Dear Secretary Vilsack, please extend Dietary Guidelines public comment past May 16 and open saturated fat limits for course-correction review!

Screen capture from https://www.dietaryguidelines.gov/

‘Preponderance of evidence’ screams for a Dietary Guidelines course-correction to expand flexibility and increase, not reduce, saturated fat limits as well as to examine the nutrient deficiencies of currently approved dietary patterns in all life stages, and to examine the effects of these overly-prescriptive one-size-fits-all patterns on vulnerable populations in government feeding situations such as children obtaining most of their nourishment at school where DGAs rule.

Editorial opinion by Sherry Bunting, Farmshine, May 6, 2022

Recently, USDA and HHS launched the 2025-30 cycle of the Dietary Guidelines for Americans (DGA). Trouble is, the first and undeniably most important part of the process that will shape WHAT can be amended and the research-screening process for doing so are the “scientific questions” to be examined.

A paltry 30-day public comment period about these already-prepared questions was announced April 15 and expires May 16, 2022.

By the time you read this, there will be fewer than 10 days to comment. To read the USDA HHS proposed scientific questions, click here and to submit a comment to the docket, click here

In addition to the links above, comments can be mailed to Janet M. de Jesus, MS, RD, Office of Disease Prevention and Health Promotion (ODPHP) Office of the Assistant
Secretary for Health (OASH), HHS; 1101 Wootton Parkway, Suite 420; Rockville, MD 20852. Be sure to reference HHSOASH-2022-0005-0001 on the submission.

Lack of time to comment on the questions is not the only problem with the 2025-30 DGA launch. The commenting instructions state: “HHS and USDA will consider all public comments posted to Regulations.gov in relation to the specified criteria. Comments will be used to prioritize the scientific questions to be examined.”

These instructions do not leave much opening to amend the already-prepared scientific questions.

I encourage others to join me in requesting an extension of this comment period to 90 days and to open the process into a course-correcting complete re-evaluation of saturated fat limits — to drive home the point that the “preponderance of evidence” screams for higher, more flexible, saturated fat limits (especially for children), to review the science on saturated fat consumption at all life stages on not only cardiovascular health, but also weight management and diabetes, cognitive health, and other areas, including how current saturated fat limits affect under-consumption of essential nutrients, how these limits affect school meal patterns where most children receive most of their nourishment most of the year — considering the 2020-25 DGA Committee admitted the three government sanctioned dietary patterns are deficient in key nutrients of concern for all age groups.

Join me in asking USDA and HHS to educate the public about the true impact of the DGAs on our most vulnerable populations (children and the elderly) and to avoid prescriptive one-size-fits-all dietary patterns.

People don’t seem to pay much attention to the DGA process because there has been no full disclosure of the true impacts of these so-called “guidelines.” People say, oh, they’re “just guidelines.” Maybe that’s true for you and I, but what about the children? What about the elderly? They are under the ruthless thumb of USDA HHS DGA implementation in feeding programs for America’s most vulnerable ages and demographics.

The ink is barely dry on the 2020-25 DGAs, leaving many to believe there is plenty of time to comment on the next round — later — when the process is fully underway. After all, USDA reminds us this is a five-step process, and they are “committed” to providing plenty of opportunities to be heard.

Wrong. This first step is in many ways the most important for public comment because it shapes how the other four steps unfold. It shapes what research will be screened in and out of the process. It shapes what areas of the DGAs can be amended and specific criteria for how they can be amended — no matter how earthshaking a dietary revelation.

This first step also shapes how your future comments will be considered. For example, many comments, even research in the screening process, will be ignored as this 2025-30 DGA cycle unfolds when it is deemed to fall outside of the specific criteria set in the scientific questions of step-one — right now — for this 2025-30 cycle.

USDA and HHS have already formulated the 2025-30 “scientific questions,” leaving most of the failed guidelines ‘base’ pretty much moving forward — as-is.

One area the Departments announced will run parallel is on ‘planetary diets.’

The USDA HHS announcement notes that the 2025-30 DGAs won’t incorporate DIRECTLY any ‘climate-related’ dietary recommendations, stating: “Sustainability and the complex relationship between nutrition and climate change is an important, cross-cutting, high priority topic that also requires specific expertise. HHS and USDA will address this topic separate from the Committee’s process to inform work across the Departments.”

That’s about as clear as mud. In this statement, USDA seems to tie nutrition and climate change together with the term “cross-cutting,” and describes the “relationship” as a “high priority topic,” assuring us that USDA and HHS will handle this separately and then “inform.”

After looking through the scientific questions in the areas of systematic review and dietary patterns, below is my citizen’s comment: 

————————–

Dear Secretary Vilsack:

To use the phrase you used repeatedly in a Congressional hearing about the 2015-20 Dietary Guidelines, the ‘preponderance of evidence’ on saturated fat limits for all ages — and for children and adolescents in particular — should be up for a complete re-evaluation in the 2025-30 DGAs.

Study after study show our government-sanctioned dietary patterns are failing our children who receive most of their nourishment at school under the thumb of USDA-HHS Dietary Guidelines. USDA even threatens to financially penalize any school that dares make nutritious, wholesome, satiating, healthful whole milk available — even for students to buy from a vending machine run by an FFA chapter seeking to raise funds for agriculture programs, simply because the calories and percent of calories from saturated fat in that nutrient-dense superior beverage exceed your arbitrary, unscientific DGA limit.

But that’s okay, say the HHS USDA DGA, just have a Mountain Dew Kickstart or a sugar-free Gatorade Zero. PepsiCo thanks you, dear USDA, for caring about the profitability of the Smart Snacks empire they and others have built on your say-so, while children become fatter, sicker and sadder and under-consume key nutrients for health and brain power.

Meanwhile, farmers wonder what on earth they can do to get the nutritious, natural, beautiful, local whole milk product they produce to the children in need of nourishment at school, while doctors bemoan under-consumption of nutrients of concern like calcium, vitamin D and potassium (abundant in milk, better absorbed with the fat).

Even the 2020-25 DGA Committee admitted that all three dietary patterns leave all age groups deficient in key nutrients. That’s okay, just get in line for our vitamin pills, right?

It’s even more concerning to see the diets in reality are even worse than they are on paper, if that’s possible, as students pass-over the obligatory skimmed milk in favor of big-brand junk drinks devoid of nutrition, or they take the skimmed milk and toss it into the trash.

USDA’s own study in 2013 showed that in the first year after the Smart Snacks regulations tied competing beverages to the DGAs — outright prohibiting whole milk and 2% milk from schools — student selection of milk fell 24%, and the amount of milk discarded by students increased by 22%. Other studies since 2012 show milk is among the most frequently discarded items at schools. World Wildlife Fund issued a report saying one way to reduce this waste is to educate schools on the fact that they are not forced to serve milk, they can offer it and educate students not to take the milk if they aren’t going to drink it.

What does that solve? It still leaves children and youth without the nourishment USDA touts in the school lunch program on paper even as the school meal situation has become an increasingly restrictive maze of fat limits and thresholds that schools give up managing it and leave it to the ‘Big Daddy’ institutional foodservice corporations with their pre-packaged, highly-processed deals that come with ‘USDA compliance guarantees.’

Why is the Biden Administration fast-tracking this agenda? There are four bipartisan bills before Congress dealing with school milk and others dealing with childhood nutrition. There are bills about allowing whole milk in schools at the state level in Pennsylvania and New York, with lawmakers in at least two other states watching closely to perhaps do the same.

The Whole Milk for Healthy Kids Act to repeal your whole milk prohibition has 93 cosponsors in 32 states. City schools, rural schools, town mayors, boards, teachers, parents, coaches, dieticians, doctors, nurses, farmers — people from all walks of life — and, yes, food and nutrition scientists are increasingly appalled at the school milk and school lunch issues — all under the thumb of the DGAs.

The DGAs are designed in a way that each 5-year cycle builds on the one before it — since 1990! The scientific questions are formulated to keep moving that way instead of looking back and re-evaluating or re-examining nutritional aspects USDA considers ‘settled science.’

In reality, however, there is nothing settled about the DGA ‘science’ on saturated fat. This build-upon process is flawed.

In fact the ‘preponderance of evidence’ would tell us the process should be opened up for a more thorough and reflective review, toward more flexible saturated fat limits — especially to expand overly-restrictive saturated fat limits that are creating concerns for children and youth and, in effect, keep nutrient-dense whole milk and 2% milk, as well as full-fat dairy products out of schools. By these standards, the DGAs actually embrace artificially-created highly processed beverages and foods — even Impossible Burger over Real Beef.

The preponderance of evidence is undeniable. The DGA saturated fat limits are a straight-jacket for schools, imprisoning children into poor nutritional health outcomes that can stay with them the rest of their lives and may affect their abilities to learn. Our future as a nation, the health of our children, the economic standing of our food producers, our nation’s food security, our national security itself are all rooted in these DGAs that are still centered on false narratives about saturated fat that the preponderance of evidence has disproven.

Please extend this comment period to 90 days and expand the input considerations and the process, especially as relates to saturated fat limits for all life stages and evaluate the current patterns for under-consumption of nutrients of concern for all life stages. Simply amending a failed base product is unproductive at best and creates more negative health consequences at worst. We need a DGA course correction, a re-do, rigorous scientific debate, acknowledgment that the science is not settled against fat with the preponderance of evidence moving toward the healthfulness of dietary fat.

Finally, we need a Dietary Guidelines product that serves more broadly as just that — guidelines — not a prescriptive one-size-fits-all straight-jacket that obviously is failing the majority of Americans.

Public discussion about the process is needed in a more open, thoughtful, comprehensive manner before the 2025-30 DGAs get underway.

-30-

Dr. Mitloehner clears the air on ‘net zero,’ sees narrative changing on America’s cows

Dr. Frank Mitloehner is a foremost authority on animal science and greenhouse gas emissions. Find him on Twitter @GHGGuru and @UCDavisCLEAR (Screen capture from American Dairy Coalition webinar)

‘Climate neutrality, not net zero carbon, should be dairy’s goal.’

By Sherry Bunting

‘Net zero’ seems like a simple term, but it’s loaded, according to Dr. Frank Mitloehner, professor and air quality specialist with the Department of Animal Science at University of California-Davis. 

He firmly believes dairy can be a climate solution, but the first step is to accurately define dairy’s contribution to the climate problem. Setting the record straight is his prime focus, and he also researches ways dairy, like every industry, “can do our bit to improve.”

Presenting on what ‘net zero’ really means for dairies, Mitloehner answered questions during the American Dairy Coalition (ADC) annual business meeting in December, attended by over 150 producers from across the country via webinar.

Based in Wisconsin, ADC is a national producer-driven voice with a regionally diverse board. President Walt Moore, a Chester County, Pennsylvania dairy producer, welcomed virtual meeting attendees, and CEO Laurie Fischer shared a federal dairy policy update. 

She said the ADC board is nimble, moves quickly, and wants to hear from fellow dairy farmers. She encouraged membership to make ADC stronger and shared about the organization’s federal policy focus in 2021 — from pandemic disruptions and assistance, Federal Order pricing, depooling and negative PPDs to real dairy label integrity, whole milk choice in schools, and farmers’ questions and concerns about dairy ‘net-zero’ actions.

“Too often, farmers think they may not understand something, so they don’t speak up,” said Fischer. “But we get calls and so much great advice from our farmers. We know you get it, you know it, because it is happening to you.” 

From this farmer input, the net-zero topic became the ADC annual meeting focus.

“We are rethinking methane, and this is influencing and shaping the discussion,” Dr. Mitloehner reported. He urged producers to use the information at the CLEAR Center at https://clear.ucdavis.edu/ and to do better networking, to have a better presence on social media. 

This is necessary because the activists are well-connected, and methane is the angle they use in their quest to end animal agriculture. He said Twitter is a platform where many of these discussions are happening. His handle there is @GHGGuru and the Center is @UCDavisCLEAR.

“This is something I have told the dairy industry. They say ‘net-zero carbon’, but they shouldn’t say that because it is not possible, and it is not needed. We need to be saying ‘net-zero warming’. That’s the goal. Then, every time you reduce methane, you instantaneously have an impact that is inducing a cooling effect,” said Mitloehner.

‘Climate neutrality’ is the more accurate term he uses to describe the pathways for U.S. dairy and beef. But it requires getting accurate information into policy in a fact-based way. 

It requires arming people with the knowledge that the constant and efficient U.S. dairy and livestock herds produce no new methane, that they are climate-neutral because not only is methane continuously destroyed in the atmosphere at a rate roughly equal to what is continuously emitted by cow burps and manure, that process involves a biogenic carbon cycle in which the cow is a key part.

