Global Forum on Food Security and Nutrition (FSN Forum)

This member contributed to:

    • Dear HLPE Secretariat and Experts,

      Thank you for the opportunity to contribute reflections on the V0 draft report on reducing inequalities for food security and nutrition. Please find attached a set of responses and recommendations from SwedBio, a programme on biodiversity and equitable development at Stockholm Resilience Centre. 

      We appreciate the opportunity to provide input and welcome this progressive and comprehensive report and its emphasis on agency, intersectionality and power relations, and transformative change through human rights-based approaches for the realisation of the right to food for all.

      Our reflections below respond primarily to the consultation questions 2 (does the V0 draft sufficiently cover the implications of broadening the definition of food security with regard to inequalities), 4 (gaps in the literature and data referred to), 7 (issues concerning inequalities in FSN or within food systems that have not been sufficiently covered).

      In our view, the framing of the issues in the early chapters could be more coherent with the systemic drivers and actions described later in the report. The coherence and logic of the report would be improved if key cross-cutting concepts and drivers related to inequalities in food systems for food security and nutrition outcomes were more clearly integrated throughout the report and introduced in the initial chapters when framing the issue. This concerns issues such as:

      - Human Rights as a general framework: a definition could be added to Table 1 to clarify as a foundation framework for addressing inequalities in FSN. The explanation should connect and emphasise the framework in line with Chapter 6, where the relation of rights perspective, FSN, and equity are more detailed. Alternatively, an opening paragraph clarifying human rights as a general framework, as stated in HLPE 14. This would pave the way for comprehension of the foundation to tackle (reducing) inequalities.

      - The Right to a clean, healthy and sustainable environment is recognized as a fundamental human right and part of the international legal framework (UNGA, 2022 https://digitallibrary.un.org/record/3983329?ln=en). Human rights and a healthy planet are mutually dependent. Therefore, it is vital to acknowledge the R2HE in the debate concerning inequalities and FSN. We observe an increase in biodiversity loss, environmental degradation, and climate change, which impact the livelihoods of a large number of people and particularly the ones in vulnerability, exacerbating inequalities and causing food insecurities, among other issues. The realization of the Right to a clean, healthy and sustainable environment is fundamental to improving environmental quality and governance, which are preconditions for healthy and sustainable food production and livelihoods. See the Right to a healthy environment: good practices report of the Special Rapporteur on the issue of human rights obligations relating to the enjoyment of a safe, clean, healthy and sustainable environment https://documents-ddsny.un.org/doc/UNDOC/GEN/G19/355/14/PDF/G1935514.pd… and the Right to a Healthy Environment – information Note https://www.ohchr.org/sites/default/files/documents/issues/climatechange/informationmaterials/2023-01-06/r2heinfofinalweb.pdf

      - Role of nature and biodiversity in relation to multidimensional poverty, human well-being, food security and nutrition: In line with the recommendation above on the R2HE, the report could more clearly outline the interdependencies between healthy ecosystems and FSN and inequalities in this realm. Diverse and productive terrestrial and marine ecosystems, both wild and managed, provide a foundation for livelihoods, food and nutrition security and rich and varied biodiversity, both wild and cultivated, contributes to reducing malnutrition and sustaining a more nutritious diet. Consequently, the main drivers of ecosystem degradation, such as land use change, overexploitation of species, and climate change, also undermine rights to sustainable and equitable development and food security and nutrition. This is particularly true for marginalised and vulnerable people living in poverty. This was evidenced in chapter 2.1 on Status and trends - Drivers of change in the IPBES Global Assessment report, 2019.

      These interdependencies could be made more clear for example by making the connection between the SDGs and food security and nutrition, e.g. as illustrated by Stockholm Resilience Centre (https://www.stockholmresilience.org/research/research-news/2016-06-14-t…) outlining how all SDGs are directly or indirectly connected to sustainable and healthy food, with the biosphere (and SDGs 6, 13, 14 and 15) providing the foundation for food security (SDG 2), but is undermined e.g. by overfishing (SDG 14), deforestation and unsustainable land use (SDG 15), freshwater shortage (SDG 6), and the climate crisis (SDG 13). These interactions and the foundational role of the biosphere-related SDGs are crucial also for SDG 1 on poverty.

