Tax credit transferability – the market so far

Intro: Welcome to The Energy Shift, a podcast series focusing on the rapidly evolving energy landscape with hosts Luisa Fuentes and James Wright.

James Wright: Hello everyone and welcome to The Energy Shift. Luisa, how’s your week going?

Luisa Fuentes: Not too bad, James. I just got back from Aruba, so no complaints and no hurricanes either.

James Wright: Awesome. Well, I’ve just shifted up the mountains. I’m in beautiful Colorado. If I lose my voice, it’s because the throat’s adjusting to 10,000 feet of altitude. We have got a great episode lined up today on tax credit transferability. And to tee this up, I pulled a quick quote actually from Ray, who we had on last week, who made a great observation about this whole topic. He said, It’s difficult to overstate the significance of today’s announcement for the clean energy market when the final Treasury guidance for tax credit transferability came out earlier this year.

Luisa Fuentes: Certainly from the banking side of the table, we would echo Ray’s sentiment. This has already resulted in some significant changes to the way US renewable and transition projects can be financed. There’s been a lot to focus on in the Treasury guidance and a lot for us to unpack and consider. As a bank, we’re focused on the way we can now help sponsors access the tax credit markets.

James Wright: Yeah, exactly. And with that, we thought we’d pull in today two great guests who’ve got fantastic perspectives on those issues. We’ve got a sponsor who’s very active in the project financing market and a lawyer who negotiates and papers those deals. With that, I’m really pleased to welcome two very well-known people in our space who I’ve personally known for many years. We’ve got Brian Callaway and Mike Duff. Brian is the CFO of Copia Power, which is a Carlyle portfolio company. And Mike is a Managing Partner at Milbank and leads their US renewable energy practice. He’s also been a bit of a legal celebrity in our space and has been instrumental in the broader tax equity market since they began back in the early 2000s. So good morning, gents, and welcome to the show.

Mike Duff: Good morning.

Luisa Fuentes: So Mike, I’m going to start with you. Your clients are primarily investors or buyers of these tax credits. How would you characterize your response? Have you been surprised? Do you see it as expected? Or have you been disappointed at all in terms of how this market has opened up since the Treasury guidance was finalized?

Mike Duff: Yeah, I think I would agree with Ray’s comment from a few weeks ago that the enactment of transferability in this market really was a seismic shift as to how renewable energy projects can be financed. Prior to the IRA, as you guys know, financing of these projects and the monetization of the tax credits was only available through very complex tax equity partnerships. Transferability has really opened the market up now to a number of tax efficient parties that may for a number of reasons not been open to or interested in investing equity in a long term kind of hold position in order to monetize the benefits. So on the one hand, I think I’m very surprised at the volume that we’re seeing, especially this year in the second half. What we’re anticipating the second half of the year will be volume wise in that market. I thought that was still going to be about a year away. But we’ve seen significant uptick. We’re probably working on well over a dozen current transfer transactions. One area where I’m not surprised is the challenges. And there are some in just educating new entrants, educating old participants in the sector, because there are new structures that are being considered with respect to transferability. And with anything that’s new, there are going to be challenges with respect to negotiating commercial provisions opposite folks like Brian or transfers between traditional tax equity investors and potential buyers. So with anything, there’s always going to be that challenge and learning curve barrier to entry, if you will. So that’s an area that I’m not surprised. I do see that challenge or some of those challenges probably being smoothed out as the industry continues to grow and a market consensus does develop over the next several months and years.

Luisa Fuentes: Thanks, Mike. Brian, back to you. Mike characterized this as a seismic shift. From the sponsor side of the table, how has this changed the way you and your investment committee evaluate financing options for new development opportunities?

