Ms. Willow Battista

Dear HLPE Secretariat and Experts,
Thank you once again for this second opportunity to engage on this important topic and to help shape what will surely be a high-impact report.
EDF was pleased to see the incorporation of some of the comments we submitted on the Scope of Report, and we attach here some additional suggestions to further strengthen and and value to the forthcoming report.
Please contact Willow Battista for any follow up questions or for additional support ([email protected]).
-Willow Battista, Senior Manager, Climate Resilient Food Systems, Environmental Defense Fund
Environmental Defense Fund (EDF) is appreciative of this opportunity to provide a response to the VO Draft for e-consultation. EDF recognizes the importance of the HLPE reports in driving ongoing research and policy advancements. As such, we have prepared comments below that acknowledge strengths of the current draft, as well as areas that can be expanded or deepened. We believe that the forthcoming HLPE report has the opportunity to elevate these critical topics and increase support for addressing food and nutrition insecurity in an equitable and comprehensive way. We hope that our suggestions will be of value.
EDF looks forward to the development of the following forthcoming sections:
In addition to these suggestions for forthcoming sections, we provide one important comment on the text already presented in this draft:
Genetically Modified Organisms and the connection to colonial approaches (pages 48, 88-89)
“Indigenous peoples have long been concerned that colonial approaches to land for growing food rooted in agribusiness and industrial agriculture characterised by large-scale farming and the adoption of scientific-technological systems such as the use of Genetically Modified Organisms (GMOs) disregards their rights to self-determination and spiritual, cultural and physical relationships to ancestral lands (Bernstein 2013; Collier 2008; Pimbert 2009).” (pg. 48)
EDF encourages the forthcoming HLPE report to consider a more nuanced approach to the connection of GMOs to the colonization of agriculture (Sahai, 2004, Pal et al., 2007). Linking GMOs ubiquitously with a negative stigma, rather than constructively critiquing the policies that surrounded their debut, limits adaptation strategies (including climate change adaptation strategies) and impacts our ability to support small-holder farmers. See below example:
EDF therefore suggests that the narrative within the HLPE report should examine and critique existing governance and intellectual property rights, which are undeniably connected to colonial practices, rather than targeting GMOs directly and explicitly – it should be made clear that GMOs should be treated carefully and the governance that regulates them should be modified according to the needs and perspectives of impacted farmers, and especially of historically marginalized food system actors, but that GMOs can have a place within adaptation strategies and can support small-holders.
Citations:
Ahmed, A. U., Hoddinott, J., Abedin, N., & Hossain, N. (2021). The Impacts of GM Foods: Results from a Randomized Controlled Trial of Bt Eggplant in Bangladesh. American Journal of Agricultural Economics, 103(4), 1186–1206. link
Ahmed, A. U., Hoddinott, J. F., Islam, K. S., Ghostlaw, J., Parvin, A., Quabili, W., Rahaman, S. M. T., Rahman, W., & Zubaid, S. (2019). IMPACTS OF BT BRINJAL (EGGPLANT) TECHNOLOGY IN BANGLADESH. United States Agency for International Development, 1-184. Link
Castañera, P., Farinós, G. P., Ortego, F., & Andow, D. A. (2016). Sixteen Years of Bt Maize in the EU Hotspot: Why Has Resistance Not Evolved? PLoS ONE, 11(5), e0154200. Link
Haque, M. S., & Saha, N. R. (2020). Biosafety Measures, Socio-Economic Impacts and Challenges of Bt-brinjal Cultivation in Bangladesh. Frontiers in Bioengineering and Biotechnology, 8. Link
Pal, S., Tripp, R., & Louwaars, N. P. (2007). Intellectual Property Rights in Plant Breeding and Biotechnology: Assessing Impact on the Indian Seed Industry. Economic and Political Weekly, 42(3), 231–240.
Sahai, S. (2004). TRIPS and Biodiversity: A Gender Perspective. Gender and Development, 12(2), 58–65.
Shelton, A. M. (2021). Bt Eggplant: A Personal Account of Using Biotechnology to Improve the Lives of Resource-Poor Farmers. American Entomologist. 52-59. Link
Shelton, A. M., Sarwer, S. H., Hossain, Md. J., Brookes, G., & Paranjape, V. (2020). Impact of Bt Brinjal Cultivation in the Market Value Chain in Five Districts of Bangladesh. Frontiers in Bioengineering and Biotechnology, 8, 498. Link
Dear HLPE Secretariat and Experts,
Please find, attached, a set of responses and suggestions regarding this scope of report from Environmental Defense Fund.
