10 Questions with Reunion, Episode 3: In-Depth Market Analysis with Hilary Lefko, Norton Rose Fulbright

Introduction

In Episode 3, our CEO, Andy Moon, gleans expert insights and unique market observations from Hilary Lefko, a partner at Norton Rose Fulbright. According to Hilary, "It's amazing how much the market has grown since the regulations came out in June."

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Takeaways

Transferability market activity has experienced incredible growth since regulations came out in June

• First movers were traditional tax equity investors purchasing credits. Now, we are seeing tax credit transfers across various sizes and technologies
• Every traditional tax equity deal that Hilary is working on has a transferability component

The bridge lending market is rapidly developing. Transfer deals with committed buyers are seeing advance rates similar to traditional tax equity bridge loans in the mid-90s

• If there's no tax credit purchasers signed up, we're seeing much lower advance rates – 75% and below

Technology and tax year is driving pricing, with higher pricing for 2023 tax year and established technologies

• 2023 tax credits are being priced much higher than later years
• Wind, solar, and storage are trading a little bit higher than technologies like biogas, where people are less familiar with the risks. PTCs are trading a little bit higher than ITCs

Key negotiation points include audit rights and scope of diligence

• Negotiations around audit are ending up similar to where tax equity is. Generally, each party controls an audit at their own level, meaning an audit of the tax credit buyer will be controlled by the buyer. If the seller has an indemnity obligation, they'll likely have notice, participation, and maybe consent over an audit that's going to result in an actual indemnity obligation
• Surprisingly, some developers are trying to limit the amount of due diligence buyers can do. They tends to be smaller developers who have insurance in place and don’t see the need for additional diligence; this will likely result in a lower price for the seller
• Limit of liability is also a negotiation point (e.g., is indemnity sized at the full tax credit amount, or the discounted amount that the buyer paid). Market is gravitating towards the purchase price of the credits plus some amount such as 20%. Important to remember that it’s rare to have a wholesale disallowance of credits

Basis step-ups continue to be important to developers, and structures are emerging to enable step-ups

• “Cash equity” structures with third party investors are emerging to help developers take advantage of step-ups. The third party investor must take true risk on their investment in order for the transaction to be respected by the IRS; however, this structure is markedly simpler than tax equity
• Not seeing many step-ups above the 20% range; traditional tax equity is capping the basis step-ups at 15% to maybe 20%. Some newer entrants with less sophisticated tax counsel are trying to go higher, though insurance will play an important role (and insurance markets may or may not be willing to insure larger step-ups)

Structures are also emerging to mitigate risk to buyers from recapture

• An internal partnership can be structured to own a project company, with one partner pledging their interest to the lender to mimic the collateral structure in back-leveraged tax equity. This can mitigate recapture risk for the buyer

Credit adders have varying levels of maturity. Energy community is the most common

• Energy community deals are appearing frequently. Projects that qualify on statistical area or on a closed coal fire and generating plant or closed mine are straightforward. Brownfield sites, which are more challenging to diligence, are beginning to emerge
• LMI bonus should appear soon. The application portal for the LMI bonus credit, which is allocated by the IRS, opened in late October
• For now, use of the domestic content bonus is limited. The market is waiting on further guidance and manufacturers are reluctant to disclose costs. Hilary has seen domestic content on two solar deals

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Chapters

• 0:00 - Introductions
• 0:59 - Question 1: What sort of transferable tax credit deals are you seeing? What have been the smallest and largest transactions you’ve worked on?
• 2:14 - Question 2: What interesting structures are emerging with transferability?
• 3:12 - Question 3: What terms are you seeing on bridge loans?
• 4:17 - Question 4: How does tax credit pricing differ between standalone deals and hybrid tax equity deals?
• 5:28 - Question 5: When negotiating tax credit transfer agreements between buyers and sellers, what negotiating point has surprised you the most?
• 6:30 - Question 6: What type of sellers have the leverage to limit a buyer’s diligence?
• 7:24 - Question 7: What specific limits are sellers putting on due diligence?
• 9:34 - Question 8: What are you seeing with respect to audit rights during transfer negotiations?
• 10:44 - Question 9: What is the 50th percentile in terms of negotiating audit rates?
• 11:33 - Question 10: Are you seeing structures emerge for developers to take advantage of a basis step-up?
• 13:20 - Question 11: What level of ownership is required to make buyers comfortable that it's a true third-party owner?
• 14:58 - Question 12: Are you still seeing tax credit transfers with step-ups above 20% to 30%?
• 15:38 - Question 13: Are you seeing any structures emerge to mitigate risks to the buyers?
• 16:50 - Question 14: What types of limits of liability are you seeing in tax credit transfer agreements?
• 19:06 - Question 15: Are you seeing buyers get comfortable with sellers not providing a guarantee when there's insurance?
• 21:09 - Question 16: Are you seeing deals with the energy community and domestic content bonuses?
• 22:39 - Question 17: What types of deals are using domestic content?
• 23:31 - Question 18: Are you seeing deals with the LMI bonus?
• 24:33 - Question 19: Are you seeing deals outside of solar, wind, and battery storage? Are you getting calls from people ready to transact on newer technologies?
• 26:28 - Question 20: Will a flood of new credits from different technologies drive pricing down over time?

