IFT Comments to USDA - CSREES on the Agriculture and Food Research Initiative

September 24, 2008

The Honorable Colien Hefferan, Ph.D.
Administrator
Cooperative State Research, Education, and Extension Service
U.S. Department of Agriculture
STOP 2240
1400 Independence Ave., S.W.
Washington, DC 20250-2240
CSREES-2008-0002

Re: Cooperative State Research, Education, and Extension Service Solicitation of Input Regarding the Agriculture and Food Research Initiative (AFRI), CSREES-2008-0002

Dear Dr. Hefferan:

The Institute of Food Technologists (IFT), the not-for-profit international, scientific society with 22,000 members working in food science, technology, and related professions in industry, academia, and government appreciates the opportunity to respond to the call announced Aug. 29, 2008 in the Federal Register (Vol. 73 [169]: 50926) for stakeholder comments pertinent to the implementing regulation to be developed for establishment of the Agriculture and Food Research Initiative (AFRI) as authorized in Section 7406 of the Food, Conservation, and Energy Act of 2008. We congratulate you on the creation of this institute, which helps to elevate the important mission of the Cooperative State Research, Education, and Extension Service (CSREES) to the priority and prestige of health research that has been held in such high regard for so many years.

Priority Areas

IFT agrees that the priority area of “food safety, nutrition, and health” is very important to the continued ability to conduct cutting-edge agricultural and food research in the United States. Continued funding for research into various topics in food safety, nutrition, and health is critical to ensure that America is able to maintain abundant, high-quality, safe, and affordable food for consumers, and contribute to the success of a food and agricultural system that creates jobs and income in the United States, protects the environment, and is sustainable. Thus, we are extremely pleased that “food research” was made part of the title of this prestigious initiative.

The six priority areas identified are fairly broad. We assume that they will embrace the full range of food science research as well as research in food safety even though not stated explicitly. It is critical to appreciate that unlike food safety topics and issues, there are no other funding sources for basic research in food science. We would hope that the priority area food safety, nutrition, and health would include applied as well as basic food microbiology. Additionally, we would hope that food science and food technology research in such areas as food processing, food engineering (e.g., alternative processing technologies), food packaging, nanoscale science and nanotechnology, food and health, and biobased materials will be captured in this priority area. Furthermore, it is important that connections between food, health, and wellness, and food science and biomaterials, be made more clearly from food science and technology perspectives for effective advancements and solutions to challenges in these areas.

IFT is also assuming and supportive that the six priority areas would accommodate food science and technology investigators who previously submitted proposals to program area 71.1 (Improving Food Quality and Value Projects). Eventually, as the effort matures, we will receive more details of the sub-areas under each priority. We hope that investigatorinitiated research is embraced in this initiative as this is typically the cornerstone of creativity in America.

Allocations for Fundamental and Applied Research

While it is appropriate for AFRI to fund fundamental (basic) and applied research, IFT believes that allocating certain percentages of funds (i.e., 60% of funds for basic and 40% for applied research) encourages categorization that limits integrative thinking. One hopes that basic research will lead to applied research, and vice versa. Moreover, given the interdisciplinary nature of today’s solutions to agricultural and food issues, 30% may not be sufficient to fund integrated approaches needed to address certain problems. Thus, IFT recommends the flexibility of at least 30% of funds being available for fundamental research grants. On the other hand, once at least 30% of the amount allocated toward basic research is allotted to integrated research conducted by multidisciplinary teams, the remaining funding to carry out other types of studies will likely be very inadequate.

An important concept that is often over looked in requests for proposals is the importance of building upon basic and applied research outcomes through follow up investigations into food science and technology research applications. A substantial amount of data published in journals is often not pursued further. Although IFT acknowledges that funding is to be allocated to applied research, and includes an education and outreach component, we suggest that language be included that would help encourage “next steps,” to further advance high potential outcomes and their impacts.

Although AFRI would be authorized to fund grants to beginning researchers fewer than five years from their initial career track positions, IFT recommends that some funding be specifically allocated for new investigators.

10 Year Terms

While IFT supports a limit of 10 years in grant terms, it is critical that research terms of much shorter duration, e.g., two years, be accommodated. A number of impressive research models have resulted in very meaningful research in a relatively short amount of time. Thus, it is imperative that research teams seeking to make a difference in the short run, who are able to streamline investigation processes, have access to funding. Thus, although certain research areas merit 10-year funding (e.g., studies measuring changes in behavior), IFT believes that addressing most issues in food science and food technology requires research with more rapid results, and hopes that adequate funding will remain available for a sufficient number of shorter-term (two to five years in duration) research projects.

Cap on Indirect Costs

The raised cap on indirect costs from 19% to 22% is a step in the right direction but it still leaves U.S. Dept. of Agriculture (USDA) funding in the position of being less supportive of institutions than other agencies (e.g., National Institutes of Health). State support of public universities is seriously dwindling, and the indirect cost recovery (ICR) of USDA grants is not high enough to come near to covering the cost of the overhead. Moreover, the low percentage of ICR for USDA grants does not help to improve the image of agriculture to university and college administrators who have backgrounds in disciplines other than agriculture.

Budget Submission and Funding

The requirement that the President must submit a single budget line item reflecting total amount requested for research, education, and extension activities as part of annual budget submission could allow for the unfortunate possibility of lack of budget line item submission.

Assistance Identifying Reviewers

IFT is uniquely well positioned to identify grant proposal reviewers having directly pertinent expertise. IFT would be happy to provide USDA with the names of respected individuals in food science, food technology, food safety, nutrition, public health, and other pertinent disciplines to serve as reviewers for grants relevant to their expertise in both basic and applied research areas.

Annual Appropriations

Finally, IFT recognizes that food and agricultural research, education, and extension are chronically under-funded. The level of current funding for food and agricultural research, education, and extension is disproportionate to the value to the economy provided by agriculture and food. The food and fiber sector contributed $13,247 billion to the U.S. Gross Domestic Product in 2006. Current funding levels are insufficient to allow an appropriate number of research awards justified on the basis of the number of high quality research proposals submitted. It is our understanding that only $200 million of the $700 million in grants authorized by the Farm Bill for FY 2008 – 2012 is funded. As long as $700 million remains a theoretical goal, the 60 – 40% formula for basic and applied research will have a negative impact on critical research programs. Moreover, IFT believes it is imperative to have adequate funds available through AFRI for basic research in food science, because there are no other funding sources for food science, unlike the situation for food safety. It is essential that adequate funds be available for basic research in food science and applied research in food technology, to enhance food safety and improve human health. Thus, IFT strongly encourages that AFRI realize adequate funding levels, increased over those of its predecessor.

Sincerely,

Sheri Schellhaass, Ph.D.
IFT President

Story Tools