in your state is currently infested with each GR and HTC species, and what would you 

project the percent infested acreage to increase to over the next 3-5 years (by 2015)?

Estimated 2010 Infested 

Acreage (% of Crop)

Estimated 2015 Infested 

Acreage (% of Crop)

Weed GR or 

HTC

Soybean* Corn* Cotton** Soybean* Corn* Cotton**

MARESTAIL

AR GR 50% 50% 50% 50% 50% 50%

GA Did not list

IA GR 5% 5% 5% 5%

IN GR 50% 50% 100% 100%

KY GR 33% 3.5% 23% 1%

KS GR 40% 20% 60% 40%

MO GR 20% 10% 35% 20%

MN Did not list

MS GR 40% 40% 40% 100% 100% 100%

OH GR 80% 80% 90% 90%

Average 32% 26% 23% 46% 41% 38%

Range 0-50% 0-50% 0-50% 0-100% 0-100% 0-100%

* Average calculated by dividing column by 10 soybean producing states. 

** Average calculated by dividing column by 4 cotton producing states AR, GE, MO, MS). 

COMMON RAGWEED

AR Did not list

GA Did not list

IA Did not list

IN GR 2.5% 2.5% 15% 15%

KY GR < 1% < 1% < 1% < 1%

KS Did not list

MO GR 1% 1% 1% 1%

MN GR 2% 2% 5% 5%

MS Did not list

OH GR 0.1% 0.1% 5% 5%

Average 0.6% 0.6% 2.6% 2.6%

Range 0-2.5% 0-2.5% 0-15% 0-15%
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GIANT RAGWEED

AR Did not list

GA Did not list

IA GR < 5% < 5% 17.5% 17.5%

IN GR 30% 30% 50% 50%

KY Did not list

KS GR < 1% <1% <2% <1%

MO GR 8% 8% 30% 20%

MN GR 2% 2% 5% 5%

MS Did not list

OH GR 20% 20% 50% 50%

Average 6% 6% 15% 14%

Range 0-30% 0-30% 0-50% 0-50%

WATERHEMP

AR Did not list

GA Did not list

IA GR 40% 40% 75% 75%

IN GR 2.5% 2.5% 15% 15%

KY GR < 1% < 1% < 1% < 1%

KS GR < 5% < 1 % 8% < 1%

MO GR 45% 20% 60% 35%

MN GR 5% 5% 5% 5%

MS Did not list

OH Did not list

Average 9% 7% 16% 13%

Range 0-45% 0-40% 0-75% 0-75%
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PALMER AMARANTH

AR GR 60% 60% 75% 100% 100% 100%

GA GR 75% 75% 90% 100% 100% 100%

IA Did not list

IN Did not list

KY GR < 1% < 1% < 1% < 1%

KS Did not list

MO Did not list

MN Did not list

MS GR 15% 5% 10% 80% 20% 60%

OH Did not list

Average 15% 14% 44% 28% 22% 65%

Range 0-75% 0-75% 0-90% 0-100% 0-100% 0-100%

KOCHIA

AR Did not list

GA Did not list

IA Did not list

IN Did not list

KY Did not list

KS GR 10% 10% 20% 20%

MO Did not list

MN Did not list

MS Did not list

OH Did not list

ITALIAN RYEGRASS

AR GR 2% 2% 2% 25% 25% 25%

GA Did not list

IA Did not list

IN Did not list

KY Did not list

KS Did not list

MO Did not list

MN Did not list

MS GR 30% 10% 10% 60% 20% 20%

OH Did not list

Average 3% 1% 3% 9% 5% 11%

Range 0-30% 0-10% 0-10% 0-60% 0-25% 60-25%
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MORNINGGLORY

AR Did not list

GA Did not list

IA Did not list

IN HTC 35% 35% 35% 35%

KY HTC 40% 40% 20% 20%

KS Did not list

MO HTC 95% 85% 95% 85%

MN Did not list

MS Did not list

OH Did not list

Average 17% 16% 15% 14%

Range 0-95% 0-85% 0-95% 0-85%

NUTSEDGE

AR Did not list

GA Did not list

IA Did not list

IN Did not list

KY HTC 5% 5% 5% 5%

KS Did not list

MO Did not list

MN Did not list

MS HTC 20% 5% 20% 30% 5% 30%

OH Did not list

Average 3% 1% 5% 4% 1% 8%

Range 0-20% 0-5% 0-20% 0-30% 0-5% 0-30%
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LAMBSQUARTERS

