NATIONAL ENVIRONMENTAL POLICY ACT DECISION

AND

PRELIMINARY FINDING OF NO SIGNIFICANT IMPACT

Monsanto Company

Event MON 88302 Canola

United States Department of Agriculture

Animal and Plant Health Inspection Service

Biotechnology Regulatory Services

The United States Department of Agriculture (USDA) Animal and Plant Health Inspection 

Service (APHIS) has developed this decision document to comply with the requirements of the 

National Environmental Policy Act (NEPA) of 1969, as amended, the Council of Environmental 

Quality’s (CEQ) regulations implementing NEPA, and the USDA APHIS NEPA implementing 

regulations and procedures. This NEPA decision document, Preliminary Finding of No 

Significant Impact (FONSI), sets forth this APHIS NEPA decision and its rationale. Comments 

from the public involvement process were evaluated and considered in developing this NEPA 

decision.

In accordance with APHIS procedures implementing NEPA (7 CFR part 372), APHIS has 

prepared an Environmental Assessment (EA) to evaluate and determine if there are any 

potentially significant impacts to the human environment from a regulatory determination about

the status of a petition request (APHIS Number 11-188-01p) by Monsanto Company (Monsanto) 

for their GE (genetically engineered) Event MON 88302 Canola (hereafter referred to as MON 

88302 Canola) which is resistant to the herbicide, glyphosate. This EA has been prepared in 

order to specifically evaluate the effects on the quality of the human environment that may result 

from approving the petition seeking nonregulated status for MON 88302 Canola. The EA 

assesses alternatives to a determination of nonregulated status of MON 88302 Canola, and the 

potential environmental and social effects that result from the proposed action and the

alternatives.

Regulatory Authority

“Protecting American agriculture” is the basic charge of APHIS. APHIS provides leadership 

in ensuring the health and care of plants and animals. The agency improves agricultural 

productivity and competitiveness, and contributes to the national economy and the public 

health. USDA asserts that all methods of agricultural production (conventional, organic, or the 

use of GE varieties) can increase farm income, and provide benefits to the environment and

consumers.
Since 1986, the United States government has regulated GE organisms pursuant to 51 FR 23302

and 57 FR 22984, which outline a regulatory framework known as the Coordinated Framework 

for the Regulation of Biotechnology (henceforth referred to here as the Coordinated 

Framework). 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 Food and Drug 

Administration (FDA), and the Environmental Protection Agency (EPA).

APHIS is responsible for regulating GE organisms and plants under the plant pest provision of

the Plant Protection Act of 2000 (PPA), as amended (7 USC §§ 7701 et seq.) to ensure that they 

do not pose a plant pest risk to the environment.

The FDA regulates GE organisms under the authority of the Federal Food, Drug, and Cosmetic 

Act (FFDCA). The FDA is responsible for ensuring the safety and proper labeling of all plantderived foods and feeds, including those that are genetically engineered. To help developers of 

food and feed derived from GE crops comply with their obligations under Federal food safety 

laws, FDA encourages them to participate in a voluntary consultation process. The FDA policy 

statement concerning regulation of products derived from new plant cultivars, including GE 

varieties, was published in the Federal Register on May 29, 1992 (57 FR 22984-23005). Under 

this policy, FDA uses what is termed a consultation process to ensure that human food and 

animal feed safety issues, and other related regulatory issues (e.g., labeling) are resolved prior to 

commercial distribution of food and feed derived from products of GE plants.

The EPA regulates plant-incorporated protectants under the Federal Insecticide, Fungicide, and 

Rodenticide Act (FIFRA). This responsibility encompasses regulation of the sale, distribution 

and use of pesticides, including those that are produced from GE organisms. EPA also has 

authority granted under the FFDCA to establish maximum contaminant levels referred to as 

tolerances for pesticides. Tolerances are maximum pesticide residue levels allowed in or on food 

for human consumption, and in feed for animals used as human food sources. One other statute, 

the Toxic Substances Control Act, authorizes EPA to regulate certain biological control 

organisms.
Regulated Organisms

The mission of APHIS Biotechnology Regulatory Services (BRS) is to protect America’s 

agriculture and environment using a dynamic, science-based regulatory framework that allows 

for the safe development and use of GE organisms. APHIS regulations at 7 Code of Federal 

Regulations (CFR) part 340 promulgated under the authority of the PPA, 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 PPA 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 a taxon that includes plant pests and is listed as such 

in 7 CFR 340.2. A GE organism is also regulated under Part 340 when APHIS does not have 

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

An individual may petition the agency for a determination that a particular regulated article is 

unlikely to pose a plant pest risk, and, therefore, is no longer subject to the plant pest risk 

provisions of the PPA and corresponding regulations at 7 CFR part 340. 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.

APHIS’ Response to Petition for Nonregulated Status

Under the authority of the plant pest provisions of the PPA, APHIS has issued regulations (7 

CFR part 340) for the safe development and use of GE organisms. As required by 7 CFR 

340.6, APHIS must respond to petitioners who request a determination of the regulated status 

of GE organisms, including GE plants such as MON 88302 Canola. When a petition for 

nonregulated status for a GE organism is submitted, APHIS must determine whether or not it 

poses a plant pest risk. If APHIS determines, based on its Plant Pest Risk Assessment (PPRA),

that the GE organism is unlikely to pose a plant pest risk, it is no longer subject to the plant 

pest provisions of the PPA and regulations of 7 CFR part 340.

