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Independent Expert
David Shaw
Giles Distinguished Professor o f Weed Science a t Mississippi State University
Dr. David Shaw is Past-President of the Weed Science Society of America, chair of WSSA's S-71 Herbicide Resistance Education Committee and Vice President for Research and Economic Development at Mississippi State University. His past roles include chairing the task force developing the USDA-APHIS report on Herbicide Resistance Best Management Practices and Recommendations and chairing the Council for Agricultural Science and Technology task force on Impacts of Herbicide Resistant Weeds on Tillage Systems. Currently, Dr. Shaw is leading an effort to develop a comprehensive suite of educational materials on resistance management based on sound scientific principles.
From This Expert
Recently Answered Questions
Studies & Articles
Do GMOs contaminate the soil?
Posted On: Thursday, 8/01/2013 9:35 am
Answered By: David Shaw, Giles Distinguished Professor of Weed Science at Mississippi State University, Friday, 1/03/2014 6:24 pm
The short answer is no-- there is no impact of GM crops on soil. More specifically, this can be viewed from three perspectives: 1. The genetically modified crops themselves break down in exactly the same manner as non-GM crops. The genetic composition is organic in nature and is quickly broken down by the soil microbial community. The genes themselves are no different than the genes for flowering characteristics, seed production or chorophyll synthesis; they are simply DNA and all...
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From: Sent: To: Cc: Subject:
Wainwright, Heather Friday, August 30, 2013 2:50 PM suzanne.thom pson@ m onsanto.com ;tlneed@ m onsanto.com Hathcock, Beth;Hood, Tina Address fo r MSU Plant & Soil Sciences
Dear Suzanne and Teri,
Thank you fo r handling the several recent Service Order payments and unrestricted gifts fo r our faculty. We appreciate Monsanto's support o f th e ir research and Mississippi State University.
In order to ensure a safe and more expedient delivery o f these funds (recent checks have been misdirected from the mail to other departments and/or centers), the Department o f Plant & Soil Sciences (PSS) respectfully requests a change of address ONLY fo r the paym ents/gifts intended fo r our faculty members.
If possible, please send any future payments to PSS faculty to the follow ing address:
Mississippi State University Department o f Plant and Soil Sciences PO Box 9555 Mississippi State, MS 39762
PSS Faculty who have received support from Monsanto:
Service Orders Dr. Darrin Dodds Dr. Brien Henry Dr. Trent Irby Dr. Dan Reynolds
Unrestricted Gifts Dr. John Byrd Dr. Darrin Dodds Dr. Trent Irby Dr. Dan Reynolds Dr. David Shaw
If you have any questions or need additional inform ation, please do not hesitate to contact me.
Thanks, again, fo r the generous support o f the research and faculty at MSU.
Best regards, Heather
Heather Wainwnght
Contracts & Grants Specialist Plant & Soil Sciences http://www.pss.msstate.edu
1
Pest Management Science
Research Article
Benchm ark study on g lyph o sate-resista n t cro p p in g system s in the United States. Part 5: E ffe cts o f g ly p h o s a te -b a se d weed m anagem ent program s on farm-level profitability
Jason W VVeirich1-'. David R Shaw 1. Michel DK Owen2, Philip M Dixon2, Stephen C W eller3, Bryan G Young4. Robert G W ilson5 and David L Jordan5
Article first published online: 2 MAY 2011 DOI: 10.1002/ps.2177 Copyright 2011 Society of Chemical Industry
Issue
Pest Management Science
Volum e 67. Issue 7. pages 7 8 1 -7 8 4 July 2011
Additional Information (Show All) How to Cite Author Information Publication History ` This research was funded by Monsanto Company.
From: Sent: To: Subject: Attachments:
Jachetta, John <jjjachetta@ dow.com > Tuesday, January 17, 2012 5:27 PM Shaw, David It's Showtime for the enlist comments!!! Enlist Public Comment Communication.pdf; Comments on weed resistance 7.pdf
Hi David,
Looks like it's Showtime for the enlist comments!!!
The current deadline for comments to be submitted into the docket is Feb 27th- so it would be perfect if you were able to submit your comments by Feb 21-26thto ensure they received without processing issues. If an extension occurs, I'll notify you, but this is the working plan.
I cannot stress enough how important your effort is to the success of the Enlist comment periods. We really appreciate your contribution in helping to bring this technology forward.
I've included two items: 1. My cover letter which introduces and includes "how to submit" instructions: ( Enlist Public Comment Communication - attached) 2. Guidance for key topics to comment on and what you may consider including in your comments - if you wanted to add comments on the reduced probability of resistance to both modes of action in Enlist, that would be great too. These are your comments, so it's important to cover what you think is important!
As we approach the submission date, it would be great if you could confirm for me that your comments were submitted. Also, I'll be at the SW SS for a few days and then, of course, at the W SSA meeting and we can talk a bit more about this if you've got any questions.
I really appreciate your help with this, quality comments do take a bit of time to develop and I know very well how busy you are,; but this is important and they will listen to you.
Kind Regards,
John J. Jachetta, Ph.D. Regulatory Sciences and Government Affairs Leader Dow AgroSciences L.L.C.
Phone: (317) 337-4686 Fax: (317) 337-4649 E-mail: iiiachetta@dow.com1
1
Suggestions on providing comments to the United States Department of Agriculture (USDA) public docket on Dow AgroSciences' petition for a determination of non regulated status for EnlistTM corn and the associated plant pest risk assessment and environmental assessment (EA)
Individual comments should be independent with regards to both content and style. The following are intended only as general guidance for your consideration. Information about particular subject areas that are of interest to the agency regarding the EnlistTM W eed Control System about which you may be especially qualified to provide comments to the agency are discussed, along with some format suggestions that have proven to be useful when submitting comments to the Agency.
A s you prepare your comments and any supporting documentation, please remember all comments submitted to this docket are considered public information.
Topics of important interest to the Agency:
1. W eed resistance and weed resistance management - the issu e. The scope of glyphosate resistance and hard-to-control weeds. What is the level of the challenge and do you see it increasing, decreasing or remaining the sam e? High level aspects of weed management and herbicide management as part of an integrated management system. Specifically the value of mixtures to provide multiple modes of action and how this can be a tool in the program Your thoughts on the value of 2,4-D as one of the herbicide tools. 2,4-D mode of action and how it relates to resistance management Based on what we have seen historically, can it be an effective tool when used as part of an integrated weed resistance
Subject and format points to consider for inclusion in your comments:
The length of your letter will depend on what information you believe will be helpful to the agency. Remember that they are looking for credible, substantive comments. One paragraph opinion comments usually cannot cover the topic(s) adequately. Comments from 2-5 pages + any attached studies or articles are typical for quality comments
Write on your letterhead if possible Introductory address for USDA
RPR4S7Ptieav0Dgte0iu,orldRnAaatiPo3lverHAe,yr-IM0SAR3Don.8aa2dly0Us7i3sn7iat-n11d2138D8evelopment Docket ID APHIS-2010-0103
1. Reference the name of the docket and docket number
2. Introduce yourself: Describe your background and qualifications relevant to commenting on weed resistance management, Enlist W eed Control System TM with Colex-D TechnologyTM or 2,4-D. Such as: Your professional experience and current position Number of years working in your field of expertise Relevant research work or programs you have been involved with Degrees and any other relevant professional accreditations Participation in and any offices held in professional organizations, advisory boards, etc.
3. Share a concise, overall conclusion or summary statement regarding what the science says on the particular issue based on your evaluation, experience and interpretation. Especially useful to the Agency will be your thoughts on: State of the research for addressing the issues How the research relates to the real-world How the research relates to use of the Enlist W eed Control system.
4. D iscuss the key results or conclusions of the most important scientific research on this topic. Consider including: Statement of what was done in the study Key results
o Summation statement o Concise compilation of key data if it adds value to the understanding of
results How these results relate to real-world situations How the particular study relates to other research on the topic such as:
o Supports conclusions of other studies o Further refines understanding or conclusion o Offers new interpretation or result
If you are referring to a published article (scientific or even popular) or have any articles you feel would be useful to the Agency, you should include them as an attachment with your comment. Although a copy of the article is always easiest for the Agency and ensures they include it the record, if you cannot provide the article, include a full reference citation.
5. Especially useful to the Agency is references to newer studies or studies which may be in progress which may not have been considered in their review. Rem em ber the docket is public, but even if you are able to generalize what you are finding in your new or ongoing research that can be useful.
6. The Agency will often be faced with conflicting studies or research opinions, so your thoughts on studies or claims that you feel are not scientifically valid or not relevant to real world conditions, would help provide perspective.
