IMPROVING INDIA’S AG-BIOTECH POLICY

Suman Sahai

The current thrust of GM research and application in India is ad hoc and arbitrary. There does not seem to be a visible purpose behind the decisions taken other than the mere availability of this or the other variety. This availability is extremely restricted and the choice can be made only from the four crops that were bred to address the problems faced by large farmers in industrial countries and the two principal traits that are available. The crops are cotton, soybean, corn and canola and the traits are herbicide tolerance and insect resistance as in the case of Bt . The Indian research program, which is developing GM crops, is poorly focussed and driven by the genes available in the repertoire of companies like Monsanto rather than the need to solve the problems of Indian agriculture. So heavy is the dependence on proprietary genes that almost half the Indian research programs are using versions of Monsanto’s Cry1 (Cry1Ab; Cry1Ac) gene, spread over a variety of crops.

If India is to be seen as a responsible nation capable of adopting a complex technology like GM technology, the science administrators will have to demonstrate far greater competence than they are doing at present. The research agenda will have to be decided after a needs assessment exercise so that research is being done on crops and traits relevant to India. A competent system of bio safety testing must be introduced, with well-established, scientifically sensitive procedures to test for risks to the environment and human and animal health. The appalling regulatory system in place for monitoring and oversight will have to be discarded and replaced with one which is technically competent, transparent, accountable and sensitive to public concerns.

For a country of India’s size and calibre, it is insupportable that the apex regulatory body, the Genetic Engineering Approval Committee (GEAC), is headed, not by a scientist of the highest technical competence, but by whichever IAS officer happens to be posted as the additional secretary in the Ministry of Environment and Forests ! In the last few months, three bureaucrats have come and gone as chairperson. The rest of the GEAC is equally bureaucratic, consisting of official positions (joint secretary….this ministry or the other ..), rather than knowledgeable people.

Setting our agenda

There must be a consultative, participatory process involving a wide range of scientists, social scientists and competent civil society organisations to deliberate on the GM issues that face the nation and the path we should take. The adoption of agricultural biotechnology can have far reaching implications for the health and welfare of an agriculture dependent country. There are serious socio-economic concerns and concerns about the impact of agri-biotechnology on the environment and human and animal health. These complex and controversial technologies cannot continue to be administered by a handful of people lacking relevant skills and technical competence to assess biotechnology. It is a disconcerting fact that the larger academic and scientific community including the Academies of Science are not included in biotechnology policy development, which is being determined, almost exclusively by a small group of people in the Department of Biotechnology.

Priorities for the development of agricultural biotechnologies must be based on indigenous needs. Yet the Indian establishment is satisfied copying the concepts and structures of regulatory and oversight systems straight from the industrial countries, without any effort to incorporate developing country perspectives and sensitivities. The research priorities in agricultural biotechnology are based on what the industrial countries have developed, and very little has been done to evolve an indigenous set of priorities based on the needs of small farmers and local agricultural production systems. Amidst this confusion, a variety of biotechnologies and their products are being commercialised by regulatory agencies in this country.

A targeted and informed biotechnology policy may help to solve some of our agricultural problems. However, if policy is ad hoc and ill informed, as is the case now, it could end up hurting rather than helping farmers. With such a high stake in agricultural technologies and the need for agricultural development, India can ill afford to be careless or irresponsible in bringing about biotechnology intervention in agricultural development.

Ability to handle GM technology

In India, the commercial approval granted to Bt cotton, is a good example to demonstrate what can go wrong when ad hoc, ill informed decisions substitute for a sound policy framework.

India permitted commercial release of its first ever GM crop, Bt cotton, in the year 2002-2003. The Bt cotton varieties belonging to Mahyco-Monsanto are reported to have fared poorly in most of the locations where they were grown. The decision to approve these Bt cotton varieties was widely criticised at the time, by civil society groups like Gene Campaign because the varieties were known to be poor performers with respect to yield but the agencies went ahead, refusing to acknowledge the public’s concerns. When the Bt cotton harvest came in, first the government made statements that the harvest was very promising, then it admitted poor performance and has now asked for a state-wise review to assess the reasons for the poor performance.

As all this unfolded, an illegal variety of Bt cotton, Navbharat 151, which was detected over three years ago, continues to be planted season after season in several variations, making a mockery of the regulatory system’s ability to take any action. In fact, producing illegal Bt cotton varieties has turned into something of a cottage industry in Gujarat and seeds of this unauthorised variety are being sold in Punjab, Haryana, Tamil Nadu and probably elsewhere too, cocking a snook at the GEAC and making it look very inadequate indeed.