One of the issues is how methane from cattle is measured, he said. Current policy uses a measurement from 30 years ago that fails to acknowledge the carbon cycle and ‘sinks’ alongside the ‘emissions.’ 

Mitloehner said accurate information is beginning to change the narrative. This is critical because methane is the GHG of concern for dairy, and the narrative about it has been incomplete and inaccurate. 

As a more potent heat-trapping gas than carbon dioxide, methane becomes the ‘easy’ target to achieve the warming limits in the Paris Accord. Methane was the focal point of ‘additional warming limits’ during the UN Climate Change Summit (COP26) in Glasgow in November.

Putting together the inaccurate narrative alongside international agreements to specifically reduce methane, it becomes obvious why cattle are in the crosshairs. Producers are already in the middle of this in California as methane regulation and carbon credit systems began there several years ago.

As the narrative is beginning to change, Mitloehner sees opportunities. He described the current California ‘goldrush’ of renewable natural gas (RNG) projects where large herds both in and out of state cover lagoons to capture and convert biogas into RNG. The state’s investments and renewable fuel standard provide a 10-year guarantee with the RNG companies typically owning the offset credits that can be traded on the California exchange from anywhere.

Getting the numbers right is mission-critical

“We are far and away an outlier because of our efficiency in the U.S with all livestock and feed representing 4% of the GHG total for the U.S,” Mitloehner confirmed. “Dairy, alone, is less than 2% of the U.S. total.”

This is much smaller than the 14.5% figure that is thrown about recklessly. That is a global number that includes non-productive cattle in India as well as the increasing herds in less efficient developing countries. This number also lumps in other things, such as deforestation.

He said the true global percentage of emissions for livestock and manure is 5.8%. Unfortunately, activists and media tend to use the inflated global figure and conflate it with these other things to inaccurately describe the climate impact of U.S. dairy and livestock herds as 14.5%.

The efficiency of U.S. production and the nutrient density of animal foods must be part of the food and climate policy equation.

Methane is not GHG on steroids

“Without greenhouse gases, life on earth would not be possible because it would be too cold here,” said Mitloehner. “We need GHG, but human activity puts too much into the atmosphere, and the toll is large concentrations.” 

The way all GHGs are measured has to do with their intensity as determined 30 years ago when scientists wanted one global warming potential (GWP) unit to compare cows to cars to cement production and so forth. They came up with GWP100, which converts methane to CO2 equivalents based on its warming potential.

Methane traps 28 times more heat than CO2, but it is short-lived, Mitloehner explained.

“Looking just at the warming potential, you get this idea that methane is GHG on steroids and that we need to get rid of all of it and all of its sources,” he said.

But is this the end of the methane story? No.

Sinks and cycles must count

Mitloehner described how ‘methane budgets’ look at sources and their emissions but ignore the carbon sinks that go alongside and ignore the chemical reactions that result in atmospheric removal of methane as well.

“Plants need sunlight, water, and a source of carbon. That carbon they need comes from the atmosphere to produce oxygen and carbohydrates,” he said, explaining how cows eat the carbohydrates and convert them to nutrient dense milk and beef. In that process, the rumen produces methane.

“Is this new and additional carbon added to the atmosphere? No it is not. It is recycled carbon,” he said.

“Say you work off the farm. You drive and burn fuel, adding new CO2 in addition to the stock in the atmosphere the day before. Stock gases accumulate because they stay in the environment. Currently, agencies treat methane as if it behaves the same way. But methane is a flow gas, not a stock gas. It is not cumulative,” said Mitloehner.

If the same farm has 1000 cows belching today and 1000 belching 10 years ago, those 1000 cows are not belching new methane because in 10 years it is gone from the atmosphere. It is cyclical.

“The take-home message is the carbon that our constant livestock herds produce is not new carbon in the atmosphere. It is a constant source because similarly to it being produced, it is also destroyed. The destruction part is not finding its way into the public policy system… but it will in the future,” he predicts.

Methane drives Paris Accord and COP26

Methane targets are driving intergovernmental agreements wanting to limit the “additional warming impact” of nations and industries.

Currently, cattle are viewed as global-warmers because they constantly emit methane. However, as Mitloehner drilled numerous times, this is not new methane, it is not additive, it is not cumulative. It is recycled carbon.

“If you have constant livestock herds, like in the U.S., then you are not causing new additional warming,” said Mitloehner.

Burning fossil fuels is much different. 

“Fossilized carbon accumulated underground. Over 70 years, we have extracted half of it and burned it, so where is it now? In the atmosphere. We added new and additional CO2 that is not a short-lived gas. It is a one-way street from the ground into the air,” he explained.

The problem for dairy and beef producers is their cattle are being depicted as though their emissions are additive, cumulative, like fossil fuels, which is not true, he said.

Signs the narrative is changing

One promising sign that the message is getting through has come from Oxford researchers acknowledging the constant cattle herds in the U.S. and UK are not adding new warming.

They acknowledge the GWP100 “grossly overestimates” the warming impact of cattle and are working on a new measurement that recognizes constant cattle herds are not adding new warming, said Mitloehner.

Another promising sign is that the International Panel on Climate Change (IPCC) issued a statement recently acknowledging that the current GWP100 overblows the warming impact of cattle by a factor of four. This new information is not in current policy, but it is making its way there.

Tale of two bathtubs

Mitloehner believes it is important to visualize climate neutrality. He described two bathtubs. One has a CO2 faucet with no drain, the other a methane faucet with a drain. Open the faucets, and even at a slow and steady rate, the CO2 bathtub continues to rise, while the methane bathtub drains as it fills to remain at a constant level.

He also explained that over the past 200 years the U.S. hasn’t seen any real change in that methane bathtub because prior to settlement in America, 100 million ruminants — buffalo and other wild herds — roamed. Today, there are around 100 million large ruminants in the U.S. dairy and beef industries.

What has changed is the U.S. does have more liquid manure lagoon storage that is producing more methane than solid manure storage. “But we know of ways to further reduce that,” he said.

Mitloehner pointed out how the current GWP100 poorly estimates the warming impact three example scenarios. If, over 30 years, methane is increased 35% from a source, or reduced 10%, or reduced 35%, the GWP100 would show significant continuous addition of cow-sourced methane in CO2 equivalents for all three scenarios because the destruction of the methane – the drain that operates with the faucet – is ignored.

The proper way to look at this, if the methane increased a lot, is that it would add a lot. But if it is balanced, then there is no new or additional warming. And, in that third scenario, he said, “where we pull a lot from the atmosphere when we reduce methane, it has the same impact as growing a forest.”

Bottom line, said Mitloehner, “We can be a solution and take it to the market and get paid for that,” but current policy does not yet reflect the neutral position of the constant and efficient U.S. herd.

Bullish about the future

‘Net zero’ is a term that is not yet clearly defined, said Dr. Frank Mitloehner several times during the American Dairy Coalition annual meeting by webinar in December. He sees the real goal as “climate neutrality,” to communicate the way constant U.S. dairy herds contribute “no additional warming,” in other words “net zero warming.”

The climate neutrality of U.S. cattle must be part of public policy, he said. Only then will dairies truly be on a path to marketing their reductions as ‘cooling offsets.’

Mitloehner, a University of California animal scientist and GHG expert is bullish about the future of “turning this methane liability into an asset, so if we manage toward reducing this gas, we can take that reduction to the carbon market,” he said.

“When we hear ‘net zero’, we think about carbon, but that would mean no more GHG is being produced, and that is not possible. I have told the dairy industry this for years. Why is (zero GHG) not possible? Because cows always belch, and we can’t offset that, and furthermore, we do not need to offset that because it is not new methane,” said Mitloehner.

On the other hand, “If we replace beef and dairy made in the U.S., this does not create a GHG reduction at all. This is because we are the most productive and efficient in the world,” he said.

Just stopping beef and dairy production here in the U.S. — and picking up the slack by producing it somewhere else or producing something else in its place — creates ‘leakage.’ This leakage, he said, is where the biogenic carbon cycle becomes disrupted. In other words, the bathtub has a faucet that is out of sync with the drain.

California’s RNG ‘goldrush’

Mitloehner touched on the strict California standards that mandate a 40% reduction of methane be achieved by the state by 2030. Again, methane is targeted because of its warming potential per the Paris Accord.

The good news, he said, is California is using incentives to encourage covering manure lagoons to capture a percentage of the biogas bubble so that it doesn’t go into the atmosphere but is trapped beneath the tarp and converted into renewable natural gas (RNG) that can be sold as vehicle fleet fuel to replace diesel. 

Because this RNG comes from a captured and converted methane source, it is considered a most carbon-negative fuel in the state’s low-carbon fuel standard. 

Those credits equate to $200 per ton of CO2 replaced with a carbon-negative renewable, said Mitloehner.

“This is a huge credit. This is why dairies are flocking to get lagoons covered to trap and convert. These credits are guaranteed for 10 years in California, but the anti-agriculture activists are fuming over them,” said Mitloehner.

Of all California investments made toward achieving the 40% methane reduction goal, dairy has received just 3% of funds, but has achieved 13% of reductions so far.

This “carrot” approach has incentivized the biogas RNG projects assuming $4000 income per cow, making an estimated $1500 to $2000 per cow per year on a 10-year California fuel standard guarantee.

Mitloehner noted that the carbon intensity of the reduction is presently viewed as greater when RNG is used in vehicles vs. generating electricity, but right now there is not enough RNG suitable for vehicle use. He sees the fuel use increasing in the future and explained that dairies anywhere can sell into the California market if they capture biogas and convert it to RNG.

The state’s 10-year guarantee has stimulated companies seeking to invest in RNG projects on large dairy farms, where they then own or share the credits.

Mitloehner answered a few questions from producers about the caveats. If the bottom and top of the lagoon are covered, what happens to the sludge that accumulates? He acknowledged there is no satisfactory answer to that question presently.

Another drawback is the technology only works for larger dairies because smaller lagoons won’t have the same breakeven. Community digester models are emerging as well, he said, but they also use clusters of large farms working together.

Soil carbon sequestration

Mitloehner cited soil carbon sequestration as a way dairy farms of any size can be a solution.

It’s the process by which agriculture and forestry take carbon out of the air via the plant root systems that allow the soil microbes to take it into the soil — unless the soil is disturbed by tilling or it is released through fires. With good forest and grassland management, as well as low- and no-till farming practices, carbon can be sequestered to stay in the ground forever, according to Mitloehner.

“Agriculture and forests are the only two ways to do this,” he said, adding that USDA seeks to incentivize practices that take and keep more of the atmospheric carbon in the soil.  

Answering questions from producers, he noted that he has not yet seen a scheme that would incentivize soil carbon sequestration through marketing offsets, but the discussions are heading in that direction.

“Many of the environmental justice communities are running wild on this. They do not want farmers to get any money for it. They are putting on significant pressure and threatening lawsuits, so it’s not settled yet,” he reported.

There is also a lot of confusion around soil carbon sequestration and “regenerative” agriculture. One big problem is that producers who are doing some of these things, already, won’t get the opportunity to capitalize on those practices when offset protocols are eventually developed — if those practices are not deemed “additive.”

“If you are doing something now and are not covered by a policy of financial incentive, then four years from now, if it is developed, they’ll say you don’t qualify because you are already doing it,” said Mitloehner. 

“They are calling it ‘additionality.’ It’s about the change to doing it to qualify. That seems crazy, but it’s like if you bought an electric vehicle 10 years ago when there was no tax credit, you don’t get a tax credit now for already owning an EV because the improvement is not ‘additional,’” he explained.

What about the burps?

For farms with under 1000 cows, other technologies like feed additives can be used on any size dairy with effects realized within a week, said Mitloehner, noting one product that is commercially available and several others on the docket.

If a 10 to 15% reduction can be achieved in enteric (belching) methane reduction, then it will be marketable. Right now, these reductions are not marketable. If an offset protocol is developed for this in the future, it will be taken to the carbon market, he said.

In the meantime, incentives are being offered within supply chains, according to Mitloehner. Companies like Nestle, Starbucks and others are doing pilot projects and buying feed additives for the farmers within their supply chains to reduce their products’ GHG. He said there is some evidence these products can enhance components and feed efficiency. This is a big area of research right now.

A question was also asked during the webinar, wondering about Amish farms using horses instead of tractors. Are they contributing to cooling?

Mitloehner replied that he has not yet seen a calculation for this, and while the impact of horses would be less than the impact of burning fossil fuels, there is still an environmental impact to calculate. 

