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

Plant at least 5 acres of non-Bt cotton (refuge cotton) for every 95 acres of Bt cotton. The refuge cotton must be embedded as a contiguous block within the Bt cotton field, but not at one edge of the field (i.e., refuge block(s) surrounded by Bt cotton). For very large fields, multiple blocks across the field may be used. For small or irregularly shaped fields, neighboring fields farmed by the same grower can be grouped into blocks to represent a larger field unit, provided the block exists within one mile squared of the Bt cotton and the block is at least 150 feet wide, but preferably 300 feet wide. Within the larger field unit, one of the smaller fields planted to non-Bt cotton may be utilized as the embedded refuge. 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, and management of other pests) similarly to Bt cotton. This refuge may be treated with sterile insects, any insecticide (excluding foliar Btk products), or pheromones labeled for the control of tobacco budworm, cotton bollworm, or pink bollworm whenever the entire field is treated. The refuge may not be treated independently of the surrounding Bt cotton field in which it is embedded (or fields within a field unit).

Embedded Refuge for Pink Bollworm Only

Plant the refuge cotton as at least one single non-Bt cotton row for every six to ten rows of Bt cotton. The refuge may be treated with sterile insects, any insecticide (excluding foliar Btk products), or pheromones labeled for the control of pink bollworm whenever the entire field is treated. The in- field refuge rows may not be treated independently of the surrounding Bt cotton field in which it is embedded. The refuge must be managed (fertilizer, weed control, etc.) identically to the Bt cotton. There is no field unit option.

Optional Community Refuge Pilot

This option allows multiple growers to manage refuge for external, unsprayed and external, sprayed refuge options or both. This option is not allowed for the embedded/in-field options. A community refuge program will be allowed as a continuing pilot for the 2002 growing season. The community refuge for insect resistance management must meet the requirements of either the 5% external unsprayed refuge and/or the 20% sprayed option, or an appropriate combination of the two options. The registrant must implement the 2002 community refuge pilot program as described in the Bollgard® Cotton 2002 Refuge Guide.

7. Regulatory Position on Bt Corn

EPA’s finding that Cry1Ab or Cry1F protein expressed in corn will not significantly increase the risk of unreasonable adverse effects on the environment is based on the analysis contained in the succeeding sections of this BRAD and the specific terms and conditions that are imposed upon this registration, as set forth in Section V. In general terms, EPA concludes that use of Cry1Ab or Cry1F as expressed in corn is effective at controlling significant lepidopteran pests of corn including European corn borer, corn earworm, and southwestern corn borer. Therefore, these products have

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