From: Sudarshan Iyengar <sudarshan54@gmail.com>
Date: 30 July 2017 at 06:54
Subject: Environmental Release of GM Mustard
To: narendramodi1234@gmail.com, connect@mygov.nic.in, indiaportal@gov.in
Cc: info@drharshvardhan.com, drhrshvardhan@gmail.com, ps2mefcc@gov.in, rsc-st@sansad.nic.in, am.krishi@nic.in, radhamohansingh@radhamohansingh.com

July 29^th 2017

To,

Hon. Prime Minister,

Government of India,

South Block, Raisina Hill,

New Delhi 110 011.

 

Sub: Environmental Release of GM Mustard

Dear Prime Minister,

Greetings!

We are economists who have been engaging with issues of farm livelihoods, food security and related matters. The current agrarian distress and a sustainable solution for the same is a matter of concern to us, like for many others. Many of us believe in sustainable agriculture/agro-ecology based solutions to empower farmers.

We are writing with concern about the recommended “environmental release” of GM mustard by regulators in Genetic Engineering Appraisal Committee (GEAC) in the Ministry of Environment, Forests and Climate Change, GoI. From the reports available about the Public Interest Litigation being heard in the Supreme Court of India, it is apparent that the Government of India is keen on authorising this “environmental release”/commercial cultivation of GM mustard. The regulators and promoters are stating that GM mustard has been successfully evaluated for food and environmental safety as well as for agronomic superiority. However, there have also been many counter-arguments questioning the testing and appraisal procedures including the fact that conflict of interest continues to pervade the regulatory decision-making. Further the crop developers themselves evolve test protocols and conduct tests themselves. No long term testing is taking place on health or environmental front. Also, there is limited public scrutiny of test data.

As economists, we would like to focus on the claimed benefits of the GM mustard. Since GM mustard which is to be released has following significant problems, the benefits claimed to the farmers and the society may not materialise.

1. GM mustard has not been proven to be a superior hybridisation or pollination control technology as compared to a non-transgenic hybridisation/pollination control technology called CMS (cytoplasmic male sterility) technology. In fact, no such testing has been done that compared GM mustard against non-transgenic technologies of pollination control.
2. In majority of countries around the world which grow rapeseed/mustard, seeds used are non-transgenic hybrids. Compared to the three countries which have adopted GM canola/rapeseed, yields in the other countries using non-transgenic hybrids are significantly higher.
3. As regards agronomic superiority, we have been made to understand that the application for authorisation for environmental release put in by Delhi University’s Centre for Genetic Manipulation of Crop Plants (CGMCP) made claims that GM mustard has higher yields and hence increased output will bring down India’s edible oil imports. However, when counter evidence was presented about unacceptable and unreliable testing of GM mustard by using protocols that were evolved by the crop developers not adhering to the norms followed by all other public sector scientists of the country, the benefit claims were shifted from higher yield to one of proof of concept of hybridisation. Interestingly proof of concept of hybridisation was not tested by the formal applicant to this day. It was brought in when public debate began on the subject challenging the yield benefit claim. Government of India has also admitted in the Supreme Court in an affidavit in October 2016, that GM mustard has not been claimed to out-yield non-GMO hybrids. It has been stated clearly stated in point 1 above that even the proof of concept has not been established by the crop developer.
4. A Sub-Committee of GEAC responsible for safety appraisal of GM mustard, while dealing with questions raised on agronomic superiority of GM Mustard noted, “the yield comparison with national and local checks which has commercial use applications is beyond the mandate of the assessment” (Para 5.2 of final report of Sub-Committee of the GEAC dated 1-11-2016). If regulators are backing off from increased yield claims, any question of saving of foreign exchange on reduced edible oil import, does not arise.
5. It is feared that there is likelihood of displacement of rural workers from manual de-weeding for daily or piece rate wages, because with an herbicide tolerant crop, farmers will spray weedicides on the crop rather than employ labourers for manual de-weeding. De-weeding is an important source of employment for poor rural women mostly (such “weeds” are also sources of fodder for livestock). No representative of the Commerce Ministry or Food Processing Industries Ministry attended any GEAC meeting or presented the stakes from the perspective of their Ministry. It is apparent that GM mustard will have adverse impact on farmers’, agricultural workers’ and beekeepers’ livelihoods. Ayurveda and Honey industry are also at risk.
6. Organic farming will be jeopardised with the commercialisation of GM mustard. This is a sunrise sector, on which the government is also investing through large flagship schemes, and a niche area in which India has the potential to be the world leader.
7. There are simple agronomic approaches, proven to be highly successful including in the extension work of state governments like Madhya Pradesh (called System of Mustard Intensification) which will increase mustard yields that need to be promoted on a large scale.