Transcript

Introductions

Andy Moon: Welcome to another episode of 10 Questions with Reunion. My name is Andy Moon, and I'm the co-founder and CEO of Reunion, the leading marketplace for clean energy tax credits. We work closely with corporate finance teams to purchase high-quality tax credits from solar, wind, and other clean energy projects.

Today's guest is Hilary Lefko, who needs no introduction to practitioners of renewable energy finance. Hilary is a partner at Norton Rose Fulbright in Washington, DC and has significant transactional experience with Section 45 production tax credits, Section 48 investment tax credits, and is now spending a lot of time advising clients on tax credit transfers via the Inflation Reduction Act.

Hilary, great to have you here today.

Hilary Lefko: Nice to be here. Thanks for having me.

Question 1: What sort of transferable tax credit deals are you seeing? What have been the smallest and largest transactions you’ve worked on?

Andy Moon: Specific to Section 6418 tax credit transfers, what deals are you seeing? What's the smallest transaction you've worked on and what's the largest?

Hilary Lefko: We're seeing all kinds of transactions. What I think is interesting relates to Congress's whole reason behind transferability: to open financing to much smaller projects than would traditionally be financed by tax equity. The first projects we saw were projects that would be financed by tax equity, and it was tax equity investors buying the credit.

But now the market is exploding. We're seeing small projects getting financed. We're seeing portfolios getting financed. We're seeing portfolios of wind and solar. We're seeing solar plus storage, small commercial and industrial solar (C&I), biogas, very large wind farms, and solar. We're even seeing nuclear and renewable natural gas (RNG).

It's incredible how much the market has grown since the regulations came out in June.

Question 2: What interesting structures are emerging with transferability?

Andy Moon: What are you seeing in terms of other interesting structures that are coming to light with transferability?

Hilary Lefko: The first deals we saw were existing wind tax equity, selling off some credits from the last few years of the PTC period. Then, we started to see portfolio deals with people bundling up existing wind farms and selling the tax credits from them.

Then, we started to see the market move into greenfield projects. We're seeing new builds for solar, new builds for wind, storage, biogas. I think everything is bespoke right now. We're seeing the plain vanilla standalone deal, but I would say every traditional tax equity deal I'm doing right now has a transferability component to it.

Transferability has become such an important part of the market. It's a feature of every transaction I'm working on right now.

Question 3: What terms are you seeing on bridge loans?

Andy Moon: You mentioned working on bridge loans against commitments of tax credit transfers. What terms are you seeing on bridge loans?

Hilary Lefko: We've seen lenders that traditionally offered tax equity bridge loans step into the transferability bridge market. I'm seeing relatively similar terms and similar advance rates: if there's a purchaser that's already signed a tax credit transfer agreement, [we're] seeing advance rates in the low to mid 90s. If there's no tax credit purchasers signed up, we're seeing much lower advance rates – 75 and below.

For the most part, the lenders that have been doing tax equity bridges have been willing to jump into the transfer bridge market.

It was, however, a steep learning curve for them. They had to get used to the fact that money was coming in later than it does with tax equity, that payment structures look different, that there are different risks, and that different structures may be necessary. But we're seeing the debt market pick up.

Question 4: How does tax credit pricing differ between standalone deals and hybrid tax equity deals?

Andy Moon: As tax equity partnerships sell credits out of the partnership, how does pricing differ on those deals versus a standalone deal? Is it a smaller discount?

