Forum global sur la sécurité alimentaire et la nutrition (Forum FSN)

Dear colleagues,

Thanks for inviting us to participate in the public consultation on the voluntary guidelines sustainable soil management. This topic is particular relevance in the current context and we are welcoming any initiative targeting solutions for more efficient soil management approaches.

The Common Forum on Contaminated Land (www.commonforum.eu) is a network organisation of policy-makers and regulators, created in 1993, from National government and agencies from 18 European Member States who are dealing with contaminated land and groundwater Issues, and for some of them with land management as a whole. The Common Forum has the following missions:

• being a platform for exchange of knowledge and experiences, for initiating and following-up of international projects among members,
• establishing a discussion platform on policy, research, technical and managerial concepts of contaminated land.

Since its creation in 1993, Common Forum gained a formal status as initiators of new concepts for redevelopment contaminated sites and brownfields such as the Risk Based Land Management concept (2000). Common Forum members are also partners of the International Committee on Contaminated Land (www.iccl.ch).

The proposed draft guidelines seem to address several stakeholder communities (“p.3 - policy developers, government officials, extension officers, farmer associations, private investors and others”).

• They have been developed in the context of the UN SDGs which have been adopted in September 2015 and will have to be implemented by all signing country partners.
• The different levels of actions are not clearly identified and therefore it could be challenging for a successful implementation even on a voluntary basis. The connection to existing policies should be at least mentioned when existing.
• The different targeted stakeholder communities are acting at different decision-making level (from governmental to local – parcel levels). Clear responsibility / roles are key for a successful implementation.

The draft references the definition of the revised World Soil Charter (see chapter 2.1, p.4). This definition explicitly provides a focus on ecosystem services. This might be understood as limiting the term “sustainable” to ecological considerations. Therefore it could be helpful to provide some lines (or a note) for explaining the connection to a generally accepted definition of “sustainable development” (e.g. Brundtland report) aiming on the integration of the ecological, economic and social dimension (see also three P’s: people, planet and profit).

To underpin the importance of appropriate soil and land management as addressed by chapter 2.2, it could be worth to consider a report published by the ELD initiative (www.eld-initiative.org) on the economics of land degradation, its Summary of Findings and the estimate that “Globally, annual ecosystem service value losses of USD 6.3 to 10.5 trillion occur, representing 10-17 per cent of the world’s GDP and highlighting the importance of combating land degradation”

As mentioned by our Dutch colleagues, the soil-sediment-water system (vs. the application to sustainable soil management in agricultural areas) needs an integrated approach:

• This system is more complex and need more than a soil sectoral approach. Agricultural production and food & feed security are also depending on the water resources availability. Groundwater use in urban areas might have an influence in agricultural areas and vice-versa.
• Managing the “transition areas” with the agricultural areas (peri-urban areas) is also a key challenge. Our experiences at national and regional levels have shown the limits of acting with a sectoral approach.
• So that’s why we consider that the document should not be limited to rural areas and should also address the different geographical dimensions to consider in soil & land management. There are needs and key actors at local, catchment / river basin, regional, national, Europe / large world regions scales. Not considering the broader perspective could generate more challenges in the implementation of the guidelines.[1]

Considering the time dimension in sustainable use of land also with regard to global and perspective changes in societal expectations, not really developed in the proposed guidelines, is also fundamental in terms of efficient management of this system.

The draft guidelines describe processes in a qualified matter for (national / regional) policy-makers. But we are missing the connections to the existing policy instruments which are used by the stakeholders.

• The link between agriculture and the reduction of the effects of climate change is important and could be more emphasized.  Farmers play a role in climate change Policy (reduction of GHG emissions and carbon storage in soils). The current draft guidelines are not designed for being operational for farmers.
• For policy-makers, how to combine “mandatory policy instruments” with this “voluntary guidelines” will also be critical.

In most countries having a soil / land protection or soil / land pollution policy, there is a distinction between: i) prevention of new threats (protection issues), ii) new threat situations and iii) legacy threat situations.

• This is why the first policy principle is prevention (avoidance, mitigation or at least limitation to minimum impact).
• For new threat, in particular pollution, the principle is zero tolerance. If any damage, it should be recovered immediately.
• For legacy contamination the approach is risk based and not a multifunctional remediation. The starting point is that the quality of the land should be suitable for the function and use(s) of the land.
• This can only be achieved by integrated approaches, which link the statutory regulations for industries and agriculture, with environmental media protection (e. g. water soil air) and the environmental damage regulations in a more consistent way.

Accordingly we suggest the following amendments (set italic) with regard to chapter 3.8 (Guidelines for neutralization of soil contamination):

• Local soil contamination caused by nowadays economic activities and production processes asks for a complementary approach on prevention and contingency plans for immediate clean-up.
• Management of local soil contamination as a legacy of abandoned activities and production processes requires surveys to seek out sites that are likely to be significantly contaminated, site investigations where the actual extent of contamination and its human and environmental impacts are defined, and identification of a suitable management approach, in particular remedial and after-care measures rehabilitating sites for beneficial use. Soils that are susceptible to the harmful effects of diffuse pollutants (e.g. acidification due to atmospheric deposition on highly weathered ancient soils) should be identified and special measures on a local scale undertaken to reduce atmospheric deposition of pollutants onto these soils.

Finally, an important dimension is missing: the costs for implementing such guidelines are not mentioned. This is a critical question in particular if the sustainability principle should apply: a balance between the three P’s of people, planet and profit. The starting point is to use land in a sustainable way and not only the focus on soil preservation and prevention.

If any question or need for clarification, please do not hesitate to contact us.

Dominique DARMENDRAIL Common Forum General Secretary