Here's a terrific response from PV Satheesh (item 1) to a piece - 'The Brouhaha about Bt-Cotton in India' - published by Dr Shanthu Shantharam on CS Prakash's pro-GM AgBioView list (item 2).

In his article Dr Shantharam effectively claims that all the studies on Bt cotton are at fault except those conducted on behalf of industry! In just his opening paragraph Dr Shantharam manages to label NGOs "vigilantes" and dismiss their research as "based on either their own ideological opposition to modern biotechnology or pathological dislike for GM crops...".

Dr Shantharam's lurid posturing would be laughable if it weren't for the fact that its target audience is not really his fellow scientists nor even the wider community with a stake in the GM debate, but industry's friends in high places. This is a point PV Satheesh makes clear: "the long winded toxic argument by Dr Shantharam is not meant for any scientific discussion. It is to discredit all the independent studies done in India in order to bring pressure on GEAC to renew the permission to Monsanto. He lets the cat out of the bag when he says 'They [the other arguments] cannot be used to draw general conclusions much less used for any decision making'."

One point, however, on which PV Satheesh may not be entirely correct is when he attributes Dr Shantharam's particular perspective to his years working for the US Department of Agriculture (USDA). Surely, one should not overlook the years he subsequently spent as an employee of GM giant Syngenta.

1.PV Satheesh's response to Shanthu Shantharam
2.The Brouhaha about Bt-Cotton in India
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1.PV Satheesh's response to Shanthu Shantharam

Dr Shantharam has a very wide brush with which he paints NGOs as black as he can. This is unsurprising since he has spent all his working life with the USDA, which has subverted all possible civil society voices in order to subserve the interest of the agro chemical industry. Dr Shantharam, being a US resident for most of his working life also has got his idea of the media from the US milieu. The "embedded" US media has to listen to its masters. But in a country like India, the media is still active, listening, and not dazed by the blitz of corporate hype. If Dr Shantharam cannot stomach the many voices and opinions that the Indian media still fortunately highlights, it is his problem.

On the other hand, reading through the painful length of Dr Shantharam's vituperation, one gets the feeling that he has very little idea of the small and marginal farmers in South Asia, just like his ideological colleagues of the CS Prakash variety. In short, this is a coterie that is the first enemy of Indian farmers. His writing is so typical of the arrogance of formal science, particularly the US variety, that it does not even pause to think that there may be other kinds of realities and truths that are not bred and hybridised in their laboratories. That is why the constant homilies about "how not to conduct a field survey". I bet my last shirt that the learned doctor has not done a single survey in his life with Indian farmers, especially the small and the marginal whom he dismisses in another part of his article as "uneducated and illiterate", unable to appreciate the fine nuances of biotechnology. His language is no different from his soul brother Dr Kameswara Rao, who is credited with the profound statement: "Indian farmers do not know how to grow cotton!".

Left to themselves, these worthies would eliminate the last farmer from his/her field and gleefully invite the Monsantos and Syngentas to take over the world. Because it is these corporations who can pay and fatten these scientists which the small farmer is incapable of doing. While the entire sensible scientific world has come a full circle in trying to figure out how to conduct farmer-led research and bring farmer-parameters into agresearch, worthies like Dr Shantharam are decades behind with their primitive idea of what "scientific" research is.

Be that as it may. What is it that Dr Shantharam has said in his long, NGO-baiting vituperative article? That people like Dr Suman Sahai, who has a Ph D in genetics, Dr Vandana Shiva who has a doctorate in Physics, Dr Ramanjaneyaloo, a proper Agriculture Ph D, Devindar Sharma who has a masters degree in plant breeding, do not know anything in science? And that a market research agency like IMRB approximates truth because it reflects Monsanto's propaganda!

What do you call such people? Scientists? Wouldn’t that be an abuse of the term?

