Name: From Policy to Practice: Interpreting the Executive Order’s Impact on Solar
Uploaded: 2025-08-21T19:17:56.254Z
Duration: 1 h
Description: From Policy to Practice: Interpreting the Executive Order’s Impact on Solar

Transcript for "From Policy to Practice: Interpreting the Executive Order’s Impact on Solar": Good morning, Jarell. How are you doing? I am good. How are you? I'm doing pretty good. Awesome. Awesome. Yeah. It is sunny here in The US Virgin Islands. Oh my goodness. You're in the I I'm jealous now. You know what's good about being back home is that I see a lot of solar panels being installed. In the past growing up, I, yeah, didn't see as many solar panels. So every time I get the chance to come back home and I see just the penetration of how many installations are being done here, not just in the resi space, but commercial space as well, it's very it's very fulfilling. So, yeah, one fact. And It can make sense. I mean, it's I imagine, you know, power generation on a tiny island is is is a kind of an issue and, like, not having to constantly import coal or coal or natural gas or whatever is probably a really good thing. Yeah. Yeah. You know, the dependency of natural gas and even prior to natural gas, we were very heavily dependent on diesel generation as well. There is still a lot of diesel generation. However, with the switch over to natural gas, the price of electricity has come down a little bit, not much, compared to if we were still to be on diesel generation mostly. But, you know, the transition into solar is helping provide, like, that energy independence because the price per watt compared to The US is, like, three times. Like, you could be paying, like, 50¢ per kilowatt hour, to consume electricity down here in The Caribbean. So it's it's a big problem. So it's good to see solar being a tool to help reduce that, cost. Mhmm. Yeah. So well, we're gonna give it a few more minutes to get folks entering into the webinar. I don't know how open the chat is here, but I'd be curious to see and hear where folks are calling from. Yeah. If folks wanna just drop in the locations that they're dialing in from, that'd be awesome. I think that'll be helpful for contextualizing, the conversation that we're about to have here today. I'm coming. Yeah. I'm calling in for I'm actually right now as, in, sunny, British Columbia. So, it's kind of a a a new situation, but I'm also seeing lots of solar here too. The building I'm in right now actually has a lot a really nice solar array on top of it that I had that I was taking a look at earlier. Oh, that's awesome. That's awesome. Okay. How about we go ahead and we just dive right in, Fox? How does that work? That sounds like sounds good to me. Yeah. Let's do it. Well, hello all. Good morning, good afternoon, and good evening to everyone calling from many different geos across the country. First of all, I'd like to say thank you for joining our policy to practice and interpreting the executive order's impact on solar. My name is Jarell Mason and I do strategic partnerships at Aurora Solar. I've been in the climate industry for a little bit over a decade, and I am joined by Aurora's very own industry and subject matter expert, Fox Swim. And I'll be moderating the event. And, Fox, I'd just like to first off say, it's always fun to do these with you. And we are so back for another round of, this type of conversation regarding policy and how that affects solar industry. So I'm excited to be doing this again with you. But to set the stage a little bit, Fox, how about this? I could give you a brief I would love to give just, like, a brief overview to the audience, sort of set the stage as to how things will go. And I think that would be helpful for folks who are in the audience to just simply, like, tag along, listen. You know, the intention of this webinar is to it to be very conversational, but also informational as well. And throughout this webinar, what we'll do is we'll give a brief overview of the OBB and what has happened. And then, you know, we'll get into the details of the treasury rules, and then we'll discuss what does these rules mean for the industry and everyone on this call. And, Fox, one last thing I'll also like to say before I hand the mic over to you and you get into some intros is that, you know, there's couple of things that we'd like to acknowledge in this webinar. First things first, we'd like to say that we're here for you. Speaking plainly, you know, installers, we understand that you are experienced a lot of chaos, a lot of changes that's happening. And we're here to provide a lot of clarity and honesty. So throughout this webinar, we just wanna let you guys know that we're here for you, and that's the most important thing. Lastly, I'll also say as we go through this webinar, we'll be having a q and a at the end. So please hold your questions in the end or just put them in the chat. We will be categorizing some questions so that folks could, get those questions answered in a meaningful way. And then lastly, what I'll say is, feel free to use the chat as a live discussion. Also oh, so the chat has closed. I'm sorry. So if you have any questions, there is a q and a section. So just please feel free to put your questions in there as well. So with that, Fox, I'll turn