He made the point that in relying on a refuge in IRM plans, the grower is, in effect, concentrating the damage from insects in a smaller area than would otherwise occur, but that this tradeoff is essential to preserve the technology. He also offered the view that he had seen no situations were alternative hosts would be effective as a refuge for susceptible insects.

Ron Fitchorn, a corn grower from McLean Illinois, noted that the ECB is an economic pest about one in five years, and that it is rarely sprayed for in most of Illinois. He said he had no problem with planting a percent of his acres to non-Bt varieties as long as he could lay out his refuge in blocks. He and others noted that growers with the typically large, modern air-seeders have to plant refuges in blocks since they cannot put non-Bt seed in just certain rows. He said there was no real difference for most farmers between planting refuges within ¼ or ½ mile of Bt-corn fields.

Gayl Hopkins, a grower from Iowa, said that planting Bt-corn cost him about $10.00 more per acre, and that Bt-corn had gained about 40 percent market penetration in Iowa in 1999. He found this fact amazing given the low prices for corn. In terms of refuge strategies, he called for maximum flexibility and noted that options given to farmers under conservation compliance had helped assure a higher level of compliance.

Hopkins reported that he had planted Bt-corn for three years, but had not received any information from anyone - not extension, a seed dealer, or a seed company - on the need for or design of a refuge. This comment triggered further discussion in the Grower Education and other panels. One of the extension entomologists on the Grower Panel commented that Mr. Hopkins must not have looked very hard for information, because "it is out there, easily accessible to anyone who looks." After this comment, Mr. Hopkins returned to the microphone and explained his efforts to get information.

First, he asked his local extension agent for information. His agent made some calls and secured a copy of a four-year-old publication on ECB biology and management that had no information on refuge issues. Mr. Hopkins held the publication up to show the audience. The extension entomologists on the panel responded by saying "…that's the wrong bulletin…" and told the audience about the September 1997 publication "Bt Corn and ECB: Long-Term Success Through Resistance Management." (BU-7055-S, NCR 602). A show of hands in the audience indicated that a majority of people had not seen this key publication despite dissemination of 47,000 copies.

An organic grower on the panel, Mr. Mark Lipson, began his talk by saying "Bt is the single most important off-farm input in the organic sector, especially on transitional farms." He reported results of an Organic Farming Research Foundation survey that found that 52 percent of organic field crop growers were using foliar Bt biopesticides. Based upon his conversations with entomologists and IPM specialists, he said that the high-dose-refuge IRM strategy was a "belief system, not a science based strategy."

In the discussion period, Mr. Brian Flood, a Del Monte IPM fieldman in Wisconsin, stated that an alternative to refuges would be a simple requirement for all growers to rotate to non-Bt varieties in a field planted to Bt-corn. He also offered the view that a "large share of growers are purchasing an input they don't need…[and that] growers can predict when and where you need treatment."

Other presenters during the day noted the importance of crop rotation - to soybeans and other crops, and to non-Bt corn varieties -- as proven, low-cost resistance management strategies. These suggestions did not elicit a response from seed industry and most academic participants.

Extension entomologists from Iowa State University and the University of Illinois explained their program efforts and information sources accessible through the Internet and in various publications.

Chuck Benbrook stated that the content and message of the grower educational campaign must be properly crafted in order to reinforce the types of changes in attitudes and pest management tactics needed to assure the continued efficacy of Bt-transgenic varieties. He stated that the educational message must include that avoiding resistance to Bt is a fundamentally different challenge then, for example, managing resistance to methyl parathion or Roundup.

He stressed that the educational campaign must encompass the scope and timing of the remedial actions that will be necessary to reverse the emergence of resistance. He also noted the conflict between "consistency in the message," a goal several presenters highlighted, and "flexibility for growers."

Benbrook also described the critical roll farmers that farmers planting Bt-transgenics must play in the IRM monitoring and trouble-shooting effort. He suggested that a new set of "thresholds" might be needed to help guide farmers in carrying out their own in-field monitoring, and to help them decide when to seek an outside expert to help them assess the performance of their Bt-transgenic fields.

Mr. Scott McFarland, National Corn Growers Association, presented data on GMO corn acreage. In 1999, he said NCGA estimates that there are 31.25 million acres planted to GMO varieties, about 40 percent of total national acreage. These acres include Bt-corn and herbicide tolerant varieties. Bt-corn accounts for about 20.3 million acres, or 25 percent of U.S. acreage in 1999. Last year (1998), there were 21 million acres of GMO corn planted, 16 million to Bt-corn.

MacFarland noted that only 16 percent to 18 percent of U.S. field corn production is exported, making the point that domestic markets can easily absorb the acreage of GMO corn.

