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U.S. manufacturers are racing to get into the game while they still can.
In the weird, wide world of energy storage, lithium-ion batteries may appear to be an unshakeably dominant technology. Costs have declined about 97% over the past three decades, grid-scale battery storage is forecast to grow faster than wind or solar in the U.S. in the coming decade, and the global lithium-ion supply chain is far outpacing demand, according to BloombergNEF.
That supply chain, however, is dominated by Chinese manufacturing. According to the International Energy Agency, China controls well over half the world’s lithium processing, nearly 85% of global battery cell production capacity, and the lion’s share of actual lithium-ion battery production. Any country creating products using lithium-ion batteries, including the U.S., is at this point dependent on Chinese imports.
This has, understandably, sent U.S. manufactures searching for alternatives, and lately they have struck on one that has the industry all excited: sodium-ion batteries. As global interest ramps up, domestic manufacturers have at least a prayer of building out their own sodium-ion supply chains before China completely takes over. Research and consulting firm Benchmark Mineral Intelligence expects to see a 350% jump in announced sodium-ion battery manufacturing capacity this year alone. And while the supply of these batteries is only in the tens of gigawatts today, Benchmark forecasts that it will be in the hundreds of gigawatts by 2030.
Sodium-ion technology itself isn’t particularly disruptive — it’s not new, nor does it serve a new market, exactly. It performs roughly the same as lithium-ion in energy storage systems, providing around four hours of power for either grid-scale or residential applications. But sodium-ion chemistries have a handful of key advantages — perhaps most critically that sodium is significantly more abundant in the U.S. than lithium, and is thus far cheaper. China has unsurprisingly taken an early lead in the sodium-ion market anyway, reportedly opening its first sodium-ion battery storage station in May. But because the industry is still so nascent, domestic manufacturers say there’s still time for them to get in the game.
“We’re focused on catching up to China in lithium-ion batteries, where in our view, we should be leapfrogging to what’s next,” Cam Dales, co-founder and chief commercial officer at Peak Energy, a Bay Area-based sodium-ion battery storage startup, told me. “There’s no CATL of the United States. That’s ultimately our ambition, is to become that.”
As political tensions between China and the U.S. mount, relying on a Chinese-dominated battery supply chain is geopolitically risky. Last month, the Biden administration announced a steep increase in tariffs on a wide array of Chinese imports, including a 25% tariff on lithium-ion non-electric vehicle batteries starting in 2026, and another 25% tariff on battery parts and certain critical minerals starting this year.
Because sodium is so plentiful and cheap, companies in the space estimate that sodium-ion storage systems could eventually be around 40% less expensive than lithium-ion systems, once manufacturing scales. This lower price point could eventually make sodium-ion economically viable for storage applications “up to eight, 10, maybe even 12 hours,” Dales told me.
Sodium-ion also has a leg up on lithium-ion when it comes to safety. While this is an ongoing area of research, so far sodium-ion batteries appear less likely to catch fire, at least in part because of their lower energy density and the fact that their electrolytes generally have a higher flashpoint, the temperature at which the liquid is capable of igniting. This could make them safer to install indoors or pack close together. It’s also possible to discharge sodium-ion batteries down to zero volts, completely eliminating the possibility of battery fires during transit, whereas lithium-ion can’t be completely discharged without ruining the battery. Finally, sodium-ion performs better in the cold than lithium-ion batteries, which notoriously struggle to charge and discharge as efficiently at low temperatures.
“When we saw announcements coming out of China about very large investments in large capacity sodium projects, that was really an eye opener for us,” Dales told me. He and co-founder Landon Mossburg launched Peak Energy last year with $10 million in funding. The company is currently importing sodium-ion cells and assembling battery packs domestically, but by 2027, Dales said he hopes to produce both cells and packs in the U.S., with an eye toward opening a gigafactory and onshoring the entirety of the supply chain.
