Comments from the Sustainable Food Trust on the HLPE Draft Report
“Sustainable Agricultural Development for Food Security and Nutrition, including the Role of
Livestock”
General comments
The Sustainable Food Trust (SFT) welcomes the opportunity to comment on a draft of the HLPE’s
important report on food security and the role of livestock. The report touches on aspects of
sustainable agricultural development in relation to food security and livestock, and gives
some insights into the issue of sustainability in livestock farming. But our view is that it fails to
recognise the key components of livestock systems which are sustainable over long periods of
time, and therefore provide reliable food security, and the components of livestock systems which
are not sustainable because they result in high levels of pollution, progressive land degradation, or
there is high use of non-renewable resources, all of which mean that ultimately such systems,
even if currently the most productive, are not sustainable. Most significantly we feel the report
fails to consider the key issue implicit in the title – what is the role of livestock in the sustainable
development of agriculture for food security? In order to aid such considerations we feel it would
be helpful if the authors were to give some consideration to timescale. Over what period do they
feel the report covers, the next a decade, 50 years, a century?
While there are a number of issues we feel the authors should expand and/or reconsider, we
welcome the fact that the report includes several references to human health impacts, animal
welfare, gender and equity, which build on a good body of research on these topics.
The framework on page 22 helps to identify key trends, challenges and pathways/responses
around which the report is structured. However, some critical components of the agri-food system
are either not included in the framework (land use change, natural capital, such as finite fossil
fuels used in the production of nitrogen fertilisers, and mineral resources used in agriculture) or
are not given detailed consideration throughout the report (biodiversity, unfertilised grassland
soils as an important methane sink, for example).
Given that most of the existing analyses comparing high-input systems with more sustainable
agricultural systems tend not to account fully for the manifold benefits agriculture can provide
(this applies particularly to grazing livestock), we recommend referencing other studies (see the
reference section) for a critical assessment of additional research to which the draft report should
refer.
From a methodological perspective, we agree that the analysis of challenges should be related to
the four broad categories of livestock systems identified in the report.
Another of our key concerns about the report is that it too readily accepts the conclusions of
earlier FAO and other reports without carefully scrutinising these from the specific perspectives of
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this report: food security and the role of livestock production. While the report pays lip service to
the issue of land degradation, it completely fails to recognise the extent to which this threatens
global food security and as a result fails to recognise adequately the extent to which many current
trends aimed at increasing productivity are through their negative impacts on soil carbon, soil
structure and soil erosion simultaneously reducing the potential for long term food security.
Our submission supports many aspects of the report but it also challenges a number of
fundamental points, which the authors appear to accept unquestioningly.
Main Points
1. We do not have a problem with the balance of the report, however we would like to see
the authors take a more questioning look at some of the issues they cover, including a number of
additional issues and refinements, as detailed below, then draw their key conclusions together
more into an integrated and meaningful vision for the future. As it stands the draft reports comes
over as a number of unconnected observations, some of which are at least partially contradictory.
2. Overall, the report acknowledges the importance of grasslands for rural livelihoods (page
32 lines 14-42; page 62, lines 32-42; Box n.8, 11,16), prevention of soil degradation and
improvement of soil fertility (page 52, lines 23-29; page 65 line 6-9). However, it fails to take these
issues into account adequately when comparing the sustainability of grazing livestock with the
sustainability of both grain-fed monogastics and grain-fed ruminants. We recommend that greater
emphasis should be given to the scale and significance for food security associated with existing
levels of land degradation. The authors are likely to be aware that a recent study calculated that
land degradation is already costing between $6.3 and 10.6 trillion dollars per year Stewart (2015).
We also feel that greater consideration should also be given to the potential contribution of
grassland, both permanent grassland and temporary grassland integrated with crop production,
to climate change mitigation. Furthermore, rather than simply relying on other reports, including
other FAO reports, the authors should take their own look at the science and the source data on a
number of key issues, including the accuracy and balance of widely quoted estimates of the
contribution of livestock to greenhouse gas emissions and the often overlooked, small, but
nevertheless significant value of the soils under undisturbed and unfertilised grassland as a
methane sink.