Monsanto has submitted a petition (APHIS Number 11-188-01p) to APHIS seeking a 

determination that GE MON 88302 Canola is unlikely to pose a plant pest risk and therefore, 

should no longer be a regulated article under 7 CFR part 340. 

MON 88302 Canola

MON 88302 Canola has been genetically modified to express the CP4 EPSPS protein, which 

conveys resistance to the herbicide, glyphosate. MON 88302 Canola provides growers with an 

alternative to existing glyphosate-resistant- (GR-) canola products on the market today. MON 
88302 Canola will provide added benefits of more effective weed control, compared to currently 

available GR-canola varieties because glyphosate can be applied at a higher rate to later 

developmental stages of crops planted in MON 88302 Canola.. 

Coordinated Framework Review

Food and Drug Administration

MON 88302 Canola is within the scope of the FDA policy statement concerning regulation of 

products derived from new plant varieties, including GE ones. Monsanto initiated the 

consultation process with FDA for the commercial distribution of MON 88302 Canola and 

submitted a safety and nutritional assessment of food and feed derived from MON 88302 Canola 

to the FDA on March 23, 2011 (Monsanto, 2011).

Environmental Protection Agency

The EPA has authority over the use of pesticidal substances and plant-incorporated protectants

under the FIFRA as amended (7 USC §136, et seq.) and the FFDCA (21 USC §301, et seq.). 

APHIS considers the EPA regulatory assessment when assessing potential impacts that may

result from a determination of nonregulated status of a GE organism. 

EPA has authority under FIFRA to establish pesticide use restrictions, which are determined

during the pesticide registration process, and are listed on the label for each product containing a 

particular pesticide active ingredient. MON 88302 Canola is similar to currently available GRcanola varieties with the exception of allowing for glyphosate applications to a broader 

range of developmental statges at a higher application rate. Monsanto submitted a request 

for amended labeling requirements to the U.S. EPA in February 2011 for EPA Registration 

Numbers 524-537 and 524-549, that would modify the current use pattern allowed for 

glyphosate on MON 88302 Canola (Monsanto, 2011). The glyphosate application rate will be 

similar to the rates for GR maize and soybeans. APHIS considered the proposed changes to the

currently approved glyphosate uses on canola in its evaluation of the potential impacts associated 

with a determination of no regulatory authority for MON 88302 Canola.

Scope of the Environmental Analysis

Although a determination of nonregulated status of MON 88302 Canola would allow for new 

plantings of MON 88302 Canola anywhere in the U.S., APHIS primarily focused the 

environmental analysis on those geographic areas that currently support canola production. A 

determination of nonregulated status of MON 88302 Canola is not expected to increase canola

production, either by its availability alone or accompanied by other factors, so no increase in 

overall GE canola acreage is likely. To determine areas of canola production, APHIS used data 

from the National Agricultural Statistics Service (NASS) to determine where canola is produced 

in the U.S. (UDA-NASS, 2012). In North America, the primary canola-growing region is 
in areas of the Great Plains characterized by high quality soil, but shorter, drier growing

seasons than that preferred by most corn and soybean varieties. Most of this region is in the 

prairie provinces of Canada, but part of it extends into North Dakota. From 2003-2012, the 

average canola production in the U.S. has been about 1.1 million acres (USDA-NASS, 2012). 

According to the 2007 Census of agriculture North Dakota produced about 93% of all the canola 

grown in the U.S.

Public Involvement

On July 13, 2012, APHIS published a notice in the Federal Register (77 FR pages 41357-41358, 

Docket no. APHIS-2012-0035) announcing the availability of the Monsanto petition for a 60-day 

public review and comment period. The deadline for receipt of comments was September 11, 

2012. All comments were carefully analyzed to identify potential environmental and interrelated 

economic issues and impacts that APHIS determined should be considered in the evaluation of 

the petition. A total of 70 dockets containing 4,670 comments1

was received during the open 

review period.

Comments were screened and sorted into categories according to the subject matter addressed 

and classified as either non-substantive or substantive. Substantive comments were defined as 

those not previously considered by APHIS that included new information and/or contributed to a 

broader understanding of the issue, and advanced the goal of an informed decision by the agency 

to regulate or not regulate MON 88302 Canola. Such substantive comments required a formal 

technical response by APHIS, and these have been addressed in the appropriate sections of the

EA. Substantive comments identified the following issues:

• Canola outcrossing with other mustards;

• Canola forming feral populations;

• Development of herbicide-resistant (HR) weeds;

• Use of herbicides on HR crops;

• The fate of glyphosate in air and water;

• The effects of glyphosate use on biological organisms;

• The effect of glyphosate drift on outcrossing to weedy or wild relatives;

• Increase in plant pathogens or susceptibility to plant pathogens from the use of 

glyphosate;

• Concerns that cross-pollination between GE and organic, or other crops for GE-sensitive 

markets, will affect sales for growers of these crops;

• Concerns that MON 88302 Canola is not approved in all export markets.

In this EA, APHIS evaluated these comments and has included a discussion of them and other 

related issues with relevant documentation and citations where appropriate.

1 Comments are available for review on line at:

http://www.regulations.gov/#!docketBrowser;rpp=25;po=0;dct=PS;D=APHIS-2012-0035.

 
Responses to specific substantive comments are included in an attachment to this Preliminary 

Finding of No Significant Impact.

Major Issues Addressed in the EA

Issues addressed in the EA were identified by considering public concerns and issues described 

in public comments for the petition for nonregulated status of MON 88302 Canola and other 

EAs of GE organisms. Issues identified in previous lawsuits, and those submitted by various 

stakeholders were also discussed. These issues, including those regarding the agricultural

production of canola using various production methods, and the environmental food/feed safety

of GE plants, were addressed to analyze the potential environmental impacts of MON 88302

Canola .

