Thursday, February 18, 2016

Planting Time and "Compliance" with Bt Corn Refuge Rules

Bt transgenic corn with insect protection can be planted as an integrated seed blend in the Corn Belt, but has mandated block or strip non-Bt refuge requirements in the southern USA where cotton is grown. Depending on the type of Bt corn, the required refuge is from 20 - 50% of planted acres. This means that 20 - 50% of the crop is subject to damage and yield loss by the pests intended to be controlled by the Bt toxins, and it also means that growers must clean out and reset their planters to deliver non-Bt seed after planting the primary Bt crop. This takes time, and time is at a premium during planting season.

When Bt corn is up for registration with EPA, the seed companies present an Insect Resistance Management (IRM) plan designed to slow down the development of resistance. Upon registration of the Bt technology, EPA mandates that the seed companies enforce the plan and provide annual evaluations of "compliance" by growers. When transgenic corn seed is sold, the companies make corn growers sign a document that says they will abide by the IRM plan. (This document is known as the Stewardship Agreement.) If growers request it, there is plenty of literature and individual help to know how to plant the refuge so as to be in compliance with the Stewardship Agreement. After planting, the seed companies have the authority to inspect on-farm acres that are planted to their technology. Growers must demonstrate that they are following the IRM plan, and if found "out of compliance" are subject to further inspection in the next growing season. There are no other penalties to growers for non-compliance, at least until year three, when an individual seed company can (and certainly will) deny the non-compliant grower access to their technology. The grower then can purchase Bt seed from another company.

This article is not about the rules of refuge planting, it is about what is ultimately compliance with the diktats of a Federal agency. I have friends in EPA who work in the division that negotiates IRM plans with transgenic seed companies. These people are excellent scientists and go to great lengths to develop a plan that will extend the life of the Bt toxins before insects become resistant. (It is a given that insects will become resistant, and the IRM plans seek only to delay that resistance.) Seed companies also want to delay resistance to their Bt toxins, in part because, in spite of conventional wisdom, they don't have new toxins waiting in the wings to clean up a resistance problem when it develops. The IRM plans in the Stewardship Agreements are the best estimates based on science as to how to delay the arrival of resistant insects that will make the technology ineffective.

However, in spite of what happens in Washington DC and corporate offices, the real power in determining how long Bt corn technology lasts is held by the men and women who plant corn seeds. You can follow the IRM plan and extend the life of the technology, or you can refuse to plant the refuge and shorten the life of the technology. The idea of "compliance" with what EPA wants is at best irritating, and some people would choose to not plant a refuge simply because EPA deems that it should be done. In one respect compliance might seem like bowing to the wishes of Washington DC and the seed companies, but in reality it is about the future. The best reason to plant a refuge is to extend the life of the technology. The choice is yours, and in the end that is the way it should be; you and your neighbors have the power to decide how long the technology lasts.