December 3, 2013

Docket No. EPA-HQ-OPP-2013-0490

OPP Docket

Environmental Protection Agency Docket Center (EPA/DC), (28221T)

1200 Pennsylvania Ave. NW., Washington, DC 20460-0001

The National Corn Growers Association (NCGA) appreciates the opportunity to provide 

comments in response to the Federal Register notice 2013-19372 announcing the Federal 

Insecticide, Fungicide and Rodenticide Act Scientific Advisory Panel (FIFRA SAP) to 

consider and review scientific uncertainties association with corn rootworm resistance 

monitoring for Bt corn Plant Incorporated Protectants (PIPs) docket number EPA-HQ-OPP2013-0490. The value of Bt technology to the US grower cannot be understated, as it has 

transformed corn production into a safer, more efficient system with fewer environmental 

impacts. Likewise, the NCGA holds in high regard the need for proper stewardship of Bt 

technology to maintain its viability and are committed to keeping these products accessible to 

growers through proper stewardship. 

Founded in 1957, NCGA represents approximately 40,000 dues-paying corn growers and the 

interests of more than 300,000 farmers who contribute through corn checkoff programs in 

their states. NCGA and its 48 affiliated state associations and checkoff organizations work 

together to help protect and advance corn growers’ interests. NCGA acknowledges 

biotechnology as a critical tool for growers, allowing increased production efficiency and 

reduced yield loss under stressed conditions.

American agriculture is the world leader in production and efficiency by having access to and 

adopting new technology. With new crop protectant tools, like Bt corn, growers have been 

able to consistently produce record crops with less inputs. This increased productivity has 

helped sustain the viability of U.S. farms, support domestic and rural economies and 

contribute to a world food supply. The modern grower understands the tools that are available 

and how to educate themselves for proper use. The introduction of Bt corn has furthered these 

efficiencies by reducing the application of insecticides, protecting yield, and increasing safety. 

The well-known PG Economics annual crop biotechnology global impacts report supports 

this, citing from 1996-2011 there was a 474 million kg reduction in pesticide spraying. 

(https://www.landesbioscience.com/journals/gmcrops/2013GMC0001R.pdf)

U.S. growers maintain a robust working relationship with their seed dealers and other 

technical experts, and NCGA continues to advocate for proper education of seed dealers, crop 

consultants, and extension agents regarding the stewardship of Bt products. However, we 

realize no product is a “silver bullet”. Growers have seen conventional crop protection

products in the past fail due to improper use and have adjusted accordingly. This means new
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technology must be developed, but also adjustments must be made with current products to 

extend their viability. We remain committed to the continued adoption of more robust 

integrated pest management, utilizing multiple modes of action, rotation, and alternative 

products. 

NCGA lacks the technical expertise to advise the SAP on the specifics of charge questions 1-3 

addressing sampling methods and assays, but we would like to offer our general positions on 

these topics. All registrants have generated individual standard operating procedures (SOPs) 

on how sampling is to be executed, how to address performance inquiries, and how to execute 

an assay to determine performance on a specific population. While these SOPs should be 

validated, they must be maintained as a key diagnostic for future monitoring. The baselines 

created by the longevity of this data will be critical in the future and will continue to be a 

viable data source for validating performance of pyramided Bt products. Developing a 

standardized sampling method and bioassay to evaluate Bt performance could contribute to 

rootworm monitoring in the future, but without long term validation this should remain in 

development. The accuracy of these assays are of equal importance to the grower and the 

registrants, neither party wants to see a technology compromised. Early identification of

performance of a Bt product will be critical to remediation, but the efficacy of that 

remediation must begin prior to the determination of resistance.

In response to charge question 4, NCGA recognizes the scientific importance to the 

determination of resistance and believes it will provide insight on the field of rootworm 

management. This can lead to future methods and products to continue controlling pests and 

increase viability of products on the market. The reality is if there are performance issues 

with a product, growers will be the first to experience it and need to change their farming 

practices accordingly and quickly. If performance is compromised for any number of reasons, 

the standard set of best management practices being developed by the registrants will be 

underway far before determination of resistance. 

NCGA has specific interest in charge questions 5 and 6. As stated prior, growers are the initial 

exposure site for any performance issues and need clear direction from registrants, EPA and 

the academic community on the best management practices to address the issue. A critical 

piece of the action plan will be to maintain the availability of tools for growers for 

remediation. NCGA continues to support the pyramiding of products to decrease the chance 

of resistance development. Removal of any single mode of action from the marketplace only 

exacerbates the pressure on other products. The common themes of multiple modes of action, 

rotation, increased scouting, insecticide application and reporting need to be formalized into a 

unified Integrated Pest Management (IPM) protocol to be applied in suspect areas. NCGA is 

willing to enhance our role in the deployment of IPM practices and dissemination of 

information to growers in areas where enhanced IPM needs to be encouraged. 

Finally, NCGA would like to recognize that the viability of this technology is critical to both 

the registrants and the growers. Final implementation will happen at the farm level, but clear 

direction from seed companies and registrants is paramount. We have stated in the past that 
WWW.NCGA.COM NATIONAL OFFICE

632 Cepi Dr.

Chesterfield, MO 63005

(636) 733-9004

Fax: (636) 733-9005

WASHINGTON, DC OFFICE

20 F Street NW, Suite 600

Washington, DC 20001

(202) 628-7001

Fax: (202) 628-1933

one of the key relationship growers must maintain in a viable business is with their seed 

dealer. Consistent messaging and implementation of IPM prior to any determination of 

resistance will be the best remediation plan. We also recognize and encourage the additional 

resources being provided by registrants to public sector researchers to continue our 

understanding of rootworm biology and development of resistance. It will play a key role in 

the development of new approaches and technology for successful pest management. 

Thank you again for the opportunity to provide comments to this SAP analyzing a critical 

issue for growers.

Sincerely,

NATIONAL CORN GROWERS ASSOCIATION

Martin R. Barbre 

President