AR Did not list

GA Did not list

IA HTC 82.5% 82.5% 82.5% 82.5%

IN HTC 50% 50% 50% 50%

KY HTC 5% 5% < 2% < 2%

KS Did not list

MO HTC 80% 80% 80% 80%

MN Did not list

MS Did not list

OH HTC 30% 30% 40% 40%

Average 25% 25% 25% 25%

Range 0-82.5% 0-82.5% 0-82.5% 0-82.5%

ASIATIC DAYFLOWER

AR Did not list

GA Did not list

IA HTC < 5% < 5% 15% 15%

IN HTC 0% 0% 0% 0%

KY Did not list

KS Did not list

MO HTC 20% 20% 35% 35%

MN Did not list

MS Did not list

OH Did not list

Average 2% 2% 5% 5%

Range 0-20% 0-20% 0-35% 0-35%
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JOHNSONGRASS

AR Did not list

GA Did not list

IA Did not list

IN Did not list

KY Did not list

KS Did not list

MO HTC 20% 25% 25% 30%

MN Did not list

MS Did not list

OH Did not list

VELVETLEAF

AR Did not list

GA Did not list

IA Did not list

IN HTC 30% 30% 30% 30%

KY Did not list

KS Did not list

MO Did not list

MN Did not list

MS Did not list

OH Did not list
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3.6 Question 6: Glyphosate Resistant Marestail Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative is at 

managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three species).

MARESTAIL - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

AR Dicamba in spring 80% 80% 8.5 Quick and adds only 

$5.00/A cost

Plant back interval, weather 

for spraying. 

IA 2,4-D as an early preplant 2.5% 15% 9 Controls a lot of winter 

annuals

Application timing (preplant 

only). Drift.

IN Glyphosate + 2,4-D, Sharpen or some other 

herbicide in burndown program

65% 100% 9 Broadens spectrum, 

improves activity on 

broadleaf weeds

Always receive questions on 

compatibility and antagonism 

although likely not a problem. 

Additional cost.

KS Fall/Early Preplant burdown 50% 90% 8 Improved 

control/planting 

Cost, time

KY Apply 2,4-D in the burndown 75% 40% 7 Adding another mode 

of action. Relatively 

inexpensive.

Drift onto tobacco beds and 

housing developments.

KY Apply Kixor with Glyphosate 20% 50% 9 No waiting to plant like 

2,4-D. Efficacy. You 

can afford to be later 

with Kixor technology 

and still control 

marestail.

Cost.
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MO Use 2,4-D or Sharpen with glyphosate 

burndown

70% 90% 8 Another mode of 

action. It is getting it 

before the crop is 

planted.

With 2,4-D need to wait 7 

days after application before 

planting.

MS 2,4-D 80% 100% 8 Economical beginning to miss some 

horseweed

MS Dicamba 40% 100% 8 Effective Severe soybean injury

MS Ignite 20% 60% 9 Effective alternative Expensive

OH Use of other herbicide with glyphosate in 

burndown

50% 60% 9 Control better than 

glyphosate alone

Waiting period to plant or 

restrictions on use of PPO 

inhibiting residual herbicides

Average 8.4

Range <5 to 

80%

15 to 100%

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

KY Apply residual ALS chemistries like Firstrate. 5% 5% 8 Controls glyphosate 

resistant broadleaf 

weed species

Additional cost. Adds 

selection pressure for ALS 

resistance. Do not have ALS 

resistance in Kentucky.

OH Use of residual herbicides 35% 60% 8 Control better than 

glyphosate alone

Not long enough control in 

some fields, multiple 

resistance reduces 

effectiveness of some options

Average 8

Range 5 to 35% 5 to 60%
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

IN Tankmix glyphosate with First Rate or 

Classic

22.5% ??? ALS 

resistance 

potential.

9, may 

be ALS 

resistant

Second mode of 

action. Fairly active on 

sensitive species

Potential for ALS resistance. 

Cost.

MS Firstrate 20% 40% 8 Only postemergence 

option

ALS resistance will develop 

soon

OH POST mixtures 10% 10% 5 Sometimes works multiple resistance reduces 

effectiveness, too expensive

Average 7.3 (Rating assumes no 

ALS resistance)

Range 10 to 

22.5%

10 to 40%

Plant LIBERTY LINK varieties and use LIBERTY

MS Ignite 20% 60% 9 Effective alternative Expensive

Use TILLAGE to control glyphosate resistant weed species

AR Spring tillage 20% 20% 8.5 Good seedbed, no 

plantback interval.

