This is to draw your kind attention to various matters of deep concern in relation to
the controversial transgenic technology in our food and farming systems in India – as
you know, there are contradictory facts and views, including in the scientific domain,
about this technology and independent analyses show that this technology is unsafe
for our health and environment. There is a dire need for any country like India where
millions are depending on agriculture for their livelihoods, to proceed very cautiously
before deploying this technology. There are fundamental questions to be answered
by any government satisfactorily before allowing deliberate environmental releases
of novel organisms in our food and farming systems and any undemocratic decision making around this would only result in great resistance from the grassroots.
Título original
Our Position on Genetically Modified Crops(GMOs) by Bharatiya Kisan Union
This is to draw your kind attention to various matters of deep concern in relation to
the controversial transgenic technology in our food and farming systems in India – as
you know, there are contradictory facts and views, including in the scientific domain,
about this technology and independent analyses show that this technology is unsafe
for our health and environment. There is a dire need for any country like India where
millions are depending on agriculture for their livelihoods, to proceed very cautiously
before deploying this technology. There are fundamental questions to be answered
by any government satisfactorily before allowing deliberate environmental releases
of novel organisms in our food and farming systems and any undemocratic decision making around this would only result in great resistance from the grassroots.
This is to draw your kind attention to various matters of deep concern in relation to
the controversial transgenic technology in our food and farming systems in India – as
you know, there are contradictory facts and views, including in the scientific domain,
about this technology and independent analyses show that this technology is unsafe
for our health and environment. There is a dire need for any country like India where
millions are depending on agriculture for their livelihoods, to proceed very cautiously
before deploying this technology. There are fundamental questions to be answered
by any government satisfactorily before allowing deliberate environmental releases
of novel organisms in our food and farming systems and any undemocratic decision making around this would only result in great resistance from the grassroots.
RoadNo.2, A 33, MahipalpurExtension,NewDelhi 110037,India
Tel: 011- 26783000,26784000;Fax:011-26785001;Email:yudhvir55@yahoo.com FARMERSPOSITIONON GENETICALLYMODIFIEDCROPS Sub: Transgenic Crops and Foods in India This is to draw your kind attention to various matters of deep concern in relation to the controversial transgenic technology in our food and farming systems in India as you know, there are contradictory facts and views, including in the scientific domain, about this technology and independent analyses show that this technology is unsafe for our health and environment. There is a dire need for any country like India where millions are depending on agriculture for their livelihoods, to proceed very cautiously before deploying this technology. There are fundamental questions to be answered by any government satisfactorily before allowing deliberate environmental releases of novel organisms in our food and farming systems and any undemocratic decision- making around this would only result in great resistance from the grassroots. Here, in this brief note, we would like to draw your attention to the following issues 1. GM in our food & farming systems wy is tere a need for greater concern from po!icy"ma#ers$ !enetic "ngineering is often equated by its proponents with conventional breeding and is also touted as precision-breeding. #s per numerous e$perts that this is simply not true %ature does not have gene constructs of viral and bacterial genes inserted into other alien organisms and there is much scientific evidence on the genetic instability caused by the process of !enetic "ngineering. !enetic "ngineering, which allows for transfer of alien genes from one organism to another, for random insertion into the host organism&s '%#, is a novel technology which is unnatural and breaks the barriers that e$ist in nature in unpredictable and irreversible ways. (e would like to strongly argue a case for great precaution before such technologies are deployed in our farming and food systems all agricultural technologies would have a large and lasting impact for the simple reasons that )a* all of us consume food that comes out of farming, )b* that a ma+ority of land on this planet is under farming and )c* that a vast ma+ority of Indians are directly connected to farming for their livelihoods. Therefore, any technology that will have impacts on health and environment that too on a large scale, has to be deployed after a careful analysis of all possible impacts. ,urther, a precautionary approach should be the central guiding principle around decision-making. -nlike the technologies that we have deployed in the past, which are showing up various negative impacts now whether it is the case of chemical fertili.ers or chemical pesticides, this time around with !