One does not have to go through a point by point rebuttal of Dr Shantharam's piece. Justifiably it lies on the website of AgBioWorld, the dustbin of corporate science. But that the learned doctor did not even care to take a look at the study done by scientists and professionals like Dr Abdul Qayum which was done with farmers, sampling them from day one of their planting Bt Cotton, is a shameful exhibition of both ignorance of the available scientific literature as well as a monumental arrogance: "I know Science, nobody else does". Dr Qayum and Mr Sakkhari did season-long studies for three years. They did not know whether a farmer they have selected to study will harvest a good Bt cotton crop at the end of the season or not. They had done a methodologically impeccable and unbiased study. That the study came out with reports of devastating impact of Bt cotton is neither their fault nor of their methodology.

Dr Shantharam also breathes fire and brimstone in his tirade against NGO studies which he says "have conducted either post-ante polls or post-harvest surveys or memory recall opinion surveys, and none of them have been designed with any standard scientific methodology". But the same doctor does not even blink while gleefully endorsing the IMRB survey which has done the same post harvest survey. He could have been a publicist for IMRB when he says "Going by international standards of survey methodology, the reports by IMRB seem reliable"

In their report Dr Qayum and Mr Sakkhari echo a genuine concern expressed by farmers that their soils are showing signs of being infected after two years of Bt Cotton cultivation. The scientists were alerting people to the possibility of something of this nature. Look at the response of the arrogant Doctor who totally dismisses it as "nonsensical". His faith in his brand of science is so total that he is blinded to other possibilities. It is his clan of scientists who, when warned about the possibility of herbicide resistant weeds years ago, called it a "non-scientific paranoia". But today glyphosate-resistance is termed by scientific institutions in the USA as an "on farm reality" and an unabashed Syngenta uses this as another money-making option by creating "herbicide resistance quick test kits". Again, it is the same clan of scientists who trumpeted that with the arrival of GE crops, pesticide use will come down dramatically. Look at the phrase that Dr Shantaram uses: "IPM (into which Bt crops fit elegantly)". You know what the USDA report says about the last ten years of pesticide consumption in that country where GM crops occupy nearly half the lands growing pesticide consuming crops? THE PESTICIDE USE HAS NOT COME DOWN BY A SINGLE OUNCE, WHILE THE WORLD TRENDS OVER THE LAST TEN YEARS HAVE SHOWN A DROP IN THE USE OF PESTICIDES. Dr Shantharam and his ilk would turn out another "elegant" phrase to explain this away. But the world will not be blind to this.

In any case at the end of his article, Dr Shantharam sums up things profoundly: "One thing is clear that Bt-cotton technology works for the purpose it is designed. It does not control non-target pests for which the farmers have to spray chemical pesticides. It is also generally clear that the germplasm of MECH varieties of Bt-cotton are inferior to some other hybrid cottons in the market during the development phases of the MECH varieties. Variability in performance is a natural order of all newly introduced varieties, GM or no GM". This is precisely what Dr Qayum and Mr Kiran Sakkhari said in their study which Dr Shantaram has so vehemently undermined throughout his piece to come to the same conclusion. Did I hear scientific duplicity?

In any case the long winded toxic argument by Dr Shantharam is not meant for any scientific discussion. It is to discredit all the independent studies done in India in order to bring pressure on GEAC to renew the permission to Monsanto. He lets the cat out of the bag when he says "They [the other arguments] cannot be used to draw general conclusions much less used for any decision making".

Bravo Dr Shantharam, you have done a yeoman service to your masters but on the day of judgement in a future not so far away, scientists like you will be remembered as "Enemies of the People".

satheesh
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2.The Brouhaha about Bt-Cotton in India

- Shanthu Shantharam, AgBioView, May 2, 2005; www.agbioworld.org (Author is at Biologistics International, Ellicott City, MD 21042)

Bt-cotton is the first Genetically Modified (GM) crop that was commercialized in India three years ago. Come every March/April for the past three years, it has been an open season for all sorts of NGOs (read vigilantes) of Bt-cotton to report on its failure mostly in Andhra Pradesh (AP), and also in Gujarat and Maharashtra. Most of them do so based on either their own ideological opposition to modern biotechnology or pathological dislike for GM crops especially if they are owned by multi-national companies.