it over to you, have you give a intro, and then we'll go ahead and dive into the webinar. Good morning, evening, or night depending on where the sun is, where, y'all are. As Adriel said, my name is Fox Swim. I'm a senior solar industry research engineer here at Aurora Solar. And I've worked in the solar industry for about for almost about five and a half years now, almost six years. And before that, I, was, working with an investigative journalism organization doing, reporting on climate and, renewable energy topics as well. So I have a lot of depth experience in this or in this space. Welcome back to everyone who was at the previous, webinar that we gave and and a big welcome to all of you who are, who are joining, just now. So the broadly speaking, where we, where we were, when we last did this in July was talking about, the rules as written path that were passed in the OBBB. And, the next step, which is where we are now, was we were waiting for, implementation guidance from the, executive branch. And just as a broad take it to take start from broad and then to go more in, this is how these things normally work. A a legislate congress passes legislation, which gives the broad, generalities of what they want the executive branch to implement. And then it includes specific guidance, that the executive or various, departments in the executive branch, have to provide us guidance on new rules changes to, the general public before those rules go into effect. And that's what the state the stage that we're at right now. Several, and, specifically, we're going to be covering, three three memos that have come out, a department of treasury memo, two department of interior memos, and we're going to talk about a a a third treasury memo regarding Fiat that hasn't come out, and talk about what that means. So just to quickly refresh everyone, on the overall changes from the OBBB. What has changed is the 25 b residential, credit is sunsetting at the end of the year with no cliff or with with just a straight cliff. Batteries are still eligible for the, 48 e ITC, through, the when they were when the original end date was set by the IRA, which is in the twenty thirties. 48 e qualification. Qualification for the 48 e, tech neutral credit, will be dependent on, compliance with FIOQ or, foreign entity of concern concern rules, at the end or, at the beginning of next year and, various redefined or various redefinitions of of, rules related to commence construction or place in service were put into effect. And so let's get into the meat of the details of that. So the big change here is, the definition the the change of definition of, what physical work or, or for qualification for the 48 e was. And there's good news and there's bad news here. The good news is that, for, so called low wattage, projects, which is less than or equal to 1.5 megawatts, These projects can still use the status quo 5% expenditure test or the other equivalent status quo tests related to that that we're all used to using. And that's that's rather a significant good news. I think many people were were not expecting this, and so I'm glad that this is here. The apprenticeship labor hour requirements for, a qualification for 48 e are still in place, and so those do need to be, and I believe those are at 15%. So the bottom line is for these low wattage projects, the the no change in, in this particular approach for start construction yet, but there is an urgency because after one year, the requirement switches from start construction to placed in service, which is, a much more difficult milestone to reach, especially within the short time frame that's given by the the sunset of the 48 e credit at the 2027. The bigger change that has happened is for projects greater than 1.5 megawatts. Those projects now must show what what is being coined as significant physical work to qualify for the 48 e, and this rule begins for any project that hasn't been qualified already, on or on or after September 2. So there were sorry. Yeah. September 2, which means and the the the good news here and perhaps maybe the only real good news here is that this these rules are not retroactive. But significant expenditure significant physical work, expenditure of funds is no longer considered in the determination of significant physical work. The Department of Treasury memo suggests that, things like installation of racking on the site or off-site assembly of inverters, transformers, and other power conditioning equipment is, are things that would qualify as significant physical work. It but they leave open the possibility that other things, may qualify. This is setting up a situation which is pretty common that we're seeing across the board in the Trump administration that they're giving broad latitude to the the the executive branch decision makers to make the final call whether, something qualifies as, is able to qualify or not. However, the memo lists, gives a defined list of what they call preliminary activities that do not count as a significant physical work. There's a there's a full list which you can find online, but some of the high points here are things like site surveying, site grading and condition conditioning, and permitting activities no longer count as significant physical work. There's a negative