Secretary Vilsack,

Thank you for the opportunity to submit a comment regarding the investments and opportunities for meat and poultry processing infrastructure. We at the Swette Center for Sustainable Food Systems at Arizona State University applaud the attention to meat processing as a key strategy to build back better.

Infrastructure is an integral part of meat processing and these funds will help increase competition and capacity for facilities of all sizes. How these funds are allocated will have a lasting and meaningful impact on both meat processing and our working lands as a whole. We encourage the USDA to dedicate a portion of these funds towards innovative research on meat processing techniques for sustainability, health, and farm/ranch viability. Examining innovative facilities and new practices to enhance the quality of products, such as dry aging and other value added techniques, will increase the options available to consumers, and provide improved financial returns for processors and farmers.

A few areas where we see an urgent need for investment in research and infrastructure development are listed below. We welcome continued dialogue on any or all of these proposals.

1. Opportunities for Tribal Nations There are over 58 million acres of Tribal Nation land in the U.S., most of which is ranchland used for cattle production. Tribal nations are already taking action in the meat sector, including dedicating funds from the CARES act for meat processing facilities. In line with the priorities of the Biden/Harris administration, and as proposed by the Native American Agriculture Fund report on infrastructure for food sovereignty, we recommend that the USDA directs funds to Tribal Nations for meat processing facilities. This will enhance Tribal food sovereignty while simultaneously creating a more resilient meat and poultry sector. An excellent example of what can be done in Indian Country is found in Quapaw Nation, where a $2 million investment resulted in a small multi-species processing facility and trained staff.

2. Grass-fed beef represents a small portion of the beef consumed in the U.S. but it is one of the fastest growing meat categories. Grass fed beef is often a more nutrient rich option when compared to conventional grain-fed beef. It also can improve pastures and decrease the carbon footprint of our food systems when managed with sustainable practices. One issue identified in our work is the lack of processing research and development as it relates to grass fed meat processing. Even though the production of grass-fed and grain-fed beef is quite different, when it comes to processing, aging, and butchering the meat, it is done exactly the same despite apparent differences in the meat depending on how the animal was fed and raised. Furthermore, there is a mismatch in the USDA grading standards when applied to grass-fed beef. Often, grass-fed beef will grade lower than grain-finished beef, largely because the grade standard was designed for a grain-fed system. Investing in research and development for the processing of grass-fed beef will enhance farmer profitability, consumer choice and nutrition, and make significant strides toward climate goals. We recommend the USDA dedicate funds on research toward grass-fed beef processing as well as toward a grading system that would increase grass-fed beef's marketability and consumer access.

3. Communication and coordination is extremely important when linking farmers to processors to grocery and retail outlets. It is well documented that the lines of communication are stressed between small-scale farmers and small and very small (SVS) meat processors. This was magnified during the Covid-19 pandemic as we saw farmers forced to look for different avenues as large-scale meat processing facilities closed their doors. To increase SVS meat processors' ability to compete in the market, the challenges surrounding communication need to be addressed. The Niche Meat Processor Assistance Network (NMPAN) has done work on the ways that coordination and communication between farmers/ranchers and meat processors can overcome the bottlenecks and supply flow that often impedes local and regional purchasing of meat products. This would also assist organic producers who oftentimes find it difficult to find dedicated organic processing as required by the NOP. This concern was highlighted in the Swette Center report, The Critical To-Do List for Organic Agriculture: 46 Recommendations for the President. We encourage the USDA to allocate a portion of these funds on communication and coordination models that can address challenges faced by small scale farmers and meat processors.

4. Community-based innovative models can offer consumers and farmers opportunities to explore alternative markets that improve access to local products. One of our partners, Stone Barns Center for Food and Agriculture, is implementing one of the many community-based models by creating a direct line from farm-to kitchen-to-plate with a focus on quality, sustainable products. Together, we are pursuing research to better understand the practices, considerations, and impacts of these models. Exploring and investing in community-based models, like the one at Stone Barns, can help farmers and SVS meat producers manage inventory, and expand processing capacity. We also note that seafood processing would benefit from this same type of research and investment. The USDA should focus a portion of these funds on investigating and promoting innovative community-based models of meat processing.

We appreciate the consideration of these recommendations, which we believe can help create a more robust and resilient meat sector.

Sincerely,

Kathleen A. Merrigan, PhD

Executive Director, Swette Center for Sustainable Food Systems

Arizona State University