The authors assume that the 14.5% figure for the contribution made by livestock to greenhouse
gas (GHG) emissions, derived from FAO’s study (2013), represents the GHG emissions from
livestock “when accounting for all direct and indirect emissions along the production chain,
including land use change, feed production and transport” (page 8, line 49). However, in order to
develop policies to ensure food security and sustainable livestock production, GHG emissions
associated with land use change really need to be differentiated from those to do with land use
itself and considered separately, in order to ensure that GHG emissions associated with LUC are
accurately apportioned between crops and livestock and between crops for humans and crops for
livestock. This, in part, is because the FAO (2013) report looks at only one side of the LUC equation
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- the losses of carbon associated with the conversion of forest or savanna to food production - and
even this only incompletely.
The study, for example, considers emissions from land use change (LUC) only for Latin America
and the Caribbean, not for the US, the EU, Asia, Africa or anywhere else, and considers these
emissions only over a single recent decade (see page 106 of the report). This was also a period
during which rates of LUC from rain forest and the virgin and pastoral regions of the Brazilian
Cerrado were particularly high.
From the perspective of the loss of forest and virgin grassland to crop production and improved
grassland this is not particularly unreasonable since (unknown trends in Africa excepted) a high
proportion of such land use change was taking place in Latin America at the time. However, this
highly influential study gives no consideration to the losses of soil carbon and nitrogen when
existing agricultural grassland is converted to crop production, as is still happening in many parts
of the world (an opposite trend to the one taking place in Latin America when considering the
relative merits of grazing and grain-fed livestock), or the sequestration potential when cropland is
converted to grassland. Significantly it also fails to take any account of more historic, including
recent historic, LUC elsewhere in the world where conversion of grasslands and forest have
predominantly been for the cultivation of crops for direct human consumption, such as in
California, or where they have been predominantly for grain-fed beef production, such as in the
US mid-West. As a result the report fails to distinguish adequately between different production
systems, which could be encouraged or discouraged; and where it does make distinctions to a
limited extent, reaches in our view largely misguided conclusions because of its failures to take
into account a fuller picture of the multiple issues.
Drawing on the same study by the FAO, for example, the report argues that feed production
accounts for 45% of sector emissions (page 52, line 6). Yet, Van Middelaar et al. (2013) found that
excluding emissions from the conversion of grassland to cropland for feed production results in an
inaccurate estimation of GHG emissions from feed production in intensive livestock systems. In
particular, when converting grassland to cropland, emissions result from changes in soil carbon,
changes in above- and below- ground carbon, and changes in soil nitrogen (Van Middelaar et al.,
2013) - nitrogen which is lost as reactive nitrous oxide.
As a further example, the report gives no consideration to the loss of methanotrophic bacteria,
which takes place when both forest and grassland are converted to cropland or fertilised
grassland. Yet there is a substantial literature indicating that such changes effectively eliminate
these bacteria, which together across all soils constitute the soil methane sink Willison et al
(1995), Nazaries et al. (2013). At least one review, previously noted in an FAO report, Mers and
Rogers 2001 has downplayed the significance of the soil methane sink, however, our view is that
this is because the authors failed to recognise the extent to which the two key sinks where
methane is oxidised were able to keep atmospheric concentration broadly stable throughout most
of human history prior to the industrial revolution. Current estimates put the soil methane at only
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5% of the overall methane sink, but since methane levels in the atmosphere have been rising at
only 0.1% during the last decade whereas they were rising at about 1% during the 1970s IPCC
(2007), cited by Nazaries et al. (2013). Globally 37.6% of the total land area is in agricultural
production Roser 2015. However, much of that land is bare rock or desert. As a result it is likely
that more than 50% of the world’s fertile soils have already been converted to agriculture and that
a high proportion of these are being cultivated and/or receiving applications of ammonium-based
nitrogen fertilisers, the two actions which suppress methanotrophic bacteria.