synergy here that I've identified between this preliminary activity and the d o and the Department of Interior permitting memo that I'll talk about later. Just as a general, note, the direct pay, and, transferability provisions here have been are still preserved. And, again, the apprenticeship labor hours requirements must be still be met for the these large projects. So, really, what this suggests to me is that there is a strategic the strategic shift is ultimately the answer to the question, how much off-site preconstruction can be done even if there's delays in permitting, or how quickly can we can, significant on-site construction be began, so that, 48 equalification requirements can be met. Giving a minute for people to catch up because I know that's a lot of information. So then yeah. Talking about FIAC. So this memo was, the FIAC memo was the memo that didn't come out. We were expecting a memo on the eighteenth, which was on Monday, detailing, what what we're we're going to what we're what was called in the executive order enhanced fee off rules that we're going to essentially clarify how how a project would certify itself to be Fiat compliant as well as how to navigate things related to that had, that were not related to Fiat previously that are now related to Fiat for the solar and wind industries. There is no new clarity. Treasury says the guidance is still coming. However, what we don't have it. What that means is that, there is a, the OBBB spells out specific rules related to, how to certify oneself, to self certify as fiat compliant before official rules are released. And those are definitely something that, folks will want to familiarize themselves with. But the but in general, the specific rules are in section 51, dash two, and basically relates to, to the to looking at the specific contracts that, that we sign that we signed with our, suppliers when we're getting ready to, as we're building up these projects and making and there are, a number of tests that are given that basically make sure that, that the effective control of everything related to the project remains in the hands of the taxpayer. So this includes, the ability to determine the timing of activities to of construction, the ability to return, whether or not, you have the right to repair or operate your equipment, whether or not any proprietary monitoring equipment is involved, and things like that. I can go into more depth about these, default rules if folks want to in the q and a. Lastly, talking about the Department of the Interior permitting memo. This is one that there's still an amount of uncertainty in terms of how it's being implemented. And it's specifically the Department of Interior memo states that, for essentially any possible permitting related activity that touches the Department of the Interior that as relates to solar or wind has to be approved of by the, the secretary of interior as well as a couple of his underlings. This is, this is a difficult, this may it's unclear exactly what the impact of this is, but we're starting to see, permitting delays related to implementations of the Clean Water Act or the Endangered Species Act, as well as, the National, Environmental Protection Act. And the best advice that I've seen and that I can pass on is to be mindful of whether or not projects, that you're, are being undertaken are involved in or or or what is called the federal nexus, which means that there's some sort of federal funding that is involved in the project or whether the, the project requires, army corps of engineer or other, Earthworks, to get involved. And both of those will involve Department of Interior permitting and budget extra time and resources for that permitting process to potentially be delayed. Alright. Next slide. So, Fox. Yeah. One thing that came to my mind as you were discussing Fiac and the permitting piece is the the uncertainty of it all. You touched on it a little bit. And I think from most, we could agree that this stuff is, like, really, really heavy. So, you know, what would be something that you would tell, say, like an installer or even, like, a developer, who is trying to enter into this space or currently operates in this space, how do they get more comfortable in that uncertainty, especially, like, around FIOCC and this permitting piece that seems to still be, up in the air a bit. Like, how how what is what is something that that you would say that would just make them a bit more comfortable? Yeah. So, there's a a few different, pieces of advice that I would give. And I think the first one is sort of the most difficult one, which is acknowledging that continuing in the solar space may not be the best decision for every, for every company. I know that many, many companies, even potentially including some people on this call today, are are really evaluating whether or not it makes sense to, to continue, in the solar space, especially after the '25 d, residential ITC goes away. And that's a really, really tough decision. I don't know what I would do in if I was in your work boots. But I do know or rather, I don't envy the decision in your work boots. But I know that it's going to be a decision that relates to the personal finances and to really just and broadly to whether essentially deciding whether or not it makes