Section
6.0
6
­
1
6
­
The
Corn
Rootworm
Problem
(
background)

6
­
Comment
Excerpts
Commenter
Name:
Charlie
Kiersh
Commenter
Organization
Name:
Charlie
Kiersh
Comment
Number:
30509­
016000
Excerpt
Number:
1
Excerpt
Text:
As
a
former
farm
resident,
I
fell
the
single
most
important
technology
that
could
be
advanced
is
that
of
rootworm
resistant
corn.
It
alone
causes
more
economic
impact
to
the
agricultural
community
than
any
insect
or
disease.
It
affects
corn
across
the
whole
corn
belt,
not
parts
as
does
corn
borer.
Corn
rootworm
is
a
significant
pest
problem
in
the
United
States.

Commenter
Name:
Kelly
Montgomery
Commenter
Organization
Name:
Kelly
Montgomery
Comment
Number:
30509­
027006
Excerpt
Number:
4
Excerpt
Text:
Growers
are
currently
under
risk
of
losing
insecticide
options
such
as
(
organophosphates
and
carbamates)
due
to
regulatory
pressures
and
we
need
new
technologies
to
fill
the
void.

Commenter
Name:
Harry
Brokish
Commenter
Organization
Name:
AgReliant
Genetics
Comment
Number:
30509­
029000
Excerpt
Number:
1
Excerpt
Text:
I
live
in
Champaign,
Illinois
which
is
an
important
corn
growing
region.
This
region
used
crop
rotation
for
many
years
to
deal
with
the
corn
rootworm.
Through
natural
adaptation.
The
corn
rootworm
is
no
longer
controlled
by
crop
rotation.
Farmers
are
forced
to
use
soil
applied
insecticides
to
protest
their
corn
crops.

Commenter
Name:
Arthur
Eggerling
Commenter
Organization
Name:
Select
Seed
Hybrids
Comment
Number:
30509­
053000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
arguably
the
most
damaging
pest
to
corn.
Previously,
in
our
region
of
the
eastern
Corn
Belt,
growers
could
control
corn
rootworm
by
means
of
crop
rotation.
With
the
spread
of
a
variant
of
the
western
corn
rootworm,
crop
rotation
is
no
longer
effective.
As
I
expect
you
are
aware,
this
has
forced
a
vast
number
of
corn
growers
to
apply
rootworm
insecticides
on
all
of
their
acres
going
to
corn
rather
than
just
on
continuous
corn
acres.
Hence,
insecticide
use
in
the
eastern
Corn
Belt
has
greatly
increased.

While
rootworm
insecticide
products
are
safe
when
handled
correctly
and
carefully,
growers
would
gladly
Section
6.0
6
­
2
switch
to
a
safer
product
if
it
were
available.
I
believe
corn
rootworm
protected
corn
would
be
safer
to
the
grower
and
safe
to
the
environment.

Commenter
Name:
Mark
Gruhn
Commenter
Organization
Name:
Mark
Gruhn
Comment
Number:
30509­
054000
Excerpt
Number:
1
Excerpt
Text:
1.
In
the
last
15
years
CRW
has
become
a
problem
in
rotated
crop
ground
due
to
extended
diapause
(
extended
egg
hatch)
and
the
recent
habit
of
the
western
CRW
laying
its
eggs
in
Soybean
stubble
poised
for
the
following
year's
corn
crop.
These
problems
are
spreading
and
becoming
common
in
key
areas
of
the
corn
belt.
Because
of
this,
CRW
insecticide
use
will
continue
to
increase.

2.
When
unprotected
corn
is
attacked
by
CRW
the
stalks
are
usually
goosenecked
or
even
flat
(
good
luck
with
harvest)
and
are
usually
holding
a
much
smaller
ear.

3.
I
can
remember
walking
through
corn
fields
a
day
or
two
after
a
rain
and
seeing
the
ground
pretty
much
covered
with
earthworms
that
the
insecticide
had
killed.

4.
If
we
want
more
targeted
pest
control
for
the
sake
of
the
environment,
and
if
we
want
safer
working
conditions
for
our
farmers,
and
if
we
want
high
yields
to
feed
a
starving
world,
and
if
we
can
do
these
things
while
supplying
a
consumer
safe
product,
then
isn't
technology
such
as
this
a
'
yes'
answer
to
prayer?

Commenter
Name:
Phillip
Sloderbeck
Commenter
Organization
Name:
Phillip
Sloderbeck
Comment
Number:
30509­
056000
Excerpt
Number:
1
Excerpt
Text:
I
am
writing
to
support
the
registration
of
corn
rootworm
protected
corn.
As
an
Extension
specialist
at
Kansas
State
University,
I
have
been
involved
with
corn
production
in
southwest
Kansas
for
nearly
20
years.
Corn
rootworms
are
a
major
pest
of
much
of
irrigated
corn
in
this
area.
Economics
and
limited
cropping
options
often
demand
that
much
of
our
irrigated
ground
be
used
for
continuous
corn
production,
which
has
lead
to
serious
corn
rootworm
problems.

Commenter
Name:
Roger
Youngman
Commenter
Organization
Name:
Virginia
Tech
University
Comment
Number:
30509­
061000
Excerpt
Number:
2
Excerpt
Text:
One
of
the
most
important
pests
of
field
corn
in
Virginia
is
the
western
corn
rootworm.
This
pest
was
first
detected
in
Virginia
in
1985
and
now
occurs
throughout
all
of
the
state's
continuous
corn
growing
areas.
The
results
of
state­
wide
surveys
I
conducted
in
1989
and
1999
indicated
that
growers
consider
corn
rootworms
as
one
of
their
main
reasons
for
basing
their
decision
to
apply
soil
insecticides
at
planting.
These
surveys
were
conducted
to
gain
insight
into
grower
pest
management
practices
and
their
use
of
soil
insecticides
on
corn
at
planting.
In
1989,
Virginia
corn
growers
reported
treating
37%
of
their
continuous
Section
6.0
6
­
3
corn
acres
with
a
soil
insecticide
at­
planting.
By
1999,
this
figure
jumped
to
62%
which
was
largely
due
to
increased
grower
awareness
of
the
potential
for
serious
damage
from
unchecked
corn
rootworm
populations.

Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
5
Excerpt
Text:
­
Based
on
the
1999
Doane
information
provided
by
Foundation
E.
A.
R.
T.
H.,
corn
rootworm
insecticide
users
in
the
ECB
and
WCB
grew
17.4
million
acres
of
corn
in
1999.
Almost
60%
of
those
acres
were
treated
with
an
insecticide
to
control
corn
rootworm.
The
results
of
this
research
suggest
that
the
introduction
of
CRW
corn
may
reduce
the
acres
treated
by
44%,
representing.
4.6
million
acres
in
the
first
year.
Since
the
current
average
use
rate
of
corn
rootworm
is
.5
pound
of
active
ingredient
per
acre,
this
would
result
in
a
reduction
of
2.4
million
pounds
of
soil­
applied
insecticide
active
ingredient.

Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
8
Excerpt
Text:
­
These
growers
have
had
some
experience
with
Bt­
corn
varieties,
since
28%
of
their
total
2000
corn
acres
were
planted
with
YieldGard
or
some
other
Bt­
com
variety.
Corn­
on­
corn
acres
were
twice
as
likely
to
be
planted
with
a
Bt­
corn
variety
than
first­
year
corn
acres
(
30%
vs.
13%).

­
When
asked
specific
details
regarding
the
insecticide
brands
used
on
their
2000
corn
acres,
Lorsban
was
applied
on
corn­
on­
corn
acres
by
22%
of
growers,
closely
followed
by
Force
(
21%).
­
Other
popular
insecticides
include
Aztec.,(
15%)
and
Counter
(
14%)
.
.
.

Commenter
Name:
Berg,
Mark
Commenter
Organization
Name:
Foundation
E.
A.
R.
T.
H.
Comment
Number:
30509­
078000
Excerpt
Number:
9
Excerpt
Text:
Twenty­
eight
percent
of
total
acres
planted
by
growers
who
used
a
soil­
applied
insecticide
were
planted
with
YieldGard
or
some
other
Bt­
corn
variety.
Corn­
on­
corn
acres
are
more
than
twice
as
likely
to
be
planted
with
a
Bt­
com
variety
than
first­
year
corn
acres
(
30%
vs.
13%).

­
When
comparing
the
Eastern
Corn
Belt
and
the
Western
Corn
Belt
in
regards
to
acres
planted
with
a
Bt
com.
variety,
growers
in
the
WCB
are
more
likely
to
plant
with
Bt­
corn
than
growers
in
the
ECB
(
28%
vs.
7%).
And,
they
are
almost
twice
as
likely
to
plant
Bt­
corn
on
corn­
on­
corn
acres
(
33%
Vs.
18%).

Commenter
Name:
David
Swinford
Section
6.0
6
­
4
Commenter
Organization
Name:
Texas
House
of
Representatives
Comment
Number:
30509­
095000
Excerpt
Number:
1
Excerpt
Text:
Corn
rootworm
is
a
significant
pest
problem
in
the
United
States.
Growers
throughout
the
country
use
insecticides
and
crop
rotation
in
an
effort
to
manage
this
pest
efficiently.
If
approved
in
the
United
States
and
other
key
export
markets,
corn
rootworm
protected
corn
could
be
the
first
biotech
product
of
its
kind
available
as
an
additional
pest
control
option
for
growers.

As
you
know,
corn
rootworm
can
cause
severe
yield
loss
if
left
untreated.
Yield
loss
typically
ranges
from
8
to
16
percent,
and
can
be
as
high
as
55
percent
including
increased
harvest
costs
from
lodging.
Chemical
insecticides
registered
for
corn
rootworm
control
were
applied
on
more
than
20
percent
of
U.
S.
corn
acreage
in
1998,
adding
up
to
some
16
million
acres
or
96
million
pounds
of
insecticides.
In
Texas
alone,
732,000
acres
were
treated
for
corn
rootworm
in
2000,
according
to
Doane
market
research.

Commenter
Name:
Thomas
Ewing
Commenter
Organization
Name:
Davis
and
Harman,
LLP
Comment
Number:
30509­
119000
Excerpt
Number:
1
Excerpt
Text:
Corn
rootworm
can
cause
severe
yield
loss
if
left
untreated.
Yield
loss
typically
ranges
from
8
to
16
percent,
and
can
be
as
high
as
55
percent
including
increased
harvest
costs
from
lodging.
[
Footnote
1:
Sutter,
G.
R.,
Fisher,
J.
R.,
Elliot,
N.
C.,
&
Branson,
T.
F.
(
1990)(
effect
of
insecticide
treatments
on
root
lodging
and
yields
of
maize
in
controlled
infestations
of
western
corn
rootworm
(
Coleoptera:
Chrysomelidae)),
Journal
of
Economic
Entomology,
83,
2414­
2420,;
Spike,
B.
P.,
&
Tollefson,
J.
J.
(
1991)(
yield
response
of
corn
subjected
to
western
corn
rootworm
(
Coleoptera:
Chrysomelidae)
infestation
and
lodging),
Journal
of
Economic
Entomology,
84,
1585­
1590;
and
Gibb,
T.
J.,
&
Higgins,
R.
A.
(
1991)(
aboveground
dry
weight
and
yield
responses
of
irrigated
field
corn
to
defoliation
and
root
pruning
stress),
Journal
of
Economic
Entomology,
84,
1562­
1576]
Chemical
insecticides
registered
for
corn
rootworm
control
were
applied
on
more
than
20
percent
of
U.
S.
corn
acreage
in
1998,
adding
up
to
some
16
million
acres
or
96
million
pounds
of
insecticides.
[
Footnote
2:
Doane
Market
Research,
1998]
In
Illinois
alone,
2.9
million
acres
were
treated
for
corn
rootworm
in
2000.
[
Footnote
3:
Doane
Market
Research,
2000]

Commenter
Name:
Steven
Pueppke
Commenter
Organization
Name:
University
of
Illinois
at
Urbana­
Champaign
Comment
Number:
30509B­
019000
Excerpt
Number:
1
Excerpt
Text:
Corn
rootworm
is
the
single
most
important
pest
problem
in
this
country.
According
to
USDA
estimates,
economic
damages
exceed
$
1
billion
annually.
Currently,
this
pest
is
managed
by
a
combination
of
insecticide
applications
and
crop
rotations.

Commenter
Name:
Jeff
Sernett
Section
6.0
6
­
5
Commenter
Organization
Name:
Jeff
Sernett
Comment
Number:
30509B­
025000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
a
major
pest
to
corn
growers
and
can
cause
losses
well
in
excess
of
$
1
billion
annually.
This
pest
is
perennial
and
will
create
lodging,
harvest
ability
and
grain
quality
losses
which
result
in
lower
quality
grain,
less
of
it,
and
subsequently
results
in
lower
net
income
at
the
farm
gate.
Insecticides
and
crop
rotation
have
been
the
historic
means
of
management
and
the
pest
has
evolved
"
around"
the
cultural
management
tool
of
rotation
to
become
annually
damaging.

