PRESS · Web viewAGRICULTURE SCIENTISTS AND RELATED ACADEMICIANS 20 Dr Abhay Shendye...

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To May 10, 2005 Mr Kapil Sibal Minister for Science & Technology Government of India, New Delhi. Dear Sir, Sub: Response to National Biotechnology Strategy Development Paper We are a group of concerned individuals (who are potential and unwilling consumers of GE foods if the DBT has its way), farmers’ organisations, agricultural scientists, lawyers, social/political and development activists, including women’s activists and sustainable agriculture groups working with farmers. We have been working on issues related to natural resource management and specifically sustainable agriculture issues with a collective experience of decades of work amongst us at the ground level with tens of thousands of farmers and agricultural workers in this country. We have gone through and discussed the draft National Biotechnology Strategy Development paper put up by the Department of Biotechnology, Ministry of Science & Technology (MST) on its website. Earlier to this, we have also followed with great concern the recommendations put out by the M S Swaminathan-headed Task Force on Biotechnology in Agriculture. The following is a set of overarching concerns and comments we would like to communicate to the Ministry. Further and more detailed feedback would be sent to the Ministry as the proposed policy and its implications are debated along with the communities that we all work with. This response is also being endorsed by scores of more individuals and groups and these endorsements would be sent to you as and when they are received. 1. Our Objection to the Policy Formulation Process: First and foremost, as citizens of a democratic society, we fundamentally object to the non-participatory and exclusionary manner that the Ministry has adopted for the policy formulation Civil Society Response to the National Biotechnology Development Strategy of Government of India 1

Transcript of PRESS · Web viewAGRICULTURE SCIENTISTS AND RELATED ACADEMICIANS 20 Dr Abhay Shendye...

To May 10, 2005

Mr Kapil SibalMinister for Science & TechnologyGovernment of India, New Delhi.

Dear Sir,

Sub: Response to National Biotechnology Strategy Development Paper

We are a group of concerned individuals (who are potential and unwilling consumers of GE foods if the DBT has its way), farmers’ organisations, agricultural scientists, lawyers, social/political and development activists, including women’s activists and sustainable agriculture groups working with farmers. We have been working on issues related to natural resource management and specifically sustainable agriculture issues with a collective experience of decades of work amongst us at the ground level with tens of thousands of farmers and agricultural workers in this country.

We have gone through and discussed the draft National Biotechnology Strategy Development paper put up by the Department of Biotechnology, Ministry of Science & Technology (MST) on its website. Earlier to this, we have also followed with great concern the recommendations put out by the M S Swaminathan-headed Task Force on Biotechnology in Agriculture.

The following is a set of overarching concerns and comments we would like to communicate to the Ministry. Further and more detailed feedback would be sent to the Ministry as the proposed policy and its implications are debated along with the communities that we all work with. This response is also being endorsed by scores of more individuals and groups and these endorsements would be sent to you as and when they are received.

1. Our Objection to the Policy Formulation Process:

First and foremost, as citizens of a democratic society, we fundamentally object to the non-participatory and exclusionary manner that the Ministry has adopted for the policy formulation process and demand an inclusive, participatory and consultative process in which especially those who will bear the impacts of these policies will have the right to examine the policy and present their views. Given the manner in which the policy is sought to be adopted, we are not surprised at the content and have serious objections to the draft policy which we set forth in this document.

The paper has substantial implications for the lives of agriculturists in this country and we object to the fact that they, or the agencies that work along with them, were not in the picture when the paper was drawn up. A couple of Delhi-based and Delhi-centric consultations cannot take care of the need to extensively consult with people who will be affected by the policy and of the

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need to genuinely take their views on board. The short time of a month or so for feedback – upto May 15, 2005 – is woefully inadequate.

It is also wrong to state that the policy framework is the result of wide consultation with stakeholders and reflects their consensus, since prominent people who took part in the consultations are vouching for the fact that their comments and views have not been taken on board!

We therefore demand an assurance from the Ministry -

that the policy would not be finalised without giving ample time for detailed consultations at various levels, across the country, with all the stakeholders including farmers;

that responses from different quarters of the country will be taken on board and to this end, it should put up the responses also on the Ministry’s website as soon as such feedback is received, including this response.

The Ministry should learn to run participatory policy formulation processes from elsewhere in the world and from civil society processes. Incidentally, two farmers’ juries held with small and marginal farmers in Karnataka and Andhra Pradesh have categorically rejected GE in agriculture as no solution. Consultations that are broad-based, adequately drawn out, decentralised and participatory are needed to resolve issues around biotechnology in agriculture. The question to be debated is whether Biotechnology is indeed needed in Indian Agriculture, and whether to draw up a policy at all, other than to say NO.

