 Hello everybody, welcome to the 2021 Hot Topics and Environmental Law Summer Lecture Series. I'm Jenny Rushlow, Director of the Environmental Law Center and Associate Dean for Environmental Programs here at Vermont Law School. We're pleased to welcome our viewers to our presentation today. Each one of these talks is worth one Vermont CLE credit, so please keep track of which talks you attend if you're looking for a CLE credit. We will have time for Q&A after the presentation today, so you can type any questions you have in the chat at any point during the lecture and we'll get to as many of them as we can in the remaining time. Today for our speaker, we are very pleased to welcome Professor Larry Behronevan. Professor Behronevan is the Director of the Center for Agriculture and Food Systems and a Professor of Law at Vermont Law School. She is an alum and received her JD from VLS in 2003 and prior to joining the faculty at VLS after a judicial clerkship, Professor Behronevan joined the faculty, or sorry, she was a staff attorney at Vermont Legal Aid where she represented adults and children in individual cases and class action litigation advocating for access to health care, education, equality and civil rights. She's also published a number of scholarly articles and book chapters that focus on the connections between human health and the food system. Her work has been cited widely and she's been quoted in many major news outlets. She's an appointed member of the Food and Drug Law Institute and Georgetown Law School's Food and Drug Law Journal Editorial Advisory Board, a founding member of the Academy of Food Law and Policy, and the Chair-Elect of the Agriculture and Food Law Section of the American Association of Law Schools, or AALS. Today Professor Behronevan will present a talk titled, Why the US Needs a National Food Strategy. Please join me in welcoming Professor Larry Behronevan. Thanks so much, Jenny. And I should say I was the Chair of the Food and Drug Law Section, but we now have a new Chair. So that's probably, I need to update my bio on the website. So great. I'm going to just talk to you all for a minute before I try to share my screen and pull up my PowerPoint, just to let you know the origins of this particular presentation and the project that this presentation is based on. So in around 2015, there was an op-ed that was published by a number of food system leaders, including Mark Bitman, Michael Pollan, Ricardo Salvador, Olivia Deschute, and some others that was calling for the creation of a US national food policy. And what they were calling for, some of you may have seen this in the Washington Post, what they were calling for was a really specific set of measures that were focused on amendments, potential amendments to the Farm Bill. And they just had very specific substantive things that they were calling for. So we, along with the Harvard Food Law and Policy Clinic, secured funding from the Kellogg Foundation to basically write a blueprint for a national food strategy in the United States to think about what it would look like for the US to adopt a national food strategy. And that we deliberately stayed away from the substance. We wanted to focus on process. And we focused on domestic examples of other national strategies that had been adopted to address other big national issues. And then we also looked at a set of international, international-level food strategies to see what steps those countries had taken to be able to develop those. We published that initial report in 2017. And we published it just before the election. And we didn't see a lot of movement in the US pushing for a national food strategy following the publishing of that report. But we did actually in Canada. And the report wound up being really helpful to advocates in Canada who were thinking about how to structure conversations around process for building their national food policy. So in October of 2020, we published an update report, the urgent call for a US national food strategy, given the upcoming election and also what we had seen as some of the outcomes of COVID and how they impacted the food system. So what I'm going to focus on today is our update report. I'll make some references to the original report that we published in 2017. But by and large, I'll focus in on the update report. So let me share my screen. So on this page, these are basically just the covers of each of the report. On the left-hand side, you can see the February 2017 report. And then on the right, you can see the urgent call report that we published in October 2020. And normally I give this presentation along with one of my co-authors, Emily Bradley, about the Harvard Food Law and Policy Clinic. But I'm just going solo today. So I will probably focus in large part on the international aspects of our report since that's where we really focused our research. And I should also say a huge thank you to the many students that have been involved in this project and these reports over the years that we developed them. And also the LLM Fellows, one of which was Sydney Pence, who some of you may have heard last week give a presentation. So I thought I would start just by going through what the food system is. And some of you watching may not be familiar with the notion of what we mean by the food system, even if you've heard people use it in language. So basically, this diagram comes out of our report. And what's important to know about the food system. So you can see in the pictures going down, farm inputs, production, processing, and manufacturing, we think of all of those as the food supply chain. So when you're thinking about food moving from farm to table, these are the sort of traditional typical steps that food takes from farm to table. The food system is more than just the food supply chain. So the food system includes a number of factors that both impact and are impacted by the food supply