Commenter
Name:
Jeff
Hinen
Commenter
Organization
Name:
Jeff
Hinen
Comment
Number:
30509B­
029000
Excerpt
Number:
1
Excerpt
Text:
As
a
farmer,
I
feel
that
in
order
to
be
productive
and
competitive
I
have
to
protect
my
crops
from
pests.
Corn
rootworm
is
one
of
the
toughest
and
most
damaging
pests
I
face
and
has
caused
me
significant
problems
in
the
past
with
my
corn
crop
and
cost
me
many
thousands
of
dollars
in
lost
yields.

Commenter
Name:
Martina
Newell
Commenter
Organization
Name:
UC
­
Systemwide
Biotechnology
Research
and
Education
Program
Comment
Number:
30509B­
030006
Excerpt
Number:
1
Excerpt
Text:
The
cost
to
farmers
through
yield
loss
and
control
measures
from
rootworm
damage
is
estimated
to
be
up
to
$
1
billion
per
annum.
The
efforts
to
control
this
pest
are
not
only
measured
in
dollars
and
time
but
also
in
cost
to
the
environment
and
worker
health.
Soil
insecticide
applications
for
corn
rootworm
control
are
currently
the
number
one
use
of
insecticides
in
the
United
States.

Commenter
Name:
Patty
Judge
Commenter
Organization
Name:
Iowa
Department
of
Agriculture
and
Land
Stewardship
Comment
Number:
30509B­
033000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
a
significant
pest
in
Iowa.
If
left
untreated,
it
can
cause
a
typical
yield
loss
of
8
to
16
percent,
but
also
as
high
as
55
percent,
including
increased
harvest
costs
from
lodging.

In
order
to
manage
this
pest
effectively,
growers
throughout
Iowa
use
insecticides
and
crop
rotation.
Recent
surveys
indicate
that
approximately
1.5
million
acres­
of
Iowa
farmland
are
treated
annually
for
corn
rootworm.
Insecticide
applications
for
corn
rootworm
are
the
number
one
use
of
all
insecticides
in
the
United
States.

Commenter
Name:
Joan
O'Brien
Commenter
Organization
Name:
Iowa
Seed
Association
Section
6.0
6
­
6
Comment
Number:
30509B­
043000
Excerpt
Number:
2
Excerpt
Text:
Corn
rootworm
is
a
significant
pest
in
Iowa
and
the
United
States.
If
left
untreated,
it
can
cause
a
typical
yield
loss
of
8
to
16
percent,
but
also
as
high
as
55
percent,
including
increased
harvest
costs
from
lodging.

In
order
to
manage
this
pest
effectively,
growers
throughout
Iowa
use
insecticides
and
crop
rotation.
Recent
surveys
indicate
that
over
1.5
million
acres
of
Iowa
farmland
were
treated
for
corn
rootworm.
Insecticide
applications
for
corn
rootworm
are
the
number
one
use
of
all
insecticides
in
the
United
States.

Commenter
Name:
Douglas
Tallamy
Commenter
Organization
Name:
University
of
Delaware
Comment
Number:
30509B­
053000
Excerpt
Number:
2
Excerpt
Text:
As
a
professor
of
entomology
at
the
University
of
Delaware,
I
have
been
involved
in
various
aspects
of
rootworm
research
for
nearly
20
years.
The
western
corn
rootworm
currently
poses
the
single
greatest
threat
to
US
agriculture
with
loses
exceeding
$
1
billion
each
year.
This
pressure
has
created
an
unprecedented
use
of
soil
insecticides,
exacerbating
problems
from
ground
water
contamination,
human
exposure,
nontarget
mortality,
and
storage,
transportation
and
disposal
of
chemical
insecticides.
Genetically
engineered
Bt
corn
products
address
all
of
these
problems
simultaneously.

I
recognize
that
the
public
has
been
led
to
believe
that
genetically
modified
agricultural
products
are
unsafe,
but
this
has
resulted
from
a
successful
campaign
to
play
on
emotion
and
the
fear
of
the
unknown
and
not
from
supportive
data.
Early
claims
of
a
threat
to
the
monarch
butterfly
have
since
been
refuted
by
several
studies.
Arguments
that
genetically
modified
pollen
will
contaminate
wild
relatives
and
organic
plots
are
baseless;
there
are
no
wild
corn
relatives
in
this
country
and
organic
farmers
buy
new
hybrid
seed
every
year.
The
fact
that
corn
pollen
blows
meters
rather
than
kilometers
is
rarely
mentioned
in
anti­
GMO
rhetoric.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Comment
Number:
30509B­
082000
Excerpt
Number:
9
Excerpt
Text:
Insecticides
are
widely
used
on
corn
in
the
United
States
for
corn
rootworm
control.
The
U.
S.
Department
of
Agriculture,
National
Agricultural
Statistical
Service
report
"
Agricultural
Chemical
Usage:
2000
Field
Crop
Summary"
published
in
May
2001
(
Ag
Ch
1(
01)
b)
(
available
at
http://
usda.
mannllb.
comell.
edu/
reports/
nassr/
other/
pcu­
bb/
agcs0501.
pdf)
indicates
that
in
2000,
29%
of
U.
S.
corn
acres
were
treated
with
insecticides
(
p.
2).
Later
tables
in
the
report
indicate
aggregate
statistics
by
state
for
those
interested,
but
in
major
corn
producing
states
such
as
Iowa
and
Illinois,
16%
and
43%
of
corn
acres
were
treated
with
insecticides
respectively
(
P.
15).
The
main
point
is
that
insecticides
are
commonly
applied
to
corn
grown
in
the
U.
S.

Data
from
the
U.
S.
Department
of
Agriculture­
Economics
Research
Service's
Cropping
Practices
Survey
Section
6.0
6
­
7
are
available
for
1990­
1995
(
http://
usda.
mannlib.
comell.
edu/
data­
sets/
inputs/
93018/).
Comparable
data
collected
by
the
U.
S.
Department
of
Agriculture
more
recently
as
part
of
the
Agricultural
Resource
Management
Study
(
ARMS)
survey,
which
replaced
the
Cropping
Practices
Survey,
are
not
available
for
public
use.
Examining
the
1995
Cropping
Practices
Survey
for
corn
indicates
that
corn
rootworm
larvae
were
the
most
common
target
for
insecticide
applications
in
corn
(
I
calculate
36.8%
of
the
applications).
I
calculate
that
corn
rootworm
adults
were
the
target
of
13.1
%
of
the
applications.

