Feedback’s response to the UK Government’s proposed reforms to the National Planning Policy Framework.

Feedback’s response to the UK Government’s review of the UK’s raw cane sugar ATQ.

Feedback’s response to the Financial Conduct Authority’s consultation.

Scientists urge governments to act aggressively over the next decade to keep global warming to 1.5°C and avert the worst consequences of climate change. Pivotal to that effort are policies to quickly end reliance on dirty energy; support a rapid transition to genuinely non-emitting and renewable energy; and protect forests and other intact ecosystems as critical carbon sinks. Industrial scale biomass-burning in the power sector threatens all three pillars of climate action and should not be subsidised.

Anaerobic Digestion (AD) of biomass feedstocks such as wastes and bioenergy crops is often a suboptimal use of land and resources, and must therefore be kept within its sustainable niche as a last-resort waste management option1. Any support for the growth of AD must be designed in a manner which does not undermine waste prevention efforts or divert land from environmentally preferable uses.

Reforming public procurement regulation is an opportunity to enshrine meaningful and mandatory
environmental and social sustainability standards into public food procurement law, so that small scale
sustainable food producers can compete for contracts and provide genuinely local employment, supply chain
resilience, reduced food waste and reduced greenhouse gas emissions.

The Paris agreement targets are unlikely to be met by mitigation alone and based on current trajectories, 1.5°C warming is likely to be exceeded between 2030 and 2052. It is therefore clear that the UK will also need to use Greenhouse Gas Removal methods to reach net zero by 2050. However, it is imperative that Greenhouse Gas Removal is in addition to maximising the mitigation potential of all sectors.

Feedback’s response to the first EFRA Committee enquiry, in April 2020, on the impact of the pandemic on UK food supply highlighted how the Government’s response needs to go beyond measures to relieve immediate scarcity – though these are of course important and vital – to encompass action that will help to build a food system that is more resilient to future shocks, especially those posed by the ongoing climate emergency. In this follow-up consultation, we build on that argument and showcase where the pandemic has exacerbated inequality in UK food supply, particularly with fresh food access, food workers’ rights and policy that does not take into account the critical role of small, local businesses in creating resilient, local food economies.

In September 2020, the UK government held a 6-week consultation about its proposals for due diligence legislation on forest risk commodities. This followed the publication in March 2020 of the Recommendations Report from the independent Taskforce for the UK’s Global Resource Initiative (GRI). Feedback’s response focused on expanding the scope of the proposed new due diligence law, and in underscoring the recommendations of the GRI.

Feedback welcome that the government is committed to zero food waste to landfill by 2030 and mandatory separate food waste collection. The government is also “committed to increasing the energy from waste produced through AD”. The summary of evidence presented here shows that Anaerobic Digestion (AD) is often a suboptimal use of the land and resources embodied in food waste, except as a last-resort waste management option, and that food waste prevention and diversion to animal feed yield far greater environmental benefits.

The government wishes to “increase the proportion of green gas in the grid” and to “provide targeted support to heat pumps”. The summary of evidence presented in our response shows that “green gas” from Anaerobic Digestion (AD) is often a suboptimal use of land and resources, except for a limited sustainable niche. Feedback therefore recommends that greater subsidies are dedicated to electrifying the heat supply as quickly as possible through technologies such as heat pumps, rather than locking in expensive and suboptimal “green gas” infrastructure. Feedback recommends increased taxes on landfill and incineration of waste feedstocks so that AD becomes attractive as a last resort only, with the revenue raised used to subsidise more cost-effective and more sustainable alternatives to AD, such as food waste prevention, afforestation, a just transition to more plant-based diets, and scaling up more efficient renewables such as solar and wind

The government wishes to “ensure that the CFD scheme continues to support low carbon electricity generation at the lowest possible cost to consumers”. The summary of evidence presented here shows that Anaerobic Digestion rarely delivers this desired outcome. Therefore, Contracts for Difference should not give support to Anaerobic Digestion (AD) plants of any size. Moreover, Feedback strongly recommends against creating a bespoke version of CfD to subsidise smaller scale AD plants than are currently covered by CfD.

Feedback welcome the CCC’s modelling of a 50% reduction in food waste by 2030. We recommend that the CCC use the following means of measuring the 50% per capita food waste reduction target, as a more ambitious scenario:
• 50% reduction of edible and inedible food waste (in practice mainly achieved through a
greater than 50% reduction in edible food waste)
• 50% reduction by 2030 against a 2015 baseline (there is a strong rationale for 2015 as
the baseline year, as the founding year of the SDGs, including SDG 12.3, which sets the
food waste reduction target)
• 50% reduction of food waste from farm to fork
• Additional prevention of edible surplus food currently sent to animal feed

The current Covid-19 pandemic is exposing many aspects of our food system which pose major challenges to both ensuring that the public’s nutritional needs are fulfilled fairly and equitably and to producing food without exacting a dangerous environmental toll. Our response to the enquiry is founded on our belief that true food system productivity should be measured as the greatest nutritional value consumed (with the least waste) for the least environmental harm or the greatest environmental enhancement. The Government’s response to the impact of the Covid-19 crisis on our food supply chain needs to go beyond measures to relieve immediate scarcity – though these are of course important and vital – to encompass action that will help to build a food system that is more resilient to future shocks, especially those posed by the ongoing climate emergency.

Feedback responds to the Government’s consultation on the new National Food Strategy, led by Henry Dimbleby. We argue that to achieve the best health and environmental outcomes, the government will need to redefine agricultural productivity, to prioritise high quality, nutritious food, low waste, and minimal environmental impact – and that implementing this approach will require a new land use strategy. We also urge the Food Strategy team to take another look at existing land uses – such as sugar beet production and feedstock crops for bio-energy – which do not contribute to human or planetary health.

Achieving net zero in the agricultural sector by as early a date as possible – ideally 2030 – is vital in order to mitigate the UK’s contribution to climate change, and to provide ‘head room’ for other economic sectors to decarbonise. There are a number of practical, implementable approaches to achieving net zero emissions, including: halving meat and dairy consumption by 2030, halving food waste by 2030, and reducing the UK’s demand for imported and domestically grown animal feed by enabling the use of food surplus as safely-treated feed for pigs and chickens.

The concept of ‘planetary health’ is particularly useful in regard to the food system, a sector across which human health and the health of our planet and the ecosystems it maintains most closely overlap. In 2016 the UK food system contributed approximately 10% of our yearly Greenhouse Gas emissions, and globally our food system drives deforestation, biodiversity loss and freshwater use. Adopting the right strategies for land use in the UK will determine outcomes for both public health and the UK’s contribution to wider climate change.

Brexit provides an opportunity to rethink how we subsidise and regulate our agricultural system. Over the past weeks, the government ran a consultation on their proposals for replacing Europe’s Common Agricultural Policy (CAP) after Brexit. Along with 44,000 other respondents to the consultation, we responded illustrating how we believe the food system should work.

Feedback’s response to the EU’s consultation on how to implement mandatory food waste measurement required under the Waste Framework Directive.

Feedback responded to the Mayor of London’s consultation on the London Environment Strategy. We strongly supported the ambition to make London a zero waste city by 2026, but argued more would need to be done to reduce food waste from both households and businesses, and to ensure that the food waste hierarchy is followed by all London food businesses. We also encouraged the Mayor to consider opportunities for London to become a pioneer in developing circular, local food systems – for example through urban growing and capturing and composting food waste at a local level.