USDA Public Comments: America’s Supply Chains

This post is for any member of the public who would like to give the Biden administration, and specifically the Secretary of Agriculture, Tom Vilsack, feedback on how you feel about the current status of our agricultural supply chains and food security. You do not have to be a farmer or own a food business. The deadline for public comments is June 21, 2021.

Below is the official invitation for comments with links to the appropriate USDA web page. The letter I am writing on behalf of California regional whole grain efforts will follow. You can also read it by scrolling through the public comments via links provided below – look for the public comment submitted by Grist & Toll on June 8. I am asking all who care about local wheat and flour, whether you grow it, mill it, bake with it, or eat it, to either post a public comment in support of my letter or to write your own. The truth is, our regional grain efforts will always be small and much more expensive until we receive help in the form of policy and funding to rebuild missing infrastructure, support independent seed resources, build new handling facilities, and regional mills. All regional grain collaborators have our own individual goals and aspirations, but the need for basic infrastructure and small scale grower/producer support is universal across the states.

If you are a farmer, miller or baker in any part of the country, please feel free to copy and paste anything from my letter and make it your own, or simply post a comment in support of mine.
If you are a consumer or home baker, please post a comment in support of my letter and tell the USDA why you support regional grain efforts.
Specifically if you live in California, please also call out Monica Spiller’s public comment. Monica ( created a 10 page pdf outlining grain handling and milling objectives for our state.

Look for the colored COMMENT Button to leave your own comment. You can also click on a link to Read the Public Comments which allows you to scroll through and read all posted comments:

Thank you for taking the time to read this! It’s time to start making some noise on behalf of our common goals. Please join me!

Here is the official invitation, copied and pasted from the Federal Register:
On February 24, 2021, President Biden issued an Executive Order on “America’s Supply Chains,” which directs several Federal agency actions to secure and strengthen America’s supply chains. One of these directions is for the Secretary of Agriculture (the Secretary) to submit, within one year, a report to the President that assesses the supply chains for the production of agricultural commodities and food products. This notice requests comments and information from the public to assist the U.S. Department of Agriculture (USDA) in preparing the report required by the Executive Order. Through this notice, USDA is also requesting public comment to inform our thinking regarding how stimulus relief programs and spending related to food supply chain resilience as authorized by the Consolidated Appropriations Act, 2021 (CAA), and the American Rescue Plan Act of 2021 (ARPA) can help to increase durability and resilience within the U.S. food supply.


Date: June 8, 2021
To: Dr. Melissa R. Baily, Agricultural Marketing Service, USDA
Re: AMS-TM-21-0034, Federal Register Page Number 20652
From: Nan Kohler, Owner, Grist & Toll, An Urban Flour Mill
Subject: Public Comments on President Biden’s Executive Order regarding “America’s Supply Chains”

As a small business owner with a vested interest in rebuilding regional grain economies, promoting economic growth in diverse local communities and mitigating the threat of climate change, I appreciate the opportunity to address this gravely important issue. My California-based flour mill, Grist & Toll, represents the type of bootstrapped supply chain collaborations that are happening across the United States between small scale grain growers, millers, professional bakers and consumers. Wheat crops, flour and bread have built nations and will remain critical to food systems as long as there are eaters on this planet. As such, it is particularly relevant that you hear from people like me, who are working hard to create alternatives to the industrial food system and who play key roles in creating healthier and more resilient food supply chains.

I appreciate that your assessment of supply chains for the production of agricultural commodities and food products supports the President’s broader mandate to secure and strengthen America’s supply chains. As you work to assess vulnerabilities, I urge you to think big; and as you endeavor to develop solutions, I urge you to think small.

As for vulnerabilities, the model of industrial agriculture and food manufacturing is failing. It is neither resilient nor environmentally sustainable. It generates maximum volumes of cheap food with minimal nutritional value, while simultaneously degrading our farmland and accelerating climate change. There is no better example of this than the power dynamics dictating how we grow wheat and turn it into flour and bread. The industrial system of monocultures, chemical dependency, roller-milled white flour and processed white bread can be directly tied to dramatic declines in both soil and human health.