As a result it can be argued that the reductions in the soil methane sink brought about by LUC and
changing agricultural practice on land producing crops to pigs, poultry and grain-fed beef could on
their own account for the increased atmospheric concentrations of methane in the atmosphere. In
this context we feel it is important to point out that while methane is, of course, a potent GHG and
IPCC may well underestimate this due to it’s relatively rapid breakdown a stable ruminant
population in extensive grass-based systems neither increases the total amount of methane in the
atmosphere, nor the total amount of carbon in the atmosphere, it simply recycles carbon fixed by
photosynthesis in the plants they eat, a proportion of this through methane, which breaks down
to carbon dioxide and water within 8-12 years. On the other hand methane lost to the atmosphere
during natural gas extraction or conversion to nitrogen fertiliser, and methane lost to the
atmosphere from coal production to provide power for nitrogen fertiliser manufacture, all
constitute additional amounts of methane and carbon added cumulatively to the atmosphere.
The reports argues that “extensively grazed ruminants are more GHG-intensive than other sources
of animal protein such as poultry, pigs or fish” (page 52, lines 16-18). While this is undoubtedly
true at a direct emissions levels, we believe that an analysis which included the historic LUC
emissions associated with the conversion of grasslands to croplands and the impact of this on the
soil methane sink would lead to different conclusions. Grassland soils are a significant store of
carbon, with global carbon stocks estimated at about 50% more than the amount stored in forests
globally (FAO, 2010). There is an interesting ongoing debate on this issue, with some researchers
arguing that grassland cannot continuously sequester large amounts of carbon (Falloon and Smith,
2002), and others claiming that grasslands have considerable potential to sequester additional
carbon and may continue to act as a carbon sink for up to 100 years (Poeplau et al. 2011), thereby
also contributing to climate change mitigation. A significant strand of the scientific literature
demonstrates that by making allowance for sequestration and storage, major GHG offsetting
occurs in low intensity grazing systems (see, for instance, Pelletier et al., 2010; Rotz et al., 2010).
In some parts of the draft report, it is claimed that the shift from ruminants to monogastric
animals, especially poultry, could help to reduce pressure on the need for additional land for
agriculture, improve productive efficiency needed to meet the expected increase in meat
consumption, and mitigate the sector’s emissions (page 62, lines 22-28; page 63, lines 25-27). Our
view is that grazing livestock at appropriate stocking density is central to the development of
sustainable food systems because of the paramount role of grass in reversing soil degradation and
rebuilding soil carbon and structure. In longterm studies at Rothamsted Research in the UK
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researchers have found that cropping systems inevitable lead to soil carbon loss, whereas the
conversion of cropland to grassland leads to soil carbon gains Johnston et al. (2009). As such we
feel great care needs to be taken when drawing conclusions on this issue, since the balance of
cropland and grassland and the potential (largely beneficial) changes that could result from a
better integration of arable cropping and grassland are also of central importance to other aspects
of food security. Studies have shown that mixed farming systems can provide a range of food and
non-food products, while helping to mitigate climate change. For example, a study by Strassburg
et al. (2014), demonstrated that improved use of cultivated pasturelands in Brazil would suffice to
meet demands for meat, crops, wood products and biofuel until at least 2040 without further
conversion of uncultivated land, while contributing to climate change mitigation by increasing soil
carbon levels. The paper includes suggestions on how to increase the productivity of pasturelands
– e.g. using improved fodder grass selection, incorporation of legumes, rotational grazing,
introduction of mixed systems, improved breed selection, reproductive management and earlier
slaughtering. We feel these issues should have been considered and discussed in Chapter 4 of the
draft report.
