One Size Does Not Fit All: Understanding the Importance of Rightsizing Regulations for Small Businesses (Senate Small Business Committee hearing, August 23, 2023)
Summary
Transcript of the August 23, 2023 field hearing of the Senate Committee on Small Business and Entrepreneurship, One Size Does Not Fit All: Understanding the Importance of Rightsizing Regulations for Small Businesses, S. Hrg. 118–116. Ranking Member Joni Ernst gave the opening statement. Witnesses were Major L. Clark, III, Acting Chief Counsel of the Office of Advocacy of the U.S. Small Business Administration, Rep. Shannon Latham of the Iowa House of Representatives, and Megan Green of Weiler Products. Statements submitted include ones from the Competitive Enterprise Institute, Daniel Goldbeck, the Job Creators Network and the National Automobile Dealers Association.
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“One Size Does Not Fit All: Understanding the Importance of Rightsizing Regulations for Small Businesses (Senate Small Business Committee hearing, August 23, 2023).”
Original at www.govinfo.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/one-size-does-not-fit-all-understanding-the-importance-of-rightsizing-b24f276d72/
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S. HRG. 118–116
ONE SIZE DOES NOT FIT ALL:
UNDERSTANDING THE IMPORTANCE OF
RIGHTSIZING REGULATIONS
FOR SMALL BUSINESSES
FIELD HEARING
BEFORE THE
COMMITTEE ON SMALL BUSINESS
AND ENTREPRENEURSHIP
OF THE
UNITED STATES SENATE
ONE HUNDRED EIGHTEENTH CONGRESS
FIRST SESSION
AUGUST 23, 2023
Printed for the use of the Committee on Small Business and Entrepreneurship
(
Available via the World Wide Web: http://www.govinfo.gov
U.S. GOVERNMENT PUBLISHING OFFICE
53–543 WASHINGTON : 2024
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COMMITTEE ON SMALL BUSINESS AND ENTREPRENEURSHIP
ONE HUNDRED EIGHTEENTH CONGRESS
BENJAMIN L. CARDIN, Maryland, Chairman
JONI ERNST, IOWA, Ranking Member
MARIA CANTWELL, Washington MARCO RUBIO, Florida
JEANNE SHAHEEN, New Hampshire JAMES E. RISCH, Idaho
EDWARD J. MARKEY, Massachusetts RAND PAUL, Kentucky
CORY A. BOOKER, New Jersey TIM SCOTT, South Carolina
CHRISTOPHER A. COONS, Delaware TODD YOUNG, Indiana
MAZIE K. HIRONO, Hawaii JOHN KENNEDY, Louisiana
TAMMY DUCKWORTH, Illinois JOSH HAWLEY, Missouri
JACKY ROSEN, Nevada TED BUDD, North Carolina
JOHN W. HICKENLOOPER, Colorado
SEAN MOORE, Democratic Staff Director
MEREDITH WEST, Republican Staff Director
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CONTENTS
AUGUST 23, 2023
OPENING STATEMENTS
Page
Joni Ernst, Ranking Member, U.S. Senator from Iowa ........................................ 1
WITNESSES
Mr. Major L. Clark, III, Acting Chief Counsel, Office of Advocacy, U.S. Small
Business Administration, Washington, DC ....................................................... 4
Prepared Statement ......................................................................................... 6
Rep. Shannon Latham (R–55th) Iowa House of Representatives, Des Moines,
IA ........................................................................................................................... 33
Prepared Statement ......................................................................................... 35
Mrs. Megan Green, Counsel and Engineering Manager, Weiler Products,
Knoxville, IA ......................................................................................................... 41
Prepared Statement ......................................................................................... 43
ADDITIONAL LETTERS/STATEMENTS FOR THE RECORD
Competitive Enterprise Institute
Statement dated August 23, 2023 ................................................................... 52
Goldbeck, Daniel
Comments submitted August 23, 2023 ........................................................... 58
Job Creators Network (JCN)
Statement dated August 23, 2023 ................................................................... 61
National Automobile Dealers Association (NADA)
Statement dated August 1, 2023 ..................................................................... 64
National Federation of Independent Business (NFIB)
Letter dated August 23, 2023 .......................................................................... 65
SBA Office of Advocacy Chief Counsel Report on the Regulatory Flexibility
Act, FY 2022
Report dated April 2023 ................................................................................... 70
Small Business and Entrepreneurship Council
Letter dated August 31, 2023 .......................................................................... 157
U.S. Chamber of Commerce
Letter dated August 23, 2023 .......................................................................... 159
Wall Street Journal Editorial Board ‘‘Regulators Gone Wild’’
Article dated August 14, 2023 ......................................................................... 163
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ONE SIZE DOES NOT FIT ALL:
UNDERSTANDING THE IMPORTANCE OF
RIGHTSIZING REGULATIONS
FOR SMALL BUSINESSES
WEDNESDAY, AUGUST 23, 2023
UNITED STATES SENATE,
COMMITTEE ON SMALL BUSINESS
AND ENTREPRENEURSHIP,
Des Moines, IA.
The committee met, pursuant to notice, at 1:00 p.m. CDT, at
Iowa Economic Development Authority, 1963 Bell Avenue, Des
Moines, Iowa, Hon. Joni Ernst presiding.
Present: Senator Ernst [presiding].
OPENING STATEMENT OF SENATOR ERNST
Senator ERNST. Well, welcome everybody. We are going to go
ahead and get started, so those that need chairs, if you can find
one.
The hearing is called to order. Good afternoon and thank you all
for joining us today in beautiful Iowa. I know that some of you
have traveled from out of state to be here today.
As the Ranking Member of the Senate Small Business and En-
trepreneurship Committee I want to specifically thank our wit-
nesses for joining us as well as Sean Moore, the Committee’s
Democratic staff director, representing Chairman Ben Cardin. The
issues facing small businesses continue to be the rare area of bipar-
tisanship in Washington, and I appreciate the hard work Chairman
Cardin, Sean, and their staff put in.