chain. And we have those over to the right. So environmental factors, economic factors, health factors, and social factors. And what's important to know about the food system in the US is that it's governed by a really complex web of laws and regulations that involves government agencies, foreign and domestic stakeholders, community organizations that are advocating for policies that often conflict with each other, create redundancies, or sometimes increase inefficiencies. And so I'll walk through some of the different impacts that we see from the food system. So one major impact that we see from the food system is health impacts. And before COVID, diet related disease, which includes obesity, heart disease, stroke, type 2 diabetes, hypertension, and various types of cancer was the most significant public health challenge facing the United States. And one thing we saw as an outcome of COVID was that individuals suffering from diet related disease had worse outcomes related to COVID than individuals who weren't suffering from diet related disease. And the rates of all of these diet related diseases have only climbed in the past few decades. So for example, at this point, nearly 10% of Americans suffer from diabetes today. More than one third are pre-diabetic, so meaning they're on their way to getting diabetes and we're talking about diet related type 2 diabetes, compared with less than 1% 50 years ago. So that's pretty significant. Another set of impacts that we see from the food system are environmental impacts. So we know that to produce food, some farmers and producers use pesticides and other environmental contaminants. Those wind up polluting our waterways. They deplete natural resources and they harm local communities. And I should say this also takes into account industrial animal agriculture production, which presents really serious harm to surrounding communities. And in the US, agriculture accounts for 80 to 90% of consumptive water use. It's also a leading cause of water quality impairment. And despite all of that, all of the resources that go into producing our food, 40% of the food that we produce in the US is either lost or wasted. And we're talking about either at the farm level or post farm level. And at this point, food waste now accounts for the highest percentage of organic waste in landfills. So that contributes further to human related methane emissions in the US. And then there are some other statistics that you can see here. So the environmental impacts of the food system are quite significant. In terms of economic impacts, even though food and agriculture contributes an enormous amount to our GDP annually, food system benefits aren't distributed equally across economic and racial groups. So if we think about the amount of money that farms are or the income that farms are realizing, 51% of farm production value comes from large scale farms that are making over a million dollars annually in gross income. Yet by contrast, small scale family farms account for only 26% of total farm production, despite representing 89% of all farms. So that means that really big farms that happen to make much more in income are actually dominating most of the production in the United States, even though we have a number of smaller farms that represent 89% of the farms in the US. In terms of racial disparities, if we think about farm subsidies and payments, white farmers received 98.9% of government farm payments according to the 2017 USDA Census of Agriculture, with only 0.6% of government payments going to farms that had Black or African American producers. And then other racial groups are similarly underrepresented in terms of receiving subsidies and farm payments from the USDA. And then finally, if we think about some of the impacts of the food system to the workers that work in the food system, despite being essential to the food supply, and I use this language being essential because food system workers and farm workers were deemed essential during the pandemic, yet they remain unprotected by most labor laws. And what we saw with COVID is that they also were unprotected in terms of receiving personal protective equipment, access to vaccines. So they've been unprotected for a very long time by most labor laws. We also saw them deemed essential and then left unprotected during COVID. Agricultural workers work in a very dangerous occupation. There's a significant risk for them for fatalities and injuries, work-related lung disease, hearing loss, skin disease, cancer associated with chemical use and prolonged sun exposure. And yet they don't receive many of the same workplace protections that workers and other protections do. Additionally, almost half of the 2 million migrant and seasonal farm workers in the US in that number is likely an underestimate because it's difficult to get the true count of how many migrant and seasonal farm workers there are in the US. Almost half of them are undocumented, which means that they're ineligible for government assistance, including the various forms that are stated on this slide. But also during COVID, when a number of individuals were able to receive unemployment or other benefits from the government, undocumented workers were also ineligible for receiving government assistance, unless the state that they lived in created legislation to directly make sure that they were going to be eligible for that assistance. And I'm proud to say Vermont is one of the states that did so. So we have all of these myriad issues presented by the food system. And I gave you a sense of those. I didn't give you all of the different issues that are presented by the food system. But basically what we argued for, both in the original blueprint and in the update report, was basically that there's a strong need for governmental coordination to solve these systemic food system issues. So we have any number of government agencies that deal