For
comparison,
I
calculate
that
European
corn
borer
and
Southwestern
corn
borer,
the
pests
targeted
by
Bt
corn
for
corn
borer
control,
were
the
target
of
8.0%
and
5.6%
of
the
insecticide
applications
in
1995
on
corn
acres
in
the
U.
S.
Even
with
these
figures,
about
20%
of
U.
S.
corn
acreage
in
2001
was
planted
to
Bt
corn
for
corn
borer
(
U.
S.
Department
of
Agriculture­
National
Agricultural
Statistics
Service.
"
Crop
Production­­
Acreage­­
Supplement
(
PCP­
BB)."
<
http://
usda.
mannlib.
comell.
edu/
reports/
nassr/
field/
pcpbba/>
June
29,
2001
a).
Bt
corn
for
corn
borers
has
had
little
impact
on
the
use
of
insecticides
on
corn
for
two
reasons.
First,
few
acres
were
treated
with
insecticides
for
corn
borers
before
Bt
corn
for
corn
borers
was
available.
Second,
even
when
planting
Bt
corn
for
corn
borers,
insecticides
are
needed
to
control
other
pests
such
as
corn
rootworm.

The
fact
that
20%
of
corn
acres
have
been
panted
to
Bt
corn
for
corn
borer
the
last
two
years
indicates
that
the
adoption
of
Bt
corn
for
corn
rootworm
control
will
potentially
be
even
greater.
Actual
adoption
rates
will
depend
on
factors
such
as
the
price
of
the
technology
and
the
price
of
substitute
insecticides.
The
main
point
I
wish
to
make
is
that
the
primary
reason
so
many
acres
of
corn
are
treated
in
the
U.
S.
is
to
control
corn
rootworm
and
the
adoption
of
Bt
corn
for
corn
rootworm.
control
is
likely
to
be
rapid
and
more
likely
to
reduce
insecticide
use
than
Bt
corn
for
corn
borers.

Commenter
Name:
Paul
Mitchell
Commenter
Organization
Name:
Texas
A&
M
University
­
Department
of
Agriculture
Economics
Comment
Number:
30509B­
082000
Excerpt
Number:
10
Excerpt
Text:
Previously,
rotating
corn
to
a
non­
corn
crop
such
as
soybeans
provided
effective
corn
rootworm.
control
so
that
soil
insecticides
were
unnecessary
in
first
year
corn.
However,
the
recent
development
and
spread
of
rotation
resistance
among
western
corn
rootworm
and
of
extended
diapause
among
northern
corn
rootworm
are
likely
to
increase
the
use
of
corn
rootworm
control
by
insecticides
or
other
means
such
as
transgenic
corn.

Rotation
resistance
first
appeared
among
western
corn
rootworm
in
east­
central
Illinois
and
has
spread
eastward
into
Indiana,
Michigan
and
Ohio
(
Levine,
and
Oloumi­
Sadeghi.
1996.
J.
Econ.
Entomol.
89:
1010­
1016,
Onstad
et
al.
1999.
Environ.
Entomol.
28:
188­
194).
Adult
females
of
rotation
resistant
western
corn
rootworm
lay
eggs
not
only
in
corn,
but
also
in
other
crops.
As
a
result,
in
areas
where
a
corn­
soybean
rotation
is
common,
eggs
laid
in
soybean
fields
hatch
in
a
corn
field
the
next
spring.
As
a
result,
farmers
in
affected
areas
have
begun
using
insecticides
on
first­
year
corn
when
farm
previously
insecticides
were
not
needed,
since
first­
year
corn
was
highly
unlikely
to
have
any
corn
rootworm
larvae.

As
an
example
of
the
expected
yield
impact
of
rotation
resistant
western
corn
rootworm
in
Illinois,
I
have
made
a
copy
of
a
working
paper
by
Mitchell,
Gray
and
Steffey
(
2002)
available
Section
6.0
6
­
8
(
http:
Hagecon.
tamu.
edu/
publications/
fpO2­
02.
pdf).
It
is
a
working
paper
and
as
­
such
has
not
been
peer
reviewed.
I
have
distributed
it
to
colleagues
around
the
U.
S.
for
an
informal
pre­
submission
review.
It
is
not
ready
for
submission,
but
I
believe
the
empirical
results
are
valid.
The
estimated
average
yield
loss
due
to
rotation
resistant
western
corn
rootworm
is
11.6%,
indicating
the
tremendous
financial
pressure
farmer
feel
to
use
some
sort
of
corn
rootworm
control
on
first
year
corn
in
affected
areas.

Extended
diapause
has
been
previously
noted
among
northern
corn
rootworm,
but
the
proportion
of
the
population
that
expresses
the
trait
has
grown
in
many
areas,
especially
in
western
Corn
Belt
states
such
as
South
Dakota,
Minnesota
and
northwestern
Iowa.
Typically,
corn
rootworm
eggs
hatch
after
only
one
winter,
but
with
extended
diapause,
the
eggs
hatch
after
two
or
more
winters.
As
a
result,
in
areas
where
a
corn­
soybean
rotation
is
common,
eggs
laid
in
corn
fields
hatch
after
two
winters,
when
the
field
is
again
a
corn
field.
As
a
result,
farmers
in
affected
areas
have
begun
using
insecticides
on
first­
year
corn
when
previously,
insecticides
were
not
needed,
since
first­
year
corn
was
highly
unlikely
to
have
any
corn
rootworm
larvae.

Commenter
Name:
Julie
Doane
Commenter
Organization
Name:
Julie
Doane
Comment
Number:
30509B­
091000
Excerpt
Number:
3
Excerpt
Text:
Today,
corn
rootworm
is
the
most
significant
agricultural
pest
problem
in
the
United
States.
Yield
loss
and
insecticide
control
costs
from
corn
rootworm
feeding
damage
are
estimated
by
the
USDA
at
$
1
billion
annually.
Currently,
farmers
use
insecticides
and
crop
rotation
to
manage
this
pest.
Your
approval
of
corn
rootworm­
protected
corn
would:

Commenter
Name:
Nicholas
Schneider
Commenter
Organization
Name:
Golden
Harvest,
Thorp
Seed
Co.
Comment
Number:
30509B­
092012
Excerpt
Number:
1
Excerpt
Text:
In
the
past,
simply
rotating
corn
with
soybeans
worked
fairly
well
at
maintaining
corn
rootworm
feeding
damage
below
economic
thresholds.
However,
two
distinct
changes
in
corn
rootworm
habit
have
made
crop
rotation
much
less
effective
for
controlling
rootworm.
Extended
diapause
of
corn
rootworm
egg
hatching
and
corn
rootworm
beetles
laying
eggs
in
soybeans
are
two
behavior
changes
that
have
made
controlling
corn
rootworm
more
difficult
in
recent
years.
As
a
result,
insecticides
applied
at
corn
planting
have
become
a
routine
production
cost
for
many
growers!

