222 Evans Road, Glenwood, Durban, South Tel: +27(0)31 206 2954 Fax: +27(0)86 510 1537 www.biowatch.org.za

Attention: HLPE Project team and steering committee By email: [email protected] [email protected].

19 November 2018

Biowatch response to the HLPE V0 Report: Agroecological approaches and other innovations for sustainable agriculture and food systems that enhance food security and nutrition

Thank you for the opportunity to comment on HLPE V0 Report: ‘Agroecological approaches and other innovations for sustainable agriculture and food systems that enhance food security and nutrition’.

We challenge the HLPE to look at agroecology and other innovations for sustainable agriculture and food systems that enhance food security and nutrition (our underline) and critique the literature, before including it in this document as innovations. It is not helpful to include “innovative” practices that use toxic herbicides and pesticides, GMOs and new unregulated biotechnologies, or other practices that do not address the devastating climatic and crisis that the earth faces and if not addressed, will result in devastating food insecurity and nutrition. Nor, should “innovation” lead to the further dispossession of peoples’ land and resources, or undermine their human rights. We urge the HLPE to be bold, to use the opportunity that they have, to take a transformative step that may be unpopular in the short term, but is of necessity to life on earth.

Our submission follows below and consists of:

1. Introduction to Biowatch South Africa 2. Comments on the HLPE V0 Report

Yours sincerely

Rose Williams Director

Trust No. IT 4212/99

Board Members: Dr David Fig (chairperson), Prof. Loretta Feris, Ms Thoko Makhanya, Dr Nombulelo Siqwana-Ndulo, Ms Beni Williams, Ms Rose Williams, Prof. Rachel Wynberg

1. Biowatch South Africa

Biowatch is a non-governmental organisation established in 1999, which strives for social and environmental justice within the context of . Biowatch works to challenge unsustainable agricultural practices and to advocate for agroecology as an ecologically viable alternative that safeguards people and land. This includes supporting smallholder farmers; working with civil society to create joint understanding and action; and constructively engaging with government in implementing policies and practices that promote, facilitate and actively support agroecology and farmers’ rights. We have a long track record of working on policy issues concerning agriculture, biodiversity, seed and indigenous knowledge systems.

2. Comments on the HLPE V0

1. The V0 draft is wide-ranging in analyzing the contribution of agroecological and other innovative approaches to ensuring food security and nutrition (FSN). Is the draft useful in clarifying the main concepts? Do you think that the draft appropriately covers agroecology as one of the possible innovative approaches? Does the draft strike the right balance between agroecology and other innovative approaches?

The chapter on agroecology does provide a comprehensive overview of the history of the developing definitions and concepts of agroecology as a science, practice and movement. However, the section on ‘agroecology as a social movement’ (1.1.3) does not give enough recognition to the role of indigenous societies in developing the diverse agroecological systems and related knowledge and foods that underlie all cultures (not just those identified by the FAO as ‘Globally Important Agricultural Heritage Systems’) and their agency in advancing agroecology.

We support the emphasis of “agroecology addresses … the economic and social dimensions of food systems in an indivisible way”, but the role of agroecology as a means to achieve the right to food through transformation of food systems, and local and regional food sovereignty must have more emphasis in the text.

This component of food sovereignty – that is the localisation and control of food systems – is also missing in the ‘Definition 2: Agroecological approach to FSN’ (page 30) for this report.

In relation to this, the document is set out with agroecology as just one of, and distinct from, the approaches described as innovations in Chapter 2, whereas civil society organisations in South Africa and elsewhere (as indicated by the Nyeleni Declarations on Food sovereignty and Agroecology) view agroecology as the means to realise the right to food and nutrition, and to transform what is patently an unsustainable and destructive food system.

2. Have an appropriate range of innovative approaches been identified and documented in the draft? If there are key gaps in coverage of approaches, what are these and how would they be appropriately incorporated in the draft? Does the draft illustrate correctly the contributions of these approaches to FSN and sustainable development? The HLPE acknowledges that these approaches could be better articulated in the draft, and their main points of convergence or divergence among these approaches could be better illustrated. Could the following set of “salient dimensions” help to characterize and compare these different approaches: human-

2 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 rights base, farm size, local or global markets and food systems (short or long supply chain), labor or capital intensity (including mechanization), specialization or diversification, dependence to external (chemical) inputs or circular economy, ownership and use of modern knowledge and technology or use of local and traditional knowledge and practices?

