Guidelines give growers more flexibility than in past seasons If you intend to plant Bollgard cotton in 2001, you need to start thinking now about where you will put your refuge acres.
At first glance, the new refuge requirements announced by EPA and Monsanto this fall might seem a bit complicated. But, the new guidelines actually provide growers with more flexibility on refuge acres than in the past.
For openers, producers will have a third option, the new "embedded" option that allows you to locate the old 4 percent unsprayed refuge - which has been increased to 5 percent - inside a Bollgard field or field unit. Those acres may be treated with any insecticide if the associated Bollgard fields are sprayed at the same time.
Under the new guidelines, growers who farm across broad areas and their neighbors may also be able to put together community refuge plans to make it easier to comply with new restrictions on how far refuge acres can be located from their associated Bollgard acres.
The changes are the result of EPA's review of Bollgard's conditional registration, which is scheduled to expire at the end of this month.
"EPA decided to use this as an opportunity to re-evaluate the refuge requirements that had been in place the last five years," said Walt Mullins, Bollgard technical manager for Monsanto.
"The problem they ran into was that for changes to be made for an extended period of time they had to undergo a public review process. They could not get all that done in time for the 2001 season, so they said they wanted to grant a one-year extension for the Bollgard registration. But, they also wanted changes for 2001."
As a result, Monsanto began negotiations with EPA and with the National Cotton Council and its American Cotton Producers organization to determine what changes would be implemented for 2001. "What we have now is basically what was negotiated by those four groups."
Briefly, here are refuge options for 2001:
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 4 percent unsprayed option has been increased to 5 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 5 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 5 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 concept of embedding the refuge was developed by Mike Caprio, a researcher at Mississippi State University," said Mullins. "The principle is that as you spray both the Bollgard fields and the embedded refuge at the same time you don't lessen the resistance management potential of that refuge.
"Although you are decreasing the numbers of individuals across both the Bollgard and the refuge, you're not changing the ratio of resistant individuals to susceptible individuals. This is a concept the majority of entomologists have accepted and promoted."
The biggest change in the guidelines is EPA's decision to allow producers to form communities to help meet the new distance requirements for the 20 percent sprayed and 5 percent unsprayed options.
"We don't call this a fourth option because you have to implement one of the three primary options in the community in order for this to work," says Mullins. "Basically, the idea is that several growers who farm in an area work as if they were one grower. As long as there is enough refuge relative to the Bollgard that is in that area, and the distance and other requirements are met, it wouldn't matter whose field the refuge was located in."
In the past, Mullins said, farmers might have a number of Bollgard fields around a block of another grower's non-Bollgard cotton. But, they could not count those as refuge acres because EPA said it couldn't regulate situations involving multiple growers.
"But, now that we're tightening up the distance requirements, and we have these width requirements on refuge blocks, I think they realized that they needed to build in more flexibility," he said. "So, they permitted this concept."
Prior to EPA's announcement of the new guidelines, environmental groups called for significant increases in the current refuge sizes, some to as much as 30 percent of the cotton acreage planted.
But, National Cotton Council economists told an EPA Scientific Advisory Panel on Bt technology that large increases in refuge requirements could reduce net returns to cotton growers by $25 million to $50 million annually.
"I think what really helped change some of the opinions was that we also had farmers speak out on this issue," said Dave Rhylander, director of marketing for Monsanto's Southern Region.
"At one time, there were plans to change it to 70-30 or two Bollgard acres to one refuge acres.
"A number of farmers said that just wasn't doable - that it would cost them too much money."
"University entomologists also responded, saying we have to be careful about causing the grower economic harm based on theories of resistance," said Mullins. "Given this new information, it appears the majority would support the current plan."
He said Monsanto has also had a number of discussions with consultants and that most of them appear to support the new plan.
"They think the distance requirements will create some work for growers - and there's no question about that," he noted.
"But, the fact that they have the embedded refuge option and the community option, they feel, will put flexibility back into the system."
The new distance requirements - one mile for the 20 percent Sprayed Option and one-half mile for the 5 percent Unsprayed Option - will require more planning by growers, Mullins says.
"Potentially, it could put more refuge fields out there," he said.
"Where growers in the past have been able to consolidate their sprayed refuge in two or three large fields, they may have to have five or six fields to meet the distance requirements."
"In an area where you have a number of diversified crops, such as North Carolina, for example, it could be you may not have another cotton field nearby," said Rhylander. "So, it will take more planning."
Community refuge plans will also require a considerable amount of coordination, they note.
"The concern is not about the technical validity of this approach, but how well this is being implemented by growers," said Mullins.
"Are they really working together to provide sufficient refuge acres?"
Monsanto is requiring growers who want to form a community to use a formal process, which will allow them to monitor compliance with the refuge size and distance requirements.
Growers must sign a community agreement form that lists the names of the growers in the community, the number of Bollgard acres and the number of refuge acres.
They must also designate a coordinator who can speak for the community and explain the plan for locating the Bollgard and refuge acres if asked to do so by Monsanto. The coordinator will not be responsible for the actions of other growers.
Monsanto will also be required to monitor compliance as a condition of its obtaining a continued registration for Bollgard.
"If we find a problem on a particular farm in 2001, then we will revisit each of the farms in the community the following year," says Mullins. "If we find a case of noncompliance, then each member of the community is at risk of losing their technology license." For now, the new options apply only for the 2001 season.
"We are hopeful that if growers will accept the community plan and we can establish a good record of compliance that EPA will allow us to use the same refuge options when they issue a longer term registration for Bollgard and when they register Bollgard II," said Mullins.
"To us, that would be far preferable to having to re-educate farmers about new requirements each year."