Dear colleagues,
this is an important effort to bring together and clarify a number of highly complex issues, thank you for this. Below, I list some comments. I first present some general comments, then more specific ones, directly referring to the text.
Please contact me any time in case questions arise and I am happy to further contribute to this in whatever form may be useful.
Best regards, Adrian Muller, Research Institute of Organic Agriculture FiBL. 9.12.2018
General comments:
Such documents are needed and important and can help guiding discussion and action, but I think that such documents often remain somewhat too general and unspecific. In my opinion, this also applies to this document.
First, I think that there is a lack of concreteness in the formulation of all the frameworks and approaches mentioned in section 2. In my understanding, these should work as toolboxes for reducing complexity and they should be formulated in an as concrete way as possible, so that one can really work with them. For some further details on this, see my comment below referring to page 19.
Second, I think the document falls short of really making concrete suggestions on what can be done. There is a general call to arms and suggestions to increase information provision, research and development, also internalization of external costs, etc. – but I think one could and should become much more concrete, e.g. on pages 40/41 on policy instruments. In my opinion, there is a number of policy instruments/approaches that could be supported in any case, i.e. that robustly would lead to improvements in a broad context of diverse characteristics. I think such a document should aim at identifying and promoting those. Examples I usually think of are the following – without having researched on those systematically, without having analyzed those in depth, and without aiming for completeness:
- Taxation of any nitrogen that is imported into certain regional boundaries: this would apply to concentrate and other feed imports and to mineral fertilizers, for example, but not to N in feed grown locally or to N from biological N fixation within these regional boundaries. Reducing these N imports to regions (what such a tax would aim at) is key to address a number of environmental challenges, from N2O emissions and climate change to biodiversity loss.
- In parallel, we need a tax on CO2 from burning fossil fuels. This is more adequate than a general GHG tax or a tax on meat, for example, as it would not put grass-fed ruminant production at a disadvantage, as it may not be optimal for the climate, but can play a central role in sustainable food systems in relation to other indicators.
- Further aspects I would suggest to pursue: a ban on any advertisement of food. Or at least a strong restriction on such advertisement, in particular a prohibition to transport wrong pictures on how farming looks like (in Switzerland, all advertisement related to food promotes an idyllic farming system that is very far from reality…).
- And I would also suggest to work towards keeping as much of the value chain of a product within the country that produces the original product. When acting on value chains, I think this approach may bring more than the general claim to support shorter value chains and to bring consumers and producers closer together (for more on the criticism of this last point, see my comment referring to page 20 below).
Third, some general guiding principles for improvement could be made stronger; these are mainly
- The aim for consistent policies. It does not make sense to work on biodiversity measures and at the same time subsidizing mineral fertilizers and pesticides, for example. Or to work on health issues by, say, a tax on sugar and on the same time supporting sugar cane production by special payments for this. Thus, a general call should be for reducing perverse incentives, combined with the internalization of external costs – the latter is part of the document, but it could be made more prominent; and it could be related to the general discussion of consistent policy approaches.
- the necessity to openly and self-critically analyze one owns values; many statements are value loaded and I think they rather have the status of hypotheses than facts – cf. the comment referring to page 20 below.
Other aspects that I would claim to be such value driven implicit hypotheses rather than facts are the following: informed stakeholders act in favor of increased sustainability; power-less stakeholders act more responsible and in support of sustainability when given more power than the currently powerful stakeholders; increased stakeholder involvement leads to increased sustainability. I do not argue against those issues per se: more information; change in power relations; stakeholder involvement (and also short value chains, see other comments) – all these can contribute much; but I think that we – the people working on sustainable food systems, etc. – tend to be biased towards expecting too much from these aspects I challenged above.
Here, I may also point to a specific discussion that relates to “naturalness” and which role this may play in sustainable food systems, as e.g. addressed in the following paper: https://www.sciencedirect.com/science/article/abs/pii/S026483771631376X
Specific comments:
Page 8, definition of “food system”: to keep it manageable and useful, there needs to be some reference to boundaries (geographical, population-wise, or whatever), otherwise, we have in many cases only one food system, the global one (besides some special cases of self-sufficiency), as it captures “all the elements” by definition, thus necessitating it to encompass everything.
Page 9: “This means that sustainable food systems are profitable throughout (economic sustainability);” I think “profitability” is a difficult term here – it should be clearly stated that this means profitability while accounting for internalized external costs and public good provision and not only profitability of a single business action in a given policy context (that thus may not get payments for public good provision, but may benefit from externalizing societal costs). Thus, may better write: “This means that sustainable food systems account for external costs and public good provision (internalization of negative and positive externalities) when being judged regarding their profitability (economic sustainability);”
Page 13: “On the social dimension, a food system is considered sustainable when there is equity in the distribution of the economic value added, taking into account vulnerable groups” – do you really mean “equity” and not “just” (justice), i.e. “…when the distribution of the value added is just, taking into account…”? This makes quite a difference.