Noble Laureate Sydney Brenner speaking at Bangalore BIO 2005 noted among other things that opponents of biotechnology don't seem to understand anything about what happens inside biotechnology laboratories, and going by these reports on Bt-cotton, they don't seem to fathom what happens to crops under field conditions and how to evaluate them objectively.

Most of the negative reports, it seems are specially designed to carry out political activism against GM crops technology. The plain and simple goal of these reports is to discredit GM crops at any cost and stop them in their tracks. If one were to go by these reports Bt-cotton must be an unmitigated disaster. Then there are several indifferent government and academic reports from Governmental Organizations (GOs). The developers of Bt-cotton have also put out their own reports of positive performance of Bt-cotton through a leading market research firm, IMRB. Because these positive reports are from the developers of the GM crop in question, NGOs and many others cast aspersions on the veracity of the reports and dismiss them out of hand. Any other positive musings on the performance of Bt-cotton or GM crops must either come from an apologist of biotechnology or by someone who has been corrupted by the industry. The media is full of all these negative reports giving an impression that Bt-cotton has failed all over the country. It seems if a dog bites a man is not news, but if man bites a dog, it is newsworthy.

The Genetic Engineering Approval Committee (GEAC) has now deferred decision of the original varieties twice in a row, partly due to the NGO pressure. GEAC has asked for reports from all states of India wherever Bt-cotton was grown for the last three years in light of the Government of AP writing a negative report on it. It begs the question why GEAC did not have these reports all this time while they met twice to deliberate on these applications. It is high time GEAC makes its deliberations completely transparent and put an end to this unnecessary brouhaha. The simple way to do it is to revamp its sorry looking web site (hidden in the messy web site its parent Ministry), and post everything on its policies, rules, regulations and the data based on which they are granting their approvals to biotech products. GEAC Chairman's recent snub to NGOs that the government is not answerable to them is not going to help burnish its image very much.

Transparency and stakeholder participation is the order of the day's governance all over the world, and all sorts of national international governments have recognized it as the only way forward to the next millennium. There is no reason to hide anything and don't see any reason to be hiding Bt-cotton data based on which they are making decisions. Recently, pharmaceutical industries of the world have come together to voluntarily post all their clinical trial data in a common data base, and here is a thing for the agbiotech industries to follow the cue and share everything that they can be shared to convince the general public that GM crops are safe and productive.

Anti- biotech NGOs all over the world have not seen anything good coming from GM crops at all. Many Indian NGOs opposing GMOs draw plenty of inspiration ands sustenance from their European comrades to support their cause, but yet call themselves independent. The reality is that GM crops acreage keeps on increasing all over the world and it is no different with Bt-cotton in India. Another twenty plus Indian seed companies have paid a hefty licensing and royalty fee to acquire Bt technology for their own proprietary lines of cotton hybrids, and soon Indian cotton farmers will have a wide choice of Bt-cotton lines. Thanks, partly to Bt-cotton India is poised to become a world leader in cotton production for the first time in decades. People who are really in the business of investing on GM crops and seeds say GM crops are unstoppable in India and one should brace up for more and more GM crops in future.

A critical review of all the reports from NGOs on Bt-cotton in India serves as fine examples of how not to conduct a field survey. These reports claim to be "independent" and "scientific" whatever they mean!!! The things that they seem to be "independent" of are scientific rigor and objectivity. Most of them have conducted either post-ante polls or post-harvest surveys or memory recall opinion surveys, and none of them have been designed with any standard scientific methodology, sampling is spotty and size so small that they cannot be used to draw any meaningful conclusions for the entire country. Bias against Bt-cotton becomes glaring when one notices that they descended in those villages in AP only after they heard that Bt-cotton had failed. It seems they have only set themselves up to seek out farmers whose Bt-cotton had failed and don't seem to have come across any farmer who had success with it. The field surveys have not been properly planned right from the beginning by setting out with a proper methodology, parameters or indicators to measure. Looking at some of the questionnaires used to collect information, it is clear that they too were not designed to double check or cross-check responses.

