Sent to the Honorable Anita Dunn, Ted Kaufman, Michelle Lujan Grisham, Cedric Richmond, and Jeffrey Zients
Co-Chairs, Transition Team of President-elect Joe Biden and Vice President-elect Kamala Harris

1401 Constitution Ave NW
Washington, DC 20230
Re: Food and Farm Transition Recommendations

Dear Co-Chairs Dunn, Kaufman, Lujan Grisham, Richmond, and Zients,

I write on behalf of Slow Food USA, the national, non-profit organization dedicated to good, clean, and fair food for all.  We advocate for the right of all to enjoy ample, culturally meaningful, biodiverse, sustainably and humanely produced food that is good for: human health and well-being; the health of the planet; and family-scale farmers and ranchers, community-based and tribal fishers, and farm and food chain workers.

At this dark moment in our history, we see opportunities to effectively address longstanding, structural food chain failings that for far too long have plagued our nation – food chain inequity, exclusion, and injustice, our national health and well-being, and the health of our planet.  It heartens us to see the Biden/Harris commitment to Build Back Better.

In full support of this commitment, we call upon our new Administration and Congress to;

• Effectively address food chain structural racism, inequity, exclusion, and injustice,
• Help local and regional, urban and rural, and tribal farm and food economies thrive,
• Ensure that the next generation of farmers, both rural and urban, ranchers, and fishers, including BIPOC producers, is successful,
• Ensure fair markets, programs, and access for farmers, ranchers, and community-based and tribal fishers, with focus on BIPOC producers,
• Re-localize our food chain through strengthened anti-trust laws and enforcement,
• Support science that serves small and mid-scale farmers and ranchers and community based and tribal fishers, with emphasis on BIPOC producers, and ensure that they are central to climate-focused, conservation and regenerative production,
• Implement a national carbon fee and dividend program that would shift the global economy toward practices that respect planetary limits and generate funding for programs to ensure that the burdens of change are equitably shared and guided by social and environmental justice,
• Support the health, dignity, and fair treatment of our essential farm and food chain workers, regardless of immigration status, and provide immigrant farm and food chain workers with a path to citizenship, and
• Because no one in our nation should be hungry, restore and strengthen our nutrition programs – SNAP, WIC, and TEFAP – to increase food security and end hunger by equitably providing low-income people with access to ample food, a healthful diet, and nutrition education that support human health and well-being and sustainable agriculture and fisheries.

Slow Food USA programs are run and operated by volunteers around the nation.

• The School Garden Network cultivates our youth to realize the potentials of their food decisions by teaching them how to grow, cook, and enjoy delicious, healthful food and advocates for school meals that positively impact their health, the health of their communities, and the health of the planet, well into the future.
• Slow Fish turns the tide away from industrial, consolidated, and exploitative seafood production and toward sustainable, community-based, and indigenous fishing communities and their working waterfronts to sustain them and the shared marine ecosystems on which they, and seafood eaters, rely.
• Slow Meat turns the herd away from industrial production that contributes to greenhouse gas emissions, abuses animals, despoils landscapes and waters, exploits family-scale farmers and  ranchers and food chain workers, and encourages excessive meat consumption and towards sustainable, regenerative, humane, and fair production and healthful consumption.

Our decades of engagement in these venues has led us to advocate for federal policies that align with our beliefs and complement our on-the-ground actions.  In support of sorely needed change in our food chain, we offer our recommendations.

Thank you for this opportunity.

Sincerely,

Anna Mulé
Executive Director
anna@slowfoodusa.org

School Garden Network 

In a typical year, our network volunteers will touch about 200 school gardens enabling hands-on experiences of planting, harvesting, and enjoying delicious, healthful food in a supportive, learning environment focused on teaching children to make food decisions that will serve them now and well into the future.  We are proud of our school garden work, but the fact is, there are 100,000 schools and 30,000,000 children participating in the National School Lunch and Breakfast Programs, that provide for about five billion lunches each school year!  Twenty-two million children qualify for free and reduced-price lunches and many rely on these meals to meet half of their nutritional needs. We cannot be successful in achieving our goals if all our children do not have equal benefit of healthful school meals that will support their learning readiness now and their health and well-being in the future.