      Interventions that ignore nature and culture can reinforce poverty (Lade et al., 2017). The concept of poverty traps as situations characterised by persistent, undesirable and reinforcing dynamics (Haider et al., 2018) is increasingly being used to understand the relationship between persistent poverty and environmental sustainability (Lade et al., 2017). A lack of social-ecological interactions in a social-ecological system can contribute to a poverty trap. For example, a lack of diverse seeds during a drought, can impoverish a farmer (https://www.stockholmresilience.org/research/research-news/2018-01-29-broadening-thedefinition-of-a-povery-trap.html)

      It might also be useful for this report to develop in parallel with and consult the IPBES process of developing the nexus and transformative change assessments, which will both provide critical insights on the relationship between biodiversity, food, health, climate change and sustainable development. This would also deepen the synergies across the IPBES knowledge base, including Indigenous and local knowledge, and the HLPE.

      Finally, the recently adopted Kunming-Montreal Global Biodiversity Framework under the Convention on Biological Diversity is a milestone toward living in harmony with nature, seeking to stop and reverse biodiversity loss. As highlighted previously, biodiversity is essential for economic and social well-being, food security and safety, and human health. The Global Strategic Framework recently adopted, as well as the supplementary agreements to the CBD, the Cartagena Protocol on Biosafety and the Nagoya Protocol on Access and Benefit-Sharing might be helpful to pay attention to. Linking the report analysis and proposed actions for reducing inequalities in FSN with the expected outcomes, targets, and goals of the Biodiversity Convention can provide more adherence of policymakers and linked work towards a more equal and sustainable society in harmony with nature. It is important to highlight Target 10 in the newly adopted Framework, which foresees ensuring sustainable use of biodiversity through biodiversity-friendly practices which contribute to food security. See COP-15 Decision documents, particularly CBD/COP/DEC/15/4 Kunming-Montreal Global Biodiversity Framework https://www.cbd.int/conferences/2021-2022/cop-15/documents

      These reflections regarding the decisions on the Convention of Biological Diversity would be suitable for Chapter 4, where the root causes for FSN inequalities are presented, and Chapter 5, where the actions to reduce inequalities are presented.

      - Food sovereignty is only introduced in Chapter 6, however as a central concept related to inequalities in food systems and closely related to the aspect of agency in the broadened definition of food security it should preferably be discussed and defined already in Chapter 1, including e.g. in table 1. As elaborated in the HLPE 14 report, the food sovereignty concept seeks to ensure more equitable trade relationships; land reform; protection of intellectual and indigenous land rights; agroecological production practices; gender equity and participation in defining policies. Aspects which are all central for addressing inequalities in food systems and widely discussed in the V0 draft.

      In addition, we are lacking and would like to see a clearer integration of the following areas in the report:

      - The role of aquatic foods (marine and inland) – fish, shellfish, aquatic plants and algae captured or cultivated sustainably and equitably in freshwater and marine ecosystems – play a central role in food and nutrition security for billions of people; they are a cornerstone of the livelihoods, economies, and cultures of many coastal and inland communities. increasingly, studies (such as the EAT Lancet Commision report (https://eatforum.org/eatlancet-commission/eat-lancet-commission-summary…) conclude that aquatic foods must play a key role in the effort to build resilient, sustainable and healthy foods for all. It can contribute to diet-related health challenges – by reducing micronutrient deficiencies, improving heart, brain and eye health, and replacing consumption of less healthy red and processed meats – and be a part of the climate solution. Blue foods also provide much more than protein. Many blue food species are rich in nutrients such as zinc, iron, vitamin A, vitamin B12 and omega 3s. Eating more blue food can help prevent non-communicable diseases and nutrient deficiencies, especially in regions and populations where there are high burdens of malnutrition. With the right management, blue foods can be caught with reduced impacts on biodiversity or grown more sustainably than various terrestrial animal proteins, thus producing lower greenhouse gas emissions and water pollution and using fewer land and water resources. See the Blue Food Assessment report (https://bluefood.earth) and specifically the Environment Performance Paper on Blue Foods (https://bluefood.earth/science/environmental-performance/).

