There's an urgent need for messages of concern to be sent to India's GM regulators - the GEAC - who are about to meet to discuss the findings of government scientists at the Central Institute for Cotton Research which show Bt cotton is ineffective against the bollworm.

It's vital that the GEAC now revoke their multiple permissions to Bt Cotton and drastically revamp their unscientific and opaque decision-making processes that made possible these disastrous approvals.

It's vital, says Kavitha Kuruganti, on bahalf of Greenpeace India and the Centre for Sustainable Agriculture in Andhra Pradesh, that as many questions as possible are now raised over how this faulty and problematic technology ever came to be approved with such damaging consequences for many cotton farmers in India.

Date: Sun, 7 Aug 2005 15:25:54 +0530
From: Kavitha Kuruganti This email address is being protected from spambots. You need JavaScript enabled to view it.

Dear friends,

on the 10th of august, GEAC is expected to meet and discuss the shocking findings put out by CICR on Bt Cotton and on the ineffective toxin expression from the plant. for many cotton farmers of this country who had adopted Bt Cotton, this is in fact too late.

many of you must have seen the Central Institute for Cotton Research's findings on the ineffectiveness of Bt Cotton on many fronts. The findings reflect the erratic results on the ground that have been reported by many NGOs and independent agencies right from the first year of commercialisation and the fact that thousands of farmers have incurred losses with Bt Cotton while the companies and the government continue to promote it aggressively as the solution.

This brings us back to questions raised in the first instance on the technology per se as well as on the decision-making processes that this country follows with regard to genetically engineered crops.

For your information, the following links take you to two scientific studies that are relevant here, including the CICR study that has been published on july 25th and an earlier study by UAS, Dharwad on baseline resistance to Bt toxin in bollworms.
2. pdf

On behalf of CSA and Greenpeace India, I request you to please take a few minutes to send a mail and/or fax to the Chairperson, GEAC demanding that they revoke their permissions to Bt Cotton and that they revamp their decision-making processes drastically. I am attaching a model letter that you could use as is or make whatever changes are necessary, to be sent to :

Shri Suresh Chandra, GEAC Chairperson at This email address is being protected from spambots. You need JavaScript enabled to view it. or faxed to 011-24363967.

For those of us working against certain agricultural technologies and decision-making processes that promote the technologies in an unscientific and opaque manner, this CICR study epitomises what we suspected all along and therefore, it is important that we act now and put pressure on the GEAC. Could you therefore please send your mail/fax to the above contacts on the 8th and 9th, before the GEAC meets on the 10th of august? thanks.

To August 6, 2005
Shri Suresh Chandra
The Chairperson
Genetic Engineering Approval Committee [GEAC]
Ministry of Environment & Forests, Paryavaran Bhawan,
CGO Complex, Lodhi Road, New Delhi.

Dear Sir

Sub: CICR findings on expression of Cry1Ac toxin in Bt Cotton GEAC's liabilities arising out of the findings

The Central Institute for Cotton Research, which falls under the ICAR had recently published some alarming findings from a study done by the agency in the 2003 cotton season in Current Science (July 25 th 2005 edition) [1].

From this study, the following findings emerge starkly, raising several unanswered questions and concerns with regard to Bt Cotton as well as decisions taken on transgenic crops in this country. These findings are being quoted below from the recently published paper in the words of the authors as much as possible.

The quantitative levels of Cry1Ac differed significantly among the eight commercial Bollgard hybrids tested it is 2 to 7-fold variable among the different hybrids.

The Cry1Ac expression was found to be variable also between different plant parts the leaves of Bt Cotton plants were found to have the highest levels of Cry1Ac expression followed by squares, bolls and flowers while very importantly, the toxin expression in the boll rind, square bud and ovary of flowers was clearly inadequate to confer full protection to the fruiting parts. These are the parts which constitute the most favored sites of bollworm attack.

The higher levels of expression in leaves are more advantageous to Bt Cotton in USA where Heliothis virescens (tobacco budworm, a major pest in the USA) compared to those countries where Helicoverpa armigera is the major pest on cotton like in the case of India. Here, it is worth noting that Helicoverpa species are at least ten-fold more tolerant to the Cry1Ac protein compared to the tobacco budworm.

Increasing levels of Helicoverpa armigera survival were correlated with the toxin levels decreasing below 1.8 µg/g in the plant parts. The CICR scientists felt that from a practical standpoint in understanding farmer complaints related to bollworm survival on Bt Cotton.

