February 8 2013

Ms Jayanti Natarajan,
Hon’ble Minister for Environment & Forests
Government of India.

Dear Madam,

Sub: TRANSGENIC CROP (FIELD TRIAL)S & FOOD SECURITY

Greetings! This is in the context of the Ministry of Agriculture responding on behalf of the Union of India to the Supreme Court Technical Expert Committee (TEC)’s first set of recommendations. Madam, you would recall that the Members and the TOR of this TEC were decided under the authority of the MoEF and submitted to the Supreme Court by your Counsel as the consensus agreement between Petitioners and your Ministry in compliance with the order of the Court in the PIL (Civil Writ Petition 260 of 2005, Aruna Rodrigues & Ors Vs. Union of India) regarding GM crops in India. In the November 9th 2012 Hearing, while we did not hear anything from the MoEF, the Ministry of Agriculture argued that transgenic technology is absolutely needed for India’s food security and what’s more, that unsafe field trials of transgenic crops were needed for India’s food security! In this letter, we intend to showcase the many serious scientific and policy fallacies in this argument of the Minstry of Agriculture.

According to the Food & Agriculture Organisation, “Food security exists when all people, at all times, have physical, social and economic access to sufficient, safe and nutritious food which meets their dietary needs and food preferences for an active and healthy life. …Essentially, food security can be described as a phenomenon relating to individuals. It is the nutritional status of the individual household member that is the ultimate focus, and the risk of that adequate status not being achieved or becoming undermined….…The declared primary objective in international development policy discourse is increasingly the reduction and elimination of poverty…”[1].

What is Genetic Engineering, on the other hand? An alteration of genetic material of an organism by modern biotechnological techniques, whereby new DNA is inserted into the host genome by first isolating and copying the genetic material of interest and then inserting this construct into the host organism. The technology of Genetic Engineering is often applied to create organisms that do not normally exist in nature (stringing together of viral, bacterial, and other genes of interest and insertion or integration into another organism does not happen in Nature, even though proponents are heard to argue that GE is similar to conventional breeding) and crossing natural reproductive barriers, cutting across even kingdom lines.

It is not clear how the Ministry of Agriculture is arguing that this controversial, nascent and unproven technology is the panacea to the problem of hunger. The first commercialized crops came into being around 16 years ago and to this day, only two commercially viable transgenic traits are present, which are cultivated mainly in 3 countries (United States of America, Brazil and Argentina which grow 77% of all GM crops). An overwhelming majority of countries worldwide do not grow GM crops. GM crops are grown on a mere 160 million hectares that comprise 3.2% of the global agriculture land[2]. Just four crops cover 99% of the area under GM crops: soybean (47%), maize (32%), cotton (15%) and canola (5%). The two traits that have been commercialized mostly are: (1) Bt (Bacillus thuringiensis) crops for insect resistance with genes from this soil bacterium inserted for a new toxin to be produced within the plant to kill insects; and (2) HT or herbicide tolerance, where the engineered plant is able to withstand herbicide sprays of particular kinds. Herbicide Tolerance is the overwhelming trait in commercially-grown GM crops today[3].

While that is the situation with GM crop cultivation, reflecting rejection from a majority of countries around the world, let us move to the issue of Hunger.

Examining the food security situation of USA or Brazil, which have adopted GM crops on a massive scale, it is evident that the situation has worsened after the introduction of GM crops. In a country like Argentina, it has remained the same. Clearly, these crops are not meant to address food security or hunger but to fill the coffers of agri-business corporations whose profits during the same period have climbed.

