Hon'ble Minister Sir,

India is an important signatory / member of UNEP-Convension on Biological Diversity (Except USA all other countries are signatories of CBD). This year (2010) being the year of International Biodiversity we look forward to the ministry to critically evaluate the warning and concerns of eminent scientists on BT-Brinjal. A sample of warnings from eminent Scientists, Environmentalists, UN Bodies all are given in the following pages for your view...

The international "Convension on Biological Diversity" or CBD says the following in Article 8 - In-situ conservation (of biological diversity) - Article 8(g), 8(h), 8(i), 8(j), given below:

(g) Establish or maintain means to regulate, manage or control the risks associated with the use and release of living modified organisms resulting from biotechnology which are likely to have adverse environmental impacts that could affect the conservation and sustainable use of biological diversity, taking also into account the risks to human health

(h) Prevent the introduction of, control or eradicate those alien species which threaten ecosystems, habitats or species;

(i) Endeavour to provide the conditions needed for compatibility between present uses and the conservation of biological diversity and the sustainable use of its components;

(j) Subject to its national legislation, respect, preserve and maintain knowledge, innovations and practices of indigenous and local communities embodying traditional lifestyles relevant for the conservation and sustainable use of biological diversity and promote their wider application with the approval and involvement of the holders of such knowledge, innovations and practices and encourage the equitable sharing of the benefits arising from the utilization of such knowledge, innovations and practices;

As the CBD defines biodiversity as genes, species and ecosystems. The impact of alien genes and alien ecosystems is often more destructive to entire biodiversity than just only species.

Please note that CBD themselves say that GMO could adversly affect the environment - "modified organisms resulting from biotechnology which are likely to have adverse environmental impacts that could affect the conservation and sustainable use of biological diversity" - Thus any and all introduction of GMO’s should be assessed under the CBD before any release is considered, as a nation we have overlooked and made a mistake with respect to BT-Cotton which has resulted in large scale damage to cattle and other species of native Cotton and with respect to BT-Brinjal we must prevent another CATASTROPHE.

Honerable Minister Sir, we request your esteemed office to prevent the entry of further GMO in India (trial & commercial), where we being the custodians of one of world's largest region of biodiversity have responsibility to protect it for the future & safety of humanity.

UNEP has defined India as "One of the "megadiverse" country and is composed of a diversity of ecological habitats like forests, grasslands, wetlands, coastal and marine ecosystems, and desert ecosystems. Almost 70% of the country has been surveyed and around 45,000 plant species (including fungi and lower plants) and 89,492 animal species have been described, including 59,353 insect species, 2,546 fish species, 240 amphibian species, 460 reptile species, 1,232 bird species and 397 mammal species"

Cordially,
CG Krishnamurthi, Environmentalist, Chennai India email This email address is being protected from spambots. You need JavaScript enabled to view it.
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1. What the GM companies themselves say about GMO

Syngenta:
“If anyone tells you that GM is going to feed the world, tell them that it is not. To feed the world takes political and financial will”
- Steve Smith, SCIMAC and Novartis (now SYNGENTA), in Tittleshall Village Hall public meeting on proposed local GM farm scale trial, on 29th March 2000

Sanofi-Aventis:
"GM crops may reduce chemical use and they may increase yields - but GM crops will not feed the world."
- Paul Rylott - Aventis - at a public meeting at Low Burnham, Lincs on Wednesday April 18, 2001

2. What the US Govt. Agri dept. says about GMO

"GE crops available for commercial use do not increase the yield potential of a variety. In fact, yield may even decrease.... Perhaps the biggest issue raised by these results is how to explain the rapid adoption of GE crops when farm financial impacts appear to be mixed or even negative"
- US Department of Agriculture report, May 2002

3. What the United Nations say about GMO

1. UN-IAASTD
"The claims of higher yield potential of GM crops is wrong and they do not increase yield compared with conventional farming practices"
- 2008, UN IAASTD Report - 'Global Summary for Decision Makers (IAASTD)'; Beintema
United Nations - IAASTD (International Assessment of Agricultural Knowledge, Science and Technology for Development). This report is culmination of a study conducted over a period of 7 years and  authored by 400 scientists and backed by 58 governments across the world.