      - In particular the role of small-scale artisanal fisheries (SSF) must be considered and highlighted in the report. They play crucial roles in employment, food security, nutrition, livelihoods, culture, and coastal communities well-being. There are major inequalities in aquatic food systems as of today. Overall, fishing communities continue facing the competition of industrial fishing fleets and other blue economy sectors, such as coastal tourism, oil and gas exploitation, struggling to access waters safely, seeing climate change impacting their activities, dying at sea in high numbers, facing challenges in financing and in equipment. For FSN, it is absolutely crucial to increase their recognition, and also create action securing their access to marine resources and markets, as promised by States under Sustainable Development Goal 14.b. In the Blue Call to Action (https://www.cffacape.org/ssfcall-to-action) - a milestone of 2022 and the year of Artisanal Fisheries and Aquaculture (IYAFA), a group of SSF organisations from around the world have come together to raises key aspects to support SSF and thereby, their invaluable contribution to FSN.

      It is crucial to reflect on the role of Blue Economy discourses as a solution to food security, but also an 'instrument' that can exacerbate inequalities and directly affect coastal communities. Reference to the FAO Blue Transformation roadmap can support the reflection and recommendations. However, adding small-scale fishers, fisherfolk, and coastal communities' perspectives and reflections on the implications of the Blue Economy to exacerbate inequalities, food insecurity and rights violation is critical. See The People's Tribunal reports http://blueeconomytribunal.org/

      One specific action with high potential is that of implementing Exclusive Small Scale Artisanal Fishing zones. There are studies on how to make such zones work: https://www.icsf.net/wpcontent/uploads/2022/10/930.ICSF223_Andhra_Pradesh_Tenure_Right.pdf

      As States have recently committed to protect 30% of marine areas by 2030 (target 3 of Montreal agreement), we and many SSF organisations along with us insist that it cannot work if it does not have a human-rights based approach. It will be important to monitor, and valuable additions to this report stating that the 30x30 goal also needs to be achieved in a way that is compatible with SDG14B and other commitments such as the Guidelines to secure sustainable small-scale fisheries.

      Connected to the appreciated highlights in the report of Farmers Organisations, we would like the authors not to forget the similarly critical role of Small-Scale Artisanal Fishers Organisations. They are much younger, but are building momentum and capacity. Some studies/articles worth looking into might be: https://doi.org/10.1080/01436597.2017.1416288 “Implicating ‘fisheries justice’ movements in food and climate politics” and “Transnational fishers’ movements: emergence, evolution, and contestation. Maritime Studies 21, 393–410 (2022) https://doi.org/10.1007/s40152-022- 00280-3 by Mills, E.N.

      - In general, reference to and inclusion of other food producer constituencies than farmers such as small-scale fishers and pastoralists, could be strengthened throughout the report.

      - Importance of collective rights: Collective rights are primarily discussed in relation to land rights, and it can be clarified that collective rights also concerns access rights to forests and fisheries. In particular, for small-scale fisheries, it is crucial to highlight collective tenure rights and have a clear understanding that tenure can be understood as how communities secure access to natural resources, which is key to their livelihood and food security. Access to resources is the base for small-scale fishers’ and fisherfolks' social, economic, and cultural well-being (SSF Guidelines, 2014). We recommend The Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication (SSF Guidelines) as an important reference to the report. It is based on HRBA and was developed in an inclusive, participatory and transparent manner where SSF representatives and their support organisations played a critical role.

      - Farmers rights and farmer seed systems: While the V0 draft describes adverse effects of corporate concentration of the global seed system in Chapter 4, it doesn’t recognize the negative impacts of seed policies, plant variety protection and other intellectual property laws, seed marketing laws, variety registration and certification schemes, that are largely designed to meet the needs and interests of the agricultural industry, on the agency of farmers (restricting their right to freely save, use, exchange and sell farm-saved seeds) and its implications for livelihoods and FSN outcomes. See e.g. The Right To Seeds And Intellectual Property Rights.pdf (geneva-academy.ch) For Member States to meet target 2.2 of the SDGs, the Special Rapporteur on the right to food has provided a framework to cohere and advance farmers’, Indigenous peoples’ and workers’ rights and ensure that the world’s seed systems are diverse and safe and fulfil the rights to life and food. This is elaborated in the 2021 thematic report A/HRC/49/43: Seeds, right to life and farmers’ rights - Report of the Special Rapporteur on the right to food, Michael Fakhri: https://www.ohchr.org/en/documents/thematic-reports/ahrc4943-seeds-righ…. These perspectives could be reflected in Chapter 3, e.g. p 50 or p. 51 related to Agency. Supporting Farmers rights and diverse farmer seed systems is important for FSN outcomes (See e.g. Farmer-Led Seed Systems - A Biowatch Briefing Securing food sovereignty in the face of looming ecological and social crises: https://biowatch.org.za/download/farmer-led-seedsystems/?wpdmdl=1958&re…). Also, this case demonstrates how diversification and promotion of local crop varieties has made it possible to shorten the hunger period https://afsafrica.org/wp-content/uploads/2019/11/cereal-banks-guineabis…