with the food system, including the Food and Drug Administration, the Department of Agriculture. You just heard about the immigration status of farm workers, which means that now we're talking about immigration. We're also dealing with international trade. The Environmental Protection Agency is involved when we're thinking about pollution and pesticides. And that's sort of just the tip of the iceberg. Homeland security plays a role in the food system. And we have all of these different agencies that play a role. And we have very few mechanisms that either require or encourage them to coordinate with each other. And the agencies that I just mentioned are all agencies at the federal level if you start to think about how that plays out at the state and local level. And then include tribal government. You basically have a whole host of bodies that are making decisions about the food system in many different ways that can have a tendency to cause inefficient or unintended consequences. If we think even just about food safety, there are 15 administrative agencies that deal with food safety alone. And that's just one single issue if we're thinking about the food system. Also, as you can see in this slide, there are a number of different committees in the house alone that deal with food policy. So you have agricultural subsidies and funding, food safety authority, and then school meals and food support for women, infants and children where you have three separate committees dealing with all three of those issues that are somewhat related. And it would make a lot of sense to have those bodies coordinating in addition to a number of other bodies. So our argument was basically that to be able to essentially address all of these systemic issues and to be thinking about them over the long term, we need some sort of mechanism in the United States that's causing agencies and government to coordinate around the food system. So the recommendations that we made in 2017 largely remain the same in our new report, although we added a couple of recommendations based on just what we had seen over the years since we had written the report and also in response to COVID. Our essential recommendations were that we need coordination. So there needs to be some sort of lead office or agency in the US that has resources, importantly. And also the authority to compel engagement across all of these different actors and action and creation of the strategy. We also felt that it was really important to have some sort of interagency working group that could coordinate the key offices and agencies that oversee the laws and regulations that shape the food system. And we also need to engage state, local and tribal government leaders as key partners. We also focused really heavily on participation and what participation looks like for food system stakeholders. So in the original report, we recommended that we create an advisory council that would engage vital stakeholders from outside government to help with strategy development so that it's not just government coming up with the strategy, but that you have a group of advisors that represent vital stakeholders in the food system that can help think about what the strategy should be. Also that there be an opportunity for stakeholders to provide feedback throughout the process and that government think really hard about how to engage in illicit stakeholder and public participation. And then to respond to that public input and explain why one course of action was chosen over another. This is actually a really important point because what we often see with decisions that impact the food system is that there are any number of trade-offs involved in decisions. And without knowing what the options are and why one course of action makes more sense than another or what stakeholders think about one course of action over another. We often make decisions that don't necessarily take into account what the long-term impacts might be. And then for accountability and transparency that there be public-facing reports, a written strategy document that the government is actually measuring progress against what the goals, metrics and expected outcomes were. And then that the strategy is durable so that there's periodic updating of this strategy and that that's built into the strategy itself to reflect changing social, economic, scientific and other technological factors. And one thing that we tossed around a lot and we still talk about is some sort of procedural mechanism like the one that's embodied in NEPA or the National Environmental Policy Act that essentially requires agencies to consider the agencies across the board not just environmental agencies to consider the environmental impacts of their actions so that that can help to guide agency decision-making that impacts the food system. So what we've seen since 2017 and we spent some time looking at this in the update report was basically to see what's happened since 2017 and like how have government agencies engaged in the food system started to coordinate and have they started to coordinate more? And what we saw is that for food safety and food waste in particular that there were a number of different interagency agreements and MOUs that agencies have entered into since 2017. What you can see though, if you look at this is basically these are like the same agencies and they're sort of the same major agencies that we often think of involved in the food system. So USDA and FDA dealing with basically having an agreement to bolster collaboration and coordination noting the fact that the GAO recommended that they need to do that and to have some sort of stronger commitment to having increased interagency communication and coordination. And then that they work to streamline produce safety requirements for farmers. So because USDA is often the agency that deals with farmers and agriculture but yet FDA has the responsibility