The Genetic Engineering Approval Committee (GEAC) of the Ministry of Environment and Forests (MoEF), Government of India (GoI), approved the release into the environment and commercialisation, of three transgenic Bt hybrid cotton varieties, developed by the Maharashtra Hybrid Seed Company (MAHYCO), namely Bt MECH 12, Bt MECH 162 and Bt MECH 184, containing Cry 1Ac gene from the bacterium Bacillus thuringiensis, and npII and aad marker genes, subject to certain conditions. The approval is valid for three years from April 2002.

The process of approval took almost five years and was mired in controversies that made the GoI adopt a very cautious approach. Nonetheless, the GEAC deserves to be congratulated for the decision finally taken.

Approval of the first Genetically Modified (GM) crop is an important development, that was applauded by the scientific community both in India and outside, as it is a landmark decision paving way for more GM crops in India. The Nobel Laureate, Norman Borlaug, an enthusiastic friend of India and the Father of Green Revolution, welcomed the much delayed decision. Not surprisingly, the anti-biotech activists and the Non-Governmental Organisations (NGOs) donned a fresh war paint.

The GEAC have taken the Precautionary Principle too seriously in attaching conditions to the approval of Bt cotton for cultivation. It is a reasonable attitude to prepare us to face what may come out of Bt cotton cultivation and necessary approach to risk management and risk mitigation. Nevertheless, the practicability and implications of some of the conditions, in the Indian context, need to be examined. This is also necessary in the context of the other GM crops that are likely to follow. The following are the more important of the issues that need to be discussed in detail:

1. THE REFUGE

The GEAC states that, "Every cotton field where Bt cotton is planted shall be fully surrounded by a belt of land called 'refuge' in which the same non-Bt cotton shall be grown.   The size of the refuge belt should be such as to take at least five rows of non-Bt cotton or shall be 20% of the total sown area, whichever is more."

A refuge (or refugee, refugium) around GM crops is possibly sourced from the regulations of the Environmental Protection Agency (EPA) of the US, which are generally observed in many parts of the world.    A refuge area is a stipulation very relevant to the monoculture situation where thousands of hectares have only one crop.    In the Indian situation, where several different crops are grown in a narrow region, the implications are different.

a) The functions of a refugium:

i) Pollen sink: Vegetation surrounding a crop field acts as a screen and prevents pollen from drifting away from the field or pollen reaching a particular field from another field.    This purpose is served by any species that grows dense and is taller than the crop.   In India, cotton is often grown as a mixed crop with pigeon pea, sunn hemp or vegetables, many of which are taller than cotton.   If the refugium is a crop/species different from the GM crop, it functions as a virtual pollen sink, as no inter-crossing is possible.    If the refugium and the main crop are the same, there will   be inter-crossing at the interface of the two varieties, in both directions, and the intended benefits of a considerable part of the GM crop are diluted by inter-crossing.

Pollen of cereals and millets (rice, wheat, corn, sorghum, pearl millet, etc.) are designed to be wind borne.   They are relatively small in size, light, smooth, dry and powdery.   They may be carried to longer distances depending upon several weather conditions. On the other hand the pollen of several other crops like cotton, ladies’ fingers, and most others are sticky and occur in lumps, and hence are hardly windborne.   They require a pollen vector, such as bees or butterflies.   Certain pollen vectors are unifloral; they visit only one particular species, while others visit several different species in a day (multifloral).    Pollen of cotton and ladies’ finger crops are spinescent and stick together more, and these crops often end up in self-pollination.   Actually cotton pollen are among the heaviest, with about 40 per cent moisture.   And cotton is highly self pollinated, even to the extent of 99 per cent.

