CFS GSF Draft

Page: 3 number: 1 section Background, ii) "The GSF will be aligned where appropriate with the Five Rome Principles for Sustainable Global Food Security"

[Comment] In what way will this aligning take place? What does "where appropriate" mean here? number: 2 section Background, ii) "voices of all relevant stakeholders – particularly those most affected by hunger, food insecurity and malnutrition"

[Comment] We would certainly want this relevance with the privations experienced by many such populations. But it is at the start of such documents that operating reality ought to be built in. Those most affected by hunger, food insecurity and malnutrition are hardly heard even by their own local administrations - they are repeat sufferers because of this persistent invisibility. The CFS must say so clearly - and by saying so allocate the responsibility of hearing their voices to those who can reliably and faithfully carry them into such instruments. number: 3 section Background, ii) "taking into account the most relevant emerging issues affecting food security and nutrition, and drawing on the advice and expertise of the High Level Panel of Experts (HLPE)"

[Comment] Good counsel can and should come from a variety of sources, and many of these sources will not be within a national institute set-up. The "living" document (never mind "high profile") desired will come to life only with as broad-based a pool of contributors as possible. number: 4 section Background, ii) " Neither approval nor endorsement will be legally binding"

[Comment] Under the operating procedures for inter-governmental bodies, CFS programmes may not from the outset of their existence be legally binding upon UN/FAO member states, but why rule out this obligation? Rather, the objective ought to be to ensure that there will, sooner and not later, be sovereign guarantees required to ensure what the CFS envisages to tackle hunger, food insecurity and chronic malnutrition. Why should it be otherwise? When the WTO is binding and rigidly enforced and its influence on national policy is deep and extensive, there is no justification for not moving towards a monitored system of international obligations to ensure food security. This the CFS must enunciate clearly and unambiguously. The international landscape of food and agriculture discussion is littered with the hulks of well-intentioned frameworks that are ignored by UN member states. Let us not consign the CFS-GSF to a similar fate.

Page: 4 number: 1

1 Section 1, 1. "eradicate hunger and malnutrition sustainably"

[Comment] The Framework will benefit from a set of definitions which explains succinctly but authoritatively what is meant by key terms. In this case 'sustainable'. number: 2 Section 1, 1. "interim objectives as laid out in the Millennium Development Goals"

[Comment] Is this forging links whose overlap may hinder the provisioning of nutrition and encouragement of food security? I say this because line departments and programme officers in charge of regional social sector schemes have a heavy work budget already, multiple superiors to report to, and far too little to work with at the best of times. It is best not to burden them – or agents like them - with multiple objectives in the pursuit of food security. number: 3 Section 1, 1. "add value to the development process" "securing buy-in across"

[Comment] A terminology matter - 'add value' in the context of human and community development just doesn't fit in. Neither does 'buy-in'. number: 4 Section 1, 3. "consolidate macro-level warnings and recommendations about present and upcoming challenges"

[Comment] This work will be most useful. It needs to be accompanied by an undertaking from FAO member-states that the bulletins that arise from such a system will find their way, as priority input, to policy and action responses on agriculture and food. What the CFS will not want is for quality input to be ignored by countries and administrative regions, especially when they lack similar mechanisms of their own. FAO's own real-time offerings, such as GIEWS and the price monitoring tool, are not used to anywhere near the degree they ought to be by national governments and regional administrations. For any GSF objective to be fulfilled in the letter and spirit of the CFS frameworks, a minimum reciprocity should be obtained. number: 5 Section 1, 3. "Promote convergence and international credibility for specific kinds of strategies"

[Comment] This is unclear. Sub-regional administrations and departments connected with the delivery of food-based or agri-linked social welfare schemes will pay no attention to this - and this is the level at which work is actually done. number: 6 Section 1, 3. "Encourage the adoption of national strategies combining short and long-term objectives"

2 [Comment] National or regional needs to be defined by a population or a total household measure. In large countries, or in countries economically dominated by one or two densely populated regions, a 'national' strategy will reach at best an arithmetic majority some of the time. The CFS-GSF will need to spend more time on ascertaining levels of granularity at which strategies can be formed.