Please contact Willow Battista for questions or follow-up.
Thank you for this opportunity to engage on this important topic.
-Willow Battista, Senior Manager of Climate Resilient Food Systems, EDF
This effort to bring together data streams and to address challenges and gaps in data collection and analysis across the food system is extremely valuable and timely. We like the conceptual food and nutrition system framework presented in section 1 and applaud the effort to combine previous frameworks (food systems, nutrition, food security, etc.) and to capture and simplify the systemic complexity. However, we note three key gaps in this proposed framework, which are also reflected in the subsequent sections on data collection and analysis:
1. The impacts of global food systems on the environment are not sufficiently represented or discussed. Given the clear need, articulated so well here in this report, to tackle the multiple linked challenges that relate to our current food system structure and functioning, it’s critical that we begin to conceptualize and target the multi-directional nature of systemic drivers and outcomes. See, for example, the recent report on how inland activities, including agriculture, are damaging rivers and freshwater fisheries, which are important food sources in their own right. Specifically, there is almost no discussion in this report of the impact of the global food system on the climate, or on biodiversity or ecosystem health at any scale. These outcome metrics should be given equal weight and attention as metrics of hunger, malnutrition, and food insecurity.
In addition to global-scale trends, data on environmental impacts of specific policies and management decisions are needed in order to avoid the risk of investing in food system interventions that appear to be improvements to the current techniques, but that actually worsen problems. For example, there has been a strong push to integrate fish into rice paddies in rice-growing regions around the world, and specifically throughout Asia. However, there is evidence that doing so can actually increase the methane off-gassing from rice paddies, thereby increasing the already significant climate change impact of this crop.
We recommend reviewing and including the following key references:
Benton, T. G., Bieg, C., Harwatt, H., Pudasaini, R., & Wellesley, L. (2021). Food system impacts on biodiversity loss: Three levers for food system transformation in support of nature (p. 75). Chatham House. https://www.unep.org/resources/publication/food-system-impacts-biodiversity-loss
Tubiello, F. N., Rosenzweig, C., Conchedda, G., Karl, K., Gütschow, J., Xueyao, P., Obli-Laryea, G., Wanner, N., Qiu, S. Y., Barros, J. D., Flammini, A., Mencos-Contreras, E., Souza, L., Quadrelli, R., Heiðarsdóttir, H. H., Benoit, P., Hayek, M., & Sandalow, D. (2021). Greenhouse gas emissions from food systems: Building the evidence base. Environmental Research Letters, 16(6), 065007. https://doi.org/10.1088/1748-9326/ac018e
References re: emissions from rice-fish systems:
Frei, M., Razzak, M. A., Hossain, M. M., Oehme, M., Dewan, S., & Becker, K. (2007). Methane emissions and related physicochemical soil and water parameters in rice–fish systems in Bangladesh. Agriculture, Ecosystems & Environment, 120(2), 391–398. https://doi.org/10.1016/j.agee.2006.10.013
Sun, G., Sun, M., Du, L., Zhang, Z., Wang, Z., Zhang, G., Nie, S., Xu, H., & Wang, H. (2021). Ecological rice-cropping systems mitigate global warming – A meta-analysis. Science of The Total Environment, 789, 147900. https://doi.org/10.1016/j.scitotenv.2021.147900
2. Although blue/ aquatic foods are mentioned in this report, their treatment feels cursory and is insufficient. Despite their importance for meeting food and nutrition goals in the face of climate change, aquatic food production and consumption are not represented or included in the high-level framework, or in the discussion around it (e.g., there are repeated references to agriculture in the Introduction section, but none to fisheries), and while there are a handful of references to aquatic foods or to fisheries in the subsequent report sections, the report misses an important discussion of the diversity of aquatic resources which have differential nutritional values, a focus on small-scale fisheries and inland fisheries, which both have a unique and important role in this challenge, and any mention of the problem of IUU fishing, which is a serious challenge to the sustainability of the world’s fisheries, and also a serious challenge to accurate data collection and analysis. Significant new data sources on the nutritional content of aquatic foods and their diversity which have recently been published in the peer reviewed literature emphasize the potential for aquatic foods to fill nutritional and food security gaps via local production, and highlight the need to continue gathering and analyzing new data as it emerges
In more detail, we recommend:
Expanding the focus of the report to better capture needs in the realm of aquatic resource monitoring and management. A key barrier to good food system planning and coherent management of wild caught fish is lack of good stock status data, which is driven by the difficulty of (a) assessing a fishery stock at any point in time, and (b) predicting it into the future, given the unknowns of climate change impacts that are without precedent.