Page 14: “…will have to be assessed against all other dimensions of sustainability to ensure there are no undesirable impacts.” This formulation is too absolute, as in most changes, there will be trade-offs and some undesirable impacts will always arise – e.g. if the internalization of external costs is strengthened, then there will be some players that loose profit. One may argue that this is “desirable” – but then we need a clear definition of which impacts are desirable and which ones are undesirable, or we need at least some guidelines on how to determine this. And even then, in many cases trade-offs will remain unavoidable – and which guiding principle will help us then? – “no undesirable impacts” hinders many actions with such characteristics. One way out could be to claim that total societal welfare increases – but this is very general (but in this it fits the level of discussion addressed in this document). This solution is offered three lines later – but then better formulate such as to allow for undesirable impacts, as long as the net overall impact is positive (which bears complexities regarding matters of equity and justice, etc…).
Page 16: I struggle with formulations as the following: “aim to ensure the provision of sufficient nutritious, sustainable, culturally acceptable, desirable and affordable food to consumers, while generating decent incomes to producers and other value chain actors, as well as protecting natural resources both domestically and abroad.” These are good aims – but in their aim to cover and improve everything, they bear the danger to result in inaction, as it is highly complex to work with such issues. What I would expect from this document is support and guidance regarding very concrete actions and goals to be pursued as proxies for all this – may not living up to all these good intentions and values, but at least reasonably well (cf. the general comments above).
Page 16: “The main actions suggested by the SFS Transformative Framework in this regard are to” the four actions that follow remain very general… - these are from another document, thus they cannot be changed here, but this document here may could try to make them much more concrete.
Page 18: “people need better information and clearer recommendations regarding environmentally, socially and economically sustainable food and how food consumption impacts on all elements of the food system.” This is a suggestion for concrete action – but on the basis of which insights? Is it really the case that more information and clearer recommendations leads to improvements? I doubt this when looking at our western societies, where we have all this information and recommendations and not much changes…
Page 19: Given the definition “A food value chain (FVC) consists of all the stakeholders who participate in the coordinated production and value-adding activities that are needed to make food products reach consumers.” I do not see how this may be primarily “an analytical approach to understanding how supply chains work in practice and how they can be influenced to achieve desired outcomes”. An analytical approach is something different, it should, for example, offer the concepts to be used for reducing complexity – thus: e.g. focusing on different stakeholders and their relations, such as “stakeholder analysis”, or focusing on governance, actors and resources, such as the “socio-economic systems” approach, or focusing on drivers, pressures, states, impacts, responses, such as the DPSIR, or focusing on different capitals, such as the livelihood approach. What is needed are suggestions for frameworks on how to reduce complexity when dealing with food systems, not definitions that encompass everything or commitments to take everything into account without concrete suggestion on how to really achieve this.
In this, also the “sustainable food value chain approach” from page 20, for example, should be made more concrete, to clearly name which concepts are used to reduce complexity and then to work with the issues of interest.
Page 20: “in creating a strong linkages between consumers and producers that contributes to the sustainability of the food system” – can you prove that this really is the case – in general, not only in case studies. I think it rather has the quality of a hypothesis. Furthermore – how scalable is this? How many consumers can and want to have a close linkage to producers? This may be a small fraction of all consumers only.
I think this is a general danger in these discussions, that people working on sustainable food systems think that people are and should be interested in food and “good” food in particular (however defined). I doubt this and I would rather say that 80% are not interested in this at all and I also do not think that people should be interested in food if they do not want to be so (I would love if they were – but can we really require this in a liberal context, where people should have their say on what is a “good life” for them?). They just want to eat – better or worse, but without much effort – and cheap. This is also merely a hypothesis, but depending on which one is right, actions to improve the food systems may look totally different…
Page 30: As observed by Godfray (2015): “Sustainable intensification if treated seriously is genuinely radical. It is not a smorgasbord of interventions that can be chosen at will to justify different farming methods and philosophies. It is a coherent program that seeks radical change in the way food is produced and which places as much weight on improving environmental sustainability as on economic efficiency. It should not be seen as business-as-usual with marginal improvements that benefit the environment, nor as a call for a purely environmental agenda that fails to acknowledge the need to meet people’s expectations for affordable, nutritious and varied food.”103 This is all nice – but this still seems to be a hypothesis – where are the concrete contents of SI as a coherent program?
Page 30, SI: may make explicit, that SI tends to have a bias towards supporting efficiency: less input and impact per kg output, etc. – this is adequate for some indicators (e.g. GHG) but less so for reactive N, for example, which affects ecosystems, and these impacts are crucially related to areas and impacts per area rather than per ton produce.
Page 38: “Food that provides calories lacking adequate nutrient density – due to impoverished soils, over-processing, unbalanced genetics, or some combination of these – are also topics of study from a public health perspective.” – With regard to this, I would suggest to also address the issue that certain yield increases are mainly driven by increases in starch, etc. , thus leading to diluted micronutrients per energy – thus, these commodities become micro-nutrient deficient due to increasing yields – thus, increasing productivity, as emphasized above, needs to be addressed with caution when choosing the measures to assess this.
Page 42, bottom: reference is made to section 2.1. on the SFS transformative framework for more concrete examples; but in 2.1, concreteness remains rather low, and there are no direct references to SFS transformative framework given. Even when googling it, one gets very few hits only and no specific document – so please make this much more concrete – ideally in section 2.1., or refer to the relevant web-resources.
Adrian Muller