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  An Open Letter To The New Minister Of Environment And ForestsHonorable Mr. Jairam Ramesh June 25, 2009
Minister of State
Ministry of Environment and Forests
Paryavaran Bhavan
CGO Complex
Lodi Estate
New Delhi

Dear Mr. Ramesh:
       At the outset, congratulations are in order for your appointment as the new Minister of State to the Ministry of Environment and Forests (MoEF), truly a daunting challenge at a time climate change is threatening worlds’ natural resources, agriculture and the environment.  India is one of the countries whose natural resource base and biodiversity are under severe threat due to population pressure.  India is expected to be one of the worst sufferers of climate change and your ministry needs a dynamic and visionary leadership that will steer India’s environmental protection programs to last beyond next few generations.  We all hope that you will step up to challenges of your new responsibilities and do right things by the country. 

No one needs to tell you how bad is India’s environmental degradation is all around, and that too at a time when it is poised to launch ambitious development and industrialization plans.  It is inescapable that sustainable environmental protection must be at the core “mantra” of all development projects in the country, and your ministry will be playing the all important gate keeper’s role for providing environmental clearances based on the Environmental Protection Act (EPA 1986).  Like all Government of India’s good intentioned policies, your ministry is no exception when it comes to implementing high standards for environmental clearances based on rigorous Environmental Impact Assessments (EIA).  There is a general impression that EIA process has been severely compromised at all levels in your ministry.  There is really no point in passing new laws and regulations, if the officers of the department do not get political support from their minister to enforce them.  If you instill transparency in your ministry’s governance, accountability will set in automatically, and many things will be set right by themselves without having to do too much.    

Apparently, the watering down of the EIA process began in the early 90s when India launched its economic liberalization program that gave a tremendous boost to economic growth that has resulted in realistic and measurable poverty reduction.  However, environmental standards of many of these investment projects have suffered.  You have an onerous responsibility to assure environmentally sustainable economic development and at the same time mitigate environmental impacts through comprehensive and through EIA. Unfortunately, there are not very many real EIA experts, which is one of the reasons, shoddy EIAs prepared by the self styled experts with questionable credentials and credibility have been accepted in a hurry as a mere formality.  Environmental protection and development need not be mutually exclusive.  India can achieve desired economic growth and at the same time protect degrading fragile environment and conserve its natural resources for the long term sustainability of its economic development.  Something must be done to build this capacity through our university systems, many of which have very poor quality environmental science degree programs.  India needs a home grown cadre of EIA experts in all fields and that must be nurtured by your ministry.

It delights the scientific community and purveyors of technology that a supporter of modern biotechnology is now in charge of the Genetic Engineering Approval Committee (GEAC) in your ministry that is the home to the statutory body to approve products of modern biotechnology.  We look forward to your enthusiastic support to the GEAC, and usher in a new science and technology era in Indian agriculture.  Many of us still remember your regular columns in India Today, and your enthusiastic support for modern biotechnology and genetically modified (GM) crops in your speeches both within India and outside.  However, we were a bit disappointed when soon after assuming the office; you made a flippant remark about your personal distaste for Bt brinjal.  We recognize that you are entitled to your personal likes and dislikes just like anyone of us; however, you’re uncalled for flippant remark will be exploited by the anti-GM lobby and will bring pressure on the GEAC to not approve the GM crop in question.  With one thoughtless personal comment, you have undermined a decision making process of your own ministry’s regulatory authority GEAC without checking facts.  Surprise, surprise, anti-GM activists at a GM foods heath conference in Delhi last week, have already quoted you with the hope of stopping GM foods in the country.

The anti-GM lobby the country constantly criticizes and attacks the GEAC’s approval process for not being rigorous in its review of GM crops, and not enforcing compliance of rules and regulations.  There is definitely some truth to the charge that the entire framework of regulations are  not in place in every state in the country, and therefore, your ministry may not be implementing rules and regulations in its entirety.  We now hear that unauthorized herbicide tolerant (HT) cotton and maize are being grown stealthily in Gujarat.  This déjà vu all over again!!!  This does not bode well for the future of GM crops in the country, and more importantly the GEAC will come under more attacks by the anti-GM lobby, and your ministry will lose in teh Supreme Court.  Scrupulous adherence to your own written rules and regulations must be enforced in your ministry.  Any infraction in implementation will attract the wrath of the court, and that will be detrimental to the development of modern biotechnology in the country. 

