PANUPS: Action Alert -- Save Bt

                         P A N U P S
                   Pesticide Action Network 
                        North America
                       Updates Service

March 10, 1997

Call for EPA to Protect Bt 

The U.S. Environmental Protection Agency (EPA) is holding a 
hearing on March 21, 1997, in Washington DC, to examine the 
resistance management plan implemented last summer for Bt 
cotton. This hearing is an opportunity for the organic and 
sustainable agriculture communities to tell EPA that it is 
not doing enough to protect the effectiveness of Bascillus 
thuringiensis (Bt) as a pest management tool.

Bt crops are transgenic plants genetically engineered to 
produce Bt toxins, which occur naturally in soil bacteria. 
Spray preparations of bacteria containing the toxin have been 
used for decades by organic growers and other sustainable 
agriculture practitioners. This past season, three Bt crops 
-- corn, cotton, and potato -- were grown on a large scale 
for the first time in the U.S.

Scientists agree that widespread use of Bt crops threatens 
the continued effectiveness of Bt by accelerating the 
evolution of insect resistance to the toxin. Once insects are 
resistant, Bt sprays and Bt crops will be ineffectual in 
controlling insect pests. To attempt to delay the development 
of resistance, EPA, under pressure from environmentalists and 
organic farmers, has required that Bt resistance management 
plans be implemented with Bt cotton and Bt corn.

At issue in the March 21 hearing is whether EPA-approved 
resistance management plans will work. For example, the Bt 
cotton plan relies on the cotton plant to produce a high 
enough dose of the toxin that all but the most highly 
resistant cotton bollworms will perish. In addition, plans 
call for using refuges -- stands of non-Bt cotton -- that 
provide habitat for non-resistant bollworm that can mate with 
the rare, highly resistant bollworm that survive the high Bt 
dose, thereby diluting resistance. 

In the first year of commercialization, dramatic evidence -- 
in the form of failures to control cotton bollworms -- has 
emerged. This evidence indicates that Bt cotton does not 
produce high enough doses of Bt to delay resistance in the 
cotton bollworm. Other evidence indicates the Bt corn does 
not produce a season-long high dose against the European corn 
borer. (These crops, however, still work well enough to 
produce satisfactory control for most farmers).

Since this past summer's failure, Monsanto is suggesting that 
a high dose is not needed for the bollworm, and that refuges 
alone are sufficient to delay resistance. This assertion 
amounts to a new resistance management plan for Bt cotton and 
the cotton bollworm. No submission to EPA by Monsanto 
detailing a resistance management plan based solely on 
refuges has been made available to the public. Nor has EPA 
evaluated any refuge-only plans, according to the Union of 
Concerned Scientists (UCS). 

UCS maintains that EPA has taken a lackadaisical approach to 
protecting Bt. After the bollworm problem arose last summer, 
UCS urged the Agency to prepare a report on the implications 
of the bollworm failure for resistance management in Bt 
cotton and to convene a meeting of the Scientific Advisory 
Panel to aid in the evaluation. Unfortunately, the Agency has 
done neither and it is now too late to complete a 
reevaluation and enact changes before farmers plant cotton 
this spring. 

EPA needs support to strengthen and enforce its requirements 
that Bt crops be grown in ways that will delay resistance. 
The sustainable agriculture community has a lot at stake. If 
insects evolve resistance to Bt in transgenic crops, they 
will also be resistant to Bt sprays upon which many organic 
and sustainable farmers and IPM practitioners rely.

*** What you can do

In preparation for the March 21 hearing, the Agency is 
soliciting comments from the public regarding the 
implications for resistance management of the bollworm 
control failure; whether resistance management plans should 
be mandatory or voluntary; and what scientific data are 
needed to evaluate these plans. In addition, EPA is seeking 
comments about criteria to be used to determine whether a 
pesticide is a "public good." 

The biotechnology/pesticide industry and other proponents of 
the technology will likely be at the hearing to highlight the 
fact that Bt crops work most of the time and to distract 
attention from the resistance issue.

Please write to EPA emphasizing that Bt is important to the 
organic, sustainable agriculture and IPM communities and that 
Monsanto should not determine the life span of Bt's 

*** Urge the Agency to:

1) Suspend current registrations and forego future approvals 
of Bt crops until workable resistance management plans are 
2) Convene a meeting of the Scientific Advisory Panel to 
evaluate the current management plans; 
3) Make resistance management plans mandatory because 
voluntary plans have not worked well in the past.

Send comments, identified with the docket control number OPP-
00470, to arrive before or on March 21.

By mail to:
Public Response and Program Resources Branch, Field 
Operations Division (7506C), OPP/EPA, 401 M St., SW, 
Washington, DC 20460

By email to:
(ASCII file with no special characters or encryption)

Source/contact: Jane Rissler, Ph.D., Senior Staff Scientist, 
Union of Concerned Scientists, 1616 P St., NW, Washington, DC 
20036; phone (202) 332-0900; fax (202) 332-0905.

For an in-depth update on Bt cotton, see "Bt Cotton -- 
Another Magic Bullet?" by Jane Rissler, in the March 1997 
Global Pesticide Campaigner. Contact PANNA for further 

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