Today’s hearing is focused on rightsizing regulations for small
businesses because one size does not fit all. Our goal is to examine
the challenges small businesses face when they are forced to com-
ply with the same regulatory requirements as much larger competi-
tors. We will also discuss the benefits to small businesses when
agencies adjust their regulatory demands accordingly.
Small businesses today are drowning in red tape and unneces-
sary regulatory costs. In less than 3 years, the Biden administra-
tion has imposed almost $400 billion in regulatory costs on Amer-
ican businesses. By comparison, the previous two administrations
combined, over the same time period, imposed $258 billion in regu-
latory costs, including during the implementation of Obamacare,
with its hundreds of accompanying rules. In other words, the Biden
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administration has already imposed almost $140 billion more in
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2
regulatory costs than the previous two administrations did, com-
bined. By one estimate, Biden’s out-of-control regulatory agenda
has imposed over $5,000 per household in costs, and I would like
to submit for the record a Wall Street Journal editorial entitled
‘‘Regulators Gone Wild,’’ showing the full scale of the overreach.
Senator ERNST. How can any small business keep up, and folks,
sadly they cannot. And while those numbers are truly staggering,
they do not even begin to tell a whole story of just how complex
the Federal regulatory climate is for small businesses in Iowa and
across the country.
While regulatory costs hit all businesses, they are particularly
damaging to small businesses, which is why, since 1980, the Regu-
latory Flexibility Act has required agencies to rightsize regulations
by providing less-costly alternatives.
When writing a new rule, the only way agencies can evade the
rightsize requirement is by checking a box to certify that the regu-
lation will not significantly impact small businesses. And folks, we
know that any time Washington is creating a new regulation,
chances are our small businesses will be severely impacted.
Unfortunately, this has become a loophole for agencies to not put
in the work to rightsize the regulation and provide flexibility to
small businesses. The SBA’s Office of Advocacy is an independent
entity in the Federal Government that is charged with policing the
Reg Flex Act, and we appreciate that the leader of this critical of-
fice, Mr. Major Clark, is with us today.
When regulators significantly underestimate the real costs of reg-
ulations it results in very real consequences for small businesses.
To illustrate let’s look at just two regulations with broad impacts
on Iowa small businesses that Advocacy found were improperly cer-
tified.
First, the Federal Trade Commission recently underestimated
the costs a regulation would place on auto dealer small businesses
by almost $70 billion. Iowa franchised auto dealerships employ over
15,000 Iowans, and most are small businesses. I would like to sub-
mit for the record a one-pager from the Iowa and National Auto-
mobile Dealers Associations illustrating the problem.
Second, the Environmental Protection Agency improperly
claimed a rule defining Waters of the United States would not sig-
nificantly impact small businesses despite the fact that it would
likely affect every farmer and small businesses that wished to build
a new barn or expand their business.
In Iowa, 98 percent of agriculture businesses, 99 percent of con-
struction businesses, and 89 percent of manufacturers are small
businesses, and collectively employ over 46,000 Iowans. That is
why I supported a resolution to repeal the WOTUS rule that
passed the Senate, but unfortunately it was vetoed by the Presi-
dent.
So what happens when small businesses or the SBA make it
known to these regulators that their costs are underestimated and
they should find alternatives to protect small businesses? Unfortu-
nately, right now agencies can simply ignore them. This is why I
introduced the PROVE IT Act of 2023, to prevent agencies from
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simply checking the box and empowering the SBA Office of Advo-
cacy to require these agencies to show their work.
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My PROVE IT Act would require Federal agencies to prove they
are not avoiding the Reg Flex Act and demonstrate that any new
regulation is actually compliant with existing laws. It would also,
for the first time, consider both the direct and indirect costs placed
on small businesses, which would directly push back on the Biden
administration’s efforts to use far-reaching global benefits to justify
imposing any costs. Finally, my bill would give Advocacy the tools
they need to require, rather than ask, agencies to consider less-
costly alternatives for small businesses.
I am proud to see that over 10,000 small businesses around the
country and 75 small businesses in Iowa have sent letters to Con-
gress showing support for my legislation.
As you can clearly see, it matters when agencies simply check
the box and avoid rightsizing regulations. One-size-fits-all regula-
tions do not suit Iowa’s entrepreneurs, and that is why I am fight-
ing to ensure our small businesses are heard and considered in fu-
ture regulatory mandates from Washington. I look forward to hear-
ing from our witnesses on this issue and how to address it.
Now we will introduce our witnesses, and again thank you to our
witnesses for being here today. First we have Major L. Clark III.
He is the Deputy Chief Counsel, Small Business Administration
Office of Advocacy. He currently serves as the Deputy Chief Coun-
sel for SBA’s Office of Advocacy. The SBA Office of Advocacy is the
independent voice for small businesses within the Federal Govern-
ment to advance the views and interests of small firms with Fed-
eral agencies. In fiscal year 2021 and 2022 alone, Mr. Clark and
his staff engaged with Federal agencies on almost 40 regulations
that led to almost $3.4 billion in estimated regulatory cost savings.
Prior to joining the Small Business Administration, Mr. Clark
was the Senior Corporate Officer for the Maxima Corporation and
served as the Chief Administrative Officer for the House Small
Business Committee. Thank you again for joining us today, Mr.
Clark.
Next we have Representative Shannon Latham. Shannon is the
Representative for Iowa’s 55th Legislative District in the Iowa
House of Representatives, serving since 2021, and it covers parts
of Wright, Franklin, and Hamilton Counties. During her time in
the Iowa House, Representative Latham has been a strong advo-
cate for Iowa small businesses and has been a staunch ally in Gov-
ernor Reynolds’ efforts to modernize the regulatory system and
make Iowa the best place in the country to do business.
