August 6, 2020
SUBMITTED ONLINE
https://www.regulations.gov/comment?D=FNS-2020-0015-0001
Kristin Koegel
USDA Food and Nutrition Service
Center for Nutrition Policy and Promotion
1320 Braddock Place, Room 4094
Alexandria, VA 22314
Re: Report of the 2020 Dietary Guidelines Advisory Committee; Docket FNS-2020-0015
Dear. Ms. Koegal:
I am submitting these comments on behalf of Farm Sanctuary and our 1.2 million members and constituents.
We appreciate the work of the 2020 Dietary Guidelines Advisory Committee and its evidence-based recommendations for the upcoming edition of the Dietary Guidelines for Americans. We are grateful that the Committee acknowledges the significant impacts food has on individual and community health and that our dietary habits are a leading cause of disease in our country. As the report states, “Diet is a modifiable factor that is critically relevant to the primary and secondary prevention of most non-communicable diseases and the leading causes of disability and death affecting Americans.”¹
This sobering assessment points out that over 70% of Americans are overweight or obese, and that the prevalence of these diet related concerns is increasing among younger people.² It also states, “The high rates of overweight and obesity are an important public health problem in and of themselves, and they are a driver for prevalent diet-related chronic diseases, such as cardiovascular disease (CVD), type 2 diabetes, and some types of cancer. At present, 6 in 10 Americans have a chronic condition and 4 in 10 Americans have 2 or more chronic conditions.”³ The sad truth is that we are eating food that is making us sick, which costs our nation billions of dollars in preventable health care costs every year and causes enormous and unnecessary pain and suffering.⁴
Seeking to remedy the prevalence of diet-induced diseases, a growing number of doctors and medical professionals are heeding the advice of Hippocrates, the founder of western medicine, who said “Let food be thy medicine.” These health practitioners are helping patients get off of medication and reverse chronic illnesses, like heart disease, by utilizing a whole food plant-based diet. The Dietary Guidelines for Americans should actively encourage this approach, and we were heartened to see the Committee affirm the benefits of plant-based foods, stating, “Based on its review of the evidence, the Committee confirmed that these Food Patterns represent healthy dietary patterns in that they provide the majority of energy from plant-based foods, such as vegetables, fruits, legumes, whole grains, nuts and seeds…”.⁵
The Dietary Guidelines for Americans have moved toward encouraging plant-based food over the years, recognizing that protein can come from non-animal sources, for example.⁶ However, they continue to be impacted by the undue influence of entrenched interests, like the dairy industry, which has a history of misrepresenting health claims and exploiting government programs at the public’s expense. While the scientific evidence may supports the Guidelines’ recommendation that mothers breastfeed their babies, the scientific evidence does not support the recommendation that children and adults ingest two to three servings of dairy per day.⁷ Dairy products are not healthy, and a large percentage of the population, especially people of color, are lactose intolerant and experience digestive maladies when they consume cows’ milk.⁸ Fact is, cows’ milk is a perfect food for baby calves, but not for humans. It is inappropriate for government nutrition programs to promote and subsidize dairy and other products that threaten public health.
A report published in 2018 found that 73% of dairy industry income came from government programs.⁹ While these programs are purported to help struggling dairies, they have led to industry consolidation and the excess production of milk, which is then purchased by the government and distributed through various channels, including food assistance programs. The Dietary Guidelines for Americans should prioritize good nutrition and public health, and they should not be used to market surplus agricultural products. Our government should stop underwriting and encouraging the overproduction of calorie rich, nutrient poor processed foods and animal products. Instead, public funding should incentivize and support a sustainable, diversified, plant-based food system that aligns agricultural production with healthy dietary patterns, and those healthy dietary patterns should in turn be reflected in the Dietary Guidelines for Americans. Doing so will help remedy a longstanding problem identified by the Committee that, “Dietary intakes have never aligned with the Dietary Guidelines recommendations.”¹⁰
Government programs should invest in agricultural structures and systems that enable healthy eating patterns and a functional marketplace. This means removing billions of dollars in annual government spending for businesses that mass produce unhealthy foods, including processed foods and animal products.
