Introducing Reunion's Transferable Tax Credit Handbook, a comprehensive guide to buying and selling clean energy tax credits.

Takeaways

• The low-income community bonus is an allocated – that is, capped – credit, and we believe it will be fully utilized
• Developers must apply for an allocation through the Department of Energy. All applications received within the initial 30 days will be treated as received at the same time
• There are 21 business days in the 30-day window. The last day coincides with the expiration of the federal government’s current continuing resolution
• Allocation amounts can different from applied-for amounts

Overview of the low-income community bonus

The low-income bonus is designed to incentivize investment in communities that have historically been left behind. Specifically, the credit promotes wind, solar, and associated energy storage investments in low-income communities, on Indian land, as part of affordable housing developments, or benefitting low-income households.

The low-income bonus is an allocated credit. For 2023, the bonus is subject to an 1,800 MW annual capacity limitation, which is further allocated across four categories:

1. Located in a low-income community: 700 MW
2. Located on Indian land: 200 MW
3. Qualified Low-Income Residential Project: 200 MW
4. Qualified Low-Income Economic Benefit Project: 700 MW

Projects in the first two categories receive a 10% bonus credit value, while projects in the third and fourth categories receive a 20% bonus credit value. All low-income projects must be less than 5 MWac in size.

For 2023, the 700 MW in category one will be further subdivided: 560 MW will be reserved for residential rooftop solar and other “behind-the-meter” (BTM) facilities, and 140 MW will be reserved for “front-of-the-meter” (FTM) facilities.

The bonus is available for §48 and §48E credits

The low-income bonus is only applicable to §48 and §48E investment tax credits. The latter credit, the technology-neutral ITC, is available to projects placed in service in 2025 or later, so it’s possible that many developers will generate §48E ITCs.

How to apply

Since the low-income bonus is an allocated bonus, developers must apply for and receive an allocation from the IRS. (The DOE administers the application process, but the IRS ultimately makes allocation decisions.)

The DOE has published a  checklist for applicants in each category.

If any category or sub-category is oversubscribed during the initial 30-day period, the IRS will make awards based on a randomized lottery. Following the initial 30-day period, any leftover capacity will be awarded on a first-come, first-served basis. Applicants may only submit one application per facility, per program year.

The IRS will make allocations with certain ownership and location priorities in mind:

• Ownership: Priority will be given to (1) projects owned directly or indirectly by Indian tribes; (2) consumer or purchasing cooperatives with controlling members who are workers or from low-income households; (3) tax-exempt charities and religious organizations; and (4) state and local governments, and U.S. territories, Indian tribes, and rural electrical cooperatives
• Location: Priority will be given to (1) persistent poverty counties, where 20% of residents have experienced high rates of poverty of the last 30 years; and (2) and census tracts designated as “disadvantaged” in the Climate and Economic Justice Screening Tool (CEJST)

Once a developer has an allocation, they will have four years to complete the project and place it in service.

When to apply

All applications received within the first 30 days will be treated as received at the same time

The allocation portal opened on Thursday, October 19th at 9:00am ET. Applications submitted within 30 days of this date will be treated as submitted on the same date and at the same time.

Submit applications before November 17th, when the federal government’s current continuing resolution expires

The 30th day of the application window falls on Friday, November 17th. Developers should strive to submit their applications before this day because the federal government’s current, 45-day continuing resolution expires at the end of it.

Allocation amounts may differ from application amounts

Developers who receive an allocation will receive an award letter from the IRS with their allocation amount. Notably, the IRS makes it clear that a developer “may receive an allocation less than its [applied for] nameplate capacity.”

The allocation, not the project’s capacity, determines the credit value.

Reunion expects the IRS to fully allocate the credit

The IRS and DOE have stated that they can adjust the category allotments within the low-income bonus credit to ensure full allocation. Therefore, we expect the low-income bonus to be fully utilized every year – likely within the 30-day, all-applications-are-equal window.

The IRS and DOE have released extensive guidance and detailed resources for applicants

Guidance

• Initial guidance (February 13, 2023): Notice 2023-17, Initial Guidance Establishing Program to Allocate Environmental Justice Solar and Wind Capacity Limitation Under §48(e)
• Proposed regulations (May 31, 2023): Notice of Proposed Rulemaking, Additional Guidance on Low-Income Communities Bonus Credit Program
• Final regulations (August 10, 2023): Final Regulations, Additional Guidance on Low-Income Communities Bonus Credit Program
• Revenue procedure (August 10, 2023): Revenue Procedure 2023-27

Resources

• The Department of Energy (DOE) maintains a low-income communities bonus credit program website
• Applicant checklist
• Category 1 eligibility map with CEJST and persistent poverty county screens
• Category 3 eligible covered housing programs
• Category 4 household income limits

As the leading marketplace for clean energy tax credits, Reunion has been approached by many non-profit organizations to help them monetize clean energy credits, primarily from distributed solar projects. Unfortunately, non-profits are not able to transfer tax credits to third parties.

