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Slow Food California in Cuba 2020

By Peter Ruddock, Slow Food California President

Dec 9, 2019

You will often hear that Cuba has the most sustainable food system in the world.  After the Soviet Union dissolved, Cuba lost its main trading partner, from whom it got most of its agricultural equipment and much of its food.  Food became scarce during the early 90s, a time that became known as the Special Period. The government, and people, of Cuba, however, buckled down and learned to grow their own food, using only the resources that they had, and their own ingenuity.  Urban gardens flourished. Food became organic. After a period of hardship, a period of learning through trial and error, Cuba came out the other side with a model food system, which is the envy of the world.

There is a lot of truth to the story of Cuba re-learning to feed itself.  As with most stories, however, there is a bit of exaggeration and wishful thinking.  Cuba did learn to grow its own food again and most of that food is organic, if not certified in the way that organic food is certified in much of the world.  However, there are a number of asterisks to that story. It’s not quite as rosy as it is often told.

In 2019, Slow Food California sponsored a tour to Cuba.  In March, a group of Slow Food members flew to Havana for a trip inspired by the Food Sovereignty Tours operated by Food First for much of the preceding decade.  That is, they went to study the food system of the country, while meeting people, eating very well and having lots of fun. They got to learn about those asterisks in Cuba’s story and appreciate the hard work behind what really happened – and the fragility of what exists today.

The most significant asterisk has to do with the food being organic.  Perhaps two thirds of the food that is grown in Cuba is organic. One third of it never was.  Farm equipment and big farms did not entirely disappear. Export crops, like sugar, got the equipment and chemicals needed to operate in the commodity world.  Sugar remains one of Cuba’s main exports. Staple crops, like onions and potatoes are also not organic. And the farmers who grow these crops don’t necessarily want them to be organic.  Like people elsewhere, they are often happy doing things the way they are. Why change?

Another third of the food is organic and will likely stay that way.  Some of the people who turned to farming, especially those who created urban farms, are true converts.  No matter what becomes available in the future, they are not likely to change their behaviors.

The final third of Cuban-grown food is also organic, but it may not remain so.  These people are not so much organic proponents as organic farmers by default. Cuba is changing fast as it has been opening up to the world.  Equipment and chemicals are becoming more available and as the people who grow this food gain access to them, many are tempted to switch to conventional methods.  The future of Cuban food will revolve around these farmers, those who can be swayed. In fact, American agrichemical companies have been pushing to end the US embargo of Cuba significantly so that they can sell to these farmers.

Not surprisingly, our tour visited mostly the true converts, from whom there was a lot to learn.  Not only are these farms often exemplars of the methods that Slow Food cherishes, but they operate under structures that give them resilience.  Some our community owned; others, like Vivero Alamar, a 27-acre urban farm in the suburbs of Havana, are worker-owned cooperatives; many use permaculture methods; and others are family farms.

Our trip wasn’t all about farms.  We ate in a variety of places, including Cuba’s famous paladares, restaurants set up in private houses.  While California struggles to implement AB 626, the Homemade Food Operations Act, having licensed just over 20 home cooks, all in Riverside County, Cuba marked 25 years of residents operating home restaurants.  California regulators fear a future of food poisoning, which is the main reason for our slow going. We heard that Cuba has had a few such issues over the years, but that on balance, the experiment has been a success, incubating small businesses while providing a variety of good, safe food to people.  In fact, the law has been expanded and liberalized to a point way beyond California’s current imagination.

We had the opportunity to meet members of Slow Food Cuba, rekindling friendships started in previous years when those folks came to the EcoFarm Conference and to Slow Food Nations.  We visited local farmers markets, but we were too early for the new Earth Market that Slow Food folks in Havana started after we returned home.

It wasn’t all food, of course.  Old Havana was getting a renovation for its 500th anniversary, which took place this summer.  It’s a beautiful old town. We visited some museums and some historical sights. And we met many wonderful people who generously shared their time, wit and wisdom with us.  We came home glowing.

If you missed out on the trip, don’t fret.  Slow Food California is sponsoring a return visit in 2020 and you can go!  At the end of March we’ll convene in Havana for 11 days. We’ll visit many of the same places – Cuba is changing so fast, that it will be good to compare them a year on.  We’ll also visit some new places, including Slow Food’s new Earth Market. We’ll strengthen friendships, eat very well, and undoubtedly come home glowing, the ties between California and Cuba having been made stronger than ever.

To sign up, visit:

Originally published on the Slow Food California Blog, Dec 9, 2020

New Cottage Food Regulations in California

By Peter Ruddock, COOK Alliance Policy Director

California’s Cottage Food law turned 9 years old this month.  Governor Jerry Brown signed AB 1616 into law in the fall of 2012; it took effect on Jan 1, 2013.  Despite California being the 33rd state to enact a Cottage Food law, the law began cautiously, with a multi-year roll in of the income cap, which finally settled at $50,000 / year in 2015,  Regulators were nervous about expanding food sales to home operations.

Cooks signed up, started cooking and selling, and problems did not materialize.  There was no rash of food poisoning; there was no spate of nuisance complaints.  By 2018, at least one environmental health department regulator was heard to say that he “loved his cottage food operators.”

Still, when advocates proposed amending the law at the end of 2020, they approached the idea with some trepidation, wondering if the legislators and regulators were ready to acknowledge the success of the program and expand it.  Cottage Food operators were succeeding, but the limitations of the original law were keeping many of them from thriving.  In particular they were looking to expand the income caps and improve opportunities for sales.

As such, they reached out to Assemblymember Robert Rivas (D-Salinas) and worked with him to craft AB 1144.  The bill was kept fairly simple, an important consideration due not only to the uncertainty of its reception, but also the uncertainties of introducing legislation in a pandemic year.  Perhaps they shouldn’t have worried, as the bill passed through the legislature without opposition and with little pushback from regulators around the state.  Last fall, Governor Gavin Newsom signed the bill and on Jan 1, 2022 it became law.

So what do Cottage Food operators need to know?  The following are the most important changes:

  • Class A Cottage Food operators (those who sell directly to their customers) can now make up to $75,000 / year in gross income.
  • Class B Cottage Food operators (those who also sell indirectly through a retailer) can now make up to $150,000 / year in gross income.
  • Income caps will be modified each January to apply a cost of living adjustment to all income caps.
  • All permitted Cottage Food operators can sell in all counties in California.
  • All permitted Cottage Food operators can ship their products within California, as well as use third-party delivery services.

