I02 Response to Public Comments

APPENDIX I02. RESPONSE TO PUBLIC COMMENTS

February 22, 2024
Audrey Lawson-Sanchez
Executive Director, Balanced
Madeline Bennett, MS
Nutrition Policy Analyst, Balanced
Re: 2024-2025 National School Foods Study
Dear Ms. Lawson-Sanchez and Ms. Bennett:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS).
We share your interest in gathering data on plant-based school food and plant-forward
school meal offerings in the National School Lunch Program (NSLP) and National School
Breakfast Program (SBP). To that end, the NSFS will estimate the prevalence of plant-based
offerings in school meals at the school level and will also understand the consumption of
plant-based meals and products at the student level, as we conduct dietary recalls as part of
this research. We will collect information on all foods procured by a sample of SFAs, for use in
both the Child Nutrition Programs as well as non-program foods. While we will ask about nut
butter, we include other vegetarian and plant-based entrees at every level of our menu
survey; we intend to assess the nutritional characteristics of all items offered and served.
Further, the surveys at the School Food Authority (SFA) director level ask about culturallydiverse meals and their intention to cater to the student population. As you note in your
letter, this information will help USDA meet the Congressional directive to “collect, analyze,
and publish research relating to the availability of plant-based and alternate protein meal
options under USDA programs in schools and other congregate settings, and the impact of
plant-based and alternate protein meal options on population health outcomes.”
We appreciate your recommendation to better understand the demand of plant-based meals
in the NSLP and SBP. The study also includes surveys to collect data from parents and

Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

Page 2 of 2
students on satisfaction with school meals. While we do not specifically ask about
preferences for plant-based or alternative meals, the parent and student instruments include
open-ended response options that provide the opportunity for respondents to provide
information about what they consumed that day. USDA would like to understand all we can
about demand for plant-based offerings, as well as many other topics, and we felt this was
the most appropriate approach to gather such information without adding substantively to
the burden of the study on SFAs, schools, and families.
Thank you again for your input. We truly appreciate the recommendations and support for
the study.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service
United States Department of Agriculture

February 22, 2024
Jennifer Molidor
Senior Food Campaigner
Center for Biological Diversity
Re: 2024-2025 National School Foods Study
Dear Ms. Molidor:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS).
We share your interest in gathering data on plant-based school food and plant-forward
school meal offerings in the National School Lunch Program (NSLP) and National School
Breakfast Program (SBP). To that end, the NSFS will estimate the prevalence of plant-based
offerings in school meals at the school level and will also understand the consumption of
plant-based meals and products at the student level, as we conduct dietary recalls as part of
this research. We will collect information on all foods procured by a sample of SFAs, for use in
both the Child Nutrition Programs as well as non-program foods. While we will ask about nut
butter, we include other vegetarian and plant-based entrees at every level of our menu
survey; we intend to assess the nutritional characteristics of all items offered and served.
Further, the surveys at the School Food Authority (SFA) director level ask about culturallydiverse meals and their intention to cater to the student population. As you note in your
letter, this information will help USDA meet the Congressional directive to “collect, analyze,
and publish research relating to the availability of plant-based and alternate protein meal
options under USDA programs in schools and other congregate settings, and the impact of
plant-based and alternate protein meal options on population health outcomes.”
We appreciate your recommendation to better understand the demand of plant-based meals
in the NSLP and SBP. The study also includes surveys to collect data from parents and
students on satisfaction with school meals. While we do not specifically ask about
Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

Page 2 of 2
preferences for plant-based or alternative meals, the parent and student instruments include
open-ended response options that provide the opportunity for respondents to provide
information about what they consumed that day. USDA would like to understand all we can
about demand for plant-based offerings, as well as many other topics, and we felt this was
the most appropriate approach to gather such information without adding substantively to
the burden of the study on SFAs, schools, and families.
Thank you again for your input. We truly appreciate the recommendations and support for
the study.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service
United States Department of Agriculture

February 22, 2024
Chloë Waterman
Sr. Program Manager, Climate-Friendly Food Campaign
Friends of the Earth
1101 15th St NW
Washington DC 20005
Re: 2024-2025 National School Foods Study
Dear Ms. Waterman:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS).
We share your interest in gathering data on plant-based school food and plant-forward
school meal offerings in the National School Lunch Program (NSLP) and National School
Breakfast Program (SBP). To that end, the NSFS will estimate the prevalence of plant-based
offerings in school meals at the school level and will also understand the consumption of
plant-based meals and products at the student level, as we conduct dietary recalls as part of
this research. We will collect information on all foods procured by a sample of SFAs, for use in
both the Child Nutrition Programs as well as non-program foods. While we will ask about nut
butter, we include other vegetarian and plant-based entrees at every level of our menu
survey; we intend to assess the nutritional characteristics of all items offered and served.
Further, the surveys at the School Food Authority (SFA) director level ask about culturallydiverse meals and their intention to cater to the student population. As you note in your
letter, this information will help USDA meet the Congressional directive to “collect, analyze,
and publish research relating to the availability of plant-based and alternate protein meal
options under USDA programs in schools and other congregate settings, and the impact of
plant-based and alternate protein meal options on population health outcomes.”
We appreciate your recommendation to better understand the demand of plant-based meals
in the NSLP and SBP. The study also includes surveys to collect data from parents and
Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