But non-profits have an alternative. The elective pay provision, sometimes called direct pay, allows “applicable entities,” including tax-exempt entities, to benefit from IRA clean energy tax credits even though they are not traditional taxpayers. This provision allows non-profits to receive refund payments directly from the IRS for the amount of eligible credits claimed.

Unlike transferable tax credits, where credits are purchased at a discount to their face value, applicable entities are entitled to receive the full amount of the credits from the IRS.

In order to qualify for elective pay, an applicable entity needs to pre-register its project with the IRS and receive a registration number. The direct payment election is made on Form 990-T, and the amount of credit would be treated as a payment of tax, which would be refundable, absent any other tax liability.

The elective payment provisions of the IRA are codified in IRC §6417. The internal revenue code (IRC) defines six applicable entities that are eligible for elective pay:

• Organizations exempt from income tax
• Any state or political subdivision thereof
• The Tennessee Valley Authority
• An Indian tribal government
• Rural energy cooperatives
• Alaska Native Corporations

Most nonprofits, including 501(c)(3) and 501(d) entities, fall into the first category.

12 credits are available for elective pay:

• §48: Energy Credit
• §48E: Clean Electricity Investment Credit
• §45: Renewable Electricity Production Credit
• §45Y: Clean Electricity Production Credit
• §45W: Commercial Clean Vehicle Credit
• §45U: Zero-emission Nuclear Power Production Credit
• §45X: Advanced Manufacturing Production Credit
• §45V: Clean Hydrogen Production Credit
• §45Z: Clean Fuel Production Credit
• §45Q: Carbon Oxide Sequestration Credit
• §30C: Credit for Alternative Fuel Vehicle Refueling/Recharging Property
• §48C: Qualifying Advanced Energy Project Credit

Key features of the IRA's 11 transferable tax credits

The Inflation Reduction Act (IRA) created 11 transferable tax credits to promote investment into clean energy. This article summarizes key features of each transferable credit including technology, duration, period of availability, and rates. Depending on the credit, we included three rates:

• Base: Rate assuming prevailing wage and apprenticeship requirements are not met.
• Full: Rate assuming prevailing wage and apprenticeship requirements are met. The full rate is five times higher than the base rate.
• Bonus: Additional rates assuming bonus credits – energy community, domestic content, low-income community – are met.

Jump directly to a credit

To jump directly to a credit, click the link below:

• §45 PTC – Electricity produced from certain renewable sources
• §45Y PTC – Clean electricity production credit (technology-neutral PTC)
• §48 ITC – Energy credit
• §48E ITC – Clean electricity investment credit (technology-neutral ITC)
• §30C ITC – Alternative fuel vehicle refueling property credit
• §45U PTC – Zero-emission nuclear power production credit
• §45Q PTC – Credit for carbon oxide sequestration
• §45Z PTC – Clean fuel production tax credit
• §45V PTC – Clean hydrogen production tax credit
• §48C ITC – Advanced energy project credit
• §45X PTC – Advanced manufacturing production tax credit

Pending guidance

Although the IRA is more than a year old, several credits and adders are still awaiting key guidance:

• Domestic content: The domestic content bonus/adder is  awaiting final guidance. We expect this guidance in Q1 2024.
• §45X PTC: The advanced manufacturing production tax credit is awaiting final guidance. According to a September press release, Treasury expects to release guidance "before the end of the year."‍
• §48C ITC: The advanced energy project credit is awaiting final guidance. According to a September press release, Treasury expects to release guidance "before the end of the year."‍

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Funding mechanism: Production tax credit

Technology grouping: Electricity

Eligibility: Facilities generating electricity from wind, biomass, geothermal, solar, small irrigation, landfill and trash, hydropower, and marine and hydrokinetic renewable energy

U.S. Code: 26 U.S. Code §45

Duration: 10 years

Period of availability: Projects must begin construction in 2023 or 2024. For projects placed in service in 2025 or later, the §45Y PTC will replace the §45 PTC

