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Bt Plant-Incorporated Protectants October 15, 2001 Biopesticides Registration Action Document

6] Requirements for the registrant to develop, and if triggered, to implement a “remedial action plan” which would contain measures the registrant would take in the event that any insect resistance was detected as well as to report on activity under the plan to EPA;

7] Submit annual reports on or before January 31st each year.

All growers of Bt cotton must employ one of the following structured refuge options:

External, Unsprayed Refuge

Ensure that at least 5 acres of non-Bt cotton (refuge cotton) is planted for every 95 acres of Bt cotton. The size of the refuge must be at least 150 feet wide, but preferably 300 feet wide. This refuge may not be treated with sterile insects, pheromones, or any insecticide (except listed below) labeled for the control of tobacco budworm, cotton bollworm, or pink bollworm. The refuge may be treated with acephate or methyl parathion at rates which will not control tobacco budworm or the cotton bollworm (equal to or less than 0.5 lbs active ingredient per acre). The variety of cotton planted in the refuge must be comparable to Bt cotton, especially in the maturity date, and the refuge must be managed (e.g., planting time, use of fertilizer, weed control, irrigation, termination, and management of other pests) similarly to Bt cotton. Ensure that a non-Bt cotton refuge is maintained within at least ½ linear mile (preferably adjacent to or within 1/4 mile or closer) from the Bt cotton fields. This option expires after the 2004 growing season unless extended by amendment as described below. EPA intends to review the data specified in the data requirements concerning alternate hosts and chemical insecticide sprays applied to Bt cotton, and decide in 2004 whether the new data support continuation of an external, unsprayed refuge as part of a larger requirement that would also likely involve alternative host plants. If these data support the continued availability of the external, unsprayed refuge option, EPA may approve an amendment to this registration to maintain the availability of this option.

External Sprayed Refuge

Ensure that at least 20 acres of non-Bt cotton are planted as a refuge for every 80 acres of Bt cotton (total of 100A) . The variety of cotton planted in the refuge must be comparable to Bt cotton, especially in the maturity date, and the refuge must be managed (e.g., planting time, use of fertilizer, weed control, irrigation, termination, and management of other pests) similarly to Bt cotton. The non-Bt cotton may be treated with sterile insects, insecticides (excluding foliar Btk products), or pheromones labeled for control of the tobacco budworm, cotton bollworm, or pink bollworm. Ensure that a non-Bt refuge is maintained within at least 1 linear mile (preferably within ½ mile or closer) from the Bt cotton fields.

Embedded Refuge

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