The EA describes the alternatives considered and evaluated using the identified issues. The 

following issues were identified as important to the scope of the analysis (40 CFR 1508.25):

Agricultural Production Considerations:

• Acreage and Areas of Canola Production

• Agronomic/Cropping Practices

• Canola Seed Production

• Organic Canola Production

Environmental Considerations:

• Water Resources

• Soil

• Air Quality

• Climate Change

• Animals

• Plants

• Gene Flow

• Microorganisms

• Biological Diversity

Human Health Considerations:

• Public Health

• Worker Safety

Livestock Health Considerations:

• Livestock Health/Animal Feed
Socioeconomic Considerations:

• Domestic Economic Environment

• Trade Economic Environment

Alternatives that were fully analyzed

The EA analyzes the potential environmental consequences of a determination of nonregulated 

status for MON 88302 Canola. To respond favorably to a petition for nonregulated status, 

APHIS must determine that MON 88302 Canola is unlikely to pose a plant pest risk. Based on 

its PPRA (USDA-APHIS, 2013), APHIS has concluded that MON 88302 Canola is unlikely to 

pose a plant pest risk. Therefore, APHIS must determine that MON 88302 Canola is no longer 

subject to 7 CFR part 340 or the plant pest provisions of the PPA. Two alternatives were 

evaluated in the EA: (1) no action and (2) determination of nonregulated status of MON 88302

Canola. APHIS has assessed the potential for environmental impacts for each alternative in the 

Environmental Consequences section of the EA.

No Action: Continuation as a Regulated Article

Under the No Action Alternative, APHIS would deny the petition. MON 88302 Canola and 

progeny derived from MON 88302 Canola would continue to be regulated articles under the 

regulations at 7 CFR part 340. Permits or notifications acknowledged by APHIS would still be 

required for introductions of MON 88302 Canola 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 absence of plant pest risk from the 

unconfined cultivation of MON 88302 Canola. 

This alternative is not the preferred alternative because APHIS has concluded through its PPRA

that MON 88302 Canola is unlikely to pose a plant pest risk (USDA-APHIS, 2013). Choosing 

this alternative would not satisfy the purpose and need of making a determination of plant pest 

risk status and responding to the petition for nonregulated status.

Preferred Alternative: Determination that MON 88302 Canola is No Longer a Regulated 

Article

Under this alternative, MON 88302 Canola and progeny derived from MON 88302 Canola

would no longer be regulated articles under the regulations at 7 CFR part 340. MON 88302

Canola is unlikely to pose a plant pest risk (USDA-APHIS, 2013). Permits issued or 

notifications acknowledged by APHIS would no longer be required for introductions of MON 

88302 Canola and progeny derived from this event. The preferred alternative best meets the 

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 

PPA. Because the agency has concluded that MON 88302 Canola is unlikely to pose a plant pest 
risk, a determination of nonregulated status of MON 88302 Canola is a response that is 

consistent with the plant pest provisions of the PPA, the regulations codified in 7 CFR part 340, 

and the biotechnology regulatory policies in the Coordinated Framework.

Alternatives Considered but Rejected from Further Consideration

APHIS assembled a list of alternatives that might be considered for MON 88302 Canola. The 

agency evaluated these alternatives, in light of the agency’s authority under the plant pest 

provisions of the PPA, 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 88302 Canola. Based on this evaluation, APHIS rejected several alternatives. These 

alternatives are discussed briefly below along with the specific reasons for rejecting each.

1. Prohibit any MON 88302 Canola 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 88302 Canola, including 

denying any permits associated with the field testing. APHIS determined that this alternative is 

not appropriate because APHIS has concluded that MON 88302 Canola is unlikely to pose a 

plant pest risk (USDA-APHIS, 2013). 

In enacting the Plant Protection Act, Congress found (§402(4) that:

“[D]ecisions affecting imports, exports, and interstate movement of products regulated 

under this title [the Plant Protection Act] shall be based on sound science;”

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 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 specific principle (among 

others) to the extent permitted by law when regulating emerging technologies:

“Decisions should be based on the best reasonably obtainable scientific, technical, 

economic, and other information, within the boundaries of the authorities and mandate of 

each agency;”

Based on the PPRA (USDA-APHIS, 2013), and the scientific data evaluated therein, APHIS 

concluded that MON 88302 Canola is unlikely to pose a plant pest risk. Consistent with this 

conclusion, there is no basis in science for prohibiting the release of MON 88302 Canola.

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 88302 Canola is unlikely to pose a plant pest risk, (USDA-APHIS, 

2013), there is no regulatory basis under the plant pest provisions of the PPA for considering 

approval of the petition only in part.

3. Isolation Distance between MON 88302 Canola and Non-GE Canola 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 88302 Canola from conventional or 

specialty (e.g., organic) canola production. However, because APHIS has concluded that MON 

88302 Canola is unlikely to pose a plant pest risk (USDA-APHIS, 2013), an alternative based on 

requiring isolation distances would be inconsistent with statutory authority under the plant pest 

provisions of the PPA and regulations in 7 CFR part 340.

APHIS also considered geographically restricting the production of MON 88302 Canola based 

on the location of production of non-GE canola 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 the APHIS PPRA for 

MON 88302 Canola, there are no geographic differences associated with MON 88302 Canola

relevant to potential plant pest risks (USDA-APHIS, 2013), so this alternative was rejected and 

not analyzed in detail because APHIS has concluded that MON 88302 Canola does not present a 

plant pest risk, and will not exhibit a greater plant risk in any geographically restricted area. 

