PUBLIC SUBMISSION

As of: February 16, 2009
Tracking No. 80829a3f
Comments Due: February 06, 2009

Docket: APHIS-2008-0094
Pioneer Hi-Bred International, Inc.; Availability of Petition and Environmental Assessment for Determination of Nonregulated Status for Corn Genetically Engineered for Tolerance to Glyphosate and Acetolactate Synthase-inhibiting Herbicides

Comment On: APHIS-2008-0094-0001
Pioneer Hi-Bred International, Inc.; Availability of Petition and Environmental Assessment for Determination of Nonregulated Status for Corn Genetically Engineered for Tolerance to Glyphosate and Acetolactate Synthase-Inhibiting Herbicides

Document: APHIS-2008-0094-0010
Comment from Bill Chase, South Dakota Corn Growers Association


Submitter Information

Name: Bill  Chase
Address:

20372 395 Ave,  SD, 

Organization: South Dakota Corn Growers Association

General Comment

Docket: APHIS 2008-0094

Docket title:
Pioneer Hi-Bred International, Inc.; Availability of Petition and Environmental
Assessment for Determination of Nonregulated Status for Corn Genetically
Engineered for Tolerance to Glyphosate and Acetolactate Synthase-inhibiting
Herbicides

January 21, 2009


Dear Sir or Madam:

The South Dakota Corn Growers Association (SDCGA) advocates for technology
tools and resources for our 14,000 growers in the state. It’s vitally important that
producers have timely access to new technology – including seeds with biotech
traits – to remain competitive in today’s marketplace. For that reason the SDCGA
requests the USDA’s expedient review of Pioneer Hi-Bred’s Optimum GAT trait.

Currently, corn producers have limited options in herbicide tolerance for corn; the
Optimum GAT trait from Pioneer Hi-Bred would offer growers a new choice in the
marketplace.

South Dakota has the highest adaptation rate of biotechnology with 93 percent of
our acres being planted to biotech traits. Biotech crops allow our South Dakota
producers to better manage herbicide and insecticide needs and control their
farming costs. We believe the availability of the Optimum GAT would allow
growers to use an environmentally-friendly herbicide, a priority for producers and
consumers alike. Clearly our producers not only embrace biotechnology tools, but
they rely on these traits to compete as least cost and environmentally conscious
producers.

We understand this product contains a unique approach not found in the
marketplace today. In addition to glyphosate tolerance, the Optimum GAT trait
enables more ALS-inhibiting herbicides which provide growers with more choices
and broader-spectrum weed control.

There are currently no commercially available corn products that are both
glyphosate and ALS herbicide tolerant. This new Pioneer offering will be the first
commercial corn product to contain both traits. Its availability will allow growers
greater ability to manage weeds and weed resistance, which is becoming
increasingly important.

The SDCGA supports new corn technologies and increased choices for
producers. The USDA should review the registration in a timely manner and move
forward with the application without delay.


Sincerely,



Bill Chase, President
South Dakota Corn Growers Association


Attachments

APHIS-2008-0094-0010.1Comment from Bill Chase