The Monsanto Company Petition (10-281-01) for 

Determination of Nonregulated Status of MON 87427 

Maize

OECD Unique Identifier: 

MON-87427-1

Environmental Assessment 

April 2013

Agency Contact 

Cindy Eck

Biotechnology Regulatory Services

4700 River Road

USDA, APHIS 

Riverdale, MD 20737 

Fax: (301) 734-8669

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U.S. Department of Agriculture over others not mentioned. USDA neither guarantees nor warrants the standard of any 

product mentioned. Product names are mentioned solely to report factually on available data and to provide specific 

information. 

This publication reports research involving pesticides. All uses of pesticides must be registered by appropriate State 

and/or Federal agencies before they can be recommended. 
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

TABLE OF CONTENTS

1 PURPOSE AND NEED.............................................................................................. 8

1.1 Background .......................................................................................................... 8

1.2 Purpose of Product ............................................................................................... 8

1.3 Coordinated Framework Review and Regulatory Review................................... 9

1.4 Purpose and Need for APHIS Action................................................................. 11

1.5 Public Involvement ............................................................................................ 11

1.5.1 First Opportunity for Public Involvement................................................... 12

1.5.2 Second Opportunity for Public Involvement .............................................. 12

1.6 Issues Considered............................................................................................... 14

2 AFFECTED ENVIRONMENT................................................................................ 15

2.1 Agricultural Production of Corn ........................................................................ 15

2.1.1 Acreage and Range of Commercial Corn Production................................. 15

2.1.2 Agronomic Practices of Commercial Corn Production .............................. 17

2.1.3 Hybrid Corn Seed Production: Pollen Control .......................................... 23

2.1.4 Organic Corn Production ............................................................................ 28

2.2 Physical Environment ........................................................................................ 30

2.2.1 Soil Quality................................................................................................. 30

2.2.2 Water Resources ......................................................................................... 31

2.2.3 Air Quality .................................................................................................. 31

2.2.4 Climate Change........................................................................................... 31

2.3 Biological Resources.......................................................................................... 32

2.3.1 Animal Communities.................................................................................. 32

2.3.2 Plant Communities...................................................................................... 33

2.3.3 Gene Flow and Weediness.......................................................................... 34

2.3.4 Microorganisms .......................................................................................... 35

2.3.5 Biodiversity................................................................................................. 35

2.4 Human Health .................................................................................................... 36

2.5 Animal Feed ....................................................................................................... 36

2.6 Socioeconomic ................................................................................................... 36

2.6.1 Domestic Economic Environment .............................................................. 36

2.6.2 Trade Economic Environment .................................................................... 37

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

3 ALTERNATIVES..................................................................................................... 38

3.1 No Action Alternative: Continuation as a Regulated Article............................. 38

3.2 Preferred Alternative: Determination that MON 87427 Corn is No Longer a Regulated 

Article ................................................................................................................ 38

3.3 Alternatives Considered But Rejected from Further Consideration .................. 39

3.3.1 Prohibit Any MON 87427 Corn from Being Released............................... 39

3.3.2 Approve the Petition in Part........................................................................ 40

3.3.3 Isolation Distance between MON 87427 and Non-GE Corn Production and 

Geographical Restrictions........................................................................... 40

3.3.4 Requirements of Testing for MON 87427 Corn......................................... 40

3.4 Comparison of Alternatives ............................................................................... 41

4 ENVIRONMENTAL CONSEQUENCES ............................................................... 44

4.1 Scope of Analysis............................................................................................... 44

4.2 Agricultural Production of Corn ........................................................................ 46

4.2.1 Acreage and Range of Commercial Corn Production................................. 46

4.2.2 Agronomic Practices of Commercial Corn Production .............................. 48

4.2.3 Hybrid Corn Seed Production..................................................................... 55

4.2.4 Organic Corn Production ............................................................................ 60

4.3 Physical Environment ........................................................................................ 61

4.3.1 Water Resources ......................................................................................... 61

4.3.2 Soil Quality................................................................................................. 64

4.3.3 Air Quality .................................................................................................. 66

4.3.4 Climate Change........................................................................................... 66

4.4 Biological Resources.......................................................................................... 69

4.4.1 Animal Communities.................................................................................. 69

4.4.2 Plant Communities...................................................................................... 71

4.4.3 Gene Flow and Weediness.......................................................................... 75

4.4.4 Microorganisms .......................................................................................... 77

4.4.5 Biodiversity................................................................................................. 80

4.5 Human Health .................................................................................................... 83

4.6 Animal Feed ....................................................................................................... 86

4.7 Socioeconomic Impacts...................................................................................... 89

4.7.1 Domestic Economic Environment .............................................................. 89

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

4.7.2 Trade Economic Environment .................................................................... 92

5 CUMULATIVE IMPACTS...................................................................................... 96

5.1 Assumptions Used for Cumulative Impacts Analysis........................................ 96

5.2 Cumulative Impacts: Acreage and Area of Corn Production............................. 97

5.3 Cumulative Impacts: Agronomic Practices........................................................ 98

5.4 Cumulative Impacts: Organic Corn Production............................................... 101

5.5 Cumulative Impacts: Physical Environment.................................................... 101

5.6 Cumulative Impacts: Biological Resources ..................................................... 102

5.7 Cumulative Impacts: Public Health and Animal Feed..................................... 104

5.8 Cumulative Impacts: Domestic Economic Environment................................. 105

5.9 Cumulative Impacts: Trade Economic Environment....................................... 106

5.10 Cumulative Impacts: Domestic Socio Economic Analysis.............................. 107

6 THREATENED AND ENDANGERED SPECIES ............................................... 108

7 CONSIDERATION OF EXECUTIVE ORDERS, STANDARDS, AND TREATIES

RELATING TO ENVIRONMENTAL IMPACTS ............................................... 115

7.1 Executive Orders with Domestic Implications................................................. 115

7.2 International Implications ................................................................................ 117

7.3 Compliance with Clean Water Act and Clean Air Act .................................... 118

7.4 Impacts on Unique Characteristics of Geographic Areas ................................ 118

7.5 National Historic Preservation Act of 1966 as Amended ................................ 119

8 LIST OF PREPARERS........................................................................................... 121

9 REFERENCES ....................................................................................................... 122

iv
List of Tables

Table 1: Certified organic corn acreage by state with more than 1,000 acres of certified land in 

2007 and 2008............................................................................................................................... 30

Table 2. Summary of issues of potential impacts and consequences of alternatives................... 41

List of Figures

Figure 1. U.S. corn production, planted acreage.......................................................................... 16

Figure 2. Adoption rates of three major tillage types in U.S. corn production, 1996 – 2010...... 18

Figure 3. Percent of U.S. corn acreage treated with pesticides, 2010.......................................... 22

Figure 4. Adoption of GE corn varieties with at least one herbicide-tolerant trait and glyphosate 

in U.S. corn production, 1994 – 2010........................................................................................... 23

Figure 5. Pollen movement: open and hybrid............................................................................. 24

Figure 6 Glyphosate-resistant weeds in the U.S. corn fields........................................................ 34

Figure 7. Hybrid corn seed planted and corn grain produced in the United States, 1975-2009 ... 48

Figure 8. Tillage trends and adoption of herbicide-resistant (HT) corn in the U.S., 2000 – 2010.

....................................................................................................................................................... 49

Figure 9. Total application of fungicides in U.S. corn production, 1995 – 2010. ....................... 52

Figure 10. Trends in the use of insecticides and Bt corn in the US............................................. 52

Figure 11. Commonly used herbicides in U.S. corn production, 1995 – 2010........................... 53

Figure 12. Genes and phenotype of MON 87427 ........................................................................ 58

Figure 13. Comparison of glyphosate application timing between Roundup Ready 2® and MON 

87427 corn. ................................................................................................................................... 58

Figure 14. US and world corn exports for marketing years 2000/2001 to 2010/2011. ............... 93

Figure 15. US and major exporters of corn for marketing years 1960/1961-2011/2012............. 94
Acronyms and Abbreviations

AIA advanced informed agreement

AMS Agricultural Marketing Service

AOSCA American Organization of Seed Certifying Agencies

APHIS Animal and Plant Health Inspection Service

BRAD Biopesticide Registration Action Document

BRS Biotechnology Regulatory Services (within USDA–APHIS)

Bt Bacillus thuringiensis protein

CAA Clean Air Act

CBD Convention on Biological Diversity

CEQ Council on Environmental Quality

CFR Code of Federal Regulations (United States)

CH4 methane

CO carbon monoxide

CO2 carbon dioxide

CRP Conservation Reserve Program

DNA deoxyribonucleic acid

DT drought tolerant

EA environmental assessment

EIS environmental impact statement

EO Executive Order

EPA U.S. Environmental Protection Agency

EQIP Environmental Quality Incentives Program

ESA Endangered Species Act of 1973

FDA U.S. Food and Drug Administration 

FFDCA Federal Food, Drug, and Cosmetic Act

FFP food, feed, or processing

FIFRA Federal Insecticide, Fungicide, and Rodenticide Act

FR Federal Register

GDP gross domestic product

GE genetically engineered

GHG greenhouse gas

GMO genetically modified organism

IP Identity Preservation

IPCC Intergovernmental Panel on Climate Change

IRM Insect Resistance Management
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Acronyms and Abbreviations

ISPM International Standard for Phytosanitary Measure

IPPC International Plant Protection Convention

LD50 lethal dose that kills 50% of the animals being tested

MBu million bushels 

NO2 nitrogen dioxide

N2O nitrous oxide

NAAQS National Ambient Air Quality Standards

NABI North American Biotechnology Initiative

NAPPO North American Plant Protection Organization

NEPA National Environmental Policy Act of 1969 and subsequent amendments

NHPA National Historic Preservation Act

NOEL no observable effect level

NOP National Organic Program

NPS Agricultural non-point source

NRC National Research Council

PPRA Plant Pest Risk Assessment

PPA Plant Protection Act

PRA pest risk analysis

RNA ribonucleic acid

TES threatened and endangered species

TSCA Toxic Substances Control Act

U.S. United States

USDA U.S. Department of Agriculture

USDA-ERS U.S. Department of Agriculture-Economic Research Service

USDA-FAS U.S. Department of Agriculture-Foreign Agricultural Service

USDA-NASS U.S. Department of Agriculture-National Agricultural Statistics Service

USDA-NOP U.S. Department of Agriculture-National Organic Program

USC United States Code

USFWS U.S. Fish & Wildlife Service

WPS Worker Protection Standard for Agricultural Pesticides

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

1 Purpose and Need

1.1 Background

The Monsanto Company of St. Louis, MO submitted petition 10-281-01 to the United States 

Department of Agriculture (USDA) Animal and Plant Health Inspection Service (APHIS) in 

October 2010 seeking a determination of nonregulated status of maize1 event MON 87427 that 

exhibits a tissue-selective glyphosate tolerant phenotype. MON 87427 corn is currently 

regulated under 7 CFR part 340. Interstate movements and field trials of MON 87427 corn have 

been conducted under notifications and permits acknowledged by APHIS since 2005. These 

field trials were conducted in typical corn production regions within the U.S., ranging from 

Arkansas to Wisconsin. Details regarding and data resulting from these field trials are described 

in the MON 87427 petition (Monsanto, 2010) and analyzed for plant pest risk in the APHIS 

Plant Pest Risk Assessment (PPRA) (USDA-APHIS, 2012).

The petition stated that APHIS should not regulate MON 87427 corn because it does not present 

a plant pest risk. In the event of a determination of nonregulated status, the nonregulated status 

would include MON 87427 corn, any progeny derived from crosses between MON 87427 and 

conventional corn, including crosses of MON 87427 with other biotechnology-derived corn

varieties that are no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

pest provisions of the Plant Protection Act.

1.2 Purpose of Product

Almost all commercial corn seed in the United States is produced through hybridization. Hybrid 

corn seed production requires the use of two corn inbred parents, one designated as the pollen 

receiver (female) and another designated as the pollen donor (male). In this process, the female 

inbred is fertilized with pollen from the male inbred. To ensure cross pollination between female 

and male inbred parents and limit self-fertilization2 of the female parent, female inbred plants are 

often detasseled3. Detasseling of the female inbred may be accomplished by hand and/or 

through mechanical means. In addition to representing one of the largest costs in hybrid corn

seed production, detasseling of female inbred parents may also incur a yield penalty through 

plant injury or inefficient detasseling (Pioneer, 2009; Monsanto, 2010).

MON 87427 corn is genetically engineered (GE) to reduce the cost of producing hybrid corn

seed. When used as a female inbred parent and sprayed with glyphosate during late vegetative 

development, MON 87427 corn is unable to produce viable pollen and self-fertilize. This 

phenotype precludes the need for manual/mechanical detasseling of MON 87427, decreasing the

costs and yield penalties generally associated with manual/mechanical detasseling. 

1 Maize and corn will be used interchangeably throughout this document.

2 Corn is a monoecious plant, meaning that both female and male reproductive structures are found on a single 

individual. The female reproductive structure is called an ear, while the male reproductive structure is called a 

tassel. Self-fertilization in corn occurs when pollen from one individual fertilizes an egg of that same individual. 

3 Pollen control of the female inbred parent may be undertaken through removal of the tassel.

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

The MON 87427 phenotype is derived from tissue-specific expression4 of cp4 epsps, a gene 

commonly used to confer glyphosate resistance in crop plants. When MON 87427 corn is 

sprayed with glyphosate prior to or during male reproductive tissue development, viable pollen 

will not develop. However, growth and female reproductive tissue development proceeds 

normally in MON 87427, such that its ears remain fully receptive to pollen from another corn 

plant

1.3 Coordinated Framework Review and Regulatory Review

Since 1986, the United States government has regulated GE organisms pursuant to a regulatory 

framework known as the Coordinated Framework for the Regulation of Biotechnology 

(Coordinated Framework) (51 FR 23302, 1986; 57 FR 22984, 1992). The Coordinated 

Framework, published by the Office of Science and Technology Policy, describes the 

comprehensive federal regulatory policy for ensuring the safety of biotechnology research and 

products and explains how federal agencies will use existing Federal statutes in a manner to 

ensure public health and environmental safety while maintaining regulatory flexibility to avoid 

impeding the growth of the biotechnology industry. The Coordinated Framework is based on 

several important guiding principles: (1) agencies should define those transgenic organisms 

subject to review to the extent permitted by their respective statutory authorities; (2) agencies are 

required to focus on the characteristics and risks of the biotechnology product, not the process by 

which it is created; (3) agencies are mandated to exercise oversight of GE organisms only when 

there is evidence of “unreasonable” risk.

The Coordinated Framework explains the regulatory roles and authorities for the three major 

agencies involved in regulating GE organisms: USDA-APHIS, the Environmental Protection 

Agency (EPA), and the Food and Drug Administration (FDA).

USDA-APHIS

APHIS regulations at 7 Code of Federal Regulations (CFR) part 340, which were promulgated 

pursuant to authority granted by the Plant Protection Act, as amended (7 United States Code 

(U.S.C.) 7701–7772), regulate the introduction (importation, interstate movement, or release into 

the environment) of certain GE organisms and products. A GE organism is no longer subject to 

the plant pest provisions of the Plant Protection Act or to the regulatory requirements of 7 CFR 

part 340 when APHIS determines that it is unlikely to pose a plant pest risk. A GE organism is 

considered a regulated article if the donor organism, recipient organism, vector, or vector agent 

used in engineering the organism belongs to one of the taxa listed in the regulation (7 CFR 

340.2) and is also considered a plant pest. A GE organism is also regulated under Part 340 when 

APHIS has reason to believe that the GE organism may be a plant pest or APHIS does not have 

information to determine if the GE organism is unlikely to pose a plant pest risk. 

A person may petition the agency that a particular regulated article is unlikely to pose a plant 

pest risk, and, therefore, is no longer regulated under the plant pest provisions of the Plant 

Protection Act or the regulations at 7 CFR 340. The petitioner is required to provide information 

4 When cp4 epsps expression is under control of the 35S-hsp70 promoter in corn, as in MON 87427 corn, glyphosate 

tolerance only occurs in vegetative and female reproductive tissues and does not occur in male reproductive tissues.

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

under § 340.6(c)(4) related to plant pest risk that the agency may use to determine whether the 

regulated article is unlikely to present a greater plant pest risk than the unmodified organism. A 

GE organism is no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

pest provisions of the Plant Protection Act when APHIS determines that it is unlikely to pose a 

plant pest risk.

Environmental Protection Agency

The EPA is responsible for regulating the sale, distribution, and use of pesticides, including 

pesticides that are produced by an organism through techniques of modern biotechnology. The 

EPA regulates plant incorporated protectants (PIPs) under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.) and certain biological control organisms under 

the Toxic Substances Control Act (TSCA) (15 U.S.C. 53 et seq.). Before planting a crop 

containing a PIP, a company must seek an experimental use permit from EPA. Commercial 

production of crops containing PIPs for purposes of seed increases and sale requires a FIFRA 

Section 3 registration with EPA. 

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) (7 U.S.C. 136 et seq.), 

EPA regulates the use of pesticides, including plant-incorporated protectants, requiring 

registration of a pesticide for a specific use prior to distribution or sale of the pesticide for a 

proposed use pattern. EPA examines the ingredients of the pesticide; the particular site or crop

on which it is to be used; the amount, frequency, and timing of its use; and storage and disposal 

practices. Prior to registration for a new use for a new or previously registered pesticide, EPA 

must determine through testing that the pesticide will not cause unreasonable adverse effects on 

humans, the environment, and non-target species when used in accordance with label 

instructions. EPA must also approve the language used on the pesticide label in accordance with 

40 CFR part 158. Once registered, a pesticide may not legally be used unless the use is 

consistent with the approved directions for use on the pesticide's label or labeling. The overall 

intent of the label is to provide clear directions for effective product performance while 

minimizing risks to human health and the environment. The Food Quality Protection Act 

(FQPA) of 1996 amended FIFRA, enabling EPA to implement periodic registration review of 

pesticides to ensure they are meeting current scientific and regulatory standards of safety and

continue to have no unreasonable adverse effects (EPA, 2011). 

EPA also sets tolerances for residues of pesticides on and in food and animal feed, or establishes 

an exemption from the requirement for a tolerance, under the Federal Food, Drug, and Cosmetic 

Act (FFDCA). EPA is required, before establishing pesticide tolerance, to reach a safety 

determination based on a finding of reasonable certainty of no harm under the FFDCA, as 

amended by the Food Quality Protection Act of 1996. FDA enforces the pesticide tolerances set 

by EPA.

Food and Drug Administration

FDA regulates GE organisms under the authority of the FFDCA (21 U.S.C. 301 et seq.). The 

FDA published its policy statement concerning regulation of products derived from new plant 

varieties, including those derived from genetic engineering, in the Federal Register on May 29, 

1992 (57 FR 22984, 1992). Under this policy, FDA implements a voluntary consultation process 

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

to ensure that human food and animal feed safety issues or other regulatory issues, such as 

labeling, are resolved before commercial distribution of bioengineered food. This voluntary 

consultation process provides a way for developers to receive assistance from FDA in complying 

with their obligations under Federal food safety laws prior to marketing.

More recently, in June 2006, FDA published recommendations in “Guidance for Industry: 

Recommendations for the Early Food Safety Evaluation of New Non-Pesticidal Proteins 

Produced by New Plant Varieties Intended for Food Use” (FDA, 2006) for establishing voluntary 

food safety evaluations for new non-pesticidal proteins produced by new plant varieties intended 

to be used as food, including bioengineered plants. Early food safety evaluations help make sure 

that potential food safety issues related to a new protein in a new plant variety are addressed 

early in development. These evaluations are not intended as a replacement for a biotechnology 

consultation with FDA, but the information may be used later in the biotechnology consultation.

1.4 Purpose and Need for APHIS Action

Under the authority of the plant pest provisions of the Plant Protection Act and 7 CFR part 340, 

APHIS has issued regulations for the safe development and use of GE organisms. Any party can 

petition APHIS to seek a determination of nonregulated status for a GE organism that is 

regulated under 7 CFR 340. As required by 7 CFR 340.6, APHIS must respond to petitioners 

that request a determination of the regulated status of GE organisms, including GE plants such as 

MON 87427 corn. When a petition for nonregulated status is submitted, APHIS must make a 

determination if the GE organism is unlikely to pose a plant pest risk. The petitioner is required 

to provide information under § 340.6(c)(4) related to plant pest risk that the agency may use to 

determine whether the regulated article is unlikely to present a greater plant pest risk than the 

unmodified organism. A GE organism is no longer subject to the regulatory requirements of 7 

CFR part 340 or the plant pest provisions of the Plant Protection Act when APHIS determines 

that it is unlikely to pose a plant pest risk.

APHIS must respond to an October 2010 petition from the Monsanto Company requesting a 

determination of the regulated status of MON 87427 corn. APHIS has prepared this 

Environmental Assessment (EA) to consider the potential environmental effects of an agency 

determination of nonregulated status consistent with Council of Environmental Quality’s (CEQ) 

National Environmental Policy Act (NEPA) regulations and the USDA and APHIS NEPA 

implementing regulations and procedures(40 CFR parts 1500-1508, 7 CFR part 1b, and 7 CFR 

part 372). This EA has been prepared in order to specifically evaluate the effects on the quality 

of the human environment5 that may result from a determination of nonregulated status of MON 

87427 corn.

1.5 Public Involvement

APHIS routinely seeks public comment on EAs prepared in response to petitions seeking a 

determination of nonregulated status of a regulated GE organism. APHIS does this through a 

5 Under NEPA regulations, the “human environment” includes “the natural and physical environment and the 

relationship of people with that environment” (40 CFR §1508.14).

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

notice published in the Federal Register. On March 6, 2012, APHIS published a notice6 in the 

Federal Register advising the public that APHIS is implementing changes to the way it solicits 

public comment when considering petitions for determinations of nonregulated status for GE 

organisms to allow for early public involvement in the process. As identified in this notice, 

APHIS will publish two separate notices in the Federal Register for petitions for which APHIS 

prepares an EA. The first notice will announce the availability of the petition, and the second 

notice will announce the availability of APHIS’ decision making documents. As part of the new 

process, with each of the two notices published in the Federal Register, there will be an 

opportunity for public involvement:

1.5.1 First Opportunity for Public Involvement

Once APHIS deems a petition complete, the petition is be made available for public comment for 

60 days, providing the public an opportunity to raise issues regarding the petition itself and give 

input that will be considered by the Agency as it develops its EA and PPRA. APHIS publishes a 

notice in the Federal Register to inform the public that APHIS will accept written comments 

regarding a petition for a determination of nonregulated status for a period of 60 days from the 

date of the notice. This availability of the petition for public comment will be announced in a 

Federal Register notice.

1.5.2 Second Opportunity for Public Involvement

Assuming an EA is sufficient, the EA and PPRA are developed and a notice of their availability 

is published in a second Federal Register notice. This second notice follows one of two 

approaches for public participation based on whether or not APHIS decides the petition for a 

determination of nonregulated status is for a GE organism that raises substantive new issues:

Approach 1: GE organisms that do not raise substantive new issues.

This approach for public participation is used when APHIS decides, based on the review of the 

petition and our evaluation and analysis of comments received from the public during the 60-day 

comment period on the petition, that the petition involves a GE organism that does not raise new 

biological, cultural, or ecological issues because of the nature of the modification or APHIS' 

familiarity with the recipient organism. After developing its EA, finding of no significant impact 

(FONSI), and PPRA, APHIS publishes a notice in the Federal Register announcing its 

preliminary regulatory determination and the availability of the EA, FONSI, and PPRA for a 30-

day public review period.

If no information is received that would warrant substantially changing the APHIS analysis or 

determination, APHIS' preliminary regulatory determination becomes effective upon public 

notification through an announcement on its website. No further Federal Register notice is

published announcing the final regulatory determination.

6

 This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Approach 2. For GE organisms that raise substantive new issues not previously reviewed by 

APHIS. A second approach for public participation is used when APHIS determines that the 

petition for a determination of nonregulated status is for a GE organism that raises substantive 

new issues. This could include petitions involving a recipient organism that has not previously 

been determined by APHIS to have nonregulated status or when APHIS determines that gene 

modifications raise substantive biological, cultural, or ecological issues not previously analyzed 

by APHIS. Substantive issues are identified by APHIS based on our review of the petition and 

our evaluation and analysis of comments received from the public during the 60-day comment 

period on the petition. 

APHIS solicits comments on its draft EA and draft PPRA for 30 days, as announced in a Federal 

Register notice. APHIS reviews and evaluates comments and other relevant information, then 

revises the PPRA as necessary and prepares a final EA. Following preparation of these 

documents, APHIS approves or denies the petition, announcing in the Federal Register the 

regulatory status of the GE organism and the availability of APHIS' final EA, PPRA, National 

Environmental Policy (NEPA) decision document, and regulatory determination.

Enhancements to stakeholder input are described in more detail in the Federal Register notice7

published on March 6, 2012.

APHIS has determined that this EA will follow Approach 1. The issues discussed in this EA 

were developed by considering the public concerns, including public comments received in 

response to the Federal Register notice (77 F.R. 41364-6) announcing the availability of the 

petition (i.e., the first opportunity for public involvement previously described in this document), 

as well as issues noted in public comments submitted for other EAs of GE organisms, and 

concerns described in lawsuits and expressed by various stakeholders. These issues, including 

those regarding the agricultural production of corn using various production methods and the 

environmental and food/feed safety of GE plants, were addressed to analyze the potential 

environmental impacts of Monsanto 87427 corn.

The public comment period for MON 87427 corn petition closed on September 11, 2012. At its 

closing, the docket file contained a total of 102 docket records, reflecting a total of 23,698 public 

comments. These were screened and sorted into categories according to the subject matter 

addressed (e.g., air, water, soil impacts), and classified as either non-substantive or substantive. 

The majority of the comments were non-substantive and expressed a general dislike of the use of 

GE organisms or were form letters sent to all of the dockets which were open at the time that this 

docket was open. The form letter expressed a concern that there were too many dockets 

published on the same day. It also referenced other open dockets and potential effects from the 

use of the subjects of those petitions. These issues are outside the scope of this EA. Only 18 

comments were deemed substantive ones. From the substantive comments, the issues raised 

included:

7 This notice can be accessed at: http://www.gpo.gov/fdsys/pkg/FR-2012-03-06/pdf/2012-5364.pdf

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

• As another glyphosate resistant corn, additional use of glyphosate will increase glyphosate 

resistant weeds, requiring use of other herbicides, and weeds will develop resistance to these as 

well.

• Should not deregulate MON 87427 until the provider has obtained authorizations from key 

foreign markets prior to deregulation. 

• More glyphosate use will increase herbicide levels in air and water sources and affect biological 

organisms. Herbicides such as glyphosate increase soil pathogens and lead to diseases including

Fusarium wilt. 

• Gene flow of the resistance trait from cultivated plants to wild/weedy/feral relatives may occur.

• Cultivation of this crop may reduce organic production of corn, because cross-pollination will 

affect sensitive markets for organic growers. 

• Concerns that GE plants cause adverse health effects on humans and animals

APHIS evaluated these issues and provided citations and has included a discussion of these 

issues in this EA where appropriate.

1.6 Issues Considered

The list of resource areas considered in this EA were developed by APHIS through experience in 

considering public concerns and issues raised in public comments submitted for this petition and 

other EAs of GE organisms. The resource areas considered also address concerns raised in 

previous and unrelated lawsuits, as well as issues that have been raised by various stakeholders 

for this petition and in the past. The resource areas considered in this EA can be categorized as 

follows: 

Agricultural Production Considerations:

• Acreage and Areas of Corn Production

• Agronomic/Cropping Practices

• Corn Seed Production

Environmental Considerations:

• Soil Quality

• Water Resources

• Air Quality 

• Climate Change

• Animal Communities

• Plant Communities

• Microorganisms

• Biological Diversity

Human Health Considerations:

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

• Consumer Health

• Worker Safety

Livestock Health Considerations:

• Animal Feed/Livestock Health

Socioeconomic Considerations:

• Domestic Economic Environment 

• Organic Corn Production

• Trade Economic Environment

2 Affected environment

2.1 Agricultural Production of Corn

2.1.1 Acreage and Range of Commercial Corn Production

Corn (Zea mays L.), a member of the Maydeae grass family tribe, is an annual plant cultivated 

under a variety of production environments (Morris and Hill, 1998). In terms of acreage, corn 

ranks first among crops cultivated in the United States (USDA-NASS, 2012a). From 1991 to 

2011, acreage planted with corn increased from just over 76.0 million acres to about 91.9 million 

acres (Figure 1) Over that 20 year span, U.S. production of field corn for grain increased from 

approximately 7.5 billion bushels in 1991 to approximately 12.4 billion bushels in 2011, and 

average annual yield increased approximately 41 percent from 109 bushels per acre in 1991 to 

147 bushels per acre in 2011 (USDA-NASS, 2012e).

In the United States, corn may be cultivated where there is sufficient moisture (natural or 

irrigated) and frost-free days to reach maturity. The geographic range of corn production in the 

United States has been expanded by growing the crop under irrigation and breeding programs to 

increase drought and cold tolerance, shorten length of growing period, and improve disease and 

pest resistance (Neild and Newman, 1990; Hoeft et al., 2000; Corn and Soybean Digest, 2009; 

Carena, 2010). U.S. corn production is primarily focused in the Corn Belt, an area that 

represents approximately 80 percent of annual U.S. corn production and includes Iowa, Illinois, 

Nebraska, and Minnesota, and parts of Indiana, South Dakota, Kansas, Ohio, Wisconsin, and 

Missouri (Figure 1) (USDA-NASS, 2010). In general, the Corn Belt has an adequate 

combination of seasonal warm weather, rainfall, and favorable soil conditions for growth (Hoeft 

et al., 2000). While the Midwest typically experiences a minimum of 30 inches of rainfall 

annually, the central part of the Great Plains (~26 percent of U.S. corn production) receives an 

average of 20 inches, making it less optimal for corn production (Lew, 2004).

Seed Production Acreage

Although the focus of this EA is on MON 87427 which is a trait whose main importance is to 

hybrid seed production, seed production is dependent upon commercial corn needs. 

Consequently it is relevant to discuss the acreage trends in commercial corn. After an extended 

15
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

historical period of changing grower preferences dating from 1933, nearly all commercial corn 

production fields are planted with hybrid seed (USDA-APHIS, 2011a). Hybrid seed production 

may occur anywhere corn is typically cultivated, although the majority is generally produced in 

the Corn Belt due to ideal environmental conditions (Monsanto, 2010). Despite a general trend 

of increasing corn acreage, hybrid corn seed production has been fairly constant in the United 

States, totaling an approximate 0.5 - 1 million acres and 21 million bushels annually (Monsanto, 

2010; USDA-ERS, 2012c). Over the last 35 years, the volume of hybrid maize seed planted in 

the U.S. has changed very little, with 20.10 million bushels (MBu) planted in 1975 and 22.55 

MBu planted in 2009 (USDA-ERS, 2010). Grain yields have increased significantly over this 

same period (Figure 7).

Selection of a suitable growing area is a key decision for seed production. Factors such as 

temperature, rainfall, day length, and soil nutrient status are important because seed yields may

be sensitive to unfavorable conditions during particular periods (Monsanto, 2010). For example, 

extremely high temperatures and dry conditions can affect the timing of silk emergence and 

growth, pollen shed and pollen viability resulting in poor seed formation and yield. 

Climatic conditions in the U.S. Corn Belt are well suited for corn seed production and include 

the major Corn Belt states of Nebraska, Iowa, Illinois, and Indiana (McDonald and Copeland, 

1997). Only limited quantities of corn seed are produced in the southern states due to high 

temperatures during pollination, inadequate rainfall during the growing season, and a higher 

incidence of insects and diseases (Chad Peters, Monsanto Global Operations, personal 

communication, 2010). Corn seed is also not produced in the most northern portions of the corn

belt due to colder temperatures where the mean number of growing degree days accumulated

during the season may not be sufficient for corn to reach maturity prior to frost (Hoeft et al.,

2000a). Hybrid corn seed is typically harvested prior to damaging frost that can reduce seed 

viability (Wych, 1988).

Figure 1. U.S. corn production, planted acreage.

(A) U.S. corn planted for all purposes, 1991 – 2011. Source: USDA-NASS (2012e). (B) Corn planted 

for all purposes, 2011. Source: USDA-NASS (2012d). 

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

2.1.2 Agronomic Practices of Commercial Corn Production

Most of the corn produced in the United States is hybrid corn adapted to regional environmental 

and soil conditions. Generally, corn agronomic characteristics, such as optimal planting 

timeframe, disease and pest pressures, length of growing period, and water requirements, may 

vary by region (Neild and Newman, 1990; Hoeft et al., 2000; USDA-ERS, 2000; Koenning and 

Wiatrak, 2012). The majority of corn planted in the United States is GE. In 2011, GE corn 

varieties represented approximately 88 percent of U.S. planted acreage (USDA-ERS, 2011a). 

Among these planted GE corn varieties, herbicide-tolerant varieties accounted for 23 percent, 

insect-resistant varieties accounted for 16 percent, and stacked varieties totaled 49 percent 

(USDA-ERS, 2011a).

Agronomic practices associated with corn production include several crop management systems 

that are available to producers. Conventional farming covers a broad scope of farming practices, 

including farmers that may occasionally or regularly use synthetic fertilizers and pesticides. 

Conventional farming also includes the use of GE varieties that are no longer subject to the 

regulatory requirements of 7 CFR part 340 or the plant pest provisions of the Plant Protection 

Act. Organic systems exclude certain production methods, such as synthetic agricultural inputs

and GE crops. Organic systems are further discussed in Section 2.1.4. Although specific crop 

production practices vary according to region and end-use market, they commonly include 

tillage, crop rotation, agricultural inputs, and corn seed production. The following introduces the 

agronomic practices commonly employed to produce corn in the United States. More detailed 

information may be obtained by consulting the MON 87427 petition (Monsanto, 2010) or the 

APHIS PPRA for MON 87427 corn (USDA-APHIS, 2012). 

Tillage and Production of Commodity Corn

Tillage may be used to prepare a seedbed, address soil compaction, incorporate fertilizers and 

herbicides, manage water movement both within and out of a production field, control weeds, 

and reduce the incidence of insect pests and plant disease (Hoeft et al., 2000; Fawcett and 

Towery, 2002; Tacker et al., 2006; Givens et al., 2009; NRC, 2010). A variety of tillage systems 

accomplishes these goals. The choice to till is dependent upon a variety of factors, such as 

desired yields; soil type and moisture storage capacity; crop rotation pattern; prevalence of insect 

and weed pests; risk of soil compaction and erosion; and management and time constraints

(Hoeft et al., 2000).

Tillage systems are often defined by the amount of remaining in-field plant residue. Tillage may 

be characterized as conservation (> 30 percent plant residue), reduced (15-30 percent plant 

residue), or intensive (0-15 percent plant residue) (CTIC, 2008). Conservation tillage includes

no-till, ridge till, or mulch till practices (CTIC, 2008). The resulting plant residues associated 

with conservation tillage may contribute to the preservation of soil moisture and reduction of

wind and water-induced soil erosion (USDA-ERS, 1997; USDA-NRCS, 2005; Heatherly et al., 

2009). In general, despite variable adoption rates before 2001, use of conservation tillage, 

especially no-till practices, has increased in U.S. corn production at the expense of conventional 

tillage (Horowitz et al., 2010) (Figure 2). In 2010, the average residue remaining on the soil 

surface after planting corn was 34 percent and an average of 1.4 tillage operations per corn crop 

were conducted (USDA-ERS, 2011b). In 2010, 51 to 62 percent of planted corn acreage in 19 

17
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

surveyed states was dedicated to no-till or minimum till systems (USDA-NASS, 2011b; USDAERS, 2012b).

Tillage and Production of Hybrid Seed Corn

Planting conditions for hybrid maize seed production are generally the same as for the cultivation 

of commercial maize. A minimum soil temperature of 50°F is recommended for planting maize 

to achieve good germination and stands. Delayed emergence from colder soil conditions can 

result in damage from microorganisms and insects. Foundation seed will generally not be among 

the first corn planted mainly because colder soil temperatures may result in non-uniform 

emergence of inbred lines and a risk of frost damage. Medium-textured, well-drained soils with 

high water-holding capacities are ideal for commercial maize and maize seed production (Hoeft 

et al., 2000a; Hoeft, et al., 2000b; a). Sandy soils are less desirable because of their low waterholding capacities, but are suitable if adequate rainfall or irrigation is available during the 

growing season. Fields with non-uniform soil conditions may result in variable growth and 

variable timing of pollination and silk emergence (Chad Peters, Monsanto Global Operations, 

personal communication, Monsanto Company, 2010). Conservation tillage is most commonly 

used in maize seed production (C. Peters, Monsanto, Global Operations, personal 

communication, 2010). No-till is seldom practiced in maize seed production due to poor 

emergence and growth of the inbred lines, plus higher incidence of insect pests and diseases. 

Soils tend to stay colder and wetter longer in the spring under no-till systems which are less 

favorable for maize production (McDonald and Copeland, 1997).). When tillage is used for weed 

control, growers may use rotary hoes and cultivators (Bennett, nd.)

Figure 2. Adoption rates of three major tillage types in U.S. corn production, 1996 – 2010.

Sources: USDA-ERS (2012b).

0

10

20

30

40

50

60

1996 1997 1998 1999 2000 2001 2005 2010

Tillage strategy - % U.S. corn acreage

Year

Conservation Tillage Reduced Tillage Intensive (Conventional Tillage)

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Crop Rotation in Commodity Corn Production

In order to sustain productivity of an agricultural field and/or maximize economic return, corn 

growers may implement various crop rotation strategies (Hoeft et al., 2000). Crop rotation may 

be used to optimize soil nutrition and fertility, and reduce weeds, insects, and disease problems

(Olson and Sander, 1988). Additionally, crop rotation may also include fallow periods, or 

sowing with cover crops to prevent soil erosion and to provide livestock forage between cash 

crops (Hoeft et al., 2000; USDA-NRCS, 2010).

Crops used in rotation with corn vary regionally in the United States and may include oats, 

peanut, soybean, wheat, rye, and forage (USDA-APHIS, 2011c). In 2010, 71 percent of corn 

acreage in 19 surveyed states was under some form of rotation (USDA-NASS, 2011b). Cropland 

used for corn and soybean production is nearly identical in many areas, where over 90 percent of 

the cropped area is planted in a two-year corn-soybean rotation (Hoeft et al., 2000). Recently, 

there has been an increase in continuous corn rotations due to high corn commodity prices and 

the strong demand for corn grain (USDA-ERS, 2011c). Continuous corn rotations generally 

require more fertilizer treatments to replace diminished soil nitrogen levels and more pesticide 

applications (Bernick, 2007; Laws, 2007; Erickson and Alexander, 2008).