Therefore, such an alternative would not be consistent with the APHIS statutory authority under 

the plant pest provisions of the PPA, regulations in Part 340 and those biotechnology regulatory 

policies embodied in the Coordinated Framework.

Based on the foregoing, the imposition of isolation distances or geographic restrictions would not 

meet the 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 PPA. However, individuals might choose on their own to geographically 

isolate their non-GE production systems from MON 88302 Canola or to use isolation distances 

and other management practices to minimize gene movement between canola fields. 

Information to assist growers in making informed management decisions for MON 88302

Canola is available from the Association of Official Seed Certifying Agencies (AOSCA, 2011).

4. Requirement of Testing for MON 88302 Canola

During the comment periods for other petitions for nonregulated status, some commenters 

requested that USDA require and provide testing for GE products in non-GE production systems. 

APHIS notes that 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 

implement and maintain. Because MON 88302 Canola also does not pose a plant pest risk 

(USDA-APHIS, 2013), the imposition of any type of testing requirements is inconsistent with 

the plant pest provisions of the PPA, regulations at 7 CFR part 340 and those biotechnology 

regulatory policies embodied in the Coordinated Framework. Therefore, imposing such a 

requirement for MON 88302 Canola would not meet the APHIS purpose and need to respond 

appropriately to the petition in accordance with its regulatory authorities.

Environmental Consequences of the APHIS Selected Action

The EA contains a full analysis of the alternatives to which we refer the reader for specific 

details. The following table briefly summarizes the results for each of the issues fully analyzed 

in the Environmental Consequences section of the EA.

Summary of Issues of Potential Impacts and Consequences of Alternatives

Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

Meets Purpose, Need and 

Objectives

No Yes

Unlikely to Pose a Plant Pest Risk Satisfied by regulated field 

trials.

Satisfied – plant pest risk 

assessment (USDA-APHIS, 

2013)

Management Practices

Acreage and Areas of Canola 

Production

Since the 1999 introduction of 

herbicide-resistant canola in the 

U.S., production has fluctuated 

between 0.8-1.6M acres. 

Average U.S. canola acreage is

about 1.1M acres. About 93% of 

it was located in North Dakota. 

Nearly all (99%) of the ND crop 

was herbicide resistant; 57% of 

that was glyphosate resistant.

No change from Alternative A
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

Agronomic Practices

Conservation tillage, which tends 

to provide a competitive 

advantage to canola production 

by promoting earlier crop 

emergence, has increased since 

the introduction of HR- canola 

varieties. In the northern U.S., 

use of tillage has declined from 

89% to 35%; in some individual 

instances it remains useful in 

managing herbicide-resistant 

weeds. About half of growers 

rely on a 3-year rotation of 

canola, a small grain, and 

soybean. The remaining growers 

use a two-year rotation of 

canola/wheat.

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa).

Canola Seed Production Most seed production is in

Alberta. In the U.S, seed 

production occurs in the

Columbia Basin in eastern

Washington, the Grand Ronde

Valley in Union County in

northeastern Oregon, and the

San Luis Valley in south central

Colorado. Most seed

companies have off-season

seed production locations in

the southwestern U.S. About

5,000 acres of commercial seed 

production supply enough seed

to plant the entire U.S. canola

crop.

No change from the No-Action 

Alternative

Pesticide Use EPA-approves uses of herbicides 

on canola. Specific treatment 

The approved in-crop 

glyphosate application rate for 
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

rates and crop stage restrictions 

apply to HR canola. 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa).

Organic Canola Production

Certified organic production is an 

extremely small component of 

canola production conducted 

primarily in regions remote from 

major GE-canola-crop sites.

No change from No-action 

Alternative

Environment

Soil Quality

Herbicide applications in 

conjunction with HR canola have 

promoted conservation tillage, 

which preserves soil quality by 

reducing erosion. Growers 

currently use best management 

practices to address their specific

needs in producing canola.

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa), which 

do not have unacceptable 

impacts on soil quality.

Water Resources

The most important source of 

non-point source pollution is 

increased sedimentation from 

soil erosion, which can introduce

sediments, fertilizers, and 

pesticides to nearby lakes and 

streams. Glyphosate has a high 

affinity for binding with most 

types of soils, where it is 

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa), which 
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

degraded. This limits its mobility 

and transport into surface and 

groundwater.

do not have unacceptable 

impacts on water resources.

Air Quality

Agricultural activities such as 

tilling, harvesting, spraying 

pesticides, and fertilizing, 

including the emissions from 

farm equipment, can directly 

affect air quality. Applications 

may impact air quality from: 

drift; diffusion; volatilization of 

chemicals; exhaust emissions 

from motor vehicles and aircraft.

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa), which 

do not have unacceptable 

impacts on air quality.

Climate Change

Agriculture-related activities are 

direct sources of greenhouse

gases(e.g., exhaust from 

motorized equipment) and 

indirect sources (e.g., soil 

disturbance from tillage, fertilizer

production)

No change from No-action 

Alternative

Animal Communities

Invertebrates that feed on 

canola are typically considered 

pests and may be controlled by 

the use of insecticides or other 

production practices. Seed 

treatments are recommended to 

prevent flea beetle damage of 

young plants and foliar 

insecticide applications are 

recommended if damage 

reaches an economic threshold.

No change from No-action 

Alternative
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

Plant Communities

Plants growing in canola fields 

are considered weeds. Weeds 

can complete with growing 

canola plants for resources such 

as water, light, and soil 

nutrients. Young canola 

seedlings are very sensitive to 

early weed competition. 