Expensive and slow. Must 

wait until soil dries enough to 

till.

IA Those in notill are the ones with the 

(marestail) problem. There is little notill in 

Iowa.
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IN Tillage. In southern Indiana we lost some 

notill acres. In 2002-2003 upto 25% of 

soybean growers resorted to tillage before 

2,4-D became the accepted burndown 

combination product. Monsanto was not 

recognizing problem and did not recommend 

use of 2,4-D at this time.

Very few 

acres

Less than 

10%.

8 Controls germinating 

weeds. Allows crop to 

get a head start. 

Horseweed is not that 

competitive and if we 

can control at 

burndown the crop will 

prevent establishment 

of weeds that emerge 

incrop

Cost, soil erosion, time. Big 

farms will not resort to tillage. 

Rather they will exhaust all 

herbicide options before going 

to tillage

KY Tillage requires additional time and expense 

toward fuel and labor, as well as soil erosion. 

We don’t do a lot of tillage. Growers are 

reluctant to use tillage. No till is a religion for 

many of our growers.

MO Tillage 20% 20% 8 You can control the 

population that is there.

Soil erosion

OH Tillage 2% 2% 9 Good control Cost, soil erosion, time

Average 8.4

Range 2 to 20% 2 to 20%
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3.7 Question 6: Glyphosate Resistant Waterhemp Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative is at 

managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three species).

WATERHEMP - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

IA Premergence PPO 

herbicides – Flumioxazin. 

Growers have started to 

look at new BASF product. 

ALS inhibitors do not work 

because of resistance.

5% 15% 6.5 Provide good residual 

control

Variability of response due to 

environmental conditions, as well as, 

potential for injury

IN Post glyphosate + Cobra or 

Flexstar

20% 35-40% 8.5 Different mode of action. 

Both herbicides are fairly 

active on watermhemp.

Cobra offers little residual control. 

Flexstar provides 2 weeks of residual 

control.

KS Preemergence herbicide 20% 50% 9 Yield protection, multiple 

MOA

Cost, inconsistent

MN Authority 

products/glyphosate

No idea No idea 9 Pre activity helps 

glyphosate timing and thins 

out population

Rain dependent and Pre efficacy 

variablilty

MN Valor products/glyphosate No idea No idea 9 Pre activity helps 

glyphosate timing and thins 

out population

Rain dependent and Pre efficacy 

variablilty
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MO Using a preemergence 

herbicide – Valor, Prefix, 

Authority

35% 65% 8 The residuals are still very 

effective on waterhemp

Cost. Almost none of them will give 

you season-long control.

Average 8.3

Range 5 to 35% 15 to 65%

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

IA Include a PPO herbicide 

with glyphosate 

postemergence – Phoenix, 

Ultra Blazer, others

10-15% 10-15%

6.5

It works and provides a little 

bit of residual.

Crop injury, resistance

IN Pre herbicide + glyphosate 

burndown - Authority or 

Valor will provide some 

suppression of waterhemp

20% 30-40%

8.5

Different mode of action. 

Both herbicides are fairly 

active on watermhemp.

Crop injury. Depending on rainfall 

late flushes make break thru the 

premergence treatment.

MN Flexstar or 

Cobra+glyphosate

No idea No idea Effective on 4-inch weeds Early time of application is critical.

MO Using a non-glyphosate 

tankmix partner with 

glyhphosate – Flexstar, 

Cobra, Aim, Cadet, Butyrac

45% 60% 6 An alternative chemistry 

that offers some control

Does not work as good as a pre 

residual because you never get 

weeds at right time and the flushes 

continue after application. Many 

people are spraying too late for the 

non-glyphosate herbicides.

Average 7.0

Range 10 to 

45%

10 to 60%
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Plant LIBERTY LINK varieties and use LIBERTY

MO Planting Liberty Link 

Soybeans

2% 15% 8 An alternative mode of 

action non-selective 

herbicide.

Only controls small weeds. Its not 

Roundup Ready. Not as effective as 

glyphosate. You can make it work if 

you are a good manager.

