Reviewing 10 years of Bt cotton:
1.NATIONAL CONFERENCE ON Bt COTTON QUESTIONS THE SUCCESS CLAIMS 
2.BT COTTON FAILED THE MAJORITY OF COTTON FARMERS IN INDIA

NOTE from Kavitha Kuruganti: The following [item 1] is a Press Release from Centre for Environment Education, Centre for Sustainable Agriculture and Council for Social Development, at the end of a two-day national conference to review the experience of ten years of Bt cotton in India. This conference had participation in various capacities (chairing of sessions, speakers, participants etc.) of Prof Abhijit Sen, Planning Commission; Dr Anupam Barik, Addl Commissioner-Crops, Ministry of Agriculture; Mr M F Farooqui, Chairperson of GEAC [regulatory body], Dr Ved Kambhoj, Chairperson of RCGM [regulatory body], Prof Bhargava, Supreme Court observer in GEAC etc, many farmers' organisations, several industry representatives (Mahyco, Nuziveedu, Sriram Bioseed, ABLE etc.), GEAC/RCGM regulators, agriculture scientists from the NARS, civil society organisations and activists and so on. The press release is pasted below, while the attached note [item 2] gives additional points that came up during
the conference.
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1."RIGHT TIME TO REVIEW TEN YEARS OF Bt COTTON" - NATIONAL CONFERENCE ON Bt COTTON QUESTIONS THE SUCCESS CLAIMS EXPRESSES CONCERN ON THREAT TO OUR SEED SOVEREIGNTY

New Delhi, June 12 2012: A two-day national conference to review ten years of Bt cotton experience in India, by various stakeholders including farmers’ groups, regulators, industry and civil society groups, acknowledged the phenomenon of large-scale adoption of Bt cotton by farmers in India even as distress amongst cotton farmers has been exacerbated, especially for the majority of cotton farmers growing the crop in risky, rainfed conditions. The conference was co-organised by Centre for Environment Education, Centre for Sustainable Agriculture and Council for Social Development and covered a variety of facets related to Bt cotton: performance against claims including pesticide usage, riskiness and suicides, regulatory regime, emerging scientific evidence, socio-political implications and so on.  The conference was organized in the context of ten years of approved Bt cotton cultivation in the country, without a formal and official review by the government, even as many definitive statements are being made by the Government of India in various fora (including in the Parliament). The Bt brinjal debate in India a couple of years ago also brought to the fore the need to review the experience of Bt cotton in India comprehensively.

In his remarks in the concluding session of the conference, Mr Jairam Ramesh, Union Minister for Rural Development stated that the structural transformation of the cotton economy, with area of cotton increasing by 20-30%, yields nearly doubling and production trebling (making India the second largest cotton producer in the world) in the last two decades and factors that have contributed to the same, should be studied.  He felt that causal correlations' analysis should be taken up, given the many factors that could have contributed to yield increases including hybrid seed, good climate, irrigation etc. The large scale adoption of Bt cotton is also a reality, he stated. He also stated that there is a need to support sustainable alternatives like NPM to the same extent as support to transgenics.  

There is a mixed picture of Bt cotton on the ground from different data sources and analyses. Farmers who grow Bt cotton in rainfed conditions, who constitute a majority of Bt cotton farmers, have not gained from its cultivation, even while their distress has been exacerbated by it (riskiness studies). The macro-data bears this out, that rainfed (Bt) cotton yields even in a state like Gujarat remain as low as one quintal per acre in unirrigated cotton (as per Navsari Agriculture University information). The macro data shows that pesticide consumption in different states has not declined but is either the same or is on the increase in different states except in the case of Andhra Pradesh (Directorate of Plant Protection & Quarantine Services data). Several micro-studies however show that pesticide use has decreased especially for bollworm control initially, while it is on the rise again now, for other pests as well as bollworm including newer cocktails of toxic chemicals (Gujarat Institute for Development Research, for instance). In the recent past, yields have stagnated and are showing a decline. Further, seed monopolies and lack of choices are clearly pointing to a threat on our seed sovereignty. 

“The conference noted that Bt cotton farmers are also committing suicides; experiences from the field and academic analysis shared in the conference established the riskiness of Bt cotton cultivation. Further, a variety of data sources are putting out contradictory/inconsistent data which does not allow for any clear evaluation to take place. In this context, the government should not be making any definitive statements on the success of Bt cotton in India. In fact, the current situation clearly points to the dire need for an appropriate monitoring system to be put in place right at the beginning, which is sadly lacking in India. The conference noted that there is no level playing field being created by the government for promoting ecological alternatives with the same support as is being given to transgenic promotion. Bt cotton has taken away seed choices for farmers, especially the ones who wish to remain GM-Free including organic farmers”, noted Dr G V Ramanjaneyulu of Centre for Sustainable Agriculture.