7. Any additional personal observations and real-world insights you may have made during your own research or experiences
8. Re-statement of your expert opinion or conclusion specifically regarding the decision the Agency is considering
9. C lose using your signature (original or scanned signature if possible)
TMCdsaiorlEeenn.ctltriioEsotlnn,SlsEi.ysnstltDi2es0mtu1Do2huiasDov,noeoawnntodyAteCgytreoroetlSegrxecis-ciDeteenirvcTeeededscfhLroenLrgoCsulaollagetyoorrayrueaspetrpaardsoevpmaalrastr;koasfptophfreoDEvoanwllsisAatrgWerpoeeSencddieCinnogcn.etsrToLhlLeSCyin.sftCeomormm. aAptoilownneanpytsrseroseefantdhteeadnEdisnflnoisoltltoWawneloeadfbfeelr for
Additional information:
Also, if you are interested in reading the A P H IS Environmental Assessm ent, you can access and printout a copy of all the materials from www.regulations.gov using that same docket number (click on listing of documents entitled "Dow AgroScience LLC; Availability of Petition, Plant Pest Risk Assessment, and Environmental Assessm ent for Determination of Nonregulated Status of Corn Genetically Engineered for Herbicide Tolerance" on the left hand-side of that page).
To assist you if there are particular aspects of interest to you, below is some general guidance of which sections of the EA may be applicable
W eed Resistance: Sections 2.2.2.3, 4.2.2, Value of no- and minimum tillage Sections 2.2.2.1, 2.3, 2.4.4, 2.7, 4.2.2, 4.3, 4.4 Auxin or 2,4-D resistance potential - potential for superweeds: Sections 4.4.2, 4.4.4, Practical aspects of Enlist system (ease of use, value to growers, etc): Sections 4.1,
4.2.2, 4.3.2, 4.3.3, 4.4.4, 4.7, Use of 2,4-D / lbs applied: Sections 2.6, 4.2.2, 4.4.2 Co-existence:
- With non-GMOs: Sections 2.2.5, 4.2.5, 4.3.3, 4.4.5 - With organics : Sections 2.2.4, 4.2.4, 4.3.3, 4.4.5 - With sensitive crops: Sections 4.3.3, 2,4-D: Sections 5.5
From: Sent: To: Subject: Attachments:
Shaw, David Monday, February 20, 2012 11:08 AM Jachetta, John Enlist Letter EPA Letter Enlist.docx
John, Here's what I have so far. Take a look and give me feedback. David1
1
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From: Sent: To: Subject:
Shaw, David Monday, February 20, 2012 3:43 PM Jachetta, John RE: Enlist Letter
You are buttering me up for something now :)
>>> "Jachetta, John" <iiiachetta@dow.com> 2/20/2012 2:33 PM >>>
David,
This is just perfect! It both reinforces the acute nature of the need and that multiple modes-of-action and new tools are critical to the management of this problem; I thought that you hit the target dead-center!
In fact, it's so perfect that I'm wondering if you would consider cc'ing Tom Vilsack, Secretary of the U S D A ? If that works for you, I'll dig up the contact information.
Thanks!
John J. Jachetta, Ph.D. Regulatory Sciences and Government Affairs Leader Dow AgroSciences LLC
From: David Shaw rmailto:DShaw@research.msstate.edu1 Sent: Monday, February 20, 2012 11:08 AM To: Jachetta, John Subject: Enlist Letter
John, Here's what I have so far. Take a look and give me feedback. David
i
From: Sent: To: Subject:
Shaw, David Wednesday, February 29, 2012 9:35 AM jjjachetta@ dow .com Re: emails fo r David Shaw
I'd be happy to. I would like some guidance on how to explain why it is being sent.
>>> "Jachetta, John" <iiiachetta@dow.com> 2/29/2012 8:30:51 AM >>> Hi David
Like I mentioned yesterday, the guys at home really liked your comments to the Enlist docket! They've asked me if you'd be willing to also send your comments to this whole list of folks below. It's OK to say no to some or all of this list if you want, it's a long list!
Kind Regards,
John J. Jachetta, Ph.D. Regulatory Sciences and Government Affairs Leader Dow AgroSciences LLC
From: Oliver, George (GR) Sent: Tuesday, February 28, 2012 8:24 AM To: Jachetta, John Subject: emails for David Shaw
John, David Shaw 's comments to the docket were excellent. Do you think he would be willing to send them to the following (identified by Constance and Brad)
Secretary Tom Vilsack - agsec@usda.gov Deputy Under Secretary Rebecca Blue - rebecca.blue@osec.usda.gov Administrator Gregory Parham - gregory.1.parham@aphis.usda.gov Deputy Administrator Michael Gregoire - Michael.C.Gregoire@ aphis.usda.gov
i
From: Sent: To: Subject: Attachments:
Shaw, David Monday, July 30, 2012 5:00 PM MILLS, ANTHONY (AG/1000) Re: Public Comment Period - Dicamba Support IMAGE.jpeg
Got it. I'll be happy to write a letter for this. David
>>> "MILLS, ANTHONY (AG/1000)" <anthony.mills@monsanto.com> 7/30/2012 3:53 PM >>> David,
Sorry I missed your call. Hope things are going well fo r you and your fam ily.
Thanks fo r agreeing to w rite a support le tte r fo r Dicamba. The attached flye r has th e details including the docket num ber and w ebsite fo r subm itting online if you choose to do so.
I know you will w rite about several of the benefits associated w ith Dicamba technology but we would like you to specifically m ention the fo llo w in g in your letter:
Sustainability: RR2 Xtend soybean system will enable im plem entation of weed resistance mgmt practices to delay/prevent resistance to glyphosate, dicamba and im portant soybean herbicides________________
Low potential for resistance to develop to dicamba or the evolution of weeds with multiple resistance (add references to support low potential for auxin). Dicamba used in a herbicide program with glyphosate and soil residuals
If you have questions let me know. Thanks again fo r your support.
Anthony Mills, Ph.D. Technology Development Representative anthony.mills@monsanto.com (662) 719-5258 - cell (901) 854-9998 - FAX
1
Product Examples New Low Volatility Formulation Nozzle (Droplet) Wind Speed Boom Height
Buffer
Drift Reduction Agent Gallons Per Acre Tank Clean Out Ground Speed Sensitive Crop Registries Weed Timing Weed Resistant Management
^
Spray < 4" weeds Use residual herbicides visit RoundupReadyPLUS.com
**Monsanto will not authorize the use of any herbicide product containing the active ingredients in final form dimethylamine salt (DMA) of dicamba and/or dicamba acid in the Roundup Ready Xtend Crop System.
Monsanto Company is a member of Excellence Through Stewardship(ETS). Monsanto products are commercialized in accordance with ETS Product Launch Stewardship Guidance, and in compliance with Monsanto's Policy for Commercialization of Biotechnology-Derived Plant Products in Commodity Crops. Commercial product(s) has been approved for import into key export markets with functioning regulatory systems. Any crop or material produced from this product can only be exported to, or used, processed or sold in countries where all necessary regulatory approvals have been granted. It is a violation of national and international law to move material containing biotech traits across boundaries into nations where import is not permitted. Growers should talk to their grain handler or product purchaser to confirm their buying position for this product. Excellence Through Stewardship is a registered trademark of Biotechnology Industry Organization.
Commercialization is dependent on multiple factors, including successful conclusion of the regulatory process. Monsanto's dicamba tolerant soybean product is currently in Phase IV of Monsanto's R&D pipeline. Dicamba formulations and premixes discussed herein are in various phases of development in Monsanto's R&D pipeline. Dicamba is not currently registered for over the top use on soybeans. It is a violation of federal law to use a pesticide in a manner inconsistent with its label.
Roundup Technologyincludes Monsanto's glyphosate-based herbicide technologies.
Individual results may vary, and performance may vary from location to location and from year to year. This result may not be an indicator of results you may obtain as local growing, soil and weather conditions may vary. Growers should evaluate data from multiple locations and years whenever possible.
ALWAYS READ AND FOLLOW PESTICIDE LABEL DIRECTIONS. Roundup Readycrops contain genes that confer tolerance to glyphosate, the active ingredient in Roundup brand agricultural herbicides. Roundup brand agricultural herbicides will kill crops that are not tolerant to glyphosate. Genuity and Design, Genuity Icons, Genuity, Monsanto and Vine Design, Roundup Ready 2 Yield, Roundup ReadyPLUSTM, Roundup Ready, Roundup Technology, Roundup WeatherMAX, and Roundup are trademarks of Monsanto Technology LLC. All other trademarks are the property of their respective owners. 2012 Monsanto Company.
Anticipated application requirements pending final label approval. This information is current as of July 2012.
July 2012
ROUNDUP READY 2 XTEND
Designed to provide more consistent, flexible control of weeds, especially -manage and glyphosate-resistant weeds, to maximize crop yield potential
advanced system from Roundup Ready PLUSTM Weed Management Solutions coming soon, pending regulatory approval.
Designed to:
> Xtend your control of resistant and tough wee with a dual-mode-of-action herbicide
Xtend your potential with the Roundup Re 2 Xtend soybean trait
> Xtend your application and planting flexibility with this innovative system
Broaden weed control with Roundup Xtend for Roundup Ready Xtend crops
Xtend your window for post applications and realize enhanced residual benefits
"Applicators have the tools & responsibility to manage drift. The Roundup Ready Xtend Crop System is developed around application methods proven to increase on target application."