Brian Callaway: Let me preface all of my answers with saying we cherish the support of all of my friends and family in the tax equity business, traditional or otherwise. And I’ve got a lot of them, so bear with me. None of this is meant to offend. So the short answer, though, with respect to, was this a seismic shift? Yes, obviously it was. This was a game changer. As a leading sponsor in an energy transition platform, we target mega scale projects, a billion dollars plus a pop. And that means we need to be very focused on our business’s growth and our quality of execution. And transferability has really allowed me and my team to concentrate more on equity underwriting risks and less frankly, and I say this with kind intent, underwriting to a financing outcome where market depth is always a question. We’re more focused on our risk tolerances and our optimizations and a little less on the highly nuanced mix of folks’ appetites when we’re swirling three or four flavors of capital together over a 10 plus year period. That’s an incredibly hard optimization. And when we look at industry growth and the corresponding market demand for tax equity, and I think we’re looking at growing somewhere between20-ish billion dollars a year in 2022-23 to 80 to 90 billion dollars three or four years from now, this is a critical piece to getting there. We got to get folks, we got to get sponsors focused on how we grow and where we go and less focused on least common denominator capital constraints. I think that being said though, generally, at Copia, we do like credits kind of general risk profiles of projects that when paired with our team, we just so happen to be pretty darn desirable across all flavors of capital, including folks that feel like more traditional big bank tax equity. And that gives us access to highest efficiency tax monetization. But the downside protection that transferability really provides as a part of our underwriting is really invaluable. And we felt that fundamentally already.

James Wright: Great, thanks, Brian. So let’s just quickly get a little wonky on diligence. Mike, back with you. This market’s still pretty new, as you said. What trends have you been seeing from the buy side, so the buyers of these credits, in terms of what they’re focusing on with their diligence as they learn this market? So I’m guessing, for example, there are some key differences there in terms of how they’re approaching ITC versus PTC diligence. Maybe you could just briefly unpack that a bit.

Mike Duff: So James, this is the part of the podcast where half the audience leaves.

James Wright: (laughs) Let’s keep it high level.

Mike Duff: (laughs) Yeah, I think the diligence, generally speaking for transferability, the legal diligence is going to be much more limited than a typical tax equity transaction. A tax equity transaction, your tax equity investor is very focused on not only the tax aspects and qualifications of the underlying project, but also just commercial operation, transmission, basis concerns, credit quality of the off-taker, you name it, because a portion of that investor’s return is coming from cash distributions from operations. Whereas in the transfer market, the buyer, the credit is really focused on just the tax qualification over the underlying asset and making sure that the credits can be transferred. So from a tax perspective, your diligence is going to look very much the same as a tax equity transaction. From a commercial perspective, it’s going to be diligence light in that regard. And then between PTC and ITC, and you’ve got different PTCs, technology that qualifies for PTCs, but generally speaking, the big difference between the PTC and the ITC, as many people know, is what we’ll call the basis step up and the amount of the ITC. So again, from a tax perspective, that’s going to be very similar to the same diligence you would do in a tax equity transaction where you’d need an appraisal and a cost sag. You’d diligence that. You’d want to make sure that the quote unquote developer markup that is ITC eligible is something that folks are comfortable with. And then oftentimes in ITC, you’ve got an insurance product as well backstopping the reps that are being made. And that’s something obviously in agreement that would be diligence by the buyers. They would be a third party beneficiary of that policy.

James Wright: Great. Well said, Mike. That was a great high level touch point on those challenges on the diligent side. Hey, Brian, just quickly your thoughts on that. So as you said just now, you’re focused on kind of mega scale projects where traditional tax equity partnership flip arrangements are still super important to your business. But I’m assuming some of those investors are now electing transferability out of some of those partnerships to help manage their tax positions on the back end. Has that changed the way you look at all those partnerships and the way your team are diligent in them?

Brian Callaway: The short answer, James, is yes. It has changed the way that we evaluate folks that are bidding into our assets or our deals. I think there’s fair to say that there’s two buckets or considerations that we think about, and especially as they dovetail to folks that want to transfer out some or all of the credits eventually. And part one is kind of called the underwriting aspect. When we first craft the deal, what floor prices is an investor willing to underwrite to with respect to their own book or transferring? What portion of credits will be kept effectively fully valued on their books versus transferred out? I guess that’s kind of the, obviously yield, et cetera. And that’s kind of, I guess, call it bucket one flanging into bucket two, which is when we start to think about the transfer process, How much flexibility is there for the tax investor? And on deals this large, what is a relatively complex risk sharing construct look like between the tax equity investor and the sponsor? And this is things like, aside from percent transferred insurance, upside sharing, indemnification, back to backing or not. And this is tricky because frankly, we want to support our tax investors, especially at this scale, when they are helping propagate in a really major way the transfer market themselves, but managing the push and pull of things like how much of my balance sheet or any sponsor’s balance sheet or how many of my reps or warranties, covenants can an investor effectively use when they’re transferring out is really, really important in all things for us to consider. And I think Mike alluded to this earlier, I feel like as an industry, we reinvent ourselves somewhere between every six months and three years and everything is new again. And so figuring out a market formulation for these concepts is challenging right now, but really critical.