Plant CORN rather than SOYBEANS

MO Plant corn and use 

alternative chemistry

20% 30% 9 Another mode of action. Many growers will not rotate to corn 

because they feel they can’t grow 

corn economically on their piece of 

ground. A lot of it is Missouri river 

bottom and prone to flooding. 
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3.8 Question 6: Glyphosate Resistant Giant Ragweed Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative is at 

managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three species).

GIANT RAGWEED - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/Benefits Weaknesses/Conseque

nces

Use HIGHER RATES of GLYPHOSATE

IN Higher glyphosate rates 75% 100% Depends 

on extent 

of 

tolerance

Good short term strategy to 

protect crop yields.

Poor long term strategy. 

Continued selection 

pressure for GR weeds

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

IA 2,4-D early preplant 5% 5% 8 Works well. Lack of residual.

IN More effective burndown –

glyphosate + 2,4-D

50% 100% 5 Another mode of action. 2,4-D 

is pretty active on giant 

ragweed

No residual.

MO 2,4-D applied at burndown Another mode of action. Controls emerged weeds 

at planting. Does not 

provide residual control.

OH Use of other herbicide with 

glyphosate in burndown

50% 60% 9 Control better than glyphosate 

alone

Waiting period to plant or 

restrictions on use of PPO 

inhibiting residual 

herbicides

Average 7.3

Range 5 to 50% 5 to 100%
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Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

IA Premergence ALS inhibitor 

herbicides

15% 15% Variable 

response 

based on 

resistance. 

0-9

It works unless the population 

is resistant

GR resistant weeds are 

also ALS resistance

IN Glyphosate tank mixed with a 

residual herbicides

20-30% 20-30% 7.5 Thins out weed population. 

Provides bigger window to 

apply post treatments

Perception of 

effectiveness. The 

perception could be that it 

failed unless have a 

check strip.

MN Pre Products containing 

FirstRate / Glyphosate

No idea No idea 9 Pre activity helps glyphosate 

timing and thins out population

Rain dependent and Pre 

efficacy variablilty

MO Residual herbicides – Authority, 

Gangster,

30% 60% 7 Another mode of action. It is such a large seeded 

broadleaf weed that you 

can’t get close to 100% 

control

OH Use of residual herbicides 35% 60% 8 Control better than glyphosate 

alone

Not long enough control in 

some fields, multiple 

resistance reduces 

effectiveness of some 

options

Average 8.1 (Assumes no ALS resistance)

Range 15 to 

35%

15 to 60%
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

IA Include a PPO inhibitor with 

glyphosate postemergence

5-10% 5-10% 7 Works well but timing of 

application is critical

IN Post Glyphosate + Cobra or 

Flexstar

20% 30-40% 8 Another mode of action. Crop injury is a concern. 

Both products have 

weed size restrictions 

that smaller than 

glyphosate.

MN Flexstar + Glyphsate No idea No idea 8 Effective on 4-inch weeds Early time of application 

is critical.

MN FirstRate + Glyphosate No idea No idea 8 Effective on 4-inch weeds Early time of application 

is critical. Some biotypes 

appear to be ALSresistant

MO Post - Reflex 50% 70% 7 Easier to hit application window 

than with waterhemp. Another 

mode of action.

Can’t think of any.

OH POST mixtures 10% 10% 5 Sometimes works multiple resistance 

reduces effectiveness, 

too expensive

Avg 7.2

Range 5 to 50% 5 to 70%

Plant LIBERTY LINK varieties and use 

LIBERTY

MO Liberty Link 2% 10% 7 Another mode of action. Requires a small weed 

size and this is a large 

seeded broadleaf weed.

Use TILLAGE to control glyphosate resistant weed species

OH Tillage 2% 2% 9 Good control Cost, soil erosion, time
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3.9 Question 6: Glyphosate Resistant Kochia Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each 

alternative is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum 

of three species).

KOCHIA - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed 

species.

KS Premergence 

Herbicide

20% 50% 8 Yield protection, Multiple 

MOA

Cost, inconsistent
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3.10 Question 6: Glyphosate Resistant Palmer Amaranth Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative 

is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three 

species).

