المنتدى العالمي المعني بالأمن الغذائي والتغذية

1. The scope of the topic of water and food security is very broad. Do you think that the V0 draft has adequately charted the diversity of the linkages between water and food security and nutrition? Is there important evidence or aspects that the present draft has failed to cover?

·         The Zero Draft captures the relevant issues around the linkage between water and food and nutrition security. Highly appreciated is the consideration of the rights-based approach.

To be consistent with the text, we recommend to include “nutrition” as essential part of food security in the title.

·         We take note that the draft focuses on water as a natural resource for agriculture and food security. We are much aware that this is only a partial analysis since water serves for many other means and sectors as well. We would like to point out that cross-sectoral linkages could be better balanced, in particular with regard to safe drinking water and sanitation.

·         The recommendations (p. 75-82) do not consider strong regional differences in the availability of water. For many regions in the world the statement “water is a resource under stress” (see p.75) does not apply (see figure 8, figure 2). The conclusion “growing demand […] will increase tension over water accessibility” does not apply in general but depends on the region in which the growing demand for water exists. Although in recommendation 7 this subject is covered other sections do not distinguish sufficiently between regions with different water availability. If regional differences are not prioritized in global water governance policy recommendations may not be efficient. I.e. in regions without water shortages policies to reduce water consumption can be ineffective or even counterproductive due to higher health risks and higher energy consumption for water treatment.

·         A close relationship between nutritional problems and access to water in general needs to be questioned (see recommendation 1, p.76). Many regions of Africa have high precipitation - even if considering the high evapotranspiration because of high temperatures.

And still in countries like Tanzania and Kenia crop yields are low. This is mainly caused by inappropriate crop cultivation, the use of old varieties and insufficient fertilization. An increase in irrigation would not improve the situation.

·         The draft does not mention the consequences of firewood use to boil water. Especially in developing countries firewood is used to boil and sterilize water. According to the FAO World Food Report 2014 this is common practice for about 764 million people or 11% of the population. Hence water quality and removal of woods from forests are directly connected. Especially because “sustainable forestry for food security and nutrition” is planned as topic for CFS 2017 possible conflicts between quality of drinking water for poor households and sustainable forest use could also be discussed in this report.

·         We kindly ask to check if the statement that “water is increasingly transferred from agriculture (see p.75, line 10) to other sectors” is valid on a global basis or more on a local or national basis. Accounting for 70-90% of water resources, the agricultural sector still has high efficiency potentials. The household use of 10% and industry use of 20% of water resources reflects competing user interests. This calls for fair solutions.

·         The report should also focus on the potential of agriculture to preserve water resources by enhancing efficiency of water usage or by reusing treated waste water (p. 78).

·         With regard to recommendation 4 (p.77, line 33) we would welcome a statement to be included that groundwater usage should not exceed its recovery rate.

·         With regard to recommendation 5 concerning “Changing diets” (p.77) the potential of reducing food waste should be included.

·         We believe that improved agricultural water management productivity (recommendation 6, p.78) should lead to increased water efficiency in agriculture. We noted that the reuse of untreated wastewater is not mentioned although nutrients could be saved/restored/recovered.

·         Regarding water governance the advantage of cross-sectoral coordination could be illuminated.

·         When dealing with collective rights such as the right to food (or water) of the community it could be examined if it was more appropriate to speak of collectively practiced rights of individuals.

·         After having read the study it is not clear where the problem is: Is it a not completely implemented right to water or is it the lack of precision of the current wording of the right to water?

·         The difference between the “capabilities”-approach of Amartya Sen and the human rights approach sometime does not become clear. It could be a possibility to leave out Sen´s “capabilities”-approach and instead emphasize the possibilities and limits of the human rights approach.

·         p. 69, line 16: “Amartya Sen...” –the capabilities approach might not be adequately summarized here: capabilities are freedoms. These freedoms serve to achieve something that the individual values, i.e. “functionings” that he or she values (“functionings” being the states and activities that make up ones existence, such as having a job, but also being healthy and safe, etc).

In essence, it conceptualizes a new multi-dimensional approach to poverty: not just in terms of economic poverty (i.e. resource-based approach), but in terms of what the individual can achieve within his or her outside parameters (as in: what choices does he or she have, based on their personal abilities and outside parameters, and up to which point can he / she exercise them).

Summary by Sen: “For this reason, while the combination of a person's functionings represents their actual achievements, their capability set represents their opportunity freedom — their freedom to choose between alternative functioning combinations” (Amartya Sen, Development as Freedom, 2001)

In this context we would like to remark that the human rights approach and the capabilities approach are not synonymous. Rights may be seen as entitlements to certain capabilities (not to all – there's no “right to the dream job” or “right to travel the world”, even though these would be functionings).

·         p. 69, line 31: the “respect, protect and fulfill” approach is common to all human rights.

·         p. 69, line 43: We suggest to replace “collective rights” with “collective exercise of these rights”.

·         p. 69, line 52: We suggest to replace “them” with “persons belonging to them”.

·         p. 70, line 28: Please add “2010” after September and “in resolution 15/9” after “the UN Human Rights Council”.

·         p. 70, line 34: We suggest to replace “as elaborated...” with “Based on General Comment 15 and the work of the Special Rapporteur, the Human Rights Council has recognized in Resolution 24/18 of 27 September 2013 that the human right to safe drinking water and sanitation ”entitles everyone to without discrimination, to have access to sufficient, safe, acceptable, physically accessible and affordable water for personal and domestic use and to have physical and affordable access to sanitation, in all spheres of life, that is safe, hygienic, secure, socially and culturally acceptable and that provides privacy and ensures dignity,”

·         p. 71, line 25: Capabilities and human rights are not synonymous; however, human rights definitely accounts for “livelihoods and subsistence needs”.

·         Chapter 1.1.1:

P. 12, line 34 and P. 13 Box 1: Besides diarrhea the text should mention intestinal worm infections (being highly prevalent in developing countries and relevant to nutrition, incl. link to anaemia)

P. 12, line 51: lack of latrines and open defecation also pose a risk for sexual harassment and violence towards young girls and women (also mentioned on page 20, line 12).

·         Chapter 1.1.3:

P. 21, line 8: hygiene practices, especially hand washing

·         Chapter 1.1.4:

P. 24, line 32/33: Water scarcity also implies limited quantities for consumption and good hygiene practices (potentially leading to negative health outcomes and malnutrition)

2. Has the report adequately covered the diversity of approaches and methodological issues, in particular concerning metrics and data for water and food security? Which metrics do you find particularly useful and which not?