2. Lessons to be learnt from the Bt Cotton fiasco:

The fiasco of Bt Cotton, the first GE crop commercially allowed and grown in India has many valuable lessons for all of us in this context. The fact that Bt Cotton performed extremely unevenly across varieties, years and locations should show that the very science behind GE crops is imprecise and unpredictable.

It is apparent that genetic composition changes with changes in varieties and there is enough evidence that GE technology is greatly dependent on both the internal environment and external environment of the plant, both of which are not in the control of GE scientists or the GE industry. Without understanding the faulty science behind GE, it cannot be glorified as the solution to humankind’s hunger problems or farmers’ livelihood issues.

Further, all the failures that one has witnessed in the regulation of Bt Crop, right from the time Monsanto imported its gene into India in 1995 inform us about the disaster that GE would mean for our environment and for the livelihoods of our farmers. There have been legal violations and regulatory failures again and again in this case. Not only have decisions been based on unscientific evidence and data, but also falsified data.

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There has in fact not been adequate scientific monitoring of the crop during its commercial cultivation and many problems that should have been assessed during the field trials stage are emerging more and more. Effects on human health as well as on soil ecology, as an example, are apparent from various reports.

In this whole episode, accountability mechanisms were not put into place and therefore, to this day, no agency or organisation has been made answerable for the proliferation of unapproved GE varieties or for the losses that Bt Cotton growers have incurred.

Any strategy development, without taking these lessons on board, would be meaningless. If such a failure of regulation can happen in a set up which (on paper) has multi-tiered processes and institutions, it would be a disaster to further simplify the institutional mechanisms and approaches in order to benefit the industry and to blindly promote biotechnology in agriculture.

3. (Lack of) Legitimacy of this Policy Formulation:

This policy clearly is not in consonance with existing policies, legislations and approaches with regard to biodiversity, environment conservation, farmers’ rights etc., including the Cartagena Biosafety Protocol (which enshrines the Precautionary Principle on such technologies), Biological Diversity Act (which seeks to ensure biodiversity conservation and regeneration and sovereign rights over the same), Environment Protection Act (which through its 1989 Rules had laid down the institutions and procedures that govern hazardous micro-organisms in this country). This would only mean much work at cross-purposes between ministries and departments.

Some of the institutional issues are also sub judice with at least two Supreme Court cases pending on the issue to this day. How can a policy be formulated and institutions formed without these cases being resolved?

This policy is being formulated with complete disregard to various unresolved issues and counter-arguments with regard to the science, need and requirement, processes for assessing such needs, suitability, safety and sustainability, political economy and social implications of biotechnology in agriculture, and takes biotechnology as a given, positive thing that is a Must. This approach is highly questionable.

This characteristic haste by this Ministry in promoting the technology is in stark contrast to the Ministry of Environment and Forests performance so far on the GE front (though there have been approvals of Bt Cotton of many varieties, there have also been rejections) and the Ministry of Health’s (ICMR in particular) pronouncements of caution with regard to GMOs.

The expressed imperative to have a long term policy on agricultural biotechnology in itself is suspect and questionable since the government has never expressed a similar need for having a long term policy on ecological agricultural options, before exploring biotechnology.

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4. Glorification of Biotechnology in Agriculture – Where is the evidence of such a glory?

Biotechnology is picturised in glorified terms in the paper, especially in the Introduction section, by a variety of expressions - “rapidly emerging”, “far-reaching”, “technology of hope”, “powerful, enabling technology”, “a number of agri-biotech products that have enormously helped manking”, “can revolutionise agriculture and environmental sustainability”, “frontier technology” and so on.

The paper accepts unquestioningly that biotechnology HAS to be applied in the field of agriculture, as if there are no other alternatives. Even if this is a blind and child-like faith in “science”, such fascination towards a ‘rapidly emerging’ area of science shorn of its other realities is unacceptable.

Genetically Modified Organisms used in agriculture are living beings that grow and reproduce. They cannot be contained. Once released, they cannot be recalled. There are numerous examples to show that GM crops are unpredictable and can have potentially dangerous effects on the environment and to animal and human health. Why is there no mention of such aspects to the technology in the Introduction? Why is then Biotechnology in Agriculture, in all its forms, a given, to be glorified by this Paper?

Further, there is no evidence whatsoever that biotechnology can indeed revolutionise agriculture or is even “rapidly emerging”. It is definitely not an enabling technology, especially for the many small and marginal farmers of the country.

There is no reference at all to the global GE scenario where debates are still going on in a large part of the developed world. This policy however takes GE as a given.