This law is a validation of the success of the program, acknowledging that homemade food can be sold safely.  It is an important step in the evolution of the laws regarding homemade food sales, other amendments likely being desirable within Cottage Food and amendments absolutely being desired by Micro Enterprise Home Kitchen Operators (MEHKOs) – but we take things one step at a time.  For now, it seems like a good time to celebrate.


David Crabill has become a driving force behind Cottage Food in California.  Not only is David a Cottage Food operator, but he documents the movement, throughout California and the country, at Forrager.  And it was David who led the effort to enact AB 1144.  Rather coincidentally, David produced his 50th episode of The Forrager Podcast at the end of 2021.  He asked the administrators of Facebook Groups which support Cottage Food Operators and MEHKOs to weigh in with advice and tips, such as they would give to their own group members.  In total, the owners of these groups represent over 125,000 people!  Facebook groups are the glue that holds the homemade food industry together. They are fantastic resources for entrepreneurs to find support and connect with each other. 

We were happy to have our How To Sell Home Cooked Food group included!

The Facebook Group, Cottage Food Law – supporters of AB 1616, the California Homemade Food Act was also included. It is the place to go for the nitty gritty about operating a Cottage Food business in California – recent discussions included one on the best way to package scones for shipping.

MEHKOs and Internet Platforms + CDPH’s New Directory

By Peter Ruddock, COOK Alliance Policy Director

Micro Enterprise Home Kitchen Operators (MEHKOs) often ask us at COOK Alliance about Internet Platforms that offer services to homemade food businesses.  These platforms, officially known as Internet Food Service Intermediaries, or IFSIs, by the California Department of Public Health (CDPH) seem to be popping up everywhere.  We estimate that at this point in time there are as many IFSIs as there are permitted MEHKOs in the US – just over 200 of each.

Some people have asked if MEHKOs have to work with an IFSI.  They do not, though there are good reasons to consider working with an IFSI.  MEHKOs first and foremost want to cook.  But a MEHKO is a business that needs to be taken as a serious entrepreneurial effort.  That means that you will need to market and sell your food, to keep books and pay taxes.  Some people like to do all of these tasks, to retain full control over the way their business operates and to save fees.  Others are happy to outsource this non-cooking work and are willing to pay a reasonable fee to do so.  Your choice about whether to use an IFSI will depend into which bucket you fall.

So, what should you do if you are a MEHKO who wants to work with an IFSI?  Definitely shop around.  They are not all created equal.

First, visit CDPH’s new IFSI directory and make sure that the IFSIs you are looking into are registered with the state, as per the law.  If they have not followed this basic law, you can wonder what other shortcuts they might be taking.  We are aware that a few IFSIs are doing business by a name other than the name that they have registered with the state (such as a DBA).  We do hope that they’ll make clear on their web-site their registration name as well.  You might ask them if you are not sure.

You should make sure that you live in an area that actually permits MEHKOs.  You can find out which counties in California do so by visiting our Status Tracker, which we keep as up to date as possible.  If you are outside of California, only Utah permits MEHKOs, a process which is still being defined (a few states permit MEHKO-like businesses under Food Freedom laws).  If you are in an area which does not permit MEHKOs, you would be taking a risk by selling food made at home.  Some IFSIs will sign you up anyway.  They too are taking a risk, but not as big as the risk that the MEHKO takes – you may be fined or shutdown for operating without a permit.

Some IFSIs tell you that all you need is to sign up with them and get a Food Handler Certificate.  What you need will vary by your jurisdiction, but it will at least include a MEHKO permit from your county’s or city’s Department of Environmental Health, a Seller’s Permit (for tax purposes) from the state and a Food Manager Certificate.  You usually will need a business license from your city as well.  (Insurance is strongly recommended, though not required by the law.)

Finally, compare both services and fees, both of which can vary dramatically.  Are there multiple fees?  Does the MEHKO pay them all or does the customer pay some of them?  This can make comparison more complicated, but it is worth the effort.  You can find out that you’re paying a lot more than you first thought, and in fact more of your profit than you want to give up for the service, no matter how good the technical aspects of it are.

You’ll do yourself a good service by researching whether you want to work with an IFSI and if so which one.  You’ll want to get good value for the cost, of course.  And you’ll want to make sure that the IFSI knows what it’s doing and won’t lead you into trouble with the regulators.  You want a safe and legal business, one that will thrive for a long time.

Meet the first MicroEnterprise Home Kitchen Operation in Palm Springs – Lola’s Kusina

By Lauren Wolfer, manager of the Palm Springs Certified Farmers Market and COOK Alliance advocate for Riverside and San Bernardino Counties

Home chef Michelle Castillo received special congratulations from Palm Springs Mayor Christy Holstege on opening the City’s first MEHKO during a City Council meeting this past June. Although Riverside County was the first in California to implement AB 626, the County’s most high profile city, Palm Springs, famous for its Mid Century Modern architecture and stunning desert landscape, waited nearly a year and a half for the first MEHKO to open within its limits. Michelle Castillo, a local artist, activist, and second generation resident, created Lola’s Kusina (which means “Grandma’s Kitchen” in Tagalog) in 2011, as an invite-only underground supper club and arts/cultural happening serving fresh Filipino cuisine. Inspired by memories of eating lunch with her family every Saturday at her late Lola Sally’s Palm Springs home, Lola’s Kusina has done community food workshops, private and public dinners, and popped up at bars, art galleries, parties, in Los Angeles, Oakland, and Coachella Valley. Seeking to capture the magic that comes from family and neighbors sharing a meal, transforming Lola’s Kusina into a legal home restaurant was an obvious choice for Chef Castillo. 

“Sharing Filipino Food to me is about decolonization and bringing awareness to our stories, culture, and multifaceted experiences as immigrants. Food and art is a common lens and love language from which we can all start to understand one another.” -Michelle Castillo
One of Lola’s Kusina’s best-selling dishes is Lola’s savory vegetable lumpia (Filipino eggroll), fried to a golden crisp served w/ a sweet chili dipping sauce, or sawsawan of vinegar, crushed garlic, and pepper.