Crop Rotation in Hybrid Seed Production

Since most hybrid seed is produced in the maize belt, a two-year rotation of maize/soybean is the 

most widely used crop rotation (Monsanto, 2010). Wheat could be added to the rotation or 

replace soybean in the cropping sequence, particularly in the western maize belt. Although seed 

producers prefer not to plant maize following maize, it is necessary in some areas (NE and MI) 

or situations because of the limited soybean acres or other crops available on the farm for 

rotation (Chad Peters, Monsanto Global Operations, personal communication, 2010). Planting 

maize following maize can result in a higher incidence of diseases, increase nutrient 

requirements and make management of volunteer maize plants more difficult and expensive.

Fertilization in Commodity Corn Production

Given the importance of nutrient availability to corn agronomic performance, fertilization is 

widely practiced in order to maximize corn grain yield (Hoeft et al., 2000). Soil and foliar 

macronutrient applications to corn primarily include nitrogen, phosphorous (phosphate), 

potassium (potash), calcium, and sulfur, with other micronutrient supplements such as zinc, iron, 

and magnesium applied as needed (Espinoza and Ross, 2006). A 2010 survey of 19 corn 

producing states conducted by the USDA National Agricultural Statistics Service (USDANASS) found that nitrogen was the most widely used fertilizer on corn, applied to 97 percent of 

planted acres at an average rate of 140 pounds per acre (lb/Ac) (USDA-NASS, 2011b). 

Macronutrient phosphate was applied at an average rate of 60 lb/Ac to 78 percent of planted corn 

and potash was applied to 61 percent of planted acres at the rate of 79 lb/Ac. The survey found 

that sulfur was applied less extensively at a rate of 13 lb/Ac to 15 percent of acres planted to corn 

(USDA-NASS, 2011b).

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Fertilization in Hybrid Seed Production

Nutrient requirements for hybrid maize seed production are generally the same as for the 

cultivation of commercial maize. Nutrient management programs include the addition of 

nitrogen, phosphorus and potassium fertilizer to optimize maize yields and profitability. Soil 

tests are used to measure pH and the levels of phosphorus and potassium. Soil pH affects nutrient 

availability and should be maintained at or above 6.0 for maximum maize yields (Hoeft et al., 

2000). Supplemental nitrogen requirements for the crop year may be based on soil tests or 

calculated from target yields (Hoeft et al., 2000). Deficiencies in secondary nutrients (calcium, 

magnesium, and sulfur) or micronutrients (boron, chloride, copper, iron, manganese, 

molybdenum, and zinc) are uncommon but can result in yield reduction unless corrected with 

supplemental nutrient applications (Hoeft et al., 2000).

Other Production Practices for Hybrid Seed Corn: Density, Isolation, Parental Inbred Delay

Just as the optimum seeding rate and subsequent plant population in commercial maize is 

specific to each hybrid, so also for inbred lines in hybrid seed production (Chad Peters, 

Monsanto Global Operations, personal communication, 2010 in (Monsanto-Co., 2010). Seeding 

rates for male and female parent inbreds planted in 30-inch row spacing are generally the same 

and are specified by seed companies (Chad Peters, Monsanto Global Operations, personal 

communication, 2010 (Monsanto-Co., 2010). Male and female parent inbreds may be planted at 

different populations, though, with the female parent inbred population typically being higher 

than the male parent inbred population. There has been considerable interest in recent years in 

narrower row spacing in maize seed production (Chad Peters, Monsanto Global Operations, 

personal communication, 2010 in Monsanto, 2010). Narrowing the row spacing from 30 inches 

can result in better distribution and spacing of maize plants for greater light penetration and less 

evaporation of water from the soil, to provide higher plant populations with no yield loss 

(Abendroth and Elmore, 2006).

In maize hybrid seed production, the male and female parent inbreds are physically separated to 

control pollination within the field. The male inbred parent can be double planted to extend the 

pollen shedding period, so that the timing of peak pollen shedding coincides with the timing of 

peak silk exposure (Monsanto, 2010). Planting patterns in seed production fields include 4:1 

(four rows of female parent inbred to one row of male parent inbred), 4:2, 4:1:2:1, 6:2, and solid 

female parent inbred with interplanted male parent inbred (Monsanto-Co., 2010)). The female 

parent inbred is never more than two rows from the male parent inbred in the first three patterns 

(Monsanto-Co., 2010). One half of the female parent inbred rows are adjacent to a male parent 

inbred in the 4:1 and 4:2 patterns, and two-thirds of the female parent inbred rows are adjacent to 

a male parent inbred in the 4:1:2:1 pattern. The 6:2 pattern has been used for production of 

doublecross hybrids, and for the production of single cross hybrids with male parent inbreds that 

shed an abundant supply of pollen. A planting pattern where every other or every fourth 

between-row space of a solid planted female parent inbred is interplanted with the male parent 

inbred fully utilizes the land area for female parent inbred production and achieves closer 

placement of the male and female parent inbreds (Craig (Craig, 1977)Wych (Wych, 1988).

Hybrid maize seed production plots are isolated from neighboring maize fields to avoid 

inadvertent cross-pollination during the flowering stage by wind-borne pollen (Monsanto, 2010). 

20
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Physical isolation is used because temporal isolation is difficult to manage and would require the 

flowering time of the male and female parent inbreds to occur in synchrony, yet independently 

from the flowering times of other nearby maize. The isolation distance from other maize is 

regulated by seed certification standards, and is typically at least 660 feet from other maize 

(AOSCA, 2009). Planting additional male parent inbred border rows around the perimeter of the 

seed production plots increases desirable pollen shed from the male parent inbred during silking 

of the female parent inbred, and reduces the potential for contamination from external pollen 

sources. Other rows can be composed of varieties which shed pollen out of synchrony with the 

recipient female lines (Bennett, N.D.).Official seed certification regulations often allow 

isolation distances between seed production fields to be reduced as the number of male parent 

inbred border rows increases (Agrawal et al., 1998).

Various parent delay techniques can be used to synchronize the flowering of male and female 

parent inbreds that would otherwise occur at different times (Monsanto-Co., 2010). Split-date 

planting is the most common of these techniques, where the male and female parent inbreds are 

planted at different times, based on a combination of the number of days, growth stages, and heat 

units accumulated from the date when the first parent was planted (Wych, 1988). In addition, 

the pollen-shedding period may be extended by planting the male parent inbred at two or more 

dates. Plantings are timed so that peak pollen shed coincides with maximum female parent 

inbred silk exposure. Special techniques are also available to manipulate the flowering dates of 

one or both of the seed parents (Wych, 1988). These techniques can delay flowering or extend 

the duration of flowering by days (Monsanto-Co., 2010). The timing of flowering of the 

second-planted seed parent may be advanced by varying planting depth or fertilization rate. The 

flowering date of the first-planted parent can be delayed using techniques that involve burning 

off the above-ground leaves and stalk of young plants, or cutting off the tops of the plants. These 

techniques are rarely used to delay the female parent inbred because they typically result in 

reduced seed yield.

Pesticide Use in Commodity Corn Production

Pest management is an integral part of any corn production system and is used to maintain yield 

and quality of the grain. Corn pests may include microbes (e.g., nematodes, fungi, or bacterial), 

insects, or weeds. Corn pest management strategies are often dependent on the corn variety 

cultivated. Fungicides, insecticides, and herbicides are the primary herbicides applied on U.S. 

corn acres (USDA-NASS, 2011b). Relative to herbicide use, fungicide and insecticide use is 

relatively minor (Figure 3).

Corn diseases may also require management by some U.S. corn growers (Cartwright et al., 

2006). The most common corn pathogens are fungi. In 2010, fungicides were applied to 8.0 

percent of acres planted to corn in 19 survey states (USDA-NASS, 2011b). Also in 2010, the 

most commonly applied fungicides in U.S. corn were pryaclostrobin (382,000 lbs. covering 51 

percent of corn acreage), propiconazole (174,000 lbs. covering 24 percent of corn acreage), and 

azoxystrobin (102,000 lbs. covering 14 percent of corn acres) (USDA-NASS, 2012b).

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

 Figure 3. Percent of U.S. corn acreage treated with pesticides, 2010.

 *Less than 0.5 percent. Source: USDA-NASS (2011b). 

Corn is subject to insect pests throughout its development, with several groups and types of 

insects capable of feeding on the seeds, roots, stalk, leaf, or ears (Hoeft et al., 2000)In 2010, 

insecticide active ingredients were applied to 12 percent of acres planted to corn in 19 surveyed 

states (USDA-NASS, 2011b). Tefluthrin was the most commonly-applied insecticide on U.S. 

corn, with 242,000 lbs. used over 3 percent of corn acreage (USDA-NASS, 2012c). The next 

most-commonly used insecticides, each sprayed on approximately 2 percent of U.S. corn 

acreage, included bifenthrin (68,000 lbs.), cyfluthrin (15,000 lbs.), lambda-cyhalothrin (24,000

lbs.), and tebupirimphos (195,000 lbs.) (USDA-NASS, 2012c). Chlorpyrifos was the most 

abundant insecticide applied in terms of lbs. of active ingredient, though it was only applied on 

1 percent of U.S. corn acreage (USDA-NASS, 2012c). 

Weed management is an integral component of any corn production system. If weeds in a corn 

field are left unmanaged, grain yield may be reduced as much as 50 percent (Smith and Scott, 

2006). The management of weeds in corn production generally involves the application of 

herbicides. Individual weed species, including glyphosate-resistant species, are discussed in 

Section 2.3.2. In 2010, 98 percent of all U.S. corn acreage was subject to herbicide application8

(USDA-NASS, 2011b). The most commonly applied herbicide in corn was glyphosate, with 

approximately 58,000,000 lbs. applied over 66 percent of all planted corn acreage in 2010

(USDA-NASS, 2011b). The use of glyphosate in U.S. corn production has increased since 1994, 

a trend associated with the increasing adoption of herbicide-tolerant [primarily glyphosatetolerant] corn varieties (Figure 4). Other commonly applied herbicides on U.S. corn acres 

include atrazine (51,000,000 lbs. covering 61 percent of corn acreage) and acetochlor 

(28,000,000 lbs. covering 25 percent of corn acreage) (USDA-NASS, 2011b).

8 As measured by total pounds of active ingredient per acre (lbs. ai/acre) applied.

0 20 40 60 80 100

Herbicides

Insecticides

Fungicides

Other*

Percent of corn acres treated

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Figure 4. Adoption of GE corn varieties with at least one herbicide-tolerant trait and glyphosate in U.S. corn 

production, 1994 – 2010. 

Source: USDA-ERS (2011a) and USDA-NASS (1996; 2002; 2006; 2011b).

Pesticide Use in Hybrid Seed Corn Production

As earlier noted, inbreds used in corn seed production are not all glyphosate resistant (usually 

only one of the parental crosses (Monsanto, 2010)). The simplified procedures favored by 

growers allowing only glyphosate for preplant as well as postemergence weed control is 

consequently not possible in these hybrid crosses. At least five post-emergence herbicides are 

labeled for use in postemergence application to seed corn including dicamba, bromoxynil, 

carfentazone-ethyl, primisulfuron and nicosulfuron often in specialized formulations or as 

premixes with other herbicides such as atrazine (Iowa-State-University, 2005). Tillage may also 

be used in addition or alternatively for weed control on acreage used in seed production (Bennett, 

nd).

2.1.3 Hybrid Corn Seed Production: Pollen Control

In contrast to other agricultural crops, nearly all commercial corn production fields are planted 

with hybrid seed (USDA-APHIS, 2011a). Hybrid seed production9 may occur anywhere corn is 

typically cultivated, although the majority is generally produced in the Corn Belt due to ideal 

environmental conditions (Monsanto, 2010). Despite a general trend of increasing corn acreage, 

hybrid corn seed production has been fairly constant in the United States, totaling an 

approximate 0.5 - 1 million acres and 21 million bushels annually (Monsanto, 2010; USDAERS, 2012c).

Hybridization is a fundamental principle of U.S. corn breeding and production programs, 

supplying the majority of seed for commercial maize grain production (Wych, 1988). Hybrid 

corn seed production requires the use of two corn inbred parent lines, one designated as the 

female inbred (pollen receiver) and the other designated as the male inbred (pollen donor). In 

9 For the purpose of this EA, hybrid production is synonymous with single cross hybrid production.

0

20

40

60

80

1994 2001 2005 2010

Percent of U.S. corn acreage

Year

GE adoption

Glyphosate use

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

general, female inbred and male inbred corn plans are interplanted in a corn seed production 

field, using a variety of time-tested measures to ensure temporal and spatial isolation (these 

measures are further discussed in Section 2.3). At its core, hybrid corn production utilizes 

heterosis10 (i.e., hybrid vigor), resulting from the crossing of a male inbred with a female inbred, 

to overcome general reductions in vigor related to the fixation of alleles in parental corn inbred 

lines (Duvick, 2001). 

Pollination Control. 

Some mechanism to prevent pollination of female inbred plants prior to anthesis11 is necessary to 

limit self-fertilization, due to the monoecious nature of maize, and ensure effective cross 

pollination with male inbred plants (Figure 5). To ensure complete pollination of female parent 

inbreds by male parent inbreds to produce the desired hybrid maize seed, the type of pollen 

reaching the female silks must be controlled (Monsanto, 2010). Pollen control in hybrid maize 

seed production is critical for producing hybrid maize seed with high purity of the background 

genetics. The first strategy for controlling pollination is comprised in large measure by planting 

patterns, but additional methods are also required. A number of these methods are described

below, including the two most common production methods of detasseling and cytoplasmic male 

sterility (Craig, 1977; Wych, 1988). Chemical hybridization agents (male gametocides) have also 

been developed for pollen control, but their use is severely limited due to off target effects 

(Loussaert, 2004).

Figure 5. Pollen movement: open and hybrid

10 Heterosis is the improvement of an organism’s biological attributes through hybridization. In the case of maize 

hybridization, grain yield is generally the target attribute of heterosis.

11 Pollen shed.

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Pollen movement (arrows) compared between corn during open pollination and tasseled (inbred male) 

and detasseled plants (inbred female) typical of hybrid corn seed production systems. Figure is derived 

from BIOfortified (2010).

Detasseling. Detasseling is the most widely used method of pollen control in the production of 

hybrid maize seed (Monsanto-Co., 2010). Tassels are physically removed from female parent 

inbred maize before undergoing pollen shed or silk emergence. Removal of all of the tassels 

from the female parent inbred avoids self-fertilization of silks by the pollen that could have been 

produced from this genetic line. Instead, fertilization of the detasseled female parent inbred is

achieved by pollination from a male parent inbred with different background genetics that is 

grown in close proximity. The window for detasseling averages 3-4 days, and occurs between 

tassel emergence from the leaf sheath and the initiation of pollen shedding (Hoeft et al., 2000).

Pollen shed usually occurs in corn over a 5-8 day period with the peak production on about the 

third day (Hoeft et al., 2000). Pollen shed is not always a continuous process, and can stop and 

restart depending on climatic conditions or when additional pollen has matured (Hoeft et al., 

2000). As a result, the window for detasseling that averages 3-4 days prior to the initiation of 

pollen shed is a critical step in corn seed production that, once begun, must be performed on a 

regular basis, regardless of weather (Monsanto-Co., 2010). Removal of the tassel from the 

female parent inbred in seed production fields is accomplished by a combination of mechanical 

and manual detasseling methods (Wych, 1988). Mechanical detasseling methods came into 

widespread use in the 1970s as a way to better control rising production costs that resulted from 

increasing labor costs and a declining labor supply (Craig, 1977).

Mechanical detasseling machines either cut or pull the tassels from the corn in all the female 

parent inbred rows (Monsanto, 2010). Mechanical "cutters" use a rotating blade or knife (similar 

to a lawnmower) to remove the top of the maize plant and tassel. In a second step performed a 

few days later, mechanical "pullers" which are complementary to cutters are sent through the 

seed production fields. The pullers use two counter-rotating wheels or rollers to grasp and 

remove the tassel and upper leaves. Mechanical detasseling is delayed as long as possible before 

silk emergence, to permit maximum exsertion of tassels and enable their removal with minimum 

leaf damage (Monsanto, 2010). Best results are achieved in a uniform seed field in which the 

tassels are well exserted ahead of pollen shedding. As conditions become less favorable, the 

percentage of tassels removed per pass will decrease and leaf damage will increase. Removal of 

the entire tassel can result in the removal of too much leaf tissue, and reduce corn seed yields by 

as much as 10% (McDonald and Copeland, 1997). In addition, the tassels that have been 

removed can become lodged in the leaf canopy and shed pollen, resulting in unwanted selfpollination (Monsanto, 2010). This complication is resolved by hand detasseling crews. Crews 

detassel by hand any corn that was not completely detasseled with the mechanical methods.

Although detasseling is relatively straightforward to accomplish, the production of hybrid

maize seed is expensive and labor-intensive (Monsanto, 2010). It employs tens of thousands of 

teenage, migrant, and other agricultural workers each year to hand detassel maize in the U.S. 

(Monsanto, 2010). The large manual labor force is needed for only a relatively short period of 

time that may last from less than a week to many weeks depending upon the volume of 

production and the range in female parent inbred maturity dates planted within a seed production 

area (Monsanto, 2010). A detasseling operation is at risk from weather such as heavy rain or 

windstorms that can lodge or tangle the female parent inbreds just as the tassels begin to emerge, 

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

making it difficult to walk or drive through the field. Extreme heat or drought during the onset of

flowering can delay the emergence of tassels and silks. Seed fields need to be monitored and 

inspected closely during the detasseling period, as even a slight mistake can have considerable 

economic consequences. The labor force must be well trained, closely supervised, and 

effectively managed. This is complicated because of the reliance on temporary seasonal workers. 

Increasing wage rates and changing population demographics (labor supply and its distribution) 

are two factors that pose challenges to the industry. Liability and worker safety issues associated 

with employing temporary manual labor are also important considerations.

Field inspections are conducted throughout the pollination and detasseling period to measure the 

progress of the male pollination and female silk emergence, to ensure that female parent inbreds 

are not shedding pollen or self-pollinating, and to evaluate the effectiveness of the detasseling 

operations (Monsanto, 2010). Genetic purity of intended crosses is dependent on compliance 

with quality standards that certifying agencies have established when the female parent inbred 

has 5% receptive silks (silks emerged and turgid), which includes a limit of 1% shedding tassels 

in the female parent inbred at any one inspection and a total of 2% shedding tassels for three 

inspections at different dates, plus a limit of 0.1% male off-types at any inspection (AOSCA, 

2009). Tassels are counted as shedding when more than 2 inches of the central spike and/or side 

branches have emerged and have shedding anthers (AOSCA, 2009). Manual and/or mechanical 

removal of female inbred tassels (i.e., detasseling) is used to reduce or eliminate self-fertilization 

on the majority of hybrid corn seed production fields (Monsanto, 2010). However, manual/ 

mechanical detasseling requires exact timing (3-4 day time window) and is expensive, ranging 

between $280 and $350 an acre (USDA-APHIS, 2011a).

Genetic Sterility. Cytoplasmic male sterility (CMS) is a genetic method that was widely 

adopted in the U.S. in the 1950s and 1960s as a means to eliminate pollen from the female parent 

inbred without the need of manual or mechanical detasseling (Ullstrup, 1972; Craig, 1977). The

genetics by which CMS functions is based on the presence of mitochondrial DNA genes that 

produce pollen sterility when dominant fertility restoration genes are absent in the nuclear DNA 

(Schnable and Wise, 1998), 1998). Pollen fertility is restored in the F1 hybrid maize seed 

produced from crossing this female parent inbred with a male parent inbred that possesses the 

dominant fertility restoration genes in its nuclear DNA. A number of CMS systems have been 

identified to facilitate the crossing of two inbreds, and include S-cms, C-cms and T-cms. With the 

T-cms system, detasseling is eliminated through the use of a female parent inbred that is 

completely male sterile. Unfortunately, this genotype also carries a hyper-susceptibility to 

Helminthosporium maydis race T that resulted in a virulent epidemic from southern maize leaf 

blight in U.S. maize in 1969-1970 (Ullstrup, 1972; Pring and Lonsdale, 1989). Continued use of 

this genotype was problematic because the male sterility trait was inseparable from H. maydis 

disease susceptibility (Levings and Siedow, 1992).

The C and S cytoplasms are not linked to disease susceptibility (Craig, 1977), and became 

important in the late 1970s as a cost-competitive and satisfactory technique for producing hybrid 

maize seed (Wych, 1988). Both the production of hybrid seed using CMS, and the cultivation of 

field maize from this hybrid maize seed are complicated. For example, C and S cytoplasms in 

certain genetic backgrounds result in only partial male sterility and still require some detasseling 

during the production of hybrid maize seed. Furthermore, the hybrid seed produced using CMS 

is typically blended with hybrid seed of the same genetic background that was produced without 

CMS, to ensure adequate pollination of the commercial maize grown from this hybrid seed.

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Because of the complexity of production using CMS systems, and increased plant susceptibility

to certain crop diseases CMS systems are used today in only 30% of hybrid maize seed 

production acres (Monsanto-Co., 2010).

Harvesting and Conditioning of Hybrid Maize Seed. Maize harvested for grain is almost 

entirely harvested and shelled with combines in the field. In contrast, hybrid maize seed is almost 

entirely harvested, and then dried, on the ear to minimize the amount of mechanical damage to 

the seed (Monsanto. 2010). The black layer that forms at the base of the seed at physiological 

maturity is an indication that maximum dry weight has been reached, and generally occurs when 

the seed has 30-38% moisture content (McDonald and Copeland, 1997). Freezing is a major 

concern to seed viability, and can be minimized by harvesting early when seed moisture content 

is high. This necessitates the need for artificial drying methods (McDonald and Copeland, 1997). 

The drying systems for maize seed are typically fan systems that force heated air through bins 

filled with maize seed on the ear. High-moisture seed is more sensitive to germination damage 

by heat than low-moisture seed, so the temperature is generally held below 95°F until 20% seed 

moisture content is achieved, and then the temperature can be increased to a maximum of 115°F. 

Seed is typically dried to a moisture content of 12-13% which is suitable for subsequent shelling 

and conditioning operations (McDonald and Copeland, 1997). Conditioning seed consists of 

three steps: 1) cleaning the seed to remove cob and kernel pieces, husks, silks, and other debris; 

2) separating the seed into sizes and shapes based on width, thickness and length; and 3) treating 

the seed with an insecticide or fungicide or both (McDonald and Copeland, 1997).

Seed Quality. Maintaining an adequate supply of the parental inbred lines is vital to producing 

an adequate supply of hybrid maize seed (Monsanto, 2010). Often referred to as foundation seed, 

parental inbred lines are produced and maintained under strict isolation in the production field to 

preserve the identity and integrity of the genetics within each inbred. Quality control checks 

performed during the production of inbreds include visual inspections of the plants grown in 

isolation, and the use of molecular tools to verify the genetics of each inbred line (Hoisington, et 

al., 1998). Hybrid maize seed is produced in the U.S. on approximately 0.5 million acres 

(Jugenheimer, 1976). Over the last 35 years, the volume of hybrid maize seed planted in the 

U.S. has changed very little, with 20.10 million bushels (MBu) planted in 1975 and 22.55 MBu 

planted in 2009 (USDA-ERS, 2010a). Grain yields have increased significantly over this same 

period (Figure 7).

Seed certification is based on varietal lineage, as well as quality production and processing 

standards. Seeds produced for sale to a crop grower (certified seeds) are a limited number of 

generations from a verified seed stock of the specified variety (Bradford, 2006) . The U.S. 

Federal Seed Act of 1939 recognizes seed certification and official certifying agencies. 

Implementing regulations further recognize land history, field isolation, and varietal purity 

standards for seed. Seed certification is important to ensure the high quality of corn seed and is 

accomplished by a wide range of programs which include field inspections and laboratory testing

(Bradford, 2006; AOSCA, n.d.-a). Various seed associations have standards to help maintain the 

quality of corn seed. New seed varieties are evaluated by review boards to determine if the 

varieties meet the eligibility requirements for certification. The Association of Official Seed 

Certifying Agencies (AOSCA, n.d.-b) defines the classes of seed as follows:

• Breeder seed is directly controlled by the plant breeder that developed the variety.

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• Foundation seed is the progeny of Breeder or Foundation seed that is handled to most 

nearly maintain specific genetic identity and purity.

• Registered seed is a progeny of Breeder or Foundation seed that is so handled as to 

maintain satisfactory genetic identity and purity.

• Certified seed is the progeny of Breeder, Foundation, or Registered seed that is so 

handled as to maintain satisfactory genetic identity and purity. 

2.1.4 Organic Corn Production

Organic maize typically commands a market premium relative to commodity maize to offset the 

additional production and record-keeping costs associated with this production method. In the 

U.S., only products produced using specific methods and certified under the USDA’s 

Agricultural Marketing Service (AMS) National Organic Program (NOP) definition of organic 

farming can be marketed and labeled as “organic” (USDA-AMS, 2010). Organic certification is 

a process-based certification, not a certification of the end product; the certification process 

specifies and audits the methods and procedures by which the product is produced.

In accordance with NOP, an accredited organic certifying agent conducts an annual review of the 

certified operation’s organic system plan and makes on-site inspections of the certified operation 

and its records. Organic growers must maintain records to show that production and handling 

procedures comply with USDA organic standards. 

The NOP regulations preclude the use of excluded methods. The NOP provides the following 

guidance under 7 CFR Section 205.105:

...to be sold or labeled as “100 percent organic”, “organic” or “made with organic 

(specified ingredients or group(s)),” the product must be produced and handled without 

the use of:...

(a) Synthetic substances and ingredients,...

(e) Excluded methods,...

Excluded methods are then defined at 7 CFR Section 205.2 as:

A variety of methods used to genetically modify organisms or influence their 

growth and development by means that are not possible under natural conditions 

or processes and are not considered compatible with organic production. Such 

methods include cell fusion, microencapsulation and macroencapsulation, and 

recombinant DNA technology (including gene deletion, gene doubling, 

introducing a foreign gene, and changing the positions of genes when achieved 

by recombinant DNA technology). Such methods do not include the use of 

traditional breeding, conjugation, fermentation, hybridization, in vitro 

fertilization, or tissue culture.

Organic farming operations, as described by the NOP, are required to have distinct, defined 

boundaries and buffer zones to prevent unintended contact with excluded methods from 

adjoining land that is not under organic management. Organic production operations must also 

develop and maintain an organic production system plan approved by their accredited certifying 

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agent. This plan enables the production operation to achieve and document compliance with the 

National Organic Standards, including the prohibition on the use of excluded methods (USDAAMS, 2010).

The use of biotechnology such as that used to produce MON 87427 is an excluded method under 

the National Organic Program [7 C.F.R. § 205.2]. Common practices organic growers may use 

to exclude GE products include planting only organic seed, planting earlier or later than 

neighboring farmers who may be using GE crops so that the crops will flower at different times, 

and employing adequate isolation distances between the organic fields and the fields of 

neighbors to minimize the chance that pollen will be carried between the fields (NCAT, 2003). 

Buyers recognize that when biotechnology-derived crop varieties are on the market, as with 

maize, a guarantee that a commodity crop is 100% “free” of biotechnology-derived material is 

not feasible based on the limitations of testing and sampling methodology and there are some 

specifications in buyer allowances that permit between 0.1 to 5% biotechnology-derived maize 

in organic maize (Born, 2005). International regulatory authorities have recognized that testing 

and sampling methodologies limit the ability to confirm that commodity or specialty maize is 

100% free of biotechnology-derived material. Thus, they have set allowable tolerances for 

biotechnology-derived material in conventional products to support food labeling and traceability 

laws. These tolerances allow from 0.9% (European Union) up to 5% (Japan) of the food or food 

ingredients to be biotechnology-derived in products considered “conventional.” Levels above the 

threshold may trigger special labeling.

Although the National Organic Standards prohibit the use of excluded methods, they do not 

require testing of inputs or products for the presence of excluded methods. The presence of a 

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

violation of the National Organic Standards (USDA-AMS, 2010). The current NOP regulations 

do not specify an acceptable threshold level for the adventitious presence of GE materials in an 

organic-labeled product. The unintentional presence of the products of excluded methods will 

not affect the status of an organic product or operation when the operation has not used excluded 

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

as detailed in their approved organic system plan (Ronald and Fouce, 2006; USDA-AMS, 2010). 

In 2008, USDA Economic Research Services (USDA-ERS) reported that 194,637 acres out of a 

total 93.5 million acres (0.21 percent) planted corn acres were certified organic (USDA-ERS, 

2010b). Wisconsin, Iowa, Minnesota, Michigan, New York, Texas, and Nebraska each had more 

than 10,000 acres of certified organic corn, totaling approximately 68 percent of all certified 

organic acreage in the U.S. (Table 1). Generally, acreage increased from 2007 to 2008, 

although, in some instances, certain states showed a decrease in the number of certified organic

corn acres. The most recent survey showed that total acres of organic corn have declined from 

earlier surveys, although a few states have shown increased plantings.

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Table 1: Certified organic corn acreage by state with more than 1,000 acres of certified land in 2007 and 

2008. 

State

Acreage

State

Acreage

2007 2008 2011 2007 2008 2011

California 1,305 2,765 1,370 New Mexico 2,700 1,552 NA

Colorado 2,445 3,043 887 New York 11,909 11,459 13,150

Illinois 7,319 8,739 6,983 North Dakota 3,292 4,761 1,194

Indiana 2,414 2,998 1,502 Ohio 8,786 8,969 6,899

Iowa 24,944 25,419 18,984 Oregon 1,072 1,712 2,734

Kansas 2,067 4,637 3,688 Pennsylvania 4,482 5,918 3,262

Maine 1,025 1,237 310 South Dakota 5,779 5,564 4,410

Maryland 1,009 1,239 1,568 Texas 7,710 11,202 1,109

Michigan 12,722 12,663 13,266 Virginia 1,286 1,472 289

Minnesota 26,849 27,565 20,432 Washington 1,970 2,265 1,266

Missouri 7,144 3,765 13,226 Wisconsin 27,431 33,619 20,059

Nebraska 12,226 10,568 9,111 U.S. Total 170,905 193,637 134,877

Source: USDA-ERS (2010b) and (USDA-NASS, 2012f).

2.2 Physical Environment

2.2.1 Soil Quality

Cultivation of corn directly impacts the qualitative and quantitative attributes of soil. For 

example, conventional tillage and mechanized harvesting machinery may disturb and expose the 

top soil surface layer, leaving the land prone to degradation. Similarly, use of detasseling 

equipement and vehicles, especially when deployed in wet fields can cause soil compaction. In 

turn, degradation of soil structure and composition may lead to decreased water retention, a 

decrease in soil carbon aggregation and net positive carbon sequestration, and increased emission 

of radiatively-active gases that contribute to the greenhouse effect (e.g., carbon dioxide (CO2) 

and nitrous oxide (N2O)) (Lal and Bruce, 1999; EPA, 2010b). Additionally, land that is prone to 

degradation is also more likely to negatively affect water resource quality and communities of 

organisms dependent on those water resources.

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2.2.2 Water Resources

Corn cultivation may directly affect water resources through the use of local water sources or 

indirectly through associated management practices, including tillage and the use of agricultural 

inputs. Corn requires a steady supply of moisture, totaling approximately 4,000 gallons through

the growing season to produce one bushel of grain (NCGA, 2007). This demand is met by a 

combination of natural rainfall, stored soil moisture from precipitation before the growing 

season, and supplemental irrigation during the growing season (Neild and Newman, 1990). 

Groundwater is the major source for irrigation, used on almost 90 percent of irrigated corn 

acreage in the United States. (Christensen, 2002). In 2007, 13.0 million U.S. corn acres were 

irrigated, reflecting 15 percent of all corn acres harvested for grain (USDA, 2008).

Agricultural non-point source (NPS) pollution is the primary source of discharge pollutants to 

groundwater (aquifers), flowing water (permanent or intermittent streams), or semi-static water 

(ponds, lakes, and reservoirs) (Ramanarayanan et al., 2005). NPS pollutants generally include 

agricultural inputs, such as fertilizers or pesticides. Although meteorological (e.g., precipitation, 

temperature), morphological (e.g., land use, soil type), and environmental fate drivers affect 

water quality, anthropogenic practices (product use and management) are the most relevant, as 

this driver is generally under direct grower control on a corn farm (Ramanarayanan et al., 2005). 

In particular, tillage practices often have a strong, indirect effect on water quality through the 

improvement of soil quality and water retention characteristics. Agricultural pollutants released 

by soil erosion include sediments, fertilizers, and pesticides that are introduced to area lakes and 

streams when they are carried off of fields by rain or irrigation waters (EPA, 2005).

2.2.3 Air Quality

Agriculture, including land-use changes for farming, is estimated to be responsible for eight

percent of all human-induced greenhouse gases (GHG) emissions in the U.S. (Massey and 

Ulmer, 2010). Many agricultural activities affect air quality, including smoke from agricultural 

burning, machinery, and N2O emissions from the use of nitrogen fertilizer (Hoeft et al., 2000; 

Aneja et al., 2009; EPA, 2010a). Emissions released from agricultural equipment (e.g., irrigation 

pumps and tractors) include carbon monoxide, nitrogen oxides, reactive organic gases, 

particulate matter, and sulfur oxides (EPA, 2010a). Tillage contributes to the release of GHGs

because of the loss of CO2 to the atmosphere and the exposure and oxidation of soil organic 

matter (Baker et al., 2005a). Pesticides may volatilize after application to soil or plant surfaces 

and move following wind erosion (Vogel et al., 2008).

2.2.4 Climate Change

Climate change represents a statistical change in global climate conditions, including shifts in the 

frequency of extreme weather (Cook et al., 2008; Karl et al., 2008). Agriculture is recognized as 

a direct (e.g., exhaust from equipment) and indirect (e.g., agricultural-related soil disturbance) 

source of GHG emissions. Greenhouse gases, including CO2, methane (CH4), and N2O, function 

as retainers of solar radiation (Aneja et al., 2009). The U.S. agricultural sector is identified as the 

second largest contributor to GHG emissions (EPA, 2010a).

Agriculture may also affect dynamic soil processes through tillage and other land management 

practices (Smith and Conen, 2004). In general, conservation tillage strategies are associated with 

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more stable and increased carbon sequestration due to a net reduction in carbon dioxide 

emissions (Lal and Bruce, 1999; West and Marland, 2002). Recent literature, however, suggests 

that the relationship between conservation tillage and increased carbon sequestration require 

more study, as soil depth level and seasonal sampling bias may inadvertently affect

measurements (Potter et al., 1998; Baker et al., 2007). Additionally, the relationship between 

different GHG emissions, such as carbon dioxide and nitrous oxide may influence paradigms 

related to tillage strategies and global climate change (Gregorich et al., 2005). For example, 

increased nitrous oxide emissions as a result of conservation tillage strategies may offset any 

gains achieved through increased carbon sequestration. Like the relationship between 

conservation tillage strategies and carbon sequestration, a broad generalization regarding the 

impact of tillage strategy and nitrous oxide emissions is difficult, as numerous factors influence 

soil nitrification cycles, including geographic location, soil structure, moisture, and farm-level 

management practices (Gregorich et al., 2005; Grandy et al., 2006; Rochette et al., 2008). 

Global climate change may also affect agricultural crop production (CCSP, 2008). These 

potential impacts on the agro-environment and individual crops may be direct, including 

changing patterns in precipitation, temperature, and duration of growing season, or may cause 

indirect impacts influencing weed and pest pressure (Rosenzweig et al., 2001; Schmidhuber and 

Tubiello, 2007). The impacts of GE crop varieties on climate change are unclear, though it is 

likely dependent on cropping systems, production practices, geographic distribution of activities, 

and individual grower decisions. APHIS will continue to monitor developments that may lead to 

possible changes in the typical production system likely to result from GE products brought to 

APHIS for a determination of nonregulated status. The potential impact of climate change on 

agricultural output, however, has been examined in more detail. A recent Intergovernmental 

Panel on Climate Change (IPCC) forecast (2007) for aggregate North American impacts on 

agriculture from climate change actually projects yield increases of 5 to 20 percent for this 

century. The IPCC report notes that certain regions of the U.S. will be more heavily impacted 

because water resources may be substantially reduced. While agricultural impacts on existing 

crops may be substantial, North American production is expected to adapt with improved 

cultivars and responsive farm management (IPCC, 2007).

2.3 Biological Resources

2.3.1 Animal Communities

Hybrid seed corn is produced in a subset of U.S. states, particularly central corn belt states of

Nebraska, Iowa, Illinois, and Indiana (McDonald and Copeland, 1997).. As a result, an array of 

wildlife species (invertebrate and vertebrate species) may occupy corn fields or habitats adjacent 

to corn fields. Adjacent habitats may include agricultural crop land, pasture, or woodland. 

However, corn fields are intensely cultivated lands that provide less suitable habitat for wildlife 

than non-cultivated lands.

Invertebrates, such as corn earworm (Helicoverpa zea), European corn borer (Ostrinia nubilalis), 

fall armyworm (Spodoptera frugiperda), and the corn rootworm (Diabrotica spp.) are important 

insect pests in corn. Many insects are also considered beneficial (Hoeft et al., 2000). Insects 

such as the lady beetle (Coccinellidae), big-eyed bug (Lygaeidae), ground beetle (Carabidae),

lacewing (Chrysopidae), damsel bug (Nabidae), insidious flower bug/minute pirate bug 

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(Anthocoridae), assassin bug (Triatominae), spined soldier bug (Pentatomidae), and parasitoid 

wasps (e.g., Braconidae, Ichneumonidae), as well as a multitude of spiders (Order: Araneae) may 

benefit corn production by preying on plant pests (Stewart et al., 2007; Iowa State University, 

n.d.). Other soil dwelling fauna such as earthworms and arthropods play critical roles in the 

aeration and turn-over of soil, processing of wastes and detritus, and nutrient cycling (USDANRCS, 2004; ATTRA, n.d.).

A few species may directly utilize corn grain or leaves orstems for food. Bird species that have 

been observed in row crop fields include, among others, blackbirds (e.g., red-winged blackbirds 

(Agelaius phoeniceus)), horned larks (Eremophila alpestris), brown-headed cowbirds (Molothrus 

ater), and vesper sparrows (Pooecetes gramineus) (Best and Gionfriddo, 1991). Specific bird 

species can act as beneficial or detrimental members in the agro-environment. For example, redwinged blackbird are often initially attracted to corn fields to feed on insect pests, but then also 

feed on the corn. Studies have shown that red-winged blackbirds can destroy more than 360,000 

tons of field corn and substantial amounts of sweet corn annually (Dolbeer, 1990). 

A variety of mammals may also be attracted to corn fields for nutrition. Deer (Odocoileus 

virginianus), raccoons (Procyon lotor), meadow voles (Microtus pennsylvanicus), and the 

thirteen-lined ground squirrel (Ictidomys tridecemlineatus) may all cause damage to corn fields, 

decreasing profitability and grain yield (Vercauteren and Hygnstrom, 1993; Neilsen, 1995; 

Sterner et al., 2003; Smith, 2005; Beasley and Rhodes, 2008; Koele, 2008). 

2.3.2 Plant Communities

The vegetative landscape surrounding a corn field varies with region; corn fields may be 

surrounded by additional soybean varieties, other crops, or woodland/pasture/ grassland areas. 

Weeds are perceived to be the most substantial pest problem in corn production, negatively 

affecting yield through competition for light, nutrients, and moisture (Aref and Pike, 1998). 