Clearly, most of them do not understand the difference between random sampling and arbitrary sampling. They also do not make distinction between an opinion poll, a survey and a field study. They use it so interchangeably that one cannot figure out which one they mean when. They also do not understand anything about standard deviation and statistical analysis that factors in weighted averages. For them, words "failure" and "poor" performance are one and the same. It becomes obvious that they have no knowledge or understanding of plant variety introduction, field testing and how and what factors make a variety successful and how long they stay in the lead. Experienced agricultural scientists clearly know that not all introduced varieties perform equally well under all sorts of farmer's field conditions and those that fail under such conditions loose out in the market place. Failure of introduced varieties makes a rich folklore in agriculture. It should not surprise anyone who is knowledgeable in agriculture that failed varieties are either withdrawn or rejected by farmers all the time. For an interested party who has some critical sense and is serious about the performance of Bt-cotton, these reports cannot be considered scientifically credible or reliable. They cannot be used to draw general conclusions much less used for any decision making. They offer no meaningful and critical analysis for the observed failures or poor performances.

Regarding the claim that their reports are "independent"; the question is independent of what? It does not matter whether the study is independent or dependent, what is important is that it has to be scientifically rigorous. As they stand, they do not pass scientific muster. Recall scathing criticisms of Qaim and Zilberman's paper on the performance of Bt-cotton in SCIENCE in 2002 and Chapela's paper in NATURE in 2003 that was eventually cancelled by the publisher! Those papers were criticized precisely for the lack of scientific rigor and over reaching conclusions that could not be supported by experimental data, although they both contained elements of basic facts! In the case of Qaim and Zilberman's paper, they used selective data sets from just one season when they had access to five year's worth of data sets, and suggested that lone Bt-gene could increase yield of cotton by more than 80%. This kind of astonishing yield increase due to a single gene trait was never going to be true and these three years of Bt-cotton tests in India has proved it.

Actually, another paper by co-authored by the same authors in April 9, 2005 issue of Economic and Political Weekly (EPW) shows a realistic yield increase by about 37%. Once again these same authors have just used only the year 2002 commercialization data for analysis. It will no doubt come under another round of criticisms for much the same reasons as their SCIENCE paper. The now beleaguered Professor Chapela's paper in NATURE that was eventually withdrawn by the publisher also used not so elegant experimental protocols without realizing the limitations of PCR and came to unsupportable conclusions. The paper proved a point that Bt-gene from GM maize transferred to non-target land races and no self-respecting scientist discounted that anytime. Anyone who understands basic biology of open pollinating crop like maize would know that genes flow freely among maize. Critics of both the papers were demanding highest quality scientific rigor in data collection and interpretation and that is what science demands all the time. It should be no different for NGO reports many of whom claim to have been drafted with help of scientist's help.

Many of these reports show that most farmers are not complying with the conditions of refugia and that must be true. In a country like India where compliance to laws is more an exception than the rule, it is not surprising that uneducated and illiterate farmers do not seem to appreciate the value of refugia. This is not just in case of modern day GM crops, it happens in the use of other farm chemicals and water management and overall crop management. That is no excuse for condoning non-compliance. But, then the illegal Bt-cotton is rampant and no one can enforce compliance on illegal varieties that cannot be proved to be Bt-cotton. But, it is really bad for the technology development as the country is awash with illegal and spurious GMOs.

Compliance takes two to tangle - the users of the technology and the regulators. This is something that GEAC and regulators all over the world have to pay serious attention and devise methods to enforce compliance. NGOs harp on lack of refugia as though it is something new that was invented just for Bt-cotton. Refugia are one of the time tested Integrated Pest Management (IPM) approaches to delay build up of insect resistance. Refugia are needed when one employs intensive pest control strategies be it chemical or biological. Critics and opponents of Bt-crops get unduly worked up about it only when it comes to Bt crops. If they truly understood the value and meaning of refugia strategy and also have studied the field reports of Bt crops in the US which employs monoculture agriculture, they should know that not a single instance of field level resistance to Bt has been reported so far. This is not to say, it would not happen in the future. Refugia is designed for monoculture agriculture where one can set aside 20 to 40 percent of land for refugia, but it cannot be done in small farm holding in a country like India and it is really not necessary as the agricultural landscape offers many alternative hosts as the target pest in a polyphagous insect that feeds o more than 100 plant species. This is why it is important for GEAC to have meaningful science based regulations that can be implemented effectively, and not force conditions that are not implementable, and more importantly, not necessary.