Arguing strictly on the basis of scientific reasoning, GEAC has been making proper decisions on GM crops, cries of the anti-GM lobby notwithstanding.  You must know that the anti-GM lobby has not yet met a regulator it likes anywhere in the world.  That is because, almost all regulatory bodies have approved GM crops for cultivation based on scientific review, and not on any other political agenda.  The anti-GM lobby in India won’t stop hectoring GEAC until it stops approval of GM crops.  You should never succumb to this dirty tricks campaign of the anti-GM lobby that are ideologically opposed to modern science and technology that is so critically needed to lift India’s agriculture out of its doldrums.  The anti-GM lobby is spreading false hoods, lies, and canards about GM crops all over the country with ample resources and help from overseas International NGOs (INGOs) and the EU.  Modern biotechnology, just like the information technology is a proven engine for economic growth and development.  Your solemn duty is to ensure its implementation without compromising on its environmental risks and biosafety.  Charges that GM crops will destroy biodiversity, cause “genetic pollution” and “genetic contamination” is one of the most scientifically insidious terms that only scientifically ignoramuses can come up with.  They don’t exist in any text book of genetics.  These terms have been coined by the anti-GM lobby long time ago just to scare the public. You must dismiss them with scientific contempt they deserve.

Another idea that GM rice should not be released in rice cultivation because India is the center of diversity is an unadulterated scientific hogwash.  This question has been examined critically by leading scientific bodies of the world, and has been put to rest.  GM crops do not threaten wild, weedy and ancestral land races of any crop including that of rice in India, simply because India happens to be one of the centers of diversity of rice.  Of late, every NGO working in rural development and agricultural development have made it a fashion to collect some local varieties of one crop or another and bottle them up to show their funders that they are trying to conserve biodiversity, of which they understand precious little.  It is a total falsehood that these NGOs claim that India had more than 3500 paddy varieties that have been lost.  These NGOs don’t know the difference between accessions and varieties or species.  They talk through hat when it comes to biodiversity.  They have no scientific expertise, and know nothing to scientifically characterize germpalsm, which is a sophisticated science today.  National and international organizations with multitude of scientific experts and millions of dollars budget are engaged in proper survey, collection and characterization of germpalsm that is available for all for breeding of improved varieties and hybrids.  Most of these NGOs are clueless as to what they are collecting and what they can do with it, other than to duplicate them and distribute them to few farmers to score publicity. The anti-GM lobby continues to rake up these worn out and clichéd nonsensical points all the time and you must listen only to scientific experts on the GEAC who know better than the collective scientific illiterate wisdom of the anti-GM lobby.  India is home to some of teh best rice experts in the world and none other than Dr. Gurdev Khush can be your best source of information on rice.

GEAC has come under severe attack by the country’s anti-GM lobby made up of a motley crew of environmental activists and NGOs whose sole purpose is to keep India “GMO-free” whatever it means to them.  One thing is for certain, they are using every dirty trick possible to delay and frustrate GEAC from doing its job. It is truly a sad commentary that GEAC, has approved only one Genetically Modified (GM) crop, namely, Bt cotton in almost 8 years.  Many GM crops have been stuck in the regulatory pipeline, not all due to the fault of the GEAC.  There is no doubt that GEACs’ functioning has been hampered because of the anti-GM activism, and also due to the ongoing cases in the Supreme Court. Otherwise, there is no reason why golden rice, Bt rice, Bt cabbage, Bt Okra, male sterile mustard, and many more such GM crops should not have seen the light of the day by now.  India’s biotech regulatory system, like anywhere in the world, is a major stumbling block for the progress of biotechnology.  The result is there for everyone to see.  There is hardly any Indian agbiotech company or a public sector laboratory that has been able to commercialize products of modern biotechnology in agriculture.  It is costing three to five crores of rupees to fulfill the regulatory requirements for GM crops, and most Indian outfits cannot afford it.  That leaves the multi-nationals to dominate the GM seeds market as they are the only ones deep pockets to bring products to the market by meeting the exorbitant regulatory costs.  The silliness of all these is due to the anti-GM lobby constantly demanding needless and unscientific standards for regulatory oversight that only leaves big multi-nationals to afford to meet regulatory costs.  The same anti-GM lobby then complains that GM crops are dominated by multi-nationals.  Is not this a farce? 