Since the international focus is on ‘additional warming impact’, methane is – like it or not — the target. Whether a dairy farm is managed conventionally or in the Amish tradition, the cows, the methane, and how governments and industry measure the ‘additional warming impact’ of cow-sourced methane, is still the crux of the issue for all dairy farms. If efficiency is reduced, then the ability to position the dairy farm as ‘cooling’ may be more complicated, or less significant, he said.

In addition to accurate definitions that acknowledge climate neutrality of constant cattle herds producing no new methane, Mitloehner’s wish is for federal policy to also take productivity (and nutrient density) into stronger consideration when evaluating emission intensity “instead of just counting heads of cattle. 

“This can be good for large or small dairies with a high or low footprint. When the relative emissions are determined by how you manage the dairy, the hope is that this is more about the how than the cow.”

-30-

‘Climate-neutral milk?’ Northeast, Southeast milksheds can already claim it

EDITORIAL – OPINION

By Sherry Bunting, Farmshine, July 16, 2021

Farmshine readers will recall coverage of the U.S. Senate Ag Committee’s climate hearing in 2019, when Tom Vilsack, then president and CEO of U.S. Dairy Export Council, lobbied the Senate for climate-pilot-farm-funding. Remember, he announced DMI’s Net Zero Initiative at that hearing – five months ahead of its formal unveiling.

In that same June 2019 hearing, animal scientist and greenhouse gas emissions expert Dr. Frank Mitloehner of University of California-Davis explained the methane / CO2 ‘biogenic’ cycle of cows. 

He said that no new warming, is produced when cow numbers are “constant” in an area because methane is short-lived and converts to CO2 in 10 years time, which is then used by plants, cows eat the plants, and the cycle repeats. It is always cycling.

Dr. Mitloehner also said that this cycle changes when cattle concentrations move from one area to another.

Nationally, dairy cow numbers are rising after decades of declining. However, in the Northeast and Southeast milksheds, cow numbers are declining — and by a wide margin. 

This should indicate net methane reductions in the biogenic cycle or climate-friendly milk for the fluid milk regions of the Northeast and Southeast.

As USDA and the industry coalesce around DMI’s unified approach through the Net Zero Initiative and the work of DMI’s Dairy Scale for Good with partner WWF — stating large integrators can be net zero in five years to spread their climate ‘achievements’ across the footprint of all milk in the dairy supply chain — I have to wonder what this means for the areas of the country beyond the ‘chosen’ growth areas.*(see footnote at the end)* 

Looking at the work of DMI’s Innovation Center and it’s fluid milk revitalization committee, sponsoring the launches of various diluted dairy-‘based’ beverages, something occurred to me from a marketing standpoint.

Here is a thought that could be helpful in the future for whole fluid milk bottled regionally to compete with emerging climate claims of dairy-‘based’ beverages that are made with ultrafiltered solids shipped by centralized cheese and ingredient facilities (without the water) to be reconstituted as mixtures with plant-based alternative beverages for population centers on the coasts.

The milk produced and bottled in the Northeast and Southeast milksheds is not just climate neutral, it’s already offsetting, producing not just no new methane, but less than prior-decades’ methane.

Bear in mind, these new dairy-‘based’ — blended — beverages are NOT Class I products. I have been informed that the 50/50 blends, for example, do not meet the standard of identity for milk, nor do they meet the milk solids profile that requires Class I pricing. This means that even though milk is part of a fluid dairy-‘based’ beverage, it is not priced as Class I.

The milk used in these emerging products that combine ultrafiltered solids with water, additives and maybe an almond or two, fall into Class II or IV, some are Class III if whey protein is used. Examples include products like DFA’s Live Real Farms ‘Purely Perfect Blend‘ that arrived recently in Pennsylvania and the greater Northeast after its first test-market in Minnesota. 

Think about it. Unity is great on many levels, and is to be encouraged in an industry such as dairy, but when it comes to marketing, who is calling the shots for future viability within the DMI integration strategy, otherwise known as unity?

Pre-competitive alliances and ‘proprietary partnerships’ working on food safety are wonderful because all companies should work together on food safety. But animal care? Environment? Climate? Why not just offer quality assurance resources and pay farmers certain premiums for investing as companies would like to see and pay them for providing the consumer trust commodity — instead of implementing one-size-fits-all branches in programs like F.A.R.M.? 

These so-called voluntary programs have the power to negate contracts between milk producers and their milk buyers even though consumer trust is a marketable commodity that producers already own and are in fact giving to milk buyers, and their brands, without being compensated. 

Instead, producers are controlled by arbitrary definitions of the consumer trust commodity that the producers themselves originate. This goes for Animal Care, Worker Care, Environment, and Climate.

The pre-competitive model used in food safety is applied to all four of the above areas today. This is exactly the supply-chain model World Wildlife Fund (WWF) — DMI’s ‘sustainability partner’ — set in 2010 to “move the choices of consumers and producers” where they want them to go.

*footnote

In the 2019 Senate hearing referenced at the beginning of the above op-ed, Dr. Mitloehner stated that the mere fact there are 9 million dairy cattle today compared with 24 million in 1960 and producing three times more milk shows that dairy producers are collectively not only emitting zero new methane, they are reducing total methane as old methane is eradicated by the carbon cycle and less new replacement methane is emitted.

The problem may be this: Year-over-year cow numbers for the U.S. are creeping higher. While still much lower than four to five decades ago, the issue emerging for DMI’s Innovation Center for U.S. Dairy is how to accommodate growth of the new and consolidating dairy structures to attain the checkoff’s expanded global export goal and to accommodate massive new dual-purpose plants if dairy farms in other areas remain virtually constant in size, grow modestly, or decline at a rate slower than the ‘designated’ growth areas are growing.

DMI is at the core of this, you see, to reach it’s new collective net-zero goal, cow numbers would have to decline in one area in order to be added in another area, or they will all have to have their methane buttons turned off or the methane captured because now the emissions are being tracked in order to meet one collective “U.S. Dairy” unit goal under the DMI Innovation Center and F.A.R.M. We don’t even know if they are using this method of calculation. U.S. cows may be on global calculations where numbers are rising.

At that 2019 Senate hearing, Dr. Frank Mitloehner testified that dairies already create zero new methane but this can be tricky when cattle move from one area to another (as we see in the industry’s consolidation). Then we have DMI’s Dairy Scale 4 Good claiming the dairies over 3000 cows can be net-zero in 5 years and ‘spread their achievement’ over the entire milk footprint. Do we see where this is going?

Will all dairy farms have to meet criteria — set by organizations under the very umbrella of the checkoff program they must fund — to get to a ‘collective’ net-zero using the GHG calculator developed by the checkoff-funded Innovation Center in conjunction with its partner WWF (12 year MOU)? This GHG calculator has been added to the FARM program. These are the big questions. Where is the science and the math?

DAIRY SOIs: FDA adopts new YOGURT standards rule, expects MILK rule next year

FDA yogurt standard of identity rule finalized; NMPF is calling it a “robust defense of dairy integrity.” IDFA is saying it is “woefully behind the times.” Frankly, it’s neither. Let’s go behind the mirror, shall we?

FDA yogurt standard of identity rule finalized. NMPF calls it a “robust defense of dairy integrity.” IDFA says it is “woefully behind the times.”

Frankly, it’s neither. Let’s go behind the mirror

By Sherry Bunting, Farmshine, July 16, 2021

WASHINGTON, D.C. — FDA’s new yogurt standard of identity was finalized this week. The final rule was published June 11 and adopted July 12, 2021 after a 30-day comment period. It was a significant part of the hearing that launched the FDA multi-year Nutrition Innovation Strategy (NIS) three years ago.

Industry compliance is set to begin Jan. 1, 2024.

Over the next 30 months, other decisions are on the to-do list for FDA before anyone can consider the yogurt rule a slam-dunk for dairy.

In fact, National Milk Producers Federation (NMPF) and International Dairy Foods Association (IDFA) responded to the new rule immediately with a little good cop / bad cop.

According to NMPF, the new rule “fits changes in yogurt-making technology.”

IDFA disagrees, and is filing a formal objection.

NMPF is calling it a “robust defense of dairy integrity.”

IDFA is saying it is “woefully behind the times.”

Frankly, it’s neither. Let’s go behind the mirror, shall we?

In the rule, yogurt is defined as: “Cream, milk, partially skimmed milk, skim milk, and the reconstituted versions of these ingredients that may be used alone or in combination as the basic dairy ingredients in yogurt manufacture.”

The rule states: “Yogurt is produced by culturing the basic dairy ingredients and any optional dairy ingredients with a characterizing lactic acid-producing bacterial culture.”

In its response, NMPF pointed to this language as “reinforcing the concept that where food comes from, and how it is made, matters.

“Logic matters. Consistency matters. That’s why the new FDA rule that defines what is and isn’t yogurt has much broader, and potentially very positive, implications in one of the most contested consumer issues of the day — the proper labeling of milk and dairy products,” NMPF states.

However, given the fact that FDA is still working on the standards of identity (SOI) for milk and dairy within its larger NIS framework, the biggest questions are still unanswered, and FDA indicated their guidance on milk and dairy SOIs won’t come until June 2022.

The yogurt rule simplifies FDA’s books and offers processors more flexibility, to a point. It revokes the previous individual SOIs for low-fat and non-fat yogurt, making one SOI for yogurt, in which low- and non-fat become labeling modifiers.

The intent of this, according to FDA, is to “modernize SOIs for technological advances while preserving the basic nature and essential characteristics.”

In the 22-page rule, FDA writes: “Any food that purports to be or is represented as yogurt, must conform to the definition standard of identity for yogurt.” — That’s the enforcement piece.

The thrust of FDA’s NIS is explained in documents as moving toward both revoking and modernizing standards so foods can compete on a nutritional basis, and to remove barriers to innovations. This includes determining how plant-based and synthetic alternatives are labeled.

New genetically-altered yeast excreting proteins are being made by companies like Perfect Day Foods, and they are pressuring FDA to designate them as dairy proteins, saying they are identical to casein and whey found in milk. They don’t want these proteins labeled as bioengineered because even though the yeast is genetically altered with bovine DNA, the protein excrement is used, not the yeast itself.

This is a bit of what’s under the surface on the dairy SOIs. 

In January 2020, IDFA had Perfect Day CEO and co-founder Ryan Pandya on an industry panel at the IDFA Dairy Forum in Arizona. During that IDFA Forum, Pandya told Food Dive in an interview that, “Every major multinational (company) is talking to us.” 

Pandya pitched the bioengineered yeast excrement to processors during the IDFA Forum, noting that they work through The Urgent Company, under the leadership of former Glanbia VP of product strategy in a business-to-business model, touting climate impact reductions by ‘partnering’ with the dairy industry to replace just 5% of dairy protein with their analog.

In fact, the January 2020 Food Dive article goes on to quote Monica Massey, an executive vice president and chief of staff for Dairy Farmers of America (DFA), as she told Pandya from the audience during the IDFA panel that she purchased the limited-edition Perfect Day ice cream last year.

“We sat down in a dairy cooperative headquarters and ate it, and I said ‘Oh, we’re screwed’ because it tasted just like ice cream,” Food Dive quotes Massey’s exchange with Pandya during the IDFA Forum. 

“In the industry we get hung up on ‘You can’t call it dairy.’ … (Perfect Day’s) not focused on the cow, you’re focused on the consumer, and we are so hellbent on focusing on the cow, the milk,” said Massey.

(Author’s note: Working for a cooperative owned by dairy farmers does kind of make it about the cows and the milk, but it can still be about the consumers, using the milk from the cows.)

An article posted publicly on the day of the new yogurt rule, July 12, gives us a good idea why IDFA is protesting the new SOI for yogurt, and why the big unanswered questions of milk and dairy identity — that the FDA expects to propose a year from now in June 2022 — are so important as the undergirding for individual SOIs like yogurt.

The July 12 article in Dairy Processing by Donna Berry (who is also a contractor on the payroll of DMI — the national dairy checkoff every dairy farmer must pay into, by law), quotes a representative of Perfect Day talking about the so-called ‘animal-free milk proteins,’ saying they are identical to casein and whey. They are excreted from microorganisms such as bacteria, yeast or fungi, that have been genetically altered with bovine DNA and are grown in fermentation vats on sugar substrate.

(The current, though unenforced, FDA SOI for milk is: “Milk is the lacteal secretion…obtained by the complete milking of one or more healthy cows.” Of course, goat milk would be a consistent qualifier in source, characteristics and nutrition, but almond, oat, soy, bioengineered yeast, are not consistent with that legal definition.)

