This effort to bring together data streams and to address challenges and gaps in data collection and analysis across the food system is extremely valuable and timely. We like the conceptual food and nutrition system framework presented in section 1 and applaud the effort to combine previous frameworks (food systems, nutrition, food security, etc.) and to capture and simplify the systemic complexity. However, we note three key gaps in this proposed framework, which are also reflected in the subsequent sections on data collection and analysis:

1. The impacts of global food systems on the environment are not sufficiently represented or discussed. Given the clear need, articulated so well here in this report, to tackle the multiple linked challenges that relate to our current food system structure and functioning, it’s critical that we begin to conceptualize and target the multi-directional nature of systemic drivers and outcomes. See, for example, the recent report on how inland activities, including agriculture, are damaging rivers and freshwater fisheries, which are important food sources in their own right. Specifically, there is almost no discussion in this report of the impact of the global food system on the climate, or on biodiversity or ecosystem health at any scale. These outcome metrics should be given equal weight and attention as metrics of hunger, malnutrition, and food insecurity.

In addition to global-scale trends, data on environmental impacts of specific policies and management decisions are needed in order to avoid the risk of investing in food system interventions that appear to be improvements to the current techniques, but that actually worsen problems. For example, there has been a strong push to integrate fish into rice paddies in rice-growing regions around the world, and specifically throughout Asia. However, there is evidence that doing so can actually increase the methane off-gassing from rice paddies, thereby increasing the already significant climate change impact of this crop.



We recommend reviewing and including the following key references:

Benton, T. G., Bieg, C., Harwatt, H., Pudasaini, R., & Wellesley, L. (2021). Food system impacts on biodiversity loss: Three levers for food system transformation in support of nature (p. 75). Chatham House. https://www.unep.org/resources/publication/food-system-impacts-biodiversity-loss

Tubiello, F. N., Rosenzweig, C., Conchedda, G., Karl, K., Gütschow, J., Xueyao, P., Obli-Laryea, G., Wanner, N., Qiu, S. Y., Barros, J. D., Flammini, A., Mencos-Contreras, E., Souza, L., Quadrelli, R., Heiðarsdóttir, H. H., Benoit, P., Hayek, M., & Sandalow, D. (2021). Greenhouse gas emissions from food systems: Building the evidence base. Environmental Research Letters, 16(6), 065007. https://doi.org/10.1088/1748-9326/ac018e

References re: emissions from rice-fish systems:

Frei, M., Razzak, M. A., Hossain, M. M., Oehme, M., Dewan, S., & Becker, K. (2007). Methane emissions and related physicochemical soil and water parameters in rice–fish systems in Bangladesh. Agriculture, Ecosystems & Environment, 120(2), 391–398. https://doi.org/10.1016/j.agee.2006.10.013

Sun, G., Sun, M., Du, L., Zhang, Z., Wang, Z., Zhang, G., Nie, S., Xu, H., & Wang, H. (2021). Ecological rice-cropping systems mitigate global warming – A meta-analysis. Science of The Total Environment, 789, 147900. https://doi.org/10.1016/j.scitotenv.2021.147900

2. Although blue/ aquatic foods are mentioned in this report, their treatment feels cursory and is insufficient. Despite their importance for meeting food and nutrition goals in the face of climate change, aquatic food production and consumption are not represented or included in the high-level framework, or in the discussion  around it (e.g., there are repeated references to agriculture in the Introduction section, but none to fisheries), and while there are a handful of references to aquatic foods or to fisheries in the subsequent report sections, the report misses an important discussion of the diversity of aquatic resources which have differential nutritional values, a focus on small-scale fisheries and inland fisheries, which both have a unique and important role in this challenge, and any mention of the problem of IUU fishing, which is a serious challenge to the sustainability of the world’s fisheries, and also a serious challenge to accurate data collection and analysis. Significant new data sources on the nutritional content of aquatic foods and their diversity which have recently been published in the peer reviewed literature emphasize the potential for aquatic foods to fill nutritional and food security gaps via local production, and highlight the need to continue gathering and analyzing new data as it emerges 

In more detail, we recommend:

Expanding the focus of the report to better capture needs in the realm of aquatic resource monitoring and management. A key barrier to good food system planning and coherent management of wild caught fish is lack of good stock status data, which is driven by the difficulty of (a) assessing a fishery stock at any point in time, and (b) predicting it into the future, given the unknowns of climate change impacts that are without precedent.