2. FAO (Food and Agriculture Organisation)
FAO supports a science-based evaluation system that would objectively determine the benefits and risks of each individual GMO. This calls for a cautious case-by-case approach to address legitimate concerns for the biosafety of each product or process prior to its release. The possible effects on biodiversity, the environment and food safety need to be evaluated, and the extent to which the benefits of the product or process outweigh its risks assessed. The evaluation process should also take into consideration experience gained by national regulatory authorities in clearing such products. Careful monitoring of the post-release effects of these products and processes is also essential to ensure their continued safety to human beings, animals and the environment
- FAO statement on Biotechnology in Food and Agriculture (http://www.fao.org/biotech/stat.asp)

3. UNEP - (International) Convension on Biological Diversity (CBD)
Article 8(g): “Establish or maintain means to regulate, manage or control the risks associated with the use and release of living modified organisms resulting from biotechnology which are likely to have adverse environmental impacts that could affect the conservation and sustainable use of biological diversity, taking also into account the risks to human health”
- UNEP CBD Conservation Article  8(g), 8(h), 8(i), and 8(j)

4. What the Largest agricultural body in US say about GMO

"While feeding the hungry is a laudable goal, current record feed stocks in the U.S. is still not finding its way to those who need it the most. Therefore, the real reasons for hunger is not necessarily the lack of food but the lack of income to purchase and the absence of an infrastructure to get the food to those who need it the most. If the hungry cannot be fed with current worldwide overproduction, what guarantee is there that additional productivity will solve the problem?"
- American Corn Growers Association (2002)

5. What the courts say on GMO in USA:
The U.S. District Court for the northern district of California ruled that the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (APHIS) violated federal law by failing to prepare an environmental impact statement before deregulating genetically altered sugar beetroots.

Monsanto developed the biotech beets to be resistant to Monsanto’s glyphosate herbicide Roundup, and promotes the sugarbeetroots as “Roundup Ready.” In 2009, 1.1 million acres were planted with GMO sugar beets and almost half of the sugar in the U.S. is made from beetroots.

In addition to High Mowing Organic Seeds, the plaintiffs include the Center for Food Safety, Organic Seed Alliance and the Sierra Club. The groups filed the lawsuit in January 2008
- September 2009

6. What the large Aid donar NGOs say about GMO:
"The claim of biotech industry and the US Government that GM crops will 'feed the world' is a myth and a big lie; GM crops would undermine food security and the income of poorer farmers" 2007

- Christian Aid
- Action Aid
- Food First and the World Development Movement
- Farmers unions in Southern nations

7. What the Scientists say about GMO:
1. “After reviewing more than 600 scientific journals,  concludes that genetically modified organisms (GMOs) are a major contributor to the sharply deteriorating health of Americans and should be stopped”
- Dr. Pushpa M. Bhargava, World renowned Molecular Biologist, Member of National Knowledge commission, Member GEAC, Ministry of Environment & Forests, Govt. Of India

2. “The indigenous breeds of  brinjals and the biodiversoty will ultimately be lost. This will result in a monopoly of a particular multinational corporation of US (Monsanto)”
- Dr. Tushar Chakraborty, Gene Regulation Laboratory, Indian Institute of Chemical Biology, Kolkata

3. “What has been of particular interest in this and past debates on the subject is the way in which those who oppose GM crops are painted as being against science (see for instance, the editorial in The Hindu on 21 October, 2009 or Starved for Science by R Paarlberg). There is a blatant attempt by GM promoters to polarise the discussion and manufacture a science-vs.-antiscience debate. All those who oppose GM crops are neither anti-science nor luddites. Indeed, many scientists have been, and still are, critical of GM for a number of good reasons. Scientists and scientific academies, including the National Research Council of the US National Academy of Sciences, have expressed serious concerns regarding the scientific rigour of experiments and the impacts of GM crops, especially on biodiversity.”
- Dr. Sujata Byravan, PhD, Molecular Biology, Nov 2009