In the USA, in 2011 according to US Economic Research Service, 17.9 million households were food insecure (constituting 14.9% of American households that were food insecure) at some point in the year.[4] This means that an unprecedented 50.1 million people (1 in every 6 Americans) live in food insecure households in this nation that has the largest area under GM crop cultivation in the world, after having begun commercializing crops with this controversial technology way back in 1996. Food insecurity has increased to 15% of the population from where it was at 12% during 1995 and since then there has been a consistent increase.[5] Despite massive adoption of GM technology, the USA does not seem to be able to stem increasing hunger in the country. On the other hand, propping of agriculture with massive subsidies continues with 15 billion dollars given as direct agricultural subsidy in 2011.[6]

In Brazil, it is seen that improvements in food security indicators have actually decelerated in the period of expansion of GM crops, compared to the earlier years. An annexure (Appendix 1) gives a picture of food security indicators in some GM-adopting developing countries which have gone in for GM crop cultivation of some food crops along with some other countries which have not, which clearly illustrates that there is no correlation and in fact, in some countries which have opted for GM crops on a large scale, things have only degenerated on the food security front.

THE MINISTRY OF AGRICULTURE’S AFFIDAVIT

In India, the affidavit from the MoA on behalf of the Union of India is arguing that our nation’s food security will be jeopardized without GM crops. It also argues that open-air field trials of GMOs are absolutely essential for this. This note has been prepared to put things in perspective, using scientific evidence in the context of the Government of India incorrectly arguing that biotechnology is mainly or even only about transgenics; and that without transgenic technology, India’s food security would be threatened.

The affidavit on behalf of the Government stated that:

“The demand for food and processed commodities is increasing due to growing population and rising per capita income. There are projections that demand for food grains would increase from 192 million tonnes in 2000 to 345 million tonnes in 2030. Hence in the next 20 years, production of food grains needs to be increased at the rate of 5.5 million tonnes annually……(Para 22);

A real-time analysis of this scenario provides sufficient justification for strengthening, intensifying and introducing cutting edge science and technology for increasing crop productivity in India…..(Para 23);

In the Indian context, with rising population, decreasing size of agricultural holding, reduced soil fertility, resource constraints in terms of land and water coupled with uncertainties arising out of agro-climatic conditions, the blend of genetic modified technology with other conventional tool is the valid solution for ensuring food security for its increasing population….(Para 24)” etc.

Incidentally, this is the same Malthusian argument of feeding the growing millions that has been put forth by global biotechnology majors to convince nations and leaders to iron over opposition to adopt GM crops and to speed up approvals. Further, even as GM crops as a pro-poor solution has been carefully built and propagated studies show that it has “seriously distorted public debate and impeded the development of sound, evidence-based policy.”[7]

In addition to making this fallacious correlation to food security, the Ministry also has misread the SC’s Technical Expert Committee’s first report (referred to as the Interim Report in some cases), by making it look as though the TEC recommended a 10-year moratorium on field trials of all GM crops, which is not the case.

Further, the Ministry’s interpretation that the technical expert committee (TEC) has come in the way of agricultural biotechnology development is a gross misrepresentation of facts since transgenics cannot be equated to biotechnology.

LET US ASSUME A SCENARIO WHERE INCREASING CROP YIELDS IS NECESSARY:

1.    Yield increases are possible beyond breeding options too: The first question to be asked is whether yields are about increasing genetic potential through breeding alone, or genetic potential to be realized by other expertise/methods. Agro-ecological approaches like System of Rice Intensification[8], Non-Pesticidal Management of crops[9], integrated farming systems[10] etc. are documented to increase yields in sustainable ways. Many of these systems have also proved their resilience to deal with climate change.[11] It has also been established that factors like irrigation, soil productivity restoration and even remunerative markets play a role in improving production and yields.

2.    Yield as a “trait” at the molecular level: No genetically engineered crop has been created so far with intrinsic yield increase potential – yield is a complex quantitative trait, requiring several genes to be manipulated, whereas the commercialized transgenic crops deal with qualitative traits (like insect resistance, herbicide tolerance etc.). Moreover, there is also enough evidence to show that greater the number of genes that are manipulated, greater the instability that is induced putting a question mark on the ability of genetic engineering to deal with intrinsic yield potential of a crop. To talk about the need for improving productivity through transgenics is therefore incorrect.