Dr. Robert E. Wolf, Application Technology Specialist, Consultant and Professor Emeritus at Kansas State University
A ir Induction
Turbo TeeJet Induction
Use nozzles and operating pressures that produce
coarse/ultra coarse droplets to minimize drift
Spray weeds less than
4 inches tall
Maintain the required label buffer to protect sensitive areas
Make sure ground
speed is less than 15 mph
Use low volatility formulations such as Roundup Xtend
and XtendiMax
Al ays read and follo label directions
Pending R egulatory A pproval
Use triple rinse tank clean-out procedure
Maintain boom height 2 0 inches above crop
canopy <
Apply when wind speed is between
3-10 mph
July 2012
SUPPORT FARMERS' CHOICE TO ACCESS NEW TECHNOLOGIES
WEIGH IN ON ROUNDUP READY 2 XTEND SOYBEANS
KW
YOUR ACTION IS NEEDED
As a member of the U.S. agricultural community, it is very important that you weigh in with the U.S. Department of Agriculture (USDA) on giving farmers the choice to plant soybeans developed to tolerate dicamba.
When commercialized, the dicamba tolerance trait will be combined with Roundup Ready 2 Yield to form Roundup Ready 2 Xtend Soybeans. This technology is designed to provide greater flexibility, simplicity and crop safety in controlling tough weeds and maximize yield opportunity.
The USDA is now accepting public comments on Monsanto's petition to deregulate dicamba-tolerant soybeans (event MON87708). These comments will help determine if farmers will have the choice to use this new technology that meets an important need in weed control options for soybean farmers.
IT'S CRITICAL FOR YOU TO BE HEARD
Farmers should have the choice to use safe and valuable new agricultural technologies to increase yields and keep theirfarms profitable.
Farmers need multiple mode-of-action weed management tools. Dicamba tolerance would be a valuable addition to the existing soybean weed control options to maximize yield potential.
Dicamba has been used in crops for many decades in the U.S. and continues to be effective on major broadleaf weeds.
The availability of new and effective soybean production tools is vital to maintaining the health of sectors beyond the farm, including the U.S. soybean processing and feed industries and the growing U.S. soybean export markets.
Farmers have proven they are able to use different application techniques and equipment for different types of pesticides to ensure proper performance of the product as well as on target application. These include, but are not limited to, application techniques, equipment settings, nozzle selection and consideration of environmental conditions during application, such as wind speed.
It is important that USDA follow through on its commitment to U.S. farmers to conduct timely, science-based reviews of new technologies, such as dicambatolerant soybeans. This is necessary to support innovation and access to technology that keeps U.S. agriculture productive, sustainable and globally competitive.
MONSANTO
SUBMIT YOUR COMMENT
YOUR INPUT MATTERS
The USDA considers public input in the decision-making process. Supportive letters are
important to be sure regulators understand the various perspectives from rural America
and agricultural industries. We also anticipate these comments will play a valuable role in
countering the campaigns waged by groups and individuals who are in vocal opposition
to biotech. Letters should be unique as the USDA counts multiple form letters as a
single comment. You can review Monsanto's petition to USDA to deregulate soybeans
(event MON87708) at http://www.aphis.usda.gov/brs/aphisdocs/10_18801p.pdf.
i
>Y
~ JKk.
ONLINE INSTRUCTIONS
You can develop an online comment at: www.roundupreadyplus.com/supportdicamba
Complete the form provided on the Submit a Comment page: http://www.regulations.gov/#!sub mitComment;D=APHIS-2012-0047-0001
You can type in your comment, but you are limited to 2,000 characters.
If you have a longer comment, you can attach it as a file.
Be sure to preview your comment for accuracy.
Once you have completed the form, typed or attached your comment, and reviewed it, you are ready to submit your comment.
MAILING INSTRUCTIONS
Submit your comment on your farm, organization or company letterhead.
Be sure to state the docket number in the subject line - Docket No. APHIS-2012-0047.
Please mail your letter before September 3, 2012 to be sure it arrives in time to be considered.
The deadline for all comments to be received by USDA is September 11,2012.
Mail your letter to: Docket No. A P H IS -2 0 1 2 -0 0 4 7 Regulatory Analysis and Development PPD, APHIS, Station 3 A -0 3 .8 4700 River Road Unit 118 Riverdale, MD 20737-1238
BE SURE TO INCLUDE:
Your name.
Your city, state and country.
A date within the public comment period - between July 13 and September 11,2012 (or September 3, if mailing the comment).
Please state that your comment refers to Docket No. APHIS-2012-0047.
Sample comment:
"I su p p o rt full d ereg u latio n of
dicam ba-tolerant soybeans
b e c a u s e th e y w ill__ "
Monsanto Company is a member of Excellence Through Stewardship (ETS). Monsanto products are commercialized in accordance with ETS Product Launch Stewardship Guidance, and in compliance with Monsanto's Policy for Commercialization of Biotechnology-Derived Plant Products in Commodity Crops. This product has not yet been approved for import into key export markets with functioning regulatory systems and is not available for sale. Once available, any crop or material produced from this product can only be exported to, or used, processed or sold in countries where all necessary regulatory approvals have been granted. It is a violation of national and international law to move material containing biotech traits across boundaries into nations where import is not permitted. At such time as the product is for sale, growers should talk to their grain handler or product purchaser to confirm their buying position for this product. Excellence Through Stewardship is a registered trademark of Biotechnology Industry Organization.
Commercialization is dependent on multiple factors, including successful conclusion of the regulatory process. The information presented herein is provided for educational purposes only, and is not and shall not be construed as an offer to sell, or a recommendation to use, any unregistered pesticide for any purpose whatsoever. It is a violation of federal law to promote or offer to sell an unregistered pesticide.
Individual results may vary, and performance may vary from location to location and from year to year. This result may not be an indicator of results you may obtain as local growing, soil and weather conditions may vary. Growers should evaluate data from multiple locations and years whenever possible.
ALWAYS READ AND FOLLOW PESTICIDE LABEL DIRECTIONS. Roundup Ready crops contain genes that confer tolerance to glyphosate, the active ingredient in Roundup brand agricultural herbicides. Roundup brand agricultural herbicides will kill crops that are not tolerant to glyphosate. Tank mixtures: The applicable labeling for each product must be in the possession of the user at the time of application. Follow applicable use instructions, including application rates, precautions and restrictions of each product used in the tank mixture. Monsanto has not tested all tank mix product formulations for compatibility or performance other than specifically listed by brand name. Always predetermine the compatibility of tank mixtures by mixing small proportional quantities in advance. Genuity and Design, Genuity Icons, Roundup Ready 2 Yield, Roundup Ready PLUSTM, Roundup Ready, and Roundup are trademarks of Monsanto Technology LLC. Banvel and Clarity are trademarks of BASF Corporation. All other trademarks are the property of their respective owners.
2012 Monsanto Company
From: Sent: To: Subject:
MD <MDSwarn@dow.com> Tuesday, August 14, 2012 1:29 PM Shaw, David;Jachetta, John RE: Enlist Soybean Comments
M r. Shaw,
Thank you fo r your Com m ent Letter regarding Enlist 2,4-D Tolerant Soybeans. Your comments have been subm itted to th e USDA on your behalf. And as John and I m entioned previously, your le tte r was very well w ritte n and we at Dow AgroSciences appreciate you taking tim e to prepare it.
Michele D. SwarnKindest Regards,
Sr. Office Professional Global Biotech RSGA Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268
317-337-4383 (Business) 317-337-4649 (Fax) E l mdswarn@dow.com
aC O N F I D E N T I A L I T Y N O T IC E : T h is e-m ail m essage (including all tta c h m e n ts ) fro m Dow A g ro S c ie n c e s LLC is f o r th e so le use o f th e intended
recipient(s). Any unauthorized review , use, d isclo su re o r d istrib u tio n is s t r ic t ly proh ibited. I f you are not th e intended re cip ie n t, please co n ta ct the sender by reply e-m ail and d e s tro y all copies o f th e original message and any attachm ents.
Learn more about Dow AgroSciences at:
From: David Shaw [mailto:DShaw@research.msstate.edu1 Sent: Tuesday, August 14, 2012 12:31 PM To: Jachetta, John; Swarn, Michele (MD) Subject: RE: Enlist Soybean Comments
Thanks, Michele. I appreciate your assistance.
1
David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 617 Allen Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
>>> "Swarn, Michele (MD)" <MDSwarn@dow.com> 8/14/2012 9:54 AM >>>
John, I w ill subm it com m ents fo r Mr. Shaw to both dockets on his behalf. And yes, I agree it was a great le tter!
Michele D. Swarn
Sr. Office Professional Global Biotech RSGA Dow AgroSciences LLC 9330 Zionsville Road Indianapolis, IN 46268
317-337-4383 (Business) 317-337-4649 (Fax) E l mdswarn@dow.com
aC O N F I D E N T I A L I T Y N O T IC E : T h is e-m ail m essage (including all tta c h m e n ts ) fro m Dow A g ro S c ie n c e s LLC is f o r th e so le use o f th e intended
recipient(s). Any unauthorized review , use, d isclo su re o r d istrib u tio n is s t r ic t ly proh ibited. I f you are not th e intended re cip ie n t, please co n ta ct the sender by reply e-m ail and d e s tro y all copies o f th e original message and any attachm ents.