Without FDA guidance and enforcement of real dairy SOIs for milk, and 80 other products with FDA SOIs that come from milk, what’s to stop “seamless” swapping of bioengineered yeast-excrement in place of dairy protein in standardized dairy products and no bioengineered labeling? What ensures that consumers know what they are consuming, and dairy farmers aren’t put out of business by captive supply in the market and?

Yes, deciding what is and isn’t ‘milk’ and ‘dairy’ is still a huge item on the FDA to-do list.

IDFA is protesting what it says are ‘overly prescriptive’ process requirements in the new yogurt rule they claim are “not current with today’s innovations,” such as requiring cream to be added before, not after, lactic acid fermentation to meet standardized 3.25% fat levels. (That’s a bit of a monkey wrench for Perfect Day.)

Just a few of the other things IDFA is objecting about include the requirement for yogurt that contains ‘non-nutritive’ sweeteners be labeled as ‘reduced calorie’, and how high the vitamin A and D levels are set for processors choosing to voluntarily fortify the yogurt. 

The rule does offer the industry a peek into where milk and dairy standards could be headed since former FDA Commissioner Scott Gottlieb made the now-famous “almonds don’t lactate” statement at the very same time that the FDA NIS was launched in July of 2018.

Tied-in with the NIS are the stated purposes of addressing chronic diseases like obesity and heart disease by modernizing all 280 standards of identity, updating food labeling rules to educate consumers on nutritional choices, clarifying standards for new innovations (including lookalikes), and developing a voluntary ‘healthy symbol’ for foods so consumers get a ‘quick signal’ to make choices lower in sodium, saturated fat, and calories via the Dietary Guidelines, while including the nutritional quality consumers expect.

During the FDA NIS hearings reported in Farmshine three years ago, FDA said it wanted to better understand how consumers understand the term ‘milk.’

Rob Post, with yogurt-maker Chobani, was a presenter that day, and he expressed concerns that the current yogurt standards made it difficult for Greek yogurt to be offered in schools and other institutional feeding situations to accurately quantify the protein levels. Strained Greek yogurt is 52% protein, twice that of regular yogurt, he said.

He asked for a better process that keeps pace with innovation, but he was very quick to defend the current definition of milk and dairy — and its enforcement.

“It’s important to have options,” said Post. “But words matter to consumers and dairy means something specific. It means nutrient dense, minimal processing. It is important that this standard is preserved. Standards are important because they assure the consistency of the product, its authenticity and nutrition.”

Meanwhile, FDA’s new yogurt rule “expands the allowable ingredients in yogurt, including sweeteners such as agave, and reconstituted forms of basic dairy ingredients.”

This simpler, more flexible statement means ultrafiltered (UF) milk solids and even dry milk protein concentrate, can be used in formulation as ‘optional functional dairy ingredients.’ As milk-derived ingredients, these examples don’t reconstitute to the properties of the basic ingredients listed in the yogurt SOI, and must be labeled. 

The new rule also “establishes a minimum amount of live and active cultures yogurt must contain to bear the optional labeling statement ‘contains live and active cultures’ or similar statement.” And, if the yogurt is treated for extended shelf life in a way that inactivates viable microorganisms, the yogurt must now include a statement ‘does not contain live and active cultures’ on the label. 

“The final rule is already out of date before it takes effect,” wrote Joseph Scimeca, Ph.D., senior vice president of regulatory and scientific affairs for IDFA in a statement. “For the most part, FDA relied on comments submitted 12 or more years ago to formulate its final rule — as if technology has not progressed or as if the yogurt making process itself has been trapped in amber like a prehistoric fossil.”

Scimeca added that the yogurt rule is “woefully behind the times and doesn’t match the reality of today’s food processing environment or the expectations of consumers.”

On the other hand, there were numerous industry comments seeking a more traditional rule in terms of milk and cream vs. ‘milk-derived’ or ‘reconstituted’. 

FDA responded in the rule, stating: “Technological advances in food science and technology allow for a wider range of milk-derived ingredients developed with advances in membrane processing technology in the dairy industry. The final rule permits the use of emulsifiers and preservatives to prevent separation, improve stability and texture, and extend the shelf-life of yogurt.”

While the rule, in effect, “permits optional functional dairy ingredients,” and “modernizes the yogurt standard to allow for technological advances,” it also requires the 3.25% milkfat and 8.25% solids not fat threshold at a point in the process before bulky flavorings are added. That’s helpful.

Calling the new rule “a robust defense of standards of identity,” NMPF cited its citizen’s petition filed with FDA in 2019, saying: “With the yogurt rule complete, our petition should be answerable in much less than 21 years.”

FDA’s NIS is also reviewing and updating its own “general principles for food standards of identity.” The seed inside the core of this huge apple.

“We are continuing our efforts to revoke or amend certain standards of identity — from frozen cherry pie and French dressing to yogurt — especially when the standard of identity is inconsistent with modern manufacturing processes or creates barriers to innovation,” states FDA about its process.

As pieces, like this yogurt rule drift out of that process, a thought emerges: FDA is cleaning its books full of hundreds of SOIs to consolidate and simplify them — before tackling the really big questions of legally defining what the broader SOIs will be.

Still on deck are the all-important SOIs defining and enforcing core milk and dairy terms, even as pressure from plant-based, cell-cultured, yeast-cultured and other lookalikes push for SOIs that simply set nutritional standards for analogs to meet. 

FOOD FIGHT: USDA, Scholastic join billionaire-invested brand-marketing of ‘fakes’ in school meals, curriculum

The cover story of a recent Junior Scholastic Weekly Reader — the social studies magazine for elementary school students — was dated for school distribution May 11, 2021, the same week USDA approved a Child Nutrition Label for Impossible Burger and released its Impossible Kids Rule report. This label approval now allows the fake burger to be served in place of ground beef in school meals and be eligible for taxpayer-funded reimbursement. Meanwhile, Scholastic Weekly Reader and other school ‘curricula’ pave the marketing runway with stories incorrectly deeming cows as water-pigs, land-hogs, and huge greenhouse gas emitters, without giving the context of true environmental science.

Is USDA complicit? Or ring-leader? One Senator objects

By Sherry Bunting

WASHINGTON – It’s appalling. Bad enough that the brand of fake meat that has set a goal to end animal agriculture has been approved for school menus, fake facts (brand marketing) about cows and climate are making their way to school curriculum as well. The new climate-brand edu-marketing, and USDA has joined the show.

“Schools not only play a role in shaping children’s dietary patterns, they play an important role in providing early education about climate change and its root causes,” said Impossible Foods CEO Pat Brown in a May 11 statement after Impossible Meats received the coveted USDA Child Nutrition Label. “We are thrilled to be partnering with K-12 school districts across the country to lower barriers to access our plant-based meat for this change-making generation.”

U.S. Senator Joni Ernst (R-Iowa), who was born and raised on a rural Iowa family farm, has called on U.S. Agriculture Secretary Tom Vilsack to ensure students will continue to have access to healthy meat options at schools. The Senator’s letter to the Secretary asked that USDA keep political statements disincentivizing meat consumption out of our taxpayer-funded school nutrition programs.

Food transformation efforts are ramping up. These are political statements where cows and climate are concerned, not backed by science, but rather marketing campaigns to sell billionaire-invested fake foods designed to replace animals. (World Wildlife Fund, the dairy and beef checkoff sustainability partner, figures into this quite prominently.)

As previously reported in FarmshineImpossible Foods announced on May 11 that it had secured the coveted Child Nutrition Label (CN Label) from the USDA. The food crediting statements provide federal meal guidance to schools across the country. The CN label also makes this imitation meat eligible for national school lunch funding.

“This represents a milestone for entering the K-12 market,” the CEO Brown stated, adding that the use of their fake-burger in schools could translate to “huge environmental savings.” (actually, it’s more accurate to say it will translate to huge cash in billionaire investor pockets.)

Concerned about ‘political statements’ made by USDA and others surrounding the CN label approval — along with past USDA activity on ‘Meatless Mondays’ initiated by Vilsack’s USDA during the Obama-Biden administration —  Sen. Ernst wrote in her letter to now-again current Sec. Vilsack: “School nutrition programs should be exempt from political statements dictating students’ dietary options. Programs like ‘Meatless Monday’ and other efforts to undermine meat as a healthy, safe and environmentally responsible choice hurt our agriculture industry and impact the families, farmers, and ranchers of rural states that feed our nation.”

No public information has been found on how Impossible Foods may or may not have altered its fake-burger for school use. My request for a copy of the Child Nutrition Label from USDA AMS Food Nutrition Services, which granted the label, were met with resistance.

Here is the response to my request from USDA AMS FNS: “This office is responsible for the approval of the CN logo on product packaging. In general, the CN labeling office does not provide copies of product labels. This office usually suggests you contact the manufacturer directly for more information.”

I reached out to Impossible for a copy of the nutrition details for the school product. No response.

It’s obvious the commercial label for Impossible is light years away from meeting three big ‘nutrition’ items regulated by USDA AMS FNS. They are: Saturated Fat, Sodium, and Calories.

As it stands now, the nutrition label at Impossible Foods’ website shows that a 4-oz Impossible Burger contains 8 grams of saturated fat. That’s 3 more grams than an 8-oz cup of Whole Milk, which is forbidden in schools because of its saturated fat content. The Impossible Burger also has more saturated fat than an 85/15 lean/fat 4-oz All Beef Burger (7g).

Sodium of Impossible Burger’s 4-oz patty is 370mg! This compares to an All Beef at 75g and a McDonald’s Quarter-pounder (with condiments) at 210 mg. Whole Milk has 120 mg sodium and is banned from schools.

The Impossible Burger 4-oz. patty also has more calories than an All Beef patty and more calories than an 8 ounce cup of Whole Milk. But there’s the ticket. USDA is hung up on percent of calories from fat. If the meal is predominantly Impossible Burger, then the saturated fat (more grams) become a smaller percent of total calories when the fake burger has way more calories! Clever.

In her letter to Vilsack, Sen. Ernst observes that, “Animal proteins ensure students have a healthy diet that allows them to develop and perform their best in school. Real meat, eggs, and dairy are the best natural sources of high quality, complete protein according to Dr. Ruth MacDonald, chair of the Department of Food Science & Human Nutrition at Iowa State University. Meat, eggs, and dairy provide essential amino acids that are simply not present in plants. They are also natural sources of Vitamin B12, which promotes brain development in children, and zinc, which helps the immune system function properly.”

She’s right. A recent Duke University study goes behind the curtain to show the real nutritional comparisons, the fake stuff is not at all nutritionally equivalent. But USDA will allow our kids to continue to be guinea pigs.

In May, Ernst introduced legislation — called the TASTEE Act — that would prohibit federal agencies from establishing policies that ban serving meat. She’s looking ahead. Sen. Ernst is unfortunately the only sponsor for this under-reported legislation to-date.

Meanwhile, within days of the Impossible CN approval from USDA, school foodservice directors reported being bombarded with messaging from the school nutrition organizations and foodservice companies, especially the big one — Sodexo — urging methods and recipes to reduce their meal-serving carbon footprint by using less beef for environmental reasons, and to begin incorporating the approved Impossible.

The Junior Scholastic Weekly Reader for public school students across the nation — dated May 11, the same day as the USDA CN Label approval for ‘Impossible Burger’ — ran a cover story headlined “This burger could help the planet” followed by these words in smaller type: “Producing beef takes a serious toll on the environment. Could growing meat in a lab be part of the solution?”

The story inside the May 11 scholastic magazine began with the title: “This meat could save the planet” and was illustrated with what looked like a package of ground beef, emblazoned with the words: “Fake Meat.”

Impossible Foods is blunt. They say they are targeting children with school-system science and social studies (marketing disguised as curriculum) — calling the climate knowledge of kids “the missing piece.”

In the company’s “Impossible Kids Rule” report, they identify kids as the target consumer for their products, and how to get them to give up real meat and dairy.

Toward the end of the report is this excerpt:“THE MISSING PIECE: While most kids are aware of climate change, care about the issues, and feel empowered to do something about it, many aren’t fully aware of the key factors contributing to it. In one study, 84% of the surveyed young people agreed they needed more information to prevent climate change. Of the 1,200 kids we surveyed, most are used to eating meat every week—99% of kids eat animal meat at least once a month, and 97% eat meat at least once a week. Without understanding the connection between animal agriculture and climate change, it’s easy to see why there has been so little action historically on their parts. Kids are unlikely to identify animal agriculture as a key climate threat because they often don’t know that it is. Similar to adults, when we asked kids what factors they thought contributed to climate change, raising animals for meat and dairy was at the bottom by nearly 30 points.