3.    Yield increases with non-GE molecular breeding tools: There is significant evidence to show that complex traits can be successfully handled by non-GE molecular breeding tools like Marker Assisted Selection and other methods[12]. Further, the breakthroughs in conventional breeding cannot be neglected either, which in many cases is the basis for the yield of the GM crop (which is then engineered with the GM trait) – however, non-GE breeding methods (molecular non-GE or conventional) is attracting lesser investment and effort both in the private and the public sector.

Appendix 2 of this letter has a compilation of some major non-GM breeding successes in the recent past. India would do well in investing on this front.

4.    Experience with various commercially cultivated GM crops in the USA: In the USA, soybean and corn are the two major genetically modified crops (often assumed to be food crops, but actually going into non-food industrial use, livestock feed and fuelling automobiles). Herbicide-tolerant soybean (GM HT soybean) and corn have not increased yields any more than conventional methods that rely on commonly available herbicides. Further, insect-resistant Bt corn varieties have provided an average yield advantage of just 3-4% compared to typical conventional practices, including synthetic insecticide use. Per acre corn production in the US has increased 28% since the early 1990s. GE is responsible for only 14% of that increase, ie., only 4% of total US yield increase. Meanwhile, non-GE plant breeding and farming methods have increased yields of major grain crops by values ranging from 13-25%. Bt corn varieties, engineered to protect plants from either the European corn borer      or corn root worm, averaged over 13 years since 1996 when it was first commercialized, resulted in around 0.2 to 0.3% operational yield increase per year (Source: Doug Gurian Sherman (2009). Failure to Yield, Union of Concerned Scientists).

Studies by USDA scientists have shown that the yield benefits of insect resistant crops depend obviously on pest infestation in a given season[13]. On the other hand, in trials of herbicide tolerant soybean, “yield drag” effects were noticed, adversely impacting yields[14].

5.    Experience with Bt cotton in India: Bt cotton is the only GM crop approved for commercial cultivation in India. 2012 marks a decade of Bt cotton cultivation in the country. There is much controversy around whether cotton yield increases seen in the early part of the decade can be attributed to Bt technology or not.

Dr K R Kranthi, Director, Central Institute for Cotton Research says that cotton yields have shown an increase between 2002-04 due to IRM/IPM practices, new hybrids, new area under cultivation and new insecticides. No significant yield advantage has been observed between 2004-2011 when area under Bt cotton increased from 5.4% to 96%. His analysis is presented as relevant extracts as Appendix 3.

In an April 2012 discussion paper of IFPRI, Gruere and Sun conclude that Bt cotton contributed (only) 19% of total yield growth over time (with the remaining increase coming from other factors at play)[15]. Besides Bt cotton, the use of fertilizer and in the increased adoption of hybrid seeds appear to have contributed to the yield increase over time, say the authors. Incidentally, the role of increased irrigation in cotton cultivation in India and good seasons/monsoons have not been comprehensively analysed by these authors.

A special case to be looked into is the state of Gujarat in India, which contributes nearly 40% of India’s cotton production. Here, in 2010 (years after Bt cotton expansion in the state), it was reported that the average productivity of cotton lint in irrigated areas was 689 kg/hectare whereas it was a mere 247 kilos in un-irrigated areas, indicating how important irrigation was[16].

A report brought out by a coalition of groups working on GM crop issues, on the occasion of ten years of Bt cotton cultivation in India shows that yields increases in Indian cotton have actually been impressive in the years when Bt cotton expansion did not take place[17].

FOOD SECURITY IS NOT ABOUT FOOD PRODUCTION & YIELD INCREASES

We would like to reiterate that the MoA’s response on behalf of the Government of India was a fallacious techno-centric response to the issue of food security, even though the international discourse, to which India is a party to and signatory of, clearly looks at food security not as a function of food production and crop yield growth, but about poverty/development, access to food etc. In addition, the MoA completely ignores the important aspect that food safety is an integral part of food security and cannot be separated from it.

