The Report of the Expert Committee (EC-II) on Bt. Brinjal Event EE-1 Developed by. M/s Maharasthra Hybrid Seeds Company Ltd (MAHYCO), Mumbai

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1 January 12, 2010 To, Mr. Jairam Ramesh Hon ble Minister of Environment & Forests Paryavaran Bhavan CGO Complex, Lodhi Road New Delhi SUB : NATIONAL CONSULATION ON BT. BRINJAL Dear Jairam, I would like to begin by thanking you for taking the initiative to hold public hearings on Bt. Brinjal. I think it is the first time a humble vegetable has been made the subject of a National Consultation. On behalf of the baigan and millions of small baigan growers who have conserved the rich diversity of brinjal in India, thank you. I write to you as an expert on Biosafety who made major contributions for the introduction of Article 19.3 on Biosafety in the UN Convention on Biological Diversity and was a member of the expert group on Biosafety set up by the Convention to evolve the framework of the Biosafety protocol and as an advisor to many Governments on issues of Biosafety. I also write to you as the Founder of Navdanya, the largest network of organic producers in the country. My main concerns are the false scientific assumptions underlying the Biosafety assessment of Bt. Brinjal and the impact of Bt. Brinjal and GM crops on our organic farmers. The Report of the Expert Committee (EC-II) on Bt. Brinjal Event EE-1 Developed by M/s Maharasthra Hybrid Seeds Company Ltd (MAHYCO), Mumbai University of Agricultural Sciences (UAS), Dharwad and Tamil Nadu Agricultural University (TNAU), Coimbatore Submitted to the Genetic Engineering Approval Committee, Ministry of Environment and Forests, is unfortunately scientifically unsound at the level of food and agriculture systems, and in the context of the organic alternative. Wrong Rationale : Bt. Brinjal is not an alternative to chemical pesticides, Organic Farming is the real alternative The Rationale for the development of Bt. Brinjal presented by EC-II, is based on the false assumption that genetically engineered Bt. crops like Bt. Brinjal are an alternative to the use of chemical pesticides for pest control. 1

2 The panel does not address the real alternative to chemical agriculture which is organic farming based on the principles of agro-ecology. Biodiverse organic farming controls pests at the systems level by enhancing pest-predator balance and by growing crops with pest and disease resilience. Increasing ecological balance and resilience are the only effective and sustainable strategies for controlling pests. The 500,000 members of Navdanya know this through practice. Research on agro-ecology confirms that ecological / organic farming systems reduce pests and have no need for the use of pesticides. In Indonesia, restrictions were introduced on the use of 57 pesticides in rice-growing, and subsidies for pesticides were eliminated. From 1987 to 1990, the volume of pesticides used on rice fell by over 50 per cent, while yields increased by about 15 per cent. Farmers net incomes increased by $I8 per farmer per season. The Government saved $120 million per year by ending pesticide subsidies. (Thrupp, New Partnerships for Sustainable Agriculture, 1997) In Bangladesh the No Pest programme led to pesticide reduction of 76 per cent and yield increases of 11 per cent. Returns increased by an average of 106 per cent in the dry season and 26 per cent in the wet season (Thrupp.) The panel has totally ignored the real alternative to chemical pesticides organic farming - in its rationale. It has distorted the organic alternative in its responses. Instead of seeing organic as a farming system, it has reduced it to external inputs. The report states In organic farming, the pest management totally relies on the use of botanical insecticides like neem oil, pongam oil, illupai oil or seed kernel extracts or leaf extracts which act as repellent, antiferdant or in some cases as toxins. None of the botanical pesticides are expected to perform well against the fruit and shoot borer (FSB) since the pest hides itself from the sprays while staying inside the fruits / shoot borer (p.60) This is an unscientific and false representation of the agro-ecological principles on which we have built the organic movement. Organic / ecological farming is not an input substitution system. It recognizes and respects the ecological processes through which pests are controlled and it also recognizes the processes through which pests are created. Pests are created through 1. Promotion of monocultures 2. Chemical fertilization of crops which makes plants more vulnerable to pests 3. Emergence of resistance in pests 4. Killing of friendly species which control pests and disruption of pest-predator balance Bt. crops are not an alternative to these pest creating systems. They are a continuation of a non-sustainable strategy for pest control which instead of controlling pests creates new pests and super pests. Bt. Brinjal, like Bt. Cotton, is grown as a monoculture, and is part of the package of chemical farming. Bt. Cotton, like Bt. Brinjal, was supposed to control the lepidopteron insects. In the case of cotton, the pest was the bollworm. In the case of Bt. Brinjal it is the fruit and shoot borer. In Bt. Cotton we have witnessed the emergence of new non target pests and diseases such as aphids, jassids, army bug, mealy bug and laliya. This has led to an increase, not a decrease in pesticide use. Navdanya studies show a thirteen fold increase in pesticide use in Vidharbha after the introduction of Bt. Cotton. 2