Growers control weeds in and 

around fields using cultural, 

mechanical and chemical 

methods.

Canola can form feral 

populations.

Canola can hybridize with certain 

sexually compatible mustard 

plants.

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa). The 

changes in the effects on plant 

communities associated with 

the preferred alternative 

would be minimal, and could 

have an overall positive effect 

on reducing weed resistance 

when compared to the Noaction Alternative. 

Soil Microorganisms

APHIS has previously examined 

potential impacts of glyphosate 

on microorganisms in soils of 

field under cultivation with HR 

crops, and has not found 

evidence linking applications of 

glyphosate to changes in soil 

microbial communities that have 

adverse effects on plants grown 

in those soils.

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 

GR-crops (e.g., soybean, 

maize, cotton, alfalfa), which 

do not have unacceptable 

impacts on microorganisms.
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

Biological Diversity

HR crops, such as canola, have 

been correlated with an increase 

in conservation tillage in U.S. 

crop production, which 

promotes biodiversity by 

allowing the establishment of 

other plants, and the 

accumulation of more plant 

residue that increases soil 

organic matter, food, and cover 

for wildlife. Effects of GE crops 

have been associated with 

positive impacts on biodiversity 

because of increased yields, 

fewer applications of less toxic 

pesticides, and facilitation of 

conservation tillage.

No change from No-action 

Alternative

Land Use

Canola is minor crop produced 

on approximately 0.04% of the 

harvested cropland in the U.S. 

Currenttrendsinfluencing the 

acreage of canola planted annually 

are driven bymarket conditions

(e.g., increased demand for US

canola products and animal feed))

and Federal policy.

No change from No-action 

Alternative

Human and Animal Health

Risk to Human Health

Canola oil has one component 

(erucic acid) of human health 

significance because of its toxic 

properties. Varieties that 

produce oil with less than 2% of

this fatty acid are defined as 

canola, and are generally 

The approved in-crop 

glyphosate application rate for 

MON 88302 Canola will 

increase from the rate 

currently approved for other 

GR-canola varieties to the rate 

currently approved for other 
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

regarded as safe by FDA. 

Residues, such as that that might 

arise from the CP4 EPSPS protein 

are removed during filtration. 

Workers that routinely handle 

glyphosate, may be exposed 

during spray operations. 

Because of low acute toxicity of 

glyphosate, absence of evidence 

of carcinogenicity and other 

toxicological concerns, 

occupational exposure data is 

not required for reregistration. 

However, EPA has classified 

some glyphosate formulations as 

eye and skin irritants. When 

used consistent with the label, 

pesticides present minimal risk 

to human health and safety.

GR-crops (e.g., soybean, 

maize, cotton, alfalfa). 

Application at the higher rate 

does not pose any 

unacceptable risks to 

consumer health and worker 

safety when applied in 

accordance with the 

glyphosate registration label 

requirements approved by 

USEPA.

Risk to Animal Feed

Most canola cultivated in the 

U.S. is used to produce 

vegetable oil and animal feed. 

Canola-based animal feed is 

currently produced from GE 

canola varieties that are no 

longer subject to the 

regulatory requirements of 7 

CFR part 340 or the plant pest 

provisions of the PPA. This 

includes HR GE canola 

varieties.

No change from No-action 

Alternative

Socioeconomic 

Domestic Economic Environment

Farm income is positively

impacted by currently available 

HR canola by reducing

No change from No-action 

Alternative
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

production costs or increasing

revenues. GR canola generally

has a positive impact on farm

income due to costsavings from

reduced fuel and pesticide use.

Trade Economic Environment

Because the U.S. crushes more 

canola seed than it produces, 

the U.S. imports canola seed to 

meet the demand of the oil 

market. The U.S. exported 150-

300 thousand metric tons of 

canola each year between 2007 

and 2011. The majority of the 

canola exported went to 

Canada where it was processed. 

Foreign sales are mostly to 

Canadian crushing plants. The 

U.S. share of world production 

remains small, but is an 

increasingly important 

component of regional 

economies in the Northern 

Plains.

No change from No-action 

Alternative

Other Regulatory Approvals

U.S. FDA completed consultations.

No change from No-action 

Alternative.

Satisfied: consultations with 

other agencies participating in 

the Coordinated Regulatory 

Framework completed.

Compliance with Other Laws
Attribute/Measure Alternative A: No-Action

Alternative B: Determination 

of Nonregulated status

CWA, CAA, EOs

Fully compliant

No change from No-action 

Alternative:

Finding of No Significant Impact

The analysis in the EA indicates that there will not be a significant impact, individually or 

cumulatively, on the quality of the human environment as a result of this proposed action. I 

agree with this conclusion and therefore find that an EIS need not be prepared. This NEPA 

determination is based on the following context and intensity factors (40 CFR 1508.27).

Context - The term “context” recognizes potentially affected resources, as well as the location 

and setting in which the environmental impact would occur. This action has potential to affect 

conventional and organic canola production systems, including surrounding environments and 

agricultural workers; human food and animal feed production systems; foreign and domestic 

commodity markets. 