Given the authors’ assertion that intensity of grazing livestock is expected to increase (page 35,
line 21-23), it would be useful to see the possible pathways of intensification in the report – i.e the
author’s vision for how intensification can be achieved in a sustainable way. Lemaire et al. (2015)
show that there is significant potential in an integrated crop-livestock system, for grazing to be
intensified to a threshold level without harming the environment. Soussana and Lemaire (2014)
suggest that the discrepancy between environmental and production goals in mixed systems can
be significantly reduced by combining intensification with mitigation by using a range of options
including pasture restoration, deep-rooted grasses and grass-legume mixtures.
Despite the draft report’s claim to examine the linkages between the livestock and crop sectors
(page 18, line 30), the arguments and references in support of this claim are not made clear in the
report. We suggest that more recent references should be used and that the ideas related to (or
vision about) livestock and crop sectors linkages should be fleshed out in more detail. We also feel
the report must acknowledge and make clear to readers that the 14.5% figure for the contribution
of livestock to GHG emissions is an average global figure and when deciding what form of
agriculture will bring greatest food security and the most sustainable use of livestock, it needs to
be recognised that GHG emissions from different production systems, even with the same
livestock species, vary greatly between countries, between different regions and even between
different farms in some circumstances.
As an example, total GHG emissions in the UK associated with UK agriculture in 2013 (the most
recent year for which final figures) are available, account for 9.4% of UK GHG emissions,
Department of Energy & Climate Change (2015) However, despite some LUC in both directions on
different areas of land (i.e., some land converted to crop production, some returned from crop to
permanent grassland, some to forest) LUC resulted in a net 5% reduction of GHG emissions
meaning that taken together, as was done by the FAO for parts of Latin America in its 2013 report,
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net UK emissions were 4.4% for agriculture as a whole, not 14.5% just for livestock. These figures
do not include imported livestock feed or transport, whereas the FAO report does include these.
They also do not include the GHG emissions in other countries associated with the large quantities
of food imported for direct human consumption, However, hey do largely reflect the GHG
emissions associated with food production in the UK, and reason the Sustainable Food Trust sees
this as a major issue is because the FAO report (2013) effectively encourages the trend of
continuing increase in chicken consumption and continuing decrease in beef and sheep meat
consumption. This is borne out by consumption data, while a recent YouGov survey undertaken
for the Eating Better Alliance found that only 35% of the UK population is willing to consider
reducing meat consumption. As a result negative publicity about beef and sheep meat production
and consumption inevitably increases poultry (and sometimes pork) consumption. Yet the farming
of these species depends entirely on grain production, which is heavily dependent on nonrenewable resources, such as fertilisers and in some parts of the world, fossil water, and is a
primary cause of land degradation. The UK is ideally suited to grass production and much of its
farmland is suitable for no other form of food production, as such these distortions move the UK
further away from food self-sufficiency, increase dependence on imported meat, including chicken
from South America and Thailand, pork from Denmark, the Netherlands and Germany and beef
also from South America, generally reducing the sustainability of livestock production in the UK.
This is happening because the 14.5% from the FAO report is taken by most campaigners, policymakers and politicians to be an absolute figure, which applies universally, leading to a widespread
belief that while cattle and sheep numbers in the UK which have fallen in recent years anyway,
there is still a need for numbers to be reduced dramatically and that grassland should be ploughed
for crops. Indeed the net total area of grassland in the UK (including rough grazing) has fallen from
approximately 73% of UK farmland to approximately 66% of UK farmland within the last decade.