3 Area under BT Cotton and cost of Pesticide in Maharashtra Year Maharashtra Area under BT Cotton (Million Hectares) Cost of Pesticide (Rs. Crores) Cost of Pesticide of BT Cotton in Maharashtra during Genetically engineered Bt. crops also contribute to emergence of resistance in the target pests. The bollworm becomes resistant to the Bt. toxin when every cell of the plant releases it in high doses all time. The need for refugia and the introduction of Bollgard II are evidences of the emergence of resistance in pests as a result of using GM Bt. technologies. The economic benefits of Bt. Brinjal are distorted because they are based on the false assumption of savings of pesticide sprays and yield benefit due to protection of fruit and shoot borer. Bt. Cotton led to increased sprays and emergence of new pests. This risk in Bt. Brinjal has not been addressed. Nor has the cost of royalties, since Bt. Brinjal is patented. Seed cost in cotton jumped from Rs. 7 to Rs. 1700/- when Bt. Cotton was introduced. The real cost benefit calculation and comparison should be between organic brinjal cultivation based on open pollinated seeds that farmers can save and Bt. Brinjal whose seeds farmers must buy every year, and which will be suceptable to new pests for which more pestices will need to be used. In an honest and scientific assessment, benefits of biodiverse organic farming outweigh the benefits of Bt. Cotton. Navdanya s organic farmers have increased their incomes tenfold when they shifted from Bt. Cotton to organic cultivation 3

4 Cost Benefit Analysis of BT Cotton and Organic Cotton BT Cotton (Rs. / acre) Organic Cotton (Rs. / acre) A. Expenses; seeds; pesticides; fertilizer; irrigation; etc. A. Output Value A. Net Income (B A) Scientifically False Assumption of Substantial Equivalence The tests carried by Monsanto / Mahyco on biosafety have not looked at the risks posed by transgene Bt. They have used the microbial Bt. which is naturally occurring, is safe, and has been used as an organic spray for decades. The surrogate Bt. protein is not the same as the transgenic protein. Plants and bacteria are very likely to produce different proteins even when transformed with the same gene (Ref. D. Schubert, A different perspective on GM food, Nature Biotechnology, 20, , 2002). One difference is that bacteria do not add sugar molecules to proteins, but plants do glcosylation which can contribute to allergenic proteins. The National Academy of Science has recommended that tests should preferably be conducted with the protein as produced by the plant. The safety of microbial Bt. sprays cannot be used as proof of safety of transgenic Bt. Bt sprays are composed primarily of endotoxins in an inactive crystalline form. They are only toxic to insects with alkaline gut conditions that permit solubilisation of the crystal to protoxin, followed by proteolytic cleavage to the active toxin. Bt. crops on the other hand are generally engineered to produce the Bt. toxin, which is active without processing. There is also evidence indicating that Cry toxins are more immune reactive than Cry protoxins (Ref. William Freese and David Schubert, Safety Testing and Regulation of Genetically Engineered Foods in Stephen Harding (Ed) Biotechnology and Genetic Engineering Reviews Vol 21, no. 2004, p , Int.) The Bt has been engineered into plants as part of a high dose strategy. Transgenic Bt. Crops have orders of magnitude of higher Bt. toxin than the naturally occurring Bt. Yet MAHYCO and the panel claim that the use of microbial Bt. was necessary due to extremely low levels of Cry 1 Ac (Bt protein) produced in the plant and the requirement of large quantity of protein for these studies (P.38) If Bt expressed in GM crops is low, why use GM? Why not use the microbial pesticide that has been used for decades? The inconsistency in the justification and risk assessment is also evident in the false claim of substantial equivalence that the genetically engineered Bt is equal to the naturally occurring Bt. The report admits that the transgenic Bt. Brinjal contains a single integration consisting of three genes viz. cry 1Ac, npt 11 and aad. Cry 1 Ac Gene The Cry 1 Ac gene encodes for an insecticidal protein and has been derived from the common soil bacterium, Bacillus thuringensis, sub species kurstaki. Bacillus thurengensis strains have been used for decades in agriculture as the basis for microbial pesticide formulation. 4

