Global Forum on Food Security and Nutrition (FSN Forum)

Humane Society International (HSI) is one of the world’s largest animal protection organizations working to protect all animals. HSI’s farm animal welfare initiatives engage stakeholders at every stage in the supply chain for eggs, milk, and meat—including farmers, governments, food retailers, financial institutions, and consumers—to improve the welfare of animals raised for food. We greatly appreciate the opportunity to provide input to the Zero Draft of the HLPE Report on Sustainable agricultural development for food security and nutrition, including the role of livestock.

Overall, we appreciate that the report tries to be comprehensive and include recommendations aimed to meet multiple sustainability and nutrition goals. Indeed, this is the type of approach necessary in the 21st century. At the same time, we see room for improvement, particularly as it relates to animal welfare, sustainable diets, and implementation.

Our comments are organized below in response to the HLPE’s twelve questions regarding the Zero Draft. We hope they are useful and look forward to discussing any questions the Panel may have.

1. The report is wide-ranging and comprehensive in analyzing the contribution of sustainable agricultural development to ensuring food security and nutrition (FSN), with a particular focus on the livestock sector because of its importance for both nutrition and sustainable futures. Do you think that the report is striking the right balance between agricultural development overall and the livestock sector specifically with respect to their relative contribution to FSN?

2. The report is structured around context, trends, challenges and pathways/responses. Do you think that these are comprehensive enough, and adequately considered and articulated? Does the report strike the right balance of coverage across the various chapters? Are there important aspects that are missing?

While the overall approach is useful, they could be clarified. Section 2 (trends) often seems to spill over to Section 3 (challenges). Further, the responses (Section 4) and recommendations (Section 5) should be more aligned. Section 5’s recommendations actually seems to have improved detail that could be reflected in Section 4.

There should be a fuller accounting of negative impacts of animal agriculture on environment, animals, and health. Many of the statements in this regard are not as specific as those presented for the positive case. For example, the impacts of farm animal agriculture on the climate, as discussed above, should be supplemented. Suggested remedies for this are listed with the specific text comments in response to question 12, below.

3. The report uses a classification to distinguish between four broad categories of livestock systems, in order to better identify specific challenges and sustainable development pathways for each of them. Do you find this approach useful for identifying specific policy responses and actions in different socio-economic and environmental contexts?

Four broad categories can be useful in terms of responses. However, the nomenclature between intensive and industrial animal agriculture is often misplaced. The “intensive livestock systems” category (p. 33 line 3) actually seems to identify the “industrial livestock systems” discussed elsewhere in the report. This category should be changed to the latter to reflect that. Further, throughout the report, the use of “intensive” and “industrial” should be reviewed to ensure that “intensive” is not used inappropriately. One term does not necessarily imply the other.

4. The report has referenced key projections and scenario studies in identifying the drivers and trends through to 2050. Are there other studies that the report needs to reference, which offer different perspectives on the future outlook for the agriculture (including livestock) sector, in particular those that focus on nutrition and diet?

The trends in terms of diet and climate change impacts are missing at least two key references. Section 3.3.1 should be expanded slightly to reference some of the numerous studies showing not only the overall large impact of animal agriculture on climate change, but the different impacts of different dietary choices. Regarding diets, vegetable-based diets have been shown as having significantly lower in emissions in different national contexts. Some of these are discussed in the IPCC Fifth Assessment Report, Working Group III, Chapter 11. Regarding the overall impacts, one study looked at animal agriculture’s impacts on sustainability boundaries in the year 2050 and found that, even assuming efficient sectoral growth, farm animals alone are projected to account for over two-thirds of the amount of GHGs considered safe by 2050. (Pelletier N and Tyedmers P. 2010. Forecasting potential global environmental cost of livestock production 2000-2050. Proceedings of the National Academy of Sciences of the United States of America 107(43):18371-18374.)

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?

6. A decision-making approach that could be useful for policy makers in designing and implementing policies and actions has been proposed in Chapter 4 of the report. Is this a useful and pragmatic approach?

7. Chapter 4 also contains case studies/examples of evolutions of agricultural development policies and actions in different contexts/countries. Could you offer other practical, well-documented and significant examples to enrich and provide better balance to the variety of cases and the lessons learned in agricultural development, including the trade offs or win-win outcomes in terms of addressing the different dimensions of sustainability and FSN?

8. The social dimension of sustainable agriculture development has often been less well described and understood, including due to lack of data. Examples and experiences on such issues (livelihoods, gender, share and situation of self employed versus wage workers, working conditions, etc.) would be of particular interest to the team.

9. The upstream and downstream sectors are playing an increasingly important role in respect of the orientation of agricultural development, food choices and diets. Can you provide examples of the role these sectors play in sustainable agricultural development and FSN?

Downstream: Hundreds of large food companies throughout the world, from Nestle to Compass Group, have adopted policies that call for higher animal welfare standards within their supply chain, and encourage more plant-based eating.

10. What are the key policy initiatives or successful interventions to improve the sustainability of food systems, in different countries and contexts that merit discussion in the report? Is there evidence about the potential of economic incentives, and which ones (taxes, subsidies etc.), regulatory approaches, capacity building, R&D and voluntary actions by food system actors?

