Глобальный форум по продовольственной безопасности и питанию (Форум FSN)

Dear Sir, Madam

Thank you for the opportunity to read your report.  Please see my comments in attached.   I apologise for the delay in responding to your request.

I note that after 30 November, my email address will change to:  [email protected]

Best wishes

Joanne Daly

Dear Colleagues:

Please find attached the U.S. Department of Agriculture’s comments on the current draft of the HLPE report on sustainable agricultural development for food security and nutrition, including the role of livestock (Draft V0).

Please let me know if you need any clarifications.

All best regards,

Elise

De nuestra mayor consideración:

Se remiten adjunto al presente correo los comentarios del Ministerio de Agricultura, Ganadería y Pesca, de la República Argentina, relativos al Borrador Cero del Informe de referencia.

Asimismo, encontrarán, a continuación, las respuestas a las preguntas propuestas por los autores del citado Informe:

I) Respuestas a las preguntas propuestas por los autores del proyecto de informe

Question: 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?

Answer: One of the challenges that the report could further elaborate on is the danger that restrictive and scientifically unjustified private standards pose on the regulatory authority if States. It is important not to undermine state capacity to regulate in a transparent, science-based and undiscriminatory manner. Concerning health and animal care the conclusions could be rewritten as follows.

"18. Extend and prioritize actions aimed at tackling the world's most serious nutritional challenges through action to:

c) review the scope for a range of interventions, preserving the State s role in regulatory matters, including labeling (covering nutrition as well as sustainability indicators), advertising restrictions, taxes and public procurement for targeted feeding programs

20. Increase efforts in animal disease surveillance and treatment, both to improve livestock sector productivity and to reduce dangers associated with the spread of pests and outbreaks of animal diseases and zoonoses.

21. Revisit policies, including the use of antibiotics in the livestock sector, to reduce the growing health risks associated with anti-microbial resistance, directing energies to strengthen the tripartite collaboration between FAO, OIE and WHO for combating antimicrobial resistance by providing recommendations and taking actions based on sound scientific evidence following the applicable multilateral rules and recomendations for the development of sustainable food production systems that prevent diseases, promote good animal husbandry and management, biosecurity, hygiene practices and health."

In the same vein, it is of the outmost importance not to create arbitrary standards - not compatible with the scientific principle - which could hinder the ability of countries to harness the oportunities that the multilateral trade system has to offer. Therefore, the conclusions could be further extended as follows:

"22. Give higher priority to establishing and enforcing agreed standards of animal care developed for different livestock production systems and species, especially in intensive systems, without creating a disguised restriction on international trade or unjustifiable discrimination between countries where the same conditions prevail: include financial and technical support for improved animal care in agricultural development funding initiatives."

Concerning Market Performance (point 3.2.2), the reasoning of the argumentation is somehow misled. Though higher prices might have a marginal effect on the demand of food and feed (inelasticity of the demand), they do encourage investment. Given that agriculture is crucial for developing countries, such dynamic should be positive for food security. Moreover, low food and feed prices discourage food and feed investment therefore causing further drop in the future price.

The report does a good job at acknowledging the importance of the multilateral trade system. Still, it fails to address the negative effects that the agricultural protectionism has inflicted on developing countries. Namely market access restrictions, domestic support measures (included the unlimited amounts of green box), export subsidies and arbitrary non-tariff trade barriers. In this respect, the report should make a call for the swift conclusion of the Doha Developing Round in accordance to its mandate. The disclaimer used for signaling that the conclusions of the paper are subject to the result fo the 10th Ministerial Conference is appropiate. Still, a stronger statement against said protectionism is in order.

Question 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.

Answer: With regard to the environmental aspect of the text, we would like to reaffirm that the primary forum for discussions related to climate change is the United Nations Framework Convention on Climate Change (UNFCCC), and that no part of this text should prejudge or duplicate neither possible results of the UNFCCC work or its principles and provisions.

In addition, we suggest the following changes with regard to specific provisions in the text (crossed out text are suggestions for removal, and underlined text are suggestions for insertion):

1. Page 7, line12: much still needs to be done, including in the way our food and agriculture systems perform economically, socially and environmentally, how they can restore and maintain the already stressed natural systems that underpin food production now and into the future

- Rationale: There is no international consensus currently with regard to the restorative capabilities of food and agriculture systems.