If these regulatory requirements were designed to scientifically address genuine biosafety and environmental risks, no one would grudge it.  But, many of the regulatory data requirements are simply based on concocted “fears” whipped up the anti-GM lobby that has nothing to do with biosafety.  The 29 biosafety tests suggested by Dr. Pushpa Bhargava, the “poster boy” biosafety expert of the anti-GM lobby forced on GEAC by the Supreme Court are the most scientifically ridiculous bordering on the insane.  By his own words, it would take another 25 years to complete all such tests, and he wants a moratorium on GM crops until such ridiculous studies are completed.  You must know that this is a well known ploy of the anti-GM lobby around the world to kill GM crops technology.  No purveyor technology can conduct useless safety tests for twenty five years and stay in the business, and that leaves no hope for the India’s public sector.  Perusing Dr. Bhargava’s recommendations for biosafety tests clearly shows that he is clueless about biosafety and knows next to nothing about crop husbandry and agronomy.  GEAC must fight this anti-GMO demagogue’s recommendations and get them dismissed out of the court.  GEAC must summon the best possible scientific experts to critically evaluate Dr. Bhargava’s recommendations, and trash them into a dust bin.
We would like to submit the following for your immediate consideration to make GEAC, a proficient regulatory outfit that will fulfill its obligations to EPA, and at the same time facilitate safe deployment of goods and services of modern biotechnology in agriculture.
  1. The PIL case by Aruna Rodriguez et al in the Supreme Court against GEAC should be dismissed.   Those cases do not have proper legal locus standi and any competent lawyer can take care of them, if he/she does some proper home work with the help of good scientific experts to file a motion in the court.

  2. It is really unfortunate that your ministry’s lawyers have allowed the case to fester so long in the court.  If they had, these cases would have been dismissed long ago. Your ministry lawyers must know that courts all over the world seldom sit in the judgment scientific and technical issues.  They are only concerned with the procedural statutes of environmental laws that affect the workings of GEAC.  If your ministry has failed to follow an established procedure, then only the courts will find fault.  In fact, the supreme court of India is on record of saying that scientific and technical matters must be left to expert committees to deal with, which is what GEAC is supposed to do.  Why then these baseless cases against GEAC in the Supreme Court are allowed to fester is beyond anybody’s comprehension.

  3. Your ministry lawyers must immediately file a motion to get rid of Dr. Pushpa Bhargava from GEAC.  Just last month, he published a commentary on the workings of GEAC in the Journal of Biosciences, an organ of Indian National Academy of Sciences, Bangalore, in which he has found everything wrong with the workings of the GEAC, and has even published an annexure of 29 points (which he has submitted to the court as well) based on which it seems biosafety test must be conducted before granting approvals for GM crops.  Until then, he wants a moratorium on testing of GM crops.  This is one of the most egregious recommendations coming from one of the “has been” scientists of the country.  He has turned into a complete scientific charlatan just to gain cheap publicity in the media.  His recommendations are totally devoid of any scientific merit, and this published paper of Dr. Bhargava must be responded to by a special committee of leading agricultural and biotechnology scientists to expose the true competence of the self-styled biosafety “expert” Dr. Pushpa Bhargava.  Based on this expert committee’s report, your ministry’s lawyer’s must file a motion to show that Dr. Bhargava be removed from the GEAC as he is no expert on biosafety or agriculture or crop husbandry, and therefore, his “expertise” is causing needless obstruction to the smooth functioning of GEAC
  4. At the same time, like most government committees, GEAC is loath to communications with the public.  It is knot known to respond to media queries, and does not see any reason to respond to all sorts of criticisms and comments on its workings, and its decisions.  But, there is what is known as court of public opinion, which is where modern biotech and GM crops are taking beating due to the relentless attack of the anti-biotech lobby of teh country and around the world.  Public have developed a feeling that there is something wrong with modern biotech and GM crops, and therefore they must be stopped.  In teh absence of any countering mechanism by GEAC or the scientific establishment in teh country, repeated lies of the anti-GM lobby become de facto facts, and it will be a Herculean task to undo this kind public relations damage after the fact.