Despite this influential campaigners still use the 14.5% figure to urge still greater falls in ruminant
numbers and yet greater conversion of grassland to crop production in the UK, much of which is to
support increased consumption of grain-fed meat. Incredibly such arguments have even been
made in the Yorkshire Dales Yorkshire Post (2015), where the loss of grazing livestock would have
a severe negative impact on biodiversity, and the conversion of grassland to cropland would have
a severe long term negative impact on the landscape, the environment and the atmosphere,
We also need to point out that the FAO report, in common with many other reports, attributes a
high proportion of the LUC in relation to soya production in South America to livestock. While we
are not in favour of intensive livestock production systems based on grain and high protein use,
not least because of the negative human health impact of the associated ammonia emissions from
confined animal feeding operations, we nevertheless feel it necessary to point out that because
only a small percentage of soya protein is used for human consumption and because oil from soya
accounts for only a small percentage of the crop, there is a tendency for a high proportion of the
LUC associated with soya production in South America to be associated with livestock in studies
and reports which consider this issue. However, it should be noted that most of the soya oil (for
instance approximately 75% of US soya oil according to the USDA) is used for direct human
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consumption, while virtually all of the remainder is used for biodiesel, cosmetics and for minor
direct human-use products. Given the ever-growing demand for vegetable oils in general and the
huge environmental and biodiversity damage being caused by the increasing demand for palm oil,
it is probable that even if livestock were not consuming soya meal, demand for soya oil would not
significantly decline. All that would happen is that the price would increase greatly. We feel this
issue should be recognised in the report, even though we are not aware of anyone else making a
similar argument before.
There is also another dimension to this issue, which we feel must be recognised. A particularly
significant aspect of this is that it is widely understood that grazing livestock in drylands, on which
approximately 1 billion people depend for their subsistence, account for a disproportionately high
percentage of GHG emissions per kg of meat or litre of milk produced because the grass is of low
nutritional content and growth rates are very low. While there is considerable potential to
improve the quality of herbage and productivity through the introduction, in some areas at least,
of deep-rooting grasses and deep-rooting forage legumes, the retention of livestock in such
regions is absolutely vital since they provide a vastly higher degree of food security in such
situations than crop production, which can fail completely. There are however, two very different
but equally import issues, which need to be recognised in the report.
First, there is a tendency for pastoralist communities to be displaced by major development
projects, for example, in order to make way hydro-electric schemes and irrigated crop production.
One of the most recent of these has been the Gibe III dam on the Omo river in Ethiopia where
200,000 pastoralist tribes are likely to be affected Perry (2015a). While there are multiple factors
behind such developments, misguided concern about the methane emissions from animals in
pastoral systems strengthens the hands of those who push for such developments, which in the
case of Gibe III are expected to have a negative impact for up to 500,000 people when (literally)
downstream impacts are also considered. The fact that such developments are often not even
sustainable in the medium-term is demonstrated by study which found that on average 2,000
hectares of fertile land has been lost every day for the last 20 years due to soil salinization Qadir
(2014), much of it due to inappropriate irrigation programmes where high evaporation rates in hot
regions cause mineral salts to accumulate in top soils.
The second issue is that while the use of average global emissions, which include the significantly
higher than average GHG emissions per kilo of meat and litre of milk in the drylands provides a
good campaign tool to raise awareness about the need to moderate meat consumption overall, in
areas where emissions are actually much lower, this can lead to misguided changes in land use,
livestock populations and meat consumption which increase, rather than decrease, overall
emissions, whilst also having other deleterious effects on soil degradation and biodiversity, as
detailed above.
3. A more general criticism is that the draft report gives little consideration to the importance
of biodiversity for global food security, livelihoods and varied diets, as well as to the positive nexus
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between low intensity grazing livestock and biodiversity. Despite the framework including
biodiversity as a component of the agri-food systems (page 22), there are only a handful of general
references to biodiversity. Biodiversity should be explicitly addressed. This could be done in
Chapter 3 where the authors analyse all the components of agri-food systems. We recommend
inclusion of the following issues:
(a) Food security: there is general consensus on the nexus between biodiversity and food security,
see for instance Hoffmann (2011).