4. "Several cases of violation of guidelines by the seed company, Mahyco (Monsanto Indian arm) with respect to health and environmental safety"  from the Report of the independent panel of Scientists on Bt brinjal. Panel members include of Prof. KP Prabhakaran (Former Prof. National Science Foundation); Dr. Ramesh Bhat, (Former toxicologist of the National Institute of Nutrition (NIN)); , Dr. A Narayanan (former ICRISAT plant physiologist); Dr. Ghafooruissa (former NIN biochemist); Dr. MS Chari (former director of Tobacco Research Institute); Dr. D Narsimha Reddy (former professor of economics, Hyd. University)

5. “From a recent comparative study of Bt and Non Bt cotton farmers in Karnataka. The study reveals that while the Bt farmers did get a marginally higher yield, the cost of getting this improved yield was so high that they ended up making less money! Thus, while the gross margin for non-Bt farmers worked out to Rs.10,880 per hectare, the margin for Bt farmers was a paltry Rs.1435. In other words, non-Bt farmers were earning 7.5 times more than Bt farmers.”
- Dr. Ashok Malkarnekar, Dr. Hermann Waibel and Dr. Diemuth Pemsl of the Chair of Agricultural and Development Economics, School of Management and Economics, Hannover, Germany

6. “I feel, we should take time to judge the suitability of Bt Brinjal for the human consumption in India. As such, with plenty and cheap Brinjal Production these days in India, there is no urgent need to spread such GMO Bt brinjal for the cultivation in India where at present over 3000 land races and varieties are available as our  Genetic variability in Brinjal. With the introduction of such untimely introduction of the GMO BT- brinjal, all such land races and many local varieties will be lost in the future?”
- Dr. Ramesh B thakare, Geneticist and Vice Chairman Bharat krishak samaj maharashtra
A largest farmers NGO for the farmers causes in India (Former World Bank ADB USAID Agric Project Adviser in Africa and In Charge Seed Project in Uganda with the EEC ADB Seed Project).

7. “Genetically modified organisms contain inherent risks to biodiversity and human health.”
-  Dr. S. Faizi, Scientist & Chairman of Indian Biodiversity Forum

8. “We should keep away hormones, antibiotics, slaughterhouse waste and genetically modified organisms (GMOs) and Pesticides should not be allowed to enter any food.”
- Dr. Shiv Chopra, Fellow WHO, Food safety expert, former scientific advisor to the Candian Ministry of Health (who exposed the curruption in approving GMO foodstuff in Canada)

9. “The genetically engineered organisms could possibly make all plant life poisonous. The implications are nothing short of terrifying. Anyone that says, ‘Oh, we know that this is perfectly safe,’ I say is either unbelievably stupid or deliberately lying.”
- Dr. David Suzuki, Geneticist

10. “GM seeds and BT Brinjal /BT Cotton are dangerous to the nature, human and animal health and will lead to GM contamination which can't be reversed”
- Prof. Sultan Ahmed Ismail, World renowned Vermicologist, India

11. “GM foods pose serious health risks”
- American Academy of Environmental Medicine (AAEM) on May 19, 2009 - based on several live human cases and animal tests by scientists

12. “The ecosystem, you can always intervene and change something in it, but there's no way of knowing what all the downstream effects will be or how it might affect the environment. We have such a miserably poor understanding of how the organism develops from its DNA; that I would be surprised if we don't get one rude shock after another”. - on GE crops in late 1990s
- Prof. Richard Lewontin,  former Dean of Genetics, Harvard University

13. “Many GMO Soy vareities, including RR soybeans produce lower yields than comparable non-GM varieties. They produced between 5.3% and 10% less than conventional varieties.” After a  large study and review the results of over 8,200 university-based soybean variety trials (yields) in 1998.
- Dr. Charles Benbrook, former Executive Director, Board on Agriculture of the National Academy of Sciences, USA

