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This article first appeared on the author’s Planetary Vegan website on 15th March 2018.


Paul Hawken is an American journalist, author and activist. He recently visited my home country, Australia, to speak about “Project Drawdown“, of which he is the executive director.

The project’s mission is “facilitating a broad coalition of researchers, scientists, graduate students, PhDs, post-docs, policy makers, business leaders and activists to assemble and present the best available information on climate solutions in order to describe their beneficial financial, social and environmental impact over the next thirty years.”

The results of the project were documented in the 2017 book “Drawdown: The most comprehensive plan ever proposed to reverse global warming”, which was edited by Hawken.

Eighty of the one hundred solutions were said to be “well entrenched with abundant scientific and financial information about their performance and cost”. The other twenty were described as “coming attractions” that are “forthcoming and close at hand”.

In what may be something of a contradiction, all one hundred were also described as the “most substantive, existing solutions to address climate change”.

From an initial review of Drawdown’s findings, I feel there are some aspects worth highlighting, some of which are a cause for concern.

The project focuses on more than drawdown

In relation to climate change, the term “drawdown” generally indicates the act of drawing carbon from the atmosphere. Project Drawdown combines that approach with the aim of avoiding future emissions. Although it is wise to consider each approach, the inclusion of the latter may cause the project’s title to be something of a misnomer.

Plant-rich diet

The researchers ranked a plant-rich diet fourth behind refrigeration, wind turbines and reduced food waste. I was pleased they had investigated the impact of diet, as it is a critical issue that has been ignored by many individuals and organisations campaigning on climate change. However, for various reasons, this solution could have been ranked higher, with a greater impact than indicated in the report.

One of those reasons is referred to in the next item, dealing with the global warming potential of different greenhouse gases.

Another is the fact that the authors of this chapter appear to have ignored the ability of native vegetation to regenerate if production animals are removed from areas that are currently used for animal agriculture.

That contrasts with the chapter on regenerative agriculture, where the authors noted that, apart from deserts and sand dunes, bare land will naturally revegetate.

The chapter on afforestation only considered the option of planting trees, and solely in areas that had been treeless for at least fifty years.

Some examples help to illustrate the importance of this issue:

  • A 2009 study by the PBL Netherlands Environmental Assessment Agency indicated that a global transition to a meat-free or animal-free diet would reduce climate change mitigation costs by 70-80 per cent. A key factor would be the ability of lands cleared or degraded for livestock grazing and feed crop production to regenerate forests and other forms of vegetation.
  • Eastern Australia has been included by WWF in a list of eleven global deforestation fronts to the year 2030 due to concerns over land clearing legislation in Queensland and New South Wales. Two-thirds of clearing in Queensland in the four years to 2015/16 (the most recent reporting period) was of regrowth, indicating the resilience of native vegetation if given an opportunity to recover.
  • Researchers behind a 2005 paper published in Nature estimated that massive portions of the north and south Guinea Savanna in Africa would have a reasonable chance of reverting to forest if livestock were removed. Their status as savanna is anthropogenic.

In addition to the issue of regrowth, two near-term climate forcers, tropospheric ozone and black carbon, are unlikely to have been accounted for in the life cycle assessments utilised by the Drawdown researchers.  They are also generally omitted from official emissions figures, but are prominent in animal agriculture. They remain in the atmosphere for a short period, but have a significant impact.

Loss of soil carbon from grazing and livestock-related land clearing may also have been overlooked.

Allowing for tropospheric ozone, loss of soil carbon resulting from livestock-related land clearing, a 20-year global warming potential (refer below) and other factors, researchers from the Sustainable Society Institute at the University of Melbourne and climate change advocacy group Beyond Zero Emissions (BZE) have estimated that the livestock sector is responsible for around fifty per cent of Australia’s greenhouse gas emissions. The findings were reinforced in a subsequent peer-reviewed journal article, which had two co-authors in common with the BZE paper. The figure compares to the official figure of around ten per cent, as referred to by the Drawdown authors.

The warming impact of greenhouse gases

A shorter time horizon for measuring the global warming potential (GWP) of the various greenhouse gases should have been considered in addition to the more common 100-year period (GWP100).

A commonly cited alternative period is 20 years (GWP20), with the IPCC and NASA providing relevant estimates. The GWP20 for methane is 86 times that of carbon dioxide after allowing for climate carbon feedbacks. Allowing for aerosol interactions, NASA researchers have estimated a multiple of 105.

The issue is critical in the context of climate change tipping points and feedback mechanisms with the potential to lead to runaway climate change over which (by definition) we would have no control.

A shorter time horizon would seem particularly relevant given the project’s focus on the next thirty years, and would have increased the impact of three of the top four solutions, namely refrigeration, food waste and a plant-rich diet.

