Food Policy: A Comparative Analysis of Local Food Policies versus Federal Government Policies

By: Elease Willis (PO ’22)

As a developed country that places a premium on technological innovation and globalization, the United States has prided itself on having transcended the immediate pressure of satisfying the lower tiers of Maslow’s hierarchy of needs, like the physiological need for food. Yet not only is food insecurity a reality for a considerable number of Americans, attaining affordable food that will beneficially fuel one’s body is a struggle for many as well. The questions that will guide this analysis are as follows: What steps have been made in recent years to address food deserts? What policies have yielded the most results? Is there a notable difference between the efficacy of more localized food policies compared to national food policies that would suggest that the reduction of food deserts would be best handled by the national government or smaller communities?

The Anatomy of a Food Desert

Per the instructions of Congress when it passed the Conservation and Energy Act, also known as the 2008 Farm Act, the U.S. Department of Agriculture (USDA) Economic Research Service (ERS) published Access to Affordable and Nutritious Food: Measuring and Understanding Food Deserts and Their Consequences (USDA, 2009). In this publication, food deserts were identified as “areas where people have limited access to a variety of healthy and affordable food.”[ref] Paula Dutko, Michele Ver Ploeg & Tracey Farrigan, ERS, Characteristics and Influential Factors of Food Deserts iii (2012), [/ref] The Food Empowerment Project—a nonprofit organization that values veganism, sustainable food practices, fair working conditions for laborers, and sufficient availability of healthy food in low-income areas—describes food deserts as “geographic areas where residents’ access to affordable, healthy food options (especially fresh fruits and vegetables) is restricted or nonexistent due to the absence of grocery stores within convenient travelling distance.” [ref] About, Food Empowerment Project, (2019). [/ref] There are keywords that appear frequently in definitions of food deserts offered by varying organizations and government bodies. However, there is greater emphasis on certain metrics used to define food deserts relative to others can affect how the issue is ultimately approached.

Is a food desert defined by the proximity of healthy food sources and the availability of resources used to acquire that food (i.e. vehicles and income)? Is it defined by the relative imbalance between the availability of nutritionally dense and nutritionally vacant in an area? Or perhaps by the price differences between healthy and unhealthy food sources? [ref] Michele Ver Ploeg, Paula Dutko & Vince Breneman, Measuring Food Access and Food Deserts for Policy Purposes, 37 Applied Econ. Persp. & Pol’y 205 (2014). [/ref] All of these components—availability, affordability, nutritional quality, accessibility—are intuitively relevant to the issue of food deserts. The implications of differences in measurements of food access on policy decisions will be more closely analyzed later in this paper, but for now, the ERS methodology will be of interest.

The 2009 report published by the ERS uses the census tract for the area-based definition of a food desert. Food deserts are identified as such if they meet both low-income and low-food-access criteria as established by the Economic Research Service. Census tracts are sections of a county containing between one thousand and eight thousand people. The ERS defined food deserts as “low-income tracts in which a substantial number or proportion of the population has low access to supermarkets or large grocery stores.” [ref] Dutko, Ver Ploeg & Farrigan, supra note 1, at 5. [/ref] A poverty rate equal to or greater than twenty percent, a median family income of eighty percent or less than the metropolitan area’s median family income or statewide median family income were counted as low-income. Low access was determined to be areas in which at least thirty-three percent of the tract population lived more than one mile from a supermarket or large grocery store in urban areas and more than ten miles in rural areas. The list of supermarkets and large grocery stores (stores that offered the major food departments found in traditional supermarkets and selling at least two-million-dollars’ worth of product) was created from both a list of stores approved to receive Supplemental Nutrition Assistance Program (SNAP) benefits as well as data from the Trade Dimensions’ (TDlinx) to source independent supermarket store listings.