2. Page 8, line 51: Climate change is already impacting on the agriculture sector, which will have to continue to adapt as well as to reduce its contribution to greenhouse gas emissions , always taking into consideration the principle of common but differentiated responsibilities, respective capabilities and social and economic conditions of countries, as expressed in the United Nations Framework Convention on Climate Change.

- Rationale: With regard to climate change, there should be an inclusion of the principle of common but differentiated responsibilities, as agreed in the UNFCCC, which is the primary international forum on this issue.

3. Page 15, line 29: Reflecting the evolution of thinking about environmental sustainability, the WDR notes that with rising resource scarcity and mounting negative externalities, agricultural development and environmental protection have become closely intertwined.

Agriculture s large environmental footprint can be reduced, farming systems made less vulnerable to climate change, and agriculture harnessed to deliver more environmental services. The solution is not to slow agricultural development it is to seek more sustainable production systems but realizing on this promise also requires the visible hand of the state providing core public goods, improving the investment climate, regulating natural resource management, and securing desirable social outcomes . There are important implications here, in maintaining equilibrium between different farming systems and between local production and international trade.

- Rationale: This paragraph makes a reference to the environmental footprint , a concept which does not have multilateral consensus, and should therefore not be included. We would suggest that the whole paragraph be removed, or at least the reference to environmental footprint .

4. Page 21, line 17: biodiversity in agro-ecosystems, including the animal component, performs important ecological services beyond food production, and conditioning such as recycling of nutrients, pollination, pest control, regulation of microclimate and local hydrological processes, detoxification of noxious chemicals, control of greenhouse gas emissions, risk reduction under unpredictable environmental conditions and the conservation of surrounding natural ecosystems.

Rationale: We believe that the CFS is not the appropriate forum to address issues related to general ecological services. Thus, we believe this paragraph should be removed.

5. Page 45, line 29: The priority environmental challenges are: reducing the intensity of greenhouse gas emissions production ; reversing land degradation and biodiversity loss; reducing water pollution; and adapting to climate change

- Rationale: We believe that with regard to food production and distribution, the focus should be on the reduction of emissions intensity and on increased efficiency, as opposed to total emissions reductions, as this would negatively affect food security.

6. Page 52, line 11: GHGs from enteric fermentation (the main source of livestock emissions) are trending upwards in developing countries while in developed countries they have decreased (Tubiello, 2013). (This is the result of increase in livestock numbers in developing countries and increase in efficiency of production in developed countries).

- Rationale: We believe this text does not accurately reflect what is expressed in the referenced document (Tubiello, 2013), which states that Averaged over the period 2000 2010, Asia and the Americas were the largest contributors, followed by Africa and Europe. Emissions growth rates were largest in Africa, on average 2:4% yr1. In both Asia and the Americas emissions grew at a slower pace (1 1:2% yr1), while they decreased in Europe (1:7% yr1). Indeed, in the previous decade 1990 2000, Europe s contribution had been larger than Africa s. In other words, the reference to the Americas includes both Latin American countries and the United States, and does not distinguish between emissions by each. In addition, the figures in the referenced document which do distinguish between developed and developing countries refer only to emissions in 2010, and not a particular upward or downward trend. Given this, we believe this text should be removed from the document, as it depicts a situation in which developing countries have a greater responsibility to act to reduce emissions, when this could adversely affect food security, in a context in which the overarching priority of developing countries is to eradicate poverty and hunger.

7. Page 54, line 12: The water footprint of livestock products is much higher than for crop products in terms of calories produced (although when biological value of protein is compared, no plant protein is significantly more efficient at using water than protein produced from eggs, and only soybean is more water-efficient than milk and goat and chicken meat (Mekonnen and Hoekstra, 2012; Shlink et al., 2010). Animal products from industrial, feed-based systems are generally more water intensive and generally consume and pollute more ground- and surface-water resources than animal products from grazing or mixed systems. - Rationale: This paragraph makes a reference to the water footprint , a concept which, like the environmental footprint , does not have multilateral consensus, and should therefore not be included. We would suggest that the whole paragraph be removed.

