Association of Official Seed Certifying Agencies 2008 Insect Resistance Management (IRM) On-Farm Assessment Survey Program

Insect Resistance Management Assessor Training Program Cotton IRM Refuge Assessments

What we’ll be covering today….. Background on IRM refuge requirements and related trait stewardship practices  Assessors are not expected to be experts on IRM  Basic understanding of IRM principles Bt Traits used in Cotton and Corn  Some regions will require IRM compliance for both crops Refuge Compliance  Requirements for B.t. crops  Configuration options and details Assessment Forms Ideas for successful on-farm assessments Frequently Asked Questions (FAQ’s)

 Comply with EPA mandated IRM requirements as described in product registration and outlined in Technology Use Guide (TUG) and grower guide.  Delay insect resistance and preserve the benefits of Bt products.  Demonstrate responsible stewardship and lack of need for additional government regulation.  Preserving Bt technology requires individual responsibility. Why Must Growers Plant a Refuge?

IRM Background Information Seed companies must register insect control traits with USEPA and meet registration requirements Compliance Assurance Program (CAP) calls for On- Farm Assessments with growers IRM applies to B.t. corn and cotton at this time Growers must maintain IRM refuges Refuges are a key component of a successful IRM strategy

Lepidopteran cotton pests have demonstrated an ability to develop resistance to many chemical insecticides. As a preemptive measure, cotton with the Bollgard and Bollgard II cottons must be managed in ways that will delay resistance development. Refuges ensure that some lepidopteran populations are not exposed to the Bollgard/Bollgard II proteins so they can reintroduce susceptibility into the selected populations. Importance of Insect Resistance Management (IRM)

Refuge Value Concept Refuge Bollgard X Homozygous SS Heterozygous Sr Homozygous rr

On-farm Assessments  Designed to assess adherence to refuge size, distance, and treatment requirements.  Growers randomly selected from Monsanto grower database.  Consists of a brief survey, which must be conducted in person.  Assessor’s role is to collect grower information.  Assessor is not required to be an expert on refuge requirements, but must have a basic knowledge in order to effectively collect information.

Major Change in 2008 IRM Program Bollgard II does not require an IRM refuge  USEPA has approved “natural refuge”  Natural refuge is not available in CA, AZ, NM, and parts of Texas – see the IRM Guide for details  See the Cotton 2008 IRM Guide  Do not include Bollgard II acres in calculations Bollgard still requires an IRM refuge  See the Cotton IRM Guide  Note Eastern and Western Regions

2008 Refuge Options 1. 20% Sprayed Option: Reminder: All Bollgard fields must be within one mile (preferably one half mile) of the associated refuge field(s) 2. 5% Unsprayed Option: Reminder: All Bollgard fields must be within one- half mile (preferably one-quarter mile) of the associated refuge field(s) and refuge must be 150 feet wide, preferably 300 feet wide. 3.5% Embedded Option: Reminder: Must be a contiguous block within the field unit and be at least 150 feet wide, preferably 300 feet

50 Acres 10 Acre Refuge 5% Unsprayed Refuge Width Requirement 75 Acres Road 7 Acre Refuge At least 150 ft. Must average at least 150 ft. wide

7 Acres 50 Acres 10 Acres 20 Acres 45 Acres 5% Unsprayed Refuge Width Requirement 75 Acres Refuge 30 Acres 50 Acres Road

7 Acres 50 Acres 10 Acres 20 Acres 45 Acres 5% Unsprayed Refuge Distance Requirement 75 Acres Refuge 30 Acres 50 Acres < 0.5 Mile Road

2008 Refuge Options 1. 20% Sprayed Option: Reminder: All Bollgard or Bollgard II fields must be within one mile (preferably one-half mile) of the associated refuge field(s)

Refuge Field ********** *********** One mile or less 20% Sprayed Refuge Distance Requirement Bollgard (20%) Sprayed

5% Embedded Option for 2008 *** Refuge must be a part of the field or “field unit” ***The refuge must be 150 feet wide (preferably 300 feet) ***The embedded refuge can be sprayed with any insecticide at the same time the Bollgard or Bollgard II field or field unit is treated. ***The embedded refuge may not be sprayed with bollworm or budworm active insecticides independently from the Bollgard or Bollgard II field or field unit. ***If the embedded refuge is treated for bollworm or budworm, the entire associated Bollgard or Bollgard II field or field unit must be treated at the same time with the same treatment.