A specific recommendation related to this gap is to expand access to data collected through the Nansen surveys (which are referenced in your report) through open access agreements. The report calls for more open access data streams, and we applaud this movement. We note that the Nansen survey data have been particularly difficult to access, even for countries who have participated in them directly. Addressing this challenge would be extremely valuable to efforts to more sustainably manage aquatic resources.
Broadening data collection efforts to capture the diversity and differential nutritional potential of different aquatic foods in order to enable informed decision-making. For example, we might prioritize a given depleted species for recovery based on its nutritional value relative to national nutritional goals, rather than on its economic value on the export market.
Disaggregating the data on aquatic foods based on fishery type, sector, scale, and gender. Small-scale and inland fisheries provide the majority of aquatic foods that are eaten directly/ locally, and the fish they catch tend to be lower-trophic level species which tend to be more nutrient dense (and are also often eaten whole, which drastically increases the nutrient intake). In addition, small-scale fishing communities, especially those throughout the equatorial tropics, tend to be among the most food and nutrition insecure, and the most vulnerable to climate change.
Similarly, disaggregating the data based on gender would be an important improvement. Women tend to make up a significant, and sometimes majority, percentage of the fishery workforce, and they also tend to make many of the food decisions for a given household, but they generally lack ownership or fishery management decision-making authority. Increasing the amount and quality of gender disaggregated production data is critical to improving gender equity across this sector as well as food systems more generally.
Examining the problem that IUU fishing, which is often occurring at unknown and unregulated levels, presents to accurate and useful data collection, and which may be seriously distorting what we think we know about stock biomass and sustainable fishing levels.
To address these gaps, we recommend adding the following emergent and innovative data streams to your report:
FishNutrients component of Fishbase, which captures or estimates the specific nutritional content of a vast array of aquatic species caught around the world: https://www.fishbase.in/Nutrients/NutrientSearch.php
Illuminating Hidden Harvests, which seeks to quantify and standardize the immense contribution of small-scale fisheries to global fishery yields and livelihoods: https://sites.nicholas.duke.edu/xavierbasurto/our-work/projects/hidden-harvest-2/ (forthcoming)
The Global Fishing Watch platform, being designed to enable the use of multiple open-source technologies and data sources to evaluate and manage fisheries: https://globalfishingwatch.org/news-views/mapping-a-new-world/
As countries operationalize their programs to comply with the Port State Measures Agreement, they are also developing systems for documentation and tracking of seafood which will create new and better sources of data that can contribute to the knowledge base for the HLPE. Since PSMA systems are in early stages of development now, those planning to use data for decisions could seize the moment while data being collected for oversight and compliance assurance are being designed to see that the systems are designed to be useful for both insofar as possible.
As well as the following references:
Bennett, A., Basurto, X., Virdin, J., Lin, X., Betances, S. J., Smith, M. D., Allison, E. H., Best, B. A., Brownell, K. D., Campbell, L. M., Golden, C. D., Havice, E., Hicks, C. C., Jacques, P. J., Kleisner, K., Lindquist, N., Lobo, R., Murray, G. D., Nowlin, M., … Zoubek, S. (2021). Recognize fish as food in policy discourse and development funding. Ambio. https://doi.org/10.1007/s13280-020-01451-4
Fluet-Chouinard, E., Funge-Smith, S., & McIntyre, P. B. (2018). Global hidden harvest of freshwater fish revealed by household surveys. Proceedings of the National Academy of Sciences, 115(29), 7623–7628. https://doi.org/10.1073/pnas.1721097115
Gephart, J. A., Henriksson, P. J. G., Parker, R. W. R., Shepon, A., Gorospe, K. D., Bergman, K., Eshel, G., Golden, C. D., Halpern, B. S., Hornborg, S., Jonell, M., Metian, M., Mifflin, K., Newton, R., Tyedmers, P., Zhang, W., Ziegler, F., & Troell, M. (2021). Environmental performance of blue foods. Nature, 597(7876), 360–365. https://doi.org/10.1038/s41586-021-03889-2
Golden, C. D., Koehn, J. Z., Shepon, A., Passarelli, S., Free, C. M., Viana, D. F., Matthey, H., Eurich, J. G., Gephart, J. A., Fluet-Chouinard, E., Nyboer, E. A., Lynch, A. J., Kjellevold, M., Bromage, S., Charlebois, P., Barange, M., Vannuccini, S., Cao, L., Kleisner, K. M., … Thilsted, S. H. (2021). Aquatic foods to nourish nations. Nature, 598(7880), 315–320. https://doi.org/10.1038/s41586-021-03917-1