From 2003-2012, the average canola production in the U.S. has been about 1.1 million acres 

(USDA-NASS, 2012). According to the 2007 Census of agriculture North Dakota produced 

about 93% of all the canola grown in the U.S. In 2008, GE (glyphosate and glufosinate) HR

canola was estimated to be 95% of the U.S. canola crop (Brookes and Barfoot, 2010). In 2006, 

99% of the production in the principal U.S. canola-growing state of North Dakota was derived 

from HR-canola varieties, with GR varieties grown on 57% of that acreage (Johnson et al., 

2007). A determination of nonregulated status of MON 88302 Canola is not expected to 

directly cause an increase in agricultural acreage devoted to canola production, or those canola

acres devoted to GE canola cultivation. The availability of MON 88302 Canola will not change 

cultivation areas for canola production in the U.S., and there are no anticipated changes to the 

availability of GE and non-GE canola varieties on the market.

Intensity – Intensity is a measure of the degree or severity of an impact, and the following ten 

factors were considered and used as a basis for this decision:

1. Impacts that may be both beneficial and adverse. 

A determination of nonregulated status of MON 88302 Canola will have no significant 

environmental impact in relation to the availability of GE, conventional, and organic 

canola varieties. As discussed in Chapter 4 of the EA, a determination of nonregulated 

status of MON 88302 Canola is not expected to directly cause an increase in agricultural 
acreage devoted to canola production, or those canola acres devoted to GE canola

cultivation. The availability of MON 88302 Canola will not change the cultivation areas 

for canola production in the U.S., and there are no anticipated changes in the availability 

of GE and non-GE canola varieties on the market. A determination of nonregulated 

status of MON 88302 Canola would add another GE canola variety to the conventional 

canola market, but is not expected to change the market demands for GE canola or canola

produced using organic methods. The 2008 Census of Agriculture indicated that there 

were approximately 232 acres of organic canola grown in four states, with a value of 

about 0.03% of the total value of the canola crop in the same year (USDA-NASS, 2008). 

Based on the data provided by Monsanto for MON 88302 Canola (Monsanto, 2011), 

APHIS has concluded that the availability of MON 88302 Canola would not alter the 

agronomic practices, locations, and seed production and quality characteristics of 

conventional and GE canola seed production (USDA-APHIS, 2013). A determination of 

nonregulated status of MON 88302 Canola will not require a change in seed production 

practices, nor current production practices. The introduction MON 88302 Canola

provides an alternative canola variety with glyphosate resistance.

2. The degree to which the proposed action affects public health or safety. 

A determination of nonregulated status of MON 88302 Canola would have no significant 

impacts on human or animal health. Compositional tests conducted by the petitioner 

indicate that MON 88302 Canola is compositionally similar to other commercially 

available canola (Monsanto, 2011). Monsanto initiated the consultation process with 

FDA for the commercial distribution of MON 88302 Canola and submitted a safety and 

nutritional assessment of food and feed derived from MON 88302 Canola to the FDA in 

March 2011. Based on the information Monsanto submitted, and as of April 23, 2012, 

FDA has no further questions regarding MON 88302 Canola (US-FDA, 2012). Based on 

the FDA’s consultation, laboratory data and scientific literature provided by Monsanto

(Monsanto, 2011), and safety data available on other HR products, APHIS has concluded 

that MON 88302 Canola would have no significant impacts on human or animal health.

3. Unique characteristics of the geographic area such as proximity to historic or cultural 

resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically 

critical areas.

There are no unique characteristics of geographic areas such as park lands, prime farm 

lands, wetlands, wild and scenic areas, or ecologically critical areas that would be 

adversely impacted by a determination of nonregulated status of MON 88302 Canola. 

The common agricultural practices that would be carried out under the proposed action 

will not cause major ground disturbance; do not cause any physical destruction or 

damage to property, wildlife habitat, or landscapes; do not involve the sale, lease, or 

transfer of ownership of any property. This action is limited to a determination of 
nonregulated status of MON 88302 Canola. The product will be deployed on agricultural 

land currently suitable for production of canola, will replace existing varieties, and is not 

expected to increase the acreage of canola production. This action would not convert 

land to nonagricultural use and therefore would have no adverse impact on prime farm 

land. Standard agricultural practices for land preparation, planting, irrigation, and 

harvesting of plants would be used on agricultural lands planted to MON 88302 Canola

including the use of EPA-registered pesticides. Applicant’s adherence to EPA label use 

restrictions for all pesticides will mitigate potential impacts to the human environment. 

In the event of a determination of nonregulated status of MON 88302 Canola, the action 

is not likely to affect historic or cultural resources, park lands, prime farmlands, wetlands, 

wild and scenic rivers, or ecologically critical areas that may be in close proximity to 

canola production sites.

4. The degree to which the effects on the quality of the human environment are likely to be 

highly controversial.

The effects on the quality of the human environment from a determination of 

nonregulated status of MON 88302 Canola are not highly controversial. Although there 

is some opposition to a determination of nonregulated status of MON 88302 Canola, this 

action is not highly controversial in terms of size, nature or effect on the natural or 

physical environment. As discussed in Chapter 4 of the EA, a determination of 

nonregulated status is not expected to directly cause an increase in agricultural acreage 

devoted to canola production, or those acres devoted to GE-canola cultivation. The 

availability of MON 88302 Canola will not change cultivation areas for canola

production in the U.S., and there are no anticipated changes to the availability of GE- and 

non-GE-canola varieties on the market. A determination of nonregulated status of MON 

88302 Canola would add another GE-canola variety to the conventional canola market; it

is not expected to change the market demands for GE canola or canola produced using 

organic methods. MON 88302 Canola is currently registered by the EPA for breeding 

and seed increase activities. A determination of nonregulated status of MON 88302

Canola will not result in changes in the current practices of planting, tillage, fertilizer 

application/use, cultivation, pesticide application/use and volunteer control. Management 

practices and seed standards for production of certified canola seed would not change. 

