NOTE: The study criticised below actually appears to claim that because the researchers found Bt cotton being cultivated more in villages with more developed services, therefore that development could be attributed to Bt cotton cultivation!! One might more reasonably conclude that it told you more about the socio-economic circumstances of farmers opting for Bt cotton.

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More baseless claims on Bt Cotton by biotech industry in the form of ASSOCHAM report

Centre for Sustainable Agriculture Reacts to the ASSOCHAM Report on Bt Cotton ["Bt Cotton farming in India ¨C 2007: Transforming Lives. Softly"]

There are many issues with the way the study has been designed, the way data has been analysed, presented and conclusions made in the Indicus study as well as the IMRB study that the ASSOCHAM publication contains.

What is important to note is the boldness with which the executive summary makes certain statements (for example, last paragraph on page 21 says "Having seen the impact of BT cultivation on the Bt predominant areas and *finding an overall development of these areas as a result of BT farming*, we investigate in detail the impacts of BT cultivation of the farmer, his household and his community" with emphasis [**] being ours) and certain fundamental flaws in the design and conclusions of the study which should have disallowed such bold conclusions.

Household level comparisons in the Indicus study do not have any baseline data incidentally nor are there any tables presented on the differences between Bt and non-Bt households in terms of their landholdings, literacy and education levels, community/caste background, dependence on farming based livelihoods exclusively or diversified base, communication media exposed to and so on [tv/radio ownership, viewership], to get a picture of the broad socio-economic profile to begin with, of each set of households.

The first question to be asked about the study is whether certain households based on their socio-economic and cultural setting would tend to pick up Bt Cotton as a technology much more than other households, for a variety of reasons. Further, would such households also have a "mindset" that is different in its trends than another group of households which exhibit a different profile along the same socio-economic and cultural parameters? If yes, how wise and acceptable is it to conclude that Bt Cotton is the cause of the behaviour, mindset, perceptions and other things studied? Shouldn't the study have accounted for the basic confounding variables rather than interpret everything happening in some households and villages in a causal fashion to Bt Cotton?

In fact, the table on "Bt Villages Better Than Non BT villages" on page 20 presents the findings and the data in an over-simplified fashion of X (for No) and ¡Ì (for Yes). Given a lack of statistical significance analysis on the data, the small differences in data between Bt Villages and Non Bt villages presented in this contrasting Yes or No fashion is highly questionable.

Similar is the table on Page 22, which tries to compare Bt Households with Non Bt households with over-simplified Yes and No symbols in a tabular form. These conclusions are questionable and misleading too.

We raise many other questions regarding the study

- How can a predominantly cotton village be compared with a non-cotton village, leave alone Bt Cotton village being compared with a non-cotton village? Commercial crops in a region would carry their own set of socio-economic dynamics as opposed to food crop cultivation or subsistence farming areas. What exactly is the difference between predominantly cotton cultivating Bt villages and the non-Bt villages in terms of cropping patterns is an important analysis to be presented upfront. Even within cotton as a crop, what is the difference in the extent of cultivation of Bt Cotton and Non-bt cotton, between study and control villages? At what point does a village become predominantly Bt Cotton, and at what point does it remain non-Bt Cotton, if both villages are cotton growing ¨C for example, will 60% of Bt Cotton in a study village and 50% in a control village make them Bt Cotton and non-Bt Cotton villages respectively for the convenience of the study? Are the interpretations along reasonable lines after such slotting? Such data is completely missing for any meaningful interpretations of the study.

- The report simply ignores all possible confounders for each of the parameters it studies. In a simplistic and reductionist fashion, it says that the beginning point for the study and control villages in 2001 was similar, with the intervening years having seen increasing Bt Cotton cultivation in the study villages and therefore, all that is good in the study villages is due to Bt Cotton!! In the control villages, as the report admits, it is not always non-Bt Cotton that is predominant but just non-cotton crops too!