Demand-side approaches deserve more attention, including current initiatives and knowledge and research gaps, with a particular focus towards implementation.

11. The design and implementation of policies for FSN requires robust, comparative data over time and across countries. Where are the data gaps that governments, national and international organizations might need to address in the future in order to understand trends and formulate better policies?

Possible interventions, responses, and impacts of shifts towards more sustainable diets would be helpful.

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.

Overall, while there are not any major omissions, there are a number of opportunities to improve the report in terms of animal welfare and healthy and sustainable diets.

In addition to the comments on the balance of the report above, we note that there seems to be a presumption that negative tradeoffs are necessary in furthering sustainable agricultural development (e.g. page 43 lines 38-39; page 64 line 39). It is not clear to us that the evidence supports this. Further, the HLPE should make efforts to find pathways that provide co-benefits, of which there are many.

In terms of projections, often they are couched in language that indicates a level of certainty that goes beyond what the projection is and that contradicts a frank discussion in Section 5, for example, that explains that projections are just that, projections (page 81 lines 30-32). Thus, care should be taken to ensure references to projections are not used with certain language, e.g. page 23 line 39 “will rise....”

Finally, and importantly, Sections 4 and 5 of the report are seriously lacking in terms of timelines. Environmental and other sustainability concerns outlined in the beginning of the report show that changes are needed immediately, yet the responses, decision-making framework, and recommendations lack any timeline, through the CFS processes or elsewhere.

Specific comments follow:

Page 16 line 16: “Care” should be changed to “welfare.”

Section 1.4 ignores healthy vegetarian diets, but this should be included.

Page 26 line 17: We are unclear of how you calculated 33 billion livestock. Using FAO Stat, we have calculated that, in 2013, 77 billion land animals were raised for food. Thus, we think your estimate is a significant underrepresentation.

Page 34 lines 16-19: The shift to industrialized animal agriculture should be more clearly shown in the report, possibly here. A good reference for this is the Pew 2008 report.

Page 38 lines 18-20: This statement is unsubstantiated and should be changed if it cannot be supported. It is unclear to us that this is the case.

Section 2.5 needs subsection on animal welfare rather than just merging the topic into conclusion comments (Section 2.7). This would also better reflect the attention given later in the report.

Page 41 line 38: The section on food waste should recognize the wasted resources consumed by the inherent inefficiencies of animal agriculture. The conversion of energy and protein in animal feed into edible meat calories and protein is highly inefficient. Most of the energy farm animals consume from grains and other sources of food is used for metabolic processes or for forming bones, cartilage, and other non-edible parts (offal), as well as feces. This suggests that, in many cases, scarce agricultural land and water are better allocated to the production of high-nutrient plant-based foods. While estimates of feed conversion vary across production systems and regions, studies conducted in the U.S. offer some insight into the inefficiency of milk, egg, and meat production. Smil calculated feed conversion efficiencies of various types of farm animal production based on USDA data from 1999 (Smil V. 2002. Nitrogen and food production: proteins for human diets. Ambio 31(2): 126-131. p. 130). According to his calculations, it takes 4.2 kg of feed to produce 1 kg of chicken meat, 10.7 kg of feed per kg of pig meat, and 31.7 kg of feed per kilogram of beef. Eggs are similarly inefficient by this measure, requiring 4.2 kg of feed to produce an edible kg of eggs.

Page 43 lines 29-31: The history and extent of the shift to industrialized animal agriculture should be more clearly shown in the report. A good reference for this development is the Pew 2008 report.

Page 45 lines 22-34: Animal welfare should be listed as a priority issue.

Page 48 line 9: “Welfare friendly” should be changed to clarify “animal welfare friendly.”

Page 49 lines 22-26: It is misleading, and against overwhelming and consistent evidence of the lower GHG emissions intensity of vegetarian foods, to pinpoint that orange juice has a higher carbon footprint than milk. This statement needs to be put into context to more accurately reflect dietary choices and impacts on climate change.

Page 54 lines 13-15: The comparison of water footprints in terms of protein efficiencies is written with bias that misrepresents the results of Mekonnen and Hoekstra (2012). They state “When we look at the water requirements for protein, we find that the water footprint per gram of protein for milk, eggs and chicken meat is about 1.5 times larger than for pulses. For beef, the water footprint per gram of protein is 6 times larger than for pulses.” Table 3 of that study also shows pulses, oil crops, vegetables, and cereals as having lower water footprints per unit of protein than eggs, chicken, or other animal products. This contradicts the tone and phrasing of the Zero Draft, which should be changed to more truly reflect the results of the study.

The current, headings of subsections 3.3.1 and 3.3.4, which on their face could be confused with one another, should be clarified to indicate the actual substance of the sections. Section 3.3.1 should be more clearly identified as concerning the impacts of farm animal production on climate change, while section 3.3.4 is in regard to the impacts of climate change on agriculture, in particular farm animals.

Section 3.4.4: As a whole, this section should include many more references to show where the statements originate.

