| The
Cotton Controversy
Jennifer Ifft
Abstract
Bt Cotton has been one of the widely adopted and effective transgenic
crops grown worldwide. Bt cotton holds great potential for India,
but so far extreme environmental groups and inefficient regulation
have stopped the introduction of Bt cotton. The All India Biotechnology
Association's Report on the Indian Biotechnology bravely sets forward
the flaws of biotechnology regulation in India and is an essential
read for anyone involved or interested in the Bt cotton debate.
The environmental concerns regarding not only Bt cotton but also
biotechnology do deserve consideration. Bt cotton has been shown
to have some manageable affects on the environment. A risk/benefit
approach to biotechnology is preferable. If the risks of Bt cotton
can be managed and the benefits are significant, farmers should
be able use to this crop. The economic benefits should be the sole
concern of farmers, not the state. This paper is written with the
viewpoint that Indian farmers are capable of learning to use new
technologies and should be allowed to modernize and prosper. The
approval process for Bt cotton has been shrouded by mystery and
created great controversy. The recommendations by the AIBA in regards
to biotechnology regulation are substantiated by what has happened
with Bt cotton. If reforms are implemented, a greater emphasis can
be placed on the liability of companies introducing biotechnology
products.
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The first annual meeting of the "Stop Mules" campaign will be held
at 8:42 at the house of Dr. V Scammathon, a certified "natural animal"
breeder. The program presented will be "How mules will destroy the
genetic diversity of horses and donkeys." The forced breeding of
horses and donkeys by evil corporations (E Cs) will certainly bring
an end to rich variety of species of horses and donkeys. The evil
corporations will gradually gain control over all horses and donkeys
to breed mules, leaving poor farmers in a situation where they have
no choice but to purchase mules from the E C. All benefits from
the mules will go to the E C, and poor farmers will be more destitute
than ever. This must be stopped! All those who believe in "natural
animal" breeding are encouraged to come out and stand up for the
rights of poor farmers everywhere.
Fortunately, the "Stop Mules" campaign failed after the first annual
meeting. The staunchest supporters of this campaign seem to have
moved on to campaign against Bt cotton in India. Bt stands for bacillus
thuringiensis, a bacterium that occurs naturally in the soil and
produces a protein toxic to Lepidoptern insect pests. Lepidoptern
insect pests include some of the worst cotton pests. Through biotechnology,
scientists have inserted a gene found in Bt into cotton genes. Bt
cotton naturally produces a protein toxic to some cotton pests.
With much controversy, Bt cotton has been widely adopted in different
countries worldwide. In 2000 Bt cotton was the seventh most widely
grown transgenic crop in the world making up 3% of the total transgenic
crops and was grown on 1.5 million hectares. Other crops, including
corn and potato, have also been genetically engineered to produce
Bt toxins. All crops producing Bt toxins make up 27% of the total
transgenic crops grown by covering 11.5 million hectares.
Logic has been defied as Bt cotton has moved through the complicated
machinery of approval of transgenic crops in India. Bureaucrats,
environmentalists, and industrialists have debated the dangers of
Bt cotton while those most affected have been left to battle the
elements. The Indian Bt cotton story tells of the irrationality
of unfree environmental organizations and of the complicated committee/
permit/ license maze of approval for transgenic crops in India.
The appropriate role of government in biotechnology regulation is
highly contested. The experience of India with Bt cotton sheds light
on this controversial issue and can give direction for future policy.
Technology rarely doesn't have some kind of adverse impact, yet
people continue innovating and accepting the new challenges that
come with new freedoms. The environmental groups fighting BT cotton
most likely sit in an office in Delhi cooled by an air conditioner
that spews some kind of harmful matter into the atmosphere. If society
abandoned all technologies that involved some kind of risk, everyone
would have to move to the forest and survive off the nuts and berries.
Nevertheless, society must be responsible for the technologies that
it develops.
A sad situation
Hardship and inefficiencies characterize cotton farming in India.
India has the largest area of cotton grown in the world but is only
the third largest producer in the world, after China and the United
States of America. Cotton is grown largely throughout India, except
in the eastern region. The yield of cotton in India is significantly
less than the world average. Yields of 943 kg/ha in China, 769 kg/ha
in the USA, and 552 kg/ha in Pakistan overshadow India's average
yield of 321 kg/ha. Textiles are very important to India's economy
and account for 30 percent of India's total export volume. 58% of
the insecticides used in India are used for cotton. 60% of the insecticides
used on cotton are to control the "bollworm complex,"
which happens to be the major group of insects controlled by Bt.