Also cause for concern is the gung ho attitude to transgenic technology on the part of science administrators, specially those in the Department of Biotechnology. The decision-makers exhibit a keen, if misplaced desire to join the ‘GM Club’ and belong to a supposedly elite community that dabbles in high-tech research. This desire to do what the developed countries are doing has led to research agendas picked from the west and introduction of crops developed for industrial agriculture. Decisions are not taken on the basis of indigenous needs but on what line of copy cat research will most quickly show some results. Tragically, funds are being diverted to these areas at the cost of research on other important branches of agriculture like classical agronomy, water management and systems based agricultural research.

The economics of Bt cotton cultivation

Field studies conducted by various agencies including Gene Campaign and the Andhra Pradesh State Agricultural department show that the economics of cultivating Bt cotton is clearly not in favour of farmers. The seed is about four times more expensive than good local hybrids. The difference in the price of seed is approximately Rs. 1200 per (450 gm) bag, which is needed to plant an acre. As against this, savings on pesticide were meagre, averaging Rs. 217 per acre because spraying had to be done to control other pests chiefly pink bollworm, which is a significant cotton pest in India. The Bt toxin does not affect pink bollworm.

As Table 1 shows, the investment per acre is much higher for Bt cotton than for non-Bt cotton varieties. The Bt cotton farmer had to invest on average, Rs. 983 more per acre than his non-Bt counterpart.

Table 1: Comparative Investment in Bt. and non-Bt. cotton in Rs./acre

Input	Non-Bt. cotton	Bt. cotton
Seed	400	1,600
Fertiliser	2,800 (1500 - 4000)	2,800 (1500 - 4000)
Pesticide	1,533 (600 - 2500)	1,316 (500 - 2200)
Total	4,733	5,716

(Gene Campaign, 2003)

Yield /acre of Bt cotton was lower than non-Bt cotton and the cotton was of poorer quality thus fetching a lower price per quintal. Added to this was the higher investment in Bt cotton fields. The net result was significantly poor results from Bt cotton which are reflected in the data on comparative incomes, in Table 2.

Table 2: Comparative income from Bt. and non-Bt. Cotton

Farm Type	Non-Bt. Cotton			Bt. Cotton
	Farmers (%)	Income/acre (Rs.)	Net Profit /acre (Rs.)	Farmers ( %)	Income (Rs.)	Net Profit/ acre (Rs.)
Low Yielding	35	7394	2661	60	5637	-79*
Medium Yielding	58	12512	7779	35	9737	4021
High Yielding	7	20475	15742	5	15375	9659

(Gene Campaign, 2003)

Net profit from Bt cotton was lower per acre compared to non-Bt cotton in all types of fields (low to high yielding). In fact, 60 % of the farmers cultivating Bt cotton were not even able to recover their investment and incurred losses averaging Rs. 79 per acre.

Regulators violate the law

One of the most shocking revelations of the field study conducted by Gene Campaign was the fact that neither State Level nor District Level Committees had been set up in areas where Bt cotton was being commercially grown. This is a breach of law and a direct violation of the prescribed rules for the manufacture, use, import, export and storage of hazardous micro-organisms and genetically engineered organisms and cells, under the Environment Protection Act, 1989. This deliberate violation of the law by the regulators themselves does not help to build confidence in their ability to administer this new technology with any degree of responsibility. It also sends the wrong signals that rules do not have to be adhered to.

Investing in GM products but not in monitoring them

Whereas agriculture research, product development and marketing receive substantial budgetary support, regulatory, monitoring and evaluation systems are not well funded. This neglect has led to weak and ineffectual regulatory systems. Given the lack of funds, research establishments in India tend to rely increasingly on the companies (whose products are to be tested) to pick up the tab for the monitoring and evaluation exercise. This introduction of the vested interest into what should be a transparent and unbiased process is decidedly undesirable and unethical and will lead to decisions in favour of the companies, not farmers.

Apart from the meagre resources for comprehensive monitoring and evaluation, India also lacks skilled manpower with experience in biosafety, risk assessment and risk management. Before such skills can be built up, the science administrators are pushing for the adoption of GM crops and food propelled by a mixture of external pressure and hasty zeal. This reckless disregard for the crisis that could emerge from a combination of resource constraints, developmental needs and the ecological vulnerability of regions, that are the centres of origin and diversity of major crop plants, is unnerving.

Protecting Centres of Origin and diversity

Centres of origin of crop plants and areas of diversity merit special attention and must be treated with extreme caution. Genetic contamination of germplasm found in centres of origin is a risk that cannot be taken since the consequences of something going wrong would be very grave indeed and the impact on global food security would be incalculable. India is a centre of origin for many crop plants , most importantly rice.

