Please find enclosed my feedback on Environmental Safety assessment of DMH-11. I am forwarding these comments since the SC orders of 7th October, 2016 have recorded that feedbacks on the Environmental Release of Genetically Engineered Mustard (Brassica juncea) Hybrid DMH-11 were still being collected. I am therefore assuming that the following observations will still be considered.

-Dr. Parthiba Basu, Director, Centre for Pollination Studies, University of Calcutta and Head, Department of Zoology, University of Calcutta, 35, B.C. Road, Kolkata 700019.

Comments on the document on

“Assessment of Food and Environmental Safety (AFES)”

On The Proposal for Authorisation Of Environmental Release of Genetically Engineered Mustard (Brassica juncea) Hybrid DMH-11 and use of Parental Events (Varuna Bn3.6 And EH2 Modbs2.99) For Development of New Generation Hybrids

Contact details

Full name*:Dr. Parthiba Basu

Male/Female: Male

Affiliation*Faculty, University of Calcutta

State Govts.(Deptt)/ Local elected bodies /Farmer /Student /NGO /academy

/faculty/association/researchers/scientists/environmentalists/educational

institutions/citizens/industry/research

institution/others

Postal Address*: Department of Zoology, University of Calcutta, 35, B.C. Road, Kolkata 700019

City: Kolkata

State:West Bengal

Country: India

Pin code:700019

Email address:

My comments are specifically with regards to CHAPTER 6 - Biosafety Assessment: Environment

Safety Assessment Studies for GE Hybrid DMH 11 and the Parental Lines.

1. There was no pollen flow studies for the parental lines and was done only for DMH-11 hybrid. Even this pollen flow study was done for just one season and it was necessary to do this for multiple seasons and for multiple years as was done for BT Brinjal.

2. Extent and rate of outcrossing was not studied while doing the pollen flow study. It must be noted that although Mustard is a self-pollinating plant their dependence on interplant insect cross pollination for seed set formation can be between 20 – 30% (Rakow and Woods, 1987).

3. It appears that the study protocol was limited by a plot distance of only 50 m surrounding the outer boundary of GE crop as specified in the AFES document(page 85) and therefore the conclusion drawn that it does not flow beyond that distance was hasty and incorrect. This protocol seems like the one used by Scheffler et al. (1993) and the foal honey bee species in that study was A.mellifera. It is quite possible that Indian rock bee A. dorsata might transport pollens further. Previous reports have also shown that the outcrossing depends on the distances between fields and it needs to be seen what happens in contiguous field in intensive agricultural landscape. Pollen transport has also been shown to increase with increased plant spacing (Morris 1993). Multiple scale study at different landscape situations would be essential before the pollen flow distance could be ascertained. I recommend a multi season trial across multiple years at multiple locations and at multiple scales (distances).

4. Our own research (being published) reveals for the first timein India that there is significant pollination deficit (causing reduced seed set) in conventional mustard grown in intensive agricultural areas where extensive agro-chemicals are used (we can show the data if called upon). This is a result of reduced pollinator populations (our data reveals that too) in such areas. Although using a methodology different from ours, Morandin et al. (2005) found highest pollination deficit in GM (herbicide resistant) B. napus and B. rapa compared to organic and conventional varieties. Organic mustard had no pollination deficit while the conventional mustard (grown with agro-chemicals) had moderate pollination deficit. No pollination deficit study was conducted apart from merely reporting that there was no change in bee visit (page 84). Mere reporting of bee visit is definitely inadequate as what needs to be done is to assess if the landscape has adequate number of bees for optimum seed set formation through cross pollination. It is therefore essential to conduct pollination deficit study comparing organic, conventional, GM hybrid and even available non GM hybrid mustard varieties across seasons, years and locations.

The above finding also implies that the present yield of mustard in intensive agricultural areas can be improved as it is by encouraging pollinator friendly farming (keeping semi natural vegetation in the landscape/field bunds and through non pesticidal pest management) instead of aiming for a claimed 30% yield improvement through GM technology mediated hybridization. Even if there is improvement in yield, deficit in cross pollination would pull it down. My question is therefore why do we need GM mediated hybridization at all! Pollinator friendly mustard farming using array of (# 12) of improved varieties of mustard seeds developed in IARI or for that matter the Coral 432 hybrid variety developed by Advanta could help achieve the desired yield improvement. It also needs to be asked if the yield comparison was done between DMH11 with other available improved and hybrid varieties. Apparently not.

5. I would also point out that impact of Gluphosinate on honeybee health was not assessed since the GE crop was not sprayed with Gluphosinate and this is a serious flaw in the assessment protocol. This assumes added concern since very little information is available on the impact of gluphosinate on terrestrial (or aquatic) animals (