He’s not alone in this ambition. Natron Energy, another Silicon Valley-based sodium-ion company, has been at this for more than a decade. The startup, founded in 2012, recently opened the first commercial-scale sodium-ion battery manufacturing facility in the U.S. When fully ramped, the plant will have the capacity to produce 600 megawatts of batteries annually, paving the way for future gigawatt-scale facilities.
It cost Natron over $40 million to upgrade the Michigan-based plant, which formerly produced lithium-ion batteries, into a sodium-ion facility, and while the first shipments were expected to begin in June, none have yet been announced. The company’s backers include Khosla Ventures as well as strategic investors such as Chevron, which is interested in using this tech at EV charging stations; United Airlines, which hopes to use it for charging motorized ground equipment; and Nabor Industries, one of the world’s largest oil and gas drilling companies, which is interested in using sodium-ion batteries to power drilling rigs. It also received nearly $20 million from ARPA-E to fund the conversion of the Michigan facility.
Beyond the U.S. and China, France-based sodium-ion cell developer Tiamat is planning to build out a massive 5-gigawatt facility, while Sweden-based Northvolt and UK-based Faradion are also hoping to bring sodium-ion battery manufacturing to the European market.
Sodium-ion isn’t a magic bullet technology, though, and it certainly won’t make sense for all applications. The main reason there hasn’t been much interest up until now is because these batteries are about 30% less energy-dense than their lithium-ion counterparts. That likely doesn’t matter too much for grid-scale or even residential storage systems, where there’s usually enough open land, garage, or exterior wall space to install a sufficiently-sized system. But it is the reason why sodium-ion wasn’t commercialized sooner, as lithium-ion’s space efficiency is better suited to the portable electronics and electric vehicle markets.
“It’s only in the last two years probably, that the stationary storage market has gotten big enough where it alone can drive specific chemistries and the investment required to scale them,” Dales told me.
Catherine Peake, an analyst at Benchmark Mineral Intelligence, also told me that lithium iron phosphate batteries — the specific flavor of lithium-ion that’s generally favored for energy storage systems — usually have a longer cycle life than sodium-ion batteries, meaning they can charge and discharge more times before performance degrades. “That cycle life is actually a pretty key metric for [energy storage system] applications,” she said, though she acknowledged that Natron is an outlier in this regard, as the company claims to have a longer cycle life than standard lithium-ion batteries.
Lithium is also a volatile market. Though prices have bottomed out recently, less than two years ago the world was facing the opposite scenario, as China saw the price for battery-grade lithium carbonate hit an all-time high, Kevin Shang, a senior research analyst at the energy consultancy WoodMackenzie, told me. “So this catalyzed a soaring interest in sodium-ion batteries,” he said.
Although Shang and Peake agree that the U.S. could seize this moment to build a domestic sodium-ion supply chain, both also said that scaling production up to the level of China or other battery giants like South Korea or Japan is a longshot. “After all, they have been doing this battery-related business for over 10 years. They have more experience in scaling up these materials, in scaling up these technologies,” Shang told me.
These countries are home to the world’s largest battery manufacturers, with CATL and BYD in China and LG Energy in South Korea. But Natron and Peak Energy are both startups, lacking the billions that would allow for massive scale-up, at least in the short term.
“It shouldn't be underestimated how hard it is to make anything in large volume,” Matt Stock, a product director at Benchmark, told me. Largely due to the maturity of lithium-ion battery supply chains, the research firm doesn’t see sodium-ion becoming the dominant energy storage tech anytime soon. Rather, by 2030, Benchmark forecasts that sodium-ion batteries will comprise 5% of the battery energy storage market, increasing to over 10% by 2040. BloombergNEF is somewhat more optimistic, predicting sodium-ion will make up 12% of the stationary energy storage market by 2030.