sense to continue through during this, particularly, loopy part of the solar coaster or if it makes more sense and to, to, bow out. And I I acknowledge and honor the decision that people are making, and, we at Aurora Solar are here to try to provide as much clarity as we possibly can to everyone to help, make the best decisions for your businesses and for your families and for your employees. Yep. That said, there's the the solar space is going to become or is has become more granular and is going to become much more granular. And was whether and how to continue operating is, gonna be dependent on a jurisdiction by jurisdiction basis. Whether in some jurisdictions, it's going to make sense to move or move to an entirely TPO model and take advantage of the fact that the 48 e credit is still available. Doing and doing that will probably is gonna require becoming intimately familiar with your supply chain and making sure that, you know the ins and outs of all of how that works and, probably dealing with a lot of, with a much with a lot more red tape at the fed for the federal, applications than we're used to dealing with. In other jurisdictions, especially those that have, better, state and local incentive programs, it may make sense to move away from TPO, to for a cash and loan. It's it has not escaped my notice, and I imagine it hasn't escaped a lot of your notices that if you don't if you're not applying for the federal 40 e credits, you don't have to worry about this whole t, fee off nonsense. But you do still have to deal with some of the permitting and things like that. And I think a lot of it is just staying staying loose and limber and keeping an eye on what is going on both or at the federal as well as the state and local levels and applying incentives or, sorry, applying pressure to your state and local represent incentives and and lawmakers to support the solar industry in their jurisdictions. Yeah. I love that response. It made me think about what this all means for us. And there's a lot that's currently happening right now, and there's a lot that could potentially happen in the future. And I think when you categorize it in multiple buckets such as twenty five d, TPO, Fiat, it's important to be nimble, as you said. And it's also important to look for solutions that helps you navigate and adapt all these different changes. You know, at Aurora, we do our best to be that software solution that helps, you know, reduce some of those, like, administrative costs, that soft costs. And, you know, what's interesting is what's happened around all of that. For example, like batteries, the attachment rate across multiple segments, residential, commercial, has been going up into the right. And it's really cool to see that happening because then we, as a solar industry, and I like to call it, like, an electrification industry, could continuously, like, build off a top of what we've been currently doing today. So my question to you would be, like, when you look at all these things that's happening right now, 25 d going away, batteries on the rise, TPO, cash, loans, you know, fee up. Like, what does this all really mean? And it'll be great to hear, you know, you, you know, give some insights on all those different buckets that comes to mind. I think the audience would love to hear your insights around that box because I know you have, like, so much knowledge on that type of stuff. Hey, Fox. I think you're muted. I know you said so much there. Many apologies. Many apologies. So, at really, I think there's a couple different forcing functions here, and the and our industry is kind of straddling both of them. On one hand, there is the, the federal government for their own reasons is is making a hard turn towards, the the energies of the past. And, and that's something and that's something that, unfortunately, we're gonna have to deal with. But at the same time, it's also true that, electricity rates and grid reliability are both, are both becoming worse. Electricity rates are are go are going up, and nothing the federal government is doing is going to make that any better. And, grid reliability is, is decreasing in many parts of the country. And I think and which gives the the, which means that, solar electrification is still needed. In fact, probably needed even more now than it, than it could be, or than it has been in the past. So as we move through this stage, there's a lot of people's wallets are suffering due to inflation and due to economic downturns. Reducing utility expenses, reducing reliance on on the grid is something that I think a lot of people are going are are becoming even more interested in doing even as the, the federal government tries to push away push push us all the way from that and back into the past. I I would that I could give, you know, a a direct advice of saying, yes. If you live in, you know, if you live in Nevada, you should do this. If you live in California, you should do that. If you live in Tennessee, you should do the other thing. Everyone here knows their business better than I do, and everyone here's businesses will is very much dependent on the needs of the communities around you. And I do really think there that there is a strong case to be made for solar in the future. And as we navigate our supply the