المنتدى العالمي المعني بالأمن الغذائي والتغذية

De nuestra mayor consideración:

Se remiten adjunto al presente correo los comentarios del Ministerio de Agricultura, Ganadería y Pesca, de la República Argentina, relativos al Borrador Cero del Informe de referencia.

Asimismo, encontrarán, a continuación, las respuestas a las preguntas propuestas por los autores del citado Informe:

I) Respuestas a las preguntas propuestas por los autores del proyecto de informe

Question: 5. The report has identified a wide range of challenges likely to be faced in the coming period to which policy makers and other stakeholders will need to take into account so that SADL can contribute to FSN. Do you think that there are other key challenges/opportunities that need to be covered in the report, including those related to emerging technologies, the concentration and intensification of production in livestock, and the implications for feedstuffs (crops and oilseeds), and international trade?

Answer: One of the challenges that the report could further elaborate on is the danger that restrictive and scientifically unjustified private standards pose on the regulatory authority if States. It is important not to undermine state capacity to regulate in a transparent, science-based and undiscriminatory manner. Concerning health and animal care the conclusions could be rewritten as follows.

"18. Extend and prioritize actions aimed at tackling the world's most serious nutritional challenges through action to:

c) review the scope for a range of interventions, preserving the State s role in regulatory matters, including labeling (covering nutrition as well as sustainability indicators), advertising restrictions, taxes and public procurement for targeted feeding programs

20. Increase efforts in animal disease surveillance and treatment, both to improve livestock sector productivity and to reduce dangers associated with the spread of pests and outbreaks of animal diseases and zoonoses.

21. Revisit policies, including the use of antibiotics in the livestock sector, to reduce the growing health risks associated with anti-microbial resistance, directing energies to strengthen the tripartite collaboration between FAO, OIE and WHO for combating antimicrobial resistance by providing recommendations and taking actions based on sound scientific evidence following the applicable multilateral rules and recomendations for the development of sustainable food production systems that prevent diseases, promote good animal husbandry and management, biosecurity, hygiene practices and health."

In the same vein, it is of the outmost importance not to create arbitrary standards - not compatible with the scientific principle - which could hinder the ability of countries to harness the oportunities that the multilateral trade system has to offer. Therefore, the conclusions could be further extended as follows:

"22. Give higher priority to establishing and enforcing agreed standards of animal care developed for different livestock production systems and species, especially in intensive systems, without creating a disguised restriction on international trade or unjustifiable discrimination between countries where the same conditions prevail: include financial and technical support for improved animal care in agricultural development funding initiatives."

Concerning Market Performance (point 3.2.2), the reasoning of the argumentation is somehow misled. Though higher prices might have a marginal effect on the demand of food and feed (inelasticity of the demand), they do encourage investment. Given that agriculture is crucial for developing countries, such dynamic should be positive for food security. Moreover, low food and feed prices discourage food and feed investment therefore causing further drop in the future price.

The report does a good job at acknowledging the importance of the multilateral trade system. Still, it fails to address the negative effects that the agricultural protectionism has inflicted on developing countries. Namely market access restrictions, domestic support measures (included the unlimited amounts of green box), export subsidies and arbitrary non-tariff trade barriers. In this respect, the report should make a call for the swift conclusion of the Doha Developing Round in accordance to its mandate. The disclaimer used for signaling that the conclusions of the paper are subject to the result fo the 10th Ministerial Conference is appropiate. Still, a stronger statement against said protectionism is in order.

Question 12. Are there any major omissions or gaps in the report? Are topics under-or over-represented in relation to their importance? Are any facts or conclusions refuted or questionable? If any of these are an issue, please send supporting evidence.

Answer: With regard to the environmental aspect of the text, we would like to reaffirm that the primary forum for discussions related to climate change is the United Nations Framework Convention on Climate Change (UNFCCC), and that no part of this text should prejudge or duplicate neither possible results of the UNFCCC work or its principles and provisions.

In addition, we suggest the following changes with regard to specific provisions in the text (crossed out text are suggestions for removal, and underlined text are suggestions for insertion):

1. Page 7, line12: much still needs to be done, including in the way our food and agriculture systems perform economically, socially and environmentally, how they can restore and maintain the already stressed natural systems that underpin food production now and into the future

- Rationale: There is no international consensus currently with regard to the restorative capabilities of food and agriculture systems.

