NEW ZEALAND COMMENTS ON V0 DRAFT OF HLPE REPORT ON DATA COLLECTION AND
ANALYSIS TOOLS FOR FOOD SECURITY AND NUTRITION
General New Zealand comments:
Re: “food systems have failed us” - as for our comments in previous HLPE and CFS papers, and in
the context of the UNFSS – the paper needs to have a balanced narrative around food systems to
reflect the achievements of food systems as well as the gaps and problems. We prefer the OECD
Narrative in its “Making Better Policies for Food Systems” report “the frequent claim that food systems
are “broken” overlooks important achievements across all three dimensions, although important
challenges exist and require urgent attention”.
We also note the premise in the introduction that that data and information might be part of the
problem, in the sense that, despite the incredible amount of data and information available nowadays,
these are not sufficiently timely, accurate or relevant, or are not properly analysed and used to guide
the actions of all agents involved in the management and functioning of food systems’. Part of this
needs to acknowledge that in many cases, uncertainty, inconsistency and/or misinterpretation of the
data can result in the scale and nature of the problem being overstated or incorrectly stated. This
relates to our concerns around the “food systems have failed us” narrative being too simplistic, and the
lack of nuance around the example of meat consumption used in the report.
For the most up to date analysis of data issues and uncertainty concerned with comparison of food
items through Life Cycle Assessment (LCA) methodologies we recommend that the authors refer to
the recently published FAO report “Integration of environment and nutrition in life cycle assessment of
food items: opportunities and challenges” (Read the Publication Here). Many relevant aspects of the
report relating to uncertainty and data intersect with the issues in the HLPE paper. Refer in particular
to Chapter 4 for data related issues with LCAs, in particular section 4.5.
We welcome that there is a reference to data on Traditional and indigenous knowledge in the report.
The UNFSS process rightly acknowledged that data on traditional and indigenous worldviews are
often not well translated in scientific terms and this pertains to data as well. Ongoing engagement with
indigenous peoples and recognition of indigenous worldviews is needed in order to capture these
perspectives in data and food systems, food security and nutrition indicators.
We consider that the report would benefit from more discussion of the range of actors within domestic
food systems that are collecting FSN data (i.e. across local government, central government,
academia, private sector, indigenous groups etc.) including the incentives they have for doing so.
Policy makers need a good understanding of these incentives if they are to encourage integrated data
systems that are capable of providing useful insights into the performance of food systems.
The report could also provide further context around how food systems data is currently, and should
be, aligned with national data strategies (the ‘macro level/distal determinant’ level from the conceptual
framework). This could help with exploration later in the document of the policy approaches for
ensuring institutional settings support FSN data systems. For instance, some governments have a
centralised function (such as out of its statistical agency) that have a mandate for this national data
system and advancing it (New Zealand has a Chief Data Steward position that is responsible for
releasing the Government Data Strategy and Road Map).
Conceptual Framework
Comments
Generally, the methodology in the conceptual framework used makes sense (evidence, data,
disseminate etc.) however based on Example 1 the application is too high a level to support national
level policy-making in any detail. National level capacity constraints are well outlined in the wider
document, however further thought needs to go into how to support policy makers to utilise the
framework given the level of complexity, uncertainty, context specificity and data gaps they face in
reality. Many of the points in the table are very complex in their own right, and there is the added
complexity of interpretation of data, and analysis of trade-offs.
We have a number of questions and suggestions on the table:
- The document (and table) does not adequately capture the essential role of international trade to support food security and nutrition – with an apparent singular focus on local food systems/farmers markets etc. International trade can help improve the “matching” of supply and demand. Trade not only enables food to move from surplus to deficit regions, but also will be necessary to ensure the efficient and sustainable use of global food and agricultural resources. However, import tariffs for agricultural goods remain higher than for industrial goods, creating distortions which limit this “matching” function of international agricultural trade. The supporting role of international trade and impact of import tariffs and harmful subsidies on food security and nutrition is currently absent from the analysis, and should be part of any country data gathering and analysis relating to food security and nutrition using a systems approach.
