I note that the four questions on which you wish to receive feedback from Permanent Representatives are not exactly the same that were posed to the Open Ended Working Group (OEWG) on 19 September, 2013. Nevertheless, I shall try to respond to all the four questions.
Question 1 : Are all relevant issues and areas related to fostering responsible agricultural investment adequately addressed in the Zero Draft? If not what should be changed?
As I understand it , the Zero Draft has a special intent, namely to elaborate the Principles that need to be observed when investment is planned for agriculture by all stakeholders. From this angle the Zero Draft adequately covers the main issues and areas in making agricultural investment responsible.
However, fostering responsible investment in agriculture at the national and local level, including for food security and nutrition, goes much beyond the 8 RAI Principles. Agricultural investment on a national scale hinges on such important consideration as macroeconomic environment, political stability, growth prospects in the sub-sectors of agriculture, suitable land and water resources, enhancing the productivity and competitiveness of agricultural commodities produced domestically, size of the internal market, choice of technology, institutional services, infrastructure, access to finance, tax and credit policies, incentives etc. At project level, the decision is based on social cost/benefit analysis in which it may prove difficult to factor in one or more of the 8 Principles into the analysis.
The notion that the eight Principles provide all the elements required for investment decision at national or project level would be an exaggeration.
Question 2 : Are the roles and responsibilities of relevant stakeholders clearly defined in order to facilitate implementation of the Principles? If not what should be changed?
The inclusion of a section on “Roles and Responsibilities” in part I, II and III is appreciated. The question is how detailed these role and responsibilities be spelled out. In Part I, it covers two full pages. Taking Part I, II and III together there are 35 bullet points on Roles and Responsibilities for States, 18 for Investors and 4 for others, making a total of 57 bullet points. We think that in order to avoid a shopping list, there should be few bullet points of high relevance. Given the wide range of capabilities and resource availability among states and given the diverse profile of investors, a short list will be more desirable. This is more so as RAI Principles are voluntary and non-binding as underlined on page 2 of the Zero Draft.
Question 3 : Does the Zero Draft achieve the desired outcome to promote investment in agriculture that contribute 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?
This is a loaded question and therefore difficult to answer. The difficulty arises due to the fact that the promotion of investment in agriculture depends on several other things that are not part of RAI Principles. Therefore, I am not able to respond to this question.
Question 4 : The Principles are intended to provide practical guidance to stakeholders; therefore:
- Are the current structure and language used clear and accessible for all relevant stakeholders to apply?
From the language point of view the Zero Draft is acceptable. With respect to structure, we have four comments to make.
First, each of the 8 Principles have bullet points, amounting to 17 bullet points for 8 Principles. Each bullet point touches on a different issue and can stand on its own. So one wonders if there are 8 or 17 Principles. We would prefer to merge the bullet points under each principle into a single concise text as was the case in the May, 2013 Session of the OEWG. It should be noted that the 7 Principles drafted jointly by FAO/IFAD/World Bank and UNCTAD at the request of G20 were also in the form of concise texts.
Second, there is considerable room for making the section on rationale for each RAI Principle crisp and short. For example, the rationale of Principle 1 could be reduced to read “Investment in agriculture and food systems contributes to the fulfillment of the four key dimensions of food security; availability, access, stability and utilization”. It is not necessary to define what food security is or explain the particulars of the four dimensions. They are well known to all stakeholders.
Third, under each Principle a number of Objectives are listed and these amount to 27 Objectives. We do not think this is the right approach because it amounts to the proliferation of RAI Objectives. We prefer that the Objectives under the 8 Principles be consolidated and shown in one place under the current title of “Objective, nature and scope” on page 1 of the Zero Draft.
Fourth, we recommend refraining of too much of subscription in the sections on Application, particularly for Principle 1 and 3.
- What steps need to be taken for the CFS/RAI Principles to be used and implemented by different stakeholders after endorsement by CFS?
Once the Principles are approved, the next steps will be advocacy, implementation and monitoring. One would think the same route would be appropriate for RAI Principles as the one observed for VGGT, which is also voluntary and non-binding as the RAI Principles.
Advocacy should be done by all organization approving the Principles, with the three Rome-based agencies taking the lead.
The IFIs would need to internalize the RAI Principles in their investment policy for agriculture and rural development and adjust their lending and grant policies accordingly.
States should be encouraged to adjust their current legislation on domestic and foreign investment to make room for RAI Principles. Implementation is the prerogative of the States and there is not much that CFS can do.
Monitoring the progress in the implementation of RAI Principles could be handled by CFS.