In our ongoing analysis of the proposal that the industry launch a generic promotion program we have made a few salient points:
1)In our piece Got Produce? Generic Marketing Program Dialog Begins, But Is It Right To Use PBH Donor Funds To Lobby For A Mandatory Assessment? — we pointed out the danger of using PBH funds that derive from donors for purposes those donors never intended. We also suggested that having to go through the process of raising money is itself a useful vetting process for an idea. If everyone claims to like an idea but nobody is prepared to fund its promotion, the support is lukewarm at best.
2) Got Produce? Both Sides Need To Be Heard included a letter complaining about the failure of the advocates of the program to publicize any critiques of the program. We pointed out the problematic nature of having the same exact people being the organizers of this industry “Dialog” and the prime advocates for the proposal! It is sort of like allowing then candidate Barack Obama to set all the ground rules for the Obama vs. McCain debates — it almost precludes a fair assessment of the issues.
3)With Got Produce? Is $30 Million Sufficient? — We began a move into substantive analysis of the proposal and we pointed out that what we need to avoid at all costs is undertaking this effort with insufficient resources to accomplish its objectives. There is simply not a persuasive case that a total $30 million dollar budget — and how much of that will inevitably wind up as office space, staff, travel, agency fees, research, etc. before we spend a dime on media — is sufficient to achieve objectives. A lot of homework remains undone: What would consumption be without the program? What is the projected effect of the program? How does this ROI compare with other uses of the money, say bolstering commodity specific or branded efforts? The proposal contains virtually no research done by bona fides third party experts. We questioned how the industry could possibly vote when it hadn’t been given any information on which to vote.
4) Got Produce? The Rent-Dissipation Hypothesis And The Issue of Cui Bono pointed out that this type of program would play out in produce very differently than in Beef, Dairy or Pork, which all draw on the fact that a cow is a cow and a pig is a pig. In produce we have so many different produce items and each would benefit or lose from the proposed scheme in a different way. In general we expect that the producers of row crops would be paying to subsidize benefits for tree crops that take a lot of capital and a long time to be established. We asked why no research had been done to assess how this would play out for different commodities and how could we expect people to vote on such a proposal without such information?
Now most of our concern over PBH’s role in this situation has revolved around two procedural areas:
First, that PBH has never raised money with the pitch being that if donated the funds would be spent on lobbying for mandatory assessments for the produce industry. Obviously it is possible for a person of integrity to both want to urge increased consumption of produce with the goal being better health for the population and to oppose mandatory assessments. In the long run we suspect this will do great harm to PBH because those who support its work but happen to oppose mandatory assessments will be hesitant to support PBH in the future.
Second, we are concerned because PBH has taken on a dual role that is in conflict. Elizabeth Pivonka, president of PBH, Mark Munger, Vice President of Marketing at Andrew & Williamson Fresh Produce and immediate past chair and Paul Klutes, Brand Sales for C.H. Robinson and current Chairman are all out there as the primary advocates for the program. Yet the exact same people have set up the “groundrules” — Who gets to speak? For how long? When and where? How is the budget to be spent? In effect, these three have been set up as both the candidates and the League of Women Voters. It is not right and it makes the process lack credibility.
Today, however, we would like to look at a substantive issue, that also calls into question the involvement of PBH with this matter. Why not Fresh?
The Produce for Better Health Foundation, because it chairs a public-private nutrition education program and works in partnership with the Centers for Disease Control is obligated to promote, frozen, canned, dried and juiced product.
So, on its web site, when asked about nutritional differences between fresh and frozen, PBH says this:
Whether it is fresh, frozen, canned, dried, or 100% juice, all forms of fruits and vegetables matter, and are part of a nutritious and healthy diet. In fact, most frozen and canned foods are processed immediately after harvest, preserving their nutritional value and flavor. Frozen fruits and vegetables are also convenient and require little preparation, as the washing and slicing is already done for you. Also, the nutrient content of fresh and frozen (as well as canned) fruits and vegetables is comparable.
To us it reads like a commercial for non-fresh product, with PBH going out of its way to emphasize the convenience and ease of preparations of non-fresh, which wasn’t even asked in the question.
Still, we understand. This is a nutrition education program being done in partnership with the government, so the rules have to be followed.
However, a generic commodity promotion program is not a “nutrition education program” it is an ad campaign for an industry. Although done under the law, it is not a public private partnership and the government doesn’t allocate money for it.
If asked a question, a generic promotion board pushing fresh produce would have no obligation to wax poetic about the convenience of canned and frozen.
One suspects that a consumer program pushing consumers to demand, say, fresh mushrooms on their pizza rather than canned imported mushrooms from China would be far more likely to be successful than an effort to get consumers to eat more mushrooms rather than Twinkies.
Selling the crispiness of fresh broccoli rather than frozen seems a more doable project than hoping to sell more broccoli by getting consumers to give up Cheesecake.
Obviously there are advantages to working with others, we can possibly have more money, it would align better with the PBH effort, etc. Yet there is also a clear reason for saying the truth — that the fresh industry competes with canned and frozen and needs to use its advertising to differentiate itself.
Now we would like to analyze thoroughly the justifications for why the fresh industry should give up the opportunity to use its generic promotion budget to emphasize its own fine qualities and hope to gain share from both frozen and canned — but the proposal is silent. It provides no research results that indicate that the returns are higher if frozen and canned are included in the program. As with much else in the proposal we are left to hypothesize as we are given no data. There is, in fact, no real basis for making a decision right now on the scope of the program.
The only reason the plan was developed this way is because this is what PBH has done. But with its non-profit status and engagement in a public/private partnership, PBH is a very different entity than the proposed generic marketing program. The industry already has PBH. It is not at all obvious that we need another organization bound by the same strictures. Maybe we need to free up fresh to pursue its own interests.