Comment submitted by Cathleen Enright, Executive Vice President, Food and Agriculture, Executive Vice President Food and Agriculture

Re: Agency Information Collection Activities; Submission to OMB for Review and Approval; Comment Request; Notice of Arrival of Pesticides and Devices under FIFRA; Docket ID No. EPA-HQ-OPP-2011-0843 To whom it may concern: These comments are submitted by the Biotechnology Industry Organization (BIO) in response to the EPA’s request to OMB to renew the existing information collection for the Notice of Arrival of Pesticides and Devices, EPA Form 3540-1 (NOA) in compliance with the Paperwork Reduction Act. BIO appreciates the opportunity to provide these comments. BIO is the world's largest biotechnology organization, providing advocacy, business development and communications services for more than 1100 members worldwide. BIO members are involved in the research and development of innovative healthcare, agricultural, industrial and environmental biotechnology. Corporate members range from entrepreneurial companies developing their first product to Fortune 100 multinationals. We also represent state and regional biotechnology associations, service providers to the industry, and academic centers. For over twenty years, BIO’s member companies have developed biotechnology-derived crops. As detailed in a recent report by the United States Department of Agriculture’s (USDA) Economic Research Service (ERS) , crops improved through biotechnology have provided significant benefits to U.S. farmers and consumers by substantially increasing the productivity of food, feed and fiber, while simultaneously decreasing the environmental impact of agriculture. In addition, biotechnology-derived crops have an excellent safety record; not a single instance of harm to human health or the environment has been documented. BIO and its members are proud of this record of health and environmental safety and of the many benefits these crops provide to growers, consumers and the environment. Background Biotechnology-derived, insect-resistant corn varieties contain