2. Page 8, line 51: Climate change is already impacting on the agriculture sector, which will have to continue to adapt as well as to reduce its contribution to greenhouse gas emissions , always taking into consideration the principle of common but differentiated responsibilities, respective capabilities and social and economic conditions of countries, as expressed in the United Nations Framework Convention on Climate Change.

- Rationale: With regard to climate change, there should be an inclusion of the principle of common but differentiated responsibilities, as agreed in the UNFCCC, which is the primary international forum on this issue.

3. Page 15, line 29: Reflecting the evolution of thinking about environmental sustainability, the WDR notes that with rising resource scarcity and mounting negative externalities, agricultural development and environmental protection have become closely intertwined.

Agriculture s large environmental footprint can be reduced, farming systems made less vulnerable to climate change, and agriculture harnessed to deliver more environmental services. The solution is not to slow agricultural development it is to seek more sustainable production systems but realizing on this promise also requires the visible hand of the state providing core public goods, improving the investment climate, regulating natural resource management, and securing desirable social outcomes . There are important implications here, in maintaining equilibrium between different farming systems and between local production and international trade.

- Rationale: This paragraph makes a reference to the environmental footprint , a concept which does not have multilateral consensus, and should therefore not be included. We would suggest that the whole paragraph be removed, or at least the reference to environmental footprint .

4. Page 21, line 17: biodiversity in agro-ecosystems, including the animal component, performs important ecological services beyond food production, and conditioning such as recycling of nutrients, pollination, pest control, regulation of microclimate and local hydrological processes, detoxification of noxious chemicals, control of greenhouse gas emissions, risk reduction under unpredictable environmental conditions and the conservation of surrounding natural ecosystems.

Rationale: We believe that the CFS is not the appropriate forum to address issues related to general ecological services. Thus, we believe this paragraph should be removed.

5. Page 45, line 29: The priority environmental challenges are: reducing the intensity of greenhouse gas emissions production ; reversing land degradation and biodiversity loss; reducing water pollution; and adapting to climate change

- Rationale: We believe that with regard to food production and distribution, the focus should be on the reduction of emissions intensity and on increased efficiency, as opposed to total emissions reductions, as this would negatively affect food security.

6. Page 52, line 11: GHGs from enteric fermentation (the main source of livestock emissions) are trending upwards in developing countries while in developed countries they have decreased (Tubiello, 2013). (This is the result of increase in livestock numbers in developing countries and increase in efficiency of production in developed countries).

- Rationale: We believe this text does not accurately reflect what is expressed in the referenced document (Tubiello, 2013), which states that Averaged over the period 2000 2010, Asia and the Americas were the largest contributors, followed by Africa and Europe. Emissions growth rates were largest in Africa, on average 2:4% yr1. In both Asia and the Americas emissions grew at a slower pace (1 1:2% yr1), while they decreased in Europe (1:7% yr1). Indeed, in the previous decade 1990 2000, Europe s contribution had been larger than Africa s. In other words, the reference to the Americas includes both Latin American countries and the United States, and does not distinguish between emissions by each. In addition, the figures in the referenced document which do distinguish between developed and developing countries refer only to emissions in 2010, and not a particular upward or downward trend. Given this, we believe this text should be removed from the document, as it depicts a situation in which developing countries have a greater responsibility to act to reduce emissions, when this could adversely affect food security, in a context in which the overarching priority of developing countries is to eradicate poverty and hunger.

7. Page 54, line 12: The water footprint of livestock products is much higher than for crop products in terms of calories produced (although when biological value of protein is compared, no plant protein is significantly more efficient at using water than protein produced from eggs, and only soybean is more water-efficient than milk and goat and chicken meat (Mekonnen and Hoekstra, 2012; Shlink et al., 2010). Animal products from industrial, feed-based systems are generally more water intensive and generally consume and pollute more ground- and surface-water resources than animal products from grazing or mixed systems. - Rationale: This paragraph makes a reference to the water footprint , a concept which, like the environmental footprint , does not have multilateral consensus, and should therefore not be included. We would suggest that the whole paragraph be removed.