the changes in supply chain difficulties as we navigate the shifting of, of of different financing options, that's something to that's something to keep in mind because there still is a real and growing need for solar electrification all over the country and all over the world. A couple silver linings that I think we can pull from this, it is true that, there is, there there has been problems in the solar supply chain in the past and especially around, some some rather nasty labor issues in in, East Asia. And, also, related to an a continued reliance on silicon based architecture even when we're, when new technologies are potentially more viable and better to be moving towards. I'm we're already seeing, development and rolling out of, so called gen three technologies that are that are not dependent on semiconductor, silicon. Most of the semiconductor grade silicon, which comes from Southeast Asia and China specifically. So those are some things that we can we can look at as, as that are gonna be helpful for our industry even in the face of the the headwinds moving forward. So then as we are looking to the future and as we're trying to navigate that, would you say installers, companies today that operate in solar should be trying to focus more on their supply chain risk, their financing risk, or is it something else, or is it all of it, really? I think it would be good to hear on the call, you know, what would be the best place to spend your time today, to better prepare yourself for that future. I do think, you know, financing is, like, top of mind for a lot of folks. That's critical to the deployment of solar. But on the same token, like, the supply chain is at risk as well with all these fee requirements. And then, you know, depending on how permitting shakes out, that may add more risk on the supply chain. So then, you know, I guess the question becomes, like, where should I spend most of my calories today to be better prepare myself for the future? And I'm curious to hear your thoughts on where you think we should be doing that. I mean, I think the, as I think, like, the answer is going to be, like alright. I I think that the, the probably the most calories, the most energy should be spent, at least in this as we're moving into or as we're moving towards the 2025 is like, one of the things is capitalizing on the urgency and getting as many solar panels on roofs as we possibly can. Yeah. And at the same time, I think the thing that the best the biggest thing is to is to figure as to make the decision of to how, how you're going to move forward in terms of financing, in the new year because that decision is going to be very is gonna be critical for then what you have to worry about in the next step. If you if the decision is, you know, I live in Illinois, and, I think that the, the Illinois I can sell solar on the SREC programs, and, I trust my state legislatures to to continue to support the solar industry in my state. I'm not gonna deal I'm not gonna worry about TPO and the the the chaos of FiOC anymore. Then the decision or then what you need to worry about next has more to do with, hardening you your supply chain from tariff chaos and, and figuring out how to best leverage local tax credits and make sure you don't run a foul of, of permitting shenanigans. Whereas if you're in another state, let's just, let's click on my home state of Kansas, which doesn't really have any Minnesota or, state incentives that you're, that you're saying, okay. I need to we're gonna become an all in on TPO shop. And so then you really need to familiarize. Then the next course of action is you need to familiarize yourself with your supply chain. You need to get, get a a really good understanding of how of, of which what things are allowed in your t with the TPOs you're working with, and making and how that, the forty eighty application process is going to work moving forward. So, really, it's but the first step is gonna be consider is thinking now about what that decision is going to be so that you know what next steps you need to take. Yeah. Yeah. I love I love your response on how we could leverage, like, things even like SRECs. I am a finance guy, and I love, like, many different financial instrumentations that could be used and deployed in multiple different parts of the industry. So, like, tax credits, SRECs, I do think those definitely well, maybe even SRECs more have have a place even more now given, like, the multiple changes, that's happening within the space. I think what we should do next, Fox, is open up the floor to q and a. Been going through the chat. We've been categorizing some of these questions. But first of all, Chad, thank you so much for putting those questions in or the audience. I'm sorry for putting those questions in. And, yeah, I think that'll be a good time to sort of transition into some of these, like, really meaty questions, that some of the audience have been, sharing with us. How does that sound for you? Sounds like a good good plan to me. Yeah. Let's do it. Yeah. So one of the things that's been coming up a bit in the chat is is one question around the 25 b and the requirements for the end of year. I know in our last webinar, we talked about this a little bit more and it's I think for this question, it'll be good to