We enclose a commented version of the draft PCR on Meat of mammals. Furthermore, we have the following general comments on chapter 8, which needs to be revised thoroughly in order to ensure that essential emissions not are neglected and that processes and mechanisms that cause emissions are correctly described. Biological processes are essential regarding the environmental impact of animal production and must be considered correspondingly. The PCR states that the upstream module shall include several details about the technical system, e.g. production of detergents for cleaning and packing. Corresponding degree of details should be applied for the biological processes. Any omission of essential biological processes must be commented on and justified.
Some of the emissions omitted are emissions of nitrate (NO3-) from soil to water and aspects of soil carbon. Nitrate leaching is essential regarding the eutrophication potential of crop production. Nitrate will also contribute to GWP. Increase or decrease of soil carbon contributes to GWP, especially when considering ILUC (indirect land use change) and cultivation on organic soils. Guidelines on how to include ILUC needs to be added. In some cases, only a few sources of the pollutant (e.g. NH3) are accounted for. Hence, the environmental impact of the product will be underestimated, especially when main sources of the pollutant are neglected. For example, the only source of NH3 pointed at in the upstream module is NH3 emissions due to spreading of (chemical) fertilizers, but most of the NH3 emissions related to animal production arise in the stable, at storage and spreading of manure, and due to dung deposited during grazing.
Some of the sources of pollutants or mechanisms that cause emissions are described inaccurately. Emissions of NH3, N2O, NOx and P from soil are suggested to be calculated based on the amount of fertilizers applied to the soil. However, these emissions are affected by other parameters (e.g. soil type and precipitation) and activities (e.g. soil management and application of manure) as well. Use of fertilizers cannot be seen as the single explanation for these emissions - emissions of NH3, N2O, NOx and P will occur on unfertilised soils and soils that receive manure. The emission factors used, e.g. that 2% of the N applied to soil via fertilizers is emitted as N2O, needs to be better justified, especially when they deviate significantly from established references such as the IPCC guidelines.
The system boundaries regarding manure management are unclear. Should spreading of manure, or alternative end-use of manure, be included or not? A significant share of the environmental impact of animal breeding is related to the handling of manure, including spreading. Manure is also to a large extent used as an input in the cultivation of animal feed, and emissions related to this used should be accounted for.
The nomenclature needs to be revised and the terms should be used accurately. For example, “soil cultivation” refers to ploughing and harrowing, but excludes harvesting of the crop. “Harvest” is a more adequate term than “feed collection”.
Maria Berglund, PhD
Katarina Lorentzon, MSc
SIK - the Swedish Institute for Food and Biotechnology