This paper draws on a content analysis of the Minnesota Food Access Planning Guide (FAPG) to consider how its text includes terms derived from food justice and equity. We carry out a word frequency analysis of the FAPG's issue areas focused on policy recommendations and strategies. Through a process of deductive coding applied with the NVIVO software, we assess how ninety-eight policy recommendations and strategies in the FAPG include or exclude food justice and equity terms. We find that the FAPG minimally addresses food justice and that 'health' emerges as an alternative category for equity within the text. While the FAPG is defned by normative assumptions of the urban planning practice, its content analysis demonstrates the importance of applying tools to address the validity of its discursive claims. Our analysis aims to engender a policy debate about food justice and the built environment in Minnesota.