      – The role of integrated agroecological approaches such as agroforestry for food security and nutrition: As the V0 report also demonstrates, tackling food insecurity and malnutrition requires an increased focus on food quality, which can be achieved for example by promoting diversified production systems such as agroforestry and other agroecological approaches. Scaling up agroforestry can contribute to food and nutrition security, while contributing to more sustainable and resilient food production systems. For cases and policy and practice recommendations on agroecology and agroforestry, see e.g. Agroforestry Network, 2020. Agroforestry, food security and nutrition (https://agroforestrynetwork.org/database_post/agroforestry-food-securit…) and Alliance for Food Sovereignty in Africa https://afsafrica.org/case-studies-agroecology/

      - We appreciate the important recognition of valuing diverse knowledge systems in the report. In order for Indigenous and local knowledge and perspectives to be adequately included, valued and also supported in the context of this study, we recommend working with existing approaches, tools and methods and consultation with Indigenous and local knowledge holders be prioritised. Some examples of methods and tools for multi stakeholder engagements and knowledge collaborations (referred to in Chapters 5) based on equity and usefulness for all involved include methods for multi-actor dialogues such as the Multiple Evidence Base approach for connecting across knowledge systems, and the Multi-Actor Dialogue methodology (see links below). Such methodologies are also useful for transformative social learning, conflict resolution and managing power relations in global negotiations. IPBES assessments such as the Global Assessment (2019) as well as resources such as the Local Biodiversity Outlooks, provide important insights into food systems and equitable livelihoods.

      ○ Multiple Evidence Base approach (MEB) and Free, Prior and Informed Consent: https://swed.bio/stories/a-multiple-evidence-base-approach-for-equity-a… ; https://swed.bio/about/guiding-principles-for-knowledgecollaboration/

      ○ Multi-actor dialogues: https://swed.bio/focal-areas/approaches/dialogueslearning/multiactor-di… ; https://swed.bio/reports/report/the-biggest-singleopportunity-we-have-is-dialogue/

      ○ Local Biodiversity Outlooks (LBO) 2: website: https://lbo2.localbiodiversityoutlooks.net/ ; report: https://www.cbd.int/gbo5/local-biodiversity-outlooks-2

      Additional comments on specific sections in the report:

      - Given the unprecedented environmental crises we are facing, the section on Sustainability in Chapter 3 could be strengthened by broadening the discussion beyond issues of farm size and agricultural production methods to the overall threats to global food system sustainability posed by climate change and biodiversity loss. Issues such as who owns which land, and how productive is the land, should also be considered.

      - We welcome Chapter 5, which highlights the need for equity-sensitive policy processes and mentions making nutrition-sensitive policies. Awareness of inequities, inequalities, and nutrition in relevant policies across sectors is critical. In addition, sensitive policies seek to do no harm. However, we would like to suggest drawing lessons from gender-responsive and - sensitive approaches. For a truly transformative change and to reduce inequalities for FSN, we see it is essential also to have responsive policies which recognize and react to inequities and inequalities in implementation. In addition, the section would gain in clarity if the discussion distinguished between the content of the formulated policies vs the process for policy formulation.

      - Table 5.1: We lack framing these actions within a HRBA. As an example, instead of ‘Develop farmers’ organisations’ (which has a top-down connotation and raises questions about who develops them) the action should rather be about supporting constituencies’ own social movements and organisations based on their priorities, needs and rights.

