参议院版本的一项庞大且出色法案的快速解读

Quick takes from the Senateversion of the "One, Big, BeautifulBill" North America Clean TechnologyPOSITIVE Compared to the House version, we thought the languagewas modestly improved for utility-scale while unchanged forresidential solar. However, relative to investor expectationsinto today, the outcome is worse than expected as the marketwas hoping for something better across the board. North America Clean TechnologyChristine Cho, CFA+1 212 526 8419christine.cho@barclays.comBCI, US Thomas Roche, CFA, CPA+1 212 526 9750thomas.roche@barclays.comBCI, US Slight positive for 48E and 45Y from the House version; 45X for solar unchanged:The ITCand PTC credits for wind and solar will start phasing outafterthis year. For projects that startconstruction in 2026, projects will only receive 60% of the value of the credit. For projects thatstart construction in 2027, it will be 20% of the credit. There are no credits for projects that startin 2028. We view this as a slight net positive from the House version, which requiredconstruction to start within 60 days of enactment of the bill and completion of the project by12/31/28 in order to receive the 30% ITC/PTC. We viewed the prior 60 day timeline as prettypunitive requirement and today's version would allow several more months to startconstruction to receive the 30% ITC while also eliminating the COD requirements. It also doesallow the ability to be eligible for partial credit beyond this year whereas the prior version didnot. The ITC/PTC credits are extended for hydropower, nuclear and geothermal energy, withthese facilities receiving 100% of the credit through 2033 for start of construction, phasing downto zero by 2036. The 45X credits were untouched for solar, but will be eliminated for windafter12/31/27. Transferability also looked intact, although there is prohibition of transferability toprohibited foreign entities. Liam Duggan, CFA+1 212 526 5416liam.duggan@barclays.comBCI, US Residential exclusions remain for both cash/loan systems and leases:Section 25D will bephased out for projects that are placed into service 180 daysafterthe date of the enactment ofthe bill vs. the House version which required completion by 12/31/25. While we had thoughtthere was an opportunity for the credits tied to solar leasing to be extended beyond what wasdetailed in the House version, it does appear that the denial remains in place. The documentdoesn't explicitly detail the timeline, but the House version required the start of constructionwithin 60 days of enactment of the bill and completion by year-end. Closes the loophole for domestic content requirements this year for ITCs:We havepreviously written about a "typo" in prior regulatory documents that kept the necessarythreshold needed for domestic equipment at 40% (vs. increasing to 45% as it was originallyintended to go to) to be eligible for the domestic content adder. We did think that this wouldeventually get fixed and it does appear to be addressed in this version. For any projects that Barclays Capital Inc. and/or one of itsaffiliatesdoes and seeks to do business with companiescovered in its research reports. As a result, investors should be aware that the firm may have aconflict of interest that couldaffectthe objectivity of this report. Investors should consider thisreport as only a single factor in making their investment decision. Please see analyst certifications and important disclosures beginning on page 3.Completed: 17-Jun-25, 00:30 GMTReleased: 17-Jun-25, 00:31 GMTRestricted - External started construction prior to 6/16/25, the threshold is 40%. However, for projects that startconstruction between 6/16/25 and 12/31/2025, it is 45%. For projects that start construction incalendar 2026, it is 50% and 55% for all of calendar 2027. FEOC restrictions:On a headline basis, the House version of the budget was pretty punitivewith respect to the "material assistance" clause, which mostly banned the use of anyequipment with FEOC ties for any projects that started constructionafter1/1/26 if a projectwanted to be eligible for the 30% ITC credit. However, it was somewhat irrelevant and notapplicable as the same version of the bill dictated that there was no ability to be eligible for the30% ITC credit if a project started constructionafter1/1/26. As seen in the above paragraph,projects had tostart constructionwithin 60 days of the enactment of the bill in order to beeligible for the 30% credit and the timing would have put that deadline sometime in October2025, rendering the FEOC timing of 1/1/26 a moot point. The Senate version today is now usinga cost ratio to determine the thresholds of FEOC. FIGURE 1. FEOC thresholds for ITC/PTC and 45X credits Source: US Senate Finance Committee As seen on theleftside of Figure 1, in order to be eligible for the ITC/PTC, a project thatstartsconstructionin 2026 has to have 40% of the cost of the projectNOTbeaffiliatedwith FEOC.This ramps through the years and by 2030, 60% of the c