8. Page 62, line 20: The livestock sector has a large potential to reduce the intensity (ghg/kg of product) of greenhouse gas emissions, although it is much less likely for total emissions given the projected increase in livestock production in the context of population growth and the need to safeguard food security . Mitigation (reduction or

prevention) of the sector s emissions could be achieved by a reduction in production and/or consumption, by an increase in production efficiency, or by shifting the structure of production towards less emission-intensive animal food types. Many technical options to reduce emissions exist, including feed supplements and feed management, grazing land and manure management, health management, improvements in genetics and animal husbandry practices. In more intensive systems, progress could be made by introducing technological innovations to increase efficiencies in production and shift towards monogastric species Promoting production and consumption of less resource- and GHG-intensive livestock types can change the emissions trajectory of the livestock sector. Soil carbon sequestration is also an important option that shows potential for mitigating net emissions from grazing livestock. For instance, restoring degraded soils, better adjusting stocking density and using legumes has a significant potential worldwide for mitigation in the livestock sector

- Rationale: We believe that there are no one-size fits-all solutions which can be applied globally, and that the mention of specific measures necessarily leaves out others which could be more appropriate and effective given specific national circumstances and capabilities, as well as economic, social and environmental priorities. As is pointed out in the same page: in each country there are priorities that reflect the particular farm systems, socio-economic and agri-ecological conditions, history and culture, and public preferences . Given this, we believe that there should be no mention in the text of specific options for measures that might be implemented.

9. Page 63, line 51: The priority environmental challenges are to meet FSN objectives while reducing the intensity of greenhouse gas emissions production , reduce pollution, reverse land and soil degradation and biodiversity loss, and conserve water resources , and enhance the provision of ecosystem services and aesthetic landscapes .

- Rationale: The question of ecosystem services is not multilaterally recognized in the UNFCCC, which is the primary forum on climate change.

In addition, we believe the CFS is not the appropriate forum to address issues such as the preservation of aesthetic landscapes. Furthermore, we believe that with regard to food production and distribution, the focus should be on the reduction of emissions intensity and on increased efficiency, as opposed to total emissions reductions, as this would negatively affect food security.

10. Page 64, line 50: However, when the impacts of farm practices are not taken into account by farmers and livestock keepers, because there is no financial remuneration for the provision of public goods (such as carbon sequestration in soils or habitats for wildlife), or penalties for polluting water courses or harming biodiversity for example, or the social consequences are not factored in to producer decisions, then sustainability is compromised

- Rationale: We believe that this sort of text can be used to justify the implementation of agricultural subsidies, which are contrary to WTO rules. We therefore believe this sentence should be removed.

11. Page 66, line 5: Use best farmer practices for reduced GHG emission intensity, including through reduced

- Comment: The sentence seems to be incomplete

12. Page 66, line 13: Set payments for using and for providing environmental services that are not remunerated through the market

- Rationale: This sort of measure may be used to justify the implementation of agricultural subsidies, which are contrary to WTO Doha Round mandate. We therefore believe this sentence should be removed.

13. Page 84, line 18: devise policies aimed at adaptation to climate change and at mitigation by reduction in emission intensity and promotion of carbon sequestration , subject to the objectives, provisions and principles of the United Nations Framework Convention on Climate Change, including that of common but differentiated responsibilities and respective capabilities.

- Rationale: The question of carbon sequestration does not have multilateral consensus and should, therefore, not be included in the text. In addition, with regard to climate change, and especially concerning mitigation, there should be an inclusion of the principle of common but differentiated responsibilities, as agreed in the UNFCCC, which is the primary international forum on this issue, and given that the obligations in this regard are different for developed and developing countries.

14. Page 84, line 35: Incorporate wherever possible incentives (to reward public goods provision)

- Rationale: This sort of measure may be used to justify the implementation of agricultural subsidies, which are contrary to WTO rules. We therefore believe this sentence should be removed.