Talking about Agri-biotechnology in the context of Nutrition and Diet is also a fragmented approach to the problem, shorn of an understanding of a socio-political context in which nutrition and diet problems occur.

A quick look at the scene of genetically engineered crops in the world today gives us the true picture. 71% of GE seeds planted worldwide in 2002 were designed to be herbicide resistant. In 2001, 91% of the GE hectares worldwide were planted with the seeds of just one multinational company. As is known, the company’s strategy includes selling GE seeds intended to be used with its herbicide. Given this situation, it is absurd to believe that investments into biotechnology in India will move into other directions in the future.

To believe that at least the public sector will take up more altruistic themes in their research and promotion of GE crops is also ungrounded in reality since all of biotechnology is also involved in a quagmire related to IPRs.

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There is also no evidence from the GE traits’ experimentation and crops in the pipeline for approval in India that even the public sector knows why it is prioritising certain traits, based on what? For instance, there are some public sector bodies in this country that are experimenting on herbicide tolerant rice and herbicide tolerant mustard. Why?

In addition, the overall research outlays for public sector are shrinking while private sector investments are growing rapidly. This means a constant competition between known technologies and “rapidly emerging” technologies and it is not clear how investments can be apportioned between these, on what basis. Realising this, the policy paper in question comes up with disastrous recommendations in the form of “enabling work conditions for scientists to take up industry-oriented research” and so on, which are discussed in greater detail later.

5. Where is the beginning point – Farmers or Industry?

Biodiversity conservation, ecological agriculture, women in agriculture, farmer-centrism and well-being of farming families are all accorded only tokenism in the Paper.

The recommendations ignore that a large chunk of farmers in this country have already expressed their dissent to genetic engineering in agriculture (including Bharat Krishak Samaj, the farmers’ union of the party in power) or are ignorant about genetic engineering and its implications.

The paper unabashedly talks about “Industry Oriented Research” at great length. For instance, “lateral mobility of scientific personnel into industries for commercialisation of their research efforts”, “dual and adjunct faculty positions” which will allow university researchers to hold positions in the industry, “joint salary support” where salary for faculty in academic institutions is contributed both by the industry and the institution, “rapid travel grants”, “institute innovation grants” for developing patentable technologies etc.

Such arrangements would end up in skewed investments in agricultural research, obviously in favour of the industry with its patented technologies, in exclusion of farmers, their needs and their rights.

Further, if any of the researchers were to end up as decision-makers, there would be a serious conflict of interest. There have also been past instances of materials being moved from one institute to the industry including germ plasm transfer in such arrangements. Issues related to IPRs would be unclear in such a case. Further, it is not clear who the scientists and researchers are supposed to be accountable to – their institution, and therefore, the public or the industry?

6. All existing guidelines to be consistent with Swaminathan Task Force recommendations…?

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The Paper says that all existing guidelines would be updated and made consistent with the recommendations of the Swaminathan and Mashelkar committees. The Swaminathan Committee, as several critiques have pointed out earlier, put out a bundle of contradictions as its recommendations.

The Swaminathan Task Force report refers to various issues like biosafety, GMO insurance, Agro-biodiversity Sanctuaries, Organic Farming Zones, risks associated with GMOs, bio-disasters etc., which are all tacit as well as express observations about the uncertainty and hazards associated with the technology. The report therefore realises that disaster potential of the technology is quite high, whether it is through contamination and threat to biodiversity or through failure of crops or health disasters and so on. However, it also talks about promotion of biotechnology in agriculture. How can such excessive caution and hasty promotion go hand in hand?

The Swaminathan Task Force report has also been criticized for its advocacy of double standards for Indian markets and export markets which could be GE-free.

The Task Force had also proposed a single window clearance system which further weakens an already unaccountable regulatory system in the country. It also made unscientific recommendations of approving an “event” and not a variety when it comes to GE.

Even though the contradictions and dangerous recommendations were pointed out for what they were by civil society agencies, the current Paper of DBT obviously chose to ignore such feedback.

7. Institutions and Accountability:

The Paper proposes an independent National Biotechnology Regulatory Authority as the single window clearance body. Further, the Department of Biotechnology will be a single window clearance mechanism for establishing Biotechnology plants. These are both expedient mechanisms to appease the industry and its operations rather than mechanisms which will actually regulate the technology keeping in mind the interests of farmers and the general public or will ensure accountability. This proposal seems to ignore the lessons from the Bt Cotton fiasco in India, which despite a multi-tiered system of regulation, resulted in lack of regulation as well as lack of accountability. GE Mustard in the country, if there were no multiple window clearance systems, would have been approved by now, despite its many shortcomings, if this proposal were to be taken up. There is a need for such technologies to be vetted by different agencies from different perspectives (environment, health, science & technology, trade & commerce, agriculture etc.) and a hasty single window clearance cannot address these various concerns.