      - Chapter 6, p. 125-126 Agroecology and food sovereignty: We welcome the clear reference to agroecology as a structural reformation approach and the emphasis on maintaining the holistic perspective of agroecology as a rights-based, justice-centred approach. However, the section could be developed with regards to how to support a just transition to agroecology within food systems, such as supporting social movements in their struggles to advance agroecology and food sovereignty and maintaining the momentum that currently exists (e.g. through ongoing social movement processes such as the Nyeleni process Nyéléni Process - International Planning Committee for Food Sovereignty (IPC)) and by supporting IPLCs in their efforts to maintain and revitalise indigenous and local food systems in support of local food security, food sovereignty and agroecology. Also, reference could be made e.g. to the FAO Scaling-up agroecology initiative or the application of the CFS Policy Recommendations on Agroecological and Other Innovative Approaches and how these initiatives and instruments effectively can contribute to reducing inequalities for FSN outcomes.

      Other relevant references:

      - Haider, L.J, Boonstra, W.J., Peterson, W.J., Schluter, M., 2018. Traps and sustainable development in rural areas: a review. World Dev., 10, pp. 311-321. Poverty arises from complex interactions between social and environmental factors that are rarely considered in development economics. A more integrated understanding of poverty traps can help to understand the interrelations between persistent poverty and key social and ecological factors, facilitating more effective development interventions.

      - Lade, S, Haider, L.J, Engström, G., and Schlüter, M. 2017. Resilience offers escape from trapped thinking on poverty alleviation. Science Advances 3 (5) DOI: 10.1126/sciadv.1603043 The poverty trap concept strongly influences current research and policy on poverty alleviation. Financial or technological inputs intended to “push” the rural poor out of a poverty trap have had many successes but have also failed unexpectedly with serious ecological and social consequences that can reinforce poverty. Resilience thinking can help to (i) understand how these failures emerge from the complex relationships between humans and the ecosystems on which they depend and (ii) navigate diverse poverty alleviation strategies, such as transformative change, that may instead be required.

      - FAO. 2022. The State of World Fisheries and Aquaculture 2022. Towards Blue Transformation. Rome, FAO. https://doi.org/10.4060/cc0461en

      - https://www.stockholmresilience.org/research/research-news/2021-10-20-w… Main points: 1) Private and public investors must collaborate with coastal communities and support locally led investable products and projects. 2) The ocean economy must be equitable, sustainable and diverse if it is to create true economic potential for Small Island States (SIDS) and those coastal Least Developed Countries (LDCs), which depend on the ocean for their lives and livelihoods, 3) Women hold the key to supporting coastal communities to adapt to the impacts of climate change and other ocean risks

      - A Policy and legal diagnostic tool for sustainable small-scale fisheries: In support of the implementation of the voluntary guidelines for securing sustainable small-scale fisheries in the context of food security and poverty eradication: https://www.fao.org/3/cb8234en/cb8234en.pdf

      - SSF People-centred methodology to assess the voluntary guidelines for securing sustainable small scale fisheries in the context of food security and poverty eradication https://www.foodsovereignty.org/wp-content/uploads/2022/07/EN_People-centredmonitoring-of-the-implementation-of-the-SSF-Guidelines.pdf

      - People-Centred assessment of the Implementation of the Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries: https://www.foodsovereignty.org/wp-content/uploads/2022/10/TNI_report-EN_web.pdf

      - IPBES (2019): Global assessment report on biodiversity and ecosystem services of the Intergovernmental Science-Policy Platform on Biodiversity and Ecosystem Services. E. S. Brondizio, J. Settele, S. Díaz, and H. T. Ngo (editors). IPBES secretariat, Bonn, Germany. 1148 pages. https://doi.org/10.5281/zenodo.3831673

      - Forest Peoples Programme, International Indigenous Forum on Biodiversity, Indigenous Women’s Biodiversity Network, Centres of Distinction on Indigenous and Local Knowledge and Secretariat of the Convention on Biological Diversity (2020) Local Biodiversity Outlooks 2: The contributions of indigenous peoples and local communities to the implementation of the Strategic Plan for Biodiversity 2011–2020 and to renewing nature and cultures. A complement to the fifth edition of Global Biodiversity Outlook. Moreton-in-Marsh, England: Forest Peoples Programme. Available at: www.localbiodiversityoutlooks.net

      This report elaborates on governance transitions towards inclusive decision-making and selfdetermined development, relevant e.g. for the section on addressing agency and power through inclusive governance in Chapter 6, and on revitalization of indigenous and local food systems for local food security, food sovereignty and agroecology as part of a just agricultural transition.