·         We would appreciate if in recommendation 8 about research and development (p. 79) research for better storage of irrigation water surplus was mentioned.

·         Given the regional differences in water scarcity the concept of the water footprint does not offer any advantages without taking into account climate and market conditions of production (food consumption requirements in relation to availability of land and water). Since for example Brazil is not affected by water scarcity and irrigation is not needed it does not seem reasonable to indicate the exact amount of water used to produce one kilogram of Brazilian sugar cane. Water availability in Brazil or global water scarcity would not be influenced if sugar cane was not grown in Brazil anymore.

·         The draft does not mention that there is a lack of data about water pollution (“grey water”). “Grey water” is defined as the (hypothetical) amount of fresh water needed to dilute water pollutants from fertilization or production processes to a concentration which is environmentally compatible. Data about grey water in agriculture only incorporates nitrate from nitrogen fertilization. Recent studies also include phosphate in their data but these are not applicable yet.

·         In many regions households are supplied with drinking water by their water suppliers. Therefore internationally coordinated guidelines for the use of installation products should be developed. In the same way as there are guidelines for packaging of drinking water the contamination of water by installation products should be considered. For food packaging positive lists have proofed to be most effective in giving advice about the use of different materials.

·         We would recommend to check if the unit in table 2 (p. 34) is correct. Possibly it rather is “liters per kilogram of product” instead of “liters per ton of product”.

3. Food security involves trade of agricultural produce, and a virtual trade of water. Agricultural trade interacts with water and food security in various ways, and differently for food importing countries, food exporting countries, water scarce versus water rich countries. Do you think the V0 draft has appropriately covered the matter?

·         Recommendation 6 (p. 78) implies the import of food in countries facing chronic water scarcity. We would like to point out that this would rather refer to staple foods than to food in general such as wheat in northern Africa. In countries with water scarcity the scarce resources could be used for products of high value such as fruits and vegetables, if appropriate for the given agriculture. We recommend to also include that in such regions an adaptation of farming systems is needed. As an example we refer to the widespread practice to plow fields. This is a technique which maximizes water losses in those regions. Aimed target should rather be to practice water-saving and water-efficient soil cultivation methods such as preserving methods or no-till.

4. In this report, we considered the potential for an expansion of the right to water to also encompass productive uses. What kind of practical and policy challenges would this bring?

5. Which systemic actions/solutions/approaches would be the most effective to enhance water governance, management and use for food security?

·         Recommendation 2 (p.76) gives the advice to revisit subsidy and policy regimes with regard to rich producers and farmers wasting or degrading water resources. In our opinion the waste or degradation of water resources is not only caused by rich producers or farmers but can be also caused by smallholders if they have access to water for a comparable small price.

·         Ensuring responsible food consumption by using regulation and incentives (see recommendation 5, p. 77) seems plausible but we have sincere doubts that this approach can be successful. The problem is with which measures shall governments initiate and implement a modification of consumption patterns of its population. Effectiveness and efficiency of such measures are highly questioned.

Comments on Recommendations:

·         P. 75, line 5: Please add: water for consumption, preparation and processing of food

·         P. 75, suggestion for title of recommendation 1: More Joined up thinking and action around WASH and food and nutrition security

·         P. 75, line 47: Please add: locally adapted, affordable and accepted solutions

·         P. 65, line 38: Please add: the role of water, sanitation and hygiene in reducing malnutrition

·         P. 78, line 29: recommendation of importing food implies risks linked to price volatility and dependency on markets potentially the situation for poor, food insecure households – import is depending on the context an option, but not a key FNS strategy. Focus should rather be on restriction of water-intense exports.

·         P. 80, line 21: Please add: time for child care

·         P. 80: Please add: promote gender equality through the reduction of work load for women, e.g. through time-saving technologies around food production and WASH 

The UN System Standing Committee on Nutrition welcomes this public consultation and would like to give the following feedback on the Zero Draft of the Report on Water and Food Security

General comments:

Terminology in the title: Title should mention nutrition, and not imply that this is adequately included in the term food security

Without water there are no crops. To alleviate hunger, people must first have access to ample supplies of water in order to grow crops year round for food security. Additionally, diarrheal diseases, common in people who are forced to drink contaminated water, diminish the nutritional benefits of the food they actually eat. According to UNICEF, malnourishment affects a child’s ability to learn and actively participate in school. Food deprivation provides a daily stress on children and stunts both their emotional and physical development (FAO).

Specific comments on:

1.            The scope of the topic of water and food security is very broad. Do you think that the V0 draft has adequately charted the diversity of the linkages between water and food security and nutrition?  Is there important evidence or aspects that the present draft has failed to cover?

We appreciate the comprehensiveness of the report addressing water in terms of drinking water, resource for sustainable food and livestock production, and water as essential element of the ecosystem.

Regarding the linkage of water with nutrition security, the bi-directional linkage between water and sanitation with nutrition should be highlighted:

On one side increased access to safe water at household and community level leads to reduction of stunting in children under five years: In calculating the relative contribution of various factors to the progressive decline in child stunting between 1970 and 2010, Smith and Haddad (2014) estimated that increased access to safe water accounted for 25 % of the change.  For example, 2010, Lim et al. (2012) attributed roughly 8 million DALYs to unimproved water globally. The risks to nutrition derive from water-borne diseases, microbial contaminants that provoke enteric disfunction, diarrhoea, and a lack of cleanliness that itself increases food safety risks and lack of hygiene-related nutritional compromise. Separately, Smith and Haddad (2014) calculated that roughly 14% of the total fall in stunting between 1970 and 2010 resulted from improved sanitation.

On the other side, improved nutritional status of the household members and populations, leads indirectly to improved water and sanitation through increased demand. As all forms of nutrition improve, which leads to the associated benefits of demand for higher food quality, education, preventative health-seeking behaviours, and a voice in development, there is greater household exposure to, and practice of, appropriate hand-washing practices, food and personal hygiene, and sanitation. This results in demand for clean water and effective personalized sanitation. As poverty falls, consumers (urban and rural) understand and afford the benefits of private access to hygienic resources and facilities.  (UNSCN 2014)

http://www.unscn.org/files/Publications/Briefs_on_Nutrition/Final_Nutrition%20and_the_SDGs.pdf

We recommend referring to the WHO stunting reduction policy brief, http://www.who.int/nutrition/topics/globaltargets_stunting_policybrief.pdf , which also contains additional case studies on the relationship between water and sanitation and stunting reduction.