for the Food Safety Modernization Act that the two agencies work together to make sure that farm inspections are more efficient and are actually effective at reducing instances of foodborne illness. A newer one was the agreement to coordinate on cell-based meat because the agencies were both in a bit of a argument about which agency was the right agency to regulate cell-based meat. And so this agreement came out of that to harmonize and get the agencies to coordinate. And then on the food waste side we see USDA, EPA and FDA entering into a couple of different MOUs. And while all of this is great while it's wonderful to see these governmental agencies making more gestures toward coordination all of these agreements and MOUs basically only involve a couple of different agencies three at the most. It's the same agency sort of over and over again. And they're limited, these agreements and MOUs are limited in their effectiveness because they're not taking into account a broader set of actors and externalities that impact the food system. And as you can see, if you take a look at these they're all on very discreet specific issues. So without expanding support for interagency coordination and making sure that there's a plan in place for them to actually coordinate MOUs and interagency agreements between two or three agencies in response to these narrow food system issues are not going to address the long-term systemic challenges that we see presented by the food system. And then I talked about a few slides ago. So I mentioned at the beginning of this presentation that most of the focus for us so we wrote this report with the Harvard Food Law and Policy Clinic the Harvard team focused on domestic strategies and other types of tools that we've used in the US to address issues of national concern. So some of those, one of the big ones was the national HIV AIDS strategy that we had in the US to address the HIV AIDS crisis. And one thing that we saw was in other countries when other countries were developing national food strategies it was often in response to some sort of national crisis. So we looked at both domestic and international strategies to see what lessons we could take from those in thinking about how to build a national food strategy in the US. And so one thing that was exciting to see was since our report in 2017, the UK who we actually cited to in the original report had at this point in July of 2020. So this was right as we were doing our research and writing announced part one of their national food strategy. And they had to pivot a bit. The UK was intending to release just a full national food strategy in July of 2020 but because of COVID, they essentially released their part one in response to COVID. And what we had seen about the UK is that the UK as a country has really valued, coordinated, comprehensive national strategies as a tool to address food system challenges. So this national food strategy came out of a longer set of discussions in the UK about how to address the challenges presented by the food system. And they also, what they referred to as it is is joined up food policy where they were basically thinking about who are all the different actors and agencies involved and how do we figure out how to get them to work together. And because the UK was leaving the European Union this was a good time for them to think about what it meant for them to address food system challenges as a country. So they have, even though they've been in a state of transition they've continued their focus on policy coordination and recognized that the pandemic provided the impetus for them to have a new approach to food system law and policy making. So they released part one of their strategy and it centered on two themes essentially. So one is addressing issues faced by the most disadvantaged children in the UK and that's the language that they used. And two, they were focused on sovereignty, trade and standards of quality. So that second piece, I think you can see the direct connection between that and Brexit because basically the UK was trying to think about how do we create our own national food system? How do we support our own national food system? And what standard of quality do we want food to measure up to in the UK? And how can we ensure that we're gonna have food that measures up to that standard? So the strategy has a bunch of different types of directives under the first category it's largely focused on expanding food assistance programs under the second theme the strategy suggested increasing import restrictions to prevent food from entering the UK that doesn't meet the UK's rigorous environmental and animal welfare standards. And the creation of a new set of core standards to be developed by a trade and agricultural commission in the UK. So the UK intends to release a part two of this report which will actually represent its comprehensive plan with recommendations for government in developing the overarching national food strategy. So that was one really positive development. So since 2017, the UK released part one of its national food strategy and it's at work on building out a more comprehensive national food strategy. The other really exciting development was that since our report was published, Canada actually developed a national food policy. So there had been a number of advocacy organizations in Canada, most prominently Food Secure Canada that had been pushing government to develop a national food policy for Canada. And so they did and created the food policy for Canada everyone at the table. And it was led by agriculture and agri-food Canada as the lead agency. We feel like because of, both because of its proximity to the US and also the similarity in the way that their government is structured. So they have a similar set of agencies engaged in the food system to us in the US that have a similar set of functions. So that to us, Canada