Although the report acknowledges that “there is unequivocal evidence that supports the important role of agroecology for enhancing FSN with benefit demonstrated at a social, environmental and economic level’ and answers most of the key concerns regarding agroecology with evidence; the report goes on to discuss other approaches without the same rigour – and often cherry-picking perceived benefits or negatives in the descriptions of the approach.

This counters the purpose of a workstream centred on agroecology, which is to address transformation of the food system due to: • The growing number of undernourished, malnourished and hungry people despite the current food system already providing sufficient calorie quantity of food for a population of 9 billion (i.e. population in 2050); • The current food system’s enormous negative impact on the climate (GRAIN 2011)1, biodiversity, waters, lands and indigenous peoples.

This transformation is urgent as our ability to satisfy food and nutrition security into the future is fundamentally premised on the ability of the earth’s ecosystems to continue to support life.

We therefore agree that the innovation chapter can better compare and distinguish the different approaches, and in some cases, exclude them from the chapter as they will not support sustainable agriculture and food systems or food security and nutrition. This would give a more succinct analysis to inform policy recommendations and the steps required to transform food systems. This could be achieved by assessing these against the specific principles of agroecology; or the overarching principles for sustainable food systems and the 5 pillars that have been identified as the framework for achieving SFS for FSN. Despite the effort to set out this framework, neither the overarching principles or the 5 pillars are used consistently in the analysis of innovations in the report. The only comparative analysis is in the form of Table 3 (page 36), which uses a new list of criteria described as ‘key aspects of FSN’ in Box 7 (page 34), without motivating why these particular aspects were chosen and their relationship to the conceptual framework for FSN outlined in the Introduction. It is also not clear how the applicability of these Key aspects was decided for each innovation in Table 3. For example, we disagree that Agroecology does not address issues of governance (represented by a X). In being grounded in local communities it directly addresses the livelihoods and wellbeing of stakeholders. It also engages with food system change, with the aim of food sovereignty, and therefore is implicitly engaged with food system governance and power dynamics.

In this regard, Figure 6 (page 37, line 23) is disingenuous in that it gives the impression that all 9 approaches satisfy the principles and pillars identified as contributing to the outcomes of SFS for FNS, when they do so in varying measures and some of the approaches are contrary to some of the principles and pillars (for example, approaches such as conservation agriculture, Climate Smart Agriculture, sustainable intensification etc) which may achieve one production principle but continue to use or even promote the use of toxic synthetic inputs). Such approaches, should in our view, not be included in the Figure or the document.

For example, policy-makers shouldn’t be given the impression that these are approaches with equal impact, but rather that these are approaches in a continuum from industrial agriculture to

1 GRAIN. September 2011. Food and climate change: the forgotten link. Against the Grain. http://www.grain.org/article/entries/4357- food-and-climate-change-the-forgotten-link

3 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 agroecology, where the focus must be on transitioning to agroecology. We are very concerned that the report and resultant policy recommendations shouldn’t provide opportunities to circumvent the radical change needed to fix our broken food system through incremental steps that provide a veneer of sustainability to ‘business as usual’. Rather this report must provide the unequivocal message that the industrial food system must be transformed to work together with nature in a way that is regenerative and life enhancing for all biodiversity and that will provide SFS for FSN.

The ‘salient dimensions’ listed above could provide another way to assess approaches. We note that some but not all of those listed represent the opposite ends of the spectrum on the dimension – for example agroecological smallholder farmers may be using modern technologies to market produce as well as utilising traditional knowledge to inform production methods and the type of foods they grow.

If this were the case, then in addition to those listed above, we would add: • Restoration of biodiversity (monocultures versus polycultures) – which is different to diversification in general and needs a specific focus. • Degree of local control over the process and resources needed for production (sovereignty versus dependence).

Principles for sustainable agriculture development (page 13, starting at line 33)

We agree with the addition of a 4th operational principle but recommend rewording to “reduce the ecological footprint” as one can’t ‘enhance’ this negative impact; but can reduce the footprint.