14. “It is my considered judgment that employing the process of recombinant DNA technology (genetic engineering) in producing new plant varieties entails a set of risks to the health of the consumer that are not ordinarily presented by traditional breeding techniques.”
-  Dr. Richard Lacey, M.D., Ph.D in Genetics, Food saftey expert,  former Professor of Medical Microbiology at the University of Leeds, UK

15. “The instability of transgenic lines has been well known since 1994, particularly in connection with gene silencing. This not only affects agronomic performance, but also safety. We have drawn attention to the structural instability of GM constructs in general, which may enhance horizontal gene transfer and recombination.”
- Dr. Mae-Wan Ho, Geneticist-Scientist, The Institute of Science in Society, London, UK, Author of the book:  Genetic Engineering: Dream or Nightmare? (1998)

16. “Given the fact that genetically modified plants are going to make proteins in different amounts and perhaps totally new proteins than their parental species, what are the potential outcomes? A worst case scenario could be that an introduced bacterial toxin is modified to make it toxic to humans. Direct toxicity may be rapidly detected once the product enters the marketplace, but carcinogenic activity or toxicity caused by interaction with other foods would take decades to detect, if ever”
- Professor David Schubert, Cell Biologist, Cellular Neurobiology Lab,  The Salk Institute for Biological Studies, San Diego, USA

17. “The presumption of "Substantial Equivalence" - the basis for current regulatory principles (for approval of GM crop and food stuff- is profoundly flawed and scientifically insupportable.”
- Professor Patrick Brown, Scientist, College of Agriculture & Environmental ScienceӬUniversity of California

18. “ Since 1983, I have closely studied various safety issues concerning the use of recombinant DNA technology (RDNA technology; genetic engineering) to develop new plant varieties. My involvement has been both intensive and extensive.  My own analyses, as well as a substantial body of published research, clearly establish that these types of unintended side effects are risks of GMO that cannot be lightly discounted.  It is because I view the FDA's policy and practices regarding genetically engineered food to be irresponsible -- and also I regard the consequent risk posed for public health to be substantial”
 - Philip J. Regal, Ph.D, Biologist, College of Biological Sciences & Professor of Ecology, Behavior and Evolution at the University of Minnesota, USA

19. MON863 (from Monsanto) a GM Corn variety is found cause toxicity in liver and kidney
 - American Academy of Environmental Medicine (AAEM)

20. “Say no to GM Foods” & “Halt GM Crop Trials”
- The British Medical Association (BMA), which has a membership of over 120,000 medical professionals and represents more than 80% of British doctors

21. “Deoxyribonucleic acid, or DNA, is the blueprint for life. Inside every cell in your body, DNA contains the code that determines what a life form is and what are the physical physiological characteristics of that life form. Any alteration could have catastrophic effect on the health and evolution of the species”
- GM food safety expert Dr. Arpad Pusztai

22. "Genes exist in networks, interactive networks which have a logic of their own. The technology point of view does not deal with these networks. It simply addresses genes in isolation. But genes do not exist in isolation. And the fact that the industry folks don't deal with these networks is what makes their science incomplete and dangerous.”
 - Richard Strohman, Ph.D., Professor Emeritus, Department of Molecular and Cell Biology”¨University of California at Berkeley

23. “ICGEB defines Bio-saftey as the avoidance of risk to human health and safety, and to the conservation of the environment, as a result of the use for research and commerce of infectious or genetically modified organisms”
- ICGEB (International Centre for Genetic Engineering and Biotechnology), UN-IDO
8. What the Environmentalists say about GMO:
1. “GMO is only about profits for Multinational Seed companies through patended seed sales and patended herbicide sales and has nothing to do with feeding the world, etc. as claimed, the yields of BT cotton in many areas in Andra is lower than conventional farming which led to several farmer suicides”
- Dr. Vandana Shiva, Navadanya Environmentalist, India

2. “For the first time in history, transnational biotechnology corporations are becoming the architects and 'owners' of life with GMO”
- Dr. Jeffrey Smith, Scientist and Author of 'Seeds of Deception'

3. Genetically engineered crops were created not because they're productive but because they're patentable. Their economic value is oriented not toward helping subsistence farmers to feed themselves but toward feeding more livestock for the already overfed rich.
- Amory and Hunter Lovins, Founders of the Rocky Mountain Institute

4. “GE Crops Can't Be Contained”
Findings of Wall Street journal after conducted a test in 2005. Found that 16 of 20 vegetarian foods labeled as being "free" of geneticalty engineered products actually contained GE soybeans.