With these parameters, 6,529 census tracts based on the 2000 Census of the Population were labelled as “food deserts” by the USDA. ERA analysts have developed a Food Desert Locator tool that maps out the locations of food deserts. This Food Desert Locator uses the definition of a food desert developed by the USDA as explained, identifying areas such as the South and West Sides of Chicago; Camden, New Jersey; and Memphis, Tennessee. [ref] Eric Goldschein, 10 American Food Deserts Where It Is Impossible to Eat Healthily, Business Insider (Oct. 12, 2011, 11:38 AM), [/ref]

Food is an invariably important component of one’s development and maintenance of overall health. Per the request of the ERS, the National Academy of Medicine and the National Research Council assembled a workshop that was held January 26-27, 2009 in Washington D.C. for the purpose of assessing the public health implications of food deserts and strategies to apply to address it. This workshop consisted of experts presenting multidisciplinary research for the common purpose of “[alleviating] problems related to the accessibility, availability, affordability, and quality of foods.” [ref] Nat’l Res. Council, The Public Health Effects of food Deserts: Workshop Summary (2009), available at [/ref] The overabundance of caloric-dense snacks and fast foods in food deserts were approached at this workshop as giving rise to notable increases in obesity, cancer, and cardiovascular diseases. Such diet-related health concerns post an economic burden.

Though estimations of said economic burden are dependent on researchers’ definition of an unhealthy diet, methodological approach, and the nature of costs that are examined, [ref] Christine J. Candari, Jonathan Cylus & Ellen Nolte, Assessing the Economic Costs of Unhealthy Diets and Low Physical Activity: An Evidence Review and Proposed Framework, 47 Eur. Observatory on Health Sys. & Pol’y (2017), available at [/ref] it can’t be argued that ameliorating the diet health of U.S. citizens would impact diet-related health costs to the economy. In comparison of food desert tracts to other census tracts according to the 2000 Census, the ERS found that in food deserts, there was a higher mean percentage of ethnic minorities; unemployment; and individuals living in poverty, receiving public assistance benefits, and living in a housing unit with no vehicle.


Food Policy: The Downfall of Federal Programs

The range of food policies and initiatives aimed at addressing the issue of food deserts is wide and complex.

The federal government has put forth several programs and laws to the effect of food desert eradication. The Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) is a federal funding program that grants money to states for “supplemental foods, health care referrals, and nutrition education for low-income pregnant, breastfeeding, and non-breastfeeding postpartum women, and to infants and children up to age five who are found to be at nutritional risk.” [ref] Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), USDA, (last visited Jan. 15, 2020). [/ref] Most WIC benefits are redeemed at larger grocery stores or supermarkets. In 2014, a revision of the food packages provided by the federal WIC program included a larger variety of fresh produce and whole grains. [ref] Eillie Anzilotti, The Ongoing Need for Healthy Food in Corner Stores, CityLab (May 12, 2016), [/ref] The research of the 2010 White House Task Force on Childhood Obesity Announce culminated in the Healthy Food Financing Initiative (HFFI) being put forth in 2010 for the expansions of nutritious food access to food deserts via “developing and equipping grocery stores, small retailers, corner stores and farmers markets selling healthy food.”[ref] CED Healthy Food Financing Initiative FY 2016, Office Commun. Serv.: Office Admin. for Children & Families, (last visited Jan 20, 2020). [/ref]


The Healthy Food Access for All Americans Act (HFAA), first introduced in 2017 and reintroduced in 2019, is a proposed bipartisan legislation that would amend the Internal Revenue Code to allow tax credits and grants for activities that provide access to healthy food in food deserts. [ref] Healthy Food Access for All Americans Act, H.R. 4260, 115th Cong. (2017). [/ref] Interesting about this legislation is that food servicers in low-access and low-income communities, including food banks and temporary access merchants (i.e. mobile, markets, farmer’s markets, and some food banks) could receive tax credits and grants by applying for certification as a Special Access Food Provider with the Treasury Department. [ref] Sen. Moran Reintroduces Bill to Incentivize Grocery Stores, Help Eliminate Food Deserts, U.S. Senator for Kansas, Jerry Moran (Mar. 18, 2019), [/ref] A pilot program introduced early 2019 will allow SNAP benefiters to use their EBT to buy groceries online and have them shipped to them. The initial phase will only be applicable to those living in specific areas of New York, but there are plans to expand to the rest of the state and other states as well. [ref] Anne D’Innocenzio, Food stamps and online grocery shopping are about to mix, AP News (Apr. 18, 2019), [/ref] This USDA pilot program was authorized by the 2014 Farm Bill for conduction and evaluation before being finalized as an option available nationwide. The federal government has the advantage of being able to fund programs such that their influence is notably widespread. However, there are some critiques to be made in order to reevaluate and refine the efforts for increasing healthy food access.

