Feed_back_form_SFS_EN comments by Compassion in World Farming

Please use this form to provide your general and more specific comments as indicated
below, for the proposed 10YFP Sustainable Food Systems draft concept note.
NB** all contributions received will be taken into account as much as possible. Due to limited capacity, we
will unfortunately not be in a position to inform respondents (individuals &/or organizations) on how their
suggestions have or have not been included in the final programme that will be submitted to the 10YFP
secretariat. Thank you for your understanding.
Name and Title
Peter Stevenson
Compassion in World Farming
Chief Policy Advisor
Type: NGO
Local authority
University/ Scientific/Research
Business organization
X NGO or not-for-profit
Financial Institution
Other (please specify):
Regional Organisation
National Cleaner Production Centre (NCPC)
Primary Producers Organization (e.g. farmers,
pastoralists, fisherfolk)
Indigenous group or community based
Inter-governmental organization
United Nations agency or programme
Mailing address
[email protected]
River Court, Mill Lane, Godalming, GU7 1EZ, UK
Telephone +447765844623
Country UK
Instructions: Please provide your feedback for each of the proposed questions on the Sustainable Food
Systems Programme by completing the following matrix. If you do not have any comments please check
the “No comment” box.
General “Sustainable Food Systems” Programme Feedback
Feedback Question
Select One
Provide Your Additional Comments
Having reviewed the draft Concept
Note, does it adequately identify the
X No
main global challenges for
sustainable food systems?
Much in the Note is welcome and helpful. However, it gives
insufficient attention to:
1. The detrimental impact on health of Western diets, in particular
their contribution to high levels of non-communicable disease. The
SFSP should discourage the adoption of Western diets in
developing countries while promoting diets of high nutritional
2. The need to promote food systems that minimise water use and
pollution, nitrogen emissions, land use (especially arable land use),
deforestation and climate change. Also, SFSP should encourage
systems that restore biodiversity (at landscape, farm, soil & seed
levels) and build soil quality.
3. Animal welfare and health. Unhealthy animals can spread
disease. Standards of animal welfare should at least reach the
international OIE standards and those of the International Finance
Corporation’s Good Practice Note on Improving Animal Welfare in
Livestock Operations
Having reviewed the proposed
They are too broadly worded and are open to a wide range of
Vision and Goal, do they adequately X
address the needs of the global
Having reviewed the proposed
objectives, do they adequately
address the needs of the global
interpretations. This would not be a major problem if the concept
note as a whole articulated a clear sense of what kind of production
approaches and consumption patterns are sustainable. However,
the note does not provide a sufficient understanding of what is and
is not sustainable and which factors should be taken into account in
assessing sustainability.
The objectives are not really objectives but tools for achieving
objectives. The objectives themselves have not really been
formulated. For example, ‘raising awareness’ (objective 1) and
‘disseminating information’ (objective 3) are not objectives in
themselves but means of achieving objectives. I have set out
below what I think the fundamental objectives of a sustainable food
system should be.
Provide Your Feedback
Programme Objectives
Programme Objective 1: Raise
awareness on the need to shift to
sustainable food systems and applying
a systems approach to addressing
No Comment
Suggested Text Change
Additional Feedback
(check the box)
(Please insert your text)
(Please insert your text)
Raise awareness on the need to
shift to sustainable food
systems and applying a
systems approach to
addressing food security and
Programme Objectives
Provide Your Feedback
food security and nutrition.
nutrition. Awareness should
also be raised as to what kinds
of farming and food systems
are sustainable.
Programme Objective 2: Build
capacity and enabling conditions for
the uptake of sustainable practices
across food systems and facilitate
access to financial and technical
The developing world is under
pressure to adopt industrial
agriculture. This would
undermine smallholder
livelihoods and soil, water and
biodiversity. Emphasis must be
given to identifying farming
practices that are appropriate
for boosting the productivity of
small farmers e.g. improved
health and nutrition for their
livestock and increasing crop
yields through enhancing soil’s
water retention capacity, the
use of nitrogen-fixing plants
and trees and integrated pest
Programme Objective 3: Take
stock of, categorize and disseminate –
and if needed develop – accessible and
actionable information tools and
methodologies to support governments,
Programme Objectives
Provide Your Feedback
the private sector, consumers and other
relevant stakeholders to act towards
more sustainable food systems.
Programme Objective 4: Bring
together initiatives and develop
partnerships to build synergies and
cooperation to leverage resources
towards the mutual goal of
promoting, enhancing and facilitating
the shift towards more sustainable
food systems
Feedback Question
Are there additional fundamental
objectives that the programme
should respond to in your view?
Select One
Provide Your Additional Comments
It should respond to the following additional fundamental
 Food security
 Provision of food of high nutritional quality
 Promotion of diets that support good health
 Resource efficiency: efficient use of food and the resources
used to produce it
 Enhancement of soil quality and judicious use of arable land
 Use water sparingly without polluting it
 Restoration of biodiversity and ecosystem services
 Sustainable consumption
Having reviewed the proposed
work areas, do they adequately
address the needs of the global
Minimisation of food-related greenhouse gas emissions
Good standards of animal welfare
Provide Your Feedback
Programme Work Areas
Programme Work Area 1: Increase
the availability, accessibility and sharing
of actionable knowledge, information and
tools for SCP.
No Comment
Suggested Text Change
Additional Feedback
(check the box)
(Please insert your text)
(Please insert your text)
This should include
dissemination of information on
the resource-inefficiency of
industrial livestock production.