Leon Corzine, an Illinois grower, stressed that farmers need to ask "…do I really need Bt-corn?" He stated that many farmers in his area were forced to buy Bt-corn to get the best genetics suited to their soils and area. He said that the seed companies had farmers "over a barrel" and that in his opinion, seed companies should offer all new varieties and genetics with and without Bt so that farmers would always have a choice. Other farmer-panelists made this same point during the day, raising one of the key issues that surfaced during the meeting.

Kevin Brussell, an Illinois farmer, expressed concern over the "rush to the market." He said it is widely known Bt-corn is needed only 1 in 5 years, and that researchers and farmers should work harder to develop methods to determine when it will be needed, so that unnecessary plantings can be avoided. He felt that educational materials should not be developed by those with a vested interest in the technology.

Dr. Blair Siegfried explained work he was doing on behalf of Bt-corn seed producers to establish baseline discriminating doses for several distinct ECB populations across the Corn Belt. He explained how existing methods can be used to track changes in susceptibility, but acknowledged that the methods are not as sensitive as desirable to help prevent resistance from emerging. He argued for a centralized and standardized monitoring method to help assure consistent results, and the focus in monitoring should be areas where the selection pressure is high, like southwestern corn growing areas.

Dr. David Andow reported on the costs of different monitoring and assay methods, and pointed out that the cost-effectiveness of different methods is a function of the frequency of resistant alleles and the sensitivity sought in the monitoring program. The discriminating dose method is cost-effective at high frequencies of resistance alleles, and when changes on the order of 1 in 10 are sought. More sensitive screens, like the F2 screen, become cost-effective if the goal of the monitoring program is to identify the first stages of resistance, when resistant allele frequencies might change from 1 in 1,000 to 1 in 800. Only the F2 screen will provide useful information if the naturally resistant allele is present in ECB populations at a frequency of 1 in 10,000 or less.

The first four pages of Chuck Benbrook's statement presents a summary of his remarks.

Ron O'Hanlon, a crop consulting in the High Plains, noted that 90 percent of the corn in his area is irrigated, and that first generation ECBs reach economic thresholds on 20 percent to 30 percent of the acres each year, and that 80 percent to 90 percent of second generation ECBs reach thresholds annually. The lack of a successful second generation treatment has led to the high interest in Bt-corn in Kansas and other High Plains corn growing areas.

O'Hanlon noted one conflict between recommended ECB resistance management practices and soil conservation goals. Corn stalk destruction through tillage is a recommended IRM practice yet can put a grower out of compliance with his conservation compliance plan. A very high percent of irrigated corn land in the High Plains is subject to high wind erosion losses, and hence growers are required to maintain soil cover as a wind erosion control practice. He also expressed the hope that the emergence of Bt corn would not lessen grower interest in crop rotation, which is an important practice for a variety of agronomic reasons in the region.

Steve Blunier, an Illinois grower, said that economics drive Bt-corn use, and that yield monitors could be used to annually check yields in refuges versus portions of fields planted to Bt. He stated that farmers are closely monitoring performance as a way to determine whether Bt-corn really pays.

Wisconsin farmer Steve Diercks noted that Bt-sweet corn is grown in rotation with potatoes in the state, and that the crop is intensively scouted since it is a well-known trap crop for ECB. He said that the emergence of resistance in Bt-sweet corn could serve as a "sentinel" for resistance in field corn or potatoes.

Mark Lipson, an organic farmer in California, said that: "If monitoring is not designed to compliment IPM - focusing on broader issues of pest ecology and pest-beneficial interactions - it will compete with it." He also made the point that the density of the sampling in the monitoring effort will determine the necessary scope of remedial action plans. If reliable information is accessible on multi-county areas, then remedial actions will have to be deployed widely. Last, Lipson offered the view that if resistance triggered by Bt-transgenics "…is a manageable risk, it is an insurable risk," and suggested that the seed industry and/or corn growers needed to establish a fund to compensate other farmers harmed in the event Bt foliar sprays loose their efficacy.

During the discussion period, a scientist from Auburn University working on Bt-cotton resistance management stated that in the south, "…you can forget about farmers and consultants doing sampling." He explained that growers and consultants were too busy in the key parts of the summer to take the time required to do field sampling. He said that other mechanisms would have to be used if there is going to be an effective monitoring program.

Dr. Mark Whelan, Michigan State University, made the same point in reference to corn, and reminded the audience of how difficult and unpleasant it is to monitor second generation ECB in 12 foot tall corn when it is 90 degrees or warmer. He also expressed the view that the field monitoring effort would be sporadic at best without dedicated funding to support it. Whelan said that resistance must be "managed in the bag," and that available evidence and experience suggests that grower education alone will prove unsuccessful. He said that a combination of new technology, economic incentives and/or regulation would be essential to assure the needed level of grower compliance.

