Comment on FR Doc # 2011-00486

The Clean Economy Network is the nation’s largest network of clean technology companies and business professionals. With 10,000 members nationwide, CEN represents a wide variety of clean technologies including wind, solar, biofuels, geothermal, and energy efficiency as well as investors in those technologies. In general, we believe that rules should be written to be as inclusive as possible to allow for a broad range of technologies to apply and compete for available resources. While good overall, our interpretation of SBA’s proposed rule (RIN 3245-AF 86) finds that it appears to exclude a very important category of technologies. As we understand it, to qualify for this program a technology must currently qualify for the Renewable Electricity Production Tax Credit. If our reading is correct, we believe the rule should be broadened to include companies which make renewable solid fuels from plant and woody biomass, using a process called torrefaction, or other forms of pyrolysis. Electric utilities are very interested in these fuels as are other users of coal, because they can co-fire or exclusively use such fuels in existing coal-fired units, without any significant equipment upgrades. As it stands currently, the production of these fuels are not covered by the Renewable Electricity Production Tax Credit, which is one of the criteria guidelines for the proposed rule. We urge SBA to consider amending the rule to include this broader class of technologies.