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.An interview with Nirvi Shah from Education Week shamed me into commenting on the Proposed Rule to align National School Lunch Program (NSLP) and School Breakfast Program (SBP) with 2005 Dietary Guidelines. I was helped enormously in this daunting task by my Ellyn Satter Institute colleagues, who brilliantly and dispassionately summarized that 80-page document and have shared it with you. Below my comments are instructions for how you, too, can work your way through the twists and coils of doing your duty on behalf of children.

Here is my comment. For lack of any better place to put it, my tracking number is 80c0cecb.

NLSP and SBP suffer from the same limitations as the Dietary Guidelines and need the following changes:

Support eating competence in the School Nutrition Programs Stop doing medical nutrition therapy and go back to supporting nutritional adequacy. Recognize that when feeding is positive and reliable, children bring themselves along with respect to improving the nutritional quality of their diets.

Emphasize providing, not depriving Maintain the structure of meals and snacks so children can count on eating - and eating enough. Offer meals that are adequate in energy for all children. Offer a variety of well-prepared and enjoyable food, then trust children to push themselves along to eat as much as they need and eat a variety of food. Also keep in mind that when the joy goes out of eating, nutrition suffers.

Think about how, not just what. Restrict between-meal drinks, munchies and treats - even nutritious ones - to structured snacks so children can go to lunch hungry and ready to eat.

Feed in developmentally appropriate ways Provide nutritious and filling sit-down snacks midmorning and midafternoon for kindergarten and first grade children. Retain food-selection leadership with middle school children, who are still forming their food habits, by keeping ala carte foods off the lunch lines. Give high-schoolers choices and opportunities to experiment with all kinds of foods, but hold the line with rules about where in the school food is allowed. In their natural quest for autonomy, adolescents get around rigid rules and controlling grownups. Forbidden-food black markets spring up in high schools that try to tightly control the food environment.

Stop being so data-resistant with respect to what school nutrition programs can accomplish. As demonstrated by huge, highly funded interventions, tight controls on school menus leave children’s overweight status unchanged. An article attached gives the evidence. Children apparently compensate elsewhere for restrictions at school.  

I attached three articles:
Satter EM. Dietary Guidelines and Food Guide Pyramid incapacitate consumers and contribute to distorted eating attitudes and behaviors. Health at Every Size. 2005;19(3):161-170.
      Satter EM. Appendix G, Feeding and Parenting in the School Setting. Your Child's Weight---Helping Without Harming. Madison, WI: Kelcy Press; 2005:409-418.
Satter E. Dietary Guidelines 2010 and Eating Competence, Family Meals Focus #54. 2011; http://www.ellynsatter.com/february-2011-family-meals-focus-54-dietary-guidelines-2010-and-eating-competence-i-166.html.

Write your comments to The Food and Nutrition Service, USDA. Submit or postmark on or before April 13, 2011.

On-line submission, which is preferred:
Federal eRulemaking Portal at http://www.regulations.gov/#!home.  Keyword or ID box: FNS_FRDOC_0001-0184.
You get a 2000 character box and the option of attaching documents. You have 20 minutes to register, enter your comments, and do your attachments.  

Mailed comments:  
Julie Brewer, Chief
Policy and Program Development Branch
Child Nutrition, FNS, USDA
3101 Park Center Drive, Rm 640
Alexandria, VA 22302–1594.