Learn more about Dow AgroSciences at:
From: Jachetta, John Sent: Tuesday, August 14, 2012 10:46 AM To: David Shaw (dshaw@research.msstate.edu) Cc: Swarn, Michele (MD) Subject: RE: Enlist Soybean Comments
Hi David,
2
Just a quick question... did you submit your letter to the docket already or did you want us to submit it on your behalf? This was a really great letter!
Thanks again!
John J. Jachetta, Ph.D. Regulatory Sciences and Government Affairs Leader Dow AgroSciences LLC
From: Jachetta, John Sent: Tuesday, August 14, 2012 10:30 AM To: 'David Shaw'; Swarn, Michele (MD) Subject: RE: Enlist Soybean Comments
Hi David A very well crafted strong-and-to-the point letter! Thanks David, great job just as I expected! You remain my hero! Kind Regards,
John J. Jachetta, Ph.D. Regulatory Sciences and Government Affairs Leader Dow AgroSciences LLC
From: David Shaw rmailto:DShaw@research.msstate.edu1 Sent: Monday, August 13, 2012 7:35 PM To: Swarn, Michele (MD) Cc: Jachetta, John; David Shaw Subject: Enlist Soybean Comments
Attached is my letter for submission to EPA as comments on the Enlist soybean technology. Best regards, David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 617 Allen Hall
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From: Sent: To: Subject: Attachments:
AG/1000 <john.k.soteres@ monsanto.com> Friday, May 24, 2013 4:08 PM Shaw, David Dicamba EIS Dicamba EIS_AcademicGroup Letter.docx
David, thanks so much fo r agreeing to w o rk on this. It is certainly im portant to M onsanto th a t dicamba to le ra n t crops be approved as quickly as possible but I tru ly believe it also critically im portant to crop production in this country.
Attached is a really rough beginnings o f a letter. The underlined parts are the key concepts I wanted to include. I wanted to get this out to you now since you are leaving in th e morning.
Have a safe trip and ta lk to you when you get back.
John
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From: Sent: To: Cc: Subject: Attachments:
AG/1000 <john.k.soteres@ monsanto.com> Tuesday, May 28, 2013 10:33 AM _mdowen@iastate.edu_ Shaw, David Dicamba EIS Dicamba EIS_Academic Group Letter.docx
Mike, do you have tim e fo r a call this afternoon? I w ould like to ask your help in organizing a le tte r to be subm itted during th e dicamba EIS com m ent period. I talked to David S. about this last Friday before he le ft fo r India and w ould like to discuss the same w ith you. W ith David I discussed the possibility o f getting a statem ent fro m WSSA and asking his help in facilita tin g a le tte r signed by m ultiple academics speaking to some o f the key points th a t those opposed to dicamba, 2,4D or any o th e r biotech derived herbicide to le ra n t technology have raised. I w anted to ask you and David to help w ith the latter. Getting som ething fro m WSSA w ould be m ore general than th e group le tte r I envision. I also recognize th a t the WSSA angle is very much a long shot.
Attached are my thoughts on issues th a t could be covered in a group letter. If you are at all interested and feel com fortable helping w ith this let's discuss which of these points could and which should not be included in such a letter. This letter, o f course, w ould be w ritte n in the words you and David feel com fortable w ith. I provide prose since it is the easiest way fo r me to provide my thoughts on which issues w ould be most im portant to cover w ith USDA. Right now USDA hears a lo t fro m the anti's but not as much fro m others. They are also well organized.
Well, w ould you have some tim e to ta lk about this? I am open any tim e between 1 and 3 PM and again fro m 4 to 5 PM.
Thanks, John
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Academic Group Letter_dicamba EIS_USDA NOI comment period_first draft
To: USDA APHIS From: (15-25 leading weed scientists or WSSA)
We the undersigned offer the follow ing comments regarding the de-regulation of dicamba tolerant soybean and cotton and th e associated use of dicamba in a diversified weed management program.
Using th e tools o f biotechnology to transform a crop which allows the safe use o f a herbicide norm ally lethal to the crop is an im p o rta n t technology to provided new weed management tools to farm ers in order to most effectively manage weeds fo r the purposes of optim izing yields and economics, m itigate th e potential fo r herbicide resistance ,and to preserve environm ental benefits th a t herbicides o ffe r in th e fo rm o f facilita tin g th e use o f conservation tillage practices. The evolution and spread o f weed populations resistant to one or m ore herbicides used in soybeans and cotton is a significant th re a t to fu tu re p roductivity in these crops and to th e continued grow th o f conservation tillage practices. We are managing the situation today fo r glyphosate resistant weeds but in so doing significant selection pressure is being put on certain chemistries (i.e. PPO, HPPD and glufosinate) th a t are effective against th e key broadleaf species w ith widespread resistance to glyphosate and ALS chemistries (i.e. Amarathus spp., and Conyza spp.). We need more herbicide options to manage these species and to preserve the u tility o f the rem aining options. The ability to safely use dicamba in both soybeans and cotton, in part, fills this need. Dicamba is effective on th e subject weeds, provides com plem entary postemergence activity to glyphosate on all key broadleaf weeds, adds to the consistency o f residual control o f other residual herbicides th a t w ould be used in th e system and w ill have an excellent safety profile due to the inserted gene. The ability to use dicamba as part o f a diversified weed management programs is not ju st a nice to have but rather is a m ust have. There are no new modes of action on the horizon and we m ust have m ore options fo r which biotechnology can provide options th a t fill critical holes. There is also a tim in g com ponent th a t USDA must consider. For dicamba to be most effective in filling this critical need, we need it w ith o u t any undue delay and, indeed, w ould ask th a t it's review be expedited. We can't afford to w ait fo r resistance to evolve and fu rth e r spread to our existing herbicide options before offering this tool to farmers. Delayed launch o f dicamba could decrease the options and thus the ability fo r farm ers to com bine dicamba w ith o ther herbicides in way to deliver m ultiple modes o f action effective on key targeted weeds. This w ould negatively im pact the ability to m itigate potential evolution of resistance to dicamba.
The myriad o f factors driving th e evolution of herbicide resistant weeds in crop production make its managem ent incredibly complex. W eed resistance management is a function o f managing the practices and the herbicides available fo r weed management in a particular crop. As such it is not a plant biotechnology issue. Likewise, weed management is ultim ately th e responsibility o f farm ers and farm advisors and require th a t the weed science com m unity, including industry, academics, crop com m odity groups and others who reach out to farmers, im plem ent robust and effective stewardship programs espousing the basic principles of good weed management and encouraging adoption o f these practices. By so doing resistance to our herbicide resources and new options such as dicamba w ill be minimized. Also it should be noted th a t resistance to dicamba represents no m ore a th re a t to ag production than resistance to o th e r critical herbicides and th e likelihood th a t it w ill be used in a manner consistent w ith
Academic Group Letter_dicamba EIS_USDA NOI comment period_first draft
best m anagement practices is good. Research indicates th a t dicamba best fits in a fu lly diversified program and such a program is particularly im portant when glyphosate resistant palm er pigweed and waterhem p are the targets. Stacking dicamba tolerance w ith th a t o f glyphosate, glufosinate, and other herbicide to le ra n t tra its w ill fu rth e r facilitate th e use of dicamba in a diversified program. Stacking herbicide traits does not in itself prom ote the evolution of resistance to m ore than one herbicides since ju st as fo r individual herbicides the evolution o f resistance is a function o f how the herbicides are used rather than a function o f the selectivity of the crop to m ultiple herbicides.
The ability o f farm ers to use dicamba in diversified weed management programs in soybeans and cotton is not expected to significantly change current farm ing practices. It w ill provide a valuable new postemergence option th a t w ill allow farm ers to most effectively manage th e ir weeds in conservation tillage practices even in th e presence o f glyphosate resistant populations. Farmers have clearly shown a preference fo r postemergence weed control in conservation tillage systems and dicamba be an im portant part o f this system.
In closing we urge USDA to expedite th e necessary reviews leading to final approval of dicamba to le ra n t soybeans and cotton. In the area o f weed management we must have new herbicides or new/expanded uses o f existing herbicides in order to m itigate resistance and thus to m eet our current and fu tu re crop production needs. Dicamba is not th e only answer to th e issues we face but it is an im portant one.
From: Sent: To: Subject:
AG/1000 <john.k.soteres@ monsanto.com> Thursday, May 30, 2013 8:17 AM Shaw, David;Owen, Micheal D [AGRON] dicamba EIS
W ould you guys have 15 to 30 m inutes on Wednesday June 5th fo r a call to discuss the current situation around a possible WSSA response and th e possibility o f still organizing a group le tte r during the present USDA com m ent period. I am open to any tim e th a t would w ork fo r you.