And while storage may be the most obvious near-term use case for sodium-ion batteries, it’s certainly not the only industry that stands to benefit. China is experimenting with using these batteries in two- and three-wheeled vehicles such as electric scooters, bikes, and motorcycles. And as the tech improves, Stock said it’s possible that sodium-ion batteries could become a viable option for longer-range EVs as well.
Ultimately, Dales thinks these batteries will follow a similar technological trajectory to lithium iron phosphate, a chemistry that many in the west thought would never be suitable for use in electric vehicle batteries. “Over time, our view is that sodium-ion will continue to increase its energy density just like [lithium iron phosphate] did,” Dales told me. Now, lithium iron phosphate is the dominant battery chemistry for Chinese-made EVs. “But what actually happened was it was so cheap and they made it better and better and better than now it’s taking over the world. We see this playing out again with sodium-ion.”
Benchmark, on the other hand, is more circumspect regarding sodium-ion’s world dominating potential. Stock said he sees the technology more as a supplement to lithium-ion, which can swoop in when lithium prices boom or critical minerals shortages hit. “When that happens, something like sodium-ion can fill the space. And that’s really where it’s a complementary technology rather than a replacement,” he told me. “If there were other technologies as mature as sodium-ion, we’d also see those being scaled alongside it, but sodium-ion is kind of next in line.”
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Ambient Carbon is doing the methane equivalent of point source carbon capture in dairy barns.
In the world of climate and energy, “emissions” is often shorthand for carbon dioxide, the most abundant anthropogenic greenhouse gas in the world. Similarly, talk of emissions capture and removal usually centers on the growing swath of technologies that either prevent CO2 from entering the atmosphere or pull it back out after the fact.
Discussions and frameworks for reducing methane, which is magnitudes more potent than CO2 in the short-term, have been far less common — but the potential impact could be huge.
“If you can accelerate the decrease of methane in the atmosphere, you actually could have a much more significant climate impact, much faster than with CO2,” Gabrielle Dreyfus, chief scientist at the Institute for Governance & Sustainable Development, told me. “People often talk about gigatons of CO2 removal. But because of the potency of methane, for a similar level of temperature impact, you’re talking about megatons.”
Over the past year or so, this conversation has finally started to gain traction. Last October, the National Academies of Sciences, Engineering, and Medicine released a report on atmospheric methane removal, recommending that the U.S. develop a research agenda for methane removal technologies and establish methodologies to assess their impacts. Dreyfus chaired the committee that authored the report.
And one startup, at least — Denmark-based Ambient Carbon — is trying to commercialize its methane-zapping tech. Last week, the company announced that it had successfully trialed its “methane eradication photochemical system” at a dairy barn in Denmark, eliminating the majority of methane from the barn’s air. It’s also aiming to deploy a prototype in the U.S., at a farm in Indiana, by year’s end.
The way the company’s process works is more akin to point source carbon capture, in which emissions are pulled from a smokestack, than it is to something like direct air capture, in which carbon dioxide is removed from ambient air. Inside a dairy barn, cows are continually belching methane, producing high concentrations of the gas that are typically vented into the atmosphere. Instead, Ambient Carbon captures this noxious air from the barn’s ventilation ducts and brings it into an enclosed reactor.
Inside the reactor, which uses electricity from the grid, UV light activates chlorine molecules, splitting their chemical bonds to form unstable radicals. These radicals then react with methane, breaking down the potent gas and converting it into CO2, water, and other byproducts. The whole process mimics the natural destruction of atmospheric methane, which would normally take a decade or more, while Ambient Carbon’s system does it in a matter of seconds. Much of the chlorine gets recycled back into the process, and the CO2 is released into the air.
That might sound less than ideal. Famously, carbon dioxide is bad. This molecule alone is responsible for two-thirds of all human-caused global warming. But because methane is over 80 times as potent as CO2 over a 20-year timeframe, and since it would eventually break down into carbon dioxide in the atmosphere anyway, accelerating that inevitable process turns out to be a net good for the climate.