We also like to refer to the WHA Global nutrition targets, http://www.who.int/nutrition/topics/nutrition_globaltargets2025/en/

and in particular to the stunting reduction target which can only be achieve through a Multisectoral approach of nutrition-sensitive actions. These include adequate access to and use of clean water and sanitation.-

Therefore, we fully support the Recommendation 1, and have the following additional comments on this recommendation 1:

In order to adequately recognize the role of clean water and sanitation in reducing malnutrition and enhancing human well-being, this recommendation should include, under the responsibilities of States, international donors, UN and NGOs, one bullet point on monitoring. Such as

·         Monitor the proportion of population with access to and use of safely managed drinking water services, as well as the proportion of population using safely managed sanitation services, in a gender and other inequalities disaggregated manner. These two indicators are supported by the UN agencies and will be presented to the WHO EB to complement the 6 global nutrition targets.

Improved nutrition outcome like reduction in childhood stunting is an important indicator for successful improvement in water and sanitation. Therefore, we recommend

·         including stunting reduction as outcome indicator to the monitoring of access to and use of clean drinking water and sanitation services, in alignment with the WHA recommended global target on stunting reduction.

In addition, we would like to see reference not only to the poor, but also to other vulnerable population groups such as elder persons, displaced populations etc.

2.            Water use in food processing and Recommendation 5

The importance of water quality in the preparation of food for infant and young child needs to be highlighted.

Poor sanitation poses more of a risk to those who are particularly vulnerable, such as the non-breastfed infant and young child. Complementary foods and breast milk substitutes are more likely to be contaminated in areas where water supply, sanitation, and hygiene are lacking. Furthermore, families living under these conditions often have fewer economic resources and thus are less apt to prepare foods freshly for each meal, adequately reheat previously prepared foods, or store foods under refrigeration. Consequently, mixed-fed and weaned infants living in poor sanitary conditions face considerably higher exposure to foodborne pathogens than similarly fed infants in less contaminated environments. Exclusive breastfeeding during the first 6 months of live as recommended by the WHO, provides protection to infants and is particularly important for those living in highly contaminated environments.

With this regard we would like to emphasise the importance of the International Code of Marketing of Breast-milk Substitutes (http://whqlibdoc.who.int/publications/9241541601.pdf?ua=1)

The aim of the code is to contribute to ensure the proper use of breast-milk substitutes, when these are necessary, on the basis of adequate information and through appropriate marketing and distribution. The environmental factors like access to and use of clean water is an essential element. There is a role for Governments, UN agencies, NGOs, consumer groups and industry. We would like to emphasize, considering that manufacturers and distributors of breast-milk substitutes have an important and constructive role to play in relation to infant feeding, and in the promotion of the aim of this Code and its proposer implementation. We propose to add this to the recommendation 5, under the private sector.

With kind regards

UNSCN Secretariat Team

Bonjour

Ma contribution concerne la qualité de l'eau au maraîchage. je vous l'envoie en fichier attaché.

Merci et cordialement

Mme GREMBOMBO Adèle Irénée

Ingénieure agronome Nutritionniste

Paris

-Redmanglar Internacional es un movimiento que agrupa a más de 260 organizaciones y comunidades en doce países de América Latina y que trabaja por la defensa de los territorios costero marinos.-

“En las zonas costero marinas el agua es elemento fundamental, íntimamente ligado a la soberanía alimentaria de los pueblos costeros. “

Debido a lo corto de los tiempos que hemos tenido para la revisión, basamos nuestras opiniones al Borrador Cero, respecto a temas vinculados con el agua y los territorios costeros marinos.

En general:

Los temas relacionados con la acuicultura, en particular la acuicultura industrial de camarones deben ser considerados y abordados con mayor detalle en este borrador. Para un informe sobre el tema del agua y la soberanía alimentaria este debe ser un aspecto de gran importancia, por sus diversas implicaciones e impactos ambientales y sociales.

A pesar de que se hace referencia a no repetir en este borrador las conclusiones del informe: “Sustainable fisheries and aquaculture for food security and nutrition” Siendo la acuicultura industrial de camarones una de las actividades a nivel mundial mayormente responsable de la pérdida y degradación de ecosistemas costeros, humedales y fuentes de agua, ese informe tampoco aborda con suficiente profundidad diversos temas que a continuación compartimos y que representan nuestros puntos de vistas.

La acuicultura industrial, limita y viola el derecho a la soberanía alimentaria de los pueblos

La producción industrial de camarones, desde la instalación de piscinas y el sistema de producción  genera graves impactos en las aguas, afectando  la salud y los medios de vida de las comunidades. La acuicultura industrial profundiza la injusticia socio-ambiental. El desarrollo intensivo de la acuicultura de camarones implica la externalización, o transferencia a la sociedad y al medio ambiente, de los costes de la degradación ambiental. Así pues, mientras que una minoría logra cuantiosos beneficios económicos, el resto de la comunidad sufre las consecuencias del aumento de la pobreza, hambre, enfermedades, contaminación y vulneración de los derechos humanos fundamentales. Se privatizan las ganancias y se socializan los impactos ambientales y sociales.

Uno de estos impactos, directamente relacionado con las aguas y la soberanía alimentaria, es el uso de productos químicos y tóxicos en los procesos de cultivo de los camarones y de conservación del producto.  Amenaza la salud de los trabajadores y consumidores, genera a la vez graves efectos en otros organismos marinos, también con efectos posteriores en la salud humana.

El metabisulfito de sodio, aunque se considera un agente químico de insalubridad máxima en numerosos países, es un conservante químico ampliamente usado por esta industria. Este compuesto, al reaccionar con agua libera dióxido de azufre (SO2), gas que causa irritación en la piel, ojos, laringe y tráquea, y cuyos efectos pueden provocar, según numerosos estudios científicos, graves enfermedades a las personas expuestas. Además, el metabisulfito de sodio también se utiliza como conservante durante el transporte, por lo que el consumo de estos productos tampoco resulta recomendable para la salud, especialmente para personas alérgicas o asmáticas. Otros estudios constatan niveles elevados de PCB (conocido tóxico y cancerígeno) en los langostinos cultivados, así como otros compuestos contaminantes. A todo esto, se debe sumar las grandes cantidades de antibióticos que se subministran a los langostinos cultivados, para prevenir la propagación de bacterias y virus, cuyos efectos tienen graves consecuencias sobre el medio ambiente, pero que también pueden tener efectos nocivos sobre el consumidor.