Managed grazing

All Drawdown’s solutions are said to be “based on meticulous research by leading scientists and policymakers around the world”.

But how meticulous was the research?

The standard may have been lowered for the 19th-ranked solution, managed grazing, which is said to include techniques such as “improved continuous”, “rotational”, “adaptive multipaddock”, “intensive” and “mob” grazing.

Using similar terms, including “rotational” and “mob” plus “regenerative”, “cell”, “adaptive” and “management-intensive rotational”, researchers at the Food Climate Research Network (FCRN) argued in 2017 that the “extremely ambitious claims” made by proponents of regenerative grazing and associated approaches are “dangerously misleading”.

FCRN is based at the University of Oxford. Other institutions that contributed to the relevant publication comprised: Universities of Aberdeen, Cambridge and Wageningen; the Centre for Organic Food and Farming (EPOK) at the Swedish University of Agricultural Sciences (SLU); the Research Institute of Organic Agriculture (FiBL) in Switzerland; and the Commonwealth Scientific and Industrial Research Organisation (CSIRO), Australia.

Although Drawdown credits the initial investigation of managed grazing to Frenchman André Voison in the 1950s, its description of the techniques appears to align with the work of Allan Savory and the Savory Institute. Drawdown states, “managed grazing imitates what migratory herds of herbivores do on wildlands”. Savory argues we must use livestock, bunched and moving, as a proxy for former herds and predators, and mimic nature“.

Hawken, Amory Lovins and Hunter Lovins wrote favourably about Savory’s methods in their 1999 book “Natural Capitalism: Creating the Next Industrial Revolution”. Hunter Lovins is a member of the Savory Institute’s “Advisory Circle”, and defended Savory’s methods in a response to a critique of his work by Guardian columnist, George Monbiot. Hawken has also praised Savory’s work individually.

Two other Savory supporters, Bill McKibben (co-founder of and Adam Sacks, are advisors to Project Drawdown. Sacks and another Savory Institute “Advisory Circle” member, Seth Itzkan, have taken credit for influencing McKibben in his support of Savory’s methods.

In prominent 2010 articles supporting Savory’s methods, McKibben and Sacks appear to have erroneously relied, in part, on what McKibben referred to as “preliminary research” favourable to livestock grazing. Critical measurements within that research were subsequently found to be out by a factor of 1,000. The articles from McKibben and Sacks have never been corrected. (I comment on them in item 2.2 here.)

Similar problems in relation to the same preliminary research have occurred in the work of Australian soils ecologist, Christine Jones, who has been cited by Sacks and others who promote Savory’s methods.

Errors can be difficult to avoid, and in this case the original research was corrected. However, the matter does not appear to have been adequately addressed in the material from McKibben, Sacks and Jones, referred to here, that utlilised it.

The FCRN authors cited a review by Swedish researcher Maria Nordborg, who analysed evidence put forward by the Savory Institute. She found the studies supporting Savory to be scanty, “generally anecdotal” and “based on surveys and testimonies rather than on-site measurements”.

Similarly, a 2014 article published in the International Journal of Biodiversity examined each of Savory’s claims. The authors stated that studies supporting Savory’s methods: “have generally come from the Savory Institute or anecdotal accounts of holistic management practitioners. Leading range scientists have refuted the system and indicated that its adoption by land management agencies is based on these anecdotes and unproven principles rather than scientific evidence.”

Drawdown appears to push aside scientific rigour in defending managed grazing practices. It does so, in part, by arguing that the transition period from traditional grazing to alternative approaches is two to three years, “about the same length of time as most of the studies that question the results shown by proponents”.

It is disappointing that a book which is claimed to be based on meticulous research argues that peer-reviewed papers criticising managed grazing practices are invalid because they are assumed to only cover the period of transition from one system to another. That is not meticulous work by the Drawdown team; it is subjective and extremely questionable.

The managed grazing issue seems almost a central theme for the authors. In addition to the chapter specifically focusing on the issue, it is mentioned in the foreword by Tom Steyer (using the term “regenerative grazing”) and in the chapters headed Plant-Rich Diet; Regenerative Agriculture; and A Cow Walks onto a Beach.

Although managed grazing may be viable on a relatively small scale subject to adequate water resources and livestock controls, it would never be sufficient to feed the masses. Animal-based food production is a grossly and inherently inefficient method of satisfying our nutritional requirements, and has a far greater impact on the natural environment than animal-free options. It causes us to use far more resources, including land, than would otherwise be required.

Permafrost and the mammoth steppe

A similar approach seems to have been taken in relation to the “coming attraction” of repopulating the mammoth steppe with grazing animals, as proposed by Russian scientist Sergey Zimov.

The steppe is a massive ecosystem that once extended “from Spain to Scandinavia, across all of Europe to Eurasia and then on to the Pacific land bridge and Canada”.