Whatever the mode of pollination, the integrity of different species is ensured in nature through reproductive isolation, operating through several different mechanisms called reproductive barriers.   On account of this basic natural safeguard, today we have about 2,75,000 species of flowering plants.   And we also have over 2,00,000 varieties of cultivated plants, belonging to hardly a score of species, that came into being entirely due to man’s efforts.   The fear that cotton or any other crop (GM or not) contaminating crops of other species is untenable and unscientific.    Only hybrids of the same crop are susceptible to such dilution and loss of characteristics, through inter-crossing.

Cauliflower, cabbage, knoll-kohl, broccoli and Brussels’ sprouts, are crop varieties developed by man, through selection, from a single species (Brassica oleracea).   These would easily inter-cross with each other, if grown in the same area and in a few generations lose their distinct identities.   Even in such a situation farmers have maintained them distinct for hundreds of years.

The only species related to cotton occurring in India is the West Asian Gossypium stocksii that grows in the wild only in Gujarat.   This wild species and the cultivated cotton plant varieties are cytogenetically incompatible and the possibility of viable seed, even if they inter-cross per chance, is extremely remote.

However, there is always a chance of one variety of a particular crop inter-crossing with another variety of the same crop (such as GM and non-GM cotton).   The recent disproved claims of GM corn contaminating non-GM corn in Mexico indicate that such events are not necessarily the rule of nature, even in the case of habitually cross pollinated crops.

It is not necessary that the refuge belt should be formed of only by cotton around a Bt cotton field.   Farmers may be permitted to use any other crop that gives them some economic returns.   Even green manure sources like Gliricidia and sunn hemp will serve the purpose of a pollen sink around a GM crop field.      A non-Bt cotton refugium around a cotton field will only result in a loss of saleable crop product, since as per the regulation the refuge and the crop should be of the same variety, and so would inter-cross.

ii) Dilution of resistance to Bt genes: In course of time some bollworms would survive on the Bt cotton, acquiring some degree of resistance to the Bt proteins, and the numbers of such resistant worms would increase with time, if this resistance is not broken down.   There would be plenty of bollworms on the non-Bt refugium.   An inter-crossing between the two categories of bollworms would dilute   the resistance developed by the bollworms to the Bt gene products.    This is a positive (and possibly the only) benefit of a non-Bt cotton refuge, around Bt cotton.

iii) Alternate hosting sites: In countries like India, where there is no practice of monoculture, structured refugia may not be required, as a large number of alternative hosts of the bollworm such as the chickpea, pigeon pea, sunflower, sorghum, maize and chillies are grown in the same area, and in the same season as cotton.   These alternative hosts support high susceptible populations of the pest, thereby serving as refugia.

When the Bt cotton plants are not palatable, the bollworm moths would move on to colonise non-Bt cotton refugium, thus reducing the effective numbers of the worms on the Bt plants.   It should be possible to select a species with some promising economic returns and which also can serve as an alternate host for bollworms, for use as the refuge belt.

iv) Conservation of bollworm: The non-Bt cotton refugium will harbour sufficient numbers of bollworms, to satisfy the   conservationists   that the cotton bollworm   would not be extinct.

v) Refugium affects saving Bt cottonseed for subsequent sowing: It is certainly not prudent to save seed from hybrids and GM crops, for sowing in the following season.   Even so, some farmers may be tempted to do just that.    If a non-Bt cotton refuge were used, even the marginal chances of saving seed would be lost.

2. INTEGRATED PEST MANAGEMENT

The GEAC states "MAHYCO   will develop plans for Bt based Integrated   Pest Management and include this information in the seed packets."
Integrated Pest Management (IPM) is an overall strategy making use of an appropriate blend of biological, chemical and cultural methods of control. IPM also needs support from appropriate forecasting methods, which are almost nonexistent in India.

The major objective of IPM is to minimise the environmental impact of the control methods used and to minimise inputs, resulting in higher returns.   Another objective is to minimise application of broad spectrum, prophylactic chemical treatments, in preference to highly targeted, specific chemical control measures.   With GM varieties tailored to specific pests, such as the Bt varieties, the use of chemicals in pest control will be phased out.

