Comments on the Zero Draft of the HLPE Study
“Investing in smallholder agriculture for food security and nutrition”
We thank you for the opportunity to feed into the development of this important report. The draft provides a concise and multidimensional overview to the often simplified issue of small scale food producer`s investment realities. Clearly the issue of agricultural investments is a matter of high priority for the CFS this year and this report will bring valuable insights, in particular into the process of the development of rai principles. The report confirms the vital importance of smallholders and their production systems to food security, as well as employment, poverty reduction and stewardship of natural resources. Given the multiplier effect that small holder investment can have to the social, economic and ecological spheres, adequate support to their production systems should be a key message of the report.
In way of a general comment we would urge the HLPE to highlight the mandate of the reformed CFS towards the progressive realization of the right to food and frame the report in that light. For instance, when mentioning the rights of smallholders (e.g. at p.58), the draft should make clear that governments have the obligation to protect, respect and fulfill certain rights, such as the right to food, which are non-negotiable. We also stress the need for the report to highlight the importance of policy coherence and their cross-sectoral implications on the right to food. Thereby further encouraging governments to align their trade, energy, investment and environmental policies to meet this end.
Besides our overall positive assessment of the Zero-Draft, there are several aspects we would like to highlight as particularly important contributions:
1) Definition and significance of Smallholder agriculture: is the approach in the report adequate?
Generally yes. In fact providing definitions with which to base the debate is one of the major contributions of the report. For instance, the draft gains a lot from using a broad concept of “investment”, which we consider as key for an appropriate understanding of small scale food producers realities and contributions (p.38). The report stands to gain from providing early on its definition for investment and productivity.
Even though the document contain a reference to the resilient aspect of the smallholder agriculture and to its multidimensionality (including environmental implications such as biodiversity, climate change mitigation, water conservation etc.) little is said about the model which supports these characteristic, most notably, agroecology and low external input sustainable agriculture technologies (LEISA) The profitability and efficiency of agro-ecological and LEISA technologies has proven to provide the best solution for “weakly” endowed farmers in many regions of the world. A general exploration of the constraints to undertaking these proven approaches could be useful, as well as, some reference to investments which could be detrimental. These should then be integrated into the recommendations section to ensure they are avoided.
As far as significance, it would be useful for the report to outline the importance of small holder innovation and knowledge, what conditions support innovation and favor technology adaptation by small holders. There are numerous examples of how smallholders have been adapting and innovating in their production models. For instance, the case of the Zai technique in the Sahel or seed saving and selection, which through thousands of years has been invaluable in ensuring food security. This priceless human heritage is now at risk of loss (GMOs for instance) and the right investments are not being made to protect it. Also, on section 2.3 barter economies are completely omitted and these often have an important function for the poorest.
Finally, smallholders waste and pollute less and contribute to closing cycles in the production process. They contribute to positive externalities such as stewardship of the natural resources and the management of the commons. These factors should be noted in the significance section.
2) Framework for Smallholder agriculture and related investments: is the typology useful, adequate and accessible for the problem at hand?
Indeed the typology is very useful and provides evidence as to the importance of integrated and coherent policies. However, the National Smallholder Vision and Strategic Framework doesn’t outline clear enough its objective. We urge the HLPE to clearly state that the aim of such politics is the realization of the right to food for the population of a particular country (national level). This is important because different countries have different realities and will need to tailor their responses accordingly.
The Framework, as well as the Code of Investment, should clearly exclude any type of investment that could offset or compete with this aim or have negative impacts on the smallholders investment conditions which would disadvantage their access to resources. This is especially important for countries facing severe hunger problems. The report should thus recall that the promotion of certain investments can undermine the capabilities of small scale farmers to invest in their own exploitation. Outlining these would be a great contribution to the debate.
3) Constraints to smallholder investment: are all main constraints presented in the draft? Have important constraints been omitted?
Generally yes but the importance of access to the means of production, particularly secure land tenure could be further strengthened in the report.
Also, we urge the HLPE to explore beyond the problem of access to markets when discussing the (so-called) “modern” retail markets or globalized markets. Concentration and competition between corporate actors and smallholders represent a strong constraint. There’s no recommendation (nor analysis) on the need to address the failure of the market in allowing cohabitation and development of different viable agricultural systems and model. In this regard, dumping, market concentration, deregulation and unfair prices could be seen as good examples. Mechanisms to bypass these should be explored, as well as the need for policy coherence at the different political levels.
Another constraint could be the general lack of understanding by policy makers about the role, value and constraints faced by smallholders. Also, the lack of coherence in policies and regulations, at local, national, regional and international level is a severe constraint to investment in smallholder agriculture. The varieties of political arenas where agriculture is being discussed (and where decisions are taken) represent a severe constraint to governance, implementation, and financing of strong coherent policies. In the field, this translates into the non-alignment of actions by various stakeholders such as philanthropic organizations, international donors, international and local NGOs and the State.
4) Are the main areas for recommendations and the priority domains for action adequate? Does the draft include sufficient information at the adequate level to support the policy messages?
The recommendations section could be improved. Contract farming should be discussed more in detail. Sometimes this can be done successfully, as noted “there is plenty of evidence that smallholders that participate in contract agriculture gain different types of benefits”. But sometimes this is not the case and there is also plenty of evidence on how this can go wrong and result in the abuse of workers and misuse of local resources. It is important for the report to reflect the different sides of this kind of investment. See, for example, the work of the special rapporteur on the right to food, on this specific topic, stating that contract farming “rarely encourages farmers to climb up the value chain and move into the packaging, processing or marketing of their produce”. Moreover, to be in line with the “resilient” and multidimensional aspect of the smallholder models, such investment/contract, must respect certain guidelines. Therefore, we feel contract farming should not be presented as a top priority in the recommendations.
At several places within the text, as well as within the recommendations, a reference to price volatility as major constraint to investment by smallholders is made. But neither regulatory stocks nor regulation of finance, as part of the solutions, are cited. This “gap” should be filled. For example, the recommendation 10.b, page 9 should include an explicit reference to those means of reducing price volatility.
We are concerned about the absence of discussion of the burden of debt among the recommendations on “innovative” financing. The trend of farmer suicide as a result of increasing debt has unfortunately become a common phenomenon, especially in countries like India which have pursued a green revolution “high external input” model. This is extremely serious and in no way should the discussion of investments in the CFS lead to further indebtness of smallholders. The question of smallholder financing should be a subject of further study by the CFS.
Finally, the recommendations section could be further strengthened by providing more best practices from certain countries.
What is missing from the report?
Additionally we offer the following points for your consideration:
Handed in: January 30th 2013
 As laid down in key documents such as the international Covenant on economic, social and cultural rights (ICESCR) or the FAO Voluntary Guidelines on the Right to Food.
 Here we also include small holder collectives in general whether farmer, pastoralists, fisherfolk or harvesters.
 These models have been referenced time and again in various other works, such as the IAATD report, but also CFS documentation, such as the GSF.
Related links and resources:
Constraints to Smallholder Investments - A consultation by the HLPE to set the track of its study
Committe on World Food Security (CFS)
High Level Panel of Experts (HLPE)
The High Level Panel of Experts on Food Security and Nutrition (HLPE) Key Elements
The FSN Forum is supported by the project Coherent food security responses: incorporating right to food into global and regional food security initiatives.