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Appendix to the Australian Dietary Guidelines: Dietary Guidelines through an environmental lens submission

This submission reflects the views of
Individual Background: 
Researcher – biomedical
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General Comments

Firstly, I think it is extremely disappointing that environmental considerations are not included in the Dietary Guidelines and have been demoted to occupying a mere appendix. Modifying food intake is the single-most effective way that humans can decrease their negative environmental impact, as this is something that is achievable by every Australian. By not including environmental considerations in the Dietary Guidelines the government is denying Australians a great opportunity to make informed choices about their diets in order to reduce their environmental impact. The Dietary Guidelines should help inform and empower people to help achieve not only better personal health but also better planetary health. Personal health will be of little consolation when our climate is severely disrupted, our water supplies polluted and inadequate, our land degraded and our resources depleted.

Secondly, while the Appendix acknowledges that measuring the environmental impact of foods is complex and inexact, it states:

"Despite the above challenges, enough evidence exists to begin developing informed, pragmatic and guiding principles to reduce the environmental impact of the food system. These practical considerations can be easily aligned with the Australian Dietary Guidelines..."

The statement gives hope, but this is soon quashed, as the Appendix ignores much of the obvious and well-documented ways that food choices impact on the environment.

Specifically, it appears that the Appendix does not adequately address the "elephant in the room", the issue of animal product consumption versus plant food consumption. It is well-established (and obvious) that raising animals for food and then consuming either the animals themselves or their products is an inefficient use of resources, including land, water, fossil fuels and even food itself, when compared to consuming plant foods directly.

  • Huge quantities of water are used in animal agriculture e.g. it takes between 50,000 and 100,000 litres of water to produce a kilo of beef, compared to 2,500 litres to produce a kilo of rice and much less for most fruit and vegetables. (1) The CSIRO has reported that it takes (on average) 800 litres of water to produce just one litre of milk.(2)
  • In Victoria 77% of agricultural water is used for pasture and hay production for grazing animals raised for meat and dairy products, compared to 10% for producing fruit and vegetables for human consumption. (3)
  • In Australia over 67% of water is used for agriculture whereas only 9% is used for household use. (4)
  • When looking at water use according to type of diet, a person on the average Australian diet uses approximately 3500 litres of water per day whereas a person on a plant-based diet uses less than 1000 litres of water per day. (5)
  • Water used to produce a single 150 gram beef burger is, on average 2350 litres, compared to 158 litres for a soy burger. ie the soy burger requires less than 7% of the water that the beef burger requires for production.(6)
  • Producing food from animals uses far more energy (often in the form of non-renewable fossil fuels) than producing food from plants. (7,8) The production of animal protein requires eleven times as much fossil fuel as does the production of the same amount of protein from plants. (7) Additionally, raising animals for food uses significant energy for the operation of livestock facilities (such as lighting, heating, cooling and slaughter), for transport of feed and livestock and for constant refrigeration, packaging and cooking.
  • The beef, sheep and dairy industries account for 92% of forest clearance and land degradation in Australia. (9,10) Reducing these industries would free up land for other uses such as food production, forestry and the production of plant-based foods, fuels and fabrics.

Not only is the production of animal products an inefficient use of resources, it is also a major contributor to greenhouse gas emissions:

  • Methane produced by animals is much more dangerous than CO2 as a contributor to global warming having a warming potential at least 72 times that of CO2 over a 20 year period. (11) The farming of livestock in Australia will contribute substantially more to global warming over the next 20 years than all of our coal-fired power stations put together. (12)
  • It is well-established that ruminant animals raised for meat are a major cause of methane production. Not surprisingly, University of Chicago researchers found that all diets containing animal products generated higher amounts of greenhouse gas emissions than a vegan diet. (13)
  • A 2002 Australian Greenhouse Office report found that beef production generated 51.7 kg of CO2eq 2 per kg of meat produced, compared with wheat at 0.4 kg of CO2eq per kg.(14)
  • Land that is used for grazing animals could be better used to absorb CO2, such as by planting native forests. Approximately 56% of the Australian continent is used for grazing (15), and additional land is used for producing hay and other food to be fed to animals that are later eaten.
  • The UN Environmental Programme identified the use of animals for food as one of the most significant factors in climate change and other environmental problems, stating that “a substantial reduction of impacts would only be possible with a substantial world-wide diet change, away from animal products.” (16)