Commenter
Name:
Clinton
Pilcher
Commenter
Organization
Name:
Clinton
Pilcher
Comment
Number:
30509B­
092015
Excerpt
Number:
1
Excerpt
Text:
Today,
corn
rootworm
is
the
most
significant
agricultural
pest
problem
in
the
United
States.
Yield
loss
and
insecticide
control
costs
from
corn
rootworm
feeding
damage
are
estimated
by
the
USDA
at
$
1
billion
annually.
Currently,
farmers
use
insecticides
and
crop
rotation
to
manage
this
pest.
Section
6.0
6
­
9
Commenter
Name:
Bryan
Hurley
Commenter
Organization
Name:
Bryan
Hurley
Comment
Number:
30509B­
092027
Excerpt
Number:
2
Excerpt
Text:
It
is
my
understanding
that
this
technology
will
have
important
benefits
for
both
America's
farmers
and
consumers.
Importantly,
by
the
USDA's
own
estimates,
the
corn
rootworm
inflicts
more
than
$
1
billion
of
damage
annually
to
America's
farmers
and
their
corn
crops
With
corn
commodity
prices
sagging
at
record
lows,
we
need
more
than
ever
to
explore
technology
options
that
will
give
American
farmers
the
tools
to
help
improve
their
production
efficiency
and
their
overall
economic
gain.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
3
Excerpt
Text:
The
event
MON
863
is
a
Bt
gene
inserted
in
the
corn
plant
for
protection
from
the
corn
rootworm.
The
corn
rootworm
is
the
number
one
pest
that
farmers
apply
insecticides
to
control.
Historically,
rotating
crops
in.
the
field
controlled
the
corn
rootworm:
planting
corn
followed
by
Soybeans
is
a
typical
rotation
in
Iowa.
However,
this
strategy
has
become
less
effective
because
the
corn
rootworm
has
developed
an
extended
diapause
which
allows
the
insect
to
survive
in
the
same
field
through
one
year
of
soybean
production.
When
corn
is
planted
in
subsequent
years,
the
corn
rootworm
infests
the
field
and
causes
damage.

Commenter
Name:
ICGA
Commenter
Organization
Name:
ICGA
Comment
Number:
30509B­
093000
Excerpt
Number:
5
Excerpt
Text:
The
corn
rootworm
has
a
significant
impact
on
agriculture.
According
to
USDA,
yield
loss
and
insecticide
control
costs
from
corn
rootworm.
damage
is
approximately
$
1
billion
annually.

Commenter
Name:
Jim
Steward
Commenter
Organization
Name:
Steward
Seeds,
Inc.
Comment
Number:
30509B­
L001
Excerpt
Number:
1
Excerpt
Text:
Each
year,
corn
rootworm
causes
over
$
1
billion
dollars
of
damage
that
comes
directly
out
of
the
pockets
of
farmers.
Lodging
and
root
feeding
can
cause
losses
up
to
over
50%
in
severe
cases
and
often
over
10%
with
limited
damaged.
This
loss
can
be
virtually
eliminated!

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Memebers
Comment
Number:
OPP02­
0016
Excerpt
Number:
1
Section
6.0
6
­
10
Excerpt
Text:
Corn
rootworms
are
certainly
a
worthy
target
of
biotechnology.
Although
crop
rotation
drastically
reduces
the
losses
corn
rootworms
could
cause,
the
complex
of
four
corn
rootworm
species
(
western
[
Footnote
1:
western
corn
rootworm,
Diabrotica
virgifera
virgifera
LeConte],
Mexican
[
Footnote
2:
Mexican
corn
Rootworm,
D.
virgifera
Krysan
&
Smith],
northern
[
Footnote
3:
northern
corn
rootworm,
D.
barberi
Smith
&
Lawrence],
and
southern
[
Footnote
4:
southern
corn
rootworm,
D.
undecimpunctata
Barber])
which
attacks
corn
in
the
U.
S.
costs
corn
growers
more
than
a
billion
dollars
in
crop
losses
and
insecticide
expenditures
annually
and
makes
corn
rootworms
the
primary
target
of
insecticide
use
on
corn
in
the
U.
S.
The
western
and
northern
corn
rootworms
are
the
key
pest
species
in
the
U.
S.
Corn
Belt
while
the
western
and
Mexican
corn
rootworms
are
the
predominant
pest
species
in
Texas.
Although
the
southern
corn
rootworm
can
be
found
in
most
states
east
of
the
Rocky
Mountains,
it
is
usually
only
a
pest
species
of
field
corn
in
the
southeast
U.
S.
Each
year,
more
acres
of
corn
are
treated
with
insecticide
for
this
pest
complex
than
any
other
single
insect
in
a
single
crop.

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Memebers
Comment
Number:
OPP02­
0016
Excerpt
Number:
13
Excerpt
Text:
­
Female
corn
rootworms
usually
mate
within
24­
48
hours
near
where
they
emerged
(
usually
within
the
same
corn
field)
while
ECB
females
often
move
to
gassy
areas
outside
of
corn
fields
(
especially
in
dryland
corn)
to
obtain
water
and
mate.

Commenter
Name:
Lance
Meinke
Commenter
Organization
Name:
NCR­
46
Memebers
Comment
Number:
OPP02­
0016
Excerpt
Number:
16
Excerpt
Text:
­
Corn
rootworms
may
only
be
part
of
the
spectrum
of
insect
pests
that
a
farmer
wishes
to
control.
For
example,
farmers
may
choose
a
planting­
time
management
tactic
(
e.
g.,
soil
insecticide
or
seed
treatment)
because
it
controls
corn
rootworms
and
other
soil
insect
pests
(
seedcom
maggots,
seedcom
beetles,
wireworms,
white
grubs,
flea
beetles,
or
cutworms).
Decisions
about
corn
rootworm,
transgenics
are
not
independent
of
the
need
to
manage
these
other
pests.
Over
the
last
few
years,
problems
with
soil
insects,
particularly
wireworms,
white
grubs,
flea
beetles
and
seedcom
maggots,
have
been
increasing
in
the
Midwest.