Hilary Lefko: It depends. The trends I'm seeing are 2023 credits are trading much higher than 2025 or 2026 credits. 2024 credits are a little bit higher than those future credits as well.

I don't know that the structure is driving the pricing so much as the timing of the credits. I also think the technology [is a factor] – wind, solar, and storage are going to trade a little bit higher than technologies like biogas, where people are not familiar with the risks. I think wind is trading a little bit higher, too. PTC is trading a little bit higher than ITC.

It'll be interesting to see once we get into the beginning of next year when 2023 tax liability has firmed up for many companies. I think we're going to see prices go up.

Question 5: When negotiating tax credit transfer agreements between buyers and sellers, what negotiating point has surprised you the most?

Andy Moon: That's very interesting. As you're negotiating tax credit transfer agreements between buyer and seller, what's come up in negotiations that surprised you the most?

Hilary Lefko: The thing that surprised me the most was a lot of sellers are trying to limit the amount of due diligence that buyers can do. Sellers are saying, "You're either getting a guarantee or you're getting a tax credit insurance policy, and you need to take our word for it – we're giving you representation."

The initial entrants into the market were traditional tax equity investors, and they were looking to do the same level of diligence that they would do on a tax equity transaction to confirm qualification for the credit.

Some of the newer entrants – corporates who haven't done tax equity before – are relying more on counsel, doing a little bit less diligence, but still wanting to kick the tires and make sure that the project qualifies. They're looking for tax credits, not an insurance payout.

Question 6: What type of sellers have the leverage to limit a buyer’s diligence?

Andy Moon: What type of sellers have the leverage to say there's limits on what due diligence you can do? Is that mainly the tax equity partnerships or the large banks who are putting those limits in place?

Hilary Lefko: I see it more from the smaller developers that want to sell their tax credits and think that they bought this insurance policy and that's going to make everything okay.

I think it has an impact on pricing. If you're not getting to kick the tires as much, you're not going to pay as much. There's a supply and demand aspect to it: if what you're offering doesn't have the same protections as what some other developer is offering, a buyer is not going to pay as much.

I think the market's going to take care of those sellers who don't want diligence being done, and they're going to get less for their tax credits than the sellers who are allowing buyers to do full diligence.

Question 7: What specific limits are sellers putting on due diligence?

Andy Moon: What specific limits are they putting on the diligence? Are they saying you can't dig into the cost segregation analysis, or are there specific areas that they want to curb diligence in?

Hilary Lefko: They’re saying, "Here's a cost segregation report, [and] you have an insurance policy. You have to trust us that we started construction. You have to trust us that the project is up and running. We've told you it's in service. You don't need to look at an independent engineer (IE) report."

"Why do you care if it's on a superfund site?" "If it is, then we get an energy community bonus." “But you can't look at environmental reports."

It's really limiting all those third-party deliverables the tax equity is used to viewing. We're seeing sophisticated tax counsel saying, "Well, you still have issues of tax ownership. We want to look at your O&M agreement, your off takes, [and] any revenue contracts to make sure that ownership of the project isn't shifting to someone else." And sellers are coming back and saying, "You don't need to look at an O&M agreement. It's an ITC. Why do you care if the project operates?" You do care during the recapture period, so there are considerations as well.

In the ITC context, we’ve seen sellers try and say, "Well, you can look at it up to placed-in-service, but you don't need to be concerned after that. We got you a recapture policy." That's just not been acceptable to a lot of buyers.

Andy Moon: That's been our experience, too. We've counseled buyers that it's important to do a comprehensive due diligence process and understand what you're buying.

There is some art, however, in making sure that this doesn't become another tax equity transaction where there is belt-and-suspenders diligence on every item. But proper diligence is important.

Hilary Lefko: Absolutely. I'm seeing some sellers try and limit the ability to get a tax opinion or what that tax opinion can cover. But, generally, more sophisticated buyers are looking for an opinion or a memo of counsel confirming that the project qualifies for tax credits in the full amount.

Question 8: What are you seeing with respect to audit rights during transfer negotiations?

Andy Moon: One other interesting point that you made is that audit rights and control of audit was one of the biggest negotiation points on the tax credit transfer agreement. Can you say more about what you're seeing there?

Hilary Lefko: Audit rights has become a big sticking point on a lot of these deals. The issue being that the regulations make clear that the audit can and will occur at the buyer.

