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

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General Comments

Re: Public Consultation of the appendix to the Australian Dietary Guidelines “Australian Dietary Guidelines through an environmental lens”.  

As academics and project managers in the fields of nutrition, dietetics and agricultural economics we would like to thank the Australian Dietary Guideline development team for this opportunity to give feedback on the draft appendix “Australian Dietary Guidelines through an environmental lens”.  

We were pleased to see the consideration to the environmental impacts and sustainability of food supply in the finalisation of the guideline. However we have a number of concerns with the document and feel that the document fails to deliver any real direction to all involved in the protection and development of the food supply and environment. 

Principally we feel the environmental, social and economic considerations should be in the main body of the guideline and have influenced the recommendations provided.  Placing this as an afterthought indicates how far behind we are in considering these issues in Australia.

After outlining the components of the food production system in G1, G2 outlines Life Cycle Analysis as a particular methodology, which has limited information. This appendix acknowledges the different components of the food production system, but has not sought information regarding a wide range of other methodologies that explore the environmental impacts of each of these components. Consequently the appendix has not fully considered the breadth of information available to make informed statements in the subsequent sections. There is significant amount of information available to help understand the potential impacts of the Australian Dietary Guidelines on the first stage of the food life cycle.  Key journals and reports to consider in the search for Australian research publications include the Australian Journal of Experimental Agriculture, Australian Journal of Agriculture and Resource Economics, The Australian Rangelands Journal, Journal of Environmental and Resource Management, Environmental Management, Agriculture Ecosystems and Environment, Land Use Policy, and reports generated from the State Agriculture Departments.  

In section G3 ‘The Guidelines through an environmental Lens’ we feel that the practical considerations and environmental benefits are vague and at times misguided and conflicting. They fail to take into account the new ‘Australian Guide to Healthy Eating recommended dietary patterns and serve sizes’ consumer brochure which has been developed with the guideline. In reading the recommended daily number of serves and serve sizes it is clear to see a considerable decline in the amount of breads and cereals recommended and a sharp increase in the amount of lean meat and poultry, fish, eggs, nuts and seeds, and legumes and beans. The food examples provided in the brochure differ for each food group compared to those provided in the previous ‘Food for Health’ and ‘The Australian Guide to Healthy Eating’ consumer brochures of the earlier dietary guidelines. 

The comments on the practical considerations and environmental benefits of each of the guidelines are unsubstantiated and at times have not considered the complexities and heterogeneity of the environmental resource which food is produced on, or the implications through the supply chain. The statements which we feel need further research and consultations include the following: 


 “Within food groups, choosing a variety of nutritious foods may minimise impact and promote biodiversity in food production”.

This statement infers that a supply driven change will result in a wider range of foods produced however does not consider the environmental impacts of that food. The necessary requirements of soil, climate and production practices for food production vary considerably and therefore although a “biodiversity” of foods may be achieved this does not necessarily result in positive environmental outcomes.

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

This statement has not considered the productive capacity of Australian grains or considered the fact that grain producers rotate grain crops to improve soil health, and improve water use efficiency to minimise environmental impacts. It has also not considered that Australian producers operate in a price-taker environment and therefore are also constrained to produce what they can efficiently, over the long term and receive the best profit from.

We agree in principal to the importance of food variety to maintain bio-diversity, minimise the environmental impact and maximise sustainability of a balanced food supply. This statement has been applied, however, without consideration to the foods actually suggested in the appendix or in the serving recommendations in the consumer brochure. For example quinoa is a grain food grown predominantly in South American countries such as Peru, Bolivia and Argentina where Australia has no impact on environmental outcomes. Quinoa is only grown very minimally in Australia and is not well suited to the biophysical conditions of Australian agriculture. To suggest Australians choose to eat quinoa to reduce environmental impact is therefore misleading. It has no impact of biodiversity of Australian land and in considering the transport and distribution costs (environmentally and economically) it is completely unsustainable.

