Foro Global sobre Seguridad Alimentaria y Nutrición (Foro FSN)

I wish to add a further comment regarding the right to food which I forgot to include in my submission earlier today. 

I would suggest to recognize the right to food more explicitly as part of good governnce in the political outcome document. In article 8, in addition to simply recalling the existence of the International Covenant on ESC rights and the Voluntary Guidelines on the Right to Food, the document could refer to the obligations of various stakeholders derived from the right to food, in particular the obligations of governments to respect, protect and fulfill these rights as far as possible.

The draft political outcome document for ICN2 starts out by stating that “threats of malnutrition are a major challenge to global development” and recognizes that the causes of malnutrition are “complex and multidimensional”.  I fully agree with both statements.

Nevertheless I would recommend beginning the document with an explicit acknowledgement of the significant improvement achieved during the last two decades in various countries including some of the poorest.  The prevalence of undernourishment in the world has declined from 19 to 12 percent 8in developing countries from 24 to 14 percent) and even the absolute global number has declined from 1.02 billion to 840 million. Improvements have also been observed in other forms of malnutrition. I do not propose acknowledging this progress as an expression of complacency, but as reference to the fact that enough is known about how to fight hunger and that there is no excuse for inaction.  

Having said this I do agree with article 2 drawing attention to specific types of malnutrition which are still affecting millions of children, women and men in spite of progress. The quantitative dimension of the problem may even be understated in so far as Lawrence Haddat’s comment is correct that the impact of dietary risk on the global burden of disease and disability might even be higher than the 10 percent mentioned in article 4.  

Regarding remedy policies the draft lists most important entry points, including not only the classical domains like food availability, access and utilization, but also various policy domains more related to nutrition, including health, education and consumer information as well as measures like social protection and school feeding which directly benefit the neediest. However, I still find the list of proposed policies unbalanced. It does not refer to policies aiming to strengthen the wider enabling environment needed to improve nutrition on a sustainable basis. For example there is little emphasis on poverty alleviation as part of strategies for equitable growth. References to research and innovation are missing. Moreover, while the need of providing access to safe food supplies is repeatedly underlined, access to safe drinking water is mentioned only once and the overall domain of WASH (Water, Sanitation and Health) is not included in spite of its vital relationship to nutrition.

A main weakness of the current draft is the vagueness of the proposed policy commitments. This leads me to the following suggestions:

·         Instead of simply renewing past, yet unfulfilled, commitments of earlier high level events, the document should underline the willingness to learn from past failures and list the main reasons for unsatisfactory progress in fighting malnutrition, e. g. lacking political will to give food security a higher priority, lacking awareness that investment in improving nutrition has a high social, economic and political benefit or lacking voice of the poor and malnourished in the political process due to bad governance. Articles 6 and 7 simply “renew” earlier commitments.  I would suggest reformulating these expressions to read “renew, strengthen and expand…”

·          As also suggested by others each of the seven commitments contained in article 21 needs to be complemented by targets and indicators which can be monitored. Moreover, governments should express their willingness to be held accountable for progress in implementing these commitments.

In conclusion, the document is rather complete in addressing most major aspects relating to hunger and malnutrition in the world.  To serve as a powerful basis for setting targets and holding governments accountable for the implementation of an effective Plan of Action the draft could be improved in several parts: recall that enough is known to achieve progress and that inaction has no excuse, improve the balance of proposed measures in favor of more nutrition sensitive policies, call for an honest and critical review of reasons for past failure in reducing all forms of malnutrition, complement the proposed political commitments by concrete targets and monitorable indicators that can serve as criteria to hold governments accountable .    

The goal of the ICN2 draft should aim to illustrate how making NUTRITION explicit in all relevant policies will maximise the opportunity to reduce poverty as rapidly as possibly as cost effectively as possible.

Policy makers from diffrent sectors need tools to help them implement this approach. Such a tool could be by providing a lens whereby they can view their policies through a nutrition perspective. Only by ensuring nutrition is explicit (and not underminded) can the sectors of agriculture, health, environment and education etc. develop coherent policies to prevent unintentional harm to human health and environment and so achieve development goals.