3. The V0 draft outlines 17 key agroecological principles and organizes them in four overarching and interlinked operational principles for more sustainable food systems (SFS): resource efficiency, resilience, social equity / responsibility and ecological footprint. Are there any key aspects of agroecology that are not reflected in this set of 17 principles? Could the set of principles be more concise, and if so, which principles could be combined or reformulated to achieve this?

The 16 principles that have been listed in Box 4 (page 24), do not in our view, adequately reflect accepted principles of agroecology. In the coalescing of principles (and dimensions) listed from the three source references, the text in this report has subtly shifted the language of these to align with mainstream framing of food system trade and economics - this changes the emphasis and spirit of the reference texts in communicating the transformative agenda of agroecology. Certain key concepts have also been left out, for example: “Agroecology supports peoples and communities in maintaining their spiritual and material relationship with their land and environment.” (CISDE, 2018).

Scientific principles The scientific/ecological principles of agroecology have been encapsulated by Miguel Altieri and Clara Nicolls in numerous publications over several decades as well as in the article cited in the HLPE report. However, these haven’t all been clearly articulated in the principles in the text. The ‘scientific’ principles in the HLPE text, which we feel are not well articulated, are extracted and commented on (in italics) below:

1. Optimize the use of local renewable resources and close resource cycles of nutrients and biomass.

4 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 Comment: This inadequately combines 2 separate concepts: 1) the recycling of biomass and thus creating balanced nutrients in the system and 2) the need for closed loop production systems for the conservation and regeneration of all resources including water, energy, soil, nutrients, and genetic diversity etc.

The included principle: “2. Reduce or eliminate the dependency on external inputs” would naturally result from the application of closed loop production based on conservation and regeneration, and we are not sure then that principle 2 needs to be included. If it is included it should be as the CIDSE originally had it “Eliminate the use of and dependency on external synthetic inputs by enabling farmers to control pests, weeds and improve fertility through ecological management. “

5. Maintain and enhance diversity of species and genetic resources and maintaining biodiversity in the agroecosystem over time and space at the field, farm and landscape levels. Comment: This is clumsy and has lost the important concept of functional diversity – rather “ Maintain and enhance the biodiversity of the system, and especially the functional biodiversity (species that work together to make the system more healthy and productive), including within and between species, above and below ground, and in time and space (on farms and in the wider landscape).

6. Enhance positive ecological interaction, synergy, integration, and complementarities between the elements of agroecosystems (plants, animals, trees, soil, water). Comment: trees are also plants, so it is not clear why these are mentioned and not microorganisms, fungi etc? Also, people are a key element in the agroecosystem. However, the original wording of this principle is better as the emphasis is on ecological processes and services: “Enhance the beneficial biological interactions and synergisms between system components that can provide key ecological processes and services within the system.”

Social equity principles The principles around social equity should take their lead from the social and peasant movements that have articulated the social and cultural dimensions of agroecology, and thus these should have a rights-based and food sovereignty approach.

The following in the current text are of concern:

7. Diversify on-farm incomes by giving small-scale farmers greater financial independence and value addition opportunities and enabling them to respond to demand of consumers. Comment: this is an example of changing the principle to fit in with mainstream agribusiness language and providing one possible solution as a principle. The CISDE version read “Agroecology promotes diversification of on-farm incomes giving farmers greater financial independence, increases resilience by multiplying sources of production and livelihood, promoting independence from external inputs and reducing crop failure through its diversified system.”

5 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 10. Build food systems based on the culture, identity, tradition, social and gender equity, innovation and knowledge of local communities and livelihoods. Comment: Reword – “Build food systems rooted in the culture, identity, tradition and knowledge of local communities that value and respect local innovation and the diversity between people.” There should be a separate principle that includes currently marginalised sectors of society: “Create opportunities for women, young people, and the differently abled and encourage women’s leadership and gender equality.”

14. Support fair trade, fair employment, and fair treatment of intellectual property rights. Comment: what is fair treatment of intellectual property rights where these are owned by corporate interests in the current system? This is another example of the shift in language. Rephrase as “Promote fair, short distribution networks rather than linear distribution chains and build a transparent network of relationships between producers and consumers.”