feels like a really strong analogue for developing a national food strategy in the US. And one thing that's really notable about Canada's process, if we're thinking about it from a process perspective is how much they engaged the public. So in our report, there's a diagram that we pulled from, I think from the government's website that basically shows like how many listening sessions they had, how many people submitted public comments. They also worked really, really hard to engage the country's indigenous populations. So they had an online survey, they had a national summit that was focused on food policy. They had regional and local town hall and consultation events that were organized by different members of parliament. They had community events that were led by various civil society groups. And they had self led discussions through national indigenous organizations which was the preference of those organizations. They didn't wanna have to participate in something that they hadn't organized. They wanted to participate in their own conversations. And the online survey had 45,000 responses with 71.2% of those coming from the general public. And the consultations, the public consultations that were led with civil society focused on four themes essentially. So increased food access and food security which is an issue in Canada, it's also an issue in the US. It's an issue in most of the world, frankly, health and food safety, natural resource conservation and producing high quality food products. So you see a similarity with the UK there. So in addition to thinking about what had happened internationally, what we wanted to consider in this report was how COVID really highlighted a number of food system challenges in the US. And it feels a little bit like we're far removed from this or somewhat far removed from this. But at the time we were writing this report, the food system impacts from COVID still felt very real and very present and very current. It was still at a time when there were very long lines for people waiting at food banks to be able to get food. It was at a time when it was hard to get certain types of food and people weren't going to the grocery store. And the conversations around the food system were how do we think about rebuilding in light of everything that we've seen from COVID? And so many of these issues that were presented to those of us who work in the food system and are exposed to these issues regularly, these issues that were highlighted in the news and that people were talking about a lot more already existed before the pandemic at crisis levels. So we saw soaring rates of food insecurity and reduced access, disproportionate impacts to underserved and BIPOC communities, inadequately protected food system workers, staggering amounts of lost income for farmers and threats to farm viability, increased food waste, concentrated distribution networks and concerns about food safety. And yet all of these things from our perspective, even if the pandemic heightened the awareness of them among the general public, they already existed before the pandemic. And so the pandemic gives us an opportunity to really think about how to address them over the long term. And unfortunately, in part because of the lack of formal structures for agency cooperation, the federal solutions to the pandemic were piecemeal, incremental and responsive rather than being sweeping, strategic and proactive like we would have wanted to see. So in terms of the key elements of a national food strategy, you hear a lot of conversations about what the actual substance of the strategy should be, which is where we started this project from in the beginning, a bunch of food system leaders suggesting what the specific policy goals and priorities should be for a national food policy. But yet to us the strategic process is equally, if not more important and a needed first step. And I think as we've seen a lot of, at the same time that COVID was happening, we were seeing a number of calls for racial equity. And I think if you start to think about those two things in tandem, this strategic process of taking public input and really hearing from stakeholders and engaging stakeholders in the creation of the actual policy goals and priorities becomes even more striking than when we wrote this back in 2017. So from our perspective, if there isn't a thoughtfully designed process that's enabling broad representation and participation, then the national food strategy could suffer from some of the same issues that we face, in the sense that it excludes the perspectives of people that may have the most vital interests in the food system. And in terms of how we think that the process should happen, that having a government created national food strategy is still what we remain committed to. Because it's important from our perspective, it's important to us that there's government buy-in, that the government is going to actively encourage and create structures for the responsible agencies to coordinate and that these things will actually take effect in some way, whether it be through laws and regulations. But we added a couple other key elements to the ones that we included in the 2017 blueprint. So one was leadership. We added that as up in the first guiding principle focused on coordination. And that change reflects our understanding that effective leadership is just as important as agency coordination to the success of a national food strategy. One of the big takeaways that we had from COVID-19 and the response to the food system was that leadership was a vital element of effective response and the lack of leadership really made it difficult for agencies to respond to food system issues in COVID. In the food context, if we think about it from a state perspective, New York City appointed a food czar, Massachusetts appointed a food security task force, and both of those mechanisms created the