Amenaza la integridad de los ecosistemas costeros.

El vertiginoso crecimiento de la acuicultura de camarones -cuya producción se centra el 99% en países del trópico en vías de desarrollo-, ha ido acompañado por una huella de explotación de los recursos naturales cada vez mayor, causando la destrucción generalizada de los ecosistemas costeros tales como deltas, estuarios, marismas, humedales y manglares, siendo éste último uno de los ecosistemas más afectados en el mundo. En zonas tropicales y subtropicales del planeta, el 38% del área del manglar ha sido destruida para la producción de langostinos destinados a la exportación, siendo esta actividad reconocida globalmente como la mayor amenaza al ecosistema manglar.

La camaronicultura y acuicultura industrial en las zonas tropicales y subtropicales afecta y hace más vulnerables a las sociedades y poblaciones costeras ante los impactos del cambio climático, tomando en cuenta la salud actual y el estado de conservación de estos ecosistemas costeros, como los manglares y otro tipo de humedales; en general los impactos de la degradación y destrucción de los ecosistemas costeros por actividades industriales acuícolas y otras, disminuye su capacidad natural de adaptación, así como la resiliencia de las poblaciones humanas ante el cambio climático. Los impactos de la destrucción del ecosistema manglar inciden directamente en la disminución de las pesquerías con efectos locales, regionales y globales, aún poco investigados y documentados.

La acuicultura industrial impacta  recursos hídricos y veda  el derecho humano al agua a los pueblos costeros:

Al destruir, acaparar, transformar e invadir los ecosistemas costeros, las empresas camaroneras realizan en el proceso inicial para la producción, el ingreso de aguas saladas o salobres a las piscinas camaroneras. Propiciando el proceso de salinización de las  fuentes de aguas frescas subterráneas. Esto ha ocurrido en muchos lugares donde la acuicultura del camarón se ha instalado. A manera de ejemplo, las comunidades de Tecojate e Isla Chicales en el Pacífico de Guatemala, padecen ya la salinización de sus fuentes de agua por la empresa camarones Oro del Pacífico. También la Sociedad Sueca para la Protección de la Naturaleza ha documentado en su informe Aguas Turbias (2011) testimonios y casos de estos procesos de salinización en comunidades de Bangladesh.

La salinización de las fuentes de aguas dulces es un serio problema que debe ser abordado en el Borrador Cero. La acuicultura industrial de camarones es uno de los principales responsables, pero también se suman: la industria de producción de sal a gran escala, y proyectos y mega proyectos de infraestructura que destruyen ecosistemas costeros estratégicos que funcionan como amortiguadores naturales, ante este efecto. La falta de aguas frescas debido a procesos de salinización es una realidad en muchas localidades, un problema concreto que veda el acceso al agua de buena calidad para el consumo. Las mujeres son uno de los grupos más afectados y vulnerables, en la búsqueda de agua no salinizada, deben recorrer largas distancias generando otros problemas sociales.  La agricultura familiar también se ve afectada, al salinizare las parcelas, estas quedan imposibilitadas para su uso, generando perdida de territorios, migraciones y afectando la producción y las economías familiares.

La contaminación por el vertió de aguas de desecho sin tratamiento es otro factor altamente preocupante. Antibióticos y otros productos químicos utilizados por las empresas acuicultoras así como los mismos desechos de los camarones, son vertidos a esteros y humedales con pocos o sin ningún tratamiento, generando la contaminación de las aguas. Se afecta y daña a los pescadores locales, debido a la disminución de la pesca, o al correr peligro  su salud al consumir pescado u otros productos contaminados.

Los desechos de las salinas o salineras, “desechos amargos” también contaminan las aguas, debido a que al aumentar las concentraciones de sal se presenta toxicidad para diversas especies en los ecosistemas.  La contaminación y degradación de las aguas por estas industrias, se da bajo un esquema de escasos o nulos controles por parte de las instituciones de gobierno en donde operan, y de violaciones a las normativas más elementales de protección ambiental.

Acaparamiento de las aguas en los territorios costeros:

El acaparamiento de las aguas y de las tierras, es otro asunto que debe ser abordado con mayor profundidad. Las agroindustrias como la caña de azúcar o la palma africana, utilizan grandes cantidades de agua, generalmente como una práctica común acaparan y desvían los ríos y otras fuentes de aguas, vedando el acceso a las comunidades locales al recurso.

Limitan el acceso al agua para consumo y para la agricultura familiar. Con la contaminación de las aguas también se ve afectada la pesca a pequeña escala, los altos niveles de contaminación propician la muerte de peces y otras especies utilizadas para el consumo o la venta afectando también la economía familiar. Impactan también ecosistemas naturales y la biodiversidad.

El uso de agrotóxicos, como: madurativos, fertilizantes y otros productos químicos como pesticidas contaminan las fuentes de agua, ocasionando graves problemas ambientales y de salud para las poblaciones humanas. Afectaciones a la biodiversidad, poblaciones de especies y organismos tanto terrestres como acuáticos. 

Los emprendimientos hoteleros y otras infraestructuras en zonas costeras que impactan el recurso hídrico: la industria hotelera demanda grandes recursos, como el agua, que es utilizada para el mantenimiento de zonas verdes, canchas de golf y para los servicios básicos para las habitaciones de los hoteles. Los hoteles utilizan el agua abriendo pozos y cada vez más disminuyendo los mantos de agua subterránea, tan importantes y delicados en una zona con gran influencia salina. Al disminuir el acuífero subterráneo, prácticamente se pierde un equilibrio entre las aguas, y la cuña salina puede ingresar y contaminar las aguas frescas o dulces.

Deben ser planteadas y consideradas de manera urgente sanciones a los agronegocios, por su responsabilidad en vedar y limitar el acceso al agua, acaparándola,  contaminándola y degradándola,  por ser éstos, factores que generan racismo ambiental. También deberían ser consideradas y exploradas obligaciones de las agroindustrias e industrias en sufragar los costos que genera la contaminación de las aguas y sistemas naturales, con el fin de restituir el entorno y el acceso al agua para las comunidades y poblaciones afectadas.

Para Redmanglar Internacional, el agua es un derecho humano fundamental, no debe ser bajo ninguna circunstancia privatizada ni sometida a ningún esquema que pretenda o plantee su mercantilización. La soberanía alimentaria es un derecho de los pueblos.