Policymakers not working from a definitionally unified concept of food deserts contributes to there being a not entirely unified push to address the issue of healthy food access. The measures used to define food deserts that have been created by various organizations “have different motivations that may be more appropriate for some policy purposes than others.” [ref] Ploeg, Dutko & Breneman, supra note 3, at 206. [/ref] Additionally, federal agricultural policies are too often in contradiction to the goals and strategies of food desert mitigating policies—in contrast to the recommended nutrient intake, most U.S. government funding given to farmers is for the production of soy, cotton, and corn. [ref] Emily B. Leib, America Needs to Get More Strategic About Food Policy, HuffPost (June 14, 2017, 1:28 PM), [/ref] Efforts to reduce SNAP/WIC benefits augment the issue of farm subsidies largely skipping over production of fruits and vegetables.

Reduction in the amount available for SNAP and WIC beneficiaries to spend on groceries, in addition to fresh produce frequently being higher priced than foods processed with high fructose corn syrup and other similar additives derived from subsidized food production, make it hard for individuals to justify buying produce over boxes of sugary snacks. Tax credits for large grocers over small grocers is a questionable practice in the long-term. Tax credits for large grocers ignores smaller, independent grocers that also need assistance. [ref] Tom Ryan, Government Incentives for Food Deserts?, RetailWire (Aug. 8, 2011), [/ref] It’s worth considering how tax credits for smaller grocers could elevate the overall economic health of the communities they are located in. Not only are these small, independent food providers already more ubiquitous in food desert areas, major food retailers have been found to fall short on their promises of opening and expanding their business to areas previously bereft of them. [ref] Tribune Wire Reports, Grocery Chains Leave Food Deserts Barren, AP Analysis Finds, Chicago Tribune (Dec. 7, 2015, 12:40 PM), [/ref]


Food Policy: A Map of State and Local Programs

There have been state and city government-level food policies that are of note as well. Urban agriculture—which can manifest as vertical and rooftop farming, urban foraging, community and residential gardens, and commercial urban farms—offers opportunities for locals to build community and build a green space in their cement and industrialization dominated environment while getting access to fresh produce. There has been interest in urban cities, such as in Oakland, California, to revamp zoning laws to accommodate increasing urban agricultural endeavors. [ref] Matthai Kuruvila, Oakland Urban Farming Prompts Plan to Redo Rules, SFGate (May 8, 2011), [/ref] These adjustments would allow anyone to grow and sell produce, and in some cases even farm livestock, on their property without a permit. Many cities have recognized the importance of corner stores to city residents’ regular grocery shopping. As such, it has been rightly acknowledged that improving the selection of healthy foods in such corner stores would affect city resident’s buying of healthy foods. These healthy corner store initiatives take shape differently in terms of scope, geography, incentivization, and policies implemented to improve access to and consumption of healthy foods. As stated in a 2014 research brief by the National League of Cities “programs that are larger in scope are able to encourage small food markets to sell healthy foods by offering training, marketing materials, technical assistance, refrigeration equipment, and even vouchers for fruits and vegetables” thereby supporting stores to provide healthier items on their shelves.[ref] Raksha Vasudevan & Bryan Barnett-Woods, Nat’l League of Cities, Bringing Nutritious, Affordable Food to Underserved Communities: A Snapshot of Healthy Corner Store Initiatives in the United States 1 (2014), [/ref] Other programs involve collaboration of community leaders, often leaders part of non-profit organizations based in the city or that have a chapter in the city, and willing small food shop owners to “make healthier options more visible in stores and more available to the public.” An example is the Minneapolis Healthy Corner Store Program. It started in 2010 as a two-phase initiative of the Minneapolis Health Department (MHD) and was supported by the aid and resources of community-based organizations. [ref] City of Minneapolis Health Dep’t, The Minneapolis Healthy Corner Store Program Summary Report (2013), [/ref] When the MHD assessed that nearly seventy-five percent of thirty-five surveyed stores did not meet the staple food requirements defined by a 2008 ordinance to “carry a minimum of five varieties of perishable produce and other minimum stock requirements of staple foods such as meat, bread, and dairy,” it was deemed necessary to provide some level of support for the food providers to “improve the visibility, accessibility, attractiveness, and availability of fresh fruits and vegetables.” [ref] Id. at 3. [/ref] Surveys and research are often conducted before food policy programs are implemented, whether that be at the federal level or city level. Surveys and research undertaken in smaller areas can translate to more specialized programs being developed that are better suited for a particular community’s needs, desires, and current resources.