Risking the health and environmental safety of Indians on the basis of unfounded benefit claims when there are safe, proven solutions is inexplicable and unjustified. Addressing issues around import duties, procuring oilseeds from farmers at attractive and remunerative prices, providing incentives on a per-acre basis for opting to cultivate oilseeds, investing on better extension services and so on, are bound to address the issue of edible oil import bill more meaningfully. It is not out of place to point out that despite very high production of mustard last year, farmers were punished by very low market prices, and they are not likely to be incentivised to produce more if this situation continues.

Lastly, no policy prescription, certainly from economists, can ignore the institutional context. Recommending ‘legal action’, as has been done by the GEAC Sub-Committee, on farmers using readily-available herbicide on a herbicide-tolerant crop, indicates complete ignorance of ground realities of Indian agriculture. ‘Legal action’ on millions of small Indian farms using herbicide on herbicide tolerant GM Mustard is simply not feasible. This country does not even have adequate extension professionals to bridge the “technology yield gap” for existing technologies, leave alone personnel who will police over farmers.

In the light of above, we request you to ensure that agricultural technologies that we invest on provide sustained social, environmental and economic benefits for our farmers and look for those solutions which will create a win-win situation for farmers, agricultural workers and consumers.

We therefore humbly submit that GM mustard is clearly not that solution and hence its environmental release should not be authorised.

Sincerely,

 

Prof Sudarshan Iyengar,

Former Vice Chancellor,

Gujarat Vidyapith, Ahmedabad and

Former President, Indian Society for Ecological Economics (INSEE)

 

Endorsed by:

1. Dr C Rammanohar Reddy, former Editor of Economic & Political Weekly
2. Dr Golak Bihari Nath, Economist, Writer and Editor of Anwesa, Odisha
3. Dr Hemant Shah, Head, Dept. of Economics, HK Arts College, Ahmedabad
4. Dr Indira Devi, Director, Centre for Excellence in Environmental Economics, Kerala Agriculture University, Thrissur
5. Dr Navsharan Singh, Delhi
6. Dr Rajinder Chaudhary, Former Professor, Department of Economics, M. D. University, Rohtak (Haryana)
7. Dr Ranjit Singh Ghuman, Nehru SAIL Chair Professor, Centre for Research in Rural & Industrial Development (CRRID), Chandigarh
8. Dr Ritu Dewan, Director, Centre for Development Research and Action, Mumbai; Retd. Director and Professor, Department of Economics, University of Mumbai
9. Dr Seema Purushothaman, APU, Bangalore
10. Prof Aldas Janaiah, PJTS Agriculture University, Hyderabad
11. Prof Atul Sood, Professor, Centre for the Study of Regional Development,  Jawaharlal Nehru University, New Delhi
12. Prof Gopal K Kadekodi, Hon. Professor, Centre for Multi-Disciplinary Development Research, Dharwad, Karnataka
13. Prof Kamal Nayan Kabra, Former Professor, Indian Institute of Public Administration, New Delhi
14. Prof Praveen Jha, Professor of Economics and Chairperson of the Centre for Economic Studies and Planning (CESP), School of Social Sciences, Jawaharlal Nehru University, New Delhi
15. Prof. Vamsi Vakulabharanam, Assoc. Prof. of Economics, formerly Hyderabad Central University, now Univ. of Massachussetts, Amherst.
16. Prof Surender Kumar, Former Dean Academic Affairs, MD University, Rohtak

 

Endorsements of Prof Amit Bhaduri, Centre for Economic Studies and Planning, Jawaharlal Nehru University, New Delhi and Prof B M Kumaraswamy, Retd Principal, DVS College, Shimoga have also been received.