Cordiales saludos

Representación Permanente de la

República Argentina ante la FAO, FIDA y PMA Piazza dell'Esquilino, 2 - 00185 Roma Tel. 06 4807 3300 - Fax. 06 48906984 [email protected]

The report is very interesting concerning the meaning of livestock for producers, consumers, industrial and developing countries as well as different farming systems. The many examples are very helpful in that regard.

On the other hand there are many repetitions and some issues are overly relativized - in particular with regard to basic positions, dilemmata and conflicts (e.g. agroecology vs. sustainable intensification or food sovereignty vs. free trade).

There are also "brave"/encouraging text passages - for instance when it is clearly mentioned that most scientists are in favor of GMOs whereas most laypersons are not. Unfortunately, these issues are not reflected in the general discussions. Even worse, no indications (criteria, information needs, research (gaps) etc.) concerning how these basic conflicts could be solved are being presented.

Furthermore, there are also some contradictions when it comes to time pressure (from "very urgent" to "we need more data, research ... to take better decisions"). Are there not some recommendations that could definitively be regarded as adequate ("no regret")? One could structure the recommendations on a scale from "no regret und urgent" to “very sensitive, more info needed, and can wait a bit longer".

Estimados/as Amigos/as

Les escribo como punto focal de la red latinoamericana de pastores y sistemas pastoriles “PASTORAMÉRICAS”, miembro de WAMIP.

Estamos enviando dos documentos con un comentario adicional:

1. Primero queremos explicitar nuestro apoyo a las observaciones y aportes realizados oportunamente por parte del grupo del Mecanismo de la Sociedad Civil (CSM)

2. Adjuntamos un documento más técnico y con aportes específicos cuya versión hemos podido elaborar en inglés.

3. El otro documento (Comentarios generales de Pastoraméricas) va más a aspectos conceptuales y políticos a tener en cuenta y resulto algo extenso para traducirlo en el tiempo disponible.

Quedamos atentos a sus reacciones y les saludo cordialmente

PABLO FRÈRE

COORDINACIÓN PASTORAMÉRICAS

SECRETARIO EJECUTIVO

Please find enclosed the specific comments from the International Poultry Council on the Report on Sustainable Agricultural Development for Food Security and Nutrition. 

Best regards, 

Marilia Rangel Campos 

Secretary General

International Poultry Council

[email protected]

+55 11 99986-7527

Greetings,

We would like to thank the members of the HLPE Project Team and Steering Committee for this opportunity to provide some feedback on the zero draft of the Report. Our comments are in the attached document and represent the opinions of the experts themselves and are not an official position of World Vision. That being said, we hope that they will be helpful for the Project Team and Steering Committee. Please do not hesitate to contact me if you have any questions.

All the best.

Doug

We commend the CFS HLPE in tackling the issue of livestock, food security and sustainable agriculture development. We believe, however, the draft report falsely assumes that increased industrial livestock operations are a necessary component of feeding the world. The reality is that we already produce enough food for close to 10 billion people on the planet today.[1]  While we will need to increase food in some regions, efforts to enhance food security should focus primarily on supporting small-scale farmers and agroecological farming systems and shifting diets in developed countries towards more plants and less meat through nutrition and procurement policies, a trend that we are already seeing today in many Western countries. [2]

While meat consumption will inevitably grow in many developing nations, we must pursue effective strategies and policies to ensure that meat consumption levels per capita in developing countries remain far below the typical western diet, and that there is wider availability of meat raised under healthier and more sustainable conditions. Finally, a stronger focus on waste reduction would also reduce the need to expand meat and grain production for factory-farmed animals.

Specifically, our recommendations emphasize the following points:

1.     Food security and nutrition (FSN) can best be achieved by supporting small and mid-sized farmers and agroecological farming systems, rather than intensive production practices, which require significant chemical and water intensive inputs and generate significant air and water pollution.

2.     Reduced meat consumption offers large GHG mitigation and health advantages.

3.     Developed nations’ consumers are already demanding meat alternatives.

4.     There must be greater emphasis on harmful health impacts associated with industrialized animal production systems, especially irresponsible antibiotic use, growth hormones, and cancer and dioxin risks.