Mayor Holstege, who worked as a social justice attorney before serving on Palm Springs City Council, was eager to commemorate Lola’s Kusina’s opening as a milestone for the city of Palm Springs. Holstege’s lifelong commitment to grassroots advocacy, and deep concern for issues of food and and economic justice (she has represented farmworkers in civil rights, housing, and employment litigation at California Rural Legal Assistance in Coachella, California) make her a natural champion for AB 626. Wanting to share the MEHKO program’s potential for advancing equity and diversifying the local food economy, as well a simply being an excellent opportunity for local aspiring entrepreneurs, Holstege coordinated with COOK Alliance volunteer, Lauren Wolfer, to draft a congratulatory statement recognizing Castillo for breaking new ground in the Palm Springs culinary scene. 

COOK Alliance would also like to congratulate Chef Castillo on this milestone, and commend the City of Palm Springs for celebrating MEHKOs as a win for their community. Hopefully this positive reception will inspire other cities to welcome MEHKOs with open arms!

Read Mayor Holstege’s full statement (video can be seen here):

Congratulations to Lola’s Kusina on becoming the first Microenterprise Home Kitchen Operation (MEHKO) in Palm Springs! 

Lola’s Kusina, which means ‘Grandma’s Kitchen’ in Tagalog, is a Filipino eatery by Chef Michelle Castillo, a local artist, activist, and second generation Palm Springs resident who grew up in the Veteran’s Tract neighborhood. I am privileged to know her personally and have seen her work in the community. She has dedicated Lola’s Kusina to her family, particularly her grandmother, as well as the immigrant experience- and serves fresh, homemade Filipino food (with plant based options!) from her permitted home restaurant in the Gene Autry neighborhood. 

Microenterprise Home Kitchens are small-scale food businesses operated out of a private residence. Riverside County was the first county to begin permitting MEHKOs after Assembly Bill 626 was signed into law by Governor Jerry Brown in January, 2019. MEHKOs are inspected and regulated just like any other food facility, so residents can safely and legally share home cooked meals with their neighbors. 

This is an excellent opportunity for our residents to begin their journey in food business ownership without being held back by the traditionally high barriers of entry into the culinary industry. The majority of the permitted home chefs in Riverside County have been women, immigrants, and people of color- not only will this program make our local food economy more diverse and inclusive, it also brings opportunities for community building and intercultural education.

MEKHOs also provide a much-needed opportunity to empower households negatively affected by the job loss and economic slowdown caused by the COVID-19 pandemic, as a pathway to getting back on their feet and starting successful businesses. 

We wish Chef Michelle the very best of luck with her MEHKO and commend her for blazing the trail for home chefs in Palm Springs! 

Utah passes HB 0094 to become second state to permit MEHKOs

By Symbria Patterson, Red Acre Center

Red Acre Center was the driving force behind the Home Consumption and Homemade Food Act that passed in 2018, allowing for food to be made in a home kitchen (unregulated, uninspected, and using meat only if it is rabbit or chicken that the producer raised and processed). It was a huge win for rural Utah: diversified farms selling direct to consumers and those in the city. We felt there was not much else we could do because red meat is regulated at the federal level. 

Then one day, a friend in California texted a copy of a newspaper clipping to me about “the tamale bill.” We were sure, just like North Dakota, Maine, and Wyoming, that the federal government would call them out on this. We also feared that if California were put in the spotlight and called out, no one would try for food freedom. We tried but were unable to reach any California representative in the legislature. 

It was serendipitous that we would do our usual visit to the Slow Food California booth at the Heirloom Expo in Sonoma County and that Peter Ruddock would be staffing the booth. We chatted for a minute, and then I saw the postcard from COOK Alliance and they were talking about that “tamale bill!!”  Peter explained to me what their involvement was. I was beyond excited and shared the news with the Center.  The Center wasn’t quite as excited, as they felt that what California had done was not possible. COOK Alliance was very willing to communicate with us to tell us the process they went through and how they came to the conclusions they did to see their Micro-Enterprise Kitchen bill passed.

Red Acre Center’s analyst was still cautious and contacted FSIS confirming California was correct and that a micro-enterprise kitchen would be legal under the federal guidelines. COOK Alliance has more resources than Red Acre Center, and we are grateful for the time and money they spent to find this most valuable information out. 

Not being able to sell food with meat is limiting. Also, being unregulated and uninspected is not for everyone. California’s Micro-Enterprise Kitchen bill solved both of those problems. With a different approach, we passed an agrotourism bill in 2020, allowing micro-kitchens on farms. Eating onsite is permitted, no limit on dollars earned, and this is a state-wide bill.

In 2021, we broadened the bill (HB 0094), patterning it after the California micro-kitchen bill. With a smaller population base in Utah, the bill is state-wide instead of county by county. There is no limit to the number of meals or money earned. Meals can be picked up or delivered, but no dining on-premises is allowed. The governor signed the bill in March, and the state health department has 180 days to write rules. Then permits can be issued in limited numbers based on the number of businesses per county until July 2022, when those restrictions will be lifted entirely.

Cheers to home cooks and more local food choices!

Public Utilities for Community Food Security

Public Utilities for Community Food Security


Guest Post by John Ikerd



Hunger is avoidable or discretionary—globally as well as in the United States. Except under circumstances of war, insurrection, or natural disasters, plenty of food is produced to provide an adequate diet for everyone in the world—mostly certainly in the U.S. We could also provide more than enough good food for everyone, meaning wholesome, nutritious, sustainably produced food—if we reduced food waste, fed less grain to livestock, and stopped using farmland to produce crops for fuel.


Experiences of the past 400-plus years have proven that food security, meaning the elimination of hunger, cannot be left to the indifference of markets, the vagaries of charity, or impersonal government programs. Markets provide food for those who are able to earn enough money to pay market prices for food. This inevitably excludes many of those who most need good food. Government programs and charities respond well to disasters but have failed to solve problems of chronic hunger. Hunger is a reflection of systemic problems imbedded deeply within our food system, economy, and society. Food security will require a comprehensive approach that addresses the logistical, economic, demographic, social, and cultural challenges of hunger. 


Prior to the enclosure movement, which began in Europe in the 1600s, land was not owned by individuals but was freely available for everyone to use to produce food and to meet other basic needs. Land was also farmed in common or by communities and no one in the community went hungry unless all were hungry. When hunger occurred then, it was not discretionary but unavoidable. In his classic book, The Great Transformation, economist Karl Polanyi details the historical consequence of “commodifying” or privatizing land. 