After showing the impressionable children Impossible marketing, they saw a big change in those “awareness” percentages and noted that teachers and schools would be the largest influencers to bring “planet and plate” together in the minds of children, concluding the report with these words:

When kids are educated on the connection between plate and planet
and presented with a delicious solution, they’re ready to make a change. And adults might just follow their lead,” the Impossible Kids Rule report said.

USDA is right with them, piloting Impossible Burger at five large schools using the Impossible brand name to replace ground beef with fake meat in spaghetti sauce, tacos and other highlighted meals. This allows brand marketing associated with the name — free advertising to the next generation disguised as “climate friendly” options with marketing messages cleverly disguised as “education.”

In the New York City school system, one of the pilot schools for Impossible, new guidelines are currently being developed to climate-document foods and beverages served in the schools.

Impossible doesn’t have a dairy product yet, but the company says it is working on them.

Impossible’s competitor Beyond Meat is also working on plant-based protein beverages with PepsiCo in the PLANeT Partnership the two companies forged in January 2021. PepsiCo is the largest consumer packaged goods company globally and has its own K-12 Foodservice company distributing “USDA-compliant” beverages, meals and snacks for schools.

How can this brand-marketing in school meals be legal? Dairy farmers pay millions to be in the schools with programs like FUTP60 and are not allowed to “market”. In fact, dairy checkoff leaders recently admitted they have a 12-year “commitment” to USDA to “advance” the low-fat / fat-free Dietary Guidelines in schools, top to bottom, not just the dairy portion.

Pepsico has a long history of meal and beverage brand-linking in schools. Working with Beyond, they will assuredly be next on the Child Nutrition alternative protein label to hit our kids’ USDA-controlled meals.

Like many things that have been evolving incrementally — now kicking into warp speed ahead of the September 2021 United Nations Food System Transformation Summit — the taxpayer-funded school lunch program administrated by USDA is a huge gateway for these companies. Ultimately, will parents and children know what is being consumed or offered? Who will choose? Who will balance the ‘edu-marketing’? Will school boards and foodservice directors eventually even have a choice as huge global companies mix and match proteins and market meal kits that are guaranteed to be USDA-compliant… for climate?

-30-

USDA to invest over $5 bil. in food supply chain, focus is transformation, not relief; Public comments due June 21

By Sherry Bunting, Farmshine, June 11, 2021

WASHINGTON — Long on transformation framework and short on meaningful details, USDA announced this week (June 8) that it will invest more than $4 billion to strengthen critical supply chains. This follows the June 4 announcement of over $1 billion for ‘healthy food’ and security infrastructure.

What these words mean is still the subject of USDA gathering input through public comments due June 21 and a series of stakeholder meetings. The first one was a 30-minute webinar attended virtually by over 3000 people representing food and agriculture organizations the day after the funding announcement (June 9).

These announcements are billed by Agriculture Secretary Tom Vilsack as part of the “Build Back Better” initiative to be funded by the Consolidated Appropriations Act of 2021 (passed by the 116th Congress and signed by President Trump in January) and the American Rescue Plan Act (passed by the 117th Congress and signed by President Biden in March.)

Vilsack will co-chair, along with Secretaries of Commerce and Transportation, the Biden administration’s new Supply Chain Disruptions Task Force for a “whole of government response.”

According to USDA, its investment announcements will include a mix of grants, loans and “innovative financing mechanisms” for the food production, processing, distribution and market access priorities that will “tackle the climate crisis and help communities that have been left behind.”

It has been six months since CAA funds were appropriated and three months since ARPA funding was authorized. These relief and support funds passed by two sessions of Congress and signed by two Presidents are now sitting in wait of a task force establishing supply chain transformation priorities after public comments and industry stakeholder meetings.

Meanwhile, dairy producers and other sectors of agriculture are still waiting for details about relief that was to some degree spelled out in the prior congressional language of these Acts. 

This includes waiting for USDA’s implementation of what was supposed to be an expanded base option for dairy producers in the Dairy Margin Coverage program; waiting for participation details for the Dairy Donation Program that is supposed to be retroactive; and waiting for a response from USDA to the bipartisan request by Senators seeking relief payments for dairy farmers for the first half of 2021 retroactive to January 1.

In the detailed request for public comment, USDA is making it clear that the CAA and ARPA funds will be spent on transformation, not relief. Guiding the transformation is President Biden’s February Executive Order 14017 America’s Supply Chain.

USDA says it is interested in comments spanning everything from animal, soil, plant and climate health, traceability, monitoring and technologies to agricultural inputs, energy, markets, storage, distribution, and digital security.

“We always knew this, but the pandemic really highlighted it for the rest of the country: Our food system is brittle, and any shock to it can have devastating effects down the chain. Now is the time — not to go back to normal — but to build a new normal,” said Mae Wu, Deputy Under Secretary of Marketing and Regulatory Programs during the first stakeholder webinar this week.

“Before we dealt with the pandemic, we had a food system in which nearly 90% of our farms did not generate the majority of the income for the farm families operating those farms. We had a food and farm system in which soil erosion was occurring at 10 times the rate that soil was being replenished,” said Vilsack as the first stakeholder webinar kicked off.

“We all know we have a substantial number of waterways that are currently impaired, and we also appreciate the fact that we had a food system that was prepared to address climate change but not yet fully embracing the opportunity side of that claim,” Vilsack continued. “So we had a system that needed help. We had a system that also was seeing rapid consolidation and a lack of competition. Then Covid hit and by virtue of Covid we learned that what we thought was a resilient system, really wasn’t resilient at all and had a difficult time shifting from food going into foodservice to going into food assistance.”

Citing the President’s February Executive Order, Vilsack said the focus of the new task force, he co-chairs, is to strengthen supply chains by “beginning the process of transformation.”

In the Federal Register document, USDA states: “(Our) initial thinking includes, but is not limited to, funding, through a combination of grants or loans, for needs such as: supply chain retooling to address multiple needs at once (i.e., achieving both climate benefits and addressing supply gaps or vulnerabilities concurrently), expansion of local and regional food capacity and distribution (e.g., hubs, cooperative development, cold chain improvements, infrastructure), development of local and regional meat and poultry processing and seafood processing and distribution, and food supply chain capacity, building for socially disadvantaged communities.”

In one subsection, USDA notes that it is interested in comments on “the availability of substitutes or alternative sources for critical goods and materials…” For example, USDA says it “encourages commenters to consider agricultural products that could be domestically grown but are not practically available today for various reasons, and to describe whether and how such products (or their alternatives) could be made available through supply chain resilience efforts.”

To-date, there are 297 public comments on the docket. A quick look through 55 that are viewable presently includes many food banks and feeding programs, some mentioning dairy, but few comments are logged from dairy organizations to-date.

For its part, the National Farmers Organization attached a document and stated: “The farmer dumping milk needs a market today, not in the long run. The person standing in a food line needs something to eat today, not in the long run. We need to look more carefully at what is going on if we are to understand, and effectively address, the dilemma of too much milk on one end of the supply chain and not enough dairy products on the other.”

Vilsack (who worked as a dairy checkoff executive for the four years between being Ag Secretary in the Obama and Biden administrations) also referenced milk dumping, saying the dairy industry had bottlenecks as foodservice demand shut down while retail demand for consumer-packaged goods skyrocketed.

In fact, in a recent Fortune magazine interview, Vilsack said the cost of $1.50 per gallon to put milk in a jug created a disincentive to donate excess milk instead of dumping it.

However, in reality, there was more to it than that in parts of the country where Governors brought the curtain down on the economy to strict degrees of people ordered to stay home, while also scolding them in public service announcements for buying too much food. Retailers hit the brakes by putting purchase limits on milk, butter and other dairy products, just as processors loaded up the silos with milk for the retail surge, only to find their retail orders came to a screeching halt as the purchase limits contributed to backing milk up from plant storage into farm pipelines faster than donation efforts could get organized or find facilities to bottle or process.

Facility issues were also cited at the time, in terms of separated cream filling storage silos with nowhere to go as butter capacity was busy switching to pull bulk butter from storage and convert it to print butter, and butter imports skyrocketed. It took a while to unwind the institutional governance of low-fat milk into making more whole milk available as consumers could choose. And it took a while for governments to allow institutions (like schools) to temporarily give whole milk. The result, in the Northeast especially, was a huge volume of dumped milk.

Among the viewable comments to USDA at the Federal Register, so far, are groups citing industry concentration and consolidation.

In its comments, the Montana Cattlemen’s Association pointed out that Secretary Vilsack, along with then Attorney General Eric Holder, held concentration and antitrust listening sessions across the U.S. during the Obama administration, and nothing ever came of it. One of those USDA / DOJ national listening sessions was on dairy, specifically, in Madison, Wisconsin in 2009.

The National Grocers Association echoed these concerns, detailing the way a few global companies already control food retail, foodservice, food processing and distribution, and how this affects farmers and ranchers, independent retailers and restaurants, and thereby affects regional food supply chains, and ultimately consumers and America’s security.

Both the cattlemen and grocers call for specific actions that would increase competition, regional processing and market access and thereby make the U.S. food system more secure and critical supply chains more resilient.

During the stakeholder webinar, Vilsack addressed a question on market competition by saying USDA will “first make sure the markets that do exist are as open and transparent as possible” by looking at the current rules along with other federal agencies and taking any steps to rectify. But he also pointed to developing new markets.

At the other end of the public comment spectrum, groups like the Good Food Institute, a lobbying organization for plant-based and cell-cultured replacements for animal-sourced foods, paint a picture of how their streamlined lab-style production through pop-up bioreactors and fermentation vats in rural, suburban and urban areas can be built to provide supply chain resiliency and food security. GFI also claims that their models would be a climate mitigation strategy.

GFI addressed each of the USDA bullet points on supply chain resilience, climate action and new market opportunities to describe why the CAA and ARPA funds should be used for research and infrastructure that shifts away from animal agriculture to plant-based and cell-cultured through digital and genetic technologies that are already within the USDA Agricultural Research Service wheelhouse.

GFI lays out their description of how recombinant proteins and GMOs, along with the storability of frozen cells and dry plant-based powders, can be turned into food quickly, and in exact amounts needed, and can be grown and manufactured anywhere — without waiting for animals to grow — leaving land available for so-called ‘climate strategies’ and biodiversity. 

But, they say, research and infrastructure are needed to make their science-fiction novel come true. This, despite the huge investments of tech industry billionaires in these replacement technologies, and the way the largest meat and dairy processors are diversifying, to brand – and blend – such alternatives to look, taste, and feel like the real thing.

Interestingly, the food economy is, right now, dealing with supply chain disruptions and inflationary price hikes on animal-sourced products from eggs and milk to bacon, beef, and chicken wings. The price squeeze is having a big impact on independent grocers, independent restaurants, and consumers. At the same time, prices paid to dairy and livestock producers are turning lower just as farmers and ranchers were hoping to get back on their collective feet.

That paradox is not sustainable nor resilient for producers or consumers, but growing cells in bioreactors or harvesting yeast-excrement from fermentation vats — instead of animals on farms —simply gives even more control of food to even fewer entities that would control the genetic alterations that make it scientifically possible.

USDA states in its press release that it wants to address competition and small and medium sized processing capacity and that it wants fairness, competition, equity, and access for producers and consumers, while accomplishing climate mitigation at the same time. 

The question is: What do these buzz words actually mean? The June 9 stakeholder webinar gave a glimpse.

Vilsack explained that USDA is putting the series of funding announcements into a series of four supply chain ‘buckets’: production, processing, distribution / aggregation and markets / consumers.

He said USDA will begin by providing assistance for beginning farmers and socially disadvantaged farmers, including the debt relief for farmers of color.

“We’ll look for ways to provide assistance for those who work on the farms and those who work in the processing facilities. We’ll look for how we can encourage those transitioning from conventional to organic agriculture if they choose to do so,” said Vilsack. “All of this will be designed to create greater resilience in terms of the number of people available to farm and the types of farming systems that we have. You’ll also see investments in urban agriculture.”

Vilsack said on the food processing side, USDA is “very focused” on ways to create more options for farmers by “shoring up and expanding” existing small and medium size processing to create more markets for farmers.

He highlighted “food hubs” in the distribution bucket and “access to healthy foods” in the consumer bucket.

Answering a question later about how government grant-writing is beyond the scope of most farms, especially small farms, Vilsack said: “One way for folks to get expertise and capacity is to join with others who are similarly situated to form a food hub to aggregate products. There is money for food hubs in this.”

Calling the Dairy Donation Program an investment in the production / producer bucket, and referencing it four times in the webinar, Vilsack said the DDP “will enable producers to more quickly shift in the event of a disruption from foodservice or retail that might not be available for whatever reason into food assistance mode.”