/ seeds, we are talking about a living technology which also implies that it is irreversible once released into the environment. #n analysis of the technologies that get deployed shows that fair apportionment of resources does not happen both at the research level and at the e$tension level to sustainable and unsustainable technologies. -nsustainable technologies, which usually also mean more markets for some agency or the other, coupled with marketing strategies and financial power, usually edge out the other technologies, especially safer, more affordable and sustainable ones, which are not pushed by anyone for the simple reason that there are no markets involved0 Tere is an urgent need to re"assess a!! tecno!ogica! options in front of us in a 1 fair and scientific fasion before dep!oying a%ardous and unsustainab!e tecno!ogies& tere is need for a po!icy directi'e tat unsustainab!e tecno!ogies wi!! not be promoted and encouraged. 2. GM crops & food security c!aims ow true are tey$ The biggest reason why !/ crops are being given a great consideration by our policy makers is the fear generated by /althusian arguments that our food supplies will be outstripped by population growth. However, as argued by many e$perts time and again including by eminent economists like 3rof #martya 4en, food security is not an issue of food supply alone but is related more to access and distribution issues. ,urther, there are many ways by which food production and productivity can be improved, including by ensuring that land meant for food production is not diverted to other purposes, that agro-ecological methods like 4ystem of 5ice Intensification which conserve resources even as they increase productivity should be encouraged on a large scale, that output incentives provided to farmers are bound to increase food productivity and so on. Time and again, many agencies including the 3lanning 6ommission have been referring to e$isting 7technology gap& between know-how and do-how to be bridged. ,urther, it has been aptly stated in the 8isan 3olicy that agriculture is not about production and productivity alone there is a multi- functionality to Indian agriculture )agriculture as a way of life* that is often ignored by /althusian arguments. There are also emerging schools of thinking which question the very notion of 9yield: as defined by narrow parameters right now, to the e$clusion of many other concerns that should govern the 9measurement of yields:. /ore important and pertinent to the current discussion is the fact that !/ technology is not meant to improve productivity technically, it cannot, since yields are a multi- genic trait and no GM product as been put into te mar#et anywere in te wor!d tat can increase yie!ds, despite years of disproportionately high levels of investment on the technology. (orse, the largest cultivated !/ crop in the world, !/ )5oundup 5eady* soybean, is shown to have actually decreased yields in countries like the -4#. #n attached report called ,ailure to ;ield, gives more information on how !/ seeds are only a red herring when it comes to issues of food security. There have been multiple instances in the past when senior policy-makers in the country have pointed out that with the e$isting technologies, both within the %#54 and with thousands of innovative farmers across the country, yields can indeed be increased at the macro-level, by bridging the technology gap. This requires institutional interventions more than anything else. There are hundreds of highly successful farmers, from whom learning can be facilitated to other farmers, provided there is a willingness to evolve intensive farmer-to-farmer e$tension models. 4ome such models do e$ist in the country which include the 6/4# )6ommunity /anaged 4ustainable #griculture* programme implemented by the #ndhra 3radesh government and programmes around promotion of 4ystem of 5ice Intensification in states like Tripura. Terefore( tere is an urgent need to pursue rea!( !asting so!utions for impro'ing farmers) !i'e!ioods wi!e increasing producti'ity as some successfu! e*amp!es a'e a!ready demonstrated. <. +re tere no a!ternati'es$ !iven that the 4=T behind !enetic "ngineering is controversial, even amongst scientists who have speciali.ed in the fields of molecular biology, biochemistry etc., and given that a ma+ority of countries around the world have taken a cautious stand, including based on available scientific rationale, it would only appear prudent that India also take a similar stand. However, there are no policy frameworks that guide 2 the 5 = ' work, if at all, on transgenics. The 4upreme 6ourt observer in the !"