Attached is a document where food and nutrition security is viewed through a policy coherence for development lens. How different sectors can work together to achieve "win-win" solutions to challenges of population growth, increasing food prices and enviromental damage is discussed. This view through a coherent lens starts with

1. Policy Coherence for Development ( as per OECD).
2. Nutrition Insecurity Hinders Development.
3. Sustainable Agriculture and Food Production to promote human health and protect the environment.
4. Post-2015 Agenda and Poverty Reductoin.
5. Climate Change, Green Growth and Biodiversity2020.

Please find enclosed my comments – yellow “stickies” with comments tracked in the text.

Best regards,

Marie Ruel

Director,

Poverty, Health and Nutrition Division (PHND)

International Food Policy Research Institute (IFPRI)

Political Outcome:

Support Required Investment for Low Cost Producer Oriented Economies of Scope Ecological Agriculture Systems of each area being Smallholder Rural Poor Producer Community friendly and Abolish Support to the High Cost Market Oriented Economies of Scale Green Revolution Technologies (mono crops) serving only the Large Farmer Interests

Strengths and Opportunities:

‘Low Cost Ecological Agriculture’ will put to work about 60% of India’s rural poor producer communities, ensuring access to their requirement of nutritious food and cash, at little or no cost thus improving livelihood, net incomes and purchasing power and their long term sustainability whilst reducing hunger, malnutrition, poverty, suicides and the effect of climate. In contrast, distortions due to the high cost green revolution agricultural economy which perversely incentivizes farmers to grow wheat and rice (mono crops which have MSPs and subsidies for highbrid/ GM seeds).

It will help boost farm production spread over 12 months, minimize risks with income from non-cereal food items, like vegetables, lentils, fruits, diary, fisheries, energy, production of inputs, etc. This will put a lid on food inflation with 60% of the rural poor producing for meeting their own requirements of nutritious food, value adding to the surplus, if any, for increasing the shelf life of the produce for storage and thus minimizing post harvest losses (presently 40%). MSPs (which have only moved upwards) and subsidies will no longer be required once the producers have become sustainable in the long term (about 10 years) with high economic development and job created through agriculture. An income support programme will ensure that needy farmers are compensated for any loss in income caused during their conversion to the low cost Ecological Agriculture System of their area abolition of subsidies and MSPs.

Weaknesses and Threats:

Conversion to ‘Ecological Agriculture Systems’ of each area from the green revolution technologies incentivized by Government/ NARES mostly followed by large industrial farmers who have benefitted from subsidies, MSPs, etc. are well organized and will protest and there will also be scientist/ political opposition to what will be portrayed as an anti-farmer policy.

Identifying needy farmers for the income support programme will be a challenge as they will require assistance and support for setting up democratic producer organizations/ company (PC amendment IX A of the companies act) but staffed by educated (general practitioners/ MBAs in agriculture) women and youth to take over all responsibilities and risks other than on farm activities.

How to get it done:

Involving the CSO/ NGO working with the producer communities for setting up their PC and staffing it with the required professionals to manage on behalf of the members the Government’s introduction of an Income Support Programme, using Aadhar successfully and then followed by announcement to abolish ‘Subsidies & MSP’.However, the implementation of both these policies could be synchronized in calibrated steps over a period of time, so as to ensure that such a major policy reform is not stalled by the sheer scale of the change. As it will curb food inflation – an issue that pinches the majority – must be used as argument by the Government to persuade public opinion.

Case Study:

New Zealand farmers mostly follow their Ecological Agriculture Systems and are sustainable in the long term (without farm subsidies). This can be achieved in India in less than 10 years provided the required investments are made in Human and Institutional Development for meeting the needs of the rural poor producer communities to correct the wrong policies of the past 50 years: · 

Announcing of a moratorium on export and futures trading ban only after the rural poor have converted to Ecological Agriculture and have access to their requirement of nutritious food and cash.· 

Invest in locally adapted modern seed technology, enabling producers to produce their own seed.· 

Amend Food Security Bill; Government’s introduction of an Income Support Programme for Rural Producer Communities through their PC and reduce coverage only to urban poor through Aadhar for cash transfers.· 

Provide the financial resources for rural producer communities to contract CSO/ NGOs to assist them to set up their PC and staffed with the required professionals.· 

Abolish the Agriculture Produce Market Committee (APMC) Act.· 

Provide funding to allow PCs to manage.· 

Fund/ Aid Integration of allied activities; Water harvesting/ table, energy production/ distribution projects, Horticulture, Poultry, Fisheries & Animal Husbandry.· 

Institutes of Agriculture be converted to serving the needs of education, knowledge, training, action research in the area leaving research to the CSIR institutes.

