5.2% of the acreage is sprayed annually for corn borers and in Iowa only 2.6%. Some of the reasons for the lack of chemical control are that the perceived yield loss has always been considered small (estimated at about 4%), the cost of pesticides is high relative to the crop 's value, and typical insecticides have not been very efficient at killing the pest after it bores into the plant.

In addition to the European corn borer, other insect pests are targeted by the Bt corn cultivars. For example, the southwestern corn borer, a major corn pest in some areas of the Midwest, can be controlled by Bt corn; and the corn earworm, a minor pest of field corn but a major pest of sweet corn, is also a potential target. A recent USDA study (1999d) indicates that in two of five regions mean yields were significantly higher with Bt corn than with non-Bt corn. How the increase in yield will affect farmers' profits is not evident, given increased seed cost and the increased potential for higher national production of corn which could lead to a decrease in prices.

At least three Bt toxins are produced by commercial transgenic pest-protected corn cultivars. The most common, Cry1Ab, is produced either as a full-length protoxin, as produced in B. thuringiensis (Monsanto variety), or as a truncated, preactivated toxin (Novartis variety). In nature, the 130 to 140 kilodalton protoxin is converted to a 60-65 kilodalton protein when the target insect ingests Bt (Federici 1998). Cry1Ac toxin is produced by the Dekalb cultivars; and a biochemically distinct Bt toxin, Cry9C, is produced by corn developed by AgrEvo (EPA 1998c). All the corn cultivars that produce Cry1A toxins have been approved for human consumption, but currently Cry9C corn has been approved only for cattle feed (EPA 1998c). That restriction by EPA has been established because the Cry9C toxin, unlike the Cry1A toxins, does not degrade rapidly in gastric fluids and is relatively more heat-stable; these characteristics of Cry9C raise concerns including those of allergenicity.

Novartis-produced Bt corn does not produce detectable levels of Bt toxin in the silks or corn kernels, so it does not effect the corn earworm, which feeds mostly on these two plant parts. The Cry9C toxin in AgrEvo corn is produced in the silk and corn ear, but it is not toxic to the corn earworm. The biological complexity of current Bt corn products is much greater than that of Bt potato and cotton; for example, only one company has commercialized Bt potato, and only one toxin type and seasonal tissue distribution are exhibited for each crop species.

Environmental impacts of Bt field corn must be judged against the typical corn system in which no insecticides are applied to control lepidopterans. Peer-reviewed studies have demonstrated adverse effects of Cry1Ab on predaceous lacewings (Hilbeck et al. 1998a, b), however, none of the studies conducted for EPA by the registrant has found adverse

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