Thanks for the opportunity given and congrats for the hard and consistent work. Regarding your key question 3, Right to Food (R2F) and the Human Rights-Based Approach (HRBA) should be included, at least, in the glossary / list of terms in chapter 4.

A. Making the case:

1. The draft-paper clearly fosters the three dimensions of sustainability, i.e. economic, social, environmental, (also called the “Triple Bottom Line” / People - Planet - Profit (TBL or 3BL)). Yet, to “ensure Food and Nutrition Security (FNS) for all in such a way that the economic, social and environmental bases / assets are not compromised” (page 8 of the paper), Rights and Governance must be part of the picture. For the propose, the “livelihoods approach” could also be helpful.

2. Sustainable Food Systems (SFS), addressing Food and Nutrition Security (FNS), involve multiple rights and subsequent obligations as well as Governance challenges. These elements clearly emerge all along the draft-paper and in the very definition of SFS (e.g. ensure food security and nutrition for all, holistic approach, Responsible investments in agriculture and food systems, address underlying / root causes, among others). The draft-paper explains that “governments remain in the driving seat, promoting efforts towards coherent implementation of globally agreed frameworks and commitments”. Yet, the Right to Food (R2F) and the Human Rights-Based Approach (HRBA) are not explicit in the draft-paper. First step on Human Rights promotion and protection is to make them explicit. To act, based on Human Rights, we have to speak Human Rights. So, what is implicit in the draft-paper must also be explicit, at least as a term under chapter 4.

3. The paper refers to “food sovereignty”, which is a good step forward, and by doing so, indirectly refers to peoples “right to define their own food and agriculture systems”, putting “those who produce, distribute and consume food at the heart of food systems and policies rather than the demands of markets and corporations”. As Olivier De Schutter, former UN Special Rapporteur on the Right to Food, said, “there is simply no other way we can combine the need to produce enough food for all and the need to meet the environmental challenge: only by supporting the vast mass of smallholders in the developing world, and by supporting them to produce for the local communities, can this challenge be met” (Desk Study on EC activities in the Right to Food area and on the Relationship between Food Sovereignty and the Right to Food, SOGES, Venetsanou, 2010 https://europa.eu/capacity4dev/file/13049/download?token ). However, the “food sovereignty” cannot substitute but combine with the Right to Food and HRBA (inter-complementary and mutually reinforced domains of action). Whereas “food sovereignty is a political claim defending the right of a community, whether at national or sub-national level, to decide how to feed itself and how to combine domestic production and international trade, the HRBA and the Right to Food (R2F) add a legal dimension to FNS” (idem).

4. The Right to Food (R2F) underpins the claim that people should be able to feed themselves as a matter of right rather than as a matter of policy choice. Poor are voiceless in the political “bargaining” to which policies’ design, interpretation and implementation are subject. Food insecure people, though in great numbers, are powerless in the political arena. The R2F sets benchmarks in the political negotiation and the trade-offs between efficiency and equity, defending people’s fundamental rights and freedoms as a non-negotiable bottom line. It does so, not at a rhetorical / abstract level of good-wishes, but, relying on the Human Rights machinery at Global (international law / binding commitments) and Country (national legislation and institutional arrangements) level. This way empowering vulnerable small-farmers can be highly relevant to sustainability (we could further develop and refer examples but, this is a big chapter and I would like to keep it as short as possible).

5. Once policies / Plans / Programmes are defined in a rights-based approach, “beneficiaries” become “rights-holders”, and the authorities designing and implementing programmes accept that they may be held accountable to them (duties-bearers). The Human Rights machinery as well as the HRBA provide a solid basis for an effective accountability. Several countries already fostered the Right to Food in their constitution and legal framework. Monitoring mechanisms, including claims and redress, are in place also at international level.

6. FNS deprived from the R2F may end up either as a catch-all rhetoric or strictly project/program anchored action. Effective ownership requires institutional and legal capabilities at country and local level. So, SFS programmes, along with technical and organisational proposals must also promote such institutional arrangements and capabilities.

B. Some key references:

1. Voluntary Guidelines on the Right to Adequate Food http://www.fao.org/3/a-y7937e.pdf

2. Right to Food http://www.fao.org/faoterm/collection/right-to-food/en

3. Special Rapporteur on the Right to Food https://www.ohchr.org/EN/Issues/Food/Pages/FoodIndex.aspx

4. European Commission, Communication from the Commission to the Council and the European Parliament: An EU policy framework to assist developing countries in addressing food security challenges. COM(2010)127 final. Brussels, EC, 31 March 2010. http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2010:0127:FIN…

5. Implementing EU food and nutrition security policy commitments: Third biennial report https://ec.europa.eu/europeaid/implementing-eu-food-and-nutrition-secur…

6. Monitoring a moving target: Assessment of the implementation plan of the EU Food Security Policy Framework https://concordeurope.org/wp-content/uploads/2017/01/Assessment-of-the-…

7. The SR's opening speech on Right to Adequate Food meeting at the Committee of Food Security, 24 January 2017 https://www.ohchr.org/Documents/Issues/Food/Event24Jan2017.pdf