Comment on FR Doc # 2026-11765
Saundra HollowayOpposeIndividual
Summary: Saundra Holloway, a resident of rural Arizona, opposes the proposed rule because it creates insurmountable administrative barriers for individual Indigenous and rural entrepreneurs by removing the rebuttable presumption of social disadvantage. She argues that the change ignores systemic socio-economic challenges and undermines the SBA's core mission to level the economic playing field for marginalized individuals.
Subject: Formal Opposition to Proposed Rule - Reforms to 13 CFR Section 124.103 (Remove SBA's 8(a) Program's Rebuttable Presumption of Social Disadvantage for Individually Owned Firms Only)<br/>I am writing to express my strong opposition to the Small Business Administration’s proposed rule to eliminate the rebuttable presumption of social disadvantage for individually owned firms within the 8(a) Business Development program.<br/>As a resident of rural Arizona, a region that is neighbor to numerous sovereign tribal nations, I witness the unique economic realities of reservation and rural communities firsthand. While this proposed rule carves out tribal entities, it inflicts severe, compounding economic damage on the individual Indigenous entrepreneurs and rural small business owners who live and work in my community and across our state.<br/>Forcing independent, solo proprietors to compile exhaustive personal narratives to prove their social disadvantage ignores the distinct, structural hurdles faced by rural and reservation-based business owners:<br/>-- Severe Geographic and Digital Isolation: In rural Arizona, entrepreneurs already operate with limited infrastructure, unreliable high-speed internet, and a vast geographic distance from traditional legal, financial, and business consulting services. Forcing an isolated, independent business owner to navigate a complex, highly legalistic narrative process—without the corporate backing of a large tribal entity—creates an insurmountable administrative barrier.<br/>-- Disregard for Documented Tribal Realities: An individual Native American business owner operating on or near a reservation faces well-documented, systemic socio-economic challenges. Eliminating their presumption of social disadvantage and requiring individual proof of discrimination completely disregards the historic and ongoing economic inequities recognized by federal law.<br/>-- Economic Suffocation of Rural Communities: Small businesses are the primary lifeblood of rural America. The SBA's recent policy shifts have already caused program acceptance to plummet to just 65 new firms nationwide in 2025. Codifying this rollback will completely starve rural areas and individual Indigenous innovators of federal contracting dollars, crippling local job creation where it is needed most.<br/>The proposed rule represents a fundamental and unlawful betrayal of the Small Business Administration’s core founding mission. The SBA was established by Congress under the Small Business Act with an explicit statutory mandate: to challenge systemic inequities, level the economic playing field, and actively lift up socially and economically disadvantaged individuals. By forcing marginalized solo entrepreneurs to cross an adversarial and burdensome hurdle just to prove their lived experiences, this rule subverts the very purpose for which the agency was created.<br/>Furthermore, the agency’s pivot toward a race-neutral framework—which incredibly allows claims based on perceived harms from DEI or affirmative action policies—turns the original intent of the law completely on its head. The SBA is transforming from an agency designed to dismantle economic exclusion into one that institutionalizes it.<br/>I urge the SBA to immediately withdraw this proposed rule. Rather than weaponizing red tape to suffocate independent small businesses and desert rural communities, the agency must honor its original congressional mandate and streamline access for individual Indigenous and rural entrepreneurs.<br/>Respectfully submitted,<br/>Saundra Holloway<br/>Yuma, Arizona