In addition to serving in the Iowa House, Representative Latham
also co-owns Latham Hi-Tech Seeds, a family-owned seed company
headquartered in Alexander, Iowa. A fellow graduate of my alma
mater, Representative Latham received her BS in Ag Journalism
and Public Service and Administration in Agriculture from Iowa
State University, and her MBA from the University of Iowa.
And finally we have Mrs. Megan Green. She currently serves as
the Counsel and Engineering Manager for Knoxville-based Weiler
Products, which designs, engineers, and manufactures equipment
for the paving market. Mrs. Green is a member of the senior lead-
ership team and serves as the President of the Weiler Foundation
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for Charitable Giving. She was also recently appointed as a mem-
ber of the People’s Bank Board of Director.
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Prior to joining her current employment, Mrs. Green served as
an in-house counsel for the State Farm in Bloomington, Illinois,
counseling clients in multiple states on regulatory, legislative, and
public policy issues. Mrs. Green also attended my alma mater, re-
ceiving her bachelor’s degree in finance from Iowa State University
and her JD from the University of Iowa.
And I will also mention, while it was not in his biography, Major
Clark also attended the University of Iowa. So we all have those
Iowa connections.
I do want to thank our witnesses very much for being here today.
We will go ahead and proceed with the testimony, and Mr. Clark,
we will start with you please, sir.
STATEMENT OF MAJOR L. CLARK III, ACTING CHIEF COUNSEL,
OFFICE OF ADVOCACY, U.S. SMALL BUSINESS ADMINISTRA-
TION, WASHINGTON, D.C.
Mr. CLARK. Good afternoon, Ranking Member Ernst and distin-
guished guests. I am honored to be able to return to Iowa. It has
been a while since I have been here, but fond memories during my
period here. Iowa taught me how to be a good lawyer, not one of
the bad lawyers, so I am very honored with that.
Congress recognized the importance of small business to our na-
tion’s economy. As such, Advocacy was created in 1976, to be an
independent voice for small businesses within the Federal Govern-
ment, particularly during the Federal regulatory process. But that
is not all that we do. Our legal team works to ensure regulations
do not unduly burden small businesses, our regional advocates and
our information team provide outreach to small business stake-
holders across the country, and our economic research team con-
ducts important research on small business and their roles, some
of that which you have just heard from the Ranking Member.
Advocacy’s research demonstrates that small businesses continue
to be a critical part not only of the nation’s economy but also local
economies, as here in Des Moines and in the total state of Iowa.
We released a new small business profile series, which is available
on the table behind you. It is the 2022 Small Business Profile,
which focuses specifically on this great state of Iowa.
This research confirms that small businesses are a vital compo-
nent of Des Moines’ and Iowa’s economy. Small businesses account
for 47 percent of Iowa’s employment, which exceed the national
share. Here in Des Moines metropolitan area, 98 percent of all
businesses are small and account for about 41 percent of employ-
ment.
Our research also shows that small businesses play an important
role in rural areas. For example, small businesses provide 54 per-
cent of rural jobs in the United States. Advocacy’s economic re-
search also inform agencies on the small business economic im-
pacts of their regulations, which is critical. It is also our hope that
this now helps stakeholders, many of you who are here today, un-
derstand the critical role that you play as small business owners
in the local economy.
After hearing from small businesses like those here in the state
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of Iowa, Congress passed what is called the Regulatory Flexibility
Act to ensure Federal regulations are not, as the Chairman said,
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one size fits all. Rather, Federal agencies must consider the im-
pacts of their regulations on small business, analyze effective alter-
natives that minimize small entity impacts, and make their anal-
ysis available for you, the public.
As the watchdog for small businesses, Congress charged Advo-
cacy with ensuring agency compliance with the RFA. Advocacy is
required to report to Congress every year on agency compliance
with the RFA, and our report for fiscal year 2022 was submitted
to the Committees, House and Senate, in May of this year. Advo-
cacy continues to remain active during fiscal year 2022. On behalf
of our nation’s small businesses, we submitted a record 37 com-
ment letters to Federal agencies and hosted a record 30
roundtables on regulatory concerns facing small businesses.
We also achieved numerous victories for small businesses by
working with agencies on RFA compliance, including what was
mentioned earlier, the $73.5 million in cost savings for our small
businesses across the country. And these numbers were due, in
large part, I think, to new methods that we implemented to reach
more stakeholders, to reach outside of the Washington, D.C., area,
including holding virtual meetings, roundtables, and events as we
are having today, and also our site visits.
In this current fiscal year, Advocacy has continued to be produc-
tive, and since October 1, of 2022, we have already submitted over
40 letters and held 23 roundtables this year.
Advocacy has increasingly argued that Federal agencies need to
conduct more outreach to small entities during the rulemaking
process and improve the quality of their small business data. Advo-
cacy relies on stakeholders, primarily you, to provide input in the
regulatory process by writing comment letters, directing to Federal
agencies, and by sending us their concerns. It is critical for all
small businesses, including those here, to express concerns to Fed-
eral agencies on regulations that may impact their economic sur-
vival. Our success, in Advocacy, depends on you, our stakeholders.
Madam Chair, this concludes my oral testimony, and I request
that Advocacy’s RFA report for fiscal year 2022 be included in the
hearing record.
Thank you for this opportunity to testify today, and you know
that I am happy to answer any questions that you may have, so
thank you.
[The prepared statement of Mr. Clark follows:]
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Senator ERNST. Thank you very much, Mr. Clark, and we will
submit that, without objection, so thank you.
[The information follows:]
Senator ERNST. Representative Latham, thank you.
STATEMENT OF REP. SHANNON LATHAM, IOWA HOUSE OF
REPRESENTATIVES, DES MOINES, IA
Ms. LATHAM. Thank you. Good afternoon, Ranking Member
Ernst, members of the Committee, and distinguished guests. It is
a real honor to be here as a representative of Latham Hi-Tech
Seeds to provide insights about difficulties faced by small busi-
nesses when complying with regulatory requirements.
