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A submission to the Soil Associations’ green paper on air freighting organic products

June 2007

Name: Dr Charles Merfield
Company:  University College Dublin, Republic of Ireland
Job Title: Researcher
Interest / occupation: Research scientist, Soil Association member, and consumer.

Name: Prof Nicholas M. Holden
Company:  University College Dublin, Republic of Ireland
Job Title: Associate Professor of Biosystems Engineering
Interest / occupation: Academic (research and teaching)


The issue of airfreight is a subset of ‘food miles’, which is a nebulous concept when addressing issues of environmental sustainability, in this case the use of fossil fuels in organic production.  Both air transport and food miles are simplistic concepts that are easy for the public to grasp and the media to promote, however, they have very limited scientific and ecological validity and should not form the basis for organic standards under any situation. 
The short answer to the question “Should the Soil Association tackle the environmental impact of airfreight in its organic standards?” is yes, but only within the context of a holistic / systems based approach to the impact of all aspects of organic farming on climate change produced by the use of fossil fuels and the release of anthropogenic greenhouse compounds, i.e., by a complete lifecycle analysis / ecological footprint approach.  If airfreight is addressed in isolation it will be a severe, retrograde move away from the holistic, systems based approach of organic standards. 


The Soil Association (SA) is to be commended in opening and widening its standard setting consultation process to include the general public as well as the traditional stakeholders.  It is also to be commended on moving beyond the customary areas that standards cover, e.g., restrictions on synthetic and potentially dangerous materials from the agricultural production system, to covering wider environmental sustainability issues.  Unfortunately, it has chosen to focus on a highly visible but reductionist and simplistic, even nebulous issue of air freighting of organic produce. 

The irrationality of targeting airfreight

Airfreight of organic and non-organic produce, is a subset of the food miles debate.  The concept of food miles is based on the increasing separation between where food is produced and consumed, which results in food being transported ever-greater distances.  Transportation in the developed world is considered to have a range of negative environmental effects due to it being primarily by vehicles and ships that use combustion engines powered by fossil fuels.  Burning fossil fuels increases atmospheric carbon dioxide concentrations, which is a cause of global warming.  There is also a range of other negative climatic and environmental effects of fossil fuel use.  The simplistic, reductionist analysis of this situation is that the greater the distance a product is transported the more fossil fuel is used and therefore the less environmentally sustainable the product becomes.  Therefore reducing food miles improves environmental sustainability. 

This reductionism is taken a step further in relation to air transport, in that it consumes considerably more fossil fuel per tonne of produce transported per km (tonne km‑1) than road or sea freight and therefore produces more carbon dioxide tonne km‑1 than the alternatives.  Air transport also releases carbon dioxide and other combustion products directly into the upper atmosphere where they have greater negative effects on climate than were they released at ground level.  The reductionist analysis therefore advances that if land and sea transport are bad, air transport is even more so, and should therefore be targeted first. 

It is our view that the reductionist logic associated with considering air freight in isolation is contrary to the holistic, systems based thinking that has been a hallmark of the environmental and organic movements to date.  As air freighting seems to be being used as a surrogate for fossil fuel consumption, a boarder, system-based view is required.  Fossil fuels support practically all aspects of modern organic (and non-organic) agricultural production systems, from farm to fork.  For many production systems, the amount of fossil fuel consumed by post-production transportation is only a small component of the total energy used, even when air freighted.  Therefore focusing on fossil fuel used in transportation fails to address the majority of fossil fuel used in the agricultural production and marketing chain (both organic and non-organic).  It is no more rational to focus on air freight or food miles that focusing only on fuel used by tractors, refrigeration or to heat glasshouses.  If the issue is to be addressed, it should be done on a system basis using the best available scientific methods rather than a by using a convenient, but questionable surrogate.  If the consumption of fossil fuels is to be brought into organic certification standards it is essential that it is introduced on a holistic / systems based approach covering all fossil fuel use, not just transportation or worse air transport. 

Fossil vs. renewable energy

In one year, 174,000 terawatts of energy from the sun traverses the biosphere while total human energy use is 10 terawatts i.e., 0.0057% of the biosphere’s annual energy budget.  The opulent use of energy is therefore not in and of itself a problem if it comes from truly renewable, environmentally sustainable, sources.  Therefore, providing there are no other negative impacts mass transportation of organic produce using renewable sustainable energy is not an inherent problem.  However, in practice this situation does not currently exist, even for many claimed ‘renewable’ energy sources as they are partially or even substantially based on fossil fuels.  This is unlikely to change significantly in the foreseeable future, particularly for transportation.  Despite this, it is essential that from inception, organic certification standards make a clear distinction between fossil derived energy sources and fuels that are truly renewable.  The distinction is required at the start, not just because it is technically correct, but because once standards are written it requires a vast amount of effort to change them, especially those enshrined in legislation. 

Leading on from this, it is essential that standards are clear on what a truly sustainable fuel is.  The only effective way to determine this is through a complete lifecycle analysis (LCA), i.e., the energy used in every single part of the fuel production and distribution systems, their construction and decommissioning must be accounted for and the proportion of that energy that comes from fossil fuel must be subtracted from the energy content of the fuel produced.  Unless there is a positive balance from this calculation, the fuel is not sustainable.  To be practically useful, the energy created needs to be several times the energy put in.  The LCA of the fuel production also needs to consider other costs, e.g., social and environmental impacts.

