BPPD Meeting Summary

Meeting: National Alliance of Independent Crop Consultants (NAICC)

Date and Time: April 22, 2015; 9:30 – 10:30 AM

Location: EPA HQ (Potomac Yards South, Arlington, VA), Room S-8771

Topic: Corn Rootworm Resistance Management; EPA’s proposal to 

enhance existing IRM strategies; public comment period

Attendees: Jim Steffel (NAICC)

James Todd (NAICC)

Kimberly Nesci (EPA/BPPD)

Mike Mendelsohn (EPA/BPPD)

Alan Reynolds (EPA/BPPD)

Bill Chism (EPA/BEAD)

Agenda (provided by NAICC):

 Review/status of Bt CRW resistance management proposal

 Who does EPA see as responsible for implementation of the various components of the 

framework

 IPM value of SAI’s 

 Suggestions for long term resistance management of CRW

 Basis for use of SAI by crop consultants

 Grower understanding and adoption of IPM

Points of Discussion:

BPPD discussed the status of the CRW IRM proposal. The public comment period, which 

closed 4/15/15, garnered 87 total comments. Many comments were received from grower 

groups, associations, farm bureaus, and crop consultants (including NAICC). The comments 

were helpful to BPPD in identifying the issues most important to growers. Most of the growerbased comments expressed concerns about restricting or mandating CRW management tools, 

such as soil-applied insecticides and crop rotation.

BPPD discussed the “next steps” in the process. In May, BPPD will convene another meeting 

with the Agricultural Biotechnology Stewardship Technical Committee (ABSTC) to discuss the 

proposal. All meetings related to the proposal will be summarized for the docket to maintain a 
transparent, open process. BPPD emphasized that no agreements or arrangements have been 

reached yet regarding the proposal.

NAICC discussed potential impacts to the 2016 growing season. It was noted that growers will

make planting decisions in the Fall and should commit to seed orders before November 1st. 

However, NAICC indicated that untraited (non-Bt) seed may be in limited supply for some 

growers.

BPPD and NAICC discussed how crop consultants integrate IPM techniques in their guidance to 

growers. Consultants have regional expertise, so many growers rely on their advice for farming 

decisions, including resistance management strategies. NAICC stated that any significant 

changes to CRW IRM (i.e., IPM techniques, refuge changes) could take several years to adapt. 

A gradual introduction of new techniques may be helpful, particularly if equipment changes are 

needed (planter boxes, tractors, pesticide application equipment, etc.). NAICC noted that many 

growers are still adjusting to the restriction/cancellation of some pesticides by EPA. NAICC 

also emphasized the need for flexibility since soil, climate, and insect pressure can vary in 

different corn-growing regions.

BPPD discussed implementation questions regarding the proposed IRM enhancements. As with 

other aspects of resistance management (e.g., refuge, compliance, and resistance monitoring), 

any changes are likely to be implemented by registrants through the terms and conditions of the 

Bt corn registrations. A significant challenge for EPA and ABSTC will be how to involve other 

important stakeholders (seed dealers, consultants, extension personnel, growers) in the process. 

These stakeholders could help with early resistance detection (i.e., field scouting), though there 

are concerns with logistics (multiple registrants) and resources (declining extension budgets).