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Bonus episode: Renewables professionals predict the World Series
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In this bonus episode, friends of the podcast give their predictions on who will win the 2024 World Series.

Ep223: Investing in decarbonization: Insights from an experienced investor
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Benoit Allehaut, chief investment officer at XCarbon Technologies, joins Todd Alexander for a discussion about investment trends in the wind and solar sectors.

Ep222: An Assessment of the IRA
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Bill Green, managing partner of Climate Adaptive Infrastructure, joins Todd Alexander in a wide-ranging discussion about how the renewable energy market may not be fully appreciating the impact of the IRA.

Ep221: Opportunities for Sustainability in Commercial Real Estate
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Michael Beckerman, CEO of CREtech, joins Todd Alexander to discuss how commercial real estate developers are taking a closer look at renewable energy sustainability.

Ep220: Taking its toll — Tolling Agreements and Offtake Strategies
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Christine Brozynski, partner in Norton Rose Fulbright’s projects practice, joins Todd Alexander to talk about recent trends in offtake strategies for energy storage projects.

Proposed Basel III Rules could be catastrophic for the traditional tax equity market
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On July 27, 2023, the Office of the Comptroller of the Currency, Treasury; the Board of Governors of the Federal Reserve System; and the Federal Deposit Insurance Corporation (the “U.S. Banking Authorities”)

Ep219: Northern Lights: Alight's CEO talks about solar in Scandinavia and the rest of Europe
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Dr. Harald Överholm, CEO and founder of Alight, joins Todd Alexander to talk about the opportunities and challenges in the European solar market.

Wage and Apprentice Requirements
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The Internal Revenue Service filled in many missing details this week in new wage and apprentice requirements.

Ep218: Debt Workouts and Liability Management Transactions
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Eric Daucher joins us to talk about debt workouts and liability management transactions, how they are executed and leveraged, their legality, how investors and lenders can avoid litigation, and more.

Ep217: Ampion CEO discusses community solar
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Nate Owen, founder and CEO of Ampion, joins Todd Alexander to talk about what Ampion does and the role it plays in managing distributed generation projects.

Low-Income Community Bonus Credit – Final Regulations
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The community solar and rooftop solar industries were starting to lose hope of claiming the economic justice bonus credits on 2023 projects.

Ep216: Heating Up: New geo-thermal developments and technology
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Neil Ethier, vice president of business development for Eavor, joins Todd Alexander to talk about the new approach Eavor has developed to tap geothermal energy.

Ep215: Getting Worked Up — What to Know About the IRA’s Wage Requirements
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Taylor Gant joins Todd Alexander to explain the wage requirements portion of the Inflation Reduction Act.

Transferable Tax Credits Treated Favorably Under the OECD’s Pillar Two
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On July 17, 2023, the Organization for Economic Cooperation and Development (the “OECD”) released favorable guidance on transferable tax credits under Pillar Two.

Ep214: Plug Power CEO Discusses Future of Hydrogen Economy
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Andy Marsh, president and CEO of Plug Power, joins Todd Alexander for a lively discussion about green hydrogen.

Post-IRA Tax Incentive Regime for Carbon Capture, Renewable Natural Gas and Clean Hydrogen
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The Inflation Reduction Act’s enhancements to carbon capture and sequestration tax credit and new tax credits for biogas investment and clean hydrogen production is creating novel opportunities for developers.

Sustainable Aviation Fuel Tax Incentives
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Among the Inflation Reduction Act’s package of credits and incentives for renewable fuel production is a new set of tax credits for sustainable aviation fuel (“SAF”).

Ep213: Community Solar Update
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Aaron Halimi, President of Renewable Properties, speaks with Todd Alexander on a range of topics concerning community solar.

Ep212: Trends in the Renewables Market
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Nick Knapp, partner and senior managing director at CohnReznick Capital, joins Todd Alexander for an overview of current and future market trends.

PTC Inflation Adjustment
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Calculation Conventions Result in Higher PTC Rate for Old Projects than New Projects After 2023 Inflation Adjustment

More Alta Wind Analysis
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A US Court of Federal Claims decision on June 20 that suggested the purchase price paid for a power project should be allocated partly to any tax credits or other government subsidies.

Purchase Price Allocations
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Buyers of projects that qualify for future government payments must allocate part of the purchase price to such payments, the US claims court suggested in mid-June.

Tax credit sales
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Prices have been mainly in the 90¢ to 93¢ range, but are creeping higher. Buyers can carry back tax credits and recover taxes paid up to three years in the past.

