Alternative Power Plays One Big Beautiful Bill -- Energy Industry Implications
Sep 3, 2025
Ed Hild, a government relations expert focused on renewable tax credits, and Carl Staiger, a tax specialist in energy projects, dive into the transformative One Big Beautiful Bill. They discuss its implications for tax credits and the nuanced 'Beginning of Construction' requirements that could dictate project success. The duo highlights the significant regulatory shifts for wind and solar developers. They also tackle strategies for navigating the complex legislative landscape and the potential need for developer advocacy amidst evolving policies.
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Legislative Tug‑Of‑War Shaped The Outcome
- The House originally eliminated the ITC and PTC, while the Senate restored them but tightened rules, creating legislative friction.
- President Trump's EO then promised to narrow eligibility via Treasury guidance to bridge House-Senate differences.
BOC Versus Placed‑In‑Service Matters
- Two timing concepts govern credits: when a facility is placed in service and when construction begins.
- Beginning of construction (BOC) can determine eligibility and the credit rate long before a project is placed in service.
Meet IRS Safe Harbors For BOC
- Use the IRS safe harbors: either incur 5% of project cost or begin physical work of a significant nature to establish BOC.
- Track budgets and retain contingency buffers so the 5% test remains valid if total costs change.