Please find comments from the Southern African Faith Communities Environmental Institute.
1. While the guidelines make brief mention to the role purchasing power plays in food security, it lacks the emphasis needed - considering that rapid urbanization is occurring in developing countries, bringing with it an increase of dependents on money for food access and growing urban poor populations.
2. There is no mention of preventing the displacement of smallholder and subsistence farmers from their land due to large agribusiness interests. A process which is occurring in many developing countries and is jeopardizing rural communities resilience to climate shocks.
3. There should be guidelines on the importance of services for home food access and food preparation (such as clean water and fuel for food preparation and cooking).
4. There should be a guideline that promotes the regulation of pesticide use, considering the impacts pesticides have on farm workers, surrounding farming communities, and the environment.
5. While the guidelines do consider sustainable sensitive agricultural practices (43.(A)) it does not put the necessary emphasis needed considering the current climate and environmental crises we are facing and the substantial impact unsustainable farming practices have on creating and perpetuating this crisis. The guidelines need to not only consider the primary processes that are used and degraded for food production but also the supporting systems and processes that are at risk. Environmentally sensitive farming approaches are essential for the survival of humans on this planet.
6. Lastly the guidelines do not mention the special role that women predominantly play as food providers and how this impacts their role in the food system. This role is important to mention as it indicates that women and the challenges they face are key in creating food systems change.
Comments aimed at specific paragraphs:
43. (G). Women producer's livelihoods (pg 11) - It would be valuable to include supporting the informal sector as it plays an important role in both food security for consumers and employment for women excluded from formal employment.
43. (K). Resilient Food Supply chains (pg 12) - This should consider the distance food is transported and the close link food price has with oil price. Shorter food distances lessen the risk of lack of food access due to oil shortages/price increases.
45. Processing and Packaging (pg 12-13) - There also needs to be a focus on innovation in packaging to enable the safe transport of food without using plastic and non biodegradable materials due to the substantial harm food packaging is causing the environment.
46. (A). Support smallholder farmers (pg 13) - In order for smallholder farmers to compete with large integrated agrifood supply chains, smallholder farmers need support with market access through the development of agricultural hubs or appropriate trading spaces.
48. (B). Public food procurement (pg 14)- There should also be an emphasis on procuring from marginalised smallholder farmers.
Compiled by Robyn Bowden - SAFCEI Food and Climate Justice Cordinator firstname.lastname@example.org