Page: 5 number: 1 Section II, 4. "Systematic analysis of the structural causes of food insecurity ... " to " ... chronic undernutrition, as measured by stunting."

[Comment] All these issues, each individually weighty, deserve reiteration here. However, what is needed in this GSF is enough recognition of the enormous body of study and analytical work that precedes this document and the CFS. Left as it is, this introductory statement to Section II of this document rings hollow. How to present substantiation when the universe of study is so vast and varied? One way may be to return to the CFS electronic outreach community and canvass references (balance needed for geographical and language distribution) so that the GSF analytical substrate is rich as a reference source. number: 2 Section II, 5. "In the longer term, a major challenge will be to meet increased global demand for sufficient and appropriately nutritious food, resulting from population and income growth and changes in diets, in the face of decreasing availability and quality of natural resources."

[Comment] This is somewhat problematic. In South and South-east Asia for example (one can include also East Asia for the meats component) the growth in income has led to reduced per capita cereals and coarse cereals consumption, a reduced basket of vegetables, more milk and dairy and more meat and fish. What is missing here is the essence of sustainability – bioresource determined sustainability as well as total cost sustainability (processed food particularly) - connected to food supply. South Asia's top three income deciles for example consume up to 50-55% more cereals than the bottom three, and the top three urban deciles consume 100- 150% more meat and dairy than the mid-three rural deciles. Which set of consumption patterns can be encouraged as sustainable for the majority of national or sub-regional populations? These are not template answers the CFS-GSF can provide, but it must raise these matters unequivocally. number: 3 Section II, 5. "The current decline in yield growth rates will have to be reversed."

[Comment] There are biophysical limits to yield growth which must be recognised. Without entering into the science and practice of assuming an indefinitely rising yield curve for crop staples, it would better behoove the GSF to instead advise equity in distribution, access and price. The yield subject moves the discussion needlessly close to the genetically modified/genetically engineered disagreement (my own view is against GM/GE and its concealed infrastructural support provided

3 by government). Reversal is needed, but a more community-centric approach will examine the gains to be had by reversal of the food retail hold on supply and distribution. This is a difficult topic and needs to be thought through carefully and then re-presented. number: 4 Section II, 5. "The role of agricultural research institutions in developing local and global solutions will be critical."

[Comment] Another statement that in fact deserves a 'portal' of its own in the CFS- GSF structure. If there is to be a non-negotiable research alignment for the national agricultural research systems, then it must be that they complement the efforts (current and legacy) of common farm innovation and selection which has supplied cultivating communities for so long. be careful when using 'global' for its trade and agribiotech connotations.

4 number: 5 Section II, 6. Full para

[Comment] These 10 points are very useful as they are, and will serve as touchstones for a number of the problem areas discussed in this document. I strongly recommend the addition of one more point, that of the GDP-dominated economic growth pathways that most UN/FAO member states currently follow and which has a continuing and pervasive impact on social sector and food + agri policy. Not including this aspect will ethically unground many of the objectives contained in this document. The GSF's future as a charter for analysis and action - one in which it can be used at national or at the most local level - will be greatly strengthened by this inclusion. number: 6 Section III, 7. "At the present time, price volatility ... " to " ... policy responses to supply or demand shocks also contribute to price volatility"

[Comment] A quick look at FAO's food price index and food commodity price index since 2011 January will confirm that it is the steady rise in the prices of food staples which is most burdensome. Volatility is no doubt a characteristic of the cost + price dynamic in countries of the South, most visibly, but the GSF must not disconnect volatility from the steady upward inflation of food costs for rural and urban households.

Page: 6 number: 1 [Comment] These two notes from the previous page - last para number: 2 Section III, 7. "given the large share of their income that poor households spend on food"

[Comment] share of income on food - the available evidence from South Asia (I use the findings of India's National sample Survey as a reliable proxy for rural and urban poor in Pakistan, Bangladesh, Nepal and Sri Lanka too) is that for the lower 3-4 income deciles, the share of monthly expenditure on food is 65%-70% in 2010. (We have to bear in mind that food staples inflation has risen since then.) This is a staggering, crippling burden on these households and immediately and dramatically affects health and education outcomes. The GSF will do well to make these connections as clear as possible.