Latham Hi-Tech Seeds is a third-generation, family-owned seed
company that is headquartered on our family’s Century Farm in
north central Iowa. Latham brand hybrid seed corn, soybeans, and
alfalfa products are sold across the Upper Midwest, primarily
through a farmer-dealer network.
We are proud to have celebrated our company’s 75th anniversary
in 2022, but our success did not come without overcoming obsta-
cles, and some of the obstacles we face today include gene editing,
antitrust enforcement, and trucking.
So I will begin with gene editing. Sustainable agriculture and
food production require a range of innovative solutions, including
the latest precision plant breeding tools, like gene editing. These
tools allow plant breeders to develop better crops, in less time, with
more accuracy than other methods. And because our seed company
has a corn breeding program, we are greatly concerned with EPA’s
recent final rule on plant incorporated protectants. The EPA’s pre-
cautionary and process-based policy imposes non-risk-based regu-
latory hurdles for certain plant characteristics created using the
latest precision breeding tools.
And antitrust enforcement. Consolidation in agriculture, live-
stock, fertilizer, chemicals, and seed is reducing competition, and
we know that reduced competition leads to increased costs. The
United States Department of Agriculture, in March 2023, issued a
competition report that issued recommendations of being a voice for
farmers and plant breeders as well as interagency coordination to
promote fair competition.
And trucking, I could have gone on a while for trucking. The U.S.
Department of Transportation’s Federal Motor Carrier Safety Ad-
ministration Entry Level Driver Training final rule went into effect
in February of 2022. The additional coursework costs between
$1,000 and $4,000, depending on the course and the provider. This
is a really large investment for small businesses. Whenever you
add time and money it discourages people from actually getting
their CDL.
In addition to decreasing regulatory costs, one policy change that
can help address trucking shortages is lifting interstate weight lim-
its and making them uniform nationwide. Increasing interstate
weight limits would create added efficiencies to transporting goods.
During the 2023 session, the Iowa legislation passed a resolution
encouraging Congress to increase weight limits on interstate high-
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ways in Iowa. Iowa allows higher weight limits on our state high-
ways during the business times for agriculture. And because driv-
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34
ers can operate heavier loads on road that are under state jurisdic-
tion they often avoid interstates. If the interstate system allowed
heavier loads, truck drivers could take the most direct route, they
would save driving time, and reduce fuel usage.
And finally, electronic logging devices, or ELDs, are time-con-
suming and expensive for small businesses. It is especially chal-
lenging for businesses like ours that serve rural America. Elec-
tronics are prone to error, plus there are just a lot of areas in our
trade territory where we lose phone service and we cannot get sat-
ellite signals.
Another downfall is that these logs start clocking your time as
soon as the truck moves. So it is problematic for a company like
ours, like when we are trying to just load seed from a dock, because
it will begin to clock the time. And then we have had instances
where the driver forgot to log out, and then it made it look like the
truck was parked and he was there. Yeah, you can overcome those,
but it takes time and energy, and it just detracts from your day-
to-day business.
One solution for the overburdensome ELD regulations is to ex-
empt companies with five trucks or fewer. Another solution is to
just simply exempt anyone who carries 100 percent of their own
products. This solution offered for ELDs is an example of how one-
size regulations do not fit all businesses. Small businesses fre-
quently encounter challenges stemming from regulations that were
designed for larger enterprises. Examples include burdensome pa-
perwork, expensive compliance measures, and intricate reporting
requirements.
These issues all impede growth, discourage innovation, and often
lead to disproportionate costs that hinder small business success.
I encourage this Committee to consider the recommendations pre-
sented here.
The written document I submitted also includes comments that
I gathered from other small business owners throughout my dis-
trict and across the state. As a member of the Iowa House of Rep-
resentatives, I visit regularly with business owners, and it is my
honor to represent them.
Thank you for your attention. Together I know that we can help
Federal regulations become a catalyst rather than a hindrance for
small business success. And you know I would be happy to answer
questions.
[The prepared statement of Ms. Latham follows:]
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Senator ERNST. Wonderful, and thank you Representative
Latham.
And Mrs. Green.
STATEMENT OF MEGAN GREEN, COUNSEL AND ENGINEERING
MANAGER, WEILER PRODUCTS, KNOXVILLE, IA
Ms. GREEN. Thank you. Good afternoon and thank you to Rank-
ing Member Ernst for inviting me to testify today. My name is
Megan Weiler Green and I am Counsel and Engineering Manager
for Weiler Products in Knoxville. We are a heavy equipment manu-
facturer. We do everything from design to taking raw steel all the
way to a finished product. We make heavy equipment, primarily for
the asphalt paving industry.
I am also a second-generation business owner. Our business was
started in 2000, with 4 employees and we have 615—or 618 or 620,
depending on the day—employees now. What started as a small
business in a 40,000-square-foot spec building is now 625,000
square feet under roof. Our equipment is sold into all 50 states and
15 countries.
We are the market leader because we listen to our customers. We
are proactive. We move quickly. We are innovative and find innova-
tive solutions. And we are hands on. These core values describe
many small businesses and many Iowa success stories. But they
are often at odds with government regulators and government reg-
ulations. Entire industries are born out of interpreting government
regulations for small businesses.
We know from our experience that every minute one of our em-
ployees spends trying to decipher new regulations, creating reports
to respond to regulations, purchasing new systems that add no
value to our organization other than compliance with a new regula-
tion is a minute taken away from what we do best: serve our cus-
tomers and design industry-leading equipment.
As we react to new regulations, small businesses are often left
wondering ‘‘who is this benefitting?’’ The purpose of regulations is
often nonobvious from the perspective of those who are asked to
comply. We have also seen several instances of regulations being
announced alongside the deadline for compliance. While we, as a
business, work diligently to decipher unreadable regulatory jargon,
announcements from the government are released days before that
compliance deadline hits, saying we are going to move that date
back. There is no recognition of the wasted time and duplicative ef-
fort that that puts on our business.