Page 2 of 2
students on satisfaction with school meals. While we do not specifically ask about
preferences for plant-based or alternative meals, the parent and student instruments include
open-ended response options that provide the opportunity for respondents to provide
information about what they consumed that day. USDA would like to understand all we can
about demand for plant-based offerings, as well as many other topics, and we felt this was
the most appropriate approach to gather such information without adding substantively to
the burden of the study on SFAs, schools, and families.
Thank you again for your input. We truly appreciate the recommendations and support for
the study.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service
United States Department of Agriculture

February 22, 2024
Re: 2024-2025 National School Foods Study
Dear Ms. Rau:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS).
We share your interest in gathering data on plant-based school food and plant-forward
school meal offerings in the National School Lunch Program (NSLP) and National School
Breakfast Program (SBP). To that end, the NSFS will estimate the prevalence of plant-based
offerings in school meals at the school level and will also understand the consumption of
plant-based meals and products at the student level, as we conduct dietary recalls as part of
this research. We will collect information on all foods procured by a sample of SFAs, for use in
both the Child Nutrition Programs as well as non-program foods.
Further, the surveys at the School Food Authority (SFA) director level ask about culturallydiverse meals and their intention to cater to the student population.
Thank you again for your input. We truly appreciate the recommendations and support for
the study.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service
United States Department of Agriculture

Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

February 22, 2024
Re: 2024-2025 National School Foods Study
Dear Ms. Thompson:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS).
We share your interest in gathering data on plant-based school food and plant-forward
school meal offerings in the National School Lunch Program (NSLP) and National School
Breakfast Program (SBP). To that end, the NSFS will estimate the prevalence of plant-based
offerings in school meals at the school level and will also understand the consumption of
plant-based meals and products at the student level, as we conduct dietary recalls as part of
this research. We will collect information on all foods procured by a sample of SFAs, for use in
both the Child Nutrition Programs as well as non-program foods. While we will ask about nut
butter, we include other vegetarian and plant-based entrees at every level of our menu
survey; we intend to assess the nutritional characteristics of all items offered and served.
Further, the surveys at the School Food Authority (SFA) director level ask about culturallydiverse meals and their intention to cater to the student population.
Thank you again for your input. We truly appreciate the recommendations and support for
the study.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service
United States Department of Agriculture

Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

February 22, 2024
Roberta Wagner
Senior Vice President,
Regulatory and Scientific Affairs
IDFA: International Dairy Foods Association
Re: 2024-2025 National School Foods Study
Dear Ms. Wagner:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS). We share your interest
in gathering data on milk offerings in the National School Lunch Program (NSLP) and National
School Breakfast Program (SBP).
The NSFS will estimate the prevalence of varied milk offerings in school meals at the school
level and will also understand the consumption of milk and other dairy products at the
student level, as we conduct dietary recalls as part of this research. We intend to assess the
nutritional characteristics of all items offered and served and, as always, intend to make
publicly-available as much data as possible. We also include varied indirect costs as we
estimate the cost of a reimbursable meal.
Further, we will collect procurement and price data for school-purchased items and USDA
Foods. We will collect data on all foods procured by a sample of SFAs, for use in both the Child
Nutrition Programs as well as non-program foods, and this definitively includes milk, cheese,
and yogurt in its many containers and types.
Finally, to the extent possible, we will compare these data to the previous School Nutrition
and Meal Cost Study and the School Food Purchase Study, to establish a trend over time.
Very best,
Ashley Chaifetz
Senior Analyst
Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender

February 22, 2024
Katie Brown, EdD, RDN
President
National Dairy Council
Re: 2024-2025 National School Foods Study
Dear Dr. Brown:
Thank you so much for the thoughtful comments you provided in response to the Federal
Register notice for the 2024-2025 National School Foods Study (NSFS). We share your interest
in gathering data on milk offerings in the National School Lunch Program (NSLP) and National
School Breakfast Program (SBP).
The NSFS will estimate the prevalence of varied milk offerings in school meals at the school
level and will also understand the consumption of milk and other dairy products at the
student level, as we conduct dietary recalls as part of this research. We intend to assess the
nutritional characteristics of all items offered and served and, as always, intend to make
publicly-available as much data as possible. We appreciate your suggestion to include take
rates for specific foods in the report and will take that into consideration as we plan for
dissemination of results from this study.
Further, we will collect procurement and price data for school-purchased items and USDA
Foods. We count on participating School Food Authorities to provide this data at the SFA
level, as we also only have State level data on USDA Foods provision.
Finally, to the extent possible, we will compare these data to the previous School Nutrition
and Meal Cost Study and the School Food Purchase Study, to establish a trend over time.
Very best,
Ashley Chaifetz
Senior Analyst

Food and Nutrition Service, Braddock Metro Center, 1320 Braddock Place, Alexandria, VA 22314
USDA is an Equal Opportunity Provider, Employer, and Lender