James Wright: Yeah, exactly. And I think that dovetails well with what we touched on a couple of weeks ago, actually, that just one of the themes that we’ve all seen has been, whilst it has been a game changer for our space, it’s undoubtedly added a bit of complication to our lives with some of the things that you just touched on there. All right, Luisa, over to you.

Luisa Fuentes: Brian, staying with you then, you’re part of a very marquee franchise, Carlyle, obviously one of the largest financial sponsors in the world. With this type of profile, are you seeing an increased number of reverse inquiries from buyers looking to source credits from your projects?

Brian Callaway: Theshort answer again is yes. So Carlyle obviously gives us a level of kind of perceived heft and notoriety that not a lot of folks get to enjoy. And the market for transfer credits is clearly robust and only gaining depth and breadth as more folks make the effort to understand the project. We won’t talk about the who’s the what’s and the how much on a podcast, but needless to say, there’s a lot of momentum and picking up even more steam. I think in trying to take this to a slightly more concrete place, if you look at the 2024 market, I think again, maybe a little bit to Mike’s point, we’ll see the tax equity throughput volumes jump from what probably was expected to be in the, I don’t know, maybe the deep 20-ish billions of dollars to closer to 30 and 40 maybe. A lot of that is going to be driven by direct transfers or what is effectively a direct transfer from a bank closing the deal and signing a transfer agreement on the other side. Hopefully that helps contextualize, but I think reverse inquiries are increasing, but obviously, we got to keep certain things proprietary.

Luisa Fuentes: And Mike, to you, have you been surprised at all by the variety of potential buyers who have expressed interest in the market? And are you seeing any early themes or takeaways there?

Mike Duff: Yeah, I mean, there have been some folks that have made quite a splash in the market to date. There are others that I think folks had anticipated would be participants that are. I think the overall enthusiasm seen by a lot of these buyers that had traditionally not been involved in the market has been almost universal. I mean, they’re all now very engaged, highly active. To Brian’s point, you probably have 15 or 20 that are very actively looking to participate in the transfer market. And it’s not just one transaction, it’s multiple. And just based on the pipeline that’s out there, the developer pipeline, the interest that we’re seeing on the transfer side, how a lot of the banks that were traditional players are utilizing their client relationships and marketing these credits as well. It’s been kind of an incredible broad-based outreach, if you will, to a number of corporates and others to gauge their interest. And again, I think the response has been quite positive.

James Wright: Mike, you almost perfectly teed up my next question to Brian. So Brian, one of the aspects I’ve kind of found interesting that we’ve all been seeing the last year or so, particularly has been the number of new brokers who’ve entered this market as third party facilitators for these credit transactions. They’ve got many different business models. Where do you as a potential seller of these credits see value from those brokerage services? Do you see room for innovation there? And I guess a bit of a self-serving plug from me, it kind of dovetails with Mike’s point just now that my personal view is that banks could also provide a bit more of a meaningful role connecting buyers and sellers there, but would love your views on that.

Brian Callaway: I think you’re completely right, James, but it does depend on the seller, right? I think that some of the non financial broker dealers, non bank kind of syndicators that are popping up are helping open the market a bit for folks that are, call it in the 50 to $100 million deal size or smaller, very highly aggregated transactions. And that’s great. I feel like that market is kind of filling in quickly. It’s harder for us to use folks like that because of the scale and the bespoke nature of our transactions. It means we’re usually targeting either a very large traditional partner or a new taxpayer that usually comes with a pretty sophisticated tax program or team and tax liabilities in the billions or deca-billions of dollars. However, that leaves a lot of room in between for folks to facilitate. And I think that banks can play an increasingly large role there. I think the trick there is in trying to come up with a product that is of greater value than just connecting folks, right? Because at least folks in our shoes, we do have the benefit of having relationships. So it’s more than just connecting folks across the desk and charging a VIG for that. It is in streamlining execution, repeatability, angling towards less complex depreciation, monetization, et cetera. But I think there is a huge market there.

James Wright: So Mike, just with that, I’m curious from a legal perspective, has adding these third party brokers into the mix on deals then added any documentation complications from your seat?