School Meal Nutrition 

The landmark Healthy and Hunger-Free Kids Act (HHFKA) of 2010 called for:  

• increased servings of fruits, vegetables, and whole grains.  

• low or fat-free milk only; and  

• elimination of most sugar-sweetened beverages.  

HHFKA standards began successful implementation in 2012 with 98% of school districts meeting the guidelines without substantial reductions in school meal participation and no increases in plate waste (the food served but not eaten). Despite these positive outcomes, there was substantial pushback in Congress and by the Trump Administration, a result of lobbying by large food industry groups and complaints from some school districts about increased food costs and plate waste. In response, Congress and the Trump Administration assaulted school food nutrition, endeavoring to establish a lesser nutrition standard for our children’s’ school meals. 

We urge the Biden/Harris Administration and Congress to work together to rescind Trump Administration rules and Congressional actions that undermined HHFKA nutritional gains in school meals and to fully restore HHFKA standards. 

Universal Free School Meals 

School meals reduce childhood hunger, decrease childhood overweight and obesity, improve child nutrition and wellness, enhance child development and school readiness, and support learning, attendance, and behavior.  It is a win/win deal for our children and our future.

We urge the Biden/Harris Administration and Congress to work together to enact the Universal School Meals Program Act that would allow school breakfast and lunch to be offered at no charge to all children, relieve schools of the costly administrative burden of managing a bifurcated, bureaucratic, system of full, reduced, and free meal eligibility and end school food “shaming,” increase federal school meal reimbursement, and award school districts for procuring locally and regionally grown food.

More Time for Lunch 

A recent USDA study shows that the great majority of our schools are meeting the nutrition standards of the Healthy and Hunger-Free Kids Act of 2010. Critics warned that healthier food would mean an increase in food costs and plate waste (the food served, but not eaten). However, even with more schools providing more nutritious meals and more children opting for those healthier meals, food waste, always high, remains so, about 30%.  

Many schools allot just 25 minutes for school lunch. When the bell rings, students leave the classroom, walk to the cafeteria, wait in the food line, choose their meals, and then find places to sit. That leaves far less time for actually eating. This limited time to eat has the greatest impact on children from lower income households, who rely on school meals for a significant portion of their daily nutrition, about up 50 %.  A National Institute of Health study concluded, “Insufficient time to eat…was associated with significantly decreased entrée, milk, and vegetable consumption…. School policies that encourage lunches with at least 25 minutes of seated (eating) time may reduce food waste and improve dietary intake.”

We urge the Biden/Harris Administration and Congress to work together to enact legislation that would

Provide incentives, guidance, technical assistance, and funding to

1. Encourage schools to provide more time for lunch — increasing the average 25-minute lunch to at least 30 minutes, with at least 20 minutes of actual, seated time to eat and

2. Improve school food service infrastructure in kitchens, lunchrooms, and points of service; improve recess and lunch scheduling and supervision; engage student stakeholders; and train kitchen staff to increase scratch cooking of more fresh, nutritious, delicious food.

Farm to School 

Farm to school activities – including procurement of local food for school meals, school gardens, and food and agriculture education – have been proven to help students build healthy eating habits and support family farmers by expanding market opportunities. While more than 42,000 schools across the country – about 42% – are engaged in successful farm to school programming, there is significant room to grow in ensuring that all students and communities can participate.  Since 2013, 1,900 applications requesting over $141 million in support have been received. Presently, with only $5 million in mandatory funding available annually, the existing USDA Farm to School Grant Program has been forced to turn away roughly 80 % of qualified applications.