“The amount of CO2 produced by methane when it oxidizes has about 50 times smaller climate effect than the methane that produced it,” Zeke Hausfather, a climate scientist and climate research lead at Stripe, told me. “So you get a 98% reduction in the warming effects by converting methane to CO2, which I think is a pretty good deal.”
As he sees it, preventing methane emissions in the first place or destroying the molecules before they’re released, as Ambient Carbon is doing, is far more impactful than pursuing after-the-fact atmospheric methane removal. Because while CO2 can linger in the air for centuries — making removal a necessity for near-term planetary cooling — when it comes to methane, “if you cut emissions, you cool the planet pretty quickly, because all that previous warming from methane goes away over the course of a decade or two.”
Agriculture represents 40% of global methane emissions, the largest single source, making the industry a ripe target for de-methane-ization. Ambient Carbon’s tech is only really effective when methane concentrations are relatively high, the company’s CEO, Matthew Johnson, told me — which still leaves a large addressable market given that in many parts of the world, cows are mostly kept in dairy barns, where methane accumulates.
In its trial, Ambient Carbon’s system eliminated up to 90% of dairy barn methane at concentrations ranging from 4.3 parts per million to 44 parts per million. But while the system can theoretically operate at the lower end of that range, Johnson told me it’s only truly energy efficient at 20 parts per million and above. “It’s a question of cost benefit, because we could remove 99% [of the methane from dairy barns] but if you do that, that marginal cost is more energy,” Johnson explained, telling me that the company’s system will likely aim to remove between 80% to 90% of barn methane.
One reason methane destruction and removal technology hasn’t gained much traction is that capturing methane — whether from the atmosphere, a smokestack, or a ventilation duct — is far more challenging than capturing CO2, given that it’s so much less prevalent in the atmosphere. Atmospheric methane is relatively diffuse, with an average concentration of just about 2 parts per million, compared with roughly 420 parts per million for CO2. “I heard the analogy used that if pulling carbon dioxide out of the atmosphere is finding a needle in a haystack, pulling methane out of the atmosphere is pulling dust off the needle in that haystack,” Dreyfus told me.
Because of methane’s relative chemical stability, removing it from the air also requires a strong oxidant, such as chlorine radicals, to break it down. CO2 on the other hand, can be separated from the air with sorbents or membranes, which is a technically simpler process.
Other nascent approaches to methane destruction and removal include introducing chlorine radicals into the open atmosphere and adding soil amendments to boost the effectiveness of natural methane sinks. Among these options, Ambient Carbon’s approach is the furthest along, most well-understood, and likely also lowest-risk. After its successful field trial, “there is not much uncertainty remaining about whether or not this does the claimed thing,” Sam Abernethy, a methane removal scientist at the nonprofit Spark Climate Solutions, told me. “The main questions remaining are whether they can be cost-effective at progressively lower concentrations, whether they can get more methane destroyed per energy input. And that’s something they’ve been improving every year since they started.”
Venture firms have yet to jump onboard though. Thus far, Ambient Carbon’s funding has come from agricultural partners such as Danone North America and Benton Group Dairies, which are working with the company to conduct its field trials. Additional collaboration and financial support comes from organizations such as the Hofmansgave Foundation, a Danish philanthropic group, and Innovation Fund Denmark. Johnson told me the startup also has a number of unnamed angel investors.
Whether or not this tech could ever become efficient enough to tackle more dilute methane emissions — and thus make true atmospheric methane removal feasible — remains highly uncertain. Questions also remain about how these technologies, if proven to be workable, would ultimately be able to scale. For instance, would methane destruction and removal depend more on government policies and regulations, or on market-based incentives?
In the short term, voluntary corporate commitments appear to be the main drivers of interest when it comes to methane destruction specifically. “A lot of food companies have made public pledges that they’re going to reduce their greenhouse gas emissions,” Johnson told me. As he noted, ubiquitous brands such as Kraft Heinz, General Mills, Danone, and Starbucks have all joined the Dairy Methane Action Alliance, which aims to “accelerate action and ambition to drive down methane emissions across dairy supply chains,” according to its website.
