This is a response from Kavitha Kuruganti of the Centre for Sustainable Agriculture (CSA), based in Andhra Pradesh in India, to a recent article claiming to both represent the concerns of the CSA over Bt cotton and to critique them.

The article was by C Kameswara Rao of the Bangalore-based Foundation for Biotechnology Awareness and Education (FBAE). Rao based his article on discussions he had when visiting the CSA in company with two other ardent GM supporters - Shanthu Shantharam, also of the FBAE and a former Syngenta and USDA employee; and Ronald Herring, an anthropologist at Cornell.

The FBAE is a controversial organisation. It claims to be a "non-profit", "grassroot", "movement" but in reality has since its inception been initimately tied in to the biotech industry. The President of the FBAE, for instance, is the General Manager of Nunhems Seeds India - a wholly owned subsidiary of Bayer CropScience.
http://www.gmwatch.org/profile1.asp?PrId=336

And the main spokespeople of the FBAE have a history of stunningly inaccurate claims about those with concerns about GM.
http://www.lobbywatch.org/archive2.asp?arcid=7904

Given this, it's hardly a surprise that Kavitha was less than impressed with the content of Rao's article, finding its representation of the CSA's position not only selective and biased but in part the product of the "fertile imagination of these (FBAE) guys". In short, Rao and co. are once again guilty of setting up straw men in order to show off their supposed brilliance in attacking them.

Rao's article follows with Kavitha's comments in square brackets [].

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*Foundation for Biotechnology Awareness and Education* http://www.fbae.org/index.htm

*Bt COTTON IN WARANGAL DISTRICT, ANDHRA PRADESH, INDIA: 1. THE NGO CHARGE SHEET* http://fbae.org/Channels/Views/bt_cotton_in_warangal_district1.htm

[KAVITHA: the "NGO charge sheet" has been clearly articulated by the NGO in any case, straight to the regulators and others, and does not really require any more interlocution]

C Kameswara Rao

Foundation for Biotechnology Awareness and Education, Bangalore, India This email address is being protected from spambots. You need JavaScript enabled to view it., www.fbae.org, www.fbaeblog.org

* *

Lately, the Warangal District, in the semi-arid Telengana region of the State of Andhra Pradesh (AP), India, has become the epicenter of everything going bad in the cultivation of Bt cotton. Reports of phenomenal failure of Bt cotton, farmer distress, death of sheep, death of cattle and alleged farmer suicides have show cased the Warangal District as an example of all that could go wrong with modern agriculture. Anti-tech activism has extrapolated all this to the other parts, in and out of AP, such as Vidharbha region of Maharashtra. A rational and scientific assessment does not support such an intensely negative outcome from Bt cotton cultivation. To assess the ground realities first hand, Professor Ronald Herring, Cornell University, Ithaca, Dr S Shantharam, Biologistics International, of USA, and I, have visited the Warangal District for about a week in the middle of December 2006.

Before going to Warangal, we visited the Centre for Sustainable Agriculture (CSA), Hyderabad/ Secunderabad and the Andhra Pradesh State Seed Certification Agency, Hyderabad, for a first hand assessment of opinions and reports.

*Centre for Sustainable Agriculture (CSA)*

The CSA are the main anti-Bt cotton activists in AP. The two functionaries of CSA we met raised the following issues against Bt cotton:

*a) Economical and technical features not up to the mark:* What is the mark and whose mark? There is certainly no serious deficiency in basic technical features and performance of Bt cotton. Achieving maximum economic benefits from a crop's potential depends upon several local factors, such as the soil type, irrigation facility, weather conditions in a particular season that influence pest pressure, and the awareness of the farmer in adopting appropriate cultivation practices. There has been a phenomenal increase in the acreage under Bt cotton, year after year, even in Warangal District. The Bt cotton acreage increased from 2.27 lakh in 2005 to 8.30 lakh in 2006 in the AP, from 6.23 to 18.40 in Maharashtra, and from 1.27 million to 3.8 million in the country, during the same period. The horror stories of failure of Bt cotton in AP and Maharashtra do not reconcile with statistics from diverse sources.

