The Community Food Security Coalition

PO Box 209

Venice, California 90294

(310) 822-5410




October 2, 2006


Patricia Daniels, Director

Supplemental Food Programs Division

Food and Nutrition Service

United States Department of agriculture

3101 Park Center Drive Room 528

Alexandria, Virginia 22303


Dear Ms. Daniels:


††††††††††† REF Docket ID Number 0584-AD77-WIC Food Package Rule


I am writing to offer the support of the Community Food Security Coalition (CFSC) for the revisions in the WIC food packages as proposed by USDA. In light of the severe health and dietary challenges confronting many Americans, especially lower income families and children, it is heartening to see a proposal that will allocate a greater share of public nutrition assistance resources for the healthiest foods available. The introduction of fruits and vegetables, particularly fresh ones, for the WIC food packages will not only encourage healthy eating for the programís mothers and children now, but will also encourage a lifetime of healthier eating for the future.


Over the last 30 years, farmersí markets have played an increasingly important role in bringing fresh, locally produced fruits and vegetables to the nationís communities. Because they have been particularly successful in making fresh produce available in lower income urban and rural areas, and especially to WIC participants, we focus our comments on the proposed revisions that address the inclusion of farmersí markets as eligible vendors.


According to USDA, there are now 3,740 U.S. farmersí markets (a number that is continuously growing) serving millions of consumers and providing tens of thousands of farmers with strong market outlets for locally produced food. They operate in every state, nearly every major city, and can be found in almost every county. Farmersí markets have been enormously successful in bringing a wide selection of affordable, extremely fresh, and locally grown produce to places that have been traditionally under served by other forms of affordable, retail food outlets. Among other places, the acceptance of farmersí markets by WIC participants is evident in a Los Angeles research study (E. Jenks,, University of California, Los Angeles) that found that WIC participants redeemed 90.7 percent of their special fruit and vegetable coupons at a farmersí market compared to 87.5 percent at a supermarket even though the location and the hours of the supermarket were more convenient.


To be successful in under served, often lower income neighborhoods, farmersí markets have had to learn the specific fresh food preferences of their residents. This has frequently meant that farmers have tailored their crop selection and marketing to the traditional food preferences of a wide variety of racial and ethnic minority groups, and in many cases, newly arrived refugee and immigrants groups. Such efforts have sometimes been aided by programs that provide training and start up needs to new and immigrant farmers who are from the same communities as WIC shoppers. The result is that new farmers are growing and marketing food at farmersí markets that is preferred by these same minority, refugee, and immigrants groups.


All in all, farmersí markets have improved the access of some of Americaís most nutritionally vulnerable people to fresh, affordable produce. And without good access to healthy food, nutrition education and increased buying power will have little effect.


A complementary aspect of farmersí market growth in low-income communities has been the development and gradual expansion of USDAís WIC Farmers Market Nutrition Program (FMNP), started in1989 and further extended by the development of the Senior Farmers Market Nutrition Program in 2001. The WIC FMNP now operates in 46 states, U.S. territories, and tribal nations and served approximately 2.7 million WIC recipients in 2005, a number which represents a third of all WIC recipients. Surveys conducted over the years by state and tribal agencies, which administer the WIC FMNP consistently find that the modest benefits provided to WIC recipients (usually about $20 per recipient annually) result in greater consumption of fresh fruits and vegetables among recipients. When WIC offices and other participating organizations, including the farmers and farmersí markets themselves, provide nutrition education information and activities to WIC recipients, the value of the FMNP vouchers is enhanced and the long-term consumption of fresh fruits and vegetables is more likely to occur. Just as farmersí markets have brought fresh produce to economically distressed communities, the FMNP has brought more socially and economically disadvantaged families to farmersí markets.


The WIC FMNP has two major benefits that will enhance the effectiveness of providing special produce vouchers that can be redeemed at farmersí markets. First, the FMNP coupons in themselves provide a strong boost to the viability of low-income farmersí markets; many such markets might not operate without such a program. Secondly, by operating WIC FMNPs, states and tribal organizations have developed the organizational and administrative capacity they will need to operate the proposed WIC produce voucher program. The current procedures for WIC FMNP benefit distribution, redemption, and accountability are very consistent with the proposed revisions pertaining to fruit and vegetable vouchers. FMNP agencies (generally state health and agriculture departments) now issue vouchers that range in value from $2 to $5. They have voucher tracking and other accountability procedures as well as procedures to authorize participating farmers and farmersí markets. Additionally, both the development of farmersí markets and the implementation of the WIC FMNP require working partnerships and collaborations between multiple agencies and organizations, both public as well as private. These experiences and practices, developed over the course of 17 years of operating the WIC FMNP, should allow state and tribal WIC agencies to make a relatively smooth transition to the implementation of the proposed fruit and vegetable voucher system.


