"From your actions it would appear that your invitation to NGOs is an expediency you resort to, to be able to say there have been consultations with civil society. We would like to look at these as not consultations but a hoax perpetrated by the GEAC in an attempt to silence criticism against its secretive and non-transparent functioning." - excerpt from a powerful letter to the Chairperson of India's official Genetic Engineering Approval Committee (item 1)

Below item 1 are 2 articles from the award winning Indian journalist, Ashok B. Sharma that help to undermine another hoax - the claim by USDA that India is experiencing bumper cotton harvests because of Bt cotton. Ashok notes how curious it is that India "with a minuscule area coverage under Bt cotton can become a 'biotech mega-country'" in the promotional work of GM lobbyists (item 2a), and that ideal weather conditions may have far more to do with a bumper cotton crop than the relatively miniscule amount of Bt being grown (item 2b).

For an article about USDA's claims:
http://www.lobbywatch.org/archive2.asp?arcid=5148

1.Letter to the GEAC
2a.GM crops: scientific analysis needed, not hype
2b.Bumper cotton crop : Is it a Bt magic?
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1.Letter to the GEAC
April 25, 2005

To,
Shri Suresh Chandra
Chairperson, Genetic Engineering Approval Committee
Ministry of Environment & Forests
Paryawaran Bhawan, CGO Complex
New Delhi

Dear Shri Suresh Chandra

Greetings! Centre for Sustainable Agriculture [CSA] and Gene Campaign, both of which were present briefly in the past two GEAC meetings, would like to raise some process-related issues with the GEAC on the way decisions are made about GE crops in this country and our objection to it.

CSA had formally sent a request by email and fax on 24th February requesting an audience with you for a delegation to have a discussion on Bt Cotton performance in the country. It was only in the afternoon of March 3rd that GEAC contacted CSA in Hyderabad inviting us for a 10-minute presentation on the 4th. In spite of our repeated request that we would need some notice before we could meet you since we are a Hyderabad-based organisation, we received the invitation only at the last minute. We, however, decided to use the opportunity to put forth our views.

The 10-minute slot promised to CSA was cut down to 5 minutes after we entered the GEAC meeting room. It was a one-sided presentation where we shared our views and findings on Bt Cotton as well as the way GEAC functions. There were no questions or discussions and everything was perfunctory. After we came out of the meeting, one of the GEAC members informed us that “this is not normally done” and that the GEAC was doing us a favour by allowing us to make a presentation. She even refused to share her identity with us saying that it is confidential!

Similarly, the interaction with Gene Campaign was a one-sided affair. There was no response to questions raised by Gene Campaign on whether or not the GEAC would take on board suggestions made by the civil society groups who had been invited to make presentations before it. The GEAC was not willing to commit either on whether it would conduct a review of the past performance of the Monsanto -Mahyco Bt cotton, as Gene Campaign, CSA and others have been demanding, or whether it had any plans to take action against the rapid spread of illegal Bt cotton varieties. The GEAC also refused to commit itself to taking any action against the violation of the government rules according to which farmers must plant 20% of ordinary cotton around Bt cotton and which most farmers do not do. In response to repeated questioning by Gene Campaign, the Chairman of the GEAC stated that "The government is not answerable to NGOs".

The minutes that were put up of the 52nd GEAC meeting on the MoEF website expectably did not have any points from the presentation CSA had made and the objections and concerns raised. It however has detailed responses from the Bt Cotton companies on some questions raised by the GEAC members. The minutes of the 53rd meeting are not available on the website yet.

From your actions it would appear that your invitation to NGOs is an expediency you resort to, to be able to say there have been consultations with civil society. We would like to look at these as not consultations but a hoax perpetrated by the GEAC in an attempt to silence criticism against its secretive and non-transparent functioning.

Both Gene Campaign and Centre for Sustainable Agriculture have well qualified people from various fields of agriculture including Plant Breeding, Genetics, Entomology, Plant Pathology, Extension etc. and have long years of credible and successful experience of working with farmers in the country and of establishing sustainable alternatives. The Boards of these organisations have a veritable line up of eminent people who have contributed to agriculture in the country. The organisations have also documented the experience of Bt Cotton in different locations and have interacted with hundreds of Bt Cotton farmers in these places during the past three years and earlier to that. Those of us working with poor farmers in this country, see GE in agriculture as a matter that is closely connected with farmers’ livelihoods and survival and hence requiring utmost caution in its implementation.

Elsewhere in the world, studies done by independent organisations as well as their views are taken on board during decision-making on GM technology. The public has been engaged in GE-related debates in Europe through a variety of innovative tools including Citizens’ Juries and Public Hearings. In the UK the government had funded a yearlong debate on GM crops termed ‘GM Nation’. Freedom of Information has been used in numerous ways in many countries including the US, where the process of conducting risk assessment is a public exercise. Moreover, the Cartagena Protocol on Biosafety mandates public participation in decision making on GMOs and India is a signatory to the Protocol. Your refusal to include the public in decision-making on GMOs constitutes violation of an international agreement.