It contracted nearly 12,000 years ago, around the end of the most recent ice age. Large herbivores that once grazed its extensive grasslands also largely disappeared.

Zimov argues that reintroducing grazing animals would promote grasslands and remove the supposed insulating effect of snow on permafrost due to the animals’ practice of removing it in order to access pasture. He contends these  changes, along with a related restriction in wooded vegetation, would prevent the melting of permafrost, which would be critical to any efforts to overcome climate change.

Central to Zimov’s argument is the belief that the nature of the steppe’s flora changed due to hunting, which caused the extinction of large herbivores that once populated the region, keeping wooded vegetation in check and acting in favour of perennial grasslands.

The conventional view, on the other hand, is that the animals became extinct because of the warming climate, resulting in the growth of wooded vegetation at the expense of grassland.

The Drawdown authors flippantly disregard conventional “published papers” that have been unable to “taint” Zimov’s excursions in the mammoth steppe. Do those papers count for nothing in a project based on “meticulous research”?

A major concern with Drawdown on this issue is the sheer scale of the permafrost problem.

Permafrost is soil, sediment or rock that remains at or below 0°C for at least two years. It covers around twenty-four per cent of exposed land in the northern hemisphere and extends to offshore Arctic continental shelves. It ranges in thickness from less than 1 metre to more than a kilometre.

The Earth’s atmosphere contains about 850 gigatons of carbon. Researchers at the National Snow and Ice Data Center estimate that there are about 1,400 gigatons of carbon frozen in permafrost.  Figure 1 illustrates the extent of permafrost in the northern hemisphere.

Figure 1: Permafrost map. Darker shades of purple indicate higher percentages of permanently frozen ground.

NSIDC Map by Philippe Rekacewicz, (Used with permission)


With rising temperatures, the permafrost has begun to thaw, releasing methane and carbon dioxide from decomposing organic matter within.

The release of those greenhouse gases creates a significant climate feedback mechanism, as it causes more warming, resulting in more thawing, then more warming, and so on.

The Drawdown authors seek to add perspective to the potential impact of Zimov’s attempt to preserve permafrost by stating: “If it came to pass, it would be the single largest solution or potential solution of the one hundred described in this book.”

But could Zimov’s efforts, if we were to assume his theory was sound, put even a dent in the permafrost problem?

In 2011, the Russian head of the International Arctic Research Centre at the University of Alaska Fairbanks, Igor Semiletov, was astonished by the extent of methane being released from permafrost in the seabed of the East Siberian Arctic Shelf. He said:

“We carried out checks at about 115 stationary points and discovered methane fields of a fantastic scale – I think on a scale not seen before. Some of the plumes were a kilometre or more wide and the emissions went directly into the atmosphere – the concentration was a hundred times higher than normal.”

Five years later, Dr Semiletov reported:

“The area of spread of methane mega-emissions has significantly increased in comparison with the data obtained in the period from 2011 to 2014. These observations may indicate that the rate of degradation of underwater permafrost has increased.”

Quite apart from the massive scale of the permafrost problem, would not the methane emissions from a growing population of ruminant animals such as bison, oxen and reindeer be a concern?

Seaweed and methane

In a chapter with the title “A cow walks onto a beach”, the authors highlight the ability of a livestock feed supplement containing the seaweed species, Asparagopsis taxiformis, to reduce methane emissions.

A key difficulty with this potential solution would be its application, which may be limited to dairy and feedlot animals, where the inclusion of dietary supplements is a straightforward process.

The emissions intensity of dairy products and beef from feedlot cattle and the dairy herd is already extremely low compared to that of specialised beef from grazing animals, meaning that the relative benefits of the supplement may be smaller than initially assumed.

Some more research that is far from meticulous

Some more examples of material that is inconsistent with Drawdown’s claims of scientific rigour and meticulous research may be worth mentioning.

Percentage of land surface

In the section on silvopasture, the authors claim that cattle and other ruminants require 30 to 45 per cent of the world’s arable land (my underline). However, the cited sources based their figures on the world’s total land surface, not just arable land.

At the time of writing, the name of one of the editors, Veerasamy Sejian, had been omitted from the relevant source on the Drawdown website.

Gigaton volume

In a section on numbers, the authors seek to demonstrate the volume of a gigaton of carbon dioxide. However, they use the volume of a gigaton of water, which represents a small fraction of a gigaton of carbon dioxide’s volume.

To illustrate the dimensions, they use 2016’s emissions of 36 gigatons of carbon dioxide, indicating they would equate to around 14 million Olympic-sized pools. That is based on the fact that one tonne of water occupies one cubic metre.

However, one tonne of carbon dioxide occupies not 1 cubic metre, but 534.8! That is 8.12 x 8.12 x 8.12 metres, not 1 x 1 x 1.

