Global Forum on Food Security and Nutrition (FSN Forum)

This member contributed to:

    • 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.


      • Aquatic Foods: We are pleased to see the inclusion of aquatic foods from land-based aquaculture, and the discussion of the impacts of food production on aquatic food systems. It would be logical to also note the value of sustainably produced aquatic foods as a climate-smart source of nutrition, which new peer-reviewed research has documented the case (see this Nature special issue, and Free et al. 2022). We strongly encourage the project organizers to expand the focus of this work to include aquatic food systems more broadly – beyond just land-based aquaculture, or even just aquaculture.
        • Aquatic foods (fish, invertebrates, seaweed, and other aquatic species) are a key source of both protein and micronutrients for billions of people, and aquatic food systems are a cornerstone of the livelihoods, economies, and cultures of many coastal and riparian communities. They are especially important for coastal and rural communities throughout the Global South and the developing tropics, where vulnerability to malnutrition and food insecurity are especially high (A. Bennett et al., 2021). In addition to their importance as sources of animal protein, and often more importantly, fish are crucial sources of vital micronutrients, such as zinc, iron, A and B vitamins, and essential fatty acids (Golden et al., 2021). These micronutrients are generally more bioavailable in fish compared with plant-source foods, and fish is also often more affordable than other animal protein sources. If eaten locally, these resources have the added benefits of being accessible and affordable to the communities who need them most, and locally-caught species are likely to be familiar, culturally appropriate food sources that can provide necessary nutrients without requiring a dietary shift (Hicks et al., 2019).
        • Additionally, fishing can be a critical food source for landless people, as well as an important safety net during political, economic, and/ or environmental shocks that disrupt land-based food production.
        • On top of all these food and nutrition benefits, fish (especially wild-caught seafood) is a significantly more sustainable food source across multiple dimensions, including greenhouse gas emissions, nitrogen release, water use, and land use, when compared with a wide-variety of land-based foods, and especially when compared with other animal protein sources (Gephart et al., 2021). A recent paper suggests that, through improved management of wild fisheries and expansion of sustainable ocean aquaculture, aquatic foods can meet or exceed per capita seafood demand in nearly every country, under all but the worst case climate scenarios (Free et al., 2022). For all of these reasons it’s critical that a holistic look at aquatic food systems be taken and that both capture and cultivated aquatic foods be integrated throughout this project.
      • Financing:
        • Climate Financing: Suggestion to detail stronger linkages between the impacts of climate change on food systems and the need for finance. Climate impacts are a looming challenge, and food producers need support to adapt. This is especially important in regards to the project’s focus on financing. If financing within the food systems does not account for the impacts and risks associated with climate change, there are limits to its long-term value.
        • Small-scale producer financing: Happy to see the focus on increasing financing for adaptation and transformation, but materials so far lacking in emphasis on the need to get these resources to the small-scale producers who need them.
      • Food system focus: Suggestion to include a stronger focus on food systems as a whole and not merely the production end. The current outline indicates greater focus on the food production level. The gist of the UNFSS’ findings is that all components of the food system including access to nutritious foods, a reduction in food loss and waste, reduced emissions, processing and cold chain during transportation and storage are in need of more robust levels of support and intervention in order to secure nature positive improvements in food security and nutrition.  
      • Staple versus non-staple crops and diversification: It is discouraging to see that the focus remains largely on staple commodities and crops. There is an urgent need to improve understanding and awareness of the nutritional, sustainability, and resilience value of non-staple crops, and to diversify our food systems (see Hertel et al. 2021, and the articles sited therein). We urge the organizers not to miss this opportunity to move the needle on this front and include a strong focus on non-staple crops.
      • Local and producer level focus: In the current format, this project focuses closely on more national and international levels in relation to capacity building, financing, and decision-making. Suggestion to include greater focus on resource and knowledge allocation and capacity building that reaches all the way to the frontline communities/local level who need them most – for example, food producers, and especially small-scale food producers and local extension services. It is also critical to ensure that local level actors have ownership over interventions and are in decision-making roles and that this reverberates to government and international level decision making. Too often, we see resources flowing at the national level, but not making it to the food producing communities who need them.  
      • Lessons learned and best practices: There are points within the results framework that switch between commenting on new interventions versus established interventions; it is hard to follow which is which. Suggestion to clarify when the authors are suggesting something new versus when they are suggesting improvements to existing practices.