He identified the need to “significantly invest in storage and refrigeration infrastructure to accept significant quantities of food to be stored for a period of time and distributed over a period of time. Right now, we are not equipped to handle a great influx of meat, and produce all at one time, and as a result, animals were destroyed and milk was dumped,” he said.

Vilsack said another way to look at USDA’s incremental roll out of the CAA and ARPA funds is that it reflects “how we are going about the transformation of our food and farm system. We need to continue to invest to make sure there are multiple ways for people to get into the farming business and to stay in business.”

To be profitable, he said, “means we need to develop more new and better markets to be invested in. We want to make sure it is sustainable, circular, regenerative in its approach. We want to make sure it is equitable in its application so that people of all races, ethnicities, gender and so forth are able to access the programs completely at USDA,” said Vilsack.

For producers, allied industry, consumers and organizations, now is the time to visit the USDA Federal Register Docket at https://www.regulations.gov/document/AMS-TM-21-0034-0001 to read the guidelines for commenting and submit a “Supply Chain Comment” referencing Docket AMS-TM-21-0034-001 by June 21, 2021.

Comments may also be sent to Dr. Melissa R. Bailey, Agricultural Marketing Service, USDA, Room 2055-S, STOP 0201, 1400 Independence Avenue SW, Washington, DC 20250-0201. For further information about how to comment and the guidelines for commenting, contact Dr. Bailey by phone at 202-205-9356 or email melissa.bailey@usda.gov

(Author’s Note: The pandemic revealed that the institutional feeding models replete with anti-fat rules based on un-scientific Dietary Guidelines are part of the supply chain disruption problem. Governmental and non-governmental organizations continue to try to systemize food distribution into dietary lanes that don’t reflect the science or consumer attitudes about healthy fat and animal protein. Now ‘climate’ is being used as a potential animal-dilution driver. When someone wants to give families a gallon of whole milk (instead of fat-free or low-fat) when they pick up the school lunches for their children during a pandemic, the last thing any governmental or non-governmental organization should be telling them is “you can’t do that, it’s against the rules,” or pushing them into an adjacent parking lot so they aren’t “next to” the institutionally rule-inundated food. That is just one aspect I plan to write about in commenting to the USDALoosen those dietary restraints that give all the power to the global consolidators in foodservice, processing and distribution. Let free-enterprise and good will work for good.)

-30-

DMI’s DS4G sees dairy feed, cropping, cow care as ‘big hammers’ for net-zero

‘Grant’ will start ‘measuring’ air, soil around dairy cropping practices in nine U.S. regions

This is the third and final part of the multi-part series about DMI’s Net Zero Initiative and Dairy Scale for Good implementation. Parts one and two in Farmshine covered some of the 12- to 13-year history, the ‘scale’ approach for getting the industry to net zero faster, and the impact of manure processing, digester models, and renewable energy policies and technologies in the NZI scheme.

By Sherry Bunting, Farmshine, May 7, 2021

ROSEMONT, Ill. — How dairy feed and forage are produced are the “biggest hammers” that are “ripe for innovation in dairy emissions reduction,” said Caleb Harper, executive director of DMI’s Net Zero Initiative (NZI) Dairy Scale for Good (DS4G) implementation.

He and Dr. Mike McCloskey, chairman of the DMI Innovation Center for U.S. Dairy’s Sustainability Initiative, presented information about the Net Zero Initiative (NZI) and ‘implementation on the farm’ during last month’s Balchem real science lecture series.

Much of the presentation used the ‘spreadsheet exercise’ of the World Wildlife Fund (WWF) white paper laying out the “business case for getting to net zero faster”, based on a 3500 cow dairy (a Fair Oaks site with 3000 milking and 500 dry). In fact, Harper’s DS4G work will exclusively pilot and model on dairies about this size.

After explaining that the DS4G goal is to make maximum impact on the entire supply of milk in the short-term using “the consolidation going on in the industry” and the idea of “scale to drive down the risk … and spread the benefit across the industry,” Harper dug into each area and showed how the models tend to work best when multiple areas are combined.

Harper said no till farming, cover crops, innovative crop rotations, renewable fertilizer, precision agriculture all fall into this feed production area of emissions.

“It all boils down to measuring the emissions,” he said, showing a slide of boxes in potato fields in Idaho, where USDA ARS has a project that monitors the air around the crop to show the emissions from a field and mitigation that can be attributed to cropping practices. He said DMI has a grant to do the same thing with dairy cropping practices beginning this year.

The key, according to Harper, is to show that the emissions are being reduced. In addition to boxes in fields measuring emissions around crops, Harper said soil core samples will be taken to determine carbon sequestration of dairy feed cropping strategies.

“This is open science, (meaning still in the proving stage),” said Harper, known for his Open Ag science project growing food in computer controlled boxes at M.I.T. That project ended amid controversy last April a few weeks before Harper was hired by DMI to lead its NZI DS4G.

During the real science lecture in April, Harper said DMI has a grant program starting this year, along with Foundation for Food and Agriculture, to do this type of field box emissions monitoring and soil core sequestration monitoring across nine different U.S. geographies to test conservation tillage practices in terms of carbon emissions and sequestration over the next five years.

Harper said he sees this area as “huge” for innovation and for generating carbon credits that are valued by markets and for reducing one-third of dairy’s ‘field to farm’ emissions while improving soil health and the ability of soil to hold water.

He projects the bottom line potential annual farm revenue on this at $70,000, saying the industry will have to combine this with other strategies, like manure processing, renewable energy generation and such to get the combination of environmental impact toward ‘net-zero’ GHG and the economic revenue stream impact for the dairies.

“Some strategies are more impactful than others,” he said about the WWF models.

In this diagram, which was also shared by DMI leaders in a Pa. Dairy Summit breakout session about what dairy checkoff has done for producers lately, Harper illustrated how WWF models show farms will have to combine areas to merge emissions reduction potential with revenue potential. This shows feed production represents 26% of field to farm emissions reduction potential but just 3% of farm revenue potential; Cow care encompassing feed additives, efficient rations and genetics represents 33% of emissions reduction potential and just 5% of farm revenue potential; but conversely, renewable energy production on the farm represents just 5% of emissions reduction potential and 23% of farm revenue potential.

The ‘hammers’ on the emissions side do not line up with hammers on the revenue side, and the question remains, where will individual dairy farms sit in terms of decision-making as supply chains scale these combinations.

Yet again, the question arises around selling or monetizing the carbon credits generated by the farm once these cropping practices are “measured” and added to models. How does the sale of these credits, or bundling with sales of milk, then change the carbon profile of the farm selling the credits vs. the buyer in the dairy supply chain. Again, as mentioned in Part II on manure technologies and energy generation, this is an important detail that the WWF, NZI and DS4G modeling has not dealt with or worked through.

So, while discussions have already progressed to model how carbon credits and milk could be bundled to milk buyers, with pilots funded by supply chain grants to model how scale can spread impact over the industry and the entire milk supply, the holes in the value proposition are more obvious in this area where farms are already doing great things for land, air and water, by keeping something green and growing on the land as part of dairy feed production: How do farmers get credit for what they are already doing?

Harper also said “amazing things” are happening in the feed additive aspect of reducing enteric emissions, but he acknowledged “it’s early” on the carbon credit side for that.

This area of feed production and feed additives in the DS4G ‘value proposition’ has been spreadsheet-modeled to account for one-third of dairy’s field to farm CO2 equivalent emissions, and yet, at the same time, carbon credits based on this area are still in the research and measurement stage, needing documentation to be ‘monetized.’ 

Harper cited an example paper from University of California-Davis showing significant reductions in enteric emissions in beef cattle with certain feed additives.

As this work in the area of feed production and feed additives continues, said Harper: “Continuing to optimize rations (for production efficiency) remains important, while feed additives and selecting genetics for lower emissions will become important.”

Author’s Notebook:

The WWF Markets Institute released the dairy business ‘case study’ for scaling to net-zero faster on Jan. 27, 2021. A mid-February Farmshine report revealed the WWF mathematical error that had inflated the magnitude of CO2 equivalent pounds contributed by all U.S. milk production. WWF on Feb. 25, 2021, corrected its baseline to show the much smaller collective impact of 268 billion pounds CO2 equivalent (not 2.3 trillion pounds).

Both Harper and McCloskey serve on the WWF Market Institute’s Thought Leadership Group.

DMI confirms that dairy checkoff had a memorandum of understanding (MOU) with WWF from the inception of the Innovation Center for U.S. Dairy around 2008 through 2019. McCloskey has chaired the Innovation Center’s Sustainability Initiative since 2008.

In 2008-09, two MOU’s were signed between DMI and USDA via former U.S. Ag Secretary Tom Vilsack — the Sustainability Initiative and GENYOUth. At the end of the Obama administration, Sec. Vilsack was hired by DMI dairy checkoff to serve as president and CEO of USDEC 2016-2021, and earlier this year he became Secretary of Agriculture again after President Joe Biden said Vilsack ‘practically wrote his rural platform and now he can implement it.”

Aside from both serving on the WWF Market Institute’s Thought Leadership Group, McCloskey and Harper have another connection. According to the Sept. 2019 Chronicles of Higher Education, Caleb Harper’s father, Steve Harper, was a grocery executive. He was senior vice-president of marketing and fresh product development, procurement and merchandising from 1993 to 2010 for the H-E-B supermarket chain based in Texas. According to a 2020 presentation by Sue McCloskey, H-E-B was their first partner in the fluid milk business in the 1990s, followed by Kroger. According to the Houston Chronicle, the McCloskeys also partnered with H-E-B in 1996 during Steve Harper’s tenure to produce Mootopia ultrafiltered milk, an H-E-B brand. This was the pre-cursor to fairlife, the ultrafiltered milk beverage line in which DMI invested tens of millions of dollars in checkoff funds through the Innovation Center for U.S. Dairy partnering with the McCloskeys, Select, and Coca Cola.

Harper also previously served as a member of the Board of Directors for New Harvest for at least three years (2017-19). New Harvest is a global nonprofit building the field of cellular agriculture, funding startups to make milk, meat and eggs without animals.

-30-

DMI’s NZI DS4G eyes climate policies, supply chain partners in net zero fastlane: but who gets the carbon credits?

Author’s Note: This is part two in a multi-part series about DMI’s Net Zero Initiative and Dairy Scale for Good implementation. Part one previously covered some of the 12- to 13-year history as well as the ‘scale’ approach for getting the industry to net zero faster. 

By Sherry Bunting, Farmshine, April 30, 2021

ROSEMONT, Ill. — The official launch of DMI’s Net Zero Initiative (NZI) in October 2020, and World Wildlife Fund’s (WWF) dairy net zero case study published in January 2021 (and corrected in February for a math error that overestimated the industry’s total CO2 equivalent emissions) are two of the mile-markers in farm visits and partnership development since Caleb Harper was hired by checkoff in May 2020 as executive director of Dairy Scale for Good (DS4G).

In those 11 months, Harper reports visiting 100 dairy farms representing over 500,000 cows in 17 states, processing 350 manure samples, and gathering over 8000 ‘data points.’

Earlier this month, Harper, along with Dr. Mike McCloskey, presented a “value proposition” for the dairy industry during a Balchem real science lecture about ‘net zero carbon emissions implementation on the farm.’

McCloskey of Fair Oaks Farm, Fairlife and Select Milk Producers has chaired the DMI Innovation Center for U.S. Dairy’s Sustainability Initiative since inception 12 to 13 years ago.

In short, DS4G pilots are setting up through “sponsorships” from large dairy-buying partners on large farms within their own supply chains. DMI’s former MOU sustainability partner, the WWF, makes the case in its report that “achieving net zero for large farms is possible with the right practices, incentives and policies within five years (by reducing) emissions in enteric fermentation, manure management, feed production and efficiency, and energy generation and use.”

“This value proposition for dairy cuts two ways,” said Harper. Farms of 2500 cows or more can go toward digesters tied to renewable fuel production, while farms 2500 cows and fewer can move toward a digester model that handles food waste, receives tipping fees and generates electricity.

Both models will depend on a combination of government subsidies, low carbon renewable fuel standards, electrification of the U.S., supply chain sponsorship and sale of resulting carbon-credits, according to information presented by Harper and McCloskey.

NZI aligns with climate policies announced and anticipated from the Biden administration, which mirrors what is coming out of the United Nations’ Food Summit, and World Economic Forum (WEF) Great Reset.

WWF has long been tied closely with WEF setting a global agenda and with the World Resources Institute (WRI) that evaluates science-based targets for companies making net zero commitments to “transform” food and agriculture.

