Comment from Daniel Kunz on FR Doc # E9-18810

September 2, 2009 David G. Frantz Director Loan Guarantee Program Office Office of the Chief Financial Officer 1000 Independence Avenue SW Washington DC 20585-0121 Subject: Department of energy, 10 CFR Part 609, RIN 1901-AB27: Loan Guarantees for Projects that Employ Innovative Technologies Dear Director Frantz, I am writing to encourage you and the Department of Energy to alter one of the rules governing eligibility for loan guarantees for projects that employ innovative technologies under the Section 1703 of Title XVII program. The current rules prohibit any one project sponsor from applying to use the same technology at more than one project. The program covers projects ranging from a small scale $25 million solar facility to a truly massive $5 billion nuclear project. There does seem to be some reasonable logic to limiting a company that has obtained a multi-billion dollar loan guarantee to a single project, however for companies proposing to use the same technology at multiple small projects, this rule may stifle the objectives of the program by discouraging the application of innovative technology. New technology brought from demonstration to commercial acceptance can be achieved by a very successful massive project, or by multiple small projects which utilize the same technology to demonstrate success. U.S. Geothermal Inc. would propose to make applications for two small geothermal projects using an innovative binary power generation technology that promises to significantly improve the commercial viability of low temperature and small-scale geothermal power projects. At one project the plant will be air cooled and at the other the plant will be water cooled. The current rules will not allow us to make the second application even though the technology deployment may benefit from the two different sites. The rule appears not to limit a technology from being applied more than once, but limits one project sponsor from applying more than once. Many a