We urge the Biden/Harris Administration and Congress to work together to enact legislation that would

1. Significantly increase annual mandatory funding for grants and increase the maximum grant award to $250,000,

2. Prioritize grant proposals that engage beginning, veteran, and socially disadvantaged farmers and serve high-need schools,

3. Increase access among Native and tribal schools to traditional foods, especially from tribal producers, and

4. Support schools in low-income, underserved communities, including tribal communities, to support paid, district-wide, school garden coordinators to provide experiential and academic programs to help children to understand, grow, prepare, and enjoy healthful, culturally meaningful, and climate friendly food.

Slow Fish

Our Nation’s fisheries are a renewable economic engine and source of nutritious, wild protein for all. We recognize the U.S. to be a global leader in our sustainable management of our federal fisheries and waters, achieved primarily by the science-based, public processes enacted under the Magnuson-Stevens Fishery Conservation and Management Act (MSA). Under these processes our fishery management councils have already banned destructive practices.

However, we are deeply concerned with the approaches that have been advanced thus far to forward the “30×30” movement (to protect at least 30% of the world’s oceans by 2030 to build ocean life resilience, to adapt to climate change and buffer other threats, such as unsustainable wild seafood harvesting). 30×30 could close large areas of already sustainably managed U.S. waters to commercial fishing using a top-down process that has not fully engaged stakeholders, such as community-based and indigenous fishers.

We urge the Biden/Harris Administration to:

• Rejuvenate federal leadership, policymaking, and funding to support just and meaningful ocean governance.

• Engage meaningfully and equitably with fishing communities and representatives from the seafood system (fish harvesters, processors, chefs, restauranteurs, fishmongers, retailers) as a prerequisite to establishing broad ocean policy goals and seek the active involvement of the people and communities who know firsthand our dynamic federal waters and the interdependent seafood system as key components of our ocean governance strategy.

Specifically, we urge the Biden/Harris Administration to:

1. Ensure that any executive action advancing 30×30 recognizes and directly incorporates the habitat protection processes in place under MSA. Non-destructive, sustainably managed commercial fishing is compatible with habitat protection and conservation of ocean space. Any inventory processes and implementation plans should be consistent with these principles.

2. Strengthen existing collaborative and scientific fisheries habitat protection processes by implementing an Executive Order to direct all federal agencies to avoid, minimize, and mitigate proposed actions that could adversely impact Essential Fish Habitat (EFH), and require that mitigation recommendations provided by NOAA in EFH consultations be adopted by action/lead agencies prior to permitting.

3.Address climate change by strengthening local food systems. Support additional NOAA and USDA funding for wild-capture fisheries in providing food to local and regional economies.

4.Promote global emissions reductions by partnering with fisheries stakeholders. Policies to incentivize carbon reductions are key to protecting our oceans and fisheries, and seafood stake holders and businesses should be viewed as partners in these efforts.

Further, we urge the Biden/Harris Administration to work with Congress to:

1. Broaden input on the Ocean-Based Climate Solutions Act before making any sweeping public announcements and engage in a “Big Table” inclusive discussion to gather intelligence from small-scale fishing communities and members of our domestic seafood systems, including Americans who love seafood. to help shape the policy that will affect them.

2. Reauthorize the MSA to include considerations for climate change, ecosystem-based fisheries management, sustained participation in local/regional fisheries by community-based fishermen and seafood system representatives.

Slow Meat

Covid-19 has shown anew the long-standing failings of our extremely concentrated livestock industry and that this industry, of its own accord, will not fairly treat small and mid-scale farmers and ranchers, protect and fairly treat meatpacking plant workers, who are largely BIPOC, nor adequately address the devastating environmental impacts of industrial scale meat production

Livestock Industry Producer Fairness

The pandemic has vividly exposed vulnerability in meatpacking. We must decentralize and localize the food chain, level the playing field for independent, small and mid-scale, family producers and regional businesses to revitalize our economy, including struggling rural economies, and grow new jobs and new businesses.

We urge the Biden/Harris Administration to:

• Strengthen fair market practices in animal agriculture,

• Decentralize and strengthen the food system by halting new mergers, strongly enforcing antitrust laws, and breaking up mega-corporations, and

• Give DOJ, FTC, USDA and other agencies stronger tools and a mandate to stem the monopolization of the food chain by enforcing antitrust laws.