Similarly, our team works together to gather complicated reports
and data to respond to various mandatory surveys and government
requests for information. While the demand for this information is
firm, there is no discernible benefit to us, as a company, or expla-
nation as to how the collection of this information is moving the
greater good forward.
In business, we operate in cost/benefit analyses. In order to come
out with an accurate assessment, we need information that we can
rely on. When new regulations are announced, we are often in a
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position to ask ourselves: Does this apply to our business? What
does this mean for our business? Can I find anyone in this govern-
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42
ment agency who can answer my questions? And maybe most im-
portantly, what happens if I do this wrong?
When the rules are unknown, or the rules change in the middle
of the game, we cannot trust that we are making decisions in the
best interest of our customers and our employees.
Entrepreneurs and small business owners created their compa-
nies out of a passion for a product, a passion for serving customers,
or a passion for improving the status quo. No one starts their own
business out of a passion for the paperwork. Dedicating resources
to regulatory compliance makes it more difficult for small busi-
nesses to compete with large companies, who can depend on big
staff and healthy budgets dedicated to outside experts who can as-
sist with information gathering, compliance, and audits.
The bottom line is this: small businesses want to do the right
thing. The Senate Committee on Small Business and Entrepre-
neurship can assist by helping small businesses in the following
ways. Help small businesses understand regulatory requirements
and the why behind new regulations. Leverage data that is already
required, rather than creating new reporting requirements. Be
flexible on what the output looks like for small businesses. Provide
resources and access to people who can help navigate changing
rules.
We appreciate the attention that Senator Ernst and her office is
bringing to this issue, and I welcome any questions that you have
and appreciate your time.
[The prepared statement of Ms. Green follows:]
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Senator ERNST. Thank you. Thank you, Megan, and a big thank-
you to all of you for being here today and serving as our witnesses.
It has been very informative testimony, and we appreciate your
unique perspectives on today’s hearing.
Mr. Clark, we will start with you, sir, and thank to you and your
staff for the great work that you do on behalf of our small busi-
nesses in Iowa and across the country. I also want to thank
Darcella Craven, who is the regional advocate serving Iowa and the
Midwest. Thank you for being here and for being a resource for
Iowans.
Mr. Clark, Federal agencies often improperly certify that a regu-
lation will not significantly impact small businesses to avoid the
Regulatory Flexibility Act, such as the EPA’s WOTUS rule. Can
you share why this happens and the significance of this issue for
our small businesses?
Mr. CLARK. Thank you for your question, and yes, I can give you
our insight as to why it may happen—well, not may happen. It
does happen in some of the situations.
One of the things—and I enjoyed the testimony from the other
two distinguished guests because everything that was said kind of
fit into what we look and see and do. But one of the things that
is missing in this equation, extensively, is adequate data on small
businesses. One of the things that we attempt to do when we
worked with agencies is to get agencies to understand, as this hear-
ing is talking about, one size does not fit all. So we want agencies
to be able to break down their small business data to better re-
spond to the types of small businesses that are being impacted, the
small business that is 1 to 5 member employees, or 10 member em-
ployees, or 20 members employees, because that analysis has a dif-
ferent impact on each one of those groups. So that is one of the
issues that goes on with this certification.
The other issue is with training. Executive order—I cannot re-
member the executive order. Gray hair makes me forget executive
orders. But there was an executive order that requires us to train
agencies on the compliance with the Regulatory Flexibility Act.
And we, in our RFA report, talk about the amount of training that
we have done. That training has been very instrumental, I think,
in getting some of these agents to better understand the signifi-
cance of why it is important to analyze small businesses. So we
have to do more training.
And I think the other part of it is really the overall just edu-
cation that goes on with this whole process. And that is, some of
the agencies simply think that they are not going to be called to
task in some of these situations. And what our office is designed
to do, by statute, is to bring this to their attention when they fail
to comply with these requirements.
Senator ERNST. And Mr. Clark, so when an agency then improp-
erly certifies a rule under the RFA, and you do bring it to their at-
tention, you are notifying them in a timely manner, what then hap-
pens if that agency just simply chooses to ignore you?
Mr. CLARK. Well, several things happen in that situation. First,
some of the agencies attempt to provide this certification when the
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rule is in its proposed stage. And when it is in that particular stage
one of the things that we bring out to them is that depending on
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45
what that rules is really saying and depending on how they have
provided the information we will bring out to them that they did
not provide an adequate, factual basis for this particular rule.
And in that regard, we will basically provide them with an alter-
native, and the alternative is to either provide a better factual
basis to comply with the certification requirement or to conduct
what is called an IRFA, an Initial Regulatory Flexibility Analysis,
which goes into a little more detail in terms of the impact of that
rule on small businesses. That IRFA looks at alternatives that the
agency could come up with, and so forth.
So in that regard, as a proposal, we are watching that process.
If that rule actually goes final one of the things that his required,
again, by another executive order, is that agency has to, in its final
regulation, specifically mention what Advocacy has shared with
them, told them about that process. And that then becomes—the
next level for that clearly is the basis for litigation once that rule
goes final.
Senator ERNST. Okay. So just bottom line up front then, an agen-
cy, they do not have to change the rule, even if presented alter-
natives by Advocacy. Would that be correct?
Mr. CLARK. They do not have to change the rule but they have
to provide a factual basis for that rule, such as we were talking
about with the trucking here. They are going to have to show how
that particular rule, what is the factual basis for that rule, how
that rule impacts small businesses so that in that proposal stage
that information can then be shared with the public for comment.
Because if that certification does not have that factual basis then
we are not able to get testimony from a Latham Seed or anyone
else in terms of the impact that regulation is having.