- The links between nutrition and sustainable production and the assumptions around these need further clarification. The problem identified (too high or low meat consumption leading to poor health outcomes) and assumptions need further clarification (i.e. is “unsustainable” meat production assumed to reduce the nutritional content of the meat? Are environmental externalities (water, GHG emissions) linked to certain livestock systems assumed to be linked to particular health outcomes? (or simply to the consumption preferences of some consumers?).
- The current approach does not reflect the holistic approach to policy, which the rest of the report is promoting. I.e. Under a systems approach poor health outcomes would be identified in populations, then the full range of factors contributing to this would be identified (including interactions and feedback loops) – policy makers should then look at interventions holistically, considering all relevant factors. Meat consumption would be one of those factors in some populations, but there will be many other factors (dietary and otherwise) contributing to health outcomes. It does not reflect a ‘systems’ approach to policy making to frame the example using one factor. Our first preference would be for the report instead use an example from real life (i.e. within x country it was found that y. If this framework was used, then z…). If the preference is to keep it hypothetical, then perhaps the example could be nuanced to reflect the above point around multiple factors contributing to health outcomes.
2. The report adopts the broader definition of food security, proposed by HLPE in 2020, which
includes the two dimensions of agency and sustainability, alongside the traditional four of
availability, access, utilization and stability.
Comments
There was a range of differing views on broadening the definition of food security in the 2020
HLPE report development process. For example, the issue of including Agency as one of the
elements was a contentious issue, and this paper notes that it is difficult to measure through
current data. The paper currently does not cover the rationale and implications in depth and
requires referral back to the 2020 HLPE paper.
a. What type of data will be most useful in measuring food security dimensions such as “agency” and “sustainability”?
Comments
For sustainability, the LCA report we refer to in our general comments provides a useful detailed
analysis of the current state of play regarding knowledge gaps, inconsistencies and assumptions in LCA analysis and data.
4. The report discusses capacity constraints at local, national and global levels, with a special
focus on statistical and analytical capacity.
Comments
We support comments on page 15 around the importance of engagement with stakeholders when
using digital technologies to address ethical concerns and ensure accuracy ground trothing at farm
level (He Waka Eke Noa example below). We agree with 3.1.5 on “usability of the data is limited when
stakeholders have not been involved in the survey planning and there is inadequate dissemination or
access to information on what data is available and how it can be used by the stakeholder”.
We support the comment on page 18 on the findings of the Independent Evaluation on FAO’s support
to countries and the need for better capitalising on regional statistical expertise. For the Pacific region,
we are glad that the FAO is engaging with the Pacific Data Hub at the Secretariat for the Pacific
Community (SPC).
7. Drawing on HLPE reports and analysis in the wider literature, in the next draft the report will
outline examples of potential policy pathways to address challenges to data collection and
analysis tools for FSN.
Comments
We suggest that this work should consider and build upon relevant OECD reports that overlap with
this area including:
- Overcoming evidence gaps on food systems, OECD 2021
- Making better policies for food systems, OECD 2021 – especially chapter 3.2.
Several ongoing initiatives within New Zealand relate to the points under question 7. We are happy
to provide further information on specific initiatives if it would be helpful to the report.
- He Waka Eke Noa is a partnership between the New Zealand Government, Industry and Māori to work towards pricing agricultural emissions. The programme that will equip farmers and growers with the information, tools and support they need to reduce emissions and build resilience to climate change. Part of the workplan includes ‘Developing criteria, methodologies and definitions for calculating on-farm emissions and a system for farm-level emissions accounting and reporting.’
- Integrated farm planning is a complementary programme to He Waka Eke Noa that seeks to pull management practices and information on business planning; animal welfare; biosecurity; employee wellbeing and management (including health and safety); agricultural greenhouse gas emissions; freshwater; intensive winter grazing; biodiversity; waste management; nutrient management; adverse event plan (to ensure an agribusiness can keep operating during a storm); Te Mana o te Wai; consents and permits; food safety.
- The Sustainable Food and Fibre Futures fund: which supports problem-solving and innovation in New Zealand’s food and fibre sectors by co-investing in initiatives that make a positive and lasting difference. This includes initiatives that will help farmers and growers, including Māori to better collect and utilise data.
Māori (the indigenous peoples of New Zealand) collect and hold data relating to FSN separate to and in partnership with Government. Should the authors be interested in such examples then we can reach out to see what examples may be appropriate to contribute.
Don Syme