Encourage Modernisation as applicable to the soil and agro climatic conditions of each area, using hand tools, etc., to improve quality and production

Estimados Señores:

A tiempo de agradecerles por la oportunidad de aportar con el borrador cero del documento politico final de la CIN-2, adjunto les envío el documento con algunas aportaciones que me parece contribuirán a contar con un documento mas preciso.

Muchas gracias

Luis A. Rico Aranibar

Bolivia

This comment is submitted on behalf of the Norwegian Network for Global Nutrition, which is a network of academics and NGOs in Norway. A list of the persons and organizations behind this statement is included in the attached document. We thank for the opportunity to participate in the process of developing the zero draft of the political outcome document of the ICN2. Below are our general comments, whereas specific comments are attached.

1. Nutrition is higher on the global agenda than ever before in history. The ICN2 needs to be a place to convene, harmonize, strengthen and advance the constructive forces at work, and be a “leading star”. To achieve this, we believe the commitments described in the policy document need to be extensively based on previous achievements (such as those mentioned below), and all relevant global initiatives and actions need to be considered, in particular the Global Strategic Framework of the reformed CFS which is to be a living annual document, the World Health Assembly objectives from 2012, the Global Action Plan for the Prevention and Control of Non-communicable Diseases 2013-2020, the 1000 days initiative of the Secretary-General’s Global Strategy for Women and Children’s Health (WHO, 2010) and the SUN movement. The only initiative mentioned in the Zero Draft is the Zero Hunger Challenge!
2. The document ought to be based in an expressed full recognition of the human right of everyone to adequate food and nutritional health and to be free from hunger, as established  and implied in Article 25 of the Universal Declaration of Human Rights (UDHR) Article 11 (1) and (2) of the International Covenant on Economic, Social and Cultural Rights  (ICESCR), Article 24 (c) of the Convention on the Rights of the Child (CRC) and Article 12 (2) of the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW). Properly framing the commitments of the ICN2 in a human rights framework will enhance previous achievements in (a) defining the content of adequate food as a human right (called for in the World Food Summit in 1996 and interpreted in 1999 in General Comment No. 12 by the United Nations Committee on Economic, Social and Cultural Rights); (b) the development by FAO Member States of the Voluntary Guidelines to support the progressive realization of the right to adequate food in the context of national food security (2004); and (c) the decisive integration of food and nutrition as human rights in a range of recent global policy food and nutrition policy and technical documents from the UN and other stakeholders, in particular the Global Strategic Framework on Food Security and Nutrition of the reformed Committee on World Food Security (CFS). Aligning the document to a human rights framework should recall the framework of corresponding State obligations in  general use by the United Nations, many states and civil society (respect, protect, fulfill (facilitate and/or provide), and which helps clarify and contextualize the responsibilities of the State; likewise the United Nations Guiding  Principles on Business and Human Rights (UN Human Rights Council, 2011) reiterates these responsibilities especially that of protect, and the implications for the private sector companies to respect human rights in their activities and relations and internal risk accounting, all pertinent to the performance also of food related companies in diverse food systems. Last but not least the extraterritorial obligations of states, meaning obligations to protect the human rights, including the right to adequate food and nutrition, of persons living within or beyond their national boundaries and, therefore, must put into place effective rules and regulations that ensure that private actors, including transnational corporations, do not infringe upon these rights (Maastricht Principles ref! 23-27). The rights of women in their often conflicting productive and reproductive roles need special attention as can be inspired e.g. by CEDAW and the ICESCR Article 14 which especially focuses on rural women.

Thus the document as a whole needs to be reviewed with a human rights lens, taking into account the key human rights principles of  participation, accountability, non-discrimination, transparency, human dignity, empowerment, and respect for the rule of law in encouraging the design of policies and conduct of interventions.  FAO has particular competence in this area and reference should be made to the Organization’s own record and achievements in developing tools and aids to assist governments and civil society in meeting their right to food responsibilities.

We also believe the various key human rights instruments that are particularly relevant to the right to food and nutritional health need to be explicitly recalled, this because of the high number of Member States that have ratified them and thus are bound by their previous commitments which will be important in the final negotiations. 