The authors of the draft HLPE claim that a shift from grazed ruminants to monogastrics would
result in a more sustainable livestock sector (page 52, lines 16-18), because grazed ruminants
are more GHG-intensive than poultry and pigs. In addition to our points above in relation to
the soil methane sink, land degradation and the fact that there are large regional variations in
the actual emissions when more complete data on LUC is taken into account, we suggest a
broader view is needed on food security and sustainability, beyond the single focus on
reducing direct GHG emissions. In particular, it should be considered that the current shift
towards more intensive agricultural systems based on poultry and pigs favours international
transboundary breeds and leads to a loss of local breeds and a narrowing of the gene pool
which could at some point in future become of particular importance, should a new disease or
disease strain develop, to which currently popular breeds are vulnerable. Diversity in livestock
breeds is also needed to reduce the impact of existing disease pressures and to maintain a
gene pool which could be of invaluable use to breeders in years to come for a wide range of
reasons. This trend towards only high productivity animals from a narrow range of breeds also
negatively affects variability in human diets and food security, resilience and rural livelihoods
(Hoffmann and Baumung, 2013).
(b) The positive impacts of low intensity grazing systems on biodiversity, including the symbiotic
relationships between grazing livestock and wildlife, and wildlife dependence on grazing
animals and the grassland they graze (Stoate et al., 2009).
Importantly, unimproved flower-rich grasslands play a crucial role for many bumblebees
species. This has major significance for food security since wild pollinators, especially
bumblebees are more important for the pollination of certain food crops than honeybees.
Some of them also have an extremely short foraging range. Goulson et al. (2005) found that
the decline of many bumblebees species can be ascribed to the decrease in unimproved
flower-rich grasslands. They show that the decline of bumblebees in the UK is especially
related to late emerging species which are critically short of nectar and pollen sources from
late May onwards, after the major commodity crops such as oilseed rape have flowered. These
species have specialized diets and mainly feed on Fabaceae, in particular T. pretense and L.
corniculatus, species associated with unimproved grassland. Consistently, Carvell et al. (2006)
confirm that he decline of pollinators is associated with the switch from hay meadows to
silage, and from species characteristic of less fertile, semi-natural habitats, such as calcareous
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grassland, to fertile habitats. Woodcock et al. (2014) showed that the presence of legumes and
forbs also increase the provision of flowering heads for insect pollinators. This is particularly
interesting in relation to sustainable agricultural development and the role of livestock, since
the increased use of legumes in grassland also has the potential to maintain productivity while
replacing nitrogen fertiliser, something which would bring significant savings in relation to the
GHG emissions associated nitrogen fertilizer production, grassland management and it would
also eliminate the ammonia emissions associated with the direct volatilisation of ammoniumbased fertilisers.
4. Other components of natural capital the report should consider include: fossil fuels,
especially natural gas used as the feedstock for nitrogen fertilisers, reserves of finite minerals,
especially phosphate-rich rocks, fossil water used for the irrigation of commodity crops such as
corn and soya, which are then fed to intensively housed livestock, antimicrobials and soil biological
and microbiological life.
Global reserves of fossil fuels have been estimated to be 35, 107 and 37 years respectively for oil,
coal and natural gas by Shafiee and Topal (2009), and 53, 109 and 54 years respectively by a major
oil company BP (2015). However, these figures are based on 100% of reserves being extracted and
some authors have doubted the feasibility of this due to the technical challenges and concerns
about climate change. While further reserves will undoubtedly be discovered, usage rates are
expected to increase, suggesting that within as little as few decades reserves of oil and natural gas
could become a limiting factor in food production.
Studies conducted in China, the largest mineral phosphorous fertiliser consumer in the world, in
pig and dairy production sectors, demonstrate that intensive systems have a lower phosphorus
use efficiency than traditional or grassland based systems (Bai et al., 2013; Bai et al., 2015). There
is still considerable uncertainty about how long phosphate reserves will last and what proportion
of these can technically and economically be extracted. However, there is widespread recognition
that reserves are finite and that a supply gap for phosphorous could occur during the present
century, Rhodes (2013).