A specific recommendation related to this gap is to expand access to data collected through the Nansen surveys (which are referenced in your report) through open access agreements. The report calls for more open access data streams, and we applaud this movement. We note that the Nansen survey data have been particularly difficult to access, even for countries who have participated in them directly. Addressing this challenge would be extremely valuable to efforts to more sustainably manage aquatic resources.

Broadening data collection efforts to capture the diversity and differential nutritional potential of different aquatic foods in order to enable informed decision-making. For example, we might prioritize a given depleted species for recovery based on its nutritional value relative to national nutritional goals, rather than on its economic value on the export market.

Disaggregating the data on aquatic foods based on fishery type, sector, scale, and gender. Small-scale and inland fisheries provide the majority of aquatic foods that are eaten directly/ locally, and the fish they catch tend to be lower-trophic level species which tend to be more nutrient dense (and are also often eaten whole, which drastically increases the nutrient intake). In addition, small-scale fishing communities, especially those throughout the equatorial tropics, tend to be among the most food and nutrition insecure, and the most vulnerable to climate change.

Similarly, disaggregating the data based on gender would be an important improvement. Women tend to make up a significant, and sometimes majority, percentage of the fishery workforce, and they also tend to make many of the food decisions for a given household, but they generally lack ownership or fishery management decision-making authority. Increasing the amount and quality of gender disaggregated production data is critical to improving gender equity across this sector as well as food systems more generally.

​​​​​​​Examining the problem that IUU fishing, which is often occurring at unknown and unregulated levels, presents to accurate and useful data collection, and which may be seriously distorting what we think we know about stock biomass and sustainable fishing levels.

To address these gaps, we recommend adding the following emergent and innovative data streams to your report:

​​​​​​​FishNutrients component of Fishbase, which captures or estimates the specific nutritional content of a vast array of aquatic species caught around the world: https://www.fishbase.in/Nutrients/NutrientSearch.php

Illuminating Hidden Harvests, which seeks to quantify and standardize the immense contribution of small-scale fisheries to global fishery yields and livelihoods: https://sites.nicholas.duke.edu/xavierbasurto/our-work/projects/hidden-harvest-2/ (forthcoming)

The Global Fishing Watch platform, being designed to enable the use of multiple open-source technologies and data sources to evaluate and manage fisheries: https://globalfishingwatch.org/news-views/mapping-a-new-world/

As countries operationalize their programs to comply with the Port State Measures Agreement, they are also developing systems for documentation and tracking of seafood which will create new and better sources of data that can contribute to the knowledge base for the HLPE. Since PSMA systems are in early stages of development now, those planning to use data for decisions could seize the moment while data being collected for oversight and compliance assurance are being designed to see that the systems are designed to be useful for both insofar as possible.

As well as the following references:

​​​​​​​Bennett, A., Basurto, X., Virdin, J., Lin, X., Betances, S. J., Smith, M. D., Allison, E. H., Best, B. A., Brownell, K. D., Campbell, L. M., Golden, C. D., Havice, E., Hicks, C. C., Jacques, P. J., Kleisner, K., Lindquist, N., Lobo, R., Murray, G. D., Nowlin, M., … Zoubek, S. (2021). Recognize fish as food in policy discourse and development funding. Ambio. https://doi.org/10.1007/s13280-020-01451-4

Fluet-Chouinard, E., Funge-Smith, S., & McIntyre, P. B. (2018). Global hidden harvest of freshwater fish revealed by household surveys. Proceedings of the National Academy of Sciences, 115(29), 7623–7628. https://doi.org/10.1073/pnas.1721097115

