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

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4 Bt Brinjal: The GEAC environmental risk assessmentConclusion 6. Most of the main kinds of possible adverse effects of Bt brinjal on biological species diversityand ecosystems have not been evaluated sufficiently. The scientific evidence does not support the EC-II conclusion (page 42), Bt brinjal event EE-1 “has no adverse impact on non-target organisms includingbeneficial organisms and soil microflora.”There are six kinds of potential adverse environmental effects that Bt brinjal could have on biological diversity. These are:increased secondary pests, either through direct enhancement or indirectly through the reduction of natural enemy controls orother means; reduction in soil quality or health, adversely affecting crop production in either the short or long term; reducedvalue of non-crop economic activities (such as honey production or wild food harvesting); reduced cultural value by affecting acultural icon or a species of cultural significance (e.g., Monarch butterfly in the United States); increased conservation concern,such as an adverse effect on an endangered species; and reduced environmental quality through an effect on an ecosystem servicesuch as pollination.EC-II argues that most species are not at risk from Bt brinjal because the Ccry1A protein has a narrow toxicity spectrum. Bydoing so, EC-II ignores the considerable scientific uncertainty about the toxicity spectrum of Ccry1A, and the over-reliance onthis assumption (EC-II, page 37) is not scientifically justified. In addition, Bt brinjal can have effects not directly related totoxicity, and these potential indirect environmental effects may be more significant.EC-II also draws conclusions about the absence of environmental risk in the absence of supporting data. For example, EC-II(page 41) concludes “there is no accumulation of the [Bt] protein in the soil associated with production of Bt brinjal,” but this isnot supported by any scientific data.Many of the experiments submitted by Mahyco in the Dossier do not address real concerns for India. Only 1 of the 7 speciestested in laboratory bioassays to assess environmental risk even occur in brinjal fields in India. These laboratory tests providelittle relevant information about the potential impact of Bt brinjal on species in India, and therefore do not assess any realconcern in India. The soil studies were not designed to evaluating effects on soil health, brinjal productivity, or the productivityof other crops grown by brinjal farmers, which are the real concerns for Indian farmers. Instead, they measure microbialpopulations, which have little relevance for assessing these real concerns.EC-II does examine, in part, one of the six potential adverse effects of Bt brinjal on biological diversity. The multi-site field trials(MST) report data on the risk of potential non target pests. EC-II, however, overstates conclusions based on the limited andhighly variable data. The MST data suggest that phytophagous mites will not become secondary pests of Bt brinjal, but the dataare insufficient to draw conclusions about whether the other important non-target pests will or will not become secondary pests.The EC-II assessment of effects on species of conservation concern, species of cultural concern, other economically significantspecies (such as silkworm), and other ecosystem services is incomplete or insufficient.Conclusion 7. The evolution of resistance in BFSB to overcome Bt brinjal is a real risk that must be managed.EC-II does not acknowledge this risk, and the Dossier does not propose effective means to manage it.Any major pest control practice will select for resistant individuals in the target pest population. If enough individuals becomeresistant, the control fails, the pest becomes abundant and crop yields decline. The evolution of resistance to Bt crops is a realrisk and is treated as such throughout the world.