  5. Your ministry’s web site and that of GEAC can receive a huge doze modernization so that it not only looks attractive, but also user friendly.  It looks like any typical government of India web site developed some informatics bureaucracy.  It is not updated properly on a daily basis, and there is no internal search engine on the web site to finds information quickly.  All these can be taken care of by a high school whiz kid these days, but somehow babus of your ministry cannot seem to take care of it.  Please order hiring a competent professional web master and designer who can present a professional image of your ministry, and at the same time usher complete transparency of its workings.  Remember that the anti-GM lobby uses internet so efficiently to disparage and discredit not only your ministry, but the biotechnology itself.  Your ministry must the same tactics to counter them and keep the public informed, and it a simple job and most cost effective as well.  The web site must be updated every night and every bit of information that the public needs to know should be on it in different languages of the country.  This will cut down on multitudes of RTI requests, challenges and counter challenges.

  6. The entire review process and protocol of GM crops applications must be posted on the GEAC web site and anyone should be able to track the status of the review of applications anytime.  All safety data must be posited with due regard to the protection of confidential business information (CBI).  Safety data of any GM crop cannot be justified to be CBI under any circumstance. It is unfortunate that Chief Information Commissioner had to order your minister to release the food safety data to the public, which should have never been protected in the first place.  Your ministry must establish criteria of claiming CBI, and implement it strictly without fear or favor.

  7. It is not clear if GEAC carries out EIA of GM crops before approving them for commercializations.  If they do, those EIAs must be posted in teh web site for public comments before final decision is made.

  8. There is a constant demand by teh anti-GM lobby to include the civil society on GEAC.  This must not be allowed.  GEAC is a statutorily established regulatory body of scientific experts that is duly constituted. There is no place for non-scientific and non-technical people to serve on it.  However, like rest of the public, they too should be allowed an opportunity to comment on the EIA and contribute to the decision making process in writing on a case by case basis.  The anti-GM lobby hankers for a seat on the GEAC just to obstruct and obfuscate and confuse the public about every small little thing and stop the technology development.  This is exactly what Dr. Pushpa Bhargava has been trying to do at GEAC meetings at the behest of the anti-GM lobby.  The real purpose is based some imported political idieolgy to oppose everything that comes from the western multinationals, and that too into the “sacrosanct” Indian agriculture.  This ideology emanates from the same worn out socialistic and leftist’s political ideology that stands discredited around the world.  This is simply Luddism. The anti-GM argument is not about safety, but it is about political fights against globalization, anti-capitalism and free entrepreneurship. 

  9. Many of these civil society organizations have vested interest in alternative form of agriculture and see modern biotechnology as a threat their business interests. They just want to promote, organic farming, natural farming, or biodynamic farming or System Rice Intensification (SRI) methods, all of which are fads, but not economically viable or sustainable.  The fact is GM crops can be an excellent fit into all these methods of growing crops.  Their goal is to defeat is to kill any successful modern technology in agriculture that will compete with their own business or vested interests.  They simply do not like modern industrial agriculture that is proficient, but would like to take India back to pre-independence form of agriculture.  India will be making a big mistake by succumbing to this kind of political activism and you should not allow it.  You will be better off to consult India’s agricultural science community who know better what works better for Indian farmers than these wackivists. No one technology must be promoted to the exclusion of any other because no single technological option is a silver bullet to India’s agricultural problems.  But, rejecting modern biotechnology will be a tragedy.
We all hope that under your leadership, India will become a powerhouse of modern biotechnology in agriculture, and hope that safe and beneficial biotechnology will bloom.

Warm regards,
Dr. Shanthu Shantharam
Senior Research Scholar
Science, Technology and Environmental Policy Program
Woodrow Wilson School of Public Policy and International Affairs,
Princeton University
Princeton, NJ