So the critical piece of that is the factual basis and then being
able to get public input as to the impact.
Senator ERNST. Right. And so you stated then that the organiza-
tions do have that right to judicial review of those improper certifi-
cations. You cannot bring the lawsuit until after the rule is final-
ized. And can you talk about why that is an issue and whether re-
view of the certification prior to the finalization could give small
entities some real relief?
Mr. CLARK. Well, the review prior to the certification would actu-
ally give small entities—we say small entities but we are really
saying small businesses—would really give small businesses the
opportunity to better dissect that rule in terms of impact. And it
would also give small businesses a better opportunity to propose al-
ternatives to what is being proposed.
I mean, for example, we just heard from dealing with trucking.
Would exempting small businesses from one to five employees be
better than just a blanket covering of that situation? So that is why
it becomes important to have that factual basis, and that is why
it becomes important for stakeholders, here today and across the
state of Iowa, to be able to provide us with comments so that we
can better challenge the agency in terms of what they are pro-
posing.
Senator ERNST. Very good. Thank you, sir.
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Representative Latham, thank you for joining us as well and the
great work that you do serving the 55th District of Iowa. And I
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would like to start by asking you about the state-led efforts here
in Iowa to reduce the regulatory burden on small businesses.
So can you share what you think are the greatest success stories
and whether there are any lessons that I could take from your ex-
amples back to Washington?
Ms. LATHAM. Sure. I would be glad to share what I think are a
couple of our successes at the state level. Three examples of re-
cently passed legislation come to mind. One is updating the Iowa
code on youth employment, another one is realigning state govern-
ment, and then prohibiting local regulations on home-based busi-
nesses.
So when we were working on updating youth employment it was
not without controversy. But what we did is we just stuck to the
facts. We also made sure we listened to Iowans and small busi-
nesses who are living this day-to-day, and that is really what guid-
ed our decision-making. We believe that youth employment can
help. It is not going to totally solve the workforce crisis, but it is
certainly going to help, especially in businesses that need help at
night, on the evenings, weekends, and during the summer.
One of the things that was outdated—and I am smiling as I even
think about this—is why should teenagers in the workplace not be
able to use a microwave? I mean, that was one of the questions we
asked because they were prohibited from doing that. As someone
who grew up in a family restaurant and bar, there were times
when there were two of us working, and we were swamped, but I
could not help in ways like grabbing the alcoholic beverage off the
bar and taking it to a table I was already serving. She would have
to walk all the way around. That is a change that has been made.
If an adult is present, the parents approve it, you are in full sight,
why not let that 17-year-old just simply deliver the alcoholic bev-
erage.
The third one is why should teenagers not be able to work past
7 p.m.? That is the heart of the dinner rush hour. They were pro-
hibited from working past 7:00. As a mom of an athlete who played
four sports, I mean, I would have loved him to be home at 7 p.m.,
but there were times when games started after that and buses did
not get home until late. So why are we penalizing teenagers who
want to work?
So we removed those barriers while still keeping the require-
ments for safety and training and supervision in place. So that is
one.
Another one that I think is worth exploring is passing prohibi-
tions on local regulations. We did that for home-based businesses.
It pertained to requiring applications, permits, fees, zoning. Basi-
cally what it would do is allow startups to grow up a little bit be-
fore they had to comply with all of the regulations of a storefront
business.
The other thing that the realignment did that we passed this ses-
sion was really to simplify the regulatory process so now it is al-
most one-stop location from the Iowa Department of Inspection and
Appeals for licensing, building permits, safety. I think the more we
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can simplify processes for small businesses, the better. I mean, I
agree with Mrs. Green when she said small businesses really want
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to comply, so let’s not make it overly cumbersome, so we can help
them do the right thing.
And then I think I would also be remiss if I did not mention
childcare. It is a huge workforce issue. We know that there are peo-
ple who cannot go to work because they cannot find quality
childcare. And the last 3 years I have served in the Iowa legisla-
ture we have sent 11 childcare-related bills that the governor has
signed. Many of these came from her task force. I think whenever
people hear ‘‘task force’’ they think, oh, that is just somebody
checking the box, but really, there were recommendations that
were implemented that are making a difference.
And again, I truly believe that is just key to economic growth,
is helping get those highly skilled, highly qualified people back in
the workforce. So those are just a few of the highlights.
Senator ERNST. Wonderful. No, that is fabulous, and I am very
excited that our Iowa House and Senate and the Governor’s Office
have been able to find a way forward on these issues. And thank
you for mentioning, as well, childcare. We did just, in the recent
package that we put through, the Senate Small Business Com-
mittee did include a provision within that package for childcare, ex-
panding opportunities for childcare, and thanking Senator Jacky
Rosen for working me on that issue, and Senator Ben Cardin for
including that in this recently passed package.
We have some work to do with the House, but still great effort
moving forward. It is key to getting people back into a place of em-
ployment if they know that they have safe and low-cost childcare
available to them. So thank you.
Mrs. Green, for you. Again, thank you for being with us and for
sharing your story as well because it is really an incredible Iowa
success story, so thank you. Iowa is very, very lucky to have Weiler
Products in our state.
In your testimony you discussed the difficulty of trying to grow
a small business, manufacturing business, in a field with many,
many large competitors. So why do you believe it is hard for a com-
pany like Weiler to face the same regulations and costs as larger
manufacturers?
Ms. GREEN. Well thank you for the question. I think it really
comes down to resources. It is hours in the day. Workforce con-
tinues to be an issue for us. And even if we were fully staffed, we
want our employees to focus on what moves our company forward,
which is taking care of our customers.
I think what we are seeing in many government regulations is
uncertainty and things being passed that may never be imple-
mented or things being implemented that may later change. And
uncertainty is really expensive for businesses, in general, and it is
increasingly expensive for small businesses. And if you think about
even in your personal life, uncertainty is expensive, it is a distrac-
tion, and it takes our focus away from where it needs to be, which
is customers and innovation on the business front.
