The School Nutrition Association of Virginia would like to express our support for the proposed regulations. We represent over 1,700 members who provide high-quality, affordable, nutritious meals to students across the Commonwealth. The SNA-VA was one of the stakeholder groups who worked on the “Healthy Snacks” legislation in 2010 and served on the advisory group that helped craft these regulations. We appreciate being included in this process and strongly support the purpose of the proposed regulations.

We previously submitted comments in support of the regulations in October 2013. We understand that the proposed regulations must be amended in order to comply with legislation passed during the 2015 legislative session. HB 2114 will allow up to 30 fundraisers per school to be exempt from the regulations. SNA-VA did not support this legislation and we are deeply concerned about the effect this law will have on students’ health and well-being. However, we understand that the Board of Education is obligated to amend the regulations to comply with this law.

While the language that will exempt fundraisers has not been added yet at this point in the process, the SNA-VA would like to give our input regarding the potential new language. We respectfully request that the Board of Education do the following:

• Provide clarification that it is optional to exempt up to 30 fundraisers. Individual school divisions may still enforce their own policies and not exempt any fundraisers.
• Provide clarity on the timeframe of the fundraisers. SNA-VA requests that a fundraiser be considered to last one academic school day. Therefore, a fundraising activity that lasts two weeks would count as 10 fundraisers, not just one fundraiser.
• Provide guidance to schools on alternative fundraisers that do not involve the sale of unhealthy foods to students.

Thank you for the opportunity to submit comments. We look forward to remaining engaged in the process and will provide comments again once the regulations are revised to reflect the 2015 legislation.