Hon’ble.SHRI JAIPAL REDDY,
Minister for Science and Technology,
E Mail: firstname.lastname@example.org
Honorable Shri Jaipal Reddy,
Sub: Dropping the Biotechnology Regulatory Authority of India (BRAI) Bill 2013 – reg.
Namaskar and Greetings!
This is to express our utter dismay and disappointment at the manner in which the controversial and objectionable Biotechnology Regulatory Authority of India (BRAI) Bill 2013 was introduced by you in the Lok Sabha, ironically on The World Earth Day! This proposal for BRAI is a direct threat to the health of our citizens, our environment and our farm livelihoods, given the deeply flawed approach and specific contents of the Bill. Parliamentarians cutting across party lines, in addition to a couple of state governments have expressed their serious reservations against this Bill in the past, as you know, and had urged the government to not table the Bill.
Most importantly, the Parliamentary Standing Committee on Agriculture already examined in great detail the regulatory frameworks that exist elsewhere in the world, and studied the BRAI Bill too. In their August 2012 report tabled in the Parliament, the Committee unanimously said the following:
“The Government have been for some years now toying with the idea of a Biotechnology Regulatory Authority. The Committee feels that regulating biotechnology is too small a focus in the vast canvas of biodiversity, environment, human and livestock health, etc. and a multitude of other such related issues. They have, therefore, already recommended in a previous Chapter setting up of an all encompassing Bio-safety Authority through an Act of Parliament, which is extensively discussed and debated amongst all stakeholders, before acquiring shape of the law. Unless and until such an authority is in place, any further movement in regard to transgenics in agriculture crops will obviously be fraught with unknown consequences”. (Section 8.120)
Analysing the lacunae of the existing regulation and studying the proposed Biotechnology Regulatory Authority of India Bill, the Standing Committee said the following: “In such a situation what the Country needs is not a biotechnology regulatory legislation but an all encompassing umbrella legislation on biosafety which is focused on ensuring the biosafety, biodiversity, human and livestock health, environmental protection and which specifically describes the extent to which biotechnology, including modern biotechnology, fits in the scheme of things without compromising with the safety of any of the elements mentioned above”.
It is important to note that ten of the 31 members of the Committee that unanimously signed off on the Standing Committee’s report belong to the ruling Congress. The then-UPA members were 13 in all! Are we to assume that the level of undemocratic functioning of the government is such that it would not listen to its own Parliamentarians who have studied the subject carefully?
I also feel deeply disappointed by your action since members of OUR Coalition had met you on the 27th of November 2012 in person and the issues with regard to the BRAI Bill were discussed in detail. You had assured Coalition that various points raised would be looked into. Similarly, the DBT Secretary Dr Vijayaragavan is quoted in a media report soon after taking up his new office early this year as BRAI Bill requiring extensive consultations. If the serious flaws being pointed out again and again are not looked into, what democracy are we talking about?
The BRAI Bill is much more retrograde than the regulation system that exists today, which itself has been proven inadequate in the Bt Brinjal case. Through the BRAI Bill your Ministry proposes to take a step back from the improvements related to transparency or public participation or federal polity enshrined in the Indian Constitution or rigorous, long term independent scientific testing all of which were incorporated into the Government’s own moratorium decision on Bt brinjal How can this BRAI Bill be rationalized by a government which is not even heeding to its own Task Force’s forceful and important recommendation around the bottom line for any regulation related to modern biotechnology in the country, as contained in the Swaminathan Task Force report of 2004 (the safety of the environment, the well being of farming families, the ecological and economic sustainability of farming systems, the health and nutrition security of consumers, safeguarding of home and external trade and the biosecurity of the nation’)?
Honorable Sir, it appears that your Ministry has chosen to support the industry only and not the ordinary citizens, their health, environment and livelihoods concerns as evidenced from celebration made by some of the industry associations when the Bill was introduced in the parliament of this noble country.
I believe that the Government of India made a grave mistake when it tabled the BRAI Bill on the 22nd of April 2013. However, I also believe that it is not too late for you to withdraw the Bill and instead propose a Bio-safety Protection Legislation.
This is to let you know that the people feel betrayed. Around the country, there is deep rejection of this Bill, by ordinary citizens, by scientists, by civil society groups, as well as by many elected representatives and their parties, in addition to state governments.
I beg to urge you to drop this Bill, and instead propose a Biosafety Protection Law, which the Government of India should bring in through the coordinated efforts of various concerned ministries, but led by the ones whose mandate it is to protect biosafety. The least that should have been done is to circulate this Bill for widespread public consultations, in addition to seeking feedback from the state governments. It is also a travesty of transparent governance that your government holds high, that the draft of this bill was never opened up for public debate, and weighed against a Biosafety Protection Law.
Honorable Sir, please withdraw this Bill immediately, responding to the faith reposed in you by the public to save our noble country and generation from the impacts of synthetic genes (Enclosure) and current methods of introduction into the God given crops.
With Respectful Regards