5 npt 11 Gene The npt11 gene has been inserted as a selectable marker which confirms resistance to the antibiotics kanamycin and neomycin. aad Gene The aad gene encodes for the bacterial selectable marker which confers resistance to the antibiotics streptomycin and spectromycin (p.30-32) It is the integration of the three genes as well as the use of the agrobacterium mediated gene insertion and the use of the viral promoter CaMV 35S which need to be assessed for safety. Instead the proven safe microbial Bt is used for the biosafety tests. These tests merely confirm the safety of the natural Bt. Not the transgenic Bt. The bias of the panel is evident in the fact that it cites the non-regulation and non-assessment in U.S as evidence of safety but ignores the safety test results in France and Austria which have led to the GM bans in these countries. The scientifically false principle of substantial equivalence was put in place in U.S immediately after the Earth Summit to undo the articles on Biosafety in the Convention on Biological Diversity. The false assumption of substantial equivalence of GMOs and non-engineered organisms establishes a strategy of deliberate ignorance. Since the transgenic is never assessed, ignorance of risks is then treated as proof of safety. Don t look, don t see, don t find leads to total lack of information about the ecological impacts of genetic engineering. Substantial equivalence also contradicts the claim to novelty and invention through patents. Mahyco has a patent on Bt. Brinjal. When industry wants to avoid risk assessment and issues of liability, the argument used is that the genetically engineered organism is substantially equivalent to the non-engineered parent organism. However, when industry wants intellectual property rights and patents, the same GMO become novel or substantially in-equivalent to the parent organism. This is ontological schizophrenia. Risks of genetic pollution and contamination, and the threat to the democratic rights and freedoms of organic farmers Genetically engineered Bt. Brinjal can lead to genetic pollution and contaimination, by destroying the unique characteristics of biodiversity, by contaminating organic farms and by effecting beneficial species. Here too, totally unscientific arguments have been used by the panel to deny the ecological risks of genetic pollution. The panel cannot make up its mind whether Brinjal is self-pollinated or cross pollinated. Brinjal is a normally highly self-pollinated crop, however the scientific data with regard to cross pollination generated independently by various agencies shows a wide range of out crossing, suggesting its classification as an often cross pollinated crop. Therefore Indian researchers have reported 2 to 48% out crossing in brinjal varieties in India (p.38). There is similar variation in the pollen flow studies carried out by Mahyco and reported in the panel. When Mahycodid the pollen flow study in 2002, the percent out crossing of the Bt trait ranged between 1.46 to 2.7% and the maximum distance transversed by pollen from Bt. Brinjal plants was 20 m. In 2007, the out crossing had dropped to the range of 0.14% and 0.85%, and the distance the Bt. Pollen traveled had increased to 30 metres. Our vegetable growers often have less than a bigha of land. This level of genetic pollution will destroy our farmers who with love and care produce pesticide free, GMO free vegetables for citizens. Instead of recognizing that approval for commercial cultivation of Bt. Brinjal is a threat to organic growers, the panel carelessly and callously states 5