Fossil water reserves in the US, especially the Ogallala aquifer and fossil water reserves in parts of
the Middle East and India and elsewhere have been extracted at rates well in excess of their
replenishment rates, resulting in the abandonment of crop production in some regions. In
addition, increasing drought in many parts of the world is leading to reduced yields, unsustainable
use of ground water resources and abandonment of food production entirely in some cases.
Drought is currently having a severe effect in nine regions globally and land degradation which
involves the loss of soil organic matter, principally as carbon and nitrogen reduces the water
holding capacity of soils and also increases the vulnerability to erosion from heavy rain, Perry
(2015b).
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There is widespread recognition that antimicrobial resistance is becoming a global problem. No
major new families of broad spectrum or Gram-negative antimicrobials have been developed since
the carbapenems in the mid-1980s. Antimicrobials are predominantly developed from naturally
occurring soil bacteria and fungi, but we have already exploited all the most easily cultured
microorganisms, which is why no major new classes have been developed recently. Arguably ‘peak
antibiotics’ occurred in the mid-1960s, though this was not recognised at the time. The
significance of this is all sectors need t use antimicrobials extremely sparingly to reduce the
potential for further large rises in antimicrobial resistance before new and completely unrelated
classes of antimicrobials can be developed. At a policy levels the easiest way to achieve this in
agriculture would be to reduce the number pigs and poultry kept and increase the number of
cattle and sheep because pigs and poultry accounts for a very high proportion of all farm
antimicrobials usage, whereas use in grazing animals, such as cattle and sheep is much lower in
comparison, Nunan and Young (2015)
It is estimated that 25% of all biodiversity on the planet is underground in the soil. With the aid of
new techniques currently under development for culturing the estimated 97% of soil
microorganisms which previously could not be cultured there is a vast potential store for the
development of new antimicrobials, anthelmintics and other medications. Yet there is a large body
of evidence to show that the use of ammonium-based nitrogen has a major detrimental impact on
soil bacteria and radically alters population densities, and the use of water-soluble phosphates has
a similar impact on soil mycorrhizal fungi, which are critically important for a healthy soil and the
uptake of nutrients by plant roots. In addition, evidence shows that some herbicides can also
causes changes in soil chemistry and microbiology.
5. The report includes relevant references to human health impacts, in particular in relation
to the importance of animal protein in human diets (page 8, lines 31-37; page 17, lines 38-48; page
28, lines 15-22), food-borne diseases, animal and human diseases and antimicrobial resistance
(page 55-58).
In several parts of the report, it is claimed that white meat is healthier than red meat (page 28,
lines 22-24; page 68, lines 2-6). We suggest that this widely held belief be reconsidered and
revised, since the most compelling evidence of harm is associated only with processed red meat
and the small statistical association between red meat overall and cancer does not distinguish
between the production methods of the meat, leaving open the possibility that it may be changes
in the make up of meat, in terms of fatty acid provides, minerals and anti-oxidants associated with
grain-fed meat production which may be prime cause poor health outcomes which are attributed
to all red meat without evidence. It is also of note that cancer levels in many developed counties
are rising, while red meat consumption is falling. McAfee et al. (2010) suggest that consumption of
lean red meat as part of a balanced diet is unlikely to increase risk for cardiovascular disease or
cancer, but might positively influence nutrient intakes and fatty acid profiles. Interestingly,
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concentrations of long chain n-3 polyunsaturated fatty acids, which have many positive health
impacts, are much higher in meat from ruminants produced on grass-based systems compared
with ruminants produced in intensive concentrate feeding systems (Ponnampalam et al. 2006;
Nuernberg et al. 2005), A more extensive and helpful paper on this issue, Daley et al. (2010)
reviews the significance of the fatty acid and other micronutrient profiles of beef from 7 studies
which compared grass-fed and grain-fed meat.
Richard Young with Stefano Orsini, Sustainable Food Trust, Bristol.
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