There is sufficient scientific evidence to show that gene flow among rice varieties is substantial. Wild relatives of rice cross with cultivated rice and many of these wild relatives are known weeds. It is also known that ‘intermediate’ forms between wild and cultivated rice are found in regions of high genetic diversity. Gene transfer from GM rice to wild relatives is therefore going to happen. If transgenes enhance the weediness of a weedy relative or create new weeds, the weed problem in rice cultivation would exacerbate several fold.

Until there is a reasonable amount of data about the likely environmental impact of gene transfer from GM rice, in this major centre of diversity, it would be prudent not to release transgenic rice in India. According to a World Bank briefing paper on rice, no studies have been done on gene flow and its impact on wild and cultivated rice germplasm and there is no sound empirical data to make any assessments. As a major centre of rice diversity, India must invoke the precautionary principle, in its own interest and the interest of global food security.

The caution exercised by Mexico with respect to corn, for which it is a centre of origin and diversity, is a good example for India to follow. Mexico which had placed a ban on growing transgenic corn, brought another ban which included even research on transgenic corn, when the contamination with GM corn was detected in ordinary, non-GM corn fields in 2001.

Why the herbicide tolerance trait should be banned in India

Traits that India needs for its agriculture should be understood through a needs assessment exercise but drought tolerance and increased nitrogen fixation will certainly be high on the list. Equally, some traits will be considered highly undesirable. Prominent among these is herbicide tolerance, a trait that should be banned in India. This technology based on a proprietary herbicide claims its goal is to “reduce drudgery” on the farm. This claim has little to do with rural reality in most parts of the developing world. In India weeding is an assured avenue for earning casual wages in rural areas, especially for women. Sometimes it is the only source of wages. What is harvested in the form of weeds fulfils two important nutritional roles. The plants that constitute weeds in fields are largely nutritious leafy greens, which are a valued source of nutrition in the family’s diet. What is not consumed by the family, serves as fodder for livestock that rural families maintain as additional income sources.

ADD FOTO- Any agricultural field showing natural vegetation around/ front of it, to show how closely the crop and the medicinal plants are found , to make the point that spraying herbicides may protect the crop but will destroy the vegetation.

Many of these so-called weeds are actually medicinal plants, of great value to rural and adivasi communities and their tradition of indigenous healing practices. According to the WHO, 70% of India is dependent on the indigenous systems of medicine for its health care needs. This system is dependent on the local flora in each area, which the local vaids and hakims use to make their medicines. Senior vaids and hakims who are members of the Medicinal Plant Board of India have been pleading for less destructive agricultural practices since this leads to incalculable harm to local medicinal flora. The trait herbicide tolerance delivers double profits for the company that owns the technology, first through the sale of expensive proprietary seeds and then through the exclusive use of proprietary herbicides. All it does for farm men and women in India is destroy the basis of added nutrition, affordable health care and an income source. That is why it must be banned.

Incorporating Equity in Intellectual Property Rights systems

Agriculture biotechnology is a sector where patent activity is very high. The current regimes of intellectual property rights (IPR) are a serious impediment to the transfer of technology to developing countries. Most of the basic technologies of genetic modification are patented and the larger companies own these patents. These companies are reluctant to license them to developing country organisations at an affordable cost. On their part, developing countries are at a disadvantage when negotiating license terms from patent holders, not having learnt to bargain and being vulnerable to pressures. An important aspect of India’s GM policy will have to be the incorporation of equity in IPR systems.

The claim for equity derives from the fact that when a transgenic variety is created, there are many more players involved than is acknowledged in the patent. A number of plant varieties are used in the breeding of a GM variety. These include land races, varieties bred by farmers and those bred by public research institutions. That is the reason why patents, that seek to appropriate the entire variety for contributing a minor share, are iniquitous and unjust. In the creation of a new plant variety, the first 80 to 90 steps are contributed by farming communities, the rest by scientists. Equity and justice demand that an IPR regime acknowledge Farmers Rights along with Breeders’ Rights. This is what the Indian law on plant variety protection, the Plant Variety Protection and Farmers Rights Act, 2001, attempts to do. The law acknowledges that farmers are also breeders. It has provisions that if farmer varieties are used in the breeding of other varieties, a certain amount of money will have to be paid for the use of these varieties, into a National Gene Fund, which will be used by farmers. The Indian law has also banned the use of the GURT (Terminator) technologies because this would totally negate the rights of farmers by denying them access to seeds in the creation of which they have played a significant role.