Inflation adjustment: Subject to an annual inflation adjustment factor

Stackability and limitations: None‍

Elective pay (direct pay): Tax-exempt entities

Rates:

The §45 PTC has two different rate regimes depending on when a project was placed in service:

• ‍Pre-IRA (pre-2022): For projects placed in service before 2022, the full PTC calculation is [1.5 cents] x [inflation adjustment factor] rounded to the nearest 0.1 cents. Current rate is $28.00 per MWh. Projects placed in service before 2022 are not subject to prevailing wage and apprenticeship requirements.‍
• Post-IRA (post-2021): For projects placed in service after 2021, the full PTC rate calculation is [0.3 cents] x [inflation adjustment factor] rounded to the nearest 0.05 cents. For projects meeting PWA requirements, this product is multiplied by five. The current wind rate, for example, assuming prevailing wage and apprenticeship compliance, is $27.50 per MWh.

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Funding mechanism: Production tax credit

Technology grouping: Electricity

Eligibility: Technology-neutral tax credit for production of clean electricity. The §45Y PTC is for facilities generating electricity for which the greenhouse gas emissions rate is not greater than zero

U.S. Code: 26 U.S. Code §45Y

Duration: 10 years

Period of availability: Projects placed in service beginning in 2025 are eligible for the credit. The credit is subject to a four-year phase-out (100%, 75%, 50%, 0%) for projects that begin construction in the first calendar year after the ”applicable year,” which is the later of (1) 2032 or (2) the calendar year in which the IRS determines that the annual greenhouse gas emissions from the production of electricity in the U.S. are equal to or less than 25% of the annual greenhouse gas emissions from the production of electricity in the U.S. in 2022.

Below is an example phase-out schedule, assuming the "applicable year" is 2032. An eligible project that begins construction in 2035 and meets PWA requirements will generate §45Y PTCs worth $13.75 per MWh when it is placed in service

Inflation adjustment: Subject to annual inflation adjustment factor

Stackability and limitations:

• Cannot be stacked with §48E or §45Q

Elective pay (direct pay): Tax-exempt entities

Rates:

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Funding mechanism: Investment tax credit

Technology grouping: Electricity

Eligibility: Fuel cell, solar, geothermal, small wind, energy storage, biogas, microgrid controllers, and combined heat and power properties

U.S. Code: 26 U.S. Code §48

Duration: 1 year

Period of availability: Projects must begin construction in 2023 or 2024. For projects placed in service in 2025 or later, the §48E ITC will replace the §48 ITC

Inflation adjustment: Not applicable

Stackability and limitations:

• Low-income bonus is limited to projects less than 5 MW

Elective pay (direct pay): Tax-exempt entities

Rates:

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Funding mechanism: Investment tax credit

Technology grouping: Electricity

Eligibility: Technology-neutral tax credit for investment in facilities generating electricity for which the greenhouse gas emissions rate is not greater than zero‍

U.S. Code: 26 U.S. Code §48E‍

Duration: 1 year‍

Period of availability: Projects placed in service beginning in 2025 are eligible for the credit. The credit is subject to a four-year phase-out (100%, 75%, 50%, 0%) for projects that begin construction in the first calendar year after the ”applicable year,” which is the later of (1) 2032 or (2) the calendar year in which the IRS determines that the annual greenhouse gas emissions from the production of electricity in the U.S. are equal to or less than 25% of the annual greenhouse gas emissions from the production of electricity in the U.S. in 2022.

Below is an example phase-out schedule, assuming the "applicable year" is 2032. An eligible project that begins construction in 2034 and meets PWA requirements will generate a §48E ITC worth 22.5% of the project’s qualified investment when it is placed in service

Inflation adjustment: Not applicable

Stackability and limitations:

• Low-income bonus is limited to projects less than 5 MW
• Cannot be stacked with §45Y, §48C, or §45Q

Elective pay (direct pay): Tax-exempt entities

Rates:

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Funding mechanism: Investment tax credit

Technology grouping: Vehicles

Eligibility: For clean-burning fuels, as defined in the statute. Alternative fuels include electricity (recharging property), ethanol, natural gas, liquified petroleum gas, hydrogen, and biodiesel

U.S. Code: 26 U.S. Code §30C‍

Duration: 1 year

Period of availability: Project must be placed in service between 1/1/2023 and 12/31/2032

Inflation adjustment: Not applicable

Stackability and limitations:‍

• The project must be located in a low-income or rural area
• The credit is capped at $100,000 per property

