shift to using Bt corn which does not produce biologically significant amounts of Bt in its pollen (EPA 1998b; Andow and Hutchinson 1998).

The potential for resistance to Bt toxin in a number of the target pests of Bt corn has been of concern to EPA, environmentalists, and university researchers (Ostlie et al. 1997; Andow and Hutchison 1998; Matten 1998; SAP 1998). In particular, the corn earworm may be especially vulnerable to evolving Bt resistance. Corn earworm is substantially less sensitive to Bt toxins than the primary target pest of Bt corn, the European corn borer. Bt corn varieties that express the toxin in the silks or corn kernels where corn earworm feed do not produce a high enough dose for corn earworm mortality. Corn earworm is also subject to selection pressure from Bt toxins in Bt cotton, since this pest feeds on a number of crops, including cotton, where it is known as the cotton bollworm (EPA and USDA 1999).

All the commercial cultivars provide substantial protection against the European corn borer (Ostlie et al. 1997). However, the Novartisproduced cultivars, which use green tissue and pollen-specific promoters to drive gene expression, have lower efficacy later in the season (Ostlie et al. 1997; Andow and Hutchison 1998). The lower late-season efficacy is also seen in the Dekalb-produced corn (Andow and Hutchison 1998). Lack of a high dose in these two types of Bt corn could undermine the high-dose refuge approach endorsed by EPA (Matten 1998; and section 2.9) and achievable with other Bt corn cultivars.

Cotton

Like potatoes, conventionally-grown cotton has been heavily treated with insecticides to control lepidopteran pests. Therefore, the introduction of Bt cotton can produce considerable environmental benefits. A 1998 survey indicated a general decrease in insecticide useage on Bt cotton (Mullins and Mills 1999). For example, in 66 comparisons in the Mississippi, Louisiana, and Arkansas region, the average number of insecticide sprays per field was 10.1 for non-Bt cotton and 7.9 for Bt cotton. Many of these insecticide treatments were made to control the boll weevil which is not affected by Bt. In 20 comparisons in the North Carolina, South Carolina, and Virginia region (where the boll weevil is not a pest), the average number of insecticide sprays was 3.7 for non-Bt cotton and 1.2 for Bt cotton. USDA's Economic Research Service found less clear patterns in changes in insecticide used on Bt cotton (USDA 1999d). Comparison of mean pesticide acre-treatments for 1997 showed that in only two of three regions surveyed did the adoption of Bt cotton reduce insecticide treatments normally used to control pests targeted by Bt. In one of three regions, total insecticide treatments for all other pests was higher for Bt adopters than for nonadopters (USDA 1999d). The results should be



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