Dear Administrator Carranza:
We write to respectfully express our concerns with the United States Small Business
Administration's (SBA) Interim Final Rule entitled Express Loan Programs; Affiliation Standards (Docket No. SBA-2020-02128 / RIN 3245-AG74), published in the Federal Register on February 10, 2020. Due to our concerns with the underlying policy changes, specifically those made to 13 C.F.R. §121.301(f), included in the rule and their potentially significant impact on poultry farmers in our states, we urge SBA to extend to October 1, 2020 the effective date of the above-referenced Interim Final Rule. We do not agree with the decision to make the effective date March 11, 2020, prior to the end of the comment period on April 10, 2020, and we believe that an extension is a more appropriate course of action that will allow SBA a meaningful opportunity to review and consider all comments.
Access to capital is one of the most significant barriers to entry for farming, which is why Congress specifically included agriculture in the SBA's mandate. Unfortunately, the Interim Final Rule, as currently written, could adversely affect many independent, small, family farmers that raise broiler chickens and turkeys across the country. Our constituent farmers deserve to have their voices heard prior to the implementation of a rule that will result in a significant impact on their livelihood. With the current state of the farm economy in mind, we urge SBA to take the necessary time to consider the potential significant impacts this rule would have on the sustainability of our family farm operations.
We appreciate your attention to this matter and look forward to your response.
Sincerely,