Indian Coordination Committee of Farmers MovementsRoad No. 2, A 33, Mahipalpur Extension, New Delhi 110 037, India

Tel: 011 - 26783000, 26784000; Fax: 011-26785001; Email: yudhvir55@yahoo.com

FARMERS POSITION ON GENETICALLY MODIFIED CROPS

Sub: Transgenic Crops and Foods in IndiaThis is to draw your kind attention to various matters of deep concern in relation to the controversial transgenic technology in our food and farming systems in India as you know, there are contradictory facts and views, including in the scientific domain, about this technology and independent analyses show that this technology is unsafe for our health and environment. There is a dire need for any country like India where millions are depending on agriculture for their livelihoods, to proceed very cautiously before deploying this technology. There are fundamental questions to be answered by any government satisfactorily before allowing deliberate environmental releases of novel organisms in our food and farming systems and any undemocratic decision-making around this would only result in great resistance from the grassroots. Here, in this brief note, we would like to draw your attention to the following issues:

1. GM in our food & farming systems why is there a need for greater concern from policy-makers?

Genetic Engineering is often equated by its proponents with conventional breeding and is also touted as precision-breeding. As per numerous experts that this is simply not true Nature does not have gene constructs of viral and bacterial genes inserted into other alien organisms and there is much scientific evidence on the genetic instability caused by the process of Genetic Engineering. Genetic Engineering, which allows for transfer of alien genes from one organism to another, for random insertion into the host organisms DNA, is a novel technology which is unnatural and breaks the barriers that exist in nature in unpredictable and irreversible ways. We would like to strongly argue a case for great precaution before such technologies are deployed in our farming and food systems all agricultural technologies would have a large and lasting impact for the simple reasons that (a) all of us consume food that comes out of farming, (b) that a majority of land on this planet is under farming and (c) that a vast majority of Indians are directly connected to farming for their livelihoods. Therefore, any technology that will have impacts on health and environment that too on a large scale, has to be deployed after a careful analysis of all possible impacts. Further, a precautionary approach should be the central guiding principle around decision-making. Unlike the technologies that we have deployed in the past, which are showing up various negative impacts now whether it is the case of chemical fertilizers or chemical pesticides, this time around with GM seeds, we are talking about a living technology which also implies that it is irreversible once released into the environment. An analysis of the technologies that get deployed shows that fair apportionment of resources does not happen both at the research level and at the extension level to sustainable and unsustainable technologies. Unsustainable technologies, which usually also mean more markets for some agency or the other, coupled with marketing strategies and financial power, usually edge out the other technologies, especially safer, more affordable and sustainable ones, which are not pushed by anyone for the simple reason that there are no markets involved! There is an urgent need to re-assess all technological options in front of us in a

1

fair and scientific fashion before deploying hazardous and unsustainable technologies; there is need for a policy directive that unsustainable technologies will not be promoted and encouraged.

2. GM crops & food security claims how true are they? The biggest reason why GM crops are being given a great consideration by our policy makers is the fear generated by Malthusian arguments that our food supplies will be outstripped by population growth. However, as argued by many experts time and again including by eminent economists like Prof Amartya Sen, food security is not an issue of food supply alone but is related more to access and distribution issues. Further, there are many ways by which food production and productivity can be improved, including by ensuring that land meant for food production is not diverted to other purposes, that agro-ecological methods like System of Rice Intensification which conserve resources even as they increase productivity should be encouraged on a large scale, that output incentives provided to farmers are bound to increase food productivity and so on. Time and again, many agencies including the Planning Commission have been referring to existing technology gap between know-how and do-how to be bridged. Further, it has been aptly stated in the Kisan Policy that agriculture is not about production and productivity alone there is a multi-functionality to Indian agriculture (agriculture as a way of life) that is often ignored by Malthusian arguments. There are also emerging schools of thinking which question the very notion of yield as defined by narrow parameters right now, to the exclusion of many other concerns that should govern the measurement of yields.