Reductions in corn agronomic performance is sometimes associated with weed competition for 

water, nutrients, and light. Common corn field weeds include giant foxtail (Setaria faberi), giant 

ragweed (Ambrosia trifida), velvetleaf (Abutilon theophrasti), common cocklebur (Xanthium 

strumarium), Canada thistle (Cirsium arvense), common lambsquarters (Chenopodium album), 

and Johnsongrass (Sorghum halepense) (Childs, 2011). 

Weed populations can change in response to agricultural management decisions, including 

decisions related to herbicide application. Weeds can develop resistance to herbicides for the 

following reasons: frequent exposure to a single herbicide, the spread of naturally-resistant 

weeds seeds, and the out-crossing of herbicide-resistant genes from plants (GE or naturallyresistant plants) to weedy relatives. The development of herbicide resistance in weeds is not 

unique to any one country , particular herbicide , or crop variety. In the U.S., 76 weed species 

have developed resistance to at least 17 herbicide MoAs (Heap, 2011). Glyphosate-resistant 

weeds have grown increasingly problematic in U.S. corn fields. Currently, nine glyphosateresistant weeds have been identified in U.S. corn fields (Figure 6), inhabiting approximately two 

million acres of farmland in the U.S. (Hubbard, 2008).

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Figure 6 Glyphosate-resistant weeds in the U.S. corn fields

.

Note that presence of a population is unrelated to prevalence. * indicates at least one population in that states 

possesses resistance to glyphosate and another herbicide. **indicates at least one population in that state 

possesses resistance to glyphosate and two other herbicides. Source: Heap (2011).

2.3.3 Gene Flow and Weediness

Gene flow is a biological process that facilitates the production of hybrid plants, introgression of 

novel alleles, and evolution of new plant genotypes. Gene flow to and from an agro-ecosystem 

can occur on both spatial and temporal scales. In general, plant pollen tends to represent the 

major reproductive method for moving across space, while both seed and vegetative propagation

tend to promote the movement of genes across time and space. 

The rate and success of gene flow is dependent on numerous factors. General factors related to 

pollen-mediated gene flow include the presence, abundance, and distance of sexually-compatible 

plant species; overlap of flowering phenology between populations; the method of pollination; 

the biology and amount of pollen produced; or weather conditions, including temperature, wind, 

and humidity (Zapiola et al., 2008). Seed-mediated gene flow also depends on many factors, 

including the absence, presence, and magnitude of seed dormancy; contribution and participation 

in various dispersal pathways; or environmental conditions and events (Zapiola et al., 2008).

Corn is self-compatible and wind-pollinated. Unlike other grass species in the United States

(Wipff and Fricker, 2002; Watrud et al., 2004), there are no native plant species that can be 

pollinated by corn pollen without human intervention (e.g., chromosome doubling or embryo 

rescue) (Mangelsdorf, 1974; Russell and Hallauer, 1980; Galinat, 1988). However, teosinte 

(wild progenitor of corn) can sometimes be found as introduced populations in botanical gardens 

(USDA-NRCS, 2011a), (USDA-NRCS, 2011b). Sparsely dispersed feral populations of the 

closely related and sexually compatible subspecies of Z. mays spp. parviglumis have also been 

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described in a single county of Florida (USDA, 2012) (Pioneer, 2009). Commercial corn 

production is not found near this location. Corn plants do not produce clonal structures nor can 

corn plants produce vegetative propagules. Therefore, asexual reproduction and gene flow as a 

result of dispersal of vegetative tissues does not occur with corn.

2.3.4 Microorganisms

Microorganisms in the field may mediate both negative and positive outcomes. Diseases that 

afflict corn with significant potential for economic loss include fungal corn rusts, corn leaf 

blights, ear smuts, ear and kernel rot fungi, and maize mosaic viruses (Cartwright et al., 2006). 

Additionally, soil microorganisms may play a key role in dynamic biochemical soil processes

(Garbeva et al., 2004). They may also suppress soil-borne plant diseases and promote plant 

growth (Doran et al., 1996). The main factors affecting microbial population size and diversity 

include soil type, plant type, and agricultural management practices (Garbeva et al., 2004). 

Microbial diversity in the rhizosphere may be extensive and differ from the microbial 

community in the bulk soil (Garbeva et al., 2004).

2.3.5 Biodiversity

Biodiversity refers to all plants, animals, and microorganisms interacting in an ecosystem

(Wilson, 1988). Biodiversity provides valuable genetic resources for crop improvement and also 

provides other functions beyond food, fiber, fuel, and income(Harlan, 1975). These include 

pollination, genetic introgression, biological control, nutrient recycling, competition against 

natural enemies, soil structure, soil and water conservation, disease suppression, control of local 

microclimate, control of local hydrological processes, and detoxification of noxious chemicals

(Altieri, 1999). The loss of biodiversity results in a need for costly management practices in 

order to provide these functions to the crop (Altieri, 1999). 

The degree of biodiversity in an agroecosystem depends on four primary characteristics: 1) 

diversity of vegetation within and around the agroecosystem, 2) permanence of various crops 

within the system, 3) intensity of management, and 4) extent of isolation of the agroecosystem 

from natural vegetation (Southwood and Way, 1970). 

Agricultural land subject to intensive farming practices, such as that used in crop production, 

generally has low levels of biodiversity compared with adjacent natural areas. Tillage, seed bed 

preparation, planting of a monoculture crop, pesticide use, fertilizer use, and harvest result limit 

the diversity of plants and animals (Lovett et al., 2003). 

Since biological diversity can be defined and measured in many ways, APHIS considers 

determining the level of biological diversity in any crop to be complex and difficult to achieve 

concurrence. Another complication with biodiversity studies is separating expected impacts 

from indirect impacts. For example, reductions of biological control organisms are seen in some 

Bt-expressing GE crops, but are caused by reduction of the pest host population following 

transgenic pesticide expression in the transformed crop plant.

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2.4 Human Health

Public health concerns surrounding GE corn primarily involve the human consumption of GE 

corn products. Additionally, corn growers and farm workers may also be exposed to GE corn 

and its respective cultivation practices. 

Under the FFDCA, it is the responsibility of food manufacturers to ensure that the products they 

market are safe and properly labeled. Food derived from GE corn must be in compliance with all 

applicable legal and regulatory requirements. GE organisms for food may undergo a voluntary 

consultation process with the FDA prior to release onto the market. Although a voluntary 

process, thus far, all applicants who wish to commercialize a GE variety that will be included in 

the food supply have completed a consultation with the FDA. 

Worker hazards in farming are common to all types of agricultural production, and include 

hazards of equipment and plant materials. Pesticide application represents the primary exposure 

route to pesticides for farm workers (USDA-NASS, 2007). However, common farm practices, 

training, and specialized equipment can mitigate exposure to pesticides by farm workers (Baker 

et al., 2005b). For example, choosing from less toxic groups of herbicides to control corn weeds

is a good common agricultural practice. 

Agricultural pesticide exposure levels are regulated by EPA labels. EPA’s Worker Protection 

Standard (WPS) (40 CFR part 170) was published in 1992 requiring actions to reduce the risk of 

pesticide poisonings and injuries among agricultural workers and pesticide handlers (EPA - 40 

CFR 170, 1992). The WPS offers protection to more than two and a half million agricultural 

workers who work with pesticides at more than 560,000 workplaces on farms, forests, nurseries, 

and greenhouses. The WPS contains requirements for pesticide safety training, notification of 

pesticide applications, use of personal protective equipment, restricted entry intervals following 

pesticide application, decontamination supplies, and emergency medical assistance.

2.5 Animal Feed

Animal feed concerns by some for GE corn primarily involve the animal consumption of GE 

corn products. Approximately 55 to 60 percent of the corn produced in the United States is used 

for livestock (KyCGA, 2011).

Similar to the regulatory control for direct consumption of corn under the FFDCA, it is the 

responsibility of feed manufacturers to ensure that the products they market are safe and properly 

labeled. Feed derived from GE corn must comply with all applicable legal and regulatory 

requirements, which are designed to protect human health. To help ensure compliance, a 

voluntary consultation process with FDA may be implemented before release of commodity 

products with origins from GE plants as animal feed into the market.

2.6 Socioeconomic

2.6.1 Domestic Economic Environment

The last three decades have been marked by significant transition in the development and 

production of seed, effectively shifting these from the public domain to large seed companies 

36
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

(Fernandez-Cornejo, 2004). At the same time, the volume of hybrid corn seed planted in the 

U.S. has changed very little, with 20.10 million bushels (MBu) harvested in 1975 and 22.9 MBu 

harvested in 2009 (USDA-ERS, 2011d). The total retail value of corn seed sales in the US 

exceeds $7 billion (assuming seed costs of $85/acre for160 Bu/acre expected yield, corn 

following soybean, IA (Duffy, 2012)). Grain yields have increased significantly over this same 

period. Seed suppliers in the US include a total of 173 independently owned companies 

(Monsanto, undated), and the petitioner is one of the four largest seed corn providers with 

multiple seed companies producing sales of seed. Additional production of U.S. seed is 

contracted by U.S. seed companies among South American growers as needed for flexibility and 

speed (Leidy, 2009; Woodall, 2012) which may reduce the need to expand acreage in the US for 

seed corn production. 

In current hybrid corn seed production systems, detasseling of the female inbred line is an 

essential task to ensure genetic integrity of the seed. Detasseling has been mechanized on seed 

production acreage, with mechanical detasseling machines frequently used if a genetic 

mechanism of sterility is not employed. Mechanical detasseling must be augmented with hand 

labor to remove nearly all the tassels that may be left after the detasseling machines have been 

sent through the female inbred rows. The physical detasseling of corn involves the removal 

tassels from the top of thousands of tall corn plants by each detasseler daily during anthesis. 

Detasseling is a temporary job lasting only one to four weeks in mid-summer. The job is time 

sensitive because tassels need to be pulled within a day of emergence before any pollen is 

released. The emergence of tassels depends on the weather: hot humid weather speeds up the 

emergence of tassels by one or more weeks and cold wet weather slows down the emergence of 

tassels by one or more weeks. In consideration of the limits on available hand labor, seed 

producers must plant seed corn earlier or later than optimal to coincide with expected dates of 

detasseling (R. Wyfels, public comment APHIS-2012-0027-0048 for petition 10-281-01). 

Because of the short duration and physical demands of the job, the detasseling operation attracts 

high school students during the summer break, migrant workers and other part-time laborers

(Monsanto-Co., 2010). Thousands of temporary employees are hired for detasseling each year to 

complete the operation on timely basis (Byrom, 2002; Pioneer, 2009; Monsanto-Co., 2010)). 

The hybrid seed production sites where they are employed are often located in some of the major 

Corn Belt states of Nebraska, Iowa, Illinois, and Indiana. Finally, although mechanical 

detasselers reduce the need for manual (human) detasselers, they tend to reduce yields even more 

than manual detasseling operations (Wych, 1988).

2.6.2 Trade Economic Environment

Export value of US corn seed for planting in 2012 was $190.3 million, likely less than 2% of the 

domestic market for seed (international sales: (USDA-FAS, 2013a)and domestic seed retail 

sales: APHIS, Section 4.6.1 Domestic Economic Environment). Total seed for planting that was 

exported was 42,000 metric tons or less than 0.04% of total US corn production 2013 (USDAFAS, 2013a). World requirement for seed for planting and estimated 392.5 million acres of corn

in 2010 (O’Brien, 2010)would be about 2.49 million metric tons (assuming 14# seed per acre to 

attain 30,000 plants/a (Duffy, 2012). In 2004, the commercial export market for US corn seed 

was $174 million (Jayasinghe et al., 2010). The primary purchasers were Italy, Mexico, Canada, 

France and Spain. Underdeveloped countries made only 10% of exported seed purchases, and 

this included India and China. By 2008, the largest purchasers of seed were Western European, 

37
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

totaling almost 32 thousand metric tons, Canada with about 28 thousand mt, and South America 

with nearly 5 thousand mt while sales to Mexico were at 2.5 thousand mt (USDA-FAS, 2013a). 

By 2012 European trade had greatly declined, but Canada continued as largest importer with 

24.8 thousand mt and Mexico second with 6.8 thousand mt and Pakistan third(USDA-FAS, 

2013a). Besides tariffs, so also sanitary and phytosanitary regulations and technical barriers 

create limitations to US exports of seed. Restrictions on importation of seed further derive from 

regulations on planting or sale of GE varieties and these limit commercial potential in many 

countries.

3 Alternatives

This document analyzes the potential environmental consequences of a determination of 

nonregulated status of MON 87427 corn. To respond favorably to a petition for nonregulated 

status, APHIS must determine that MON 87427 corn is unlikely to pose a plant pest risk. APHIS 

has concluded through a PPRA that MON 87427 corn is unlikely to pose a plant pest risk 

(USDA-APHIS, 2012). Therefore, APHIS must determine that MON 87427 corn is no longer 

subject to 7 CFR part 340 or the plant pest provisions of the Plant Protection Act.

Two alternatives are evaluated in this EA: (1) No Action: Continuation as a Regulated Article

and (2) Preferred Alternative: Determination that MON 87427 corn is No Longer a Regulated 

Article. APHIS has assessed the potential for environmental impacts for each alternative in the 

Environmental Consequences section.

3.1 No Action Alternative: Continuation as a Regulated Article

Under the No Action Alternative, APHIS would deny the petition. MON 87427 corn and 

progeny derived from MON 87427 would continue to be regulated articles under the regulations 

at 7 CFR part 340. Permits issued or notifications acknowledged by APHIS would still be 

required for introductions of MON 87427 corn and measures to ensure physical and reproductive 

confinement would continue to be implemented. APHIS might choose this alternative if there 

were insufficient evidence to demonstrate the lack of plant pest risk from the unconfined 

cultivation of MON 87427 corn. 

This alternative is not the Preferred Alternative because APHIS has concluded through a PPRA 

that MON 87427 corn is unlikely to pose a plant pest risk (USDA-APHIS, 2012). Choosing this 

alternative would not satisfy the purpose and need of making a determination of plant pest risk 

status and responding to the petition seeking nonregulated status.

3.2 Preferred Alternative: Determination that MON 87427 Corn is No Longer a 

Regulated Article

Under this alternative, MON 87427 corn and progeny would no longer be regulated articles 

under the regulations at 7 CFR part 340. MON 87427 corn is unlikely to pose a plant pest risk

(USDA-APHIS, 2012). Permits issued or notifications acknowledged by APHIS would no 

longer be required for introductions of MON 87427 corn and progeny derived from this event. 

This alternative best meets the purpose and need to respond appropriately to a petition seeking

nonregulated status based on the requirements in 7 CFR part 340 and the agency’s authority 

under the plant pest provisions of the Plant Protection Act. Because the agency has concluded 

38
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

that MON 87427 corn is unlikely to pose a plant pest risk, a determination of nonregulated status 

of MON 87427 corn is a response that is consistent with the plant pest provisions of the Plant 

Protection Act, the regulations codified in 7 CFR part 340, and the biotechnology regulatory 

policies in the Coordinated Framework.

Under this alternative, growers may have future access to MON 87427 corn and progeny derived 

from this event if the developer decides to commercialize MON 87427 corn.

3.3 Alternatives Considered But Rejected from Further Consideration

APHIS assembled a list of alternatives that might be considered for MON 87427 corn. The 

agency evaluated these alternatives with respect to the agency's authority under the plant pest 

provisions of the Plant Protection Act, and the regulations at 7 CFR part 340, with respect to 

environmental safety, efficacy, and practicality to identify which alternatives would be further 

considered for MON 87427 corn. Based on this evaluation, APHIS rejected several alternatives.

These alternatives are discussed briefly below along with the specific reasons for rejecting each.

3.3.1 Prohibit Any MON 87427 Corn from Being Released

In response to public comments that stated a preference that no GE organisms enter the 

marketplace, APHIS considered prohibiting the release of MON 87427 corn, including denying 

any permits associated with the field testing. APHIS determined that this alternative is not 

appropriate given that APHIS has concluded that MON 87427 corn is unlikely to pose a plant 

pest risk (USDA-APHIS, 2012).

In enacting the Plant Protection Act, Congress found that 

[D]ecisions affecting imports, exports, and interstate movement of products regulated 

under [the Plant Protection Act] shall be based on sound science...§ 402(4).

On March 11, 2011, in a Memorandum for the Heads of Executive Departments and Agencies, 

the White House Emerging Technologies Interagency Policy Coordination Committee developed 

broad principles, consistent with Executive Order 13563, to guide the development and 

implementation of policies for oversight of emerging technologies (such as genetic engineering) 

at the agency level. In accordance with this memorandum, agencies should adhere to Executive 

Order 13563 and, consistent with that Executive Order, the following principle, among others, to 

the extent permitted by law, when regulating emerging technologies: 

“[D]ecisions should be based on the best reasonably obtainable scientific, technical, 

economic, and other information, within the boundaries of the authorities and mandates 

of each agency” 

Based on the APHIS MON 87427 PPRA (2012) and the scientific data evaluated therein, 

APHIS concluded that MON 87427 corn is unlikely to pose a plant pest risk. Accordingly, there 

is no basis in science for prohibiting the release of MON 87427 corn.

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

3.3.2 Approve the Petition in Part

The regulations at 7 CFR 340.6(d)(3)(i) state that APHIS may "approve the petition in whole or 

in part." For example, a determination of nonregulated status in part may be appropriate if there 

is a plant pest risk associated with some, but not all lines described in a petition. Because APHIS 

has concluded that MON 87427 corn is unlikely to pose a plant pest risk, there is no regulatory 

basis under the plant pest provisions of the Plant Protection Act for considering approval of the 

petition only in part.

3.3.3 Isolation Distance between MON 87427 and Non-GE Corn Production and 

Geographical Restrictions

In response to public concerns of gene movement between GE and non-GE plants, APHIS 

considered requiring an isolation distance separating MON 87427 from non-GE corn production. 

However, because APHIS has concluded that MON 87427 corn is unlikely to pose a plant pest 

risk (USDA-APHIS, 2012), an alternative based on requiring isolation distances would be 

inconsistent with the statutory authority under the plant pest provisions of the Plant Protection 

Act and regulations in 7 CFR part 340. 

APHIS also considered geographically restricting the production of MON 87427 corn based on 

the location of production of non-GE corn in organic production systems or production systems 

for GE-sensitive markets in response to public concerns regarding possible gene movement 

between GE and non-GE plants. However, as presented in APHIS’ PPRA for MON 87427 corn, 

there are no geographic differences associated with any identifiable plant pest risks for MON 

87427 corn (USDA-APHIS, 2012). This alternative was rejected and not analyzed in detail 

because APHIS has concluded that MON 87427 corn does not pose a plant pest risk, and will not 

exhibit a greater plant pest risk in any geographically restricted area. Therefore, such an 

alternative would not be consistent with APHIS’ statutory authority under the plant pest 

provisions of the Plant Protection Act and regulations in Part 340 and the biotechnology 

regulatory policies embodied in the Coordinated Framework.

Based on the foregoing, the imposition of isolation distances or geographic restrictions would not 

meet APHIS’ purpose and need to respond appropriately to a petition for nonregulated status

based on the requirements in 7 CFR part 340 and the agency’s authority under the plant pest 

provisions of the Plant Protection Act. However, individuals might choose on their own to 

geographically isolate their non-GE corn production systems from MON 87427 corn or to use 

isolation distances and other management practices to minimize gene movement between corn

fields. Information to assist growers in making informed management decisions for MON 87427 

corn is available from the Association of Official Seed Certifying Agencies (AOSCA, n.d.-b) and 

hybrid seed growers are likely to receive detailed direction from the trait developer.

3.3.4 Requirements of Testing for MON 87427 Corn

During the comment periods for other petitions for nonregulated status, some commenters 

requested USDA to require and provide testing for GE products in non-GE production systems. 

APHIS notes there are no nationally-established regulations involving testing, criteria, or limits 

of GE material in non-GE systems. Such a requirement would be extremely difficult to 

40
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

implement and maintain. Additionally, because MON 87427 corn does not pose a plant pest risk

(USDA-APHIS, 2012), the imposition of any type of testing requirements is inconsistent with 

the plant pest provisions of the Plant Protection Act, the regulations at 7 CFR part 340 and 

biotechnology regulatory policies embodied in the Coordinated Framework. Therefore, 

imposing such a requirement for MON 87427 corn would not meet APHIS’ purpose and need to 

respond appropriately to the petition in accordance with its regulatory authorities.

3.4 Comparison of Alternatives

Table 2 presents a summary of the potential impacts associated with selection of either of the 

alternatives evaluated in this EA. The impact assessment is presented in Section 4 of this EA.

Table 2. Summary of issues of potential impacts and consequences of alternatives.

Attribute/Measure Alternative A: No Action Alternative B: Determination of 

Nonregulated Status

Meets Purpose and 

Need and 

Objectives

No Yes

Unlikely to pose a 

plant pest risk

Satisfied through use of 

regulated field trials

Satisfied—risk assessment (USDAAPHIS, 2012)

Management 

Practices

Acreage and Areas 

of Corn Production

Yearly fluctuation but no or 

small net increase of acreage 

and no new regions of corn 

planted

Unchanged from No Action 

Alternative

Agronomic 

Practices

Seed production practices will 

will continue to depend on 

mechanical and hand 

detasseling

Unchanged from No Action 

Alternative except for use of 

glyphosate to sterilize male tissue 

and prevent pollination. May see 

some reductions in use of 

mechanical and hand detasseling

Pesticide Use Herbicide use patterns on GE 

and non-GE corn will continue 

with present rates

Glyphosate use in seed corn 

production may increase slightly

Corn Seed 

Production

Fluctuates yearly somewhat; 

foreign seed production is used 

to respond to specific needs 

Unchanged

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Organic Corn 

Production

Yearly production not affected 

by conventional corn production

Unchanged

Environment

Land Use Seed corn acreage generally 

may range from 0.5 to one 

million acres

MON 87427 corn is not expected to 

have any effect on land use 

Water Resources Herbicides in water fluctuate 

with weather, climate and usage 

MON 87427 corn is not expected to 

have any effect on water 

Soil Glyphosate in soil has a short 

half-life. Conservation tillage 

may be increasing slightly 

MON 87427 corn is not expected to 

increase tillage or substantially 

change glyphosate use

Air Quality Air quality (particulates) 

affected by tillage and weather

MON 87427 corn is not expected to 

have any effect on air quality 

Climate Change Climate changes affected by 

land use, tillage and greenhouse 

gases

MON 87427 corn is not expected to 

change land use, tillage practices or 

greenhouse gases 

Animals and 

Plants

Animals Vertebrates interact infrequently 

with corn agriculture; impacts 

on invertebrates from corn 

production similar to impacts 

from any other agricultural 

production

MON 87427 corn and glyphosate is 

not expected to have any effect on 

vertebrate animals or most 

invertebrate animals. Unchanged 

from the No Action Alternative

Plants Natural vegetation highly 

reduced near farms; herbicide 

resistant weeds increasing

Unchanged from no action 

alternative

Gene Movement No gene flow to wild plants; 

gene flow to other corn 

controlled by grower needs. 

Horizontal gene flow not 

observed

MON 87427 corn used in seed 

production will allow pollination to 

be more directed, but not expected to 

have any effect on vertical or 

horizontal gene flow 

Soil 

Microorganisms

Microorganisms affected by 

tillage, agronomic activity and 

pesticides 

Unchanged from no action 

alternative

Biological Diversity Contemporary agriculture 

already impacts biological 

Unchanged from no action 

alternative

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

diversity 

Consumer and 

Animal Health

Risk to Consumer 

Health

EPA rates glyphosate impacts 

from glyphosate resistant corn 

as having no reasonable 

certainty of harm 

MON 87427 corn does not have any 

adverse human health effects. 

Unchanged from No Action

Risk to Animal 

Feed

Corn is a major feed protein for 

animal nutrition; quality is 

unchanging and adequate to 

animal needs

MON 87427 will be used for seed, 

but no effects expected on animal 

nutrition 

Socioeconomic

Domestic and 

Economic 

Environment

Corn seed with various traits has 

a competitive market in the US, 

with four major seed suppliers, 

and over a hundred smaller ones

MON 87427 would be deployed in 

inbreds for hybrid corn production, 

replacing mechanical and 

cytoplasmic sterility in the domestic 

seed corn production business; some 

gradual decline expected in 

summer temporary worker hiring

Trade Economic 

Environment

Corn export levels decreased by 

23% from 2010 to 2012 in the 

US

MON 87427 corn not likely to 

change corn production 

Other Regulatory 

Approvals

FDA completed consultations, 

EPA tolerance exemptions and 

conditional pesticide 

registrations granted

FDA completed consultations, EPA 

tolerance exemptions and conditional 

pesticide registrations granted

Compliance with 

Other Laws

CWA, CAA, Eos Fully compliant Fully compliant

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

4 Environmental Consequences

This analysis of potential environmental consequences addresses the potential impact to the 

human environment from the alternatives analyzed in this EA. Potential environmental impacts 

from the No Action Alternative and the Preferred Alternative for MON 87427 corn are described 

in detail throughout this section. Certain aspects of this product and its cultivation would be no 

different between the alternatives: those instances are described below.

A cumulative effects analysis is also included for each resource area in Section 5. A cumulative 

impact may be an effect on the environment which results from the incremental impact of the 

proposed action when added to other past, present, and reasonably foreseeable future actions. 

Examples include breeding MON 87427 corn with other events no longer subject to the 

regulatory requirements of 7 CFR part 340 or the plant pest provisions of the Plant Protection 

Act. If there are no direct or indirect impacts identified for a resource area, then there can be no 

cumulative impacts.

4.1 Scope of Analysis

Under the No Action Alternative, Mon 87427 corn will remain subject to the regulatory 

requirements of 7 CFR part 340 (Section 3.1); additionally, under the Preferred Alternative, 

MON 87427 corn will no longer be subject to the regulatory requirements of 7 CFR part 340 or 

the plant pest provisions of the Plant Protection Act (Section 3.2). 

Potential environmental impacts from the No Action Alternative and the Preferred Alternative 

for MON 87427 corn are described in detail throughout this section. An impact would be any 

change, positive or negative, from the existing (baseline) conditions of the affected environment 

(described for each resource area in Section 2.0). Impacts may be categorized as direct, indirect, 

or cumulative. A direct impact is an effect that results solely from a proposed action without 

intermediate steps or processes. Examples include soil disturbance, air emissions, and water use. 

An indirect impact may be an effect that is related to but removed from a proposed action by an 

intermediate step or process. Examples include surface water quality changes resulting from soil 

erosion due to increased tillage, and worker safety impacts resulting from an increase in 

herbicide use. 

Where it is not possible to quantify impacts, APHIS provides a qualitative assessment of 

potential impacts. Certain aspects of this product and its cultivation may be no different between 

the alternatives; those are described below. 

Although the Preferred Alternative would allow for new plantings of MON 87427 corn to 

occur anywhere in the United States, APHIS will primarily focus the environmental analysis 

to those areas where hybrid corn seed is produced. To determine these, APHIS relied on 

information from Monsanto and the scientific literature.

Assumptions. MON 87427 utilizes a specific promoter and intron combination (e35S-hsp70) 

to drive CP4 EPSPS protein expression in vegetative and female reproductive tissues, 

conferring tolerance to glyphosate in the leaves, stalk, and root tissues and tissues that develop 

into seed or grain and silks (Monsanto, 2010). This specific promoter and intron combination 

also results in limited or no production of CP4 EPSPS protein in two key male reproductive 

44
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

tissues: pollen microspores which develop into pollen grains, and tapetum cells that supply 

nutrients to the pollen. Thus, in MON 87427, male reproductive tissues critical for male 

gametophyte development are not resistant to glyphosate (Monsanto, 2010). This allows 

glyphosate-treated MON 87427 containing inbred lines to serve as a female parent in the 

production of hybrid seed. Two glyphosate applications beginning just prior and/or during

tassel development stages (approximate maize vegetative growth stages ranging from V8 to 

V13) will produce a male sterile phenotype through tissue-selective glyphosate tolerance, and 

will eliminate or greatly reduce the need for detasseling which is currently used in the 

production of hybrid maize seed. 

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

4.2 Agricultural Production of Corn

4.2.1 Acreage and Range of Commercial Corn Production

No Action Alternative: Acreage and Range of Corn Production

Under the no action alternative MON 87427 would remain a regulated article and would not be 

available to seed producers. Under the no action alternative maize hybrid corn seed growers 

would continue to produce seed using hand and mechanical detasseling methods. As direct and 

associated labor costs continue to increase, (Section VIII.C.) hybrid seed production costs are 

also likely to increase. Because hybrid corn seed production is dependent upon commercial corn 

demand, it is relevant to discuss the acreage trends in commercial corn.

Existing trends related to the acreage and range of corn is expected to continue under the No 

Action Alternative. U.S. hybrid seed production in support of a mostly domestic market is found 

on about 0.5-1 million acres annually (Monsanto, 2010). The acreage is found principally in the 

Midwestern Sates of the Corn Belt (Monsanto, 2010). U.S. commercial corn production has 

generally increased in the past 20 years, from just over 76 million acres in 1991 to about 92

million acres in 2011 (USDA-NASS, 2012e). USDA-ERS (2012d) projects corn acreage to peak 

at 94 million acres in 2012 and then recede to 92 million acres by 2021. With regard to 

geographic range, corn is expected to continue being commercially cultivated in 49 U.S. states, 

with the majority of production centered in the Midwestern Corn Belt. 

Dictating this general increase in U.S. corn acreage are external market forces across many

commercial sectors. Increasing demand and favorable net returns for corn products are likely to 

sustain the market for U.S. corn grain (USDA-ERS, 2012d). In response to these market forces, 

U.S. farmers are planting additional corn acreage primarily at the expense of other agricultural

crop commodities (e.g., wheat, soybean, and hay) (USDA-ERS, 2011c). Additionally, 

government policies have and will continue enabling U.S. farmers to meet corn production 

targets by providing economic incentive to retain arable land in agricultural production. For 

example, as stipulated in the Food, Conservation, and Energy Act (2008), a net reduction in 

Conservation Reserve Program (CRP) land enrollment from 39.2 to 32 million acres and 

increased funding for Working Land Conservation Programs (e.g., The Environmental Quality 

Incentives Program [EQIP]) represented two Federal policy tools to increase the amount of 

arable land for agricultural production while also encouraging farmer adoption of

environmentally-friendly practices to maintain agricultural productivity.

External market forces leading to a growing demand for U.S. corn, reactive government policy 

designed to increase domestic production of agricultural crop commodities while maintaining the 

productivity of arable land, and responsive farmer land-use decisions to meet corn grain

production targets by primarily implementing acreage shifts away from other agricultural 

commodities reflect current economic conditions and trends. These current economic conditions 

and trends are likely to continue under the No Action Alternative.

Preferred Alternative: Acreage and Range of Corn Production

A determination of nonregulated status of MON 87427 corn under the Preferred Alternative is 

unlikely to substantially impact projected trends in U.S. corn acreage (USDA-ERS, 2011c) nor 

46
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

are existing trends likely to greatly change demand for hybrid seed production and for MON 

87427. As previously discussed, both external market forces (i.e., increasing demand for U.S. 

corn products) and government policies (e.g., reduction in CRP land enrollment or increased 

funding for EQIP) strongly affect domestic levels of corn production. MON 87427 corn is 

unlikely to substantially increase U.S. corn acreage under the Preferred Alternative, as increases 

in U.S. corn acreage and production generally reflects commercial demand for U.S. corn 

products and not the cultivation of any one corn variety. Second, MON 87427 corn is unlikely to 

substantially increase U.S. corn acreage and production because it is a product meant to facilitate 

hybrid seed production and not general corn production. While U.S. corn production has 

increased in the past 20 years, hybrid corn seed production has remained relatively stable at 0.5 –

1 million acres (Pioneer, 2009; Monsanto, 2010). Hybrid corn seed production is a small 

proportion of general corn production, with yearly fluctuations in general corn acreage and 

production sometimes exceeding that of hybrid corn seed production (Figure 6). Due to the 

external market forces that ultimately affect U.S. corn acreage and the small proportion of 

acreage dedicated to hybrid corn seed production relative to general corn production, U.S. corn

acreage is unlikely to substantially increase beyond projected values under the Preferred 

Alternative.

Like many domesticated crop plants, corn is not likely to persist and spread outside the 

agricultural environment (USDA-APHIS, 2012). In the United States, the range of corn 

cultivation is generally limited by moisture and frost-free days to reach maturity. Field study of 

MON 87427 corn indicates that the agronomic performance of it and conventional corn is not 

substantially different (Monsanto, 2010; USDA-APHIS, 2012). Accordingly, the range of 

cultivation for MON 87427 corn is similar to conventional corn, as neither its introduced trait nor 

agronomic performance suggests an increased capacity to grow on land not already managed for 

agricultural production. Under the Preferred Alternative, MON 87427 corn is likely to be 

cultivated on managed land, thus limiting its range to that of currently available corn varieties 

and ensure that land planted to MON 87427 corn will be derived from existing corn acreage or 

acreage previously used for agricultural crop commodities (USDA-ERS, 2011c; USDA-ERS, 

2012d).

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Figure 7. Hybrid corn seed planted and corn grain produced in the United States, 1975-2009

Sources: Monsanto (2010) from USDA-ERS (2010a).

4.2.2 Agronomic Practices of Commercial Corn Production

Corn (Zea mays L.) is the largest crop cultivated in the United States, in terms of planted acreage 

and net value (USDA-NASS, 2010). U.S. corn is typically produced as a hybrid, due to positive 

gains associated with heterosis (Wych, 1988; Duvick, 2001), . In contrast to open-pollination, 

hybrid seed production in corn maintains heterosis and genetic uniformity (Duvick, 2001). 

Accordingly, corn growers in the United States generally purchase new hybrid seed at the start of 

each growing season to ensure optimal grain yield (Wych, 1988; USDA-APHIS, 2011b). Hybrid 

corn seed production, while generally similar to that of commercial corn production, does differ 

in some practices, including tillage, herbicides, details of planting and practices necessary for 

pollen control.

No Action Alternative: Tillage

Under the No Action Alternative, U.S. hybrid seed corn growers are likely to continue using 

conservation tillage practices which is the current practice of the majority of these producers.

No-till practices are highly uncommon in corn seed production, however, which distinguishes

this crop from those of commercial corn practices. Similarly, U.S. commodity corn growers will 

continue to use conservation, , or conventional tillage to prepare the soil for planting prior to 

planting hybrid corn seed. However, recent data from USDA-ERS and the USDA Agricultural 

Resource Management Survey (ARMS) indicates that conservation tillage, and in particular notill activities (Figure 8), have generally increased in U.S. commodity corn production (Horowitz 

et al., 2010; NRC, 2010). 

Conservation tillage is generally associated with broad-spectrum herbicide use, because this 

tillage facilitates efficient weed control using herbicides prior to planting a crop (Mask et al., 

1994; Uri, 1999). In recent years, herbicide-resistant crops have further enabled broad spectrum 

48
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

herbicide use for pre- and post-planting weed control. Though the causality between herbicideresistant crop adoption and conservation tillage may be debated (Fernandez-Cornejo et al., 2003; 

Mensah, 2007), more recent empirical evidence suggests a direct relationship, where overall 

adoption of herbicide-resistant crops have encouraged increasing overall adoption of 

conservation tillage practices (NRC, 2010). This relationship, however, appears to be weaker in 

corn than other commodity crops, such as cotton or soybean (NRC, 2010). Although herbicide 

use is common in hybrid seed production, they do not include the glyphosate or glufosinate that 

can be used in crops with resistance to these herbicides.

Figure 8. Tillage trends and adoption of herbicide-resistant (HT) corn in the U.S., 2000 – 2010. 

HT corn varieties were increasingly adopted following regulatory approval of glyphosate-resistant corn in 

2004. Sources: USDA-ERS (2011a; 2012b) and CERA (2010).

Preferred Alternative: Tillage

Under the Preferred Alternative, a determination of nonregulated status is unlikely to 

substantially affect tillage trends in U.S. hybrid corn production. The predominant practice in 

hybrid corn production is already to primarily use herbicides for weed control, although not over 

the top application of glyphosate. Consequently, existing practice in seed production is already 

compatible with conservation tillage practices. MON 87427 corn, like many other 

commercially-available herbicide-resistant corn varieties, is resistant to glyphosate application. 

Glyphosate-resistant corn varieties, similar to MON 87427, have been shown to positively affect 

rates of conservation tillage adoption in U.S corn production (Givens et al., 2009; Horowitz et 

al., 2010). Although MON 87427 is another glyphosate-resistant variety, the needs of the hybrid 

corn production industry require different parameters; one of these is that inbreds will require 

additional tillage compared to commercial varieties which themselves are successfully produced

under no-till conditions. Conservation tillage in hybrid seed production will continue to be 

practiced, but no-till will likely not be common. MON 87427 is primarily intended for hybrid 

corn seed production and as previously described; hybrid seed corn represents a small proportion 

of U.S. commodity corn acreage. Yearly fluctuations in acres of commercial corn production is 

often greater than the total amount of hybrid seed corn production itself (Section 4.2.1). Thus, 

0

25

50

75

100

0

10

20

30

40

50

60

2000 2001 2005 2010

HT corn - % U.S. corn acreage

Tillage - % U.S. corn acreage

Year

HT corn Conservation Tillage

Reduced Tillage Intensive (Conventional Tillage)

49
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

any possible effect on tillage by MON 87427 would be minor, due to the relatively small scale of 

hybrid corn seed production. However, no factors would encourage change in tillage practices if 

MON 87427 corn has nonregulated status.

No Action Alternative: Fertilization and Crop Rotation

Under the No Action Alternative, existing trends in US hybrid seed corn production related to 

fertilization and crop rotation are expected to continue, which are the same as those for 

commodity corn production. Fertilization is an important management consideration for 

maximizing corn grain yield (Hoeft et al., 2000). In 2010, nitrogen and phosphate were applied 

to 97 and 78 percent of U.S. corn acreage, respectively (USDA-NASS, 2011b). Additionally, in 

order to maintain productivity of an agricultural field and maximize economic return, U.S. corn

growers may rotate their crops with a variety of other crops, including oats, peanut, soybean, 

wheat, and rye (USDA-APHIS, 2011c). In 2010, 71 percent of corn acreage in 19 surveyed 

states was under some form of rotation (USDA-NASS, 2011b). Cropland used for corn and 

soybean production is nearly identical in many areas, where over 90 percent of the cropped area 

is planted in a two-year corn-soybean rotation (Hoeft et al., 2000). Recently, there has been an 

increase in continuous corn rotations given the profitability of corn production and the strong 

demand for corn grain (USDA-ERS, 2011c).

Preferred Alternative: Fertilization and Crop Rotation

Similar to the No Action Alternative, a determination of nonregulated status for MON 87427 

corn is unlikely to substantially change fertilization patterns in U.S. hybrid corn seed production. 

Standard agricultural practices related to corn production are required for the cultivation of MON 

87427 corn (Monsanto, 2010), thus suggesting that it does not require different nutrient 

supplementation than conventional commodity corn.