Mike Duff: It’s a great question, James. I don’t think they’ve added any complications at all with respect to where we’re operating. And I think I’d echo what Brian’s observations were, which is that I think where we see a lot of these brokers playing a really vital role is in some of the smaller deals. I say smaller, they’re still very meaningful. But, you know, where you’re looking at selling 25 million of credits or 50 million of credits, the bigger chunkier deals where those credits are being sold to kind of your Fortune 100 type companies, if you will, your top corporates. We’re not seeing the brokers playing that space so much, oftentimes because the sponsors know who those entities are or those entities have already reached out to CIBC and asked for introductions and support. And to Brian’s point, I think where the financial institutions like yourself, James, play an important role that distinguishes you guys from a traditional broker is that because you have the experience in the tax equity market, they’re likely, I would think, from some of these buyers will be a tremendous comfort level in working with you. You can help them with the diligence. You understand the very complex kind of tax qualification requirements and what have you that, you know, maybe a broker is not as educated upon, right? Because you guys have done 10, 15 years, if not longer of tax equity transactions. You’ve done the lending to them, so on and so forth. Beginning of construction is not like a new concept to you guys. And some of these arcane and very nuanced rules are things that we all have kind of gotten very familiar with. So while you’ve got kind of brokers generally, I do think that you’re going to see that market kind of maybe segregate into the financial brokers that are going to add that additional piece of support, which is we understand the asset, we understand how the asset qualifies for the credit, we can have that additional value add. And then maybe you’re a more traditional broker that really is just, you know, it’s introducing buyer and seller and moving a transaction forward in an efficient way, and that’s very important. But that’s different than kind of what other financial institutions would be able to offer to clients of the bank.

James Wright: Thanks Mike. With that you single-handedly reinvigorated my love of banking. So thank you.

Luisa Fuentes: I also appreciate you validating our business model, so thank you. Mike, I’m going to assume that not all tax credits are created equal, at least in the eyes of buyers, and maybe not yet. To pull on that thread a bit more, outside of the more standard, well-known ITC and PTCs for solar and wind, which we all know and love, are you seeing challenges for buyers that could impact their appetite for other types of credits, say from advanced manufacturing, hydrogen, CCUS, et cetera? And maybe while we’re on that topic, a new feature that came about was direct pay for some of these hydrogen CCUS and manufacturing tax credits. Would be curious to see how you’re seeing that come into play. 

Mike Duff: Sure. So what we’re seeing, and we’re working on a bunch of transfers that touch a number of different technologies. And what we are seeing, it’s still early, so the market is still kind of settling, but that there does seem to, at least from our perspective, be a preference. So when I say a preference, it just means the credits are trading at a higher value for your 45X credits. And then it’s kind of your wind PTCs. And then it’s solar ITCs. I think that’s just a function of the fact that with your ITC, there is recapture exposure. And if you’re a corporate that is not familiar or have a long track record in the renewable sector, having to go to senior management and walk them through, if you’ve got two different credits you’re looking at, and you say we can buy $100 million of PTCs or we can buy $100 million of ITC. And the ITC comes with an insurance policy and a five-year tail risk on recapture, so on and so forth. What I’ve been told is management kind of says, well, wait a second, let’s go back to this PTC. Does that have any of those other features? And the answer is no. And it’s like, well, let’s go buy the PTC. So I do think there is a bit of a preference that we’re seeing in the market where PTCs, and particularly 45X type credits, are highly sought after. On direct pay, right now that’s still a bit of an unknown. I think there is some general concern if you had a change in the administration as to whether or not direct pay and the timing of those payments could be slowed down. So from just a financing perspective, it makes financing direct pay a bit challenging. If there’s uncertainty or additional uncertainty as to when you’re actually going to receive the payment. So as of right now, I’m not seeing the same deal flow with respect to direct pay transactions as we are seeing with just pure transfer, credit transfer transactions. That may change if we get past November and you don’t have a Republican in the White House. The direct pay, folks may feel a little more settled about that and banks look to lend against it, sponsors look to utilize it on a go-forward basis.

Luisa Fuentes: Yeah, I have to say even with the direct pay feature, a lot of people are still looking to not use that option and to transfer that as well.

James Wright: Brian, one question I’m dying to ask you, again, slightly self-serving from the banking side of the table. One of the maybe unintended consequences of transferability that we’ve seen has been a bit more complexity in how construction lenders for renewable projects may have to think about their repayment scenarios now. How do you think about that? What are you seeing on your side of the table? Obviously, you’ve been pretty active in that market the last year or so with some mega-sized construction deals. Have you been observing that with your construction lenders and how have you been dealing with it?