Specifically, we urge the Biden/Harris Administration to:

1. Refrain from approving new food chain mega-mergers and

• convene a federal inter-agency task force to assess and evaluate the impact of food system mergers on small and mid-scale, family farmers and ranchers, food chain workers, rural communities, consumers, and food system resilience and

• strengthen guidelines to evaluate new mergers and use this evaluation to break up merged companies that engage in anticompetitive practices or have excessive sector and regional market share.

2. Establish a new USDA division to assess the state of competition in agricultural sectors and in regions and recommend cases for federal antitrust authorities (DOJ or FTC) enforcement.

3. Immediately

• Reinstate the Grain Inspection Packers and Stockyards Administration as a stand-alone USDA entity,

• Withdraw the 2020 Undue and Unreasonable Preference or Advantage Rule and replace it with one that actually protects farmers from unfair, deceptive, and discriminatory practices on the part of meatpackers, hog contractors, and live poultry dealers, as intended in the 2008 Farm Bill and in the 2010 rule,

• Restore accurate labeling standards for meat and dairy industry, and

• Reinstate the Organic Livestock and Poultry Practices Rule (OLPP) of January 2017.

4. Initiate new Farmer Fair Practice rulemaking to address anticompetitive practices in the livestock and poultry sectors:

• Make clear that individual farmers and ranchers need not show anti-competitive impact on the entire industry to pursue a complaint under the Packers & Stockyards Act (PSA),

• Eliminate “pro-competitive effects” or “legitimate business justifications” as defenses to claims arising from a meatpackers’ violation of conduct prohibited under the PSA, and

• Address a broader set of criteria and standards regarding livestock and poultry company actions that would be considered violations of the Act.

Further, we urge the Biden/Harris Administration and Congress to work together to:

1. Pass the Food and Agribusiness Merger Moratorium and Antitrust Review Act to halt new mergers until antitrust guidelines are strengthened to better protect farmer, worker, and consumer interests and evaluate impacts on the resilience and competitiveness of the food system.

2. Amend the Packers & Stockyards Act (P&SA) of 1921 to protect farmers from unfair and abusive practices to:

• Prohibit practices that enable meatpacking industries to distort the market price of cattle, including prohibiting packer ownership of cattle in the seven days prior to slaughter, and requiring 50% of slaughtered cattle to come from the spot market,

• Require transparency in contract grower compensation and prohibit “tournament systems” that unfairly pit farmers against each other,

• Provide the USDA with the authority to undertake enforcement against abusive and deceptive practices by integrator companies and eliminating “legitimate business justifications” as a defense for meatpackers’ violations, and

• Protect contract growers from retaliation for speaking out against unfair practices.

3. Give USDA administrative enforcement authority for poultry under the Packers and Stockyards Act and end the bifurcated authority between USDA and DOJ.

Livestock Food Chain Worker Safety and Fairness

Integrators, like giants Tyson and Smithfield, have made huge profits during the pandemic, while workers—who are mostly BIPOC—are compelled to work in crowded meatpacking plants at risk of losing their jobs, even if they are sick. Instead of issuing an Emergency Temporary Standard to protect food chain workers, waivers were issued by the Trump Administration allowing meatpacking plants to increase line speeds, which already were dangerously fast.

Specifically, we urge the Biden/Harris Administration to direct OSHA to:

1. Respond to worker complaints, including treating potential exposure to Covid-19 as an imminent danger, with immediate, unannounced, in-person inspections of workplaces.

2. Ensure that all workers, including those who are undocumented, receive protection from retaliation.

3. Aggressively enforce the Whistleblower Protection Program and the Occupational Safety and Health Act’s requirements, including under the General Duty Clause or any standard issued.

Further, we urge the Biden/Harris Administration and Congress to work together to:

1. Ensure OSHA funding for enforcement and the Whistleblower Protection Program and inspections.

2. Immediately pass legislation to mandate that employers provide premium pay at a minimum of time and a half to all essential, food chain workers, including meatpacking workers, regardless of immigration status given the increasingly hazardous, deadly conditions due to Covid-19.