#6, 'r 3ushpa >hargava had laid down the contours of an ideal regulatory regime and said that for every !/ application that is received on the food?farming front, a question that the regulators should immediately ask is whether there are no alternatives to a given problem that this !/ product professes to address and proceed only after a thorough need assessment. 4imilarly, there are no policy level guidelines that guide 5 = ' on crops for which we are the 6entre of @rigin and 'iversity. >rin+al was such a case and crops like rice, pigeonpea etc., which are in the pipeline also pose a big question on the future of biodiversity in these crops with their !/ versions. Today, any person or agency can walk up to the regulators in India for a permission to tinker with any plant through r-'%# technology, for any novel trait with any set of genes and move almost ine$orably forward towards our plates. This is obviously unacceptable. Tere is an immediate need to assess a!! te products in te pipe!ine and sta!!,stop,re-ect a wo!e set of app!ications on te simp!e grounds tat tere are oter a!ternati'es or tat we are te Centre of .i'ersity for a particu!ar crop. @therwise, this would only constitute a diversion of precious resources from much-needed research on other aspects. /. Te current rea!ity of GM crops is tis wat we need$ 'espite all the hype around !/ crops as being the only solution for a ma+ority of problems in modern day agriculture, the reality is that there are only two 9traits: that form the basis of !/ crops and their commercial cultivation around the world today insect resistant >t crops and herbicide tolerant crops )that too mostly tolerant to /onsanto&s brand of herbicide called 5oundup*. 3est management in fact is quite possible without the use of either !/ seeds or synthetic pesticides as large scale e$periences around India and elsewhere show. In fact, Insect 5esistant >t crops have an intrinsic shortcoming if a population of insects is sought to be killed by technologies like synthetic pesticides or >t crops, it is only natural that the pests will select for resistance0 (hen it comes to Herbicide Tolerant crops, which seems to be the trait that crops have been engineered for in nearly AAB of !/ crop cultivation around the world today, it is quite apparent that this is a technology which is meant for labourless farming. It increases chemical usage in farming and has actually resulted in more chemicals being applied in #merican farming in the past 1< years, after the advent of !/ crops, rather than reduce chemicals0 ,urther, resistant weeds are posing a ma+or challenge in several parts of #merica, as several reports indicate. # ma+ority of !/ crop cultivation to this day is with +ust one country - the -4#. The desperation of this one country to find markets for its produce and for its agri- business corporations )for their seeds and proprietary technologies* is quite apparent, in a world which is increasingly having more and more areas actually re+ect !/@s and declare themselves !/-,ree. /ost !/ product goes into animal feed, biofuels or cotton products as shoppers avoid eating !/ foods in most countries around the world. In 2CCD 12.2 million hectares of !/ crops in the -4 were used for biofuels )1E.FB of total -4 !/ area and 1CB of the global !/ area*. This situation has to be kept in mind by policy-makers in India when they advocate !/ crops as a solution tat te tecno!ogy as been app!ied to main!y two app!ications bot of wic are unneeded in our conte*t and tat te < +merican need to find more acceptance in countries !i#e ours is commerce" dri'en. (hen the world is so divided on the issue and when the scientists of the world are also so divided on the matter, on what basis is India ready to trust the data and defence proffered by crop developers and move ahead on !/@sG If there are any lessons that have been learnt from the !reen 5evolution, they should teach us not to sacrifice medium and long term sustainability at the altar of short term gains especially when sustainable solutions do e$ist. 0. Te socio"economic aspects is tis tecno!ogy suitab!e for India$ # ma+ority of !/ crops grown around the world are Herbicide Tolerant )HT* !/ crops. In countries like the -4# where less than 2B of the population lives off farming, it is understandable that the agriculture research system there comes up with technologies like HT !/ seeds, even though that would not necessarily make the technology safe or desirable. # 2CC2 -4'# study which sought to look at !