October 19, 2000

Farmers, scientists, public interest groups and the agricultural biotechnology industry are concerned that the widespread planting of crops improved through biotechnology could hasten the development of resistance to plant protectant Bt endotoxins. And although effective insect resistance management can reduce the risk of resistance development, farmers are going to have to be educated in the most effective means to comply with resistance management techniques.

Michael J. Phillips, executive director for food and agriculture, Biotechnology Industry Organization, Washington, told an Environmental Protection Agency advisory panel that collaboration among stakeholders has helped to achieve a high level of compliance. "Efforts to increase understanding and awareness of IRM (insect resistance management) requirements have been successful; compliance with Bt crop resistance management strategies is generally high - over 80%," Phillips said.

Growers have accepted the responsibility for resistance management so long as approaches are "logistically feasible, economically sound and flexible for a variety of common farming practices." Consistent and simple IRM strategies "are critical to reduce confusion and ensure compliance with IRM requirements," he continued.

The biotech industry works with various crop organizations such as the National Cotton Council and the National Corn Growers Association to communicate IRM plans and information to growers, Phillips said. "A program that educates growers to the necessity of IRM and provides guidance on deployment of IRM programs needs to be an integral part of any resistant management strategy. BIO members make every attempt to provide growers with consistent messages and with the most current resistance management guidelines."

Still, to achieve a higher level of grower compliance, programs may need to be developed to ensure grower conformity. "We would support studying alternative mechanisms regarding IRM compliance to ensure that resistance is kept at a bare minimum," he added.

IRM is an important component of production agriculture with Bt products because of the threat insect resistance poses to the future of Bt plant protection products and to the future of Bt plant technology, said Phillip.

Cotton producers echoed Phillips' position with a request to the EPA cotton advisory panel to consider producers' need to maintain economical and flexible options for the management of insect resistance to Bt cottons. Hollis Isbell, a Muscle Shoals, AL, cotton producer and chairman of the American Cotton Producers (ACP) of the National Cotton Council, told members of EPA's Science Advisory Committee (SAP) for Bollgard Cotton that he was "acutely aware of the consequences when an insect complex gains resistance to a control measure . . . . we take resistance management recommendations seriously."

Isbell said the Tennessee Valley of Alabama where he farms was devastated by the tobacco budworm in 1995 as pyrethroids and other insecticides became virtually useless due to resistance. Bt cotton varieties, he said, have enabled producers in his area to continue commercial cotton production.

"It is a win-win proposition for the environment with a reduction of insecticides and for the farmer in higher yields and lower costs," he said. "The issue before us, therefore, is how we best protect this technology from resistance and at the same time maintain its effective use for producers."

Isbell told the panel that producer compliance is the key to success of any resistance management plan and that cotton producers are learning the importance of refuge compliance. "The National Cotton Council is committed to work in cooperation with Monsanto, crop consultants and extension personnel to help educate growers on the new options and the importance of compliance," he testified.

He said flexible and economical options for refuges are needed because cotton is grown under a number of systems - diverse in size, cultural practices and ownership structures. Specifically, the ACP urged the panel to maintain the basic size requirements for refuge plans enacted for the 2001 crop and to allow the use of shared refuges.

Regarding the proximity of the refuge to the Bt cotton, Isbell said the ACP urges that the distance requirements be reevaluated during the 2001 season if found to be overly restrictive of the producer's planting flexibility and ability to comply.

Isbell also reiterated U.S. cotton's stance that resistance management models should only be used as one of the tools in evaluating and developing resistance management plans and "not be the regulatory endpoint." He also noted that cotton producers are extremely excited about the potential for Bollgard II - that the chance of resistance from the double gene is greatly reduced.

"The availability of Bollgard II seems imminent and will have a profound effect on Bt resistance management," Isbell said. "Our industry urges EPA and this committee to consider the availability of Bollgard II as it re-evaluates refuge requirements. Bt technology is just the tip of the iceberg as to what potential benefits biotechnology can provide to the betterment of agriculture and to its ability to feed and clothe this world."