Commenter
Name:
N/
A
Commenter
Organization
Name:
Center
for
Science
in
the
Public
Interest
Comment
Number:
OPP02­
0028
Excerpt
Number:
1
Excerpt
Text:
Center
for
Science
in
the
Public
Interest
[
Footnote
1:
CSPI
is
a
nonprofit
education
and
advocacy
organization
that
focuses
on
improving
the
safety
and
nutritional
quality
of
our
food
supply
and
on
reducing
the
carnage
caused
by
alcoholic
beverages.
CSPI
seeks
to
promote
health
through
educating
the
Section
6.0
6
­
11
public
about
nutrition
and
alcohol;
it
represents
citizens'
interests
before
legislative,
regulatory,
and
judicial
bodies;
and
it
works
to
ensure
advances
in
science
are
used
for
the
public
good.
CSPI
is
supported
by
the
more
than
800,000
member­
subscribers
to
its
Nutrition
Action
Healthletter,
through
foundation
grants,
and
through
sales
of
educational
materials.]
(
CSPI)
appreciates
the
opportunity
to
comment
on
Monsanto
Co.'
s
application
to
register
MON
863
corn.
Corn
rootworms
(
CRW),
the
target
of
MON
863,
are
extremely
destructive
pests.
More
chemical
insecticide
is
used
to
control
CRW
then
any
other
insect
pests
of
corn
in
the
U.
S.
The
insecticides
that
control
CRW
include
several
organophosphates,
which
can
have
serious
adverse
effects
on
humans
and
the
environment.
In
addition,
rotation
of
corn
with
soybeans,
which
reduces
insecticide
use,
is
no
longer
controlling
CRW
in
some
regions.
As
those
regions
expand,
chemical
insecticide
use
can
be
expected
to
increase.

Commenter
Name:
NONE
Commenter
Organization
Name:
NONE
Comment
Number:
OPP02­
0035
Excerpt
Number:
3
Excerpt
Text:
Pest
Biology
­
One
generation
a
year
­
Over­
winter
egg
mortality
­
Earliest
developing
larvae
have
higher
mortality
due
to
unavailability
of
sufficient
roots
­
Limited
larval
movement
among
plants
­
Density­
dependent
larval
mortality
­
Random
mating
within
fields/
blocks,
density­
dependent
a
Females
mate
only
once;
males
can
mate
multiple
times
­
9­
14
day
pre­
oviposition
period
­
Fecundity
and
survival
decline
with
time
­
No
immigration
Commenter
Name:
Helen
Inman
Commenter
Organization
Name:
Helen
Inman
Comment
Number:
OPP02­
0036
Excerpt
Number:
4
Excerpt
Text:
Corn
rootworm
­
like
many
pests
­
is
extremely
expensive,­
costing
producers
millions
of
dollars
in
lost
yields.
While
crop
rotation
mitigates
some
damage,
we
still
need
to
treat
some
acres
every
year.
These
treatments
cost
about
$
15
to
$
20
an
acre,
or
$
7,500
to
$
10,000
on
a
500­
acre
farm.

EPA
Response:
The
Agency
agrees
with
the
comments
that
the
corn
rootworm
is
the
most
important
insect
pest
in
terms
of
insecticide
use
and
potential
economic
damage
and
that
due
to
behavioral
adaptations,
crop
rotation
is
less
effective
than
in
the
past
and
that
the
area
infested
by
CRW
is
increasing.
Holding
the
price
of
corn
and
the
cost
of
alternative
treatments
constant,
the
corn
acres
treated
to
control
CRW
will
increase
as
the
infested
acreage
increases.
These
factors
are
considered
in
the
benefits
assessment.

Commenter
Name:
Ron
Fitchorn
Section
6.0
6
­
12
Commenter
Organization
Name:
Illinois
Corn
Growers
Association
Comment
Number:
30509­
104000
Excerpt
Number:
4
Excerpt
Text:
We
are
specifically
concerned
about
the
impact
this
technology
could
have
on
our
corn
gluten
market.
Although
we
ship
little
corn
the
European
Union,
Illinois
annually
ships
millions
of
bushels
of
corn
equivalent
in
the
form
of
corn
gluten
to
this
market.
Loss
of
this
market
over
inadvertent
introduction
of
this
technology
would
be
devastating
the
Illinois
farmers
who
export
more
than
40%
of
their
corn
crop.

EPA
Response:
The
Agency
recognizes
the
concern
that
biotechnology
has
introduced
to
foreign
trade
issues
and
has
included
these
costs
in
the
computation
of
economic
benefits.
The
model
includes
an
estimate
of
the
negative
costs
associated
with
the
technology
and
includes
such
factors
as
discounts
due
to
limited
marketability,
refuge
requirements,
or
any
other
costs
associated
with
this
technology.
Also,
the
cry3Bb
protein
has
been
approved
for
use
in
food
and
feed.
There
are
no
health
related
reasons
why
corn
gluten
cannot
be
consumed
when
corn
is
grown
using
MON
863.

Commenter
Name:
Charles
Benbrook
Commenter
Organization
Name:
Union
of
Concerned
Scientists
Comment
Number:
30509­
115000
Excerpt
Number:
17
Excerpt
Text:
A
critical
change
has
occurred
in
corn
insect
population
dynamics
as
a
result
of
a
behavioral
adaptation
of
the
Western
corn
rootworm
(
WCR).
Rotating
corn
with
soybeans
has
been
recommended
for
decades
and
widely
practiced,
and
is
one
of
the
great
success
stories
in
IPM.
On
continuous
corn
acres
in
the
1990s,
farmers
apply
corn
rootworm
insecticides
on
90
percent
or
more
of
acres
planted,
while
less
than
15
percent
of
rotated
corn
has
been
treated.

The
reliability
of
the
corn­
soybean
rotation
in
limiting
WCR
pressure
set
the
stage
for
trouble.
Both
farmers
and
scientists
were
lulled
into
thinking
that
no
other
steps
were
needed
in
managing
this
pest.
Evolution
is
a
powerful
and
patient
force.
In
the
mid­
1980s
University
of
Illinois
corn
IPM
specialist
Dr.
Michael
Gray
documented
the
first
signs
of
trouble
­­
isolated
but
economically
significant
Western
corn
rootworm
damage
in
first­
year
corn
following
soybeans.

Over
the
next
10
years
the
pattern
of
WCR
infestation
was
uneven
and
sporadic.
Some
seasons,
like
the
wet
crop
year
in
1998,
did
not
favor
WCRs
and
populations
never
reached
damaging
levels.
But
in
recent
years
it
has
become
clear
that
the
Western
corn
rootworm
has
developed
behavioral
resistance
to
a
management­
based
control
strategy,
in
this
case
crop
rotation.
This
change
in
rootworm
behavior
has
led
to
an
increase
in
insecticide
use
since
1996
in
parts
of
the
Midwest.
It
has
also
heightened
grower
interest
in
Integrated
Pest
Management
(
IPM)
strategies,
including
area­
wide
population
suppression
strategies
being
developed
by
a
multi­
state
USDA­
funded
team,
as
well
as
non­
engineered
varieties
bred
to
resist
corn
rootworm
feeding
damage.

Corn
Rootworms
Pose
Tough
Management
Challenges
Section
6.0
6
­
13
Only
a
few
insects
are
resistant
to
more
insecticides
than
the
corn
rootworm
(
CRW).
Populations
are
resistant
to
chemicals
in
all
major
classes
of
insecticides.
The
Monsanto
document
setting
forth
the
Cry
3Bb
resistance
management
plan
provides
a
brief
summary
of
the
historical
evolution
of
resistance.

