April 10, 2023

Tina Namian
Chief, School Programs Branch
Policy and Program Development Division, 4th Floor
Food and Nutrition Service
1320 Braddock Place
Alexandria, VA 22314

Dear Ms. Namian:

Pennsylvania Farm Bureau (PFB) is pleased to offer its comments on the proposed rule, “Child Nutrition Programs: Revisions to Meal Patterns Consistent with the 2020 Dietary Guidelines for Americans” (Document ID #FNS-2022-0043-0001).

PFB is the Commonwealth’s largest general farm organization, representing over 30,000 members engaged in all manner of agricultural activities, including the production and processing of crops; the production and processing of animals; the production and processing of forestry products; landscaping and horticultural services; agriculture-related support services; and food manufacturing.

PFB reiterates its staunch support for allowing the National School Lunch Program (NSLP) and School Breakfast Program (SBP) to offer flavored milk options, alongside unflavored options, as part of a reimbursable meal and for sale. Milk, including flavored options, is critical for children and adolescents who may not obtain necessary levels of vitamin D, potassium, high-quality protein, calcium, vitamin A, vitamin B12 and other key nutrients. Consumption of milk dropped from 64 to 54 percent of students when flavored options were removed, and a limited selection and lower consumption contribute to food waste. Additionally, parents—whose tax dollars make the program possible—have shown widespread support for including flavored milk in public school meals for children in their community, with 85 percent of parents nationwide in support, according to a March 2022 International Dairy Foods Association survey.

PFB also strongly supports the return of whole and 2 percent milk, flavored and unflavored, in the NSLP and SBP. Children and adolescents often find whole and 2 percent milk options more palatable than low-fat or nonfat options. As with the removal of flavored milk, restrictions on fat content reduced consumption of vital nutrients by students. Between 2008 and 2018, weekly milk consumption per student dropped more than 15 percent, and student milk consumption dropped more rapidly once whole and 2 percent milk options were removed from schools after implementation of the so-called Healthy, Hunger Free Kids Act.

In addition to contributing to lower consumption, a continued ban on whole and 2 percent milk in schools contradicts modern nutritional science. It is widely recognized by pediatric dieticians that adequate fat intake is essential to proper brain development and to support the energy requirements of young children. Furthermore, numerous recent studies, including 2016 and 2020 articles published in the American Journal of Clinical Nutrition, have revealed the previously assumed correlation between obesity and milk fat content to be false. In this case, at the very least, the most recent Dietary Guidelines for Americans, which effectively prohibit whole and 2 percent milk in schools, are contrary to sound science and, if their creators’ goal was to promote healthy nutritional habits, are a failure in that regard as well.

We are also concerned about the proposal to allow nuts and seeds to credit for 100 percent of the meat/meat alternative component in all child nutrition programs and meals, rather than only credit toward 50 percent of the component at breakfast, lunch and supper while served alongside another meat/meat alternative. Meat is a natural, complete source of protein, providing the body with zinc, iron and B-12 for muscle strength and recovery and to help prevent bone density loss (Vitamin B-12, which is also critical to brain and nervous system functions, is only found naturally in animal products).

Vegetarian diets, in contrast, contain lower amounts of calcium and vitamins D and B-12, all of which play a critical role in bone health, according to the American Journal of Clinical Nutrition. In fact, vegetarians must consume twice the iron to make up for what they miss with a meatless diet, according to McGill University. High-protein, low-carbohydrate diets have also proven to lower blood pressure.

Finally, regarding stricter sodium requirements within the NSLP and SBP, PFB notes that many healthy food options, such as cheese, face feasibility and technical barriers when allowable sodium levels are reduced. Palatability, shelf life and general product functionality can be impacted by mandated shifts in underlying recipes. Further sodium restrictions should neither impede students’ access to nutritious food options like cheese nor make students unwilling to consume those items because of palatability changes. If the goal of these programs is truly to help ensure that kids are healthy and hunger-free, local school districts should be given flexibility in how they meet the nutritional needs of their students without mandatory federal limits.

PFB thanks USDA for the opportunity to provide comments on the proposed rule.

 

Best regards,

Grant R. Gulibon
Regulatory Affairs Specialist