This is indeed a unique proposal since such an arrangement does not exist anywhere else, not even the US (which has a 3-tier process). Further, given that the current legislation that governs GE in this country (1989 Rules of Environment Protection Act 1986) has clearly laid down institutional

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mechanisms (which has of course seen its own share of violations), the rationale behind doing away with these is not clear or explained in the Paper. There is no doubt that the current mechanisms have to be improved vastly but the solution proposed will only make things worse. Is removal of delays in the form of hasty approvals more important than other legitimate concerns related to biosafety, trade and commerce etc.?

Though the Paper makes a mention of scientific, rigorous, transparent regulatory mechanisms, it is not at all clear how these are proposed or ensured. Right now, the regulatory mechanisms in India are notoriously opaque, secretive and arbitrary.

8. Public Communication and Participation

While there is recognition of widespread discontent and skepticism with regard to GM technology, the policy proposes to iron out these questions by repackaging and disseminating the untested benefits of the technology in beneficial, propaganda terms. The Paper does not make any mention of broad based systems of participation in decision-making and monitoring. This particular section only talks about reducing resistance and increasing public awareness – a PR exercise is proposed for this.

There is an urgent need for the concerned government bodies to engage with the ongoing public debate. One of the first steps in this direction is to make public all data on GMO research and field trials with regard to the trait, the genes involved, the institution involved, updated status of the research, biosafety assessment reports, locations of the field trials, data generated so far etc. All this information needs to be updated regularly on the government website. The next step would be transparency and participation with regard to decision-making, which would involve not just stakeholder consultation but participation in decision-making. This should also involve accountability to civil society, as per the Cartagena Protocol.

This section (2.6) also mentions that well respected appellate and judicial system for redressal of grievances exists at present, in addition to a sound biosafety regulatory system. If that is the case, why are decisions being taken while matters are sub-judice in several instances? Further, if sound systems exist, why are new systems and institutions being proposed?

9. Regulatory Mechanisms (2.5) and Short-circuiting of Biosafety Issues:

An extremely dangerous and non-scientific approach is proposed under this section: “It is recommended that an event that has already undergone extensive biosafety tests should not be treated as a new event if it is in a changed background containing the tested and biosafety evaluated “event””.

This Paper should realise that genes never act in isolation. Their effect is determined (in part) by the genetic background and the environment. Genes function differently in different species and environments and therefore, their

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impacts may vary drastically. There are complex interactions that happen here which humankind has not understood yet and has no control over. The impacts might be related to biosafety issues, toxicity, allergenicity etc. Regulation that goes case-by-case, therefore, is indeed scientific and needed.

In India, in the case of Bt Cotton, the released transgenic event itself has been assessed very narrowly in the first instance. Compounding the problem by saying that biosafety tests will be done away in the case of released transgenic events will only make things worse.

It is also not clear whether the policy has assessed accountability issues on this matter – for instance, there are outbreaks of skin allergies when Bt Cotton is stored at home and is handled manually; there are also instances of failure of a subsequent crop after Bt Cotton is harvested due to deterioration in the soil quality – who is accountable for the lapses so far? What additional mechanisms are being proposed for the future, even as fast-track approvals are being recommended?

India also happens to be the centre of origin and centre of diversity for many important crops. Genetic contamination through GE crops could be a real disaster in this situation. How can the livelihoods and lives of millions of Indians be put in real danger in the haste to promote biotechnology?

10. On Proposed Biotechnology Applications for Livestock Development:

The draft policy says: “Priority target traits in livestock would be enhanced fertility and reproductive performance, improved quality, resistance to diseases for reduced drug use, production of therapeutically useful products and quality feed. Livestock of priority would be buffalo, cattle, sheep and goat. Emphasis would be given to animal healthcare, nutrition, development of transgenics and genomics. It is proposed to set up an autonomous institution for animal biotechnology". It is a well-known fact that the phenotype or expression of a gene depends not only on the genotype but also vitally on the environment within which that genotype exists. Today the single most important constraint to the reproductive performance of breeds is not their genetic make up, but the severe constraint/shortage of feed. Thus using biotechnology to enhance the fertility and reproductive performance of the animal – which will largely depend upon genetic manipulation such as cloning and embryo transfer - is fundamentally flawed science, where it is assumed that an individual is determined entirely by its genetic makeup. This does not address the primary underlying problem which has absolutely nothing to do with genes. The Policy then talks about engineering domestic livestock such as sheep, goat, cattle and buffalo to secrete useful drugs, ""therapeutically useful products" and "feeds". We protest this "pharming" of animals on the following grounds:

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i) It is completely unethical from the animal welfare view point for an animal to be under permanent metabolic stress when it has to continuously produce foreign proteins in addition to all the normal proteins in its milk. The suffering of the animal is completely unjustifiable in relation to a purported "good". ii) Second is the question of safety. None of these proteins thus far produced have been approved for clinical trials - and their safety is a major area of concern. The hazards involved far outweigh any potential benefits. There is a strong recognized possibility that animal viruses for instance can cross into human beings. The act of transferring genes between unrelated species with chimaeric vectors is sufficient to facilitate the generation of new pathogenic viruses by recombination.

While the real feed problem is seasonal shortage of biomass, the policy talks about using biotechnology to engineer "nutrition"- which translates to hormone therapy (like Bovine Somatotrophin Hormone for enhance growth), pro-biotics, and feed additives- all of which are a far cry from the issue of basic biomass. The deleterious effects of Bovine Somatotropin hormone [otherwise known as Bovine Growth Hormone] used in cattle to enhance milk production, has been well studied in Europe and USA. As early as 1999 the Scientific Committee of European Union on Veterinary Measures relating to Public Health after closely studying the use of Bovine Growth Hormone, warned of Human Health and Cancer Hazards (specifically breast and prostate cancer) of Monsanto's recombinant Bovine Growth Hormone (rBGH)1. The European Union has maintained its moratorium on the use of rBGH and milk products from BST-treated cows are not sold in countries within the Union. Canada has also so far resisted pressure from the United States and the biotechnology lobby to approve the use of rBGH commercially. In USA it has been reported extensively that as a result of the use of genetically engineered Bovine Growth Hormone (rBGH) in dairy cows, there has been a rise in udder infections, reproductive disorders, birth defects and other problems.

In short, the cloning and pharming of livestock and the creation of transgenic animals are all seriously flawed scientifically and morally unjustified. They also carry inherent hazards in facilitating cross-species exchange and recombination of viral pathogens. Therefore, it is time that the government learns from past experiences of other countries and does not blindly follow the same disastrous path. There is a need for a complete halt on such dangerous research.

11. Response to other Specific Recommendations related to Agri-biotechnology

“Precautionary, yet promotional approach should be adopted in employing transgenic R&D activities based on technological feasibility, socio-economic considerations and promotion of trade” :

1 ref: europa.eu.int/comm/dg24/health/sc/scv/out19_en.html

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If the precautionary principle were to be applied, as it indeed should be, promotion of such technologies cannot co-exist. There is enough evidence of the damage that the technology could cause that the precautionary principle should be invoked immediately.

“Transgenic plants should not be commercialized in crops/commodities where our international trade may be affected”:

Farmers who depend on domestic markets are being discriminated here. There is also an implicit agreement that rejection elsewhere is valid and should be upheld.

The proposition to protect export commodities such as basmati rice from genetic engineering on one hand while encouraging the genetic engineering of other varieties for domestic consumption is a display of blatant double standards. There is also a much-disproved assumption here that co-existence is possible between GM and non-GM varieties.

The illegal proliferation of Bt Cotton in India and the complete incapability of the government to stop it or do anything against it is an example closest home. Experiences from the rest of the world clearly show that co-existence is impossible. Organic rapeseed growers in Western Canada have sued Monsanto because they can no longer produce an organic crop, due to constant threat of contamination. Traditional varieties of maize in isolated mountain valleys in Mexico have become contaminated with US GMO maize. By pretending it is possible, the policy threatens sectors of great importance to India – its basmati rice exports and its organic agricultural sector, in addition to subjecting farmers of GE crops and consumers of GE crops to blatant double standards.

“Regulatory requirement in compliance with Cartagena Protocol”:

Cartagena Protocol requires greater attention to biosafety issues, greater civil society participation and the application of the Precautionary Principle when it comes to GMOs. However, this paper, even as it talks about compliance, is promoting contradictory elements, approaches and systems.

There is also a conflict between the Cartagena Protocol principles and the principles of WTO which now embodies Codex guidelines. How is this to be resolved?

“Public funding should be avoided to research areas of low priority or those that could reduce employment and impinge the livelihood of rural families”:

All GM technologies that one sees today have been evolved in the developed world, for conditions that might be suitable for large landholdings and industrialized agriculture. All IPRs in relation to GM crops is in the hands of large multi-national companies and they would obviously like to get

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maximum commercial gains from a given set of research investments. They are obviously going to bring in research in ‘areas of low priority’.