Land was privatized or commodified so it could be priced, allowing market competition rather than community consensus to determine who had access to and benefited from land. The commodification of land essentially forced commodification of labor, as those left without access to land to produce their own food were forced to sell their labor to employers in order to feed their families. While all people may be of equal “inherent worth,” people are inherently unequal in their ability to produce things of economic value. A significant portion of people in any given community or population has always been unable to earn enough money to meet even their basic needs for food. English Poor Laws were instituted in 1601 to provide food for those physically unable to meet their basic needs but failed to address the inequity among others.  


By 1795, Thomas Paine concluded, “the landed monopoly… has produced the greatest evil. It has dispossessed more than half the inhabitants of every nation of their natural inheritance… and has thereby created a species of poverty and wretchedness that did not exist before.” Paine was not advocating a return to common ownership of land. He proposed a universal, life-long government indemnity to compensate the people for their loss of access to the commons and their right to produce their own food. His proposal was never implemented. In 1834, after many decades of enclosures, the English Poor Laws were nationalized and expanded to cover the entire working class, not just the young, old, and disabled. Various other attempts were made to protect the working class from social upheaval caused by privatizing land. Nothing seemed to work. 


A variety of social welfare and food assistance programs have been tried over many years, culminating in the U.S. with the New Deal programs of the 1930s and Great Society programs of the 1960s. None have adequately addressed the twin perils of chronic poverty and discretionary hunger which began with privatization of land and labor. Experiments with socialism and communism have been frustrated by the same basic challenges as today’s social welfare programs—primarily impersonal bureaucracy and functional inefficiency. With the resurgence of free-market fundamentalism in the U.S in the 1980s, social welfare and food assistance programs came under, and remain under, persistent attack. Obviously, government programs have at least mitigated hunger for many, but “poverty and wretchedness” seem destined to continue. 


Admittedly, the challenges of food security are formidable—but are not unsurmountable. I have proposed a specific approach to ensuring food security primarily for the purpose of stimulating a dialogue concerning how best to meet the historic challenge of chronic hunger. History has shown that to solve large, systemic problems such as hunger we first have to find points of leverage where small, doable actions can lead to large, seemingly impossible effects – like the small trim tab that helps turn the rudder of a ship—causing the whole ship to change direction. My proposal is to find, build, and turn a trim tab—trusting that fundamental change will follow.


First, we must recognize that hunger is a “market failure.” A market failure is a situation in which rational individual market decisions fail to produce results that serve the common interest of society. While markets are capable of meeting the needs of those who have the ability to earn enough money to buy good food, markets are fundamentally incapable of meeting the needs of those who can’t earn enough money to buy enough good food. Hunger is a market failure, and thus, government programs or public assistance of some kind is a requisite for food security.


Unfortunately, current public food assistance programs have the same basic weakness as markets: they are “impersonal.” Being impersonal, markets are indifferent to needs, unless those in need have money. Government food assistance programs also have been impersonal. There no sense of “personal” connectedness between the taxpayers who pay for the programs and those who receive the benefits. Recipients may be seen as “those people on welfare”—who could and should be working. Recipients may see providers of benefits as “the government,”—with no sense of personal gratitude or responsibility toward those who pay taxes to support government.


Many organized food charities have also become large and impersonal. Supporters of such charities simply write checks and trust that their money will be put to good use. Personal knowledge of or connections with individual recipients are rare. Those who receive food assistance from charities may be thankful, but there is little sense of personal connection with or responsibility to those who fund the charities. Increasingly, large charitable food assistance organizations receive most of the food they distribute from large food corporations. These corporations receive tax write-offs for their “charitable contribution” of food items they can’t sell. Such charitable transactions are as impersonal as market transactions.


The failure of these past efforts to provide food security is clearly and consistently documented by government statistics. In 2015, the U.S Department of Agriculture classified nearly 13% or one in eight U.S. households as “food insecure.” Nearly 17% or one-in-six of American children lived in food insecure households. Food insecurity in the case of government statistics means uncertainty regarding whether enough food will be available to meet the nutritional needs of households at all times. The percentage of hungry children has been as high as 20% in recent years. In 1968, when CBS-TV aired its classic documentary, “Hunger in America,” only 5% of the people in the U.S. were estimated to be hungry. For several decades food insecurity was closely linked with unemployment. In recent decades, the “working poor” account for a major portion of food insecurity in America. Sixty years of agricultural and economic “progress” has done nothing to alleviate hunger in America.


Furthermore, industrialization of the American agri-food system has led to a new kind of food insecurity, foods that lack the nutritional value essential to support healthy, active lifestyles. The U.S. is confronted with a growing epidemic of obesity and related diseases, such as diabetes, high blood pressure, heart disease, and a variety of diet related cancers. While the percentage of the GDP spent for food has declined, the percentage of GDP spent for health care in the U.S. more than tripled, from 5% in 1960 to nearly 18% in 2015. A large portion of these increases have been linked to diet-related illnesses.


I’m convinced that we will not eliminate hunger in America until we accept that everyone has a “right to good food,” as a basic human right. Once accepted, the assurance of rights is no longer discretionary but becomes a moral obligation. As long as hunger is accepted as an inevitable consequence of human frailty or moral deficiency, there will be starving children living in the midst of abundant wealth. Accepting food as a basic right at the national level might seem impossible, at least at this time in history. However, progressive local communities might well accept this responsibility, much as some communities have accepted the challenge of global climate change. These communities could be the “trim tabs” of national and global food security.


Ultimately, hunger is a reflection of a lack of caring. Discretionary hunger emerged from the depersonalization of local economies, when buying and selling replaced personal relationships. I am convinced hunger has persisted because of the same basic reason: the impersonal nature of markets, many food charities, and government food assistance programs. The best hope for reestablishing the sense of personal connectedness essential to eliminate hunger is the reemergence of caring communities—communities where people share a personal sense of connectedness, concern, and mutual responsibility.


A commitment to food security today requires more than simply ensuring that everyone has access to enough food calories to meet their daily requirements. Food security requires sufficient “nourishment,” meaning enough wholesome, nutrient-dense foods to sustain health and vitality, life and longevity. Today’s corporately controlled agri-food system simply cannot be trusted to provide “good food” as long as they can make more money selling “junk food.” Corporations may provide good food for those willing and able to pay for it, but will not provide good food for poor people. They can make more money selling poor people “cheap junk food”—meaning foods with an abundance of calories, fat, and salt, but largely lacking in essential nutrients.