Potential stimulus for carbon capture and clean hydrogen
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New EPA rules should create more demand for carbon capture and low-carbon hydrogen at coal- and gas-fired power plants.

Key issues for hydrogen developers
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Green hydrogen projects are significantly more complicated than the typical wind or solar project.

Hydrogen pipeline regulation
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The US has no clear framework for regulating interstate hydrogen pipelines. There are three possible regimes.

LMI bonus credit guidance
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Bonus tax credits of 10% or 20% of project cost can be claimed on some community and rooftop solar projects. The complexity is vastly out of proportion to the small size of the projects.

Comparing carbon offset credits
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Demand for voluntary carbon credits is outpacing the supply. The supply is hampered by concerns about quality of the carbon credits.

Sports stadiums and renewable energy
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Sports stadiums consume large amounts of electricity during games, making them good candidates for renewable energy.

Domestic content calculations
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Project developers are having a hard time getting the data they need from manufacturers to do the calculations required to claim a domestic content bonus tax credit.

Contract manufacturing
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Contract manufacturing is becoming more important as some manufacturers angling for section 45X credits for making components for wind, solar and storage projects farm out the physical work to other companies.

Wage and apprentice negotiations
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Developers are having to negotiate more wage and apprentice provisions in construction contracts now that the January 28 deadline to avoid them has passed.

Split-scope battery purchase contracts
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Splitting contracts to buy and then install utility-scale batteries among multiple contractors is a complicated process that can be done, but carries risk.

Environmental update
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The US Supreme Court stripped protection under the Clean Water Act for more than 50% of the nation's previously-regulated wetlands.

Manufacturer tax credits: Section 48C
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Manufacturers who plan to apply for an initial round of $4 billion in tax credits for building production lines to make products for the green economy have until noon eastern time on July 31 to submit.

PTC inflation adjustment
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Production tax credits for producing renewable electricity will be higher this year than in 2022, but the amount varies depending on when the project went into service.

Ep211: New Proposed IRS Guidance on Tax Credits Transferability
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Hilary Lefko joins host Todd Alexander in a conversation on the proposed guidance on tax credits and transferability recently released by the IRS.

The Two Low-Income Community Bonus Tax Credit Programs
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As sponsors and investors begin to plan projects and investments to take advantage of the Inflation Reduction Act’s ("IRA”) low-income community bonus tax credits (the “LIC Bonus Credit”)

IRS Transferability Guidance
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The tax credit sales market should ramp up quickly. Buyers will have to repay the government if tax credits are recaptured or disallowed on audit.

Ep210: Fuel Cells
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Gregory Adams, Senior Vice President of FuelCell Energy, joins host Todd Alexander for a discussion about fuel cells.

USDA’s New Funding for Rural Electrification
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One of the many aims of the Inflation Reduction Act of 2022 (IRA) is to bring reliable and affordable renewable energy sources to rural America. The U.S. Department of Agriculture (USDA) recently announced its

Ep209: New legislation in Texas creates a murky landscape for renewables
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Judd Messer and Jeffrey Clark of the Advanced Power Alliance in Texas join host Todd Alexander in a discussion on the new legislation passed in Texas that imposes restrictions on renewable energy development.

Mexico Redefines Clean Energy
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The Mexican energy sector is embroiled in a new controversy. A resolution issued in May by the CRE lowers efficiency requirements for cogeneration facilities ...

EP208: Current Trends in Renewables
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CEO of Marathon Capital Ted Brandt talks with Todd Alexander about  how the Inflation Reduction Act has affected the landscape of deals in the renewables sector and more

Ep207: The Climate Mobilization Act
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Jeff Hendler, CEO of Logical Buildings, and our host Todd Alexander discuss the Climate Mobilization Act.

ITC and PTC Cheat Sheet
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A colleague, who is not a tax lawyer, asked for a cheat sheet with key facts about the production tax credit (PTC) and the investment tax credit (ITC) after the Inflation Reduction Act of 2022 (IRA).

Texas Debates Tilt Toward Gas-Fired Power Plants
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Texas legislators are pushing seven bills aimed at bolstering traditional dispatchable power in a bid to fix a reliability problem with the Texas power grid.

Domestic Content Bonus Credit
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The Internal Revenue Service explained today how to determine whether wind, solar, storage and other renewable energy projects qualify for a bonus tax credit for using enough domestic content. inflation

Table 2 – Categorization of Applicable Project Components
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The Internal Revenue Service explained today how to determine whether wind, solar, storage and other renewable energy projects qualify for a bonus tax credit for using enough domestic content.