leadership that was necessary to make an impact across all aspects of the food system. So developing a strong national food strategy will require identifying a particular individual leader or some sort of group of leaders that can provide effective and decisive oversight to the process. And then the second thing that we added, and we suggested this in terms of that there be a procedural mechanism, but we added to the update, the blueprint update, the need for proper enforcement mechanisms. Otherwise a national strategy would risk becoming little more than symbolism that has no teeth. So we updated the principles to include enforceability. We noted that the interagency working group on environmental justice, which we profiled in great detail in the original blueprint, featured cross-agency coordination, which obviously is something that we're pushing for strongly, but it lacked the power to issue enforceable regulations or to compel its member agencies to do so. And consequently, that interagency working group wound up being highly dependent on the executive, leaving it subject to the political whims of the president. From our perspective, a national food strategy should avoid that by ensuring it has a lead officer agency that can compel action by agencies that are participating for the strategy and pushes the agencies to create enforceable regulations and allows citizens the opportunity to hold government accountable. So finally, so this is the, this is basically the text of the end of our report. But from our perspective, after COVID, it felt like a really opportune time to push government to think about how to confront the inequities and the externalized costs that are rampant in the food system and also to address the critical economic, health, environmental, and social impacts. So from our perspective, there's no better time to do that than now. And that having a national food strategy allows us to do that efficiently and effectively and in a way that can be a long-term strategic solution to address the many food system challenges that we face. So thank you. I'm gonna stop sharing my screen. I think. Okay. Thank you so much, Professor Byronavan. That was a great talk. I do wanna remind folks that we do have time for Q&A. We have about 10 minutes. And for those of you in the audience, if you're watching on our website live stream, you click on the icon at the bottom of the video to bring up the chat box where you can add your question or if you're watching on the Facebook live stream, add your question to the comment box below and we'll get to as many as we can. I'll kick things off, especially appropriate for a professor of administrative law. I'm wondering, have you conceived of this agency as a new agency that would oversee coordination or appointing an existing agency and is there precedent for an existing agency to be able to issue mandates for other agencies to do things as sort of an existing agency becoming a super agency? Yeah, that's a great question. Initially when we thought about it as we consider just having a lead office or agency be the body and not create some new agency that would be responsible for this. Now that I think about it more, and since 2017, one of the things that I really loved when I did this research, just because I dorked out on the research was that in the UK, they had this whole strategy unit that basically looked across government and was trying to figure out how to get governmental agencies to coordinate on any issue that was in need of coordination. And I was like, oh my God, that's so fascinating and something that would be so incredibly useful in the US, not just for the food system, but any issue that involves a number of agencies. Why not have a body that basically is going to the agencies and being like, okay, you guys need to coordinate and like, here's what you need to do and here's the various responsibilities that you all have. And what was really sad to me was to see that since we wrote that report that that body had been disassembled, basically. And what they realized was that agencies don't want to coordinate, which is like no surprise. They all have their own area that they want to regulate in and the things that they want to address and they don't want to deal with other agencies in doing that. And so as I thought about it more and I was thinking about it with this update report, I wonder from a really practical perspective, if you were to give this authority to an existing lead officer agency, if you create the same issues. So like, if you were to say to FDA, which isn't actually the right agency for this, you know, FDA does a lot with food, but it doesn't do a lot with the food system. But if you were to say to an agency like FDA, okay, FDA, you get to be the lead officer agency, like are all these other agencies that are responsible going to listen to FDA and are they actually gonna do the things that FDA is saying, even if FDA has the authority in some way to enable them to do that. So I do wonder if there needs to be some sort of new body that's created in the executive that in some way has the authority to be able to force all these different agencies to coordinate in some way and has some super authority, but you likely need an act of Congress to create something like that. I think and what we were pushing for was basically that Congress, we put out a number of calls to Congress to write legislation, essentially pushing for a national food strategy so that some of these mechanisms could be put into place. But I don't think there's any sort of like one single answer and it's sort of hard to know what the best structure is. I think they all, that's some of the follow-up research that we wanna do is to think about the pros and cons of very specific different types of approaches to do this. That would be really exciting to see. Yeah. Wonder about, there's so much activity that's happened in terms of