Cotton crop failures have added to the misery of farmers in India.
Major insect pests have constantly developed resistance to pesticides
due to indiscriminate use. Farmers have been known to use a mix
of several pesticides, referred to as a "pesticide cocktail" and
spray up to thirty times per season. Yearly it is estimated that
344 million dollars are spent on cotton pesticides. Bollworm (the
target pest of Bt) control is estimated to cost farmers 235 million
dollars yearly. In 1998, 500 cotton farmers were officially reported
to have committed suicide due to crop failures and high debt.
Cotton farmers in India do need more technology and innovative
techniques to improve their situation, whether "modern" or "traditional."
Bt cotton could improve cotton farming, but is not the only "answer."
A recent "Cotton Technology Mission" has been launched by the Ministry
of Textile to improve research and production of cotton (among other
objectives) to the tune of Rs. 593 crore. Interestingly, 78% of
the fund is earmarked for the spread of technology that has yet
to be developed. If cotton farmers are to prosper, they must be
allowed to choose among new technologies and innovations. No matter
how "ignorant" or "illiterate" a farmer may be, he still deserves
the opportunity to improve his operations.
Bt cotton in India
The Maharastra Hybrid Seeds Company (Mahyco) imported Bt cottonseeds
into India in 1996. The seeds were imported from Monsanto Enterprise,
which own a 26% share in Mahyco. After being crossed with Indian
cotton varieties, Mahyco conducted greenhouse and small-scale field
trials on the newly developed varieties through 1999. In 2000, the
first large-scale field trials were approved two months after planting
time. In 2001, Mahyco was instructed to undertake one more year
of large-scale field trials before commercialization of Bt cotton
could be considered.
The public sector has also been developing Bt cotton since as early
as 1994. A project funded by the Department of Biotechnology (Ministry
of Science and Technology), based in the National Botanical Research
Institute ended in 1998 with no Bt cotton variety. Five crore are
estimated to be spent on this project, in comparison to the two
crore offered by Monsanto to Indian Council of Agricultural Research
in the mid 1990's for this technology. Two Bt cotton varieties were
developed at the Central Institute of Cotton Research at Nagpur,
without the knowledge of the Department of Biotechnology, which
is embodied with legal powers to cover such developments. These
varieties developed at the CICR were not developed further due to
agronomic problems. Currently, the public sector has two projects
to develop Bt cotton. One project is funded by the National Agriculture
Technology Fund (World Bank) and the research is being conducted
by the ICAR. Another project using "slightly different" Bt technology
is being conducted at the University of Delhi, South Campus.
The results of the Bt cotton field trials have not been fully made
public, despite protest by environmental NGOs. Mahyco could make
this data public, but has strangely remained removed from the debate.
However, the results of the trials have been reported to be positive,
both by agronomic and environmental measures. The field trials have
shown that Bt cotton provides control for the main caterpillar pests:
the American Bollworm, the Spiny Bollworm, the Spotted Bollworm,
and the Pink Bollworm. Chemical sprays were less used, decreasing
to 0-2 times from 9-12 times. Bt cotton was also shown to not be
compatible to out-cross with any related plants in the Indian environment.
Overall Bt cotton was reported to have no significantly different
risks for the environment as compared to non-Bt cotton.
Regulatory confusion
Any organization/ company that wishes to develop a transgenic crop
must first form an Institutional Biosafety Committee. The IBSC has
a Department of Biotechnology Representative and can approve low
risk contained research and must report to the Review Committee
on Genetic Manipulation. The RCGM approves all small-scale trials
of transgenic crops and power to monitor the trials. Recently, a
Monitoring-cum-Evaluation Committee has been appointed by the RCGM
to visit and evaluate standards at trial sites. The State Biotechnology
Coordination Committee and the District Level Committee also have
roles in monitoring transgenic crops at the corresponding levels.
The Genetic Engineering Approval Committee is the ultimate authority
that decides whether or not a transgenic crop can be commercialized
or if large scale field trials can be conducted (over 20 acres).
The GOI is often criticized for the arbitrary and confusing process
of GMO approval, which shouldn't be a surprise as the inefficiency
of bureaucracy is no great secret. The All India Biotechnology Association
(AIBA) released a damning report in November of 2000 blaming the
complicated bureaucratic process for the failure of India to adopt
GMOs. Their report bravely covered all the inadequacies of GMO regulation.
