Comment submitted by Larry Jacobs, Jacobs Farm

Docket ID number EPA-HQ-OPP-2009-0609 I depend on Bacillus thuringeiensis to manage population dynamics of lepidoptera species on a wide range of crops that we farm on over 2,000 acres. The inevitable sdevelopement of insect resistance will cause my company and many others significant economic loss. Widespread planting of genetically transformed plants has hastened the developlment of resistance to pesticidal Bt endotoxins. Resistance is well documented. See: Science Daily Feb 2008, First Documented Case of Pest Resistance to Biotech Cotton; GMWatch, 22 Dec 2009 12:35, New study shows "strong evidence" of BT resistance; Physorg.com, Aug 30, 2011, Researchers identify insect resistance to Bt pesticide. I strongly object to the continued permitting of Bacillus thuringeiensis eCry3.1Ab protein in corn. This is a short sighted strategy to insect population management that can only end in higher costs to growers and the loss of an excellent material. Larry Jacobs / President