1. We appreciate that improving food systems is highlighted as playing a key role to improving food and nutrition security. Food systems is an important concept but has different meanings for different people and interests. In this context account must also be taken of how different food systems and changes in these affect different groups’ very livelihoods, which will determine the way households access food or resources for food.  It is important that ICN2 adopts a strong stance on what food systems are expected to deliver; in this context we refer as inspiration to the very last report to the Human Rights Council by  the UN Special Rapporteur on the right to food,  professor Olivier De Schutter: “The transformative potential  of the right to food”  where he deals both with these expectations for, i.a., poverty reduction, and looks at the way forward  in terms of reshaping local food systems, deploying national strategies and shaping an enabling international environment. (U.N.Doc.A/HR/C/25)
2. However, we also agree with many other commentators that the document fails to take adequately into account the many other important underlying and basic factors determining nutritional problems. Key underlying challenges include intra-household distribution and infant and young child care and feeding practices which should be reflected in the document; furthermore the need to underline women’s many, often competing, productive and reproductive roles - as food producers and processors,  and in bearing, breastfeeding and taking care of their children, and at the same time often being discriminated and economically marginalized in many societies.
3. Important basic causes include gender inequality, inadequate access to education and other resources, misuse of resources and corruption, and, as has unfortunately been repeatedly shown in the past and increasingly during the last years – internal conflict, where food even has been used as weapon which is completely unacceptable and a severe breach of the human right to adequate food.
4. The key term “malnutrition” is not used consistently throughout the draft. Consider revising with clear use of the terms undernutrition and malnutrition (as referring to both under- and over-).

Thank you for the opportunity to comment on the zero draft political outcome document. We applaud the inclusion of malnutrition in all its forms and believe that it is of paramount importance to not only treat and prevent the occurrence of malnutrition but also build sustainable food systems to ensure long-term impact.

Please consider the following comments for consideration:

Paragraph 1: Thank you for acknowledging the threat that malnutrition poses to individual and societal well-being. However, we suggest that the paragraph be altered to include an acknowledgment of the growing problem of obesity, the critical period of development during the first two years of life, and the economic costs of malnutrition. Please replace the paragraph with the following: “Acknowledge that malnutrition poses one of the greatest threats to people’s health and well-being. Malnutrition—undernourishment, micronutrient deficiencies, unbalance diets, obesity—imposes unacceptably high costs on individuals, families and societies. In particular, malnutrition early in life–from pregnancy through early childhood—restricts the attainment of human potential, negatively impacts human physical and cognitive development, and increases susceptibility to non-communicable diseases.  Malnutrition also impacts economic growth and can cost a country as much as 11 percent of Gross Domestic Product.

Paragraph 2: Please replace the word “modest” with “insufficient” in the first sentence so it reads: “Note, with profound concern, that recent decades have seen insufficient and uneven progress in reducing malnutrition…”

Under bullet number 5: “about a third of all women suffer from anaemia,” please add more on how this is linked not only to poor maternal nutrition but also to newborn mortality, such as: “Poor maternal nutrition is a contributing factor to maternal, infant and child mortality. Stunted mothers are more likely to give birth prematurely and have an underweight baby, and fetal growth restriction is a cause of 800,000 deaths in the first month of life each year (Lancet).”

Please change bullet number 6 to read: “Obesity and overweight in children and adults has dramatically increased and is projected to reach epidemic proportions in the next several years. In addition, the incidence of non-communicable diseases related to diet has been rising rapidly all over the world.”

Paragraph 5: Thank you for recognizing that women and children have specific needs, especially during particular phases of life. The consequences of malnutrition during the critical 1,000 day “window of opportunity” from a woman’s pregnancy to her child’s second birthday are irreversible, and can cause long-lasting damage. Maternal nutrition and support are therefore crucial to break the intergenerational cycle of malnutrition and build the foundations of healthy individuals and societies. We suggest adding the following in bold:

5. Recognize that nutritional needs change over the life cycle, and certain groups, including women and children, have specific needs, especially during particular phases of life, including the 1,000 day window of opportunity from a woman’s pregnancy to her child’s second birthday.