Six reasons were listed for this failure:
- Testing and Approval Has A Poor Track Record
- Private And Public Sectors Conflicts Blocks The Former At The
Entry Point
- Mission Overlap: Regulators Are Competitors
- Large public sector funding disfavors private investment
- Prioritization by R&D in public sector is unresponsive to
Market needs
- Sub-critical resource allocation from Lack of focus.
The AIBA report critically clarified the problems of biotechnology
regulation. The progress or lack of progress for BT cotton substantiates
some of these claims. Two committees have made the majority of the
decisions regarding BT cotton approval, the Review Committee
on Genetic Manipulation and the Genetic Engineering Approval
Committee.
The RCGM approved all import, research, and field trials for Bt
cotton up to the year 2000. The GEAC came into the picture in 2000,
when it finally approved Bt cotton for large-scale field trails
two months after regular planting time. The GEAC decided this year
that Bt cotton would not be commercialized and that one more year
of trials was necessary. Although the RCGM gave the go-ahead for
Bt cotton for four years, the final decision is now in the hands
of the GEAC. The waste in public resources is apparent, as the committee
members of the GEAC would have to acquaint themselves with trial
results and related information already well reviewed by the RCGM.
The makeup of both committees is similar in some respects. The
RCGM has a DBT representative, the GEAC is co-chaired by a DBT representative.
The RCGM has an Indian Council of Agricultural Research (ICAR) Representative,
while the one of the expert members of the GEAC is the Director
General of the ICAR. A similar make-up exists in regards to the
Indian Council of Medical Research and the Council of Scientific
Research. The ICAR therefore is partially regulating its own development
of Bt cotton along with the Bt cotton variety of Mahyco.
The Research Foundation for Science, Technology, and Ecology has
a pending court case against the Department of Biotechnology (Ministry
of Science and Technology), the Ministry of Environment and Forests,
the Ministry of Agriculture, Monsanto-Mahyco Biotech (India) Private
Limited, and M/s. Maharashtra Hybrid Seeds Company Limited (Mahyco).
The court case is mainly based upon technicalities in the laws governing
biotechnology regulation and is not being taken seriously by government
or industry. Interestingly, the RFSTE has documented instances where
trial fields were planted before official approval was given. Could
Mahyco have known that approval would be given? The significance
of the court case so far has been that it has slowed the approval
process and shed light upon the technical problems in the laws related
to biotechnology.
Interestingly, both sides on the biotechnology debate have criticized
the regulation of GMOs on a few counts. Lack of transparency and
no means to appeal decisions of the RCGM and GEAC are common complaints.
The distinction between small-scale and large-scale trials has drawn
criticism. The RFSTE court case was partially based upon an unclear
distinction between small and large-scale trials. The AIBA Report
on the Indian Biotechnology Industry also called for end to the
distinction between small and large-scale trials. Such a vague difference
in the regulatory process could hardly be anything but arbitrary
and creates overlaps in regulation. The common consensus on certain
aspects of regulation by opposing sides of the biotechnology debate
indicates the drastic need for changes.
A recent study indicates that India has been promotional of GM
crops through investment in public research, while being precautionary
on biosafety aspects. In trade and intellectual property rights
India has had a record of a preventive approach. Public research
can play an important role in developing crops targeted towards
poorer farmers that have so far been left out of the "market" for
GM crops. However, the history of spending on research and the experience
of regulation has been quite contradictory. India is shooting itself
in one leg while strengthening the other.
Biotechnology in most countries where it is allowed is regulated
by a number of agencies and committees at a very high cost. In the
United States GMOs are regulated by three agencies and the cost
going through the approval process is estimated to be as high as
two million dollars. Despite the high cost, several GMOs have been
commercialized and more are in the pipeline. One cannot say that
the approval process in India is necessarily more complicated or
expensive than that of other countries, but going by the current
situation the approval process has definitely been ineffective.
The All India Biotechnology Association and the Confederation of
Indian Industry have called for a single-window clearance for transgenic
crops. Simplified regulation would be an improvement and speed the
implementation of biotechnology in India. The regulation could be
simplified without changing existing laws.
An alternative to the regulatory approach to transgenic crops is
a liability-based approach. When a company has to prove to a committee
or agency that a product is safe, the approving body isresponsibile
for its decisions. Under a liability-based approach without government
approval or regulation, anything that would go wrong with the GMO
would essentially be the full responsibility of the company that
introduced the product. Under the current system, a company produces
a GMO and creates data so the regulatory body can determine whether
or not the product is safe. Start-up costs for biotechnology development
would be lower, increasing the possibility for more competition.
