Monday, December 06, 2010

Food Stamping on Auto-Pilot

The Bloombergistas got a gift last week when erstwhile foe, Public Advocate Bill de Blasio, endorsed the mayor's food stamp restriction on the purchase of soda: "Bucking his traditional supporters, Public Advocate Bill de Blasio is endorsing Mayor Michael Bloomberg's proposal to bar recipients of food stamps from using them to buy soda or other sugar-sweetened drinks. Mr. de Blasio, a Democrat from Brooklyn who won citywide elective office last year with the help of liberal voters, sent a letter this week to the U.S. Department of Agriculture urging approval of Mr. Bloomberg's proposal for a two-year pilot program excluding sugary drinks from food-stamp purchases in the five boroughs."

Now our position on this is abundantly clear-we not only are suspicious of this kind of government control, we also see it as a harbinger of an even greater intrusiveness if the current version of Obama Care isn't radically amended. But there is another issue here that deserves to be mentioned-the unintended consequences that the new regulation will have on the viability of the city's bodegas.

This is not an insubstantial issue-the state of the bodegas in this city, and the Korean green grocers as well, is not a rosy one. But the city-in its obsession in promoting health above all other concerns-never even bothers to examine the potential economic impacts of its myriad of health initiatives. When the mayor made his first anti-tobacco foray-raising the cigarette tax by over 1800%-no consideration was given to how this would: (1) Drive sales out of existing stores; and (2) Create a lucrative, and crime producing black market.

When it was documented that bodegas and other city outlets were losing $250 million a year! the mayor told reporters that this was a, "minor economic issue." Meaning that the health of the citizens trumped the lost bodega revenue. Of course, lower priced smokes flooded city streets from black market sources, demonstrating that the health policy was not only unhealthy for the city's smallest stores, but that it was counterproductive as a health initiative at the same time.

A similar lack of concern was seen when the city decided to mandate really gross cigarette signs in the bodegas and delis-and even the newsstands as well. That the signs might turn off non smokers and cost sales for the stores never entered the city's calculus. It was health ubber alles.

The best-or, perhaps, worst-example of this health policy blinders was the city's foray into menu labeling. Here there was no scientific evidence that this kind of policy would educate the public into making better fast food choices, yet the Board of Health proceeded-willing to fly blind-without any idea of the proposal's efficacy. Subsequent studies indicated that the calorie posting is ineffective, but the rule remains in effect.

As with the other health initiatives, no evaluation was undertaken to determine how menu labeling would impact the profitability of fast food outlets-no cost benefit analysis was even considered, in spite of the fact that the FDA did a rigorous economic impact analysis before it launched its package labeling for nutrition in the early nineties. Scientific justification and cost/benefit analysis was superfluous; the only thing that the Bloombergistas needed to promote its health policies was self-righteousness.

But, as we have seen with the Climate Gate scandal, when science is corrupted it is little solace that the stated goals might be worthy-and the cynicism this kind of cavalier attitude breeds is ultimately destructive to rationale debate and discourse. Of course, we saw just that when NYC's health commissioner disregarded all scientific evidence in his promotion of a soda tax-a fraudulent campaign that in any other venue would have inevitably forced the perpetrator to resign.

Which brings us back to the mayor's food stamp pilot program-another shoot from the hip policy effort that has absolutely no regard for the potential collateral damage it could do to the city's most vulnerable small food retailers, stores whose income depends on the sale of soda and other ready to drink cold beverages. Before undertaking such an initiative, the city should be required to analyze the role that soda plays in the economies of the food retailers who would be targeted by the food stamp restriction.

The rationale for this kind of approach devolves from the need to understand, not only baseline health needs and customer buying patterns, but the economic role of soda sales as well. Doing a pilot before gathering this kind of information will insure that any result will have little claim to scientific validity-and will likely generate obfuscation, or outright fraud, designed to justify the continuation of the pilot.

In fact, the entire underpinning of this pilot program is permeated with mystification. How will the data be gathered? What, if any, will be the penalties for failure to comply? How many inspectors will be needed to insure compliance, and what will the added work force cost? Shouldn't the Bloombergistas be forced to conduct this experiment with at least a degree of  scientic rigor and transparency?

The reality is that bodegas don't have the electronic accounting systems that supermarkets have, and tracking the food stamp pilot restrictions will mean significant increases in manpower and on-site inspections; and the likelihood that bodegas will be subject to additional enforcement measures that go beyond the soda experiment.

Without a well defined and publicly vetted methodology it is unlikely that this pilot will reach the goals that the mayor-and now the public advocate-wants to achieve: "Mr. de Blasio acknowledged the proposal is "sensitive and complicated" and that many of the advocates he's worked with over the years disagree with his position. "By subsidizing the purchase of soda with food stamps, we've been unwittingly stacking the deck in favor of these unhealthy beverages," said Mr. de Blasio, who was lobbied by one of the mayor's commissioners on the soda ban. "This pilot program could help even the odds for healthier foods."

DeBlasio, without knowing the parameters of the pilot program, is taking a shot in the dark-buying a pig in a poke from a mayor who loves to issue stacked deck studies done by house slave consultants. The PA is certainly no fan of Ronald Reagan, but before giving this pilot his blessing, he should have heeded the former president's famous admonition: "Trust but verify."