Additionally, similar to the No Action Alternative, a determination of nonregulated status for 

MON 87427 corn is unlikely to substantially change current patterns of rotation in U.S. corn 

production. Crop rotation is primarily used to maintain productivity of the soil and to mitigate 

reduce pest pressure in an agricultural field (Olson and Sander, 1988). Hybrid seed is mainly 

grown by contract growers, many of whom are most likely already growing conventional corn. 

Seed production acreage would likely be one part of the rotation for the commodity corn and 

other crops that they also grow. MON 87427 corn exhibits similar agronomic performance to 

conventional corn (Monsanto, 2010; USDA-APHIS, 2012), suggesting that would benefit from 

current corn rotational strategies. The decision to practice crop rotation, however, is a farm-level 

decision dependent on factors unrelated to the specific corn variety cultivated, such as corn 

commodity market prices (USDA-ERS, 2011c; USDA-ERS, 2012d). For example, continuous 

corn cultivation has increased following increased demand and high corn prices (USDA-ERS, 

2011c). Rotation crops preceding seed production are likely the same as those used by growers 

of conventional crops, including commonly soybean, wheat, minor crops and corn (Monsanto, 

2010). A corn on corn rotation where desired by growers requires extra effort be given to 

eliminating volunteer corn. To avoid pollination from the unwanted corn, an investment must be

made to use pre-plant or in-crop cultivation, or herbicides such as sethoxydim or quizalofop on

the volunteers (Monsanto, 2010). Use of MON 87427 will not affect rotations for corn.

50
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

No Action Alternative: Pesticide Use

Corn production fields may contain a variety of pests, including fungi, insects, and weeds. 

Management of these pests to maintain grain yield and quality is an integral part of corn 

production that may be approached with a variety of strategies. The adoption of insect-resistant 

and herbicide-resistant GE corn varieties by U.S. commodity corn growers has strongly 

decreased some pesticide use patterns. However, the inbreds used in hybrid seed production may 

not have traits to provide protection against insects such as Bts that provide resistance to 

European corn borer, other grain and leaf infesting insects, and corn rootworms, and pesticides 

would be employed more frequently on these fields in the absence of genetic means of 

protection.

Insecticides are used to control above and below ground pests, and protect against insect damage

to stands, the growing plants, and the female parent inbred ears. Seed companies practice 

integrated pest management principles and evaluate seed fields to determine if and when 

insecticide application is justified (Monsanto, 2010). Fungicides are also an important

component of hybrid maize seed production and are used to protect susceptible parent lines from 

damaging fungal diseases. Although genetic resistance to disease is preferred, chemical 

protection is often needed when resistance is not adequate in the parent line. Spray applications 

effectively reduce damage from foliar disease in susceptible inbred lines, and seed treatments are 

widely used to prevent seed and seedling diseases (Smith and White, 1988).Under the No Action 

Alternative, fungicide and insecticide use

12 in U.S. corn production fields will likely continue as 

it is currently practiced. In general, fungicide use has increased since 1995, primarily due to the

increasing use of fungicides in corn seed coatings (Figure 9)). Use of fungicides, however, is 

substantially less than that of other pesticides (e.g., insecticides or herbicides) (USDA-NASS, 

2011b). In 2010, approximately 744,000 lbs. of fungicides were applied to 8 percent of U.S. 

corn acres (USDA-NASS, 2011b; USDA-NASS, 2012b). Additionally, insecticide use will

likely continue as it is currently practiced on U.S. corn fields. Insecticide use to control insect 

pests has decreased since 2003 (Benbrook, 2009; Fernandez-Cornejo et al., 2009; NRC, 2010), a 

trend generally related to the increasing adoption of GE insect-resistant corn varieties that are no 

longer subject to the regulatory requirements of 7 CFR part 340 or the plant pest provisions of 

the Plant Protection Act.In 2010, this trend culminated in 1.6 million pounds (lbs.) of insecticides

sprayed on 12 percent of U.S. corn acreage (USDA-NASS, 2011d; USDA-NASS, 2012c). 

12 Pesticide use is defined here as total pounds (lbs.) of active ingredient (a.i.) applied over corn.

51

 
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Figure 9. Total application of fungicides in U.S. corn production, 1995 – 2010.

Source: USDA-NASS (2012b).

Figure 10. Trends in the use of insecticides and Bt corn in the US

Total application of insecticides (lbs. active ingredient, red line) and percent of U.S. corn acreage cultivated 

with genetically engineered Bt corn varieties (green line), 2002 - 2010. Sources: USDA-NASS (2012c) and 

USDA-ERS (2011a). 

Weeds are the most problematic pests of corn fields. At present, herbicide application is the 

primary method of controlling weeds in corn fields. In 2010, herbicidal active ingredients were 

applied to 98 percent of all U.S. corn acreage, representing nearly two-thirds of all pesticide 

active ingredients applied on corn (USDA-NASS, 2011b). Under the No Action Alternative,

herbicide use trends are likely to continue as currently practiced on U.S. corn fields. U.S. corn 

growers will continue to have access to broad-spectrum herbicides and GE herbicide-resistant

corn varieties no longer subject to the regulatory requirements of 7 CFR part 340 or the plant 

0

200,000

400,000

600,000

800,000

1995 1997 2003 2005 2010

Fungicides applied (lbs.)

Year

Fungicide application

(lbs.)

0

2,000,000

4,000,000

6,000,000

8,000,000

0

25

50

75

100

2002 2003 2005 2010

Insecticide application (lbs)

Percent of U.S. corn

Year

Bt corn in the U.S.

Insecticide application (lbs)

52
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

pest provisions of the Plant Protection Act. While herbicide use trends and its relationship with 

glyphosate-resistant corn varieties are subject debate (Fernandez-Cornejo et al., 2003; Benbrook, 

2009; Fernandez-Cornejo et al., 2009), it is clear that a general substitution effect has occurred in 

U.S. corn production in the years following the introduction of herbicide-resistant corn varieties 

(NRC, 2010). With the exception of acetochlor, glyphosate use has generally increased at the 

expense of other common corn herbicides between 1995 and 2010 (Fernandez-Cornejo et al., 

2009; NRC, 2010) (Figure 11). This statement, however, should not be misinterpreted to mean 

that total herbicide use has decreased in U.S. corn production; rather, total herbicide use has 

increased since 1995 due to increasing adoption of glyphosate and decreasing use of nonglyphosate herbicides (NRC, 2010; USDA-NASS, 2011c). It is prudent to note that total 

herbicide use is not an effective metric to measure environmental impact, as this does not 

effectively permit the environmental comparison of different herbicides across time or across 

management strategies (Fernandez-Cornejo et al., 2009). 

The increasing frequency of glyphosate-resistant weeds in some corn production fields may 

decrease the efficacy of glyphosate for control of weeds. In spite of this, some U.S. farmers

are hesitant to stop using glyphosate through familiarity and satisfaction with the 

glyphosate-resistant crop system. For example, a survey of 400 corn, cotton, and soybean 

growers found that a majority would not restrict their use of glyphosate-resistant crops [or 

glyphosate] when facing increased weed pressure from glyphosate-resistant weed populations

(Scott and VanGessel, 2007). 

. 

Figure 11. Commonly used herbicides in U.S. corn production, 1995 – 2010

Source: USDA-NASS (1996; 2002; 2006; 2010).

U.S. farmers, however, are beginning to understand that a diversification of selection pressure in 

their weed management strategies may be necessary to manage and slow glyphosate-resistant 

weed development (Johnson et al., 2009; NRC, 2010; Owen et al., 2011). One general farmlevel response to glyphosate-resistant weeds has been to increase the rate/frequency of 

glyphosate application and incorporate the use of different herbicidal chemistries (NRC, 2010). 

A possible consequence of this action may be an increase in total herbicide use in U.S. corn

production (NRC, 2010; Owen, 2010). However, total herbicide use may not be an effective 

0

20

40

60

80

Percent of all U.S. corn acreage

1995

2010

53
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

metric to measure environmental impact, as this does not effectively permit the environmental 

comparison of different herbicides across time or across management strategies (FernandezCornejo et al., 2009).

Preferred Alternative: Pesticide Use

Control insects, and diseases within the hybrid maize seed production field is an integral and 

necessary part of seed production (Wych, 1988). Seed growers rely heavily on herbicides for 

effective weed control, since inbred maize lines do not compete effectively with weeds. General 

trends related to corn pest management in hybrid seed corn production are unlikely to change 

under the Preferred Alternative. The inbred parental lines carrying MON 87427 may not possess 

resistance to disease or insects (i.e., Bt protein), and thus fungicide and insecticide applications 

trends will continue as they would under the No Action Alternative. Additionally, MON 87427 

corn does not show increased susceptibility to microbial or insect pests, suggesting that 

management practices would not differ between it and commodity corn, including pesticide use 

or conventional breeding selection for disease resistance (Monsanto, 2010; USDA-APHIS, 

2012). Environmental observations in field studies have demonstrated no apparent impact on 

arthropods of maize. Therefore, no changes to current insect management practices are 

anticipated from the introduction of MON 87427, including pesticide use, conventional breeding 

selection for resistance, or when used in conjunction with biotechnology-derived traits.

Control of weeds in inbred corn fields that are used for producing new hybrid seeds is highly 

important to high yields. In typical hybrid corn seed production fields, glyphosate is generally 

not used to control weeds because not all inbred corn lines contain a glyphosate-resistant trait. 

Under the Preferred Alternative, producers of hybrid corn seed will be able to use glyphosate as 

an herbicide to control weeds through use of MON 87427 and NK603/MON 88017 traits 

expressed in inbred corn lines, and in addition will make use of the tissue selective trait as

intended, as an inducer of male sterility in MON 87427 corn (Monsanto, 2010).

MON 87427 provides an option for producing viable hybrid maize seed as an alternative to 

detasseling or the use of a CMS systems, using minimal additional agricultural inputs, i.e. late 

stage applications of glyphosate, (Section I.5.3.). With the introduction of MON 87427, 

glyphosate can be applied to hybrid maize seed production fields in early growth stage 

applications as part of the weed control system and applied at later vegetative growth stages (V8 

through V13) to produce the male sterile phenotype through tissue-selective glyphosate tolerance 

in the female parent inbred line. This has not been possible before as usually only one of the 

inbred lines contained the trait for glyphosate tolerance.

Weed management practices in the production of hybrid maize seed using a system with MON 

87427 are anticipated to be substantially the same as current hybrid maize seed production 

practices, with the added option of using glyphosate for early post-emergent weed control. Weed 

management practices in the cultivation of commercial maize with MON 87427 stacked with 

other already approved glyphosate-tolerant maize traits will also remain unchanged. Producers of 

hybrid maize seed and growers of commercial maize will be able to achieve the same high level 

of weed control as other biotechnology-derived herbicide tolerant maize hybrids. Additionally, 

because MON 87427 is agronomically and phenotypically equivalent to conventional maize as 

described in Section VII, it is not anticipated that MON 87427 will respond differently to 

commonly used herbicides, except glyphosate.

54
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

While a determination of nonregulated status of MON 87427 corn may increase total glyphosate 

use in U.S. corn production, this is unlikely to substantially affect the herbicide use trends 

already described under the No Action Alternative. Based on USDA-NASS data, glyphosate use 

in corn is increasing, partially related to increasing adoption of glyphosate-resistant corn 

varieties (USDA-NASS, 1996; 2002; 2006; 2011c). A determination of nonregulated status is 

unlikely to affect this existing trend, as MON 87427 corn a GE corn variety resistant to 

glyphosate. Additionally, while MON 87427 corn may increase total glyphosate use, this 

increase is unlikely to be substantial, due to the proportionally small acreage where hybrid seed 

corn is grown. The late stage glyphosate applications will be made only on hybrid maize seed 

production acres that comprise 0.6% of total maize acres in the U.S. The acreage used for hybrid 

seed production has been relatively constant (Monsanto, 2010), with yearly fluctuations in U.S. 

corn acreage (USDA-NASS, 2012a) often exceeding the annual acreage used for hybrid corn 

seed production.

4.2.3 Hybrid Corn Seed Production

No Action Alternative: Seed Corn Production: Pollen Control

Seed corn production differs from hybrid seed production in the details of crop spacing, 

isolation, treatments that affect the pollination of the crop and harvest. Hybrid maize seed 

producers typically must physically isolate production plots from neighboring maize seed or 

grain production fields to avoid cross-pollination during the flowering stage by wind-borne 

pollen. The isolation distance from other maize is regulated by seed certification standards, and 

is typically at least 660 feet from other maize.

Pollen control refers to practices that ensure complete pollination of female parent inbreds by 

male parent inbreds to produce hybrid maize seed. Pollen control in hybrid maize seed 

production is extremely critical for producing hybrid maize seed with high genetic purity. 

Detasseling is the most widely used method of pollen control in the production of hybrid maize 

seed. The detasseling period begins prior to pollen shedding when tassels have emerged from the 

leaf sheath. Tassels are physically removed from a female parent inbred maize line after the 

tassel has fully emerged and before undergoing pollen shed or silk emergence occurs. Removal 

of all of the tassels from the female parent inbred avoids the risk of self-fertilization of the 

female parent inbred. Instead, fertilization of the detasseled female parent inbreds is achieved by 

pollination from a genetically distinct male parent inbred line that is grown in close proximity. 

Pollen shed usually occurs in maize over a five to eight day period with the peak production on 

about the third day (Hoeft et al., 2000a). Pollen shed is not always a continuous process, and can 

stop and restart depending on climatic conditions or when additional pollen has matured (Hoeft 

et al., 2000a). As a result, the window for detasseling that averages 3-4 days prior to the

initiation of pollen shed is a critical step in maize seed production that, once begun, must be 

performed on a regular basis, regardless of weather. Removal of the tassel from the female 

parent inbred in seed production fields is accomplished by a combination of mechanical and 

manual detasseling methods (Wych, 1988).

The pollination process must be accompanied by additional steps such as hiring of labor to begin 

and complete detasseling by hand to prevent pollination of inbreds by undesired pollen. Other

changes include time of harvest differences of when the crop moisture content is adequate for 

55
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

seed production, and harvesting that includes gathering of complete cobs, not usually with

combines that remove kernels from the cobs in the field (Monsanto, 2010).

Preferred Alternative: Hybrid Seed Corn Production.

The Monsanto Company developed MON 87427 corn to provide flexibility and reduced 

production costs in hybrid corn seed production. The MON 87427 trait permits the use of 

glyphosate to eliminate viable pollen, effectively allowing MON 87427 corn to function as a 

detasseled female inbred parent. This inducible male-sterile phenotype does not substantially 

alter other aspects of growth and development (USDA-APHIS, 2012), thus allowing MON 

87427 corn to be integrated into current hybrid corn seed production practices.

Certified seed production is a carefully managed process (Section VIII.B.2) for maintaining high 

quality seed stocks, an essential basis for U.S. agriculture. Seed producers have learned to 

account for and manage pollen flow both within a seed production field and between nearby 

fields. For several decades the hybrid maize seed industry has created and adopted systems to 

maintain and preserve the purity of maize germplasm developed for commodity and specialty 

uses. To maintain the genetic purity of hybrid maize populations, seed production activities for 

each maize type are isolated from one another and from commercial grain production (Wych, 

1988). Isolation is achieved through various means, but may include physical separation to 

prevent cross pollination, temporal isolation by planting at different times to stagger pollination 

times of different materials, detasseling, and the use of cytoplasmic male sterility. The goal of 

detasseling and CMS is to produce hybrid seed that meets the necessary purity for hybrid maize 

seed. Seed must meet state and federal seed standards and labeling requirements. AOSCA is 

dedicated to assisting companies in the production, identification, distribution and promotion of 

certified classes of seed. AOSCA establishes minimum standards for quality and identity. Its 

goal is to standardize certification regulations and procedures internationally so companies 

compete with one set of standards. The association cooperates with the OECD and other 

international organizations to develop standards, regulations, procedures, and policies to expedite 

movement of seed and encourage international commerce in improved seed products.

The AOSCA standards for maize seed are described in the petition, Section I.3.5

(Monsanto(Monsanto, 2010). MON 87427 meets or exceeds established seed purity standards 

(Feng et al., 2009).Thus, adoption of MON 87427 is not expected to have a significant impact on 

production of certified hybrid maize seed.

It is anticipated that hybrid seed containing MON 87427 will be produced and marketed in 

accordance with OECD and AOSCA standards and the U.S. Federal Seed Act, and will have no 

adverse impact on current hybrid seed production practices or the ability of breeders and seed 

producers to meet these standards.

Induced Male Sterility and MON 87427 Corn

Glyphosate is a systemic, broad-spectrum herbicide that inhibits aromatic amino acid synthesis 

in susceptible plants. Following glyphosate exposure, translocation of the molecule to 

meristimatic regions occur within the plant, following a typical source/sink relationship. 

Regions of meristimatic activity within a plant may include apical nodes, leaf primordia, and 

areas of reproductive development.

56
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

The inducible male-sterile phenotype is conferred through the introduction of a specific 

promoter-intron combination (35S-hsp70) used to drive expression of the cp4 epsps coding 

sequence (Figure 12). Glyphosate tolerance is conferred by the CP4 EPSPS protein, but only in 

MON 87427 corn vegetative tissues (leaves, stalks, and roots) and tissues derived from the 

female reproductive system (seed, grain, and silks). MON 87427 corn accumulates little or no 

CP4 EPSPS protein in tapetum cells and pollen microspores. Following exposure to glyphosate 

during male reproductive system development (V8 to V13), MON 87427 pollen microspore 

viability is compromised through insufficient nutrient transport to the developing pollen 

microspore (tapetum) and death of the pollen microspore itself. The introduced regulatory 

element, 35S-hsp70, is derived from the cauliflower mosaic virus (35S) and corn (hsp70). The 

cp4 epsps coding sequence is derived from Agrobacterium sp. strain CP4. Specific details 

regarding additional T-DNA components and generation of MON 87427 corn may be found in 

the MON 87427 petition (Monsanto, 2010) and the APHIS plant pest risk assessment (USDAAPHIS, 2012).

Application of glyphosate on MON 87427 corn during the vegetative growth phase will produce 

a phenotype similar to any other glyphosate-tolerant corn variety. If glyphosate is applied on 

MON 87427 between V8 and V13 (tassel/pollen microspore development), viable pollen 

production is compromised. However, growth of MON 87427 and development of its female 

reproductive system is not inhibited, due to the tissue specificity of the e35S-hsp70 regulatory 

element driving expression of cp4 epsps. When the male-sterile phenotype is induced, MON 

87427 performs like a detasseled female inbred in hybrid corn seed production systems, limiting 

self-fertilization and ensuring cross fertilization with male inbred pollen donor corn plants. 

Cultivation of MON 87427 corn will widen the glyphosate application window in hybrid corn 

seed production systems (Monsanto, 2010). In contrast to corn containing the Roundup Ready 

2® trait, MON 87427 corn will be able to tolerate glyphosate exposure past stage V8 (Monsanto, 

2010). Additionally, when compared to typical hybrid corn seed production systems, the window 

of opportunity to limit self-fertilization of female inbred parents is wider (Figure 13 ) following 

the cultivation of MON 87427 corn (Monsanto, 2010). Manual or mechanical detasseling 

generally occurs over a three to four day window in typical hybrid corn seed production systems, 

while glyphosate may be used to inhibit pollen development over a 14 day period in MON 87427 

corn (Monsanto, 2010). 

Only specifically timed applications of glyphosate will produce the male sterile phenotype 

through tissue-selective glyphosate tolerance, and enable specific cross pollinations to be made 

in maize (Monsanto, 2010). Glyphosate is a systemic herbicide that is readily translocated in 

plants to areas of high meristematic activity, following a typical source to sink distribution 

(Franz, et al., 1997a). Early tassel growth stages start at the approximate maize vegetative growth 

stage V9, therefore glyphosate applications made at approximately this time allow maximum 

translocation of glyphosate to the male reproductive tissues, and selectively cause cell death in 

only those cells that are not tolerant to glyphosate (i.e. tapetum and pollen cells). Glyphosate 

applications made during early vegetative stages, consistent with the application timing specified 

in the current Roundup agricultural product label for weed control purposes, do not affect pollen 

production of MON 87427 because the sensitive male reproductive tissues are not actively 

developing at that time.

57
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Figure 12. Genes and phenotype of MON 87427

(A) TDNA insert conferring tissue-specific glyphosate tolerance in MON 87427. 

LB/RB = left/right border; e35s - promoter from cauliflower mosaic virus; hsp70 - first intron from corn heat 

shock protein 70; CTP2 - transit peptide from Arabidopsis thaliana; cp4 epsps - codon-optimized epsps from 

Agrobacterium sp. strain CP4. (B) Diagram showing glyphosate tolerant tissues in MON 87427. Figure 

derived from The Robinson Library (2011). Source: Monsanto (2010).

Figure 13. Comparison of glyphosate application timing between Roundup Ready 2® and MON 87427 corn.

Figure derived from ISU (2012). Source: Monsanto (2010).

58
EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

Using the hybridization system made possible with MON 87427, weed management practices in 

the production of hybrid maize seed are anticipated to be substantially the same as current hybrid 

maize seed production practices, with the added option of using glyphosate for early postemergent weed control Monsanto, 2010). Weed management practices in the cultivation of 

commercial maize with MON 87427 stacked with other already approved glyphosate-tolerant 

maize traits will also remain unchanged (Monsanto, 2010). Producers of hybrid maize seed and 

growers of commercial maize will be able to achieve the same high level of weed control as 

other biotechnology-derived herbicide tolerant maize hybrids. Additionally, because MON 

87427 is agronomically and phenotypically equivalent to conventional maize as described 

earlier, it is not anticipated that MON 87427 will respond differently to commonly used 

herbicides, except glyphosate (Monsanto. 2010).

Applications of glyphosate will be made only on production acres of hybrid maize seed and these 

are only 0.6% of total maize acres in the U.S. Currently registered uses of glyphosate do “not 

pose unreasonable risks or adverse effects to humans or the environment” as determined by the 

EPA (U.S. EPA, 1993). Glyphosate has been authorized by the EPA for in-season, post-emergent 

use in a variety of crops (U.S. EPA, 1993). Additionally, the EPA’s evaluation of glyphosate use 

on glyphosate-tolerant maize covers all uses in maize to a maximum amount of six pounds acid 

equivalent per acre (lbs a.e./acre). This rate will not be exceeded in MON 87427 even with the 

anticipated additional applications of glyphosate at the V8 through V13 growth stage or in hybrid 

seed production using this trait (Roundup PowerMAX Herbicide, 2007; 2008; Roundup 

WeatherMAX Herbicide, 2002; 2009).

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EA of MON 87427 Glyphosate Tolerant Male Sterile Corn (10-281-01)

4.2.4 Organic Corn Production

Organic production plans prepared pursuant to the National Organic Program (NOP) include 

practical methods to protect organically-produced crops from accidental admixture with GE 

materials. Genetic admixture of organic corn with GE corn varieties is a concern of some 

growers because corn naturally cross-pollinates (Moncada and Sheaffer, 2010). Typically, 

organic growers use more than one method to prevent unwanted pollen or other material from 

entering their fields including: isolation of the farm; physical barriers or buffer zones between 

organic production and non-organic production; planting border or barrier rows to intercept 

pollen; changing planting schedules to ensure flowering at different times; and formal 

communications between neighboring (NCAT, 2003; Watrud et al., 2004; Baier, 2008). These 

practices follow the same system utilized for the cultivation of Certified seed under the AOSCA 

procedures. During the cultivation period, cross-pollination is managed by recognizing corn 

pollen dispersal patterns and maintaining adequate distances between fields (Thomison, 2009; 

Mallory-Smith and Sanchez-Olguin, 2010). A minimum isolation distance of 250 feet between 

varieties is recommended; whereas, 700 feet is preferred for complete isolation (CCSP, 2008). 

APHIS recognizes that producers of non-GE corn, particularly producers who sell their products 

to markets sensitive to GE traits (e.g., organic or some export markets), reasonably can be 

assumed to be using practices on their farm to protect their crop from unwanted substances, and 

genetic admixture and thus maintain their price premium. APHIS will assume that growers of 

organic corn are already using, or have the ability to use, these common practices as APHIS’s 

baseline for the analysis of the alternatives.

Organic corn acreage has increased over time concurrent with the increase in GE corn 

cultivation. Since 1995, organic corn acreage has increased from approximately 32,000 acres to 

over 194,000 acres in 2008 although these acres have declined to 135,000 in 2011 (USDA-ERS, 

2011d-a; USDA-NASS, 2012f)). Since its introduction in 1995, GE corn is now cultivated on 

over 88% of the U.S. acreage (USDA-NASS, 2012b). This concurrent growth of organic crops 

and GE corn is indicative of the successful adoption of these coexistence strategies. The size of 

the seed corn acreage compared to the current size of organic production is nearly four-old 

higher. Historically, organic corn production represents a small percentage (approximately, 

0.2%) of total U.S. corn acreage (USDA-ERS, 2011d-b). The percentage of corn acreage 

dedicated to organic corn is not anticipated to change under either the No Action or the Preferred 

Alternative.

No Action Alternative: Organic Corn Production

No change in availability of inbreds or conventional (GE or non GE) corn varieties is expected. 

Those corn varieties that are developed for organic production are also expected to remain the 

same under the No Action Alternative. Commercial production of conventional and organic 

corn is not expected to change and likely will remain the same under the No Action Alternative. 

Organic growers are already coexisting with commercial production of conventional and GE 

corn. The grower strategies employed to support this coexistence are not expected to change and 

likely will remain the same under the No Action Alternative. Planting and production of GE, 

non-GE, and organic corn will continue to fluctuate with market demands, as it has over the last 

10 years, and these markets are likely to continue to fluctuate under the No Action Alternative 

(USDA-ERS, 2011a; USDA-ERS, 2011b). 

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It is important to note that the current NOP regulations do not specify an acceptable threshold 

level for the adventitious presence of GE materials in an organic-labeled product. The 

unintentional presence of the products of excluded methods will not affect the status of an 

organic product or operation when the operation has not used excluded methods and has taken 

reasonable steps to avoid contact with the products of excluded methods as detailed in their 

approved organic system plan (Ronald and Fouce, 2006; USDA-AMS, 2010). However, certain 

markets or contracts may have defined thresholds which growers need to attain (Non-GMOProject, 2012).

Preferred Alternative: Organic Corn Production

The MON 87427 trait production in female inbreds for glyphosate resistant will not change any 

conditions of the corn market place or impose any new production issues that are any different 

from the herbicide-resistant varieties that are already in use by farmers. MON 87427 corn 

allowing growers to use glyphosate-dependent sterility should not present any new impacts for 

organic and other specialty corn producers and consumers different from those of existing 

varieties that require detasseling operations for seed production.

Organic producers employ a variety of measures to manage identity and preserve the integrity of 

organic production systems (NCAT, 2003). The trend in the cultivation of GE corn, non-GE, 

and organic corn varieties, and the corresponding production systems to maintain varietal 

integrity, are likely to remain the same as the No Action Alternative.

According to the petition, agronomic trials conducted in 2008 in a variety of locations in the U.S. 

demonstrated that MON 87427 corn is not significantly different in plant growth, yield, and 

reproductive capacity from its nontransgenic counterpart (USDA-APHIS, 2012). No differences 

were observed in pollen diameter, weight, and viability. Therefore, MON 87427 corn is 

expected to present a no greater risk of cross-pollination than that of existing corn cultivars. The 

practices currently employed to preserve and maintain purity of organic production systems 

would not require changes to accommodate the production of MON 87427 corn. 

Organic corn production acres are only 39% of total US seed production acres, assuming the low 

average estimate of corn seed acres and using the 2008 values for organic corn production 

(USDA-ERS, 2010b) Historically, organic corn production represents a small percentage 

(approximately, 0.2%) of total U.S. corn acreage (USDA-ERS, 2011b). Organic production

likely would remain small regardless of whether MON 87427 corn or other new varieties of GE 

or non-GE corn varieties, , become available for commercial corn production. 

4.3 Physical Environment

4.3.1 Water Resources

No Action Alternative: Water Resources

Production of hybrid seed corn differs somewhat from hybrid commercial corn production in 

some protocols that impact water resources, including plant total residues expected (inbreds are 

shorter than hybrids) and differences of herbicides employed, but hybrid corn seed production is 

likely to have no greater impacts on water resources than those of conventional production of 

corn. Irrigation from surface and subsurface sources can reduce water quantity and impact water 

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quality by the used water acquiring increased sediment, nutrients, and chemicals adsorbed to soil 

that is subsequently leached to groundwater, or returned to surface water. Recent estimates 

indicate only about 11.0% of corn acreage was irrigated in the U.S in 2010(NCGA, 2011). 

As discussed in Subsection 2.2.1, Water Resources, fertilizer and pesticide use has the potential 

to impact water quality. In 2010, fertilizer (primarily nitrogen) was applied to the majority of 

commercial corn acres, and herbicides applied to 98% of planted corn (USDA-NASS, 2011a). 

Of the treated acres, glyphosate was the most commonly applied herbicide active ingredient that 

year (USDA-NASS, 2011a). When used consistent with registered uses and EPA-approved 

labels, glyphosate presents minimal risk to surface and groundwater.

Some differences exist as earlier noted (Section 2.2.2), in the types of herbicides used on seed 

production acres compared to the most common conventional production acres. Herbicides can 

potentially be washed into water resources following heavy rainfall. Indirect impacts from 

herbicide use of the five herbicides earlier identified for corn seed production are not likely to 

present greater leaching (Gillespie et al. 2011) or transport risks (except primisulfuron with 

mobility to 9 inches, but limited solubility (Primisulfuron-Methyl - Herbicide Profile June, 1990. 

EPA Pesticide Fact Sheet) than glyphosate.

Hybrid seed producers may not have available inbreds that are all glyphosate resistant (usually 

only in one parental line (Monsanto, 2010), so use of postemergent glyphosate would be 

infrequent on acres on which seed production is currently undertaken. Weeds on seed 

production acres would be similar weeds on adjacent acres that the same grower uses for 

commercial corn production. Likewise, there is no expectation that quantities of the herbicides 

presently available to seed growers will be consistently used more often than the glyphosate or 

glufosinate used by conventional growers. If anything, growers may use quantitatively less 

herbicide, because post emergent application of these other herbicides can only be made for a 

short part of the corn development cycle. No survey exists for preferred tillage methods on corn 

seed production acres, although both rotary hoes and cultivators are notably used for seed 

production (Bennett, N.D.). Presumably commercial and seed production acres have similar 

tillage needs, and are dealt with similarly, since the same growers who produce seed corn also 

produce commercial corn, and herbicides are available for each crop.

The size and also the total mass of inbred plants used in hybrid seed production may be less than 

that of conventional plants. Studies indicate that multiple seasons of corn crop residue may 

reduce subsequent corn yield, since additional residue from continuous corn production has such 

an impact (Gentry et al., 2013).Thus, hybrid seed producers are likely to have less residue 

production than commodity corn producers, which may provide some benefit to inbreds when 

grown continuously and which are already sparingly productive.

Seed corn is presently grown by contractors most likely on the same acreage as that on which 

their commercial corn is grown, but mostly in locations where soil water holding capacity is 

high, and water resources are abundant. Seed companies will likely select seed corn production 

acres to be those on which the highest likely moisture levels can be assured (either natural or 

irrigation-available acres). However, since the contract growers who produce most of the seed 

for seed companies would be growing other corn or corn rotation crops on these same acres, 

there is not likely to be any difference in water use. Tillage protocols are also relevant to how 

much water may runoff planted fields. As described in Section 2.1.2, tillage in seed corn is 

predominately conservation tillage, but not no-till. The reasons for this difference from

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conventional farming of corn is that the inbreds under no-till have growth and emergence 

problems, and are more affected by susceptibility to disease and insects (Monsanto, 2010), 

whose incidence may be greater under no-till. In addition, soil under no-till also remains colder 

and wetter during spring, thus also increasing pest susceptibility. A earlier noted, conservation 

tillage is the most frequent protocol in both hybrid seed and corn for grain production. As noted 

in section 2.1.1, conservation tillage helps minimize any impacts of maize production on water 

quality by reducing soil erosion is likely similar in extent in hybrid seed corn and commercial 

production.

As discussed in Subsection 4.2.1, Acreage and Area of Corn Production, commodity corn is 

expected to continue to be a major crop in the U.S., with a predicted increase in production from 

approximately 88 million acres of land in 2010 to between 90 and 92 million acres through 2020 

(USDA-OCE, 2011a). Current agronomic practices associated with corn production that have 

potential to impact water quality or quantity include tillage, agricultural inputs such as fertilizer 

and pesticide use, and irrigation. The majority of herbicide-resistant corn grown in the U.S. is 

glyphosate-resistant (Duke and Powles, 2009). 

No expected changes to water use associated with corn production is expected for this 

alternative. Under the no action alternative MON 87427 would remain a regulated article and 

would not be available to hybrid maize seed producers. Maize hybrid seed producers would 

continue to produce seed using current detasseling methods with no anticipated changes in seed 

production acres or land use. In terms of water quality, impacts to the environment under the no 

action alternative would not change from the current conditions and therefore, would not result 

in significant impacts. As discussed above, both the approval in whole and no action alternatives 

would result in no significant changes to water quality.

Preferred Alternative: Water Resources 

Water quality could be impacted either directly by MON 87427 via plant material impacts on 

water resources, or indirectly via impacts from the use of glyphosate or tillage practices 

associated with the planting of MON 87427. Conservation tillage, a system that leaves 30% or 

more of the previous crop residue covering the soil when planting another crop has been 

increasingly employed in commercial maize and hybrid maize seed production acres, and helps 

minimize any impacts of maize production on water quality by reducing soil erosion.

In terms of potential direct impacts on water quality, the CP4 EPSPS protein contained in MON 

87427 is a member of the larger family of EPSPS proteins that are ubiquitous in plants and 

microbes in the environment (CaJacob et al., 2004).The mode of action of this family of proteins 

is well known (Alibhai and Stallings, 2001) and the introduced CP4 EPSPS protein itself was 

derived from a common soil bacterium (Agrobacterium sp. strain CP4). The safety of CP4 

EPSPS protein present in other glyphosate-tolerant crops has been extensively evaluated 

(Harrison, et al., 1996), and the U.S. EPA has granted a tolerance exemption for CP4 EPSPS. A 

history of safe use of CP4 EPSPS is supported by the lack of any documented reports of adverse 

effects since the introduction of Roundup Ready crops. Therefore, it is unlikely that the 

presence of CP4 EPSPS protein in MON 87427 will have a significant impact on water quality. 

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Under full deregulation of MON 87427 hybrid seed producers would be able to use glyphosate in 

seed production fields, which has not been possible previously since inbreds often did not have 

glyphosate resistance. MON 87427 corn’s nonregulated status under the Preferred Alternative 

would not present any qualitatively different impacts on water resources than existing varieties 

of glyphosate-resistant corn and their weed management options. Just as commercial growers of 

particularly glyphosate resistant corn may use both glyphosate and cultivation or glyphosate in 

conservation tillage systems, so also growers of corn seed will doubtless use the weed 

management potential of glyphosate, and also cultivation when needed. As MON 87427 corn is 

similar in its growth and agronomic characteristics to its control cultivars and other nonregulated 

glyphosate-resistant maize lines (USDA-APHIS, 2012). Greater than 80% of current maize acres 

contain the same glyphosate tolerance trait as in MON 87427. No changes to irrigation and other 

agronomic practices such as fertilizer and insecticide or fungicide applications, that have the 

potential to affect water quality or quantity, would occur as a result of this alternative.

Current inbreds do not all carry traits for glyphosate resistance, and the herbicide is not used in 

hybrid production. However, the corn seed crops must be treated with other herbicides, and 

these would no longer be needed; thus, fewer types of herbicides would likely enter water 

resources, some of which are more persistent than glyphosate (such as primisulfuron); 

glyphosate possesses a relatively short environmental half-life and limited effects on nontarget 

animals. It is not likely that use of glyphosate with MON 87427 seed corn production would 

have a significant impact on water resources.

4.3.2 Soil Quality 

No Action Alternative: Soil Quality

The no action alternative would continue the practice of pollen control by use of detasseling 

operations for hybrid seed production. One consequence of detasseling is that multiple passes of 

heavy vehicles must be made to transport the mechanical cutters along with teams of detasselers 

to complete the work . Typically, vehicles including a rotating blade to remove the tassels are 

driven through the field, and a second puller type detasseler may then follow within a few days 

to continue to remove tassels. Because the detasseling is not complete after the two mechanical 

passes, hand labor must be used to complete the process and so prevent self-pollination and 

resulting mixture of seed types. Each vehicular pass increases compaction of soil and may limit 

good root penetration (Hoefft et al., 2000)

Both hybrid seed and commodity corn production use agronomic practices that benefit soil 

quality and include contouring, and use of cover crops to limit the time soil is exposed to wind 

and rain. Still other beneficial practices are the introduction of depleted certain soil nutrients, 

crop rotation, tillage for crop establishment and windbreaks which are the same or generally 

similar in both types of production. Agronomic practices that differ include weed control, not in 

general practice of herbicide use with some tillage, but in the types of herbicides used. These 

differences are cited in section 2.1.2 and some of the consequences of their use in soil noted in 

Section 4.3.1. 

The production of conventional herbicide-resistant GE corn utilizes EPA-registered pesticides 

for insect and plant pest management, including glyphosate. In 2010, herbicides were applied to 

98% of cropland planted to corn (USDA-NASS, 2011a). Pesticides (including herbicide, 

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insecticide, and fungicide) consist of active ingredients that control pests and inert ingredients to 

facilitate their application. In 2010, 66% of all active ingredients applied to corn treated with 

pesticides were herbicidal (USDA-NASS, 2011a), indicating their widespread use and potential 

to affect the environment The amount of herbicides other than glyphosate applied to corn has 

declined over the last decade (NRC, 2010) (see Subsection 4.2.2, Agronomic Practices). The 

environmental risks of pesticide use are assessed by the EPA in the pesticide registration process 

and are regularly re-evaluated by the EPA to maintain their registered status under FIFRA. In 

this process, steps to reduce pesticide residuals and persistence in soil are included on a 

pesticide’s label and approved by the EPA. 

As discussed in Subsection 2.2.2, Soil Quality, there have been several reports of the long-term 

use of glyphosate immobilizing manganese and potentially reducing plant uptake or ability to use 

this nutrient (Eker et al., 2006; Neumann et al., 2006; Ozturk et al., 2008; Cakmak et al., 2009; 

Huber, 2010). Additional investigations have disclosed that with the legally permissible rate of 

glyphosate application, no effects are seen on either greenhouse or field micronutrients, 

including manganese (Duke et al. 2012). The current understanding is manganese-glyphosate 

interaction resulting in manganese problems appears to occur in areas where manganese 

deficiency already exists (Hartzler, 2010), and producers should be prepared to address it with 

agronomic practices designed to augment manganese (Camberato et al., 2010).