PALMER AMARANTH - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

AR

Soil residual 

herbicide

60% 90% 8.5 Better control Costs 

GA Three or more 

residual herbicides 

applied throughout 

the weed control 

program plus 

MSMA mixtures at 

layby

98% 98% 7 Numerous modes of action Requires rainfall on dryland 

production acres

MS Valor pre 40% 80% 8 Economical Severe soybean injury possible

MS Prefix pre 40% 80% 9 Two modes of action Short lived residual

Average 8.1

Range 40 to 

98%

80 to 98%
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

MS Flexstar post 50% 90% 8 Only postemergence option Weed size

Plant LIBERTY LINK varieties and use LIBERTY

GA Ignite based 

programs

25 75 7 Topical applications if 

timely will control Palmer

Very timely applications required

Use TILLAGE to control glyphosate resistant weed 

species

GA Tillage 50% 25% 5 Reduces Palmer 

populations at least 50%

Erosion, high costs

GA Hand weeding 50% 25% 7 No seed produced Very high costs, must be timely

Other

GA Rye residue 1% 20% 7 Reduce Palmer populations 

at least 50%

Convincing growers they can 

adopt this production practice
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3.11 Question 6: Glyphosate Tolerant Common Lambsquarters Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative 

is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three 

species).

LAMBSQUARTERS - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strentths/Benefits Weaknesses/Consequ

ences

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

OH Use 2,4-D in 

burndown

50% same 9 Control better than 

glyphosate alone

Waiting period to plant

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

MN Authority or Flexstar 

or Valor package 

mixtures / glyphosate

No idea No idea 8 Pre activity helps 

glyphosate timing 

and thins out 

population

Rain dependent and Pre 

efficacy variablilty

OH Use of residual 

herbicides

35% 60% 10 Good control cost
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

MN Harmony GT 

products + 

glyphosate

No idea No idea 7 Only consistent 

postemergence 

herbicide labeled in 

soybeans to 

compliment 

glyphosate

Timing to proper crop 

size to avoid crop injury. 

Weather and weed size 

greatly influence 

efficacy.
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3.12 Question 6: Glyphosate Resistant Italian Ryegrass Control in Soybeans

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative 

is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three 

species).

ITALIAN RYEGRASS - SOYBEANS

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

MS Paraquat 20% 80% 7 Only option close to planting Resistance may develop soon

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

MS Dual in the fall 10% 60% 9 Expensive output after 

cropping

Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

AR Select 1% 20% 8 No tillage required/no plant 

back interval

Expensive 

MS Select Max 40% 90% 8 Effective on small plants antagonism with phenoxy’s
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3.13 Question 6: Glyphosate Resistant Marestail Control in Corn

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each 

alternative is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum 

of three species).

MARESTAIL - CORN

Control Measure

% of 

Growers 

Currently 

Using

Estimated

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strentths/Benefits Weaknesses/Consequences

Use 2,4-D or another NON-GLYPHOSATE HERBICIDE with BURNDOWN glyphosate applications to provide 

another mode of action for control of glyphosate resistant weed species.

KS Fall/preplant 

burndown

60% 90% 9 Improved control/planting Cost
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3.14 Question 6: Glyphosate Resistant Waterhemp Control in Corn

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative 

is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three 

species).

WATERHEMP - CORN

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

KS Premergence herbicide 70% 80% 9 Yield protection, Multiple 

MOA

Cost

MN

Lumax / Glyphosate No idea No idea 9 Pre activity helps 

glyphosate timing and 

thins out population

Rain dependent and Pre 

efficacy variablilty

MN

Surestart / Glyphosate No idea No idea 8 Pre activity helps

glyphosate timing and 

thins out population

Rain dependent and Pre 

efficacy variablilty

MN

Harness or 

Surpass/Glyphosate

No idea No idea 8.5 Pre activity helps 

glyphosate timing and 

thins out population

Rain dependent and Pre 

efficacy variablilty

MN

Higher PRE rates needed for 

high populations to maintain 

control into the season

Average 8.6

Range
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

KS Postermegence tankmix50% 70% 9 Improved control, Multiple 

MOA

Cost

MN

Callisto or Impact or 

Laudis or Capreno + 

glyphosate

No idea No idea 8.5 Effective control with 

residual that can extend

into later weed flushes

Timing before weeds exceeds 

4-inches in height.

MN

Dicamba products + 

glyphosate

No idea No idea 8 Effective control with 

residual that can extend 

into later weed flushes

Timing to proper crop size to 

avoid crop injury. Control not 

as consistent as with Pigment 

inhibitors

Average 8.5

Range
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3.15 Question 6: Glyphosate Resistant Kochia Control in Corn

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative 

is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three 

species).