Elective pay (direct pay): Tax-exempt entities

Rates

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Funding mechanism: Production tax credit

Technology grouping: Electricity

Eligibility: The §45U PTC is for electricity from qualified nuclear power facilities

U.S. Code: 26 U.S. Code §45U

Duration: 9 years

Period of availability: Available for electricity produced and sold after 12/31/2023, in tax years beginning after that date. Not available for tax years beginning after 12/31/2032

Stackability and limitations:

• ‍‍Cannot claim §45J credit
• Credit amount phases down depending on the amount of energy produced and the gross receipts of the facility
• Payments from federal, state, or local zero-emission nuclear subsidies reduce the credit amount

Inflation adjustment: Subject to annual inflation adjustment factor

Elective pay (direct pay): Tax-exempt entities

Rates

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Funding mechanism: Production tax credit

Technology grouping: Electricity

Eligibility: The §45Q PTC is for carbon dioxide sequestration coupled with permitted end uses within the U.S.

U.S. Code: 26 U.S. Code §45Q

Duration: 12 years

Period of availability: Facilities must be placed in service prior to 2033‍

Stackability and limitations: 

• The credit is limited to U.S. facilities within minimum volumes: (1) 1,000 metric tons of CO2 per year for direct air capture (DAC) facilities; (2) 18,750 metric tons for electricity-generating facilities with carbon capture capacity of 75% of baseline CO2 production; (3) 12,500 metric tons for any other facility
• Cannot be stacked with §45V, §45Z, §48C, or §48E

Inflation adjustment: Subject to annual inflation adjustment factor

Elective pay (direct pay): Tax-exempt entities. Taxable entities for up to five years

Rates:

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Funding mechanism: Production tax credit

Technology grouping: Fuels

Eligibility: The §45Z PTC is for the domestic production of clean transportation fuels, including sustainable aviation fuels. Fuels with less than 50 kilograms of carbon dioxide equivalent per one million British thermal units (CO2e per mmBTU) qualify as clean fuels eligible for credits

U.S. Code: 26 U.S. Code §45Z

Duration: 3 years‍

Period of availability: Available for fuels produced after 2024 and used or sold before 2028‍

Stackability and limitations: 

• Producers must be registered as a producer of clean fuel under 26 U.S. Code §4101‍
• Fuels must be produced in the U.S.
• Fuels must be sold to an unrelated this person
• To be considered "clean," fuels must emit no more than 50 kilograms of carbon dioxide equivalent per one million British thermal units (CO2e per mmBTU)
• "Transportation fuels" must be deemed "suitable for use as a fuel in a highway vehicle or aircraft"
• Cannot be stacked with §45V or §45Q

‍Inflation adjustment: Subject to an annual inflation adjustment factor after 2024

Elective pay (direct pay): Tax-exempt entities

Rates:

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The Congressional Research Service (CRS) has estimated clean fuel values by emission factor.

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Funding mechanism: Production tax credit

Technology grouping: Fuels

Eligibility: The §45V PTC is for the production of clean hydrogen at a qualified clean hydrogen facility

U.S. Code: 26 U.S. Code §45V

Duration: 10 years

Period of availability: Credit is for hydrogen produced after 12/31/22. Credit is available for facilities placed in service before 1/1/33

Stackability and limitations:

• Producers must be in the U.S.
• The project developer can make a non-irrevocable election for an ITC (instead of the §45V PTC) as long as the project has not claimed the §45Q PTC for carbon sequestration
• Cannot be stacked with §45Q, §45Z, or §48C

Inflation adjustment: Subject to an annual inflation adjustment factor

Elective pay (direct pay): Tax-exempt entities. Taxable entities for up to five years

Rates:

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Funding mechanism: Investment tax credit

Technology grouping: Manufacturing

Eligibility: For investments in advanced energy projects, as defined in §48C(c)(1) – a project that (1) re-equips, expands, or establishes an industrial or manufacturing facility for the production or recycling of a range of clean energy equipment and vehicles; (2) re-equips an industrial or manufacturing facility with equipment designed to reduce greenhouse gas emissions by at least 20 percent; or (3) re-equips, expands, or establishes an industrial facility for the processing, refining, or recycling of critical materials

U.S. Code: 26 U.S. Code §48C

Duration: 1 year

Period of availability: §48C is an allocated credit. It is available when the application and certification process begins and ends when the credit is fully allocated. Projects must be placed in service within two years of application approval and certification‍

Stackability and limitations:

