"Strong Objection to GM Mustard" - Letter to Sh. Prakash Javadekar

To:

Shri Prakash Javadekar,                                                                                               3^rd February, 2016

Minister for Environment, Forests & Climate Change,

Government of India,

New Delhi

Dear Shri Prakash Javadekar Ji,

Sub: Strong objection against, and deep concerns with regard to the secretive and hurried processing of GM mustard “environmental release” application and possible approval of GM mustard

From the media reports it has been brought to our notice that Ministry of Environment, Forests and Climate Change is convening a meeting on February 5^th 2016 for considering the commercial approval and cultivation of its transgenic mustard hybrid called DMH11. This genetically modified, hybrid mustard, Dhara Mustard Hybrid-11 (DMH-11) has been developed by the Centre for Genetic Manipulation of Crop Plants (CGMCP) of the Delhi University and though funded initially by NDDB (National Dairy Development Board) reports now confirm that even NDDB seems to have distanced itself from this initiative. We understand that this GM mustard contains three alien bacterial genes, namely bar, barstar and barnase, which are to induce male sterility in the plant and later to restore fertility, in addition to a third gene that is a marker gene which also makes the plant herbicide tolerant. There are numerous problems  associated with this GM crop on counts of safety of technology, the secrecy and lack of transparency in decision-making, and the risks involved on account of human health, environmental safety and farmer livelihoods. Further, this GM mustard has been developed using Genetic Use Restriction Technology (GURT), which induces male sterility in the plant. Indian laws like the PPVFRA (Protection of Plant Varieties and Farmers Rights Act) disallow GURT.

While the genetic modification is ostensibly to increase productivity by creating a hybrid, it is worth noting that non-GM hybrids exist in the market; more importantly, other agronomy based practices exist to improve yields significantly and there is no need to resort to such a risky and irreversible option. Therefore, without having a need for such a transgenic option, we are trying to unleash an unaccountable and irreversible experiment on the country.

The use of a herbicide tolerant gene as a marker potentially allows for the back door entry of herbicide tolerant crops in India.  A Technical Expert Committee (TEC) of scientists, appointed by the Supreme Court, had expressly recommended not to introduce HT crops in India. Mustard, as you are aware, is a very significant oil seed, food and forage crop. It forms an important source of income for farmers through food and also through honey, an important secondary source of income. With the introduction of GM mustard, honey production and bee populations themselves will be jeopardized.

India is the centre of diversity for mustard and as you aware has immense use even in Ayurveda. 

The Parliamentary Standing Committee and the Supreme Court-appointed TEC had specified that no genetic modification should be allowed in the case of such plants, to prevent contamination of the germplasm and gene pool. Introduction of GM mustard in villages will certainly lead to contamination of non-modified mustard varieties thereby harming the vast diversity that is our food insurance.

One of the most disturbing aspects of the whole process with regard to GM mustard biosafety data, field trials and the regulatory approvals is the shroud of secrecy around it. Orders from the Supreme Court (in relation to the PIL related to GM crops) have clearly mandated that all biosafety data of GM crops should be pro-actively shared in the public domain. However, the regulatory process, instead of becoming more transparent, has been made completely opaque with biosafety data being refused even in response to RTI queries. This raises the important question about the regulatory process itself, about its integrity, and in is solely seen serving the interest of global seed and chemical manufacturers at expense of Indian ecology and farmers.

It is also seen that the Supreme Court has just heard a Contempt Petition for the regulators violating some basic Orders of the court in the past related to scientific, bio-safe, transparent and independent regulation, and notices have been served to the Government regulators on the same. At such a juncture, it is indeed a matter of concern that the GEAC meeting is being scheduled on the 5^th of February, ignoring all developments.

NDA government has repeatedly asserted “Transparency & Accountability” as major “pivots” of its governance policy and these are ever seen to be grossly violated in letter and spirit. Not expanding the importance of “Contempt”, which the government seems to be taking casually and ignoring at its own peril, the permeation of vested interests driving these decisions and abject capitulation by the government to “serve” this interest is visibly alarming. The NDA regime is continuously seen making decisions which are Anti Farmer, Anti Poor and Anti Ecology and Environment and resultantly the image of government and the tall promises which seemingly follow, squarely appear shallow with no intention of holding them to see through the actual intent.

The Center’s insistence in pushing this decision shall be in defiance of wishes of states which don’t want GMO’s in general and this GM Mustard in particular. This also is a breach upon the “basic features” of the “Federal Structure” and is a departure from constitutional probity which this government has come to be identified with through several “unilateral” decisions, as was seen during the Land Acquisition Ordinance, sans applying any merit of wisdom on such sensitive issues.

We also would like to remind you that your party in your election manifesto mentioned that “GMO would not be allowed unless there has been a strenuous evaluation on the aspects which could be detrimental to the farmers, the community and more specifically to the environment and the ecology”. Needless to mention that the processing of this GM mustard application, conducted in such secrecy is neither responsible to science nor responsive to society.

Please also recall that the Prime Minister very recently announced in Sikkim a comprehensive initiative towards Organic Farming and called for an active governance and policy mechanism by all stakeholders to promote organic farm practices and called out this initiative as “The Sikkim Declaration”. As you know, organic farming prohibits the use of GMOs.

Given all the above, we urge you to kindly intervene in this matter, and ensure that the regulators do not proceed on this GM mustard commercialization application, especially given that lasting alternatives exist, for improving mustard yields.

Thank you,

KN Govindacharya

Abhishek Joshi

New Delhi

K.N.Govindacharya

kngovindacharya@yahoo.com

Twitter : @kgovindacharya

Abhishek Joshi

abhishek.ar.joshi@gmail.com

Twitter : @abhjoshi