5 number: 3 Section III, 7. "However, high food prices and experiences of poor performance of international food markets have also increased incentives for agricultural investment, including cross-border capital movements. Such investments are not always beneficial to recipient countries and poor populations, nor have they always considered nutritional outcomes"

[Comment] If we discuss cross-border movement of capital into the food industry (organised aggregation, processing, logistics, retail) we must also include the growing development, within countries, of the food and food services industries. These may or may not attract trans-national capital, but either way exert a major influence on crop selection and a localised imbalances in food staples (cereals, pulses). Again there is a link with the GDP-dominated model of economic growth, as the food industry is a front-running sector and its increasing contribution to national GDP encourages a widening raft of incentives given to it, often at the cost of smallholder agriculture. number: 4 Section III, 8. "Many food production systems are at the same time lagging behind in achieving productivity and production potential while contributing to the degradation of natural resources on which agriculture depends"

[Comment] The GSF has to be careful in its treatment of this subject. 'Productivity' and 'production potential' are entry points for a high-input, heavily industrialised market-driven cultivation system which is utterly at odds with the rural livelihood patterns that smallholder farming households need to see reinforced, rather than dismantled. 'Degradation' in turn comes from the widespread adoption of this model. This perspective is surprising to see here for, especially in the last four years since the IPCC's 4th Assessment (2007), UN and inter-governmental groupings associated with earth sciences study have time and again warned of the negative resource balances arising from the pursuit of 'productivity' as a primary objective. We have ample evidence for instance of the catastrophic groundwater depletion in northern India and adjacent north-eastern Pakistan, and more recently the advancing desertification in the intensively farmed regions of eastern and central China. The 'unsustainable increases in production and yields' (next sentence) is what this point must rest upon, not the insistence on 'productivity' gaps.

6 number: 5 Section III, 8. "needs through sustainable systems along the value chain"

[Comment] 'value chain' poses problems. Whose 'value' will be furthered or protected? This needs to be clearly spelt out number: 6 Section III, 8. Challenges faced by women. Full para

[Comment] This point cannot be over-emphasised enough. What is called in the South, and which is visible as, the feminisation of agriculture has as much to do with underlining the smallholder nature of the cultivation of food staples as it has to do with the dominant model of economic (GDP-driven) growth and axiomatic urbanisation referred to in an earlier note. Rural districts therefore have lost and continue to lose male labour to towns and cities - which affects the seasonal availability of agricultural labour and again imposes a multiple heavy burden on women for their child-rearing roles, which directly impacts nutrition, health and educational outcomes. number: 7 Section III, 8. Role of smallholder producers. Full para

[Comment] Effective links to markets, improved production systems - while important, the GSF will in the interests of fostering development equity need to guide the discussion along 'what kind of markets', 'what cost for improved productivity'. At this time (2011 August) the price of oil in international markets is USD100 a barrel +-5%. Whether this experiences a linear rise over the next 20 years or whether renewables form a greater part of the energy mix, the input cost of a kilowatt devoted to cultivation will rise. Markets must be seen as being determined by the cost of reaching them (including the off-balance sheet energy subventions given to the food industry). If more 'capital intensive' is the answer to finding a route through higher energy costs through the much-abused 'economies of scale' argument, then the GSF must tackle this question too. After all FAO's new 'Save and Grow' campaign helps encapsulate the practical methods and benefits of the smallholder approach. number: 8 Section III, 8. "Promoting viable systems of tenure that promote poverty reduction and food security and nutrition is an important issue, especially in view of increasing competition for and declining availability of agricultural resources"

[Comment] This is extremely important and deserves more detailed treatment. 'Competition for land' is an intensely political subject, and is far more visible as 'land grab' within national boundaries than is the trans-continental land grab that is often reported nowadays. It is baseline requirements of land that satisfied sustainable agro-ecological systems which must be a commitment UN/FAO members states must provide the CFS set of structures.

