Ten years of Bt cotton in India: Review findings
(Annexure to Press Note released by CEE/CSA/CSD on June 13th 2012)

A 10-year review process of Bt cotton in India was initiated by Centre for Environment
Education (Ahmedabad), Centre for Sustainable Agriculture (Hyderabad) and Council for
Social Development (New Delhi), through a national conference organized in Delhi on June
11th and 12th. The conference had more than 150 participants from all over India, consisting
of several regulators from Genetic Engineering Appraisal Committee and Review Committee
on Genetic Manipulation, agriculture and molecular biology experts from different parts
of the country, industry representatives, farmers’ organizations, organic farming groups,
other civil society groups, academics and representatives of media. The Conference also
saw Central Government representatives including Prof Abhijit Sen, Member in charge of
Agriculture, Planning commission; Dr Anupam Barik, Addl Commissioner, Crops, Ministry
of Agriculture and Mr M F Farooqui, Chairman, Genetic Engineering Appraisal Committee
chairing various sessions. The experiences, studies and available data while questioning the
absolute success of Bt cotton across the country brought forth the fact it has failed in the
rainfed regions, which cover 65% of the total cotton cultivation in the country, due to various
reasons. The conference organizers opined that this is a first step towards a comprehensive
review process that needs to be taken up.

The review saw a number of presentations of micro-studies as well as macro-data on a variety
of subjects including farm economics (yield, production, farmer incomes) with Bt cotton in
different comparative frameworks, pesticide usage, regulatory regime, policy frameworks
related to GMOs, riskiness and farmer suicides associated with Bt cotton, on public sector
Bt cotton, on emerging scientific evidence with Bt cotton, on social, political and other
implications etc., with further analysis and discussions on the same.

The main issues that emerged from this conference are:

The conference noted that adoption of Bt cotton in India is quite high. It also noted
that distress amongst a large majority of cotton farmers is also high (especially in
rainfed growing conditions).

The conference acknowledged the fact that such adoption should also be understood
in the context of the failure of an earlier, related technology of chemical pesticides.

The conference found a mixed picture as the reality with Bt cotton with the agreement
that it is not the best solution for rainfed regions. It was also noted that results from
irrigated farming with Bt cotton have shown varying trends across regions and across
years.

The conference also noted that different official sources of data are inconsistent with
each other, and unreliable. While different micro-studies are questionable on their
methodologies or design adopted, macro-data is sometimes contradictory between
different sources. It was however acknowledged that cotton area, production and yield
has increased in the country in the past decade. How much of this is attributable to
Bt technology and whether there is a causal correlation at all requires an in-depth

investigation given that:
o There has been a large scale shift to hybrid cotton cultivation in the country;
o That irrigated cotton area is on the increase;
o That there have been favorable climatic conditions, especially in states like
Gujarat;
o That input use on Bt cotton has been higher, in terms of chemical fertilizers
etc.

This causal correlation analysis has to be taken up also because in the years that
India reported the highest year on year increases in cotton yields, AICCIP (All India
Coordinated Cotton Improvement Project) results were showing that bollworm
incidence was low to moderate. When Bt cotton can result in higher productivity only
under pest pressure by protecting the crop from pest damage, how can such yield
increases then be related to Bt technology?

Moreover, the recent stagnation and decline in cotton yields has to be understood
further.

There was also a near-complete agreement on the increase in cost of cultivation after
the adoption of Bt cotton. Comparative analysis with other alternatives like NPM and
organic farming practices highlighted the definite advantage of these practices in cost
of cultivation in comparison to intensive agricultural practices with Bt cotton hybrids.

On pesticide consumption data, some micro-studies seem to indicate pesticide use
reduction initially, with use on sucking pests and other pests increasing, with per
acre pesticide usage increasing in the past and a dangerous cocktail of pesticides on
the rise, while others indicate a steady increase. However, official data on pesticide
consumption in India does not reflect any decline, except in Andhra Pradesh, where
large-scale adoption of NPM is being followed.

The conference brought out the fact that riskiness analysis has to be incorporated
into decision-making in technology assessment, more importantly in the case of
transgenics like Bt cotton.

Concerns around the existing regulatory architecture in India, including the total
absence of policy directives against even crops for which we are the Centre of Origin
and diversity, in which we have trade security interests and where intense social
implications lie (like herbicide tolerant crops) came to the fore.
The discussion on the regulatory mechanisms identified the need for further safety
assessments for Bt cotton especially in the light of high volumes of oil from Bt cotton
seeds reaching the edible oil supply and the usage of oil cakes as cattle feed.

It was also clearly pointed out that any decision-making on transgenics should
incorporate need assessment and an assessment of alternatives, before considering a
transgenic option at all.

The need for a liability regime to be put into place in addition to a labeling regime
was emphasized.

93% of cotton seed being ‘controlled’ by one American MNC was noted. Seed
sovereignty being threatened, with the public sector in India becoming redundant and
irrelevant was a concern shared by many. It was noted that Bt cotton seed companies
were not being made accountable, with the seed industry often taking governments to
court – in this situation, the hope for farmers’ rights being upheld appears meagre.

There was concern around public funds being wasted in several ways, including
on transgenic research that gets bogged down in IPR issues and “contamination”
issues, in addition to lack of ability to take the R&D products to farmers; further,
governments are paying compensation packages to farmers when the crop fails, with
public funds.

The conference noted that public sector research is being sidelined with private sector
takeover of seed. This is also limiting seed choices for farmers.

On the other hand, increased chemical fertilizer usage in Bt cotton was acknowledged,
especially in terms of data available from Gujarat state – this not only has further
public financing implications, but also serious environmental concerns where we are
not treating our soil fertility as our main capital.

The conference also repeatedly noted that safer, cheaper and sustainable ecological
alternatives exist, which are acknowledged by the NARS system and also practiced
on a large scale by lakhs of farmers in the country. The conference put forward a
recommendation that the government should create a level playing field between such
alternatives and intensive agricultural technologies, for rational, informed choices to
be made.

The conference identified that various parameters to assess Bt cotton have not been
taken on board so far.

Aggressive marketing of Bt cotton seed was noted as a matter of concern and it was
opined that this should be curbed, given that Seed is an Essential Commodity.

The concluding session was chaired by Mr Jairam Ramesh, Union Minister for Rural
Development, who opined that the story of Indian cotton needs to be studied thoroughly, to
understand the “structural transformation” in the cotton economy in India in the past two
decades. He pointed out that Bt cotton adoption by farmers is a fact to be noted, even as the
contribution of hybrid seed and irrigation to cotton yield increases is to be acknowledged.
Jairam Ramesh also pointed out that there is more scientific evidence that has emerged
in the recent past which needs to be taken seriously. He pointed out that biotechnology
in agriculture should not be restricted to one tool like Bt/Genetic Engineering and should
explore and invest in a spectrum of tools like marker assisted breeding etc. He appreciated
the more active role being played by state government in the recent past. There are a large
number of scientific problems that have to be addressed. He felt that appropriate lessons
have to be gleaned for research, seed production, extension, regulatory regime and so
on, by the country taking up a comprehensive review of Bt cotton at this point of time.
Most importantly, he pointed out that he does not see any reason why organic and NPM
alternatives cannot be promoted by the government as much as support for transgenic
research.