December 2, 2010

Michael H Friddle
3032 S. Mountain View Ext
Moscow, ID 83843

Docket No. APHIS–2010–0047

Regulatory Analysis and Development, PPD
APHIS, Station 3A–03.8,
4700 River Road Unit 118,
Riverdale, MD 20737–1238

Dear Secretary Vilsack:

As an agriculture industry representative and plant breeder, I feel it is

necessary to weigh the importance of authorizing the production of
Roundup Ready Sugar Beets (RR Sugar Beets) in the United States.
There are many factors that are involved in such an important
decision, yet I trust that APHIS representatives will consider the voices
of the producers and research staff involved in the development of this
new crop.

My concern starts with the fear of Genetically Modified (GM) crops, also
known as Genetically Engineered (GE), and the fear of large companies
like Monsanto. While there have been small problems in the past as
this technology has grown, misperception and influence from
environmental action groups have driven the movement to stop further
developments and the research of Monsanto, solving critical issues
that could help this practice become safe. There have been public
outcries of cross pollination and spread of undesired seed into
conventional seed stock that are manufactured from this false fear of
GE crops.

If you refer to The Botanical Review volume 15, number 9, titled

“Control of Pollination in Sugar Beets”, written by Alexander
Archimowitsch, you will find on page two a summary from 1938 in
regards to the horizontal spread of sugar beet pollen. The claim the
former professor makes, which was field tested in Germany, is that
beet pollen can rise to 2,200 meters in the air, with the highest
concentration at 750 meters. He also claims that the pollen moved an
estimated 4,500 meters from the test site. I have been unsuccessful in
retrieving any updated horizontal pollination research since varieties
and plant phenotypes have changed, leaving an open estimate and no
solid, proven information. It would be unprofessional for APHIS to

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prohibit the production of this crop due to outdated information
without providing several years for opponents of the RR Sugar Beets to
fund the proper organizations to research and prove their accusations
to be true or false. Cross pollination due to wind or any horizontal
movement is not a legitimate argument without the proof in research.

Contamination of seed stock is a management issue. In our program

we do not research GE crops, fear being the main issue and
management of our inventory as a secondary. With the need to
produce results year in and year out, the ability to pay attention to our
inventory is a tough practice and keeping conventional products as our
sole inventory is a key to our success. In the commercial farm
industry, the management of seed inventory is more achievable. With
large quantities of seed, farmers are able to track seed lots and seed
sacks better, allowing those large quantities to be identifiable and
manageable with a low level of concern for contamination. The
industry has been outstanding in the management of their crop and
seed mixing has become minimal.

In plant genetics research I have found it rewarding to develop new

plant varieties and have seen the importance of genetic variation in
breeding programs. While my company does not deal with GE crops in
my breeding program, I am excited to know that we are on the break
of this new technology that could help feed an ever growing
population, projected to double in the next 20 years. Permitting the
production of a crop that has been proven safe for the environment in
the Environmental Assessment, provided by the USDA, would allow the
agriculture industry to start developing their action plan as this task is
presented to producers.

When RR Sugar Beets were approved for production, the sugar beet
industry adopted this crop because of the benefit this technology has
offered producers. In history we have yet to see a commodity that was
adopted as fast, quoted by industry leaders to make up 80-95% of
sugar beet seed within just five years. This proposes a problem for the
industry, as these farms have dropped conventional seed from
production inventory and accommodated production programs to suit
this new crop. If APHIS does not allow production of this crop, I fear
there is not enough conventional seed stock to meet production needs.
This is a serious concern not only for the producers and their
livelihoods, but for the sugar industry as a whole.

The greatest concerns that I believe both sides of this issue have deals
with chemical application and farm management. While conventional
farmers want to save money and achieve higher yields, smaller organic
and natural producers want to avoid the use of chemicals altogether.

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The development of glyphosate resistant genes has allowed this to be
achievable for both production practices. Controlling broad-leaf type
weeds requires different chemicals than thin-leaf grass types,
developing into complex chemical application plans that allow more
exposure of chemicals that could leach through the soil or run off
through drainage systems, depending on the producer’s management
practices. This is a negative possibility for organic and natural
producers. Allowing such technologies in agriculture to develop will
allow farmers from all industries to find middle ground; organic and
natural producers find less exposure and conventional farmers save
money.

It is essential that America keeps pressing forward in their

development of technology. With the ability to have clean fields
because of the resistance to glyphosate and Roundup products, farms
are able to better utilize water through less irrigation, less chemicals
due to lower weed population, and higher yields due to the availability
of nutrients. We cannot let the public’s fear for things unproven drive
the food industry. While it is important to hear the concern of our
consumers, it is equally important to back claims with solid evidence
from credible sources, all while striving to solve these problems.

It is obvious that the positives outweigh the negatives in the case of

Roundup Ready Sugar Beets. I urge APHIS to deregulate this
technology to allow producers to continue the practices already in
place. This has become a timely issue with planting season quickly
approaching and planning is critical to the success of agriculture.

Thank you,

Mike Friddle
Moscow, ID 83843

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