The effect of MON 88302 Canola on wildlife or biodiversity is not different than that of 

other HR canola currently used in agriculture, or other GE or non-GE canola produced in 

conventional agriculture in the U.S. During the public comment period, APHIS received 

comments opposing a determination of nonregulated status of MON 88302 Canola. No 

new issues, alternatives or substantive new information were identified in any of the 

comments received by APHIS. APHIS has addressed substantive comments in the 

response to public comments document attached to this preliminary FONSI based on 

scientific evidence found in peer-reviewed, scholarly, and scientific journals.
5. The degree to which the possible effects on the human environment are highly uncertain 

or involve unique or unknown risks.

Based on the analysis documented in the EA, the possible effects on the human 

environment are well understood. The effects of the proposed activities are not highly 

uncertain and do not involve unique or unknown risks on the natural or physical 

environment. As discussed in Chapter 4 of the EA, a determination of nonregulated 

status of MON 88302 Canola is not expected to directly cause an increase in agricultural 

acreage devoted to canola production, or those acres devoted to GE-canola cultivation. A 

determination of nonregulated status of MON 88302 Canola will not result in changes in 

the current practices of planting, tillage, fertilizer application/use, and volunteer control. 

Management practices and seed standards for production of certified canola seed would 

not change. The effect of MON 88302 Canola on wildlife or biodiversity is no different 

than that from other HR crops currently used in agriculture, or other GE or non-GE 

canola produced in conventional agriculture in the U.S. As described in Chapter 2 of the 

EA, well-established management practices, production controls, and production 

practices for GE, conventional, and organic canola production are currently being used in 

canola cropping systems (i.e., commercial and seed production) in the U.S. Therefore, it 

is reasonable to assume that farmers, who produce GE, conventional non-GE, or organic 

canola crops will continue to implement these reasonable, commonly accepted best 

management practices for their chosen systems and varieties in agricultural canola

production. An additional consideration is that GE canola is planted on the majority of 

canola acres (95% of acreage in 2008) (Brookes and Barfoot, 2010). Based upon historic 

trends, conventional production practices that use GE varieties will likely continue to 

dominate in terms of acreage with or without a determination of nonregulated status of 

MON 88302 Canola. Given the extensive experience that APHIS, stakeholders, and 

growers have in implementing the use of GE-canola products, the possible effects to the 

human environment from the release of an additional GE-canola product are already well 

known and understood. Therefore, the impacts are not highly uncertain, and do not 

involve unique or unknown risks.

6. The degree to which the action may establish a precedent for future actions with 

significant effects or represents a decision in principle about a future consideration.

A determination of nonregulated status for MON 88302 Canola would not establish a 

precedent for future actions with significant effects or represent a decision in principle 

about a future decision. Similar to past regulatory requests reviewed and approved by 

APHIS, a determination of nonregulated status will be based on whether an organism is 

unlikely to pose a plant pest risk pursuant to the regulatory requirements of 7 CFR part 

340. Each petition that APHIS receives is specific to a particular GE organism and 

independently undergoes this review process to determine if the regulated article poses a 
plant pest risk. Under the authority of the plant pest provisions of the PPA , APHIS has 

issued regulations (7 CFR part 340) for the safe development and use of GE organisms. 

As required by 7 CFR 340.6, APHIS must respond to petitioners who request a 

determination of the regulated status of GE organisms, including GE plants such as MON 

88302 Canola. When a petition for nonregulated status is submitted, APHIS must make a 

determination about whether or not the GE organism poses a plant pest risk. If APHIS 

determines, based on its PPRA, that the GE organism is unlikely to pose a plant pest risk, 

it is no longer subject to the plant pest provisions of the PPA and 7 CFR part 340. 

APHIS regulations at 7 CFR part 340, which were promulgated pursuant to authority 

granted by the PPA, 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 PPA 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 enough 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 PPA or the regulations at 7 CFR part 340. 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.

7. Whether the action is related to other actions with individually insignificant but 

cumulatively significant impacts.

No significant cumulative effects were identified through this assessment. The EA 

discussed cumulative effects on canola management practices, human and animal health, 

and the environment and concluded that such impacts were not significant. A cumulative 

effects analysis is provided in Chapter 5 of the EA. In the event APHIS reaches a 

determination of nonregulated status of MON 88302 Canola, APHIS would no longer 

have regulatory authority over it. In the event of a determination of nonregulated status 

of MON 88302 Canola, APHIS has not identified any significant impact on the 

environment which may result from the incremental impact of a determination of 

nonregulated status of MON 88302 Canola when added to past, present, and reasonably 

foreseeable future actions.
8. The degree to which the action may adversely affect districts, sites, highways, structures, 

or objects listed in or eligible for listing in the National Register of Historic Places or 

may cause loss or destruction of significant scientific, cultural, or historic resources.

