Modified Cry3A Protein and Genetic Materials Necessary for its Production in Corn; Notice of Filing a Pestcide in Corn; Notice of Filing a Pesticide Petition to Establish a Tolerance for a Certain Pessticide Chemical in or on Food

The National Corn Growers Association (NCGA) is submitting the following comments on the pesticide petition to establish a tolerance for a certain pesticide chemical in or on food by Syngenta Seeds Inc. as described in the October 27, 2004, Federal Register (FRL-7370-1). The NCGA was founded in 1957 and represents more than 33,000 dues-paying corn growers from 48 states. In addition, NCGA represents the interests of more than 350,000 farmers who contribute to corn check-off programs in 19 states. In order for producers to stay competitive and remain profitable they must have access to new products and new technologies. Agriculture biotechnology helps farmers better manage herbicide and insecticide needs and in many cases helps reduce the overall use of chemicals, lowering farmers? expenses, improving profitability and preserving the environment. Therefore, NCGA believes the continued availability and marketability of products derived from biotechnology is important. Technology protecting corn plants from pests like the corn borer is of great value, no other plant pest causes as much damage to corn as the rootworm. However, only one event developed by one company currently provides protection. Competition from other technology developers will provide growers with more choices and options and can contribute to potentially lower costs. The Association supports Syngenta?s application to establish a tolerance exemption regarding the modified Cry3A protein (mCry3A) and respectfully requests EPA act expeditiously on the request. The product will undoubtedly provide corn growers with another tool to help with insect resistance management and help ensure the long-term viability of the technology. The National Corn Growers Association appreciates this opportunity to comment and values EPA?s continued commitment to a thorough and transparent regulatory process.