KOCHIA - CORN

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed species.

KS Premergence herbicide 70% 80% 9 Yield protection, Multiple MOA Cost

Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

KS Postemergence 

herbicide

50% 70% 9 Improved control, spectrum Cost, drift potential
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3.16 Question 6: Glyphosate Resistant Giant Ragweed Control in Corn

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each 

alternative is at managing each problem weed? (Complete the chart for each weed species in each crop for a maximum 

of three species).

KOCHIA - CORN

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate on 

1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate 

resistant weed 

species.

MN Lumax / Glyphosate No idea No idea 9 Pre activity helps glyphosate 

timing and thins out 

population

Rain dependent and Pre efficacy 

variablilty

MN Surestart / 

Glyphosate

No idea No idea 9 Pre activity helps glyphosate 

timing and thins out 

population

Rain dependent and Pre efficacy 

variablilty

Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to 

provide another mode of action for control of glyphosate resistant weed species.

MN Glyphosate + 

dicamba

No idea No idea 8 Effective on early V2-V3 

corn 

Early time of application is critical

MN Glyphosate + Hornet No idea No idea 8 Effective on early V2-V3 

corn 

Early time of application is critical
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3.17 Question 6: Glyphosate Tolerant Common Lambsquarters Control in Corn

6. Now let’s detail what growers are currently doing to manage each GR and HTC weed and how effective each alternative is at 

managing each problem weed? (Complete the chart for each weed species in each crop for a maximum of three species).

LAMBSQUARTERS - CORN

Control Measure

% of 

Growers 

Currently 

Using

Estimated 

% of 

Growers 

Employing 

by 2015

Efficacy 

(Rate 

on 1-10 

scale)

Strengths/Benefits Weaknesses/Consequences

Use a PREMERGENCE RESIDUAL HERBICIDE(S) to provide another mode of action for control of glyphosate resistant 

weed species.

MN Lumax / Glyphosate No idea No idea 8 Pre activity helps 

glyphosate timing 

and thins out 

population

Rain dependent and Pre 

efficacy variablilty

MN Surestart / 

Glyphosate

No idea No idea 9 Pre activity helps 

glyphosate timing 

and thins out 

population

Rain dependent and Pre 

efficacy variablilty

MN Harness or 

Surpass/Glyphosate

No idea No idea 7+ Pre activity helps 

glyphosate timing 

and thins out 

population

Rain dependent and Pre 

efficacy variablilty
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Use a POSTEMERGENCE NON-GLYPHOSATE HERBICIDE(S) with postemergence glyphosate treatments to provide 

another mode of action for control of glyphosate resistant weed species.

MN Callisto or Impact or 

Laudis or Capreno + 

glyphosate

No idea No idea 8+ Effective control 

with residual that 

can extend into later 

weed flushes

Timing before weeds exceeds 

4-inches in height. Weather 

and weed size greatly 

influence efficacy.

MN

Dicamba products + 

glyphosate

No idea No idea 8+ Effective control 

with residual that 

can extend into later 

weed flushes

Timing before weeds exceeds 

4-inches in height. Weather 

and weed size greatly 

influence efficacy.

MN

Atrazine + glyphosate

No idea No idea 9 Effective control 

with residual that 

can extend into later 

weed flushes

Timing before weeds exceeds 

4-inches in height. BMP’s 

and crop height restrictions 

limit timeliness flexibility.
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3.18 Question 7

7. How significant of a problem are GR weeds that are also resistant other herbicides 

(resistant to multiple modes of action) in your state?

State Response

AR Ryegrass is resistant to at least three modes of action. We have not 

confirmed all three in the same biotype, but will be just a matter of time. 

GA Palmer is resistant to ALS and glyphosate. Approximately 50% of the GR 

Palmer is also ALS resistant.

IA Did not ask

IN

Most glyphosate resistant giant ragweed, marestail and waterhmp will also 

be resistant to ALS herbicides. This is a significiant problem in Indiana. 

KY Multiple resistance is not widespread but growing. 

KS Very.

MO Yes 

– Waterhemp (Gly, PPO, ALS), giant rag (gly and ALS), 

MN It is likely that most of the GR common waterhemp and some (amount not 

known) of the the GR giant and common ragweed biotypes are also 

resistant to ALS herbicides.

