My Comment Letter To Secretary Burwell and Secretary Vilsack Regarding the 2015 Dietary Guideline Committee Recommendations…

Dear Secretary Burwell and Secretary Vilsack,

After researching the science of nutrition and the history of the U.S. Dietary Guidelines, I write to you as a concerned American and a mother of three girls, as well as a cattle rancher. I have great misgivings with respect to the recommendations of the 2015 Dietary Guidelines Advisory Committee.

While raising teenagers is inarguably a challenge, mentoring my own teenage girls through the “sea of dietary confusion” reminds me distinctly of an Iron Man Competition. The CDC reports that 9% of all girls age 12-19 are iron deficient. In particular, athletic girls require more animal protein which uniquely provides heme-iron to ensure good health. Yet, the recommended 2015 Dietary Guidelines reduce even further the recommended dietary intake of animal protein. The “one size fits all nature” of this approach to diet inaccurately provides for the American people, and the resulting dietary education as well as the lunch nutrition that my girls’ receive in the public school system thereby runs contrary to their needs.

The high carbohydrate/low fat diet that serves as the basis for the U.S. Dietary Guidelines stems from epidemiological work begun by Ancel Keys in the 1960’s. Repeatable clinical trial studies since Dr. Keys’ hypothesis was formed have not provided scientific validation to the proposed merits of the diet. A small number of clinical trials done on middle-aged men provide the only non-epidemiological scientific basis for this dietary recommendation. To date, there is virtually no scientific data supporting this hypothesis as healthy for women or children. Perhaps even more disturbing is the culture created in the nutritional community since the establishment of the first Dietary Goals in 1977. Actions include stymieing other diet hypotheses and scientific trial work that do not match the original Key hypothesis. For instance, the 2015 Dietary Guidelines Committee refused to include the BOLD dietary research study in the reference section of their report thereby enabling them to “selectively choose their science” and further cut the recommendation for red meat.

Good science is both debatable and able to be replicated over time. Unfortunately, in addition to a biased approach to nutritional research, the 2015 U.S. Dietary Guidelines Committee Recommendations also include a further reach outside of documented science and into the realm of philosophy relative to the topic of sustainability. The science of sustainability is in its infancy. Much deeper analysis into topics like food waste and appropriate land use need to be completed before substantial information exists to promote one diet over another in the name of sustainability. Additionally, the topic of sustainability is clearly outside the scope of committee responsibilities.

In closing, I request that both of you do what is best for the American public and take a moment to read the research demonstrating that perhaps the high carbohydrate diet is part of the cause of the dietary ailments of Americans rather than the solution. In the lifetime of the Dietary Guidelines the culture of the American diet has shifted dramatically. According to USDA, the consumption of grains (41%), vegetables (23%) and fruits (13%) rose significantly from 1970-2005 while red meat (-22%), milk (-33%) and eggs (-17%) fell dramatically. Overall carbohydrate intake for Americans rose with low fat starches, and vegetable oil took the place of animal protein and fat in the diet. Animal protein lovers shifted from beef to chicken, and many traded whole fat dairy for skim milk and margarine thereby forsaking nutrition density for lower saturated fat options. All of this occurred during a time in the United States when obesity rates more than doubled (15-32%), the prevalence of heart failure, cancer and stroke all increased, and the rate of diabetes increased from less than 1% to 11%. Clearly, the dietary changes caused by dietary guidelines resulted in an “unhealthier America” as Americans traded protein for sugar.

I ask you to help put the science back in nutrition by:
1.Recognizing that the nutrient requirements of Americans vary according to age and sex thereby rendering a one size fits all approach to diet both ineffective and potentially harmful to women and children.
2.Including diverse animal protein options (including beef and whole fat dairy) as part of a balanced and healthy diet.
3.Encouraging a robust and healthy dietary science community where hypotheses are proven before they are sold as truth, and studies on all hypotheses are universally included in the discussion.
4.Removing all verbiage relative to sustainability from the dietary guidelines as that topic is both outside the realm of the committee as well as lacking the necessary scientific basis to be meaningful.

Thank you for your time and consideration.

Sincerely,
Anne Burkholder