المنتدى العالمي المعني بالأمن الغذائي والتغذية

I am attaching the template with the pro forma information added and the spreadsheet pertaining to the submission files a few moments ago. Ironically, spreadsheets are not acceptable forms of documents for uploads to the FAO consultation website, so I have converted it to a PDF.

Please consider the attached comments on the State of Food and Agriculture 2023.

Respectfully submitted, 

Bill Jeffery, Centre for Health Science and Law

Dear SOFA team, 

Please find a summary of potential contributions attached.

Best wishes,

Marco

Dear SOFA Team

Global Dairy Platform is pleased to submit comments regarding the recent report on True Cost Accounting. 

Thank you very much for the opportunity to provide feedback on this well done report.

The Global Dairy Platform (GDP) is pleased to have the opportunity to comment on the concept of True Cost Accounting, and its potential to serve as a catalyst to more sustainable global food systems in the future. As we seek ways to generate healthier,  more just, and environmentally sustainable means of producing and consuming foods, we believe that True Cost Accounting can serve as an important metric for assessing the hidden costs, both positive and negative, associated with food and diet production and consumption practices.

A key issue, from our perspective, lies in the definition of the terms “better”, “healthier”, and “sustainable”, and the means we will use for defining these terms. This is more than a semantical consideration; defining foods as healthy or unhealthy, or a production system as sustainable, and assigning costs to these factors based on pre-determined  definitions is a key point that can potentially elevate or undercut the concept of True Cost Accounting, and its utility.

Diet, health, and the environmental implications of food production is a Rubik’s Cube of possibilities. A food that is deemed unhealthy in one context (i.e., a higher animal sourced food diet in an overweight, over-fed population) may be healthy or possibly lifesaving in another (a malnourished, protein-deprived population). We run the risk of “throwing the baby out with the bath water” when we label foods as heathy or unhealthy in a reductionist manner, not considering the context in which these foods are consumed. Similarly, can we deem production of animal sourced foods to be unsustainable in locales in which land used by grazing animals is largely non-arable or unsuitable for growing crops? And how will we balance tradeoffs of growing food that may have a bit higher environmental cost in a region where that food has great cultural significance, or is a significant source of income for a large swath of the population? Attaching costs to foods or diets in a system that is not always black and white has its pitfalls, which need to be well thought out.

Further, nutrition science is ever changing, and foods deemed unhealthy based on current science may be considered healthy as new science emerges, or existing data are re-evaluated. Much of our uncertainty about what constitutes healthy from unhealthy eating is related to the fact that conducting quality nutrition research is difficult. Controlling all the aspects of a person’s life necessary to truly isolate and ascertain the effects of specific foods and diets is almost impossible, often forcing nutrition researchers to rely on short term, not-well-controlled studies or observational data never meant to assess cause and effect relationships.

For several years a  high carbohydrate, low saturated fat and cholesterol diet was considered best (particularly in a Western diet context) for mitigating non communicable disease risk. Newer data, however, indicates that eating high carbohydrate diets with impunity carries health risks of their own, and consuming particular fat sources against a backdrop of a high carbohydrate diet can carry risks that don’t exist when those fats are eaten as part of a lower carbohydrate diet.

In a similar vein, research on the environmental impacts of particular foods or diets is in its relative infancy, and much of our perceive knowledge of what connotes a high or low GHG producing diet is derived from models and estimates that are highly imperfect.

All of this begs the question of how we will or can accurately assign true costs to particular foods or diets without acknowledging the margin of error inherent in doing so. In this regard, True Cost Accounting may be more well suited as a conceptual framework  on how we should produce and consume foods, rather than as a final arbiter of “good” and “bad.”  

Other issues we believe require addressing as the concept evolves are 1) the lack of information on cultural aspects of sustainable food systems (how do we deal with foods deemed less than optimal from a True Cost Perspective, but that have been cultural staples for millennia)? 2)  will the True Cost concept unfairly impact poor people who won’t be able to afford particular foods once a true “cost” is added to that item? 3) who will be the arbiters of what ultimately constitutes the true cost of a food item or diet, particularly when decisions may need to be made based on partial or imperfect science? 4) how nimble will a True Cost Accounting system be to adapt and change as our scientific understanding of the variables change?

