Response to Wellesley Institute’s Time to Regulate Food Prices Like a Utility Report, May 2024

Dr. Kwame McKenzie Chief Executive Officer Wellesley Institute

Via email: kwame@wellesleyinstitute.com

May 13, 2024

Dear Dr. McKenzie,

Ontario Dietitians in Public Health (ODPH), the official voice of Registered Dietitians working in the Ontario public health system, is writing to offer feedback on the Wellesley Institute’s policy brief, Time to regulate food prices like a utility. ODPH provides leadership and expertise in public health nutrition practice, including food insecurity, family and child health, school health, and food systems.

ODPH firmly agrees that access to affordable, nutritious food is a health equity issue that requires urgent action, and that policymakers must ensure nutritious food is affordable for all Canadians. However, we disagree that regulation of the cost of foods included in the National Nutritious Food Basket (NNFB) will lead to food affordability for all Canadians who experience food insecurity. This approach is not supported by existing evidence. Moreover, it diverts attention from policy interventions that ensure wages and income supports are sufficient to meet basic needs of Canadians.

As presented in our Position Statement and Recommendations on Responses to Food Insecurity, policy interventions that improve the financial circumstances of vulnerable households are fundamental to effectively address food insecurity. Although the name of the problem implies it, food insecurity is not strictly indicative of food deprivation but rather a symptom of overall financial hardship and pervasive material deprivation.

Households struggling to afford food also struggle to afford other costs of living such as housing, personal care, clothing and transportation.

The policy brief aptly asserts that food and nutrition can be considered optional while other necessities are not − this is precisely why addressing income inadequacy is essential to reducing food insecurity. In other words, the way to address food insecurity is to ensure adequate income for inelastic costs of living. The elasticity of food expenditures means that financial hardships can be detected more sensitively through measurement of food insecurity – if a household is compromising its food spending, they are struggling financially in many ways.

The fact that Statistics Canada has reported 78% of families experiencing food insecurity had incomes above the poverty line does not mean food insecurity is breaking away from poverty, but rather it underscores a problem with relying solely on Canada’s official poverty line, the Market Basket Measure (MBM), to understand Canadians’ financial hardships and inform social policy. As an experience-based measure of material deprivation, household food insecurity captures financial hardship in a way that income-based measures of poverty do not, accounting for the security, stability, and sufficiency of income.

Since 2008, Ontario public health units (PHUs) have been mandated by the Ministry of Health to monitor food affordability. This is achieved by comparing sample single- person and family household income estimates to local rental housing rates combined with the local cost of the Nutritious Food Basket. Food affordability reports by Ontario PHUs (see examples from Huron-Perth, Thunder Bay, Ottawa) and similar reports from other jurisdictions such as British Columbia consistently and repeatedly illustrate that households with low incomes (e.g., minimum wage employment and social assistance) cannot afford the basic costs of living.

The situation is most severe for social assistance recipients where monthly benefits are woefully inadequate. The inadequacy of Ontario Works rates is particularly glaring for single people as demonstrated by the following 2023 food affordability data from selected PHUs.