Reply to USDA Proposed Rule: USDA needs to review the overall proposal to consider the consequences and the impact on schools by making such dramatic changes to the best Child Nutrition Program in the world. Although everyone believes we can always improve the current program, it does not come without costs and challenges that cannot be overlooked. Feeding our children and being sure the neediest are not disenfranchised is key to the programs success. The changes USDA are proposing come with significant cost increases yet only .06 cents per DAY increase in funding. This falls well short of the required funding—this is a huge unfunded mandate that falls squarely on the backs of our children and that is unfair to say the least to them and the program. The unintended consequences that these changes will have are UNKNOWN even by USDA’s acknowledgement. We strongly support the SNA National reply offered to USDA and encourage USDA to reconsider the recommendations and the timeline. The rule imposes an unreasonable timeline due to the complexity of the program, supply chain; procurement and bidding process, menu and recipe changes, and staff retraining in all areas of the school, equipment needs, storage needs, and commodity purchases are just some of the key factors that will be impacted at the operational level of the program. Although it may seem easy to say increase fruits and vegetables, whole grains and reduce sodium- there are so many more complexities to accomplishing these goals that USDA does not seem to be considering with this rule change. Too many changes too quickly are a recipe for disaster- yet schools are held accountable to meet these changes or jeopardize their reimbursement funds. This is unfair to set unrealistic expectations. In order to provide schools adequate time to train staff, secure necessary equipment, change menus, identify new suppliers, and help students adapt to the new meals, we support SNA’s request delaying mandatory implementation of the rule until at minimum the school year 2013-2014. However, we request that USDA be required to PILOT these massive changes to see if they even meet the objective of reducing childhood obesity since schools only provide a minimal portion of the child’s actual annual calories- with 180 lunches and possible serving them breakfast when children consume a minimum of 1095 meals a year not including the snacking they do. We cannot control the outside behavior, physical activity, home environment, fast food /convenience store offerings and the likes. Additionally, forcing children to TAKE foods they do not want does not mean they will CONSUME the item and not wind up in the trash. School’s teaching curriculum MUST include nutrition education. The single major barrier to meeting the new standards is cost: The estimations that if the proposed rule is fully implemented, the cost of preparing a school lunch could rise by more than 15 cents whiles the cost of preparing a school breakfast could rise by more than 51 cents. In addition to purchasing more produce, whole grains and lean proteins, schools will face significant equipment and training expenses. Meeting the new requirements will require schools to secure additional coolers, freezers and dry storage spaces; upgrade small-wares and sinks required to wash and process the additional fresh produce; modify and replace serving lines to accommodate larger portions; and train staff on storage, preparation and service of new menu items. These challenges arrive at a time when schools and states are cash-strapped and reconsidering any financial support of our programs. With harsh winter conditions, world events and commodity shortages have driven food prices to historic heights and these new food costs were NOT factored into the USDA calculations; using out dated data when projecting the cost increase is not fair to the schools that are responsible for operating the programs. In light of cost concerns, we support SNA recommendations that implementation of the revised breakfast meal pattern requirements be delayed until additional funding is available to help offset costs. We also support the requests easing the new meat/meat alternate requirement for school breakfast, which could eliminate popular and healthy breakfast choices.
Additionally, the breakfast changes are so prescriptive that school menu planners will have a difficult time creating menus that are cost effective, meeting the requirements that will be acceptable to the students. The current Breakfast changes will negatively impact the overall objective that USDA has; to close the gap and feed the most venerable students the most important meal of the day. The changes in this rule will quite frankly cause many of our schools to eliminate the breakfast program altogether- unrealistic cost increases will force this decision and this is not the direction we want to go—backwards. We as stakeholders are on the front line feeding our children yet it seems that no consideration has been given to these consequences. Additionally, we support SNA’s recommendation that the weekly requirement for legumes, dark green and orange vegetables be changed to encourage, rather than require, schools to vary vegetable selections (as is currently done in the HealthierUS School Challenge- which is USDA’s own program to incorporate the DGA’s changes recommended in 2005). SNA also calls for easing the proposed rule’s severe limit on starchy vegetables, which include green peas, corn, lima beans and potatoes. The proposed rule impedes school efforts to offer locally grown vegetables throughout the fall and winter, as well as regionally preferred foods such as corn in Mexican dishes and does not take into account salad bars and how vegetables would receive credit for those servings- all addressed in SNA’s comments. Additionally, many upper grade children have different serving lines to select from—if corn is with one meal but broccoli is on another line with another meal how are schools to factor only one starchy vegetable per week? All vegetables should be encouraged-- the preparation method should be addressed prohibiting the method of deep-frying in the cafeteria vs. good food/bad/food of a VEGETABLE of any variety. The proposed rule also calls for unrealistic strict limits on sodium, requiring schools to cut sodium in lunches by more than 50 percent within 10 years. We all agree that the need to reduce sodium exists but takes issue with the rule since USDA cannot even determine in the rule how we will be able to accompolish these severe restrictions. The rule needs to be PILOTED, data collected over time to see the impact on the program and student acceptability. SNA recommends that USDA make an allowance for naturally occurring sodium found in foods like milk and meat and we support that recommendation. Product availability is also a concern when it comes to the proposed rule’s whole grain requirement. SNA points out that “Some regions have little or no supply of whole grain products at the present time, and may have to secure new suppliers.” As such, the Association recommends that implementation of the whole grain requirement be delayed until school year 2013 to 2014. And we support the request that a definition for the CN program be in place at least a year before any required implementation. We have already been well ahead of any other segments with incorporating Whole Grain Rich products into the children’s meals. If USDA is going to make any definition changes or changes to a creditable grain serving size, we will all need adequate time to develop new products- both in schools and or by manufacturers. School nutrition professionals are also worried about how these changes will impact student participation in school meal programs. SNA has asked USDA to monitor changes in participation rates, increases in plate waste and to look at whether students have adequate time, given shortened breakfast and lunch periods imposed by the schools teaching day, to consume the additional amounts of food required by the rule change. We strongly agree with SNA”s position and request that USDA PILOTS these changes and adequately fund the pilot and cost increases before moving forward with implementation. If USDA cannot fund these changes then they need to redevelop a new rule that allows for the required foods. This may take more time but the unintended consequences of schools dropping out of the program and eliminating access is not in anyone’s interest especially our children. We appreciate the opportunity to comment am hopeful that USDA gives strong consideration to SNA’s recommendations and ours.