Advocating for the Future of Family Farms: A Plea for Critical Regulation Change

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Working on behalf of American Food & Agriculture businesses, K·Coe Isom submitted an open letter to USDA Secretary Sonny Perdue on October 28, 2020 regarding new regulations that threaten the well-being of thousands of American family farms.

The “Payment Limit and Payment Eligibility” regulation released on August 24, 2020 will fundamentally change the landscape on which American family farms businesses operate, and we have made the request to withdraw and re-issue regulation.  Simply put, these businesses cannot afford to expend limited capital to restructure their businesses and cannot afford to face reduced eligibility for disaster payments. This regulation needs to be withdrawn and reissued.

“We are especially concerned that this far-reaching regulation was released without an opportunity for public comment, depriving American farmers the opportunity to provide input on a proposal that significantly impacts them and our nation’s food supply system,” says Brian Kuehl, K·Coe Isom’s director of Government and Public Affairs.

“As a result of this new regulation, thousands of families across this country will now be forced to either restructure their businesses or qualify for lower levels of USDA disaster assistance,” he adds.

At a time when the current economic climate in rural America is already down, K·Coe Isom has made a plea for the Department to reconsider the regulation and either repeal it entirely, or issue a new final rule that reinstates the vital “commensurability” test for farm programs.


“K·Coe is urging farm businesses to voice concerns over this issue directly to the Office of the Secretary.  Through all our voices, we will be heard.”


Office of the Secretary:

Email (preferred):

Fax (preferred):      (202)720-2166

Office: (202)720-7100

Enclosed is the full letter, with details regarding its applicability, examples of its negative impacts, and consequences if it remains intact without further consideration and revisions in a new final rule.


Contact a K·Coe advisor with questions.

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