Gephart, J. A., Henriksson, P. J. G., Parker, R. W. R., Shepon, A., Gorospe, K. D., Bergman, K., Eshel, G., Golden, C. D., Halpern, B. S., Hornborg, S., Jonell, M., Metian, M., Mifflin, K., Newton, R., Tyedmers, P., Zhang, W., Ziegler, F., & Troell, M. (2021). Environmental performance of blue foods. Nature, 597(7876), 360–365. https://doi.org/10.1038/s41586-021-03889-2

Golden, C. D., Koehn, J. Z., Shepon, A., Passarelli, S., Free, C. M., Viana, D. F., Matthey, H., Eurich, J. G., Gephart, J. A., Fluet-Chouinard, E., Nyboer, E. A., Lynch, A. J., Kjellevold, M., Bromage, S., Charlebois, P., Barange, M., Vannuccini, S., Cao, L., Kleisner, K. M., … Thilsted, S. H. (2021). Aquatic foods to nourish nations. Nature, 598(7880), 315–320. https://doi.org/10.1038/s41586-021-03917-1

Harper, S., Adshade, M., Lam, V. W. Y., Pauly, D., & Sumaila, U. R. (2020). Valuing invisible catches: Estimating the global contribution by women to small-scale marine capture fisheries production. PloS One, 15(3), e0228912. https://doi.org/10.1371/journal.pone.0228912

Hicks, C. C., Cohen, P. J., Graham, N. A. J., Nash, K. L., Allison, E. H., D’Lima, C., Mills, D. J., Roscher, M., Thilsted, S. H., Thorne-Lyman, A. L., & MacNeil, M. A. (2019). Harnessing global fisheries to tackle micronutrient deficiencies. Nature, 574(7776), 95–98. https://doi.org/10.1038/s41586-019-1592-6

Maire, E., Graham, N. A. J., MacNeil, M. A., Lam, V. W. Y., Robinson, J. P. W., Cheung, W. W. L., & Hicks, C. C. (2021). Micronutrient supply from global marine fisheries under climate change and overfishing. Current Biology, 31(18), 4132-4138.e3. https://doi.org/10.1016/j.cub.2021.06.067

Vianna, G. M. S., Zeller, D., & Pauly, D. (2020). Fisheries and Policy Implications for Human Nutrition. Current Environmental Health Reports. https://doi.org/10.1007/s40572-020-00286-1  

3. The report and framework are missing the “group” and “farm/ fishery” scales/ levels of analysis. In both the introductory framework and the subsequent report there are discussions of data collection challenges and gaps at macro, systemic, global, national, community/household, and individual scales, but the specific challenges and data needs associated with the “group” and “farm/fishery” scales of analysis are overlooked. Many of the issues discussed in this report around barriers to data collection and use at the national and global level are even more pronounced at the “group” and “farm/fishery” levels.



And in addition:

The “group” level may be larger or smaller than “community,” as “group membership” can be defined by, for example, culture, race, gender, Indigenous status, income, or scale of production (for producers), among other factors. However, despite its imprecision, a focus on the “group” level is critical when approaching food system challenges, as group membership has relevance for both food system drivers (e.g., social norms and cultures around food that drive demand) and for how the current food system will be experienced across the 6 FSN dimensions (agency, stability, sustainability, access, availability and utilization). Explicit inclusion and examination of the food system at the scale of the “group” will help ensure inequities are identified and addressed. 

The “farm/ fishery” level is especially critical to explicitly discuss in relation to data collection. We strongly suggest the incorporation of a section in this report dedicated to the need for measurement, metrics, and indicators of the climate forcing, biodiversity, and other environmental impacts of various methods of food production at the farm/fishery level. Such data are desperately needed, especially throughout the small-scale farms and fisheries of the world, to enable more accurate and appropriate valuation of different food resources, and to facilitate the creation of policies and management plans that incentivize more sustainable and regenerative practices. If we seek to make progress on the challenges of food system transformation in an equitable way, we must be able to account for farm-level differences in performance along a variety of metrics. Without this precision, policies and market incentives will favor larger-scale, industrialized operations that can afford to adopt expensive new technologies, and smaller-scale farmers and fishers will be left behind.