5. “You cannot build a wall high enough to prevent genetic pollution of wild and organic crops”
- Dr. Arran Stephens, President Nature's Path Foods

6. In 2000 alone, a coalition of biotech companies spent a $50 million media /PR campaign to keep fears about genetically altered foods from spreading through the US. Bankrolling the campaign (which included $32 million in TV and print advertising) were Monsanto, Dow Chemical, DuPont, Swiss-based Novartis, the British Zeneca, Germany's BASF and Aventis of France. The ads, complete with soft-focus fields and smiling children, pitched "solutions that could improve our world tomorrow" and could help end world hunger.
- John Robbins - author of 'Diet for a New America', Founder Earth Save International, 2007

7. “Science is being utterly abused by all sides for nonscientific purposes,” said Benedikt Haerlin, head of Save Our Seeds, an environmental group in Berlin
 - Benedikt Haerlin, former member of the European Parliament

8. “After a dozen years, I still oppose genetically modified crops. This may sound like sheer truculence on my part ”” a Luddite reluctance to accept the future. It is certainly dispiriting. Like many people, I feel, as I did a decade ago, that genetically modified crops were introduced with bland assurances of safety based on studies from small test plots, a far different thing from the uncontrolled global experiment we now find ourselves in the midst of. GMO represents the final transfer of the collective farming wisdom of the human race into corporate hands”
- Verlyn Klinkenborg - Member Editorial board - New York Times

9. Ninety-nine per cent of commercially grown GM crops have been engineered to exhibit just two traits herbicide tolerance and insect resistance. The agricultural biotech industry is dominated by just a handful of multinational corporations: Syngenta, Bayer CropScience, Monsanto, Dow Chemicals, BASF and DuPont. In 2001 these firms had a combined revenues from seeds and agrochemicals of $27.6 billion and in 2007 they have grown to over $100 billion in revenues

Company        Agrochemical        Seeds/biotech         Total
  sales (2001)          ($ million)              ($ million)           sales ($ million)            

Syngenta              5,385                     938                      6,323
Bayer Aventis         6,086                      192                      6,278
Monsanto              3,505                 1,707                   5,212
DuPont                1,922                 1,920                     3,842
BASF                  3,114                     0                     3,114
Dow Chemicals    2,627                      215                   2,842
Total                         22,639                 4,972                            27,611
- AgriFutura (29), - Phillips McDougall AgriService, US, 2008

10. “GMO is dangerous to health, environment, economy and future of India. study (by GEAC) has completely ignored the adverse effects of consuming Bt Brinjal in the next generation and various other areas before introducing this poisonous vegetable for human consumption.”
- Devindar Sharma, Food Policy analyst

9. What is the status of BT-Cotton which was introduced few years back?

1. BT-Cotton in Andra Pradesh leads to death of 1,820 sheeps in just 4 villages, 2006

The Bt trail of dead sheep, ill workers and dead villagers over three years. At least 1 820 sheep were reported dead after grazing on post-harvest Bt cotton crops; the symptoms and post-mortem findings strongly suggest they died from severe toxicity. This was uncovered in a preliminary investigation conducted by civil society organisations in just four villages in the Warangal district of Andhra Pradesh in India. The actual problem is likely to be much greater.
This latest report confirms the findings of an earlier fact-finding investigation, also conducted by civil society organisations, on illnesses in cotton farm workers and handlers caused by Bt cotton in another cotton-growing state, Madhya Pradesh, in India (“More illnesses linked to Bt crops”, this series).
And not so long ago, we reported similar illnesses and deaths among villagers in the Philippines linked to exposure to Bt maize since 2003 (“GM ban long overdue, dozens ill and five deaths in the Philippines”, Institite of Science in Society 29)