“Innovative models are just now starting to bear fruit,” said Harper, citing McCloskey as a forerunner of “building out” the anaerobic digester concept.

For his part, McCloskey said they “counted on incentives” back in 2008 to be able to grow and “be the catalyst.” He talked about a future sustained by marketing the new products created as substitutes for fossil fuels, mined fertilizers and other products, as well as continuing to take in other carbon sources instead of landfills.

“We have the vision to set this all up, to perfect the technology and get it cheaper… so when we’re all doing the same things, incentives won’t be needed,” said McCloskey looking 10 to 20 years down the road when he sees this “surviving on its own.”

Harper described distributive models from the WWF report. One “being born” in California incorporates separate large scale dairies in a cluster – up to 20 or 30 farms within a 20-mile radius — each with its own digester that can “drop compressed methane into a transmission line to a centralized gas cleaning facility.” In this model, dairies either have a manure or land lease contract or an equity position in the operation.

This model, he said, relies on “societal values of green energy.”

Another distributive model being born in Wisconsin is described as a central digester with adjacent gas cleaning and upgrading. In this model, the manure from multiple farms is sent to the centralized digester by pipe or truck.

“These dairy clusters become ‘green’ clusters,” Harper elaborated. “So, it’s not just about the milk. They become a primary source of green energy inside of a state or nation.”

Food waste co-digestion is part of a different DS4G model driven by states adopting regulatory policy to keep organic material out of landfills. Harper said dairy farms can take advantage of such policies by centralizing waste collection for co-digestion.

“As we think about reducing emissions… a big part of that is bringing things grown off farm on farm, destroying their greenhouse gas potential, and taking credit for that ‘sink,’” Harper explained. 

However, in this example, the co-digestion is what gives the dairy its carbon credits, so technology that can handle higher waste-to-manure ratios and state / local regulations allowing farms to handle the off-farm waste are necessary. Such details were not discussed by Harper, and are presumed to be what large scale dairy pilots address.

The WWF case study showed bottom line profit and loss of $500,000 annually for a 3500-cow dairy. Harper believes this is a “conservative” estimate based on electricity production. With the right policies in place, the renewable natural gas value proposition would produce higher returns, according to Harper.

The renewable natural gas market will still be building over the next five to 10 years, he said, so these models also rely on renewable fuel credits and other fixtures they expect to be part of the Biden administration’s climate policies.

Manure handling technologies apart from the digesters were also discussed, which according to the WWF case study, represent one-third of both emissions-reduction and income potential.

Harper is actively engaged in studying the differing chemical profiles of manure between farms, regions, and states — saying he wants to “understand manure” — with and without digester.

Looking at scale, Harper talked about adapting municipal human waste treatment systems for processing manure on large dairies. He highlighted what is called the “omni processor” — a Bill Gates investment to separate small scale municipal waste and create drinking water using a spindle with multiple discs heated to where nonvolatile solids are in the dry matter and the rest are captured as they volatize.

One “off the shelf technology” Harper is focusing on is already in use to produce discharge quality water. It is the membrane system of ultrafiltration (UF) and reverse osmosis (RO) — the same UF RO technology McCloskey pioneered in milk processing to remove water from milk for transport and refine elements for value-added products.

Stressing the large amount of water in dairy manure, Harper said UF RO “is a process designed exactly for de-watering.” Whether this process occurs before or after the digester, he said it is part of “the technology train, so whatever you are tagging onto is working more efficiently, processing less water and more nutrients and refining more things to find value in.”

All of these technologies, according to Harper, can build on each other and tie together with “electrifying” the United States, strengthening low carbon renewable fuel standards, adopting renewable fertilizer standards, and monetizing carbon. 

One unsettled aspect in this regard, however, appears on page 9 of the WWF case study and was not mentioned by McCloskey or Harper in their presentation. 

What happens to farmers when their carbon reductions and removals become part of the supply chain in which they sell their milk, or are sold to companies as part of a milk contract?

The WWF report makes this observation: “There could be significant interest from large dairy buyers in reducing embedded carbon in their products by purchasing value-added carbon ‘insets’ directly from farmers or cooperatives within their supply chains. Were companies to work closely with the dairy industry to advance these initiatives and enable greater GHG reductions, they could potentially use these measures toward meeting their own reduction targets … and incentivize dairies to embrace net zero practices through long-term contracts or other purchase or offtake agreements.”

That’s an aspect of the tens of millions of dollars in dairy pilot partnerships pledged by Nestle, Starbucks and potentially others for their own supply chains through DMI’s NZI DS4G.

WWF explains further in its report that, “Such agreements could provide stability and collateral as dairies consider investing in technology like anaerobic digesters. Some of these companies might even be interested in finding ways to bundle and purchase carbon credits produced on dairy farms where they buy milk.”

Such incentives, contracts and bundling – starting with DS4G pilots — leave dairy farms exactly where in the supply chain?

The WWF report states it this way: “Such purchases would shift the emissions reductions from the farmer to the company. This would result in the dairy essentially selling the credits that would enable its net zero status, as the emissions reductions cannot be double counted. 

“So, if the reductions are sold, the farmer can no longer be considered net-zero. This is a conundrum that is beyond the scope of this paper,” the WWF report admits.

This important detail in the NZI DS4G implementation was not mentioned by Harper or McCloskey.

Meanwhile, these initiatives also rely on climate policy, with former DMI executive Tom Vilsack now having crossed back over into government as U.S. Ag Secretary just 20 months after seeking pilot farm funding and Net Zero target policies when he testified before the Senate Ag Committee in June of 2019 while employed by checkoff as CEO of the U.S. Dairy Export Council.

President Joe Biden has said USDA is a key department in his administration’s climate action policies.

To be continued

-30-

2021 WWF / DMI ‘Net Zero’ report inflated GHG baseline for total U.S. milk production

By Sherry Bunting, Farmshine, Feb. 26, 2021

EAST EARL, Pa. – At a time when dairy producers are in the fight of their lives to prove how sustainable they already are in providing nutrient-dense milk and beef from the much-maligned bovine, they can ill-afford publication of overblown climate data on total U.S. milk production. And yet…

Dairy producers have unknowingly paid to applaud, promote and contribute to inflated baseline greenhouse gas (GHG) emissions data via their own national dairy checkoff.

The Jan. 27 report, produced by DMI’s former MOU partner World Wildlife Fund (WWF), established a GHG baseline that has been confirmed and admitted as being mathematically wrong by an order of magnitude — 10 times greater than reality.

So egregious is the mathematical error inflating dairy’s baseline GHG emissions, that the entire WWF / DMI Net Zero Initiative ‘Dairy Scale for Good’ case study is now questionable in the significance of its reductions because the significance of the starting-point — the ‘problem’ — is overblown.

Since receiving the DMI press release and copy of the 14-page white paper on Feb. 1, we have been reviewing it. The WWF Markets Institute ‘white paper’ entitled An Environmental and Economic Path Toward Net Zero Dairy Farm Emission” has been widely promoted by DMI. 

Its case-study model was concerning to us initially because of its narrow representation of comparable dairy farms and grand claims about what is needed for large farms to be “net zero in five years” and selecting pilot farms for the industry to prove-out the model.

Yes, the report was produced by WWF, but in a recent Pa. Dairy Summit breakout session on “What dairy checkoff has done for you lately,” DMI president Barb O’Brien confirmed that the WWF report is being promoted because it supports the Net Zero Initiative launched by DMI’s Innovation Center for U.S. Dairy.

More importantly, she said the report is a “spreadsheet exercise” that will now be piloted on large farms by Dairy Scale for Good executive director Caleb Harper to see if the exercise can be “proved out.” An exercise, mind you, that has inflated the significance of the problem it is purporting to solve. 

In the same “What has dairy checkoff done for you lately” session at Dairy Summit, O’Brien said the data for the WWF white paper came from DMI input!

This emperor has no clothes. This dog doesn’t walk. This math does not “add up.” 

We are talking about the math that established the baseline GHG for all U.S. milk production used to determine the significance of the reduction from the ‘Net Zero’ dairy case study, a 3000-cow Fair Oaks-style dairy, that does not represent reality for many large and small dairies in various geographies. But at the same time overblows the level of the problem everyone else contributes to.

We weren’t the only ones struggling to make sense of the WWF / DMI white paper. A Pennsylvania dairy producer did the math using his bulk tank calibration conversions and brought the “immense blunder” to Farmshine’s attention. 

He was concerned about what this means for all dairy farms, stating in an email: “Why would anyone set a specific reduction amount when it can be demonstrated that the starting amount is wrong? DMI may wish to partner with someone with better math skills.”

The producer who wished to remain anonymous pointed out to us in his email – and we agree – that DMI may want to get their facts straight with a Net Zero Initiative that shows this level of baseline blunder. In fact, as the producer observes: “If the objective (as indicated in the WWF report) is for a 10% reduction from the inflated number, then hallelujah! The EPA numbers show a 90% reduction (already — across all milk production).”

Could the inflated GHG baseline have been intentional? After all, that inflated number is instrumental in bolstering the significance of a prescribed ‘case study’ reduction for which pilot farms are being selected to ‘prove out’.

An inflated baseline harms all dairy farms because it does not reflect the truth about how small the GHG emissions really are – already — for all milk produced on all U.S. dairy farms, under sustainable dairy farm conditions, right now!

In fact, when the Pa. dairy farmer who alerted us to the math error supplied his figuring for the CO2 equivalent (CO2e), his figures put the inflation error at 8.6 times greater than reality.

We sent a media inquiry asking GHG expert Dr. Frank Mitloehner of University of California-Davis CLEAR Center to review the WWF report and let us know what we might be missing in our calculations.

Dr. Mitloehner agreed that the starting point for GHG emissions in the WWF / DMI report was off by “an order of magnitude”. 

We asked him for his expert review and on Wednesday, we received a copy of a letter Dr. Mitloehner sent to WWF. In it, Mitloehner references the white paper’s value of 2.3T pounds (trillion pounds) of GHGs as the emissions from total U.S. milk production (page 7 of the WWF white paper).

“When I went over your calculations, I noticed some potential errors. My own estimate arrived at GHG emissions that are about 10 times lower than the number you reported,” Mitloehner wrote in his letter to WWF.

“Assuming the conversion of the annual milk production in 2018, using Thoma’s equation, into kg fat-and-protein corrected milk (FPCM) and then changing to gallons of FPMC, my calculated values come out to be 287,453,374,279 (287 billion) pounds (not 2.3 trillion pounds),” 

GHG expert Dr. Mitloehner writes. “Using GHG emissions of 10.6 lb CO2e per gallon FPCM, the total GHG come out to 2.87453E+11 lbs CO2e. To simplify the number using the Tera unit prefix, the GHG would be 0.287T pounds CO2e, which differs significantly from the aforementioned value (in the WWF white paper) of 2.3T pounds.”

In his letter, Mitloehner emphasized that the WWF / DMI report was “very informative and points toward solutions that are attainable and scalable, both of which are considerations desperately needed as we look at feeding people in a sustainable manner.”

However, he adds, “I do worry that if the calculations are incorrect, it could lead to misinformation and confusion.”

Along with a copy of his letter to WWF, Dr. Mitloehner included in his email reply to Farmshine the WWF response thanking him for bringing it to their attention. 

“There is indeed an error and we are in the process of fixing it and will have an updated PDF soon and will share it with you, and we will fix the links on the website,” wrote Katherine Devine, director of business case development for WWF Markets Institute.

Once again, a climate-focused NGO with global goals against animal agriculture overblows GHG emissions from cattle, in this case dairy cattle. But this time, it happened within the full purview of mandatory producer-funded dairy checkoff.

 The reason this is a big deal is that it is being used to set policy. The DMI and WWF press releases point to this report as being based on “stakeholder” data that can “demonstrate what is possible with the right practices, incentives and policies within five years.”

For the four weeks, this WWF report has been applauded and promoted by DMI, using case study data that was contributed by DMI. 

The question now is how did this happen and what will the retraction look like? 

Will anyone stand up for the sustainability of dairy farms as they are – today – for an accurate baseline of their real contribution to GHG emissions, especially per unit of nutrition provided? Where is logic in the overall equation?

Dr. Mitloehner indicated in his email reply that the overblown GHG baseline does not completely jeopardize the paper’s ideas about strategies that can position dairy as a climate solution. However, when the starting math is off by 10 times the true amount, it becomes obvious the larger truth is that dairy is a small emitter and should already be paid for so-called ‘ecosystem services.’ Why is checkoff not pounding that message?

While dairy farms across the U.S. should be applauded and promoted for the reality of how small their emissions are while producing nutritious food for all of us – already – every day, DMI got its focus set on spreadsheet modeling to tell one story when the truth is they could have used accurate numbers to tell a better story.