Food wastage is mentioned in the Appendix but the biggest source of food waste in the world, raising animals for food, is omitted. A major contributor to food waste both globally and nationally is the raising of livestock for consumption of its flesh or products (such as eggs and milk). Most of the edible grain produced globally is used to feed animals for meat, milk and egg production rather than being used directly for human consumption.(17) This represents a huge waste of food, as the conversion of plant food to animal flesh or other products is inefficient. For example, six kilos of protein is consumed by livestock in order to produce one kilo of meat protein. Food energy (KJ) and protein available from plants is being wasted when fed to animals rather than being consumed directly.( 7) Practices such as fish farming highlight the absurdity of this, with approximately 5 kilos of wild fish being fed to farmed fish per kilo of farmed salmon produced. (18)

In light of the above the statement: "Choose protein sources that have a lower environmental impact, such as pork, poultry, eggs, tofu, tempeh, nuts and seeds, and legumes/beans. Choose fish and other seafood from stable stocks." is clearly inadequate, considering that the "Protein" food group is named: "Lean meat and poultry, fish, eggs, tofu, nuts and seeds, and legumes/beans". While mentioning the obvious - that the "Protein" group should be renamed (in order to demote lean meat and poultry from being first on the list) is outside the scope of this submission, clearly more will need to be done to coax or educate Australians away from their reliance on red meat and chicken.

I suggest that the above statement ("Choose protein sources....") be amended to:

"Choose plant foods such as legumes, soy products, nuts and seeds in preference to animal-derived foods as protein sources, as these have a lower environmental impact and use less resources to produce. Avoid red meats and consume other animal-derived sources of protein minimally, if at all. "

Regarding the food group "Milk, yoghurt, cheese and/or their alternatives, mostly reduced fat (reduced fat milks are not suitable for children under the age of 2 years)" the Appendix states: "Consuming quantities in line with the Australian Dietary Guideline for this food group, and consuming a mixture of milk, cheese and yoghurts, rather than rely on any one food, will help minimise the environmental burden associated with consumption of foods from this group."

However this statement is untrue. It ignores the existence of the "alternatives" in the group, such as plant milks, including fortified soy milk, and the following facts:

  • It takes 10- 14 kcal of fossil fuel energy to produce 1kcal of milk protein, whereas it takes only 0.26 - 0.31kcal of fossil fuel energy to produce 1kcal of soybean protein. (19)
  • A study in 2010 of the top 45 food commodities in the UK found that replacing dairy products with soy-based milk products would significantly reduce greenhouse gas emissions. (The adverse effect of methane production from cows is well-documented.) (20)
  • Producing soymilk requires on average 297 litres of water per litre, whereas producing cows' milk requires on average 1050 litres of water per litre of milk produced. (6)

Considering the vast difference in environmental impact of producing fortified soy products versus dairy products (not to mention the well-documented health benefits of soy products over dairy products) I suggest that the "practical considerations" for the "Milk" group be reworded as:

"Choose plant milks and other non-dairy alternatives in preference to cows' milk and other dairy products, as the alternatives have a much lower impact on the environment than traditional dairy products. By choosing plant milks that are fortified with calcium and vitamin B12 these can entirely replace cows' milk in the diet."

By rewording the practical considerations associated with the "Meat" and "Milk" groups not only will it give consumers clear guidelines to assist with their eco-friendly food choices, but will also have positive health implications, given the benefits of plant-based eating over animal product consumption, duepartly   to the lower saturated fat content and higher fibre and antioxidant content of plant-derived foods. (21)

Finally it should be noted that while the other practical considerations listed, such as minimising waste and considering packaging have merit, their potential effect on the environment pales into insignificance when compared to the potential impact of reducing animal product consumption. It does not make sense to mention these small effect actions while failing to give clear information and guidelines on the step which would have the greatest environmental impact: reduction in animal product consumption.


