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Bacillus thuringiensis - Experimental Use Permit for Small-Scale Field Testing of Genetically Engineered Strains 6/94

                                    JUNE 13 1994

CERTIFIED MAIL
RETURN RECEIPT REQUESTED

Ms. Marion A. Burgwin
Regulatory Affairs
Ecogen Inc.
2005 Cabot Boulevard West
Langhorne, PA  19047-1810

Dear Ms. Burgwin:

     Small-Scale Field Testing of Genetically Engineered Strains of
Bacillus thurinqiensis

     This letter will serve as the experimental use permit for small-scale
field testing of genetically engineered strains of Bacillus thurinqiensis.
The tests will take place at the NYS Agricultural Experiment Station in
Geneva and at the Cornell University Vegetable Research Farm in Freeville.

     This permit is issued for the experiments with the following
objectives:

       1. Evaluate Bacillus thurinqiensis-based products produced by
recombinant DNA technology, applied at selected rates, against the true
first generations of obliquebanded leafroller (OBLR), tufted apple budmoth
(TABM) and other leafroller species which are present in the summer in
orchards.

       2. Evaluate new strains of Bacillus thurinqiensis produced by
recombinant DNA technology, applied at selected rates, against Colorado
potato beetles on potatoes.

     The orchard field testing will be done by Mr. Harvey Reissig at the
NYS Agricultural Experiment Station in Geneva. The experiment is designed
so that there will be a single tree plot per treatment, replicated 4-5
times in a completely randomized layout. If small trees are to be used,
each plot should include 3-4 trees to provide a buffer for the center tree
which will be treated.The total acreage treated will not exceed 0.02 acre.
First application should be applied at first egg hatch, early summer,
approximately 500 degree days (DD) following first adult catch and followed
by 2-3 applications at 5-7 day intervals. Mr. Reissig will monitor damage
by first generations of OBLR and/or TABM. The damage will be assessed by
visually counting the leafroller shelters and/or other types of damage
symptoms on foliage. Damage on 100 picked apples from each replicate per
treatment will also be assessed. Damage by other species of leafroller, if
present, will also be recorded. The assessment of treatment impact to other
pests and beneficial species will be noted.

     The potato field testing will be done by Dr. Ward Tingey at the
Cornell University Vegetable Research Farm in Freeville. The experiment is
designed so that each plot consists of 2 rows x 30 feet (0.004 acre). The
two rows will be completely treated and data will be collected. Each
treatment will be replicated four times in a completely randomized block
design. The total acreage treated will not exceed 0.03 acre. The plots will
be monitored on a weekly basis to determine when the first application
should be made. It is recommended that the first application be made when
30-50% of observed egg masses have hatched. Subsequent applications will be
made on a 5-7 day spray interval. When insect pressure is high,
applications may be made even more frequently, for example 3-4 day
interval. Applications may need to be repeated following heavy rains.

     Data should be collected at 7-day intervals and each plot should be
sampled for Colorado potato eggs, larvae and adults from at least 10 stalks
or plants. Larval counts should be categorized and reported as small,
instars 1-2, or large, instars 3-4. Plots should be sampled 3 to 4 days
following each application. Defoliation estimates are to be taken early,
middle and late season. All data should be analyzed and reported using
Analysis of Variance (ANOVA) and subjected to mean separation such as LSD,
DMRT or Waller-Duncan.

     This permit is issued for the experiments with the following

     1.   The experiment will be conducted according to the documentation
          provided to the Department and to the United States Environmental
          Protection Agency.

     2.   After use, all equipment used in the experiments will be
          decontaminated with a commercial bactericide.

     3.   All potatoes, potato plants and fruit used in this experiment
          will be destroyed at the end of the study.

     4.   A copy of the brief interim report, required for each test at
          mid-season, must be submitted-to this Department. Content of the
          reports can be limited to a summary of mean values for the
          treatments and any other pertinent information.

     5.   A final, more complete, report must be submitted to the
          Department within sixty (60) days of completion of the trials.
          Reports must be submitted to:

          Maureen Serafini, Supervisor
          Pesticide Product Registration Section
          Division of Hazardous Substances Regulation
          New York State Department Environmental Conservation
          50 Wolf Road - Room 436
          Albany, NY  12233-7250

     6.   You must contact our appropriate regional pesticide inspectors,
          for Tompkins County (Freeville) and Ontario County (Geneva), or
          this office 5 days prior to the start of the experiments.

     If you have any questions or concerns, please contact Ms. Jeanine
Broughel, of my staff, at (518) 457-7446.

                                 Sincerely,

                                 Maureen P. Serafini
                                 Supervisor
                                 Pesticide Product Reg. Section
                                 Division of Hazardous Substances
                                   Regulation

cc:  D. Rutz (Cornell) I