Energy vs. chemical components of fossil fuels

Fossil fuels not only contain energy but also chemical compounds that are the starting point for the manufacture of a vast array of synthetic compounds, e.g., plastics, that have revolutionised life in industrialised countries.  Many of these starting compounds have yet to be synthesised from their elemental components, or where they have, the economic or energy cost of doing so are prohibitive.  The number of fossil fuel derived products in industrialised countries is so overwhelming it is hard to conceive such societies managing without them for the foreseeable future.  Therefore, the use of fossil fuels as an energy source rather than only using them for the unique chemicals contained within them could be considered a scandalous waste.  Organic agriculture is as dependent on such products and processes as non-organic agriculture, despite a desire not to be.  It is therefore perverse to address the use of fossil fuels within organic standards only in terms of energy, while ignoring their use as a chemical feedstock.  A truly integrated and holistic approach within organic certification regulations towards the use of fossil fuels must encompass both their energy and chemical components. 

Volume of organic airfreight is unknown

As the green paper points out air freighting of food is only a small proportion of total food transportation, although it is now the fastest growing freight sector.  Unfortunately, the green paper states that the amount of air freighting of organic produces is not known.  This is a fundamental flaw in the green paper, in that it is attempting to address an issue of unknown size or importance.  If a proper debate is to be held, it is vital that such information is available. 
While the green paper makes it clear that the data are not being currently separated from non-organic food air freight, i.e., it is not easily available, it is beholden of an organisation such as the SA to make a concerted effort to accurately identify the scale of the issue if it wishes to address the subject.  As indicated by the green paper, the SA already holds considerable data on which of the producers it certifies use airfreight and the quantities they transport, so it appears possible for the SA to determine the amount of organic airfreight by its members and then extrapolate that to the European and ideally global scale based on existing organic production and consumption statistics and then calculate the impact this is having on climate change and compare that with how other aspects of organic agriculture effect the climate.  As this has not been done the whole consultation exercise could be addressing a section of fossil fuel use that only represents a fraction of a percentage of the fuel consumed, i.e., a nearly non-issue.  If so, the return on investment (i.e., the amount of effort put into the consultation exercise compared with the reduction in fossil fuel consumption) would be miniscule and the green paper would be far better addressing the main fossil fuel uses within organic agriculture, which would have a far greater impact on reducing fossil fuel consumption and climate change. 

Integration of energy with other production aspects

It is also of vital importance that regulation of energy within certification standards is fully integrated with the other aspects of production, i.e., the IFOAM principles of health, ecology, fairness and care.  There is only limited value trying to minimise the amount of fossil energy used in a production and marketing system if it results in significant negative effects in other aspects of the production system.  For example, the production of biofuels from food products e.g., the seed of Zea mays and Brassica napus reduces food production due to their being a finite area of farmland.  The use of the non-harvested portion of crops for energy will lead to the depletion of soil organic matter and as a result soil ‘health’ as crop residues are, for many farm systems, the primary source of soil carbon. 

The desire to localise production and consumption is far better founded on principles other than reducing transportation distances, for example, social issues such as forming stable, vibrant communities, and building resilience and redundancy into production and supply systems.  It is also essential that the benefits of local production and consumption are not confused with nationalistic issues.  Buying locally is not the same as basing purchasing decisions on the nationality of the producer or production area.  Ecological processes have no regard for national boundaries, and nor should nationalism play any role in ecologically based purchasing decisions. 

Is the ultimate issue fossil fuel consumption or climate change?

The SA also needs to be clear as to what its ultimate concern is in relation to this consultation exercise.  If the ultimate concern regarding air freight is its impact on climate change, then focusing on air freight may not be the most effective way of reducing organic agricultures’ effect on the climate.  Agriculture effects climate change by a wide range of mechanisms other than burning fossil fuels, for example, soil management and methane produced by ruminants.  It is therefore essential to take a system-based approach to addressing the situation.  If the issue is consumption of non-sustainable fossil fuel stocks, which have a broader use than energy supply, again a system-based approach will yield a better result than taking a simple surrogate of questionable scientific merit.

The way forward

The introduction of regulation of fossil fuel use and/or other agricultural effects on climate change are very complicated issues.  A holistic / systems based approach using methodologies such as complete lifecycle analysis and ecological footprints, are the best approach.  Unfortunately, the science and data needed for such systems are still in development, although considerable progress is being made.  The need to ‘walk before you can run’ in terms of new regulations cannot be overstressed, in that initial regulations should be introduced as broad, high level, statements laying out a framework but with limited detail.  This can be progressively filled in as the debate within the organic movement and the science develops and matures.  This is similar to how other sections of the standards were first created, e.g., in regard to the prohibition of synthetic biocides early standards simply said that as they were novel chemicals, the long-term fate and effects of which could not be predicted in biological systems, so they should not be used in organic production.  As the standards matured ever-increasing detail was given as to which natural chemicals were permitted, restricted or prohibited while maintaining a ban on synthetic chemicals.  The same stepwise approach is needed to address fossil fuel use and climate change. 

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Copyright 2008 Charles N. Merfield.