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

Environmental Risk Assessment 41districts were due to pink bollworm resistance. The substantive basis for Monsanto’s determination has not been released to thepublic, so it is not possible to verify independently this conclusion.Monsanto’s conclusion has been vociferously criticised by Dr. Kranthi (Director Central Institue of Cotton Research (CICR),Nagpur) who stated that the methodology followed by Monsanto was unscientific and therefore unacceptable on the followinggrounds:1. The unusual survival of the pink bollworm in Saurashtra region of Gujarat was due to weather conditions that favouredthe pest survival and not because of resistance as stated by Monsanto.2. There were unusually high numbers of pink bollworm males during 2009 in Saurashtra. CICR data 3, All IndiaCoordinated Cotton Improvement Project (AICCIP) reports (2009-10) demonstrate that during 2009, there wereunusually high catches of pink bollworm moth in the pheromone traps installed in Junagarh at an average of about 700moths per week all through mid-November until the end of January. This occurred only in Saurashtra, only in 2009. Atthe other 12 centres where monitoring was carried out, trap catches were less than 100 moths per trap per week.3. India is the only country in the world that cultivates hybrids and also that the bolls on F1 hybrid plants possess 25%non-Bt seeds. This enables high survival of pink bollworm larvae that can feed on the developing non-Bt seed.4. The Monsanto bioassay data were derived from 33 pink bollworm larval population samples collected from Bt cottonfields in all the four districts of Saurashtra, instead of collecting on conventional cotton as per the standard methodology.Therefore, their inferences on resistance were not correct.5. Further, thus far there has been no scientific evidence anywhere in the world including India to indicate that the pinkbollworms had developed resistance to Cry1Ac under field conditions.Although none of the points raised by Dr. Kranthi either singly or together refute Monsanto’s conclusion, some of thepoints raise sufficient doubt in the conclusion. Kranthi’s point 5, whether true or not, is irrelevant to India. Just becauseresistance failures have not occurred elsewhere, does not mean that India cannot be the first place they occur. Point 4 doesnot throw the Monsanto conclusion into question. It simply means that they have discovered resistance associated with Btcotton. Kranthi’s point would indicate that resistance may have not yet spread to all fields in the districts, but his point does notdeny that resistance occurred. Kranthi’s point 3 probably undercuts his argument more than it supports it. While the non-Bt seed may contribute to a higher pink bollworm population, it is also likely that it led to faster resistance evolution becauseRS heterozygous larvae probably had a higher than normal survival rate. Points 1 and 2 also do not disprove Monsanto’sconclusion, but they do raise alternative possibilities that together lead to doubt about the validity of the conclusion. Kranthi’spoints 1 and 2 essentially say that the environmental conditions in the Saurashtra region were substantially different fromnormal. If these unusual environmental conditions also reduced expression of Cry1Ac toxin in the Bt cotton varieties, thenresistance failures may not have occurred. Instead, the alternative explanation is that environmental conditions caused failureof the Bt cotton product to perform as expected. Thus, Monsanto’s conclusion cannot be accepted as fact. If the details of theMonsanto studies were released, then it would be possible to determine if Monsanto’s conclusion is sound.Finding 19. The aspects of the IRM plan for EE-1 Bt brinjal that could delay resistance evolution are all purelyvoluntary and contain no incentives for farmers. Only the non-Bt refuge is likely to delay resistance evolution, butcompliance to the refuge strategy is likely to be low. The education program is aimed both to ensure sales of Bt brinjalseed and affect the risk of resistance.Of the seven elements of the Bt brinjal IRM plan, A, B, C, and G are compulsory, and Mahyco has the responsibility tocarry them out. However, A, B, and C will not affect the rate of resistance evolution, and the only compulsory aspect about Gis that educational programs will be conducted for farmers. The remaining elements of the IRM plan are voluntary. The use ofnon-Bt refuges will delay resistance; however, their use is voluntary. If Bt brinjal is effective at controlling BFSB on actual farmsand the losses to BFSB are severe, then there will be incentives for farmers to plant most of their brinjal as Bt brinjal. Thereare no incentives to plant non-Bt brinjal, and no disincentives to planting too much Bt brinjal. Thus compliance to the refugestrategy is likely to be low (however, see discussion below). If Bt brinjal is not that effective at controlling BFSB or losses from3(www.cicr.org.in)