Annexure 1: Letter submitted by a delegation to the Minister for Environment & Forests, Government of India, with a copy to Chairperson, GEAC on June 15^th, 2006

To                                                                                                        June 15, 2006

Shri A Raja
Hon’ble Minister for Environment & Forests
Government of India, Paryavaran Bhawan
CGO Complex, Lodhi Road
New Delhi 110003

Respected Sir

Sub: Bt BRINJAL – BIOSAFETY AND BEYOND

We are a group of concerned civil society organizations consisting of leading farmers’ unions, consumer organizations, organic farming groups, NGOs working on environmental and sustainable agriculture issues, women’s groups, members of the medical fraternity etc., representing in turn lakhs of Indians, approaching you to intervene into the matter of Bt Brinjal, which is on the verge of obtaining permission for large scale trials and seed production in this country.

This would be the first time that a GM food crop could be allowed to be released into the open environment for this stage of research. This is also the first time in the world that a GM vegetable crop would be grown with the Bt toxin incorporated into it and consumed with very little or even no processing or cooking. It is not out of place to remind here that it was during large scale trials that Bt Cotton’s illegal proliferation began in this country and the regulators only watched with helplessness. Things have not improved an iota since 2001 when such contamination began with Bt Cotton in this country.

There are grave concerns with regard to these various developments and since the Environment Ministy’s mandate is to protect the Indian environment and the environmental health of all Indians and since the Ministry constitutes one of the important regulators of GM in agriculture in India [by virtue of the GEAC located in the Ministry and by the presence of the Ministry’s representatives in the GEAC] we approach you to seek your urgent positive intervention in the issue.

We would like to begin by stating that while we welcome the fact that GEAC has offered, for the first time more than a decade after GM crop research began in India, to put up data related to findings from biosafety tests on Bt Brinjal, the entire process run was completely unacceptable. The data that was put up, as presentations by M/S Mahyco to the GEAC, is completely inadequate for any intelligent and scientific feedback to be provided. This also showed the world how GEAC takes its decisions. It is clear that a body that should ask basic, scientific questions related to health and environmental implications in addition to socio-economic implications for our farmers, has decided to function as a mere ‘bureaucratic approval’ body and runs its processes only on such company-produced meaningless presentations. This is a shame to this country, which is a signatory to international conventions like the Cartagena Biosafety Protocol that enshrine the concept of biosafety when it comes to GMOs. To make this farcical process worse, GEAC’s own press release put out through the PIB [Press Information Bureau] on May 25^th, 2006 says that the company’s biosafety findings would be put up under the sub-heading “GEAC Clearance Shortly” on the MoEF’s website. Does that mean that the GEAC has already decided on the clearance shortly?

We provide our feedback on Bt Brinjal hereunder. Below, we bring up biosafety issues as well as more fundamental issues beyond biosafety. Much of this feedback should also serve as a feedback on the serious shortcomings of our biosafety regime in general and why there is a need to invoke the precautionary principle on GM crops.

1.       There is no justifiable reason whatsoever for experimenting on and introducing Bt Brinjal [and GM crops in general]: The GEAC or the DBT [Department of Biotechnology] has no good reason and justification to promote a GM Brinjal in this country. Pest management on Brinjal is being successfully practiced by numerous IPM, NPM and organic farmers with non-chemical, non-GE approaches with very satisfactory results all over the country. Within the ICAR establishment, numerous research projects, including on farmers’ fields, show that there are very good, inexpensive and absolutely safe results following non-chemical IPM methods in particular and IPM methods in general. Given such vast experience, why is there no political will to put the control over the technology in farmers’ hands? We are attaching to this letter a collection of such experiences [Annexure1] which should provide a way forward for our thinking. We are once again reiterating that for the pest management paradigm to shift in this country, what is needed is political will and not GE-like solutions. We all know that pesticide use in fact has very little to do with pest/disease incidence any more and it has suited the pesticide industry and the regulators/agriculture scientists very well to encourage such a situation so far. To get out of this, we don’t need a technology-fix but an alternative paradigm of pest management which empowers the farmers to understand their farm ecology and depend on local resources and sustainable practices for pest management.

More importantly, there is no crisis with Brinjal production. In fact, due to overproduction, farmers do not get adequate market price.

2.       The science is imprecise and the technology unpredictable – Impact Assessment to be broad in scope: It is well known that GE is based on imprecise science and is an unpredictable technology as there is little control on where the new genetic construct will lodge within one or more of the target cell chromosomes. It is also well known that tests are not conducted to assess the results from the variety of genes that are inserted along with the desired gene [the markers, promoters, terminators etc. etc.]. Scientists do not understand the mechanisms of GE-induced changes in gene expression in sufficient detail. They do not know what to look for and these things are termed ‘unintended effects’. It is for this reason that on a whole range of issues, a great deal of res