Preferred Alternative: Soil Quality

Approving a determination of nonregulated status to MON 87427 corn would not affect soil 

quality. Use of MON 87427 for hybrid seed production will also reduce soil compaction, as 

there will be no need to run heavy detasseling machinery across seed fields. Compaction from 

detasseling operations, especially when fields are wet and operations must be conducted to 

prevent pollen flow, can also increase erosion, and require more tillage in the following season. 

Since detasseling damages plants and reduces plant health, seed yields will be increased by using 

the chemical sterilization process, resulting in a potential reduction in acres needed for parent 

inbred seed production. 

MON 87427 corn is agronomically and compositionally equivalent to other glyphosate resistant

corn, and other GE and non-GE corn varieties currently in commercial production (Monsanto, 

2010; USDA-APHIS, 2012). Most corn acreage is currently planted to either herbicide-resistantonly corn or herbicide-resistant corn varieties stacked with other GE traits (Duke and Powles, 

2009; USDA-NASS, 2012b). Agronomic practices such as tillage and the application of 

agricultural chemicals that could impact soil quality or its community structure and function 

would not change from those currently used for production of other nonregulated glyphosateresistant corn varieties.

Since it is expected to replace non glyphosate-resistant inbreds, the nonregulated status of MON 

87427 corn would not affect weed management practices or their effects on soil quality as 

practiced on the majority of corn acres planted to glyphosate resistant varieties. As discussed 

above, more diverse weed management tactics potentially including more aggressive tillage 

practices that can affect soil quality may be needed to address the increasing emergence of 

glyphosate-resistant weeds (Beckie, 2006; Owen et al., 2011). As described under the No Action 

Alternative, the weed management tactics selected by an individual producer would be 

dependent upon many factors (Beckie, 2006). Weed management practices needed for the 

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production of MON 87427 corn would be no different than those used in other commercially 

available glyphosate-resistant corn cultivars. 

As discussed above, the impact of glyphosate on manganese availability for uptake by crops after 

its application is an issue that may be addressed with common practices used to augment 

deficient soil nutrients. MON 87427 corn is agronomically similar to other GE and non-GE corn 

varieties and the same methods used to address manganese deficiency in current corn production 

would also be used with MON 87427 corn; therefore, impacts to soil quality under the Preferred 

Alternative would be the same as the No Action Alternative.

4.3.3 Air Quality

No Action: Air Quality 

The process required for detasseling corn inbreds which are used for seed production does add 

indirectly to greenhouse gases not produced by conventional commodity corn agriculture. 

Typically, vehicles equipped with a rotating blade to remove corn tassels are driven through the 

field, and a second puller type detasseler may then follow within a few days to continue to 

remove tassels. Because the detasseling is not complete after the two mechanical passes, hand 

labor must be used to complete the process and so prevent self-pollination and resulting mixture 

of seed types. The vehicles contribute to greenhouse gases as they are driven through the field

multiple times. 

Preferred Alternative: Air Quality

Seed production using inbreds expressing MON 87427 will result in reduced fossil fuel use and 

in soil compaction, because there will be no need to run heavy detasseling machinery across seed 

fields. Instead, either an aerial glyphosate delivery or a herbicide sprayer will deliver the 

glyphosate to produce sterile female parents. Using a glyphosate based system to produce male 

sterility will result in fewer engine emissions from the frequent use of vehicles for the necessary 

detasseling operations in seed production. Since detasseling damages plants and reduces plant 

health, seed yields will be increased by using the chemical sterilization process, which could 

potentially result in at least potential reduction in acres needed for hybrid seed production. The 

reduction in needed seed production acreage and the unneeded trips by detasseling operations 

could lead to modest declines in overall greenhouse gas emissions.

Using a glyphosate based system to produce male sterility will result in fewer engine emissions 

from the frequent use of vehicles for the necessary detasseling operations in seed production.

Changes to agronomic practices that are sources of emissions or positively contribute to air 

quality will result from different equipment used, and less vehicular traffic in the field following 

a decision that MON 87427 corn is nonregulated. 

4.3.4 Climate Change

No Action Alternative: Climate Change

The major sources of GHG emissions associated with crop production are soil N2O emissions, 

soil CO2 and CH4 fluxes, and CO2 emissions associated with agricultural inputs and farm 

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equipment operation (US-EPA, 2012). Agricultural practices that produce CO2 emissions 

include liming and the application of urea fertilization (i.e., nitrogen) to agricultural soils, and 

CH4 produced by enteric fermentation and animal manure management. Agricultural soil 

management activities including fertilizer application and cropping practices are the largest 

source of N2O emissions in the U.S. (US-EPA, 2012). Corn crop production primarily affects 

climate-changing emissions through: (1) fossil fuel burning equipment used for production and 

nitrogen fertilization producing CO2; and, (2) cropping production practices including residue 

management and tillage (see Subsection 2.2.4, Climate Change, for detailed discussion). The 

adoption of herbicide-resistant crops and the attendant increase in conservation tillage has been 

identified as providing climate change benefits. Conservation tillage practices increase crop 

residue on the surface, promoting the production of SOC and protecting the soil from erosive 

forces that would release SOC back to the air. These practices also reduce the use of emissionsproducing equipment normally used in tilling. The USDA has estimated approximately 74.5% 

of planted corn acres in 2010 were produced under conservation tillage practices ranging from 

no-till to reduced till (USDA-ERS, 2011b). Recent increases in the incidence of herbicideresistant weeds, including glyphosate, may require increased tillage to effect control (Beckie, 

2006; Owen et al., 2011) although new herbicide use protocols exist and would likely be 

preferred by growers over changes in tillage. Tillage increases could potentially release more 

SOC sequestered in upper soil layers; however, the particular weed management methods 

employed by individual farmers would be dependent on many factors unique to the individual 

farm, including its agroecological setting, the particular problem weed type, and on-farm 

economics (Beckie, 2006).

Nitrogen is also the most-used fertilizer in U.S. corn production (USDA-NASS, 2011a). 

Nitrogen in the form of urea is commonly applied to cornfields and contributes CO2 emissions 

from the urea volatilization which also produces ammonia. Recommended BMPs to reduce 

volatilization include incorporating urea with equipment, accompanied with irrigation or rainfall; 

topdressing urea when temperatures and soil moisture levels are low; and avoiding topdressing 

urea in higher risk conditions, except if there is an opportunity to incorporate the urea within a 

few days of application (Jones et al., 2007).

Impacts of climate change are apparent in Corn Belt states at the present time. For example, in 

Iowa precipitation totals are significantly increasing and summers have increasing incidents of 

heavy precipitation (Iowa-General-Assembly, 2011). Consequently, farmers are installing 

increasing amounts of drain tile to respond to increased flooding of fields (Iowa-GeneralAssembly, 2011). With increased drain tiling, greater nitrate-nitrogen losses are incurred (David 

et al., 2010; Iowa-General-Assembly, 2011). Weeds have increased and more pesticides are used 

which accompanies reduced herbicide efficacy (Iowa-General-Assembly, 2011). Delayed 

planting and increased replanting attend increased heavy precipitation (Iowa-General-Assembly, 

2011). Because the growing season has increased, growers have begun to use corn maturity 

groups suitable for lower latitudes, which may increase the yield (E. Takle, Iowa State

University, USDA Climate Change Seminar, Pers. Comm. 2012 (Krapfl, 2012). As climate 

change begins to be manifest in additional US corn growing regions, growers will continue to 

make accommodations to maintain production and yield. 

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Preferred Alternative: Climate Change

Because corn line MON 87427 is similar to other GE and non-GE corn cultivars in terms of its 

growth habit, agronomic properties, disease susceptibility, and composition (USDA-APHIS, 

2012), several of the agronomic practices required to cultivate corn with the MON 87427 trait 

would be no different than those used to produce these other herbicide-resistant corn cultivars. 

However the process required for detasseling corn inbreds which are used for hybrid seed 

production does produce additional greenhouse gases not produced by commercial commodity 

agriculture. Typically, vehicles bearing equipment to remove the tassels are driven through the 

field, first a cutter with rotating blades and a second puller type detasseler may then follow 

within a few days to continue to remove tassels. Because the detasseling is not complete after 

the two mechanical passes, hand labor must be used to complete the process and so prevent selfpollination and resulting mixture of seed types. The vehicles contribute greenhouse gases as 

these are driven through the fields. A possible decline in GHG emissions would be expected 

from determining nonregulated status for MON 87427. To the extent that the cultivation of a 

corn variety expressing resistance to glyphosate allows a grower to not decrease conservation

tillage, the potential impacts associated with the Preferred Alternative would be the same as 

those under the No Action Alternative.

The MON 87427 cp4 epspsgene conveyed to corn inbreds for hybrid seed production is similar 

to the same cp4 epsps in commercially available glyphosate-resistant corn varieties. The majority 

of planted corn in the U.S. is herbicide resistant (73% in 2012) primarily consisting of 

glyphosate-resistant cultivars (Duke and Powles, 2009; USDA-NASS, 2012b). Conferring 

nonregulated status to corn line MON 87427 would not likely change the development of 

glyphosate-resistant weeds, since it is most likely to be planted on acreage typically planted to

glyphosate-resistant commercial corn; thus, no change to GHG emissions would occur from use 

of fossil fuels, release of SOC, or carbon sequestration in plant residue and soils compared to 

these other varieties under the Preferred Alternative. As discussed under the No Action 

Alternative above, more diverse weed management tactics, potentially those including more 

aggressive tillage practices that can affect GHG emissions, may be needed in the long term to 

address the increasing emergence of glyphosate-resistant weeds (Beckie, 2006; Owen et al., 

2011). Since corn line MON 87427 is expected to be grown with mostly similar management 

practices used on other glyphosate-resistant cultivars, its nonregulated status would not alter 

weed management practices and their effects on GHGs contributing to climate change; therefore, 

the potential impacts to climate change under the Preferred Alternative would be similar to the 

No Action Alternative.

When comparing seed production practices under the No Action Alternative, use of inbreds 

expressing MON 87427 for seed production processes will reduce fossil fuel use and soil 

compaction, as there will be no need to run heavy detasseling machinery across seed fields. 

Instead, either an aerial glyphosate delivery or a herbicide sprayer will deliver the glyphosate to 

produce sterile female parents. The reduction in exhaust gas emitting equipment could lead to a 

modest decline in overall greenhouse gas emissions under the Preferred Alternative.

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4.4 Biological Resources

4.4.1 Animal Communities

No Action Alternative: Animal Communities

Under the No Action Alternative, hybrid seed corn production will continue as currently 

practiced while MON 87427 corn remains a regulated article. Seed production practices 

resemble commodity corn production in most details, but with some differences, none likely to 

impact animal communities. The acreage of hybrid corn seed production is about 0.6% of that of 

conventional corn. Cultivation of other glyphosate-resistant GE corn varieties along with nonGE corn will also continue following the trends as noted in Section 2.1.2 Potential impacts of 

GE and non-GE corn production practices on non-target terrestrial (insect, bird, and mammal) 

and aquatic (fish, benthic invertebrate, and herptile) species would be unchanged. 

Corn production potentially impacts animal communities through the conversion of wildlife 

habitat to agricultural purposes. As discussed in Subsection 2.1.2, Acreage and Area of Corn 

Production, hybrid seed corn was produced on about 0.5 million acres, acreage relatively 

unchanging with conventional corn produced on over 96 million acres in 2011, an increase of 

approximately 4.5 million acres over 2011 (USDA-NASS, 2012b). Corn is expected to continue 

to be a major crop in the U.S. through 2020 (USDA-OCE, 2011a). A wide array of wildlife 

occupy or use habitats that are within or adjacent to cornfields (see Subsection 2.3.1, Animal 

Communities). While cornfields are less suitable for wildlife than adjacent pasture, fallow fields, 

windbreaks, or shelterbelts, those in conservation tillage management provide greater benefit for 

wildlife than those in more intensive tillage Under this tillage regime, greater diversity in plant 

species would occur and so provide more habitat and potential food sources, soil would be less 

disturbed, and potentially sediment and agricultural pollutant loading of nearby surface waters 

would be reduced, improving water quality (Brady, 2007; Sharp, 2010).

Glyphosate-resistant corn varieties have been approved as nonregulated since 1997 (USDAAPHIS FR Notice, 2012), and the majority of corn cultivated today is herbicide resistant 

(USDA-ERS, 2011a), primarily glyphosate-resistant (Duke and Powles, 2009). All glyphosateresistant corn varieties currently available on the market have been evaluated for their food and 

feed safety impacts by the FDA. The EPSPS protein that confers glyphosate resistance in MON 

87427 corn is derived from the soil inhabiting species, Agrobacterium spp. strain CP4, which is a 

protein also expressed in a large number of other nonregulated glyphosate tolerant corn and 

soybean lines (Monsanto, 2010). This EPSPS has been earlier evaluated by the FDA, who 

found no safety concerns from its consumption as animal feed (US-FDA, 2000) Consumption 

of nonregulated glyphosate-resistant corn presents minimal risk to animal communities. A final 

food consultation with the FDA for MON 87427 corn was submitted by Monsanto on 15 

December, 2010 and completed 23 March, 2012 (BNF-00126). 

Current corn agronomic practices potentially impacting animal communities include application 

of agricultural inputs, such as fertilizer, herbicides, and pesticides. Both fertilizer and pesticides 

are applied to the majority of corn acres in the U.S. (USDA-NASS, 2011a) and potentially 

impact non-target wildlife from ingestion or spray drift. Glyphosate is the primary herbicide 

applied to herbicide-treated corn acreage in the U.S. (USDA-NASS, 2011a). As discussed in 

Subsection 2.1.2, Agronomic Practices, there are several glyphosate formulations (US-EPA, 

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2009f) that differ in the timing and amount of application to field corn. The environmental risks 

of glyphosate herbicides are assessed by the EPA in the pesticide registration process. The 

glyphosate RED was last accomplished in 1993, and the herbicide is currently undergoing 

registration review scheduled for the final decision in 2015 (US-EPA, 2009e). As discussed in 

Subsection 2.3.1, Animal Communities, the registered uses for glyphosate pose minimal risk to 

animals, but spray drift may adversely impact non-target plants that provide habitat. The EPA is 

evaluating new regulations for labeling and BMPs to control drift (US-EPA, 2009d). When used 

consistent with the EPA-registered uses and labels, glyphosate application in corn presents 

minimal risk to animal communities. In 2010, 66% of all active ingredients applied to corn 

treated with pesticides were herbicidal (USDA-NASS, 2011a).

More diverse weed management tactics that can affect animal communities may be needed to 

address the increasing emergence of glyphosate-resistant and other herbicide-resistant weeds,

potentially including more aggressive tillage practices (Beckie, 2006; Owen et al., 2011). As 

discussed above, more intensive tillage can reduce wildlife habitat and contribute to increased 

sedimentation and pollutants in runoff to nearby surface waters, affecting water quality that 

could impact wildlife. The particular mix of weed management tactics selected by an individual 

producer would be dependent upon many factors, including the agroecological setting, the 

problem weed type, and agronomic and socioeconomic factors important to farmers (Beckie, 

2006). 

Preferred Alternative: Animal Communities

As part of the assessment for the proposed action, APHIS has evaluated the potential effects of 

each alternative on a wide array of wildlife species and their habitats occurring in the U.S. 

Under the Preferred Alternative, a determination of nonregulated status would be extended to 

MON 87427 corn, and it would be available as both a weed management option for hybrid seed 

farmers as well as a technology to sterilize male tissues in female inbreds . As stated above, the 

majority of corn planted in the U.S. today is herbicide and glyphosate resistant (Duke and 

Powles, 2009; USDA-ERS, 2011a). MON 87427 corn is similar in its growth and agronomic 

characteristics to other nonregulated glyphosate-resistant corn lines (Monsanto-Co., 2010; 

USDA-APHIS, 2012); hence, no changes to agronomic practices such as cultivation, crop 

rotation, irrigation, tillage, or agricultural inputs with potential impacts to wildlife and their 

habitat would likely occur under this alternative. 

As discussed in Subsection 2.5, Animal Feed, a final food consultation with the FDA for MON 

87427 corn was submitted by Monsanto on 15 December, 2010 and completed 23 March, 2012 

(BNF-0000126). As discussed in the No Action Alternative, the food safety of the EPSPS 

protein conveying glyphosate resistance was previously established by an FDA evaluation. In 

accordance with FDA (US-FDA, 2011) guidance, since the EPSPS has previously been 

evaluated by the FDA in an earlier food safety evaluation, no new evaluation is required for 

MON 87427 corn commercial distribution. Because the composition of MON 87427 corn is 

similar to other nonregulated glyphosate-resistant corn lines (Monsanto-Co., 2010), with no 

expected hazards associated with its consumption, the risk of MON 87427 corn affecting wildlife 

species is also unlikely, regardless of exposure. 

Commercial use of glyphosate is not expected to change if MON 87427 corn is approved as 

nonregulated. Based upon information provided by Monsanto (Monsanto, 2010), MON 87427

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corn is similar in its growth characteristics to other nonregulated glyphosate-resistant corn. No 

overall increases in glyphosate above those already possible for registered uses of glyphosate 

products on commodity corn would be required to cultivate MON 87427 corn. Consequently, 

there would be no difference in the potential of MON 87427 corn cultivation to impact wildlife 

or habitat from that of other nonregulated glyphosate-resistant corn varieties. As discussed 

above, the EPA is currently evaluating new regulations for labeling and BMPs to control drift 

(US-EPA, 2009d). When used consistent with the EPA-registered uses and labels, glyphosate 

application in MON 87427 corn fields presents minimal risk to animal communities. 

Approving MON 87427 corn as nonregulated would not change the development of glyphosateresistant weeds or the methods used for their control that may impact animal communities, such 

as increased tillage. As discussed above, MON 87427 corn would replace other herbicides 

labeled for use on seed production corn. The label for this product and use of glyphosate for 

weed management is similar to that currently used on the majority of the 73% of corn acres 

planted with herbicide-resistant cultivars (USDA-NASS, 2012b).

Based on the above, the impacts of determining nonregulated status for MON 87427 corn to 

animal communities would be similar to those of the No Action Alternative. 

4.4.2 Plant Communities

No Action Alternative: Plant Communities

Hybrid seed corn can be grown in a wide number of environments, dependent upon appropriate 

soil profiles, and locations where weather is not limiting (Iowa-State-University, 2012). Hybrid 

seed production locations are concentrated in the Midwestern states of the corn belt, as noted in 

Section 2.1.1, and would be found in locations with either abundant water or where irrigation is 

available. Plants communities are varied and adapted to local climate and soil, as well as the 

frequency of natural or human-induced disturbance (Smith and Smith, 2003). Non-crop 

vegetation in cornfields is limited by farmers’ cultivation and weed control practices. Plants 

communities adjacent to cornfields commonly include other crops, borders, hedgerows, 

windbreaks, pastures, and other natural vegetation. The majority of U.S. corn acres are planted 

with GE herbicide-resistant corn cultivars, and genetically engineered traits do not change the 

adaptation to the various agronomic environments in which corn hybrids can be produced. 

Agricultural practices affect plant communities by exerting selection pressures that influence the 

type and composition of plants present in a community. Preparation of fields for planting of 

crops removes other plants that compete for light and nutrients. Natural selection in frequently 

disturbed environments enables colonization by plants exhibiting early germination and rapid 

growth from seedling to sexual maturity, and the ability to reproduce sexually and asexually 

(Baucom and Holt, 2009). These weedy characteristics enable such plants to spread rapidly into 

areas undesired by humans. 

Weeds are the most important pest in agriculture, competing for light, nutrients, and water and 

can significantly affect yields (Gibson et al., 2005; Baucom and Holt, 2009).Weeds commonly 

encountered in hybrid corn production are likely the same as those encountered in commercial 

corn production, since seed corn and commercial corn are likely both rotated on the same 

acreage. These weeds include water hemp, giant ragweed, common lambsquarters, and others as 

described in Subsection 2.3.2, Plant Communities. Agronomic practices common in corn 

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production, such as tillage and herbicide use, impart selection pressures on the weed community 

that can result in shifts in the relative importance of specific weeds (Owen, 2008). In aggressive 

tillage systems, weed diversity tends to decline and annual grasses and broadleaf plants are the 

dominant weeds; whereas, in no-till fields, greater diversity of annual and perennial weed species 

may occur (Baucom and Holt, 2009). The most common weed management tactic in U.S. corn 

production is to use herbicides. Recent estimates indicate herbicides are applied to 98% of 

planted corn acreage, and on that acreage, the most frequently applied herbicide is glyphosate 

(USDA-NASS, 2011a). 

Herbicide resistance occurs when a plant survives the application of an herbicide and reproduces, 

passing on its resistance to new generations. Herbicide-resistant weeds can become 

agronomically important as they out-compete crops and require additional resources to affect 

control. As discussed in Subsection 2.3.2, Plant Communities, weed species resistant to 

glyphosate are becoming agronomically more important in crop production. For example, 

glyphosate-resistant Palmer pigweed (amaranth) is a major economic problem in the Southeast 

U.S. while glyphosate-resistant waterhemp is an economically important weed in Midwestern 

states (Culpepper et al., 2006; Owen, 2008). In response, producers are diversifying weed 

management tactics in corn production to include alternating crops resistant to different herbicide 

modes of action grown in a field, alternating the herbicide modes of action used, practicing more 

crop rotation, and increasing tillage to effect control of herbicide-resistant weeds (Owen et al., 

2011). Weeds are developing resistance to multiple herbicides, but are also controlled with 

adjustments to standard practices, so as to include crop rotation and tillage (Owen et al., 2011)

when overreliance on herbicides obviates such changes.

As discussed above in Subsection 4.3.2, Soil Quality, more diverse weed management tactics, 

potentially including more aggressive tillage practices that can affect soil erosion, may be needed 

to address the increasing emergence of glyphosate-resistant weeds (Beckie, 2006; Owen et al., 

2011). Increased tillage could result in more soil erosion that could consequently increase 

sedimentation and residual pollutant loading of nearby waters. New herbicide protocols for 

managing resistant weeds are available and would likely be preferred by growers, since herbicide 

focused strategies have captured the preponderance of the corn production market. The particular 

mix of weed management tactics selected by an individual producer, however, are dependent 

upon many factors such as the agroecological setting, the problem weed type, and agronomic and 

socioeconomic factors important to farmers (Beckie, 2006). 

For risks of weed resistance to glyphosate, USDA in its various units is funding programs aimed 

at understanding weed resistance development, and managing crops to avoid resistance. At the 

Agricultural Research Service, this includes research programs whose goal is providing 

“recommendations for appropriate rotation frequencies of both crops and herbicides to stymie 

evolution of weed resistance and shifts to naturally tolerant weed species, and cause a general 

reduction in weed populations” as described in the Action Plan for 2008-2013 of the National 

Program 304, Crop Protection and Quarantine (USDA-ARS, 2010). The USDA, National 

Institute of Food and Agriculture (NIFA) recognizes the need for a broad collaboration of 

federal, state, academic and industry endeavors to provide responses to these and other risks to 

which agriculture may be exposed and provides competitive grant awards, such as those of 

Westra and Chisolm (2012) and Davis and Tranel (2012) to support research directed toward 

weed resistance. USDA presently devotes substantial funds to support research, teaching and 

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outreach programs (especially through the support of USDA-Extension staff and programs in 

individual States) for herbicide resistance management, and awarded to agricultural researchers 

and growers. Additionally, farmer organizations such as the National Corn Growers Association 

offer online training to their members for averting development of weed resistance 

(http://ncga.adayana.com/). The Weed Science Society of America has produced a five-module 

training course for certified crop protection specialists and others titled “Current Status of 

Herbicide Resistance in Weeds” which is also available online 

(http://www.pentonag.com/wssa.wrm). Seed technology developers such as Monsanto offer 

courses for certified pesticide applicators, such as “Weed Resistance Management (WRM) in 

Agronomic Row Crops & Trees, Nuts & Vines” (http://www.pentonag.com/CA/AZWRM). 

Finally, state extension services also provide documents online that supply information and 

management tactics for prevention of herbicide resistance, such as that from University of 

Minnesota (Gunsolus, 2008).

As discussed in Subsection 2.3.3, Gene Flow and Weediness, there are no extant populations of 

sexually compatible species related to Z. mays within the continental U.S., its territories, or 

possessions; therefore, (USDA-APHIS, 2012) has concluded there is no significant risk of gene 

flow between cultivated corn and its weedy relatives that may impact plant communities.

Volunteer herbicide-resistant corn pose an additional management challenge when they appear in 

subsequent crops with the same herbicide resistance and can be extensive and problematic (see 

Subsection 2.3.2, Plant Communities). These volunteers arise from spilled corn from the 

previous cropping season. Corn rootworm may infest corn volunteers arising in a glyphosateresistant soybean crop (Marquardt et al., 2012). These volunteers may become another source of 

rootworm infestations for successive corn plantings. Existing agronomic practices, however, are 

effective in the management of such volunteer corn. 

Glyphosate-resistant volunteer corn may be controlled by the application of corn-active 

herbicides (e.g., ACCase and ALS inhibitors), mechanical means, and rotation of crops with 

resistance to different herbicide modes of action (Beckie and Owen, 2007; Zollinger et al., 2011). 

The incidence of glyphosate-resistant volunteer corn in cornfields where corn was not planted 

the year before could be the result of pollen-mediated gene flow. These volunteers can be 

controlled by maintaining adequate spatial or temporal isolation distances between corn crops. 

See Subsection 2.3.3, Gene Flow and Weediness, for a description of pollen-mediated gene flow 

in corn.

The application of an herbicide in corn production has the potential to impact non-target plant 

communities through spray drift, volatilization (evaporation), its adsorption to soils incorporated 

in runoff, leaching, and cleaning and disposal of the equipment used to dispense it. The EPA is 

currently evaluating new regulations for pesticide drift labeling and the identification of BMPs to 

control such drift (US-EPA, 2009d), as well as identifying scientific issues surrounding field 

volatility of conventional pesticides (EPA, 2010a). Glyphosate is currently under review by 

EPA for continued registration of the herbicide, with a reregistration decision expected in 2015 

(US-EPA, 2009e). 

Glyphosate is toxic to most terrestrial and aquatic plants, inducing plant death. The herbicide 

has low leaching potential, low vapor pressure, and low volatility from soils (US-EPA, 1993a; 

Senseman, 2007) and these properties show low potential for damage from volatility. In its 1993 

glyphosate reregistration decision, the EPA required additional studies concerning vegetative 

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vigor, droplet size spectrum, and a drift field evaluation that did not affect the reregistration 

eligibility of the herbicide (US-EPA, 1993a). The potential effects of glyphosate spray drift are 

minimized when growers follow EPA-approved labels that provide detailed measures to manage 

spray drift; these measures include applying only during optimal wind conditions and 

temperature inversions and at appropriate humidity, adjusting spray droplet size and sprayer 

boom heights and including drift reduction additives, and judicious use of aerial spraying from 

aircraft (Monsanto, 2010b). 

In summary, under the No Action Alternative, natural selection, and the selection pressure 

exerted through the use of herbicides and other agronomic practices, impact plants communities 

by either inducing plant death, selecting for weedy characteristics, inducing shifts in the 

composition of the plant community, through gene flow to other related plants, and in some 

cases, contributing to the development of herbicide-resistant weeds. Plant species (i.e., weeds) 

that typically inhabit GE and non-GE corn production systems will continue to be managed 

through the use of mechanical and chemical control methods, as currently practiced. Multiple 

herbicides, including the herbicide glyphosate, will continue to be used on corn. 

Preferred Alternative: Plant Communities

Corn line MON 87427 could potentially have different impacts to plant communities adjacent to 

or within agroecosystems that would be different from currently available glyphosate-resistant 

corn cultivars, mainly because the time of application of glyphosate for male sterility is different 

from that of commercial corn. The post emergent application of glyphosate must be completed 

by vegetative stage 8 for Roundup Ready crops, but when glyphosate is used to prevent

development of male tissue and pollen with the MON 87427 trait, the application can continue 

from vegetative stage 8 up to stage 13. According to the average development stages and 

summarized timing of corn development, the difference between stage 8 and 13 could be about 

one month (Odell's-World, 2010) . The end of glyphosate treatment for conventional corn 

would be about 50 days following emergence. It is likely that most plants within range of the 

glyphosate treatment would have been emerged earlier than the corn and by the approximate end 

of application window, would be as old (two months) or older than the MON 87427 corn. 

Typical of glyphosate application, larger and older plants are less or may not be sensitive to 

glyphosate (Hartzler et al., 2006) (Gauvrit and Chauvel, 2010) . Since any non target plants 

likely to receive glyphosate would be less sensitive later than earlier, it is not clear that the 

additional window of application would impact such plants. As discussed in Subsection 4.2.2, 

Agronomic Practices, the agronomic and phenotypic characteristics of MON 87427 have been 

evaluated in field trials (Monsanto, 2010) and determined by APHIS to be similar to its 

comparator corn cultivars (USDA-APHIS, 2012). MON 87427 would, therefore, be cultivated 

similarly to other glyphosate-resistant corn, and have impacts to plant communities similar to 

those described under the No Action Alternative when glyphosate was used for weed 

management.

A determination that MON 87427 is nonregulated would not be expected to increase the 

development of glyphosate-resistant weeds. The planting of this crop will likely only replace 

similar commodity corn grown on the same farm.MON 87427 is basically similar to other

glyphosate-resistant corn cultivars and the allowable application of rate of glyphosate to corn is 

the same as that for these commodity cultivars. 

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Deterring development of glyphosate resistant weeds is a topic frequently addressed to growers 

by University extension staff, seed developers, and corn producers associations, among many 

others. State specific advice, as for example, in Iowa, has identified existing methods that would 

be highly relevant to corn growers (Owen et al., 2011). Owen (2011) has noted that simplicity 

and convenience of depending solely on glyphosate “has run its course” and that diversity in 

weed management strategies (integrated weed management) is needed. He calls for (1) use of 

herbicide tank mixes, with specific knowledge of existing weed resistances on the farm (2) 

redundant herbicides for control of key weeds (3) multiple herbicides at each application (4) 

inclusion of mechanical and cultural strategies. Specific weeds of high concern for resistance 

development such as horseweed (Conyza canadensis) have been shown to be effectively 

controlled by combinations of herbicides, such as mesotrione and atrazine and other 

combinations (Armel et al., 2009). Likewise, combinations of these can be used for control of 

Palmer amaranth, common waterhemp, and giant ragweed (see review in Owen (2011e).

Similarly, multistate successes with two or three herbicides pre-emergence have been 

demonstrated for giant ragweed, common lambsquarters, and giant foxtail, which build on use of 

atrazine (Louex et al, 2011). While atrazine is already widely used (see Section 2.1) and weed 

resistance to atrazine is known in Corn Belt states (Heap, 2011), some state weed extension staff 

continue to see a place for its use in corn production (Owen et al., 2011). The extent of weed 

resistance in Iowa is yet comparatively small, with state-wide estimate of about 1% of acres 

infested with glyphosate resistant weeds (Hartzler, 2010) (out of 14 million acres of corn planted 

in Iowa in 2012 (USDA-NASS, 2012b). However, some estimates place row crop glyphosate 

resistant water hemp as being found on 20% of Iowa acres (Corn-and-Soybean-Digest, 2013). 

Corn growers are aware that overuse of glyphosate as principle herbicide results in weed 

resistance (multistate survey from 2005: (Givens et al., 2011), and alternative strategies are both 

available and being publicized by a variety of expert resources (as noted in sections 2.3.2 and 

4.4.2). 

As discussed above, corn has no sexually compatible relatives in the U.S. likely to be in the 

vicinity of commercial corn cultivation, and there is little risk of its cultivation contributing to 

weediness that may impact plant communities; further, APHIS has determined that there are no 

phenotypic differences between MON 87427 and control lines that would contribute to enhanced 

weediness (USDA-APHIS, 2012). Herbicide-resistant corn such as MON 87427 has the 

potential to impact other crops in the same fields or adjacent fields in later seasons as volunteers. 

As MON 87427 is similar to other nonregulated corn cultivars, its volunteers would be 

controlled by common agronomic practices as discussed under the No Action Alternative. 

Based on these findings, the potential impact to other vegetation in corn and the landscapes 

surrounding cornfields from approving a determination of nonregulated status to MON 87427 is 

not expected to differ from the No Action Alternative.

4.4.3 Gene Flow and Weediness

No Action Alternative: Gene Flow and Weediness

Hybrid seed production is focused on highly restricting gene flow, except for that occurring in 

the planned crosses. Pollen control methods begin with distance isolation, requiring at least 

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enough as that specified by prevailing state and AOSCA standards. The standards for isolation 

distance may be augmented or partly replaced by sufficient border rows of standard hybrid corn 

varieties, again to prevent unwanted gene movement. The need to precisely restrict pollen 

movement to female parental inbreds additionally requires either genetic sterilization methods, 

such as cytoplasmic male sterility methods, directed chemical (gametocyte) sprays or mechanical 

and hand detasseling. At each site of seed production, vigorous efforts are made to prevent 

genetic dilution of the inbred stocks, the hybrid crosses, or mechanical mixing of seed of 

unknown or uncertain parentage, since quality control is highly necessary for maintaining the 

reputation of the seed developer. 

As described in Subsection 2.1.2, Agronomic Practices, corn is the largest crop grown in the U.S. 

in terms of value (USGC, 2010), acreage planted, and geographic area of production, and is 

predicted to remain an important crop in USDA projections to 2020 (USDA-OCE, 2011a). Gene 

flow may occur through dispersal of vegetative tissues, pollen, or seed. Asexual reproduction 

and gene flow as a result of dispersal of vegetative tissues does not occur with corn. Corn is selfcompatible and primarily pollinated by wind or gravity, with minimal contribution from insect 

pollination (McGregor, 1976; Thomison, 2009), and is propagated by seed. There are no extant 

populations of sexually compatible species related to domesticated Z. mays within the 

continental U.S., its territories, or possessions; therefore, APHIS (2010) has concluded that there 

is not a risk of gene movement between corn and its wild or weedy maize relatives. 

The reproductive morphology of corn encourages cross-pollination between corn plants and 

there is no evidence (genetic or biological barriers) to indicate that gene flow is restricted 

between genetically modified, conventional, and organic corn. Spatial and temporal isolation 

can be the most effective barriers to gene exchange between corn crop cultivars. Requirements 

and methods to ensure seed and crop purity are discussed in more detail in Subsections 2.1.3, 

Organic Corn Production, and 2.1.4, Specialty Corn Production.

Corn does not possess the characteristics for efficient seed-mediated gene flow. Through 

thousands of years of selective breeding by humans, corn has been extensively modified to 

depend on human cultivation for survival (Doebley, 2004). As a result of its domestication, corn 

is not able to survive in the wild and also has several traits that greatly reduce its ability to 

disperse via seeds (OECD, 2003). Corn seed dispersed after harvest may survive in fields and 

develop into volunteer plants, but such volunteers are controlled with common agronomic 

practices (see Subsection 2.3.2, Plant Communities). 

Gene transfer between microorganisms is common (Keese, 2008; McDaniel et al., 2010). Yet, 

biodegradation of plant materials tilled into soils generally results in fragmentation of DNA 

strands into small pieces (Lerat et al., 2007; Levy-Booth et al., 2009; Hart et al., 2009b), which 

would be unlikely to present an intact cp4 epsps gene. Cleaves (2011) have evaluated the ability 

of shorter DNA strands to adsorb to soil aggregates, potentially affecting their persistence in soil; 

however, these were unlikely to convey functional genes. Although unlikely, if a microorganism 

incorporated an intact epsps gene (found in many glyphosate resistant lines), it might transfer the 

gene to other microorganisms, resulting in a greater presence of the gene in the environment. As 

described in Subsection 2.3.3, Gene Flow and Weediness, gene transfers between plants and 

microorganisms are thought to occur on an evolutionary timescale, reflecting the conclusion of 

long term selection against accreting new genes especially those that conveyed either no 

advantage or a metabolic “drag”. Nevertheless, even if transfer occurred, the epsps genes have 

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previously been approved for release under 7 CFR part 340 and the plant pest provisions of the 

Plant Protection Act since 1994 (USDA-APHIS FR Notice, 2012) in several herbicide-resistant 

crops because no impact on the environment can be determined. However, an incremental 

increase in gene transfer among microorganisms under the No Action Alternative is unlikely.

Horizontal gene flow or gene flow to unrelated species in any currently cultivated corn is 

unlikely, and its potential occurrence in any crop is discussed more theoretically than practically. 

It has never been documented under realistic conditions (Stewart, 2008) (see Subsection 2.3.3, 

Gene Flow and Weediness). The horizontal transfer of entire transgenes, including portions of 

the DNA that code for the production of specific proteins, has never been shown to occur in 

nature (Stewart, 2008), and the risk of its occurrence in corn cultivation is considered low. 

Preferred Alternative: Gene Flow and Weediness

As a component of a system to control pollen flow, the trait expressed in MON 87427 corn will 

efficiently limit the movement of genes to only the desired corn plants. In response to treatment 

with glyphosate, the female parental inbred will become male sterile, preventing the selfpollination of the silk and of selfed seed. Instead, the growers will position the male parental 

inbreds to effectively become the only pollen source likely to fertilize the desired female parental 

inbred. Border rows may be chosen not only to provide space and substrate for catching non 

desired pollen, but have been selected and planted because they will shed pollen at a time 

different from the expected time of receptivity of the female inbred that will complete the cross 

and make the expected hybrid seed. The MON 87427 trait will provide increased effectiveness in 

attaining preferred genetic identity and complete uniformity in hybrid seed production and for 

economic production of hybrid seed. Control of gene flow will be modestly enhanced by the 

attainment of nonregulated status for MON 87427 corn.

4.4.4 Microorganisms 

No Action Alternative: Microorganisms

Soil microorganisms are important in soil structure formation, decomposition of organic matter, 

toxin removal, nutrient cycling, and most biochemical soil processes (Garbeva et al., 2004). 

They may also suppress soil-borne plant diseases and promote plant growth (Doran et al., 1996). 

As described in Subsection 2.3.4, Microorganisms, the main factors affecting microbial 

population size and diversity include soil and plant type, and agricultural management practices 

(crop rotation, tillage, herbicide and fertilizer application, and irrigation) (Garbeva et al., 2004). 

Plant roots, including those of corn, release a variety of compounds into the soil creating a 

unique environment for microorganisms in the rhizosphere. 

GE plants potentially impact soil microbes either (1) directly from the transfer of introduced 

genetic material, (2) by exposure to expressed proteins through root exudation and crop residue 

incorporated into soil, or (3) changes in agronomic practices used to produce crops. Indirect 

impacts may arise from (1) effects of the glyphosate or (2) changes in the amount and 

composition of residue from crops.