Over a period of time, based on global experience, some basic rules have been developed for IPM practices, among which the following are significant:

a) understanding the biology, particularly reproductive biology, of the crop is essential.   Different varieties of the same   crop are likely to have significant differences   in reproductive biology and hence focussed studies on each variety are needed;   it is important to know the stages at which the crop/variety is most vulnerable to a particular pest, in order to develop the most effective protection measures;

b) knowledge of the key pests which cause an economically significant damage to the crop is needed, so that they can be targeted; the key pests may vary from one agro-climatic region to another;

c) understanding the biological and physical factors, that determine the population densities of the key pests, are also required;

d) adequate surveillance and forecasting   of   key   pest populations;

e) susceptible stages of the key pests' life cycle, that are appropriate in the timing of control measures, need to be identified;

f) flexibility; IPM relies on being able to institute control measures at short notice, rather than to act to a set rigid pattern;

g) minimisation of environmental impact; this   prevents disruption of natural populations of predators and pathogens; and

h) maintenance of ecological diversity; a diverse ecosystem prevents the build up of dominant pest populations.

The most important aspect of IPM is to develop long-term surveillance monitors so that one can record the changes in pest populations due to the large scale and long term deployment of Bt cotton.   If Bt cotton despatches the bollworm as a serious pest, some other pest may take the place in course of time, for which Bt cotton varieties may be susceptible.

IPM programmes are more difficult to manage than traditional control measures, because of the need to continuously monitor the agricultural ecosystem and the need for rapid decision-making.   Nevertheless, IPM practices represent the future in pest management strategies.

Evidently IPM is a complex issue requiring long years of study and planning.   MAHYCO is now required to develop plans for Bt based IPM and include this information in the seed packets.   MAHYCO will not be possibly able to do this in the first phase of three years of approval.   It is quite doubtful if any other agency/institution can provide all the information needed for developing IPM protocols for cotton in India, in the near future. There is not much of a chance of any IPM information, particularly Bt based information, getting into the seed packets immediately.   MAHYCO needs to work diligently to develop the monitoring system, even if it takes more than three years.

3. OTHER CONDITIONS

MAHYCO should comply with a number of other conditions related to a) packing, b) labelling, c) physical and genetic description of the seeds, d) information on sowing pattern, e) monitoring susceptibility of the bollworm to the Bt cotton varieties, f) undertaking awareness and education programmes for farmers, g) recording impact on non-target insects and crops, h) deposition of 100 g of the seed of Bt cotton varieties with the National Bureau of Plant Genetic Resources (NBPGR), i) providing NBPGR with DNA finger print data of the released varieties, and j) providing testing procedures for identifying the transgenic varieties by DNA and protein methods.
The Indian agricultural system in general, and cotton production system in particular is not sophisticated enough to render itself to keep Bt cotton segregated for all the time to come nor it is really necessary.   The majority of GEAC’s conditions only serve to appease the critics of GM crops.   The GEAC in fact has set a trap for themselves, as many of the conditions are impossible to be implemented and at any rate not within the time frame stipulated.   The critics will later on criticise on the failure of implementation of not merely some of the conditions, but in fact the whole of the biosafety package, which has been quite successful outside India.
For the time being, the best thing for MAHYCO, seems to be to accept the conditions, release the seed varieties, make all efforts to comply with the conditions to the possible extent and convince the GEAC on modification of conditions that are not practicable.

