As the 2012 planting season approaches, the National Corn Growers Association reminds farmers that newly revamped on-farm refuge assessments are part of the enhanced Compliance Assurance Program or CAP. The new rules aim to improve compliance with the U.S. Environmental Protection Agency's Insect Resistance Management requirements for Bt corn hybrids.

Corn growers found to be out of compliance with refuge requirements will be checked more frequently by Bt corn registrants (seed companies) and have a higher probability of losing access to Bt corn if compliance isn't established and maintained.

The Agricultural Biotechnology Stewardship Technical Committee, a consortium of firms that have Bt corn registered, submits an annual CAP report to EPA describing industry-coordinated compliance assurance efforts for Bt traits. The 2011 report is the first following implementation of the enhanced CAP last year.

New procedure designed to improve grower compliance with refuge requirement

"To put CAP into effect, technology providers made major changes to their procedures last year as directed by EPA," says Mike Smith, ABSTC IRM committee co-chairman. "One of the changes was the selection process for on-farm assessments. In past years, we've randomly selected those participants, but in 2011 we used a more targeted approach and conducted assessments based on purchase history, and as anticipated, using this method resulted in the identification of more non-compliant growers than in years past. Changes were also made to the grower survey and included more Bt corn products with differing refuge requirements."

Survey results include compliance with refuge requirements for corn borer traits and rootworm traits, either alone or in stacked Bt corn products, regardless of refuge size differences. Highlights of the report include:

*  The CAP for all Bt corn products with structured refuge requirements continues to be effective. In 2011, a majority of growers surveyed planted the required refuge size on their farms and the majority of growers surveyed planted a refuge within the required distance for all their Bt corn fields. Furthermore, the survey indicates the vast majority of all Bt corn fields have an associated refuge.

* The majority of growers found out of compliance in 2010 were found to be complying with IRM requirements during the 2011 growing season. This result is consistent with previous years and confirms that the CAP's phase compliance approach in which non-compliant growers were provided additional educational materials and re-assessed in 2011 is working.

* Targeted on-farm assessments identified more than three times as many corn growers who were out of compliance than in years past. Each member company independently reviewed available sales data for its Bt corn customers and assessments were conducted with growers who, according to sales records, may have bought little or no refuge seed. All non-compliant growers will undergo a second on-farm assessment to help ensure compliance in 2012.

"The objective of the on-farm assessment program is to identify individual non-compliant growers and bring them back into compliance through a phased approach," says Joanne Carden, ABSTC IRM committee co-chair. "The new approach to conducting IRM on-farm assessments has resulted in more non-compliant growers being identified, demonstrating that the enhanced CAP is working as planned."

Targeted approach was tried last year, found more growers not complying

Carden says the committee is pleased with the outcomes of the phased compliance approach based on the 2011 experience. "The goal of these enhancements is to help growers understand the importance of following refuge requirements, provide clarity on how to meet the minimum refuge requirement for each product and ultimately improve compliance," she says.

Calculator available to help growers develop plans for corn refuge compliance

Since the introduction of biotech traits, "the vast majority of growers have followed refuge requirements to help protect the effectiveness and usefulness of this important technology," says Chad Blindauer, chairman of the National Corn Growers Association Trade Policy and Biotechnology Action Team. "All growers must follow these requirements to help preserve the long-term value of these traits. We encourage growers to work with their seed dealers and seed companies to understand the enhanced requirements under the CAP and improve refuge compliance."

To assist farmers in developing an IRM plan and a refuge strategy for their farms, NCGA has established a number of resources, including recently launching an updated IRM calculator to clarify refuge system options and show growers how to fulfill the requirements properly. The IRM calculator was developed in collaboration with seed and biotech companies to ensure it reflects all Bt products available in the industry. Farmers can access the IRM calculator via computer or smart phone by logging on to www.irmcalculator.com.