“There is no connection between food and health. People are fed by the food industry, which pays no attention to health, and are healed by the health industry, which pays no attention to food.” Wendell Berry, 1993, Sex, Economy, Freedom & Community: Eight Essays

“Today, approximately 40 million Americans and 12 million children are food insecure, meaning they are often forced to skip meals and buy cheap non-nutritious food.”

As if that reality weren’t shocking enough, in 2019, multiple studies based on a full 20 years of data revealed that 11 million people around the world died of malnourishment, which has now officially surpassed tobacco as the leading underlying cause of death. The top recommended solution has been shouted out in every single study: a mandate to increase consumption of whole grain foods. There is no debate or confusion regarding this. And yet, not a single part of our industrial food supply chain has any incentive to deliver the healthy, whole grain foods our populations need.

Instead, we continue the devastating cycle of breeding proprietary, chemically dependent wheat varieties (Corteva, Chemchina, Bayer) suitable for roller mills (Ardent, ADM, Graincraft) and their production of pure endosperm flour, which is then sold mainly to the two corporate giants who control the industrial scale bakeries (Bimbo, Flowers) pumping out white bread as well as packaged baked goods loaded with high fructose corn syrup. Whole grain flour production is virtually nonexistent: the system simply isn’t designed for it. And because the system doesn’t concern itself with producing high quality whole grain flour, it reinforces and perpetuates the narrative that consumers will not purchase whole grain foods, a self-fulfilling prophecy.

Here in California we are home to giant industrial roller mills with the highest milling capacity of any state in the country, however, these mills do not support California grown wheat. Wheat is imported from other states and countries. We have gone from a high of 1,150,000 acres of wheat grown in 1982 (98% of that harvested for human consumption) to our lowest low last year of 425,000 acres planted to wheat (74% of it green chopped for cattle feed). Our wheat growers make more money feeding cattle than they do feeding us. Is it any wonder our farmers are struggling when the commodity system has locked them into dependency on a vanishing export market and spiraling financial losses?

Bold, visionary action is required to correct the destructive path we are on. The answer lies in directing funds and policy away from Big Ag and Big AgroIndustry that perpetuate our big broken system and towards creating new smaller systems that foster diversity, regionality and local economic prosperity. We will not have healthy supply chains or food security until this work begins in earnest.

To quote the IPES (International Panel of Experts on Sustainability) and their 2016 report From Uniformity to Diversity: A Paradigm Shift from Industrial Agriculture to Diversified Agroecological Systems, “The key is to establish political priorities, namely, to support the emergence of alternative systems which are based around fundamentally different logics, and which, over time, generate different and more equitable power relations. Incremental change must not be allowed to divert political attention and political capital away from the more fundamental shift that is urgently needed, and can now be delivered, through a paradigm shift from industrial agriculture to diversified agroecological systems.”

With this letter, I am not only advocating for the development of regional grain hubs that build local economies, protect and improve the food chain, promote health and contribute to reducing climate change, but specifically for the production of whole grain flour and whole grain foods. Our overly industrialized system is not only disinterested in producing whole grain flour and whole grain foods, it is quite literally incapable of doing so. And yet, to increase human health and decrease health costs the solution is obvious – increase whole grains. To increase food security and food system resiliency the solution is equally obvious – increase diversity: diversity of seed, farms, farmers, handlers, millers and bakers in pursuit of whole foods.

“The whiter the bread, the sooner you’ll be dead.” – Michael Pollan, 2009, Food Rules

It wasn’t the corporate giants who came through with flour for consumers during the COVID-19 lockdowns, it was regional farmers and small, regional mills like Grist & Toll. The world does not suffer from food insecurity due to low production volumes. We produce an abundance of food that, at best, has little nutritional value and, at worst, is actually detrimental to our health. Food insecurity is a direct result of failing politics and policies.