    1. Meyer W. Water for food: the continuing debate. Cooperative Research Centre for Irrigation Futures. www.clw.csiro.au/issues/water/water_for_food.html (accessed 12/10/2009)
    2. Khan, S., Abbas, A., Rana, T., Carroll, J. ‘Dairy water use in Australian dairy farms: Past trends and future prospects’, CSIRO: Water for a Healthy Country National Research Flagship, 2010.
    3. Australian Bureau of Statistics, AusStats: 4618.0. Water use on Australian Farms, Australia, 2005-6. www.abs.gov.au (accessed 12/10/2009)
    4. CSIRO and Australian Govt. State of the environment report, AGPS 2006.
    5. Rutherford I, Tsang A, Tan SK. City people eat rivers: estimating the virtual water consumed by people in a large Australian city. (in Wilson AL, Dehaan RL, Watts RJ, Page KJ, Bowmer KH, Curtis A. Proceedings of the 5th Australian Strem Management Conference. Australian Rivers: Making a Difference, Charles Sturt University, 2007.
    6. Ercin A, ALdaya M, Hoekstra A. 'The Water footprint of soy milk and soy burger and equivalent animal products' in Value of Water Research Repost Sries No. 49, Twente Water Centre, University of Twente, Enschede, The Netherlands 2011.
    7. Pimentel D, Pimentel M. Sustainability of meat-based and plant-based diets and the environment. Am J Clin Nutr September 2003 vol. 78 no. 3 660S-66
    8. Brand RA, Melman AG. Energy values of inputs of animal husbandry. TNO, Insituut voor milieu-energietechnologie, Apledoorn, The Netherlands, 1998.
    9. DEWHA. Assessment of Australia’s terrestrial biodiversity 2008. Department of the Environment, Water, Heritage and the Arts. 2009.
    10. Foran B, Lenzen M, Dey C. Balancing act: a triple bottom line analysis of the 135 sectors of the Australian economy. CSIRO, 2005.
    11. IPCC. Working Group1, 2007. The physical basis of climate change, AR4 final report, Intergovernmental panel on climate change, 2007.
    12. Russell G. CSIRO Perfidy, Vivid Publishing, Fremantle WA, 2009.
    13. Eshel G & Martin P. 'Diet, energy, and global warming'. Earth Interactions, 10(9), 2006.
    14. Wilkenfeld G et al. 'End Use Allocation of Emissions: Report to the Australian Greenhouse office.' Technical report, Australian Greenhouse Office, 2002.
    15. Australian Collaborative Land Use and Management Program (ABARES-BRS 2010).
    16. Hertwich E, van der Voet E, Suh S, Tukker A, Huigbregts M., Kazmierczyk P, Lenzen M, McNeely J, Moriguchi Y. ‘Assessing the Environmental Impacts of Consumption and Production: Priority Products and Materials, A Report of the Working Group on the Environmental Impacts of Products and Materials to the International Panel for Sustainable Resource Management’, UNEP, 2010.
    17. USDA, 2006. Production, supply and distribution, electronic database.
    18. Fish Farming May Soon Overtake Cattle Ranching as a Food Source, Worldwatch Issue Alert, 03.10.00.
    19. Pimentel D. 'Impacts of Organic Farming on the Efficiency of Energy Use in Agriculture An Organic Center State of Science Review' Cornell University Ithaca NY 2006
    20. Williams, AG. Chatterton, JC. Murphy-Bokern, D, Brander M. Audsley E. 'Greenhouse gas emissions from UK food and drink consumption by systems LCA: current and possible futures' 2010 http://dspace.lib.cranfield.ac.uk/handle/1826/6497
    21. Fraser GE. Diet, Life Expectancy, and Chronic Disease. Studies of Seventh-day Adventists and Other Vegetarians. New York, NY: Oxford University Press; 2003


Page reviewed: 4 February, 2013