Government Lawyers Discuss Energy Tax Credits at ABA Meeting
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The American Bar Association 2023 May Tax Meeting was held in Washington, DC, over a three-day period.

Ep206: How the IRA has affected the MCOE
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Michael Tatarsky, managing director, and Colin Smith, senior research analyst, with CohnReznick Capital join Todd Alexander to discuss the market cost of energy.

Tax Credit Insurance Mitigates Risk for Tax Credit Transfers but Due Diligence is Still Necessary
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The Inflation Reduction Act of 2022 (IRA) changed almost a century of federal tax law and allowed energy credits to now be sold.

Ep205: “Transferability” - Tax Credit Sales
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The Inflation Reduction Act last August let companies sell nine types of federal tax credits to other companies for cash

Energy Community Qualification and IRS Rules for Unemployment Data
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The Bureau of Labor Statistics (BLS) published the official 2022 unemployment data, which provides the final puzzle piece for some owners of clean energy projects to be able to determine if their project

Ep204: Global Mining Supply Chain
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Martin McCann, partner in London, joins Todd Alexander to discuss the global mining supply chain.

Are you using the right version of the IRS’s energy community notice
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Notice 2023-29 was generally welcomed news to the renewable energy industry as it provided significant clarify about how to determine if a project is sited in an “energy community.”

Energy community bonus credit guidance
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The IRS filled in missing details that were making it hard for renewable energy developers to feel confident about which projects qualify for a new 10% bonus tax credit for projects in "energy communities."

Overview of Energy Tax Credits After the IRA
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The New York Energy Summit, presented by Infocast, was held in Albany from April 4 to 6 where David Burton served as Summit Chair.

The Solar + Wind Finance and Investment Summit Soundbites: the Corporate Offtake and M&A Markets
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The second annual Solar + Wind Finance and Investment Summit was held in Phoenix from March 12 to 15.

FASB’s proportional amortization method for tax equity deals ain’t all it’s cracked up to be
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On March 29, the Financial Accounting Standards Board (FASB) issued Accounting Standards Update 2023-02 (ASU 2023-02).

Texas legislature considers tougher permitting for renewables
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Companion bills pending in Texas House and Senate committees would impose new permitting requirements for wind and solar projects, but not other types of power plants.

Ep203: Transferability of Tax Credits
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Hilary Lefko, partner in Washington, joins Todd Alexander to discuss the transferability of tax credits.

The Solar + Wind Finance and Investment Summit Soundbites: the Debt and Sponsor Equity Markets
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The second annual Solar + Wind Finance and Investment Summit was held in Phoenix from March 12 to 15.

The Solar + Wind Finance and Investment Summit Soundbites: the Tax Equity Market and Transferability
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The second annual Solar + Wind Finance and Investment Summit was held in Phoenix from March 12 to 15.

Ep202: Bridge Banks: Silicon Valley Bank and Signature Bank Market Watch
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Tim Byrne, Eric Daucher and Tom Delaney join Todd Alexander to discuss the formation of the bridge banks for Silicon Valley Bank and Signature Bank and what to expect from them and government regulation.

Ep201: Silicon Valley Bank Outlook
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Tim Byrne, Eric Daucher and Tom Delaney join Todd Alexander to discuss what has unfolded for Silicon Valley Bank over the weekend and what it means

Environmental Update
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The White House Council on Environmental Quality, or CEQ, released interim guidance for how federal agencies should assess climate change effects of federal agency actions in their environmental assessments ...

Cryptocurrency Contributions
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Charitable contributions made in cryptocurrency cannot be deducted without an appraisal to establish how much the cryptocurrency is worth.

Applying for Section 48C Tax Credits
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Manufacturing angling for some of the $10 billion in tax credits that the Inflation Reduction Act authorizes to encourage construction of new US factories to make products for the green economy ...

Section 45V Tax Credits: Open Issues
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A showdown over standards that must be met to count hydrogen as clean is pitting hydrogen producers against environmental groups and some renewable energy generators.

LMI Bonus Credits
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LMI bonus credits will be hard to claim on 2023 projects the way the Internal Revenue Service plans to implement the program.

Make-Whole Provisions and Bankruptcy
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Make-whole provisions may be unenforceable where a bankrupt company is trying to restructure its debts and reemerge from bankruptcy.

New Hurdle for Some European Acquisitions and Tenders
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New European Union notification and approval requirements will hit public tenders valued over €250 million and acquisitions of EU businesses with more than €500 million in EU revenue

EPA Greenhouse Gas Reduction Fund
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The Inflation Reduction Act establishes a $27 billion Greenhouse Gas Reduction Fund at the US Environmental Protection Agency.