        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:

        • For example, according to the FAO closing the gender gap report, in developing nations, women make up an estimated 43% of the agricultural workforce. The report also notes that with the same access to productive resources as men, women could increase yields on women-run farms by 20-30%. Production gains from this yield increase could reduce the number of hungry people in the world by 12-17%. We would strongly encourage this project to focus on lessons learned and gaps within inequity challenges such as this to address food systems challenges. This should not be exclusive to just gender differences but should also investigate youth, traditional and indigenous knowledge, marginalized and frontline communities, land tenure gaps in access, best practices, and knowledge and voices that should reverberate into government and international policies and planning.
      • Indicators: Suggestion to revisit draft indicators. Overall, the indicators identified are insufficient. For example, counting the number of partnerships formed, or the number of management plans developed may not be directly translatable to any meaningful insight that can lead to real-world change.  We are encouraged by some of the gender and demographic disaggregated indicators but believe that there is also great value to complimenting quantitative indicators and findings with qualitative data from frontline communities to really understand how initiatives are translating at the community level. For comparison, it would also be helpful to indicate which indicators are building from prior studies and figures and which assume that we are starting at ground zero/capturing baseline level data.

      Country level plans:

      • Happy to see reference to diversity of approaches, but need to ensure that this is aligned with all the talk about scaling and spreading in the global section above – sometimes something should not “scale,” context is critical.
      • Concern about livestock being treated as homogeneous across countries and geographies – critical to not take a broad brush to this challenge and to recognize and respect those places where livestock production is done sustainably and may be the most climate-resilient source of protein available to vulnerable populations
      • Concern about the focus on alternative proteins – ensure these are sustainably produced and accessible to those populations needing them the most. Also, critical to clarify between types of “alternative” protein sources – e.g., cell-derived sources have a very different footprint than do plant or insect derived sources.

      Some key issues specifically related to aquaculture:

      • While a discussion of investment in sustainable aquaculture is very welcome, and is overdue, it is unclear why the investment is restricted to aquaculture that is linked to land-based practices. Coastal/marine aquaculture and aquaculture in inland waters merit equal consideration, and no explanation is offered as to why they are excluded.  
      • Some clarity about what “sustainable” aquaculture means would also be welcome. (One approach would be to cite the pending Guidelines for Sustainable Aquaculture and propose to use the GSA definition(s) as a guideline once the GSA are adopted as final.)
      • The document should acknowledge the variety of aquatic food species currently consumed and be explicit about the need to encourage selection and cultivation of appropriate (and appropriately varied) aquatic species that are both ecologically suited and culturally appropriate.  
      • Since the Blue Transformation roadmap indicates the intention to move very swiftly to expand aquaculture in Africa and the SIDS, it is critical to ensure this rapidly-developing industry also develops equitably – that the people and communities whose existing food sources will be hard hit by climate change are the ones who will benefit, not just from the food produced through aquaculture but also from the wealth produced as this industry expands. We urge the inclusion in this programme of positive lessons learned from, for example, FAO-assisted projects that create locally-based and women-led small-scale aquaculture to support School Feeding Programs in India, Africa and Latin America.
      • Strong governance and policy guidance is critical to the development of sustainable, equitable aquaculture in marine and freshwater systems – which will be critical to meet the aquatic food demands of the growing population with climate change (Free et al. 2022), so we hope this opportunity to catalyze this development will not be missed. 
      • With IFAD in the lead in this programme, it is essential that deficiencies in the Agency’s capacity to promote and oversee aquaculture programme development for small-scale fisheries and aquaculture, as detailed in the Evaluation Synthesis conducted by the IFAD Independent Office of Evaluation, be addressed. This report found that IFAD had “given limited explicit attention to aquatic resources and to the rural poor who depend on them” in its strategic frameworks and sectoral policies, and that IFAD had “limited in-house expertise in these areas of work.”


      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?

      1. Do the barriers identified reflect your experience as Community Based Organizations (CBOs) / Non-Governmental Organizations (NGOs), private sector and local communities (women, men, youth, indigenous peoples)? Are there key barriers that are missing in TOC?
        • 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:

          • Happy to see mindsets etc., but the current TOC is missing the system paradigms beneath them – like the paradigm of agro-industrial trade that drives the mindset that food resources should be valued as commodities on the market rather than based on their nutritional value; the paradigm that productivity/ a country’s success should be judged based on economic growth and production rather than on something like food sovereignty, or the Bhutan-inspired Gross National Happiness Index which considers nine domains rather than GDP alone (psychological wellbeing; health; education; time use; cultural diversity and resilience; good governance; community vitality; ecological diversity and resilience and living standards).
          • 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.