food system, well, some activity that's happened in terms of food system planning and food system improvements at the state and local level, especially at the local level. And what you're proposing here is really a swing in the other direction to go as high as possible in the chain in terms of government. And I wonder whether this might create kind of an all or nothing approach that prevents incremental change because with so many stakeholders, it can be really difficult to agree on anything. And so that slows everything down. It makes me think of the Farm Bill and SNAP and how that makes it so, you know, Farm Bill's run so far behind because there are these difficult issues. And, you know, you talk about, one of the reasons for needing this coordination is to avoid externalities, but it's exactly because a process that would include externalities, you know, like impacts from subsidies to corporate farms and maybe unintended consequences to low income consumers, it makes it really difficult to move forward at all. So how do you envision avoiding gridlock with such a big process like that? Yeah, I mean, I think, so what we really was really valuable to us to see how the process unfolded in Canada and to see how they engage stakeholders and how they envisioned engaging stakeholders. One of the strategies that we looked at as an example for public participation was Brazil because Brazil essentially had these mechanisms where local, state and federal government all involved a high percentage of civil society and in creating food policies in Brazil, they had these advisory councils that included members of local, state and federal government to be able to create those. And we thought that that was an interesting model and a way to ensure that you're not losing some of the innovations that are happening at the state and local level. That was certainly a concern that we had about suggesting such a top down federal national type of strategy that people would be worried about losing the state and local innovations and momentum and even autonomy that's been happening in the food system for so long. I think what we're really focused on is developing a broad set of goals at the outset. So like really big picture goals like to reduce food insecurity by like X percentage if not completely by such and such year and to just have these really broad based goals that I think it's hard to argue against those as goals. And I think you will have, there will be some competition in terms of like which of those goals is sort of like the highest priority. But as a first matter, I don't necessarily see the creation of those goals creating so much gridlock. I feel like the gridlock will come in when you start to get into the details of like how is that going to happen? Like what are the steps gonna be to implement that? And that we envision being a really participatory process which you're right can result in gridlock but really like similar to notice and comment rulemaking so that there are, you know, proposals that are created that are sent out so the public has the opportunity to weigh in but ultimately the decision makers are gonna make a decision based on the comments and feedback that they get which I think ends up avoiding the gridlock that you're talking about. It obviously also means that like not everyone's gonna be happy 100% but it does mean that someone is authorized to be making decisions so that things can continuously kind of move forward and progress. Okay. Thank you. And then we're close to being out of time but one more real quick, really easy one for you. So food system issues can be tricky in terms of politics. You know, at least in my observation it tends to be a little more complex than just the classic partisan Republicans versus Democrats. And so since what you're proposing is pretty much entirely in the executive branch and we've seen about as dramatic a swing from president to president right now as we may ever see. So how do you protect against losing all that progress when it comes to election time? Yeah, that's something that we were worried about which is why we created the durability principle that we are the durability recommendation that we included in the original blueprint so that there's some way to ensure whether it be that there's legislation that calls for the creation of a national food strategy so that endures from president to president. That's also incredibly hard. Or that we at this point because we're at the beginning of a presidency that if a national food strategy was created now which we sort of feel like the time is now and agencies started taking some action in response to it it's not as easy to sort of just like undo the actions of the agency within incoming administration as it would be to just undo an executive order even if we had an executive order that created a national food strategy and then directed agencies to do specific things that the agencies start doing those things now and they continue to do those things for the next few years. I think a lot of that will be hard to undo with an incoming president. And we really see this issue as bipartisan that a lot of these things not only are gonna be good for the environment and good for public health which ideally you hope that those are bipartisan issues but we know that those can tend to fall across different party lines but also that this can be good for the economy and it can be good for regulatory efficiency which is certainly something that Republicans are in favor of as well. Okay, well thank you so much. It was great to talk with you about these issues and unfortunately we're out of time so we need to wrap up our talk today. Thank you so much Professor Beirut-Van for your presentation and thank you to everybody who joined us today. Our next Top Topics talk will take place here on June 17th at noon Eastern time and we hope you can join us then. Thanks everyone. Thank you.