In India both the public and private sector engaged in GE research and commercialisation display an astonishing arrogance and behave as if independent agencies have nothing to contribute to the debate, discussion, monitoring and decision-making. The GEAC participates in this web of secrecy and joins the industry and the public sector in keeping the people out of any discussions. No reports are shared with the public on such important matters like GMOs. The basis on which decisions are being made is extremely unclear and therefore questionable. The public’s Right to Know is being violated again and again. It is objectionable that the GEAC refuses in this manner to be accountable to the people and prompts the question: what are you hiding if there is nothing to hide?

NGOs in this country have always been on the forefront of people-centred development alternatives and have successfully influenced government policies and programmes in favour of people. The due role of NGOs has been recognised by agencies the world over, including UN bodies, bilateral and multilateral development agencies and by the governments in India.

In this context, we demand that the GEAC should

- create time and space to dialogue with civil society groups interested in GMOs and agriculture, before decisions are taken this dialogue should be truly participatory and not the farce that we have seen recently
- put up all the objections and concerns raised by stakeholders like us, and your responses to the same, on your website
- share all information being presented by other stakeholders like ICAR bodies, the companies involved etc., through the website and other means and put this out for public scrutiny
- take on board the findings of various independent agencies who work closely with farmers if an advertising and market research firm can do studies for the companies involved and the findings are then submitted to the GEAC, there is no reason why credible findings from independent agencies are not accepted by the GEAC as evidence
- provide the test data and rationale for decisions on the website

Unless all these issues are addressed, the credibility of the GEAC remains questionable. As the body which gives approvals for large scale trials and commercial cultivation, GEAC is ultimately accountable to the farmers and the people of this country.

Sd/- G V Ramanjaneyulu
Executive Director
Centre for Sustainable Agriculture
12-13-445, Street No 1
Tarnaka, Secunderabad 500 017

Sd/- Suman Sahai
Gene Campaign
Director
J 235/A, Lane W 15 C,
Sainik Farms Khanpur,
New Delhi 110 062
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2a.GM crops: scientific analysis needed, not hype
ASHOK B SHARMA
Monday, February 14, 2005
http://www.financialexpress.com/fe_full_story.php?content_id=82555

The commercial cultivation of genetically modified (GM) crops across the globe completes nine years - just a year left to complete a decade.

All through these years much of the time was spent on creating hypes, instead of addressing the issues of genuine public concerns in a valid scientific manner.

An instance of such a hype comes from the recent preview of the global status of commercialised GM crops conducted by the International Service for the Acquisition of Agri-biotech Applications (ISAAA). The ISAAA has designated 14 countries along with India as "biotech mega-countries."

The only criteria used for judging a 'biotech mega-country' is that which grows GM crops over an area of 50,000 hectare or more.

ISAAA has been too generous in conferring the status of 'biotech mega-country' to India. But for what reasons ?

India has approved only three varieties of Bt cotton for commercial cultivation and that in select cotton-growing areas. In fact, Bt cotton is the only GM crop approved so far for commercial cultivation.

As per ISAAA, the area coverage under Bt cotton in India in 2004 increased by 400% to be at 500,000 hectare. Thus India qualifies the ISAAA criteria to be designated as 'biotech mega-country.'

The ISAAA, however, admits in a passing reference that the total cotton area in country is nine million hectares. The reference of nine million cotton area pertains to the year 2003. The cotton area in the country has increased in 2004 to about 10 million hectare. In comparison to the total cotton area in the country, the coverage of Bt cotton is still minuscule. Further to justify the given status of biotech mega-country, the ISAAA estimated that Bt cotton was grown in 11% of the area where hybrid cotton was cultivated. It has estimated hybrid cotton area at 4 million hectare.

Strangely, India with a minuscule area coverage under Bt cotton can become a 'biotech mega-country' as per ISAAA estimate. The ISAAA further said that the acceptance of Bt cotton amongst farmers is growing. It gave the old data of a survey conducted by Neilson & Co on behalf of Monsanto showing benefits to 75,000 farmers who had grown Bt cotton in 2003 over an area of 100,000 hectare. The report gives a hope for further commercialisation of GM crops in India saying: "Bt cotton provides both China and India with the confidence and experience to approve their first biotech food crops - rice in China and eggplant in India."

Regulatory approval for eggplant in India will definitely take more time than what ISAAA expects. It has yet to pass through various stage of clearances. It is natural to expect hypes of GM technology from ISAAA which is supported by the seed multinationals. But a genuine review of the situation should be one which reflects and analyses the real situation.

This article, however, is not analysing the status of other 13 ‘biotech mega-countries’ mentioned by ISAAA due to lack of reliable comparative data. But commenting on the global situation in general, it can be said that the increase in GM crop are as stated by ISAAA and is due to new countries approving GM crops for cultivation. The increase in area coverage may not necessarily mean more acceptance of the technology. It may also suggest that farmers are experimenting on GM crops to see as to whether they give them adequate benefits as compared to conventional crops.