MS Did not ask

OH Major problem with horseweed and giant ragweed (ALS + gly-R),_minor 

problem for common ragweed (only because we have almost no gly-R 

common ragweed though – much of the common ragweed is already gly-

R)
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3.19 Question 8

8. Do you expect the acreage infested with multiple herbicide resistance weeds to continue 

to increase in your state?

State Response

AR No doubt

GA Yes

IA Did not ask

IN Yes.

KY

I expect it to increase. With palmer amaranth and waterhemp we are likely 

to develop multiple resistance. 

KS Yes

MO Yes will increase

MN

Good question, with the influx of PPO herbicides in soybean, Pigment 

Inhibitor herbicides in corn and the option of Ignite in corn and now soybean 

I think we can manage the ALS/GR resistance.

MS Did not ask

OH yes

Summary

7 Increase

1 Flat

2 Did not ask
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3.20 Question 9

9. In your opinion, what needs to be done to sustain the longevity of the GR system and continue to reap the economic, 

soil conservation and environmental benefits the GR cropping system offers?

(Responses were the same for corn and soybeans except where specified.)

AR New modes of action herbicides. Begin holistic approach to weed control with entire farm and multiple year 

consideration.

GA Corn: Continue to use atrazine plus alternative chemistry to protect from atrazine and glyphosate resistance

GA Soybeans: Preplant herbicide applications and timely postemergence applications, rotate with other crops 

where possible, move to Ignite based programs

IA We need to include more diverse tactics and eliminate the likelihood that growers will use glyphosate exclusively 

for weed management. Use education and incentivize other behaviors. New tools are always important, but at 

least in the Midwest, the tools we have can be effective if they would use them correctly.

IN For both corn and soybeans I think we need to go after the worst weed problems with more than one mode of 

action. We need to think about glyphosate as atrazine. We used to use 4-5 lbs of atrazine on corn by itself. As 

we cut rates we began adding other products to control weeds that were not controlled by the lower rate atrazine 

treatment. We still will use atrazine but use it with other herbicides to control the weeds that are present in a 

field. That is how we will use glyphosate. We will use glyphosate as the base herbicide and combine it in a 

system with other products to control the weeds that are present. 

KY A complete understanding of the new herbicide chemistries needs to be central. Whatever technology (herbicide 

or trait) you use is going to be based on where its best fit is. Being timely, using the right labeled rate, and not 

cutting corners. We have gotten lax with weed management. We need to get back to focusing on weed 

management. If we don’t it won’t take us long to screw up the new technologies as well.

KS Diversify weed control programs with modes of action, timing, and crop rotation.

MO What is realistic? It important to give growers more options. Stacking Liberty Link with glyphosate and DHT 

traits all in one variety. When we encounter problems with multiple resistant weeds we can’t do anything about it. 

It’s a pretty simple fix but have not been able to educate growers to implement practices or the economics are 

against them and they are not choosing to use the practices we recommend. The reality is that farmers want 

more tools. They won’t manage resistance, they will control it with a tool and will end up with more resistance in 

the future.

MN In a word – diversification. Chemical diversification is the key driver. I personally think that more PRE residual 

chemistry is needed in fields with difficult to control weeds as it has benefits to improve timeliness of weed 

control and adds chemical diversification. 
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MS Moderate benefit

OH Corn: Return to labeled rates of PRE herbicides, use of other POST/burndown herbicides with glyphosate or 

instead of glyphosate. Soybeans: Use of PRE herbicides and alternatives to glyphosate (eg glufosinate), use of 

effective birndown POST herbicides with glyphosate (need new ones though)
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3.21 Question 10

10. In your opinion, how significant of a contribution will DHT herbicide tolerant technology contribute to 

preserving the utility and benefits of GR crops?

a. No benefit

b. Small benefit

c. Moderate benefit

d. Substantial benefit

State Response

AR d

GA d

IA d

IN d

KY b

KS c

MO d

MN b

MS c

OH d

Summary

Average c to d

Range b to d
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Why (strengths and weaknesses)?

(Responses were the same for corn and soybeans except where specified.)

AR Application timing flexibility. Adding another economical herbicide in the program. 

GA I question grower use of GR crops by 2015; thus, I am not sure DHT technology will benefit GR crop production very much. 

If your question was how valuable will DHT be to manage the GR Palmer amaranth then the answer would be a substantial 

benefit.

