Siluria DOE Comment Letter to LPO Rule change FINAL

November 2, 2016
Loan Programs Office
RE: RIN-1901-AB38
1000 Independence Ave, S.W.
Washington, DC 20585-0121
RE: Comments on proposed changes to 10 CFR Part 609 Loan Guarantees for Projects That Employ
Innovative Technologies
Dear Sir or Madam:
Siluria Technologies, Inc. (“Siluria”) submits these comments in response to the proposed changes to 10
CFR Part 609 Loan Guarantees for Project That Employ Innovative Technologies (RIN-11901-AB38)
issued by the Loan Programs Office (“LPO”) in the Department of Energy (“DOE”).
Section 609.11 (c) of the proposed change describes a fee referred to as a “Risk-Based Charge”.
However, it is unclear if this “Risk-based Charge” is simply renaming the existing credit-based interest
rate spread1, or imposes a new fee. If the latter, the imposition of any supplemental fees beyond what is
currently contemplated in the existing program for applicants and borrowers would likely make many
projects infeasible and have potential significant impact on the loan program as a whole. We kindly ask
for clarification or reconsideration of this proposed fee.
Thank you for your time and consideration.
Sincerely,

David J. Zaziski, Ph.D.
Director, Government Affairs
Siluria Technologies, Inc.

1

The credit-based interest is defined in the DOE notice titled “Credit-based Interest Spread For Title XVII”.