in the name of the Swiss NGO-Coalition on FAO/CFS issues: Alliance Sud, Berne Declaration, Biovision, Bread for all, Lengthen Fund, HEKS, Helvetas Swiss Intercooperation, SWISSAID I would like to share with you our joint comments on the rai Zero Draft (according to the guiding questions for the regional consultations):
Are all relevant issues and areas related to fostering responsible agricultural investment adequately addressed in the Zero Draft ? If not what should be changed ?
The importance of small-scale producers, their contributions and particular needs are missing in the Zero Draft. In fact, the document is drafted from the perspective of large investors, while small-scale producers are added on as needing safety-net type protections. Also, in this draft, small-scale producers are grouped in the same category as other “private investors,” who include large investors and companies. This is not acceptable. Small-scale producers need to be recognized as important investors for social and ecological sustainable food production. They should therefore be prioritised, their particular needs addressed appropriately and imbalances of power among small scale producers, corporations, governments, financiers, be acknowledged and addressed—especially in the sections on Roles and Responsibilities in Parts I and II.
Similarly, the rai principles need to better distinguish between public and private investors in agriculture, and their respective rights and responsibilities.
The document should provide a clear condemnation of land and resource grabbing. After having referenced the VGGT as one of the baselines for the rai principles, the rest of the document remains almost completely silent on the issue of safeguarding legitimate tenure rights. The reference to the VGGT as an important complementary document needs to be much more explicit.
There is no reference to agro-ecology. Agricultural systems should primarily be based on the use of local resources and natural interactions of ecosystems rather than external inputs. There is a strong need for supporting farmer-led bottom-up processes to make the best use of local farmers’ traditional knowledge, know-how, experimentation and innovation. This has also been stated by the UN Special Rapporteur on the right to food in his report to the UN General Assembly (December 2010), to which the new Zero Draft should explicitly refer.
The draft focuses excessively on increasing productivity, market mechanisms (such as incentives) and integrating small-scale producers into value chains. Marketsneed to be established in a way that they benefit small scale food producers and poor consumers. The draft should reflect existing power relations and ensure that fair share of value addition remains with small-scale producers and rural economies.
Women food producers are rather treated as an add-on. The rai principles need to acknowledge women as major food producers, as well as those processing and marketing food. The wording on women’s right to food is still weak and needs substantial improvement.
Language on regulating contract farming and public-private partnerships are also missing in the current draft.
In relation to Indigenous Peoples, the rai principles must make reference to the ILO convention no.169.
The document fails to address adequately the concerns of agricultural and food workers in relation to responsible investment in agriculture. As they make up 40% of the agricultural workforce and work on all sizes of enterprises – small, medium and large, their views, requirements and concerns should be much more fully reflected.
Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the principles? If not, what should be changed ?
There are major gaps in mechanisms, laws and regulations to discipline large-scale investors who violate the rights of small-scale producers and who fail to comply with the Voluntary Guidelines and the rai principles. Also missing is language on regular monitoring of large investments and renegotiating investment contracts and agreements that undermine the capacities and rights of small-scale producers.
The concept of accountability has been included in a rather vague manner. Particularly the sections on roles and responsibilities need to be more explicit about who is accountable to whom and for what.
Does the Zero Draft achieve the desired outcome to promote investment in agriculture that contributes to food security and supports the progressive realization of the right to adequate food in the context of national food security? If not, what should be changed ?
The state as investor: We see major gaps in the roles and responsibilities of the state in relation to public investment, provision of public goods and services, public policy, and regulatory and legal frameworks that address the interests and priorities of small-scale producers.
A change of perspective is needed: Across the document, language about enabling investment favours large-scale investors and not small-scale producers, and local food systems that link producers and consumers. It is not enough that agricultural investment generates co-benefits for concerned communities; small-scale producers and their communities must be the principle beneficiaries of agricultural investment. Furthermore, the interests of large investors are protected by ‘hard law’—including international agreements and investor protection – whereas small-scale producers and workers are only protected by ‘soft law’ such as voluntary norms, corporate social responsibility, mediation, conflict resolution, etc.
4. a Are the current structure and language used clear and accessible for all relevant stakeholders to apply
Given that the current document primarily focuses on large-scale producers and fails to distinguish between different roles and responsibilities for small and large, private and public investors, the document remains unclear and cannot provide clear guidance for most of its target groups. In addition, the principles per se are formulated in a pretty short manner, leaving room for interpretation and contestation.
4.b What steps need to be taken for the CFS-rai principles to be used and implemented by different stakeholders after endorsement by CFS?