GA Cotton: DHT systems can effectively mange GR Palmer amaranth; however, if the herbicide drift and/or volatility of these 

herbicides can not be managed then the technology will not be adopted 

IA It provides another way to use existing products. Some of these product will focus very nicely on the weeds that are 

emerging in the GR system. Phenoxy herbicides have drift and contamination issues. The ACCase herbicides could be 

very important if we begin to see resistance evolve in grass weeds. However, it complicates volunteer management. And 

regardless, Dow is going to have to strongly emphasize stewardship on the DHT trait.

IN If we look at the weeds that are becoming more problematic, they are mostly broadleaf weeds. We have many effective 

broadleaf herbicides in corn. With 2,4-D in soybeans we are able to use a broadleaf herbicide that is very effective on 

broadleaf weeds and does not any resistant weeds in corn and soybeans. 2,4-D has a low likelihood of resistance 

development. There are no current resistance issues in corn and soybeans. Its is fairly compatible with glyphosate. Mixing

does not result in any huge issues with antagonism. The issue will be to manage off-site movement. 

KY Kentucky has had problems with 2,4-D drift issues. There will be situations where it will fit but it will need an education. In 

the grand scheme of things it will be a small thing in Kentucky. Drift will be an issue with 2,4-D and dicamba technology.

KS Corn: Strengths: Improved crop safety, expanded rates and wider window of application of 2.4-D. Weakness: Field 

identification and management. Drift potential.

KS Soybeans: New mode of action and weed control. Weakness: Field identification and management. Drift potential.

MO It has no preplant interval. Ability to burndown key resistant species like marestail and giant ragweed. Higher flexibility on 

rate range in-crop. Currently most problematic resistant weed species are broadleaves and 2,4-D would do a go job at 

controlling them.

MN It could improve early season weed control options where we have had difficulty getting a fall- or early-spring burndown for 

winter annual and perennial weeds in reduced tillage. Concerns during the postemergence time period would include offtarget movement and tank contamination issues. 

MS Did not ask

OH Corn: mixtures of 2,4-D with glyphosate for burndown/POST without risk of crop injury. Soybeans: same as corn, 

although we already have some 2,4-D resistant horseweed populations
Supplemental Information for USDA Petition for Nonregulated Status of DAS-40278-9 Corn

Dow AgroSciences LLC

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3.22 Question 11

11. What would be your recommendations for building a resistance weed management program that would include 

DHT herbicide trait technology in corn and soybeans?

(Responses were the same for corn and soybeans except where specified.)

AR Don’t know enough about the DHT trait technology at this time. Only after we have had an opportunity to test 

the technology and see it in the field will we be able to offer recommendations for use. 

GA Cotton: At least three alternative modes of action included in the system including at least one at plant 

residual, one POST residual, and one residual at layby, timely applications, crop rotation, adoption of heavy 

cover crop residues

IA Did not ask

IN The key is to understand what the worst weed problems are in a field and use multiple modes of action to 

control those weeds. That would include residual herbicides to allow for timely post spraying and 

postemergence herbicides. In the short-term I am not concerned about using 2,4-D twice during a single 

season. In the long-term using 2,4-D as a burndown and again postemergence will likely hasten the 

development of weed resistance weeds. However, in Indiana we have a house every 300 feet in the country 

and I am concerned about offsite movement. Everyfield will present a unique set of circumstances. If you have 

god-awful weed problems, blow on as much as you can. If you have waterhemp, use 2,4-D postemergence 

because you can use other herbicide at burndown for waterhemp control. If you have markestail, you should 

use 2,4-D with a residual herbicide at burndown because marestail is not problem weed in crop. The biology of 

the DHT technology fits soybeans best. 

KY Did not ask

KS Utilize as needed. Still encourage use of preemergence herbicides.

MO We are trying to figure out the rates and timing on resistant weeds. It is not as simple as I thought. The rate of 

2,4-D you can use is higher than I thought. We are working on the right mixes and rates. 

MN Build a PRE herbicide component into it to improve the postemergence window of opportunity so that it is easier 

to avoid spraying under unfavorable conditions. This would also add some chemical diversification.

MS Did not ask

OH Corn: use of active rates of residual herbicides, use of mixtures of glyphosate and 2,4-D POST. Soybeans: 

same as corn with the addition of ability to use 2,4-D at or after planting for burndown in mixtures with 

glyphosate, other burndown herbicides.