      See the attachments:

    • Comments from SwedBio (at Stockholm Resilience Centre) on the:

      ‘Zero Draft of the CFS Voluntary Guidelines on Gender Equality and Women and Girls’ Empowerment in the context of Food Security and Nutrition’

      General comments

      • We welcome the Zero draft’s holistic approach to gender issues, commitment to Human Rights and to the realisation of the Right to Adequate Food, and gender-transformative approach, which is crucial to address the root causes of gender-based inequalities and focus on gender-equitable control over assets and productive resources.

      There are still topics that don’t find enough focus in the Zero Draft

      • We believe that an overwhelming emphasis is put on the lives of rural women, yet the focus on urban and peri-urban women and their role in food security and nutrition is underplayed. Women in cities, informal settlements, working in territorial markets, etc also play an important role in food systems and face challenges particular to their setting. It can be better reflected that women are not a homogenous category, but characterised by diversity. This diversity comes from their diversity of perspectives, contexts and experiences. Women are also affected by multiple forms of discrimination.
      • The work for gender equality involves engaging with women and girls, men and boys, as well as non-binary people in order to break down destructive gender stereotypes that can be harmful to all genders. We would suggest non-binary people be also included when the text refers to ‘women and men’. Language on sexual orientation and gender identity should be included, particularly in the section on violence against these people, so as to promote broader recognition of the challenges faced by all genders in regard to food security and nutrition.
      • It is broadly recognized that the current food systems are main drivers of land-use change, deforestation and loss of biodiversity, and that transformative change towards more sustainable, equitable and inclusive food systems is needed. The guidelines could more clearly articulate the need for a holistic systems approach that addresses the underlying indirect drivers and supports transformative change (that transforms the structures of power in society) in what is produced, how and by whom it is produced, processed, and consumed with a focus on human rights and well-being and the protection of the environment and natural resources for food security and nutrition. The ‘by whom’ it is produced is important because the right to food is connected to the right to choose how and by whom that food is produced: the food sovereignty concept and framework is an important notion in this regard. The HLPE report on ‘Agroecological and other innovative approaches for sustainable agriculture and food systems that enhance food security and nutrition’ (page 147), highlights the fact that that rights-based approaches to addressing food security and nutrition encompass not only women’s empowerment and the right to food, but also food sovereignty.

      PART 1 - INTRODUCTION

      Guiding question Nr. 1: Does the Zero Draft appropriately capture the main challenges and barriers that hinder progress in achieving gender equality and the full realisation of women’s and girls’ rights in the context of food security and nutrition in the region? If not, what do you think is missing or should be adjusted?

      • The Right to Adequate Food should be unpacked more clearly in the background section, especially to emphasise a Human Rights-Based Approach to food, and how that relates with gender equality. In addition, when referring to rights-based language such as ‘rights-holders’, we would suggest a clear articulation of who the rights-holders are and which groups they belong to. This should also be distinguished from duty-bearers. Referring to women as ‘rights-holders’ is not enough to bring forward the diversity of perspectives, contexts and experiences.
      • Paragraph 4 should in addition to highlighting the impacts of COVID-19 as an important challenge for food security and nutrition also refer to the challenges posed by, and the gendered impacts of, climate change, ecosystem degradation and biodiversity loss. This is underlined by the inextricable linkages between human health, animals, and the environment as emphasized by a One Health approach in relation to sustainable food production, 
      • It is not widely understood that agriculture includes fisheries (page 5 footnote). We support the comment submitted by ICSF, stating that “It should be clearly stated that rural women include not only farmers, but also fishers and fishworkers, pastoralists (and it is insufficient to mention this only in a footnote).’ We suggest that when agricultural systems are mentioned, they are complemented as such: Agricultural systems - including farming, fishing and pastoralism”.
      • Agency of women and girls should be more strongly articulated. In line with the HLPE report 15 Building a Global Narrative towards 2030, it should be acknowledged that the concept of food security has evolved to recognize the centrality of agency, as well as sustainability, along with the four other dimensions of availability, access, utilization and stability and as also reinforced in the right to food concept.
      • As a principle of a Human Rights-Based Approach, everyone has the right to active and meaningful participation in decisions which affect their lives. We feel that full and effective participation is lacking in the background.
      • Intersecting forms of participation are mentioned only once. We believe intersectionality would be important to have in the introduction. Women do not represent one experience but are diverse in their background, knowledge and access to power. Women’s opportunities in life are shaped by intersecting identities such as cultural background, ethnicity, age, religious beliefs, sexual orientation, class or income and other circumstances. These multiple factors shape women’s identity, access to resources, life opportunities, power and influence. Highlighting Human Rights principles explicitly could cover the need of embracing intersectionality.
      • We feel the categories of stakeholders mentioned as involved in addressing food security and nutrition, gender equality and women’s empowerment (page 5-6) should be unpacked, particularly ‘c) Civil society, including women’s, farmers’ and small-scale food producers’ organizations, trade unions of domestic, rural and agricultural workers, and indigenous peoples’. Civil society does not differentiate between environmental NGOs vs. social movements, grassroots organisations, etc. But these organisations hold different priorities, mandates, and power relations, and are not fit to merge into one category. To remain committed to rights-based language, the categorisation of stakeholders could mention which are rights-holders and which are duty bearers.
      • We welcome the focus on gender transformative approaches, as gender equality involves transformation of gender norms beyond ensuring the rights of women and girls, and since such approaches have proven important not only for gender equality and women’s empowerment, but also in relation to poverty and food security[1]. Definitions and a discussion of how the concepts of gender transformative and gender responsive approaches are used and promoted by the Voluntary Guidelines could be included.
      • Also, similarly to the comments submitteed by ICSF, we believe that “Point 1.1.7: Needs to include women’s contributions to fisheries - especially small-scale fisheries - including fishing, processing and marketing. Their role extends beyond production, and includes crucial reproduction tasks, such as sustenance of families and communities, and the protection of natural resources and local ecosystems”.