Summary and Conclusion 5Event EE-1 Bt brinjal poses several unique challenges because the likelihood of resistance evolving quickly is high. Without anymanagement of resistance evolution, Bt brinjal is projected to fail in 4-12 years. Effective use of 20% non-Bt refuges can extendthis time by 25% or more. The reason for this high risk is that EE-1 is a “low dose” event, by virtue of the relatively low controlefficacy already mentioned under conclusion 2. It will require extra effort to delay resistance substantially. Resistance risk wouldbe substantially reduced if EE-1 BT brinjal were never released commercially and India were to wait for a “high-dose” Bt brinjal.Resistance to EE-1 would be a stepping stone for more rapid resistance in any subsequent, improved event.The Dossier presents a plan to delay resistance in BFSB. EC-II makes no reference to this plan. The plan in the Dossier ispurely voluntary and contains no incentives for farmers to comply voluntarily. In the plan, only a voluntary non-Bt refuge islikely to delay resistance evolution, but farmers are unlikely to comply. The planned education program to encourage adoptionof non-Bt refuges is aimed both to ensure sales of Bt brinjal seed and affect the risk of resistance. Farmers will likely hearthis mixed message and cooperate in undermining the voluntary plan. New approaches for resistance management must bedeveloped, and some strategies are suggested.Resistance monitoring in BFSB should begin as soon as possible, initiated first in the large-scale commercial production regionswhere hybrid Bt brinjal may first be adopted, and then expand to include rural areas at risk.Socioeconomic AnalysisConclusion 8. Hybrid Bt brinjal may increase profitability for large-scale, commercial brinjal producers by atmost Rs.23,439/ha. For these producers, a reduction of 6.5 insecticide applications may also occur, but thispotential benefit may be unrealised if secondary pests arise. Small-scale resource-poor farmers may improveprofit by only Rs.3,250/ha, and many may see no benefit from hybrid Bt brinjal. In contrast, adoption of brinjalIPM will almost certainly increase profitability, perhaps by Rs.66,794/ha for small-scale resource-poor farmers.Farmers are expected to retain only 10% of the increase in profitability from Bt brinjal, but are expected toretain 63% of the increase from brinjal IPM.Bt brinjal has been suggested to improve brinjal profitability in India through increased marketable yield and reduced insecticideapplications. A narrow utilitarian analysis can be used to evaluate effects on profitability using data on yield and insecticide usein field production systems. The multi-site field trials (MST) and large-scale field trials (LST) were conducted under controlledconditions on experimental plots. They were designed to estimate yield and insecticide use in hybrid Bt brinjal compared togenetically similar non-Bt hybrids under conditions appropriate for large-scale commercial brinjal production. The data arenot representative of the production systems used by small-scale resource-poor farmers. Consequently, the data are probablyappropriate for only about 4% of the brinjal producers in India. The estimated yields probably greatly overestimate the yieldsthat will be obtained on farm. Yield gaps are prevalent and large between experimentally estimated yield and average farmer yieldfor any agricultural technology. To take the yield gap into account, yields of Bt and non-Bt brinjal reported in the MST and LSTexperiments should be multiplied by 0.54 to estimate the yield benefit for the average large-scale commercial farmer. Taking intoaccount the differences between production systems of large-scale commercial farmers and small-scale resource-poor farmers, theexpected maximum potential yield benefit from Bt brinjal is probably ≤43.7 q/ha for large-scale commercial farmers and ≤7.2 q/ha for small-scale resource-poor farmers; about 16 % of the time Bt brinjal is not expected to out-yield non-Bt brinjal.Insecticide use might decline in large-scale commercial Bt brinjal production systems by an average of 6.5 applications.However, other factors may modulate this substantially, and new secondary pests would result in more insecticide use. Becausethis risk is not adequately evaluated, it is not possible to develop an unbiased estimate of insecticide use for Bt brinjal. It is not
Page 1 and 2: Table of Contents 1Bt Brinjal Event
Page 3 and 4: Table of Contents iBt Brinjal:The s
Page 5 and 6: Summary and Conclusion 1Summary an
Page 7: Summary and Conclusion 3The EE-1 t
Page 11 and 12: Summary and Conclusion 7Conclusion
Page 13 and 14: Context and Need 9standards for ER
Page 15 and 16: Context and Need 11and seek to incr
Page 17 and 18: Context and Need 13the reported yie
Page 19 and 20: Characterisation of Transgene 15Cha
Page 21 and 22: Characterisation of Transgene 17wor
Page 23 and 24: Characterisation of Transgene 19In
Page 25 and 26: Characterisation of Transgene 21Sci
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