4. ISSUES ARISING

Consequent to the release of the three Bt cotton varieties by the GEAC, and with the prospect of another variety soon to be released, a number of other issues arise for discussion:

a) Benefits to farmers:
The farmers growing Bt cotton will certainly be benefited.   The anticipated benefits of growing Bt cotton are i) reduced insecticide use, ii) improved control of target insect pest, iii) improved yield, iv) reduced cultivation costs and improved profitability, and v) reduced farming risk, reduced tension and improved economics for the farmers.   The farmer may pay about 1,000 to 1,500 for a 450 to 500 g packet of seeds needed for one acre, against about Rs. 550 for non-Bt cotton seed, but would save about Rs. 5,000 on pesticides and labour per acre.   The increase in yield will be substantially high, not due to an increase in productivity but due to prevention of loss.   A six to ten times increase in the harvest has been realised by cotton growers in different parts of the world.

b) Risk to formers:
Farmers growing Bt cotton may run the risk of vandalism of their crop by activists. The Guardian (UK) commented recently, that Bt cotton growing in India can only be with the help of guards.   But the Indian farmer has enough experience in protecting his crop from vandals and thieves.   And the State Governments should come to his rescue.
The farmer growing non-Bt cotton in the neighbourhood of Bt cotton runs the risk of greater damage from the American bollworm, as the pest seeks alternate hosts, in the face of Bt cotton resistant to it.   In times to come, farmers may see the benefits of Bt cotton and non-Bt cotton growing would diminish, and so the risk of increased pest incidence.

c) Use of pesticides:
Sowing Bt cotton reduces the use of pesticides to a third.   With over 50 per cent of pesticide use in India being on cotton, there will be a substantial saving to the farmer and the Government.   However, it is erroneous to think that the use of Bt cotton varieties will totally eliminate the need for pesticides.   Only the need to use pesticides against the bollworm is now minimised and there are other insect pests on cotton.   Bollworm is the target because it causes extensive damage to the saleable product while other pests affect productivity, for example by reducing the photosynthetic area.   The combination of different pests varies from one agro-climatic zone to another.   It is in this context, the concept of Integrated Pest Management becomes significant.

d) The GEAC should prevent a repetition of the Navbharath episode:
The GEAC should have a mechanism to watch for a clandestine cultivation of unapproved GM crop varieties produced by any seed company, in order to prevent a repetition of the Navbharath episode.

The Financial Times (April 20, 2002) reported that one Piyush Patel from Gujarat promises pest resistant cotton for Pubjab and Haryana, a very tempting offer since MECH 915, the Bt cotton variety that is most suited to these states has not been approved yet.   When such an event is discovered, the GEAC should act firmly and in time.   The GEAC should put in place a legally tenable procedure to prosecute such clandestine release of any unapproved GM crop variety; by anyone including Government funded institutions.

e) Spurious seed and black marketing:
In addition to unauthorised pest resistant cotton, there are chances that seeds of an ordinary cotton variety may also be passed on to gullible farmers, as pest resistant.   The GEAC should put in place a legally tenable procedure to prosecute such clandestine or spurious release of any unapproved GM crop variety by anyone.

Last year, a Canadian Court made a farmer pay compensation and legal costs to Monsanto, for having grown Bt cotton from clandestinely obtained seed.   His claims of ignorance of the source and qualities of the seed did not wash with the Court.

f) ICAR’s pest resistant cotton varieties:
The Deputy Director General (DDG) of the Indian Council of Agricultural Research (ICAR), New Delhi, told the Financial Express on April 9, that three varieties of pure line pest resistant cotton are being produced by the National Agriculture Research System of the ICAR.   These would be released in three years.   After all the ‘ifs’ and ‘buts’, after discounting for the enthusiasm of the DDG and with the national commitment to always being late, the release of these varieties may take five years, at the earliest. These varieties also should pass through the same thorough tests, trials and screening, as the Monsanto Bt cotton was subjected to.    In fact the safety, suitability, and financial viability of these varieties should be assessed more thoroughly, since they are quite nascent, whereas the Monsanto product underwent rigorous testing in different parts of the world, for nearly a decade.   Particularly important is the verification of the veracity of the claims: a) that these varieties are resistant not just to the bollworm but also other pests of cotton and b) that the farmers can recycle the seed for subsequent season’s sowing as they are pure line, unlike the Monsanto hybrids.