In its current form, the CFS-rai principles must not be endorsed at all. At a later stage, it will be essential that involved stakeholders at all levels use these principles in practice and declare their observation a prerequisite for collaboration with all types of development partners.
Mme Tina Goethe
Dear Christina Blank, dear all
in the name of the Swiss NGO-Coalition on FAO/CFS issues: Alliance Sud, Berne Declaration, Biovision, Bread for all, Lengthen Fund, HEKS, Helvetas Swiss Intercooperation, SWISSAID I would like to share with you our joint comments on the rai Zero Draft (according to the guiding questions for the regional consultations):
The importance of small-scale producers, their contributions and particular needs are missing in the Zero Draft. In fact, the document is drafted from the perspective of large investors, while small-scale producers are added on as needing safety-net type protections. Also, in this draft, small-scale producers are grouped in the same category as other “private investors,” who include large investors and companies. This is not acceptable. Small-scale producers need to be recognized as important investors for social and ecological sustainable food production. They should therefore be prioritised, their particular needs addressed appropriately and imbalances of power among small scale producers, corporations, governments, financiers, be acknowledged and addressed—especially in the sections on Roles and Responsibilities in Parts I and II.
Similarly, the rai principles need to better distinguish between public and private investors in agriculture, and their respective rights and responsibilities.
The document should provide a clear condemnation of land and resource grabbing. After having referenced the VGGT as one of the baselines for the rai principles, the rest of the document remains almost completely silent on the issue of safeguarding legitimate tenure rights. The reference to the VGGT as an important complementary document needs to be much more explicit.
There is no reference to agro-ecology. Agricultural systems should primarily be based on the use of local resources and natural interactions of ecosystems rather than external inputs. There is a strong need for supporting farmer-led bottom-up processes to make the best use of local farmers’ traditional knowledge, know-how, experimentation and innovation. This has also been stated by the UN Special Rapporteur on the right to food in his report to the UN General Assembly (December 2010), to which the new Zero Draft should explicitly refer.
The draft focuses excessively on increasing productivity, market mechanisms (such as incentives) and integrating small-scale producers into value chains. Markets need to be established in a way that they benefit small scale food producers and poor consumers. The draft should reflect existing power relations and ensure that fair share of value addition remains with small-scale producers and rural economies.
Women food producers are rather treated as an add-on. The rai principles need to acknowledge women as major food producers, as well as those processing and marketing food. The wording on women’s right to food is still weak and needs substantial improvement.
Language on regulating contract farming and public-private partnerships are also missing in the current draft.
In relation to Indigenous Peoples, the rai principles must make reference to the ILO convention no.169.
The document fails to address adequately the concerns of agricultural and food workers in relation to responsible investment in agriculture. As they make up 40% of the agricultural workforce and work on all sizes of enterprises – small, medium and large, their views, requirements and concerns should be much more fully reflected.
There are major gaps in mechanisms, laws and regulations to discipline large-scale investors who violate the rights of small-scale producers and who fail to comply with the Voluntary Guidelines and the rai principles. Also missing is language on regular monitoring of large investments and renegotiating investment contracts and agreements that undermine the capacities and rights of small-scale producers.
The concept of accountability has been included in a rather vague manner. Particularly the sections on roles and responsibilities need to be more explicit about who is accountable to whom and for what.
The state as investor: We see major gaps in the roles and responsibilities of the state in relation to public investment, provision of public goods and services, public policy, and regulatory and legal frameworks that address the interests and priorities of small-scale producers.
A change of perspective is needed: Across the document, language about enabling investment favours large-scale investors and not small-scale producers, and local food systems that link producers and consumers. It is not enough that agricultural investment generates co-benefits for concerned communities; small-scale producers and their communities must be the principle beneficiaries of agricultural investment. Furthermore, the interests of large investors are protected by ‘hard law’—including international agreements and investor protection – whereas small-scale producers and workers are only protected by ‘soft law’ such as voluntary norms, corporate social responsibility, mediation, conflict resolution, etc.
4. a Are the current structure and language used clear and accessible for all relevant stakeholders to apply
Given that the current document primarily focuses on large-scale producers and fails to distinguish between different roles and responsibilities for small and large, private and public investors, the document remains unclear and cannot provide clear guidance for most of its target groups. In addition, the principles per se are formulated in a pretty short manner, leaving room for interpretation and contestation.
4.b What steps need to be taken for the CFS-rai principles to be used and implemented by different stakeholders after endorsement by CFS?
In its current form, the CFS-rai principles must not be endorsed at all. At a later stage, it will be essential that involved stakeholders at all levels use these principles in practice and declare their observation a prerequisite for collaboration with all types of development partners.