Even in a country like USA, refugia are implemented by about 60 to 70 per cent of the farmers growing Bt crops. Yes, vigilance is a must and everyone involved in stewarding Bt crops must pay close attention this potential problem. In fact, refugia are lot more critical in chemical control strategies, and none of these critics of Bt-cotton seem to be worried about it. IPM (into which Bt crops fit elegantly) must be promoted all the time in pest control in any kind of agriculture including organic agriculture.

Another recent report from a Hyderabad NGO shows that soils in which Bt-cotton was grown no longer support other crops suggesting that somehow the soil has been poisoned. This is an incredible allegation which has not been reported from anywhere in the world. As much as this observation warrants verification, scientifically it sounds non-sensical.

Another NGO report mentions of how the Bt-cotton lint fetched low prices in some local markets in AP. It is important to know that agronomic performance, quality of fiber and market prices are not directly related. Agricultural commodities prices vary according to the vagaries of market forces. Unblemished white color of the lint and length of the staple are the key determinants of cotton prices in the market. In fact, in the first two years, it was widely reported in the media that Bt-cotton fetched premium price than non-Bt-cotton fiber, and every cotton growing farmer rushed to plant Bt-cotton in Gujarat, Maharashtra and Karnataka. Blaming low prices of Bt-cotton on Bt technology makes no sense. Will Bt technology be given credit if the prices go up next year? All over the world, agricultural commodities have been low for decades now and that cannot be blamed entirely on the technology used to produce those commodities. North American agriculture employs more sophisticated and many other precision agricultural technologies and no one suggested that these technologies are the cause of low commodity prices. Markets react to supply and demand, a simple fact of basic economics. What cotton farmers in India are facing this year is a glut of cotton and Bt-cotton is a small part of it for the moment. Anyone following horticultural commodity markets in India (especially onions, tomatoes and green hot peppers) where there are no known GMOs yet will understand what is happening to agricultural market prices India. It is totally a different topic for discussion, and a political hot button issue. This should not be mixed up with biotechnology.

At best, these negative reports contain elements of truth in them and at worst they are highly selective and misleading. Critical reviews of the reports betray the poor quality of scientific competence used. It seems most NGOs either lack resources, skills, competence or the knowledge to carry out a scientifically rigorous field study. NGOs should not grudge GEAC if their poor quality reports are not being taken seriously. Even the scientific community does not take cognizance of these reports. All the negative reportage from NGOs cannot seem to explain the paradox of increased Bt-cotton acreage year after year. If NGOs still think they have done a scientifically competent job of carrying their studies, then they should simply submit their reports to a peer review process and earn some credibility for their reports.

Positive reports published by IMRB, the largest market survey company in the country shows the overall performance of Bt-cotton in good light. Their results seem to be congruent with the increased sales of Bt-cotton seeds and planting acreage. Not withstanding the fact that the positive reports of the performance of Bt-cotton are put out by its owners, a critical review shows that the methodology used is an universally accepted survey method with a large enough sampling from all Bt-cotton cultivating areas of the country to be truly statistically significant, and done consistently for three years in a row. Consistency, standardized methodology and reliability are evident from the data from these reports. Because the methodology is clearly explained, it is easy to cross-check results with their sampling data to confirm their conclusions. What is important in trusting any report is the sound methodology used and not who did the survey?