g) Should product generators sit on the GEAC?
By the claims of the DDG of the ICAR, the ICAR is a party to the development of the pest resistant Indian pure line cotton varieties, which means that the ICAR is a product generator and the future patent holder, like many other seed companies.   The DDG is a member of the GEAC, which is the national authority for the approval of similar crop varieties.   The GEAC has taken a very long time to approve the Bt cotton.    With his own products in the pipeline, and in the interests of the country, the DDG might not have been keen on the release of a foreign product.   All this makes one wonder if it is right for the ICAR, a generator of similar products, to be a member of the GEAC.   In the face of possible conflict of interests, it will be wise on the part of the GEAC to ensure that the DDG, or any other official from ICAR, is excluded from decision making whenever its product(s) come up for discussion.

Similarly, the Department of Biotechnology, Government of India, supports research on various biotechnological applications, many of which have to pass through the GEAC, sooner or later.   Extending the same logic as to the ICAR, the DBT also should not be sitting on the GEAC, approving release of biotechnology products, as the DBT itself is a product generator.

h) Responsibilities of the State Governments:

The state Governments have two immediate jobs on their hands:

a)      Make cultivation of the approved varieties of Bt cotton smooth without further waste of time.   The
          Safety and Risk Assessment Board of each State should be put in place immediately and get to
          the job of approving cultivation of Bt cotton in the respective states;

b)      Although it is not clear what purpose the state level boards will serve, in addition to adding to
          time delays, it would be prudent if the states address the socio-economic concerns peculiar to a
          particular state, in order to be able to advise the farmers;

c)      Some NGOs have threatened that they will destroy the standing Bt cotton crop.   When the
         MAHYCO trial plot was destroyed a year or so ago in Karnataka, the farmer did not suffer any
         loss.   Now it is a different matter as the standing crop is the property of the farmers concerned.
         When a legally approved crop variety is under cultivation, vandalisation of the crops should be
         considered as a criminal act and should be firmly dealt with under the laws of the State
         Governments.    The European Commission has recently declared that (GM) crop vandalisation
         is a violent act (to be dealt under the state laws).

d)      As against nine million acres under cotton in the country, it appears that the presently available
         Bt cotton seed is adequate for only about 100,000 acres, opening a fertile ground for black
         market.   This also promotes sale of clandestine Bt seed and spurious seed.   It is the
         responsibility of the Governments to prevent the farmers from being taken for a ride.

i) Public education:
Most opposition to products of biotechnology stems from sheer ignorance or malice rooted in a hidden agenda.   Many stakeholders are in the dark.   The GEAC have actually directed MAHYCO to conduct awareness and education programmes for the farmers.   It is high time that the scientists involved in the development of GM products and the product generators like Monsanto and MAHYCO, who have been silent all the while, came forward to promote awareness and educate the public and the farmers on the benefits and risks of GM crops.   At least they can support organisations that can do the job for them.   The Central and State Governments should assume the role of leaders in creating public awareness about biotechnology.   So far they did precious little about it.
Bacillus thuringiensis, a universally occurring soil bacterium, was discovered a hundred years ago.   It has been in use as a spray pesticide for over 60 years.   A related species, Bacillus kurstaki, was intentionally sprayed from air-craft over Auckland (New Zealand) to eradicate the White-spotted Tussock moth and over Ontario (Canada), to eradicate the Asian Gypsy moth, some five or six years ago, and no untoward effects on human or other populations or the environment have been reported.   The claim that GM crops (including Bt crops) become aggressive weeds was disproved by a ten-year study in Cambridge, last year.   Bt crops are the products of a refined technology that facilitates picking out of just the gene that is responsible for the pesticidal action, a practice far safer than putting the whole bacterial (or other ) genome into the crop plant.

In conclusion, the road ahead for GM crops in India is certainly bound to be quite rough, but hopefully the approval of Bt cotton by the GEAC would augur well for other GM crops in India.