None of the issues we’ve raised here should suggest that GDP is not supportive of the concept of True Cost Accounting, or what it endeavors to achieve. We are, however, grateful that the concept will undergo a multiphase  assessment process, first raising awareness of the idea before moving towards evaluations to prioritize solutions and guide actions. We believe the concept requires a great deal more deliberation and “pressure testing” before it can be fully enacted. GDP is interested in participating in discussions as the idea moves forward, and to assist in its development in any way possible.

Sincerely,

Mitch Kanter, PhD

Global Dairy Platform

Dear SOFA Team,

Please find our submission attached.

Yours sincerely, Thijs de Lange

Dear SOFA team, 

Please see my submission below.

Use of dangerous agrochemicals: The increased use of dangerous agrochemicals in Uganda presents adverse effects on environmental safety and human health. Uganda is required to update and register agricultural chemicals as mandated under the legal framework- Section 4 of Agricultural Chemicals (Control) Act, 2007 and as according to the updated register (As of October, 2021), agrochemicals containing mancozeb as an active ingredient are listed and still traded to date.

The increased use of and trade in highly hazardous agro-chemicals is partly attributed to the absence of the Regulations to facilitate enforcement of the legal framework, porous borders that open up to the sell and trade of dangerous agrochemicals. Worse still, small scale farmers lack knowledge on the application, dangers of agrochemicals for instance, a study in Uganda showed that 24.5% of farmers were not aware of any health risks of spraying tomatoes close to harvest time, almost 50% of farmers (45.8%) sprayed their tomatoes less than a week to harvest time, 29.2% sprayed their tomatoes on harvesting, with intentions to extend the shelf-life while 50% did so to attract consumers.[1] Another study conducted in 2015 shows how farmers sprayed tomatoes 6 times beyond the manufacturer’s recommended dosage and harvested these tomatoes 2–3 days after the last spraying session compared to the recommended pre-harvest interval of 4–7 days.[2]

The continuous use of agrochemicals in the agrifood system by small holder farmers undermines the achievement of Sustainable Development Goals especially, eradicating extreme poverty for all people everywhere. This is because most of the would be profit is spent in procuring and applying agrochemicals.

With this in consideration, the SOFA report should demystify the double standards in the export and trade in and use of dangerous agrochemicals in developing and low income countries. In December 2020, the E.U parliament classified mancozeb as toxic for reproductive category 1B and also it concluded that non-dietary exposure to mancozeb cannot be considered negligible. Subsequently, the approval of active substance mancozeb was not renewed under Article 1.

It is our considered submission that whereas the use of agro-inputs in the food system is important for food productivity, the negative impacts outweigh the positives with reference to the hidden cost. Agrochemicals are leading to illnesses among farmers, cause climate crisis, unsafe food among other costs. The report should demystify the dangers of agrochemical use and suggest the sustainable agriculture practices like agroecology for small scale farmers. It should reflect the urgent call for the implementing and developing legal frameworks to promote sustainable agrifood systems.  

Land: There is a lot of speculation on sustainable land use in Uganda. A large percentage of land in Uganda is privately owned and hence many small scale farmers have limited access to land. This has created a growing trend of land fragmentation and accessing land for rent. This has created an environment of human rights violations over land matters, low productivity. Renting costs are not considered in determining the true cost of food. On the same note, despite Uganda having a well streamlined legal framework on land matters, many people especially the vulnerable/rural small scale farmers still face violations in form of destruction of food, and illegal evictions by large investors for plantations hence leaving many landless and/or with small portions of land for agriculture.

To comprehensively protect farmers and their interests in land, decision makers should monitor and implement land laws and curb any sort of violations over land. Decision makers should also develop policies to promote issuance of premium prices/incentivize small scale agrifood producers.

Congratulations to the SOFA team on this excellent report

This is a much-needed report to help kick-start and speed up the process of food system transformation.

The assessment of externalities throughout our food system is a vital exercise in helping to identify priority implementation measures to effect the necessary changes. It will also be a valuable resource to add to the teaching of externalities in our food economics classes.