Therefore, why just public funding and why not private funding also? As the picture from across the world shows, much private research goes into herbicide tolerant crops which certainly reduce employment and impinge on rural livelihoods. Who is to put a curb on this, and how? All clearances for R & D should have this as a priority.

“Priority target traits in crop plants would be yield increase, pest and disease resistance, abiotic stress tolerance, enhanced quality and shelf life, engineering male sterility and development of apomixes”

For many of these traits, there are successful, sound and safe solutions in sustainable agriculture practices. Why should agri-biotechnology form the answer to these traits, in such a case? Many of these should also be viewed not as “misplaced” solutions that emerge from a gene, but should be viewed as management issues at the farmer level – yield management, pest management, disease management etc. There is ample, successful experience on such an approach with the civil society and the government should learn from such experience and from farmers.

“Crops of priority should be rice, wheat, maize, sorghum, pigeon pea, chickpea, moong bean, groundnut, mustard, soybean, cotton, sugarcane, potato, tomato, cole crops, banana, papayas and citrus”

All the major staple crops of the people of our country are being prioritized here. While there has been inadequate participation of farmers in the decision-making related to the first (non-food) GE crop in the country (Bt Cotton), this cannot be repeated in the case of consumers of the country. Where have they been consulted, and where have their views been heard before such prioritization took place?

“…Obtaining environmental and pollution control approvals would be simplified and streamlined within shorter time frame (page 14)”:

What does simplification of environmental and pollution control clearances mean? Is it possible to simplify these, other than to mean that these will be bypassed?

“Human Resource Development: Academic and Industry Needs”

This section of the policy deals with embedding biotechnology and the guiding principles deeper into the curriculum. This must be viewed with caution as present day science has moved far ahead of certain primitive principles that Genetic Engineering bases itself on.

“Priorities for crops and traits should be set after conducting a need assessment exercise in various farming zones”

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Even as need based assessment is mentioned, the indicative list given by Swaminathan is also included. Such a list can be misconstrued and misinterpreted as a given priority by industry as well as decision-makers for expedient reasons.

“Conversion of our biological resources into economic wealth and employment opportunities (page 4)”:

It is this kind of a view that comes up with extremely exploitative interpretations to our biological resources rather than look at these resources as survival means of communities. Given this approach, it is not surprising that the policy proposes Gene Banks which can be accessed by paying User Charges. This will only restrict access to farmers. However, in-situ conservation of biological resources, which can be done only in a non-GE environment, is the only way that rightful community rights can be protected over such resources.

“Biotechnology is needed as a solution (to decreasing productivity) due to decrease in per capita arable land”

It is known and established that decreasing per capita arable land is not a problem since productivity is actually higher in small holdings. Therefore, wrong diagnosis of a problem cannot be the reason why biotechnology can be justified.

“The challenge now is to join the Global Biotechnology League”:

Indeed not. The challenge is to join the Global Organic League or Global non-GE League since the Global Biotechnology League will only take away opportunities available to farmers right now.

““Public good” and “for profit” research should become mutually reinforcing”

How is such mutual reinforcement possible given the current IPRs regimes, and that biotech is usually a proprietary technology? Page 22 clearly articulates this dilemma though gives a wrong answer.

“The advancement of biotech as a successful industry confronts many challenges”

It is interesting to note that bio-safety is not mentioned anywhere here. Has not the Bt Cotton experience taught the government any lessons about this?

The whole faulty approach of environmental conservation as restoring the environment by using biotechnological processes after having contaminated and spoilt it in the first instance (reflected in other parts of the paper) is apparent through out the policy.

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Given all these major objections that we have to the policy draft and given the current global reality with regard to GM crops, we demand that:

- the DBT withdraw the policy draft immediately

- the DBT initiate large scale, honest, genuinely participatory processes of consultation with the primary stakeholders – farmers and agricultural workers and consumers of this country before coming up with a decision on GE in agriculture

- accountability be fixed immediately for all the lapses seen so far in implementation of current regulations, including due to illegal approvals given by the DBT

- the Ministry of Science & Technology and Ministry of Agriculture first invest in safer, ecological, alternative technologies that are farmer-centric.