Figure 2: Volume of one tonne of carbon dioxide


That means that 36 gigatons of carbon dioxide equates to around 7.7 billion Olympic-sized pools, not 14 million.

1.5°C vs 2°C

In their comments on the mammoth steppe (referred to earlier in this article), the Drawdown authors paint a clear line between the impacts on permafrost of temperature increases of 1.5°C and 2°C. In reality, there is no distinct line between the two.

They suggest that, beyond 2°C, “the emissions released from the permafrost will become a positive-feedback loop that accelerates global warming”. However, that is already happening; it is simply a question as to how strongly the feedback mechanism operates at different temperatures.

Carbon dioxide vs methane

Also in the section on the mammoth steppe, the authors refer to the release of “carbon and methane” to the atmosphere.

It is important to note that both carbon dioxide (CO2) and methane (CH4) contain carbon atoms. The authors may have meant “carbon dioxide and methane” but their intention is unclear.

Where did the nitrous oxide and carbon dioxide go?

In the chapter on seaweed and methane (“A cow walks onto a beach”), the authors correctly point out that methane emissions from enteric fermentation in the digestive system of ruminant production animals represent around 39 per cent of greenhouse gas emissions from livestock production.

They then mention that methane is not the only greenhouse gas caused by livestock, but fail to mention the others. They simply indicate that feed production and processing accounts for around 45 per cent of livestock-related emissions. Those emissions are split fairly evenly between carbon dioxide and nitrous oxide.

Using the authors’ source document (from the UN FAO) the split is: methane 43.8% (including manure management and rice used as animal feed); nitrous oxide 29.3%; and carbon dioxide 26.9%.

Those apportionments are based on a 100-year global warming potential for measuring the relative impact of the various greenhouse gases. Based on a 20-year GWP, methane’s share increases to 66 per cent.

Animal suffering, human health, and more on climate change

The Drawdown authors appear to have fallen for the trap of assuming that animal agriculture outside the regime of factory farming has little negative impact on animals, human health and the climate. For example, they claim that there are “reams of data” regarding the contribution to climate change of conventional cattle raising systems that involve feedlots. But where is the data indicating such systems are worse than alternative forms of animal agriculture?

To the contrary, researchers from the USDA’s Agricultural Research Service, Texas A&M University and Australia’s CSIRO have reported that ruminant animals eating grass produce methane at four times the rate of those eating grain. [Footnote]

Similarly, Professor Gidon Eshel of Bard College, New York and formerly of the Department of the Geophysical Sciences, University of Chicago, has reported, “since grazing animals eat mostly cellulose-rich roughage while their feedlot counterparts eat mostly simple sugars whose digestion requires no rumination, the grazing animals emit two to four times as much methane”.

The UN Food and Agriculture Organization (FAO) has estimated that specialised beef from grazing animals is around 6.4 times as emissions intensive as that from animals partially reared in feedlots (95.1 kg CO2-e/kg product vs 14.8 CO2-e/kg product).

In terms of human health, an April 2016 study by researchers from the University of Oxford estimated that if the global population were to adopt a vegetarian diet, 7.3 million lives per year would be saved by 2050. If a vegan diet were adopted, the figure would be 8.1 million. More than half the avoided deaths would result from reduced red meat consumption.

The results primarily reflect anticipated reductions in the rate of coronary heart disease, stroke, cancer, and type 2 diabetes. They apply to all forms of red meat, and are consistent with findings of the World Health Organization, the World Cancer Research Fund and researchers from Harvard Medical School, Harvard School of Public Health, the German Institute of Human Nutrition, and elsewhere.

Alternative farming systems are not generally cruelty free. For examples, most jurisdictions permit horrendously cruel practices through exemptions to prevention of cruelty legislation in favour of the livestock sector. In terms of cattle, permitted practices generally include (without pain prevention or relief): castration; dehorning; disbudding; hot iron branding; and forced breeding, often involving artificial insemination. Such breeding practices cause the animals to be sexually violated, and may be considered illegal outside the food production system.


The Project Drawdown concept has much merit, but its excessive support for animal agriculture appears to conflict with its stated aims. For many who are following it in the hope of finding solutions to the climate crisis, the project may help to justify existing dietary patterns. However, a general transition away from animal agriculture is necessary, and should not be too high a price to pay in exchange for retaining a habitable planet.


Paul Mahony


Although the CSIRO subsequently reported a reduction of around 30 per cent in emissions from the northern Australian cattle herd, emissions from grass-fed cattle remain on a different paradigm to those of most food-based emissions.