provide, like, a refresher, but also, of course, answer the question in particular. So the question is, like, do we finally have clarity on what needs to happen for an install to meet 25 b requirements for the end of the year? Yeah. So installed, connected, paid for? What's the So yes. So, yeah, this is one of the ones where there is there is a lot of, uncertainty around, especially because and I just was literally looking at this to see if it had changed. The IRS hasn't actually updated its, the rules as written on on the official IRS web page, which is frustrating. But in the OBBB, the rules are, the the rules, as written in the OBBB section seven zero five zero six, which is relates to the the changes to 25 d, which is based it says that the, section 25 d h is amended by striking the, property placed in service after 12/31/2034 and inserting with respect to any expenditures made after 12/31/2025. So this strongly to me, strongly implies that the new, the new requirement is any is, expenditures made before 12/31/2025. But the, there are, like, the official documentation has not been updated. I've been watching it, and we're gonna send out, information once there is more clarity. But that is, just based on the, the black letter text of the the final bill path as passed, that is what is said. Got it. Is there anything more you wanted to say there? There's, like, a few other questions that we could go through. Okay. And did you did you want me to just read through them, or do you wanna read through them? So I'll I'll read them. I'll re I can read through them for you and I could prompt you with them. Like, for example, this one I think is, like, really interesting. What does the OBB considered minimum project start completion to allow homeowners to be eligible for the legacy 30% federal tax credit? Yeah. So, the bill text itself doesn't say anything. The bill text punts and says department of treasury will define new rules. And, so basically, what the new what the rules are is before September 2, the, the the rules that we're all used to working with or the so the previous rules for the 48 e, related for project start construction are the rules. After September 2, the rules are as we were talking about before, and they're split between, the low wattage below 1.5 megawatt and higher wattage above, high. Yeah. And related to that, I'm seeing this for projects lower. Do low wattage projects include residential projects? It includes residential TPO projects, which are which are the only TPO projects are eligible for the 48 e credit, because of how TPOs are structured. However, just cash loan projects are not eligible for 48 e, and so they will no longer be able to receive the the thirty eight percent twenty five d credit after the end of the year. There is searching ends in 2027. So so long as the, if the so the the question is is if a sub 1.5 megawatt project starts and ends in 2027, fully placed in service, and there was no pre July 2026 safe harbor, will it qualify for the tax credits? Yes. So long as it meets all of the, the fee requirements. And that's one thing I looking at my notes realized that I wanted to mention as a call out here. That is something that I want to make sure that none of us run a foul of, in the fee off is what's called the fee off clawback provision, which basically says that, you that if you get you take 48 e and have to deal and, have to deal with the fee of requirement, so that's after the beginning of 2026. Not only does the actual installation and construction of everything involved in installation and construction of the project have to be compliant with the FEOK rules. But any o and m or any, or any o and m and other expenditures you make related to the project for the next decade also has to be compliant with Fioc. And the penalty there is if you, if the, if you violate that provision in o and m, they'll actually, essentially force you to pay back the credit. So, Fox, this one is going back to the twenty five b. What resi project milestone must be achieved by 12/31/2025 for a project to be placed in service and earn 25 b? Is it PTO? Is it interconnection? Is it something else? Yes. So that's, so alright. So, yeah, that that's basically that goes back to what the the first question, was, which is that the, what is the sort of the qualifying event to be to qualify for, 25 d. And that with all the confusion, the rule the as I said, the black letter text here in, in the OBB says with respect to any expenditures. And it's possible they could finagle a different, date out of that, but until new guidance unless and until new guidance is given, that's what I believe is true because that's what's written in the in the text of the OBBB. When we say qualified by September 2, does that mean in reference to interconnection or what qual there it's in reference to what qualifies a project. So, basically, is if you if you hit the qualifying event before September 2 and you've and you've already applied before September 2, then you can use the old rules. But after September 2, then, you, have to use the new rules. So I think this is an interesting one, and it's on storage. The battery only and battery add on add ons will still be eligible for ITC. Is that also true of the battery portion of solar projects? I believe