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

<p style="text-align: justify;">Field studies were designed to compare agronomic performance of the transformed GlyTol cotton event GHB614, with the non-transformed Coker 312 counterpart. Data from agronomic trials were taken from 17 locations in 5 states over the 2004 and 2005 growing seasons. Studies were conducted in geographic regions of the southern United States representative of the regions in which nearly 94% of the total upland cotton production occurs. A comparison of 18 agronomic characteristics across eight locations in 2004 and nine locations in 2005 compared plant growth and plant mapping data taken by field agronomists to evaluate the growth and development of the plant. Plant mapping data was taken to evaluate the potential reproductive success of the cotton plant. The number of bolls, first position bolls, plant height, and total number of nodes are all key parameters for cotton production as it impacts the value, maturity, and development of the cotton fiber. Plant height and height to node ratio was calculated from these parameters as it is used as an indication of insufficient herbicide tolerance. These parameters are also used to determine the application timing of plant growth regulators (PGR) used to manage the height of the cotton plant which improves mechanical harvesting efficiency. Morphology ratings were taken to monitor for irregular plant development in key portions of the plant such as the leaves, flowers, and bolls. Fertility of the plant was measured in rating the number of embryos (seed) in the boll, their weight and the size of the fruit developed to house them. Fertility ratings were also taken to evaluate the fertility of the flower by the amount of pollen present and dehiscence.</p>

<p style="text-align: justify;">Evaluation of plant mapping data and crop development data showed no significant differences in the GlyTol cotton event GHB614 and the non-transgenic Coker 312 counterpart. Findings across locations show that GlyTol cotton is similar for maturity and yield to the nontransformed counterpart in both Coker 312 and commercial cotton varieties. No differences were noted in the morphology of the plants when compared across testing locations. All plants with the GlyTol cotton event GHB614 and their non-transgenic Coker 312 counterparts appeared to develop normally, with no abnormalities noted in field observations.</p>

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

<p style="text-align: justify;">Seed dormancy was evaluated in the GlyTol cotton event GHB614 to ensure that seed dormancy was not affected by the transformation of the Coker 312 germplasm or the production of the 2mEPSPS protein. Seeds were collected from the 2005 efficacy trials of transformation event GHB614 in six locations to test for effects to the seed dormancy. No significant differences were seen in germination between the transgenic and nontransgenic seed produced from the 2005 plot sites. Normal variation was detected between those which were planted immediately after harvest, and those which were stored for six months. This indicates that transformation event GHB614 does not increase seed dormancy and therefore does not contribute to the weediness of the transformed cotton plant through increased seed dormancy.</p>

<p style="text-align: justify;"><b>Potential Plant Pest Risk</b></p>

<p style="text-align: justify;">In addition to agronomic performance composition of the seed was evaluated for any potential plant pest risks to current cotton production in the United States. Composition data provided information on gossypol, antinutrient levels, and other toxicant contents. The overall conclusion is that there are no agronomically meaningful differences between the transformed GlyTol cotton event GHB614 and non-transformed cotton varieties evaluated. The resulting conclusion is that there are no new agronomic plant pest risks from the introduction of GlyTol cotton.</p>

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

<p style="text-align: justify;">In the United States, cotton (<i>G. hirsutum</i>) is not a weed pest and has no sexually compatible weedy relatives except perhaps <i>G. tomentosum</i> in Hawaii where there is no commercial cotton production. There is limited probability that Glytol cotton event GHB614 or any <i>Gossypium</i> species containing GlyTol cotton event GHB614 would become a weed problem. From the agronomic and phenotypic data, there were no consistent significant differences in germination, dormancy, phenotypic or plant morphological characteristics between the transgenic GlyTol cotton event GHB614 and the conventional near isogenic line Coker 312 that would impact plant pest or noxious weed potential. Based on these data there was no evidence to suggest that GlyTol cotton has a higher likelihood to become a weed than conventional cotton. There were no instances in which volunteer monitoring after harvest revealed any differences in survival or persistence relative to other cotton varieties.</p>

<p style="text-align: justify;"><b>Potential Impact on Non-Target Organisms</b></p>

<p style="text-align: justify;">Compositional analysis on the plants containing 2mEPSPS protein indicated no significant changes in the overall gossypol content of the plants or antinutrient levels between GlyTol cotton event GHB614 and the non-transgenic counterpart. This indicates that the transformed cotton is no more toxic than its non-transgenic counterpart. Composition findings are reinforced by visual field observations made by cooperators conducting field evaluations of the GlyTol cotton plants. Cooperators visually monitored all plots for differences in beneficial insect populations and types for each trial, as well as birds, pollinators, and other wildlife species. No reports of differences in populations for any of these non-target organisms were made by cooperators making these observations.</p>