I w ant to thank you both o f helping on this. It is certainly im portant to M onsanto but also to fu rth e r developm ent of new herbicide options and the speed w ith which these options become available.
John
From: Sent: To: Cc: Subject: Attachments:
AG/1000 <john.k.soteres@ monsanto.com> Thursday, June 06, 2013 3:30 PM Owen, Micheal D [AGRON] Shaw, David Dicamba EIS Freese letter to EPA 2012.pdf; Jaffe Letter-to-EPA-Feb-4.pdf; food and water watch 0320.pdf; J Egan Penn State DTS USDA.pdf; Mortensen et al. 2012. Navigatinga critical juncture for sustainable weed management(2).pdf
Mike, attached are 5 significant public letters/papers presented by those opposed to dicamba (auxin) tolerant crops. I highlighted sections in each and summarize some o f th e main points in each as follow s. There are a few other negative letters but they do not deal specifically w ith herbicide use/resistance.
I hope this helps your efforts. I look forw a rd to hearing your perspective after reviewing this material. Also, as you continue to develop your outline please keep in mind there are a fe w issues specific to USDA's Notice th a t I included as suggested topics, i.e. im pact o f use o f dicamba on current farm ing practices.
John
Food and W ater W atch le tte r to APHIS, Sept 11, 2012 Urged USDA to conduct EIS "Herbicide resistant crops w ill continue to spur weed resistance." In short HT crops are the problem . "Approving the corps in th e USDA pipeline w ill only worsen this problem ." In general, it appears th e ir argum ent is th a t these new herbicide approvals are "n o t sustainable solutions to the problem of resistant weeds"....
Egan le tte r to USDA, 2012 Urged USDA to conduct EIS Dicamba crops w ill lead to overuse of dicamba and outbreak of auxin resistant weeds. Urge delay in deregulation until policy fo r regulation and management o f herbicide resistance has been developed. Use o f DT soybeans "w ill th w a rt th e evolution o f sustainable integrated weed management systems". Use o f DT crops w ill "encourage simple, non-integrated weed management s y ste m s.".
Freese le tte r to EPA, 2013 "HR crops systems prom ote m ore rapid evolution o f resistant weeds than do o ther (non-HR crop) uses of the pertinent herbicides." "It is highly doubtfu l w hether any voluntary stewardship plan fo r DT cotton w ould be effective in forestalling weed resistance to dicamba." In general, Freese 's approach was to dispute all M onsanto claims. Calls fo r m andatory weed resistance plans. HR crops do not drive increased use o f conservation tillage systems M onsanto and Dow are falsely hyping auxin to le ra n t crops as solutions
Jaffe Letter to EPA, 2012 Overall, Jaffe argued fo r mandated regulations W ith o u t EPA involvem ent farm ers are not likely to carry o u t integrated weed management
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M ortensen e t al, paper published 2012 Argues th a t m ultiple resistance is likely w ith stacked HT crops. Argues fo r regulatory mandated herbicide use restrictions.
2
From: Sent: To: Cc: Subject:
Shaw, David Friday, June 21, 2013 2:21 AM john.k.sote re s@ m onsa nto.com m dow en@ iastate.edu;rhonda.m .m annion@ m onsanto.com Re: USDA Virtual meetings on dicamba/2,4-D EIS
John, I w ill call in to the firs t one.
David R. Shaw Vice President fo r Research and Economic Development Mississippi State University 662-325-3570 dshaw @ research.m sstate.edu
On Jun 20, 2013, at 2:56 PM, "SOTERES, JOHN K (AG/1000)" <ohn.k.soteres@ m onsanto.com > w rote:
David/M ike, another ask fo r help....
USDA is setting up tw o virtual meetings to solicit verbal input on the dicamba and 2,4 D EISs. Our Regulatory Affairs and G overnm ent Affairs groups feel it is im portant th a t USDA hear from folks like you on th e key issues since th e re is a high probability th a t many negative voices w ill be heard during these calls. Your voice not only count fro m the standpoint of presenting scientifically based view points but also to a degree fro m a numbers standpoint. We feel th a t Vilsack and his management team are paying as much a tte n tio n to th e optics o f this as to the technical issues / merits. In a way this boils down to a numbers game which means we can't just sit back and let the opposition dom inate the conversation. Thus another request fo r help.
W ould one or both o f you be available fo r one of these calls and o ffe r comments along th e lines o f the talking points I had sent earlier (or ones you feel com fortable making)?
I summarize the main points to consider offering as follow s; (1) im portance o f dicamba and, in general, biotech solutions (single tra it and stacked) to address the growing needs relative to herbicide resistance in the US, (2) the need fo r USDA to act expeditiously to provide these tools fo r managing resistance, (3) resistance is not a plant biotech issue but rather a herbicide issues, and (4) need fo r dicamba to preserve the gains made in expanding use o f conservation tillage. In addition to these, th a t we had previously discussed, please also consider offering points about the risk o f resistance to dicamba. Possible talking points here could include; (1) because o f th e activity of dicamba it w ill most often be used in weed management systems th a t include other herbicides (residual and postemergence) th a t have com plem entary and overlapping activity, (2) past history indicates th a t probability fo r presence of resistance alleles in m ost weed species is low and (3) th e com bination o f these tw o factors suggests th a t the risk o f resistance is low w ith o u t im plying th a t the risk is non existence.
I hate to keep asking fo r your tim e on this stu ff but it is im portant to not only these technologies but to an overall e ffo rt to educate USDA on the issues. Call in inform ation is provided by Rhonda below. If you
1
d o n 't feel com fortable doing this or have conflicts please let me know. Either way I / we appreciate your involvem ent in o th e r ways.
Thanks fo r your consideration of this.
John
From: MANNION, RHONDA M [AG/1000] Sent: Wednesday, June 19, 2013 4:58 PM To: SOTERES, JOHN K [AG/1000] Subject: USDA Virtual meetings on dicamba/2,4-D EIS
John,
The inform ation on the virtual meetings fo r th e Dicamba/2,4-D NOI can be found using the below link. There are tw o meetings options to choose from :
June 26 7-9pm ET June 27 4-6 pm ET
APHIS has only done one o th e r virtual meeting, cold to le ra n t eucalyptus, and the virtual meeting was held open only fo r an hour due to lack o f activity. Plus I believe they do a query at the beginning on who wishes to com m ent so need to be on the call at the start.
You can register directly through th e website, it's very easy. It requires you to download M icrosoft Office Live m eeting but it is free.
http://www.aphisvirtualm eetings.com /participate.htm l
Rhonda
Biotech Regulatory Affairs Manager Monsanto Company Telephone: 314-694-8785 Mobile: 314-452-0475
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2
From: Sent: To: Cc: Subject:
AG/1000 <john.k.soteres@ monsanto.com> Wednesday, June 26, 2013 9:20 PM Shaw, David mdowen@iastate.edu RE: Dicamba EIS call
So p re tty much a non-event. I th in k I owe you a really good steak fo r this one. Mike, I bet you can't w a it fo r to m o rro w 's call. W ell, at least it w ill be a really short call.
Thanks David, John
From: David Shaw [mailto:DShaw@research.msstate.edul Sent: Wednesday, June 26, 2013 8:08 PM To: SOTERES, JOHN K [AG/1000] Cc: mdowen@iastate.edu Subject: Re: Dicamba EIS call
Interesting, somewhat. Two people spoke before I did, and both were growers. The first read a prepared statem ent that he obviously d id n 't w rite. The second was on th e board fo r th e soybean association. Both w ere strongly in favor o f the technology. I was the th ird speaker. A fter a long period of silence the firs t speaker came back on and said a few more things. A fter listening to music fo r another 30 minutes I got off.
David R. Shaw Vice President fo r Research and Economic Development Mississippi State University 662-325-3570 dshaw @ research.m sstate.edu
On Jun 26, 2013, at 7:38 PM, "SOTERES, JOHN K (AG/1000)" <iohn.k.soteres@ m onsanto.com > w rote:
David, how did th e USDA call go to n ig h t. I could not call in. Anything interesting?
Thanks again fo r doing this.