Sd/-:

FARMERS', AGRICULTURAL WORKERS` and MASS BASED ORGANISATIONS1 Bharat Krishak Samaj Krishanbir Chowdhary2 Agargami Kisan Sabha Bir Singh Mehto3 All India Kisan Sabha N K Shukla4 All India Kisan Sabha & National

Kisan PanchayatAtul Kumar Anjaan

5 All India Organic Farmers' Association

Ramaswamy Selvam

6 A.P. Vyavasaya Karmika Sangam Venkateshwarlu7 A.P. Ryota Sangam Kolli Nageswara Rao8 Andhra Pradesh Adivasi Aikya

VedikaK Pandu Dora

9 Bhartiya Kisan Sangh Krishan Chander Suryavanshi10 BKU (Ekta) Pishora Singh Sidupur11 Indian Farmers' Congress Dr K R Chowdhary12 Jana Vignana Vedika Dr Mohan13 Karnataka Rajya Raitha Sangha Prof K C Baswaraju14 Kisan Sangharsh Samiti Dr Sunilam15 National Alliance for People’s

MovementsChennaiah

16 National Farmers' Protection Committee

Prabhakaran Pandiyode

17 TVNN-Tamil Nadu Farmers’ Institute of Water Resources

K Thachinamurthy

18 Telangana Rythu Samithi Dr K R Chowdhary19 Vidarbha Organic Farmers’ Ram Kalaspurkar

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Association

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AGRICULTURE SCIENTISTS AND RELATED ACADEMICIANS

20 Dr Abhay Shendye Agricultural Biotechnologist21 Dr A Latha Agricultural Scientist, River Research

Centre22 Dr Arabandi Prasada

RaoAgricultural Scientist

23 Dr Arul Lakshminarayan Scientist, IIT-Chennai24 Dr Basappa Directorate of Oilseeds Research25 Dr. Chari M.S. Ex. Director, Central Tobacco

Research Institute; Entomologist26 Dr Debashis Banerjee Agricultural Biotechnologist, Samaj

Pragati Sahyog27 Dr Devinder Sharma Forum for Biotechnology and Food

Security28 Dr Elizabeth Joseph Fisheries Scientist29 Dr Gowri Shankar Scientist, Indian Institute of

Vegetable Research30 Dr Kajri Jain Academic31 Dr K R Chowdhary Agricultural Scientist32 Dr Nitya S Ghotge Veterinary Scientist33 Dr Qayoom Joint Director Agriculture (Retd),

Consultant34 Dr Raghunath Entomologist 35 Dr Ramanjaneyulu Agricultural Scientist, Centre for

Sustainable Agriculture36 Dr Ravindra Agricultural Scientist and Secretary,

Watershed Support Services and Activities Network (WASSAN)

37 Dr Sagari Ramdas Animal Geneticist38 Dr Shambu Prasad Science Policy Expert; Centre for

Research in Innovation & Science Policy (CRISP)

39 Dr Suman Sahai Geneticist & President, Gene Campaign

40 Dr Suresh K Agriculture Scientist, WASSAN41 Dr T N Prakash Agriculture Scientist42 Dr Uma Maheswara Rao Senior Scientist, IARI

Dr Vandana Shiva RFSTE43 Dr Venugopal Entomologist, ANGRAU44 Dr Vinod Vyasulu Economist45 Mr Harvir Singh Directorate of Oilseeds Research46 Mr Kiran S Agriculture Extension Scientist,

Permaculture Association of India47 Mr Krishnadevarao IPRs lawyer, Gujarat Natnl Law

University48 Mr Lakshmi Narayana DOR

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49 Mr Vinod Goud Agriculture Scientist, WWF India50 Ms Lakshmamma DOR51 Ms Lakshmi Prayaga DOR52 Ms Lavanya Directorate of Oilseeds Research53 Ms Padma DOR54 Ms Radha ANGRAU

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DEVELOPMENT/CONSUMER/WOMEN’S/ENVIRONMENTAL/HEALTH/ AGRICULTURAL ACTIVISTS & ORGANISATIONS55 Afsar Jafri Navdanya56 Anjali Gopalan The Naz Foundation (India) Trust57 Ashima Roy Chowdhary Gramya Resource Centre for

Women58 Ashish Kothari Kalpavriksh59 Biraj Patnaik ActionAid India60 Ira Roy Sachetan – MUMBAI61 Jagrutha Mahila Sangathan (a women’s CBO), Raichur62 M.V. Sastri Convenor, Centre for World

Solidarity63 Madhumita Dutta The Other Media64 Dr Mihir Shah Samaj Pragati Sahayog65 Monimoy Sinha Jharkhand Resource Centre66 Nalini Naik SEWA – Kerala67 Narendar Kumar Public Advocacy Initiative for

Rights & Values in India (PAIRVI)68 Neju George Vimukti, Raichur, Karnataka69 P V Satheesh Deccan Development Society70 Prabha Nagaraja TARSHI71 Radhika Chandiramani TARSHI72 Rajeev Baruah Maikal bioRe73 Rukmini Rao Executive Director, CWS74 Shubash Sule Centre for Holistic Studies –