Washington Policy Outlook
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Tom West, deputy assistant secretary of the Treasury for tax policy, told the 18th annual renewable energy law conference at the University of Texas in Austin in late January that the Treasury hopes ...

Cost of Capital: 2023 Outlook
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Yields on 10-year and 30-year Treasuries are above 4% for the first time since 2007, up from only 1.9% a year ago. The futures markets shows investors expect the federal funds rate to peak at 5.45% ...

Rising Solar Insurance Premiums and Shrinking Coverage
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Property insurance premiums are up 15% to 45% across the solar industry and are becoming a major concern for developers, investors and construction contractors.

Transferability: Selling Tax Credits
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The US Treasury is expected to issue guidance about direct sales of federal tax credits by the second quarter this year ...

Stimulus With Bottlenecks
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The Inflation Reduction Act is stimulating demand at the same time that developers are running into multiple bottlenecks. Some of the bottlenecks are consequences of the war in Ukraine.

What did we learn from the Advanced Energy Manufacturing Tax Credit Guidance?
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Notice 2023-18 provides guidance on the advanced energy manufacturing tax credit. Except for explaining the application process, it did little more than parrot the statutory language in section 48C and promised

Ep200: Cost of Capital: 2023 Outlook
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Four veteran tax equity investors and lenders talk about what to expect in the year ahead.

IRA Tax Credit Opportunities for Clean Energy Technology Companies
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Below are bullet points outlining tax credit opportunities for clean energy technology companies.

Ep199: The DoC’s Preliminary Determination of Circumvention Issues
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Stefan Reisinger, partner in Washington, joins us to discuss the Department of Commerce’s preliminary determination of circumvention issues.

Anti-Circumvention Duties and Solar Panels
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The Commerce Department said this morning that it made a preliminary decision to impose anti-circumvention duties on solar panels produced in Vietnam, Malaysia, Thailand and Cambodia using Chinese parts.

IRS Issues Wage and Apprentice Requirements
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Ep198: Book talk: California Burning
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The Wall Street Journal's Katherine Blunt talks to Keith Martin about her book, California Burning, which addresses the challenges facing utilities with aging power lines in drought-stricken parts of the US.

Ep197: Post-Election Analysis
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Five veteran Washington observers talk with Keith Martin in our Washington office about what the midterm election results mean for clean energy, storage, carbon capture, hydrogen and the project finance market.

IRS Confirms Higher PTC Rate due to the IRA
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IRS Announcement 2022-23 updates the production tax credit (PTC) rate to 2.75 cents a kWh for wind, solar, geothermal and closed-loop biomass power plants placed in service after 2021.

Battery storage tax credit opportunities and development challenges
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Below are slides the authors prepared about tax credit opportunities and development challenges for battery storage.

IRS acknowledges PTC increase
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The IRS said this afternoon that production tax credits on new wind, solar, geothermal and closed-loop biomass power plants put in service in 2022 are 2.75¢ cents a KWh.

California solar property tax exemption
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California extended a property tax exemption for solar projects placed in service by the end of 2026.

FEMA power plant proposal
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The fate of a FEMA proposal to require power plants and other projects to be able to withstand extreme weather events should be decided around November 1.

Shared-appreciation loans
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A shared-appreciation loan was a pure loan and did not make the lender a partner with the borrower, the US Tax Court said.

Tax equity partnerships and QIOs
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Tax equity partnerships take note.

Solar anti-circumvention moratorium
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Solar developers planning to import solar panels by mid-2024 to avoid any US anti-circumvention duties the US decides to impose on panels from Vietnam, Malaysia, Thailand or Cambodia must actually use the panel

Wage and Apprentice Guidance
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Wage and apprentice guidance is expected by year end.

Environmental Update Oct 2022
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Solar generating equipment withstood much of the wrath of the two hurricanes that struck Puerto Rico and Florida in September, providing advocates for the industry with reason to argue ...

US Offshore Wind Lease Issues
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Offshore wind developers bidding in federal auctions of sites off the US coast commit to a time-consuming and expensive process.

Carbon Capture Economics
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The Inflation Reduction Act increased a tax credit for capturing carbon oxide emissions and extended the deadline to qualify. The tax credit, even before the latest increase, was already contributing to ...

Recycling and Renewable Energy
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End-of-life management of renewable energy is both a looming challenge and a potential opportunity.