5.     Report should highlight health benefits of pastured/grass-fed meat and organic/agroecologically produced food.

1. SMALL-SCALE AGROECOLOGICAL FARMING SYSTEMS ARE THE SOLUTION

 

Far from feeding the world, today’s industrial food system — backed by agribusiness-friendly trade and agriculture policies — accelerates global poverty and hunger through its exploitation of workers and displacement of farmers. Our dominant food system prioritizes mass-scale livestock and monoculture crop production, processed foods, biofuels and exports — all of which undermine small producers, public health and the growth of local, diversified and resilient farming communities. Ironically, millions of small farmers face some of the highest rates of poverty and hunger.[3]

As the world grapples with how to feed 9 billion people by 2050, overwhelming evidence shows that large-scale industrial food and farming practices are a major part of the problem, not the solution. Our industrial food system — based on monocultures and factory farms, genetically engineered seeds, and chemical pesticides and fertilizers — is rapidly depleting and degrading our soil, land and water.[4] This food system is compromising resources that are essential for our future food security, while contributing to a major obesity epidemic and health care crisis that is costing the world hundreds of billions of dollars a year.

Agroecology provides a powerful solution — highly productive food systems that can amply feed the world while reducing fossil fuel use, saving water, restoring soils and building vitally needed carbon. A growing body of research, including a recent 2014 UC Berkeley meta-analysis, shows that diversified organic agriculture and agroecology systems are highly productive and can deliver yields just below or in some cases on par with industrial agriculture.[5]  Impressive research from the USDA shows that agroecological grain production, using fewer synthetic chemicals, can match or exceed U.S. industrial grain yields — particularly over the long term — while providing equal or higher profits to farmers.[6]

When produced on a smaller, more sustainable scale, animal agriculture can reduce emissions. Pastured and grass-fed livestock require less feed and enable manure to become a fertilizer, rather than a pollutant. As the USDA notes, pastured operations return manure directly to the soil rather than storing it in huge vats, producing fewer methane emissions. Permanent, properly managed grazing grasslands used as pastures, rangelands and hayfields can store great amounts of much-needed carbon, building climate resiliency and reducing GHG emissions.

Comments

“In terms of food availability at the global level, agriculture, including livestock, has recorded impressive progress in production over time, due to a combination of economic development, advances in technology, knowledge and improved management along the supply chain. This increased production has mostly occurred through specialization, intensification, industrialization and economies of scale that depend increasingly on inputs often grown outside the farm, including animal feed from the crop sector and non-renewable sources of energy.” (pg 9)

See comments above.

“The needed increase in agricultural production (including livestock) offers a huge opportunity to lift smallholders out of poverty.” (pg 13)

Lifting smallholders out of poverty requires systemic changes, including support for the millions of small-scale farmers worldwide who produce 70 percent of our food on 25 percent of farmland.[7] Rather than increasing agricultural production, poverty reduction can be alleviated through technical assistance for small-scale farmers, protection against land grabs, and building climate resiliency through diversified, agroecological farming. Research published in the Journal of Peasant Studies shows that diversified Cuban farms exhibited crop losses fifty percent lower than neighboring monoculture farms during negative climate conditions, while showing a faster productive recovery. [8]

“Second, by facilitating the correction of nutrient deficiencies and addressing undernutrition. For this increase in access to animal-sourced foods, livestock numbers need to increase, but so too will the productivity of these animals, the latter being particularly important if natural resources (particularly water) are to be used wisely, and environmental pressures and greenhouse gas emissions are to be mitigated.” (pg 26)

While animal food products in small quantities may be necessary in developing nations for FSN, these needs can be satisfied through integrated livestock-crop farming systems. This section fails to account for the negative externalities of the large-scale industrial livestock sector (i.e. water pollution, grain dependence, corporate consolidation) as well as its tendency to lead to overproduction of livestock. A new UN Food and Agriculture Report, puts the cost of the environmental damage from agro-industrial production at $3.36 trillion annually, including $1.1 trillion in costs from livestock production.[9] The same report finds that organic and agroecological alternatives, such as holistic grazing, greatly diminish these costs and can provide a path forward that more effectively sustains both humans and the planet.