More important and pertinent to the current discussion is the fact that GM technology is not meant to improve productivity technically, it cannot, since yields are a multi-genic trait and no GM product has been put into the market anywhere in the world that can increase yields, despite years of disproportionately high levels of investment on the technology. Worse, the largest cultivated GM crop in the world, GM (Roundup Ready) soybean, is shown to have actually decreased yields in countries like the USA. An attached report called Failure to Yield, gives more information on how GM seeds are only a red herring when it comes to issues of food security.

There have been multiple instances in the past when senior policy-makers in the country have pointed out that with the existing technologies, both within the NARS and with thousands of innovative farmers across the country, yields can indeed be increased at the macro-level, by bridging the technology gap. This requires institutional interventions more than anything else. There are hundreds of highly successful farmers, from whom learning can be facilitated to other farmers, provided there is a willingness to evolve intensive farmer-to-farmer extension models. Some such models do exist in the country which include the CMSA (Community Managed Sustainable Agriculture) programme implemented by the Andhra Pradesh government and programmes around promotion of System of Rice Intensification in states like Tripura. Therefore, there is an urgent need to pursue real, lasting solutions for improving farmers livelihoods while increasing productivity as some successful examples have already demonstrated.

3. Are there no alternatives? Given that the S&T behind Genetic Engineering is controversial, even amongst scientists who have specialized in the fields of molecular biology, biochemistry etc., and given that a majority of countries around the world have taken a cautious stand, including based on available scientific rationale, it would only appear prudent that India also take a similar stand. However, there are no policy frameworks that guide

2

the R & D work, if at all, on transgenics. The Supreme Court observer in the GEAC, Dr Pushpa Bhargava had laid down the contours of an ideal regulatory regime and said that for every GM application that is received on the food/farming front, a question that the regulators should immediately ask is whether there are no alternatives to a given problem that this GM product professes to address and proceed only after a thorough need assessment.

Similarly, there are no policy level guidelines that guide R & D on crops for which we are the Centre of Origin and Diversity. Brinjal was such a case and crops like rice, pigeonpea etc., which are in the pipeline also pose a big question on the future of biodiversity in these crops with their GM versions.

Today, any person or agency can walk up to the regulators in India for a permission to tinker with any plant through r-DNA technology, for any novel trait with any set of genes and move almost inexorably forward towards our plates. This is obviously unacceptable. There is an immediate need to assess all the products in the pipeline and stall/stop/reject a whole set of applications on the simple grounds that there are other alternatives or that we are the Centre of Diversity for a particular crop. Otherwise, this would only constitute a diversion of precious resources from much-needed research on other aspects.

4. The current reality of GM crops is this what we need?Despite all the hype around GM crops as being the only solution for a majority of problems in modern day agriculture, the reality is that there are only two traits that form the basis of GM crops and their commercial cultivation around the world today insect resistant Bt crops and herbicide tolerant crops (that too mostly tolerant to Monsantos brand of herbicide called Roundup).

Pest management in fact is quite possible without the use of either GM seeds or synthetic pesticides as large scale experiences around India and elsewhere show. In fact, Insect Resistant Bt crops have an intrinsic shortcoming if a population of insects is sought to be killed by technologies like synthetic pesticides or Bt crops, it is only natural that the pests will select for resistance!

When it comes to Herbicide Tolerant crops, which seems to be the trait that crops have been engineered for in nearly 77% of GM crop cultivation around the world today, it is quite apparent that this is a technology which is meant for labourless farming. It increases chemical usage in farming and has actually resulted in more chemicals being applied in American farming in the past 13 years, after the advent of GM crops, rather than reduce chemicals! Further, resistant weeds are posing a major challenge in several parts of America, as several reports indicate.

A majority of GM crop cultivation to this day is with just one country - the USA. The desperation of this one country to find markets for its produce and for its agri-business corporations (for their seeds and proprietary technologies) is quite apparent, in a world which is increasingly having more and more areas actually reject GMOs and declare themselves GM-Free. Most GM product goes into animal feed, biofuels or cotton products as shoppers avoid eating GM foods in most countries around the world. In 2008 12.2 million hectares of GM crops in the US were used for biofuels (19.5% of total US GM area and 10% of the global GM area).