/ crop adoption by #merican farmers raises a pertinent question to itself 9perhaps the biggest issue raised by these results is how to e$plain the rapid adoption of !" crops when financial impacts appear to be mi$ed or even negative:, it says suggesting that 7other considerations may be motivating farmers& Hwhat is now called the 9convenience effect:I 1 . However, in a country like India, the very concept of introducing !/ crops poses a big question on the socio-economic implications for the poorest rural families in the country who earn a substantial part of their livelihood through de-weeding activity which this technology seeks to replace. The poorest rural women in India obtain employment through this activity which HT !/ crops will surely decimate, in addition to leaving to$ic impacts behind through the increased use of agri-chemicals. It seems incomprehensible that the government first seeks to destroy e$isting employment potential in Indian farming and on the other hand, seeks to prop up rural employment by pumping in crores of rupees of ta$payers& funds in the form of %5"!4 and such other programmes. This is simply not sustainable and we need a vision for farming in India that creates a win-win situation for agricultural workers and bigger farmers, even as proper social security measures are put in place for the workers. 1. Farmers) rigts and researcers) rigts wi!! tey be protected in te face of big corporations !i#e Monsanto and its I23s$ !" technology goes hand in hand with rigid I35s in fact, it is often seen that even without the I35s being enforced legally, an unstated 9business etiquette: around such I35s secured by big /%6s allows for more and more e$clusive and monopolistic use of this technology. There are at least two unrecorded instances in India where companies like /onsanto used their I35s to prevent public sector researchers in their breeding programmes and release of varieties to farmers one is the initial >t 6otton development effort by 6entral Institute of 6otton 5esearch )6I65* in the late 1EECsJ another is the effort by -#4-'harwad to come up with its own >t 6otton varieties around 2CC<. (hile these 1 Fernandez-Cornejo, Jorge and McBride, William D., Adoption of Bio-engineered crops, Agricultural Economic Report o. !"#, Economic Re$earc% &er'ice, (&DA, Ma) *##* K instances remain anecdotal, the government might want to look into this and draw out lessons. It is also well-documented by now that /onsanto does not hesitate to sue and +ail farmers in the name of 9patent infringement:, in order to secure its own markets and profits. #ttached is a report from 6entre for ,ood 4afety in the -4# on this anti- farmer attitude and behaviour of /onsanto. 5ight now, there are several anti-trust investigations underway in the -4#, undertaken by the 'epartment of Lustice, about its anti-competitive behaviour. # ,rench documentary on /onsanto and its misdeeds is available in the public domain )http??www.youtube.com?watchGvMh"rvNF;"Hk"*, which captures the various ways in which this corporation +ust chased profits irrespective of anything else. It is shocking that India, on the other hand, officially provides several platforms to this profit-hungry corporation to direct the policies and regulatory frameworks related to agriculture and to constantly e$pand its monopolistic e$clusive markets at the e$pense of poor, hapless farmers. 4e urge you to urgent!y !oo# at ways by wic Seed So'ereignty of tis country and tereby( food so'ereignty( needs to be protected from corporations !i#e Monsanto. 5. Coices for farmers and consumers wi!! tey a'e any !eft$ It has to be remembered that the choices for farmers get limited not +ust through I35 regimes but through market maneuvers of corporations. In the case of cotton in India today, there are no choices left for farmers since non->t 6otton seed is not available in the markets. %o seed company or public sector corporation is investing in producing non-!/ cotton seed. %early DC-DFB of the seed in the market is controlled indirectly by +ust one corporation /onsanto through its proprietary technology being sub-licensed to Indian companies. If it took only eight years for nearly all non- !/ seed varieties to disappear from the market, after the advent of >t 6otton, one can imagine what lies in store for the farmers in other crops. It has been documented that seed prices are being raised e$ponentially after the advent of the !/ versions in the market and attached is a report on the same from the -4#. This does not augur well for the crisis-ridden Indian farmer. # ,act ,inding report of the 3lanning 6ommission to Nidarbha found that the rural distress in the region was e$acerbated by e$orbitantly priced seed and once farmers lose their physical stocks of seed, they would be perpetually dependent on corporations like /onsanto and its sub-licensees for supplying seeds at the prices that they choose. It took a large battle from #ndhra 3radesh government to bring down the prices of >t 6otton seed in the country through challenging the royalty charges on the technology. However, in this battle, it became clear that the governments have no legal power or means to control seed pricing. 