As you look to create healthier and more resilient food supply chains I strongly encourage you to:

  • Address the needs of socially disadvantaged and small-to mid-sized producers
    • Help beginning farmers purchase land and equipment for organic and regenerative farming, giving preference to our BIPOC community and those socially disadvantaged.
    • Make government owned land available for beginning farmers.
    • Make vacant farmland available to young, regenerative farmers.
    • Overhaul and diversify leadership at national farm institutions that have deeply entrenched histories of discriminatory practices.
    • Make disaster coverage available to small, independent farms.
    • Reform agricultural subsidies to give more federal support to small- and mid-sized farms instead of the small number of industrial producers.
    • Provide grants and technical assistance in support of small-scale grain handling facilities and equipment.
  • Bolster local and regional food systems
    • Use government funding to keep land in agriculture instead of housing and retail development.
    • Fund the development of regional grain hubs by increasing funds for LAMP (USDA’s Local Agricultural Market Program) and direct it to build strategically placed cleaning, milling and storing facilities which benefit small- to mid-sized grain growers.
    • Fund the development of local, independent distribution facilities for delivering the products of regional farm-to-market collaborators.
    • Pass legislation to address climate change that rewards transition to regenerative farming practices and benefits independent family farms. Grains are an important rotational crop in regenerative farming systems.
    • Shift the focus of Land Grant Universities away from the industrial model and biotechnology and back to agroecology and sustainable practices. Decreases in funding have led to privatization of seed and farming research at the university level. This must be reversed. Chemical companies should not be dictating seed research and development priorities. Please fund the university breeding programs again so they may gain the independence necessary to better serve their local farming communities and address climate change.
    • Fund the creation of regional seed banks to give farmers the ability to reproduce, share and access seed for crops with genetic biodiversity – we need to give the power of seed selection back to the farmers.
  • Support and promote consumers’ nutrition security, particularly for low-income populations
    • Issue a federal mandate for the production of whole grain flour and whole grain foods.
    • Provide grants and other funding opportunities for the development of regional whole grain flour mills.
    • Strengthen labeling requirements for “whole” foods. Whole should mean WHOLE and not a percentage of. Consumers are confused and big industry is playing the corners.
    • Mandate that school lunch programs transition to 100% whole grain.
    • Use public procurement to support local whole grain flour and food production, such as spending government money on whole grains for school lunch programs, military bases, hospitals, and additional market endeavors providing food to the vulnerable and disadvantaged.
    • Assist with the education, marketing and promotion of whole grain foods.
  • Create fairer and more competitive markets
    • Strengthen labeling standards in favor of smaller producers rather than large corporations which circumvent requirements to suit their own agendas.
    • Enforce the Clean Air and Water Acts for large, factory farms.
    • Let’s say hello to Anti-Trust Laws again and break up the monopolies.
    • Good food manufacturing practices must adapt to partner, rather than block, smaller, independent operations, and should accurately reflect the scale and manufacturing process a food business is engaged in – not all food manufacturers are giant Foster Farms raw chicken processing plants, and should neither be treated as such nor held to the same food handling requirements! One-size-fits-all discourages diversity and outside-the-box thinking, and prices out most budding food entrepreneurs. It’s time to acknowledge that big is more dangerous than small and the most egregious food safety issues happen at the industrial level.

Supporting regional grain efforts checks all the boxes for increasing food supply chain resiliency, diversity and security.  Regional grain efforts promote prosperity of local communities, support public health objectives and reduce environmental impact.

Certainly, on behalf of Grist & Toll and a developing national network of grain advocates, we are your visionaries with the skills and drive to make sustainable change. We have accomplished quite a bit without any assistance at all, even though we have been severely disadvantaged by a lack of capital, resources and regional infrastructure. However, the need to scale these efforts is obvious, and the market support is growing. Please end the doomed cycle of catering to the chemical and farming giants, the milling and baking monopolies. We, as regional collaborators, are ready to step up if you are ready to step away from the status quo.

The solution is to redistribute power in food systems.  Regional grain efforts hold the key to big change. We can’t do it on our own. You can’t do it without us.

Nan Kohler
Owner, Grist & Toll, an urban flour mill
Board Member, California Wheat Commission
990 S. Arroyo Parkway, #1
Pasadena, CA 91105

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