FCS Diversity and Inclusion - PROPOSED RULE - MARCH 2011 Dear Mr. Van Meter,
Thank you for this opportunity to provide comment on ways the FCS can better serve small and midsized, local and regional food producers. We support your efforts to diversify the FCS loan portfolio and would ask that in defining what needs to be included in FCS marketing plans that you include:
1. A requirement that each FCS institution create a baseline analysis of producers who meet the farm bill definition of local and regional food producers by number of borrowers, by loan volume, and other key characteristics.
2. An investment goal for local and regional food producers of not less than 10% of each institution’s capital within 5 years.
3. A plan for conducting outreach to local and regional food producers.
4. A requirement that such an outreach plan and periodic progress reports be made public.
5. A commitment to adding local and regional food producers to the FCS board.
6. A plan for providing staff development training to FCS personnel across the full spectrum of lending, accounting, farm transfer and business planning services appropriate for serving local and regional food producers.
7. A plan for developing lending and business support products with terms and benefits appropriate for local and regional food producers.
8. An inventory of strengths and weaknesses of financing for local and regional food infrastructure (aggregation, processing, distributing, etc.) and an FCA plan for how to use FCS local and regional food producer financing to leverage other public and private capital necessary to address the larger weaknesses in the rest of the local and regional food supply chain.
Thank you for your consideration of these concerns.