so. But, again, there is, the, because the, of how the rules for the 48 e credit are, I believe that it own the it would only qualify if there was some sort of a TPO or PPA or potentially a virtual battery bank type, situation involved with the battery installation. That it's that if it was just a cash or loan, residential installation, that it would not be able to qualify for $40.80. Very clear. How can the government determine how much we charge for storage? I mean, they're gonna ask you to submit the receipts, basically. One of the things that is yet it seems to be pretty clear about the, these credits or about the the changes is that they're good. There's a lot more red tape. There's a lot more bureaucracy that we're all gonna have to deal with. And, that means you're gonna there's gonna be a lot more that, we're gonna need to show the federal government. There's one question here about TPO, and it's asking, is Aurora doing TPO financing of solar? And the question is, Aurora has three integrations today to date for TPL financing. We're integrated with LightReach, GoodLeap, and Enfin. So the answer is, yes. Aurora supports TPOs. And the beauty about that is if you're an installer that has a sales organization or you manage your sales yourself, you can use Aurora and you you could finance, those installations of those projects via our TPO integrations, whether it's with Lightreach, Good Leap, or Infin. There's a lot of material that's online that's helpful for for folks to navigate those integrations, whether it's, like, the help centers, and we could share some of that information as well post this, seminar. And I think, Fox, this this one could be an interesting one for you. The question around TPO and the financing is did the executive order, change TPOs in general? I mean, in, like, in general, the process of, because the, the transfer avail transferability, rules are are the same. Not really. It it it didn't really change, like, the underlying mechanics of how TPOs work. It's just that, there are additional rules or there there are now additional rules that are going that are, going into effect, that TPOs will have to, more rules and hoops to jump through for TPOs to be able to qualify for that 48 e credit. Yeah. And and, Fox, one thing I'll add there too, when it comes to the TPO providers, I'd say, like, they are very open and helpful in as far as, like, answering questions that folks may have. You know, if you have the chance to engage with the TPO provider, I highly recommend engaging with them because they could even give you their perspective specifically around, like, how the finance and landscape is shaping up and what they're looking to do as far as supporting the industry today, but also, you know, how are they thinking about the future or what new technologies or new products they may put out in there into the market to support some of these, new things that's happening. So I'd highly recommend folks to reach out to TPO providers, your financing partner in general. Get, like, really close with them. Aurora is working closely with financing providers, really trying to understand and get a full picture on how we could ultimately be helpful, for everyone who's on this call. So definitely would say reach out to your TPO providers if there's any questions or, things that's not clear. For sure. Yeah. Do you mind if I go I guess, where I see that we're, getting close to time. Do you mind if I'd, like, kinda go lightning through some of these last questions? Absolutely. You take it away, Fox. Great. So is there any so is there any chance that we'll make all these changes, and in 2029, it goes right back to the old rules? So the, the election like, there will be a presidential election in 2028. And I suppose, like, short answer is there is a chance. I believe that probably if there, if there is any change, it's not going to be to go back to the old IRA rules, but it will be to go to new some something new and different that, if there is a a more friendly, legislature or and or executive in place, in 2029, I believe that they will implement something completely new, which means we get to learn about a completely new set of rules. Yay. So The, safe harbor. So 25 d is 25 d is basically, is in an interesting state. 25 d is basically on is basically they've made very little changes to '25 d other than, say, it ends at this year. Twenty five d doesn't have to deal with Fiat. 25 doesn't have to deal with these, commence these, commence construction rules. So, the rules are the same except air until it ends. Is there a list of manufacturing products that would fall under the fiat categories? I really wish there was, and, unfortunately, there isn't. There is a there is a state department a department of state database that you can access on the Department of State website that lists, that lists organizations and individuals which are being tracked as, as as Fox concern or entities that are that we're concerned about like, they're that are being concerned about, for Fox. But it doesn't directly list those, entities. Like, it'll list a name and the or, a part or a organization that's or a funder that's believed to be connected with the Chinese military or something like that. But it doesn't list the the next step of, like, who that person is