A=20 Embedded Refuge Plan Example For Very Large Fields Two Miles **Refuge** Bollgard

A=20 Embedded Refuge Plan Example B=30 A=50 One Mile Field Road 50 Acres Bollgard 100 Acres Bollgard 50 Acres Bollgard 40 Acres Bollgard 40 Acres Bollgard 100 Acres Bollgard 10 Acre Refuge 400 Total Acres 5% = 20 Total Refuge Acres Needed

A=20 Embedded Refuge Plan Example B=30 A=50 One Mile Field Road 50 Acres Bollgard 80 Acres Bollgard 50 Acres Bollgard 50 Acres Bollgard 50 Acres Bollgard 100 Acres Bollgard 20 Acre Refuge 400 Total Acres 5% = 20 Total Refuge Acres Needed

5% Embedded Refuge Option Field Unit Definition Field Unit = Any group of fields that are contained within a one mile squared (one mile by one mile) area. 1 mile Field Refuge

Embedded Refuge Language for Pink Bollworm areas in CA, AZ & NM: Please see page 5 of the Western Region IRM Guide for specific details of this provision.

Community Refuge Plan NO LONGER ALLOWED IN 2008

Assessors’ responsibilities and the Assessment form…..

Assessor’s Responsibilities  Understand BollGard ® Refuge Requirements - keep IRM guide with you as a reference.  Set up an appointment with the grower at his/her convenience on their farm (Rainy times are good).  Confirm accuracy of grower demographic (address and phone) information. Conduct survey, using the instructions provided.  Your job is to record the grower’s responses to the survey questions, not to determine compliance with the IRM regulations.  Sign and date form. Grower signs/dates the form. (top box)  Leave a copy with the grower and send other two copies to your Agency. AOSCA will send reports to Monsanto in St. Louis.  After you leave the farm, recheck the survey form for completeness, correctness, legibility, etc.  Deadline for all forms: September 1, but our goal is much earlier.

IRM Assessment Forms We will send the 2008 IRM Assessment Form  Grower information and forms are on-hand  Distributed from AOSCA office to Agencies Complete all sections and be sure to include all acres of biotech varieties, even if not purchased from Monsanto – total to 100% of acres  Key is to complete the calculations for only Bollgard, not Bollgard II

Let’s review some questions that you might have……

Questions Q. Why is Monsanto doing these on-farm assessments? As a condition of EPA registration of BollGard ® products, Monsanto is required to conduct IRM compliance assessments during the growing season to ensure grower compliance.

Questions Q. What if a grower does not want to participate in the IRM Assessment Program? Growers who fail to participate in the IRM Assessment Survey risk losing access to the Bt cotton technologies. The IRM Assessment Survey is part of the registration for all Bt products and a requirement by EPA to ensure that stewardship requirements for these technologies are followed. If the grower refuses to participate, do not push the issue. Notify AOSCA.

Questions Q. How are grower’s chosen to participate in the IRM on-farm assessment? Participants are chosen randomly from the list of growers who purchase B.t. corn and cotton products. Q. How are compliance assessments made? After the survey forms are returned to St. Louis, the growers’ responses are reviewed and compliance is determined according to the IRM guidelines.

Questions Q. What should I do if a grower tells me that he or she is not in compliance ? Fill out the survey with the grower’s original answers. Do not attempt to “coach” the grower to the correct answers. After the questionnaire is completed, you may record in Section D the grower’s comments as to why they were out of compliance. Do not offer your opinion regarding the grower’s compliance. State that the assessment will be reviewed at Monsanto and the grower will be notified whether or not they are in compliance.

Questions Q. What will happen to a grower who is in compliance in 2008? There may be very little follow-up, but a survey might be sent later. Q. What will happen to a grower who is not in compliance in 2008? Growers who are out of compliance will receive a follow up letter and/or visit depending on the severity of the infraction. Growers not in compliance in 2008 will receive another OFA in 2009.

Questions Q. What if a grower tells me they have already been surveyed and answered these questions in 2008? Because other companies have insect-resistant products and are also required by the EPA to conduct on-farm assessments, it is possible for a grower to be selected to be assessed by Monsanto and another Company in the same season. Assure the grower that the selection process is random and the companies conduct their assessments independent of each other. The grower must still complete the Monsanto on-farm assessment. Thank the grower for their extra-ordinary participation

Questions Q. What if the grower chosen to be assessed is deceased, or did not plant Bollgard cotton in 2008? Basically, the grower cannot be assessed for IRM compliance. A. Move on to the next assessment and notify your office, if need be.

If you have questions or comments throughout this project, contact…… Your Agency’s designated contact Chet Boruff Office phone Leave a message, if after business hours to Return all survey forms to your Agency

The IRM On-Farm Assessment Program depends upon you to be successful….. Working knowledge of IRM requirements Understanding of the value of refuges Courteous and timely meetings with growers Professional attitude Thorough reporting and feedback to AOSCA

Please help preserve the utility of Bollgard and Bollgard II cotton by following the IRM guidelines.

Comments and questions…. Thank you for your participation.

Association of Official Seed Certifying Agencies 2008 Insect Resistance Management (IRM) On-Farm Assessment Survey Program