Carlos Salvatierra

Secretario Ejecutivo

Redmanglar Internacional

Cogmanglar – Secretaria Ejecutiva 2011 – 2016

29 Calle – 17-37 zona 12 Condominio El Rosario

Guatemala, Centroamérica

www.redmanglar.org

[email protected]

To Whom It May Concern,

As the lead for the U.S. Department of Energy's Water Energy Tech Team (WETT) Outreach and Stakeholder Engagement working group, I would like to provide the following recommendation for an addition to the HLPE Report Draft v0.

Page 21, Section 1.3.4, I recommend you add the following introductory paragraph:

“Present day water and energy systems are tightly intertwined. Water is used in all phases of energy production and electricity generation. Energy is required to extract, convey, and deliver water of appropriate quality for diverse human uses, and then again to treat waste waters prior to their return to the environment. Historically, interactions between energy and water have been considered on a regional or technology-by-technology basis. At the national and international levels, energy and water systems have been developed, managed, and regulated independently. As the largest single consumer of water, agriculture competes directly with the energy sector for water resources. However, agriculture also contributes indirectly to the energy sector via production of biofuels. Both connections will be strained by increasing concerns over water availability and quality. (DOE 2014).”

Reference: DOE (U.S. Department of Energy), 2014. The Water-Energy Nexus: Challenges and Opportunities.  (Page v. and vi.)

http://www.energy.gov/sites/prod/files/2014/07/f17/Water%20Energy%20Nexus%20Full%20Report%20July%202014.pdf

Justification: Section 1.3.4 elucidates the "water for energy" and "energy for water" aspects of the nexus, but they aren't actually called out. This also provides an opportunity to share the U.S. Department of Energy report on the nexus.

Perhaps of additional interest, pages x. and xi. of the report explain and illustrates: “The connection of water and energy to land is particularly important (Figure ES.4), as are the connections to global and regional climate, technology options and strategies, and broader aspects of socioeconomic development.”

Thank you, and please let me know if there are questions. Also, if you desire a more detailed conversation, including a briefing on our report, please feel free to contact me. Scott.

Summary

Landgrabbing and monocultures  are violating food sovereignty  and create  a tremendous threat upon  water and food security. The  main reasons  are the increasing meat consumption and biofuel targets  for drop in fuels, like bio diesel and bio ethanol.

Cold plasma technology for small scale production of syntethic diesel . (SD ) has however given a sustainable alternative,  since it can be introduced easily without any engine modifications . The  production cost per liter same  as for 1000 times larger Fischer Tropsch diesel plants . The potential is giant since the synthetic diesel  can be produced directly from biogas or by thermal gasification of any substrate with carbon  like  by example  tires and  waste from households. Introduction of biogas technology will also open up the possiblity for reclaim of denuded land that will contribute to rescuing of the rainforests, our rain cloud factories, thus securing one of our most important rainwater water supplies

Maintenance of soil fertility is a key challenge for  humanity to create food security. Use of chemical fertilizer and linear flows of nutrients will never be sustainable since rock phosphate is a limited resource.

Recycling of organic waste is thus a key issue. There are two ways of recycling  - composting and production of bio manure  from  anaerobic digestion in a biogas plant.

Composting is frequently used but has some limitations especially in metropolitan areas. It also creates huge losses of energy (heat)  and nitrogen.  Anaerobic digestion however can be adapted to any situation from family digesters to municipality digesters with  several thousands m3 of reactor volume. During fermentation in the digester, around 50 % of the raw material is transformed into bio methane a flexible bio fuel with the highest exergy and energy content of all bio fuels.

At the same time bio manure is produced that can be spread directly in growing crops, since nutrients are mineralized during fermentation and can be taken up directly by the plants without losses.

Thus the use  of bio manure from biogas plants will be a possibility for organic farmers to  increase the crop yields compared to conventional farming.

Biogas technology is like introducing an industrial cow that produces fertilizer. In Sweden initially cattle where kept for producing manure and feedstock for fermented milk products. But when chemical fertilizer was introduced and electricity became available,  milk and meat production became key issues for farmers and a disaster for humanity. They are now the biggest contributors to the global warming and declining  health in the world.

However biogas technology offers an excellent solution. By switching from the real cow to  the industrial cow, meat and milk producing farmers can get a sustainable alternative since the industrial cow feeds very well on grass and any organic waste including black water. In Sweden 4 out 5 fishes are used as feedstock for cattle. Thus declining fish populations can be restored by switching the cows.

Raw vegan food will lower the demand for cooking fuel and thus prevent deforestation and soil degradation. .The only cooking fuel you need is for making safe  water for soaking beans and cereals.

A family digester feed by household waste and black water will produce around 1 m3 of biogas per day which will be more than enough for the raw vegan family.

On a global level 240 Mha of arable land is used for producing cattle feed. If we lowered our meat consumption with 80% we would be able to release 200 Mha of arable land for growing grass and energy crops that together with any carbon waste  can support all our vehicles with bio methane. and synthetic  diesel.

 Monoculture crop production for Biodiesel and bio  ethanol can be abandoned once and for all. Further on biogas technology will make it possible to reclaim denuded land that makes it possible for exploiters of the rain forest to operate outside the rainforest. Rescuing  of the rain forest is the most important issue right now since the rain forest is a rain cloud factory that distributes rain to surrounding countries. Clearing rain forests is like stealing rain from your neighbor and without rain there will be no food.

Time is ripe for introduction of biogas technology  in combination with cold plasma technology  paving the way for introduction of 100% organic farming  and 100% renewable vehicle fuel, biomethane and  synthetic diesel. 

Bjorn Marten, independent  sustainable system designer

Sweden

please find enclosed comments made from our collegues of Spain, specifically from a perspective of WASH (water and sanitation in humanitarian work)

Looking forward to further engage with the HLPE processes and thinking

Best

Thierry Kesteloot

Oxfam-Solidarity

Good morning, it is very exciting to participate as a consultant to FAO documents. From my point of view it is an activity that has to be filled with pride to all participants.

Comments and inputs on the following important aspects:

1) The scope of the topic of water and food security is very broad. Do you think that the V0 draft has adequately charted the diversity of the linkages between water and food security and nutrition? Is there important evidence or aspects that the present draft has failed to cover?

