This link takes you to the complete United Fresh Produce Association comments - 14 pages worth - on the proposed rule regarding "Nutrition Standards in the National School Lunch and School Breakfast Programs"

United Fresh offer fourteen areas of support for the proposed rule and four points of difference. Three of the differences relate to potatoes/starchy vegetables.

From that section on the proposed rule's restrictions on potatoes:

United Fresh is concerned the Proposed Rule promotes incorrect and damaging implications about certain healthy vegetables.

It is important that USDA rely upon nutrition science in all of its recommendations, and not further misconceptions that may be held about healthy vegetables such as white potatoes. White potatoes provide key nutrients to children, and are an excellent source of potassium and a good source of dietary fiber. Both potassium and dietary fiber are currently under consumed by children. Additionally, potassium and dietary fiber are two of the four “nutrients of concern” in the 2010 Dietary Guidelines. Potatoes have three times the potassium and a similar amount of fiber as a serving of broccoli and 50 percent more vitamin C and more potassium than a serving of spinach. Potatoes are the top source of potassium and fiber for high school students and the top source of vitamin B6 for all ages. Few vegetables contain the levels of potassium that potatoes do. Therefore, limiting the amount of potatoes served in school meals can have a negative impact on the intake of two of the four nutrients of public health concern.

Children also like potatoes. Limiting potatoes may lead to a reduction in overall vegetable consumption among school lunch participants. Potatoes are very popular with students and limiting the number of days they can be served may lead to reductions in overall vegetable consumption. The focus should be on serving nutrient-dense forms of potatoes and other vegetables to increase children’s overall vegetable intake.

We are also very concerned that restricting potatoes incorrectly teaches children (and school officials) that potatoes are not part of a healthy diet. This is a fallacy, and one that USDA should work hard to avoid as a science-based organization. Once again, the focus should be on preparation and serving children nutrient-dense forms such as baked, roasted and boiled potatoes to expose them to a wider variety of ways to prepare and eat this popular vegetable. Potatoes are also economical for schools to serve and an affordable, nutrient-dense choice. One serving of a baked potato can be provided for about $.05. Given that the proposed rule will increase the overall cost of school lunch, and the Healthy, Hunger-Free Kids Act will provide only an increase of $.06 per school lunch, it would be a major mistake to limit an affordable, nutrient–dense food that provides important nutrients for healthy development of children.

Finally, it is clear that school food officials do not support limiting starchy vegetables, like potatoes, and believe that they can serve a wide variety of vegetables each week without such limits. Of all the provisions in the proposed rule, the restriction on only serving 1 cup of starchy vegetables a week has caused great concern and debate among school food officials. At the recent School Nutrition Association Town Hall Meeting on the proposed rule, many school food service officials stated that they believed the restriction will increase costs and plate waste, are not necessary to improve vegetable diversity, and will not have a positive effect on student health. Schools need the flexibility to prepare meals that meet the nutritional goals recommended in the proposed rule, are economically sustainable and will be consumed by school-aged children.

United Fresh agrees that children need to significantly increase vegetable consumption, and consume a wide variety of colorful vegetables each week, However, we do not believe restrictions and prescriptions are necessary to achieve these goals, and could in fact, be counter-productive.

TK: Whether or not these comments about potatoes from United Fresh and other similar arguments from NPC and PMA will prompt the agency change the particulars in the proposed rule is only speculation. The agency may not want to deviate the IOM recommendations as a way to minimize political heat.

Finally, here is the conclusion offered by Lorelei DiSogra of United Fresh:

United Fresh commends USDA for proposing important changes to the nutrition standards for the National School Lunch and School Breakfast Programs that align with the 2010 Dietary Guidelines.

In the final rule, we urge USDA to provide greater flexibility to schools in meeting recommendations to increase the variety of fruits and vegetables offered. This specifically must avoid restrictions on healthy starchy vegetables, including white potatoes, and rather focus schools on method of preparation and serving nutrient-dense forms of these vegetables.

Finally, we urge USDA to implement the new meal standards by the 2012-13 school year. Because increased meal cost is a critical issue impacting implementation, we also urge USDA to quickly provide rules that qualify schools and deliver increased reimbursement upon compliance with the new meal p
atterns, as well as consider other policy levers that can shift more resources to the food component of the meal.