“The WDR makes the case for liberalization of agricultural markets – domestically and globally – as an important means of revitalizing the sector in support of development and FSN. It notes, for example, that access to world priced imports of food staples can be pro-poor, including for smallholder agricultural producers who are net buyers of food. Similarly, removal of export restrictions on food, often intended to dampen prices in local markets, can hamper access of poor farmers to valuable export market opportunities and noting two-thirds of agricultural value added is in developing countries.” (pg 14)

Liberalizing trade regimes such as the WTO, NAFTA, and CAFTA only prioritize industrial production of export commodities while eroding public investments in small-scale diversified farming for local and regional consumption.[10] These regimes promote input-intensive agriculture, pushing millions of farmers deep into debt, causing mass farm closures, poverty and migration.[11]

“The world is only able to support its present population because of the “green revolution”, which was driven by innovations in plant breeding, including mutation breeding, fertilizer and pest control.” (pg 48)

Others have noted that the “green revolution” actually led to environmental damage, reductions in biodiversity, loss of traditional knowledge, deep debt for poor smallholders and increased farm consolidation for the wealthier farmers.[12] Furthermore, this analysis of the green revolution fails to account for an alternative scenario, in which more research and development could have been invested in agroecological solutions. Any modest yield gaps that do exist from industrial agriculture result primarily from a huge gap in public-funded research. In the US, less than 2% of agricultural research spending focuses on improving and expanding organic farming.[13]

“At the same time, opponents are concerned about currently unknown harmful effects, the escape of genetically modified organisms into the environment and the transfer of allergens into new foods (Buiatti et al., 2013).” (pg 48)

Agribusiness has pushed biotech crops in developing nations as a solution for hunger and drought – but it has failed in many cases, a Cornell University study found.[14] Analysis by the Australian government found that “crops genetically engineered for drought tolerance have not been found to outperform traditional varieties.”[15] Most GMO crops, including corn, soy and cotton, are grown primarily for animal feed, biofuels, fiber or ingredients for processed foods — and thus fail to address the root causes of hunger or deliver healthful benefits to consumers.

“In a world of increasing competition for the scarce natural resources on which agricultural production depends, meeting future demands for FSN requires improving the efficiency of current use of inputs rather than expanding land and water inputs.” (pg 48)

See comments above.

“For example, industrial, intensive livestock operations tend to be efficient in production, but sometimes at the expense of water pollution and the welfare of animals, and depend on feedstuffs from the crop sector, with knock-on environmental effects. Extensive livestock operations tend to depend on pasture and conserve land at risk from erosion vulnerability, but sometimes at the expense of productive efficiency.” (pg 65)

As noted in our comments above, production efficiency is only one of many factors to be considered when looking at FSN. For example, pasture-raised livestock not only conserve land, but also offers increased carbon sequestration benefits,[16] not to mention improved farmer livelihoods and decreased water pollution. To quote a Nature published paper, “When appropriately stocked and managed, grassland–ruminant ecosystems are an efficient, sustainable method of producing high-quality protein with minimal environmental impacts.”[17]

2. REDUCED MEAT CONSUMPTION OFFERS LARGE GHG MITIGATION ADVANTAGES

The Potsdam Institute for Climate Impact Research and the UN Intergovernmental Panel on Climate Change (IPCC)’s recent 2014 report on agriculture and climate change mitigation notes that reducing meat consumption would decrease non-CO2 greenhouse gas emissions more than technological mitigation options; combining both approaches would deliver even greater GHG reductions.[18] According to Dr. Rajendra Pachauri, the past IPCC chair, “In terms of immediacy of action and the feasibility of bringing about reductions in a short period of time, it clearly is the most attractive opportunity. Give up meat for one day [a week] initially, and decrease it from there.”[19]

Comments

“The economic yield gap is accompanied by a similar environmental efficiency gap: numerous studies have shown that ASF from animals reared in more intensive and specialized systems have a relatively lower carbon footprint than those from extensive systems” (pg 48)