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Exuded proteins

The potential for intact CP4 EPSPS protein conveying glyphosate resistance to remain functional 

in soils is unlikely, because similar EPSPS proteins degrade once released from cells, decaying 

in soils (Australian Government, 2006). If some molecules did persist in soils, there is no reason 

to anticipate toxicity of the CP4 EPSPS protein to soil microbes. Root exudates have been found 

to promote certain microbial populations, such as soybeans in symbiotic relationship with 

nitrogen-fixing bacteria, and other free-living microbes that have co-evolved with plants that 

supply nutrients to and obtain food from their plant hosts (USDA-NRCS, 2004; Bais et al., 

2006). Glyphosate-resistant crops such as corn could potentially impact the soil microbial 

community even when not treated with the herbicide, if for example, there were properties of the 

plant, say novel susceptibility to disease, that were associated with the genetic transformation 

(Kremer and Means, 2009). However, the first author later noted that the inorganic mineral 

content of soils where the research was accomplished (reported in Kremer and Means, 2009 and 

earlier) was “highly variable” and that this soil condition could “contribute[s] to non-target 

effects,” (Zobiole et al., 2012) possibly including effects apparently deriving from the RR 

soybean cultivar. In an earlier survey of studies of the impact of GE plants on soil microbial 

communities, including many with herbicide tolerance, no significant non-target effects were 

observed Kowalchuk (Kowalchuk et al., 2003). However, if the transformation was engineered 

to produce a specific chemical, then this chemical could be expected to produce an effect on soil 

bacteria (Kowalchuk et al., 2003). Presently, there is no evidence that corn exudates have

impacts on soil microorganisms.

Changes in agronomic practices 

Management practices used in corn production can affect soil microorganisms by altering 

microbial populations and activity through modification of the soil environment. An agronomic 

practice may be beneficial for one microorganism but detrimental to another. As presented in 

Subsection 2.3.4, Microorganisms, crop rotation, irrigation, tillage, and agricultural chemicals 

such as fertilizers and pesticides affect microbial community structure and functions such as 

nutrient cycling, disease promotion or suppression, and presence in soil. As discussed in 

Subsection 2.1.2, Agronomic Practices, the adoption of glyphosate-resistant corn (and other 

herbicide-resistant crops) has enabled the use of conservation tillage, creating less soil 

disturbance and retaining more crop residue which has been found to increase soil microbe 

population diversity (Locke et al., 2008). 

Indirect effects of glyphosate 

The primary agents degrading glyphosate in soil and water are microorganisms feeding on the 

herbicide (Senseman, 2007). As discussed in Subsection 2.3.4, Microorganisms, investigations 

into the toxicity of glyphosate to microorganisms have produced varied results. Earliest studies 

investigating the impact of glyphosate on soil microorganisms did not detect adverse effects 

under field use conditions, such as on specific, limited functional properties of soil bacteria, such 

as nitrification, or specific species of soil bacteria; others found minor effects that could not be 

separated from changes in habitat, and still others reported effects at or near normal glyphosate 

use rates, but in most cases, the effects were minor and temporary (Giesy et al., 2000). In more 

recent experiments, glyphosate was applied to two different soil types, and glyphosate stimulated 

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bacterial biomass up to 25 fold and utilization of all carbon substrates by culturable bacteria 

increased substantially (Ratcliff et al., 2006). As summarized by Hart (2009a) while some studies 

have found effects of glyphosate or the glyphosate resistant crop, many more have shown only 

minor, transient effects. In the case of glyphosate resistant corn, neither crop effect nor 

glyphosate effects resulted in changes to the rhizosphere, denitrifying bacteria, or fungi (Hart et 

al., 2009). Later work showed that glyphosate could directly decrease rhizosphere populations of 

three types of soil bacteria around roots of glyphosate resistant soybean (Zobiole et al., 2011). 

Glyphosate applied to soils may reduce soil microbial diversity (Barriuso and Mellado, 2012) but 

less than that of acetochlor (a common, corn herbicide) applied pre-emergence; in three year 

observations and with different soil types glyphosate did not impact microbial phyla diversity 

(Barriuso et al., 2011). Other authors show that bacterial biomass can be reduced 7 days after 

treatment in soybean rhizosphere, in soil previously unexposed to glyphosate, but that 

biodiversity does not change in response to glyphosate (Lane et al., 2012). The inconsistent 

results of these observations suggest that any effects of glyphosate may not be easily 

distinguished from multiple other influences, including soil, cultivar type, growth stage of the 

plant, and experimental details Hart, (Hart et al., 2009; Farago and Faragova, 2010).

Although mostly anecdotal evidence suggest that use of glyphosate and some glyphosate 

resistant crops may increase frequency, virulence or susceptibility to certain plant diseases (as 

reviewed in Johal and Huber (2009) substantiation is lacking. APHIS has previously examined in 

detail the potential impacts of glyphosate to microorganisms in the cultivation of glyphosateresistant alfalfa and sugar beets on soil with previously cultivated glyphosate resistant crops 

(USDA-APHIS, 2010; USDA-APHIS, 2011a). Based on extensive review of the literature, these 

EISs conclude glyphosate application might favor development of detrimental microbial species 

(or harm some beneficial microbes); however, to date, there is no conclusive evidence linking 

applications of glyphosate to changes in soil microbial communities that have adverse effects on 

plants grown in those soils.

Corn cultivation, including the production of glyphosate-resistant corn and its potential impacts 

to soil microorganisms, is expected to continue under the No Action Alternative. The majority 

of corn grown in the U.S. is herbicide resistant, and glyphosate is the most frequently applied 

herbicide to corn (USDA-ERS, 2011b; USDA-NASS, 2011a). Farmers have access to nonglyphosate-resistant corn varieties, and manage their crops by implementing practices to control 

pests and weeds, including the use of glyphosate.

Preferred Alternative: Microorganisms

A determination of nonregulated status to MON 87427 is not expected to result in any new 

impacts to microbial communities. MON 87427 expresses the same EPSPS protein that is found 

in a large percentage of both current and recent corn and soybean varieties (Monsanto, 2010; 

USDA-APHIS, 2012). The EPSPS sequence inserted into MON 87427 is functionally the same 

as that associated with the native EPSPS-encoding gene in corn and derives from a common soil 

borne plant pathogen, Agrobacterium spp. (USDA-APHIS, 2012). As such, nothing new or 

unique would be introduced into the environment or soil that may impact the microbial 

community under the Preferred Alternative.

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MON 87427 has been determined to be agronomically and compositionally similar to other 

nonregulated glyphosate-resistant corn varieties (USDA-APHIS, 2012). It is not expected to 

change the acreage or area of glyphosate-resistant corn production that potentially would expand 

the use of glyphosate herbicide with potential impacts to soil microorganisms. MON 87427 is 

another glyphosate-resistant corn that will be used in production of hybrid seed, and thus will see 

limited adoption for this small acreage activity. Approximately 73% of corn cultivated in the 

U.S. today is herbicide-resistant and the majority of herbicide-resistant corn is glyphosateresistant, (Duke and Powles, 2009; USDA-NASS, 2012b). Because MON 87427 is 

agronomically similar to other glyphosate-resistant and conventional corn, its cultivation would 

not change the agronomic practices needed for its cultivation, such as amount and rate of 

glyphosate application. Since the use of glyphosate for corn production is not expected to 

change under the Preferred Alternative, there would be no potential impacts to microorganisms 

compared to those of the No Action Alternative.

4.4.5 Biodiversity

No Action Alternative: Biodiversity

All the plants, animals, and microorganisms interacting in an ecosystem contribute to 

biodiversity (Wilson, 1988) that provides valuable life functions. In agriculture, biodiversity 

contributes to critical functions such as pollination, genetic introgression, biological control, 

nutrient recycling, and other processes the loss of which requires costly management (Altieri, 

1999). Concerns regarding the potential impacts to biodiversity associated with the introduction 

of GE crops (and crops in general) include the loss of diversity, which can occur at the crop,

farm, or landscape scale (Visser, 1998; Carpenter et al., 2002; Ammann, 2005) see Subsection 

2.3.5, Biodiversity). 

At the crop scale, research suggests that developing GE crops has introduced novel genes that 

have not decreased crop diversity because of widespread use of the traits in multiple breeding 

programs; the technology effectively enables the introduction of novel genes in crops (Carpenter 

et al., 2002; Ammann, 2005). Additionally, the concern for the loss of genetic variability has led 

to the establishment of an extensive network of genebanks (van de Wouw et al., 2010), including 

an active collection of more than 14,000 accessions of corn at the ARS North Central Regional 

Plant Introduction Station at Iowa State University, Ames, Iowa (USDA-ARS, 2005). These 

collections are shared with researchers worldwide, which helps ensure a continuous reservoir of 

genetic diversity for future crop development. Under this alternative, growers have access to 

existing nonregulated herbicide-resistant and other GE corn varieties, as well as other non-GE 

corn varieties, while MON 87427 corn would remain a regulated article.

At the farm scale, agronomic practices that can impact biodiversity include cropping practices 

(e.g., strip or contour cropping, crop rotation), soil conservation practices that maintain grass 

strips, windbreaks and shelterbelts and the like, tillage, and the application of agrochemicals. 

The rotation of crops and strip contour cropping provide varied habitat that can benefit 

biodiversity. Recently, there has been an increase in corn-to-corn rotation given the profitability 

of corn production (USDA-ERS, 2011b). As discussed in Subsection 2.1.2., Agronomic 

Practices, continuous corn production must be highly managed to maintain productivity, which 

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can be less beneficial to biodiversity; however, the practice does accumulate more crop residue 

that benefits some species. The establishment of soil conserving grass and other vegetative 

borders stabilize soil that maintains additional wildlife habitat, and improves the quality of 

existing habitat (such as surface water quality) that contributes to biodiversity. Allowing 

unproductive field edges to become managed wildlife habitat promotes diversity in both plants 

and animal species (Sharp, 2010). 

Herbicides are used to control plants in areas where humans do not want them. As described in 

Subsection 2.1.2, Agronomic Practices, weeds compete with crops for light and nutrients, 

reducing yields. Glyphosate effectively kills grass and broadleaf plants when applied at the 

recommended rates. At the farm scale, herbicide use in agricultural fields may impact 

biodiversity by decreasing weed quantities or causing a shift in weed species present in the field, 

which may affect those insects, birds, and mammals that use these weeds. The quantity and type 

of herbicide use associated with herbicide-resistant corn crops, however, is dependent on many 

variables, including cropping systems, type and abundance of weeds, production practices, and 

individual grower decisions. See Subsection 2.1.2, Agronomic Practices, for a detailed 

discussion of pesticide use in corn production. The effects of glyphosate on plants and animals 

are presented in the following discussion of landscape-scale biodiversity. 

Use of herbicide-resistant crops such as corn has been linked to increased rates of conservation 

tillage in U.S. crop production (Givens et al., 2009). This promotes biodiversity by allowing the 

establishment of other plants between crop rows and the accumulation of more plant residue that 

creates more soil organic matter, food, and cover for wildlife. In a review of literature that 

assessed the impacts of GE crops on biodiversity, (Carpenter et al., 2002) found that, for the 

most part, impacts to biodiversity have been positive due to increased yields, decreased usage of 

insecticides, use of more environmentally friendly herbicides, and facilitation of conservation 

tillage. In 2010, 62% of planted corn acreage in 19 surveyed states was dedicated to no-till or 

minimum till systems (USDA-NASS, 2011a). As described in Subsection 2.3.2, Plant 

Communities, the increasing incidence of herbicide-resistant weeds is also causing farmers to 

turn to more diversified weed management strategies, including increased tillage that potentially 

reduces biodiversity. 

Crop production in general impacts biodiversity at the landscape scale by potentially converting 

natural lands that have greater animal and plant species diversity to more monocultural 

landscapes. Corn is the largest crop grown in the U.S. in terms of acreage planted and 

geographic area of production with over 96 million planted acres in 2012 (USDA-NASS, 

2012b). USDA projections to 2020 indicate the acreage devoted to corn production in the U.S. 

will remain relatively stable at this level (USDA-OCE, 2011a). 

Area-wide herbicide application may negatively impact species that are dependent on the 

targeted weeds, reducing diversity. As stated above, the majority of corn cultivated in the U.S. is 

treated with herbicides and glyphosate is the most-applied herbicide to corn (USDA-NASS, 

2011a). Potential impacts to landscape-scale diversity can be related to the effects of herbicides 

on non-target animal and plant species. Assessments of the toxicity of glyphosate to animal 

species indicate a minimal risk to animals, but it is toxic to targeted plants and may affect nontargeted plants and animals through spray drift, volatilization (i.e., evaporation) and runoff. 

Inadvertent exposure may cause adverse effects to plants composing animal habitats that could 

lead to a decrease in biodiversity. As discussed in Subsection 2.3.1, Animal Communities, 

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glyphosate was found by the EPA to be no more than slightly toxic to birds, moderately toxic to 

practically nontoxic to fish, and practically nontoxic to aquatic invertebrates and honeybees (USEPA, 1993). The EPA is currently evaluating additional labeling requirements concerning BMPs 

for controlling pesticide spray drift (see Subsection 2.3.2, Plant Communities). While herbicide 

use potentially affects biodiversity, the application of pesticides in accordance with registered 

uses and label instructions, and careful management of chemical spray drift, minimizes the 

potential impacts from their use. 

In 2009, the EPA initiated reregistration of glyphosate and has identified additional data needs. 

Part of the risk assessment will include an acute avian oral toxicity study for passerine species. 

Additionally, some inert ingredients used as surfactants are more toxic than glyphosate to aquatic 

organisms, and will also be evaluated for acute toxicity to estuarine and marine mollusk, 

invertebrates, and fish (US-EPA, 2009f). 

Preferred Alternative: Biodiversity

Under the Preferred Alternative, MON 87427 corn would be determined a nonregulated variety, 

providing hybrid seed growers a variety trait that can both extend the use of glyphosate for weed 

control into inbred lines of corn needed in hybrid seed production, and also establish a new 

technology to provide male sterility in inbred varieties. MON 87427 corn is functionally the 

same other GE and non-GE corn with regard to agronomic characteristics, growth, reproductive 

habit, utilization of resources, and production practices (Monsanto, 2010; Stebbins and Plume, 

2011; USDA-APHIS, 2012). Determining MON 87427 corn to have nonregulated status is 

unlikely to have any direct effects on non-target organisms associated with exposure to its gene 

products and the modified EPSPS protein expressed by the cultivar. The genetic material in and 

proteins produced by MON 87427 are closely similar to those of the nonregulated corn varieties 

in commercial production (USDA-APHIS, 2012). Approval of nonregulated status for MON 

87427 would, therefore, have no impact on biodiversity at the crop-, farm- or landscape- scales.

Because hybrid seed production acreage has remained relatively static for decades, MON 87427

corn would likely replace certain non-glyphosate resistant inbred corn lines without expanding 

the acreage or area of hybrid corn seed production that could impact farm- and landscape-scale 

biodiversity. This acreage comprises about 0.5 million acres. Among the much larger acreage of 

commercial of corn planted in the U.S. in 2012, approximately 73% was already glyphosateresistant (Duke and Powles, 2009; USDA-NASS, 2012b). Based on its similarity to other corn 

as described above, determining nonregulated status of MON 87427 corn would not result in 

changes to agronomic practices such as crop rotation, soil conservation, tillage, weed 

management, or pesticide use that potentially impact farm- or landscape-scale biodiversity. 

Based on the above information, APHIS has concluded that a determination of nonregulated 

status to MON 87427 corn under the Preferred Alternative would not have impacts to crop-, 

farm-, or landscape-scale biodiversity that differ from other currently available glyphosateresistant corn cultivars. In conclusion, the impacts to biodiversity under this alternative would be 

similar to the No Action Alternative.

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4.5 Human Health

No Action Alternative: Public Health

Under the No Action Alternative, the production of hybrid seed would continue with little or no 

use of glyphosate, especially none for post emergence weed management, since many of the 

inbreds do not have genes for glyphosate resistance. Because of permits required for growing of 

the crop, APHIS would expect little cultivation of MON 87427 corn under the No Action 

Alternative. Agricultural workers that are currently engaged in detasseling would likely have 

little exposure to glyphosate, since most of the hybrid seed production fields do not use 

glyphosate, and inbreds do not all contain the glyphosate resistance trait. These workers are 

exposed to other herbicides registered for hybrid seed production.

The environmental risks of pesticide use are assessed by the EPA in the pesticide registration 

process and a pesticide is regularly reevaluated by the EPA to maintain its registered status under 

FIFRA. The human health effects from exposure to glyphosate have been evaluated by the EPA. 

The 1993 glyphosate RED presents the data used by the EPA for chemical reregistration (USEPA, 1993). As previously discussed in Subsection 2.4.1, Human Health, the review for 

reregistration began in July 2009; the EPA is currently conducting a comprehensive human 

health assessment for all uses of glyphosate and its salts (US-EPA, 2009f). The glyphosate RED 

presents the EPA’s analysis of the toxicity, carcinogenicity, and developmental toxicity of this 

herbicide. Glyphosate is classified as having low toxicity via the oral, dermal, and inhalation 

routes and is not classified as a carcinogen or teratogen (US-EPA, 2009f), (US-EPA, 2009b). 

Moreover, neurotoxicity has not been reported in any acute, subchronic, chronic, developmental, 

or reproductive studies, although additional studies will occur as part of the current review 

process (US-EPA, 2009b). Based on additional toxicity tests, the EPA determined the main 

glyphosate metabolite AMPA does not require regulation (US-EPA, 2009b). 

Preferred Alternative: Public Health

Field laborers working with MON 87427 corn would be potentially exposed to chemicals that 

include the CP4 EPSPS protein and to glyphosate, since MON 87427 corn is a tissue-selective 

glyphosate resistant GE variety of corn that facilitates the production of viable hybrid maize seed 

(Monsanto, 2010). 

Worker Health. Workers most likely to be affected by a nonregulated status of MON 87427 

would be the temporary workers who would be hired to mechanically and hand detassel corn in 

midsummer to support hybrid seed production. Many of these workers would no longer be 

needed since MON 87427 would be using glyphosate application between vegetative stage 8 and 

13 to sterilize male tissue, and thus prevent pollination. These workers may previously have 

been exposed to residues of other herbicides than glyphosate, since the inbreds which they 

detasseled did not receive glyphosate treatment. Instead, field workers who were retained would 

apply glyphosate for weed management at similar times to the herbicide applied on commercial 

corn production, as well as that applied in the sterilization process at later times than the times

used on glyphosate resistant commercial corn. However, the total glyphosate used for MON 

87427 crops would be the same as that currently approved for commercial corn, so the exposure 

at a later time would not result in a different total exposure compared to those who work on the 

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commercial glyphosate resistant corn. Glyphosate may also be used preplant, and this would be 

about 4 weeks or more after emergence on average before beginning use of glyphosate for 

control of the pollination process and then no later than about 6 weeks on average after 

emergence for a second application.

Agricultural workers that will routinely handle glyphosate (mixers, loaders, and applicators) may 

be exposed during and after use. Due to glyphosate’s low acute toxicity and lack of 

carcinogenicity and other toxicological concerns, occupational exposure data is not required for 

reregistration (US-EPA, 1993a); however, the glyphosate RED does classify some end-use 

glyphosate products as eye and skin irritants and recommends PPE be worn by mixers, loaders, 

and applicators (US-EPA, 1993). Additionally, due to the potential for skin and eye irritation, 

the EPA has set the restricted entry interval for glyphosate to 12 hours after products have been 

applied. Due to the expected short-term dermal and inhalation exposures of occupational 

handlers and growers, no endpoints were identified by the HED, and as such, no occupational 

handler or occupational post-application assessments are required for reregistration (US-EPA, 

2009b). Current EPA-approved labels for glyphosate include precautions and measures to 

protect human health. When used consistent with the label, pesticides present minimal risk to 

human health and safety. 

Under the Preferred Alternative, pesticide tolerance levels for glyphosate on field corn would not 

change. Tolerances are the limits on the amount of pesticide that may remain on or in foods 

marketed in the U.S. established for every pesticide based on its potential risks to human health. 

In 2010, Monsanto submitted information to the Environmental Protection Agency (EPA) 

requesting herbicide label changes to reflect the new use patterns of glyphosate that this product 

would require (Monsanto 2010), in order to increase tolerance levels for glyphosate. Monsanto 

was granted an increase in the tolerance for glyphosate on this corn variety, increasing it for field 

and forage to 13 ppm from 6ppm (On May 11, 2011, EPA published its approval of this request 

(EPA 76 FR pp. 27268-27271, May 11, 2011)). This increased tolerance was still considerably 

lower however than the 300 ppm allowed for nongrass animal feed (400 ppm) and forage (300 

ppm) for beef and dairy cattle. 

It has been suggested that the importance producers place on worker safety, perceived increased 

simplicity and flexibility of farm management, and decreased risk in production can be partially 

attributed to the high rate of adoption of GE crops (USDA-NRCS, 2004). Producers and farm 

workers experience reduced exposure to potentially harmful pesticides compared to before the 

adoption of GE crops and are also able to spend less time applying pesticides with greater 

flexibility in determining when pesticides are applied. There are no data indicating that workers 

exposed to herbicide-resistant corn (raw or byproducts), such as that which might occur during 

production, transportation, and milling, have experienced adverse reactions. While a small 

portion of the population does suffer from corn allergies, the EPSPS protein that confers 

glyphosate resistance in MON 87427 corn has been determined not to be an allergen (see 

Subsection 2.4.1, Human Health). 

The environmental risks of pesticide use are assessed by the EPA in the pesticide registration 

process and a pesticide is regularly reevaluated by the EPA to maintain its registered status under 

FIFRA. The human health effects from exposure to glyphosate have been evaluated by the EPA. 

The 1993 glyphosate RED presents the data used by the EPA for chemical reregistration (USEPA, 1993). As previously discussed in Subsection 2.4.1, Human Health, the review for 

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reregistration began in July 2009; the EPA is currently conducting a comprehensive human 

health assessment for all uses of glyphosate and its salts (US-EPA, 2009f). The glyphosate RED 

presents the EPA’s analysis of the toxicity, carcinogenicity, and developmental toxicity of this 

herbicide. Glyphosate is classified as having low toxicity via the oral, dermal, and inhalation 

routes and is not classified as a carcinogen or teratogen (US-EPA, 2009f), (US-EPA, 2009b). 

Moreover, neurotoxicity has not been reported in any acute, subchronic, chronic, developmental, 

or reproductive studies, although additional studies will occur as part of the current review 

process (US-EPA, 2009b). Based on additional toxicity tests, the EPA determined the main 

glyphosate metabolite AMPA does not require regulation (US-EPA, 2009b). 

Consumer Health. Glyphosate resistance in MON 87427 was conferred using a sequence of 

DNA derived from the soil borne crown gall pathogen, Agrobacterium spp. strain CP4. MON 

87427 produces the same 5-enolpyruvylshikimate-3-phosphate synthase (CP4 EPSPS) protein 

that is produced in commercial Roundup Ready® crop products, via the incorporation of a cp4 

epsps coding sequence. CP4 EPSPS confers tolerance to the herbicide glyphosate. Tissueselective expression of CP4 EPSPS protein in MON 87427 enables an extension of the use of 

glyphosate resistant maize as a tool in hybrid maize seed production (Monsanto, 2010). 

As discussed above, studies have found that the EPSPS protein expressed in glyphosate-resistant 

crops is compositionally similar to, and is as safe and nutritional as, the same non-GE crops 

(Ridley et al., 2002; Batista et al., 2005; Monsanto, 2010). APHIS considers the FDA regulatory 

assessment in making its determination of the potential impacts of removing a new agricultural 

product from regulated status. As discussed in Subsection 2.4., Public Health, Monsanto had 

earlier completed a consultation with the FDA by submitting a food and feed evaluation of the 

CP4 epsps protein in NK603 corn, the same as the one expressed in MON 87427 corn and FDA 

concluded that there were no safety issues to address under its regulatory authority(BNF-0071: 

Agency Response Letter) and that they had no further questions (US-FDA, 1998b; US-FDA, 

2000). Because MON 87427 corn is within the scope of the FDA policy statement concerning 

regulation of products derived from new plant varieties, including those produced through 

genetic engineering, Monsanto initiated the consultation process with FDA for the commercial 

distribution of event MON 87427. A food and feed safety consultation on MON 87427 was 

completed by the FDA on March, 23, 2012, and FDA concluded the product was not materially 

different in composition or any other relevant parameter from other corn varieties now grown, 

marketed, and consumed in the U.S. (BNF-00126). From the final biotechnology consultation 

with the FDA, potential impacts to food safety from production of MON 87427 corn under the 

Preferred Alternative would be similar to those of other glyphosate-resistant corn cultivars as 

described for the No Action Alternative. 

As discussed in Subsection 2.1.1, Acreage and Area of Corn Production, 88% of corn grown in 

the U.S. in 2012 was GE (USDA-NASS, 2012b). The majority of GE herbicide-resistant corn 

grown in the U.S. is glyphosate resistant (Duke and Powles, 2009). Human health concerns 

associated with GE crops include the potential toxicity of the introduced genes and their 

products, the expression of new antigenic proteins, and/or altered levels of existing allergens 

(Malarkey, 2003; Dona and Arvanitoyannis, 2009). Previous studies of the EPSPS protein, 

which confers glyphosate resistance, found that the EPSPS protein expressed through genetic 

engineering poses no potential for toxicity or allergenicity (Harrison et al., 1996; Ridley et al., 

2002; Batista et al., 2005; Hoff et al., 2007; Herouet-Guicheney et al., 2009). Some people are 

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allergic to corn, but corn is not included in the FALCPA as one of the most common food 

allergens (see Subsection 2.4.1, Human Health). An additional concern with GE food crops is 

the potential for increased levels of anti-nutrients (Dona and Arvanitoyannis, 2009). As 

discussed in Subsection 2.4.1, Human Health, there are several naturally occurring anti-nutrients 

found in corn, including phytic acid, DIMBOA, raffinose, and low levels of trypsin and 

chymotrypsin inhibitors (OECD, 2002). In Monsanto’s study of these anti-nutrients, raffinose, 

phytic acid and trypsin inhibitors were not significantly different from non-transgenic controls or 

reference hybrids (Monsanto, 2010). In Monsanto’s study of 51 nutrients and anti-nutrients in 

MON 87427 corn, a few were significantly different from the non-transgenic control, but all 

were found to be within the ranges expected of commercial corn (Monsanto, 2010). Similarly, in 

a study of the CP4 EPSPS protein conferring glyphosate resistance in other corn hybrids, Ridley 

(2002) (Ridley et al., 2002) found the genetic modification to confer glyphosate resistance did 

not significantly change any of the 51 biologically and nutritionally important components 

evaluated. 

Under the FFDCA, it is the responsibility of food and feed manufacturers to ensure that the 

products they market are safe and properly labeled. The food safety evaluation of the EPSPS 

protein imparting glyphosate resistance was completed by the FDA on the MON 87427 corn 

variety (BNF No. 000126) on March 23, 2012. No food safety issues were found by the FDA in 

previous consultations regarding the EPSPS protein in corn or any other GE corn cultivars (See 

the FDA website Final Biotechnology Consultations http://www.fda.gov/Food 

/Biotechnology/Submissions/ucm225108.htm). 

Potential risks to occupational handlers and growers during glyphosate application to MON 

87427 corn would be the same as those of workers in glyphosate resistant GE corn, and different 

from those who worked in fields of non-herbicide resistant inbreds and were exposed to different 

herbicides other than glyphosate. Moreover, as discussed above, the application rate of 

glyphosate would not likely change although the registered use of glyphosate proposed under 

the Preferred Alternative increases the allowable stage of corn at which glyphosate may be 

applied. There would be no increased risk to workers’ health or safety from exposure to MON 

87427 corn or byproducts during typical agricultural-related activities. Fewer workers would be 

exposed to any possible chemical or mechanical hazards, since MON 87427 would decrease the 

needs for numbers of workers. FDA has no questions about consumer safety for MON 87427 

Potential risks to farm workers from the use of glyphosate would be similar to the No Action 

Alternative. APHIS has concluded there would be no expected negative effects to human health 

or worker safety under the Preferred Alternative.

4.6 Animal Feed

No Action Alternative: Animal Feed

Hybrid seed resulting from planned inbred crosses is used primarily for sale as seed for planting, 

and by breeders to supply specific traits needed by commercial growers. Any seed that derives 

from inbreds (such as male pollen donor plants) that does not have the genetic background or 

trait stack of desired commercial seed may also be used for animal feed, as may any hybrid seed 

that was produced beyond the capacity of the seed producer to sell as grower seed. As described 

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in Subsection 2.5, Animal Feed, most of the corn produced in the U.S. is for animal feed that is 

consumed primarily by cattle, poultry, and swine, (NCGA, 2011; USDA-ERS, 2011a). Corn 

comprises over 95% of the total feed grain produced in the U.S. (USDA-ERS, 2011b). In 2012, 

corn was grown on over 96 million acres (USDA-NASS, 2012b) and measurably produced in all 

states but Alaska (USDA-NASS, 2009). As discussed in Subsection 2.5, Animal Feed, 45% of 

the corn consumed in the U.S. in 2010 was used for animal feed (Fig. 6 and(Schnepf, 2011). In 

2012, 73% of the corn produced in the U.S. was genetically engineered to be resistant to 

herbicides, consisting primarily of glyphosate-resistant cultivars (Duke and Powles, 2009); 

(USDA-NASS, 2012b). The amount of corn that is used for feed is dependent on a number of 

factors such as the number of animals that are fed corn, its supply and price, the amount of 

supplemental ingredients added, and the supply and price of competing ingredients (USDA-ERS, 

2011a). Under the No Action Alternative, corn forage, silage, grain, and refined corn feed 

products from currently cultivated GE herbicide-resistant and conventional corn varieties are 

utilized by livestock producers. 

It is the responsibility of feed manufacturers to ensure that the products they market are safe and 

properly labeled and feed derived from GE corn must comply with all applicable legal and 

regulatory requirements, which in turn protect human health (see Subsection 2.5, Animal Feed). 

All applicants who wish to commercialize a GE variety that will be included in the food supply 

complete a consultation with the FDA to identify and discuss relevant safety, nutritional, or other 

regulatory issues regarding the bioengineered food and submits a summary of its scientific and 

regulatory assessment of the food to FDA (US-FDA, 2012). The FDA evaluates the submission 

and responds to the developer by letter. 

As previously noted, because MON 87427 corn is within the scope of the FDA policy statement 

concerning regulation of products derived from new plant varieties, including those produced 

through genetic engineering, Monsanto initiated a consultation process with FDA for the 

commercial distribution of event MON 87427 corn. Monsanto submitted a safety and nutritional 

assessment of food and feed derived from MON 87427 corn to the FDA on December 15, 2010

(BNF-000137). FDA completed the evaluation and found that foods and feeds derived from 

MON 87427 are as safe as conventional corn varieties on March 23, 2012 (BNF-00126). A 

biotechnology consultation for a similar EPSPS protein was completed by the FDA on the GA21 

corn variety (BNF No. 000051) on February 10, 1998 (US-FDA, 1998a). No food safety issues 

were found by the FDA in their review of Monsanto’s safety and nutritional assessment of GA21 

corn and the modified EPSPS protein (see the FDA website Final Biotechnology Consultations 

http://www.fda.gov/Food/Biotechnology/Submissions /ucm225108.htm). 

This herbicide currently has established tolerances for residues, including established residue 

concentrations for glyphosate in field corn for forage, grain, and stover. The EPA establishes 

tolerances to regulate the amount of pesticide residues that can remain on food or feed 

commodities as the result of pesticide applications (see, e.g., 

http://www.epa.gov/pesticides/bluebook/chapter11.html). The tolerance level is the maximum 

residue level of a pesticide that can legally be present in food or feed, and if pesticide residues 

are found to exceed the tolerance value, the food is considered adulterated and may be seized.

Agricultural production of existing commercially available glyphosate-resistant corn varieties 

uses EPA-registered pesticides, including glyphosate. The interval between post emergence corn 

application of glyphosate and when the grain may be subsequently harvested is seven days 

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(Monsanto, 2010b). The interval between post-harvest application of glyphosate and when the 

corn vegetation may be used as feed varies with product labels, for example the Roundup Power 

Max® interval is seven days (Monsanto, 2010b) while the Glyphosate 41 Plus ® interval for any 

stage is 50 days (CropSmart, 2009). Tolerances are the limits on the amount of pesticide that 

may remain on or in foods marketed in the U.S. that are established for every pesticide based on 

its potential risks to human health. The maximum tolerance level for glyphosate in field corn is 

5.0 ppm for grain and is 6.0 ppm for forage (40 CFR §180.364). 

Preferred Alternative: Animal Feed

MON 87427 expresses a trait to be used in production of hybrid seed, for incorporation into 

inbreds. Hybrid seed resulting from planned crosses of inbreds will be used exclusively for sale 

as seed with specific traits. Seed from inbreds used in the hybrid cross such as male pollen donor 

plants, or excess quantities of the planned hybrid seed may potentially enter the commodity 

stream for animal feed as decided by the seed producer. Hybrid seed deriving from the 

production process will also contain the cp4 epsps gene. As described in Subsection 4.2.1, 

Acreage and Area of Corn Production, no change to the area or acreage of corn production is 

expected to occur as the result of approving a determination of nonregulated status to MON 

87427 corn. Also, as described in Subsection 4.2.2, Agronomic Practices, the cultural 

requirements and agronomic practices for corn production that could impact the supply of cornbased animal feed would not change under this alternative because agronomic and growth 

characteristics of MON 87427 corn are similar to other commercially available glyphosateresistant corn. As described for the No Action Alternative, the amount of corn that is used for 

feed is dependent on several factors, including price, supply, and the number of animals that are 

fed corn (USDA-ERS, 2011a). Because herbicide-resistant corn is the majority of corn produced 

in the U.S. today, and most of that is glyphosate resistant (USDA-ERS, 2011a), MON 87427

corn would likely replace other glyphosate-resistant cultivars without impacting the supply of 

corn for animal feed.

Monsanto has submitted compositional and nutritional characteristics of MON 87427 corn grain 

and forage to APHIS (Monsanto, 2010). Samples of MON 87427 corn and its comparators that 

were sprayed with glyphosate were collected from six different field trial locations (four for 

grain samples and two for forage samples) and analyzed for comparable nutritional components 

in accordance with Organisation for Economic Co-operation and Development (OECD) 

guidelines (OECD, 2002). Tested parameters include proximates (protein, fat, carbohydrates, 

fiber, ash, calcium phosphorus and moisture), minerals, amino acids, fatty acids, vitamins, 

isoflavones, and antinutrients and secondary metabolites (i.e., ferulic acid, phytic acid, trypsin 

inhibitor, raffinose, inositol, and ρ-coumaric acid) (Monsanto, 2010). MON 87427 corn is similar 

in compositional and nutritional characteristics to other varieties of GE and non-GE corn 

(Monsanto, 2010; USDA-APHIS, 2012).

A biotechnology consultation of the EPSPS protein that confers glyphosate resistance in the 

MON 87427 corn variety has been completed (See Subsection 4.5, Public Health). Monsanto

submitted a safety and nutritional assessment of food and feed derived from MON 87427 corn to 

the FDA in March 2012 in support of the consultation process with the FDA for the commercial 

distribution of MON 87427 corn (Monsanto, 2010). Pending results of the final biotechnology 

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consultation with the FDA, potential impacts to the safety of MON 87427 corn under the 

Preferred Alternative would be similar to those of the No Action Alternative.

As discussed above, label restrictions for glyphosate’s application to corn prohibits harvesting 

the grain prior to seven days after application and the interval for harvesting or feeding the 

vegetation is dependent on the individual glyphosate product label. As discussed in Subsection 

4.2.2, Agronomic Practices, the registered uses of glyphosate on MON 87427 corn or other corn 

would not change as a result of the Preferred Alternative, nor would herbicide label restrictions 

for feeding corn after treatment. Similarly, no change to the EPA-established tolerances of 

glyphosate in treated corn intended for forage or grain harvested for animal feed that could 

impact animal health would be required if the request for nonregulated status of MON 87427

corn is decided. 

Based on the analysis of field and laboratory data and scientific literature provided by Monsanto

(2010), as well as safety data available on other glyphosate-resistant corn in commercial 

production, APHIS has concluded that approving a determination of nonregulated status to MON 

87427 corn would not adversely impact the safety of animal feed and animal health. Overall, 

impacts of the Preferred Alternative would be to the same as the No Action Alternative.

4.7 Socioeconomic Impacts

4.7.1 Domestic Economic Environment

No Action Alternative: Domestic Economic Environment

Under the No Action Alternative, MON 87427 corn would continue to be a regulated article 

under 7 CFR part 340 and the Plant Protection Act, cultivated only in limited test fields. The 

petitioner and other hybrid seed producers involved in production of corn for seed would not 

have access to MON 87427 corn, but continue to have access to existing inbreds that do not have 

herbicide resistance and do not have improved technology to the make the male sterilization 

process more efficient. Growers would continue to rely on mechanical detasseling of the female 

inbreds used in hybridization, with subsequent needs for hand detasseling crews to complete the 

process. Recruitment of hand detasselers for temporary mid-summer employment would 

continue for seed producers and growers. 

During hybrid maize seed production, Monsanto contracts for the services of approximately 

10,000 agricultural workers for roughly four weeks (or approximately 0.1% of the agricultural 

work force annualized) to detassel maize in a combined manual and mechanized detasseling 

operation (Monsanto, 2010). The Monsanto detasseling work force is comprised of 70% 

teenagers and 30% migrant farm workers (Patrick Geneser, Monsanto Migrant Seasonal Labor 

Manager, personal communication, in Monsanto, 2010). Recent publications place detasseling 

costs for the seed producer anywhere from USD $130 per acre using a combination of 

mechanical and manual detasseling, to USD $200 per acre with manual detasseling (Koetters, 

2007). Another estimate represents costs as between $280 and $350 per acre (APHIS, 2011). 

Certain economic and environmental issues are important when hybrid corn seed producers are

contracted by seed companies to grow corn. The first is that the inbred corn used to produce the 

seed are low yielding corn varieties, so that compensation must be guaranteed above that 

accruing from commercial corn production (Monsanto, 2010). The minimum compensation for 

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contracted growers is likely to be equivalent to the returns that would be expected from growing 

conventional corn, and based on the average yields in the area and the commodity corn price

(Monsanto, 2010). For example, the local average yield might be 170 bushels with a commodity 

price of $4.00 per acre making the minimum standard $680 per acre (Monsanto, 2010). Thus, 

pay premiums and minimums are typical parts of the standard contract (Monsanto, 2010). Seed 

companies also require the contract growers to meet exacting planting, growing and harvesting 

standards, and schedules, and this imposes additional human impacts.

Adverse environmental consequences of growing hybrid seed corn can also be sustained by 

growers. Contract inclusions may require that the farmers accept the large ruts that are left by 

detasseling machines used in muddy conditions (Monsanto. 2010). These ruts destroy soil 

structure, increase tillage requirements, increase erosion, result in major yield reduction in the 

corn crop and possibly in the crop the following year as well, and result in damage to harvesting 

and tillage machinery (Daum, 1996; Kok et al., 1996; UK AgNews, 2009; Roegge, 2010; South 

Dakota AgConnection, 2010).

Most corn planted in the U.S. today is stacked GE varieties with both herbicide and insect 

resistance (USDA-ERS, 2011c). The widespread adoption of herbicide-resistant corn has been 

attributed to the cost savings for production, among other non-monetary benefits as described in 

Subsection 2.1.2, Agronomic Practices (Duke and Powles, 2009; NRC, 2010; Green and Owen, 

2011). Of the herbicide-resistant corn varieties on the market today, growers may choose from 

glyphosate, glufosinate, glyphosate stacked with imidazolinone resistance traits (USDA-APHIS, 

2012).