      2. Do the first level Outcomes appropriate and adequate for transformation of food systems’ impacts on the environment?
        • Challenging to state at this point due to their currently vague descriptions– would be helpful to articulate how each of the barriers will be addressed.
        • Suggestion to include further discussion of revaluation of food resources (true costs and benefits of food systems) - this is in the barriers but not carried through as an outcome.
        • Further need to clarify who needs the finance and support for adaptation – need to prioritize small scale producers and vulnerable communities.
        • Would be helpful to clarify meaning of different abbreviations.


      Draft Results Framework:

      Our comments on this Framework are provided in the document, as an attachment.


      Experiences and Advice on:

      • Scaling up approaches
        • Scaling and spreading successful interventions through behavioral and systemic change are topics that we have spend significant time thinking about and working towards. You may find our 2017 paper titled How to Achieve Conservation Outcomes at Scale: An evaluation of scaling principles (Battista et al. 2017) useful, and we also highly recommend the “scaling out, scaling up, scaling deep” framework presented in Taking Nature-Based Solutions Programs to Scale (Salafsky et al. 2021).
        • On the ground:
          • EDF India partnered with an Indian nonprofit, the Syngenta Foundation India (SFI), to create and launch a new capacity building train-the-trainer program aimed at helping local farmers adopt climate-smart agriculture techniques to meet their local needs. Through this program, agronomists and senior agri-entrepreneurs from SFI participate in a week-long educational program on climate smart agriculture in India. Then, they are asked to train a network of thousands of rural entrepreneurs and extension agents who will each train hundreds of local farmers about ways to protect their incomes while reducing environmental harm. The week-long climate smart agriculture training curriculum includes modules on the science of climate crisis, the impact of changing climate on Indian agriculture and economy, nitrogen and water management for improving yields and income, minimizing greenhouse gas emissions, maintaining soil health, and the credibility and efficiency of carbon credits.
          • The Small-Scale Fisheries Resource and Collaboration Hub — or the SSF Hub —  is an multilingual, interactive, and free-to-use platform aiming to connect small-scale fishers, fishworkers, fishery communities, and their allies. Its purpose is to spread best practices in fisheries management and policy, and to strengthen small-scale fisheries governance and community development by providing free resources, access to an online community, relevant events, and so much more. The SSF Hub was created collaboratively between EDF and other organizations from across different countries.
      • Multi-stakeholder processes
        • Supporting and facilitating multi-stakeholder participatory processes is core to EDF’s vision and theory of change, and we have significant experience and expertise in more than a dozen countries in doing so. We approach this work holistically to develop long-term solutions to related and compounding challenges, listening to the needs and perspectives of local partners and communities and offering our technical science and policy expertise to support them in meeting their goals. We provide here a few examples but would be happy to discuss this topic and offer our support more extensively if desired.
          • Fisheries: EDF’s Fishery Solutions Center houses a comprehensive set of practical fishery management tools, including our Framework for Integrated Stock and Habitat Evaluation (FISHE). FISHE is a participatory framework for adaptively assessing and managing data-limited fisheries in order to support effective, resilient, and durable co-management systems. EDF has worked with fishery managers, scientists, fishers, and other stakeholders to apply tools from FISHE in diverse fishery contexts, including:
            • Ghana – Environmental Defense Fund (EDF) has been brought in by the USAID Feed the Future Ghana Fisheries Recovery Activity (GFRA) team to support the Ghana’s newly-formed Fisheries Management Operational Committee (FMOC) in developing management measures that can support the recovery of four small pelagic fish species which are both critically overfished and critically important to food and nutrition security, as well as livelihoods, in Ghana. We are designing and facilitating a series of three multi-stakeholder workshops focused on building capacity for participatory, inclusive decision-making and for understanding and utilizing the stock, ecosystem, and climate change assessments to support progress toward co-developed goals. The outcome of this series of workshops will be a detailed Operational Management Plan for the four focal small-pelagic stocks.
            • Belize – EDF provided technical support for UNCTAD’s Oceans Economy and Trade Strategies (OETS) project in Belize by organizing and delivering a capacity building workshop for finfish fishery management in Belize and developing a proposal for a national science-based Adaptive Multispecies Finfish Fishery Management Plan.