There should be a separate principle dealing with the rights to our common heritage. Many traditional societies distance themselves from the concept of ownership over life and natural resources. Such a principle could read: “Return the control over resources including seed, biodiversity, land and territories, water, knowledge and the commons to the local communities who are part of the food system; respecting customary systems for ensuring collective rights.”

Missing principles There is a principle missing that reflects the conservation of natural and agricultural resources necessary for food production. Such a principle could be : “Dynamically conserve and regenerate the natural resource base and agricultural heritage for coming generations”.

Grouping under the over-arching pathways towards SFS for FSN The principles don’t neatly group under the four over-arching pathways towards SFS for FSN as several of these are cross-cutting. For example, the listed principle 1 helps to use resources efficiently but also to reduce environmental footprint and both lead to greater resilience.

Table 1: Scale of application of agricultural principles and contribution to FSN It is not clear what the purpose of Table 1 (page 25) is, and how the analysis was made, as each principle’s application and contribution to food security can be interpreted in different ways and there has been no attempt to apply this analysis to the other ‘innovation’ approaches.

The following provide examples of how this analysis can be contested:

Principle 1 can be applied beyond field and farm in the food system by for example collecting food waste from markets or households at central composting facilities or by so processing sludge at sewage treatment works into compost so that these nutrients can be redistributed to farmlands. This has a direct benefit for soil fertility and the thus the productivity and nutrient content of plants thereby improving food security and nutrition.

Principle 3 also contributes directly to nutrition by improving the availability of nutrients in the soil for uptake by crops thereby improving the nutrition in the food.

6 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018

Principle 4 on animal health and welfare does apply beyond the farm as livestock continue to be transported long distances to slaughter. Poor treatment of animals creates stress that often leads to illness which is often treated with antibiotics which then affect the safety of meats and dairy products.

Principle 5 on enhancing the diversity of species in the agroecosystem can also be applied in catchments or other areas that are larger than individual farms. This leads to the greater availability of diverse and seasonal foods in a local market which directly contributes to better nutrition through more diverse diets of fresher foods.

Principle 6: enhancement of ecological interactions enables a reduction in external inputs, thereby saving smallholders money, which as discussed in line 12, 13 provides more resources to buy food.

Principle 8 - local and indigenous knowledge enables communities to know how to process and prepare more diverse foods, and where to gather and how to prepare additional wild foods, which all contribute to better nutrition and food security throughout the seasons.

4. The V0 draft is structured around a conceptual framework that links innovative approaches to FSN outcomes via their contribution to the four abovementioned overarching operational principles of SFS and, thus, to the different dimensions of FSN. Along with the four agreed dimensions of FSN (availability, access, stability, utilization), the V0 draft also discusses a fifth dimension: agency. Do you think that this framework addresses the key issues? Is it applied appropriately and consistently across the different chapters of the draft to structure its overall narrative and main findings?

We agree with the addition of ‘Agency’ as a 5th pillar for achieving food security, as this adds a missing dimension to securing SFS for FSN that is implied in the concept of food sovereignty. Agency also implies that food producers and the communities they serve are central in making decisions about their production processes and resources, including the assessment and acceptance of innovations according to local social, economic and environmental contexts.

We would add to the definition of agency (page 14, lines 35-39) as follows:

Agency: empowerment of citizens in defining and securing their own food and nutritional security, requiring socio-political systems wherein policies and practices may be brought forth by the will of citizens and be reflected in governance structures to enable the achievement of FSN for all. This includes access to accurate information, the right to such information and to other aspects of food security, and the ability to secure such rights, including access and control over the resources required for production, harvesting and preparation of foods.

As mentioned previously, we find the 5 pillars (and the principles) to be applied inconsistently in structuring the report and in assessing the various innovation approaches.

5. The V0 draft provides an opportunity to identify knowledge gaps, where more evidence is required to assess the contribution that agroecology and other innovative approaches can make progressing towards more sustainable food systems for enhanced FSN. Do you think that the key knowledge gaps are appropriately identified, that their underlying causes are sufficiently articulated in the draft? Is the draft missing any important knowledge gap? Is this assessment of the state of knowledge in the draft based on the best up-to-date available

7 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 scientific evidence or does the draft miss critical references? How could the draft better integrate and consider local, traditional and empirical knowledge?