Please find attached a report providing some brief feedback on the report and answers to some of the questions listed on the template form,

best regards

Dr Stephen Thornhill, University College Cork, Ireland.

Ceci implique une analyse approfondie des impacts sociaux, environnementaux et économiques. Cela peut se faire en adoptant des pratique durable en évaluant des empruntes écologiques en favorisant la transparence dans la chaine d’approvisionnement et en encourageant l’innovation technologique respectueuse de l’environnement.

L’intégration des couts peut se faire à plusieurs niveaux de la chaine alimentaire incluant la production agricole, la transformation, la distribution et la transformation alimentaire.

Cordialement,

Dear SOFA team,

We are glad to submit the official contribution of the Ministry of Agriculture and Livestock of Brazil, below.

In addition, please find attached a publication that describes the ABC Plan, a policy of Brazil regarding low carbon agriculture. Please, feel free to contact us for further inquires.

Best regards.

Although the costs of agrifood systems are constantly (and asymmetrically) emphazided during most of the discussions regarding the sustainability of the process, we do believe it is absolutely crucial to call attention to the distinguished benefits of such complex and essential human activity. For instance, agrifood systems are the main providers of calories and nutrients for human beings’ requirements, generate jobs worldwide and can participate as an important, strategic mechanism to balance Greenhouse Gas (GHG) emissions.

Notwithstanding the fact that the present call announces that it seeks to "discover the true impacts, both positive and negative, of global agrifood systems", their beneficial aspects have not been explored accordingly. As a matter of fact, only unfavorable effects of the activity were portrayed by FAO’s flagship publication “The State of Food and Agriculture 2023” (SOFA 2023) (https://www.fao.org/documents/card/en/c/cc7724en) and even the Call for Submissions (https://assets.fsnforum.fao.org/public/resources/2023-12/EN_TOPIC_SOFA2…). It is important to mention that although the SOFA 2023 edition does state in the introductory note that “Agrifood systems generate significant benefits to society, including the food that nourishes us and jobs and livelihoods for over a billion people”, the entire SOFA document is massively and exclusively focused on negative impacts of agrifood systems.

It is very much in this sense that we have critical concerns regarding the TCS (True Cost Accounting) approach methodology as the backbone of SOFA 2023. Leaving benefits aside (or even if only to be partially considered in second rounds or phases of the exercise) does not guarantee, at all, that transformative actions on agri-food systems can be adequately assessed or evaluated after consideration of hidden costs through TCA.

Moreover, as we could gather from the TCA definitions and meanings of hidden costs and hidden benefits as well as in the Executive Summary of SOFA 2023 (on pages xviii, xx, xxiii, for instance, and also, in other parts of the full SOFA document), these seem far from what would be considered as valid, more strictly correct, or really useful according to the classical literature of Cost-Benefit Analysis - CBA. In the literature of CBA (cf. Dasgupta et al., UNIDO Guidelines for Project Evaluation, for instance), all costs and benefits (visible, invisible, hidden, true, etc) of projects, activities, or programmes, must be considered properly in a sound analysis.

In sound CBA’s, costs are “sacrificed/foregone benefits”. As such, benefits (among which the hidden benefits of the SOFA TCA approach) must be appropriately valued, and cannot be just, or merely, reduced to a “negative” “reflection” of costs (negative hidden costs) as in the proposed TCA approach. Therefore, some of the affirmatives on the usefulness of TCA, such as, for instance, the one contained on page xxiii of the Executive Summary are very questionable – “… A comprehensive assessment of costs and benefits with TCA can also help businesses mobilize financial resources for the transition to sustainability ….”. The exact meaning of the statement remains to be clarified: (i) a comprehensive assessment of costs and benefits with TCA, meaning comprehensively assessing costs and benefits as per the definitions, meanings and methods of TCA? Or (ii) a comprehensive assessment of costs and benefits as contained, for example, in a sound CBA, but also using TCA? If (ii) is the chosen meaning, then a sound CBA seems more recommendable, and may suffice.