            • Portugal – EDF provided strategic advice and detailed planning support to the ParticiPESCA coalition to organize a stakeholder group that will co-manage the fishery; EDF is guiding the group through key decisions to create a management plan that applies the FISHE framework, including through providing a technical training to the Science Advisory Group. 
          • Food systems more widely: EDF’s Climate Resilient Food Systems team has been working to apply the lessons we’ve learned from decades working on sustainable fisheries management to new efforts to address food systems challenges more broadly around the world. We are working to apply the same principles – of engaging an inclusive group of stakeholders meaningfully and deeply in a participatory goal setting, decision-making, design, and implementation process – so that solutions are owned by, and sure to benefit, locally impacted groups. For example:
            • Puerto Rico: Puerto Rico’s food system faces a host of challenges that are common to food systems around the world. These include 1) high and inequitable food and nutrition insecurity driven by lack of accessibility and affordability of nutritious foods; 2) drastic changes in both food production and diets over the course of recent history that have reduced health, livelihoods, and sustainability; and 3) a serious lack of resilience of the food provisioning system, as demonstrated by both COVID and the 2017 Hurricane Maria. We are currently working to plan and coordinate a food systems analysis workshop in Puerto Rico with a diverse, and inclusive group of stakeholders. Through this facilitated workshop we seek to uncover hidden barriers and root causes of persistent food system challenges as viewed by the people who are experiencing them, and to identify the most effective pathways toward nourishing the people of Puerto Rico sustainably in the face of climate change. By co-developing these pathways with local actors who are already driving change, and whose lives and livelihoods are at the center of these issues, we will ensure the durability, efficacy, and equity of these solutions.
      • Public-private partnerships
        • EDF has been instrumental in supporting the Lowering Emissions by Accelerating Forest finance (LEAF) Coalition, which seeks to halt deforestation by financing large scale tropical forest protection through public-private collaboration. In 2021, the Coalition mobilized $1bn in financing, kicking off the largest-ever public-private effort to protect tropical forests.
        • Following on the UN Food Systems Summit, EDF facilitated the formation of the Aquatic Blue Food Coalition. This multi-stakeholder, multi-sectoral group includes the government representatives from European Union, Fiji, Germany, Iceland, Japan, New Zealand, Canada, Palau, Portugal and the United States of America, in addition to representatives from intergovernmental organizations, NGOs, academic institutions, aquatic food producers and those along the value chain, consumer groups, financial institutions and philanthropies. The Coalition seeks to 1) Raise the profile of blue/aquatic foods in discussions of the future of food systems, including in the context of international forums such as CBD, the UNFCCC and CFS, and in national policymaking -- highlighting the relevance of aquatic foods to the SDGs and to the priorities of many government decision-makers, including health ministers, development ministers, finance ministers, and prime ministers; 2) Mobilize support -- including investment, technical capacity, and partnerships -- for countries, or groups of countries, that are setting out to integrate aquatic/blue foods into their food systems and to implement core aquatic food priorities.
      • Research gaps
        • There is a clear need to develop new methods to assess the nutritional, environmental, and social impacts of different food resources and food production methods in data- and capacity-limited contexts. For example, in systems dominated by small-scale producers it can be very difficult to quantify the water quality benefits stemming from one farmer’s reduction in fertilizer or pesticide use. Such data are desperately needed 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.
        • Similarly, as referenced above, there is also a critical need to capture data on informal food production and consumption. For example, food resources that are foraged, gathered, or gleaned by individuals who are not members of the formal food production sector will not be considered or valued in policy or management decision-making, and will therefore not benefit from any efforts to protect or restore those resources, or to ensure access to them for all individuals in need. In some cases, new data streams are becoming available, such as the Illuminating Hidden Harvests data on unassessed fisheries, which should definitely be captured in this report. In other cases, bespoke efforts will be needed to capture a comprehensive picture of food resource use in any given area.



