Bt Brinjal The scope and adequacy of the GEAC environmental risk assessment

36 Bt Brinjal: The GEAC environmental risk assessmentthat are considered are likely to have different degradation rates, and studies directly on Bt brinjal should be conducted. Thesestudies should mimic normal brinjal residue management practices by brinjal farmers rather than rely on artificial experimentalmethods.The Supplemental Materials have two reports on soil biology. As just noted, both of these studies were unreplicated andthe quantitative values of the results are not reported. Thus, the data provided in EC-II, the Dossier, and the SupplementalMaterials are insufficient to conclude anything about degradation or accumulation of Ccry1A in the soil.Finding 18. The assessment of effects on species of conservation concern, species of cultural concern, othereconomically significant species (such as silkworm), and other ecosystem services is incomplete or insufficient.Relatively little care was given to evaluating potential adverse effect (C): reduced value of non-crop economic activities (suchas sericulture. honey production, or wild food harvesting). Only European honey bee was considered in a pair of toxicity trialsusing native Cry1Ac toxin. Other species of concern include Asian honey bee (Apis cerana), and silkworm (Bombyx mori) whichis grown by many brinjal producers. Indeed, in many places, mulberry, the food of silkworm, and brinjal are grown side-by-side.In addition, some consideration should be given to potential impacts on other economic activities that occur near brinjal fields,including effects on fish (singara), water chestnut, hilsa (Bengal salmon), and surrounding crops (climbing French bean, otherclimbing varieties of beans, and leafy greens, such as amaranth and spinach).There is little consideration given to potential adverse effect (D): reduced cultural value by affecting a cultural icon or aspecies of cultural significance (e.g., Monarch butterfly in the United States). Some obvious cultural icons in India are cows(Bos taurus) and bhodi tree (Ficus religiosa), but additional consideration should be given to identifying species that are culturallysignificant to the many ethnic and religious groups in India. Some assessment of effects of Bt brinjal on cows is given underthe human and animal health assessment section. Indeed, in some cases, brinjal itself is a cultural icon, important in weddings,religious ceremonies, and culturally significant foods. Threats to cultural identity are of considerable significance to mostpeoples, and this issue should not be dismissed or glossed over.Potential adverse effect (E): increased conservation concern, such as an adverse effect on an endangered species, is addressedin one paragraph in the Dossier (volume 1), which states, “There are no listed endangered species of Lepidoptera in India thatwill be exposed to the Cry1Ac protein produced in Bt brinjal. The Cry1Ac protein is contained within the tissues of the Btbrinjal plant; therefore only insects that feed on brinjal will be exposed to the Cry1Ac protein.” It would be more useful and asubstantially better environmental risk assessment to list all known endangered species that live near brinjal fields (or the onesclosest to brinjal) and then provide reasons for why each may not be at risk. Endangered species may be affected indirectly byother affected species, in addition to the direct effects from consuming Bt brinjal as referenced by the Dossier.Finally more consideration should be given to considering effects on ecosystem functions and services. Although pollinationis considered in EC-II, effects on Asian species of bumblebees need to be evaluated. In addition, effects on soil nutrients andmicronutrients, soil organic matter, and possibly other functions and services should be considered.Needed Experiments and ObservationsAlthough this aspect of the environmental risk assessment may fulfil the requirements of the GEAC, in actual fact, theGEAC has never made clear what concrete environmental values are at stake. One of the main goals of risk assessment is toidentify specific potential adverse effects and estimate the probability that a specific adverse effect of a given size would occur viasome feasible and concrete pathway. When judged against this standard, EC-II is substantially inadequate, either because therisk assessment model that was used is inadequate or because the EC-II did not apply the risk assessment model properly. Itseems quite possible that risk assessment model is inadequate, and to the end of providing an adequate model, many of thefollowing are needed.1) Kinds of risks to biological diversity. Determine the kinds of risks to biological diversity that are important for India inthe use of Bt brinjal. The kinds of possible risks associated with a Bt crop are:• Increased secondary pests, either through direct enhancement or through the reduction of natural enemy controls. EC-IIexamined this cursorily, but given the common occurrence of secondary pests on Bt crops around the world (e.g., Greene