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