2. Farmer Suicides and Bt Cotton Nightmare Unfolding in India

5000-odd farmers of the Maharashtra village have decided to shun Bt cotton, and are now growing soybean instead. Some have also taken to organic farming.
“We were cheated by the seed companies. We did not get the yield promised by them, not even half of it. And the expenditure involved was so high that we incurred huge debts. We have heard that the government is now planning commercial cultivation of Bt brinjal. But we do not want Bt seeds of any crop anymore,” said farmer Sahebrao Yawiliker.
Successive studies in Maharashtra have concluded that indebtedness was a major cause of suicides among farmers [4].
Within a week, two farmers in neighbouring villages in Wardha district killed themselves. Their Bt cotton crops were devastated by lalya, a disease that caused the cotton plants to redden and wilt [5]. The first farmer, 55 year old Laxman Chelpelviar in Mukutban, consumed the pesticide Endoulfan when the first picking from his six-acre farm returned a mere five quintals and an income of Rs.15, 000, way below his expenses of Rs.50,000.  The second farmer, 45 year old Daulat Majure in Jhamkola, was discovered by his mother hanging dead from the ceiling. The cotton yield from his seven-acre farm was a miserable one quintal, worth Rs3,000.
Agricultural scientists said lalya points to a lack of micronutrients and moisture content in the soil. Lalya develops with pest attacks, moisture stress and lack of micronutrients in the soil. The plant’s chlorophyll decreases with nitrogen deficiency, resulting in another pigment, anthocyanin, which turns the foliage red. If reddening starts before boll formation, it results in a 25 percent drop in yield, said a scientist from the Central Institute of Cotton Research at Nagpur, who wished to remain anonymous. “Lalya is here to stay.” He declared.
According to the agricultural scientists, the disease has its roots in the American Bt technology that India imported. Almost all of the 500-plus Bt seed varieties sold in India in 2009 are of the same parentage, the American variety Coker312 Bt cotton, a top CICR scientist said. They are F1 hybrids, crossed with Indian varieties.
Coker-312 (initially from Monsanto) showed high susceptibility to attacks by sucking pests like jassids and thrips. The thrips disperse within plant cells, while jassids suck the sap as they multiply under a leaf’s surface, forcing the plant to draw more nutrients from the soil, aggravating the soil’s nutritional deficiency.
Another characteristic of Bt cotton that depletes the soil is that the bolls come to fruition simultaneously, draining the soil all at once. In a region like Vidarbha, plants wilt in two or three days. “It is like drawing blood from anemic woman.”
“If such a technology mismatch continues, soil health and farmers’ economy will take a further hit,” a top ICAR scientist with years of experience in cotton research was reported saying [5]. “The state needs to take up soil and water conservation efforts on a war footing in Vidarbha.”
India has about ten million ha under hybrids and Bt cotton, much higher than in China (6.3 m ha), US (3.8 m ha) and Pakistan (3.1 m ha). Unlike India, 79 other countries use self-seeding and non-Bt hybrids.
The cotton crisis and successive crop failures due to declining soil health goes hand in hand with the imported GM (genetic modification) technology, which is energy and input intensive, the report [5] concluded
- ISIS Report 06/01/2010 (full report http://www.i-sis.org.uk/farmersSuicidesBtCottonIndia.php)

10. Organic Farming is it profitable for farmers?
Certainly yes. Poabs Group, Khandige, Fabmall, Enfield, Pro-Organic, and scores of other Agricultural companies are into Fully certified organic crops and food products mainly for export markets. If organic farming is not profitable then why would these companies invest millions into Organic agricultural ventures. If Indian government trains and helps farmer cooperatives to promote organic farming and obtain group certification it can lead to a lot of income (forex) from farm products exports as well as create a sustainable livelihood for farmers and protection of the environment and ensuring food safety, food security, food soverignity and sustainability