Senator ERNST. That is very good. I was doing a county visit ear-
lier today in Taylor County, and that was brought up by a number
of the farmers, the contractors, the state workers. It was at a con-
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servation project that had been done in some farmland. And they
mentioned just the changes in rules and regulations from one ad-
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48
ministration to the next, and that uncertainty, how it affects the
decision-making process of those that are investing in their farm-
land, in their businesses. That is a very, very good point.
Representative Latham, going off of Mrs. Green’s comments, I
am going to ask you to take off your legislative cap and focus on
your business cap and ask the same question as well. Can you
please talk about why it is so important to ensure regulations are
rightsized so that your family-owned seed business is not burdened
by the same costs as much larger companies in the grain industry?
Ms. LATHAM. Sure. So family-owned businesses like ours are op-
erating on much smaller margins, so regulations that might just be
considered maybe inconvenient for a larger competitor could essen-
tially shut down our business. It could put smaller businesses just
simply out of business.
You know, larger companies have resources that we do not have.
You know, we do not have anybody on staff with a legal back-
ground. We rely a lot on trade associations to help keep us abreast
of regulations. There are companies who cannot even, because of
the economy they are in today, cannot even afford to pay for those
associations. So they are trying to navigate through these regula-
tions, and it really does have that ripple effect. You wind up with
lower competition, increased costs.
And it does have a ripple effect on the small communities too.
Like I am just thinking at Latham Seeds we invest not only in our
people but I mentioned we market through farmer-dealer networks,
and those people are invested in their communities. They are the
ones that are helping support the local league, the prom, the what-
ever. So as you get larger competitors who are not located in those
communities, you have got out-of-state or out-of-country, they just
do not have that same commitment to community. And then, ulti-
mately, that affects the whole culture in the state of Iowa. We are
a state of many small businesses, many small communities. That
is really the backbone and the heart of who we really are, as
Iowans.
Senator ERNST. I really appreciate that context as well because
we do have so many visitors that are here from out of state. The
makeup of Iowa is large, in part, small, rural, Ag-based commu-
nities where those small businesses really do reinvest back into
their communities. You mentioned prom and things of that nature.
But yes, that is how our communities survive is by assisting one
another. So whether it is here in Iowa, whether it is in Maryland,
wherever it might happen to be, all of these little, small commu-
nities made up of small businesses and people reinvesting in the
livelihoods of others. So thank you for that perspective.
Mr. Clark, we will turn back to you. The Biden administration
recently changed how agencies calculate the costs and benefits of
their regulations. According to the Wall Street Journal article I ref-
erenced in my opening statement, those changes have given agen-
cies the ability to justify regulatory costs on Iowans by claiming the
rules could provide global benefits.
What are your thoughts on this change, and do you believe agen-
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cies should be required to consider indirect costs if they are going
to consider indirect benefits?
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49
Mr. CLARK. Madam Chair, I am not sure what global really
means in terms of small business because as you just said, small
businesses are really very localized. One of the things that we—as
I said earlier in my testimony, one of the things that we strive to
do is to provide and to solicit and to gain data on the various im-
pacts on small business. So changing the cost-benefit analysis, I am
not sure really deals with the essence of what happens with a regu-
lation in terms of its impact on small business.
We just heard from Representative Latham and Mrs. Green that
it is the margins. So when you start looking at cost-benefit anal-
ysis, and you are not able to break that analysis down into the de-
tail it has to be broken down into in terms of the small business
itself, it is hard to get a true cost-benefit analysis in terms of the
impact.
We had a regulation some years ago with the Department—not
some years ago but a few years back—Department of Defense on
what is called RFI, radio frequency, and the Department of Defense
did not want to do a cost-benefit analysis on small business. We
were able to get them to do one, and what we found was that the
small business that only had a contract with the Department of De-
fense for one or two items paid a great cost as opposed to that reg-
ulation than a business that had 10 or 15 contracts.
So it is very important, in Advocacy, when we look at this issue
that we look at it from the context of who is being impacted, what
size business is being impacted, and what are the margins, and
what are the other parameters that impact of that situation.
So when we go to whether it is direct or indirect, right now we
are primarily looking at direct costs. But there are arguments to
be made for looking at indirect costs. And the only situation that
really occurs with looking at indirect costs is how far down that
chain do you go to find the real impact, and continuing to go down
that chain may force a missing of the family seed farm and other
entities in that process.
So we need to be careful as to how far we go down that chain,
looking at indirect costs. But definitely look at direct costs and look
at some baseline for indirect costs makes a lot of sense, yes.
Senator ERNST. Thank you, and I had the same thoughts about
global benefits. I was not sure exactly what the definition of ‘‘global
benefit’’ was. Thank you.
Mr. CLARK. Well, I am not sure it relates to small business, and
that is our statutory authority, to look at small business.
Senator ERNST. Right. Thank you very much.
Mrs. Green, one important piece of the PROVE IT Act is that it
would ensure small businesses like Weiler can easily access agency
guidance documents and allow small businesses to comment on
these documents to seek clarification or suggest improvements. Can
you discuss your experience with guidance documents and whether
this provision would help you and other small businesses?
Ms. GREEN. I think the concept is wonderful, and if it is imple-
mented effectively it has great potential to be really useful. The
concerns that I would have are being sure that whoever the com-
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ments are going to have the ability to respond quickly to those
comments and that whoever is on the other end of responding to
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those comments has the authority to buy into whatever agency that
are responding on behalf of.
I have a law degree so I am the one who ends up, on behalf of
the company, calling a lot of these agencies, saying, ‘‘What does
this mean?’’ And a lot of times the agency, either they are not real-
ly sure or we have not really gotten there yet, or I am not sure how
that is going to apply to you yet. But all of the time when you call,
what I am about to tell you is just my interpretation, this is not
binding on this agency. I mean, if I were to answer a question to
my customer in that way, think about how that would go.