The way Ambient Carbon envisions this market working, its food industry partners would be the ones to encourage farms to buy the startup’s methane-destroying units, and would pay farmers a premium for producing low-emissions products. This would enable farmers to cover the system’s cost within five years, and eventually generate additional revenue. Whether the food companies would pass the green premium onto consumers, however, remains to be seen.
But as with the carbon dioxide removal sector, voluntary corporate commitments and carbon crediting schemes will likely only go so far. “Most of what’s going to drive methane elimination is going to be policy,” Hausfather told me. Denmark, where Ambient Carbon conducted its first trial, is set to become the first country in the world to implement a tax on agricultural emissions, starting in 2030. Europe also has a comprehensive greenhouse gas reduction framework, as do states such as California, Washington, and New York.
“It’s such a low-hanging fruit of climate impacts that it’s hard to imagine it’s not going to be regulated pretty substantially in the future,” Hausfather told me. But stringent regulatory requirements are often shaped by the technologies that have been established as effective. And in that sense, what Ambient Carbon is doing today could help pave the way for the ambitious methane targets of tomorrow.
“Moving from a lot of the voluntary pledges that we have towards more mandatory requirements I think is going to have a really important role to play,” Dreyfus told me. “But I think it’s going to be easier if we have more proven technologies to get there.”
On tax credit deadlines, America’s nuclear export hopes, and data center flexibility
Current conditions: Hurricane Erin’s riptides continue lashing the Atlantic Coast, bringing 15-foot waves to the eastern end of New York’s Long Island • In Colorado, the Derby fire tripled in size to more than 2,600 acres, prompting evacuations in the county north of the ski enclave of Aspen • Heavy rain in Sydney set a new 18-year record.
Trump is preparing to onshore turbines, likely shrinking their numbers. Scott Olson/Getty Images
The Trump administration launched an investigation into imported wind turbines and parts, teeing up what Bloomberg called a “potential precursor to adding more tariffs on the clean-energy components.” The Department of Commerce started a national security probe on August 13 to query whether the imports undermine domestic production and put the country at risk from foreign opponents, according to a notice posted Thursday on the agency’s website. The agency already said this week that it would include wind turbines and related parts on the list of products facing 50% steel and aluminum tariffs. As of 2023, at least 41% of wind-related equipment to the U.S. came from Mexico, Canada, and China, according to figures Bloomberg cited from the consultancy Wood Mackenzie.
Also on Thursday, the Treasury Department published an FAQ document outlining the phaseout dates for eight key energy efficiency tax credits repealed under the One Big Beautiful Bill Act. The rules all deal with zero-carbon vehicles or energy efficiency rebates for home improvements.
As Heatmap’s Emily Pontecorvo and Robinson Meyer wrote when the first tranche of data on the programs came out around this time last year, millions of Americans had already taken advantage of at least one of the credits. But the uptake was largely concentrated among households earning $100,000 per year or more.
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For years, Westinghouse has been locked in an intellectual property dispute with South Korea’s two state-owned nuclear companies, as the American atomic energy giant accused the Korea Electric Power Corporation and its subsidiary, Korea Hydro & Nuclear Power, of ripping off its reactor technology. This week, the companies brokered a settlement that would keep the Korean giants from bidding on projects in North America, Europe, Japan, the United Kingdom, and Ukraine, effectively eliminating what is arguably the United States’ most capable rival outside of Russia and China from the key markets Washington wants to dominate. That could spur a lot more bids for Westinghouse’s flagship gigawatt-sized AP1000 reactor, projects for which are already underway in Poland, Slovakia, and Ukraine. But KoreaPro reported on Thursday that South Korea is pushing back on a deal Seoul fears infringes on its sovereignty.