Nashik

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CONCERNED ACTIVISTS AND INDIVIDUALS75 Aparna Krishnan Engineer & Organic Farmer 76 Aradhana Seth Film maker/Production Designer77 Arun Environmental Science teacher, KFI78 Aruna Rodrigues Economist, Environmental &

Alternative Energy Policy Analyst79 Arundhati Roy Author80 Asmita Rangari Development Consultant81 C.B.Ramkumar Concerned Citizen of India & the World82 Deepak Thakur Advocate83 Dhritiman Chaterji Cinema, Communications84 Dinesh Gopinath Lecturer, Govt. Engineering College85 Dr Leo Rebello World Peace Envoy, Mumbai86 Dr. R. Sukanya Medical Doctor – Kerala87 Dr. S. Shanthi Environmentalist88 E.S. Jayachandran Lecturer, Govt. Engineering College 89 Fr Erasto Fernandez Catholic Priest90 Gijs Spoor Organic Farming activist91 Gitanjali Singhal Practising Architect92 Gorrepati Narendranath Organic Farmer & Land Rights/Dalit

Rights activist93 G T Arasu TASS Agro ventures94 Jai Prakash Prajasakthi Daily Newspaper95 Jashwant Purohit Concerned Citizen96 Joanne van Gruisen Wildlife Photographer/Conservationist97 K Nagarajan Bangalore98 Lawrence Surendra Organic Horticulturist & Environmental

Economist99 Nagesh Kolagani Organic Farmer 100

Nityanand Jayaraman Independent Journalist/Researcher

101

Paul Calvert EcoSolutions

102

Pervin Jehangir Activist

103

Pradip Krishen Naturalist and Ecological Gardener

104

Pramada Menon Concerned Citizen

105

Prashant Bhushan Supreme Court Lawyer

106

Pushpa Surendra Organic Horticulturist and Writer

107

Rashna Imhashy-Gandhy Trees For Life India

108

Robin Keraleeyam – Media & Development

10 S M Daud

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9110

Uma Shankari Organic Farmer and Traditional Irrigation Systems expert

111

Virginia Saldanha Women’s activist

112

Zamrooda Khanday Concerned Citizen

Civil Society Response to the National Biotechnology Development Strategy of Government of India

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SUSTAINABLE AGRICULTURE, ORGANIC FARMING AND ENVIRONMENTAL GROUPS113 Anthra Afsar114 AOFG India E M Koshy115 AP Coalition in Defence of

Diversity Jayashree116 APPS - Anantha Paryavarana

Parirakshana Samithi V Kristappa117 * RIDS * REDS *HANDS * MGYS *VOICE*SRIRED *CARD

*KREDS*SAVE *FORD *LANDS *CERA * CHAITANYA 118 Aranya Agricultural Alternatives K Narsanna119 ASDS Gandhi Babu120 CEAD A P Rao121 Centre for Sustainable

Agriculture Kavitha Kuruganti122 CIKS A V Balasubramanian123 CONARE Saleem124 CROPS Lingaiah125 Deccan Development Society P V Satheesh126 DDN K Aruna127 Dharamitra Dr Tarak Kate128 ETC – India Arun Ambatipudi129 Foundation for Ecological

Security Jagdeesh Puppala130 GMM Vijaya Lakshmi131 Greenpeace Ananthapadmanabhan132 Gurukula Botanical Sanctuary Suprabha Seshan133 ICRA Babu134 Jana Jagruti Balram135 Jatan Kapil Shah136 Kalpavriksh Kanchi Kohli137 Kheti Virasat Umendra Dutt138 KPPS - Khammam Paryavarana

Parirakshana Samithi G Satyanarayana139 Krishi Vigyan Kendra(-DDS),

MedakSalome Yesudas, Nutrition Scientist

140 Krushi Premchand141 MARI R Murali142 Navajyothi B Manohar Rao143 Navdanya Afsar Jafri144 Niramayam Foundation Ramesh Ganeriwal145 Prakruti Kisan Mehta, Priya Salvi,

Rajiv Bhatt146 REDS Bhanuja147 Sampark Nilesh Desai148 Sarvodaya Youth Organisation P Damoder

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149 SECURE Venu Madhav150 SEVA U Raja Rao151 SPEAK India Shameer152 Telangana Natural Resource

Management Group Arjun Prasad153 Thanal Usha 154 Wayanad Prakruthi

Samrakshana Samithi N Badusha158 Yakshi Madhusudan

Cc: The Secretary, Department of Biotechnology, Ministry of Science & Technology

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