3. Pass the Safe Line Speeds in Covid-19 Act to prohibit dangerous, higher-speed slaughter systems from operating during the Covid-19 pandemic and direct the Government Accountability Office to review actions taken by the USDA in response to the pandemic to determine their effectiveness in protecting animal, food, and worker safety.

4. Prohibit USDA funds from being used to implement the New Swine Slaughter Inspection System, issue regulatory waivers allowing slaughterhouses to increase line speeds, and draft or implement new rules deregulating slaughter.

Livestock and the Environment

Factory animal farming is a leading contributor to climate change and its consolidation makes our food supply particularly vulnerable to climate and other disasters. Taking animals off the land and confining them in factory farms on a massive scale is a leading driver of climate change and concentrates environmental and health threats by polluting drinking water, poisoning the air, harming the welfare of animals, creating new antibiotic resistant pandemic threats, and spreading toxic pathogens in the soil.

We urge the Biden/Harris Administration to:

• Accelerate the transition to a climate resilient food system

• Rebuild USDA’s research capacity including the Economic Research Service and National Institute for Food and Agriculture with emphasis on climate issues,

• Invest in the transition toward regenerative agriculture through the Conservation Reserve Program, Conservation Stewardship Program, and the Environmental Quality Incentives Program,

• Focus additional aid on deeper investments in pasture and plant-based, regenerative farming and small and mid-scale meat processing facilities to strengthen local and regional infrastructure, and

• Protect community and ecosystem health by restoring vital protections for water.

Specifically, we urge the Biden/Harris Administration to:

1. Prioritize wind and solar through the Rural Energy for America Program (REAP), end support for animal manure biogas projects, and end the USDA-EPA AgStar program.

2. Prioritize Environmental Quality Incentives Program (EQIP) livestock payments for sustainably managed grazing, not CAFOs, in all USDA decision-making (regulation, establishing program priorities, etc.).

3. Place a moratorium on the Farm Service Agency guaranteed loan program backing of new or expanding factory farms.

4. Freeze new guaranteed loans made to livestock and poultry CAFO facilities utilizing production and marketing contracts under the Small Business Administration (SBA) loan program until Congressional action reinstates the SBA final rule on affiliation

5. Oppose public resources and tax (or other) incentives at the federal and state-level from supporting the buildout of animal manure biogas infrastructure; and oppose the inclusion of animal manure-based power in renewable energy definitions for renewable energy credit or other incentive programs.

6. Establish CAFO regulation under the Clean Air Act by developing mechanisms to better monitor air emissions and collect air emissions data to improve understanding of community exposure risks.

7. Regulate factory farms under the Clean Air Act as a stationary source category, establishing performance standards that mandate dramatic reductions in methane and nitrous oxide.

8. Finalize Emission Estimation Methods (EEMs) using all available peer-reviewed data, require Animal Feeding Operations (AFOs) to seek Clean Air Act permits if they emit

9. Restore National Environmental Policy Act (NEPA) protections and repeal the Trump Administration’s illegal NEPA rollbacks rescinding all versions of its guidance and rules exempting CAFOs from reporting under EPCRA and CERCLA.

10. Reinstate the Organic Livestock and Poultry Practices Rule.

Further, we urge the Biden/Harris Administration and Congress to work together to:

1. Repeal the Fair Agricultural Reporting Act

2. Enact  the Farm Systems Reform Act that would invest in a just transition from mega-corporate-controlled factory farming, that is exploiting farmers, ranchers, and workers, animals, and the environment, to farming that would benefit independent, small and mid-scale and tribal farmers and ranchers, rural communities, food safety, human health, clean air and water, and the welfare of animals.

3. Protect community and ecosystem health by restoring previous protections for rivers, streams, lakes, and wetlands and further ensure that Clean Water Act (CWA) protections apply to protecting the groundwater and other drinking water sources from pollution from CAFOs, a significant cause of water degradation.