OneWorld.net (U.S.)

April 25, 2005

To, Shri Suresh Chandra Chairperson, Genetic Engineering Approval Committee Ministry of Environment & Forests Paryawaran Bhawan, CGO Complex New Delhi

Dear Shri Suresh Chandra

Greetings! Centre for Sustainable Agriculture [CSA] and Gene Campaign, both of which were present briefly in the past two GEAC meetings, would like to raise some process-related issues with the GEAC on the way decisions are made about GE crops in this country and our objection to it.

CSA had formally sent a request by email and fax on 24th February requesting an audience with you for a delegation to have a discussion on Bt Cotton performance in the country. It was only in the afternoon of March 3rd that GEAC contacted CSA in Hyderabad inviting us for a 10-minute presentation on the 4th. In spite of our repeated request that we would need some notice before we could meet you since we are a Hyderabad-based organisation, we received the invitation only at the last minute. We, however, decided to use the opportunity to put forth our views.

The 10-minute slot promised to CSA was cut down to 5 minutes after we entered the GEAC meeting room. It was a one-sided presentation where we shared our views and findings on Bt Cotton as well as the way GEAC functions. There were no questions or discussions and everything was perfunctory. After we came out of the meeting, one of the GEAC members informed us that "this is not normally done" and that the GEAC was doing us a favour by allowing us to make a presentation. She even refused to share her identity with us saying that it is confidential!

Similarly, the interaction with Gene Campaign was a one-sided affair. There was no response to questions raised by Gene Campaign on whether or not the GEAC would take on board suggestions made by the civil society groups who had been invited to make presentations before it. The GEAC was not willing to commit either on whether it would conduct a review of the past performance of the Monsanto -Mahyco Bt cotton, as Gene Campaign, CSA and others have been demanding, or whether it had any plans to take action against the rapid spread of illegal Bt cotton varieties. The GEAC also refused to commit itself to taking any action against the violation of the government rules according to which farmers must plant 20% of ordinary cotton around Bt cotton and which most farmers do not do. In response to repeated questioning by Gene Campaign, the Chairman of the GEAC stated that "The government is not answerable to NGOs"

The minutes that were put up of the 52nd GEAC meeting on the MoEF website expectably did not have any points from the presentation CSA had made and the objections and concerns raised. It however has detailed responses from the Bt Cotton companies on some questions raised by the GEAC members. The minutes of the 53rd meeting are not available on the website yet.

From your actions it would appear that your invitation to NGOs is an expediency you resort to, to be able to say there have been consultations with civil society. We would like to look at these as not consultations but a hoax perpetrated by the GEAC in an attempt to silence criticism against its secretive and non-transparent functioning.

Both Gene Campaign and Centre for Sustainable Agriculture have well qualified people from various fields of agriculture including Plant Breeding, Genetics, Entomology, Plant Pathology, Extension etc. and have long years of credible and successful experience of working with farmers in the country and of establishing sustainable alternatives. The Boards of these organisations have a veritable line up of eminent people who have contributed to agriculture in the country. The organisations have also documented the experience of Bt Cotton in different locations and have interacted with hundreds of Bt Cotton farmers in these places during the past three years and earlier to that. Those of us working with poor farmers in this country, see GE in agriculture as a matter that is closely connected with farmers' livelihoods and survival and hence requiring utmost caution in its implementation.

Elsewhere in the world, studies done by independent organisations as well as their views are taken on board during decision-making on GM technology. The public has been engaged in GE-related debates in Europe through a variety of innovative tools including Citizens' Juries and Public Hearings. In the UK the government had funded a yearlong debate on GM crops termed 'GM Nation'. Freedom of Information has been used in numerous ways in many countries including the US, where the process of conducting risk assessment is a public exercise. Moreover, the Cartagena Protocol on Biosafety mandates public participation in decision making on GMOs and India is a signatory to the Protocol. Your refusal to include the public in decision-making on GMOs constitutes violation of an international agreement.

In India both the public and private sector engaged in GE research and commercialisation display an astonishing arrogance and behave as if independent agencies have nothing to contribute to the debate, discussion, monitoring and decision-making. The GEAC participates in this web of secrecy and joins the industry and the public sector in keeping the people out of any discussions. No reports are shared with the public on such important matters like GMOs. The basis on which decisions are being made is extremely unclear and therefore questionable. The public's Right to Know is being violated again and again. It is objectionable that the GEAC refuses in this manner to be accountable to the people and prompts the question: what are you hiding if there is nothing to hide?

NGOs in this country have always been on the forefront of people-centred development alternatives and have successfully influenced government policies and programmes in favour of people. The due role of NGOs has been recognised by agencies the world over, including UN bodies, bilateral and multilateral development agencies and by the governments in India.

In this context, we demand that the GEAC should

- create time and space to dialogue with civil society groups interested in GMOs and agriculture, before decisions are taken - this dialogue should be truly participatory and not the farce that we have seen recently - put up all the objections and concerns raised by stakeholders like us, and your responses to the same, on your website - share all information being presented by other stakeholders like ICAR bodies, the companies involved etc., through the website and other means and put this out for public scrutiny - take on board the findings of various independent agencies who work closely with farmers - if an advertising and market research firm can do studies for the companies involved and the findings are then submitted to the GEAC, there is no reason why credible findings from independent agencies are not accepted by the GEAC as evidence - provide the test data and rationale for decisions on the website

Unless all these issues are addressed, the credibility of the GEAC remains questionable. As the body which gives approvals for large scale trials and commercial cultivation, GEAC is ultimately accountable to the farmers and the people of this country.

Sd/- G V Ramanjaneyulu Sd/- Suman Sahai Executive Director Director Centre for Sustainable Agriculture Gene Campaign 12-13-445, Street No 1 J 235/A, Lane W 15 C, Sainik Farms Tarnaka, Secunderabad 500 017 Khanpur, New Delhi 110 062

Source: The Gene Campaign