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Attachment 3. Letter from 26 University Entomologists to EPA

Public Submission: EPA-HQ-OPP-2008-0836-0043.  Docket   EPA-HQ-OPP-2008-0836
 Docket Title   Evaluation of the Resistance Risks from Using a Seed Mix Refuge with Pioneer's Optimum AcreMax 1 Corn Rootworm-Protected Corn  
Document  EPA-HQ-OPP-2008-0836-0001; Public Submission EPA-HQ-OPP-2008-0836-0043    
 Public Submission Title    Anonymous public comment     Receipt Date  02/09/2009   
Doc. Legacy ID  EPA-HQ-OPP-2008-0836-0032(0900006480849377) Track No.    8084de39    

General Comment  
 Comment:  The following statement has been submitted by 26 leading corn insect scientists  working at public research institutions located in 16 corn producing states.  All of the scientists have been active participants of the Regional Research Project NCCC-46 "Development, Optimization, and Delivery of Management Strategies for Rootworms and Other Below-ground Insect Pests of Maize" and/or related projects with corn insect pests.  The statement may be applicable to all EPA decisions on PIPs, not just for the current SAP.  It should not be interpreted that the actions and opinions of these 26 scientists represent those of the entire group of scientists participating in NCCC-46.  The names of the scientists have been withheld from the public docket because virtually all of us require cooperation from industry at some level to conduct our research.

"Technology/stewardship agreements required for the purchase of genetically modified seed explicitly prohibit research.  These agreements inhibit public  scientists from pursuing their mandated role on behalf of the public good unless  the research is approved by industry.  As a result of restricted access, no truly  independent research can be legally conducted on many critical questions  regarding the technology, its performance, its management implications, IRM, and  its interactions with insect biology.  Consequently, data flowing to an EPA Scientific Advisory Panel from the public sector is unduly limited."