المنتدى العالمي المعني بالأمن الغذائي والتغذية

Dear Sir or Madam,

we thank you for having the opportunity to contribute to your online consultation on the voluntary guidelines for sustainable soil management.

Here are our comments and suggestions:

It would be very helpful to specify the stakeholders to which the guidelines will be addressed. To address governments and other institutions will not be sufficient in our opinion.

We think that it is necessary and important to identify and adress multipliers which are close to farmers and farmers associations, e.g. food business, food standards, consumer organisations, environmental NGOs.

3.2         Non-tillage and conservation agriculture is mentioned as a good practice with multiple environmental benefits. It shoul be added this practice is only sustainable if it is combined with other practices, especially cover crops and longterm crop rotation. If not, non tillage can lead to a massive use of herbicides and fungicides.

3.4         It should be clearly stated that a nitrogen balance should be the decision tool to ensure an appropriate nutrient management. Farmers should at least try a rough approximation to its calculation based on realistic yields and baseline information on the crop.

3.5          We recommend to include appropriate training for using pesticides. Also that soil disinfection shall be banned (and alternative solutions used such as diverse and long rotation).

3.7.         We  recommend to include a comment for enhancing the use of decision-support tools for better irrigation (tensiometers, software, etc.).

4.0         We don`t understand the use of the term “Sustainable Intensification” and recommend to better use a term like e.g. “ “efficient management for better yields”.

Furthermore we recommend to include the following aspects into the guidelines:

- recommendations for governments to deliver to multipliers soil maps as a basis for agricultural decision

- recommendation for having records of soil operations, as a training methodology for continuous improvement

- recommendation on regular soil analysis as a baseline for decision-making in terms of fertilization (farm-gate-balance)

- promoting the use of legumes for cover crops, crop rotations, winter crops, catch crops, intercrops, etc.

- continuous training for understanding agricultural soils

Kind regards

Patrick Trötschler

Bodensee-Stiftung

Dipl.-Ing. agr. Patrick Trötschler

stellv. Geschäftsführer

Fritz-Reichle-Ring 4

Dear moderator

Please find below the comments from Fundación Global Nature (Spain) to the Online consultation for developing the Voluntary Guidelines for Sustainable Soil Management. Apologies for not addressing specifically the questions included in your invitation, but we think that our comments would better contribute to the improvement of the draft. Here is our contribution:

In general terms (but also specifically for point 5.0), we miss a part in the text for identifying the stakeholders to which these guidelines are addressed. It is stated that these guidelines shall be generalist, non specific to crops or regions, etc., as all this require a multi-scale assessment and further work. These guidelines are said to be addressed to governments and other institutions. In our opinion, a higher effort should be made in the document to identify “multipliers", that is, stakeholders on the ground that could potentially reach farmers and farmer communities (let's not forget that farmers are the responsible for implementing all this) to spread this document. At least defining their profile would be interesting. We are pretty sure NGOs, consumers and society-based organizations would fit these requirements and would be happy to contribute. Agrifood companies could be addressed and for most of them, it could be a good inspiration.

Point 3.1. We think a much more emphasis should be placed to highlight the importance of suburban agricultural areas. At least in the Mediterranean basin, the best soils are beside rivers where cities have been historically located. Urban growing has sealed these soils forever, leaving the worst soils for agriculture. The problem is somehow stated but no practical recommendations are given (urban land planning according to soil relevance, longterm strategies to preserve and/or restore soils, agricultural areas included inside cities, etc.)

Point 3.2. Non-tillage and conservation agriculture is mentioned as a good practice with multiple environmental benefits. However, it should be stated that this practice is only sustainable if it is combined with other practices, specifically cover crops and longterm rotations. Otherwise, non-tillage techniques lead to a massive use of herbicides and fungicides.

Point 3.4. It should be clearly stated that a nitrogen balance should be the appropriate decision tool to ensure an appropriate nutrient management. Farmers should at least try a rough approximation to its calculation based on realistic yields and baseline information on the crop.

Point 3.5. We would go further and include that appropriate training shall exist for using pesticides. Also that soil disinfection shall be banned (and alternative solutions used such as diverse and long rotation).

Point 3.7. We would recommend to include a comment for enhancing the use of decision-support tools for better irrigation (tensiometric probes and similar equipment, software, etc.)

Finally there is a point with which we disagree: in 4.0 there is a whole section devoted to “Sustainable Intensification”. The fact is that all what is mentioned in section 4.0 is a repetition of the good practices mentioned before, that leads to a better management of the soils, and obviously to a better yield thanks to reduction of risks: erosion, pests, soil depletion, nutrient excess, loss of soil structure. Therefore, the use of “intensification” is completely unnecessary and the word “efficient management for better yields” or “competitive and friendly agriculture” is much more appropriated. However this section is directly linked to a document approved before… so we are not sure if it makes much sense to come into this aspect.