8. Page 62, line 20: The livestock sector has a large potential to reduce the intensity (ghg/kg of product) of greenhouse gas emissions, although it is much less likely for total emissions given the projected increase in livestock production in the context of population growth and the need to safeguard food security . Mitigation (reduction or

prevention) of the sector s emissions could be achieved by a reduction in production and/or consumption, by an increase in production efficiency, or by shifting the structure of production towards less emission-intensive animal food types. Many technical options to reduce emissions exist, including feed supplements and feed management, grazing land and manure management, health management, improvements in genetics and animal husbandry practices. In more intensive systems, progress could be made by introducing technological innovations to increase efficiencies in production and shift towards monogastric species Promoting production and consumption of less resource- and GHG-intensive livestock types can change the emissions trajectory of the livestock sector. Soil carbon sequestration is also an important option that shows potential for mitigating net emissions from grazing livestock. For instance, restoring degraded soils, better adjusting stocking density and using legumes has a significant potential worldwide for mitigation in the livestock sector

- Rationale: We believe that there are no one-size fits-all solutions which can be applied globally, and that the mention of specific measures necessarily leaves out others which could be more appropriate and effective given specific national circumstances and capabilities, as well as economic, social and environmental priorities. As is pointed out in the same page: in each country there are priorities that reflect the particular farm systems, socio-economic and agri-ecological conditions, history and culture, and public preferences . Given this, we believe that there should be no mention in the text of specific options for measures that might be implemented.

9. Page 63, line 51: The priority environmental challenges are to meet FSN objectives while reducing the intensity of greenhouse gas emissions production , reduce pollution, reverse land and soil degradation and biodiversity loss, and conserve water resources , and enhance the provision of ecosystem services and aesthetic landscapes .

- Rationale: The question of ecosystem services is not multilaterally recognized in the UNFCCC, which is the primary forum on climate change.

In addition, we believe the CFS is not the appropriate forum to address issues such as the preservation of aesthetic landscapes. Furthermore, we believe that with regard to food production and distribution, the focus should be on the reduction of emissions intensity and on increased efficiency, as opposed to total emissions reductions, as this would negatively affect food security.

10. Page 64, line 50: However, when the impacts of farm practices are not taken into account by farmers and livestock keepers, because there is no financial remuneration for the provision of public goods (such as carbon sequestration in soils or habitats for wildlife), or penalties for polluting water courses or harming biodiversity for example, or the social consequences are not factored in to producer decisions, then sustainability is compromised

- Rationale: We believe that this sort of text can be used to justify the implementation of agricultural subsidies, which are contrary to WTO rules. We therefore believe this sentence should be removed.

11. Page 66, line 5: Use best farmer practices for reduced GHG emission intensity, including through reduced

- Comment: The sentence seems to be incomplete

12. Page 66, line 13: Set payments for using and for providing environmental services that are not remunerated through the market

- Rationale: This sort of measure may be used to justify the implementation of agricultural subsidies, which are contrary to WTO Doha Round mandate. We therefore believe this sentence should be removed.

13. Page 84, line 18: devise policies aimed at adaptation to climate change and at mitigation by reduction in emission intensity and promotion of carbon sequestration , subject to the objectives, provisions and principles of the United Nations Framework Convention on Climate Change, including that of common but differentiated responsibilities and respective capabilities.

- Rationale: The question of carbon sequestration does not have multilateral consensus and should, therefore, not be included in the text. In addition, with regard to climate change, and especially concerning mitigation, there should be an inclusion of the principle of common but differentiated responsibilities, as agreed in the UNFCCC, which is the primary international forum on this issue, and given that the obligations in this regard are different for developed and developing countries.

14. Page 84, line 35: Incorporate wherever possible incentives (to reward public goods provision)

- Rationale: This sort of measure may be used to justify the implementation of agricultural subsidies, which are contrary to WTO rules. We therefore believe this sentence should be removed.

Cordiales saludos

Representación Permanente de la

República Argentina ante la FAO, FIDA y PMA Piazza dell'Esquilino, 2 - 00185 Roma Tel. 06 4807 3300 - Fax. 06 48906984 [email protected]