The report is comprehensive and covers many important topics and story to the problematic of water and food securitya and I think the link between water management, food security and nutrition is demonstrated. As a matter of high importance to cover: the teaching of proper water management education as well also in terms of food security related to drinking water and higinizarse.

2) Has the report adequately covered the diversity of approaches and methodological issues, in particular concerning metrics and data for water and food security? Which metrics do you find particularly useful and which not?

The report is very explanatory in terms of approaches and methodology used to demonstrate metric parameters of the water.The most useful parameter is indicating how related is between the amount of water per capita and the amount of water that is in condition to be used in the feeding and sanitation to be food secure. As in the case of countries that have a high average rainfall but water infrastructure issues can not be exploited and that is used does not have adequate conditions for safe use.

3) Food security involves trade of agricultural produce, and a virtual trade of water. Agricultural trade interacts with water and food security in various ways, and differently for food importing countries, food exporting countries, water scarce versus water rich countries. Do you think the V0 draft has appropriately covered the matter?

Okay addressed the issue of issues related to food trade (in its various forms such as grain, meat, etc) and food security. Anyway there most food production is related to the private sector which is not presented in its most respect for water use. In many developing countries it is difficult to control by the state over the private sector mainly due to problems related to bribery, inefficiency in the management of water or lack of interest on water management. This is seen a lot when they are corporations that comercilizan food produced in other countries and not in the country of origin of the food. A controversy was raised in Argentina with the theme of soybean monoculture industrializing little to consumption in Argentina and one of the issues that were raised to consider is water loss suffered by Argentina which is built into the seed and not it also takes into account the wear and extraction of minerals from the soil. Also in international trade by large ships and make port in freshwater rivers, has lately proved that they are filling their ballast tanks with fresh water marketed in countries where the load carrying grain and sell this water sweet crude for them to be potabilizadas. This has been observed in the basin of the Rio de la Plata-Parana where is the port city of Rosario which is the largest grain agribusiness hub Argentina. These practices Trading are not regulated and may affect property rights of countries own their natural resources which through special taxes or charges may allocate those revenues to improve infrastructure for uptake of water for use in the food chain and to improve structure safe water in poor areas.

4) In this report, we considered the potential for an expansion of the right to water to also encompass productive uses. What kind of practical and policy challenges would this bring?

The right to water, to food, to health and to education should be inherent in every human being. As for the right to water for the production should be considered two aspect that may be related to conflicting ethical-legal-political kind. If the right to produce is referenced to the generation of food and if those foods to be marketed elsewhere in the world, we must take into account that production will not be available for residents of the region where it is realized production and also for such production water that may be in need of the citizens in their daily lives is removed. In such circumstance is this privileging people in other areas who have money to buy these foods rather than privileging locals production which compete for water supply. As the people have the right to water and feed is necessary to generate food but if the food is produced in a developing country with water issues and are sold in developed countries with high aquisitivo power, situation or problematic generates me in developing country? The production is entitled to water but also the people have the right to water and what produccido in that region and the surplus can be traded but can not remove the right to water to the inhabitants to produce food that will be marketed in other areas because we would be increasing the money power generating monetary inequality and inequity and lead to pay more for the right to water.

5) Which systemic actions/solutions/approaches would be the most effective to enhance water governance, management and use for food security?

From my point of view the approach may be more effective water management and food security should be the politico-social with a focus in the awareness of water management. In developing countries water management, unless there escazes no interest in the agenda of states and are not worried about pollution or increasing desertification. Governments in many of these countries are more concerned in the following year in the coming decades. It is the state approach that can enable increased infrastructure for the uptake of rainwater and can be ensured by controls pollution of aquifers not. Reports and recommendations will not be effective but become one of the most important issues on the agenda of governments. Without an international protocol to regulate and to consider a challenge to water management by all the countries the individual actions of each country will be governed according to the convenience of each country according to the problems that are identified on the fly and not are going to be working on real long-term solutions. Like for example I live in the city of Cordoba in Argentina. We are very close to a lake called Lago San Roque which provides us with water to the city of 1,250,000 inhabitants. This lake has been filled for decades by the growing mud generated in hilly areas due to deforestation that can not attract and retain water. The lake's capacity to retain water has led us to begin to suffer water shortages Alerts. The government policy was not only clean up the lake shore and increase the height of buildings leading to increased eutrophication of water and a minor amount of water to dissolve the contaminants. Do not plan on water management but governments often think of other government actions regardless of water management.

In addition to the issues and queries also wanted to make a contribution regarding the editing of the report which is not justified paragraphs, there are figures that are not mentioned in the text and no mention in the text of figures that are not included or has the name changed. In addition there are figures that are far removed from the text where they are mentioned and are displaced for several pages back or forward. Some figures to be extracted from other bibliographic materials or reports lack some information or axes which explains that seen in the figure which could be remedied with a footnote at the bottom of the figure. It would also be good to include a list of all abbreviations used for a more comprehensive document management. Give certain impression that the times were very short and could not make a review about the edition of the paper to reduce such errors.

Anyway it is a very good outreach and effort devoted to collecting and searching for solutions to water management shows.

I would like to thank for the opportunity to be working albeit with opinions or suggestions that maybe are not available to the excellence that is in the report but all views add to the plurarilad in water management and food security . I would have liked to do some stress upon the management of water purification to be consumed and possible technological alternatives who are within reach of at risk populations and poverty.

Also highly motivating and mobilizing of reviewers would be if there was the possibility of reward by an electronic certificate which has participated and collaborated in that FAO is an umbrella organization that to me proud and professional responsibility for the work and reports that perform and to have a certificate of collaborating is really pleasing. They are wont as a suggestion.

Greetings and at your disposal.

Ph.D. Professor Ruben Olmedo

Faculty of Agricultural Sciences

National University of Cordoba

ICYTAC-CONICET

Institute of Science and Food Technology.

Av. Valparaiso s/n. Ciudad universitaria.

Córdoba Argentina. CP:5000

+054-0351-59-5657

2. CICMA suggests not approaching the right to food in terms of right of poor groups or as priority  for  the most vulnerable the categories. This approach is not in  harmony with the universal level of  "human rights". The right to water and to food is universal and must be guaranteed to everyone, not just only to the most vulnerable people.

Our proposal is to confirm, in the draft,   the universality of   "human rights" linked to human dignity. The human rights   must be   recognized and guaranteed by all   the States.   It is time to assert the universal, inalienable, supra-national, inter-religious level of “human rights”  and promote the States' commitment  to recognize the “rights of nature/land” (ecosystems).

