<div align="justify">There have been a flood of media reports about the Genetic Engineering Appraisal Committee (GEAC) under the Environment Ministry having recommended the release of genetically modified (GM) mustard developed by the Centre for Genetic Manipulation of Crop Plants (CGMCP), University of Delhi.<br /><br />At the centre of the news is the GEAC’s decision and the GEAC itself. But there is another regulatory authority in the ministry itself, which can be its voice of conscience.<br /><br />Miles away from the ministry headquarters of Paryavaran Bhawan in New Delhi, the Chennai-based National Biodiversity Authority (NBA) seems as distant from Delhi as its office is. The NBA was set up in 2003 under the Biological Diversity Act, 2002 to implement the same. <br /><br />It is an autonomous body meant to be like an amicus curiae to the ministry. The NBA is tasked with giving advice to the ministry on matters related to biodiversity. If the NBA does choose to do what it is meant to do, these are some key issues in the context of GM crops it must consider.<br /><br />NBA competence: The Authority is a body with competence on the subject of GM crops. The membership of the NBA comprises ex officio representatives from the Government of India departments that among others, deal with biotechnology, science and technology. The NBA has the responsibility to look into the impact of the application of modern biotechnology on biodiversity. <br /><br />A critical aspect of risk analysis in such matters is risk communication. Unless the NBA, tasked with conservation, is fully cognisant of the matter, and it makes the state level biodiversity boards (SBBs) and local-level biodiversity management committees (BMCs) aware of the issue too, they cannot carry out their conservation responsibilities under the biodiversity regulatory regime.<br /><br />The NBA can rightfully ask for the full communication on GM mustard made by the GEAC to the environment minister and thereafter make that available to the SBBs and BMCs, particularly in the states in which mustard is grown.<br /><br />Duties of the government: Section 36(4)(ii) of the BD Act makes it a legal duty of the central government to regulate, manage or control the risks associated with the use and release of living modified organisms resulting from biotechnology likely to have adverse impact on the conservation and sustainable use of biological diversity and human health. <br /><br />The present is a fit situation for the NBA to invoke this particular provision of the law. The GM mustard is an LMO (living modified organism) — a live seed, from which gene flow cannot physically be controlled once grown in the open environment. Thus, adherence to the precautionary principle is warranted. <br /><br />The NBA should insist on the minister to apply the precautionary principle in this matter and encourage the available local alternatives to GM mustard.<br /><br />Expert committee: The NBA has a 21-member expert committee (EC) on agro biodiversity. The committee has a duty to conserve mustard diversity in the country. Given its mandate, the panel has a critical role to play in aiding the ministry on how to proceed with the subject from the point of view of agro biodiversity. <br /><br />Unless the NBA keeps track of the state of biodiversity in our fields, there is no baseline from which to compare and measure the extent of damage from GM crops to pin liability if things go wrong. <br /><br />The NBA must call for an urgent meeting of this EC to consider the recommendations of the GEAC and their implications on agro biodiversity. The expert opinion of the EC on this issue may also be put up on the NBA website, as minutes of EC meetings are not publicly accessible. <br /><br />Documented agro biodiversity: The NBA has been encouraging SBBs to undertake documentation of local biodiversity across India through BMCs. The key function of BMCs has been reduced to the making of people’s biodiversity registers (PBRs) to list out local seeds, breeds, etc. <br /><br />As per NBA’s own statistics, 2,485 PBRs have been prepared up to September 2015. These registers bear testament to India’s agro biodiversity. They are several farmers’ varieties of Indian mustard documented in the PBRs. <br /><br />Existing local varieties of mustard should not remain as mere entries in a register while they are made to go out of use in our farms. In fact, it is this documented crop diversity that has to be kept alive. Agro biodiversity is our only insurance as climatic and other challenges confront our food and farm systems.<br /><br />The NBA ought to direct the SBBs to collate information on local mustard varieties from the PBRs made in their states and make it known to the environment minister as evidence of the existing crop diversity that both needs to be promoted as well as protected from GM mustard.</div>