The Cry1Ac expression declines progressively over the crop growth with toxin levels falling below the critical level of 1.9 µg/g after 110 DAS [Days After Sowing]. The decline in Cry1Ac expression was more rapid in some hybrids compared to the others. The results suggest that the decline in Cry1Ac expression is more rapid in medium to long duration hybrids, as was evident with Bollgard MECH 162, Bollgard RCH2 and Bollgard RCH 20.

The data available support the presumption that Bt Cotton hybrids in India may require more supplemental insecticide sprays than being used on Bt Cotton varieties elsewhere in the world.

A global analysis on the comparative performance of Bt Cotton varieties and hybrids against bollworms indicates that Bt Cotton Varieties appear to be more effective in controlling the Helicoverpa species compared to the hybrids grown in India.

"Hence, the Indian farmer would have to be mentally prepared for the possibility of extra supplemental insecticide applications for bollworm control on Bt Cotton hybrids".

These findings raise several important and urgent questions especially on the functioning of Genetic Engineering Approval Committee (GEAC) that you head:

Why were such studies as the CICR one, conducted in 2003 season, not done much before Bt Cotton hybrids were commercialized in India?

What did GEAC do about asking for such studies to be done?

What kind of results can be expected if CICR did the same study over several seasons given that Bollworm survival was found to be increasing, with toxin levels decreasing?

Why did the CICR choose to publish the findings now in July 2005 in Current Science?

In what way did CICR use its findings to influence decision-making at the DBT and GEAC levels?

What did GEAC then do with the findings?

If it is known that Bt Cotton is more effective against tobacco budworm rather than cotton bollworm and is therefore a technology more suitable for the Americans than the Indian farmers, what was done about it?

If it was known that Bt Cotton is more effective in varieties rather than in hybrids as in the case of India, why was it allowed on hybrids, unless to help the profit-making ventures of agri-business companies which only deal with cotton hybrids and not varieties?

If the variability of toxin expression is so significant amongst different hybrids (2 to 7 fold variability), what are the implications for bio-safety? This country has decided to do away with elaborate biosafety tests once an event is approved and goes in only for agronomic tests and that too, for only one year in some cases. However, the CICR results clearly caution us about the dangers of such an approach. What are the different biosafety tests taken up for these different hybrids that have been approved so far? Does GEAC know the toxin expression levels for each of these hybrids, in different parts of the plant, across the whole season and was this information created before the approvals were granted?

If there is a rapid decline in Cry1Ac expression in certain hybrids like RCH2 Bt and RCH 20 Bt, and if these findings emerged around the same time that GEAC was taking a decision on approval for commercial release of RCH2Bt, what did CICR do about influencing the decision? What did GEAC do about the findings that CICR would have presented to it?

Equally importantly, if the toxin expression is the lowest in the most favored sites of bollworm attack the ovary of flowers and the boll rind of green bolls what is the technology ultimately guaranteeing? What is GEAC in turn guaranteeing to the farmers of this country when it is approving and clearing these hybrids for commercial cultivation?

If we combine the findings of this study with an earlier study done by University of Agricultural Sciences, Dharwad which shows that baseline resistance to Bt toxin is already high in several populations of bollworm in several locations of Bt Cotton hybrid cultivation, we are faced with the ludicrous situation where on the one hand, the toxin expression is the lowest in the most vulnerable parts of the cotton plant (vulnerable to bollworm attack) and on the other hand, there is already resistance existing in several cotton growing locations to such toxins!

This whole situation clearly vindicates the position that NGOs and independent agencies have been taking for years now about the technology being imprecise and out of control and your decision-making processes being unscientific, irrational and opaque. We are very concerned about the manner in which such studies are taken up only after decisions for commercialization are made, while GEAC does not wait to heed from such findings even afterwards.

In this context, we demand that the GEAC revoke all the approvals given so far for Bt Cotton commercial cultivation. GEAC should make itself liable for the losses incurred by farmers in many locations because of the failure of the technology.

We once again demand that all studies being conducted in the country and their findings whether of the public sector or the private sector based on which your decisions are being made be put in the public domain immediately for independent scrutiny and make your approval procedures broad-based and transparent.

(Organisation, if applicable):

[1] "Temporal and intra-plant variability of Cry1Ac expression in Bt Cotton and its influence on the survival of the cotton bollworm, Helicoverpa armigera", Kranthi K R et al (of Central Institute for Cotton Research, Nagpur), Current Science, Vol 89, No 2, 25 July 2005