The organic and local food movements have emerged as a rejection of the industrial agri-food system, not simply for food safety and environmental reasons but also because of the nutrient deficient foods being produced by industrial agriculture. With the industrialization of organics, many concerned eaters turned to local farmers, to people they knew or could know and could trust, to ensure the integrity of their food.  True food security will require nothing less in terms of food quality, meaning nutritious foods produced with ecological and social integrity, to meet the basic food needs of all—including those who are poor and hungry. 


Thus far, the sustainable agriculture movement has been reluctant to embrace or even accept a commitment to ensuring enough good food for all. A sustainable agriculture, by definition, must meet the food needs of all in the present without diminishing opportunities for those of the future to meet their food needs as well. Thus far, primary emphasis has been placed on providing opportunities for those who can afford the higher costs of good food today while maintaining the productivity land and water resources needed for future food production. Little attention has been given to the first requisite of agriculture sustainability: ensuring “enough good food for all.”


The right to good food is a foundational principle of the global Food Sovereignty movement. The movement was initiated globally in the mid-1990s by Via Campesina, an organization bringing together small-scale farmers, farm workers, women farmers, and indigenous people to resist agricultural industrialization. Food Sovereignty is defined as the “people’s right to healthy and culturally appropriate food produced through ecologically sound and sustainable methods, and their right to define their own food and agriculture systems” Food Sovereignty not only proclaims a right to food, but also the right of local communities to determine the basic nature of their own agri-food systems.


While a commitment to national or global food sovereignty may require a few more decades, local commitments for community food sovereignty could be made today. A community could simply proclaim that access to good, sustainably produced food is a fundamental right of everyone in the community. The community could then accept the responsibility of ensuring that right to those who are unable to afford enough good food to meet their basic nutritional needs. Those who benefit from assurance of that right could logically be expected to contribute something of comparable value to the well-being of the community, regardless of the economic value of their contribution. A personal sense of reciprocity could replace impersonal transactions in cases where the markets have failed to provide food security. 


Obviously, a commitment to community food security would require some form of local organizational structure to facilitate carrying out the commitment. I have suggested the establishment of Community Food Utilities (CFUs). Some Americans are quick to label government food assistance and other social welfare programs as socialist or communist. Some also might see a “right to food” as a step toward socialism rather than a step toward ensuring the unalienable rights of all to life, liberty, and the pursuit of happiness—as proclaimed in the American Declaration of Independence. Public utilities are commonly used to provide essential public services such as electricity, water, sewers, and telecommunications. Few people think of their water or electricity as being steps toward socialism or communism. Thus, a Community Food Utility should minimize local political resistance, and equally important, could be organized under existing laws that authorize and regulate other public utilities.


Some might question using public utilities for food security because utilities are typically used in cases that economists refer to as “natural monopolies.” For example it is logical to utilize only one electrical system, water system, or sewer system because of the high cost of building and maintaining the infrastructure for these systems. Only one service provider would constitute a monopoly with the power to exploit its customers. Thus the justification for government intervention. However, public utilities are appropriate in any case of “market failure.” Natural monopolies are one example of market failure and hunger is another.


For example I grew up without electricity, because our house was a couple of miles from the end of the existing “power line.” It didn’t make economic sense to extend the power line to serve a couple of customers who would pay “light bills” of a couple of dollars a month. This wasn’t a case of a natural monopoly but nonetheless a “market failure.” The Rural Electrification Association (REA), a public utility, was established to provide electricity for everyone in the county, regardless of the economic costs and benefits of doing so. The REA even paid electricians to install electrical wiring in our old house—which was quite a task. Access to electricity had become a “right,” rather than a privilege, at least in my county. 


Some may contend that a Community Food Utility would represent unfair competition with local food retailers. However, local food retailers are not currently meeting the needs of “everyone” in the county, even if they are offering low quality foods at low prices to people with low incomes. In addition, public utilities are often used to provide public services when private services exist but are inadequate to meet the basic needs of all people in the community or municipality. Public transportation, including busses, light rails, and even taxi cabs, are frequently provided by municipalities or regulated as public utilities.


Public utilities essentially establish local “public service monopolies.” This would allow communities that are committed to local food security to “insulate,” but not isolate, themselves from national and global agri-food markets. One of the primary reasons that hunger has persisted in the U.S. is that current interstate commerce laws have prevented local communities from interfering with the market-based agri-food system that has limited food access to those in low income areas—rural as well as urban. “Food deserts” in America will persist as long as communities are unable to insulate local food systems from national and global markets. Community Food Utilities could provide a legal means for communities to declare Food Sovereignty: the right to determine the nature of their own community-based food systems.


Legal local protection from the global food system, such as that provided by public utilities, is essential for several logical reasons.  First, wholesome, nutritious, sustainably produced food will cost more to produce than the industrial “junk foods” that are currently affordable for people with low incomes. A CFU could simply choose to pay the higher costs of providing good food to low income recipients, without allowing potential providers of cheaper industrial foods to compete for the earned incomes or government assistance food dollars of food recipients. 


A CFU could also give priority to locally produced and locally processed foods, even if costs of local foods were higher than similar foods that could be procured elsewhere. A fundamental purpose of the CFU would be to establish personal relationships among food recipients, local farmers and food providers, and members of communities in general. Local procurement of food could also provide personal assurance that foods purchased by the CFU met locally-determined standards of “good” food—in terms of wholesomeness, nutrition, and ecologically sound and sustainable production methods. The CFU could also assure that local food producers who met those standards of quality were paid enough to cover their production costs plus a reasonable return for investments and efforts—ensuring their economic sustainability. None of these things would be possible without the protection provided by a public utility or local public monopoly.


The higher procurement costs of the CFU could be mitigated by providing raw or minimally-processed foods to recipients. Approximately 85% of the average costs of food in the U.S. is not to cover costs of the actual food but costs of processing, transportation, packaging, advertising, and corporate profits. While these non-food costs cannot be totally eliminated, they can be greatly reduced by providing locally-grown, raw or minimally-processed foods. Raw and minimally processed foods are also higher in nutritional value than are processed foods. Such foods would not ordinarily be selected by many low-income consumers who lack knowledge regarding selection and preparation of healthful foods. The CFU would need to accommodate recipients by providing educational programs for food selection, preparation, home processing and storage, and such. Current government programs supporting food and nutrition education could be administered and augmented by the CFU.