John
btiiTaosmlehlsrmiratesertceictecedae-ticimilvavhyetaemepidslleryuomon.chntPhesilslbyifesniraatbofesgyomdeer.pmdmaeenaralsyteyiootsencnesoi.rtvneIaefntanrtysiidont,luehpdahrriavdvildeergrievecedesiavonerdda/ontrhyicsootenh-femirdaeminletiidnailae.irnrOofotrh,rmeprlaeutaisoseeno,nfaotnthidfisyiseth-inmeteasnieldnbdeyderytoou AMlol nes-amnatoil,sianncdluadtitnagchitms ents sent and received are subject to monitoring, reading and archival by
1
From! SACHS, ERIC S (AG/1000) <ric,s.Bachs@monsarto.com>
Sent time; oS/OS/2013 12:06:46 AM
Prabhu Pengali (plp39@coraoll.edu) <plp39@comdl.edu>; Nicholai Kfllaitzandonakes(Kalait2flndonakeaN@missouri.odu) ^ ^ <KalaitzandonakcsN@missomi.edu>; David Shaw (DShaw@research.nustaio.edu) <DShaw@research,nujtatc.edu>; Roger Beachy
<rbeachy@hiology2.wustl.odu>; Jume, Calealoui <caloatousjuma@harvard.edu>; Carl E. Pray <pray@AESOP.Rutgers.edu>; Phillips, Peter <peler.phillipi@usajk.ca>; Folta, Kevin M.; Tony Shelton <ami5@cornell.edu> C SACHS, ERIC S (AG/IOOO) <eric.i.iachs@monsanto.com>; Beth Anne Mumfbrd <bethannem@cmabuildstniit.com>
Subject: Invitation to Author a Policy Briofin tho Sories "Perspectives on Science Matters"
All, As some of you know based on Initial contacts, I have started an important project to produce a series of short policy briefs on important topics in the agricultural biotechnology arena called "Perspectives on Science Matters." Based on initial feedback, I decided to reach out to all of you collectively. I understand and appreciate that you need me to be completely transparent and I am keenly aware that your Independence and reputations must be protected. I hope after reviewing this message you will support thi
vision and agree to author one of the briefs. Prospective authors and topics are listed below.
Individually and collectively the topics were selected because of their Influence on public policy, GM crop regulation and consumer acceptance. The specific goal Is to frame some of the Important Issues facing biotechnology with reasoned thoughtful messages in a way that helps thought leaders and Influence to better appreciate the growing body of knowledge available on the safety and benefits of GM crops. The broader goal is to elevate the public dialogue and public policy discussion from its current over-emphasis on perceived risks toward a broader understanding of the societal benefits of GM crops and needed improvement In policies that are unnecessarily limiting innovation In the biotechnology arena.
I am convinced that this Initiative to publish and promote seven policy briefs on agricultural biotechnology will spark new opportunities for outreach and engagement with policy makers and consumers. The key to success Is participation by all of you - recognized experts and leaders with the knowledge, reputation and communication experience needed to communicate authoritatively to the target groups. You represent ai elite group whose credibility will be strengthened by working together. Naturally, If you would like to add a co-author that Is entirely up to you and welcome.
To ensure that the policy briefs have the greatest Impact, the American Council for Science & Health is partnering with CMA Consulting to drive the project. The completed policy briefs will be offered on the ACSH web site. The series of briefs as envisioned will facilitate policy maker engagement and serve as a basis for supplemental knowledge mobilization to a range of audiences. Both ACSH and CMA have expertise to leverage experts, knowledge and key messages to serve the project goals. CMA Consulting wl manage the process of producing the policy briefs. This Is an important element because Monsanto wants the authors to communicate freely without Involvement by Monsanto. As the process develops, CMA and ACSH will coordinate web site posting and promotion. CMA and ACSH also will merchandize the policy briefs, including development of media-specific materials, such as op-eds, blog postings, speaking
engagements, events, webinars, etc. The briefs will cover a range of Important topics and themes. Some background is included below but this is only a suggestion. As the author, you will know how to best approach the topic and are free to do so In
your own way.
Meeting World Challenges
Carl Pray and Prabhu Pengali
Background: Explore the ways In which the use of GM crops and foods can help to address many of the world's most pressing challenges and Improve the global standard of living today and for future generations. Specifically, discuss how GM technology helps address key policy concerns, such as shrinking agricultural resources (land, water), food security, food affordability and environmental sustainability. In addition, provide an overview of the challenges inherent in farming and how GM technology addresses these challenges by providing farmers with beneficial tools for on-farm management.
Stifling Innovation
Peter Phillips
Background: Discuss how over burdensome regulation of GM crops and food stifles the Innovatli
and technological advancements important for helping support global food security and improve
overall quality of life. Consider the limitations to innovation and advancements in GM technology
that results from a regulatory process that dismisses positive scientific conclusions and assumes
molecular modification techniques carry a higher risk than other techniques used to generate new
crop varieties.
Holding Activists Accountable
Kevin Folta
Background: Demonstrate how activlstsnessages and tactics regarding Genetically Modified
(GM) crops and plant biotechnology undermine worldwide efforts to ensure a safe, nutritious,
plentiful and affordable food supply using responsible and sustainable agricultural practices.
Provide examples of activist campaigns that spread false information that goes unchallenged and
results In further erosion of the public's confidence In agricultural innovation. Detail how the
Impact of these efforts If not challenged ultimately would limit consumer choice, Increase food
prices, decrease farmer viability, and undermine global food security.
GM Crop Safety
Roger Beachy
Background: Address consumer and policy-maker concerns that GM crops and foods are not
adequately tested for safety compared to other crop and food products approved for human
consumption. Explain early GM crop evaluation, event selection, equivalence characterization and
product safety assessment through each step of development and regulatory assessment; and
detail how this comprehensive process meets the same stringent scientific and regulatory
standards developed for other crop and food products.
Consequences ofRejecting GM Crops
Calestous Juma
Background: Explore the issues and consequences within both developed and developing countries
that lead to rejection of or barriers to adoption of GM crop and food technology at the farmer,
consumer and regulatory level. Understand the combination of issues; including consumer and
political resistance, food safety and public health fears, concerns about biodiversity and biological
safety, restrictive regulation, and lack of information (or existence of misinformation) about
Intellectual property rights that create barriers to GM acceptance. Detail the consequences,
Including Impacts on yield, household income, food security and social impacts, as well as on
pesticide use, health risks from pesticide exposure and on biodiversity that result.
Sustainable Crop Systems
Tony Shelton and David Shaw
Background: Detail how GM crop technology provides farmers with safe, efficient and effective
tools to manage crop pests (Insects/weeds/dlsease), delivers environmental benefits, increases
yields and Improves productivity. Specifically discuss the use of GM crops containing herbicide
tolerant (HT) and Insect resistance (IR) traits and the risk versus benefit of their use. In addition,
detail how educational outreach and a focus on responsible use can address public concerns about
plant resistance and the envlronmental/eco-system Impacts of GM crop technology.
Responsible Choice
?
Background: Explore the competing issues inherent in crop production used for food versus crop
production used for fuel and highlight the role GM crop technology can play In ensuring we can
adequately increase production and balance our needs for food, feed, fiber and fuel.
Your role would be to write a short brief aimed at a broad audience, Including academics, opinion leaders, policy-makers, regulators and other Influences. Each brief should be about 4-6 pages In length and Include key themes and messages related to the specific topic, recommendations, and a call to action. The briefs will serve as the foundation for further outreach and engagement to extended audiences and the broader public via supplemental media platforms, Including allied organizations web sites, blogs and social media. Be assured that nothing will ever be distributed under your authorship unless you have approved the contents and use in its entirety.
I have copied Beth A nne M u m fo rd of C M A (w w w .c m a b u lld tru st.c o m ) because she and h er colleagues that have been w o rk in g on th is Initiative. Please fe e l fre e to co n ta ct Beth A n ne If you co n tin u e to have questions. O f course you can co nta ct me as w e ll b u t I need to step aside so th a t I doh co m p rom ise the project.
This w ill be an Im portant project and Is designed to lead to Increased engagem ent on critical topics th a t are barriers to broader use and acceptance of G M crops globally. You are the best possible messengers and I hope you w ill m ake tim e to participate,
W arm Regards,
Eric
Eric Sachs Regulatory Policy & Scientific Affairs Desk: (314) 694-1709 Mobile: (314) 637-7650 Uric.S.SiidWinnpnsmilo.com
Trtaisoemlthlrcriimeacseittcevteleadye-icmidvaphetarmoeoinsllehyulmnyi.cbthPesbitslyeifesnrdaaopf.sgomeeerrmsdmaoenanaltyesiyotseencen.orittvnIitefatlarneysiddon,uhpahrriadvvildeergrievecedesiavonerdda/onthryicsootenh-femirdameinletidinailae.irnrOofotrh,remprlaeutaisoseneo,nfaotnhtdii_fsyiset-himnetaesineldnbedyderytooubeis AMsttM"hruValiobolnsinnsrseeuissm-d-asammieninatsatttaro"eoiiiled,l,sosioarb.nalryncoToaldnthounhgerdyaeitarwrntacea"gticccttMahoihipctmmashiiltempswenanseatntunrsoyebt.if"ssne,itgdhniitasarenie-dms,raeaiccleciiesvpestdoslnealroyelrsiaeubsbpijleoitcnytsitfobolremafononyritdcoahrmiencagkg,ienregcaafduoisnregtdhaebnypdraeansrceyhnsicuveaclhofbcyode
*rom: David Shaw <DShaw@research.msslale,edu> Sent time: 08/09/2013 10:59:21 PM
Prabhu Pengali (plp39@comelI.edu) <plp39@cornell.edu>; Nicholas Kalaitzandonakes(KalaitzandonakesN@misscmri.edu) ^ <KalaitzandonakesN@missouri.edu>; Carl E. Pray <pray@AESOP.Rutgcrs.edu>; Roger Beachy <rbcachy@biology2.wustledu>; Tony Shelton
<ams5@corncll.cdu>; Calestous' 'Juma <calestous_juma@harvard.edu>; ERJC S (AG/1000) SACHS <eric.s.sachs@monsanto.com>; Folta, Kevin M.; Peter' 'Phillips <pctcr.phillips@usask.ca> ^ c: Beth Anne Mumford <bethannem@cmabuildstrust.com> Subject: Re: invitation to Author a Policy Brief in the Series "Perspectives on Science Matters"
Thanks for organizing this, Eric. I'm definitely interested. David
DVMBMaF6dn6sAoaiiihdc2sxvsXae/ssiE3w6iid:Pssc23@ssrRo546iienpp-.36rs3oppei2Sd5msii/he3e7SSiaan20cwttrt5aacDtf-theeo8e.,r0vUmM2Rens8lesoSivtspaeemt3ares9re.ice7nthdy6tu2
> "SACHS, ERIC S (AG/1000)" <eric.s.sachs@monsanto.com> 8/7/2013 11:06 PM >
All, As som e of you know based on initial contacts, I have started an Im portant project to produce a series of sh o rt p o licy b rie fs on im p o rta n t to p ics in th e a g ricu ltu ra l b io te c h n o lo g y a rena called "P e rsp e ctiv e s on Science M atte rs." Based on in itial feedback, I d e cid e d to reach ou t to all o f you co llectively. I u nd e rsta n d and appreciate that you need me to be com pletely transparent and I am keenly aw are that your in dependence and rep u tation s m ust be protected. I hope after review ing th is m essage you w ill su pp o rt t h visio n and agree to a u th o r on e of the briefs. P rosp ective authors and to p ics are listed below .