[KAVITHA: We said that economic and technical features related to Bt Cotton are nowhere near the promises and claims. We certainly know that a crop's performance depends on a complex web of factors and that is precisely why we think that reductionist science will not help in solving farmers’ real life problems. Despite the increases in crop acreage related to Bt Cotton, socio-political issues like "de-skilling" of farmers have been well brought out by (social) scientists like Dr Stone.]

*b) Promises on reduction of pesticide use, yield increase and higher profit not realized:* No evidence was offered other than perceptions and opinions. This is contrary to all reports, and feed back from the farmers, which indicate that Bt cotton, did substantially reduce pesticide use, increased yield by preventing loss due to bollworm, which enhanced profits, all reflected in the increase of acreage.

[KAVITHA: No evidence needs to be given to the visitors. Our data from our studies has already been published.]

*c) There was no environmental and socio-economic impact assessment:* Studies prior to commercialization in India and elsewhere for over a decade, have not indicated any adverse environmental impact. The socio-economic impact is rooted in a tension free cultivation and higher financial returns, which were realized by the farmers to a great extent, when the cultivation conditions and practices were right and the expectations were not unrealistic. If the farmers from any part of the country suffer losses, they would immediately dump any technology and this has not happened.

[KAVITHA: The adverse impacts are evident from many official reports, leave alone civil society findings. It cannot be over-emphasised that experimentation related to GM crops is happening at the expense of farmers in this country. The many serious shortcomings in the so-called risk assessment procedure adopted right now have been brought out time and again. Once again, we ask Dr Rao what studies has he reviewed related to environmental and socio-economic impact assessment, can he put out the studies with full data and what comments does he have as a scientist for each such study, if he was asked to peer-review?]

*d) Spurious seed in authentic packaging:* This is a serious problem of marketing throughout the country. Some greedy farmers and unscrupulous dealers have sustained a vast market for illegal and/or spurious Bt cotton seeds, which has affected all others. Scientists of the Agricultural Research Station (ARS), of the Acharya NG. Ranga Agricultural University (ANGRAU, Hyderabad), at Warangal, also expressed concern over this issue. The Governments in different States have taken remedial measures, but there was some laxity on account of political compulsions.

[KAVITHA: This was something that the visitors seemed to be obsessed with, in making this the crux of their defence. We did not bring this up. This small example is evidence enough of how conveniently the GM-advocates package their lies. The visitors wanted to know how we knew that in our studies, the farmers who were called as Bt Cotton farmers were indeed growing Bt Cotton. We said that we went by the purchase bills and the seed containers. They seemed agitated by this issue and are now claiming that this is something we raised!]

*e) No authentic information on cultivation practices:* This is partly true, as the seed dealers did not always provide adequate and appropriate post-sale monitoring and guidance in most places. There were mistakes in choosing the Bt varieties suitable for a particular area. A large proportion of the farmers did not plant refugia, which should have been enforced. The Officers of the ARS, ANGRAU at Warangal, also feel that the farmers need regular guidance on the choice of seed varieties and on crop cultivation methods.

[KAVITHA: On information related to cultivation practices, a shocking apathy and lack of responsibility have been exhibited both by state governments and the seed industry. This is evident from the fact that recommended seed rates have been fixed and changed arbitrarily over the years for Bt Cotton, that state governments are now saying that Bt Cotton is not recommended for unirrigated areas, even though the majority of cotton cultivation in the country is rainfed!

Planting of refuge is not something that we brought up we in fact questioned the scientificity of refuge-planting. In any case, for the partial truth that Dr Rao acknowledges with regard to 'no authentic information on cultivation practices', what does he propose to do with regard to accountability?]

*f) No studies on the efficacy of Bt technology in controlling bollworm:* This is totally baseless. Bt cotton was mainly developed to control bollworm and its efficacy has been demonstrated all over the world and so in India too.

[KAVITHA: We quoted from the CICR (CENTRAL INSTITUTE FOR COTTON RESEARCH) study in 2005. This cannot be termed as baseless.]

*g) All India coordinated field trials only on agronomical parameters:*

Not true again. The mandatory all India coordinated trials were conducted by the Indian Council of Agricultural Research. Both agronomical parameters and biosafety issues were evaluated during different field trials, which were accepted by the Review Committee for Genetic Modification (RCGM), before recommending to the Genetic Engineering Approval Committee (GEAC) for commercialization.