In fact, the CFU could be largely funded by administering all government food assistance programs for which recipients are eligible through the CFU. For example the Supplemental Nutritional Assistance Program currently provides recipients with a SNAP “debit card” to use to buy food. Additional funds are added to the SNAP card account for each payment period. SNAP funds for which CFU food recipients are eligible could instead be deposited in a CFU account. In return, the CFU would ensure that each recipient received enough good food to meet their basic needs, regardless of the amount of their individual SNAP payment. Some non-profit organizations are currently operating in this general fashion. I don’t know how widespread the practice may be, but it’s possible. Funds available to recipients through other public food assistance programs could be handled similarly.


The CFU’s commitment to local food security through food sovereignty would require a commitment to sustainable community development and sustainable local food production. So, the CFU would be eligible for government subsidies and grants that support community development and could also seek grants from non-profit and philanthropic organizations—particularly during the formative stages of conceptual development and implementation.  


No blueprint or recipe for development of a CFU is possible. Food security through Food Sovereignty would require that each community develop its own food system and CFU to fit the culture of its community and the ecology of its agricultural area. That being said, some common characteristics are likely to evolve over time that define the “essentials principles” for successful CFUs. The following are some characteristics that are at least worthy of consideration when contemplating the development of a CFU.


The basic missions of a CFU is: “to ensure enough good, sustainably produced food for members of the community who have insufficient funds to buy enough good food to meet their basic needs.” The maximum levels of income or economic means allowed to be eligible for “membership” in the CFU should be determined locally—reflecting a consensus of the community. However, if government food assistance funds are to be used to support the CFU, federal and state requirements would need to be met or exceeded in determining local CFU requirements. The geographic scope of the CFU would also need to be a factor in determining eligibility, with consideration for maintaining a sense of interpersonal community connectedness. The local community must share common values and a common commitment to community food security.


Membership in the CFU would need to be a voluntary choice on the part of eligible recipients. A CFU would not replace government food assistance programs or food charities, but rather would be an additional option that eligible members could choose—similar to “Medicare Advantage” health insurance programs. Community members who prefer government food assistance programs would be under no pressure to join the CFU. A logical approach to establishing a CFU might be to start with a pilot program, with an initial limited membership of “believers” in the concept. The concept could be fully implemented and expand in scope and membership after the inevitable “bugs” have been worked out during the pilot program. 


The CFU could be organized utilizing any structure available to public utilities in states where CFUs are located. Existing public utilities include cooperative, government agencies, and investor-owned/publicly-regulated corporations. The cooperative organizational structure would seem most appropriate for a CFU. The emphases on food security, food sovereignty, and sustainability all suggest that everyone involved with the CFU, or all “stakeholders,” should be involved in organizing and governing the organization. CFUs organized as government agencies, or investor owned corporations might be more likely to fall back into the same impersonal bureaucratic or economic efficiency patterns that have failed to provide food security. 


I have suggested that CFUs be organized as “vertical cooperatives.”  Most current food related cooperatives function at “one level” in the “vertical food chain”—linking farmers, to processor, to distributor, to retailer, and finally to consumers. The boards of these ‘horizontal” cooperatives may include representatives of different stakeholder groups, but the focus is on serving the interest of those at one level—whether it is a consumer cooperative, producer cooperative, or focuses on some other level. The focus of a vertical cooperative must be on meeting the needs of “all vertical levels” or links in the food system. The system as a whole is to be sustainable if the CFU is to continue to provide food security for the community. All recipients and participants in the vertical system would be members of the CFU cooperative.


This suggests also that stakeholders at all levels from farmers to recipients, as well as local government officials and community members, should be involved in governing the organization. Each group could have representatives on the CFU Board with the ability to “veto” any major decision to protect the interests of all. The CFU must be supported by a consensus of the membership to ensure the community consensus essential for its sustainability. CFU managers obviously should be given the authority to make most routine decisions without continually consulting the Board. This decision making process may be a bit messy, but so are democracies. 


As indicated previously, a CFU should give priority to local producers in procuring foods. The highest priority should be given to local farmers who are willing and able to provide food products that meet locally determined standards of quality and ecological integrity. Priority should also be given to small-scale, local producers who rely on the CFU as a market for a significant part of their production—if not their sole market. The purpose of favoring such producers would be to establish “mutually-beneficial” personal relationships between the CFU and its suppliers. For large-scale producers, the CFU would simply be an unessential niche market, even if the large producers were “local.”


A CFU could have an active program to support beginning local farmers and recruit existing local farmers as CFU suppliers. Beginning farmers in particular might be potential recipients of food as well as food suppliers. The CFU would also give priority to local food processors and packers. As with small producer, this would give priority to those for whom the CFU would represent a major market rather than a nonessential market niche. In cases where critical processing and distribution functions are not available locally, the CFU could encourage and support establishment of new facilities—or even establish such facilities as part of the CFU.


Food needs of the CFU that cannot be met locally could be met by establishing personal contacts with food networks or individual producers in other communities who are willing to meet local standards for food production. If such sources are not available for some foods, remaining needs of the CFU could be met by working through local distributors or retailers. Priority would be given to securing foods from elsewhere that best meet the quality and production standards of the CFU, rather than prioritizing food costs. Efforts should be made not to exclude local food retailers and distributors from CFU activities. However, the CFU must be vigilant and avoid being pulled back into the failed “cheap food” mentality of the industrial agri-food system.  


CFUs should make foods available to recipients by a variety of means in order to ensure that the basic food needs of everyone in the community is met. One logical means of distribution would be for the CFU to operate a retail food store where recipients could freely choose food items from the assortment chosen by the CFU to best meet their needs. Their choices at the CFU store would exclude “junk foods,” highly-processed foods, over-packaged foods, partially-prepared foods, and ready-to-eat foods. A limited variety of dessert items and such might be available, but the emphasis would be on providing ingredients for items that could be prepared at home. 


The CFU Board, in collaboration with local dietitians, could decide what kinds of foods to exclude from those made available to recipients.  Other food choices would be made with critical input from recipients, farmers, and other food providers. The food items made available must accommodate the needs of food recipients as well as everyone else in the vertical cooperative system. However, the emphasis on wholesomeness, nutrition, and opportunities for healthy balanced diets must remain the priority of any CFU committed to food security.