6 The section of farmers who have a preference for organic farming can do so by following established agronomic practices such as maintaining isolation distance, differences in flowers time etc. for preventing cross contamination and ensuring identity preservation for organic produce (p.60) Why should our small organic growers have to bear the burden of genetic pollution and the burden of avoiding contamination of their crops? Liability systems need to be evolved which make the company liable for economic damages to organic farmers. And till then there should b e a moratorium on Bt. Brinjal. The panel says there is no impact of GM Bt. Crops on soils. Our survey in Vidharbha shows a radical decline in beneficial soil micro-organisms in soils cultivated with Bt. Cotton. Effect on microbial population due to cultivation of Bt cotton Microoganisms Control soil (Non Bt Bt cotton plots% increase (+) orl e v e l Cotton plots) decrease (-) significant Actinomycetes ( 10 5 g -1 ) ** Bacteria ( 10 6 g -1 ) * Fungi ( 10 4 g -1 ) NS Nitrifiers ( 10 2 g -1 ) NS a Average of 25 plots; NS - Non significant; * significant at 5% level; ** significant at 1% level Activities of soil beneficial enzymes a due to the cultivation of Bt Cotton Types of enzymes Control soil (Non Bt B t c o t t o n % increase orl e v e l cotton plots) plots decrease significance Dehydrogenase * (p kat g -1 ) Esterase (EU 10-5 ) NS Acid phosphatase *** (EU 10-5 ) Alkaline phosphatase (EU NS 10-5 ) Nitrogenase ** (n mol C2H4 h -1 ) a Average of 25 plots; NS Non significant; * significant at 5% level; ** significant at 1% level; *** significant at 0.1% level o f o f Such studies have not been done in the impact assessment. The regulatory chaos is another reason why we need a moratorium on GMOs. In our case on Biosafety in the Supreme Court, the Government has argued the Biosafety will be regulated by the new Food Safety and Standards Authority under the Ministry of Health, not by the GEAC. Yet, the GEAC continues to give approvals on the basis of sloppy science. We need a public system of independent testing and assessment of GMOs. And we need scientific and regulatory coherence. Till such systems are put in place, no approvals for commercial releases should be granted. Bt. Brinjal is a test case for the future of our food, our democracy, our science. That is why it should not be introduced in our farms and our kitchens without a proper reassessment, especially in the context of false assumptions made to present Bt. Brinjal as the only alternative available ignoring the proven agro ecological approach to pest control. The safety tests should be done with transgene Bt, not with surrogate proteins. The genetic contamination risks also need reassessment given the scientific unsoundness on cross pollination data. There is no GM liability framework. This must be put in place to protect organic farmers. Above all, to avoid conflict of interest, developers of GM crops should not be engaged in the Biosafety testing. 6

7 2010 is the year of Biodiversity. We are celebrating it by protecting our indigenous vegetable biodiversity, and protecting our organic vegetable growers. No matter what the outcome of the approval process, we in Navdanya are committed to keep our villages and our farms GMO free. Navdanya members who have organised themselves as GMO free Jaiv Panchayats (Living Democracy) at the village level have resolved that they reject the approval of Bt. Brinjal. This is Living Democracy. This is our Bija Satyagraha to stop GM seeds. It is our Bija Swaraj to defend our food and seed sovereignty. I enclose the first set of letters from 126 Jaiv Panchayats signed by 4365 farmers. More will be forwarded to you as I receive them from our farming communities. With warm regards, Dr. Vandana Shiva Founder Director 7