The sampling and monitoring programs must be designed to contribute to basic knowledge of insect ecology, and to the optimization of Integrated Pest Management practices. If the IRM monitoring efforts are not designed to be scientifically and administratively complementary to these wider efforts, then they likely will be competitive. This would be tragically shortsighted, and would further compound the overall failure to utilize and improve the application of non-pesticidal, biological pest control. It is essential that monitoring be conducted by everybody, from the individual grower, to the county extension agents, to state university personnel. I think the order of magnitude should be close to one sampling program per county where the Bt crops are being commercially grown.
Resistance is likely to spread rapidly from just a few areas.
If there are 500 miles between sampling sites, the common sense presumption has to be that you would impose remedial actions in at least a 250-mile radius around an isolated resistance outbreak. Simply put, more sampling would mean more precision in applying the hypothetical remedial actions. In this discussion so far, remedial action is a misnomer. I have heard and read general descriptions of plans for changing pest management methods when resistance is detected, but I have not seen any suggestions for actually reversing a loss of susceptibility in target pest populations. EPA should require much more specific detail and justification in this area in order to consider continuing the registrations.