Similar assortments of food items could also be provided as weekly or biweekly food boxes. These boxes could be picked up by recipients at convenient pickup points in the community—or perhaps even delivered to recipients’ homes by the CFU. Recipients could be given box options that reflect different preferences—vegetarian, vegan, low-meat, low-carb, and such—but each box would include sufficient variety and quantities of food to provide healthful, balanced meals for the individual or family until the next box is to be picked up or delivered. Recipes and meal planning guides could be provided with each box to ensure that recipients were able to use the foods effectively. One objective of the box programs would be to teach people how to select and prepare healthy meals for themselves. Single meal boxes could be made available for those who are physically or mentally unable to be fully engaged in meal preparation. 


The CFU could also work with operators of local commercial kitchens to provide prepared meals for those who have no or very limited abilities to prepare their own meals—“good meals on wheels.” Alternatively, the CFU would operate its own commercial kitchen or could even operate a restaurant to prepare and provide meals for food recipients. In such cases, some provision would need to be made to limit utilization of prepared meals to some maximum portion of total food provided to individual recipients as a means of controlling the cost of operation. 


One of the basic causes of food insecurity is that low-income workers often eat many meals away from home. Or they may pick up or have prepared foods delivered because they don’t feel they have time to cook. They often end up paying high prices for unhealthy food without actually saving very much time. A major task of any CFU will be to help food recipients understand that taking time and learning to prepare nutritious meals at home can often save more money for the family than spending extra hours of work and buying prepared foods. Parents preparing healthful, nutritious meals with children can also be far more important to healthy families and healthy children than spending money for various “lessons” or spending time attending sporting activities. A primary mission of a CFU should be to develop a healthier community food culture, not only for recipients or members of the CFU but for the whole community.


The day-to-day operation of a Community Food Utility must accommodate the social and economic culture of the community. Some communities are more altruistic and might be willing to provide good food to all recipients in need, regardless of the willingness or ability of recipients to provide anything in return. Other communities are more utilitarian and believe that people must earn or be willing to work for whatever they receive.


One alternative means of accommodating a variety of community cultures would be for the CFU to issue its own currency to be used to purchase food available through the CFU. Community Food Dollars, or CFU$, could serve the same basic function as food stamps or SNAP payments in current government food assistance programs—with some notable exceptions. All foods offered by the CFU would be “priced” to allow and to encourage the selection of healthy, balanced diets by recipients.  A sufficient number of CFU$ would be made available to all recipients to ensure their right to food security—enough good food to support healthy, active lifestyles.


For recipients who currently qualify for maximum SNAP payments, particularly those who are disabled or elderly, the allocation of CFU$ would logically be provided to them without requiring anything other than SNAP eligibility. (For simplicity, I will ignore government benefits other than SNAP payments for the following examples.) The CFU would be required to make up any difference between the cost of providing these recipients with food security and the amount of SNAP benefits deposited in the CFU on their behalf.


The amount of current maximum SNAP benefits range from 20% to 25% of maximum incomes, for families of one to four people allowed to quality for SNAP benefits. “Average” SNAP benefits in 2017 were just over $125 per person and $250 “per family” per month. The “maximum” family incomes for a two member family is about $1,760 per month or $21,120 per year. For simplicity, assume that the median family income in the CFU community is $52,800 per year or 2.50 times as great as the maximum for SNAP recipient families. Next, assume that median income families in the CFU community on average spend 15% of their income for food, amounting to $7,920 per year or $660 per month. The average family size in the U.S. is about 2.6 people, so food cost per person would be just over $250 per person—compared with $125 per person average SNAP benefits. This means the average deficit or difference between CFU income from SNAP benefits and the average amount non-SNAP families spend on food would be about $125 per person, per month. 


Some of this deficit could be made up by focusing on raw and minimally processed foods, but the CFU would also need to come up with additional operating money in addition to government food assistance payments. Since the food made available through the CFU would be greater in quantity—to eliminate hunger—and superior in quality—fresher, more nutritious, more healthful—recipients who are physically capable might be asked to make contributions to offset some of the operating costs of the CFU—in money, if fully employed, or time, if not employed or underemployed. 


If the average family in the community spends 15% of its income for food, presumable family members spend 15% of their combined working hours earning money to buy food. An alternative for those who cannot afford to pay their share of the operating deficit of the CFU in dollars would be to allow them to spend an equivalent number of hours working for the CFU, or doing something else they are able to do to provide benefits to the community. If SNAP benefits make up only half, or 50%, of the total CFU costs of providing good food, then recipients might be required to provide one-half as much time as the average person in the community spends working to buy their food. One-half of 15% would be 7.5% or 3 hours of a 40-hour work week. 


The work requirement could be adjusted to account for SNAP benefits larger or smaller than the average, the actual CFU operating deficit, and the willingness of the community to fund the CFU with local tax dollars. Those who choose to work for the CFU could contribute time as farmers, farm workers, in food processing, food preparation, nutritional education, food preparation education, food distribution or delivery, clerical work, maintenance, or whatever needs to be done. Those whose talents do not fit the needs of the CFU could contribute to the community in other ways—as musicians, artists, child care, in nursing homes, or any other way the CFU deems is of real value to the community. Time is the greater leveler of human value. We all have only 24 hours a day and none of us knows how many days we have left. 


CFU$ would then represent a composite of government food assistance benefits and earned benefits for those able to work and provide valuable services to the CFU directly or to the larger community. For recipients who are fully employed or prefer to supplement their SNAP benefits with US dollars, CFU$ would represent a composite of the two sources. CFU prices could be assigned to accommodate the various options for securing food—the coop supermarket, food boxes, meal boxes, or home delivery. If the CFU decides to operate a restaurant or other retail prepared food service, a limited percentage of special CFU$ could be allocated for prepared foods to encourage purchase of raw or minimally processed foods for home preparation.


Over time, as local food production expands beyond amounts needed to eliminate local hunger, CFU$ could be made available for purchase by anyone in the community. The cost of community purchases would be sufficient to cover the CFU’s full cost of items purchased, in order to avoid unfair competition with local food retailers. When shopping in the CFU supermarket, eating in the CFU restaurant, or receiving a CFU food box, the community member who paid full cost for their CFU$ would be indistinguishable from those who paid less than full cost, worked for the CFU, or were unable to contribute anything of economic value. Relationships formed by patronizing and participating in the CFU would perhaps be the most important community building aspect of the community food sovereignty program.