Generally, these tend to be relatively buyer-friendly agreements, in which the seller has a lot of indemnities to the buyer. When the seller has an indemnity, they're going to want some level of control or participation in an audit. But you have corporates that aren't used to doing tax equity, and the thought of someone meddling in their audit is foreign to them.

Further, tax equity investors are buying these credits through their bank entities, and they can't have somebody else participating in an audit at the bank entity level.

So, [we've seen] a lot of negotiation on what kinds of rights sellers get where they do have an indemnity, where the buyer is clearly being protective of their audit process and should be.

Question 9: What is the 50^th percentile in terms of negotiating audit rates?

Andy Moon: Where would you say the 50th percentile is netting out in terms of audit rights?

Hilary Lefko: I think similar to where tax equity is. If the seller has an indemnity obligation, they have notice and participation rights [in the audit]. Ultimately, though, the buyer is going to control any audit at the buyer level. With respect to seller audits, we've seen a little bit more give – some sellers are willing to give buyers a bit more participation rights.

Generally, where the market is settled is you control an audit at your own level. If there are indemnity rights, we'll let you be involved, we'll let you have notice, participation, and maybe consent over an audit that's going to result in an actual indemnity obligation.

Question 10: Are you seeing structures emerge for developers to take advantage of a basis step-up?

Andy Moon: Flipping over to other structures that you've seen, we've heard a lot of talk of structures within transfers to enable a basis step up in the case of an investment tax credit - for example, an affiliate sale of a project company to a joint venture (JV). Have you seen this happening in practice?

Hilary Lefko: In terms of the step-up partnerships, I think this is going to be the key to unlocking the market. I think that everyone doing ITC deals is looking for a way to do a step-up partnership to get more value from the tax credit.

Initially, people were referring to these as accommodation parties, but I think to me it's more of a cash equity transaction. It's not tax equity. The investor is putting money in and getting a return on cash back. They're looking for credit card-like returns.

Initially, people were looking at these step-up partnerships as if they needed to look like tax equity and needed to satisfy the revenue procedure. “We need to have a pre-tax profit.”

To me, it's different. This is more like a cash equity transaction, where you have someone putting cash in and wanting a cash return.

Yes, a large portion of that return is coming early in the partnership because the partnership is selling tax credits. However, I think there needs to be some variability, and investors need to have some skin in the partnership game, some entrepreneurial risk – upside and downside. They're getting some of their return from the actual operations of the partnership – not just selling tax credits.

There was handwringing over making these interests look like tax equity when they're not tax equity. They're more like cash equity, which no one ever had these concerns about structuring cash equity.

Question 11: What level of ownership is required to make buyers comfortable that it's a true third-party owner?

Andy Moon: Do you have any sense of what level of ownership is required to make buyers comfortable that it's a true third-party owner?

Hilary Lefko: I think in terms of what percentage do these cash equity accommodation parties, whatever we're calling them, need to have. I think initially people said 20% because that's what we think of as a meaningful stake in the partnership. I think we'll start there. No one wants to be the guinea pig. I think the first deals are going to get done at 20% or higher.

The issue is if you're stepping up the basis of a tax credit, there needs to be a robust appraisal supporting that fair market value. The partner interest to me is a little bit more of a red herring.

While they do need to be respected as a partner – and I'm not writing that off or being flippant about not making sure that they're a true partner in the partnership – I think we're losing sight of the bigger issue, which is, can we support the step up? Is the step up too much? Is there an appraisal behind it?

I'm not saying that we don't need to make sure the partner is a real partner; I'm absolutely saying that. I think we're losing sight of the bigger issue, and that's we still need to be able to support the step up.

Andy Moon: For sure. We have two separate issues. One is to ensure that the IRS respects the partnership as a true third-party transaction. And the second is the level of step up. The latter is an ongoing question. The IRS didn't provide clear guidance or a clear line on what's acceptable in terms of step-up level. I think that'll be very interesting to see.

Question 12: Are you still seeing tax credit transfers with step-ups above 20% to 30%?

Andy Moon: Are you still seeing tax credit transfers with step-ups above 20% to 30%?

Hilary Lefko: Not really. We're seeing the traditional tax equity want to cap it at 15%, maybe 20%. Newer entrants into the market, if they're not represented by sophisticated tax counsel, can be convinced to go higher.