In order for WIC recipients to secure as much nutritional value as possible from the use of the proposed fruit and vegetable WIC vouchers at farmersí markets, we offer the following comments and recommendations for inclusion in the WIC Food Package regulations:


        USDA shall do no harm to the WIC Farmers Market Nutrition Program either through reducing current funding levels or establishing rules, systems, or procedures at the federal or state levels that would adversely affect the operation and effectiveness of the WIC FMNP.

        Coordination shall be required between the proposed WIC fruit and vegetable voucher program and all existing and future federal-state WIC Farmers Market Nutrition Programs.

        Farmers and farmersí markets that are currently authorized under state WIC FMNP procedures shall be automatically eligible for vendor specification under the new fruit and vegetable voucher program. These WIC FMNP farmer and farmersí market authorization procedures shall also be applied by states in the future vendor specification process.

        States shall be required to allow farmersí markets as eligible vendors for fresh fruits and vegetables, with the provision that they comply with farmersí and farmersí market authorization procedures.

        Farmers and farmersí markets that are currently authorized under state WIC FMNP procedures shall be automatically eligible as WIC vendors for the new fruit and vegetable vouchers issued by the WIC program. The WIC FMNP farmer and farmersí market authorization procedures shall also be applied by states as the vendor requirements for farmers or farmersí markets for this program.

        With respect to vendor requirements, farmersí markets shall be allowed to participate as seasonal vendors since most farmersí markets in the country are unable to operate year round. Similarly, farmersí markets shall be exempt from the ďWIC-onlyĒ cost containment requirement and shall not be required to carry a full-range of WIC food package products.

        When practicable, states should seek to develop systems for the distribution and use of fruit and vegetable vouchers that are compatible with existing WIC FMNP procedures. Nutrition education efforts and state and local promotion of fresh fruit and vegetable vouchers should be compatible with and seek to take advantage of existing WIC FMNP education and promotion practices. States should be encouraged to reduce the administrative costs associated with a fruit and vegetable voucher system by developing systems that are compatible with their respective WIC FMNPs

        In the event that states adopt EBT technology for the use of nutrition benefits by WIC recipients, farmersí markets must also be provided with the most practical EBT systems for the fruit and vegetable redemption process.


With respect to all vendors that may be specified under this program and other key operational issues for the new fruit and vegetable voucher program, the Community Food Security Coalition recommends the following rules:


        State agencies shall not have the authority to limit the range of fruit and vegetable items that may be purchased with fruit and vegetable vouchers, though preference shall be given to fresh fruits and vegetables first, then to frozen, and lastly canned.

        There shall be a cost of living adjustment reflected in the value of the vouchers in order to keep pace with inflation.

        The denomination of fruit and vegetable instruments shall be in small amounts such as $1.00 and $2.00 denominations.

        No change shall be given for vouchers that donít purchase their full denominational value.

        Consistent with Institute of Medicineís recommendation, we support the amount of $10 per month of fruits and vegetables for mothers and $8 for children.

        State advisory groups shall be established to develop the most effective and responsive system possible for operating the fruit and vegetable voucher program. Where states and/or municipalities have food policy councils, their participation in the advisory process is strongly encouraged.

        Just as farmersí markets have been pioneers in making the best fruits and vegetables available to people and places that need them the most, CFSC recommends that WIC encourage the availability of high quality fresh fruits and vegetables in all outlets that serve WIC recipients. In this regard the national WIC Program should consider implementing pilot projects that test various methods of increasing access to fresh produce in a variety of retail food outlets, including farmersí markets, in areas that are poorly served by such outlets.


On behalf of the CFSC, I thank you for the forward-looking proposal to make fruits and vegetables a regular part of the WIC food package. This advance in the food package will not only prove immeasurably valuable for lower income women and children, but also assist the nationís family farmers for whom farmersí markets are essential to preserving their livelihoods. Farmersí markets can make a substantial contribution to the success of this new initiative, one that promises to provide a healthy tomorrow for all Americans.







Andy Fisher

Executive Director

Community Food Security Coalition