We also miss the following points:

- recommendations for governments to deliver to multipliers soil maps as a basis for agricultural decision

- recommendation for having records of soil operations, as a training methodology for continuous improvement

- recommendation on regular soil analysis as a baseline for decision-making in terms of fertilization

- promoting the use of legumes for cover crops, crop rotations, winter crops, catch crops, intercrops, etc.

- conduct regular soil machinery maintenance for better performance

- continuous training for understanding agricultural soils

For further details and/or comments, please do not hesitate to contact us.

Cheers,

Jordi Domingo Calabuig

Fundación Global Nature

C/ Real, 48. Las Rozas (Madrid)

E-28231 Spain

www.fundacionglobalnature.org

Thank you for the opportunity to comment on the Global Soil Partnership’s draft Voluntary Guidelines for Sustainable Soil Management.  I applaud the breadth of expertise and effort that has gone into its preparation.  The ITPS has produced a useful set of guiding principles to inform and encourage farmers, public policy makers and private stakeholders to restore and steward our planet’s soils.

However, as the major objective of the VGSSM is “to promote and support the global adoption of sustainable soil practices”; I believe these Guidelines should be much more direct in advocating actionable practices appropriate to local conditions and circumstances that enable field-to-landscape scaled soil stewardship.  Although the draft VGSSM presents an extensive list of soil functions and processes; it fails to provide cohesive propositions and integrated practice examples that could guide decision making by farmers, input suppliers and public policy makers.

More discussion is needed of the soil building benefits of diversified crop rotations that deliver organic carbon inputs; biological nitrogen fixation; weed management; root penetration of compacted soils; pest pressure disruption; and other supportive functions.  Attention should be given to advancing private sector and public policy initiatives that would develop local, regional and national capacities for producing varietal seeds; reduced tillage and direct seeding mechanical equipment; large volume organic composting; and supplying other farming system resources and technical support services.

While beneficial soil microbes and fungi are briefly mentioned in the draft VGSSM; there should be much more discussion of the importance of establishing healthy soil biota through crop residue retention; inoculating seed and soil with beneficial microbial and fungal treatments; and measures that promote the production of Glomalin and other exudates that enrich soil tilth and structure.  The Guidelines should also draw attention to the value of increased research in the fields of beneficial soil biota and their symbiotic interrelationships that promote plant growth and improved resilience.  Global agricultural research efforts significantly focus on developing improved commodity crops; with extremely limited research underway to discover and leverage the biological dynamics of soil fertility and microfauna biodiversity.  This research imbalance must be corrected.

The GSP aspires to promote soil management practices that contribute to achieving the UN’s Sustainable Development Goals concerning food security, ecological balance and improved social and economic equity.  These important additional dimensions of beneficial outcomes of soil management would be advanced if the Guidelines acknowledged and recommended practices and implementation strategies that are particularly applicable to smallholder farmers; promote rural development; and advance reliance on sustainably sourced soil nutrients and other agronomic resources.

The VGSSM should explicitly promote soil management actions that encourage formation of rural enterprises that supply sustainably sourced inputs or convert and recycle organic wastes into restorative soil amendments and nutrients.  It would also be useful to recognize and advocate innovative agricultural and land use policies that provide incentives to invest in improved soil management; or that regulate practices that damage or degrade soils or diminish fresh water availability and quality.

The Guidelines should also more clearly describe and encourage practices and technologies that enable soil carbon and biochar sequestration to be implemented as high potential measures for reducing Greenhouse Gas levels (e.g. see Dr. Pete Smith’s recent paper in Global Change Biology, 2016).  As nations struggle to adapt to climate change and reduce their GHG emissions; it is critically important that the global community develop and implement agricultural practices that reduce emissions while increasing productivity and resiliency.  Sustainable soil management and organic carbon sequestration pathways should be included in national climate action plans.  The Guidelines should help increase public awareness of these cost effective GHG mitigation opportunities.

I hope that my comments are useful to further strengthen and improve the utility and impact of the Voluntary Guidelines for Sustainable Soil Management. 

With best regards,

Patrick Binns

Westbrook Associates LLC

Seattle, WA   USA

Dear Sir,

Apology for responding late to the content of the above subject.

The guidelines are comprehensive addressing critical concerns to sustainable soil management.

My fear is that it mentions little on the direction of research in soil  management., Concerns of research are that there is little investment by some countries on the same; and where it is financed it is enterprise and not farm system based. 

Secondly on conservation and or rehabilitation of soils at watershed level,   some funds are required to demonstrate and or establish physical soil and water conservation structures, a practice that is labour intensive. Most interventions at such a scale ignore financing such activities. 