India may not have the institutions to handle this kind of approach
to biotechnology, but it also has not proven that the regulatory
system can keep pace with the rapidly growing biotechnology industry.
Environmental concerns
The environmental impact of Bt cotton or other Bt crops is not
yet fully known but has been predicted by scientists as both sustainable
and highly detrimental. Strong objections to Bt cotton have been
based on projected negative impacts on the environment. Generally,
those opposed to Bt cotton tend to be opposed to biotechnology.
The environmental concerns raised do deserve serious consideration
and ACTION.
Development of resistance by insects to Bt is of great concern
to farmers, environmentalists, industry, and policy-makers. It is
a well-established fact that insects can and will (under certain
circumstances) develop resistance to Bt. In the United States, the
Environmental Protection Agency has mandated that all farmers use
"refugia" to prevent/delay the development of resistance. Several
options are available and proven to prevent and/or delay resistance.
The refugia option mandated by the EPA in the USA involves planting
non-Bt cotton as a certain percentage of Bt-cotton. Insects without
resistance are supposed to be allowed to survive in the non-Bt cotton
and breed with insects that may have developed resistance. The strategy
of using refugia to delay resistance has been considered highly
successful in parts of the USA, but still resistance in some cases
has been considered to have slightly increased. Non-compliance with
refugia requirements of farmers in the USA is reported to be from
six to nine percent.
Another option for resistance management is the inclusion of more
than one kind of Bt toxin or a different toxin (non-Bt). Developing
Bt cotton to have more than one active Bt toxin is referred to as
'gene pyramiding.' There are over fifty known strains of the Bt
toxin and each attaches to different receptors in the stomach of
the targeted insects. The ICAR is utilizing this method of gene
pyramiding by incorporating two strains of BT into the variety being
developing through the NATP. Mahyco's Bt cotton variety does not
use this method.
Integrated Pest Management can be used to delay the resistance
of insects to Bt cotton indefinitely. IPM is already used in parts
of India and involves careful use of a package of different practices.
Designed to minimize chemical use, IPM involves the use of a variety
of pest prevention techniques. These techniques include fungal viruses,
botanical pesticides, and natural predators. Bt cotton can be an
integral part of IPM, as it attacks the major cotton pests.
Many aspects of IPM would work well with use of Bt cotton that
were not possible with conventional pesticide practices. A strong
possibility exists for Bt cotton and other insect-resistant cotton
varieties to be the "foundation" for more sustainable and environmentally
friendly IPM. If built in resistance can control the major pest,
less significant pests can be controlled through IPM techniques
that did not work with conventional pesticide use. This IPM approach
towards Bt cotton originates from Australia and differs significantly
from the implementation of Bt cotton in North America. India farmers
have the liberty of evaluating different approaches to using Bt
cotton that already have been implemented in other countries.
Resistance management is the most serious and pressing environmental
issue for Bt cotton, but other less likely possibilities for environmental
problems do exist. Bt supposedly can be harmful to beneficial insects,
but has proved to be much better than conventional pesticide in
this respect. Mahyco's Bt cotton does have an antibiotic resistant
marker gene but the chance of this gene being passed on is almost
nil. Bt cotton genes could also be passed on to weedy relatives,
but this phenomenon is a part of the testing for approval and considered
not to be a threat. In countries where it has been approved, Bt
cotton has gone through rigorous testing.
Experiences of other countries
Opponents of biotechnology say that India cannot pursue biotechnology
simply because it has worked for another country. However, India
has the advantage of being able to analyze the failures and triumphs
of other countries in biotechnology and apply this knowledge to
the unique challenges it faces.
China's experience with Bt cotton is particularly insightful for
India. Bt cotton was first commercially grown in China in 1998,
although research began in 1991. This time span is comparable with
the US, as Bt cotton had its first field trials in 1989 and was
first commercially used in 1995. China is similar to India in the
respect that it has many small farmers and scattered land holdings.
Bt cotton performed well on the environmental scorecard. Pesticide
use was substantially reduced by around 15,000 tons. The reduction
in pesticides did not only have positive ecological effects; it
also improved farmers' health. In 1997 Bt cotton was found to improve
the biodiversity of insects. 31 insect species (23 beneficial) were
found in Bt cotton, while only 14 insect species (5 being beneficial)
were found on non-Bt cotton treated with conventional pesticides.
Little insect resistance developed due to the scattered plots, small
farmers and available alternative hosts. Resistance could also have
been delayed due to an extra insecticidal gene being present in
the Chinese Bt cotton variety.