GE technology is patented and GE seeds are proprietary in the U.S. (NRC, 2010). The costs for 

GE seed are higher than that for conventional seed, as GE seed includes technology fees (NRC, 

2010). The higher seed costs, however, may be offset by other premiums offered by companies, 

such as discounts for herbicides to use on the resistant crop, and reductions in crop insurance 

(NRC, 2010). As discussed in Subsection 2.6.1, Domestic Economic Environment, estimates of 

the economic benefits of herbicide-resistant crops to farmers are limited (NRC, 2010), and 

studies that have been conducted have had mixed results. Overall, these studies indicate in the 

early years of the adoption, GE cultivars exerted downward pressure on crop prices while the 

earnings of adopting farmers increased, and barriers to market access for GE crops reduced 

grower income (NRC, 2010). 

With the increase in stacking of traits and multiple offerings for commercial growers comes a 

corresponding increase in combinations of seed traits which need to be produced. Each trait, 

deriving from different inbreds, requires a large amount of effort to track the development of 

pollen producing tassels on male pollen donors, correlate them with potentially interfering 

weather developments, and coordinate with crews of mechanical detasselers and needed crews of 

hand detasselers. Technology to simplify and make the process more economical have been 

developed since corn hybrids became the standard seed corn for industry (Bennett, nd).

Farmers have recently broadened weed management to treat herbicide-resistant weeds which 

may be impacting yields, leading to more variety in herbicide application and increased tillage, 

potentially incurring higher production costs. Weirich (2009), however, investigated the 

economic effects of alternative glyphosate weed resistance management programs, finding that 

although they increased cost substantially, higher yields offset these costs such that no 

statistically significant decrease in net returns occurred. Their study suggests growers may be 

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able to effectively respond to glyphosate resistance using weed BMPs without substantially 

affecting their returns.

As indicated in Subsection 2.1.1, Acreage and Area of Corn Production, the trend over the last 

several years in the U.S. has been to stack herbicide resistance with primarily insect-resistant 

traits. Developers have recently sought approvals for corn varieties that have multiple herbicide 

and insect resistance, as well as other value added traits ((USDA-APHIS, 2012). Herbicideresistant-only corn has consistently comprised approximately 22 to 23% of planted corn in the 

U.S. since 2007 (USDA-ERS, 2011c). Only two companies hold the licenses for the majority of 

herbicide-resistant corn in the U.S.: Monsanto patented glyphosate-resistant corn technology 

and offers varieties in their Roundup Ready® corn lines, and Bayer CropScience licenses 

glufosinate-resistant corn in their LibertyLink® corn lines. Glufosinate-resistant corn has been 

commercially available even longer than glyphosate-resistant corn, but has not been as 

successful, thought to be due to the higher cost of glufosinate and its more restrictive application 

timings to smaller plants to increase its efficacy (Owen, 1999a; Green and Owen, 2011). 

Growers have perceived a lack of competition in the U.S. herbicide- and insect-resistant seed 

corn market based on substantial increases in the price of GE seed in the last several years 

(Neuman, 2010). This observation may correlate with the ongoing concentration of the U.S. seed 

market since passage of the Plant Variety Protection Act in the 1970s established proprietary 

rights for certain plant varieties (Fernandez-Cornejo, 2004). In 2011, corn seed comprised 

approximately 25% of total per acre operating costs for farmers (USDA-ERS, 2012c). Industry 

has responded that the quality of seed offered has improved, and new GE traits have been added 

that lower costs associated with improved insect and weed control, among other production costs 

(Neuman, 2010). If the MON 87427 corn was not determined as nonregulated, growers would 

have one less technology that may provide a means to reduce costs of seed production. 

Preferred Alternative: Domestic Economic Environment

Availability of MON 87427 corn could potentially impact agronomic inputs and associated onfarm costs as well as the U.S. domestic corn market. Under the Preferred Alternative, MON 

87427 corn would be extended nonregulated status. One expected consequence of the MON 

87427 trait is that the complexities of detasseling inbreds for hybrid seed corn would be 

simplified. The step of detasseling would be eliminated by timed application of glyphosate to 

sterilize male tissues and prevent pollen shed and self-pollination of female inbreds. The 

specified timing of glyphosate application would be broader than that required for mechanical 

and hand detasseling operations and the replacement of technology involved would be much 

more limited. Thus, the need for a large number of temporary workers who need annual 

recruiting, training, organizing, retaining and compensating would no longer be a critical 

necessity for the hybrid seed producer. Another indirect impact is that the temporary workers 

who have previously been hired for this agricultural task would in large part no longer be 

needed.

The transition by seed producers from mechanical and hand detasseling to fully using the 

Monsanto Roundup Hybridization System may occur over an extended period. When producing 

an elite inbred line from a non-elite line, four generations of backcrossing and up to three 

generations of selfing would be needed to insure homogeneity and purity of the inbred (Groth, 

2013). Then a cross is made to produce the hybrid seed, for a total of eight generations. In 

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tropical locations up to three generations can be produced annually, which would be two and one 

half to four years, and additional years if produced at temperate locations. The timeframe of any 

seasonal job losses would likely be a gradual one as the developers adapt their inbred line to the 

new technology. When introduction of MON 87427 is finally complete, Monsanto estimates that 

its detasseling work force of 10,000 will decline to approximately 500 to 1,000 seasonal workers 

for four weeks (representing a decline from 0.1% to approximately 0.01% of the agricultural 

work force annualized), which is a small percentage of the total agricultural workers in the U.S.

(USBLS, 2010).Given the large number of agricultural workers, relative stability of the forecasts 

for these, the number of jobs (800,000) are plentiful for those who wish to find employment in 

this sector, particularly for crop, greenhouse and nursery farm workers. Many of those jobs are 

seasonal, because of the relatively large numbers of workers who leave these jobs for other 

occupations (USBLS, 2010).

The practices for the production of hybrid maize seed with MON 87427 are essentially 

unchanged with regard to current practices for hybrid maize seed production, with the exception 

of the reduction in the use of mechanical detasseling and the use of glyphosate sprays during the 

corn vegetative stages ranging from V8-V13 needed to produce the male sterile phenotype in 

inbred female plants. As a result, production of seed corn with MON 87427 will reduce the 

number of seasonal workers recruited by seed producers to an unknown extent; this would 

include high school students and other classes of workers. It is reasonable to assume that such 

losses would have a potential negative impact until another source of income might be secured to 

replace these temporary jobs but the impact is not likely to be a significant one, and the decline 

of these temporary seasonal jobs would be gradual as the producer began to incorporate the 

MON 87427 trait into greater numbers of inbreds.

4.7.2 Trade Economic Environment 

No Action Alternative: Trade Economic Environment

Under the No Action Alternative, MON 87427 corn would continue to be a regulated article. 

Farmers, processors, and consumers in the U.S. would not have access to MON 87427 corn, but 

do have access to existing nonregulated herbicide-resistant and non-GE corn varieties, as do the 

major U.S. corn export competitors. 

The U.S. is the leading exporter of corn in the world market (see Subsection 2.6.2, Trade 

Economic Environment), while other important exporters are Argentina, Brazil, and Ukraine. In 

the 2011/2012 marketing year (August to September), the U.S. exported approximately 37% of 

the world’s corn while Japan, Mexico, and South Korea were the major importers (USDA-FAS, 

2008). In 2011, corn exports were worth approximately $13.7 billion (USDA-ERS, 2012d). 

U.S. corn supply, the value of the U.S. dollar and other currencies, oil prices, U.S. and 

international agricultural policy, the U.S. and international biofuels sector, livestock and meat 

trade, prices, and population growth are all factors affecting where and how much of U.S. corn is 

exported (USDA-ERS, 2011g); (USDA-OCE, 2011a). In addition, consumer perception of GE 

crop production and products derived from GE crops may present barriers to trade. Over the past 

decade, U.S. corn export share has eroded as exports have remained relatively stable while

global exports have increased by almost 20% (See Subsection 2.6.2, Trade Economic 

Environment). U.S. share of world corn production has declined as well, even as total world 

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production increased. This is attributed to greater domestic use of U.S. corn, smaller corn crops, 

and increased competition from other major corn exporters such as Argentina, Brazil, and 

Ukraine (USDA-FAS, 2008), countries with increasing GE herbicide- and insect-resistant corn 

production acreage (Brookes and Barfoot, 2010). 

Figure 14. US and world corn exports for marketing years 2000/2001 to 2010/2011.

Source: (USDA-FAS, 2004; USDA-FAS, 2005; USDA-FAS, 2006; USDA-FAS, 2007; USDAFAS, 2008a; USDA-FAS, 2009; USDA-FAS, 2010a; USDA-FAS, 2011a)

Market years extend from September to August. Major world exporters include Argentina, 

Brazil, Canada, China, EU-27, India, Paraguay, Romania, Serbia, South Africa, Thailand, 

Ukraine and Zambia as well as other smaller exporting countries (Figure 13). Note that the US 

percentage of corn exports in relation to overall world exports declined at the end of the last 

decade.

0

20

40

60

80

100

120

Million Metric Tons

Marketing Year (Sept.-Aug.)

Rest of

World

United States

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Figure 15. US and major exporters of corn for marketing years 1960/1961-2011/2012.

Source: (Capehart, 2013 ). 

Note the increase in exports of corn in countries other than the top three, and the decline in US 

exports in most recent years.

Farmers in the U.S. and abroad have begun to utilize BMPs to control glyphosate or other 

herbicide-resistant weeds, but these BMPs have not necessarily increased costs (Weirich et al., 

2011) such that the competitiveness of U.S. corn and trade economic environment would be 

affected. Increasing herbicide weed resistance is also occurring in other countries producing 

herbicide-resistant crops, including U.S. corn export competitors (for example, Argentina and 

Brazil (Heap, 2011) that would likely incur increases in production cost to mitigate the incidence 

of glyphosate-resistant weeds, similar to the U.S. experience.

As of publication of this EA, Monsanto is likely to submit applications for regulatory approval to 

export MON 87427 to Canada, the EU and to Japan for cultivation and use as food and feed. 

Canada is not a major corn export competitor of the U.S.; in the 2011/2012 market year, 

Canadian corn exports equalled only about 4.3% of the U.S. corn exports that year (USDA-FAS, 

2013b).

Preferred Alternative: Trade Economic Environment

Under the Preferred Alternative, MON 87427 would be determined nonregulated and available 

to U.S. growers. Availability of MON 87427 could potentially impact the corn seed, feed, and 

food trade. MON 87427 is compositionally and agronomically similar to its comparators and 

other nonregulated glyphosate-resistant corn (Monsanto, 2010; USDA-APHIS, 2012). As such, 

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it is not expected to affect the seed, feed, or food trade any differently than other nonregulated 

glyphosate-resistant corn varieties (see Subsections 4.7.1, Domestic Economic Environment). 

Although this variety is a glyphosate-resistant corn cultivar, MON 87427 it is not expected to

replace any other glyphosate resistant corn, since the purpose of the developer is to deploy the 

trait within inbred corn varieties that are used in hybrid seed production. Approval of the request 

to determine nonregulated status to MON 87427 would, therefore, not likely increase the U.S. 

supply of corn that may affect trade. As discussed above, other countries are increasing their 

production of herbicide-resistant corn, including glyphosate-resistant cultivars, and are becoming 

significant export competitors to U.S. corn trade. Although this trait will have specific usefulness 

to the US hybrid seed production industry, and to international field sites where developers 

might increase seed (e.g., South America) it will also be present as an additional trait in 

commercial grain sold on the world market. As noted above, Monsanto plans to submit 

applications to Canada for import clearance of MON 87427(Monsanto, 2010); however, Canada 

is not a major U.S. corn export competitor. 

As discussed in Subsection 4.4.2, Plant Communities, the cultivation of MON 87427 would not 

change the development of glyphosate-resistant weeds nor affect the BMPs to control 

glyphosate-resistant weeds any differently than other nonregulated glyphosate-resistant corn. 

These BMPs would not necessarily increase costs such that the competitiveness of U.S. corn and 

trade economic environment would be affected, as the increased costs may be offset by increased 

yields (Weirich et al., 2011). 

As discussed under the No Action Alternative, global corn export markets respond to many 

factors, including consumer perception of GE crops and derived products. As a glyphosateresistant corn cultivar, the availability of MON 87427 for hybrid seed production in the U.S. 

would not likely affect foreign consumer perception of GE corn products or those global forces 

shaping the U.S. corn trade economic environment. 

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5 CUMULATIVE IMPACTS

A cumulative impact may be an effect on the environment which results from the incremental 

impact of the proposed action when added to other past, present, and reasonably foreseeable 

future actions. For example, the potential effects associated with a determination of 

nonregulated status for a GE crop in combination with the future production of crop seeds with 

multiple deregulated traits (i.e., “stacked” traits), including drought tolerance, herbicide 

tolerance, and pest resistance, would be considered a cumulative impact. 

5.1 Assumptions Used for Cumulative Impacts Analysis

Cumulative effects have been analyzed for each environmental issue assessed in Section 4, 

Environmental Consequences. In this EA, the cumulative effects analysis is focused on the 

incremental impacts of the Preferred Alternative taken in consideration with related activities 

including past, present, and reasonably foreseeable future actions. Certain aspects of this product 

and its cultivation would be no different between the alternatives; those instances are described 

below. In this analysis, if there are no direct or indirect impacts identified for a resource area, 

then APHIS assumes there can be no cumulative impacts. Where it is not possible to quantify 

impacts, APHIS provides a qualitative assessment of potential cumulative impacts. 

APHIS considered the potential for Maize Line MON 87427 to extend the range of corn 

production and affect the conversion of land to agricultural purposes. Monsanto’s studies 

demonstrate Maize Line MON 87427 is similar to conventional maize and other GE and nonGE corn in its growth habit, agronomic properties, disease susceptibility, and composition, 

with the exception of the tissue-selective glyphosate tolerance character (Monsanto, 2010; 

USDA-ERS, 2012a). As such, its agricultural requirements would be no different than those 

of other corn or no different from what growers provide in the specific areas in which corn 

is currently cultivated. As presented in Subsection 2.1.1, Acreage and Area of Corn 

Production, the majority of corn cultivated in the U.S. is herbicide-resistant, most of which 

is glyphosate-resistant (Duke and Powles, 2009; USDA-ERS, 2011a). Nonregulated Maize 

Line MON 87427 is glyphosate resistant for weed control purposes and would replace 

inbreds which do not have glyphosate resistance used for seed production (Monsanto, 2010). 

Although some of these inbreds and lines used for parental lines are resistant, but some of 

these not resistant, Monsanto has not been using glyphosate for weed control in seed 

production fields (Monsanto, 2010). If future seed production technology incorporating 

glyphosate resistance continues to have the same inputs as would continuous corn or as 

current rotation crops on lands now in production agriculture, APHIS does not expect any 

cultivation of new, natural lands would be undertaken by developers. Land use changes 

associated with approving a determination of nonregulated status to Maize Line MON 

87427 are not expected to be any different than those associated with the cultivation of other 

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corn cultivars used in seed or commercial corn production. Accordingly, although the 

preferred alternative would allow for new plantings of Maize Line MON 87427 to occur 

anywhere in the U.S., APHIS will focus the analysis of cumulative impacts to the areas in the 

U.S. that currently support corn production for seed. 

Potential reasonably foreseeable cumulative effects are analyzed under the assumption that seed 

producers who produce conventional corn have used in the past and would continue to use 

reasonable, commonly accepted BMPs for their chosen system and selected varieties during seed

corn production. APHIS recognizes, however, that not all farmers will use such BMPs. Further, 

the cumulative impact analysis assumes that it is not necessary to change the use pattern of 

glyphosate for weed control on the glyphosate-resistant MON 87427 variety. Hence, APHIS 

will use current glyphosate labels for current glyphosate products as the basis for its potential 

past, present, and reasonably foreseeable impacts from the use of and exposure to glyphosate, 

and these are compared to the provisional label proposed by Monsanto, and which EPA has 

responsibility for issuing. APHIS assumes growers of MON 87427 will adhere to the EPAregistered uses and EPA-approved labels for all pesticides applied to this crop. 

As part of the cumulative impacts analysis, APHIS accepts that that Maize Line MON 87427 

will become as proposed, a common trait for most future inbreds used in seed corn production 

(Monsanto, 2010). Field study of MON 87427 corn indicates that the agronomic performance of 

it and conventional corn is not substantially different (Monsanto, 2010; USDA-APHIS, 2012), 

and when this trait is incorporated into inbreds, these seed production lines will be more similar 

to the conventional corn. In these inbreds, the MON 87427 trait will be combined with many 

other traits, whether non GE or nonregulated GE, such as pathogen, herbicide, insect, or drought 

resistance using traditional breeding techniques that along with MON 87427 will no longer be

regulated by APHIS. Such varieties used in seed production could provide seed producers and 

developers such as Monsanto with the options of herbicide tolerance for control of weeds when 

inbreds for seed production have incorporated the trait. 

5.2 Cumulative Impacts: Acreage and Area of Corn Production

Neither the No Action nor the Preferred Alternative are expected to directly cause a measurable 

change in agricultural acreage or area devoted to corn grown for seed in the U.S. (see 

Subsections 4.2.1, Acreage and Area of Corn Production). The majority of corn grown in the 

U.S. is GE and herbicide resistant (USDA-ERS, 2011b). Long-term projections show planted 

corn maintaining between approximately 90 and 92 million acres a year through 2020, about the 

same as the 96 million acres planted to corn in 2012 (USDA-OCE, 2011a; USDA-NASS, 2012a; 

USDA-OCE, 2012). APHIS expects that MON 87427 for hybrid seed production would be 

grown where other similar corn cultivars are grown, and in many of the same contracted

locations where seed production is currently engaged without expanding the acreage or area of 

corn production. There are no anticipated changes to the availability of GE and non-GE corn 

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varieties on the market under either alternative. The Preferred Alternative, therefore, would have 

no impacts to acreage or area of corn production and corn grown for seed different than the No 

Action Alternative.

The potential future development and cultivation of MON 87427 glyphosate-resistant corn used 

as a trait in inbred and breeding stocks stacked with various GE and non-GE traits is not likely to 

change the area or acreage of corn production. Despite the availability of these cultivars, corn 

production acreage is expected to remain relatively stable until 2020 (USDA-OCE, 2011a).

5.3 Cumulative Impacts: Agronomic Practices

In the preceding analysis, the potential impacts from a determination of nonregulated status to 

MON 87427 corn were assessed. The agronomic characteristics evaluated for MON 87427 corn 

encompassed the entire life cycle of the corn plant and included germination, seedling 

emergence, growth habit, vegetative vigor, days to pollen shed, days to maturity, and yield 

parameters. The compositional analysis included the major constituents (carbohydrates, protein, 

fat, and ash), minerals, vitamins, amino acids, fatty acids, secondary metabolites, antinutrients, 

phytosterols, and nutritional impact. MON 87427 corn is agronomically and compositionally 

similar to other GE and non-GE corn varieties (Monsanto, 2010; USDA-APHIS, 2012). As a 

result, and as determined in Section 4, Environmental Consequences, the potential impacts under 

the Preferred Alternative for all the resource areas analyzed would be the same as those 

described for the No Action Alternative.

The potential impacts under the Preferred Alternative from the use of herbicides would be the 

same as those under the No Action Alternative (see Subsections 4.2, Agricultural Production of 

Corn; 4.3, Physical Environment; 4.4, Biological Resources; 4.5, Public Health; and 4.6, Animal 

Feed). The method and timing of application for herbicides to be applied to MON 87427 corn 

would not change from those already approved for use on other nonregulated glyphosateresistant corn cultivars, except for applications during development of male reproductive 

structures. For tassel control, an over-the top glyphosate application to MON 87427 plants 

targets reproductive parts when the plant development is between the V8 and V13 stage 

(Monsanto, 2013). If RR2 plants are to be sprayed with glyphosate during these development 

stages (V8 and later), the applicator must use drop nozzles to avoid application to the 

reproductive structures of the plant, especially when the plant height is 30-48” (Monsanto, 

2009). These application methods that differ slightly will be unlikely to cause different impacts 

on the evaluated resource areas when considered together.

The use rate for the conventional glyphosate resistant (RR2) and the MON 87427 tissue selective 

line to be used for hybridization are the same. For post emergence weed control using 

glyphosate for both Roundup Ready 2 (RR2) corn crops and MON 87427 the total rate (Roundup 

Powermax), is 64 ounces, with at a 32 ounce maximum application rate for RR2 crops, and the 

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same for MON 87427 (Monsanto, 2009; Monsanto, 2013 - Supplemental Labeling Personal 

communication). In addition, the use for tassel control in MON 87427 is 11-32 ounces, with a 

64 ounce total post emergence application of glyphosate inclusive of all uses. There does not 

appear to be a difference in allowable timing of post emergent use of glyphosate under the EPA 

approved label. Because the volume of herbicide for both applications of glyphosate is similar, 

no differences in impacts of herbicide are expected between Monsanto 87427 and conventional 

RR2 corn and therefore no differences in potential cumulative impacts between MON 87427 and 

other types of glyphosate resistant corn. Other crops also contain a glyphosate resistant trait, 

with which MON 87427 lines might be rotated on leased seed corn production acres, including 

soybean and cotton. Labels for both of these crops allow a maximum of 5.3 quarts glyphosate 

per acre per season, as does that for MON 87427. However, for cotton, the label allows 

application of 4 quarts per acre for all in-crop application compared to 64 ounces (two quarts) 

with soybean, RR2 corn and MON 87427; nevertheless, total yearly application per acre is the 

same for all four crops. Again, APHIS determines that there will be no likely cumulative impact 

of differences from glyphosate application rate or methodology on MON 87427 crops when 

considering impacts from all other conventional RR2 crops, nor when considering possible 

impacts of other non-glyphosate resistant crops in rotation with corn.

Glyphosate is not presently used for weed control in hybrid seed corn production (Monsanto, 

2010), because many of the inbreds employed do not incorporate the glyphosate resistant trait. 

The deployment of MON 87427 in the hybrid seed production system will potentially allow as 

many acres that are currently used for seed production overall to show some increase in the use 

of glyphosate. While these acres will not likely be increasing in number, the proprietary acres on 

which Monsanto grows seed corn and the larger number of acres on which Monsanto grows seed 

corn on leased acres (Groth, 2013), may show a trend towards increased use of glyphosate. On 

these leased acres, RR2 corn (or soybean) already will most likely have been one of the rotation 

crops. In these cases, the soil and water in the leased lands will already have had some 

continuing exposure to the glyphosate herbicide, and production of acreage with some additional 

glyphosate exposure at standard rates will not likely present significant new impacts, especially 

since the year to year variation in the predominating glyphosate-resistant corn is greater than the 

total of all the continuing seed corn production acres.

MON 87247 corn will be grown primarily for hybrid seed production, and therefore will be

expected to be planted on a small percentage of acres compared to corn destined for grain and 

feed production. Corn planted for purposes of hybrid seed production has historically been 

restricted to small amounts of land, about 0.5 million acres annually (Jugenheimer, 1976), an 

area that is not expected to change with the introduction of MON 87427. Over the last 35 years, 

the volume of hybrid maize seed planted in the U.S. has changed very little, with 20.10 million 

bushels (MBu) planted in 1975 and 22.9 MBu planted in 2010 (USDA-ERS, 2011b). Grain 

yields have increased significantly over this same period. Thus, corn acreage with the trait will 

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be 0.5/88.1 or 0.57% of total US corn acres in 2010 (USDA-NASS, 2013) quite small in relation 

to the surrounding corn and as noted earlier, small in relation to the fluctuation of acres in corn 

production on a yearly basis. In addition, glyphosate has one of the least environmental impacts 

of all herbicides (Duke and Powles, 2008) on the agricultural and surrounding acreages; given 

the already high use of glyphosate in soybean and cotton acres, does not represent a substantial 

new burden of herbicide into the environment.

The total amount of herbicides applied as tank mixes that could be applied to MON 87427 corn 

would be limited by the authorized EPA-registered uses and the total application amount allowed

by that label. Glyphosate and other pesticides are registered by the EPA under FIFRA and are 

reviewed and reregistered every 15 years to assess potential toxicity and environmental impact. 

In order to be registered for use, a pesticide must be able to be used without unreasonable risks to 

people or the environment. Pesticide residue tolerances for glyphosate and other herbicides and 

pesticides are listed in 40 CFR §180.364 and include acceptable concentrations for corn grain 

and forage. In addition, the safety precautions and EPA-labeled instructions for the application 

of pesticides would not change under the Preferred Alternative, ensuring continued human health 

and worker safety (see Subsection 4.5, Public Health). Again, because any possible increase in 

such tank mixed additional herbicides on seed corn production would remain less than the total 

of such corn-applied herbicides through typical year to year variation of production corn acreage, 

no significant environmental impact is likely.

The herbicide glyphosate has been implicated by some in reductions of plant mineral uptake or 

nutrition (Duke and Powles, 2009) As noted by Duke et al. (Duke et al., 2012) the work showing 

such reduction has almost all been done in the greenhouse on glyphosate resistant soybean. 

Notable also is work that shows such changes in nutrition in response to glyphosate are most 

different at dosage rates beyond the allowable single application label rate (Zobiole et al., 2012) 

Also, although some mineral nutrition depression with glyphosate can be detected, these appear 

to be “within the normal ranges for these crops” (Duke et al., 2012). Finally, when field trials are 

performed using label rates, content of 13 minerals was not lower following either one or two 

applications of glyphosate in either leaves or seed (Duke et al., 2012) . In the case of glyphosate 

resistant corn, neither crop effect nor glyphosate effects resulted in changes to the rhizosphere, 

denitrifying bacteria, or fungi (Hart et al., 2009). APHIS concludes that there is no consistent 

evidence for an effect of glyphosate on mineral nutrition of soybean, and not likely of corn, 

either. 

MON 87427 corn stacked with other herbicide-resistant traits would, however, narrow the 

options for herbicidal management of volunteer corn. In crop rotations where glyphosate 

resistant soybean or some other broadleaf cultivar is rotated with corn, an approved grass 

herbicide could be used to control volunteer corn (Sandel et al, 2011). In continuous corn 

cropping systems with the same herbicide resistances, control becomes more complicated and in 

some cases may be accomplished through other means such as tillage (Louex et al, 2011; Sandel 

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et al, 2011). Loux et al. (2011) recommend careful rotation planning to eliminate this potential 

problem. MON 87427 stacked with insect-resistant traits would be no more likely to exhibit 

increased weediness characteristics than other currently available glyphosate- and insect-resistant 

stacked transgenic corn cultivars. Similarly, stacked MON 87427 is not expected to exhibit any 

gene flow characteristics different from the parent transformation events (i.e., crop lines) that 

would pose a plant pest risk.

Under the Preferred Alternative, approving a determination of nonregulated status to MON 

87427is not expected to result in changes to current corn cropping practices. Studies conducted 

by Monsanto demonstrate that, in terms of agronomic characteristics and cultivation practices, 

MON 87427 corn is similar to other corn varieties currently grown (Monsanto, 2010; USDAAPHIS, 2012) and the aggregate of possible impacts are not likely to be cumulative ones.

Consequently, no changes to current corn cropping practices such as tillage, crop rotation, or 

agricultural inputs associated with the adoption of MON 87427 are expected (see Subsection 

4.2.2, Agronomic Practices). 

5.4 Cumulative Impacts: Organic Corn Production

Based upon recent trends, adding GE varieties to the market is not related to the ability of 

organic production systems to maintain their market share (see Subsection 4.2.3, Organic Corn 

Production). As described above, the majority of corn in 2012 was GE and herbicide resistant 

(USDA-NASS, 2012d). Since 1994, 27 GE corn events or lines have been determined by 

APHIS to be no longer subject to the regulatory requirements of 7 CFR part 340 or the plant pest 

provisions of the Plant Protection Act (USDA-APHIS, 2012) U.S. organic corn production 

acreage grew 83% from 32,650 acres in 1995 to 194,637 acres in 2008, and remained at about 

0.2% of total U.S. corn acreage from 2005 to 2008 (USDA-ERS, 2011d-a). Availability of 

another GE glyphosate-resistant corn variety, such as MON 87427 under the Preferred 

Alternative, is not expected to impact the organic production of corn any differently than other 

GE varieties, based on past growing experience or from presently available traits under the No 

Action Alternative.

5.5 Cumulative Impacts: Physical Environment

As discussed in Subsection 4.3, Physical Environment, approving the petition for nonregulated 

status of MON 87427 under the Preferred Alternative would have the same potential impacts to 

water, soil, air quality, and climate change as that of nonregulated glyphosate-resistant corn 

varieties presently available. Agronomic practices that have the potential to impact soil, water 

and air quality, and climate change such as tillage, agricultural inputs (fertilizers and pesticides), 

and irrigation would not change because MON 87427 is agronomically similar to other 

glyphosate-resistant corn and other GE and non-GE corn. Other practices that benefit these 

resources, such as contouring, use of cover crops to limit the time soil is exposed to wind and 

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rain, crop rotation, and windbreaks would also be the same between the No Action and Preferred 

Alternatives. Because of its similarity to other nonregulated glyphosate-resistant corn and the 

fact that most cultivated corn in the U.S. is glyphosate resistant, adoption of MON 87427 for 

seed production would replace inbred and other breeding lines without changing the acreage or 

area of corn production that could impact water, soil, air quality, and climate change. No 

difference in impacts to these resources would occur between the Preferred and No Action 

alternatives.

While the principle reason for adoption of MON 87427 would be for pollen control, EPA also 

allows weed control with glyphosate application that may total 64 ounces for all “ postemergence 

(in-crop) early-season weed control applications (provisional label, Roundup PowerMAX® 

Herbicide, EPA Reg. No. 524-549). If the petition for nonregulated status for MON 87427 is 

approved and it is crossed into inbreds qualified for hybrid production, depending on the extent 

of its adoption, it may contribute to sustaining or increasing conservation tillage (CT) in U.S. 

corn production. CT both directly and indirectly impacts water, soil, and air quality. Bennett 

(N.D.) notes that in some locations, seed producers were still using moldboard plows and 

conventional tillage; these could potentially to be converted to minimal tillage when a glyphosate 

resistance trait were introduced that accompanies the trait for hybridization efficiency. If it is 

true that “the primary reason for tillage has been for weed management” (Duke and Powles, 

2009), then the availability of MON 87427 may reduce the need for tillage in some locations, 

thus benefiting soil, water, and air quality. However, in some seed production situations, the 

need for conventional tillage is more likely to be that inbreds being less vigorous than hybrids 

yield better when conventional tillage is provided (Monsanto, 2010). However, if reduced tillage

were to be a consequence of adoption of MON 87427, soil quality may be improved and soil 

erosion reduced. When considered with other glyphosate resistant corn and rotation crops, 

hybrid production with use of MON 87427 may possibly provide environmental benefits to the

physical environment.

5.6 Cumulative Impacts: Biological Resources

The impacts of the Preferred Alternative to animal and plants communities, microorganisms, and 

biodiversity as discussed in Subsection 4.4, Biological Resources would be no different than that 

experienced under the No Action Alternative. MON 87427 corn is both agronomically and 

compositionally similar to other nonregulated glyphosate-resistant corn; thus, it would not 

require any different agronomic practices to cultivate, and does not represent a safety or 

increased weediness risk any differently than other currently available glyphosate-resistant corn. 

Availability of MON 87427 corn would not more frequently lead to development of glyphosateresistant weeds or diminish the trend to broaden weed management tactics to effect control over 

herbicide-resistant weeds, as it is expected to provide glyphosate resistance to inbreds for 

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hybridization without expanding the acreage or area of corn production or changing the 

application rates of glyphosate (see Subsection 4.4.2, Plant Communities). 

MON 87427 inbred corn would be incorporated with numerous other traits for production of 

stacked varieties of GE corn. Potential future stacking of MON 87427 corn might include 

development of inbreds using other currently available nonregulated corn varieties expressing 

resistance to other herbicides, or resistance to select insect pests by stacking with one of the 

biopesticidal Bt genes. APHIS regulations under 7 CFR part 340 do not provide for Agency 

oversight of stacked varieties combining GE varieties with previously approved nonregulated 

status, unless it can be positively shown that such stacked varieties are likely to pose a plant pest 

risk. Whether MON 87427 would be stacked with any particular nonregulated GE variety is 

unknown, as company plans and market demands play a significant role in those business 

decisions. In addition, the adoption level of MON 87427 would depend on the extent producers 

value the traits offered by stacked versions of MON 87427 over other available stacked corn 

varieties.

Following a determination of nonregulated status, MON 87427 corn would likely be stacked 

with insect-resistant corn varieties that express the Bt endotoxin. Based on studies undertaken to 

assess the potential impacts of the Bt endotoxin to the monarch and other non-target butterflies, 

as well as factors such as the location of corn production and the characteristics of corn pollen, 

the EPA determined that the potential risk to non-target butterflies is low (EPA, 2002). Any 

insect-resistant trait that may be developed in the future and stacked along with the MON 87427

trait would be subject to APHIS, EPA, and FDA approval. The adoption of MON 87427 inbreds

would be contingent on the extent breeders see value in conferring additional traits to a

commercial corn cultivars or to generate inbreds that express herbicide- pathogen- and insectresistant traits.

The purpose of this trait is to facilitate pollen flow from male inbreds to female inbreds; thus, 

gene flow is desired. With respect to gene flow not planned, to commercial or seed production 

fields, there are no differences in the potential for gene flow and weediness between the No 

Action and Preferred Action Alternatives. There is also no risk of gene movement between corn 

and its wild or weedy maize relatives (EPA, 2010a; USDA-APHIS, 2012). Additionally, corn 

seed does not possess the characteristics for efficient seed-mediated gene flow, does not establish 

wild or feral populations, and is dependent on human cultivation for survival (Doebley, 2004). 

As discussed in Subsection 2.3.3, Gene Flow and Weediness, MON 87427corn is similar to other 

glyphosate-resistant corn varieties. The risk of gene flow and weediness of MON 87427 corn is 

no greater than that of other nonregulated glyphosate-resistant corn varieties.

As discussed in Section 4.2.2., Plant Communities, Maize Line HCEM485 would not likely 

impact the development or treatment of herbicide-resistant weeds or their associated costs in 

crop losses or methods to affect control. Weeds commonly encountered in commercial corn 

production will be similar to those arising in seed corn production and in commercial corn 

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production, since these may often be on common rotation acreage. Agronomic practices 

common in seed corn production, such as tillage and herbicide use, will be common ones found 

in commercial production. More use will be made of glyphosate when using MON 87427 

because glyphosate resistance will be imparted in those inbreds used for hybridization. 

Consequently, conventional management used in the commercial production will also be 

employed in the inbred seed production fields. While the use of glyphosate when done without 

more comprehensive weed control plans can lead to development of new glyphosate resistant 

weeds, no additional weeds or new weed shifts will be expected in the MON 87427 fields than 

those already developing in the conventional corn and rotation crops grown on the same acreage 

under seed corn production. Just as growers have become more conscious of the need to 

proactively deal with weed development issues stemming from over-reliance on glyphosate in 

commercial corn fields (Beckie, 2011; Prince et al., 2012), the same growers who produce seed 

from glyphosate resistant inbreds will also likely respond similarly to the measures they took for 

their commercial production acres.

As discussed in 5.5 Cumulative Impacts: Physical Environment, it is possible that less use of 

tillage may be a consequence of adoption of MON 87427, and habitat value may be improved 

through increased water quality, availability of waste grain to animals, retention of cover in 

fields, and increased populations of invertebrates (Brady, 2007; Sharp, 2010). Introducing 

glyphosate resistance into the inbreds for seed production may promote or at least sustain 

conservation tillage rates, which subsequently would improve soil quality and reduce soil 

erosion, sustaining both crop and non-crop plants and greater plant diversity in fields (see 

Subsection 2.2.2, Soil Quality). When considered with other glyphosate resistant corn and 

rotation crops, hybrid production with use of MON 87427 may potentially provide benefits to the 

biological environment.

5.7 Cumulative Impacts: Public Health and Animal Feed

Food and feed derived from GE corn must be in compliance with all applicable legal and 

regulatory requirements and may undergo a voluntary consultation process with the FDA prior 

to release onto the market to identify and discuss relevant safety, nutritional, or other regulatory 

issues regarding the bioengineered food. As discussed in Subsections 4.5, Public Health and 

4.6, Animal Feed, MON 87427would have no toxic effect to human health or livestock

(Monsanto, 2010). Monsanto has submitted data for a food safety and nutritional assessment of 

MON 87427 corn to FDA in December, 2010, (BNF No. 000126), and FDA completed their 

response letter on 13 April 2012. The decision is posted on the FDA website 

(http://www.fda.gov/Food/Biotechnology/Submissions/ucm304083.htm). A food safety 

evaluation of the same EPSPS protein as that used in the MON 87427 corn variety was 

completed by the FDA (BNF No. 51) on February 10, 1998, which found no safety concerns 

(FDA, 2012a; FDA, 2012b). In addition, the potential environmental impacts from the 

cultivation of glyphosate-resistant corn varieties have been thoroughly evaluated by APHIS (see

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http://www.aphis.usda.gov/publications/biotechnology/index.shtml ). As discussed in 

Subsection 4.4, Biological Resources, APHIS has determined there would be no significant risk 

to biological resources from the presence of the EPSPS protein that confers glyphosate 

resistance in MON 87427, which is identical to the protein found in nonregulated glyphosateresistant corn cultivars in commerce today. No change in food and feed safety would occur 

between the Preferred and No Action alternatives.

Following a determination of nonregulated status, MON 87427 could be incorporated into 

inbreds and stacked with insect-resistant corn varieties that express the Bt endotoxin. In 

accordance with 40 CFR part 174, all the currently nonregulated insect-resistant corn varieties 

that contain the Bt endotoxin are exempt from the requirement of tolerance in feed commodities.

In inbred corn varieties incorporating MON 87427 and stacked with insect-resistant (Bt) traits 

herbicide and insect resistance traits would likely be found as well with. Any insect-resistance 

trait that may be developed in the future and stacked along with MON 87427 for hybrid 

production would be subject to APHIS, EPA, and FDA approval. The adoption of stacked MON 

87427 corn would be contingent on the extent seed developers see value in the traits expressed in 

comparison to other commercially available corn cultivars with similar herbicide- and insectresistant traits.

Any additional GE traits for inbreds that may be incorporated with MON 87427 have already 

been assessed by APHIS and determined to be nonregulated. As such, the production and use of 

products from these cultivars as food or feed have been determined on the basis of FDA 

evaluation of food and feed uses to have no significant negative impact on the biological 

resources, human health, or animal feed analyzed in this EA. As discussed above in Subsection 

4.5 Public Health and 4.6 Animal Feed, food and feed derived from GE corn must be in 

compliance with all applicable legal and regulatory requirements and may undergo a voluntary 

consultation process with the FDA prior to release onto the market. All GE traits into which 

MON 87427 would be incorporated for producing varieties of inbred corn have undergone, or 

are expected to undergo, this process to ensure their safety as food and feed products.