Individually and co lle ctively th e topics w ere selected because o f th e ir influence on public policy, G M crop re g u la tio n a n d c o n s u m e r a c c e p ta n c e . T h e s p e c ific g o a l Is to fra m e s o m e o f th e Im p o rta n t is s u e s fa c in g b io te ch n o lo g y w ith reason ed th ou g htfu l m essages in a w ay th a t helps th o u g h t leaders and in flu e n ce rs to better appreciate th e grow ing body of know ledge available on the safety and benefits of G M crops. The b ro a d e r g oal Is to e le v a te th e p u b lic d ia lo g u e and p u b lic p o lic y d is cu s s io n fro m its cu rre n t o v e r-e m p h a s is on perceived risks to w a rd a broad er understanding of th e societal benefits o f G M crops and needed im p ro v e m e n t in p o lic ie s th a t are u nn e ce ssa rily lim itin g Innovation in th e b io te ch n o lo g y arena.
I am convinced th a t th is in itiative to publish and p rom o te seven policy briefs on agricultural b iotech nology w ill spark new o p p o rtu n itie s fo r outreach and engagem ent w ith policy m akers and consum ers. The key to su cce ss is p a rtic ip a tio n b y all o f y o u - re co g n ize d e x p e rts and le a d e rs w ith th e k n o w le d g e , re p u ta tio n and co m m un icatio n e xp erien ce needed to co m m un icate a u th o rita tive ly to th e targ et groups. You rep resent ai elite group w hose cre d ib ility w ill be strengthened by w orking together. N aturally, if you w ould like to add a c o -a u th o r th a t is e n tire ly up to you and w e lc o m e .
T o e n s u re th a t th e p o lic y b rie fs h ave th e g re a te s t im p a ct, th e A m e ric a n C o u n c il fo r S cie n ce & H e a lth is partnering w ith C M A C onsulting to drive the project. The co m p leted policy briefs w ill be offered on the ACSH w eb site. The series o f briefs as envisioned w ill facilitate policy m aker engagem ent and serve as a basis fo r su p p le m e n ta l kno w led g e m o b ilization to a range o f audiences. Both ACSH and C M A have exp e rtise to leverage experts, kno w ledge and key m essages to serve th e p roje ct goals. C M A C o nsu ltin g wi m anage th e p roce ss o f p ro d u c in g th e p o licy b riefs. T his is an im p o rta n t e le m e n t because M o n s a n to w a n ts
-- GMO --
BEYOND
THE SCIENCE
GMOs and Global Food Security
David Zilberman | December 18,2014 | University of California Berkeley
GMO Safety and Regulations
Alan McHughen December 16,2014 | University of California
Economic Consequences of Regulations of GM Crops
Peter W.B. Phillips | December 11,2014 | University o f Saskatchewan
Global Risks of Rejecting Agricultural Biotechnology
Calestousjuma | December 9,2014 | Harvard Kennedy School
Anti-GMO Activism and Its Impact on Food Security
Kevin Folta | December 4, 2014 | University o f Florida
TGoreleernanGteanneds:ISnussetcatinRaebsiilsittaynAt Cdvroapnstages of Herbicide
Anthony Shelton & David Shaw | December 2, 2014 | Cornell University Mississippi State University
oMo
IEE YSCOIENNC
GSceineentciec Literacy Project Special Report: GMO: Beyond the
Jon Entine | December 2, 2014 | Genetic Literacy Project
Browse t A uthors Sources
or try our A
From: Sent: To: Subject: Attachments:
Shaw, David Monday, June 15, 2015 12:40 PM W alton, Larry (L) RE: USDA Comment Period fo r Enlist Cotton Traits EPA Letter Dicamba 2015.docx
Well, duh. Sorry about th a t - w orking on it w ith one th o u g h t in mind, meaning th e other! Here's the revised letter. Do you want me to submit or do you want to?
David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: W alton, Larry (L) [mailto:LW alton@ dow.com1 Sent: Sunday, June 14, 2015 6:33 AM To: Shaw, David Subject: RE: USDA Comment Period fo r Enlist Cotton Traits
Thanks so much fo r your le tte r David. One com m ent th a t I do have is to switch dicamba to 2,4-D to le ra n t (Enlist cotton traits) soybeans and cotton. You m ention dicamba a few tim es in paragraphs under BMP. Since this is a com m ent period fo r Enlist Traits, this w ould be very beneficial.
Thanks again David.
From: Shaw, David [mailto:DShaw@research.msstate.edu1 Sent: Saturday, June 13, 2015 1:29 PM To: Walton, Larry (L) Cc: Shaw, David Subject: RE: USDA Comment Period for Enlist Cotton Traits
Larry,
Take a look at the attached and let me know w hat you think.
David
David R. Shaw, Vice President Research and Economic Development Mississippi State University
1
3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: W alton, Larry (L) [m ailto:LW alton@ dow .com 1 Sent: Thursday, June 11, 2015 5:14 AM To: Shaw, David Subject: USDA Comment Period fo r Enlist Cotton Traits
Hi David, First let me ask you if are planning on attending the MAIC this year? We have an all star line o f speakers in including our own President o f MSU, M ark Keenum! We also have M eredith Laws from EPA who w ill be speaking also in addition to several m ore th a t I w ill not m ention at this tim e. We have w orked extrem ely hard to make th e MAIC "bigger and b e tte r" each year. In addition, we are providing some very good scholarship funding through our endow m ent funds fo r some to p MSU grad and undergraduate students. Please try to make it if you can and bring your fam ily.
The MS. roundtable also continues to grow each year as well. I still rem em ber th e day I was sitting next to you at the MS. roundtable and m entioned 2,4-D to le ra n t cotton th a t Dow was working on. I th in k a couple at th e meeting almost fell out of th e ir chairs.
David, WE are getting very close to commercial registration and I w ould appreciate if you could take tim e o u t of your busy schedule and send your comments about this new technology and w hat it means to cotton farmers during this com m ent period. The USDA's re c o m m e n d a tio n to d e re g u la te th e Enlist C o tto n T ra it was released fo r public co m m e n t. The com m ents th a t you su b m itte d last year concerning corn and soybeans was gre a tly a p p re c ia te d .
The c o m m e n t p e rio d w ill close on June 29, 2015. I have a tta c h e d is a gu id a n ce d o c u m e n t d e s c rib in g h o w to
s u b m it co m m e n ts and th e fe d e ra l re siste r a n n o u n cin g th e USDA's decision.
A tta c h e d to th is e -m a il yo u w ill fin d th e PDF o f th e in fo rm a tio n pub lish e d in th e Federal Register. I have also attached a w ord docum ent th a t w ill provide guidance on su b m ittin g com m ents w ith step by step instruction. If you have any questions, please do n o t hesitate to give me a call.
Best Regards,
Larry W alton D ow AgroSciences 662-213-4872
2
From: Sent: To: Subject:
Shaw, David Tuesday, June 16, 2015 12:20 PM W alton, Larry (L) Re: Your Comment Submitted on Regulations.gov (ID: APHIS-2013-0113-0196)
I will very much look forward to the stories from this year's adventure.... DVM66aiic2sve-si3idPs2sRr5iep.-s3piS5dih7eSan0wttatfeorURneivseerasricthy and Economic Development dshaw@research.msstate.edu On Jun 16, 2015, at 11:18 AM, Walton, Larry (L) <LWalton@dow.com> wrote:
W ill do David, During the to u r the past 4 to 8 years I have observed 2 th a t actually fell in th e flooded rice paddy, one th a t got overheated, one th a t stepped on a small alligator, one th a t a cottonm outh snake struck at him and h it his rice boot, and one fem ale th a t lost a very expensive wedding ring! I should have to purchase a ticke t fo r this to u r because it is so much fu n !!!!!