Page 58 lines 5-8: The definition of animal welfare should not solely rest on the OIE, especially given that the OIE is still developing specific standards. Another helpful reference here would be to the Five Freedoms. The Five Freedoms is a framework for approaching animal welfare. It is a logical way of thinking about the animal welfare problems that can occur in different housing and management systems, and lays out the important needs of animals that should be addressed. The concept originates from a 1965 British government committee, which was first tasked with a formal examination of the welfare of animals in proliferating industrial production systems (http://webarchive.nationalarchives.gov.uk/20121007104210/http://www.fawc...).

Page 58 lines 40-46: The origin of this list of challenges should be shown and clarified. Currently, it is unclear whether this list is complete or correctly reflects the body of evidence. At least, a fourth category for public and private finance, for example in the form of development banks, should be added. The European Bank for Reconstruction and Development, for example, updated its Environmental and Social Policy to ensure that any agribusiness projects it finances meet or exceed European Union animal welfare laws (as reflected in Box 17, p. 79).

Page 58 line 51: Alone, the noted difficulty in producing global consensus ignores the wide-reaching animal welfare improvements in numerous national contexts and production systems, including those stimulated by consumers and major multinational companies (as reflected in Box 17, pp. 79-80). This section should more clearly contextualize the current progress and continuing, major improvements in global treatment of farm animals.

Page 62 lines 20-28: It should be noted that the choice of mitigation practice or technology can have implications outside of climate change. One example is in terms of animal welfare, and pathways should be chosen that amplify co-benefits and avoid negative tradeoffs (Shields S. and Orme-Evans G. 2015. The Impacts of Climate Change Mitigation Strategies on Animal Welfare. Animals 5(2):361-94.)

Page 62 lines 29-31: It should be clarified that the referenced FAO report suggests that wholesale system changes, for example to industrial production, are not necessary for the vast majority of benefits (Gerber et al., 2013, at pp. 45-46).

Page 62 lines 36-37: It should be noted that this approach, particularly towards more production of monogastric species, implies significant negative animal welfare impacts (Shields and Orme-Evans, 2015). And there are alternative pathways that imply little to no tradeoff.

Page 63 lines 26-27: Again, it should be noted that this approach, particularly towards more production of monogastric species, implies significant negative animal welfare impacts (Shields and Orme-Evans, 2015). Yet, alternative options offer co-benefits and avoid such tradeoffs.

Page 63 line 55 to page 64 line 20: The purpose of list should be clarified. At least, animal welfare and health should be added to the considerations.

Page 64 line 39: The evidence that tradeoffs must be made in most cases seems, at best, weak. Gerber et al. (2013) does not seem to imply this in terms of climate change. Nor, in the case of animal welfare, is this necessarily the case (Shields and Orme-Evans, 2015). Thus, language discussing whether tradeoffs may or may not be necessary should be softened.

Page 66 lines 15-30: Animal-welfare-related responses should be strengthened. To call for development of animal care standards leaves ample opportunity for standards that do not actually meet the physical and behavioral needs of the animals. Thus, it should be added that responses should be based on the Five Freedoms and not allow backsliding from global progress. One useful response for minimum standards, for example, is the banning of gestation crates in pig production and battery cages in laying hen facilities (referenced in Box 17, p. 80).

Page 66 line 31-page 67 line 4: Healthy and sustainable diets should be added to the cross-cutting responses, which can positively impact many aspects in this report. And it is already, rightly, included in the cross-cutting recommendations (p. 83 line 36).

Page 68 lines 4-6: This change also implies negative tradeoffs for animal welfare (Shields and Orme- Evans, 2015).

Pages 74-75 Box 13: For this, too, multiple goals must be met at the same time. The intensification of beef production in this context should not lead to negative animal welfare or environmental tradeoffs. For example, it should not lead to an increase in feedlots.

Pages 76-77 Box 15: The animal welfare implications of these changes should be discussed.

Pages 79-80 Box 17: The IFC Good Practice Note was updated in 2014, so the 2006 version referenced here is no longer current. The subheading “Delivering animal welfare” should include Humane Society International, which has also been working throughout the globe with governments, businesses, investors, and industry to implement practical and meaningful farm animal welfare improvements. Further, a different subheading for the last two paragraphs of this box is necessary, since those do not fall under the IDF.

Page 81 lines 18-19: “Animal care” should be changed to “animal welfare.”

Page 82 line 14: “Some people” seems inconsistent with the “billions seriously affected” regarding overnutrition in Table 1 at page 54.

Page 84 line 10: “Care” should be changed to “welfare.”

Page 85 line 20: In the heading of this section, “care” should be changed to “welfare.”

Page 85 lines 42-45: As we suggested for Section 4, the animal welfare recommendation should be strengthened. While it is good here to point to industrial systems, this recommendation still leaves ample opportunity for standards that do not actually meet the physical and behavioral needs of the animals. Thus, it should be added that these should be based on the Five Freedoms and not allow backsliding from global progress. One useful response for minimum standards is the banning of gestation crates in pig production and battery cages in laying hen facilities.