In response to a question about the stability of resistance, Dr. David Andow described an emerging technique that could be used to actually reverse resistance, thereby restoring the susceptible gene pool to, or close to its initial status. The technique involves planting strips of crops that ECB are strongly attracted to within Bt-corn fields. Examples of such crops include sweet corn and sorghum. A few rows of these crops would, within a Bt-field, attract a high percentage of susceptible adults emerging from the refuge. This would lead to a non-random distribution of susceptible adults in the Bt-portions of fields where resistant insects will be seeking mates, and could greatly increase the odds that a resistance adult would find and mate with a susceptible moth. If resistance is recessive, the offspring will remain susceptible.

Andow highlighted the importance of management options that alter patterns of mating within the field and refuge. Any management practice that increases the chances a resistant adult maturing in the Bt-portion of fields mating with susceptible adults will improve the chances of success. By planting ECB trap crops intermittently within the treated portion of a field, the odds of non-random mating will be greatly increased. Andow suggested this approach should be field tested as a possible remedial action triggered when resistance reaches some threshold level in a region. If designed in an optimal fashion and used in the context of an area-wide approach, he offered the view that this approach might make it possible to reverse resistance in just a few years. Other panelists noted that this idea also would make it easier to sample fields for adults.

Terry Hurley, a University of Minnesota agricultural economist, noted the temptation for farmers to "free-ride" on the decisions of neighbors to plant refuges. His research shows that growers have a clear economic incentive to comply with refuge requirements up to 10 percent to 15 percent of acres, but not with refuges above that level. He offered the view that higher refuge requirements will lead to lower levels of compliance.

Tom Buman, Agren Inc., described an emerging crop insurance program targeting yield losses in unsprayed refuges. The program could offer farmers a tangible economic incentive to comply with refuge requirements, and to the extent compliance rates increase, the insurance program would increase the odds of success in managing resistance. Through one program under consideration, grower-premiums would go into a fund which would then be available to pay for damages suffered on the refuges managed on certain farms - an event expected about one in five years in most of the Corn Belt.

Dr. Becky Goldburg, Environmental Defense Fund, stated that the best way to assure growers got the information they needed to design and manage IRM plans and refuges was to deliver the information at the point of purchasing seed.

Mike Clark, a Homer, Illinois farmer stated that seed companies in his area were not offering the best genetics for his farm in non-Bt varieties, and hence he had no real choice. He repeated the request that seed corn companies should offer all varieties with and without Bt.

Gerald Tumbleson, a Minnesota farmer, noted that seed corn companies were offering non-Bt varieties at a 25 percent to 50 percent discount in his area as a way to assure that growers bought enough non-Bt corn to meet the refuge requirement.

James Riddle, member of the Minnesota Department of Agriculture's Organic Advisory Board, raised issues linking Bt IRM compliance with the ability of organic producers to remain in compliance with organic certification regulations. Mr.. Riddle pointed out that genetic engineering is strictly prohibited under all organic standards worldwide. Genetic pollen drift from Bt crops onto organic fields constitutes a violation of organic producers' property rights.

In addition, the development of Bt resistance in target organisms may decrease the efficacy of Bt sprays, which have been used by organic producers for more than 50 years. Scientific evidence also indicates that Bt crops impact non-target insects, including lepidoptera and coleoptera, which may reduce beneficial organism populations on organic farms.

In response to prepared questions, Mr.. Riddle quoted research by Andow and Hutchinson (U of MN), who recommend that, "Growers should plant no more than 50% of their corn acreage in Bt corn." This calls into question the 20%-40% refugia requirement, which is currently accepted by the EPA and the industry. Mr. Riddle stressed that compliance needs to be directed at the manufacturer and distributor levels, where it can be most effectively regulated. Biotech seed companies need to be held accountable for grower compliance and education. Advertising statements about refugia requirements, mandatory labeling of genetically engineered crops and products, "identity preserved" product segregation and grower certification are all critical for effective compliance.

Carl Eichenwald of the EPA's Office of Regulatory Enforcement stated that compliance can only be enforced at the registration level. The EPA has no mechanism to enforce grower compliance directly. When companies register Bt crops, they are required to submit their IRM plans for review. At the present time, the EPA review of compliance reports has been a paper review only, with no field inspections to verify the registrant's enforcement of grower agreements.

Discussion of registrant compliance issues followed, with a representative of Novartis expressing that he was not aware that registrants are being held responsible for growers following the grower agreements. Questions were also asked about comparisons between the resources spent by biotech companies on investigation and litigation of patent protection versus the resources they are devoting to enforcement of IRM provisions of grower agreements.

At the conclusion of the panel, it was apparent that much more needs to be done in order for effective enforcement of IRM plans to become a reality.

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