Despite these precautious remarks and considering that a second phase for SOFA may be forthcoming with more in-depth assessments targeting specific components or sectors of agri-food systems, we believe that Brazilian agriculture research institutions and other stakeholders would be willing to participate and contribute in this future process.

Having said that, through the document attached, we present a thriving, robust, and ambitious public policy, named ABC (Low-Carbon Agriculture) Plan, applied in Brazil and focused on sustainability and food security to harmonize sustainable development with mitigation and adaptation strategies against climate change throughout the rural production sector. This initiative, which also considers economic, environmental and social aspects, should work as an illustrative, distinctive example of (hidden) benefits of agrifood systems. Indeed, its focus makes the ABC Plan a global benchmark, unique in its scope, breadth and reach.

To explore existing case studies of agrifood systems benefits, the reading of the whole document entitled “ABC Plan: Ten years of success and a new sustainable form of agricultural production” is highly recommended. Both Chapters 3 (“Expanding results in the adoption of ABC technologies and GHG mitigation foreseen in the ABC Plan”) and 5 (“The ABC program as a finance instrument for climate-sustainable agriculture”) summarize and clarify some distinguished cases.

We believe that the ABC Plan is a very good example of transformative actions towards sustainable agrifood systems applied by Brazil and illustrates, quite remarkably, how decision-makers and other stakeholders are implementing the strategy and impacting the benefits of such systems. Hopefully, this initiative will inspire decision-makers elsewhere to adopt similar programmes to foster sustainable agrifood systems worldwide, to guarantee food security and nutrition for a growing global population, providing livelihoods to those along the food supply chain in an environmentally sustainable way (OECD, 2023). Furthermore, irrigation practices, considered within the ABC+ Plan, are also widely discussed as a key strategy for adapting agriculture to climate change to guarantee production as they contribute to avoid crop failures due to water stress caused by extreme weather events. Regarding mitigation, irrigated systems are effective in controlling GHG emissions, as they alter soil microbial activity and substrate supply, as long as the water use in irrigation is optimized, according to a broad review by Sapkota et al. (2020). In addition, studies on organic carbon levels in Brazilian sandy soils show that they can be reestablished to levels observed in native vegetation, after a long period under irrigation, and accumulate an expressive quantity of C per ha per year as compared to rainfed areas (Campos et al., 2020; Dionizio et al., 2020). Maintaining soil moisture increases carbon stock in the soil, as soils rich in organic matter retain more nutrients, increasing yield, while promoting carbon sequestration and storage. Finally, irrigation enables the use of “fertirrigation”, which allows the use of animal waste.

Moreover, agricultural subsidies should be considered as an important aspect of hidden costs as, according to OECD, “Producer Support Estimate” (PSE), the annual monetary value of gross transfers from consumers and taxpayers to agricultural producers, in 2020-22, was USD 234 billion (EUR 208 billion), per year on average, in OECD countries (Agricultural Policy Monitoring and Evaluation 2023).

References

Dasgupta, P., Marglin, S., Sen, A.K. Guidelines for Project Evaluation (New York: UNIDO, 1972).

OECD (2023), Agricultural Policy Monitoring and Evaluation 2023: Adapting Agriculture to Climate Change, OECD Publishing, Paris, https://doi.org/10.1787/b14de474-en.

Saptkota, A, Haghverdi, A, Avila, CCE, and Ying, SC. Irrigation and greenhouse gas emissions: a review of field-based studies. Soil Syst. V.4, n.20, Apr. 2020. DOI:10.3390/soilsystems4020020

Campos, R, Pires, GF, and Costa, MH. Soil carbon sequestration in rainfed and irrigated production systems in a new Brazilian agricultural frontier. Agriculture, v. 10, n. 156, May 2020. DOI:10.3390/agriculture10050156

Dionizio, EA, Pimenta, FM, Lima, LB, Costa, MH. Carbon stocks and dynamics of different land uses on the Cerrado agricultural frontier. PLoS ONE v. 15, n. 11, Nov. 2020. DOI: https://doi.org/10.1371/journal.pone.0241637.

Dear SOFA 2024 Team,

Please find our submission attached herewith. Please let me know if you need any help or item.

Thank you.

Sincerely,

Dikshit Poudel, FAO and University of Georgia