Comment submitted by William D. Hutchison, University of Minnesota

Re: Comments for: Docket: EPA-HQ-OPP-2007; MON 89034, Monsanto Dt: August 23, 2007 Fr: William D. Hutchison Professor, Dept. of Entomology, University of Minnesota In brief, my comments are related to the benefits of the stacked Bt toxin event, MON 89034, expressing two Bt proteins, Cry1A.105 and Cry2Ab2, including: a) reduced risk of Bt resistance by the primary, target pest, European corn borer, and in tandem with the continued use of EPA mandated non-Bt corn structured refugia, improved long-term resistance management for ECB, and b) much improved efficacy against another economically important insect pest, the corn earworm (CEW). This observation is based on the results of a field efficacy trial in southern Minn., 2007. Please refer to my complete letter, which expands on these views, attached (pdf). Regards, William D. Hutchison Professor, Extension Entomologist