“We need a holistic regulatory system in the country which takes into account issues that go beyond yields and production other social, cultural and political parameters need to be incorporated. Further, the sustainability debate has to drive our decision-making related to GMOs. The precautionary principle has rightly guided the nation’s decision with regard to Bt brinjal this should be our constant guiding principle. I agree with what Mr Jairam Ramesh said that this is the right time for a review of Bt cotton this should include an area- and zone-wise review”, said Mr Kartikeya Sarabhai, of Centre for Environment Education.

Chairing a session on regulatory system in India, Mr M F Farooqui, Chairperson of Genetic Engineering Appraisal Committee agreed that the regulatory regime needs to be improved in many ways in the country. 

Reflecting on the emerging scientific evidence related to Bt cotton and its impacts, Dr Pushpa Bhargava pointed out that many recent studies actually point to the risks and unpredictability associated with GM plants and that it would be irresponsible to take the technology to farmers and into the open without first taking up independent, long term, comprehensive risk assessment, including for chronic impacts. He also emphasized that transgenics should be considered an option at all, only after a thorough need assessment and only if no other alternative exist.

The conference also agreed that India’s decision-making on GMOs should be guided by broad policy directives, which prevent transgenic research and development in crops for which we are the Centre of Origin/Diversity, in which we have trade security interests and GMOs that pose serious socio-economic concerns like in the case of herbicide tolerance. Further, there is an urgent need to put into place a liability and redress regime into place, in addition to labeling for upholding consumer rights. All of these are in line with India’s commitments made in the Cartagena Biosafety Protocol. Further, sustainability frameworks and perspectives being incorporated into our education and research systems was emphasized. 

Prof Muchkund Dubey, President, Council for Social Development and Dr T Haque, Director of Council for Social Development welcomed the gathering and emphasized the importance of the meeting, which included around 150 participants from across India.

For more information, contact:

Dr G V Ramanjaneyulu, Centre for Sustainable Agriculture at 09000699702

Mr Atul Pandya, Centre for Environment Education at 9825406608

Dr Pushpa Bhargava: 09949476067
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2.BT COTTON FAILED THE MAJORITY OF COTTON FARMERS IN INDIA
EXPERIENCE NEEDS TO BE REVIEWED COMPREHENSIVELY
Ten years of Bt cotton in India: Review findings
(Annexure to Press Note released by CEE/CSA/CSD on June 13th 2012 [see above – item 1])

A 10-year review process of Bt cotton in India was initiated by Centre for Environment Education (Ahmedabad), Centre for Sustainable Agriculture (Hyderabad) and Council for Social Development (New Delhi), through a national conference organized in Delhi on June 11th and 12th. The conference had more than 150 participants from all over India, consisting of several regulators from Genetic Engineering Appraisal Committee and Review Committee on Genetic Manipulation, agriculture and molecular biology experts from different parts of the country, industry representatives, farmers’ organizations, organic farming groups, other civil society groups, academics and representatives of media. The Conference also saw Central Government representatives including Prof Abhijit Sen, Member in charge of Agriculture, Planning commission; Dr Anupam Barik, Addl Commissioner, Crops, Ministry of Agriculture and Mr M F Farooqui, Chairman, Genetic Engineering Appraisal Committee chairing various sessions.
The experiences, studies and available data while questioning the absolute success of Bt cotton across the country brought forth the fact it has failed in the rainfed regions, which cover 65% of the total cotton cultivation in the country, due to various reasons. The conference organizers opined that this is a first step towards a comprehensive review process that needs to be taken up. 
The review saw a number of presentations of micro-studies as well as macro-data on a variety of subjects including farm economics (yield, production, farmer incomes) with Bt cotton in different comparative frameworks, pesticide usage, regulatory regime, policy frameworks related to GMOs, riskiness and farmer suicides associated with Bt cotton, on public sector Bt cotton, on emerging scientific evidence with Bt cotton, on social, political and other implications etc., with further analysis and discussions on the same.

The main issues that emerged from this conference are:

    The conference noted that adoption of Bt cotton in India is quite high. It also noted that distress amongst a large majority of cotton farmers is also high (especially in rainfed growing conditions). 

    The conference acknowledged the fact that such adoption should also be understood in the context of the failure of an earlier, related technology of chemical pesticides.

    The conference found a mixed picture as the reality with Bt cotton with the agreement that it is not the best solution for rainfed regions. It was also noted that results from irrigated farming with Bt cotton have shown varying trends across regions and across years.  