Some of the insurance markets are more conservative than others. Some will insure step-ups over 20%, while others will not. A lot of people view that step-up over 20% like an insurance arbitrage – we're going to get our tax credits, or we're going to get our insurance.

Question 13: Are you seeing any structures emerge to mitigate risks to the buyers?

Andy Moon: Are you seeing any structures emerge to mitigate the risk to the buyers? For example, if you have a partnership own a project company, that can help mitigate the risk of recapture if there's an upstream change in control.

Hilary Lefko: Absolutely. In the ITC space, we're seeing a lot of internal partnerships. These are not being done for step-ups. Rather, they're being done to mitigate recapture risk.

It almost creates a synthetic tax equity partnership where you have your class A interest that's getting tax benefits, and your class B interest that's getting more cash. The synthetic class B member can pledge that interest to the lender to mimic the collateral structure in traditional tax equity that they would have with back leverage.

I think if you can get that in place, lenders are getting comfortable. With deals that are already placed in service, though, where they didn't have the foresight to put something like that in place, lenders are saying, "Too bad, we have asset-level security. We're not going to forbear during the recapture period unless we have access to that sponsor-level interest as collateral."

Question 14: What types of limits of liability are you seeing?

Andy Moon: And flipping back to the tax credit transfer agreement, what limits of liability are you seeing? Are buyers asking for liability coverage in excess of the credit amount?

Hilary Lefko: I literally had two calls about this today! One with a lender, and one with a purchaser about what's "market" on sizing of indemnities for tax credit transfer deals.

If you're a purchaser, you're going to argue that market is the face value of the tax credits, and it should be uncapped. If you're the seller, you're going to say, "No, why should I pay you the face value of the tax credits? I should only be out for my purchase price."

We're seeing the "true" market settle somewhere between those two positions. We're seeing purchasers get comfortable if their indemnity amount is sized to the actual value of the tax credits – that is, the dollar amount of the tax credits. Then, they're willing to accept some limit on liability, such as purchase price plus 20%.

It's rare to have a wholesale disallowance of tax credits. Usually, you're looking at the basis step up or you have a piece of property that you claimed ITC on that you shouldn't have in the cost segregation. It's rare for the IRS to say you shouldn't have gotten the ITC at all.

For that reason, we're seeing purchasers accept some cap as long as they're getting the indemnity and the amount of the credit.

It also goes to the size of your insurance policy. We didn't talk about this, but all these deals I'm seeing are done with either insurance or a strong, creditworthy parent guarantee. To a seller that has insurance, if their tax credit insurance policy is sized to the face value of the tax credits, then they're fine with their indemnity looking like that because their agreement is going to say the buyer must go against the insurance policy before they can seek recourse against the seller.

Question 15: Are you seeing buyers get comfortable with sellers not providing a guarantee when there's insurance?

Andy Moon: That's fascinating. Are you seeing buyers get comfortable with sellers not providing a guarantee when there's insurance?

Hilary Lefko: I've seen several deals done with insurance only with a very limited parent guarantee. If you have insurance, what you're really looking at is retention (the uncovered amount) and whether contest costs count towards the retention.

You can quantify what's not covered by the policy and see how comfortable you can get with or without a guarantee. But I've seen deals done insurance only, with the seller pushing back on a guarantee or pushing back on a creditworthy parent giving a guarantee.

Andy Moon: That's fascinating. It's great to talk to you, Hilary, because you see so many deals in the market. It's interesting to see what each party is willing to accept because, at the end of the day, it's a negotiation.

Hilary Lefko: I would say "no guarantee" is the exception rather than the rule, and it certainly is going to impact pricing.

All these levers are levers that you can pull economically, and if you're willing to go without a guarantee, perhaps you can get a better deal on pricing. If you're insisting on a guarantee, then maybe the seller won't be is willing to work with you on pricing and some other factors.

The scope of the indemnity – whether it's just breaches (bad act-type things) or if it's more comprehensive (any loss disallowance recapture) – factors into the deal’s economic terms. All these deals are bespoke, and everyone's negotiating what they want out of them.

Andy Moon: Right. We've seen some buyers express that they want the indemnity from the seller to prevent moral hazard – that is, to make sure that the seller doesn't do anything that might trigger a recapture. Nobody wants to deal with having to get claims from an insurance policy.

Hilary Lefko: That's consistent with what we've seen as well.

Question 16: Are you seeing deals with the energy community and domestic content bonuses?