Additional references

Agroecological principles

See Parmentier, S. 2014. Scaling-up agroecological approaches: what, why and how? Belgium: Oxfam-Solidarity. Available: http:// www.fao.org/fileadmin/templates/agphome/scpi/Agroecology/Agroecology_Scaling- up_agroecology_what_why_and_how_- OxfamSol-FINAL.pdf [18 January 2016].

Innovation and transitioning to agroecology

IPES Food. 2018. Breaking away from industrial food and farming systems: Seven case studies of agroecological transition.

Connection between nutrition and obesity in the urban food insecure

Steyn, N.P. 2006. Nutrition and chronic diseases of lifestyle in South Africa. In: Fourie, J., Steyn, K., & Temple, N.J. (Eds). Chronic Diseases of Lifestyle in South Africa since 1995-2005. Tygerberg: South African Medical Research Council. Available: http://www. mrc.ac.za/chronic/cdlchapter4.pdf [19 November 2012].

Sustained yields from agroecology in times of climate and weather stress

Altieri, M.A., et al. 2012. Nourishing the world sustainably: scaling up agroecology. Geneva: Ecumenical Advocacy Alliance

Integration of local and traditional knowledge Local and traditional knowledge is often not documented in peer-reviewed studies, and much richness and local experience salient to these issues is lost. We suggest that a greater proportion of case studies and research from civil society organisations is included to balance the scientific “way of knowing” especially since agroecology seeks to foreground the local and traditional knowledges of food producers and consumers.

6. A series of divergent narratives are documented in Chapter 3 to help tease out key barriers and constraints to innovation for FSN. Is this presentation of these divergent narratives comprehensive, appropriate and correctly articulated? How could the presentation of the main controversies at stake and the related available evidence be improved?

The divergent narratives – that is main points of disagreement – are well identified. However, there can be improvement in the fair presentation of both sides of these divergent /opposing narratives. We have issue with the following:

3.2.6 Can GMOs be part of SFS for FSN? (page 76)

The focus on GMOS as an innovative approach is contradictory, and Biowatch believes that GMOs should not be included in SFS approaches for FSN. In this regard we don’t think that the text thoroughly explores the literature against the inclusion of GMOs. Please see the attached Biowatch

8 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 Factsheet: GMOs in South Africa for further critique and references in this regard, also downloadable from http://www.biowatch.org.za/docs/fs/2018/Biowatch_GMOsinSA_Feb2018.pdf. We are concerned that the negative health impacts of GMOs are downplayed in the Report. The safety of food for human health is an important aspect of food security and nutrition, and many new studies are emerging that throw their safety for health into question. Herbicide tolerant GMOs also cannot be divorced from their corresponding herbicides, which remain as residues on GM crops. In the section on objections to GMOs in the report point 2 on the disempowerment of farmers only covers the issue of intellectual property rights and neglects to discuss many other aspects of farmer disempowerment that directly affect food security. These include: • Increasing dependence on expensive synthetic inputs as GMOs are bred to grow with fertiliser and the associated herbicides. Pesticide use also increases with time, as pests become adapted to the insecticidal toxins in Bt GMOs. • Weed resistance associated with GMOs can result in uncontrollable weeds taking over lands and preventing farmers from growing food. • GMOs are cross-pollinating with farmer varieties, affecting preferred farmer traits, such as drought resilience.

• Bt toxin impacts on microbial communities that affect traditional practices of leaving crop residues to compost in place and provide free fertilisation of their lands for the coming season. Citing industry sponsored research is disingenuous. Some examples of skewed GMO-positive referencing in the document are: • Reference to drought tolerance, the efficacy of which is widely criticised.2 Why are traditional varieties that are resilient to drought not cited.

• The reference to ‘golden rice’ when the focus is on food security and nutrition – there is no doubt that a diverse diet is the best way for nutrition.