Harper, S., Adshade, M., Lam, V. W. Y., Pauly, D., & Sumaila, U. R. (2020). Valuing invisible catches: Estimating the global contribution by women to small-scale marine capture fisheries production. PloS One, 15(3), e0228912. https://doi.org/10.1371/journal.pone.0228912
Hicks, C. C., Cohen, P. J., Graham, N. A. J., Nash, K. L., Allison, E. H., D’Lima, C., Mills, D. J., Roscher, M., Thilsted, S. H., Thorne-Lyman, A. L., & MacNeil, M. A. (2019). Harnessing global fisheries to tackle micronutrient deficiencies. Nature, 574(7776), 95–98. https://doi.org/10.1038/s41586-019-1592-6
Maire, E., Graham, N. A. J., MacNeil, M. A., Lam, V. W. Y., Robinson, J. P. W., Cheung, W. W. L., & Hicks, C. C. (2021). Micronutrient supply from global marine fisheries under climate change and overfishing. Current Biology, 31(18), 4132-4138.e3. https://doi.org/10.1016/j.cub.2021.06.067
Vianna, G. M. S., Zeller, D., & Pauly, D. (2020). Fisheries and Policy Implications for Human Nutrition. Current Environmental Health Reports. https://doi.org/10.1007/s40572-020-00286-1
3. The report and framework are missing the “group” and “farm/ fishery” scales/ levels of analysis. In both the introductory framework and the subsequent report there are discussions of data collection challenges and gaps at macro, systemic, global, national, community/household, and individual scales, but the specific challenges and data needs associated with the “group” and “farm/fishery” scales of analysis are overlooked. Many of the issues discussed in this report around barriers to data collection and use at the national and global level are even more pronounced at the “group” and “farm/fishery” levels.
And in addition:
The “group” level may be larger or smaller than “community,” as “group membership” can be defined by, for example, culture, race, gender, Indigenous status, income, or scale of production (for producers), among other factors. However, despite its imprecision, a focus on the “group” level is critical when approaching food system challenges, as group membership has relevance for both food system drivers (e.g., social norms and cultures around food that drive demand) and for how the current food system will be experienced across the 6 FSN dimensions (agency, stability, sustainability, access, availability and utilization). Explicit inclusion and examination of the food system at the scale of the “group” will help ensure inequities are identified and addressed.
The “farm/ fishery” level is especially critical to explicitly discuss in relation to data collection. We strongly suggest the incorporation of a section in this report dedicated to the need for measurement, metrics, and indicators of the climate forcing, biodiversity, and other environmental impacts of various methods of food production at the farm/fishery level. Such data are desperately needed, especially throughout the small-scale farms and fisheries of the world, to enable more accurate and appropriate valuation of different food resources, and to facilitate the creation of policies and management plans that incentivize more sustainable and regenerative practices. If we seek to make progress on the challenges of food system transformation in an equitable way, we must be able to account for farm-level differences in performance along a variety of metrics. Without this precision, policies and market incentives will favor larger-scale, industrialized operations that can afford to adopt expensive new technologies, and smaller-scale farmers and fishers will be left behind.
Ms. Willow Battista
EDF Comments on GEF-8 funded FAO/ IFAD “New Food System Integrated Program to support the transformation of food systems into nature-positive, resilient, and pollution free system”
Please contact Willow Battista, Senior Manager of Climate Resilient Food Systems ([email protected]) for questions or follow-up
Environmental Defense Fund (EDF) is appreciative of this opportunity to provide comments on the initial components of this important New Food System Integrated Program. We see this effort as an important and globally impactful initiative stemming from the UNFSSS. We hope our suggestions will be of value and are happy to provide additional support as needed.
We provide here some higher-level comments and suggestions, followed by answers to the specific questions on the Theory of Change. Our comments on the Draft Results Framework are provided directly on that document and submitted here as an attachment.
Overall:
Further, the document strongly focuses on setting up new and different models and places less emphasis on supporting, or improving upon and bolstering, existing models. Suggestion to promote and highlight local lessons learned and best practices within the food systems and ensure that promoted practices are equitable, because the speed of uptake might be greater and levels of resistance lower:
Country level plans:
Some key issues specifically related to aquaculture:
Theory of Change
Overarching comment: it is not clear what the colors/ groupings mean – are they intended to tie to specific SDGs with similar colors?