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Volume Calculations

1 gigaton = 1 billion tonnes

1 tonne of H2O = 1 cubic metre

1 tonne of CO2 = 534.8 cubic metres

1 gigaton of H2O = 1,000,000,000 cubic metres

1 gigaton of CO2 = 534,800,000,000 cubic metres

36 gigatons of H2O = 36,000,000,000 cubic metres

36 gigatons of CO2 = 19,252,800,000,000 cubic metres

1 Olympic-sized pool = 2,500 cubic metres

36 gigatons of H20 = 14,400,000 Olympic-sized pools

36 gigatons of CO2 = 7,701,120,000 Olympic-sized pools


Drawdown’s figures are based on metric, rather than imperial, tons.

At standard pressure and 15°C, the density of carbon dioxide gas is 1.87 kg/m3. One tonne of carbon dioxide gas occupies 534.8 m3. It would fill a cube 8.12 x 8.12 x 8.12 metres, compared to a tonne of water, which would fill a cube 1 x 1 x 1 metres.


The item “Animal suffering, human health, and more on climate change” was added on 15th March 2018, subsequent to the initial release.

New paragraph and reference added in relation to managed grazing on 18th March 2018.

This post highlights some material from this site’s memes and charts page, focusing on animal slaughter and meat production figures from 1961 to 2016.

Although there appears to have been significant progress in veganism (from a small base) in many countries, there is a long way to go on a global basis, with a strong overall increase in slaughter numbers over the full period and in recent years. For example, in the ten years from 2006 to 2016, the annual number of animals slaughtered globally increased by 19 billion, or 34 per cent, to 74.1 billion.

In 2016, we slaughtered a staggering 2,352 animals per second, on average.

The animals paying the highest price are chickens. In 2016, 65.8 billion of them were slaughtered for meat, representing 89 per cent of the total. The figure does not include male chicks gassed or macerated (using a conveyor belt and industrial grinder) on the first day of life in the egg industry. As they cannot lay eggs, they are considered waste.

There has been an increasing preference for the flesh of chickens over the flesh of other animals, such as cattle and sheep. As highlighted in my article, The global slaughter index, anyone adopting such an approach is massively increasing their cruelty footprint.

In the USA, 182 chickens are required to replace the meat from one cow. The figure varies by country, and depends on the average yield of meat from each species. In Australia, 138 chickens are required.

Whether they are a chicken or a cow, animals suffer in almost unimaginable ways. They are regarded by the livestock sector as products or commodities, bred simply for the purpose of being killed. The horror includes legalised and routine cruelty, including practices such as: mutilation without pain prevention or relief; lifelong confinement indoors; and forced breeding with human intervention.

By definition, any form of human intervention is unnatural, and livestock production represents an extreme example.

Here are the latest figures for the world, USA and Australia. The charts reflect absolute and “per person” figures.





We have been conditioned socially, culturally and commercially to ignore the horror that exists behind these charts. They represent hell on earth for animals, but animals are not the only ones paying a price.

Animal-based food production is a grossly and inherently inefficient method of satisfying our nutritional requirements. That is a key factor in it having a far greater impact on the natural environment and the existential threat of climate change than animal-free options. It causes us to use far more resources, including land, than would otherwise be required, and is not sustainable on a scale required to feed the masses.

The livestock sector, with the mass slaughter and environmental destruction it entails, may seem like a juggernaut, but the juggernaut can be stopped. Recognition of its massive scale and impact is an essential step on that path.


Paul Mahony

Data Sources

Food and Agriculture Organization of the United Nations

World Bank


© Tamara Kenneally Photography,


The article was published at 12.13 am on 10th January 2018 Australian eastern summer time, which was 9th January in most parts of the world, including North America.

I did not expect to see significant improvements for animals in the Victorian government’s recently released Animal Welfare Action Plan, so I was not surprised when I read it. [Footnote 1]

It has outlined four areas for action: policy and legal framework; collaboration; education; and compliance and enforcement.

A draft version was released in 2016, and I highlighted two key points in my response:

  • Exemptions to the Prevention of Cruelty to Animals Act in favour of animal-based industries permit horrendous acts of cruelty to occur on a routine basis.
  • The community should be informed of the reality through advertising, public relations and product labelling, to enable informed purchasing decisions.

Neither issue has been addressed in the final plan, despite references to “care and respect” and “consumer confidence” (as referred in more detail below).

The government still claims elsewhere, as it has for over three years, that the exemptions do not permit cruelty to occur. That is an outrageous claim, which shows no respect for animals or people seeking information on the issue. By their nature, the exemptions permit cruelty.

Such government doublespeak is consistent with the failure to adequately address community education in the plan, with its intention (for example) to communicate “information about . . .  good practice husbandry”, as referred to under the item “improve general animal welfare knowledge”.

It appears that most animals have again been abandoned for the sake of political support from animal-based industries and others, with the government trying to give the impression that something meaningful has been achieved. (In referring to “most animals”, I note that the government has indicated there are more that 150 million farm animals in Victoria, compared to 6.7 million companion animals.)