This situation has to be kept in mind by policy-makers in India when they advocate GM crops as a solution that the technology has been applied to mainly two applications both of which are unneeded in our context and that the

3

American need to find more acceptance in countries like ours is commerce-driven. When the world is so divided on the issue and when the scientists of the world are also so divided on the matter, on what basis is India ready to trust the data and defence proffered by crop developers and move ahead on GMOs? If there are any lessons that have been learnt from the Green Revolution, they should teach us not to sacrifice medium and long term sustainability at the altar of short term gains especially when sustainable solutions do exist.

5. The socio-economic aspects is this technology suitable for India?

A majority of GM crops grown around the world are Herbicide Tolerant (HT) GM crops. In countries like the USA where less than 2% of the population lives off farming, it is understandable that the agriculture research system there comes up with technologies like HT GM seeds, even though that would not necessarily make the technology safe or desirable. A 2002 USDA study which sought to look at GM crop adoption by American farmers raises a pertinent question to itself perhaps the biggest issue raised by these results is how to explain the rapid adoption of GE crops when financial impacts appear to be mixed or even negative, it says suggesting that other considerations may be motivating farmers [what is now called the convenience effect]1.

However, in a country like India, the very concept of introducing GM crops poses a big question on the socio-economic implications for the poorest rural families in the country who earn a substantial part of their livelihood through de-weeding activity which this technology seeks to replace. The poorest rural women in India obtain employment through this activity which HT GM crops will surely decimate, in addition to leaving toxic impacts behind through the increased use of agri-chemicals.

It seems incomprehensible that the government first seeks to destroy existing employment potential in Indian farming and on the other hand, seeks to prop up rural employment by pumping in crores of rupees of taxpayers funds in the form of NREGS and such other programmes. This is simply not sustainable and we need a vision for farming in India that creates a win-win situation for agricultural workers and bigger farmers, even as proper social security measures are put in place for the workers.

6. Farmers rights and researchers rights will they be protected in the face of big corporations like Monsanto and its IPRs?

GE technology goes hand in hand with rigid IPRs in fact, it is often seen that even without the IPRs being enforced legally, an unstated business etiquette around such IPRs secured by big MNCs allows for more and more exclusive and monopolistic use of this technology.

There are at least two unrecorded instances in India where companies like Monsanto used their IPRs to prevent public sector researchers in their breeding programmes and release of varieties to farmers : one is the initial Bt Cotton development effort by Central Institute of Cotton Research (CICR) in the late 1990s; another is the effort by UAS-Dharwad to come up with its own Bt Cotton varieties around 2003. While these

1 Fernandez-Cornejo, Jorge and McBride, William D., Adoption of Bio-engineered crops, Agricultural Economic Report No. 810, Economic Research Service, USDA, May 2002

4

instances remain anecdotal, the government might want to look into this and draw out lessons.

It is also well-documented by now that Monsanto does not hesitate to sue and jail farmers in the name of patent infringement, in order to secure its own markets and profits. Attached is a report from Centre for Food Safety in the USA on this anti-farmer attitude and behaviour of Monsanto. Right now, there are several anti-trust investigations underway in the USA, undertaken by the Department of Justice, about its anti-competitive behaviour. A French documentary on Monsanto and its misdeeds is available in the public domain (http://www.youtube.com/watch?v=hErvV5YEHkE), which captures the various ways in which this corporation just chased profits irrespective of anything else. It is shocking that India, on the other hand, officially provides several platforms to this profit-hungry corporation to direct the policies and regulatory frameworks related to agriculture and to constantly expand its monopolistic exclusive markets at the expense of poor, hapless farmers. We urge you to urgently look at ways by which Seed Sovereignty of this country and thereby, food sovereignty, needs to be protected from corporations like Monsanto.