So I think that is just really important, that whatever advice we
are getting from that agency, we have to be able to rely on it, be-
cause again, that uncertainty is so expensive, so distracting, and
just makes it so difficult to run a business.
Senator ERNST. Okay. That is a very important point, Mrs.
Green. And you have the legal background. But when you are call-
ing an agency they will state that ‘‘This is just my interpretation.
It is not binding on the agency that I represent.’’
Ms. GREEN. Yes.
Senator ERNST. So again, why the call in the first place then, be-
cause it could change in the future. You may start to act on a rule
or regulation and not actually have that be the right interpretation
then.
Ms. GREEN. Correct. And again, we would not be calling if we
were not trying to do the right thing. We want to play by the rules,
but we have to understand what they are.
Senator ERNST. Okay. Very important point. Thank you.
And for all of our witnesses—and again, thank you so much for
this incredible testimony—I would like to finish today’s hearing by
asking one question to each of you, and we will start with Mr.
Clark and then we will go on down the table.
Mr. Clark, if you could leave one message for Federal regulators
about the importance of truly considering how their regulatory
costs hurt small businesses, what would it be?
Mr. CLARK. You are asking a lawyer to leave one message.
[Laughter.]
Mr. CLARK. Well, the message to the regulatory community has
to be that small businesses are the economic backbone of our na-
tion, and if we do not have small businesses then this global envi-
ronment that they are talking about does not exist. So we have to
find ways to ensure that our small businesses continue to survive,
but more so than continue to survive we have to find ways to en-
sure that they continue to grow and to expand and become
multigenerational businesses because that is where wealth is built
for many of our small businesses.
So from a regulatory standpoint, it is clearly what we have
pushed, and that is that one size does not fit all, that we must look
at a deeper dive, take a deeper dive into the impact of the regula-
tion on our small businesses.
Senator ERNST. Thank you so much. And one of my favorite
phrases, Mr. Clark, is ‘‘not just survive but thrive.’’ We really want
them to thrive. Thank you very much.
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would your message be?
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Ms. LATHAM. So if I could just leave them with one message it
would be just because you can does not mean you should. And as
a business owner, whenever we are starting a new project or some-
body proposes a new idea, my very first question is what is the ob-
jective?
So I think we need to ask, is it going to make it easier for small
businesses, less confusing, easier for compliance? Does it increase
safety? I think every regulation, every administrative rule should
really be scrutinized to make sure it is even needed or is it vitally
important.
Again, less is more. The smaller the code is, the fewer the regula-
tions, the more small businesses can thrive. Thank you.
Senator ERNST. Wonderful. Thank you, Representative Latham.
And Mrs. Green.
Ms. GREEN. I would echo both thoughts. I think regulators need
to take a step back and figure out what the end goal is, what is
the actual objective that they are trying to accomplish, and then
say is this actually moving the ball forward or are we regulating
for the sake of regulating. And then just to continue with my
theme of anything that we can do to reduce uncertainty and make
it easier to run a business for the long term I think will be very
effective.
Senator ERNST. Wonderful. Thank you. Once again, thanks to all
of you for joining us today, and a special thank you to our wit-
nesses for their enlightening testimony.
Before we conclude the hearing I would like to add to the record
the following: an op-ed from John Sorensen, President and CEO of
the Iowa Bankers Association, who published in the Des Moines
Register. Thank you for that very much. We are very lucky to have
you with us today. And also a statement from the U.S. Chamber
of Commerce, who I am thankful has sent Tom Sullivan, the
Chamber’s Vice President for Small Business Policy, to join us
today. As well, a letter from Alfredo Ortiz, the President and CEO
of the Job Creators Network, who we are also lucky to have join
us today. Thank you, Mr. Ortiz. And then a statement from the
National Federation of Independent Businesses; a letter from Dr.
James Berlau, a senior fellow and regulatory economist with the
Competitive Enterprise Institute; a letter from Daniel Goldbeck,
the Director of Regulatory Policy at the American Action Forum;
and a statement from Karen Kerrigan at the Small Business and
Entrepreneurship Council.
[The information follows:]
Senator ERNST. And with that today’s hearing has concluded. I
want to thank everyone for joining us today.
[Whereupon, at 1:57 p.m., the hearing was adjourned.]
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DMWilson on DSKJM0X7X2PROD with HEARINGS
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135
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 170 here 53543.121
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136
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 171 here 53543.122
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137
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 172 here 53543.123
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138
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 173 here 53543.124
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139
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 174 here 53543.125
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140
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 175 here 53543.126
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141
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 176 here 53543.127
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142
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 177 here 53543.128
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143
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 178 here 53543.129
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144
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 179 here 53543.130
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145
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 180 here 53543.131
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146
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 181 here 53543.132
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147
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 182 here 53543.133
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148
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 183 here 53543.134
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149
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 184 here 53543.135
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150
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 185 here 53543.136
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151
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 186 here 53543.137
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152
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 187 here 53543.138
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153
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 188 here 53543.139
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154
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 189 here 53543.140
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155
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 190 here 53543.141
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156
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 191 here 53543.142
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157
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 192 here 53543.143
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158
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 193 here 53543.144
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159
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 194 here 53543.145
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160
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 195 here 53543.146
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161
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 196 here 53543.147
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162
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 197 here 53543.148
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163
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 102 here 53543.053
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164
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 103 here 53543.054
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165
DMWilson on DSKJM0X7X2PROD with HEARINGS
Insert offset folio 104 here 53543.055
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File and source
- File
- CHRG-118shrg53543.pdf
- Size
- 64,421,740 bytes
- SHA-256
- 9e6b2142fbbe8b86217ae55d71764720d3e52a2d2475631089a126d80e78154f
- Our copy
- CHRG-118shrg53543.pdf
- Original
- www.govinfo.gov