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
Dr. Mitchell Kanter