Organochlorine
(
DDT)
use
started
in
the
late
1940s
and
resistance
was
first
documented
in
Nebraska
in
the
late
1950s.
Aldrin
and
dieldrin
use
began
in
1952
and
heptachlor
use
in
1954.
Resistant
populations
to
these
cyclodiene
insecticides
emerged
about
10
years
later
and
were
100
to
1,000­
fold
less
sensitive
than
susceptible
populations.

Organophosphate
and
carbamate
insecticides
were
introduced
in
the
1960s
and
pockets
of
resistance
began
to
emerge
in
the
1970s.
Synthetic
pyrethroids
were
introduced
in
the
1980s
and
provided
farmers
another
option
to
rotate
families
of
chemistry,
a
common
practice
that
has
slowed
the
evolution
of
resistance.

The
challenge
in
managing
resistance
to
Cry3Bb
corn
varieties
will
be
significant.
According
to
Dr.
Gray:

I
suggest
that
the
potential
for
resistance
development
by
corn
rootworms
is
much
more
acute
than
for
European
corn
borer,
Ostrinia
nubilalis
(
Hubner). 
Even
with
[
resistance
management]
strategies
in
place,
in
my
opinion,
resistance
will
develop
eventually."
(
Gray,
2000).

According
to
Gray,
"
Corn
rootworms
have
shown
repeatedly
that
they
are
superbly
capable
of
adapting
to
a
variety
of
insecticides
and
even
to
a
cultural
practice.
Any
notion
that
they
will
not
develop
resistance
to
transgenic
insecticidal
cultivars
at
some
point
is
foolhardy"
(
Gray,
2000).

Corn
rootworm
adults
are
highly
mobile.
During
its
adult
stage,
the
Southern
corn
rootworm
is
also
known
as
the
spotted
cucumber
beetle,
a
common
vegetable
pest
that
can
thrive
on
a
wider
variety
of
crops
than
Northern
and
Western
corn
rootworms.
The
Monsanto
application
cites
data
showing
that
the
Western
corn
rootworm
can
survive
on
21
species
and
the
Northern
corn
rootworm
on
14
species.

Commenter
Name:
Charles
Benbrook
Commenter
Organization
Name:
Union
of
Concerned
Scientists
Comment
Number:
30509­
115000
Excerpt
Number:
20
Excerpt
Text:
The
behavioral
change
in
Western
corn
rootworms
has
undermined
the
confidence
of
some
farmers
in
the
efficacy
of
crop
rotations.
Still,
rotations
remain
the
backbone
of
corn
IPM
systems.
According
to
Illinois
entomologist
Michael
Gray,
additional
control
tactics
and
attention
to
IPM­
system
details
are
needed
to
augment
rotation­
based
IPM
systems
(
Gray,
2000).

Less
than
10
percent
of
the
acres
planted
to
corn
following
soybeans
or
another
crop
require
an
insecticide
treatment.
The
extra
expense
of
Cry
3Bb
corn
would
also
not
be
justified
on
these
acres.
Gray
writes
that,
"
Economic
infestation
levels
of
corn
rootworm
larvae
do
not
occur
in
most
cornfields.
This
knowledge
supports
the
use
of
established
scouting
techniques
for
adult
corn
rootworms
in
late
summer
and
the
use
of
transgenic
hybrids
for
corn
rootworms
the
subsequent
spring
in
only
those
fields
that
exceeded
economic
thresholds."
(
Gray,
2000).
Section
6.0
6
­
14
In
addition,
area­
wide
CRW
population
suppression
systems
are
under
development
and
show
promise.
New
approaches
show
promise
in
targeting
insects
at
multiple
stages
in
their
lifecycle,
when
control
interventions
can
be
carried
out
economically
and
safely.
Area­
wide
management
strategies,
coupled
with
new
ways
to
design
field­
edge
habitats
supportive
of
natural
enemies,
may
prove
to
be
highly
costeffective
and
adequate
to
restore
the
former
efficacy
of
the
corn­
soybean
rotation
in
management
of
corn
rootworms
(
Landis,
et
al.,
2000).

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
2
Excerpt
Text:
It
is
widely
accepted
that
corn
rootworms
(
CRW)
are
much
more
damaging
insects
than
ECBs
(
Gray
and
Luckman,
1994).
When
rootworm
populations
reach
or
exceed
thresholds
during
a
corn
crop's
vulnerable
period,
control
measures
are
strongly
recommended
to
avoid
economic
losses
(
Grey
and
Steffey,
1998).
According
to
the
Monsanto
application,
"
CRW
is
the
most
significant
insect
pest
problem
for
corn
production
in
the
U.
S.
Corn
Belt
from
the
standpoint
of
chemical
insecticide
usage"
(
Monsanto
#
00­
CR­
032E­
6,
January
8,
2002).
The
linkage
between
ECB
populations
and
damage
is
more
circumstantial
­
sometimes
relatively
high
populations
result
in
only
modest
or
no
damage
because
of
either
the
vigor
of
the
crop
or
ECB
population
crashes
triggered
by
weather
or
other
conditions
(
Grey
and
Luckman,
1994).

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
1
Excerpt
Text:
The
corn
rootworm
complex
of
insect
pests
has
triggered
more
insecticide
use
in
the
United
States
than
any
other,
with
the
possible
exception
of
the
cotton
budwormbollworms.
[
Footnote
2:
When
use
is
measured
by
pounds
of
insecticide
applied,
corn
rootworm
complex
insecticide
use
almost
certainly
exceeds
cotton
budworm­
bollworm
use.
Measured
as
the
number
of
acre­
treatments,
budwormboll
worm
use
would
likely
exceed
the
number
of
corn
rootworm
complex
applications.
In
almost
all
instances,
only
one
application
of
an
insecticide
is
made
per
year
to
treat
corn
rootworms,
while
multiple
applications
are
the
norm
in
cotton
insect
pest
management.]
Four
principal
species
make
up
the
corn
rootworm
complex:
northern
corn
rootworms,
western
corn
rootworms,
southern
corn
rootworms,
and
Mexican
corn
rootworms.
These
insects
overwinter
in
the
soil,
hatch
as
larvae
in
the
spring,
attacking
corn
roots
as
their
sole
or
primary
feed
source,
and
emerge
as
adults
in
early
summer.
The
insect
goes
through
one
generation
each
year.
Rootworm
damage
to
corn
plants
is
done
as
larvae;
the
most
common
way
and
time
for
farmers
to
intervene
in
an
effort
to
reduce
yield
losses
is
applying
insecticides
at
planting
time
to
limit
feeding
damage
on
roots
in
the
first
six
to
eight
weeks
of
the
corn
production
cycle.