4pecial ordinances and state level legislations had to be passed by states like #ndhra 3radesh and !u+arat to control >t 6otton seed price. The /inister for #griculture in your government is meanwhile refusing to include seed price control into regulation in the proposed 4eeds >ill. ,armers& choices will also be curbed due to the very nature of this technology to contaminate neighboring crops. Those who wish to remain non-!/ or even organic will have their crops +eopardi.ed due to the new threat of contamination from others planting !/ seeds. #s far as consumers are concerned, their right to safe food and their right to food of their choice will be +eopardi.ed?violated with the entry of !/ foods. In a country where the vast ma+ority of food is consumed in open conditions )not packed or F packaged*, labeling cannot be a real solution for upholding consumers& right to informed choices. 6. +merican interference in India wi!! te 7S+ a!!ow a simi!ar interference by India$ It is very clearly apparent, on records, that the -4# which has a huge vested interest in trying to push !/@s into other countries )with India being the most prominent of these battlegrounds* is being allowed to tweak the regulatory systems in India in favor of the industry, in the name of harmoni.ation of guidelines, laws etc. #nalysts are pointing out that the Indo--4 8nowledge Initiative on #griculture )8I#* is more about such regulatory interference than bringing about a second green revolution in India. #n initiative of this sort should have been debated in the 3arliament, given that it has implications for millions of farmers and given that not enough critical investigation has happened into the lessons we should learn from the first !reen 5evolution. In the case of >t >rin+al too, regulatory committees are being tilted by pro-!/ people who are part of various -4#I'-supported pro+ects which leaves very little scope for independent assessments. 8. Te regu!atory regime: sou!d any more appro'a!s come out of tis$ The current regulatory regime in India is ridden with various problems. It is shocking that with the e$isting shortcomings which clearly demonstrate that scientific, pro- people, democratic, transparent and independent decision-making is ne$t to impossible given the current regulatory regime, that India is still continuing to give approvals for open air trials and for various applicants to move from stage to stage with their 5=' efforts. /uch has been already written and said about the woeful inadequacies of the regulatory regime in India and why all approvals of !/@s in should be stopped immediately. 19. :ow( te ;iotecno!ogy 3egu!atory +utority of India <;3+I= draft ;i!!> (hile much has been said and articulated about the problems with the current regulatory regime, the proposals to replace it with a >iotechnology 5egulatory #uthority of India are worse. # version of the draft >ill which has apparently been sent to the 6abinet before being tabled in the 3arliament is now available in the public domain and the ob+ectionable and unacceptable shape and components being given to the >5#I has evoked much sharp reactions all around. #n attachment here talks about what the ideal regulartory regime should be like, in the form of a %ational >iosafety 3rotection statute, and the ob+ections around the >5#I proposals. 11. Te ea!t and en'ironmenta! imp!ications of GM foods: It has to be remembered that very few studies on chronic impacts of !/ foods actually e$ist and this was a big shortcoming in the case of safety assessment of chemical pesticides too today, many thousands around the world are paying a heavy price for this lack of assessment of chronic adverse effects of such to$ins in our environment and food. The same mistake is being committed, knowingly, in the case of !/ foods unfortunately. O (hile the technical implications of this imprecise and random insertion of alien genes creating changes and instability in the host genome which then manifest themselves as health and environmental implications at the organism and eco-system level are documented through various studies, a point that is worth noting is that not enough resources are allotted for generating more scientific findings on such impacts. /uch of the research that is taken up on !/@s is taken up by crop developers and in fact, it has come to light recently that research of an independent nature is actively discouraged by placing curbs on access to seed materials. # %ature >iotechnology )@ctober 2CCE* article says that 9it is no secret that the seed industry has the power to shape the information available on biotech cropsPcommercial entities and their ownership of the proprietary technology allows them to decide who studies the crop and how:. There are several instances where independent scientists& research funding was cut off or where they even lost their +obs soon after they publici.ed their findings which showed adverse impacts from !