7. This preliminary version of the report presents tentative priorities for action in Chapter 4, as well as recommendations to enable innovative approaches to contribute to the radical transformations of current food systems needed to enhance FSN and sustainability. Do you think these preliminary findings can form an appropriate basis for further elaboration, in particular to design innovation policies? Do you think that key recommendations or priorities for action are missing or inadequately covered in the draft?

Comments on the recommendations (page 9)

We recognise that the Recommendations on page 9 are a preliminary draft and will be re-worked as the report text is fine-tuned, and we have the following non-exhaustive comments.

2 See for example: Gurian-Sherman, D. 2012. High and Dry: Why Is Not Solving Agriculture’s Drought Problem in a Thirsty World. Union of Concerned Scientists. Available:http://www.ucsusa.org/sites/default/files/legacy/assets/documents/food_and_agriculture/high-and-dry- report.pdf

Gurian-Sherman, D. 2009. Failure to yield: Evaluating the performance of genetically engineered crops. Cambridge, MA: Union of Concerned Scientists. Available at: http://www.ucsusa.org/assets/documents/food_and_agriculture/failure-to- yield.pdf.

9 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 In general, it is not clear how these specific areas for policy intervention were identified or concluded from the detail of the report. They remain general and unsubstantiated.

The recommendations omit the following key areas contributing to SFS for FNS:

• Conservation and strengthening of soil ecosystems. • Conservation of agricultural and biodiversity/wild food resources, and natural ecosystems that contribute to traditional food systems. • Measures to shift large-scale and commercial producers to agroecological practice, and especially to decease the use of harmful toxic inputs and industrial farming practices. • Support for and protection of traditional and indigenous food production systems. • The recommendations, and the report in general, pay insufficient attention to pastoralists and fishers.

Specific comments on recommendations:

1.b) Private sector value chain innovation may lead to niche markets of higher value products, which while providing extra income, do not improve food security and nutrition in the local market. Value chain innovation should also address improved dietary diversity and nutrition through local processing, which may need public sector intervention.

1c) This recommendation is particularly focused on financial value but doesn’t address retention of food value and nutrition in the local area. In other words, investment in entrepreneurs shouldn’t just focus on income-generation as poor quality fast-foods may sell well but do little to improve nutrition security.

2b) What constitutes ‘Sustainable’ should be articulated here as too often this is interpreted as financial sustainability and doesn’t include ecological and social dimensions.

2c) This recommendation should include an emphasis on farmer-directed and participatory research.

3b) Access should not be limited to land and land tenure, but also include other resources such as water and seed.

3c) Reformation of national and regional seed legislation should extend to ‘farmers’ rights’ as described in the Treaty on Plant Genetic Resources for Food and Agriculture, that includes all forms of exchange (including sale) of seed in local farmer seed systems, including those of protected varieties that may have entered the seed system unintentionally.

4. Support for equitable and sustainable food value chains.

Add a recommendation on f) supporting access to appropriate technology powered by renewable energies that facilitate localised processing.

7. Development and strengthening of linkages between urban communities and food production systems.

Add recommendations that support urban food production systems – these could include: access to safe irrigation water, urban planning that includes and facilitates food production, review of bylaws to facilitate safe and healthy food production, establishment of local urban food markets, composting of organic waste linked to urban farms, etc.

10 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 8a) Include ‘reduction of toxicity and ecosystem pollution from food systems’. Note that it should say reduction of ecological footprints.

8. Throughout the V0 draft there has been an attempt to indicate, sometimes with placeholders, specific case studies that would illustrate the main narrative with concrete examples and experience. Are the set of case studies appropriate in terms of subject and regional balance? Can you suggest further case studies that could help to enrich and strengthen the report?