Mike Duff: I’m not sure I’m going to jump in here, James. I think Brian may need representation that I interact with based on the current relationship. I mean, Brian, let me know if you’d.

James Wright: Yeah, if you want to plead the fifth, Brian, go ahead. It’s all good.

Brian Callaway: We don’t want to negotiate against ourselves. That’s right. So I’m happy to and I’ll try to attack this a couple different ways. And frankly, it’ll sound like a little bit like a rebuttal to the concept that this is more complex generally, James. Because I think when I say it out loud, can I think of anything more complex than trying to land a large non-recourse debt financing on top of a large non-recourse tax equity investment or tax monetization plan right at the point when the project starts to incur its most significant spend and prior to mechanical completion, that sounds really hard to me. And when all of those parties are very sophisticated and have retained very strong representation like Mike Duff here, I think that that is very complex. And in a way, transferability and moving from a tax equity bridge loan types construct to what we call a TCBL or tax credit bridge loan types construct is actually simplifying and gives the system a little bit more space to work. And so, I’ll get a little anecdotal. We’ve made what we’re calling that TCBL or tax credit bridge loana real centerpiece in our financing playbook. It replaces the tax-regulated bridge loan and focuses on an eventual transfer scenario, transfer agreement, something like that, instead is the takeout. We closed the Harpahalla one and two deals late last year for about $1.2 billion on a fully non-recourse basis predicated on this structure. And I think it was the first of its kind. And frankly, it went quite well. I think because even if there are parts that feel unfamiliar and therefore complex. In aggregate, this structure is a little bit more simple than the tax every bridge loan that we’re all used to. And so I think it’s fair that you highlight this as feeling complex, but I think that’s just because it’s new. Here, we’re asking folks to underwrite to a liquid market takeout with a reasonable discount to price and in some cases volume. And we’re giving lenders a front seat at the project, unlike back leverage. While in our case, we’re intending on doing better, I’m using my quote fingers for the listeners, by securing a more traditional tax equity structure eventually that everybody’s familiar with, I think that that will become increasingly less necessary as a base case, as everybody gets smarter and more comfortable with this stuff. And I’ll wrap up with, I think this is great for the space, risk sounding like a broken record, but this is another element where we can now focus on the project and flawless execution, closing on efficient debt at NTP, focus on building the asset the right way, managing schedule aggressively, and not having to manage our project schedule around financing considerations. And then in due course, secure the tax monetization. And frankly, this all lines up better, Mike, I’m looking at you, this lines up better for the risk that traditional tax equity wants to take on anyhow, which is not development or construction risk.

Mike Duff: I totally agree, Brian. And to Brian’s point, James, you know, anything new is kind of hard, and especially in a sector that for like 20 years out of structure that it had gotten comfortable with, even though it was very complex, it was one that everybody kind of knew. And I do think I agree with Brian, we’re moving into now a new era of things ultimately being much simpler from a financing perspective. It’s just getting over the newness of it, educating the participants. But once this transfer market and it’s getting there, I think more quickly than I would have thought, becomes truly liquid where lenders like yourself, James, can look at the market and say, okay, in the event, you know, something goes wrong, we have to foreclose on the project. Is there a liquid market to sell these credits? And I think the answer to that is going to be a resounded yes. I mean, you know, it is there now, and it’s only going to grow, which to Brian’s point allows the financing timeline to set up much more efficiently and opportunistically for a developer as well as tax equity that doesn’t want to come in early on and take that construction risk.

Brian Callaway: If I can paraphrase you both guys, you’re saying it’s simple, don’t worry about it.

Brian Callaway: Well, it’s probably harder than that, James, but I mean, it is in aggregate simpler, even though not everybody’s there yet. I know, James, y’all obviously supported us on the Hark deals, and not everybody, not the whole market is right there with you, but it makes a ton of sense. Most of the market is there now. There’s still a little bit of price to squeeze out of it to increase liquidity in the space. Hopefully we get a bunch more of these things done.

James Wright: Yeah, well said. All right, Luisa, why don’t you close this out?

Luisa Fuentes: All right, my question involves you making a wish. So if we had an audience of public policy folks listening and, again, acknowledging that this is still a very new market, are there any gaps in the guidance or other areas where you think regulations still need clarification that would help spur the growth of this market?

