From: Kevin Rafferty [mailto:raffertk@oit.edu]
Sent: Thursday, November 21, 2002 1:15 PM
To: Hadjy, Pandor
Subject: Section 9006


To Whom it May Concern:

Thank-you for the oportunity to comment on the implementation of Section
9006 of the 2002 Farm Security and Rural Investment Act.  I would like
to submit the following thoughts:

1.) I would like to encourage you to allow for the inclusion of
geothermal direct use (systems that use water in the range of 100 F to
250 F from wells and spings) and ground source heat pump systems among
the eligible measures qualifying for support under the Section.  Direct
use systems are particularly feasible in the Western portion of the
country and the application of geothermal fluids to the heating oof
greenhouses and aquaculture facilities is a very effective way for those
with acceess to such resources to diversify their farm operation.
Geothermal resources are widely distributed and in use in such states as
OR, WA, ID, NV, AZ, CA, NM, UT and CO.

Ground source heat poump systems are an efficient way to heat and cool
buildings.  many different types of systems are available to accommodate
different site conditions.  One of the most cost effective system types
is referred to as an "open loop" system.  Under this approach waster
from a well is used to support the operation of the heat pump (which
supplies heating cooling and domestic hot water to the home) and the
water, after passing through the heat pump can then be used for stock
waterin or irrigation.  Ground source heat pump systems are recognized
by DOE and EPA as among the most efficient space conditioning systems
available.

2.)  Loans or loan guarantees are more effective mechanisms that direct
grants.  Grants - particularly in the ground source heat pump arena have
been shown to simply "index up" installation costs since the contractors
often factor the grant availability into their bids.

3.)  A balanced approach in determining awardees should be used in terms
of projects which generate electricity (typically wind and solar
voltaics) and those which conserve energy or displace conventional fuel
use (ground source heat pumps and direct use geothermal).

Some sort of cost effectiveness criteria should apply - simple payback
etc.

Sincerely
Kevin Rafferty

************************************************************************

* Kevin Rafferty, Assoc. Dir.         Phone: (541) 885-1750            *

* Geo-Heat Center                     Fax:   (541) 885-1754            *

* 3201 Campus Dr.                     Webpage:                         *

* Klamath Falls, Or. 97601            http://www.oit.edu/~geoheat      *

************************************************************************