The ISAAA report said that Indonesia and Bulgaria pulled out of the biotech race as the regulatory authorities in these countries did not extend "permits" beyond 2003. But why the permits were not extended? The ISAAA report is silent!

The ISAAA report says of Paraguay officially joining the biotech race after years illegal cultivation of soyabean. Illegal cultivation of GM crops was also in Brazil before the official approval.

There are still illegal cultivation of Bt cotton in several parts of India where it is not yet approved. This is a genuine public concern which needs to be addressed. Concerns are there that if the GM crops are cultivated without following the scientific protocols it may cause health and environmental hazards. The onus lies both upon the advocates of the technology and the regulatory authority.

The ISAAA stated that the global market for biotech crop at $5 billion by 2005. This is much less in size as compared to the market for organic food which is estimated at $37 billion. This raises a moot question: Should farmers go for biotech crops or organic farming?

It is desirable that a research study should engage more on a comparative analysis rather than have an intention to create hypes.
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2b.Bumper cotton crop : Is it a Bt magic?
ASHOK B SHARMA
Monday, February 21, 2005
http://www.financialexpress.com/fe_full_story.php?content_id=83185

The recent estimate of the government shows a bumper cotton crop, while the output of foodgrains, oilseeds, jute and sugarcane has declined.

According to the government estimate for the crop year 2004-05, the total foodgrains output will decline by 2.67% to be at 212.08 million tonne. The data, however, shows a marginal improvement in rice output to 87.80 million tonne from 87 million tonne in the previous year. Wheat output is pegged at 73.03 million from 72.06 million tonne in the previous year. Coarse cereals output has fallen by 15.6%. Pulses out has declined by 10.25%. The output of nine major oilseeds has declined by 1.21%.

Incidentally, the output of cotton has dramatically increased to 17.07 million bales (of 170 kg each) from 13.788 million bales in the previous year.

This indeed is a record production. It has also surpassed the target of 15 million bales. This situation leads us to consider how this could happen when the output of all other crops has fallen.

As for other crops there is a simple answer. The deficient monsoon rainfall in 2004 adversely impacted the output of major summer crops. But cotton too is a summer crop. How could it survive the nature’s fury ? We had a Bt cotton cultivation in an area of 500,000 hectare in 2004 as reported by the International Service for the Acquisition of Agri-biotech Applications (ISAAA). Was this phenomenal increase in cotton output due to the cultivation of Bt cotton?

The advocates of transgenic technology in India do make out a case that the increase in cotton output is solely due to larger cultivation of Bt cotton. But this may not be true. There are several other factors responsible for the increased cotton output.

Cotton, a summer crop, thrives well when the incidence of pest and diseases is less. In year 2004, fortunately for cotton, the deficient rainfall in the monsoon season was a blessing. The deficient rainfall resulted in low humidity in the atmosphere. Pests like bollworm thrive when levels of humidity are high. Thus on account of poor rainfall there was less incidence of pests and diseases and lesser damage to cotton crop leading to a bumper harvest.

The weekly reports of the government's Crop Weather Watch Group (CWWG) had also reported time to time about low incidence of pests in areas of deficient rainfall. The CWWG has also noted shifting of area from other crops to cotton. Cotton requires comparatively lesser water than other crops and farmers found convenient to shift to cotton on account of deficient rainfall. This resulted in an increase in cotton area in 2004 to about 10 million from the the normal of nine million hectare. The CWWG reported in August end about 8.22 million hectare being covered under cotton. This figure of CWWG, however, is not the total area coverage under cotton. Cotton sowing continues till later part of the year in southern states, particularly, in Tamil Nadu. Hence there are evidences of cotton area increasing above the normal.

India had experienced a severe drought in 2002 and the output of all crops including cotton fell sharply. Cotton output fell to 8.72 million bales. But the impact of deficient rainfall in 2004 was less severe than that in 2002.

Now coming to Bt cotton in particular. The inserted Bt gene is said to protect the balls from bollworm. It does not otherwise increase the yield of the crop, it may save from damages caused by certain pests.

As per ISAAA the area covered under Bt cotton is only 500,000 hectare out of the total area of about 10 million hectare. It also says that area under Bt cotton represents only 11% of the hybrid cotton area. (Only Bt cotton hybrids are approved in India so far). Ranjana Smetacek of Monsanto India said ; "About 2.5 million out of 4 million cotton growers in the country grows hybrid cotton and Bt cotton seeds were sold to over 350,000 farmers in 2004." She said that IMRB is conducting a survey to assess the performance of Bt cultivation in 2004.

PV Satheesh of Deccan Development Society said that Bt cotton failed to perform yet again in the third consecutive year in parts of South India. "We have conducted a survey with the help of agronomists and scientists and will soon come out with a report."

The performance of Bt cotton in 2004 is still an open debate. But it is certain that there are several factors responsible for a bumper cotton crop, particularly, the low incidence of pests and diseases on account of deficient rainfall. In 2004 there was a low incidence of pests and diseases in major cotton growing areas. Hence it is time to consider whether it is a Bt magic or a monsoon magic behind the bumper cotton output.