An Open Letter to the Environment Minister

Posted on Wednesday, January 27th, 2010

Jairam RameshJanuary 12, 2010

Mr. Jairam Ramesh
Hon’ble Minister of Environment & Forests
Paryavaran Bhavan
CGO Complex, Lodhi Road
New Delhi – 110 003


Dear Jairam,

I would like to begin by thanking you for taking the initiative to hold public hearings on Bt. Brinjal. I think it is the first time a humble vegetable has been made the subject of a National Consultation. “

On behalf of the “baigan” and millions of small “baigan” growers who have conserved the rich diversity of brinjal in India, thank you.

I write to you as an expert on Biosafety who made major contributions for the introduction of Article 19.3 on Biosafety in the UN Convention on Biological Diversity and was a member of the expert group on Biosafety set up by the Convention to evolve the framework of the Biosafety protocol and as an advisor to many Governments on issues of Biosafety.

I also write to you as the Founder of Navdanya, the largest network of organic producers in the country. My main concerns are the false scientific assumptions underlying the Biosafety assessment of Bt. Brinjal and the impact of Bt. Brinjal and GM crops on our organic farmers.

“The Report of the Expert Committee (EC-II) on Bt. Brinjal Event EE-1 Developed by –

M/s Maharasthra Hybrid Seeds Company Ltd (MAHYCO), Mumbai

University of Agricultural Sciences (UAS), Dharwad and

Tamil Nadu Agricultural University (TNAU), Coimbatore”

Submitted to the Genetic Engineering Approval Committee, Ministry of Environment and Forests, is unfortunately scientifically unsound at the level of food and agriculture systems, and in the context of the organic alternative.

Wrong Rationale : Bt. Brinjal is not an alternative to chemical pesticides, Organic Farming is the real alternative

The “Rationale for the development of Bt. Brinjal” presented by EC-II, is based on the false assumption that genetically engineered Bt. crops like Bt. Brinjal are an alternative to the use of chemical pesticides for pest control.

The panel does not address the real alternative to chemical agriculture which is organic farming based on the principles of agro-ecology. Biodiverse organic farming controls pests at the systems level by enhancing pest-predator balance and by growing crops with pest and disease resilience. Increasing ecological balance and resilience are the only effective and sustainable strategies for controlling pests. The 500,000 members of Navdanya know this through practice. Research on agro-ecology confirms that ecological / organic farming systems reduce pests and have no need for the use of pesticides.

In Indonesia, restrictions were introduced on the use of 57 pesticides in rice-growing, and subsidies for pesticides were eliminated.  From 1987 to 1990, the volume of pesticides used on rice fell by over 50 per cent, while yields increased by about 15 per cent.  Farmers’ net incomes increased by $I8 per farmer per season.  The Government saved $120 million per year by ending pesticide subsidies. (Thrupp, ‘New Partnerships for Sustainable Agriculture’, 1997)

In Bangladesh the ‘No Pest’ programme led to pesticide reduction of 76 per cent and yield increases of 11 per cent.  Returns increased by an average of 106 per cent in the dry season and 26 per cent in the wet season (Thrupp.)

The panel has totally ignored the real alternative to chemical pesticides – organic farming – in its rationale. It has distorted the organic alternative in its “responses”. Instead of seeing organic as a farming system, it has reduced it to external inputs. The report states “In organic farming, the pest management totally relies on the use of botanical insecticides like neem oil, pongam oil, illupai oil or seed kernel extracts or leaf extracts which act as repellent, antiferdant or in some cases as toxins. None of the botanical pesticides are expected to perform well against the fruit and shoot borer (FSB) since the pest hides itself from the sprays while staying inside the fruits / shoot borer” (p.60)

This is an unscientific and false representation of the agro-ecological principles on which we have built the organic movement. Organic / ecological farming is not an input substitution system. It recognizes and respects the ecological processes through which pests are controlled and it also recognizes the processes through which pests are created.

Pests are created through –

  1. Promotion of monocultures
  2. Chemical fertilization of crops which makes plants more vulnerable to pests
  3. Emergence of resistance in pests
  4. Killing of friendly species which control pests and disruption of pest-predator balance

Bt. crops are not an alternative to these pest creating systems. They are a continuation of a non-sustainable strategy for pest control which instead of controlling pests creates new pests and super pests. Bt. Brinjal, like Bt. Cotton, is grown as a monoculture, and is part of the package of chemical farming. Bt. Cotton, like Bt. Brinjal, was supposed to control the lepidopteron insects. In the case of cotton, the pest was the bollworm. In the case of Bt. Brinjal it is the fruit and shoot borer.

In Bt. Cotton we have witnessed the emergence of new non target pests and diseases such as aphids, jassids, army bug, mealy bug and “laliya”. This has led to an increase, not a decrease in pesticide use. Navdanya studies show a thirteen fold increase in pesticide use in Vidharbha after the introduction of Bt. Cotton.

Genetically engineered Bt. crops also contribute to emergence of resistance in the target pests. The bollworm becomes resistant to the Bt. toxin when every cell of the plant releases it in high doses all time. The need for refugia and the introduction of Bollgard II are evidences of the emergence of resistance in pests as a result of using GM Bt. technologies.

The economic benefits of Bt. Brinjal are distorted because they are based on the false assumption of savings of pesticide sprays and yield benefit due to protection of fruit and shoot borer. Bt. Cotton led to increased sprays and emergence of new pests. This risk in Bt. Brinjal has not been addressed. Nor has the cost of royalties, since Bt. Brinjal is patented. Seed cost in cotton jumped from Rs. 7 to Rs. 1700/- when Bt. Cotton was introduced.

The real cost benefit calculation and comparison should be between organic brinjal cultivation based on open pollinated seeds that farmers can save and Bt. Brinjal whose seeds farmers must buy every year, and which will be suceptable to new pests for which more pestices will need to be used.

In an honest and scientific assessment, benefits of biodiverse organic farming outweigh the “benefits” of Bt. Cotton. Navdanya’s organic farmers have increased their incomes tenfold when they shifted from Bt. Cotton to organic cultivation


[You can download the complete letter by Clicking here ]

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“An Open Letter to the Environment Minister”

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