7 Page: 7 number: 1 [Comment] These two notes from the previous page, second last para highlights number: 2 Section III, 8. Price volatility. "Responses to such challenges often involve ad hoc and uncoordinated interventions in food and agriculture markets, which may exacerbate price volatility and the global market situation"

[Comment] It will help the GSF document to make clear what is referred to when saying "ad hoc and uncoordinated interventions". For the multilateral lending agencies for example, this means banning the export of and therefore trade in certain crops. Leaving aside the question of whether financially, or money market-oriented judgment can be exercised over food security imperatives, what are the alternatives? Are regional or supra-regional buffer stocks (such as Asean has planned) an answer to knee-jerk interventions? At what cost? It is always useful to look at such challenges from the household point of view. If it takes an intervention, no matter what the laissez faire contingent calls it, to stall the slide of many households into shock malnutrition and poverty, then that is the prerogative and duty of the state. The GSF needs to side with the smallholder and urban/rural poor on this matter. number: 3 Section III, 8. Price volatility. "volatility, including transparency in transactions in all markets and provision of better information, and action to address the underlying structural causes of volatility"

[Comment] Transaction transparency and free-flowing information may be used to advantage by the very drivers of price volatility. The GSF must aim to help UN/FAO members states build this infrastructure into agri + food administration, however the ability and motive of the market (financial + commodities) to pipe this into decision support systems that govern trades and movements must be recognised early enough. It will then only be intervention based on moral grounds that will neutralise the comparative advantage between the needs of providing food staples to the needy, and of permitting business as usual. number: 4 Section III, 8. Investment. "It is important to ensure that investments, especially those involving land and other resource transactions, do not compromise food security and nutrition, access to resources by the poor and environmental sustainability"

[Comment] The CFS-GSF may flag investment issues as requiring close monitoring at national and sub-regional level, but where are the commitments from states to follow this direction with policy regulations that ensure such outcomes? What we call 'resource transactions' are in fact, in the biosphere arena, resource annexations. The ideals espoused here must be critically examined for what they become in practice - 'bringing development benefits' is rare, because technology transfer can quickly encourage agricultural deskilling and the erosion of traditional knowledge,

8 employment creation can encourage economic migration and upstream-downstream linkages can increase farmers' exposure to external price factors. This set of advice needs to be very carefully qualified. number: 5 Section III, 8. Investment. "International investments should bring development benefits to the receiving country in terms of technology transfer, employment creation, upstream and downstream linkages"

[Comment] Through what lens must the investment subject be seen. An answer is provided in the para above on 'Challenges faced by women' [Sec III, Priority Issues]. In South Asia and sub-Saharan Africa, the overwhelming majority of farmers still rely on traditional farmers’ seed systems in order to grow their crops. Women play a key role in these systems: up to 90% of planting material used in smallholder agriculture is seed and germplasm produced, selected and saved by women, and it is predominantly women who grow and preserve underutilised species which local communities use to supplement their diets. number: 6 Section III, 8. Investment. "requires that voices of all relevant stakeholders are heard in the policy debate and that policy coordination is improved. The issue to be resolved is how to balance multistakeholder interests"

[Comment] The interests of the majority of small farmers in less industrialised countries, and the interests of rural and urban poor, marginal and low-income households - these are the interests the CFS must protect. CFS guidance cannot accommodate other interests. number: 7 Section III, 8. Uniformity in agricultural subsidies. Full para

[Comment] On the matter of WTO and TRIPS, the CFS must deal with the matter of seeds and farmers' rights - how international regulations affect farmer seeds. Over time a web of enormous complexity has been woven around seeds and plant reproduction organs, trapping farmers in a tangle of decrees, laws, directives and conventions. Farmers are denied their say in the incomprehensible regulations affecting their right to produce, multiply, use, exchange and sell the seeds of plants cultivated in their own fields. While the market is becoming globalised and industrial concentration is consolidating the monopoly over the food industry into the hands of a small number of multinationals, industrialised countries’ suffocating regulations are spreading across the developing world. How do international regulations affect farmer seeds? What are the threats to farmers’ rights over their seeds, the foundation of food sovereignty? number: 8 Section IV, 10. "Lessons learned from an increasing number of countries that use the right to food as a framework for the design, implementation and evaluation of national laws, policies and programmes should be effectively disseminated"

9 [Comment] This compendium of policy and practice will be most useful - the smaller the granularity of the region in which they function (district) the better, for that is where inclusion decisions are made.