Brian Callaway: For me, domestic content is the obvious one. We’ve got a first notice that requires proof of manufacturer’s costs. We’ve got a second notice that contains safe harbor that is proving, I think, maybe for some more than others not particularly as useful as we hoped it would be and we’re awaiting further regulations that could change everything on a timeline that is unknown. So if I could fix all of that with a magic wand, I sure would, because there’s just a pot full of value sitting there that could help do what it’s supposed to do and spur growth in the space. And it’s really, really hard to use right now.

Mike Duff: No, no, I totally agree. I think it’s the DC Adder. And I would also say, and this may not be a popular position to take, but I think the sector would actually benefit if we get the DC Adder set and the guidance they’re set from effectively treasuring the IRS, sort of saying this is what we’ve got now. Because the constant reassurance of guidance and kind of changing the playing field makes it challenging for institutions to sort of transact because there’s always a fear that something may change. And so far, the changes have all been taxpayer friendly. But you wonder whether or not that could change. So like for transferability, like we’ve got a set set rules. Could they be tweaked here or there to make things a little more efficient? I’m sure they could be, but they work pretty well, you know, as evidenced by the market and where the market is. I think the one area to Brian’s point that really does need some focus and some clarity is with respect to domestic content. They kind of get that taken care of. You know, I think we’ve got a good foundation and the market, you know, I know, you know, sure, you guys feel this way. I’m sure Brian feels the way. No, I feel this way. You know. I don’t know if the market needs any more to take off. I mean, it feels like it’s on rocket fuel right now. So, you know, but I do think kind of just getting things to settle will be a good sign for the market and folks then can kind of just understand what the basics are and then make their financing decisions based on that.

James Wright: Yeah, I fully agree with all that. So guys, that was a fantastic conversation. Thank you. We could have probably gone on for hours on this stuff. So listen to wrap us up. What we love to do on this podcast is just finish off with a quick segment where we’ll do a quick round robin on what’s been shifting all of our weeks. I’ll happily kick us off this week. I’m going to keep it on a sporting theme. The England soccer team has been giving me perpetual heartburn, but I still believe something magical may happen. So I’m a believer. I’m also going to give a plug to the cycling world. I’m an avid cyclist. And I’m just going to mention that minutes before this pod that we started recording, Mark Cavanish actually just won his 35th Tour de France stage win. Which made him the all -time greatest rider ahead of Eddie Merckx. So it was fantastic. I’m a big Manx Missile fan as Cavanish is known. And that’s certainly going to give me some motivation to try and shift myself into the bike seat and burn off some calories. So that’s for me. Louisa, what about you?

Luisa Fuentes: Having just returned from Aruba, my only comment is that life is so much better when you get a mid-day refreshing drink. So I’m looking forward to that later this afternoon.

Brian Callaway: You know, I’ll go out of industry as well. I try to mix in some non-clean energy infrastructure wisdom to keep me human and keep me sane. I’m big on quotes, and this one felt particularly rationalizing to my life, given all of the change in our space every week, and it’s a Mark Twain one. I think I pulled it out of some cheesy ink article, but it ain’t what you don’t know that gets you into trouble. It’s what you know for sure that just ain’t so. And so that felt real appropriate as we’re navigating pretty uncertain times for a lot of different reasons while experiencing pretty wild levels of success as an industry in space.

Mike Duff: So I will say James on your soccer theme, very disappointed with the US men’s team. Fire the coach, very disappointed with my Lakers. And then, I’ll leave with the cliffhanger, I guess, pretty still uncertain as to what to make of the debacle last Thursday and where that leaves things, just generally speaking, and how this is going to ultimately affect, obviously, much more than just our sector, but with respect to our sector, and what to take out of that debate and where things go from here. I think that was that was a talk about seismic shifts. That was one of them that if you watched the debate, you were able to see real time. And it’s one that I think we’ll have to navigate through as a country here and obviously as a sector, kind of figure out what comes next. 

James Wright: Thank you again, Brian, Mike. That was really fantastic. Great conversation. The tax credit transferability market certainly has been really rapidly evolving for all of us. Lots of newness, lots of really cool things happening. I think we’re all very excited about what we’re seeing in the market. We’re going to circle back on a number of these themes in later pods. Thanks again, gents.

Brian Callaway: Thank you both. Cheers.

Mike Duff: Thanks, guys.

Luisa Fuentes: Bye guys.

Outro: Please join us next time on The Energy Shift as we continue to tackle some of the hottest topics in the US energy transition landscape, providing fresh insights and viewpoints to help you shift your perspective.

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