/@s. (ith very little resources flowing into such independent research and where researchers who are reporting adverse findings are intimidated by critics and face repeated and orchestrated attacks )!/ crops >attlefield, %ature, 4eptember 2CCE*, it is obvious that generation of more findings of an independent and rigorous nature in itself is a task before proceeding further on this controversial technology. In fact, given the e$isting evidence, a precautionary principle-based approach is the only way forward. It should also be remembered that the situation with !/ crops is such that apart from the biosafety concerns flowing from the 4=T of genetic engineering, issues around trade security, socio-economic implications and farmers& rights etc., should also form an integral part of impact assessment of the technology. 1?. :o !iabi!ity regime rigt now India does not have a liability regime right now to make the crop developer liable for any damage including contamination of non-!/ crops. (ithout such a liability regime being in place, no further approvals should be provided on any product to move forward in the pipeline, especially related to deliberate environmental release of !/@s. 1@. Aessons from ;t Cotton in India The >t 6otton cultivation e$perience in India over the past eight years has many valuable lessons to teach policy makers, regulators, farmers and consumers of the country, if we choose to pick them up in pursuit of sustainable development ob+ectives. )a* It has been shown time and again that the >t technology is unpredictable and the very mi$ed results over years, locations and hybrids are there for everyone to see. In those places where results have been good, deeper analysis points to good seed source )germplasm into which the >t gene has been backcrossed*, good monsoon years, higher inputs in the form of water and nutrients etc. The technology has failed in many areas which are resource-poor in terms of soils, irrigation as well as farmers& ability to provide inputs. )b* 3est and disease ecology has changed in cotton in unpredictable ways. 4econdary pests are emerging into ma+or pests in several places. )c* Impacts on soil are being observed and reported by farmers and there is increased use of chemical fertili.ersJ a senior agriculture scientist of India had predicted that with even a OB e$pansion of !/ crop land in the country, there would be a doubling of chemical fertili.er demand and this brings its own problems including that of public financing of an unsustainable input. )d* 4tress intolerance is found to be higher on >t 6otton than on other non-!/ A cultivars. This has implications for risks and vulnerabilities of our resource-poor farmers. )e* >t 6otton has left its impacts on animals which have gra.ed on the crop residues in different parts of the country including from consumption of >t 6otton seed cake etc. #nimals have either died or fallen sick after consuming >t 6otton and this phenomenon though acknowledged by some officials, has not been investigated scientifically and systematically by concerned agencies to this day )f* #gricultural workers have also reported allergies after working in >t 6otton fields and media and %!@ reports e$ist from different states about this phenomenon which is also uninvestigated to this day. )g* @n the regulatory front, >t 6otton has repeatedly showcased the regulatory incapabilities of India, right from the time that illegal proliferation of unapproved >t 6otton was first noticed in 2CC1. 5egulatory failures were not +ust on the biosafety front but in terms of monitoring, reviewing, transparent and scientific decision making and so on. )h* 4tate governments also found out through the tough way that there are no legal mechanisms available to them to regulate seed marketing, seed advertising, seed pricing and for liability and redressal for failures. >t 6otton has often been cited as the reason for the impressive yield increases in Indian cotton over the past few years. However a careful analysis of various factors, mostly culled out from official records of state governments, shows that other reasons would have contributed to the success of 6otton and without really factoring them in, !/ proponents are hyping up the success of >t 6otton. #ttached is a paper published in "conomic = 3olitical (eekly on the myth around >t 6otton and yields of 6otton in India. It is surprising that no one has boldly asked as yet why such dramatic results have not come out of other countries )including the -4#, which continues to heavily subsidise its farming* that have adopted !