       

      PART 2 – CORE PRINCIPLES THAT UNDERPIN THE GUIDELINES

      Guiding question Nr. 2: Does Part 2 of the Zero Draft satisfactorily reflect the core principles which should underpin the Guidelines? If not, how do you propose to improve these principles?

      • Paragraph 17: We believe reference to some crucial resolutions, declarations or policy products are missing in the list in part 2, particularly:

      - For a document which has a great focus on rural women, we feel that the ‘United Nations Declaration on the Rights of Peasants and Other People Working in Rural Areas’ (UNDROP) as a guiding framework is lacking.

      - To fully engage with Indigenous peoples’ food systems and Indigenous women, reference to the United Nations Declaration on the Rights of Indigenous Peoples (UNDRIP) is crucial.

      - The ‘CFS Voluntary Guidelines on the Responsible Governance of Tenure of Land, Fisheries and Forests in the Context of National Food Security’ which are only referred to as a footnote.

      - The ‘Voluntary Guidelines for Securing Sustainable Small-Scale Fisheries in the Context of Food Security and Poverty Eradication’ (SSF Guidelines).

      - The Human Right to a Clean, Healthy and Sustainable Environment (HRC/RES/48/13)

       

      • Paragraph 19: We appreciate that Human Rights and the Right to Adequate Food are listed as core principles of the Voluntary Guidelines.
      • Paragraph 28: Could stress the importance of multi-stakeholder collaborations and partnerships being under-pinned by a Human Rights-Based Approach which recognizes the different roles, rights and responsibilities of rights-holders and duty bearers. It should similarly make a clear distinction between stakeholders and right holders.

       

      PART 3 – THE VOLUNTARY GUIDELINES ON GENDER EQUALITY AND WOMEN’S AND GIRLS’ EMPOWERMENT IN THE CONTEXT OF FOOD SECURITY AND NUTRITION

      Guiding question Nr. 3: Do the nine sections of Part 3 of the Zero Draft comprehensively cover the policy areas to be addressed to achieve gender equality and the full realization of women’s and girls’ rights in the context of food security and nutrition? If not, what do you think is missing?

      3.2 Elimination of violence and discrimination against women for improved food security and nutrition

      • Language on sexual orientation and gender identity should be included, particularly in the section on violence against these people, so as to promote broader recognition of the challenges faced by all genders in regard to food security and nutrition.