2. Has the report revealed adequately covered the diversity of approaches and methodological issues, in Particular Concerning metrics and data for water and food security? Which metrics do you find Particularly useful and Which not?

Consideration.

Referring  to the parameters of "quantification" to ensure food and water in terms of  “security”, the document suggests some  parameters  proposed by UN Agency for the minimum quantity of access to water. On the basis of the experience and assistance provided by FAO, it is possible  to propose in the draft a minimum quantify of water necessary to produce food for basic nutrition in rural areas?

Proposal

CICMA proposes that the draft  would formalize some proposals  regards the minimum quantity of water for drinking and sanitation in terms of “human water right”.   In order to realise and implement  the UN resolution is necessary to quantify the minimum guaranteed as a "human right" and at the same time  to identify  an instrument of international law that ensures this “ water right”.

CICMA  propose that the document adopt  of certain parameters in terms of the right to water for human use and for food production.

The parameters  to introduce as a benchmark are as follows:

1. Universal human water-right

• The right to water: minimum quantity of between 50 and 100 litres per day per person taken in charge by the State;
• The right to individual and collective welfare: between 100 and 250 litres day/peers access is guaranteed through a progressive tariff system in respect of good state of eco-systems;
• The right of water (sustainability of ecosystems): the  domestic use  in excess of 250 litres/day/p  is prohibited.

2. Universal right to access to water for food production and uses

• Right to collective water use: up to 1700 m3 year for all purposes, cost taken in charge by  to local community;
• Right to collective water use: uses ranging from 1.700 m3 /y/p   at to 2500 m3/y/p , access is guaranteed through a progressive tariff system
• Uses of water for intensive production   from   3500 m3 /y/p are prohibited if unendurable for the ecosystems.

3. Food security Involves trade of agricultural produce, and a virtual trade of water. Agricultural trade interacts with water and food security in various ways, and differently-for-food importing countries, food exporting countries, scarce water versus water rich countries. Do you think the draft V0 Has appropriately covered the matter?

Consideration.

Referring to  the concept of “food security”  it should be noted that not all the rural communities and farmers recognize the priority of these approaches, because food security do not defend their rights, but those who

have the ability to access the food market and to purchase it.

Access to food, the right to food and nutrition,  can not be addressed only as " availability of a food", possibly to access at low-cost or an affordable price, and  at if possible with a low water footprint.

The growth of national income  of  the countries  through export of agricultural products  with virtual trade water, does not the guaranties to transfer  these incomes to the peasants and the opportunity to ensure the

food.  The vision of “food security”  in terms of production and access to food does not guarantee the right to

food and basic nutrition for all, in particular for the poor community.

The right to food, the access to food  can not be assuring  providing to the rural community  the money to buy the food on the market or giving food-free .

To adopt the “virtual trade water” as a parameter to select or  to orient local agricultural and food production improve  the necessity to realize a national “market price of water”.  This approach support the prevailing view, imposed by the water companies and many national policy, that “water is a commodity” and not a human right.

Proposal

CICMA suggest introducing in the document the concept of “food and water sovereignty” as a way to real ensure food security, in terms of the right to access to water and food.

The paradigms of “food sovereignty”  and  “water sovereignty”  are used to strengthen the claim of the right to food,  to  water, to land of communities and to manage  production and agriculture processes, may  be realized in respect of human and environmental rights.

A vision of the right to food and water based on "sovereignty", namely in terms of self-determination of the

farmers, rural communities and peoples engaged to the rights to water, to the environment and the sustainable use of common resources (water, land , seeds, biodiversity) is preferable to a model of agricultural production oriented only to respect  “water footprint” or national food security through  the importation of technology, seeds and economic standards for agricultural production.

CICMA suggest preventing in the document the approach of “virtual water consumption”, witch strengthening the vision of “water is a commodity”, a resource with economic value in the market.

4. In this report, we considered the potential for an expansion of the right to water to encompass productive uses. What kind of practical and policy challenges would this bring?

The approach of "extension" of the right to water raised by the report is good but requires the positions defined on the legal basis on which the claim can be set.

Consideration

The approach of the report to consider the potential for an expansion of the right to water to encompass productive uses is good approach. We suggest, however, that this approach should be strengthened by clarifying the legal framework and the bases of reference.

Thanks to the mobilization of the water movements, ad international et national level, “water” is characterized today from a very advanced  international legal framework in terms of recognition as “human right to water and sanitation”.  The recognition of this right is secured by a specific UN resolution  and supported by States and subsequently by the Human Rights Council.

This  can proceed fire  by introducing   an international legal instruments concretely  realising the resolutions and conventions already ratified by the States and sanctioning j the violations.

The legal framework currently existing  for right to food and nutrition as human right is only at the level of reference in the Declaration of Human Rights (article 25) and of principles in terms of economic, cultural and social rights. There is no specific resolutions at human right.

Proposal

Cicma suggest that to explore the hypothesise that   water and food rights must be associated, with the support of experts.   A legal basis   such as   a Treaty or Protocol specific for human as a human right, adopted by the States and international community defining obligations of States, in terms of quantities, methods and sanction against of the violations of universal right to water.

Only  through the adoption  of this framework and the procedures for guarantying  the human righty to water we think   it will be possible to introduce principles in relation to  the right for water and food of vulnerable groups.

With reference   to other productive uses of water, it is proposed that this international legal framework confirms  that the human right to water and sanitation should  prevail  of other productive uses,  and that access to water for all other uses is subject to the balance of available water resources in that territory. Access to water for agricultural production and other purposes, must be based on a progressive tariff system for levels of consumption. The uses incompatible with the water balance of an area (resources of ecosystem or basins) should be prohibited.

5. Which systemic actions/solutions/approaches would be the most effective to enhance water governance, management and use for food security?

Consideration.

The document highlights the importance of water governance and identifies three level and models, but does not identify what is the most relevant to ensuring the right to food and food security.   The reflection on the most appropriate models of “governance” brings us back to the concept of the management model in terms of “food security”, “water security”.

Proposal.

1.Cicma suggest the opportunity to activate a process of analysis, with debate  and  consultation in CFS respect to the food security production, as model to access to right-food and to  promote  individual welfare of the poor, the farmer, and the rural community .