I would thus be happy to see aspects like;

Research

Research on soil management should be participatory and recognize components of the farm system so as to come out with information that may not impede adoption of technologies promoted

Financing 

Governments and or private sector should invest in practices that are labor intensive 

Gender experts may be consulted to enrich on extension information/technologies that may not be gender sensitive.

Thank you

Peter 

Dear colleagues,

Thanks for inviting us to participate in the public consultation on the voluntary guidelines sustainable soil management. This topic is particular relevance in the current context and we are welcoming any initiative targeting solutions for more efficient soil management approaches.

The Common Forum on Contaminated Land (www.commonforum.eu) is a network organisation of policy-makers and regulators, created in 1993, from National government and agencies from 18 European Member States who are dealing with contaminated land and groundwater Issues, and for some of them with land management as a whole. The Common Forum has the following missions:

• being a platform for exchange of knowledge and experiences, for initiating and following-up of international projects among members,
• establishing a discussion platform on policy, research, technical and managerial concepts of contaminated land.

Since its creation in 1993, Common Forum gained a formal status as initiators of new concepts for redevelopment contaminated sites and brownfields such as the Risk Based Land Management concept (2000). Common Forum members are also partners of the International Committee on Contaminated Land (www.iccl.ch).

The proposed draft guidelines seem to address several stakeholder communities (“p.3 - policy developers, government officials, extension officers, farmer associations, private investors and others”).

• They have been developed in the context of the UN SDGs which have been adopted in September 2015 and will have to be implemented by all signing country partners.
• The different levels of actions are not clearly identified and therefore it could be challenging for a successful implementation even on a voluntary basis. The connection to existing policies should be at least mentioned when existing.
• The different targeted stakeholder communities are acting at different decision-making level (from governmental to local – parcel levels). Clear responsibility / roles are key for a successful implementation.

The draft references the definition of the revised World Soil Charter (see chapter 2.1, p.4). This definition explicitly provides a focus on ecosystem services. This might be understood as limiting the term “sustainable” to ecological considerations. Therefore it could be helpful to provide some lines (or a note) for explaining the connection to a generally accepted definition of “sustainable development” (e.g. Brundtland report) aiming on the integration of the ecological, economic and social dimension (see also three P’s: people, planet and profit).

To underpin the importance of appropriate soil and land management as addressed by chapter 2.2, it could be worth to consider a report published by the ELD initiative (www.eld-initiative.org) on the economics of land degradation, its Summary of Findings and the estimate that “Globally, annual ecosystem service value losses of USD 6.3 to 10.5 trillion occur, representing 10-17 per cent of the world’s GDP and highlighting the importance of combating land degradation”

As mentioned by our Dutch colleagues, the soil-sediment-water system (vs. the application to sustainable soil management in agricultural areas) needs an integrated approach:

• This system is more complex and need more than a soil sectoral approach. Agricultural production and food & feed security are also depending on the water resources availability. Groundwater use in urban areas might have an influence in agricultural areas and vice-versa.
• Managing the “transition areas” with the agricultural areas (peri-urban areas) is also a key challenge. Our experiences at national and regional levels have shown the limits of acting with a sectoral approach.
• So that’s why we consider that the document should not be limited to rural areas and should also address the different geographical dimensions to consider in soil & land management. There are needs and key actors at local, catchment / river basin, regional, national, Europe / large world regions scales. Not considering the broader perspective could generate more challenges in the implementation of the guidelines.[1]

Considering the time dimension in sustainable use of land also with regard to global and perspective changes in societal expectations, not really developed in the proposed guidelines, is also fundamental in terms of efficient management of this system.

The draft guidelines describe processes in a qualified matter for (national / regional) policy-makers. But we are missing the connections to the existing policy instruments which are used by the stakeholders.

• The link between agriculture and the reduction of the effects of climate change is important and could be more emphasized.  Farmers play a role in climate change Policy (reduction of GHG emissions and carbon storage in soils). The current draft guidelines are not designed for being operational for farmers.
• For policy-makers, how to combine “mandatory policy instruments” with this “voluntary guidelines” will also be critical.

In most countries having a soil / land protection or soil / land pollution policy, there is a distinction between: i) prevention of new threats (protection issues), ii) new threat situations and iii) legacy threat situations.

• This is why the first policy principle is prevention (avoidance, mitigation or at least limitation to minimum impact).
• For new threat, in particular pollution, the principle is zero tolerance. If any damage, it should be recovered immediately.
• For legacy contamination the approach is risk based and not a multifunctional remediation. The starting point is that the quality of the land should be suitable for the function and use(s) of the land.
• This can only be achieved by integrated approaches, which link the statutory regulations for industries and agriculture, with environmental media protection (e. g. water soil air) and the environmental damage regulations in a more consistent way.