- To attribute various things like perceptions on women and perceptions on gender equality improving due to cultivation of Bt Cotton is amazing!! If that were indeed so easy, why put in any other effort into rural development in this country, other than develop GM crops as a solution for all development issues!! In fact, there are many studies that show that the contrary is true ¨C that with the commercialization of farming, women's role in decision-making in farming is reduced.

- NGO activity in villages increasing is usually associated with further impoverishment ¨C what does this mean in the Bt Cotton villages, as per the researchers?

- The study seems to conclude that agri-input shops increasing in a village is a good indicator for farmers. This is clearly questionable.

- In the same table [page 49 of ASSOCHAM report], general stores, hardware stores etc. are more in non-Bt Cotton villages than Bt Cotton villages. It is amazing that any conclusions should be drawn at all on something like this, especially given that there is no comparison with baseline figures [from 2001] other than presenting existing figures from the current survey!! In the simplistic table in the executive summary, the overall conclusion is that Bt Cotton villages have more shops now and therefore, more economic activity!

- Nowhere does the survey mention how many of the "Bt Cotton villages" are closer to the town or mandal headquarters and how many of the "Non Bt Cotton villages" are, within a selected range of distance [there is only a passing mention of this on page 42, without any data on distances, paved roads, transport facilities etc.]. Similarly, there is no mention of communication tools like radio and tv which could have influenced many decisions and behaviour patterns of respondents. The study does not account for any such critical and important confounders.

- The parameters related to "Availability of facilities across village type" [bt vs. non-bt] (table 4.2 on page 47) is worth reading. In fact, while one table from 2001 census provides data in terms of mean numbers, this table provides data in the form of percentages, making comparisons difficult. The table ignores decision-making parameters adopted for setting up banks by nationalized and cooperative banks, for instance, and tries to attribute even these to Bt Cotton cultivation!

- Page 50 has a last paragraph that reads like this: "While no causal inference can be drawn as regards the differential provision of these services (like electricity, drinking water supply, street lights etc.), vis-a-vis Bt or non-Bt villages, there can be an indirect relation between the data provided by respondents and the actual state of affairs. The paradox in the situation should be read in terms of higher incomes gradually translating into a greater substitution of government facilities with private ones on the strength of higher earnings. Thus, respondents in Bt areas reported lesser dissatisfaction possibly because to an extent, the expected public solutions to these problems have been compensated for by private expenditure to improve living facilities". All this speculation by the researchers apart, we would only like to remark that this is a highly debatable state of affairs, that poor farmers in the country have to spend their private resources to substitute government facilities.

- All the issues of Pages 60-65 (women's health indicators and other women related indicators; children's issues etc.) have all been turned upside down. Various indicators of certain households like ANC visits during child birth, women requiring permission to go out etc. have been turned upside down on their heads and a causal relationship is sought to be established for better indicators to Bt Cotton cultivation. In fact, it should have been the other way round on finding out how many families which adopt a particular kind of "modern living" approach also adopt Bt Cotton or generally, practices and products that are labeled as "modern or progressive technologies" in farming.

- It is also not clear what conclusions can be drawn without doing a thorough statistical analysis on many of the figures mentioned. IN AP for instance, non-Bt Cotton households have exhibit more gross enrolment of children in 14-18 age group than Bt Cotton households. More non-Bt Cotton households and villages have attendance in private schools across age groups than Bt Cotton households and villages. "Bt New" farming households exhibit higher attendance at private schools than "Bt Old" households. What would ASSOCHAM like to conclude from that

- The design of the study assumes that by studying "Bt Old" and "Bt New" households, a kind of longitudinal assessment has been achieved. However, across different tables, there is great inconsistency between how Bt Old households and Bt New households hold perceptions and behave on various socio-economic parameters picked up. Such an assumption of longitudinal assessment is highly questionable and no conclusions can be drawn without adequate baseline data and without taking into account confounding variables that determine the "mindsets" [page 68].