The ‘International Assessment of Agricultural Science and Technology for Development’ (IAASTD) report has clearly concluded that smallholder agriculture with access to land, markets and sufficient resources is the best way to ensure food and livelihood security. The report sees no significant role for GM crops in ensuring food or livelihood security for farmers.[18]

The United Nations’ Special Rapporteur on the Right to Food, Olivier De Schutter, in his report to the UN in March 2011 has stated that agro-ecological approaches with low external inputs, empowering farmers and building their knowledge and skills can effectively increase productivity at the field level, reduce rural poverty, improve nutrition and help adapt to climate change.[19]

Food security, as we are all aware, is a problem not only of production but of distribution and access/purchasing power. Today India’s paradox of overflowing godowns/rotting grains, with 320 million people going hungry is well-known. The world over and in India, most of the hungry people are ironically partaking in the food production process. Clearly hunger is a more multi-faceted problem than what can be fixed by using a particular seed or cocktail of chemicals. Therefore, we seek that the government address the issue of food security in a holistic manner taking into account the issue in its totality rather than look for short cuts and get distracted by red herrings like GM crops and pesticides.

WHAT IS THE CONNECTION BETWEEN GMO FIELD TRIALS & FOOD SECURITY? 

The Ministry of Agriculture, Government of India, argued in the Supreme Court against the interim report of the Technical Expert Committee. It said in its affidavit, …”the 10 year moratorium on field trials of GM crops recommended by the TEC would mean a complete stop to agri-biotech research applications…” and that it will result in indirectly benefiting MNCs, with India having to import GM technology from abroad (Para 28). The MoA argues that ‘these technologies will hugely benefit in achieving genetic potential of a crop by making cost of cultivation cheaper, which means achieving higher productivity’. This whole argument is flawed.

Firstly, the TEC is not about (all) agri-biotech research applications. The Ministry has in its narrow definition included only GM crops as agriculture biotechnology. The TEC is specific; it is about GM crops and trees and not about other agri-biotechnologies.

Secondly, the TEC has not recommended a 10-year moratorium on field trials of all GM crops. It has specified what kind of GM crops the moratorium recommendation applies to (Bt GM crops, HT GM crops and crops for which India is Centre of Origin or Diversity). Contrary to the assertions by the Ministry of Agriculture, it is in fact the Indian public sector GM crop research that will continue in a scenario where the TEC’s recommendations are accepted. Almost, all multinational GM research is centred around Bt and HT crops (Appendix 4 has a list of GM crops under research) whereas most public sector crops are non-Bt and non-HT and also in crops other than for which India is the Centre of Diversity. While this may be so, we believe that there is much wrong with the public sector GM research too, and many important issues came to the fore in the recent report of the Sopory Committee.
 

Thirdly, linking field trials of GMOs to food security is absolutely fallacious. In fact, in a situation where commercialized GMOs are yet to prove their success on yield, safety or sustainability fronts, there is no connection between field trials and food security. Therefore field trials of GM crops are an unconnected and independent issue that should be governed based on considerations of biosafety and the precautionary principle.

It is completely unscientific and unbecoming of the Ministry of Agriculture to insist on unsafe field trials.

The TEC recommendation to have a preliminary biosafety assessment before open-air field trials and after establishing the need for a transgenic option is indeed welcome. Further, the TEC is suggesting some policy directives (not for the first time in India and the Parliamentary standing committee in its report had made similar recommendations), on particular GM crops and traits to be discarded, which is also a welcome suggestion.

Madam, it is in the context of the above reality and evidence that we urge you to pro-actively come forward to adopt the sound recommendations already made by the TEC in this matter.

Sincerely,

Sd/-

1.    Padmabhushan Dr Pushpa Mittra Bhargava, Founder Director of Centre for Cellular & Molecular Biology; Anveshna, Hyderabad, Andhra Pradesh

[For the rest of the signatories and the references and appendices go to:  http://indiagminfo.org/?p=540 ]