While many studies do find that intensive livestock systems have lower GHGs for enteric fermentation, feed production, and manure management, those same studies do not consider the carbon sequestration benefits of pasture based systems. Several studies have found that when those sequestration benefits are accounted for, pasture based systems can in fact lower overall GHG emissions.[20],[21],[22],[23] In any case, rather than focusing on a singular issue, such as GHGs, it is important to consider the overall environmental harm of intensive systems, and the potential environmental and economic benefits of agroecological alternatives. Meat and dairy raised in sustainable, organic, humane and well-managed pasture-based systems can reduce greenhouse gas emissions, increase climate resiliency, protect natural resources and enhance soil and water quality[24],[25],[26] biodiversity, and pollinator health.[27] These practices also improve public health and provide safer conditions for workers. Furthermore, as grass-fed pastures are often not suitable to intensive crop production, these systems can use marginal land to actually increase food security. All these factors should be taken into account.

3.3.1 GHG emissions from the livestock sector (pg 52)

This section is missing the large GHG benefits from encouraging reduced livestock consumption.

“Mitigation (reduction or prevention) of the sector’s emissions could be achieved by a reduction in production and/or consumption, by an increase in production efficiency, or by shifting the structure of production towards less emission-intensive animal food types.” (pg 62)

This section could further stress the effects of consumption change on mitigation (see footnotes 18 and 19 in the section above).

3. DEVELOPED NATIONS’ CONSUMERS ARE DEMANDING MEAT ALTERNATIVES

The report’s focus on increasing livestock production fails to note that developed nations — who currently over-consume meat and animal products — are beginning to shift towards more nutritionally and environmentally sound plant-based diets. Research suggests that 36 percent of U.S. consumers prefer milk and meat alternatives and that between 26 and 41 percent of Americans have eaten less meat over the past year.[28] In fact, many food service providers are aware of these trends and ready to provide such options. One Datassential study found that, “reducing the portion size of animal protein on menus is expected by nearly half of operators to increase the healthfulness of the entrees, and by over a third to increase the culinary innovation involved with the dishes.”[29] The same survey found that meals with animal protein as a garnish, rather than as a central portion, appeal to half of consumers; and more than seventy percent of consumers were concerned about transparency in food sourcing.

Comments:

Projections (pg. 13)

Implicit in these projections are that total global meat/animal product consumption will increase significantly — a scenario that does not have to happen.

“As diets become richer and more diverse, the livestock sector offers improvements to the nutrition of the vast majority of the world. Livestock products not only provide high-value protein but also are important sources of a wide range of essential micronutrients, in particular minerals such as iron and zinc, and vitamins such as vitamin A. By providing essential nutrients, especially in the critical first 1 000 days from conception, animal-sourced foods can help ensure normal physical and cognitive development. Well-nourished and well-educated children can grow up to be healthy young adults who are able to realize their full potential and contribute to family income-earning and national development. On the other hand, diets rich in livestock products, in particular red meats, are implicated in rising health concerns in some countries, although the scientific evidence and nutritional guidance has often changed through time and can be confusing to consumers.” (pg 28)

This paragraph should open with the acknowledgement that, in developed countries, industrially produced livestock food products are often implicated in some of the most pressing chronic health problems. High consumption of industrially produced meat, especially red and processed meat, is associated with increased risks of diet-related disease, including heart disease,[30] diabetes[31] and cancer.[32] U.S. government guidance on need to consume less meat is clear. The 2010 USDA/HHS guidelines recommend no more than 1.8 ounce servings a day of red meat).[33] It should also be emphasized that a plant-based diet is a nutritionally appropriate alternative that is beneficial to the health of people and the environment. The USDA,[34] Academy of Nutrition and Dietetics,[35] and other top health organizations agree that a well-planned vegetarian or vegan diet can provide all necessary nutrients and protein required for a healthy diet. And importantly plant-based diets are associated with decreased risks of all heart disease, diabetes and some cancers.[36]

Claims that red meat and processed meats are “nutrient dense” are misleading because they ignore all the harmful components of industrially produced meat:

4a. ANTIBIOTICS

The industrial system of food animal production is putting human health at risk due to misuse of vital antibiotics. Seventy to eighty percent of antibiotics sold[37] in the United States go toward livestock production. These drugs are often used to accelerate animal growth and prevent diseases stemming from poor diets and crowded, unsanitary conditions, rather than for treatment of sick animals.[38] In its 2013 report Antibiotic Resistance Threats in the United States, the CDC states: “Up to half of antibiotic use in humans and much of antibiotic use in animals is unnecessary and inappropriate and makes everyone less safe.”[39]

Comments:

“Livestock production and products also carry important health risks, especially in terms of food-borne disease, emerging diseases and occupational hazards. There are also social concerns such as human health, animal care and industrialization associated with livestock, with attendant social and economic costs.” (pg 8)

Antibiotic resistance should be included as a health risk.

“Risks in an interconnected world” (pg 50)

Antibiotic resistance should be included as a health risk.

4b. GROWTH HORMONES

Industrial meat production, specifically in the United States, relies heavily on the use of growth hormones and growth promoters in beef, pork and turkey production to fatten animals as quickly as possible with the least amount of feed. While this can be economically advantageous for meat companies and producers, it also may pose serious risks to humans, animals and the environment.[40] Numerous studies have found potential links between zeranol (a growth hormone) intake and heightened risk for breast cancer.[41]

4c. CANCER RISKS

There is strong evidence that diets high in red meat (beef, pork, lamb) and processed meat (hot dogs, bacon, sausage, deli meats, etc.) increase the risk for colorectal cancer.[42] Many epidemiologic studies have reported a modest but significant association between high intakes of processed meats and red meats and increases in cancer incidence and mortality in a dose-response relationship, as well as death from other causes.[43],[44] Both the American Institute for Cancer Research (AICR)’s Recommendations for Cancer Prevention and the American Cancer Society’s guidelines mention the importance of nutrition, including reduced red and processed meat, and physical activity for cancer prevention.[45]

In contrast, plant-based diets are associated with decreased risks of all heart disease, diabetes and some cancers.[46] 

4d. DIOXIN RISKS

According to the Environmental Protection Agency, 95 percent of our exposure to cancer-causing dioxin like compounds (DLC) come from meat, dairy, fish and shellfish.[47] The Food and Drug Administration, Environmental Protection Agency, World Health Organization and National Academy of Sciences all agree that the best way to lower personal dioxin levels is to reduce dietary exposure to dioxins by lowering animal fat intake and increasing consumption of fruits, vegetables, and whole grains.[48]

5. HEALTH BENEFITS OF GRASS-FED/PASTURED MEAT

When consumed in moderation, responsibly raised meat and animal products can bring health benefits. Grass-fed and pastured meat and dairy provide a dense source for many of the shortfall nutrients identified in the DGAC’s report recommendations, including calcium, iron, and A, E, and B vitamins. Grass-fed meat is leaner than that produced in the grain-fed commodity system and, in the case of both meat and dairy, the fat profile is healthier than that of its grain fed counterparts. A 2010 review of three decades of research found that grass-fed beef provides higher levels of nutrients, including Omega-3 fats, beta-carotene, conjugated linoleic acid and Vitamin E than grain-fed beef.[49] A 2013 study published in PLoS ONE found that grass-fed organic dairy has far higher levels of Omega-3 fats than grain-fed dairy.[50]   The Dietary Guidelines Advisory Committee has examined the sustainability of different production practices for fish and seafood and fruits and vegetables, but ignores the substantial differences in meat production practices and makes the blanket recommendation to consume less red meat and dairy. This does a disservice to consumers and producers alike.

REFERENCES

Dear Members of the High Level Panel of Experts,

We appreciate the opportunity to contribute to this excellent work.

Our comments are in attachment: Comments - MAP - FAO Report.

Best regards,

Jonathas de Alencar Moreira

Agronomist, M. Sc.

Federal Agricultural Inspector

Ministry of Agriculture, Livestock and Food Supply of Brazil

Dear HLPE Project Team and Steering Committee

Attached are comments on the zero draft from the UK Food Group, which we hope will be useful. We look forward to continuing to engage as the report progresses.

We also note our support for the comments separately provided by the Civil Society Mechanism, of which we are part.

Regards

Jean Blaylock