<div align="justify">There have been a flood of media reports about the Genetic Engineering Appraisal Committee (GEAC) under the Environment Ministry having recommended the release of genetically modified (GM) mustard developed by the Centre for Genetic Manipulation of Crop Plants (CGMCP), University of Delhi.<br /><br />At the centre of the news is the GEAC’s decision and the GEAC itself. But there is another regulatory authority in the ministry itself, which can be its voice of conscience.<br /><br />Miles away from the ministry headquarters of Paryavaran Bhawan in New Delhi, the Chennai-based National Biodiversity Authority (NBA) seems as distant from Delhi as its office is. The NBA was set up in 2003 under the Biological Diversity Act, 2002 to implement the same. <br /><br />It is an autonomous body meant to be like an amicus curiae to the ministry. The NBA is tasked with giving advice to the ministry on matters related to biodiversity. If the NBA does choose to do what it is meant to do, these are some key issues in the context of GM crops it must consider.<br /><br />NBA competence: The Authority is a body with competence on the subject of GM crops. The membership of the NBA comprises ex officio representatives from the Government of India departments that among others, deal with biotechnology, science and technology. The NBA has the responsibility to look into the impact of the application of modern biotechnology on biodiversity. <br /><br />A critical aspect of risk analysis in such matters is risk communication. Unless the NBA, tasked with conservation, is fully cognisant of the matter, and it makes the state level biodiversity boards (SBBs) and local-level biodiversity management committees (BMCs) aware of the issue too, they cannot carry out their conservation responsibilities under the biodiversity regulatory regime.<br /><br />The NBA can rightfully ask for the full communication on GM mustard made by the GEAC to the environment minister and thereafter make that available to the SBBs and BMCs, particularly in the states in which mustard is grown.<br /><br />Duties of the government: Section 36(4)(ii) of the BD Act makes it a legal duty of the central government to regulate, manage or control the risks associated with the use and release of living modified organisms resulting from biotechnology likely to have adverse impact on the conservation and sustainable use of biological diversity and human health. <br /><br />The present is a fit situation for the NBA to invoke this particular provision of the law. The GM mustard is an LMO (living modified organism) — a live seed, from which gene flow cannot physically be controlled once grown in the open environment. Thus, adherence to the precautionary principle is warranted. <br /><br />The NBA should insist on the minister to apply the precautionary principle in this matter and encourage the available local alternatives to GM mustard.<br /><br />Expert committee: The NBA has a 21-member expert committee (EC) on agro biodiversity. The committee has a duty to conserve mustard diversity in the country. Given its mandate, the panel has a critical role to play in aiding the ministry on how to proceed with the subject from the point of view of agro biodiversity. <br /><br />Unless the NBA keeps track of the state of biodiversity in our fields, there is no baseline from which to compare and measure the extent of damage from GM crops to pin liability if things go wrong. <br /><br />The NBA must call for an urgent meeting of this EC to consider the recommendations of the GEAC and their implications on agro biodiversity. The expert opinion of the EC on this issue may also be put up on the NBA website, as minutes of EC meetings are not publicly accessible. <br /><br />Documented agro biodiversity: The NBA has been encouraging SBBs to undertake documentation of local biodiversity across India through BMCs. The key function of BMCs has been reduced to the making of people’s biodiversity registers (PBRs) to list out local seeds, breeds, etc. <br /><br />As per NBA’s own statistics, 2,485 PBRs have been prepared up to September 2015. These registers bear testament to India’s agro biodiversity. They are several farmers’ varieties of Indian mustard documented in the PBRs. <br /><br />Existing local varieties of mustard should not remain as mere entries in a register while they are made to go out of use in our farms. In fact, it is this documented crop diversity that has to be kept alive. Agro biodiversity is our only insurance as climatic and other challenges confront our food and farm systems.<br /><br />The NBA ought to direct the SBBs to collate information on local mustard varieties from the PBRs made in their states and make it known to the environment minister as evidence of the existing crop diversity that both needs to be promoted as well as protected from GM mustard.</div>