The focus is unashamedly welfare rather than rights. A welfare approach treats the question of rights as a one-way street by taking the position that humans have the right to exploit animals.

It looks like a business plan

The banner heading for the plan’s vision and purpose is: “Victoria cares”

But does it?

The vision:
A Victoria that fosters the caring and respectful treatment of animals.”

The purpose:
“To ensure Victoria continues to improve animal welfare and is well respected globally for animal welfare practices.”

It seems the plan has been created largely with the aim of ensuring that Victoria is well respected globally, with the related aim of protecting export markets.

Most animals are clearly regarded by the government as products, with reference to “production animals” and “ethical and responsible animal production”. However, it is not in an animal’s interest to become someone else’s product.

That means they are being exploited.

Exploitation is unethical.

It is irresponsible.

It does not reflect “caring and respectful treatment”.

With contradictions such as those, the “vision and purpose” statement does not represent a strong base on which to establish a plan for the benefit of animals. They are only some of the contradictions and inconsistencies within, or related to, the plan.

The vision statement also refers to the need to avoid “unnecessary” harm. However, it is all unnecessary. For example, in respect of diet, both the American Dietetic Association and Australia’s National Health and Medical Research Council have written favourably about a vegan approach.

Within her foreword to the plan, the minister for agriculture, Jaala Pulford, states (with my underlines):

“The government is also committed to promoting market access and maintaining consumer confidence in Victoria’s livestock industries.”

The economic theme is prominent throughout. Here are some more examples (with my underlines):

“The way animals are treated reflects on Victoria’s national and international reputation, including market access, consumer confidence and the ability to create and sustain jobs.”

Australian and overseas markets are experiencing growing demand for humane and responsibly produced food. Many of the world’s food production companies are setting animal welfare standards for their suppliers. Many industry quality assurance programs include animal welfare requirements to provide confidence to consumers and markets about Victoria’s standard of care for production animals. This is important to maintain and expand Victoria’s domestic and global market access in an environment where there is growing demand for animal products that are produced in animal welfare credentialed systems.”

“The new Act must be capable of evolving to keep pace with animal welfare science, community expectations, industry practices, and domestic and international market access opportunities.”

“For example, Victoria’s agricultural industries recognise that animal welfare underpins productivity.”

“The Victorian Government values and continues to support key animal industries and activities, such as agriculture, sport, recreation (including hunting and fishing), research and teaching, invasive species management, pets, breeding and exhibition.”

I accept that economic issues need to be treated seriously by governments. However, animals should not be forced to pay the price for the well-being of the human population. The government is virtually admitting that “production animals” are regarded as economic cannon fodder, while pretending to be concerned about them.

Other animals, such as those used in research, sport and entertainment, are suffering a similar fate, with financial motives again often playing a part.

Some more contradictions and a massive generalisation

In her foreword, Jaala Pulford also states (with my underlines) that we all have a role to play in ensuring the welfare of pets, farm animals and wild animals.

Similarly, the minister’s ambassador for animal welfare, Lizzie Blandthorn, states that we must protect animals from cruelty and support their quality of life, including on farms and in their natural environment.

Those statements are from members of a government that (as indicated earlier) exempts many animal-based industries from the provisions of cruelty prevention legislation.

They are from members of a government that permits the shooting of ducks, kangaroos and other wild animals as “recreation”.

Allowing people to shoot animals “in their natural environment” is not my idea of protecting animals from cruelty. Many suffer horrendously before dying, and those left behind in their family and social groups are forced to fend for themselves, if they are able. Many victims of shooting are supposedly protected species.

A grave concern in respect of kangaroos is that the prime targets of shooters are the largest, strongest individuals, with potentially critical impacts on the prospects of their mob (the term used to describe their group), along with the gene pool and the resilience of the species in increasingly challenging environmental conditions.

The minister also claims that “animal welfare matters to all Victorians”. That is a massive generalisation in a state of over six million people.


Much of the media reporting of the plan’s release focused on the intention to recognise animal sentience within legislation. However, that may be a form of tokenism, without meaningful benefits for animals.

According to the plan:

“Science demonstrates that animals are sentient. This means they experience feelings and emotions such as pleasure, comfort, discomfort, fear and pain. Sentience is the primary reason that animal welfare is so important. All people and industries within Victoria have a responsibility to treat all animals with care and respect.”

Do we really need science to tell us that? Any child who has interacted with an animal knows it.