With the success of the CFU and positive testimonials of CFU families, more SNAP recipients would voluntarily choose to join the CFU, until “involuntary” hunger or food insecurity is eliminated from the community.  There will always be some people who will choose “junk food” or choose to live “on the streets” and beg for money to buy food. As more non-SNAP community members join the CFU the quality and variety of its services can expand accordingly. At some point, the CFU could begin to provide foods through local schools, hospitals, and other publicly supported local institutions. 


As local farmers expanded in numbers and volume of production beyond the needs of their local community, they can begin providing food to other markets—giving priority to other CFUs that are being established in their bioregions. Community food sovereignty does not mean community self-sufficiency, but simply the right and the ability to choose what food items communities produce locally and what they choose to procure from other communities. 


Relationships among sovereign communities would not be impersonal economic or political relationships but personal relationships based on a shared commitment to the fundamental principles of food sovereignty—“people’s right to healthy and culturally appropriate food produced through ecologically sound and sustainable methods, and their right to define their own food and agriculture systems.” Slowly but surely, the “trim tabs” of food sovereign communities will begin to move national and global agri-food systems toward a more just and sustainable future for humanity.

Heritage Radio Network – Interviews at Slow Food Nations

On Friday, July 13, John Ikerd, Meighen Lovelace and Peter Ruddock participated in a panel session at the Slow Food Nations 2018 Leader Summit titled Eliminating Hunger .  They laid out the problem of hunger in our world and its causes, then presented some ideas for solving this serious problem, and finished with a deep discussion with an engaged and savvy audience.

Heritage Ratio Network interviewed the panelists over the course of the weekend, asking them about their session at the Summit, their work on hunger and other issues and generally about the sustainable food movement and Slow Food.  You can listen to the podcasts of those interviews.




Meighen Lovelace and Peter Ruddock talked food policy, how it relates to hunger, the ability to grow ones own food, sell homemade food and more.  Listen here.




Among other things, John Ikerd laid out his idea for a Public Food Utility, modeled after the Public Utility Commissions which regulate energy utilities.  Listen here.

The Homemade Food Operations Act – An Introduction


The Homemade Food Operations Act

An Introduction

Peter Ruddock


It’s estimated that at least 50,000 people in California at least occasionally sell meals that they cook at home.  Most of them have no idea that what they are doing is illegal. Normally, no one bothers them. This is not because no one wants to enforce the law, but rather because the county health departments which are in charge of enforcement could not keep up with such a volume of activity.  And there are political consequences to enforcing a law that people do not generally approve of once they are aware of it. However, health departments do occasionally cite individuals, usually in a public way, so that the citation acts as a deterrent to others.

The Homemade Food Operations Act (AB 626), would change this, making it legal to sell certain meals made in a home kitchen in California.  This bill is in its final leg through the state Legislature: it will be heard by the State Senate in August and should find its way to the governor’s desk from there.  It’s been a long journey.

First proposed in 2016 as AB 2593, by Assemblywoman Cheryl Brown (San Bernardino), with sponsorship from the Internet platform Josephine, which was working to organize home cooks, the bill met with a lot of resistance, significantly from health officials, who worried about its implications to food safety and public health.  Quickly shelved for the year, the current version of the bill was introduced by Assemblyman Eduardo Garcia (Riverside), with continuing sponsorship from Josephine. This version of the bill has been winding its way through the legislature for the last year and a half, getting amended, picking up supporters and opposition, losing its original sponsor Josephine, which went out of business, but getting a new sponsor in the C.O.O.K. Alliance, a community group formed by the founders of Josephine and community advocates.  Somehow through all of this, the bill has survived and is on the verge of becoming law.

Why a Homemade Food Operations Act?  We can trace the origins of this law back to a predecessor, the Homemade Food Act (AB 1616), also known as the Cottage Food Law, of 2012.  This law, championed by Assemblyman Mike Gatto (Los Angeles) and sponsored by the Sustainable Economies Law Center (SELC) was inspired by the raid of home baker Mark Stambler, who had been selling his bread to local restaurants, something not then allowed under California law.  Passage of this law, which was also met with resistance, permitted the production of small quantities of certain “non-potentially hazardous” (think shelf stable) foods, like breads, dried fruit and jams, to be sold from home kitchens by licensed producers.

Some people have noted that the foods permitted under the Cottage Food Law are not the healthiest.  Some shelf stable foods are made stable by adding lots of sugar and permitted cottage foods do tend to be sugary.  This may be true, but that was not the main reason for passing the law. Rather the Cottage Food Law was a step toward re-localizing food production, allowing home-based food businesses to exist, whether as a side-line for a homebound person, or as a starter kit for a potential new business, which if successful would move into its own facility.  It was an attempt to boost local economies. It acknowledged that home food production was happening anyway, and that licensing even part of it should make it safer (not that there were reports of homemade food creating significant health problems to begin with). It began a process of re-connecting people to their food, giving them new channels to buy local food from people they know, rather than buying food from unknown sources at large grocery stores.

Since 2012, a number of other bills have passed through the California Legislature which have also acted to re-connect people to their food.  Some notable bills that have become law include the Neighborhood Food Act, which created a right for citizens to grow food in their backyards and on patios, the Seed Exchange Democracy Act, which enshrined the right of libraries and other community groups to hold seed libraries and seed exchanges of small amounts of local seeds, and the Urban Agriculture Incentive Zones Act, which gives communities the right to give private landowners tax incentives for dedicating their property to agriculture.  We seem to be on a roll.

The Homemade Food Operations Act is arguably then only the latest in a series of bills to re-connect people with their food.  It is not even alone in 2018, as the Safe Sidewalk Vending Act (SB 946) authored by Senator Ricardo Lara (Los Angeles), which is also working its way through the legislature, would also work to re-localize food by legalizing sidewalk vendors throughout California and so making them safer.  And it will not be the last. Food advocates have ideas for future bills which will continue this work.

Of course, this bill is not without controversy.  Besides the food safety and public health issues raised by health officials, concern with Internet platforms gaining too much control over home cooks – the “Uberization” of homemade food – and concern by counties who don’t feel that they can afford to implement the law have been raised.  Look for future blog posts which dive into these issues. And for ways that you can support the bill during its final passage through the legislative process.


Peter Ruddock is a California food advocate, who works with a number of local, grassroots non-profits which focus on education around the concepts of good, healthy, local food, on building resilient local economies, significantly through the re-localization of food, and on changing laws which act as impediments to healthy food and resilient local economies.

Full disclosure:  Peter is an advisor to the bill’s sponsor, the C.O.O.K. Alliance.