Paragraph 10: Please change the first line to read: “Acknowledge that food systems must produce more nutritious food…”

Paragraph 18: Thank you for recognizing that a framework for collective commitment, action and results is needed to reshape the global food system to improve people’s nutrition. However, the sentence: “Governments should take responsibility for leadership on nutrition,” should be expanded to include an emphasis on the need to develop responsible food policies. We recommend changing the sentence to:  “Governments should take responsibility for leadership on nutrition by developing food policies that at a minimum do not harm people’s nutrition and ideally are aimed at improving nutritional status.”

Paragraph 21: It is critical to make the commitments to action list more specific and ambitious. We suggest the following commitments be added to the list:

• We will ensure policies, investments and incentives that affect food systems provide an enabling environment for the effective implementation of nutrition policies and programs, including adopting a “do no harm” policy in order to mitigate any negative externalities of food systems.

• We commit to leveraging local food systems and engaging local populations to support the adoption of sustainable and nutritious diets, including by establishing markets for smallholder and family farmers, developing urban food systems to meet the needs of the local population, leveraging traditional/indigenous crops, and supporting women engaged in local and smallholder food production systems. 

• We commit to accelerating progress to achieve the 2012 WHA nutrition targets at national levels.

• We commit to establishing (or enshrining, if already established) a multi-sectoral coordination mechanism for nutrition to ensure that policy decisions are owned by all relevant ministries and have domestic budget lines for nutrition; as well as appoint a government nutrition focal point who is responsible for ensuring that the country’s nutrition efforts effectively engage the whole of government and external stakeholders.

Please see attached file.

HelpAge International's Comments on

THE ROME ACCORD - ICN2 zero draft political outcome document for 19 November 2014

Thank you for the opportunity to comment on this document. Please find below our comments on paragraphs 4-23.

General comments

Like some of the other commentators, we would like to see a stronger grounding of the political outcome document in a human rights framework. This requires more explicit references to nutrition being a crucial element of the human right to adequate food and nutrition as well as references to states being obliged to protect and fulfil this right and citizens being right holders, rather than merely being ‘consumers’. Human rights violations that cause or contribute to malnutrition should be mentioned in the document too.

Comments on paragraphs 4-20

There needs to be a stronger commitment to protect and improve nutrition outcomes throughout the whole life cycle

The right to adequate food and nutrition applies to all, including to people of all ages. It is encouraging to see that paragraph 5 proposes to take into account the different nutritional needs during the ‘life cycle’. The text then however only singles out women and children as having specific needs. Similarly, paragraph 7 only mentions nutrition targets for children under 5 and women of reproductive age. To do justice to a rights based approach however, we need to commit to better understand, protect and improve the nutritional status throughout the whole life cycle (including in old age).

To this end, there needs to be a commitment to improve the evidence base on the nutritional status of people beyond reproductive age (especially with view to under-nutrition) by routinely including them in food and nutrition surveillance and by age-disaggregating data. We recommend adding such a commitment to paragraph 20. In the same vein, there needs to be a commitment to provide targeted support to people of all ages in need of nutritional support. This should be added to paragraph 15.

There needs to be a stronger commitment to social protection

The document focuses on the food system in its traditional sense (food production, storage and distribution) and neglects the crucial role of social protection systems for improving and protecting nutrition outcomes. While the ICN2 technical preparatory meeting in November 2013 devoted several sessions to social protection in support of nutrition outcomes, the political outcome paper is very quiet on this topic. There are only two vague references to social protection in paragraph 12 and paragraph 13.

Given the frequent livelihood shocks and stresses that poor households in low and middle income countries experience, a sole focus on improving productivity, improving availability and affordability of healthy food is insufficient to ensure that poor households have secure access to healthy food and that they reach sustainable improvements. The majority will face times where their ability to produce food or their ability to generate a cash income is undermine and healthy nutritious food is out of their reach. Reliable social protection systems that guarantee access to basic services and minimum income security across the life cycle are crucial for bridging this gap.

We therefore recommend adding a clear commitment to support social protection systems. References to this should be made in paragraphs 12 and 13 and ideally a standalone paragraph on social protection should be added too. It is thereby important to advocate for social protection systems that guarantee social security throughout the life cycle.

Comments on paragraphs 21-23

In line with the comments made above, we, firstly, recommend to state a clear commitment to improve the nutrition of people throughout the whole life-cycle. This would be part of the introductory sentence of paragraph 21.

Secondly, we recommend to add a standalone sub-paragraph to paragraph 21 on the commitment to support reliable social protection systems that provide access to basic services and basic income security throughout the life cycle.