In Sweden, meanwhile, the U.S.-Japanese joint venture GE Vernova-Hitachi Nuclear Energy secured a new deal to build its 300-megawatt small modular reactor that the government in Stockholm explicitly pitched as a bid to strengthen its trans-Atlantic security ties. “This is the beginning of something bigger, in many ways,” Ebba Busch, Sweden’s deputy prime minister, wrote in a post on LinkedIn. “As in the NATO process, Sweden is part of a larger movement.”
The Department of Energy extended its emergency order directing the J.H. Campbell Generating Plant in Michigan to remain open past its planned retirement. Secretary of Energy Chris Wright initially ordered the 1,420-megawatt coal station to stay online three months past its May 31 shutdown date, citing risks of electricity shortages in the Midcontinent Independent System Operator, the electrical grid that runs from the Upper Midwest down to Louisiana. Starting Thursday, the latest order directs the plant’s owners to keep the station running November 19. The consultancy Grid Strategies estimated last week that if the Trump administration expands the effort to cover all 54 aging fossil fuel plants slated for closure between now and 2028, the program will cost upward of $6 billion. Last week, the Federal Energy Regulatory Commission approved a framework for the utilities that own the affected plants to recoup the costs of operating the power stations past the closure dates from ratepayers, despite surging electricity prices.
The Data Center Coalition, a leading trade association representing the burgeoning server farm industry, has endorsed adopting programs to curb electricity demand when the grid is under stress. In a filing Thursday with the North Carolina Utility Commission, the industry group said it “supports exploring well-structured, voluntary demand-response and load flexibility programs for large load customers that allocates risk appropriately, provides clear incentives and compensation, and allows customers to meet their sustainability commitments.”
Researchers at Duke University put out an influential paper in February that found the U.S. could add gigawatts of additional demand from new data centers without building out an equivalent amount of generating plants if those facilities could curtail power usage when demand was particularly high. Heatmap’s Matthew Zeitlin described the strategy as “one weird trick for getting more data centers on the grid,” boiling down the approach simply as: “Just turn them off sometimes.” When I interviewed Tyler Norris, the study’s lead author, he pitched the idea as a way “to buy us some time” to figure out exactly how much electricity the artificial intelligence boom requires before we build out a bunch of gas plants that are even more expensive than usual due to the years-long backorder of turbines.
Researchers at the University of Houston claim to have made two major breakthroughs in carbon capture technology. The first breakthrough, published in the journal Nature Communications, introduces a new electrochemical process for filtering out carbon dioxide that avoids using a membrane like traditional carbon capture technology. The second, featured on the cover of the journal ES&T Engineering, demonstrates a new vanadium-based flow battery that could be used both to capture carbon and to store renewable energy. “We need solutions, and we wanted to be part of the solution. The biggest suspect out there is CO2 emissions, so the low-hanging fruit would be to eliminate those emissions,” Mim Rahimi, a professor at the University of Houston’s Cullen College of Engineering, said in a statement. “From membraneless systems to scalable flow systems, we’re charting pathways to decarbonize hard-to-abate sectors and support the transition to a low-carbon economy.”
A conversation with Scott Cockerham of Latham and Watkins.
This week’s conversation is with Scott Cockerham, a partner with the law firm Latham and Watkins whose expertise I sought to help me best understand the Treasury Department’s recent guidance on the federal solar and wind tax credits. We focused on something you’ve probably been thinking about a lot: how to qualify for the “start construction” part of the new tax regime, which is the primary hurdle for anyone still in the thicket of a fight with local opposition.
The following is our chat lightly edited for clarity. Enjoy.
So can you explain what we’re looking at here with the guidance and its approach to what it considers the beginning of construction?
One of the reasons for the guidance was a distinction in the final version of the bill that treated wind and solar differently for purposes of tax credit phase-outs. They landed on those types of assets being placed in service by the end of 2027, or construction having to begin within 12 months of enactment – by July 4th, 2026. But as part of the final package, the Trump administration promised the House Freedom Caucus members they would tighten up what it means to ‘start construction’ for solar and wind assets in particular.