• Allocated credit subject to $10 billion cap. At least $4 billion must be allocated to energy communities
• Cannot be stacked with §45X, §48, §48E, §45Q, or §45V

Inflation adjustment: Not applicable‍

Elective pay (direct pay): Tax-exempt entities

Rates:

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Funding mechanism: Production tax credit

Technology grouping: Manufacturing

Eligibility: The §45X PTC is for domestic manufacturing of components for solar and wind energy, inverters, battery components, and critical minerals

U.S. Code: 26 U.S. Code §45X

Duration: 10 years

Period of availability: Credit for critical materials is permanent starting in 2023. For other components, credit is subject to a phase-out beginning in 2030 (75%, 50%, 25%, 0%)

Stackability and limitations:

• Producers must be in the U.S.
• Property must be sold to an unrelated party
• Cannot claim §45X credit for property produced at facilities that received the §48C credit
• Credit is subject to a phase-out beginning in 2030 (75%, 50%, 25%, 0%), except for critical minerals

Inflation adjustment: Although §45X is a PTC, the credit is not inflation-adjusted

Elective pay (direct pay): Tax-exempt entities. Taxable entities for up to five years

Rates: Rates for the §45X PTC are component-specific

Introduction

Andy Moon, Co-Founder and CEO of Reunion, joined Shannon Holzer, Joey Lange, and Matt Donath of Edison Energy for an hour-long panel, "Powering Progress: An Overview of Policy Trends Shaping the North American Renewable Energy Landscape," on August 22, 2023. The panel provided a transferability overview, market update, and several policy insights, and concluded with audience Q&A.

Video recording and slides

We invite you to view the recording and download the panel's presentation.

Transcript of Andy's presentation

Overview of Reunion

Andy Moon: I'll start with a very brief introduction on Reunion. We're a marketplace that facilitates the purchase and sale of tax credits from clean energy projects. We currently have over $2 billion in near-term credits from leading clean energy developers available on our platform. We work closely with corporate finance teams to identify high quality projects and ensure a low-risk transaction. Our company was formed in the wake of the IRA, but our team has spent over 40 years in clean energy finance. We have a lot of experience both in tax equity as well as private finance.

Transferable tax credits will transform the way clean energy projects are financed

Andy Moon: When the Inflation Reduction Act passed, we saw a large opportunity in the transferability clause because financing has always been a major challenge for clean energy product developers. Transferability provides a much simpler and more streamlined structure, and tax credits from many technologies can now be transferred. In addition to solar, wind, and battery storage; now biogas, nuclear, manufacturing, and hydrogen projects can be transferred. There's a whole slew of tax credits that are available to be transferred. Historically, tax credit monetization has been dominated by tax equity, which is controlled by a handful of large banks. So, a major goal of transferability is to broaden the pool of investors that are investing in the energy transition. Any corporation that pays US federal tax can now be an investor in clean energy projects.

Corporations are paying attention to clean energy tax credits, given the volume of tax credits and the length of the program

Andy Moon: There's a lot of momentum that we're feeling right now from CFOs and tax teams from companies because the opportunity is large. The chart is from CohnReznick, which shows that the demand for tax credit monetization will reach $70, $80, or $90 billion annually in just a few years.

Andy Moon: And tax credit supply is hovering around the $20 billion range. There's just really a lot of demand for additional investors to come support clean energy projects. The other item is that, as many people here know, ITCs and other incentive programs have been extended piecemeal on a three- or five-year basis. And the Inflation Reduction Act is a long-term program. At the earliest, it will go to 2034. But many observers believe that because tax credits are uncapped until certain emission targets are reached, this program could last 20 or 30 plus years.

Treasury guidance from June 2023 provided certainty to transact

Andy Moon: As Shannon mentioned – just to highlight how new this market is – Treasury released guidance on June 14th, and that is really unlocked a lot of interest from corporate buyers. I think there was always the fear that potentially guidance would come with some unwelcomes surprises, but that certainly was not the case. Transferability, the mechanism, was explained quite clearly over a 108 pages. I think the biggest win is just having a clear sense of the mechanism by which how tax credits can be transferred. There were also some important economic clarifications to the positive side. So one is that tax credits that are purchased can be used to offset quarterly estimated tax payments, which greatly improves the return profile of the investment. And Treasury also clarified that if you buy a tax credit at a discount, so say you buy one dollar tax credit for 92 cents, that eight-cent discount is not taxable. We can go over any questions about the mechanisms in the Q&A, but just in brief – the way it works is the seller of the credit will be required to pre-register their project on an IRS platform and get a pre-registration number. Both the buyer and the seller need to attach a transfer election form when they file their tax reasons.