As to treating animals with “care and respect”, here are some examples of practices permitted by legislative exemptions, most of which I highlighted in a letter to the minister in March 2016 and in my plan submission:


  • life-long confinement indoors;
  • confinement in a sow stall, with insufficient room to turn around, for up to 16.5 weeks, day and night;
  • confinement in a farrowing crate, with insufficient room to turn around or interact with piglets, for up to 6 weeks, day and night;
  • tail docking, ear notching, teeth clipping and castration, all without anaesthetic or subsequent pain relief.

The Australian pig industry’s so-called voluntary ban on sow stalls allows them to be used for up to eleven days per pregnancy, and is not be binding on individual producers. In any event, the ability to monitor compliance is questionable, while the alternative of “group housing” is also inherently cruel.

The industry has not indicated any action in respect of farrowing crates, which are even more restrictive than sow stalls.

Chickens and turkeys:

  • life-long confinement indoors, including (for egg-laying hens) cages;
  • beak trimming of chickens without anaesthetic;
  • removing the snood of turkeys (the skin drooping from the forehead) without anaesthetic;
  • removing terminal segment of males’ inward pointing toes without anaesthetic;
  • killing of “surplus” chicks (mainly male) in the egg industry through gassing with CO2 or by “quick maceration”, whereby they are sent along a conveyor belt to an industrial grinder while still alive.


  • castration without anaesthetic if under six months old or, under certain circumstances, at an older age;
  • dehorning without anaesthetic if under six months old or, under certain circumstances, at an older age;
  • disbudding (prior to horns growing) without anaesthetic. Caustic chemicals may be used for that process under certain circumstances, including an age of less than fourteen days;
  • hot iron branding without anaesthetic;
  • forced separation of cows and calves in the dairy industry within a day of birth to enable human access to the cow’s milk, with most male calves being sent to slaughter and many females retained for future production.


  • forced breeding, often involving stimulation by humans, penetration with artificial devices, and ongoing confinement.

Here’s an image of a calf being branded with a hot iron, which I included in my submission responding to the draft plan.

Here’s an example of group housing of sows, which is the main alternative to sow stalls. [Footnote 2]

What appears to be the intended continuation of exemptions in respect of practices such as those described above is particularly damning when a stated outcome in relation to the legal framework is for the law to provide for “reasonable and considerate treatment of all animals, regardless of species, use or activity”.

Does this mean that the relevant practices are considered “reasonable and considerate” for “production animals”, when many could result in jail terms if committed on companion animals?


With the release of the new plan, the Victorian government has effectively abandoned animals and misled the community.  The plan represents a classic and tragic example of government doublespeak and disregard for others. We and the animals deserve much better.


Paul Mahony


  1. For the purpose of the article, my usage of the word “animal” is based on the definition used in the plan, being “an animal covered by Victorian animal welfare legislation”.
  2. In nature, pigs are clean animals, and do not defecate where they eat and sleep. Wallowing in mud is an evolved behaviour, which they share with other animals, such as the hippopotamus. In a paper published in the journal Applied Animal Behaviour Science, researcher Marc Bracke from the Wageningen University and Research Centre reported that pigs and other wallowing animals did not develop functional sweat glands because wallowing was a part of their lifestyle. The mud now helps them to regulate their body temperature. Most pigs and other production animals lack the opportunity to undertake natural behaviours, with resultant detrimental impacts on their well-being.


Mahony, P., “Submission in Response to Victorian State Government’s Draft Action Plan 2016 – 2021 ‘Improving the Welfare of Animals in Victoria'”, 11th October 2016,

Agriculture Victoria, Department of Economic Development, Jobs, Transport and Resources, “Animal Welfare Action Plan” (accessed 7th January 2018),

Agriculture Victoria, Department of Economic Development, Jobs, Transport and Resources, “Prevention of Cruelty to Animals Legislation”,

Department of Economic Development, Jobs, Transport and Resources, “Victoria’s Animal Welfare Action Plan”, 18th December 2017,

Preiss, B., “New laws to recognise pain and fear suffered by animals”, The Age, 31st December 2017,

Mahony, P., “Open Letter to Jaala Pulford”, Terrastendo, 31st March 2016,

Bracke, M.B.M., “Review of wallowing in pigs: Description of the behaviour and its motivational basis”, Applied Animal Behaviour Science , Volume 132 , Issue 1 , 1 – 13,, cited in Braconnier, D., “Wallowing in mud is more than just temperature control”,, 2nd May 2011,


© Frances Jane Lea, “Alpaca Llama Lama”, Shutterstock

© androdphoto, “Branding a calf”, iStock

©, Golden Grove Piggery, NSW 2013

Related articles

Victorian animal cruelty

In my article “When is a plant-based diet not plant-based and what about health?“, I expressed concern about the fact that Melbourne-based food sciences academic, Katherine Livingstone, had indicated that plant-based diets could legitimately contain meat and dairy products.