7. Choices for farmers and consumers will they have any left?

It has to be remembered that the choices for farmers get limited not just through IPR regimes but through market maneuvers of corporations. In the case of cotton in India today, there are no choices left for farmers since non-Bt Cotton seed is not available in the markets. No seed company or public sector corporation is investing in producing non-GM cotton seed. Nearly 80-85% of the seed in the market is controlled indirectly by just one corporation Monsanto through its proprietary technology being sub-licensed to Indian companies. If it took only eight years for nearly all non-GM seed varieties to disappear from the market, after the advent of Bt Cotton, one can imagine what lies in store for the farmers in other crops. It has been documented that seed prices are being raised exponentially after the advent of the GM versions in the market and attached is a report on the same from the USA. This does not augur well for the crisis-ridden Indian farmer. A Fact Finding report of the Planning Commission to Vidarbha found that the rural distress in the region was exacerbated by exorbitantly priced seed and once farmers lose their physical stocks of seed, they would be perpetually dependent on corporations like Monsanto and its sub-licensees for supplying seeds at the prices that they choose. It took a large battle from Andhra Pradesh government to bring down the prices of Bt Cotton seed in the country through challenging the royalty charges on the technology. However, in this battle, it became clear that the governments have no legal power or means to control seed pricing. Special ordinances and state level legislations had to be passed by states like Andhra Pradesh and Gujarat to control Bt Cotton seed price. The Minister for Agriculture in your government is meanwhile refusing to include seed price control into regulation in the proposed Seeds Bill.

Farmers choices will also be curbed due to the very nature of this technology to contaminate neighboring crops. Those who wish to remain non-GM or even organic will have their crops jeopardized due to the new threat of contamination from others planting GM seeds.

As far as consumers are concerned, their right to safe food and their right to food of their choice will be jeopardized/violated with the entry of GM foods. In a country where the vast majority of food is consumed in open conditions (not packed or

5

packaged), labeling cannot be a real solution for upholding consumers right to informed choices.

8. American interference in India will the USA allow a similar interference by India?

It is very clearly apparent, on records, that the USA which has a huge vested interest in trying to push GMOs into other countries (with India being the most prominent of these battlegrounds) is being allowed to tweak the regulatory systems in India in favor of the industry, in the name of harmonization of guidelines, laws etc. Analysts are pointing out that the Indo-US Knowledge Initiative on Agriculture (KIA) is more about such regulatory interference than bringing about a second green revolution in India. An initiative of this sort should have been debated in the Parliament, given that it has implications for millions of farmers and given that not enough critical investigation has happened into the lessons we should learn from the first Green Revolution. In the case of Bt Brinjal too, regulatory committees are being tilted by pro-GM people who are part of various USAID-supported projects which leaves very little scope for independent assessments.

9. The regulatory regime: should any more approvals come out of this?

The current regulatory regime in India is ridden with various problems. It is shocking that with the existing shortcomings which clearly demonstrate that scientific, pro-people, democratic, transparent and independent decision-making is next to impossible given the current regulatory regime, that India is still continuing to give approvals for open air trials and for various applicants to move from stage to stage with their R&D efforts. Much has been already written and said about the woeful inadequacies of the regulatory regime in India and why all approvals of GMOs in should be stopped immediately.

10. Now, the Biotechnology Regulatory Authority of India (BRAI) draft Bill

While much has been said and articulated about the problems with the current regulatory regime, the proposals to replace it with a Biotechnology Regulatory Authority of India are worse. A version of the draft Bill which has apparently been sent to the Cabinet before being tabled in the Parliament is now available in the public domain and the objectionable and unacceptable shape and components being given to the BRAI has evoked much sharp reactions all around. An attachment here talks about what the ideal regulartory regime should be like, in the form of a National Biosafety Protection statute, and the objections around the BRAI proposals.

11. The health and environmental implications of GM foods:

It has to be remembered that very few studies on chronic impacts of GM foods actually exist and this was a big shortcoming in the case of safety assessment of chemical pesticides too today, many thousands around the world are paying a heavy price for this lack of assessment of chronic adverse effects of such toxins in our environment and food. The same mistake is being committed, knowingly, in the case of GM foods unfortunately.

