Please see attached file, an excerpt of which is copied below.
Pesticide Action Network North America (PANNA) welcomes the initiative of the High Level Panel of Experts (HLPE) to develop a report on the contributions of agroecology to food security and nutrition. We appreciate the opportunity to submit comments (below) on the proposed scope of the report, as well as on the authorship, execution and governance of the report.
PANNA is a non-profit, public interest organization representing the concerns of over 100,000 supporters across the United States, including farmers, farmworkers, health professionals, members of sustainable agriculture, labor, environmental and consumer groups and individuals concerned with the safety, sustainability, fairness, resilience and integrity of our food and farming system. PANNA is one of six regional centers in the PAN international network, which consists of 600 groups in over 90 countries dedicated to building healthy, ecologically-sound and climate-resilient agriculture.
Contribution of agroecology. PANNA defines agroecology as the science, practice and social movement of applying ecological concepts, principles and knowledge to the study, design, development and management of sustainable farming systems. Agroecology combines scientific inquiry from multiple disciplines (including the social sciences) with local and Indigenous knowledge and community-based experimentation. It often includes social and institutional innovations to ensure secure access to land, water, diversity of seeds and the protection of farmers’ rights to freely exchange knowledge and resources. The highly biodiversified and robust farming systems that result mimic and support (rather than repress) natural ecosystem functions, are knowledge-rich, low cost and readily adaptable to local and changing social and environmental conditions.
As such, agroecology has proven ability — and enormous additional potential if better resourced — to provide abundant food, invigorate local economies, restore degraded agroecosystems, phase out highly hazardous pesticides, reduce farmers’ vulnerability to global commodity price fluctuations and their dependency on international corporations, while eliminating many of the negative impacts of prevalent chemical-, water-, and energy-intensive agricultural, forestry and livestock systems. Furthermore, agroecology can strengthen the ecological, cultural, economic and social resilience of our food and farming systems in the face of enormous stresses posed by climate change.
Modern and innovative agroecological approaches which integrate hundreds of years of farmers’ experiences with state-of-the-art science are proving to be sustainable, economically advantageous and good for food security as well as food sovereignty. Supporting agroecological farming systems is key to fighting environmental degradation, adapting to and mitigating climate change, and securing future generations’ health and livelihoods.
“Other Innovations.” The inclusion of this phrase in the title and throughout the Scope is curious and troubling. The phrase itself is so broad as to be meaningless, and could easily be interpreted or used as an excuse to introduce approaches and technologies that undermine agroecology and have no place in an ecosystem-based approach to equitable and sustainable food and farming systems. Certainly, many innovations from the pesticide and biotechnology industries have been assessed already and have occupied a tremendous amount of reviewers’ time, energy and publishing space. The UN-led International Assessment of Agricultural Knowledge, Science and Technology for Development (IAASTD) assessed many of these technologies, as detailed in its 2008 report. Nearly a decade later, a great deal of controversy continues to surround these technologies (as well as geo-engineering initiatives), with critics pointing out industry ties and conflicts of interest among recent reviewers, such as those involved in a recent US National Academy of Sciences report on biotechnology).
While it may well be time for another independent assessment of the approaches, technologies or products owned or developed by corporate actors, this can and should be done at a different time and place. We strongly urge the HLPE to maintain a clear-eyed focus on agroecology, for its potentially one-of-a-kind report. At the very least, the phrase “and other innovative approaches” should be modified by the term “ecosystem-based,” so that it reads “and other ecosystem-based innovative approaches.” Examples should then be spelled out, e.g. “and other ecosystem-based innovative approaches such as permaculture, organic, regenerative farming, etc.”
Project team. When forming the project team, the HLPE should ensure that members of the team represent a range of disciplinary expertise (including especially the ecological and social sciences), genders and geographic regions, as well as expertise from the field (i.e. farmers and members of social movements implementing agroecology on the ground, representing or accountable to those having direct experience of or most directly impacted by agroecology, climate change, etc.). While we understand that author time is generally expected to be contributed on a pro bono basis, we urge HLPE to consider providing stipends for team members such as farmers whose livelihood would be constrained by participation in this initiative. Project team members should have ability and proven experience in working and thinking holistically, across disciplines and in terms of complex interacting systems. Furthermore, members should be independent of agribusinesses or corporate lobbying associations that have a vested interest in the outcome of the report, i.e. members should have no ties, direct or indirect, with such corporations). The latter interests would be welcome to submit evidence for scrutiny, but should not be represented on the project team. A useful model for author selection and team composition is provided by the IAASTD (please see Appendix A).
Evidence. The report should admit evidence from peer-reviewed sources, as well as "grey literature" from civil society (e.g. reports and contributions from peasant farmers, NGOs, research and development institutes and foundations). The report should exclude marketing information, public relations material and product promotions, e.g. from sources with a financial or competing interest in promoting commercial products and technologies.
Transparency and governance. HLPE’s decision-making process and outcomes, and the project team’s work should be conducted with total transparency. Following the model of the IAASTD, Principles and Procedures should be developed and agreed on at the outset, with civil society participation, particularly by directly impacted communities, and with oversight provided by an independent governance body that also includes civil society participation (see Appendix A.) First and second order drafts should be made available for public review and comment, and the review process (including a compilation of all reviewers’ comments and how project team members respond to each comment) should be transparent and made public. The Principles and Procedures should identify how differing assessment of the evidence and conclusions by authors will be presented and include a "conflict resolution" processes. Following the IAASTD, if and when differences appear, we encourage the Project Team to report and discuss these differences, rather than reduce analysis to a less rigorous “least common denominator” approach, by including only those conclusions reached by consensus.
Scope. Proposed changes to the draft Scope by HLPE Steering Committee follow in attached document
[Additions are written in bold red, deletions are crossed out]
Marcia Ishii-Eiteman