/ crops if what is being touted about >t 6otton in India is indeed true0 ,inally, the recent admission by /onsanto about pink bollworm developing resistance to its first-generation >t 6otton and urging farmers to adopt >ollgard II which gives it a possibility of raking in more money and the counter statement provided by a public sector body like 6entral Institute of 6otton 5esearch )6I65* questioning the findings even as it is struggling to find markets for its own single-gene >t 6otton need to be investigated systematically before moving further. # 'harwad agriculture university study also shows that bollworms are able to survive, mate and proliferate on >t cotton. 1/. 3ea!( !asting so!utions !ie e!sewere wy are we not in'esting on tem and wy are we ignoring tem$ There is a growing reali.ation worldover, as the debate about the future course of agricultural research and e$tension as well as the future course of farming itself on this planet has unfolded on several platforms, that !/ crops are not the solution for many of the current problems related to food and farming and certainly not for the real problems of the small and marginal holders of developing countries. #n international scientific research process along the lines of the I366 for 6limate 6hange was initiated in 2CC<, supported by the (orld >ank and the -% and came up with its report in 2CCE. The I##4T' the International #ssessment of #gricultural 8nowledge, 4cience and Technology for 'evelopment which ran between 2CC< and 2CCD, involving over KCC scientists worldwide, was an ambitious attempt to encourage local and global debate on the future of agricultural science and technology. This global team of KCC e$perts from different fields, including social scientists, went on to challenge the conventional gatekeepers of agricultural D knowledge. The process of I##4T' was initiated 7to assess agricultural knowledge, science and technology in order to use it more effectively to reduce hunger and poverty, improve rural livelihoods, and facilitate equitable, environmentally, socially and economically sustainable development&. The I##4T' report was endorsed by FD governments including India. This report represents the work of the largest research effort to date on the history and future of modern agriculture. I##4T' endorsed a renewed emphasis on technologies that have proven track records for improving yield, reducing e$ternal inputs into agro-ecosystems, preventing the conversion of more land for agriculture and helping agriculture to improve the lives of poor and subsistence farmers. The final report of the I##4T' concluded that the business-as-usual model of prevailing industrial agriculture cannot meet the food needs of the E billion who are e$pected to inhabit 3lanet "arth within a few decades. In particular the I##4T' report emphasised that food security requires a multi-functional approach to agriculture and ownership structures -- particularly protecting local knowledge systems that have been passed on from one generation to the other over millennia. The main messages of I##4T' include alternative production systems, notably those based on agro-ecological methods, can be competitive with or superior to conventional and genetic- engineering-based methods of productivityJ these alternative methods, moreover, not only lower the environmental impacts of agriculture, they may reverse past damageJ an emphasis on farmer-initiated and conducted innovation, research and manipulation of biotechnologies is a proven method for achieving higher levels of food security and has collateral benefits of building social capacity, community independence and ongoing local research and knowledge sharingJ to capture the benefits of alternative production systems, the world must readdress the imbalance in funding between genetic engineering and agro- ecological research, must establish workable policies for farmer participation and agree to eliminate developed country subsidies for agriculture intended for e$port. These approaches are also ones which will contribute to mitigation as well as adaptation in the era of climate change, as opposed to intensive agriculture models. It is time that India, which has more stake in conserving and improving its agriculture than most other countries given the rich heritage of farming in this country and given that millions of lives are directly dependent on agriculture, re-looked at its misplaced emphasis on transgenics and promoted farmer-centric agro-ecological models of farming. (e urge you, in the light of all the above arguments which clearly point out the many adverse implications of transgenics and question the very need for this technology in our farming, to put a complete stop on all open air, deliberate releases of !/@s in our food and farming, a ban on import of any !/ foods into the country and a complete re-hauling of our vision for Indian farming in the pursuit of sustainable development for all Indians. Thank you. E