6

While the technical implications of this imprecise and random insertion of alien genes creating changes and instability in the host genome which then manifest themselves as health and environmental implications at the organism and eco-system level are documented through various studies, a point that is worth noting is that not enough resources are allotted for generating more scientific findings on such impacts. Much of the research that is taken up on GMOs is taken up by crop developers and in fact, it has come to light recently that research of an independent nature is actively discouraged by placing curbs on access to seed materials. A Nature Biotechnology (October 2009) article says that it is no secret that the seed industry has the power to shape the information available on biotech cropscommercial entities and their ownership of the proprietary technology allows them to decide who studies the crop and how.

There are several instances where independent scientists research funding was cut off or where they even lost their jobs soon after they publicized their findings which showed adverse impacts from GMOs. With very little resources flowing into such independent research and where researchers who are reporting adverse findings are intimidated by critics and face repeated and orchestrated attacks (GM crops: Battlefield, Nature, September 2009), it is obvious that generation of more findings of an independent and rigorous nature in itself is a task before proceeding further on this controversial technology. In fact, given the existing evidence, a precautionary principle-based approach is the only way forward.

It should also be remembered that the situation with GM crops is such that apart from the biosafety concerns flowing from the S&T of genetic engineering, issues around trade security, socio-economic implications and farmers rights etc., should also form an integral part of impact assessment of the technology.

12. No liability regime right nowIndia does not have a liability regime right now to make the crop developer liable for any damage including contamination of non-GM crops. Without such a liability regime being in place, no further approvals should be provided on any product to move forward in the pipeline, especially related to deliberate environmental release of GMOs.

13. Lessons from Bt Cotton in IndiaThe Bt Cotton cultivation experience in India over the past eight years has many valuable lessons to teach policy makers, regulators, farmers and consumers of the country, if we choose to pick them up in pursuit of sustainable development objectives. (a) It has been shown time and again that the Bt technology is unpredictable and the very mixed results over years, locations and hybrids are there for everyone to see. In those places where results have been good, deeper analysis points to good seed source (germplasm into which the Bt gene has been backcrossed), good monsoon years, higher inputs in the form of water and nutrients etc. The technology has failed in many areas which are resource-poor in terms of soils, irrigation as well as farmers ability to provide inputs. (b) Pest and disease ecology has changed in cotton in unpredictable ways. Secondary pests are emerging into major pests in several places. (c) Impacts on soil are being observed and reported by farmers and there is increased use of chemical fertilizers; a senior agriculture scientist of India had predicted that with even a 6% expansion of GM crop land in the country, there would be a doubling of chemical fertilizer demand and this brings its own problems including that of public financing of an unsustainable input. (d) Stress intolerance is found to be higher on Bt Cotton than on other non-GM

7

cultivars. This has implications for risks and vulnerabilities of our resource-poor farmers. (e) Bt Cotton has left its impacts on animals which have grazed on the crop residues in different parts of the country including from consumption of Bt Cotton seed cake etc. Animals have either died or fallen sick after consuming Bt Cotton and this phenomenon though acknowledged by some officials, has not been investigated scientifically and systematically by concerned agencies to this day (f) Agricultural workers have also reported allergies after working in Bt Cotton fields and media and NGO reports exist from different states about this phenomenon which is also uninvestigated to this day. (g) On the regulatory front, Bt Cotton has repeatedly showcased the regulatory incapabilities of India, right from the time that illegal proliferation of unapproved Bt Cotton was first noticed in 2001. Regulatory failures were not just on the biosafety front but in terms of monitoring, reviewing, transparent and scientific decision making and so on. (h) State governments also found out through the tough way that there are no legal mechanisms available to them to regulate seed marketing, seed advertising, seed pricing and for liability and redressal for failures.