Accordingly we suggest the following amendments (set italic) with regard to chapter 3.8 (Guidelines for neutralization of soil contamination):

• Local soil contamination caused by nowadays economic activities and production processes asks for a complementary approach on prevention and contingency plans for immediate clean-up.
• Management of local soil contamination as a legacy of abandoned activities and production processes requires surveys to seek out sites that are likely to be significantly contaminated, site investigations where the actual extent of contamination and its human and environmental impacts are defined, and identification of a suitable management approach, in particular remedial and after-care measures rehabilitating sites for beneficial use. Soils that are susceptible to the harmful effects of diffuse pollutants (e.g. acidification due to atmospheric deposition on highly weathered ancient soils) should be identified and special measures on a local scale undertaken to reduce atmospheric deposition of pollutants onto these soils.

Finally, an important dimension is missing: the costs for implementing such guidelines are not mentioned. This is a critical question in particular if the sustainability principle should apply: a balance between the three P’s of people, planet and profit. The starting point is to use land in a sustainable way and not only the focus on soil preservation and prevention.

If any question or need for clarification, please do not hesitate to contact us.

Dominique DARMENDRAIL Common Forum General Secretary

Dear Colleague,

Thank you inviting us to contribute to the online consultation for the development of the Voluntary Guidelines for Sustainable Soil Management.

Please find enclosed the combined response of Soil Cares Research and the Nutrient Management Institute, both in Wageningen, the Netherlands.

A major point from us is that farmers should have access to reliable and affordable soil analysis techniques on which they can decide which fertilizers and/or lime are to be used.

Best wishes with your future activities and we are looking forward to hearing from you.

Kind regards,

Marjoleine Hanegraaf

http://www.soilcares.com/en/research/

Marjoleine C. Hanegraaf

Soil Scientist

Nutrient Management Institute NMI BV

Dear Moderators,

In my view, the authors of the voluntary guideline have done a good job: they combined existing and binding policy documents with the state-of-the-art of science on soil protection and distilled a set of rules and procedures which can be applied in any agricultural production systems to ensure sustainable soil management. The questions that prompted the consultation can be positively answered with good conscience.

The scope of the presented work includes: „The guidelines will focus on technical and biological aspects …..” From this standpoint, the normative nature of the proposal is understandable: all soil degradation processes are equally important everywhere on earth. Although I can gladly accept this starting point, I still agree with many of the contributors who emphasize the importance of social aspects.   

The 4th principle of the revised World Soil Charter says: „The implementation of soil management decisions is typically made locally and occurs within widely differing socio-economic contexts. The development of specific measures appropriate for adoption by local decision-makers often requires multi-level, interdisciplinary initiatives by many stakeholders. A strong commitment to including local and indigenous knowledge is critical.”

Any soil threats except contamination with man-made organic compounds produced by the chemical industry have both natural and human induced causes. Even such events like pollution with crude oil, heavy metals or radionuclides have their natural parallels: tar sand or ores with high radionuclide or heavy metal content may occur at or near to the land surface posing imminent effect on the ecosystem including humans. Other soil degradation processes (acidification, salinization) are mainly natural phenomena and involve millions of hectares of  agricultural land. Water erosion has always been present on slopes in areas with some precipitation nevertheless, human activity increased it by several magnitudes.

Societies and local communities have existed in the vicinity of these soil degradation processes for long and people have learned how to cope with the harmful effects. Communities have developed certain sensitivity and a certain tolerance to those threats. However, societal and economic driving forces have changed the whole game: intensity of soil degradation processes have been altered but tolerance and sensitivity of the societies have changed, too. In my view, this framework should be comprehensively understood to formulate proper policy targets.

What hurts and why?  - this question should be answered including the explanation for why some of the soil degradation processes do not exceed tolerance level of the societies in spite of their clear detrimental effects on soil functions.

However, this was not the scope of the presented guideline and the aimed exercise to elaborate technical and biological aspects was clearly and elegantly solved by the authors. 

Best regards

István Sisák

University of Pannonia, Georgikon Faculty

16 Deák F. st., H-8360 Keszthely, Hungary

Dear all,

Please, find attached my contribution in relation to traffic-induced soil compaction.

Best regards,

Frans Tijink

Dear Ronald,

Please find attached the review of the VGSSM guidelines. We hope that this is useful in your next iteration and would be happy to contribute to any further discussion. The document contains a review made by the LANDMARK consortium.

Kind regards

Rachel

Buenas tardes,

De manera atenta y para los fines pertinentes envío los comentarios trabajados por la Dirección de Bosques, Biodiversidad y Servicios Ecosistémicos de este Ministerio al borrador cero de “Guías voluntarias de manejo sostenible de suelos” de la FAO

Saludos,

Jessika Carvajal González

Profesional Especializado – Biodiversidad Oficina de Asuntos Internacionales