Comment from Susan Pettit on FR Doc # E9-18810

Comments of the National Electric Cooperative Association (NRECA) on Loan Guarantees for Projects that Employ Innovative Technologies (RIN 1901-AB27) I. Background on Electric Cooperatives The National Rural Electric Cooperative Association (NRECA) is a trade group that represents the interests of rural electric cooperative utilities and their consumers. In addition to advocating consensus views on legislative and regulatory issues, NRECA provides health care, pension, financial investment and many other programs for its members. Electric cooperatives are not-for-profit, private businesses governed by their consumers (known as “member-owners”). Today, 930 electric cooperatives serve 42 million consumers in 47 states. 66 of those are generating and transmitting (G&T) cooperatives that generate nearly five percent of the total electricity produced in the U.S. each year. Cooperatives are a unique sector of the utility industry, serving an average of only 7 consumers per mile compared with 35 customers per mile served by investor-owned utilities (IOUs) and 47 customers per mile served by municipal utilities. To put this in perspective, electric cooperatives serve 12% of the population, but maintain 42% of the nation’s electricity distribution lines covering three quarters of the nation’s land mass. The Department of Energy (DOE) loan guarantee program is valuable in light of the significant needs the utility industry has for new generation and transmission resources. The Energy Information Agency (EIA) projects in its March, 2009 Annual Energy Outlook reference case that national electricity demand will increase 26 percent by 2030. Moreover, the North American Electric Reliability Corporation predicts that demand will soon outstrip supply in some regions. The burden of meeting the increasing demand for electricity falls disproportionately onto electric cooperatives. The electric co-op sector is growing at twice the rate of the other utility