In relation to diet, I believe most vegans regard the terms “vegan” and “plant-based” as synonymous. Examples are easy to find, including:

Will Tuttle, author of “The World Peace Diet”

Tuttle refers to “a plant-based way of eating” under the heading “The Vegan Revolution”. He uses the term “plant-based” more than sixty times in his book, usually with the word “diet”, but also with “food”, “meals”, “eating”, “way of eating” and others, and argues strongly against the use of egg and dairy products.

Beyond Meat, a company producing only vegan products

The company refers to its products as “plant-based”.

On its FAQ page, it poses the question: “Beyond Meat® looks just like meat. Is it really vegan?”

The response: “Absolutely. Beyond Meat® products are 100% vegan.”

Beyond Meat has received widespread media attention, including (but not limited to): CNN; Forbes; Fortune; Fox Business; LA Times; New York Times; Wall Street Journal; and Washington Post.

Australian campaign group, Animal Liberation Victoria (ALV)

The term “plant-based” appears dozens of times on ALV’s stand-alone “Vegan Easy” website (including on the page “Why Vegan” and on pages highlighting vegan businesses), and many times on its main website.

A response to my article caused me to look into the issue further. It appeared on the “Cellular” website, which I had not heard of previously. [Footnote]

I was unimpressed with various aspects of the Cellular article, including the fact that the author used the main image from my article and misspelt my name. (Both issues were unchanged at the time of posting this article.)

However, to the extent there are competing views among well-credentialed authors on the subject, the Cellular author had reasonable grounds for an alternative view.

He linked to another article partially addressing the issue, by Martica Heaner, which appeared on the website of the T. Colin Campbell Center for Nutrition Studies. Heaner focused initially on the terms “vegan” and “whole food, plant-based” but also commented on “plant-based”.

She noted that the concept “appears to have been co-opted by many in the non-vegan world”. That notion is consistent with the concern I had expressed regarding potential confusion among consumers.

Nevertheless, those who take the position that the term “plant-based” allows for some animal products may justify their approach through a strict interpretation of the word “base”. For example, the word is defined by the Oxford dictionary as:

“A main or important element or ingredient to which other things are added”

Heaner indicated that prominent author Marion Nestle, from the Department of Nutrition, Food Studies, and Public Health at New York University, re-defined the term “plant-based” when she said in an interview that it “does not necessarily mean vegan, which entirely excludes animal products”.

Other academics who appear to have adopted a similar position include:

  • Frank B Hu of the Department of Nutrition, Harvard School of Public Health. Hu distinguishes between “plant-based” and “strict vegetarian” diets.
  • David Pimentel and Marcia Pimentel from Department of Ecology and Evolutionary Biology, Cornell University. They have referred to the lactoovovegetarian diet (which includes egg and dairy products) as plant-based.
  • Emma Lea, Anthony Worsley and David Crawford from (like Katherine Livingstone) the School of Exercise and Nutrition Sciences at Deakin University. They define a plant-based diet as “an eating pattern that is dominated by fresh or minimally processed plant foods and decreased consumption of meat, eggs and dairy products”.

Another relevant point is that some products consumed by many vegans are not plants or derived from plants. For example, mushrooms are fungi.


To assist in conveying a clear message, I recommend that those who promote a vegan lifestyle or vegan diet avoid using the term “plant-based”.

With benefits for all animals (including humans) and the environment, it should be natural to express and perceive the term “vegan” in an extremely positive sense, and those of us who adopt and promote the lifestyle should be proud to use it.


Paul Mahony


The response to my article appeared without an author’s name on the “Cellular” website. The “About” page refers to the site’s author as Rico.

The Cellular article also criticised various aspects of my involvement with the animal rights group Melbourne Pig Save. I will respond separately to those comments.


Livingstone, K., “Why you should eat a plant-based diet, but that doesn’t mean being a vegetarian”, 13 July 2017,

Heaner, M., “Vegan, Plant-Based Diet or… What Label Works?”, T. Colin Campbell Center for Nutrition Studies, 16 Oct 2015, (The article was utilised for the Cellular article.)

Tuttle, W. “The World Peace Diet”, Lantern Books, 2005,

Hu, F.B., “Plant-based foods and prevention of cardiovascular disease: an overview”, Am J Clin Nutr 2003;78(suppl):544S–51S,

Pimentel, D. & Pimentel M. “Sustainability of meat-based and plant-based diets and the environment”, Am J Clin Nutr 2003;78(suppl):660S–3S,

Lea, E.J., Worsley, A., Crawford, D., “Consumers’ readiness to eat a plant-based diet”, European Journal of Clinical Nutrition (2006) 60, 342–351 (2006), doi:10.1038/sj.ejcn.1602320,


saschanti17, “Healthy homemade chickpea and veggies salad, diet, vegetarian, vegan food, vitamin snack”, Shutterstock

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