    The conference also noted that different official sources of data are inconsistent with each other, and unreliable. While different micro-studies are questionable on their methodologies or design adopted, macro-data is sometimes contradictory between different sources. It was however acknowledged that cotton area, production and yield has increased in the country in the past decade. How much of this is attributable to Bt technology and whether there is a causal correlation at all requires an in-depth investigation given that:
o    There has been a large scale shift to hybrid cotton cultivation in the country;
o    That irrigated cotton area is on the increase;
o    That there have been favorable climatic conditions, especially in states like Gujarat;
o    That input use on Bt cotton has been higher, in terms of chemical fertilizers etc.


    This causal correlation analysis has to be taken up also because in the years that India reported the highest year on year increases in cotton yields, AICCIP (All India Coordinated Cotton Improvement Project) results were showing that bollworm incidence was low to moderate. When Bt cotton can result in higher productivity only under pest pressure by protecting the crop from pest damage, how can such yield increases then be related to Bt technology?

    Moreover, the recent stagnation and decline in cotton yields has to be understood further.

    There was also a near-complete agreement on the increase in cost of cultivation after the adoption of Bt cotton. Comparative analysis with other alternatives like NPM and organic farming practices highlighted the definite advantage of these practices in cost of cultivation in comparison to intensive agricultural practices  with Bt cotton hybrids.

    On pesticide consumption data, some micro-studies seem to indicate pesticide use reduction initially, with use on sucking pests and other pests increasing, with per acre pesticide usage increasing in the past and a dangerous cocktail of pesticides on the rise, while others indicate a steady increase. However, official data on pesticide consumption in India does not reflect any decline, except in Andhra Pradesh, where large-scale adoption of NPM is being followed.

    The conference brought out the fact that riskiness analysis has to be incorporated into decision-making in technology assessment, more importantly in the case of transgenics like Bt cotton. 

    Concerns around the existing regulatory architecture in India, including the total absence of policy directives  against even crops for which we are the Centre of Origin and diversity, in which we have trade security interests and where intense social implications lie (like herbicide tolerant crops) came to the fore.

    The discussion on the regulatory mechanisms identified the need for further safety assessments for Bt cotton especially in the light of high volumes of oil from Bt cotton seeds reaching the edible oil supply and the usage of oil cakes as cattle feed.

    It was also clearly pointed out that any decision-making on transgenics should incorporate need assessment and an assessment of alternatives, before considering a transgenic option at all. 

    The need for a liability regime to be put into place in addition to a labeling regime was emphasized. 

    93% of cotton seed being ‘controlled’ by one American MNC was noted.  Seed sovereignty being threatened, with the public sector in India becoming redundant and irrelevant was a concern shared by many. It was noted that Bt cotton seed companies were not being made accountable, with the seed industry often taking governments to court in this situation, the hope for farmers’ rights being upheld appears meagre.

    There was concern around public funds being wasted in several ways, including on transgenic research that gets bogged down in IPR issues and “contamination” issues, in addition to lack of ability to take the R&D products to farmers; further, governments are paying compensation packages to farmers when the crop fails, with public funds. 

    The conference noted that public sector research is being sidelined with private sector takeover of seed. This is also limiting seed choices for farmers. 

    On the other hand, increased chemical fertilizer usage in Bt cotton was acknowledged, especially in terms of data available from Gujarat state this not only has further public financing implications, but also serious environmental concerns where we are not treating our soil fertility as our main capital. 

    The conference also repeatedly noted that safer, cheaper and sustainable ecological alternatives exist, which are acknowledged by the NARS system and also practiced on a large scale by lakhs of farmers in the country. The conference put forward a recommendation that the government should create a level playing field between such alternatives and intensive agricultural technologies, for rational, informed choices to be made.

    The conference identified that various parameters to assess Bt cotton have not been taken on board so far. 

    Aggressive marketing of Bt cotton seed was noted as a matter of concern and it was opined that this should be curbed, given that Seed is an Essential Commodity.

The concluding session was chaired by Mr Jairam Ramesh, Union Minister for Rural Development, who opined that the story of Indian cotton needs to be studied thoroughly, to understand the “structural transformation” in the cotton economy in India in the past two decades. He pointed out that Bt cotton adoption by farmers is a fact to be noted, even as the contribution of hybrid seed and irrigation to cotton yield increases is to be acknowledged. Jairam Ramesh also pointed out that there is more scientific evidence that has emerged in the recent past which needs to be taken seriously. He pointed out that biotechnology in agriculture should not be restricted to one tool like Bt/Genetic Engineering and should explore and invest in a spectrum of tools like marker assisted breeding etc. He appreciated the more active role being played by state government in the recent past. There are a large number of scientific problems that have to be addressed. He felt that appropriate lessons have to be gleaned for research, seed production, extension, regulatory regime and so on, by the country taking up a comprehensive review of Bt cotton at this point of time. Most importantly, he pointed out that he does not see any reason why organic and NPM alternatives cannot be promoted by the government as much as support for transgenic research.