The following additional case studies/evidence is suggested:

We submit the attached publication as a case study illustrating best practice in the implementation of agroecology in a smallholder context in South Africa and the positive impact this has had on food and nutrition security as shared by the farmers’ stories highlighted in the publication: Williams R., Pelser D. & Black V. (Eds). 2018. Agroecology is best practice. Biowatch South Africa’s work with smallholder farmers. Biowatch South Africa: Durban. Downloadable from: http://www.biowatch.org.za/show.php?id=3001

The Case study on Fall Army Worm (page 21) could reference an example in addition to the general and diverse approaches to the control of FAW using agroecological methods. One of the methods not specifically mentioned in the box is the ‘push-pull’ system. See for example: Midega CAO; Pittchar JO; Pickett JA; Hailu GW; Khan ZR (2017) A climate-adapted push-pull system effectively controls fall armyworm, Spodoptera frugiperda (J E Smith), in maize in East Africa. Crop Protection. Downloadable from: http://www.sciencedirect.com/science/article/pii/S0261219417303216

We submit additional journal references towards the case study on Bt in South Africa:

Witt, H., Patel, R., and Schnurr, M. 2006. Can the Poor Help GM Crops? Technology, Representation and Cotton in the Makhathini Flats, South Africa. Review of African Political Economy (109), 2006, pp. 497-513.

Pschorn-Strauss, E. 2005. in South Africa: the case of the Makhathini farmers. GRAIN: Seedling, April 2005. Downloadable: https://www.grain.org/article/entries/492-bt- cotton-in-south-africa-the-case-of-the-makhathini-farmers

9. Are there any major omissions or gaps in the V0 draft? Are topics under-or over-represented in relation to their importance? Are any facts or conclusions refuted, questionable or assertions with no evidence-base? If any of these are an issue, please share supporting evidence.

2.3 Innovative approaches towards sustainable food systems

2.3.1 Rights based approaches (page 38)

We strongly object to the right to food, women’s’ empowerment, and food sovereignty being assembled alongside other approaches to innovation under the headings ‘rights-based approaches’. These are not approaches, but the actual rights that must underpin this report.

11 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 Women (and youth) empowerment and the right to food are at the heart of achieving a sustainable food system delivering food and nutrition security, and together with food sovereignty, are essential outcomes in the agroecology movement.

By separating these rights out as an approach, the other approaches are not analysed for their contribution to these rights. Any approaches to innovation included in this report must be evaluated by their contribution to realising these rights, especially the right to food.

We also object to the inclusion of approaches in this report that do not meet the overarching principles to improve resource efficiency, strengthen resilience, secure social equity and reduce ecological footprint. The extent to which innovations reduce negative impacts should be analysed and compared.

The approaches that should not be included are:

Conservation Agriculture (CA) / sustainable intensification Although Conservation Agriculture appears to complement agroecology through practices of minimum soil disturbance/tillage, permanent organic soil cover and increased crop diversity through rotations and intercrops it only addresses some aspects of improved production methods. These practices may improve soil quality and its ability to store water and carbon, but benefits are counteracted by the use of herbicides to kill weeds and cover crops, and the continued use of fertiliser. These synthetic inputs harm soil organisms reducing soil fertility and carbon storage. Agribusiness companies are using the condoning of herbicides in Conservation Agriculture to expand their market, rather than reduce the use of these harmful chemicals. For example, stated on their website that “Roundup agricultural herbicides enable and encourage the practice of conservation tillage” because of their “broad-spectrum effectiveness in controlling weeds.”3

Although the link between conservation agriculture and increased herbicide use is contentious, it is also interesting to note that conservation agriculture emerged from Brazil and that the four Latin American countries that lead the adoption of conservation agriculture are also leading producers of GM crops (mostly herbicide tolerant GM Soya). In Latin American, the main system of producing genetically modified RoundUp Ready soybean uses the no-till technique; enabling monocrop soya plantations to extend intensify and extend into areas where it was not possible to produce before, displacing rural peasant farmers and exposing communities to “chemical warfare” through intensive herbicide spraying.4

Crop diversity, inter-cropping and cover crops in conservation agriculture are also not applied in the way that these are in agroecology or Permaculture. In agroecology there is a genuine diversity in one field, whereas in conservation agriculture a legume crop may be grown and slashed or killed with herbicide before a grain is planted.