Since
the
1970s
about
one­
third
of
corn
acres
have
been
treated
annually
with
insecticides
for
all
insects
(
see
bottom
line
in
Table
1
at
the
end
of
these
comments;
e.
g.,
32.4
percent
of
corn
acres
in
2000
were
treated
with
an
insecticide).
[
Footnote
3:
Unless
otherwise
noted,
all
pesticide
use
data
in
these
comments
are
from
annual
field
crop
agricultural
chemical
use
reports
issued
by
the
USDA's
National
Agricultural
Statistics
Service
(
NASS).]
Management
of
the
European
corn
borer
(
ECB)
has
led
to
applications
on
6.5
Section
6.0
6
­
15
percent
to
8.1
percent
of
corn
acres
since
1995.
This
share
of
acres­
treated
includes
products
applied
just
for
ECB
control,
plus
one­
quarter
of
the
acres
treated
with
products
targeting
"
Multiple
Pests,"
(
see
the
"
Multiple
Pests"
rows
in
the
second
column
in
Table
1).
[
Footnote
4:
The
percent
of
applications
targeting
different
insect
pests
is
based
on
documents
published
by
land
grant
university
departments
of
entomology
and
communications
with
recognized
experts.]

The
corn
rootworm
complex
has
triggered
two­
thirds
or
more
of
annual
insecticide
applications
made
on
corn
acres.
In
2000,
a
total
of
32.4
percent
of
corn
acres
were
treated
with
an
insecticide.
About
23
percent
of
total
corn
acres
that
year
were
treated
for
corn
rootworm
management,
or
70.6
percent
of
total
corn
insecticide
treatments.
Nearly
all
these
applications
are
made
at
the
time
corn
is
planted,
with
insecticides
applied
directly
in
the
furrow.
[
Footnote
5:
Table
5
in
Monsanto's
interim
insect
resistance
management
plan
document
(
Vaughn
et
al.,
2001)
reports
marketshare
for
corn
insecticides
and
shows
that
only
5
percent
are
applied
as
adult
sprays,
and
the
majority
of
these
are
for
ECB
control.]
This
use
pattern
[
Footnote
6:
A
pesticide
"
use
pattern"
encompasses
the
number
and
timing
of
applications
and
the
method
and
rate
of
application
per
acre.]
minimizes
exposure
to
aboveground
nontarget
organisms.
Residues
in
harvested
corn
are
virtually
nonexistent
from
such
applications;
human
health
and
ecological
problems
can
arise
from
the
leaching
of
some
soilincorporated
insecticides
to
groundwater
or
into
surface
water
systems
through
field
drainage
systems.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
3
Excerpt
Text:
Until
the
early
1980s
most
farmers
routinely
rotated
corn
with
soybeans
for
pest
management
and
soil
fertility
benefits.
[
Footnote
7:
For
a
review
of
the
evolution
of
Midwestern
corn
rootworm
mangement
strategies
as
influenced
by
changes
in
insect
behavior,
see
Steffey
et
al.,
1992.]
For
decades
this
simple
cultural
practice
has
largely
eliminated
the
need
for
soil
insecticides
on
first­
year
corn,
[
Footnote
8:
"
First
year
corn"
refers
to
an
acre
planted
to
corn
that
produced
a
different
crop
the
year
before.]
but
in
recent
years
important
behavioral
changes
have
occurred
in
populations
of
the
western
and
northern
corn
rootworm
(
Grey,
2000;
Ostlie,
2001).
Populations
of
the
western
corn
rootworm
are
now
moving
in
the
fall
from
cornfields
into
nearby
soybean
fields,
where
they
deposit
theur
eggs
before
dying.
As
the
eggs
hatch
in
the
spring,
newly
planted
corn
is
vulnerable
and
supports
rapid
population
growth.
In
the
case
of
northern
corn
rootworm,
populations
with
an
extended
diapause
(
a
period
of
dormancy),
resulting
in
the
hatching
of
eggs
a
full
year
later
than
in
the
past,
have
also
lessened
the
efficacy
of
rotation
as
a
corn
rootworm
management
tool.

Commenter
Name:
Rissler
Commenter
Organization
Name:
UCS
Comment
Number:
30509B­
089000
Excerpt
Number:
4
Excerpt
Text:
Despite
the
changes
in
corn
rootworm
behavior
noted
above,
there
is
no
evidence
of
an
increase
in
corn
insecticide
use
targeting
the
rootworm
complex
through
crop
year
2000,
based
on
USDA
corn
pesticide
use
data.
Indeed,
the
percentage
of
corn
crop
acres
treated
has
fallen
about
3
percent
from
1998
to
2000.
The
Section
6.0
6
­
16
Monsanto
registration
documents
submitted
to
EPA
in
conjunction
with
its
Cry
3Bb
application
place
great
significance
on
these
behavioral
changes
in
making
the
case
for
MON
863
corn
(
e.
g.,
see
pages
27­
28,
Monsanto
00­
CR­
032E­
6).
Likewise,
Dr.
Ken
Ostlie,
University
of
Minnesota
corn
IPM
(
Integrated
Pest
Management)
expert,
highlights
the
significance
of
recent
changes
in
corn
rootworm
behavior
on
farmer
demand
for
insecticides
and/
or
transgenic
corn
varieties
in
a
Nature
Biotechnology
"
News
and
Views"
piece
addressing
the
need
for
and
potential
of
a
new
Dow­
Dupont
Bt­
RW
product
(
Ostlie,
2001).
A
November
2001
Farm
Journal
article
on
emerging
transgenic
corn
rootworm
products
notes
that
many
central
Corn
Belt
farmers
do
not
own
insecticide
application
equipment
anymore,
and
are
hoping
to
purchase
their
northern
corn
rootworm
protection
"
in
the
seed."

EPA
Response:
The
Agency
disagrees
with
the
conclusion
that
the
lack
of
evidence
of
increasing
corn
insecticide
use
implies
that
the
behavioral
adaptations
of
corn
rootworm
are
not
important
or
that
the
infested
acreage
is
not
increasing.
The
selling
price
of
corn,
after
adjustment
for
inflation,
has
significantly
decreased.
Average
selling
price
was
$
3.00
in
the
1990
to
1995
period,
$
2.26
in
the
1996
to
2001
period,
and
projected
to
be
$
2.00
in
2001.
This
means
that
the
economic
threshold
for
treatment
has
increased
which
is
a
major
factor
that
accounts
for
the
lack
of
growth
of
insecticide
treatments.