Andy Moon: Let's flip to bonus credits because there's still outstanding guidance on domestic content. What are you seeing in energy community, domestic content, and LMI?

Hilary Lefko: For the energy community bonus, I'm not seeing any issues with purchasing credits from projects that qualify on statistical area or on a closed coal fire and generating plant or closed mine.

It's been a bit more difficult to get a brownfield financed, and I think the reason for that is the determination must be made by an environmental lawyer. Environmental lawyers are not tax lawyers and are not used to writing opinions.

It's been hard to get the level of support and the documentation that tax credit investors expect when you're talking about a brownfield. I'm not saying it can't be done. There probably have been a few, but it's been difficult to get brownfield financed.

The other two, however, are easy to diligence: you look at the address and see if it's on the appendix. You must make sure the test year works in terms of whether it's placed in service, or every year during the credit period for PTC, or if you fit into the beginning-of-construction safe harbor. But I think that's probably the more difficult qualification piece than the underlying qualification itself.

Question 17: What types of deals are using domestic content?

Andy Moon: Are the deals you're seeing on domestic content win re-powers, or are they traditional solar installations?

Hilary Lefko: I have not seen a lot of domestic content financed. I know of two deals, and they have insurance. For the most part, sellers are finding that, right now, the market is not willing to finance domestic content. The reason for that being that it's just impossible to get manufacturers to disclose their direct and labor costs.

Everyone's putting this wait-and-see approach on domestic content. If we get better guidance or if we get manufacturers to disclose costs, then we're going to include the domestic content bonus. The projects that I know included the domestic content bonus in sizing were solar.

Question 18: Are you seeing deals with the LMI bonus?

Andy Moon: Fascinating. What are you seeing on LMI credits?

Hilary Lefko: The LMI portal opened last week, and everyone's scrambling to get their applications in. (Although you don't have to scramble because it's not first in, first out if you meet the [30-day] deadline. All applications [submitted within the first 30 days] get considered at the same time, based on the weighting criteria.)

If [the developer] get an allocation and other conditions are met, then we'll finance the credit.

People were hesitant until the portal opened and were worried that it wouldn't open – that we wouldn't, initially, have awards.

The DOE and the Treasury have been doing a road show of webinars, so everyone's gotten more comfortable with how you apply and how you qualify. We've been seeing more LMI elements added to these deals.

Question 19: Are you seeing deals outside of solar, wind, and battery storage? Are you getting calls from people ready to transact on newer technologies?

Andy Moon: Looking forward, we know there's a lot of demand for solar, wind, and battery storage tax credits. What are you seeing in terms of other technologies? Are buyers willing to purchase credits from other technologies?

Hilary Lefko: I am, although I am seeing lower pricing for other technologies. We are seeing a lot of sellers going to market with other tax credits. I think the next biggest category would be biogas and renewable natural gas (RNG). I think there's going to be a lot of those. There are a few projects that came online in 2023, and I think we'll see more 2024.

Anytime a potential seller comes to me with those types of credits and says, "I can get 96 cents of credit," I say, "Well, you're not selling 2023 wind [credits]. You probably can't [get that pricing]. You need to redo your economic projections assuming a much lower price per credit and make sure that this is still economically viable for you. Anything above that is going to be crazy.”

We've heard of some 45U nuclear credits coming out – maybe some other nuclear facilities selling technology-neutral credits. It'll be interesting to see what those trade at.

I think there's a lot of considerations with public perception around nuclear and whether investors will be willing to buy those credits and be associated with those technologies. It'll be interesting to see what the market will bear. It may be a great way for companies to get a bargain on tax credits.

As we start to see newer technologies flood the market with lower pricing, it'll be interesting to see if those impact the other end of the market – that is, the credits with which people are [familiar] and the technologies that investors are comfortable financing.

Andy Moon: I think that's right. There's a lot of expectation among developers that pricing will go up – that there will be a smaller discount as the market matures.

Question 20: Will a flood of new credits from different technologies drive pricing down over time?

Andy Moon: If there's a flood of new credits from many different technologies all competing for the same tax credit buyer dollars, will that provide downward pressure on pricing over time?

Hilary Lefko: I think it's going to be interesting to track.

Andy Moon: Thanks for coming on the show today, Hilary. It's been great to have you. Great to see you, as always.

Hilary Lefko: Yes, this was great. Great chatting.