Comment submitted by Gene Hugoson, Minnesota Department of Agriculture

February 5, 2009 Dr. Janet Anderson Biopesticides & Pollution Prevention Division Office of Pesticide Programs 1200 Pennsylvania Avenue Washington DC 20460 To Whom It May Concern: As Commissioner of Agriculture for Minnesota, I spend a great deal of my time interacting with farmers from across the state. They talk about the challenges they face from narrowing profit margins and natural disasters to commodity speculation and IRM guidelines. Farming has never been so risky and complicated. I know this as I am a farmer myself. Fortunately, equipment manufacturers, chemical companies, seed developers and processors are doing what they can to simplify farming and minimize risks. This in turn can help farmers to maximize yields and profits. America will continue to serve a greater role in feeding and fueling the world as our global population quickly approaches nine billion in the coming decades. Therefore, I support technology innovations that assist Minnesota farmers and advance American agriculture. For the reasons stated above, I want to express my support for a technology concept called Optimum AcreMax that is undergoing U.S. regulatory review for approval. This technology proposes using approved biotech traits that are already on the market in a unique way to simplify and integrate refuge requirements, expand insect protection, increase yields and prolong the effectiveness of a proven corn rootworm trait. I am an advocate of safe, innovative, sustainable technologies that will help farmers in my state. This new technology concept would have real value for Minnesota farmers as well as agriculture throughout the United States. Thank you for your consideration. Sincerely, Gene Hugoson Commissioner Minnesota Department of Agriculture