Dear friends at FAO,
You launched an e-consultation on this new document. Here is my contribution:
1. Do you have any general comments on the draft Framework for Action? Yes I do. Plenty.
· Do you have any comments on chapter 1-2?
The Introduction can be significantly shortened by referring to the Political Declaration where the content can be found already. No need to repeat.
· Do you have any comments on chapter 3 (3.1 Food systems, 3.2 Social Protection; 3.3 Health; 3.4 International trade and investment)?
I feel the introductions to 3.1 through 3.4 again are too wordy and repetitive of the Declaration.Suggest cutting with references to the Declaration.
A framework for action must go more directly to points of action expected of members states and particularly of public interest civil society organizations. Crisp is best.
As regards the priority actions recommended, nothing less than a paragraph by paragraph critique will do justice to the draft 0. It is often totally unclear whom the recommendations are made to... This being a framework for action its recommendations must be more precise --which they are not thus allowing for interpretation and loopholes. We went through that already in 1992!
So I have spent the hours needed to do the para by para review. See attached. Such a detailed analysis I think is needed for the JWG to get a feedback on their own text and to (hopefully) consider amendments.
· Do you have any comments on chapter 4-5?
Chapter 4 is unacceptably not human rights based. To enforce accountability, both rights holders and duty bearers need to understand what accountability is in the context of the right to food. Nothing is said about the massive HR learning that will be needed for this. I have made pointed comments on this in the text itself.
Chapter 5 on recommendations for follow up is weak to the point of only caricaturizing the role of public interest civil society in giving f/u to ICN2; we know little comes from top-down. Moreover, not a word is said about steps towards the progressive realization of the RTF. This is unconcionable in 2014 coming from a document to be backed by UN agencies.
2. Does the Framework for Action adequately reflect the commitments of the Rome Declaration on Nutrition, and how could this be improved?
Difficult for me to say since I expressed in writing my serious concerns about the contents of the Political Declaration in this same FAO forum. (Given the shortcomings of this Framework, I would say, yes, it reflects the shortcomings of the Political Declaration). Improvements will have to address a good number of the critiques that I make and others will be making in this forum. Will the JWG listen? (Our experience with the Political Declaration seems to indicate not).
3. Does the Framework for Action provide sufficient guidance to realize the commitments made?
To me, clearly not --and I point this out in many a place in the attached.
4. Are there any issues which are missing in the draft Framework for Action to ensure the effective implementation of the commitments and action to achieve the objectives of the ICN2 and its Declaration?
Many, many. They can be found in blue font in the attached so they are easy to find.
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Dear friends, I do not see why a critique has to be a collection of niceties. With so little time left, I do think that one has to be direct --as much as it may hurt: Calling a spade a spade; asking incisive questions. I just want to assure you that no disrespect is intended from my part when I sometimes use mordent language. I know the JWG has worked hard and I salute them, the question is with what level of in-house expertise on these complicated issues, especially as relates to human rights and the RTF.
Worried,
Claudio Schuftan
Dr. Claudio Schuftan