A determination of nonregulated status of MON 88302 Canola will not adversely impact 

cultural resources on tribal properties. Any farming activities that may be taken by 

farmers on tribal lands are only conducted at the tribe’s request. Thus, the tribes have 

control over any potential conflict with cultural resources on tribal properties. A 

determination of nonregulated status of MON 88302 Canola 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 they likely cause any loss or destruction 

of significant scientific, cultural, or historic resources. This action is limited to a 

determination of nonregulated status of MON 88302 Canola. Standard agricultural 

practices for land preparation, planting, irrigation, and harvesting of plants would be used 

on these agricultural lands including the use of EPA-registered pesticides. Adherence to 

EPA label use restrictions for all pesticides by the applicant will mitigate impacts to the 

human environment. A determination of nonregulated status of MON 88302 Canola is 

not an undertaking that may directly or indirectly cause alteration in the character or use 

of historic properties protected under the National Historic Preservation Act (NHPA). In 

general, common agricultural activities conducted under this action do not have the 

potential to introduce visual, atmospheric, or audible 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 audible effects on the use and enjoyment of a historic 

property when common agricultural practices, such as the operation of tractors and other 

mechanical equipment, are conducted close to such sites. An inherent mitigating factor 

for this issue is that use of these methods is transitory, so they have temporary effects on 

the audible nature of a site that can be ended at any time to restore the audible qualities of 

such sites to their original condition with no further adverse effects. Furthermore, these 

cultivation practices are already being conducted throughout the canola production 

regions. The cultivation of MON 88302 Canola would not inherently change any of 

these agronomic practices, qualitatively or quantitatively, so as to give rise to an impact

relevant to the NHPA.

9. The degree to which the action may adversely affect the endangered or threatened 

species or its habitat that has been determined to be critical under the Endangered 

Species Act of 1973.

As described in Chapter 4 of the EA, APHIS has analyzed the potential for effects from a 

determination of nonregulated status of MON 88302 Canola on federally listed 

threatened and endangered species (TES) and species proposed for listing, as well as 

designated critical habitat and habitat proposed for designation, as required under Section 

7 of the Endangered Species Act. After reviewing possible effects of a determination of 
nonregulated status of MON 88302 Canola, APHIS has concluded that a determination of 

nonregulated status of MON 88302 Canola would have no effect on federally listed TES 

and species proposed for listing, or on designated critical habitat or habitat proposed for 

designation.

10. Whether the action threatens a violation of Federal, State, or local law or requirements 

imposed for the protection of the environment.

The proposed action would be in compliance with all Federal, state, and local laws. 

Because the agency has concluded that MON 88302 Canola is unlikely to pose a plant 

pest risk, a determination of nonregulated status of MON 88302 Canola is a response that 

is consistent with the plant pest provisions of the PPA, regulations codified in 7 CFR part 

340, and the biotechnology regulatory policies in the Coordinated Framework. Monsanto

initiated the consultation process with FDA for the commercial distribution of MON 

88302 Canola and submitted a safety and nutritional assessment of food and feed derived 

from MON 88302 Canola to the FDA on March 23, 2011 (Monsanto, 2011). Based on 

the information Monsanto submitted, and as of April 23, 2012, FDA has no further 

questions regarding MON 88302 Canola (US-FDA, 2012). 

MON 88302 Canola is compositionally similar to currently marketed canola, with the

exception that it provides a product that can be treated with glyphosate at a higher 

application rate over a broader range of developmental stages than is currently

recommended and authorized. Monsanto submitted requests for amended labeling to the

U.S. EPA in February 2011 for EPA Registration Numbers 524-537 and 524-549, that

propose to modify the current use pattern of glyphosate for MON 88302 Canola 

(Monsanto, 2011). There are no other Federal, state, or local permits that are needed 

prior to the implementation of this action.

NEPA Decision and Rationale

I have carefully reviewed the EA prepared for this NEPA determination and the input from the 

public involvement process. I believe that the issues identified in the EA are best addressed by 

selecting Alternative 2: Determination that MON 88302 Canola is No Longer a Regulated 

Article. This alternative meets the APHIS purpose and need to allow the safe development and 

use of GE organisms consistent with the plant pest provisions of the PPA.

As stated in the CEQ regulations, “the agency’s preferred alternative is the alternative which the 

agency believes would fulfill its statutory mission and responsibilities, giving consideration to 

economic, environmental, technical and other factors.” The preferred alternative has been 

selected for implementation based on consideration of a number of environmental, regulatory, 

and social factors. Based upon our evaluation and analysis, Alternative 2 is selected because (1) 

it allows APHIS to fulfill its statutory mission to protect America’s agriculture and environment 

using a science-based regulatory framework that allows for the safe development and use of GE
organisms; (2) it allows APHIS to fulfill its regulatory obligations. As APHIS has not identified 

any plant pest risks associated with MON 88302 Canola, the continued regulated status of MON 

88302 Canola would be inconsistent with the plant pest provisions of the PPA, regulations 

codified at 7 CFR part 340, and the biotechnology regulatory policies in the Coordinated 

Framework. For the reasons stated above, I have determined that a determination of 

nonregulated status of MON 88302 Canola will not have any significant environmental effects.

_____________________________ ___________________

Michael C. Gregoire Date

Deputy Administrator

Biotechnology Regulatory Services
References

AOSCA. (2011). Programs and Services. Association of Official Seed Certifying Agencies. 

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Brookes, G., & Barfoot, P. (2010). GM Crops: Global Socio-Economic and Environmental 

Impacts 1996-2008 (pp. 165). PG Economics Ltd, United Kingdom.

Johnson, S.R., Strom, S., & Grillo, K. (2007) Quantification of the Impacts on US 

Agriculture of Biotechnology-Derived Crops Planted in 2006. (pp. 88). National Center for 

Food and Agricultural Policy, Washington, DC.

Monsanto. (2011). Monsanto Company Petition for Determination of Nonregulated Status 

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Table http://www.aphis.usda.gov/biotechnology/not_reg.html). 

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USDA-NASS. (2009). 2007 Census of Agriculture, United States, Summary and State Data

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from http://quickstats.nass.usda.gov/results/2904E4C8-C882-3F85-B141-1DF20129AFB4

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