School Lunch Nutrition Downgrade

A new USDA rule change proposed for the National School Lunch and Breakfast Programs will allow food service operators to offer a school lunch nutrition downgrade to students across the US. Some of the claims by critics are are not entirely true, like pizza and burgers at every meal. However, the USDA’s counter arguments on Twitter are not very convincing either. Only the text of the rule change can bring light to these arguments. The trouble is, getting that document is unnecessarily difficult.

When the USDA started promoting this rule change, which they emphasize will benefit food service operators, they splashed it on the USDA home page and sent out press releases. News organizations published stories and started commenting on the unofficial document. Everyone encouraged people to comment and gave a link to do so. The link is

Now the trouble gets worse. As of 1/17/2020, you can’t find this rule change on because it isn’t there. Instead, you must become a detective to find out what is going on. Here’s the path I followed.

School Lunch Nutrition Downgrade

I started on the USDA home page. You can’t miss the announcement. Click the “Learn More” button. That loads the press release page. I saw the publication date of 1/23/2020, but glossed over it. I was focused on commenting on the proposed rule change. The USDA wanted me to comment on it, and so did everyone else, and I didn’t want to disappoint. So I clicked on the most logical link listed, Public Inspection Document. That gave me an official-looking document. Little did I know it was NOT official.

Before this turns into something much worse than a shaggy dog story, I’ll cut to the chase. The proposed rule change is not yet published, the PDF is not official, nor is the proposal open for comments. I gleaned all that information by visiting the unobtrusive Federal Register Link on the USDA press release page.

That’s where the gold is. That page clearly states that the document is not yet published and not ready for comment. It is slated for publication on January 23. Presumably, that is also when the comment period will open and when the document will be available on Here’s what you will need to know to find it on that site and make a comment.

The easiest way to find the document and a button to begin the comment process is by searching for the RIN (Regulation Identifier Number). It appears near the top of the unofficial PDF. The number is 0584-AE67. Paste that into the search box and it should pop up, I hope, and only on 1/23 and later.

Comment On Nutrition Downgrade

The whole point of this article is to encourage you to add your voice to a rule change that will reverse significant progress made in eliminating hunger and malnutrition for many school children. The result is a school lunch nutrition downgrade. I base my opinion on the text of the proposal itself, not on the USDA cheerleading efforts.

I used the unofficial PDF because that is all I had to work with. I’ll review the official document when it is available. Page 5 states “some Program operators have experienced challenges” implementing the nutritional standards that Michelle Obama inspired and made happen.

This sounds innocuous. No program is 100% effective. But the administration’s response to these complaints is telling. Instead of offering help to get the failing food service operators up to standard with best practices, the administration decided to lower the standard. Never mind that thousands of other schools met and exceeded the standards. Instead, the USDA wants to make life easier for these operators by letting them offer less food and less nutritious food. The argument is that by “offering” nutritious food instead of “serving” nutritious food, the child will get to choose, less food will be wasted, and the operator will get more profits.

Last time I checked, children generally don’t like vegetables, especially overcooked, tasteless veggies. They do like whole, fresh fruits and vegetables that are prepared well and actually taste good. They also have underdeveloped judgement and often make poor choices. That’s why this policy of giving kids a choice is passing the buck and letting the food service operators off the hook for delivering healthy, nutritious, and flavorful meals.

In a similar vein, page 8 notes the change will make permanent exceptions to the “Milk, Whole Grains, and Sodium Requirements”. Those exceptions allow sweetened flavored milk products (higher sugar, less nutrition), more salt, and replacing whole grain foods with highly refined and less nutritious alternatives.

The details of exactly how these changes will play out appear deeper in the document. Search for “Specific Public Input Requested” to go quickly to these detailed explanations and see exactly how the new rules trade nutrition for operator convenience.

That’s my take on this proposed rule. I think it’s a bad idea and ought to be rejected in whole. I’ll update this post on January 23 when the official document goes public.

School Lunch Program Rule Change Published

The USDA school lunch nutrition downgrade rule change is now available for public comment. Go to and enter  0584-AE67 in the search box. That is the official RIN value. When the search completes, the results page looks like the image below. You can also click here to go straight to the search results. Then click the dark blue “Comment Now!” button to make your comments.

School Lunch Nutrition Downgrade Comment

The document on the Federal Register page is also available. It is the official publication that you should read before commenting. You must submit your comments by March 23, 2020. That is when the public comment period closes.

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Ray N. Franklin lives in Fort Collins, Colorado. He has been a software engineer, granola entrepreneur, and internet marketer. Now he edits palindrome anthologies at and writes science fiction. is the place to find his stories and SF news. When not writing software he might be gardening or cooking up a mystery soup.

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