[KAVITHA: Well, the FBAE person seems to know something that even the GEAC (India's apex regulatory body) itself is not claiming! What biosafety issues were evaluated during the all India coordinated trials, please? Pollen flow? Soil impacts? Impacts on beneficial insects? Which? Allergies? Has this gentleman seen any results himself before claiming authoritatively that many things were evaluated? What scientific mechanisms/processes were applied for this evaluation, as per this gentleman, for him to feel so confident about ICAR, RCGM and GEAC, other than a simple unscientific bias? In fact, even official monitoring teams in AP, Chattisgarh and West Bengal have gone on record to say that even agronomic parameters could not be assessed for various reasons. Dr Rao better update himself on all these details.]

*h) Andhra Pradesh has neither State nor the District Committees mandatory under the regulatory regime of GE crops:* This is an administrative lapse, though AP is not alone in this. Cultivating any genetically engineered crop without these committees to oversee and monitor is highly irregular. Nevertheless, it is hard to form scientifically competent committees at the State and District levels.

It seems necessary to review the purpose, need and practicability of such committees.

[KAVITHA: What did the likes of FBAE do about such 'highly irregular' matters, one wonders! Probably there was no time to worry about such things, away from celebration after celebration, based on industry figures!]

*i) Death of sheep:* At the time of our discussion, death of sheep was the major issue and the number of dead sheep mentioned was 120, but not in thousands. The death of goats and cattle on account of consuming Bt cotton leaves, and farmer suicides on account of cultivating Bt cotton, was not yet made an issue. The death of cattle http://www.fbae.org/Channels/Views/why_do_cattle_die_eating_bt_cotton.htm­

in the Warangal District was discussed on this blog earlier (March 14, 2007). However, like Professor Herring, one would be amazed to note that the number of both dead cows and dead sheep became 1600, which also seems to be the number of dead cows mentioned on a poster in Delhi, in a different context.

[KAVITHA: The author better check available official records and documents too, before showing his ignorance on the subject. There is a Parliamentary query responded to in August 2006 itself and now official communication from the Animal Husbandry department to the GEAC on this subject.]

*j) The undercurrent: * The strongest undercurrent behind the tirade against Bt cotton is the anti-Monsanto campaign. The NGOs have a tongue-in-cheek admiration for the performance of Navabharath's illegal Bt cotton, which contained the stolen Monsanto's Cry 1Ac gene. Almost every other Bt cotton variety contains the same sublicensed gene. If Monsanto's Cry 1Ac dominates the Indian Bt cotton scene, the fault lies more with the public sector which has not yet released any of the promised Bt cotton varieties.

[KAVITHA: For detecting undercurrents, you have to be sensitive and empathetic, traits which seem to be alien to Dr Rao & company. What he has perceived to be the undercurrent with NGOs is the farthest thing from the truth.

We began by talking about some fundamental things like how GM crops do not fit into our vision (shaped in turn by farmers that we work with) of ecological farming which ensures viable economics, sustainable resource management, political control and socio-cultural connections that Indian farmers have had with their farming. We are opposed to any GM crops, even if they come through the public sector in India (which are in turn being pushed into GM crops in the garb of PPP, through American interests). Therefore, stolen genes and tongue-in-cheek admiration cannot be attributed to us or any conversation that these two men had in our office and can only be attributed to the fertile imagination of these guys.

This whole ordering of various points that they insisted on discussing with us when they visited CSA in itself is a selective, biased and sometimes imagined 'chargesheet' and deserved no response. However, since there are some points being attributed to us, leaving aside fundamental issues raised, we had to put out a clarification.]

There is a certain element of truth and genuineness of concern in what the NGOs say, but distortion of facts, exaggeration of problems and scaremongering ruin their case. The anti-tech activists are stretching them too far from science to pursue their political agenda of 'GM-Free India', and in the process are throwing the baby out with the bath water.

[KAVITHA: Dr Rao better watch out for distortions, exaggeration and hyping up of false promises from groups like his, lest it ruin his case! I would like to know what data did FBAE collect personally, for him to believe that what he quotes is science and that the others are "too far from science"??? Does he have anything apart from what the industry has produced in the case of Bt Cotton in India?

We have a political agenda, yes that of ensuring control over Indian farming in the hands of Indian farmers. That of them shaping their own future. It is a shame that more Indians like Kameswara Rao do not have such an agenda.]

May 21, 2007