development, or SEED-SCALE. MDG 8 uniquely focuses on donor achievements, rather than development successes. The Commitment to Development Index, published annually by the Center for Global Development in Washington, D.C., is considered the best numerical indicator for MDG 8. It is a more comprehensive measure of donor progress than official development assistance, as it takes into account policies on a number of indicators that affect developing countries such as trade, migration and investment. The MDGs were attacked for insufficient emphasis on environmental sustainability. Thus, they do not capture all elements needed to achieve the ideals set out in the Millennium Declaration. Agriculture was not specifically mentioned in the MDGs even though most of the world's poor are farmers. Alleged lack of legitimacy The entire MDG process has been accused of lacking legitimacy as a result of failure to include, often, the voices of the very participants that the MDGs seek to assist. The International Planning Committee for Food Sovereignty, in its post 2015 thematic consultation document on MDG 69 states "The major limitation of the MDGs by 2015 was the lack of political will to implement due to the lack of ownership of the MDGs by the most affected constituencies". Human rights The MDGs may under-emphasize local participation and empowerment (other than women's empowerment). FIAN International, a human rights organization focusing on the right to adequate food, contributed to the Post 2015 process by pointing out a lack of: "primacy of human rights; qualifying policy coherence; and of human rights based monitoring and accountability. Without such accountability, no substantial change in national and international policies can be expected." Human capital MDG 2 focuses on primary education and emphasizes enrollment and completion. In some countries, primary enrollment increased at the expense of achievement levels. In some cases, the emphasis on primary education has negatively affected secondary and post-secondary education. A publication from 2005 argued that goals related to maternal mortality, malaria and tuberculosis are impossible to measure and that current UN estimates lack scientific validity or are missing. Household surveys are the primary measure for the health MDGs but may be poor and duplicative measurements that consume limited resources. Furthermore, countries with the highest levels of these conditions typically have the least reliable data collection. The study also argued that without accurate measures, it is impossible to determine the amount of progress, leaving MDGs as little more than a rhetorical call