a board member of, what company or something like that. And so the process and I think, like, taking a step back here, FIAC, this use of FIAC is novel and is not what FIAC was originally intended to be used for. In all of in all previous implementations of of FIAC rules, it was related to things that were directly tied to national security, security, like weapons manufacturing or most recently AI chip manufacturing. And this meant that there wasn't a a laid out like, there wasn't a, repeatable laid out public process. Manufacturers and contractors whose job it was to comply with FEOC would essentially work out a, a bespoke certification process with the Department of State and the Department of the Treasury and Energy and probably Defense to certify at or sort of on a a case by case basis. So this is really new and undefined territory. Related to what is the process to self certify then, basically, the process to self certify right now is to to make sure that you have documentation. Fiat compliant are releasing sort of, cert certificates or or, explainers of explaining why they're Fiat compliant. And, basically, collecting those various certificates, collecting, making sure that the contracts that you that you have are don't run a foul of any of the, of any of the rules laid out in the OBBB, which many most of our contracts don't. Like, nobody's saying telling you, oh, you can't put solar panels here. You have to put them over there or something. And then, basically, just having that documentation on hand for when someone asks for it, if someone asks for it. That's not a well defined process. I don't like how ill defined that is, but that's where we are. Do callback provisions extend to projects already placed in service? No. Yay. Let's see. Will fabrication of custom racking qualify as an off-site activity under the physical work test? Maybe. That sounds like something that would qualify as or under the physical work test. It sounds similar to the, the examples given in the, Department of Treasury memo. It's not specifically called out, and that's that's one of the, the frustrations is that there isn't a, like, specific rules as to what qualifies. There's just rules as to what disqualifies. And so it sounds like that's going to qualify. And it's possible that as we move start moving forward in this process, I think we're gonna all have to share our our homework and basically say, hey. I tried to submit this and it was accepted. Yay. Or I submitted this, but it got kicked back because of of x and y reasons. So we can all learn from each other, through this process as to what department of treasury is going to consider to be significant work and what they're not. Is direct pay still in play for in, NOPs? Yes. Direct the direct pay provision is also, still, valid. Or it is still existing as well as the transferability provision. So, Fox, we've got about four minutes, maybe a little bit less than four minutes left. Any lasting words that you want to leave folks in the audience with? I mean, this industry has been through a lot, and a lot of us are really good at are are are good at navigating the uncertainty in the industry. And, I have every confidence that we're gonna make it through this stronger than ever. And we're and as I said last time, we are going to, I think that at the end of this, we're going to show that even even if they're trying to to squish us down, that we're going to show that the solar industry and solar energy is here to stay and is even and is even more the energy of the future than than before. Yeah. I'm plus one to that. I think change is always scary, but it always comes with new opportunity and things that we could ultimately, be ultimately be beneficial for everyone. So I'd say as we wrap up, as a industry, as folks here on this call, what we wanna do at Aurora Solar is ensure that we are continuously providing updates on all these things because things is changing very, very fast. And we want to always provide that level of calm for everyone. So I'd say, please, everyone, stay close to Aurora Solar, And please check out any blogs and information that we have online. Check out our policy hub, and reach out if you have support. And, Fox, I know that there's one more last thing that you'd like to say. Yeah. So I just want and I just want to, like like, that we are that we're gonna continue to do, to do webinars like this as we, as new changes happen, as new wrinkles or bumps, happen in our industry. And, and know that we are also, working to advocate for the solar industry too. I was in, Sacramento helping lobby to, to overturn a b nine forty two. Our CEO was in Washington during the OBBB negotiations, lobbying on behalf of the solar industry and specifically on behalf of the residential solar industry as well, which is a a group that frequently gets lost in the, in the the midst of negotiations in a lot of these other places. So we're here for y'all. We're gonna continue to be here for y'all, and stay sunny. Yes. Please stay sunny. This call was recorded, so we'll share this out as well. But thank you all for joining, Fox. This was a lot of fun, and we will keep you guys posted on the next one. Right? We're gonna be so back again. So Yep. Hopefully, we have good news. But yeah. Stay sunny. Stay sunny. Take care.