Instead, the baseline GHG math error undermines the current sustainable performance of all dairy production while putting on a pedestal the Net Zero model based on a 3000-cow Fair Oaks-style dairy with no heifers on site, 80% of forages grown on site, a ration that is 70% forage, and a methane digester mix made up of more than 50% co-digestion of other waste streams.

In fact, some producers of similar size who have inquired about this model, have hit brick walls in having their sustainable practices even considered to  show levels of reduction. No wonder! The starting math for the WWF / DMI model is inflated and banks on that inflation to achieve the “significant” reduction in farmgate pounds of CO2 equivalent (CO2e).

While the math is muddy, the problem here is clear. Cattle as contributors to climate change continue to get a black eye by those inside and outside the industry overblowing the problem to push a marketing agenda that fits a global transformation narrative.

(POSTCRIPT NOTE: Just this morning after Farmshine went to press, we notice the PDF file at the WWF link (previously called ‘version 9’) has been quietly replaced with a file noted in its name as ‘v.10’. In it, on page 7, the total U.S. milk production GHG baseline of 268 billion pounds CO2e now appears where 2.3 trillion pounds once stood. No other change or discussion. We’ll be following up to do comparisons of how the smaller baseline impacts the significance of sweeping transformation, including calculations per unit of nutrition vs. other foods in next week’s Farmshine.)

Connecting dots:

— The January 27, 2021 WWF white paper uses a Fair Oaks-style 3000-cow Net Zero dairy case study. The WWF report was produced by the WWF Markets Institute and was written by WWF Markets Institute senior vice president Jason Clay, Ph.D.

— Clay heads the WWF Markets Institute Thought Leader group. According to the WWF Markets Institute website, the Thought Leader group members include DMI Innovation Center for U.S. Dairy Sustainability Alliance chairman Mike McCloskey of Fair Oaks fame, along with May 2020 DMI hire Caleb Harper serving as Dairy Scale for Good executive director.

— Harper started with DMI a few weeks after his departure from the MIT Media Lab under a cloud of press reports raising questions about aspects of donations, performance and environmental compliance within his digital food research project at MIT. For three years prior to being hired by DMI, Harper served on the board of directors for New Harvest, an organization that supports research and promotion of cell-cultured fake animal protein with the tagline ‘meat, milk and eggs without animals.’

— According to a Sept. 2019 Chronicles of Higher Education article, Harper’s father Steve was a grocery executive, senior vice-president of marketing and fresh product development and procurement from 1993 to 2010 for the H-E-B supermarket chain in Texas and northern Mexico and stayed on part-time through 2012 before retiring.

— During that time, H-E-B became the first and longstanding partner of Mike and Sue McCloskey when they were dairying in New Mexico and founded Select Milk Producers. Sue explained this in her presentation at the 2020 Pennsylvania Dairy Summit, that the H-E-B alliance was instrumental and painted a picture of how it progressed to dairy’s future as seen by DMI’s Innovation Center for U.S. Dairy and its food industry partners, with Mike serving as chair of the Sustainability Alliance.

— According to a June 15, 2014 Houston Chronicle article, the McCloskeys worked with H-E-B, supplying their milk and in 1996 producing Mootopia, the ultrafiltered milk H-E-B store brand and pre-cursor to fairlife, now solely owned by Coca Cola.

— During a February 2021 zoom presentation at the 2021 Pa. Dairy Summit, DMI’s vice president of sustainability Karen Scanlon confirmed that DMI had an MOU partnership with WWF from the inception of the Innovation Center for U.S. Dairy in 2008-09 and that this partnership opened doors with companies on shared priorities over the past decade. The MOU between DMI and WWF expired in 2019 and was not renewed, but Scanlon confirmed that a close relationship and exchange of information continues.

-30-

Gates et. al. peddle fake food, climate propaganda; Guarding real food ID will be critical

Bill Gates is pictured here in a Jan. 27, 2021 screenshot talking about carbon markets during the World Economic Forum Davos Agenda 21 livestream. A massive land grab is underway at the same time as this push toward ‘synthetic animal protein’ and as the WEF and UN goals of 30 x 30 are implemented. Big tech billionaires, like Gates the single largest owner of  U.S. farmland, are heavily invested in ‘synthetic animal protein’ (otherwise known as ‘lab-garbage’). WEF screenshot by Sherry Bunting

By Sherry Bunting, Farmshine, Feb. 26, 2021

EAST EARL, Pa. — Bill Gates gave hair-raising interviews last week with the Feb. 16th release of his new book: How to Avoid a Climate Disaster. In it, Gates lays out what he says it will take to eliminate greenhouse gas (GHG) emissions to ‘save the planet’.

Grabbing headlines is the Microsoft founder and software developer’s proclamation that ‘rich’ nations should move to 100% synthetic animal protein, while ‘poor’ nations, like Africa, can keep consuming animal-sourced proteins — if they reduce animal GHGs and environmental footprint by “merging-in” the meat and milk genetics and other technologies that have made U.S. cattle herds so productive.

Specifically, in a published interview with MIT Technology Review, Gates was asked: “Do you believe plant-based and lab-grown meats could be the full solution to the protein problem globally?”

Gates replied: “No, I don’t think the poorest 80 countries will be eating synthetic meat. I do think all rich countries should move to 100% synthetic beef. You can get used to the taste difference, and the claim is they’re going to make it taste even better over time. Eventually, that ‘green premium’ is modest enough that you can sort of change the (behavior of) people or use regulation to totally shift demand.”

That’s a mouthful.

Gates laments the “politics” of animal-sourced foods being a challenge for his fake-food-based climate goals and investments. “There are all these bills that say it’s got to be called, basically, ‘lab garbage’ to be sold,” Gates said. “They don’t want us to use the beef label.”

He goes on in the interview to explain why poor countries will continue to animal-source protein.

“For Africa and other poor countries, we’ll have to use animal genetics to dramatically raise the amount of beef per emissions for them. Weirdly,” says Gates in the MIT interview, “the U.S. livestock, because they’re so productive, the emissions per pound of beef are dramatically less than emissions per pound in Africa. And as part of the (Bill and Melinda Gates) Foundation’s work, we’re taking the benefit of the African livestock, which means they can survive in heat, and crossing-in the monstrous productivity both on the meat side and the milk side of the elite U.S. lines.”

Here’s the thing. A month before his book release, Gates made headlines as “the man who is about to change the way America farms.” In January, the 2020 Land Report 100 featured Gates as “America’s leading farmland owner with 242,000 acres of productive farmland in more than a dozen states.”

According to the Land Report map, Gates’ swaths of farmland, amassed through front-company Cascade Investments, are located mainly near water and ports across 19 states.

Gates is also a founding member of an investor group (Leading Harvest), setting a sustainability standard for over 2 million farming acres in 22 states and another 2 million in 7 countries, according to the Land Report.

Furthermore, the Bill and Melinda Gates Foundation (separate from Cascade Investments and Breakthrough Ventures) has a farmland initiative called Gates Ag One, based in St. Louis. According to the St. Louis Business Journal, its focus is research to help farms in low- and middle-income countries adapt to climate change by becoming “more productive, resilient and sustainable.”

The Breakthrough Energy Ventures (BEV) investment fund recently changed its website, but the strategies for agriculture and food production are still clear when clicking through tabs. Here’s just the tip of the iceberg. BEV website screenshot by Sherry Bunting

Gates also chairs the investment fund called Breakthrough Energy Ventures (BEV), mentioned in various ‘fake-meat’ and ‘fake-dairy’ articles published in Farmshine over the past three years.

The BEV fund is mentioned throughout Gates’ new book as a ‘philanthropic’ fund with a climate strategy. Digging into the website, one sees the fund’s climate investments described as “patient, risk-tolerant capital” that will recoup return on investment years down the road once the global supply chains, government policies, and other strategies move consumers toward the various sector outcomes the BEV billionaires are investing in.

The BEV investor list includes significant interests based in China; Democratic party candidates and/or donors like George Soros, Tom Steyer, and Michael Bloomberg; big tech billionaires like Gates, along with Mark Zuckerburg, founder of Facebook, and Jeff Bezos, CEO of Amazon.

The two-pronged approach to animal protein in Gates’ book reflects the two-pronged investments of Gates, BEV, Leading Harvest and the Bill and Melinda Gates Foundation. On the personal and fund investment side, Gates and friends have put billions of dollars into ‘replacement ag systems’ featuring fake-animal-protein for ‘rich’ countries, while on the foundation side, the focus is on research for efficient animal ag systems in poor countries.

In fact, the Bill and Melinda Gates Foundation – which has endeared itself to Big Ag by supporting biotech research for developing countries — was among 11 top-level sponsors in the $100,000-plus donation category for the American Farm Bureau Federation’s virtual convention in January.

During the 2021 convention, Farm Bureau president Skippy Duvall and Land O’Lakes CEO Beth Ford — together — provided a joint keynote discussion under the ‘stronger together’ 2021. Ford spoke of Land O’Lakes’ 2020 partnership with Microsoft to build an “artificial intelligence” ag-tech platform to automatically gather data from farms and trade carbon credits. The discussion ended with a focus on climate-smart technology and a more “inclusive” advocacy platform less cluttered by production identity labels.

For his part, Duvall stated that, “There’s room in the marketplace for everyone, every type of production — organic, conventional, plant-based meat, whatever it might be — there’s enough room in the market for all of us,” he said. “We have to stop throwing ourselves under the bus and work together as one united family.”

This sentiment dovetails with the global food transformation agenda of companies and investors wanting to mix-match-and-blend in a way that melts-away protein identities in favor of planetary diet standards, labels and symbols. Walmart’s director of sustainability talked about this during a World Economic Forum virtual event reported in Farmshine in January, and it is showing up in Walmarts today with big name frozen entrées in lookalike packaging, featuring BE’F, CHICK’N and DAI’Y. How clever.

On the fake-animal-protein investments, Gates and friends are working with global mainline agriculture companies like Cargill, Tyson, ConAgra and ADM, as well as global food supply chains like PepsiCo, Nestle, Unilever, and Coca Cola, along with ‘replacement’ plant-based and cell-cultured fake-meat and fake-dairy manufacturers like Beyond Meat, Impossible Foods, Memphis Meats, BioPrint, and Perfect Day.

All of this ‘replacement’ or ‘alternative’ ag push is setting the stage for a massive land grab to meet the 30 by 30 executive order of President Biden that dovetails with United Nations goals to have 30% of U.S. and global lands in conservation protection by 2030. That would double the current 15%.

With billions in ‘patient capital’ invested, Gates and friends want to see U.S. consumers ‘herded’ toward the ‘herdless’ imposter-foods they’ve invested in.

The USDA-HHS Dietary Guidelines have the facilitating low-fat diets positioned and ready. The FDA Nutrition Innovation Strategy is a multi-year effort underway to modernize standards of identity and develop a universal ‘healthy’ symbol for ‘approved’ foods.

Meanwhile, Gates and friends are pushing for polices and pricing that shift diets more quickly from the ‘climate’ side. For example, wholesale boneless wing and tender prices, as well as beef, are rising rapidly (but not to producers). This effectively narrows the gap between real and fake to help with the transition. Even the dairy industry is moving to ‘dual purpose’ processing.

Digesting Gates’ book interviews, hearing him talk about carbon markets during a World Economic Forum Davos Agenda 21 livestream, and seeing the ‘who’s who’ board of the BEV investment fund – it is clear Gates and friends are politically well-positioned to push policies that can shift diets based on their investments.

They are also getting help from within the animal-sourced food industries to corral Gen Z as ‘agents of change’ that will embrace these China-sourced pea-protein concentrates and lab-created franken-foods as they scale up across household name brands. In its recent joint-venture announcement with Beyond Meat, PepsiCo admitted their alternative snack and beverage rollouts must be “effortless” so consumers don’t have to think about making the “right choices for the planet.”

Food transformation is unfolding rapidly as Big Ag, Big Food, Big Tech, Big Money players align with governments, non-governmental organizations (NGOs) and globalized supply chains.

To affirm the identity of real, local, U.S.-produced animal-sourced foods from farms will require a direct appeal to consumers and accountability for industry leaders and policymakers.

Overblown climate propaganda about dairy and livestock fuel policies that gradually undermine food production identity. Gates is not a food fortune-teller, but rather he is fixing to be a food fortune-maker believing he and his billionaire big tech cronies can ‘software program’ food and behavior to enrich their own outcomes.

We need to follow the money and wake up the public to see the garbage the elites are selling for what it really is. Some of us are ready to pick this food identity hill to die on.

-30-