Page: 8 number: 1 Section IV, 10. "Nutritional concerns should be addressed both by direct interventions and also through integration of nutrition in policies and programmes for agriculture, food security, food quality and safety, rural development and overall development"

[Comment] I am involved with the agricultural production and with the nutrition discussion and what we have found is that it has become absolutely essential to create costing indices for what we call 'food-based remedial programmes' - this means government funded programmes which provide hot cooked fresh meals to schoolchildren in government-aided schools. It is an enormous programme, and by the start of the 12th plan will reach 50 million children (and still fall short!). The group I work with on this matter has strongly advocated a food, fuel and labour input cost index for such programmes, as I found that the existing measures of consumer price index (CPI) and wholesale price index (WPI) are not useful for budgeting for their increases (or volatility) over a multi-year period. If providers of cooked meals to children in a city or region have suddenly to pay 8% more at open market prices for pulses because 'assured' supplies are interrupted, it ruins their annual budgets. number: 2 Section IV, 10. "will advance progress towards sustainability and development goals, and attention to child nutrition will help combat intergenerational reproduction of hunger"

[Comment] In spite of over two decades of international attention, agricultural technology transfer, 'advances' in crop science and new information channels to aid human development, under-nutrition levels remain persistently and unacceptably high in sub-Saharan Africa, South Asia and parts of South-East Asia. Women and children are undernourished, underweight and stunted in unacceptably large percentages of populations, resulting in limited survival rates and compromising the right to achieve their full development potential and active learning capacity. Food, nutrition and health must be viewed and treated by the CFS as a development continuum. This is because there has been inadequate progress in the prevention and management of common neonatal and childhood illnesses that accentuate a vicious cycle of under-nutrition, morbidity and mortality. The cycle reflects multiple deprivations, such as inadequate access to health and child care services, drinking water, environmental sanitation, inadequate access to household food security and livelihoods, inadequate caring practices and underlying gender discrimination, poverty and exclusion. Other determinants include access to education and life skills, social protection safety nets and control and use of resources (human,

10 economic, natural) - all of which are shaped by prevailing socio-economic policy environments. It is these that the CFS-GSF must focus on. number: 3 Section IV, 10. Agriculture as an engine for development. "The food security agenda ... " to " ... social and human capital"

[Comment] This is fraught with potential contradictions. Please see earlier notes on economic drivers and their effects, and to be read with agro-ecological approaches.

11 number: 4 Section IV, 10. Research and development. "greater emphasis is needed on the role of agricultural research and the development and transfer of appropriate and adapted technologies, and development of capacity for their effective utilization, to farmers in developing countries"

[Comment] Agroecology as a mode of agricultural development not only shows strong conceptual connections with the right to food, but has proven results for fast progress in the concretization of this human right for many vulnerable groups in various countries and environments, as the report submitted to the UN General Assembly, 2010 December, by the UN Special Rapporteur on the right to food has emphasised: Para 17. "Such resource-conserving, low-external-input techniques have a proven potential to significantly improve yields. In what may be the most systematic study of the potential of such techniques to date, Jules Pretty et al. compared the impacts of 286 recent sustainable agriculture projects in 57 poor countries covering 37 million hectares (3 per cent of the cultivated area in developing countries). They found that such interventions increased productivity on 12.6 millions farms, with an average crop increase of 79 per cent, while improving the supply of critical environmental services." [Jules Pretty et al., "Resourceconserving agriculture increases yields in developing countries," Environmental Science and Technology, 40:4, 2006, pp. 1114-1119. The 79 per cent figure refers to the 360 reliable yield comparisons from 198 projects. There was a wide spread in results, with 25 per cent of projects reporting a 100 per cent increase or more] "Disaggregated data from this research showed that average food production per household rose by 1.7 tonnes per year (up by 73 per cent) for 4.42 million small farmers growing cereals and roots on 3.6 million hectares, and that increase in food production was 17 tonnes per year (up 150 per cent) for 146,000 farmers on 542,000 hectares cultivating roots (potato, sweet potato, cassava). After UNCTAD and UNEP reanalyzed the database to produce a summary of the impacts in Africa, it was found that the average crop yield increase was even higher for these projects than the global average of 79 per cent at 116 per cent increase for all African projects and 128 per cent increase for projects in East Africa." [UNEP-UNCTAD Capacity Building Task Force on Trade, Environment and Development (CBTF), Organic Agriculture and Food Security in Africa, New York/ Geneva, United Nations, 2008, p. 16.]