Bt cotton was found to be higher yielding on an overall basis than
non-Bt varieties, with significantly lower costs. Bt cotton was
also found to be clearly more profitable for farmers, especially
smaller farmers. The study found that farmers with smaller farms
and smaller incomes had constantly been enjoying larger increases
in net income than the larger farmers.
Farmers in South Africa have also had considerable success with
Bt cotton. Large-scale farmers received benefits of $112 per acre,
while small-scale farmers received benefits of $165 per acre. The
small-scale farmers reduced insecticide sprays by 6 and increased
yield by 26%, compared to large-scale farmers who reduced insecticide
sprays by 4 and increased yield by 23%.
In the United States, Bt cotton use increased from 12% of total
acres in 1996 to 39% of total acres in 2000. Bt cotton has caused
yield increased, insecticide reduction, and cost savings. In 1999
it is estimated that 260 million pounds of extra cotton was produced
and revenues increased by 99 million dollars due to Bt cotton use.
Average insecticide applications went from ten to two to zero due
to Bt cotton use, with total reduction estimated to 2.7 million
pounds in 1999. Farmers hold ultimate power over whether Bt cotton
is used or not. The increasing use of Bt cotton in the USA indicates
that farmers have seen enough benefits from Bt cotton to increase
adoption.
Environmentalists and anti-globalization proponents may be able
to dismiss the success of BT cotton worldwide as not applicable
to India, but the millions of small and marginal farmers in India
do not have this liberty. They are at the mercy of a committee to
decide whether or not they can at least try out a crop that may
(or may not) make a huge difference for their farming operations.
Pharmaceutical companies often test a drug that is successful in
one country in another country before they introduce the drug in
the other country. They know that because the drug has been successful
in one country, it also has the potential to be successful in other
countries. The impact of Bt cotton in India would obviously not
be the same as that of other countries but studies from other countries
do give are an important indication of projected benefits.
Bt maize
Bt maize has been adopted and has been shown to be beneficial.
Bt maize was grown on 7.3 million hectares in 2000. Bt maize made
up 20% of the total transgenic crops grown in the world and 19%
of the total corn acres grown in the United States in 2000. From
1997 to 1999 the net gain over the three years in revenues was 20
million dollars. Bt maize targets the European Corn Borer, which
is documented to have different infestation levels yearly. In the
long run Bt corn is projected to be beneficial to producers, despite
varying levels of infestation. Environmentally, Bt corn has been
determined to be relatively benign and the risks are quite manageable.
The FDA has approved most Bt Field corn varieties for human and
animal consumption after extensive testing. The EPA has granted
temporary approval and studies are still being done on Bt corn.
From committee to farmer
The plight of Indian cotton farmers is well documented. Several
suicides have occurred due to the crop failures and mounting debts
of cotton farmers. BT cotton may be able to improve the livelihood
of Indian farmers. However, 70% of small and marginal farmers do
have access to credit and extension facility. BT cotton is believed
to be most effective and environmentally friendly when used as a
part of Integrated Pest Management. IPM is more complicated than
a "recipe" for applying pesticides and farmers would have to be
educated. Taxpayer's money would be better spent financing farmers'
education than financing committees to deliberate the value of Bt.
A recent study on IPM in a village in Maharashtra indicates that
IPM could be an economic and effective alternative to conventional
pesticide use. However, difficulties are projected in the areas
of farmer's education and production of bio-pesticides. Removing
subsidies on chemical pesticides is one of the suggestions to increase
implementation of IPM, along with adequate education/publicity.
BT is here to stay
Bt cotton and other Bt crops are increasingly becoming a large
part of modern agriculture. Challenges may arise and will have to
be addressed. Bt cotton is one transgenic crop that holds great
promise for India but has yet to be commercially used. A committee
in Delhi has made a decision to delay the introduction of something
that could be very beneficial to farmers. Members of the GEAC would
receive a guaranteed paycheck but Indian farmers do not have this
privilege. Indian farmers should have the chance to try Bt cotton
and see if it works for them.
Bt cotton and other transgenic crops have great potential in India.
Farmers are best left to decide if the crop is economical, as they
should be under no pressure to continue producing a crop that does
not work for them. For environmental concerns, the AIBA and CII
recommends that in the proposed single-window clearance systems,
the leading committee should be able to put a moratorium on use
of a potentially dangerous GMO. Otherwise companies introducing
transgenic crops, such as Bt cotton, should have to go through the
minimum level of bureaucracy and accept the maximum level of liability.
Until the complexities of biotechnology regulation are addressed
in India, farmers will go on facing the same hardships as before
and continue waiting for committee approval.
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