      3.3 Access to education, capacity building, training, knowledge and information services

      • Formal knowledge is referred to, but not non-formal forms of knowledge: traditional knowledge, cultural knowledge; and knowledge transmission: intergenerational, horizontal peer-to-peer learning etc, should be included. Education is not just about seeing women and girls as receivers of knowledge, but as important knowledge holders when it comes to agriculture, nature and wellbeing. The knowledge that women have produced and passed down for generations, from the identification of wild plants, food production, seed production and conservation, is crucial when it comes to diversity in farming methods and healthy ecosystems and biodiversity.

      3.5 Access to and control over natural and productive resources

      • Linkages to climate change are clear, but the section could more clearly articulate the challenges posed by ecosystem degradation and biodiversity loss (e.g. in paragraph 89) as well as refer to the importance of full and effective participation of women in the work of the Convention on Biological Diversity (paragraph 91). Drawing parallels with the CBD Gender Plan of Action could provide interesting entry points and synergies. Right to a Clean, Healthy and Sustainable Environment as a new framework could be integrated into the Guidelines.
      • Paragraph 84: The problem statement should be broadened to reflect the diverse productive sectors referred to in 3.5.1. In addition to land rights it should also encompass customary rights, water rights, etc.
      • Paragraph 95: Referring to agricultural inputs excludes small-scale fishers (SSF) and pastoralists. SSF women face challenges in accessing technologies as well, and there is a need for them to mobilise and cooperate, especially facing changes in regulations. Ex. changes in net sizes or changing materials.
      • Right to seed should be mentioned here.
      • Agroecology as a viable alternative to address unsustainable and unjust food systems is not sufficiently emphasised in the text. Reference to the Policy recommendations on Agroecological and other innovative approaches for sustainable agriculture and food systems that enhance food security and nutrition is lacking. Here we support the comment sent by the EU: “We believe that the agroecological transformation of agrifood systems is not limited to food production practices, but entails more balanced access to resources, more balanced relations and distribution of power. Agroecology could be a key opportunity for women to gain influence and recognition and to contribute to better nutrition/food security. We therefore believe that there is considerable scope for the guidelines to address the significance of agroecology and the promotion of territorial markets (as opposed to increased reliance on retail food outlets) for food systems transformation and the implications for integrating gender equality and women’s and girls’ empowerment into such a transformative process.”

      3.6 Access to labour markets and decent work

      • Paragraph 105: The situation for migrant women and refugees are highlighted. However, it can be clarified that, in general, women are subject to all sorts of abuse in the labour market due to social and cultural norms, power relations and intersecting forms of vulnerability—for example, sex for fish.

      3.8 Women and men’s ability to make strategic choices for healthy diets and good nutrition

      • We feel the scope of this section could preferably be broadened as it lacks the important connections between integrated, diversified production systems and more diverse and nutritious diets as well as the interconnected challenges posed by climate change, ecosystem degradation and biodiversity loss for the realisation of healthy and nutritious diets that impacts women, girls, men and boys differently.

       

      PART 4 - IMPLEMENTATION AND MONITORING OF THE USE AND APPLICATION OF THE VOLUNTARY GUIDELINES

      Guiding question Nr. 4: Does Part 4 of the Zero Draft provide all the elements necessary for effective implementation and monitoring of the use and application of the Guidelines? If not, what do you propose to add or change?

      • Paragraph 131: Implementation of the Voluntary Guidelines (on Gender) could be supported by stating the international declarations and legally binding instruments that have been endorsed, such as CEDAW and the Universal Declaration of Human Rights, in this section which pertains to implementation. This could ensure greater guidance but also greater commitment to the Voluntary Guidelines (on Gender). Reminding that the principles stated at the start of the document also apply to sound implementation of the guidelines, especially those relating to non-discrimination, inclusiveness and participation in policy-making, could also provide further guidance on implementation.
      • Building and strengthening capacity for implementation, paragraph 134: we lack mention of support to women-led networks and civil society organisations, or collective action done by women.
      • Paragraph 135: Government ‘in consultation with other stakeholders’ – full and effective, and meaningful participation, is lacking. Referring to governments as duty bearers and distinguishing them from rights holders would be a proper commitment to a Human Rights-Based Approach.

      [1] E.g. Lawless et al., 2017. Considering gender: Practical guidance for rural development initiatives in Solomon Islands. Penang, Malaysia: WorldFish. Program Brief: 2017-22. (https://digitalarchive.worldfishcenter.org/bitstream/handle/20.500.12348/268/4134_2017-22.pdf?sequence1=)