The Environmental Protection Agency is reviewing a phase out plan for first generation Bollgard that includes provisions on how cottonseed containing Bollgard will be allocated, stored, tested and shipped to cotton growers for the 2010 season.

Registration for Monsanto’s original, single-gene Bollgard trait — which was approved under the Federal Insecticide, Fungicide and Rodenticide Act — expires Sept. 30, 2009, and is being replaced with Bollgard II, which contains an additional Bt gene. However, cottonseed containing original Bollgard can still be planted in the 2010 growing season as long as the seed is purchased by Sept. 30, 2009.

Deltapine is the only brand of cottonseed that has filed with the EPA to have Bollgard products to sell for 2010. The varieties are DP 555 BG/RR, DP 445 BG/RR and DP 444 BG/RR.

The plan was developed by Monsanto to address issues which came to light as the company prepared to phase out Bollgard and allocate any remaining seed containing Bollgard for 2010. The proposal includes a provision that allows Monsanto to finance cotton producers who purchase cotton varieties containing Bollgard for the 2010 season.

Dave Rhylander, marketing lead for the D&PL regions, noted that in meetings with farmers, many said the EPA-required September 2009 cutoff date was too early to secure financing to pay for the seed. There was also concern about the lack of storage facilities for seed as well as state seed law requirements that seed has to be tested within six months of planting.

Under the plan, to minimize potential credit issues, growers would be invoiced $25 per bag on or before Sept. 30, 2009. Monsanto would provide a deferred payment option to carry receivables on traits, seed and seed treatment costs of Bollgard varieties (less the $25) until July 2010.

Most supplies of the popular DP 555 BG/RR cotton variety will likely be headed east. According to the Agricultural Marketing Service, in 2008, DP 555 BG/RR was planted on 57 percent of the cotton acreage in the Southeast and 10 percent of the cotton acreage in the Mid-South. DP 444 BG/RR was planted on 5 percent of the cotton acreage in the Southeast and 16 percent of the cotton acreage in the Mid-South. DP 445 BG/RR was planted on 13 percent of Mid-South cotton acres in 2008.

The marketshare of DP 555 BG/RR in Georgia alone in 2008 was around 85 percent. Georgia’s demand for the variety will be strong again for the 2010 season, according to Richey Seaton with the Georgia Cotton Commission. “But our producers are beginning to look at some of the new varieties from all the companies, knowing that after 2010, DP 555 BG/RR won’t be available any longer. There will be a high level of competition to fill the marketshare void left by DP 555 BG/RR.

“There is some anxiety on our producers’ part as to how they’ll replace a variety that’s performed so well. You also have a bit of a learning curve in how you manage a new variety. All the companies have done a good job of getting new varieties out there, but it’s going to take some hands-on management in grower fields.”

David Ferrell, Crop Production Services, a Memphis-based retailer with responsibility for the southern United States, also expects solid demand for cotton varieties containing Bollgard in 2010, especially DP 555 BG/RR by Louisiana producers.

“There will probably be more producers looking at varieties they haven’t looked at before. But I don’t know that growers are going to have enough information on the new varieties where they’ll want to transfer a lot of their acres over to them.”

Asked to comment on the phase out plan, Ferrell said, “They’re asking for a very small amount of the total to be paid in the fall. There may be some growers who aren’t going to like it, but given the unique circumstances we’re having to deal with, I think it’s very fair.

“We have a really short window to make all this happen. We’ve not been faced with this type of situation before. So we’re having to work through it the best we can as an industry.”

The proposed plan calls for Monsanto to store seed inventories and ship all Bollgard cottonseed by Feb. 28, 2010, to distributor/dealer locations based on grower orders placed by Sept. 30, 2009. All seed shipped would meet Monsanto and industry standards for quality and germination.

Because large supplies of Bollgard seed are not expected, seed will be allocated by region and by state, according to a three-year average of sales. Under the allocation plan, Monsanto would announce initial supplies of Bollgard seed for 2010 on July 20, 2009. Final supply quantities will be announced on Aug. 20, 2009.

Rhylander said seed treatment options will be limited to standard, Cruiser and Avicta Complete Cotton, and seed will be offered in bags only. Growers must specify which of the three seed treatments they desire, and no downstream seed treating will be permitted under the proposed plan. However, hopper box treatments would be permitted under the plan once the product is in control of the grower.

Growers purchasing Bollgard for 2010 planting must sign a new 2010 Monsanto Technology Stewardship agreement and will be required to purchase refuge-qualifying varieties of seed in time for 2010 planting.

Under the plan, Monsanto must also furnish EPA with the names of growers who purchase Bollgard seed along with the number of bags purchased. Rhylander said the information could be helpful to EPA for monitoring refuge compliance.

Rhylander said stringent stewardship guidelines are being put into effect with the plan requiring all remaining bags of Bollgard seed not used in 2010 be returned to the retailer/seed company. Rhylander said growers should order accurately to provide others access to seed. Credit will not be issued on returned bags, and all sales of cotton varieties containing Bollgard will be final.

The proposal is under review by EPA. Monsanto hopes to receive a response from the agency by early August 2009.