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

This submission reflects the views of
Organisation Name: 
Department of Agriculture Fisheries and Forestry
Please identify the best term to describe the Organisation: 
Government Department – Federal
Personal Details
General Comments


2 November 2012

The Department of Agriculture, Fisheries and Forestry (DAFF) does not support the inclusion of the Appendix Australian dietary guidelines through an environmental lens in the Australian Dietary Guidelines. DAFF considers that the provision of information on sustainability is not consistent with the legislated aims of the NHMRC with regard to public health and related ethical issues.

The sustainability of food production is a complex issue. The provision of overly simple advice has the potential to mislead and confuse consumers. It is likely that industry stakeholders will raise major concerns about the draft appendix and question the adequacy of the evidence cited to supply the claims made.

DAFF has three main issues with the guidelines:

  1. There are insufficient data or evidence to support the guidelines
  2. The environmental impact of food production cannot be assessed on a commodity basis; it is dependent on where and how the product is grown
  3. The Australian Government does not dictate what farmers grow but does support the uptake of sustainable management practices to facilitate better environmental outcomes.


1.       There are insufficient data to support the recommendations provided in the guidelines

There is a risk that, if challenged by industry or consumers, the NHMRC would not have sufficient evidence to back the following claims in the Australian dietary guidelines through an environmental lens. There are currently some incorrect and unsubstantiated claims outlined below.

Guideline 2

Within food groups, choosing a variety of nutritious foods may minimise environmental impact and promote biodiversity in food production. Choose a variety of seasonal and local fresh fruit and vegetables to reduce environmental impact.

Choosing a variety of nutritious food may not minimise environmental impact or promote biodiversity—for example, some horticultural production systems can tend to have a higher environmental impact than other production systems (if all other variables remain the same). Many horticultural production systems are high intensity and require higher levels of inputs (eg water for irrigation). Traditionally, they have been located in peri-urban environments on small areas of land, limiting the potential to provide biodiversity outcomes.  If horticultural products are grown in unsuitable locations without being properly managed, inputs such as water, pesticides and fertilisers may need to be increased to compensate, which may affect the quality of the soil and impact the quality of other natural resources, such as water. Additionally, storage costs and wastage of fruit and vegetables may also increase the overall environmental footprint of these products.

The department does agree that it is desirable to source a variety of seasonal and local fresh fruit and vegetables to minimise environmental impact.


Varying the types of grain foods you eat may reduce their overall environmental impact

There is no evidence to suggest that consuming varying types of grains would reduce environmental impact. Without knowing the environmental impact of some grain types, it is possible that a consumer may contribute to a greater environmental impact.

Also, some grains require further processing (hence, more inputs) before they can be consumed and may have a greater environmental impact.

Choose protein sources that have a lower environmental impact, such as pork, poultry, eggs, tofu, tempeh, nuts and seeds, and legumes/beans

A high volume of some commodities such as pork are imported. Australia has limited control of how imported commodities are produced and the environmental impact of the production methods. Furthermore, intensive animal industries such as the pork industry may not have a lower environmental impact due to their large water footprint (drinking and washdown), effluent generated, feed source impacts and emissions.

The advice appears to contradict the advice in the Australian Dietary Guidelines about the recognised health benefits of consuming lean red meats and fish.

Additionally, any assertion that red meat such as beef and lamb has a greater environmental impact than intensively produced protein sources fails to recognise the complexities and variation in animal production processes. For example, well managed, low input pasture-based production which focuses on retaining remnant native vegetation, improving biodiversity and increasing perennial native grass species can be among the most sustainable of agricultural enterprises.

Choose fish and other seafood from stable stocks

Advising people to choose fish and seafood from ‘stable stocks’ is unhelpful without supplying any reference to what defines a ‘stable stock’. Asking the general public to second guess the management practices of state and Commonwealth regulators is more likely to lead to poor outcomes than simply recognising that Australian governments take seriously the need to manage fisheries sustainably and the importance of protecting vulnerable marine species.


Australian fisheries are recognised as being among the best managed in the world. Australians can be confident that the pursuit of ecological sustainability is a cornerstone of fisheries management in Australia. Commonwealth fisheries legislation requires that fisheries management takes a precautionary approach and has regard to the impact of fishing on non-target species and the long-term sustainability of the marine environment. The government has implemented harvest strategies in Commonwealth fisheries to manage the risks of fishing on key commercial species, improve productivity and rebuild previously overfished stocks.


All Commonwealth-managed fisheries and those state or territory fisheries which export product are independently assessed under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC ACT) to ensure that, over time, they are managed in an ecologically sustainable way. In addition, the EPBC Act provides explicit protection for threatened and otherwise protected species.

In addition, ‘stock stability’ is not an appropriate indicator of fisheries sustainability. This is because more productive species (e.g. squid, prawns and sardines) tend to have higher rates of natural mortality and reproduce and recruit faster in response to environmental conditions. As a result, these species are subject to significant natural fluctuations in response to environmental factors and, in general terms, are more quickly able to replenish their stocks in response to fishing. On the other hand, those fish stocks which tend to be naturally ‘stable’ tend to be less productive and must be more ‘closely’ managed to avoid overfishing. Proper fisheries management takes account of the productivity and biology of stocks, and so stability is not an indicator of sustainability.

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

All dairy products come from the same source. Cheese and yoghurts may increase the environmental impact due to the activities related to processing.

2.       The environmental impact cannot be assessed on a commodity basis; it is more dependent on where and how the commodity is grown

The production of agricultural commodities is complex and the environmental impacts depend on interactions between the commodity, soil, climate and management practices. Sustainability cannot be categorised on a commodity basis. One commodity may have a limited environmental impact in one region or farm, but a high impact if produced in another region or farm.

3.       The Australian Government does not dictate what farmers’ produce, rather it promotes sustainable management practices

The Australian Government does not indicate to farmers what they can grow or what individuals can eat—Australians are free to make their own choices. It is the farmer that decides the food they produce based on a range of economic, environmental and social factors.

The Australian Government promotes the use of sustainable agricultural practices that maintain and improve the natural resource base by providing support to farmers where there is public benefit and where there is market failure. This support may be through R & D, training and development, and through activities to protect the entry of diseases and pests. The Australian Government does not promote one practice over another; rather it allows a farmer to choose the right management practice for their farming system. The adoption of sustainable practices will result in the provision, support and regulation of a range of essential ecosystem services that benefit the community (e.g. clean air and water, biodiversity etc).

This approach is being delivered through the Caring for our Country initiative that aims to achieve an environment that is healthier, better protected, well managed, resilient, and provides essential ecosystem services in a changing climate. Caring for our Country is a current Australian Government program (2008-13) which has been renewed for another 5 years to 2018. The policy underpinning the program remains the same - to assist farmers and fishers adopt sustainable practices to maintain and improve the natural resource base.

Evidence provided by the Australian Bureau of Statistics through the Agricultural Resource Management Survey indicates that Australian farmers have improved, and continue to improve the management of their land.

Page reviewed: 4 February, 2013