We must also acknowledge disparities in our food system, which reflect broader societal inequities that predominantly harm BIPOC (Black, Indigenous, People of Color) and lower income communities who lack access to healthy food and who experience higher rates of diet related illness.¹¹ Health disparities and high-risk populations have become more visible amid the COVID 19 pandemic, which has killed disproportionately more nonwhite Americans because of food induced risk factors and vulnerabilities. As the Committee recognizes, “Food insecurity and lack of access to affordable healthy food is a persistent problem. In 2018, more than 37 million people, including 6 million children, lived in households that were uncertain of having, or unable to acquire, enough food to meet their needs. Certain populations are disproportionately affected, including low-income, Black non-Hispanic, and Hispanic households, households with young children, and households headed by a single woman or man.”¹² Food assistance programs should prioritize healthy food for lower income and disenfranchised communities, and farm assistance programs should also support and empower communities who’ve lost agricultural opportunities because of systemic racism and structural oppression over many generations.
The Committee is correct in recognizing that agricultural structures and systems impact public health outcomes, stating, “The achievability and maintenance of healthy food and beverage intakes is dependent on a complex number of factors that influence food access, availability, and cost. Long-term maintenance of healthy intakes requires long-term support of associated food systems.”¹³ Improving our nation’s health will also require systemic reforms in agricultural production and distribution.
The food we ingest has profound impacts on our health and wellbeing, and the scientific evidence is clear that our nation’s health is being undermined by eating too many processed foods and excessive quantities of animal products and by consuming too few fruits, vegetables, legumes and other whole plant foods that are rich in fiber and other valuable nutrients. United States citizens deserve honest and accurate guidance, and the 2020 Dietary Guidelines can help improve our nation’s health and lower risks of hypertension and cardiovascular disease, obesity, diabetes, certain cancers, and other food-borne illnesses that sicken and kill millions of Americans every year, while also incentivizing necessary reforms in U.S. agriculture, by encouraging a shift toward a whole food plant-based diet.
We commend the Committee for its work on providing evidence-based recommendations, and we urge the Committee to produce Dietary Guidelines that promote increased consumption of whole plant foods and discourage the intake of meat, dairy, eggs, and processed foods.
Thank you for your time and thoughtful consideration.
Sincerely,
Gene Baur
President and Co-founder
Farm Sanctuary
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1 Dietary Guidelines Advisory Committee. 2020. Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services. U.S.
Department of Agriculture, Agricultural Research Service, Washington, DC, Part A, Executive Summary, p. 2.
2 Id. at Part B, Chapter 2, p. 2.
3 Id. at Part A, Executive Summary, p. 1.
4 Dariush Mozaffarian and Dan Glickman, Our Food Is Killing Too Many of Us: Improving American nutrition would make the biggest impact on our health care. www.nytimes.com, Accessed August 5, 2020, https://www.nytimes.com/2019/08/26/opinion/food-nutrition-health-care.html.
5 Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services, Part A, Executive Summary, p. 12.
6 U.S. Department of Health and Human Services and U.S. Department of Agriculture. 2015–2020 Dietary Guidelines for Americans. 8th Edition. December 2015. Available at http://health.gov/dietaryguidelines/2015/guidelines/.
7 Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services, Part D, Chapter 1, p. 43.
8 Rebecca A Lapides and Dennis A Savaiano, Gender, Age, Race and Lactose Intolerance: Is There Evidence to Support a Differential Symptom Response? A Scoping Review, Nutrients. 2018 Dec; 10(12): 1956.
9 Grey, Shih and Associates. 2018. Congress Thumbs Its Nose at WTO and the Doha Round: US Federal and State Subsidies to Agriculture. 2018. Available at http://www.greyclark.com/wp-content/uploads/2018/02/US-Subsidies-
Post-2014-Farm-Bill-FEB-2018.pdf.
10 Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services, Part D, Chapter 1, p. 87.
11 PolicyLink. 2010. The Grocery Gap Who Has Access To Healthy Food And Why It Matters. 1st ed. Available at https://www.policylink.org/sites/default/files/FINALGroceryGap.pdf.
12 Scientific Report of the 2020 Dietary Guidelines Advisory Committee: Advisory Report to the Secretary of Agriculture and the Secretary of Health and Human Services, Part A, Executive Summary, p. 1.
13 Id. at Part E, Future Directions, p. 6.