Consultation Feedback Form
Project:
Organisation:
Food Wise 2025
Department of Agriculture, Food and the Marine
Question
Do you agree with the approach and methodology
used for the Strategic Environmental
Assessment?
Comments
No. The Geographic extent of the assessment has been limited to the national territory
(including marine areas). This precludes assessment of transboundary issues. In practice,
the human impacts have been limited to rural areas, while nutritional effects can have
wider impact, including urban areas, and in areas receiving produce from Ireland.
Have all relevant Plans, Programmes and Policies
been identified and considered? If not can you
advise of any gaps?
Has the relevant baseline data been identified for
each objective?
Are you aware of any additional on-going
research or monitoring that should be considered
in terms of the baseline environmental conditions?
Has the baseline information been correctly
interpreted to identify the key challenges and
opportunities arising from the plan?
Do the strategic environmental objectives (SEO’s)
cover all relevant areas?
The World Health Organisation policy on breastfeeding, and the International Code of
Marketing of Breastmilk Substitutes have not been considered.
No. The Strategic Environmental Objectives entail ensuring that plan strategies do not
impact negatively on human health. Health impacts of increased infant formula, and of
marketing milk products to regions where adults are dominantly lactose intolerant, have not
been assessed.
The claim that “Effects on human health and wellbeing can derive from Interactions with
environmental factors such as water, soil or air through which contaminants or pollutants
can come in contact with human beings” omits to identify the direct product as having any
human-health effects.
Do you consider that the alternative strategies
outlined are reasonable and have been assessed
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correctly?
Do you think that cumulative and trans-boundary
impacts have been assessed fully?
Do you agree with the assessment outcomes and
potential impacts addressed?
Do you agree with the list of mitigation measures
and monitoring proposed? Are there any further
measures you consider should be included?
Are you aware of any further environmental
information that will help to inform the
environmental assessment findings?
Do you have any other comments you wish to
make on the Food Wise 2025 and/or the related
SEA Environmental Report and Natura Impact
Statement?
No. Trans-boundary impacts of increased supply and marketing of infant formula, in
opposition to the World Health Organisation promotion of breastfeeding have not been
identified as warranting consideration.
No. While human health is identified as a top-level concern of the SEOs, there are no
statements on human health impacts, whether positive or negative, in the summary
assessment of alternatives (the Base Case and Base Case+ scenarios).
Food Wise 2025 fails to identify the issues of lactose intolerance, and the displacement of
breastfeeding. The World Health Organisation recommends that we we “Significantly limit
the marketing of breastmilk substitutes”. These issues must be recognised and assessed.
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