Going by international standards of survey methodology, the reports by IMRB seem reliable even if one can lop 25% off the top. But, anti-biotech NGOs will have none of it. Yes, indeed IMRB report is also not peer reviewed, and it would be advisable for the developers of Bt-cotton to submit their data and analysis for publication in a peer reviewed journal. There are other peer reviewed publications on the commercial performance of Bt-cotton. A paper published in Current Science in June 2004 by scientists of the Indian Agricultural Research Institute (IARI) from a study conducted in Maharashtra clearly demonstrated positive performance of Bt-cotton under farmer's field conditions. Another publication is a survey conducted by University of Reading in Maharashtra published in Agbio Forum in 2004 also demonstrated positive performance of Bt-cotton. The third one was published in the April 9 2005 issue of EPW which is already under attack by the NGO community. In this paper, the sample size is small covering four different states where Bt-cotton was grown, but their statistical treatments of the data is authentic and have come to some reasonable conclusions and offer explanations for some of the paradoxes. Another weakness of the paper is that it draws its conclusions based on just the first year (2002) of commercialization. It is necessary to have used all the three years of commercialization data to make their conclusion more credible and reliable. Peer review does not always guarantee correctness or accuracy, but that is the only known method to affirm any credibility to a scientific study. The rest are just there to serve self-fulfilling ideologies and propaganda.

Regarding the indifferent reports of mixed performance of Bt-cotton published by state agricultural universities and both GEAC monitoring committees and state agricultural departments, the less said the better. The same can be said about the state agricultural universities. Indeed it is unfathomable that none of the competent and qualified scientists of the establishment either at the state level or at the central level have seen it fit to carry out a comprehensive assessment of the agronomic performance and economic impact of Bt-cotton all these years, especially when it is under the microscope.

The only agency that seems to have the sole privilege of having some sort of a "reliable" quality data on Bt-cotton based on which they have been granting approvals is GEAC, but it is not making it public. Even the data from ICAR's coordinated field tests have not made public. Here is a paradox where all the unscientific reports of NGOs are known world wide (thanks to their media relations, and dogged persistence), indifferent government reports that are hardly publicized, and positive reports of the developers that are not trusted. But, the only proof positive thing is more and more Bt-cotton varieties are being authorized and Bt-cotton acreage keeps increasing. No farmer has filed a case against GEAC or the developer of Bt-cotton to claim compensation for their alleged failures or losses. Many NGO reports indicate that they have contacted hundreds of farmers who have suffered losses due to Bt-cotton. If that is the case, then they can consider filing a class action suit in a consumer court and obtain relief for them. One would think that if NGOs can find so many farmers whose Bt-cotton failed, it should not be difficult to find equal number of farmers who had success with Bt-cotton using similar methods by some other "independent" study groups. It is just a question of who is doing it for what purpose?!?!

One thing is clear that Bt-cotton technology works for the purpose it is designed. It does not control non-target pests for which the farmers have to spray chemical pesticides. It is also generally clear that the germplasm of MECH varieties of Bt-cotton are inferior to some other hybrid cottons in the market during the development phases of the MECH varieties. Variability in performance is a natural order of all newly introduced varieties, GM or no GM. If the introduced varieties perform to the basic minimum level across the board as claimed, then they are considered successful. Most new varieties have market span of three to six years and seldom a decade. New and improved varieties usually displace old varieties and those that do not perform well, and business of improving agriculture goes on. Now that new Bt-cotton varieties have been approved, the problem of under or poor performing varieties will be taken care of. Farmers all over the world and especially Indian farmers are extremely astute to quickly decide whether it is good for them to grow the same variety twice, and they will make proper and correct decision on these varieties.

If NGOs are serious about the credibility of their reports, they should pool their resources and hire competent scientists to carry out scientifically rigorous field study on the performance of Bt-cotton in future, and then plan their activism based on high quality peer reviewed data. That would be a just case for activism in the name of the public good. In light of so many instances of illegal GM crops getting mixed in all parts of the world lately, many anti-biotech NGOs are demanding peer review quality test results for GMO certification, and why not? When NGOs demand high scientific standards of others, then they too should live up to the same high standards, and that goes for GOs as well. As far as GEAC is considered, it would serve a just public cause by convening an independent scientific panel to review all these reports and then determine which one of them deserves to be taken cognizance of. The rest can be ignored for the good of the public.

P.S: This commentary is based on a forthcoming comprehensive review of all reports available in the public domain on the performance of Bt-cotton in India since its commercialization in 2002.