Producer urges Bt compliance Cotton growers may have the most to lose if they fail to implement EPA's new refuge requirements for Bollgard cotton, an Arkansas producer leader says.

Speaking at the NCC's Beltwide Cotton Production Conferences in Anaheim, Calif., Allen Helms said farmers could jeopardize the continued registration of Bollgard cotton if they fail to voluntarily comply with the new requirements.

"It is in the growers' best interest to practice good use of these insect resistance management guidelines," said Helms, who helped develop the new rules in negotiations between EPA, Monsanto and the National Cotton Council.

"Cotton producers stand to lose the most if this technology becomes ineffective," said Helms, former chairman of the American Cotton Producers, the producer arm of the NCC. "These refuge requirements were collectively agreed upon as an effective plan to prevent resistance."

In addition, he said, the refuge requirements are part of the contractual agreement Monsanto uses to license the use of its Bollgard technology. "Failure to comply could result in your inability to obtain a Bt cotton variety," he said.

Finally, to maintain reasonable Bt refuge requirements in future crop years, growers must continue to prove that they are voluntarily complying with the current refuge requirements.

"Many of the critics of this technology accuse cotton producers of being careless in their stewardship of this valuable production tool," said Helms, who farms at Clarkedale in northeast Arkansas. "We have made a strong case for compliance in the continued success of any refuge strategy, and producers are the key to compliance."

Last fall, EPA announced a temporary extension of the Bollgard registration that was scheduled to expire on Jan. 1 of this year, giving them the remainder of the year to consider a longer-term registration.

"As we speak, the process is under way for the 2002 crop year and beyond," said Helms. "All of the current refuge options are under review. The National Cotton Council has said that for the resistance management plan to be effective, it must be feasible and consistent.

"We believe the requirements for the 2001 crop are feasible. For them to remain consistent, we must continue to show good faith in our compliance. Therefore, the burden is on us, the users of this technology. We must demonstrate to EPA and our critics we will continue a high level of compliance and improve where we can."

He outlined the refuge options for the 2001 crop year:

(1.) The existing 20 percent sprayed option has an added requirement that all Bollgard fields must be within one mile of the refuge (from field border to field border). As in previous years, the 20 percent sprayed option means you plant 25 acres of conventional cotton as a refuge for every 100 acres of Bollgard cotton.

(2.) The previous four percent unsprayed option has been increased to five percent or five acres of unsprayed refuge for every 95 acres of Bollgard. This unsprayed refuge must be at least 150 feet wide (about 48 rows). To comply with the five percent unsprayed option, all Bollgard fields must be within one-half mile of the unsprayed refuge. (Note: The unsprayed refuge cannot be treated with any cotton insecticide labeled for control of tobacco budworm, bollworm or pink bollworm.)

(3.) EPA added a third refuge option, which allows the five percent refuge to be placed inside or "embedded" in a larger field or field unit. This new option also allows the refuge to be treated with any insecticide used to treat the Bollgard fields within the same 24 hours. The embedded refuge cannot be treated for bollworm, tobacco budworm or pink bollworm independently of the surrounding field.

The new rules also offer producers who farm across broad areas and their neighbors the opportunity to put together community refuge plans to make it easier for them to comply with new restrictions on how far refuge acres can be located from their associated Bollgard acres.

Helms said some aspects of the community refuge plan are still being negotiated with EPA.