This inefficiency stems from its
dependence on feeding
human-edible cereals to
animals. Studies show that for
every 100 calories fed to
animals in the form of humanedible crops, we receive on
average just 17-30 calories in
the form of meat and milk. i A
FAO report points out that the
feeding of cereals to livestock
Programme Work Areas
Programme Work Area 2:
Encourage, facilitate and support
inclusive multi-stakeholder dialogue to
help inform interconnected policymaking
towards sustainable food systems at
local, national, regional and international
Provide Your Feedback
capacity building provision to
governments and policy makers
to facilitate:
(i) the sustainable management of
natural biological processes to
increase efficiencies for
sustainable intensification
provided that this does not
undermine natural resources or
animal welfare;
(ii) the uptake of new
technologies for production,
processing, and for the mitigation
of negative externalities while
recognising that negative
could threaten food security by
reducing the grain available for
human consumption.ii The use
of cereals as animal feed is a
wasteful use not just of the
crops but of the land, water
and energy used to produce
them. In contrast to this the
following forms of livestock
production are efficient: raising
animals on pastures and using
crop residues, by-products and
unavoidable food waste as
animal feed.
(i) In the West further
intensification of farming (which
is already highly industrialised)
would not be sustainable. It
would undermine the natural
resources – soil, water,
biodiversity – on which the ability
of future generations to feed
themselves depends.
In the developing world
increased crop yields (e.g.
through agro-forestry and wáter
harvesting) and livestock
productivity (e.g. through
Programme Work Areas
Provide Your Feedback
externalities are best addressed
by farming that works in harmony
with natural resources rather than
by high-tech;
Programme Work Area 3: Facilitate
the use and enhance opportunities for
market-based and/or voluntary
approaches throughout supply chain
towards sustainable food systems.
Facilitate the use and enhance
opportunities for market-based
and/or voluntary approaches
throughout supply chain towards
sustainable food systems
including giving consumers
information about the health,
environmental and animal
welfare implications of their
dietary choices.
improved health and nutrition)
are possible. However, the term
‘sustainable intensification’
should not be used to justify the
further expansion of industrial
(ii) Many food system negative
externalities (e.g. water and air
pollution; biodiversity erosion)
stem from industrial agriculture.
It is inappropriate to use hightech to solve the problems caused
by high-tech. Instead negative
externalities should be addressed
by adopting farming methods that
produce positive rather than
negative externalities.
If food consumption is to be
sustainable, consumers must be
given information regarding the
fact that certain diets, in
particular those with a high
proportion of animal products,
have a larger negative impact on
natural resources and produce
more greenhouse gas emissions
than other diets.iii iv
Programme Work Areas
Provide Your Feedback
Studies show that a reduction in
Western consumption of animal
products would also produce
important health benefits.v vi
Feedback Question
Are there other work areas you
think should have priority, if so,
Can you propose priority activities
under the Work Areas, if so, what?
Select One
Provide Your Additional Comments
The concept of ‘food waste’ should be extended to include the feeding of
human-edible cereals to animals. Globally 36% of cereals are used as
animal feed.vii However, as indicated earlier, only 17-30% of these
calories are returned for human consumption as meat or milk. The effect
of this is that 70-83% of the 36% of the world’s crop calories that are
used as animal feed are wasted; they produce no food for humans. This
means that 25-30% (70-83% of 36%) of the world’s crop calories are
being wasted by being fed to animals.
Other Feedback on the document
Line Number
Provide Your Feedback
Line Number
Provide Your Feedback
We must be careful about what is entailed in saying that food systems “have to become more efficient in their
use of resources”. For example, at first sight the use of monocultures and chemical fertilisers appears to be
efficient in boosting yields. However, in the medium-term they can erode biodiversity and soil quality. A recent
study concludes that “modern agriculture, in seeking to maximize yields ... has caused loss of soil organic carbon
and compaction, impairing critical regulating and supporting ecosystem services”.viii Similarly, industrial livestock
production may appear efficient. However, its dependence on using grain as animal feed (which animals convert
very inefficiently into meat and milk) means that it generally uses more arable land and pollutes and uses more
ground- and surface-water than pasture and integrated crop-livestock systems.
Nellemann, C., MacDevette, M., Manders, et al. (2009) The environmental food crisis – The environment’s role in averting future food crises. A UNEP rapid
response assessment. United Nations Environment Programme, GRID-Arendal, www.unep.org/pdf/foodcrisis_lores.pdf
Gerber, P, 2013. Tackling climate change through livestock – A global assessment of emissions and mitigation
opportunities. Food and Agriculture Organization of the United Nations (FAO), Rome.
Westhoek H et al, 2014. Food choices, health and environment: Effects of cutting Europe’s meat and dairy intake. Global Environmental Change, Vol 26, May
2014 p196-205. http://www.sciencedirect.com/science/article/pii/S0959378014000338
Bajželj B. Et al, 2014. Importance of food-demand management for climate mitigation. Nature Climate Change
Green R et al, 2015. The potential to reduce greenhouse gas emissions in the UK through healthy and realistic dietary change. Climatic Change (2015)
129:253–265 DOI 10.1007/s10584-015-1329-y
Cassidy E.M et al, 2013. Redefining agricultural yields: from tonnes to people nourished per hectare. University of Minnesota. Environ. Res. Lett. 8 (2013)
Edmondson et al, 2014. Urban cultivation in allotments maintains soil qualities adversely affected by conventional agriculture. Journal of Applied Ecology 2014, 51, 880–
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