Draft EA and Petition for Syngenta's Alpha-Amylase Corn

The National Corn Growers Association Comments Regarding Docket No. APHIS-2007-0016 (73 Federal Register 69602, November 19, 2008)

To Whom It May Concern: These comments are offered in reference to USDA Docket No. APHIS 2007-0016; Petition and Environmental Assessment for Determination of Non-regulated Status for Alpha-Amylase Maize (Corn Amylase) Event 3272. A trial was designed and conducted to compare the growth performance of growing pigs consuming conventional yellow corn and corn amylase. Experimental treatments consisted of feeding increasing inclusion levels of corn amylase at the expense of conventional corn. Meticulous measurements were collected to compare food intake, daily body weight gain, final body weight, the efficiency of conversion of food intake to body weight gain, and stool consistency. Our results indicate that pigs consuming corn amylase performed similarly than pigs consuming conventional corn. Deregulation of Event 3272 has the potential to improve the US ability and efficiency to produce ethanol from renewable sources and decrease our dependency of foreign fossil fuels and carbon footprint. In addition, improved efficiency in ethanol production will enhance the quantity and quality of corn distillers dried grains with solubles (DDGS) for animal feeding. Based on the foreseen beneficial effects for the US economy, the ethanol and fuel industries, animal agriculture, our carbon footprint, similar growth performance results when fed to growing pigs, and the FDA designation as "safe for use in food and feed", I support deregulation of Event 3273.