### 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

c onsider and review scientific uncertainties association with corn rootworm resistance monitoring for Bt corn Plant Incorporated Protectants (PIPs) docket number EPA

- HQ

- OPP

2013

- 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 prod ucts 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 i ts 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 los s 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 wi th 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 exten s ion 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. T his means newWWW.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 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. A ll registrants have generated individual standard operating procedures (SOPs) on how sampling is t o 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

creat ed 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 contr ibute to rootworm monitoring in the future, but without long term validation th is 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. Ea rly 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 pe sts 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 compromis ed 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 th e 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 comm on 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 grower s. Final implementation will happen at the farm level, but clear direction from seed companies and registrants is paramount. We have stated in the past thatWWW.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 relationshi p 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

u nderstanding 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 cr itical issue for growers.

Sincerely,

NATIONAL CORN GROWERS ASSOCIATION

Martin R. Barbre

President