We think that the approach of "food sovereignty" linked to the rights of communities and rural producers, is a and responsible model of agricultural production with a more respectful cycle, combining individual rights, and more respect of the environment right’s (use of soil, land, water etc)

Referring to the management-governance of common goods, particularly of water, the governance must be conceived in terms of the sovereignty at global level (humanity, peoples) with the involvement of local people and communities, and not in terms of local, national security for access to food, water, and environment.

The concepts of “food security” and “water security” are linked to a concept of “national sovereignty” (State / Country) of naturals resources (water, soil, food) and therefore are associated to national security and defence policies.   In order to defend the access to national   goods it’s allowed and tolerated the use of military security in the name of “sovereignty” ( see   water wars, land wars ( grabbing),   wars for   food / bread),

To avoid these conflicts and ensure the “security of access to resources” for all, current trends’ tend to build models of “governance” that give the power to “definition of rules and legal bases” to stakeholders, reducing State’s sovereignty. We suggested to avoid  in  the “draft  zero”  supporting this model of governance  only practiced and supported by European Commission  and the principal corporations for “water management and  governance”  (  refer  to  policy’s  of  World  Water  Council,  CEO,  UNwater,  Blue  print  of  EC,TTIP negotiations USA-UE )

2. With respect to governance models, we believe it urgent to promote a reflection on   designing new models. The most appropriate model to ensure news governance  for the rights of the commons goods  is to create instruments of international law and supranational structures of law with legislative and sanctioning powers, about of the  national sovereignty of  States. One hypothesis, at international level, proposed by CICMA and other Movements is to promote a World Water Authority and  an International Court for Water and the commons goods.

At the regional level   it is necessary to propose and to adopt models of governance based on local communities.  These models  may  be recognized  by  legal  frameworks, by protocols or by treaties that introduce management at a local  areas, particularly transboundary basins of water.    Basin management committees should be  composed by  representatives of local governments and citizens  who live on the land and use the water resources, in particular citizens, farmers, stakeholders.

3. With reference to the principles, the appropriate model of governance must ensure   the rights of the citizens living  in the territories. Necessary to guarantee: the right to information on the quality of water  and on sources used by public or private actors; the right to the participation for civil sociality ;  the sanctions  of the right to violations;  the respect of the  human-right  water also in the wars  the respect for the rights of the environment (soil, climate) .

Part 2 : Recommendations

Point. 12 - The right to water and food

Consideration

On the basis of the above considerations, for CICMA suggest

• Binding  human right to water and the right to food, referring only to the common belonging as “human rights” recognized byn the Declaration of the United Nations, is a wach approach
• difficulties are even greater for the proposal to associate the right to food to recognition of the  rights of nature and ecosystems.  The failure of the Climate conferences’  that the States are not willing to give up their sovereignty over natural resources managed in terms of security

The recognition of the human right to water and sanitation, as established by resolution of the United

Nations, does not make an explicit reference he right to food ; it is difficult to sustain that it  be automatically extended in terms of food right, especially as a right to access to food for the poor.

Maybe it ’s possible to introduce the right to water for food  and  extension of the human right to water and the right to a dignified life ( right for the life).

The recognition of the right to water may be promoted and pursued:

-  At the level international, through a Treaty or International Protocol

-  At the level of individual countries,   through national legislative frameworks

The  definition  of  the  human  right  to  water,  the  regulation  of  the substantive  issues  that  need  to  be guaranteed by the States at the substantive and the procedural level, through an international Treaty adopted by the United Nations Assembly, could increase the possibility of obtaining a specific recognition for the right to water for food production, particularly for the most vulnerable groups.

At international level,   CICMA is engaged to promote a proposal for a Second Optional Protocol to the

International Covenant on Economic, Social and Cultural rights, on the right to water and sanitation

( PIDESC) ; in this  draft  there are  definitions of  water-right  in terms of “drinking water and sanitation”, and “drinking water”   is inclusive of   water use by human for   drinking, cooking, food preparation, personal hygiene and health or similar purposes.

At national level,  it is necessary that States adopt national law ensuring that “everyone has access to  safe water” and adopt roll propose  by the Optional Protocol for water an sanitation .

We   here remind that   the most advanced model of water-right is implemented in Ecuador : after having inserted of the right to water and right of nature in its Constitution, the Government passed a national law to regulating the different uses and recognizing the right to water to communities for food self-production.

Proposals

The Italian World Water Contract proposes to the drafting group to introduce in the “draft-zero” the following proposal :

1. to request to the Human Rights Council to propose to the States to adopt an instrument of international law,  a Treaty or Protocol, in order  to ensure the human right, autonomous, specific to water and sanitation, the obligations of States on the substantive and procedural terms.

2. to request to the Human Rights Council to adopt a  resolution  formally declaring  the connection between the human water-right, food-right” and right of water ecosystems. Such resolution should recognized the local community  as the subject who has the right to  manage plans for protection and use of  water, land and food.

3. to request to FAO to identify  the appropriate channels, at the level of United Nations, supporting  the proposal for a Second Optional Protocol to the International Covenant on Economic, Social and Cultural Rights (PIDESC) and at the same time promoting, among the objectives of sustainable development of the UN Agenda post-2015, the formalisation of the right to water, food, land as State’s commitments.

4. the request to FAO to give immediate effect to "voluntary guidelines" on land and resources management, by identifying the legal means for effectively implementation the protection of rights by the States.

I think it is a comprehensive report covering almost all the aspects. Please find suggestions on the report.

• There is a need to emphasis more focus on the efficient and wise use  of water for the crop production in the introduction.
• Water harvesting and its linkages crop production
• Trans boundary water issues and its nexus with livelihood, agriculture, crop production women role needs to be emphasized.
• I think there is a need to include latest food insecurity, water scarcity data in the introduction
• There is a need to analyze role on MNCs engaged in the water business like Nestle and its link with the water scarcity and water rights
• More emphasis required for the industrial waste, its linkages with water use for crop production especially vegetables(mainly women job)
• Water harvesting especially in the water scarcity regions.
• Need to include water insecure regions
• Monitoring water rights
• Need to demand promoting crops which needs less crops,
• Promote/advocate livelihood diversification including staple food/crops
• Information need to be added on impact of climate change on the decreased yield and its nexus with food security
• Need to include role of agriculture/water research institutes
• Need to emphasize on promoting food crops instead of cash crops
• Propose budget allocation
• Need more focus on the water conservation local methods, water erosion control etc
• Need to critical look into water privatization(based on the experience in south Africa, argentine etc)
• I think in the introduction a paragraph on the international commitments on right to water is required