Purchasing credits is a simple process that drives tangible benefits

Andy Moon: I'll quickly go through a simple example for how a tax credit transfer will work. So if a corporation has, say, $50 million in tax liabilities, they could purchase tax credits from a clean energy developer or through a platform such as Reunion at a discount. And this discount is typically in the 7% to 10% range, but it really depends on a number of factors. So, assume that they pay $45 million in cash, they would then be able to offset $50 million of their federal tax liabilities. And given that the tax credit can now be used to offset quarterly tax payments, this is a big boon for IRR-driven investors, because that means that the effective IRR will be quite compelling.

Buyers face several manageable risks, which can be mitigated through due diligence, seller indemnity, and insurance

Andy Moon: I'll talk a little bit about the risks to be aware of when investing in a tax credit. In general, buyers do need to conduct due diligence on these projects to mitigate the risk that a tax credit is challenged by the IRS. That said, the diligence checklist is much narrower than a tax equity investment because you are just buying a tax credit. You are not making a true equity investment into the project. There are specific categories of diligence that need to be checked. In some instances, you are ensuring the project was actually constructed and connected to the grid, ensuring that the cost basis of the project is properly calculated in the case of an investment tax credit, and really ensuring that some of the bonus credit adders have properly been incorporated.

Beyond due diligence, sellers generally sign a broad indemnity, promising that if the tax credit is recaptured or reduced for any reason, the buyer will be made whole. However, if the buyer needs assurance that if the IRS successfully challenges the tax credit and the seller does not make good on their indemnity, tax credit and insurance is also available to ensure that the buyer doesn't realize a loss. In the future, we also think that diversification of projects will also be an important mitigator of risk.

Observations on current and future market

Andy Moon: Everybody wants to know about price, so I'll give some general observations on what we're seeing in the market. In 2023, which we're already at the end of August, I'd say buyers are very focused on a narrow set of projects. They tend to look for projects that are from very experienced developers that have financial strength behind them. They look for projects, generally with scale, that have proven technologies such as solar, wind and battery storage. And these are generally trading in a fairly narrow band. We're seeing these 2023 credits trade in the $0.90 to $0.92 range to the developer after all expenses.

Now, of course, there are a number of factors that can further impact the price for 2023 projects. One is product size. So, if the project size is small – say, a $5 to $10 million transaction – we're seeing buyers want a larger discount for those small projects just because this is a new asset class and there's a lot of diligence and new education that's required to do a project. So a lower price is required to motivate buyers to the table. Technology – I think there's a smaller pool of buyers for newer technologies. So, even biogas carries a bit of a larger discount, and it remains to be seen where pricing will settle for new technologies such as hydrogen or carbon capture. And then project risk is another piece. Projects that have items like large step-up in cost basis or that have large debt attached to the project can also carry a larger discount.

Production tax credits that are traded spot. 2023 spot credits trade at a narrower discount because there is not the risk of recapture or reduction in credits because those credits are typically sold after they're generated. For 2024 and beyond, conventional wisdom has been that prices on credits will eventually narrow and the discount will narrow over time. However, we are seeing that there's going to be massive influx of credits in 2024 and beyond. We have many projects such as nuclear, solar, and wind, and all these other credit categories that will be competing for the same tax credit buyers. I think the impact on price in 2024 and beyond really does remain to be seen.

We're seeing a lot of developers that have projects that will be constructed in late 2024 or in 2025 who are looking for a commitment from a buyer today to buy the credits when the project is completed. These forward commitments do generally carry a larger discount. The reason why a developer wants the forward commitment is because they want to be able to take that piece of paper to a bank and get a bridge loan against a forward commitment to buy credits in the future. So, that's another example of where buyers can achieve a larger discount and a higher return is by committing to a forward commitment in advance.

Reunion's digital platform has $2B+ in near-term tax credits from leading clean energy developers

Andy Moon: As I mentioned, Reunion launched our digital platform last month. We already have over $2 billion in near-term credits available for transaction with leading clean energy developers. We work very closely with tax credit buyers to really ensure a low risk and streamlined transaction process. If this sounds of interest, we love to talk and answer questions. We do realize that this is new for many people. And so a lot of our job today is really to answer questions and really make sure that buyers and sellers both understand exactly how the process works and feel comfortable with these transactions.