Non-Profit Food Projects

There are initiatives related to combating the presence of food deserts that aren’t strictly public policies. These are initiatives put forth by companies in an effort to be socially conscious and by community-based organizations that have an arguably better pulse on the specific needs of their community. Food charters are becoming increasingly used as a way to describe the visions, strategies, and actions necessary to promote a “civically engaged food system.” [ref] What’s a Food Charter, N. D. State Univ., (last visited Jan. 16, 2020) [/ref] Michigan and Minnesota both have food charters, the former being the first in the nation to establish one as a state, that “highlight what state, county, city, and town levels of government can do to stimulate access to healthy foods for all.” [ref] Id. [/ref] While these are more-so decrees of intent than legal decrees, they have the advantage of describing the community’s food needs in concrete terms that is not bogged down by descriptions of what necessarily constitutes a food desert (such as can be the case in government laws). In early 2019, Lyft implemented a pilot program in Washington D.C. in conjunction with the nonprofit organization Martha’s Table. This Grocery Access Program offered flat-rate rides of $2.50 to the five hundred enrolled families to take trips to their nearest full-service grocery store. [ref] Bridget Hallinan, Lyft Grocery Access Program Will Expand Nationwide, Offering Discounted Rides to Supermarkets, Food & Wine (Apr. 25, 2019), [/ref] Currently, the program operates in twelve different cities, but with plans to expand. [ref] Access to healthy food – Lyft Grocery Access Program, Lyft Inc., (last visited Jan 16, 2020). [/ref]

This program is a remarkable way for companies and nonprofit organizations to collaborate to address the factors contributing to food deserts, this case being that of increased accessibility to grocers despite a lack of vehicle and/or distance. Mobile fresh produce markets offer direct distribution of fresh produce, often locally sourced, to areas of high need. Peaches & Greens, a Detroit operated mobile produce market founded in 2008, was actually inspired by People’s Grocery in Oakland, California. Peaches & Greens had originally been intended to be a brick and mortar produce market, but upon reading the strategy of People’s Grocery, despite the fact that the Oakland market shut their mobile produce delivery service down, decided to implement this service in the community as well. As described by a driver of the Peaches & Greens truck during an NPR interview, residents in the neighborhood were thrilled to learn of such a service once they recognized that the truck was not a distributor to various stores specifically, but as a distributor to the community generally. [ref] Detroit Truck Responds to City’s Food Crisis, NPR (Nov. 2, 2010, 12:00 PM), [/ref]

Another interesting program is California FoodWorks. It is a loan and grant program offering financial assistance to eligible food enterprises that have a mission to “increase access to affordable, healthy food in low-income and underserved communities in California” who would otherwise be unable to receive help from traditional sources. [ref] About Us, California FreshWorks, (last visited Jan. 16, 2020). [/ref] Evaluation of businesses interested in being part of the lending program is based on the goals of healthy food access, economic development, racial and social equity, environmental stewardship, and local sourcing.

This lending network highlights what is a large obstacle to many food access initiatives that rely on private contributions—funding. Financial stability for many food access initiatives, like those who operate mobile fresh produce markets, is a serious concern that can stall a community organization’s goals or result in its unmaking entirely. The burgeoning corporate interest in food policy and the continued efforts of non-profit organizations further fortify the government policies and initiatives that address issues of food access. It is not readily apparent that there is considerable conflict between state and local government food access policies and nonprofit or corporate-funded projects, unlike federal food access programs that can be at odds with the state of agricultural subsidies and the extensiveness of SNAP/WIC benefits.

Food Policy: A Map…But to Where Exactly?

Though impressive steps have been made to address food deserts, there are gaps in the formation of government policy that have undermined the efficacy of these advances. In order for government policy to achieve desired efficacy, a more comprehensive definition of food deserts is needed that adequately acknowledges all factors contributing to a food desert. However, the efforts that would need to be invested in developing a cohesive and comprehensive food desert definition are considerable. Food policy initiatives developed on a more local level need to be more readily supported by federal funds.

States and local communities best understand the fervor for healthy food access in their location and the particular strategies that could be best used with their citizens. This isn’t to say that all federal government programs and policies are without worth; WIC is a very important program. But when one considers the often tumultuous future of WIC due to partisanship for example, or government attention to big grocers that are companies that may ultimately consider tax credits not enough of an economic pull to establish themselves in these food deserts, it becomes apparent that more local initiatives have their own weight in influencing healthy food access.

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