<p style="text-align: justify;"><b>Field Testing</b></p>

<p style="text-align: justify;">The transgenic sugar beet line T120-7 was field tested in the United States (1994, 1996, 1997) and in Canada, Western and Eastern Europe, and in the former Soviet Union. T120-7 was evaluated extensively and no differences were found in the agronomic characteristics, plant emergence and seedling vigour for line T120-7 compared to non-transformed counterpart beets and standard commercial sugar beet varieties growing in nearby fields.</p>

<p style="text-align: justify;"><b>Outcrossing</b></p>

<p style="text-align: justify;">Sugar beet is an outcrossing, largely wind pollinated plant. It is normally a biennial, developing a large succulent root in the first year and a seed stalk the second. Certain conditions such as low temperatures after planting and longer day length may induce bolting and produce a seed stalk during the first growing season. Beet is also highly sensitive to frost and a poor competitor with other plants.</p>

<p style="text-align: justify;">During the reproductive phase, large amounts of pollen are produced which can travel long distances. The genus Beta, including the wild relatives, is divided into four sections: Beta, Corolinnae, Procumbentes, and Nanae. Sugar beet hybridizes freely with all members of the section Beta and the resulting progeny are fertile but hybridization is unlikely with other members of the Chenopodiaceae family. Hybrids between sugar beet and members of the other three sections do not naturally occur without human intervention. Assuming proximity, synchrony of flowering and suitable conditions, <i>B. vulgaris</i> may freely hybridize with other varieties.</p>

<p style="text-align: justify;">During production of T120-7, for purposes of than seed production, plants are harvested before the natural onset of the reproductive phase in the same manner that unmodified cultivars are grown. Since it is uncommon for sugar beets to bolt, except in fields or plots grown specifically for seed production, there is little opportunity for uncontrolled pollen flow due to adequate isolation distances enforced by seed certification agencies.</p>

<p style="text-align: justify;">Specific concerns have been raised about potential outcrossing with subsp. macrocarpa, in the Imperial Valley, California. Isozyme studies indicated the introgression of genes from commercial sugar beets has occurred, although other reports show that gene flow between these two plant populations is not likely due to non-synchronous flowering periods, sterile F1 hybrids, and poor growth in F2 hybrids.</p>

<p style="text-align: justify;">It was determined that the transgenic sugar beet line T120-7 was no more likely to become a weed than herbicide tolerant cultivars currently in use or that can be developed by traditional breeding techniques. T120-7 was unlikely to increase the weediness potential of any other cultivated plant or native wild species with which it may interbreed.</p>

<p style="text-align: justify;"><b>Weediness</b></p>

<p style="text-align: justify;">Sugar beet plants are not a serious weed, although sugar beets have escaped cultivation and their progeny have persisted in the environment for many years. Occasionally, sugar beet volunteers may arise from the presence of wild beet, the bolting of fodder beet plants, the development of groundkeepers, which arise initially from vegetative growth of beet crowns or tops left after harvest or the germination of seed (which may be dormant in the soil for up to 10 years). Volunteer plants may be controlled by mechanical means or the use of registered herbicides that can be used on sugar beet volunteers.</p>

<p style="text-align: justify;">Sugar beet plants have escaped from past commercial cultivation in the San Francisco Bay area and persist to this day. However, transgene movement via pollen to these plants is highly unlikely as sugar beets are no longer in commercial production in the Bay area. Other populations of sexually compatible plants are located in the Imperial Valley of California, but no wild populations exist outside of California.</p>

<p style="text-align: justify;">The movement of the glufosinate tolerance trait from T120-7 to any other sexually compatible plant should not have a significant impact as the glufosinate tolerance would not confer any competitive advantage to these plants, especially if glufosinate is not applied to these plants. This would only occur in managed ecosystems where glufosinate is applied for broad-spectrum weed control, or in plant varieties developed to exhibit glufosinate tolerance and in which glufosinate is used to control weeds. As with glufosinate tolerant sugar beet volunteers, these individuals, should they arise, would be controlled using other available chemical means. Hybrids, if they developed, could potentially result in the loss of glufosinate as a tool to control these species. However, this can be avoided by the use of sound crop management practices including not using the same herbicide every year.</p>

<p style="text-align: justify;"><b>Secondary and Non-Target Adverse Effects </b></p>

<p style="text-align: justify;">It was concluded that the genes inserted into the transgenic sugar beet line T120-7 would not result in any deleterious effects or significant impacts on nontarget organisms, including threatened and endangered species or beneficial organisms. Field observations of event T120-7 revealed no negative effects on nontarget organisms. The lack of known toxicity for the introduced PAT enzyme suggests no potential for deleterious effects on beneficial organisms such as bees and earthworms. The high specificity of the enzyme for its substrates makes it unlikely that the introduced enzyme would metabolize endogenous substrates to produce compounds toxic to beneficial organisms.</p>

<p style="text-align: justify;"><b>Impact on Biodiversity</b></p>

<p style="text-align: justify;">Genetically engineered event T120-7 sugar beet is no more likely to become a weed than lines developed by traditional breeding techniques. It is unlikely to increase the weediness potential of any other cultivated plant or native wild species with which it may interbreed. It will not harm threatened and endangered species and non-target organisms. It was concluded that there was no potential impact of event T120-7 on biodiversity.</p>