12 number: 5 Section IV, 10. Social protection. Full para.

[Comment] Important, with the caveat that social protection is not automatically taken to be cash transfers, which do not help strengthen agricultural livelihoods and further expose households to the impacts of persistent food staples inflation and price volatility. number: 6 Section IV, 10. Strengthened trading systems. Full para.

[Comment] This point cannot stand in a document whose objective is to protect the interests of the rural and urban poor, smallholder farmers and cultivators, the informal workers who labour in the agri sector (including fish, animal husbandry, agro-forestry). The CFS cannot advocate increased and greater trade in food and food products while ruing price volatility - the one is caused by the other. The GSF cannot include an encouragement to the increased movement of food and food products at the cost of deepening the causal relation between reduced food access and lowered development potential. This is also directly contradicted by the values contained in the immediate following para.

Page: 9 number: 1 Section IV, 10. Investment in agriculture. "supported by donors ... " to " ... legislative and policy frameworks"

[Comment] Please see discussions in earlier notes on economic drivers, the movement of capital and industry/market influences on food policy and food flows in less industrialised countries. number: 2 Section V, 11. Full para.

[Comment] The CFS must recognise - and make its recognition public with clarity - that; (1) There is a need for a new synthesis concerning food and culture. In most countries, science and governance related to food and nutrition has been fragmented. Reductionism at the scientific level has perpetuated Green Revolution models and GM/GE crops. Reductionism in nutritional science has led to nutritionism where food is not seen as a system but only a composite of its nutrient parts, encouraging 'quick fix' single nutrient based solutions while the overall food system disintegrates and hunger grows, as stated by the Global Conference on Meeting Nutritional Challenges with Sustainability and Equity, held in New Delhi, India, in August 2009. Such science must be replaced by science that sees food holistically within a cultural and ecological context - and especially with regard to natural resource and energy limits. The CFS-GSF can advocate science-based solutions which address hunger and malnutrition only if they are based on independent publicly funded research and not driven by corporate interests. The CFS must recognise - and make its recognition

13 public with clarity - that; (2) On a deeper community level, in more industrialised countries, people are organising to overcome the health, environmental and social costs of the expanding industrial food system. Movements and campaigns for organic food or to "go local", in other words to buy food produced nearby and boycott products shipped from far away, have been spreading in many countries. The alarming rise in obesity, type 2 diabetes, cancers and other diseases that are directly linked to unhealthy eating is mobilising many people to change their lifestyles and work with others to promote more wholesome food and farming options. Specific campaigns and actions to stop the demonisation and destruction of local alternatives to an over-sanitised food system, such as street hawkers, raw foods and backyard or traditionally raised livestock, are also growing in popularity. For example, the global peasant/smallholder rights group La Vía Campesina has mounted a campaign to establish the concept of food sovereignty: the "right of peoples to healthy and culturally appropriate food produced through ecologically sound and sustainable methods, and their right to define their own food and agriculture systems". There is equally a need to integrate into this framework a right to food/durable food security reading of the concerns over, and food + agri links to: The general framework for the Convention on Biological Diversity (CBD); The Cartagena Protocol on Biosafety; and the International Treaty on Plant Genetic Resources (ITPGR). number: 3 [Comment] Thank you for providing this excellent opportunity to contribute to this important discussion. Rahul Goswami Social Sector Researcher, National Agricultural Innovation Project (Agropedia programme), Ministry of Agriculture, Government of India; Research Associate, Centre for Communication and Development Studies, India