In another example, corn has been suggested in several different forms (fresh corn, polenta, cornmeal) in the consumer guideline brochure. This is in contrast to the consumer brochures related to the pervious dietary guidelines which did not emphasise corn in the same manner. Corn is grown in Australia, however to a much lesser degree then countries in the northern hemisphere. Corn has high water requirements compared to some other grain crops commonly grown in Australia.  Furthermore if Australians were to increase consumption and production of corn for its use as cereal flour, it would inevitably also be used to produce corn syrup. The emphasis on corn therefore not only conflicts with the environmental statement but conflicts with the recommendation to reduce sugar consumption, which we are assuming here does not mean to replace with corn syrup.        

 “Choose protein sources that have a lower environmental impact such as pork, poultry, eggs, tofu, tempeh, nus and seeds, legumes and beans”.

This statement is conflicting with the guidelines consumer brochure which again conflicts with the main body of the guidelines. The draft consumer book ‘Australian Guide to Healthy Eating recommended dietary patterns and serve sizes’ gives no consideration to the environmental, economic, social or health impacts.  The recommendation to dramatically increase lean meat and poultry, fish, eggs, nuts and seeds, and legumes and beans is environmentally unsustainable. Especially when we consider Australian population growth and the predicted continued future exports to our Asian neighbours.  This would be particularly concerning if people in Australia and Asia choose to meet the increased recommendation primarily through red meat and pork. This highlights the need to integrate the environmental perspective with the main body of the guidelines and in particular with the consumer information.

However it is also important to note Australia consists of 43 per cent rangelands (3.2 million km2 ). This high percentage of land is only suitable for the production of beef and goats and would be unsuited environmentally to the production of pork, poultry, nuts and seeds (attempting to grow these foods in this environment is likely to have a greater environmental impact). Environmentally sustainable grazing practices which in northern rangelands include management through stocking to long term pasture availability, rotational grazing, wet season spelling, fire, and land regeneration all reduce the environmental impact of the grazing system. Therefore recommendations for small amounts of red meat per person per week can be produced in Australia (for the Australian population with some export capacity for our near neighbours) in an environmentally sound manner.  Similarly in suggesting pork,  poultry and eggs, the statement has not considered the food sources for these forms of protein is predominately grains, and therefore the environmental impact of grains.

We recommend that rather than avoiding red meat altogether as the statement is suggesting, it may better to provide specific recommendation about the mix of red meat, white meat, eggs, fish, nuts, seeds, and legumes that would best meet nutritional needs and consider the environment simultaneously.

Legumes have the added environmental benefit of returning nitrogen to the soil, and breaking mono cultures in soils for improved soil health and nitrogen fixing qualities. Specific recommendations therefore about the amounts of legumes and lentils (that would best contribute to the lean meat and poultry, fish, eggs, tofu, nuts and seeds and legumes and beans) group would have the added benefit of increased demand for these products. This would make them more viable option to produce in a whole grain or crop production cycle. Thus reducing the amounts of inputs (fertilisers) required, and allow for the production of crops in a more sustainable manner.        

We feel that the public are ill prepared to understand what are ‘stable fish stocks’ and further explanation needs to be provided. 

 “consuming a mix 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”

The reference to the dairy industry being an environmental burden is also unsubstantiated and malicious to the dairy industry. Similarly given that the variety of dairy products produced are all derived initially from milk, the environmental impact from consuming a variety will have no net affect on the environment.

Indigenous Foods and Health

The guidelines and this environmental appendix fail to give consideration to the history of Australia and the understandings of the environment from an Indigenous Australian perspective.  There is no mention of Indigenous food varieties in the current guidelines e.g. kangaroo, bush tomatoes, crocodile, native leek, desert raisin, wattle seed, quandong, and native citrus. Indigenous health issues could be helped by identification of these foods and where they fit within the food guideline.  

In conclusion

Although the appendix has good intent it requires much further research and consultation with key agricultural, environmental and food processing bodies within the food production system. As it currently stands there is little value in having such an appendix. 

 Juliet Wiseman


Lecturer in Nutrition and Dietetics
School of Public Health

Griffith University

Anita Star

PhD, BHlthSc (Nutrition and Dietetics), APD

Senior Lecturer in Nutrition and Dietetics
School of Public Health

Griffith University


Megan Star

B.Agricultural Economics. PhD candidate CQUniversity

Manager Strategic Projects and Planning

Queensland Department of Agriculture, Fisheries and Forestry




Page reviewed: 4 February, 2013