In terms of changes, probably the biggest difference is that for projects over 1.5 megawatts of output, you can no longer use a “5% safe harbor” to qualify projects. The 5% safe harbor was a construct in prior start of construction guidance saying you could begin construction by incurring 5% of your project cost. That will no longer be available for larger projects. Residential projects and other smaller solar projects will still have that available to them. But that is probably the biggest change.
The other avenue to start construction is called the “physical work test,” which requires the commencement of physical work of a significant nature. The work can either be performed on-site or it can be performed off-site by a vendor. The new guidance largely parrotted those rules from prior guidance and in many cases transferred the concepts word-for-word. So on the physical work side, not much changed.
Significantly, there’s another aspect of these rules that say you have to continue work once you start. It’s like asking if you really ran a race if you didn’t keep going to the finish line. Helpfully, the new guidance retains an old rule saying that you’re assumed to have worked continuously if you place in service within four calendar years after the year work began. So if you begin in 2025 you have until the end of 2029 to place in service without having to prove continuous work. There had been rumors about that four-year window being shortened, so the fact that it was retained is very helpful to project pipelines.
The other major point I’d highlight is that the effective date of the new guidance is September 2. There’s still a limited window between now and then to continue to access the old rules. This also provides greater certainty for developers who attempted to start construction under the old rules after July 4, 2025. They can be confident that what they did still works assuming it was consistent with the prior guidance.
On the construction start – what kinds of projects would’ve maybe opted to use the 5% cost metric before?
Generally speaking it has mostly been distributed generation and residential solar projects. On the utility scale side it had recently tended to be projects buying domestic modules where there might have been an angle to access the domestic content tax credit bonus as well.
For larger projects, the 5% test can be quite expensive. If you’re a 200-megawatt project, 5% of your project is not nothing – that actually can be quite high. I would say probably the majority of utility scale projects in recent years had relied on the manufacturing of transformers as the primary strategy.
So now that option is not available to utility scale projects anymore?
The domestic content bonus is still available, but prior to September 2 you can procure modules for a large project and potentially both begin construction and qualify for the domestic content bonus at the same time. Beginning September 2 the module procurement wouldn’t help that same project begin construction.
Okay, so help me understand what kinds of work will developers need to do in order to pass the physical work test here?
A lot of it is market-driven by preferences from tax equity investors and tax credit buyers and their tax counsel. Over the last 8 years or so transformer manufacturing has become quite popular. I expect that to continue to be an avenue people will pursue. Another avenue we see quite often is on-site physical work, so for a wind project for example that can involve digging foundations for your wind turbines, covering them with concrete slabs, and doing work for something called string roads – roads that go between your turbines primarily for operations and maintenance. On the solar side, it would be similar kinds of on-site work: foundation work, road work, driving piles, putting things up at the site.
One of the things that is more difficult about the physical work test as opposed to the 5% test is that it is subjective. I always tell people that more work is always better. In the first instance it’s likely up to whatever your financing party thinks is enough and that’s going to be a project-specific determination, typically.
Okay, and how much will permitting be a factor in passing the physical work test?
It depends. It can certainly affect on-site work if you don’t have access to the site yet. That is obviously problematic.
But it wouldn’t prevent you from doing an off-site physical work strategy. That would involve procuring a non-inventory item like a transformer for the project. So there are still different things you can do depending on the facts.
What’s your ultimate takeaway on the Treasury guidance overall?
It certainly makes beginning construction on wind and solar more difficult, but I think the overall reaction that I and others in the market have mostly had is that the guidance came out much better than people feared. There were a lot of rumors going around about things that could have been really problematic, but for the most part, other than the 5% test option going away, the sense is that not a whole lot changed. This is a positive result on the development side.