5.8 Cumulative Impacts: Domestic Economic Environment

As discussed above, based on its similarity to other nonregulated corn cultivars, MON 87427

corn would be deployed in inbreds used for hybridization without impacting corn acreage or 

production area that may affect domestic markets. Additionally, since MON 87427 corn is 

agronomically and compositionally similar to other commercially available corn, there would be 

few changes to agronomic inputs or practices following approval of the nonregulated status to 

MON 87427 other than using glyphosate to eliminate tassels during pollination. Although the 

hybrid system may reduce costs of seed production, it is not certain that the reductions would 

necessarily be passed to growers purchasing seed. Consequently, we do not expect that any 

production changes for seed producers may impact on-farm costs for corn seed purchasers whose 

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seed derives from MON 87427, other purchasers of conventionally derived seed, or the domestic 

economic environment, including the organic corn market. As cited above, MON 87427

compared to other glyphosate resistant corn hybrids would not be likely to impact differently the 

development or management of herbicide-resistant weeds or their associated costs in crop losses 

or methods to effect control. Impacts of the Preferred Alternative on the domestic economic 

environment would therefore be no different than experienced under the No Action Alternative.

Corn inbreds for hybridization with single and multiple herbicide resistance or insect resistance 

are already widely used, since commercial seed with these traits comprised 73% of U.S. corn 

acreage in 2012 (see Subsection 2.1.1, Acreage and Area of Corn Production). While the 

adoption of herbicide-resistant-only corn has remained relatively level and the production of 

insect-resistant-only corn has decreased since 2007, the adoption of stacked varieties that confer 

resistance to herbicides and insects has steadily increased from 1% of planted corn acres in 2000 

to 49% in 2011 (USDA-ERS, 2011b). MON 87427 corn would likely be used to produce new 

varieties stacked with insect-resistant and other traits and would have impacts similar to other 

such stacked corn cultivars already on the market. Agronomic practices, including inputs for 

production of MON 87427 inbreds stacked with insect resistance or other traits, would be no 

different than those needed to cultivate other corn with the same resistant properties; thus, 

changes to on-farm costs for corn seed producers or to the U.S. domestic corn market would be 

unlikely. Overall, it is not likely that any cumulative impact to the domestic economic 

environment would result from the addition of the MON 87427 trait to inbreds for making new 

stacked products or from the stacked products deriving from them, consisting of other readilyavailable GE traits, or non-GE traits. 

5.9 Cumulative Impacts: Trade Economic Environment

Under the Preferred Alternative, it is possible MON 87427 corn would not be approved for 

import into other countries. Because the U.S. and other countries already have access to other 

glyphosate-resistant corn cultivars, and MON 87427 corn presents marketplace means to 

efficiently produce new hybrids, and its availability only to U.S. producers would not likely 

significantly impact the economic trade environment. Only 15% of domestically produced U.S. 

corn is dedicated to the export market (USDA-ERS, 2011g), and the extent of plantings of MON 

87427 seed corn producers find value in this hybrid production system. If MON 87427 corn 

were not approved for import by other countries but were to be approved as nonregulated in the 

U.S., it would not likely affect the supply of U.S. corn eligible for import to other countries. 

Likewise, if it were approved both in the U.S. and for import by other countries, based on its 

similarity to other glyphosate-resistant corn cultivars MON 87427 corn would still be unlikely to 

affect the supply of U.S. corn available for export. If it were approved in the US, but not for 

import by other countries, growers may find that more limited options were available for grain 

sales (Stebbins and Plume, 2011), but again, any significant impact on exports would be unlikely 

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because the growers would likely hesitate to grow the crop and large quantities would not be 

produced.

As discussed in Subsection 2.6.2, Trade Economic Environment, U.S. corn exports have 

remained relatively stable over the last decade, a period in which other corn varieties with 

stacked glyphosate and other traits have been brought to market. Global export markets respond 

to many factors and are unlikely to change with the commercial availability of this glyphosateresistant corn cultivar such as MON 87427 corn alone, or if it had been used to produce stacked 

varieties with other currently available traits.

5.10 Cumulative Impacts: Domestic Socio Economic Analysis

MON 87427 will be used to facilitate the production of viable hybrid maize seed and offers an 

alternative to mechanical and manual detasseling methods, and to Cytoplasmic Male Sterile 

technology. Another trait to provide male sterility for corn hybridization is SPT by 

DuPont/Pioneer and was recognized by APHIS as nonregulated in 2011. The technology uses 

genetic means and color sorting to select the desired seed, and may be in use for hybrid 

production. This trait also removes the need to provide detasseling of female inbreds. Pioneer in 

2011 had about 36% of the corn seed market, and Monsanto had 34%. As both of these 

technologies begin to be used by their developer, nearly 70% of the market will be eventually 

capable of avoiding manual detasseling. As discussed, for Monsanto, the transition to use of 

their inducible male sterility trait will require 2.5-4 years when using tropical seed production 

locations, and presumably, a similar number of years will be needed by Pioneer to convert their 

inbreds to ones carrying the genetic male sterility trait. As noted in Section 4.7.1, the impact of 

reduced employment for high school students, migrants and temporary workers who are 

employed in detasseling operations for about one month in summer is likely to be a gradual one

because the process requires numerous crosses to obtain the inbreds with the traits. Historically, 

the amount of hand labor needed in detasseling has declined after the initiation of the hybrid seed 

production era, first with the introduction of mechanical detasseling in 1974 (cuts off first round 

of female plant tassels), then with wheel pullers (removes 40-85% of remaining female plant 

tassels) in the 1990s (Leidy, 2009) (Monsanto, 2010). With increasing contributions of 

technology, labor needs have declined and efficiencies of mechanical, genetic and chemical 

strategies have improved seed and agricultural production. It is reasonable to assume that such 

losses would have a potential negative impact until another source of income might be secured to 

replace these temporary detasseling jobs but the impact is not likely to be a significant one.

The cumulative impacts of MON 87427 along with the availability and development of Pioneer’s 

SPT trait for hybrid production may also have impacts on overall efficiency of seed production 

that could have at least marginal impacts on acreage needed for seed production. As noted,

removal of the entire tassel can result in the removal of too much leaf tissue, and reduce maize 

seed yields by as much as 10% (B. and O., 1997). The percentage of tassels removed per pass 

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will increase when a mechanical detasseling method is replaced and leaf damage will decrease. 

In addition, the tassels that have been removed in mechanical detasseling can become lodged in 

the leaf canopy and shed pollen, resulting in unwanted self-pollination. This complication is 

presently resolved by hand detasseling crews. Because plant damage will be reduced by the 

elimination of detasseling, additional productivity from plants may be possible, and a potential 

exists for reduction in allocated acreage for seed production. 

6 Threatened and endangered species 

THREATENED AND ENDANGERED SPECIES 

Congress passed the Endangered Species Act (ESA) of 1973, as amended, to prevent extinctions 

facing many species of fish, wildlife and plants. The purpose of the ESA is to conserve 

endangered and threatened species and the ecosystems on which they depend as key components 

of America’s heritage. To implement the ESA, the U.S. Fish & Wildlife Service (USFWS) 

works in cooperation with the National Marine Fisheries Service (NMFS), other Federal, State, 

and local agencies, Tribes, non-governmental organizations, and private citizens. Before a plant 

or animal species can receive the protection provided by the ESA, it must first be added to the 

Federal list of threatened and endangered wildlife and plants.

A species is added to the list when it is determined by the USFWS/NMFS to be endangered or 

threatened because of any of the following factors:

The present or threatened destruction, modification, or curtailment of its habitat or range;

Overutilization for commercial, recreational, scientific, or educational purposes;

Disease or predation;

The inadequacy of existing regulatory mechanisms; and

The natural or manmade factors affecting its survival.

Once listed in accordance with the ESA, protective measures apply to the species and its habitat. 

These measures include protection from adverse effects of Federal activities. 

Section 7 (a)(2) of the ESA requires that Federal agencies, in consultation with USFWS and/or 

the NMFS, ensure that any action they authorize, fund, or carry out is not likely to jeopardize the 

continued existence of a listed species or result in the destruction or adverse modification of 

designated critical habitat. It is the responsibility of the Federal agency taking the action to 

assess the effects of their action and to consult with the USFWS and NMFS if it is determined 

that the action “may affect” listed species or critical habitat. To facilitate APHIS’ ESA 

consultation process, APHIS met with the USFWS from 1999 to 2003 to discuss factors relevant 

to APHIS’s regulatory authority and effects analysis for petitions for nonregulated status, and 

developed a process for conducting an effects determination consistent with the Plant Protection 

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Act of 2000 (Title IV of Public Law 106-224). APHIS uses this process to help fulfill its 

obligations and responsibilities under Section 7 of the ESA for biotechnology regulatory actions. 

APHIS’ regulatory authority over GE organisms under the Plant Protection Act is limited to 

those GE organisms for which it has reason to believe might be a plant pest or those for which 

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

pose a plant pest risk (7 CFR § 340.1). APHIS does not have authority to regulate the use of any 

herbicide, including glyphosate. After completing a PPRA, if APHIS determines that MON 

87427 corn does not pose a plant pest risk, then MON 87427 corn would no longer be subject to 

the plant pest provisions of the Plant Protection Act or to the regulatory requirements of 7 CFR 

Part 340, and therefore, APHIS must reach a determination that the article is no longer regulated. 

As part of its EA analysis, APHIS is analyzing the potential impacts of MON 87427 corn on the 

environment including any potential effects to threatened and endangered species and critical 

habitat. As part of this process, APHIS thoroughly reviews the GE product information and data 

related to the organism (generally a plant species, but may also be other genetically engineered 

organisms). For each transgene/transgenic plant, APHIS considers the following information, 

data, and questions: 

• A review of the biology and taxonomy of the crop plant and its sexually compatible relatives;

• Characterization of each transgene with respect to its structure and function and the nature of 

the organism from which it was obtained;

• A determination of where the new transgene and its products (if any) are produced in the 

plant and their quantity;

• A review of the agronomic performance of the plant including disease and pest 

susceptibilities, weediness potential, and agronomic and environmental impact;

• Determination of the concentrations of known plant toxicants (if any are known in the plant); 

• Analysis to determine if the transgenic plant is sexually compatible with any threatened or 

endangered species (TES) of plants or a host of any TES; and

Any other information that may inform the potential for an organism to pose a plant pest risk.

Consistent with this review process, APHIS, has evaluated the potential effects that approval of a 

petition for nonregulated status for MON 87427 corn may have, if any, on Federally-listed TES 

and species proposed for listing, as well as designated critical habitat and habitat proposed for 

designation. Based upon the scope of the EA and production areas identified in the Affected 

Environment section of the EA, APHIS obtained and reviewed the USFWS list of TES species 

(listed and proposed) for each state where corn hybrids are commercially produced from the 

USFWS Environmental Conservation Online System (USFWS, 2012). Prior to this review, 

APHIS considered the potential for MON 87427 corn to extend the range of corn production and 

also the potential to extend agricultural production into new natural areas. Monsanto’s studies 

demonstrate that agronomic characteristics and cultivation practices required for MON 87427 are 

essentially indistinguishable from practices used to grow other corn varieties, including other 

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herbicide-resistant varieties (Monsanto, 2010; USDA-APHIS, 2012). Although MON 87427 

may be expected to replace other varieties of corn currently cultivated, APHIS does not expect 

the cultivation of MON 87427 to result in new corn acres to be planted in areas that are not 

already devoted to hybrid corn seed production. Accordingly, the issues discussed herein focus 

on the potential environmental consequences of the determination of nonregulated status of 

MON 87427 corn on TES species in the areas where hybrid corn seed are currently produced. 

APHIS focused its TES review on the implications of exposure to the CP4 EPSPS protein in 

MON 87427, the interaction between TES and MON 87427 corn, including the potential for 

sexual compatibility and the ability to serve as a host for a TES, and the ability to affect plants 

and habitat by naturalizing in the environment. However, in furtherance of NEPA, APHIS also 

considered the potential impacts of the use of glyphosate, expected to be used on MON 87427 

Corn, to non-target organisms and the natural environment.

Potential Effects of MON 87427 Corn on TES

Threatened and Endangered Plant Species and Critical Habitat

The agronomic data provided by Monsanto were used in the APHIS analysis of the weediness 

potential for MON 87427 corn and potential to affect TES. Agronomic studies conducted by 

Monsanto tested the hypothesis that the weediness potential of MON 87427 corn is unchanged 

with respect to conventional corn used in hybrid seed production (Monsanto, 2010; USDAAPHIS, 2012). No differences were detected between MON 87427 corn and conventional corn 

in growth, reproduction, or interactions with pests and diseases, other than the intended effect of 

tissue-specific herbicide tolerance (USDA-APHIS, 2012). Potential of corn weediness is low, 

due to domestication syndrome traits that generally lower overall fitness outside an agricultural 

environment (Stewart et al., 2003). Mature corn seeds have no innate dormancy, are sensitive to 

cold, and in colder climates, many do not survive in freezing winter conditions, although 

volunteers can be an issue in many locations. Corn has been cultivated around the globe without 

any report that it is a serious weed or that it forms persistent feral populations (USDA-APHIS, 

2012). Corn cannot survive in the majority of the country without human intervention, and it is 

easily controlled if volunteers appear in subsequent crops. APHIS has concluded the 

determination of nonregulated status of MON 87427 corn does not present a plant pest risk, does 

not present a risk of weediness, and does not present an increased risk of gene flow when 

compared to other currently cultivated corn varieties. Based on the agronomic field data and 

literature survey on corn weediness potential, MON 87427 corn is unlikely to affect threated or 

endangered plants or their habitat as a troublesome or invasive weed, nor is it likely to affect 

critical habitat of any species (USDA-APHIS, 2012).

APHIS evaluated the potential of MON 87427 corn to cross with a listed species. As discussed 

above and in the analysis of Gene Movement and Weediness, APHIS has determined that there is 

no risk to unrelated plant species from the cultivation of MON 87427 corn. Corn is an annual, 

wind-pollinated crop which lacks sexually compatible wild relatives in the U.S., except for 

occasional botanical garden specimens (PPRA, APHIS, 2012). After reviewing the list of 

threatened and endangered plant species in the States where seed corn hybrids are grown, APHIS 

determined that MON 87427 corn would not be sexually compatible with any listed threatened or 

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endangered plant species or plant proposed for listing as none of these listed plants are in the 

same genus nor are known to cross pollinate with species of the genus Zea. APHIS considered 

the possibility that MON 87427 corn could serve as a host plant for a threatened or endangered 

species. A review of the species list reveals that there are no members of the genus Zea that 

serve as a host plant for any threatened or endangered species.

Threatened and Endangered Animal Species 

Monsanto has presented information on the food and feed safety of MON 87427 corn, comparing 

the MON 87427 corn variety with conventional varieties currently grown. There are no toxins or 

allegens associated with this plant, and the CP4 EPSPS protein are present in many crop plants 

and have been analyzed in numerous EAs prepared for petitions for nonregulated status 

(Monsanto, 2010, Monsanto, 1996). Compositionally, MON 87427 Corn was determined to be 

the same as conventional varieties. Compositional elements compared included moisture, 

protein, fat, carbohydrates, ash, minerals, dietary fiber, essential and non-essential amino acids, 

fatty acids, vitamins, and antinutrients (Need Citation) Results presented by Monsanto show that 

the incorporation of the cp4 epsps gene and the attendant expression of the CP4 EPSPS protein 

in MON 87427 corn does not result in any biologically-meaningful differences between MON 

87427 corn and the non-transgenic hybrid. Therefore, there is no expectation that exposure to 

the protein or the plant will have any effect on T&E animal species that may be exposed to MON 

87427 corn. 

I suggest inserting a paragraph here that discussed the results of the FDA review. Here is an 

example from another EA:

The FDA has concluded its review of Monsanto’s submittal of safety and nutritional data for 

MON-87427-7 corn (FDA, 2012). Monsanto conducted safety evaluations based on Codex 

Alimentarius Commission procedures to assess any potential adverse effects to humans or 

animals resulting from environmental releases and consumption of MON-87427-7 corn 

(Monsanto, 2010). These safety studies included evaluating protein structure and function, 

including homology searches of the amino acid sequences with comparison to all known 

allergens and toxins, an in vitro digestibility assay of the proteins, an acute oral toxicity feeding 

study in mice, and a feeding study in broiler chickens. MON-87427-7 corn protein was 

previously determined to have no amino acid sequence similar to known allergens, lacked toxic 

potential to mammals, and was degraded rapidly and completely in gastric fluid Monsanto, 

2010). At this time, the FDA considers the consultation on MON-87427-7 corn to be complete. 

A copy of the FDA consultation is provided in an Appendix. 

Conclusion

After reviewing the possible effects of allowing the unregulated environmental release of MON 

87427 corn, APHIS has not identified any stressor that could affect the reproduction, numbers, or 

distribution of a listed TES or species proposed for listing. Therefore, a detailed species by 

species analysis of effects is not necessary. APHIS also considered the potential effect of 

approval of a petition for nonregulated status of MON 87427 corn on designated critical habitat 

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or habitat proposed for designation, and could identify no differences from effects that would 

occur from the production of other corn varieties. This corn variety has been developed for use 

in hybrid seed production, and as such its use will be limited to areas where seed is produced. 

Corn is not considered a particularly competitive plant species and has been selected for 

domestication and cultivation under conditions not normally found in natural settings. Corn is 

not sexually compatible with, or serves as a host species for, any listed species or species 

proposed for listing. Consumption of MON 87427 corn by any listed species or species 

proposed for listing will not result in a toxic or allergic reaction. Based on these factors, APHIS 

has concluded that approval of a petition of nonregulated status for MON 87427 corn, and the 

corresponding environmental release of this corn variety will have no effect on listed species or 

species proposed for listing, and would not affect designated habitat or habitat proposed for 

designation. Because of this no-effect determination, consultation under Section 7(a)(2) of the 

Act or the concurrences of the USFWS or NMFS are not required. 

Potential Impacts of Glyphosate Use on T&E species and Critical Habitat

To help clarify our ESA and NEPA obligations, APHIS met with USFWS officials on June 15, 

2011 to discuss whether APHIS has any obligations under the ESA to analyze the impacts of 

herbicide use associated with all GE crops on T&E species. As a result of these joint discussions, 

the USFWS and APHIS have agreed that it is not necessary for APHIS to perform an ESA 

effects analysis on herbicide use associated either with MON 87427 corn or other currently 

planted GE crops.

APHIS has no statutory authority to authorize or regulate the use of glyphosate, or any other 

herbicide, by corn growers. Under 7 CFR 340, APHIS only has the authority to regulate MON 

87427 corn or any GE organism, if the agency believes it may pose a plant pest risk. APHIS has 

no regulatory jurisdiction over any other risks associated with GE organisms, including risks 

resulting from the use of herbicides or other pesticides on those organisms. Nevertheless, APHIS 

is aware that there may be potential environmental impacts resulting from the use of glyphosate 

on MON 87427 corn, including potential impacts on T&E species and critical habitat, based on 

assessments provided by the EPA and in peer reviewed scientific literature.

Under the Preferred Alternative, approval of a petition for non-regulated status for MON 87427 

Corn does not change the weed management usage of glyphosate, nor the total allowable 

application of glyphosate, but adds an over-the-top application to corn at time when drop nozzle 

application would be recommended. As noted in this EA in the Section 2.2.1, the 

preponderance of corn grown in the US is herbicide resistant (USDA-NASS, 2012) Approval of 

non-regulated status for MON 87427 corn would only result in the addition of a glyphosate 

resistant variety to be used in hybrid seed production. Therefore, approval of a petition for nonregulated status for MON 87427 corn would mean a potential increase of 0.52% of corn acreage 

that would be glyphosate treated. Because the adoption by Monsanto of this trait for inbreds and 

potentially by other companies would be gradual, the slight increase in treated acreage would 

only occur over 3-8 years. Based on these considerations, APHIS has concluded that a 

determination of non-regulated status for MON 87427 Corn, would not result in any changes in 

impacts of glyphosate on T&E species or their designated critical habitats. 

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General considerations relevant to the impact of glyphosate on T&E species have been reviewed 

by EPA, which has developed the Endangered Species Protection Program (ESPP). This 

program identifies pesticides that may cause adverse impacts to T&E species, and mitigation 

measures that address these impacts. To analyze the potential of registered pesticide uses that 

affect any particular species, the EPA assesses toxicity and exposure data developed for REDs 

(Reregistration Eligibility Decisions). A determination that there is a likelihood of a potential 

impact on a T&E species may result in limiting registered uses of a pesticide, other measures to 

mitigate any potential impact, and/or consultations with the USFWS and/or the NMFS.

Glyphosate is currently under reregistration review, which is scheduled to be complete in 2015

(US-EPA, 2009a). As part of the review, the EPA will conduct a risk assessment to support a

complete endangered species determination (US-EPA, 2009b). 

Assessments of the toxicity of glyphosate on animal species indicate low risk to animals, but 

high risk to plants. Glyphosate is moderately toxic to mammals, less than or slightly toxic to 

birds, and virtually non-toxic to fish, invertebrates, and honeybees (US-EPA, 1993). Impacts to 

T&E species and/or their habitats may result from non-target exposure from pesticide drift, 

runoff, volatilization, adsorption into soils, leaching, and cleaning and disposal of herbicide 

dispensing equipment. These impacts are mitigated by the requirements for the use of each 

product that appear on the EPA registration label. Since past ecological assessments indicated 

possible exposure risk to non-target terrestrial and aquatic plants outside treated fields, a spray 

drift buffer zone analysis is planned for the glyphosate reregistration review currently underway 

(US-EPA, 2009b). EPA will direct any mitigations necessary for users or growers to eliminate 

or reduce the potential of glyphosate to impact terrestrial or aquatic non-target plant species, 

including T&E species, by either changing the terms of the pesticide registration or establishing 

geographically specific pesticide use limitations. When geographically specific use limitations 

are necessary, they will be reflected in Endangered Species Protection Bulletins.. 

The surfactant polyethoxylated tallow amine (POEA) is included in some glyphosate product 

formulations. POEA is more toxic to aquatic organisms than glyphosate itself (US-EPA, 2009b). 

Therefore, EPA will identify and consider formulations containing POEA in its ecological and 

endangered species risk assessments. Under the new requirements of 40 CFR Part 158, studies 

to determine acute toxicity of POEA to estuarine and marine mollusks, invertebrates, and fish 

species will be accomplished for inclusion in the current registration review.

In the ecological risk assessment for the current reregistration process, the EPA has reviewed 

whether the approved uses of glyphosate represent a “no effect” or “may affect” impact on T&E 

species, their designated critical habitats (US-EPA, 2009b). The EPA has consulted with the 

USFWS and NMFS on the effects of glyphosate on certain T&E species and designated critical 

habitat (US-EPA, 2008a, b; US-EPA, 1993; US-EPA 2004a, b). Throughout the reregistration 

process, EPA will consult with USFWS and NMFS as necessary to meet their obligations under 

section 7 (a)(2) of the ESA to ensure that uses of glyphosate that are consistent with label 

regulations will not affect T&E species.

APHIS focused its TES review on the implications of exposure to the CP4 EPSPS protein in 

MON 87427, the interaction between TES and MON 87427 corn, including the potential for 

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sexual compatibility and the ability to serve as a host for a TES; and potential impacts of the use 

of glyphosate to non-target organisms and the natural environment.

Based on the agronomic field data, literature survey on corn weediness potential, and that there 

are no TES sexually compatible with corn, APHIS has concluded that MON 87427 corn will 

have no effect on threatened or endangered plant species.

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7 Consideration of executive orders, standards, and treaties relating to 

environmental impacts

7.1 Executive Orders with Domestic Implications

The following executive orders require consideration of the potential impacts of the Federal 

action to various segments of the population.

• Executive Order (EO) 12898 (US-NARA, 2010), "Federal Actions to Address 

Environmental Justice in Minority Populations and Low-Income Populations,"

requires Federal agencies to conduct their programs, policies, and activities that 

substantially affect human health or the environment in a manner so as not to exclude 

persons and populations from participation in or benefiting from such programs. It 

also enforces existing statutes to prevent minority and low-income communities from 

being subjected to disproportionately high and adverse human health or 

environmental effects. 

• EO 13045, “Protection of Children from Environmental Health Risks and Safety 

Risks,” acknowledges that children may suffer disproportionately from 

environmental health and safety risks because of their developmental stage, greater 

metabolic activity levels, and behavior patterns, as compared to adults. The EO (to 

the extent permitted by law and consistent with the agency’s mission) requires each 

Federal agency to identify, assess, and address environmental health risks and safety 

risks that may disproportionately affect children.

The No Action and Preferred Alternatives were analyzed with respect to EO 12898 and EO 

13045. Neither alternative is expected to have a disproportionate adverse effect on minorities, 

low-income populations, or children. 

Available mammalian toxicity data associated with the CP4 EPSPS proteins establish the safety 

of MON 87427 corn and its products to humans, including minorities, low-income populations, 

and children who might be exposed to them through agricultural production and/or processing 

(61 CFR 150, 2007). No additional safety precautions would need to be taken. 

Based on the information submitted by the applicant and reviewed by APHIS, MON 87427 corn

is agronomically, phenotypically, and biochemically comparable to conventional corn except for 

the introduced and tissue-specific CP4 EPSPS protein. The information provided in the 

Monsanto petition indicates that the CP4 EPSPS protein is not expected to be allergenic, toxic, or 

pathogenic in mammals (Monsanto, 2010). Monsanto plans on initiating and completing the 

voluntary FDA consultation regarding MON 87427 corn before commercialization.. 

Human toxicity has also been evaluated by the EPA in its development of pesticide labels for 

glyphosate (EPA, 1993; EPA, 2009b). Pesticide labels include use precautions and restrictions 

intended to protect workers and their families from exposures. It is reasonable to assume that 

growers will adhere to these EPA herbicide use precautions and restrictions. As discussed in 

Subsection 4.5, Public Health, the potential use of glyphosate on MON 87427 corn would be no 

more than rates currently approved by the EPA and should not to have adverse impacts to human 

health when used in accordance with label instructions. It is expected that EPA would monitor 

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the use of MON 87427 corn to determine impacts on agricultural practices, such as chemical use,

as they have done previously for herbicide-resistant products.

Based on these factors, a determination of nonregulated status of MON 87427 corn is not 

expected to have a disproportionate adverse effect on minorities, low-income populations, or 

children.

The following executive order addresses Federal responsibilities regarding the introduction and 

effects of invasive species:

EO 1311 (US-NARA, 2010), “Invasive Species,” states that Federal agencies take 

action to prevent the introduction of invasive species, to provide for their control, 

and to minimize the economic, ecological, and human health impacts that 

invasive species cause. 

Corn is not listed in the U.S. as a noxious weed species by the Federal government, nor is it 

listed as an invasive species by major invasive plant data bases. Cultivated corn seed does not 

usually exhibit dormancy and requires specific environmental conditions to grow as a volunteer 

the following year (OECD, 2003). Any volunteers that may become established do not compete 

well with the planted crop and are easily managed using standard weed control practices. Corn

does not possess characteristics such as the tolerance for a variety of habitat conditions, rapid 

growth and reproduction, aggressive competition for resources, and the lack of natural enemies 

or pests (USDA-APHIS, 2012) that would make it a successful invasive plant. Non-engineered 

corn, as well as other herbicide-resistant corn varieties, are widely grown in the U.S. Based on 

historical experience with these varieties and the data submitted by the applicant and reviewed 

by APHIS, MON 87427 corn plants are sufficiently similar in fitness characteristics to other corn

varieties currently grown and are not expected to become weedy or invasive.

The following executive order requires the protection of migratory bird populations:

EO 13186 (US-NARA, 2010), “Responsibilities of Federal Agencies to Protect 

Migratory Birds,” states that federal agencies taking actions that have, or are 

likely to have, a measurable negative effect on migratory bird populations are 

directed to develop and implement, within two years, a Memorandum of 

Understanding (MOU) with the Fish and Wildlife Service that shall promote the 

conservation of migratory bird populations. 

Data submitted by the applicant has shown no difference in compositional and nutritional quality 

of MON 87427 compared with other GE corn or non-GE corn, apart from the presence of the 

CP4 EPSPS. MON 87427 corn not expected to be allergenic, toxic, or pathogenic in mammals. 

The CP4 EPSPS proteins has a history of safe consumption in the context of other food and feeds

(61 CFR 150, 2007). Based on APHIS’ assessment of MON 87427, it is unlikely that a

determination of nonregulated status of MON 87427 will have a negative effect on migratory bird 

populations.

The environmental effects associated with glyphosate have been analyzed by the EPA. 

Glyphosate is considered no more than slightly nontoxic to birds (EPA, 1993). Based on these 

factors, it is unlikely that the determination of nonregulated status of MON 87427 corn would 

have a negative effect on migratory bird populations.

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7.2 International Implications

EO 12114 (US-NARA, 2010), “Environmental Effects Abroad of Major Federal Actions”

requires federal officials to take into consideration any potential environmental effects outside 

the U.S., its territories, and possessions that result from actions being taken. 

APHIS has given this EO careful consideration and does not expect a significant environmental 

impact outside the U.S. in the event of a determination of nonregulated status of MON 87427 

corn. All existing national and international regulatory authorities and phytosanitary regimes 

that currently apply to introductions of new corn varieties internationally apply equally to those 

covered by an APHIS determination of nonregulated status under 7 CFR part 340. 

Any international trade of MON 87427 corn subsequent to a determination of nonregulated 

status of the product would be fully subject to national phytosanitary requirements and be in 

accordance with phytosanitary standards developed under the International Plant Protection 

Convention (IPPC, 2010). The purpose of the IPPC “is to secure a common and effective action 

to prevent the spread and introduction of pests of plants and plant products and to promote 

appropriate measures for their control” (IPPC, 2010). The protection it affords extends to natural 

flora and plant products and includes both direct and indirect damage by pests, including weeds. 

The IPPC establishes a standard for the reciprocal acceptance of phytosanitary certification 

among the nations that have signed or acceded to the Convention (172 countries as of March 

2010). In April 2004, a standard for PRA of living modified organisms (LMOs) was adopted at 

a meeting of the governing body of the IPPC as a supplement to an existing standard, 

International Standard for Phytosanitary Measure No. 11 (ISPM-11, Pest Risk Analysis for 

Quarantine Pests). The standard acknowledges that all LMOs will not present a pest risk and 

that a determination needs to be made early in the PRA for importation as to whether the LMO 

poses a potential pest risk resulting from the genetic modification. APHIS pest risk assessment 

procedures for genetically engineered organisms are consistent with the guidance developed 

under the IPPC. In addition, issues that may relate to commercialization and transboundary 

movement of particular agricultural commodities produced through biotechnology are being 

addressed in other international forums and through national regulations.

The Cartagena Protocol on Biosafety is a treaty under the United Nations Convention on 

Biological Diversity (CBD) that established a framework for the safe transboundary movement, 

with respect to the environment and biodiversity, of LMOs, which include those modified 

through biotechnology. The Protocol came into force on September 11, 2003, and 160 countries 

are Parties to it as of December 2010 (CBD, 2010). Although the U.S. is not a party to the CBD, 

and thus not a party to the Cartagena Protocol on Biosafety, U.S. exporters will still need to 

comply with those regulations that importing countries which are Parties to the Protocol have 

promulgated to comply with their obligations. The first intentional transboundary movement of 

LMOs intended for environmental release (field trials or commercial planting) will require 

consent from the importing country under an advanced informed agreement (AIA) provision, 

which includes a requirement for a risk assessment consistent with Annex III of the Protocol and 

the required documentation.

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LMOs imported for food, feed, or processing (FFP) are exempt from the AIA procedure, and are 

covered under Article 11 and Annex II of the Protocol. Under Article 11, Parties must post 

decisions to the Biosafety Clearinghouse database on domestic use of LMOs for FFP that may be 

subject to transboundary movement. To facilitate compliance with obligations to this protocol, 

the U.S. Government has developed a website that provides the status of all regulatory reviews 

completed for different uses of bioengineered products (NBII, 2010). 

APHIS continues to work toward harmonization of biosafety and biotechnology consensus 

documents, guidelines, and regulations, including within the North American Plant Protection 

Organization (NAPPO), which includes Mexico, Canada, and the U.S., and within the 

Organization for Economic Cooperation and Development (OECD). NAPPO has completed 

three modules of the Regional Standards for Phytosanitary Measures (RSPM) No. 14, 

Importation and Release into the Environment of Transgenic Plants in NAPPO Member 

Countries (NAPPO, 2009).

APHIS also participates in the North American Biotechnology Initiative (NABI), a forum for 

information exchange and cooperation on agricultural biotechnology issues for the U.S., Mexico, 

and Canada. In addition, bilateral discussions on biotechnology regulatory issues are held 

regularly with other countries including Argentina, Brazil, Japan, China, and Korea.

7.3 Compliance with Clean Water Act and Clean Air Act

This EA evaluated the potential changes in hybrid corn seed production associated with a 

determination of nonregulated status of MON 87427 corn (Section 4.2) and determined that the 

cultivation of MON 87427 corn would not lead to the increased production or acreage of corn in 

U.S. agriculture. The herbicide tolerance conferred by the genetic modification to MON 87427 

corn would not result in any changes in water usage for cultivation. As discussed in Section 

4.3.2 and 4.3.3, there are no expected negative impacts to water resources or air quality from 

potential use of glyphosate associated with MON 87427 corn production. Based on these 

analyses, APHIS concludes that a determination of nonregulated status of MON 87427 corn

would comply with the CWA and the CAA.

7.4 Impacts on Unique Characteristics of Geographic Areas

A determination of nonregulated status of MON 87427 corn is not expected to impact unique 

characteristics of geographic areas such as park lands, prime farmlands, wetlands, wild and 

scenic areas, or ecologically critical areas.

Monsanto has presented results of agronomic field trials for MON 87427 corn. The results of 

these field trials demonstrate that there are no differences in agronomic practices between MON 

87427 and conventional corn. The common agricultural practices that would be carried out in 

the cultivation MON 87427 corn are not expected to deviate substantially from current practices, 

including the use of EPA-registered pesticides. The product is expected to be deployed on

agricultural land currently suitable for production of corn and replace existing varieties, and is

not expected to increase the acreage of corn production. 

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There are no proposed major ground disturbances; no new physical destruction or damage to 

property; no alterations of property, wildlife habitat, or landscapes; and no prescribed sale, lease, 

or transfer of ownership of any property. This action is limited to a determination of 

nonregulated status of MON 87427 corn. This action would not convert land use to 

nonagricultural use and, therefore, would have no adverse impact on prime farmland. Standard 

agricultural practices for land preparation, planting, irrigation, and harvesting of plants would be 

used on agricultural lands planted to MON 87427 corn, including the use of EPA-registered 

pesticides. 

With regard to pesticide use, a determination of nonregulated status of MON 87427 corn is likely 

to result in changes in the use of glyphosate on hybrid corn seed production fields. The potential 

changes in herbicide use are discussed in Section 4.2.2. Glyphosate is currently not generally 

used in hybrid corn seed production. APHIS assumes that the EPA label would provide for label

use restrictions intended to mitigate potential impacts to the human environment, including 

potential impacts to unique geographic areas. As noted above, APHIS further assumes that the 

grower will closely adhere to EPA label use restrictions for all pesticides.

All pesticides distributed or sold in the U.S. are subject to registration by the EPA under 

authority of FIFRA. Glyphosate was first registered for use by the EPA in 1974, and has been 

assessed several times since then by the EPA and other Federal Agencies (EPA, 2009b). At 

present, glyphosate is currently undergoing registration review by the EPA; in 1993, EPA 

determined that all currently registered pesticide products containing glyphosate would not pose 

unreasonable risks or adverse effects to humans or the environment, thus permitting its eligibility 

for the EPA pesticide reregistration program (EPA, 2009b). A preliminary problem formulation 

has been conducted as part of the registration review of glyphosate by the EPA, identifying what 

is currently known and uncertainty regarding the ecological risk, environmental fate, endangered 

species, and drinking water assessment of glyphosate and its transformation products (EPA, 

2009b). EPA produced an estimated timeline for the completion of the glyphosate registration 

review, with a final decision due in 2015 (EPA, 2009a). Submittals that are relevant to the EPA 

registration review of glyphosate can be submitted under the docket designation EPA-HQ-2009-

0361 at the Regulations.gov website. 

Based on these findings, including the assumption that EPA label use instructions are in place to 

protect unique geographic areas and that those label use instructions are adhered to, a 

determination of nonregulated status of MON 87427 corn is not expected to impact unique 

characteristics of geographic areas such as park lands, prime farm lands, wetlands, wild and 

scenic areas, or ecologically critical areas.

7.5 National Historic Preservation Act of 1966 as Amended

The NHPA of 1966 and its implementing regulations (36 CFR 800) require Federal agencies to: 

1) determine whether activities they propose constitute "undertakings" that have the potential to 

cause effects on historic properties and 2) if so, to evaluate the effects of such undertakings on 

such historic resources and consult with the Advisory Council on Historic Preservation (i.e., 

State Historic Preservation Office, Tribal Historic Preservation Officers), as appropriate. 

APHIS’ proposed action, a determination of nonregulated status of MON 87427 corn is not 

expected to adversely impact cultural resources on tribal properties. Any farming activity that 

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may be taken by farmers on tribal lands would only be conducted at the tribe’s request; thus, the 

tribes would have control over any potential conflict with cultural resources on tribal properties.

APHIS’ Preferred Alternative would have no impact on districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places, nor would it 

likely cause any loss or destruction of scientific, cultural, or historical resources. This action is 

limited to a determination of non-regulated status of MON 87427 corn. 

APHIS’ proposed action is not an undertaking that may directly or indirectly cause alteration in 

the character or use of historic properties protected under the NHPA. In general, common 

agricultural activities conducted under this action do not have the potential to introduce visual, 

atmospheric, or noise elements to areas in which they are used that could result in effects on the 

character or use of historic properties. For example, there is potential for increased noise on the 

use and enjoyment of a historic property during the operation of tractors and other mechanical 

equipment close to such sites. A built-in mitigating factor for this issue is that virtually all of the 

methods involved would only have temporary effects on the audible nature of a site and can be 

ended at any time to restore the audible qualities of such sites to their original condition with no 

further adverse effects. Additionally, these cultivation practices are already being conducted 

throughout the corn production regions. The cultivation of MON 87427 corn is not expected to 

change any of these agronomic practices that would result in an adverse impact under the NHPA.

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8 List of Preparers

Craig R. Roseland, Ph.D.,

Senior Environmental Protection Specialist

Environmental Risk Analysis Programs

USDA APHIS

Khamkeo Vongpaseuth, Ph.D.,

Environmental Protection Specialist, 

Environmental Risk Analysis Programs

USDA APHIS

Rebecca L. Stankiewicz Gabel, Ph.D., 

Chief, Biotechnology Environmental 

Analysis Branch, Environmental Risk

Analysis Programs

USDA APHIS

Adam Tulu, Ph.D.,

Environmental Protection Specialist 

(Intern), Environmental Risk Analysis 

Programs

USDA APHIS

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