Coming to the IMRB report on economic benefits from Bt Cotton cultivation [pages 86 to 98 of the ASSOCHAM report], CSA would like to draw the attention of readers to information obtained by the organization on the Bt Cotton monitoring report of Andhra Pradesh state department of agriculture for 2006-07 and the striking difference between the official findings and the IMRB's findings:

IMRB report claims that the net additional benefit to farmer from Bt Cotton cultivation is Rs. 7125/- per acre, at the national level, with additional yield for Bt Cotton farmers being put at 3.44 more quintals per acre than non-Bt Cotton growers. Te yield for Bt Cotton farmers is put at 10.33 quintals per acre and non-Bt Cotton growers at 6.89 quintals per acre at the national level while the summary on Page 92 portrays this as "50% higher average yield (quintal per acre) in Bt Cotton"! There is also no information provided on how many in the Bt Cotton growers' sample had irrigation for Bt Cotton and how many in the control sample had irrigation for their cotton crop studied.

Total expenditure on pesticides for Bt Cotton farmers is put at Rs. 1997/-, at Rs. 933/- lesser than non-Bt Cotton farmers per acre at the national level.

In Andhra Pradesh specifically, the IMRB study claims that Bt Cotton growers obtained 10.08 quintals per acre on an average and non-Bt Cotton growers ostensibly obtained 8.21 quintals per acre. The Government of AP reports that the average difference in yield per acre between Bt Cotton and non-Bt Cotton is only 75 kilos across six districts.

Expenditure on pesticides is supposed to be Rs. 2605/- per acre for Bt Cotton on an average, while it is Rs. 3723/- for non-Bt Cotton. The AP government also reports a difference of around Rs. 1040/- between Bt Cotton plant protection costs and non-Bt Cotton's.

In Andhra Pradesh, net income for Bt Cotton cultivators is supposed to be Rs. 7212/- and for non-Bt cotton cultivators Rs. 2274/-, after including the price of seeds, as per the IMRB study. Taking the earlier two points into account, the AP government's monitoring report obviously says very different things on this front.

As per the AP government's department of agriculture and its monitoring, in some districts like Khammam and Adilabad, non-Bt Cotton growers have obtained more net benefits and places like Guntur show negligible difference Bt Cotton and non-Bt Cotton [that, in a report on six districts!].

Further worth noting are the recommendations of the Acharya N G Ranga Agricultural University in Hyderabad to farmers, as part of its "Vyavasaya Panchangam" for 2007-08 in page 129:

*In extreme weather conditions like water scarce situations and with heavy rains, Bt Cotton's effect is not as expected *Bt Cotton does not have any tolerance against sucking pests; further, it has been found that incidence of sucking pests is higher on Bt Cotton as per studies *Studies are also showing that incidence of diseases is higher on Bt Cotton, compared to Non-Bt Cotton *After adverse conditions, development of tender shoots again in Bt Cotton is much lesser than on Non-Bt Cotton.

Agriculture University also points out that Bt Cotton requires more chemical fertilizer use. There is an increased dosage of chemical fertilizer as per recommendations of the university for Bt Cotton. Overall, this would mean an increased demand of chemical fertilizers to the tune of 9600 tonnes of Nitrogen, 4800 tonnes of Phosphorus and 4800 tonnes of Potash to cater to the requirements of Bt Cotton, just as 1/3rd more fertilizers on the usual dosage recommended [the University incidentally is recommending more than this for Bt Cotton]. Seed dealers, when contacted, are recommending more dosages. This would mean a minimum of 22 crores of rupees more expenditure for Bt Cotton farmers at last year's acreage. In a situation when chemical fertilizer demand against supply is resulting in farmers' agitations across the country, how does the government propose to raise the additional supply? More importantly, how are the overall energy economics of such increased use of fertilizers compatible with claims about benefits from Bt Cotton? What about the deterioration to natural resources from increased use of such inorganics?

THE ASSOCHAM REPORT GLOSSES OVER ALL THESE ISSUES in its report. It makes only questionable correlations and analysis between Bt Cotton's entry into a village and overall development. Next, we will be told that India's GDP growth rate being high in the past few years is because of Bt Cotton!

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