From: Shaw, David [mailto:DShaw@research.msstate.edu1 Sent: Tuesday, June 16, 2015 11:12 AM To: Walton, Larry (L) Subject: RE: Your Comment Submitted on Reaulations.aov (ID: APHIS-2013-0113-0196)
You HAVE to send me a picture o f Darla in amongst the mud and snakes!
David R. Shaw, Vice President Research and Economic Development Mississippi State University 3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: W alton, Larry (L) [m ailto:LW alton@ dow .com 1 Sent: Tuesday, June 16, 2015 10:55 AM To: Shaw, David Subject: RE: Your Comment Subm itted on Regulations.gov (ID: APHIS-2013-0113-0196)
Thanks so much David, I can't thank you enough. I hope to see you soon. On a side note, I w ill see "ole" Huffy w ife next week Darla on our annual rice weed to u r. Can't w ait to see her and those "Indy" folks in the rice fields fighting snakes and mosquitoes. I w ill have my camera ready to take a few photos. It's always fun to see this group and I th in k it w ill be Darla's 1st official rice tour.
1
Take care David
From: Shaw, David [mailto:DShaw@research.msstate.edu1 Sent: Tuesday, June 16, 2015 10:33 AM To: Walton, Larry (L) Subject: Fwd: Your Comment Submitted on Reaulations.gov (ID: APHIS-2013-0113-0196)
Done!
David R. Shaw V ice President for Research and Econom ic Development M ississip pi State University 662-325-3570 dshaw@research.msstate.edu
Begin forwarded message:
From Date:
: Regulations.gov <no-reply@ regula
June 16, 2015 at 10:32:02 A M C D T
tion
s.g
ov>
To: <dshaw@research.msstate.edu>
Subject: Your Comment Submitted on Regulations.gov (ID: APHIS-2013
0113-0196)
Pthlaeat sceandnoontoatcrceeppltyintocothmisinmgeesmsaagile.. This email isfrom a notification only address
Your comment was submitted successfully! Comment Tracking Number: 1jz-8jgf-4apw Your comment may be viewable on Regulations.gov once the agency has reviewed it. This process is dependent on agency public submission policies/procedures and processing times. Use your tracking number to find out the status of your comment. Agency: Anim al and Plant Health Inspection Service (APH IS) Document Type: Nonrulemaking Title: Environmental Assessments; A vailab ility, etc.: D ow AgroSciences L L C ;
Cotton Genetically Engineered for Resistance to 2,4-D and Glufosinate
Document ID: APHIS-2013-0113-0196 Comment:
Please see attached letter.
Uploaded File(s):
. E P A Letter 24-D 2015.pdf
2
This information will appear on Regulations.gov: First Name: David LCCStaioatsuytten:NtMorayrmi:PsUserio:snvsSiiitnhpecapdewi:SStMatatSetes This information will not appear on Regulations.gov: MZEmIaPia/lPiilnoAgstdAadldrCdesroesd:sesd::s33h90a70w61@2LreeeseHaarcllh,.Mmsissstaistsei.pedpui State University Fploerasfue rvtihsietrhitntpfo:/r/mwwatwio.nregaubloautitotnhse.gRove/g#u!lfaatqiso.ns.gov commenting process,
3
From: Sent: To: Cc: Subject: Attachments:
Shaw, David Saturday, June 13, 2015 2:29 PM W alton, Larry (L) Shaw, David RE: USDA Comment Period fo r Enlist Cotton Traits EPA Letter Dicamba 2015.docx
Larry, Take a look at the attached and let me know w hat you think. David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: W alton, Larry (L) [mailto:LW alton@ dow.com1 Sent: Thursday, June 11, 2015 5:14 AM To: Shaw, David Subject: USDA Comment Period fo r Enlist Cotton Traits
Hi David, First let me ask you if are planning on attending the MAIC this year? We have an all star line o f speakers in including our own President o f MSU, M ark Keenum! We also have M eredith Laws from EPA who w ill be speaking also in addition to several m ore th a t I w ill not m ention at this tim e. We have w orked extrem ely hard to make th e MAIC "bigger and b e tte r" each year. In addition, we are providing some very good scholarship funding through our endow m ent funds fo r some to p MSU grad and undergraduate students. Please try to make it if you can and bring your fam ily.
The MS. roundtable also continues to grow each year as well. I still rem em ber th e day I was sitting next to you at the MS. roundtable and m entioned 2,4-D to le ra n t cotton th a t Dow was working on. I th in k a couple at th e meeting almost fell out of th e ir chairs.
David, WE are getting very close to commercial registration and I w ould appreciate if you could take tim e o u t of your busy schedule and send your comments about this new technology and w hat it means to cotton farmers during this com m ent period. The USDA's re c o m m e n d a tio n to d e re g u la te th e Enlist C o tto n T ra it was released fo r public co m m e n t. The com m ents th a t you su b m itte d last year concerning corn and soybeans was gre a tly a p p re c ia te d .
The c o m m e n t p e rio d w ill close on June 29, 2015. I have a tta c h e d is a gu id a n ce d o c u m e n t d e s c rib in g h o w to
s u b m it co m m e n ts and th e fe d e ra l re siste r a n n o u n cin g th e USDA's decision.
1
A tta c h e d to th is e -m a il y o u w ill fin d th e PDF o f th e in fo rm a tio n pub lish e d in th e Federal Register. I have also attached a w ord docum ent th a t w ill provide guidance on su b m ittin g com m ents w ith step by step instruction. If you have any questions, please do n o t hesitate to give me a call. Best Regards, Larry W alton D ow AgroSciences 662-213-4872
2
From: To: Subject: Date:
W alton, Larry (L) Shaw. David RE: USDA C om m ent Period fo r Enlist C otton T ra its M o nd a y, Ju ne 15, 2 015 1 :3 8 :1 6 PM
Looks great David, please go ahead and submit and I would appreciate. Thanks again and travel safely
From: Shaw, David [mailto:DShaw@research.msstate.edu] Sent: Monday, June 15, 2015 11:40 AM To: Walton, Larry (L) Subject: RE: USDA Comment Period for Enlist Cotton Traits
Well, duh. Sorry about that - working on it with one thought in mind, meaning the other! Here's the revised letter. Do you want me to submit or do you want to?
David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: Walton, Larry (L) [mailto:LWalton@dow.coml Sent: Sunday, June 14, 2015 6:33 AM To: Shaw, David Subj'ect: RE: USDA Comment Period for Enlist Cotton Traits
Thanks so much for your letter David. One comment that I do have is to switch dicamba to 2,4-D tolerant (Enlist cotton traits) soybeans and cotton. You mention dicamba a few times in paragraphs under BMP. Since this is a comment period for Enlist Traits, this would be very beneficial.
Thanks again David.
From: Shaw, David [mailto:DShaw@research.msstate.edu] Sent: Saturday, June 13, 2015 1:29 PM To: Walton, Larry (L) Cc: Shaw, David Subject: RE: USDA Comment Period for Enlist Cotton Traits
Larry,
Take a look at the attached and let me know what you think.
David
David R. Shaw, Vice President Research and Economic Development Mississippi State University 3001 Lee Hall Mississippi State, MS 39762 662/325-3570 Fax: 662/325-8028 dshaw@research.msstate.edu
From: Walton, Larry (L) [mailto:LWalton@dow.coml Sent: Thursday, June 11, 2015 5:14 AM To: Shaw, David Subject: USDA Comment Period for Enlist Cotton Traits
Hi David, First let me ask you if are planning on attending the MAIC this year? We have an all star line of speakers in including our own President of MSU, Mark Keenum! We also have Meredith Laws from EPA who will be speaking also in addition to several more that I will not mention at this time. We have worked extremely hard to make the MAIC "bigger and better" each year. In addition, we are providing some very good scholarship funding through our endowment funds for some top MSU grad and undergraduate students. Please try to make it if you can and bring your family.
The MS. roundtable also continues to grow each year as well. I still remember the day I was sitting next to you at the MS. roundtable and mentioned 2,4-D tolerant cotton that Dow was working on. I think a couple at the meeting almost fell out of their chairs.
David, WE are getting very close to commercial registration and I would appreciate if you could take time out of your busy schedule and send your comments about this new technology and what it means to cotton farmers during this comment period. The USDA's recommendation to deregulate the Enlist Cotton Trait was released for public comment. The comments that you submitted last year concerning corn and soybeans was greatly appreciated.
The comment period will close on June 29, 2015. I have attached is a guidance document describing how to submit comments and the federal resister announcing the USDA's decision.
Attached to this e-mail you will find the PDF of the inform ation published in the Federal Register. I have also attached a word document that will provide guidance on subm itting comments with step by step instruction. If you have any questions, please do not hesitate to give me a call.
Best Regards,
Larry Walton Dow AgroSciences 662-213-4872