South Africa provides evidence of the promotion of synthetic chemicals in the roll out of CA: The South African Agricultural Research Council’s Grain Crops Institute advised farmers in its 2013 Maize

3 Monsanto. 2005. History of Monsanto’s Glyphosate Herbicides. Available: http://www.monsanto.com/products/documents/glyphosate-background-materials/back_history.pdf [accessed 16 May 2015]. 4 Rulli, J. 2009. South American GM Soy close to get carbon credits – agribusiness lobby in the climate negotiations. Available: http://library.wur.nl/WebQuery/file/cogem/cogem_t4bc46447_001.pdf

12 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 Information Guide: that when changing to conservation agriculture “expenditure on herbicides usually increases. Without the inclusion of a glyphosate tolerant crop in the rotation system, the conversion to a conservation agriculture system will be very difficult.”5 This is of concern given that these CA initiatives are targeting smallholder farmers and encouraging them to abandon their low input traditional farming in favour of CA, leading them into debt and dependence on external inputs, which jeopardises household food security. Further discussion of this issue can be found in our publication on Conservation Agriculture - Downloadable from: http://www.biowatch.org.za/docs/fs/2015/Biowatch_Fact_Sheet_CA_web.pdf

Climate Smart Agriculture (CSA) Our objection to the inclusion of CSA is contained in the “Joint submission of organisations sharing concerns over climate-smart agriculture” (attached).

In addition, our objection to CSA includes:

• The inclusion of CA as a form of Climate Smart Agriculture. • The continued so-called “wise” use of synthetic fertilisers rather than doing away with them. Practices described in CSA documents include making changes in the rates, timing and type of nitrogen fertiliser applications; using slow release fertilisers that control the formation of nitrates; adding nitrification inhibitors containing ammonium to fertiliser;9 deep placement of urea fertiliser granules; and site-specific testing for optimal fertiliser dosage or micro- dosing.

• Although the FAO states that CSA does not promote the use of GMOs; it has left a back-door open for their use by saying that solutions are developed for specific local conditions with the key stakeholders involved, and that the use of GMOs is determined by the national policies of each country.

This approach tacitly allows GMOs to be promoted as “climate-smart” technologies. For example, in South Africa two projects are promoted as “climate-smart” because they are developing maize lines that are supposedly more resilient to environmental stresses. In particular, a GM maize claiming to be drought tolerant has been field-trialled under the Water Efficient Maize for Africa (WEMA) Project targeting small-holder farmers in Kenya, Mozambique, Tanzania, Uganda and South Africa. The efficacy of the drought tolerance gene (MON87460)in the maize is highly contested6.

For more detail on our objection to CSA, and its application in South Africa, please see our information sheet: ‘Climate Smart Agriculture: why we say no’ downloadable from: http://www.biowatch.org.za/docs/fs/2015/Biowatch_Fact_Sheet_CSA_web.pdf (and attached).

5 ARC-Grain Crops Institute. 2013. Soil cultivation and conservation agriculture Maize Information Guide 2013. Available: http://www.arc.agric.za/arc -gci/Pages/MIG.aspx [Accessed 19 May 2015]. 6 See: • Gurian-Sherman, D. 2012. High and Dry: Why Genetic Engineering Is Not Solving Agriculture’s Drought Problem in a Thirsty World. Union of Concerned Scientists. Available:http://www.ucsusa.org/sites/default/files/legacy/assets/documents/food_and_agriculture/high-and- dry-report.pdf • Gurian-Sherman, D. 2009. Failure to yield: Evaluating the performance of genetically engineered crops. Cambridge, MA: Union of Concerned Scientists. Available at: http://www.ucsusa.org/assets/documents/food_and_agriculture/failure-to-yield.pdf.

13 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018 Nutrition Sensitive Agriculture

We object to the inclusion of approaches focused on biofortification for the following reasons: • these disregard individual sensitivities to added nutrients which may not be in the form or dose that every person can consume, and there is no follow up or monitoring of the consumers. Negative impacts will only be picked up many years later, if at all. • Doses of added nutrients cannot be controlled as food intake is variable. • Biofortification does not address the broader food system constraints to the consumption of adequate and nutritious diets and serves instead as a quick fix to the symptom. • As with the example of GM Golden Rice, the increase of nutrients in a single crop is often incomparable to eating a diverse and nutritious diet requiring the consumption of large amounts of this single crop to make a difference, thereby further entrenching a diet of only a few foods. • We object to the inclusion of GMOs as being safe, sustainable or contributing to FNS.

14 Biowatch SA_ response to the HLPE V0 Agroecology Report November 2018