Missing drivers:
System structures, rules, and paradigms – these are partially captured in the barriers but not mentioned in the drivers. Drivers seem to focus on individual behaviors and decisions rather than systemic issues
Missing barriers:
Suggestion to include more on holistic decision-making and evaluation of tradeoffs, especially across geographic boundaries – e.g., using food resources for biofuels; or a requirement to grow only organic food, and the potential for these “sustainability” policies to drive deforestation elsewhere. We need frameworks to assess these tradeoffs and to create holistic policies to avoid externalities of the process of transformation.
Inclusion and valuation of traditional and Indigenous knowledge and local expertise for decision-making is currently missing in this TOC. There is a lot of emphasis on knowledge throughout this TOC – often the lack of knowledge is not the problem, it’s the lack of access to resources or capacity to act on that knowledge. (It is notable that the CFS-HLPE flagged ‘building a meaningful interface for diverse knowledges and practices for FSN’ in its 2022 Note on critical, emerging and enduring issues meriting further attention.
Lack of concrete barriers to equitable food systems – e.g., women having less land ownership, access to education/ knowledge, productive assets, technology, etc. There is need to discuss specific groups accessing knowledge and capacity – this could be linked to other FAO related work such as Closing the Gender Gap for Development or FAO’s work on Indigenous Peoples’ Food Systems work, and implementation of the Voluntary Guidelines on Responsible Governance of Tenure for Land, Fisheries and Forests in the Context of National Food Security.
Draft Results Framework:
Our comments on this Framework are provided in the document, as an attachment.
Experiences and Advice on:
References:
Battista, W., Tourgee, A., Wu, C., & Fujita, R. (2017). How to Achieve Conservation Outcomes at Scale: An Evaluation of Scaling Principles. Frontiers in Marine Science, 3. https://doi.org/10.3389/fmars.2016.00278
Bennett, A., Basurto, X., Virdin, J., Lin, X., Betances, S. J., Smith, M. D., Allison, E. H., Best, B. A., Brownell, K. D., Campbell, L. M., Golden, C. D., Havice, E., Hicks, C. C., Jacques, P. J., Kleisner, K., Lindquist, N., Lobo, R., Murray, G. D., Nowlin, M., … Zoubek, S. (2021). Recognize fish as food in policy discourse and development funding. Ambio. https://doi.org/10.1007/s13280-020-01451-4
Free, C. M., Cabral, R. B., Froehlich, H. E., Battista, W., Ojea, E., O’Reilly, E., Palardy, J. E., García Molinos, J., Siegel, K. J., Arnason, R., Juinio-Meñez, M. A., Fabricius, K., Turley, C., & Gaines, S. D. (2022). Expanding ocean food production under climate change. Nature, 1–7. https://doi.org/10.1038/s41586-022-04674-5
Gephart, J. A., Henriksson, P. J. G., Parker, R. W. R., Shepon, A., Gorospe, K. D., Bergman, K., Eshel, G., Golden, C. D., Halpern, B. S., Hornborg, S., Jonell, M., Metian, M., Mifflin, K., Newton, R., Tyedmers, P., Zhang, W., Ziegler, F., & Troell, M. (2021). Environmental performance of blue foods. Nature, 597(7876), 360–365. https://doi.org/10.1038/s41586-021-03889-2
Golden, C. D., Koehn, J. Z., Shepon, A., Passarelli, S., Free, C. M., Viana, D. F., Matthey, H., Eurich, J. G., Gephart, J. A., Fluet-Chouinard, E., Nyboer, E. A., Lynch, A. J., Kjellevold, M., Bromage, S., Charlebois, P., Barange, M., Vannuccini, S., Cao, L., Kleisner, K. M., … Thilsted, S. H. (2021). Aquatic foods to nourish nations. Nature, 598(7880), 315–320. https://doi.org/10.1038/s41586-021-03917-1
Hertel, T., Elouafi, I., Tanticharoen, M., & Ewert, F. (2021). Diversification for enhanced food systems resilience. Nature Food, 2(11), 832–834. https://doi.org/10.1038/s43016-021-00403-9
Hicks, C. C., Cohen, P. J., Graham, N. A. J., Nash, K. L., Allison, E. H., D’Lima, C., Mills, D. J., Roscher, M., Thilsted, S. H., Thorne-Lyman, A. L., & MacNeil, M. A. (2019). Harnessing global fisheries to tackle micronutrient deficiencies. Nature, 574(7776), 95–98. https://doi.org/10.1038/s41586-019-1592-6
Salafsky, N., Suresh, V., Bierbaum, R., Clarke, E., Smith, M. S., & Whaley, C. (n.d.). Taking Nature-Based Solutions Programs to Scale. https://stapgef.org/sites/default/files/2022-02/Taking%20Nature%20Based%20Solutions%20to%20Scale%202021-01_0.pdf