Bt Cotton has often been cited as the reason for the impressive yield increases in Indian cotton over the past few years. However a careful analysis of various factors, mostly culled out from official records of state governments, shows that other reasons would have contributed to the success of Cotton and without really factoring them in, GM proponents are hyping up the success of Bt Cotton. Attached is a paper published in Economic & Political Weekly on the myth around Bt Cotton and yields of Cotton in India. It is surprising that no one has boldly asked as yet why such dramatic results have not come out of other countries (including the USA, which continues to heavily subsidise its farming) that have adopted GM crops if what is being touted about Bt Cotton in India is indeed true!

Finally, the recent admission by Monsanto about pink bollworm developing resistance to its first-generation Bt Cotton and urging farmers to adopt Bollgard II which gives it a possibility of raking in more money and the counter statement provided by a public sector body like Central Institute of Cotton Research (CICR) questioning the findings even as it is struggling to find markets for its own single-gene Bt Cotton need to be investigated systematically before moving further. A Dharwad agriculture university study also shows that bollworms are able to survive, mate and proliferate on Bt cotton.

14. Real, lasting solutions lie elsewhere why are we not investing on them and why are we ignoring them?

There is a growing realization worldover, as the debate about the future course of agricultural research and extension as well as the future course of farming itself on this planet has unfolded on several platforms, that GM crops are not the solution for many of the current problems related to food and farming and certainly not for the real problems of the small and marginal holders of developing countries.

An international scientific research process along the lines of the IPCC for Climate Change was initiated in 2003, supported by the World Bank and the UN and came up with its report in 2009. The IAASTD the International Assessment of Agricultural Knowledge, Science and Technology for Development which ran between 2003 and 2008, involving over 400 scientists worldwide, was an ambitious attempt to encourage local and global debate on the future of agricultural science and technology. This global team of 400 experts from different fields, including social scientists, went on to challenge the conventional gatekeepers of agricultural

8

knowledge. The process of IAASTD was initiated to assess agricultural knowledge, science and technology in order to use it more effectively to reduce hunger and poverty, improve rural livelihoods, and facilitate equitable, environmentally, socially and economically sustainable development. The IAASTD report was endorsed by 58 governments including India. This report represents the work of the largest research effort to date on the history and future of modern agriculture. IAASTD endorsed a renewed emphasis on technologies that have proven track records for improving yield, reducing external inputs into agro-ecosystems, preventing the conversion of more land for agriculture and helping agriculture to improve the lives of poor and subsistence farmers.

The final report of the IAASTD concluded that the business-as-usual model of prevailing industrial agriculture cannot meet the food needs of the 9 billion who are expected to inhabit Planet Earth within a few decades. In particular the IAASTD report emphasised that food security requires a multi-functional approach to agriculture and ownership structures -- particularly protecting local knowledge systems that have been passed on from one generation to the other over millennia.

The main messages of IAASTD include: alternative production systems, notably those based on agro-ecological

methods, can be competitive with or superior to conventional and genetic-engineering-based methods of productivity;

these alternative methods, moreover, not only lower the environmental impacts of agriculture, they may reverse past damage;

an emphasis on farmer-initiated and conducted innovation, research and manipulation of biotechnologies is a proven method for achieving higher levels of food security and has collateral benefits of building social capacity, community independence and ongoing local research and knowledge sharing;

to capture the benefits of alternative production systems, the world must readdress the imbalance in funding between genetic engineering and agro-ecological research, must establish workable policies for farmer participation and agree to eliminate developed country subsidies for agriculture intended for export.

These approaches are also ones which will contribute to mitigation as well as adaptation in the era of climate change, as opposed to intensive agriculture models.

It is time that India, which has more stake in conserving and improving its agriculture than most other countries given the rich heritage of farming in this country and given that millions of lives are directly dependent on agriculture, re-looked at its misplaced emphasis on transgenics and promoted farmer-centric agro-ecological models of farming.

We urge you, in the light of all the above arguments which clearly point out the many adverse implications of transgenics and question the very need for this technology in our farming, to put a complete stop on all open air, deliberate releases of GMOs in our food and farming, a ban on import of any GM foods into the country and a complete re-hauling of our vision for Indian farming in the pursuit of sustainable development for all Indians. Thank you.

9