Dear moderator
Please find below the comments from Fundación Global Nature (Spain) to the Online consultation for developing the Voluntary Guidelines for Sustainable Soil Management. Apologies for not addressing specifically the questions included in your invitation, but we think that our comments would better contribute to the improvement of the draft. Here is our contribution:
In general terms (but also specifically for point 5.0), we miss a part in the text for identifying the stakeholders to which these guidelines are addressed. It is stated that these guidelines shall be generalist, non specific to crops or regions, etc., as all this require a multi-scale assessment and further work. These guidelines are said to be addressed to governments and other institutions. In our opinion, a higher effort should be made in the document to identify “multipliers", that is, stakeholders on the ground that could potentially reach farmers and farmer communities (let's not forget that farmers are the responsible for implementing all this) to spread this document. At least defining their profile would be interesting. We are pretty sure NGOs, consumers and society-based organizations would fit these requirements and would be happy to contribute. Agrifood companies could be addressed and for most of them, it could be a good inspiration.
Point 3.1. We think a much more emphasis should be placed to highlight the importance of suburban agricultural areas. At least in the Mediterranean basin, the best soils are beside rivers where cities have been historically located. Urban growing has sealed these soils forever, leaving the worst soils for agriculture. The problem is somehow stated but no practical recommendations are given (urban land planning according to soil relevance, longterm strategies to preserve and/or restore soils, agricultural areas included inside cities, etc.)
Point 3.2. Non-tillage and conservation agriculture is mentioned as a good practice with multiple environmental benefits. However, it should be stated that this practice is only sustainable if it is combined with other practices, specifically cover crops and longterm rotations. Otherwise, non-tillage techniques lead to a massive use of herbicides and fungicides.
Point 3.4. It should be clearly stated that a nitrogen balance should be the appropriate decision tool to ensure an appropriate nutrient management. Farmers should at least try a rough approximation to its calculation based on realistic yields and baseline information on the crop.
Point 3.5. We would go further and include that appropriate training shall exist for using pesticides. Also that soil disinfection shall be banned (and alternative solutions used such as diverse and long rotation).
Point 3.7. We would recommend to include a comment for enhancing the use of decision-support tools for better irrigation (tensiometric probes and similar equipment, software, etc.)
Finally there is a point with which we disagree: in 4.0 there is a whole section devoted to “Sustainable Intensification”. The fact is that all what is mentioned in section 4.0 is a repetition of the good practices mentioned before, that leads to a better management of the soils, and obviously to a better yield thanks to reduction of risks: erosion, pests, soil depletion, nutrient excess, loss of soil structure. Therefore, the use of “intensification” is completely unnecessary and the word “efficient management for better yields” or “competitive and friendly agriculture” is much more appropriated. However this section is directly linked to a document approved before… so we are not sure if it makes much sense to come into this aspect.
We also miss the following points:
- recommendations for governments to deliver to multipliers soil maps as a basis for agricultural decision
- recommendation for having records of soil operations, as a training methodology for continuous improvement
- recommendation on regular soil analysis as a baseline for decision-making in terms of fertilization
- promoting the use of legumes for cover crops, crop rotations, winter crops, catch crops, intercrops, etc.
- conduct regular soil machinery maintenance for better performance
- continuous training for understanding agricultural soils
For further details and/or comments, please do not hesitate to contact us.
Cheers,
Jordi Domingo Calabuig
Fundación Global Nature
C/ Real, 48. Las Rozas (Madrid)
E-28231 Spain
www.fundacionglobalnature.org
Jordi Domingo Calabuig