      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.

      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.

      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.

      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.

      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.

      Hertel, T., Elouafi, I., Tanticharoen, M., & Ewert, F. (2021). Diversification for enhanced food systems resilience. Nature Food, 2(11), 832–834.

      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.

      Salafsky, N., Suresh, V., Bierbaum, R., Clarke, E., Smith, M. S., & Whaley, C. (n.d.). Taking Nature-Based Solutions Programs to Scale.

    • 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:

      • Chapter 7 on prioritized recommendations
        • The inclusion of a strong list of recommendations within this HLPE report will push this current draft into an operational domain. We highly encourage the HLPE report to highlight best practices and linkages to existing resources and frameworks throughout this section.
        • We strongly appreciate that the current HLPE draft does have emphasis on climate change and nutrition. As the HLPE works towards finalizing the recommendations section, we would like to reiterate comments from our prior submission related to four key priority recommendations: connecting climate change to food and nutrition policy; centering the need for nutrition security; elevating the value of aquatic foods; and the importance of data-limited impact assessments. We hope that these points also are centered in this final chapter.
          • There is an important opportunity with this report to draw an explicit connection between climate change and inequity in food and nutrition security. We believe a priority recommendation in chapter 7 should be the need to create climate-informed food and nutrition policies and interventions because climate change is worsening existing inequities in food and nutrition insecurity while at the same time our food systems are a major driver of climate change. It is thus critical that these issues be addressed in tandem.
          • Second, we strongly suggest that the focus should be on nutrition security, not just food security, and an important priority recommendation to flow from this report should be a drive to re-value our food resources based on their nutritional content, rather than on traditional economic factors. Doing so will incentivize the production of highly nutritious foods, as well as the channeling of these foods to the groups and people who need them most. This is in contrast to the current value system, which drives the most nutritious food resources away from the most vulnerable groups and into the hands of the wealthiest people while simultaneously incentivizing the overproduction of unsustainable and under-nutritious foods, which are then consumed in high quantities by the world’s poor because they are the most affordable and available foods.
          • Third, we were pleased to see that the report draft contains a short section on fisheries, but we urge the authors to elevate this dialogue into the priority recommendations as well. Aquatic resources, which are a critical and climate-friendly source of both protein and micronutrients for billions of people, have been chronically overlooked by entities seeking to address food and nutrition security, and the result has been detrimental to both the sustainability of our aquatic food systems and the achievement of our global food and nutrition security goals. The sustainable production of aquatic foods, and the improved affordability and accessibility of these resources, should be key goals of funders, policy makers, and development organizations.
          • Finally, we believe a fourth priority recommendation for this report should be a call to action for further focus on accounting for small-scale, data-limited food systems and not just large scale. Otherwise, policies may continue to focus on and favor only the large-scale food systems. For example, food resources that are foraged, gathered, or gleaned by individuals who are not members of the formal food production sector will not be considered or valued in policy or management decision-making, and will therefore not benefit from any efforts to protect or restore those resources. To this end, new information streams such as the Illuminating Hidden Harvests data on unassessed fisheries would be appropriate to reference as an example for this recommendation.
      • Sections in Chapter 4 on the political economy and fragility and conflict
        • EDF applauds the inclusion of this forthcoming section. Narrative on the implications of politics and conflict on our fragile food systems are needed. Further, a call to action for researchers, practitioners, governments, and the public, to engage in the development of strategies towards bolstering our food systems against such shocks is opportune.
      • Forthcoming report on “Revitalizing climate policies for food security and nutrition”
        • EDF is encouraged by the creation of a dedicated report connecting climate policies with food security and nutrition. That said, we do want to reiterate how integral climate change is in relation to issues of equity, equality, and food and nutrition security. As mentioned at length in our prior submitted comments, we believe that there is scope within this current report to further strengthen that argument.

      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:

      • Pest resistant transgenic crops developed with the insertion of Bacillus thuringiensis (Bt) such Bt Brinjal, or eggplant, received public opposition across Bangladesh, India, and the Philippines as a result of anti-GMO criticism. This led to smear campaigns in Bangladesh, it was placed under a moratorium in India, and Bt Brinjal field trials were vandalized out of protest in the Philippines (Shelton, 2021). At the same time, the introduction of BT Brinjal in Northern Bangladesh has shown to significantly reduced harmful pesticide use which has decreased farmer input cost, decreased pest related food loss plus increased available nutritious products for sale, and resulted in improved health outcomes due to reduced exposure to noxious chemicals (Shelton et al., 2020; Shelton, 2021; Ahmed et al., 2019; Ahmed et al., 2021; Haque et al., 2020). The Bangladeshi Minister of Agriculture Begum Matia Chowdhury has noted her support for the genetically modified Bt Bringal as a tool to support in feeding the nation’s 160 million people and protecting the environment (Shelton, 2021).

      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.


      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

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      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

    • 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.

      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.

      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.

      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.

      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:

      Illuminating Hidden Harvests, which seeks to quantify and standardize the immense contribution of small-scale fisheries to global fishery yields and livelihoods: (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:

      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.

      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.

      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.

      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.

      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.

      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.

      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.

      Vianna, G. M. S., Zeller, D., & Pauly, D. (2020). Fisheries and Policy Implications for Human Nutrition. Current Environmental Health Reports.  

      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.